Little Belt Mountains Hazard Tree Removal Project Environmental Assessment & Finding of No Significant Impact

United States Department of Agriculture Forest Service Little Belt Mountains Hazard Tree Removal Project Environmental Assessment & Finding of No Significant Impact

Judith, Musselshell, Belt Creek and White Sulphur Springs Ranger Districts Lewis & Clark National Forest Cascade, Judith Basin, Meagher, and Wheatland Counties, Montana Responsible Official: William Avey, Forest Supervisor September 2014

Figure 1: Hazard Trees along Scenic Highway 89

For More Information Contact:

William Avey Lewis & Clark National Forest 1101 15th Street North, Great Falls, MT 59401 Phone: (406) 791-7700 Fax: (406) 731-5302

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 program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication for program information (e.g. Braille, large print, audiotape, etc.) please contact USDA’s TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.

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Table of Contents

INTRODUCTION ...... 8

BACKGROUND ...... 8

EXISTING CONDITION ...... 8

DESIRED CONDITION ...... 9

PUBLIC INVOLVEMENT ...... 9

PURPOSE AND NEED ...... 9

ALTERNATIVE DEVELOPMENT PROCESS ...... 10

ALTERNATIVES ELIMINATED FROM DETAIL STUDY ...... 10

ALTERNATIVE 1 ...... 11

ALTERNATIVES 2 AND 3: PROPOSED ACTION AND ALTERNATIVE DEVELOPED IN RESPONSE TO PUBLIC COMMENTS ...... 11

Project Analysis Area ...... 11

Proposal Development – Exposure & Risk ...... 13

Proposed Treatments ...... 14

Additional Considerations for IRAs, RNAs, the TCEF, and the WSA ...... 15

ALTERNATIVE 2: PROPOSED ACTION HAZARD TREE DEFINITION ...... 16

ALTERNATIVE 3: ALTERNATIVE DEVELOPED IN RESPONSE TO PUBLIC COMMENT REGARDING HAZARD TREE DEFINITION ...... 18

RESOURCE PROTECTION MEASURES ...... 18

Heritage ...... 18

Noxious Weeds ...... 19

Recreation ...... 19

Scenery ...... 21

Sensitive Plants...... 22

Watershed (Fisheries, Hydrology, and Soils) ...... 22

Wildlife ...... 25

Monitoring ...... 25

EFFECTS ANALYSIS ...... 26

AIR QUALITY ...... 26

Alternative 1 Effects ...... 27

Alternatives 2 and 3 Effects ...... 27

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FISHERIES ...... 27

Alternative 1 Effects ...... 29

Alternative 2 Effects ...... 30

Alternative 3 Effects ...... 32

FUELS ...... 33

Alternative 1 Direct and Indirect Effects ...... 33

Alternative 2 Direct and Indirect Effects ...... 34

Alternative 3 Direct and Indirect Effects ...... 35

Cumulative Effects of All Alternatives ...... 35

HERITAGE ...... 36

Alternative 1 Effects ...... 36

Alternative 2 Effects ...... 36

Alternative 3 Effects ...... 36

HYDROLOGY ...... 37

Alternative 1 Effects ...... 39

Alternative 2 Effects ...... 40

Alternative 3 Effects ...... 41

INVENTORIED ROADLESS & WILDERNESS STUDY ACT AREAS ...... 42

Alternative 1 Effects ...... 50

Effects Common to Alternatives 2 and 3 ...... 51

Alternative 2 Direct and Indirect Effects ...... 51

Alternative 3 Direct and Indirect Effects ...... 53

Cumulative Effects of Alternatives 2 and 3 ...... 54

NOXIOUS WEEDS ...... 55

Alternative 1 Effects ...... 56

Alternative 2 Direct and Indirect Effects ...... 56

Alternative 3 Direct and Indirect Effects ...... 57

Cumulative Effects of Alternatives 2 and 3 ...... 57

Conclusions for Alternatives 2 and 3 ...... 58

RECREATION ...... 58

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Alternative 1 Effects ...... 58

Alternative 2 Effects ...... 59

Alternative 3 Effects ...... 61

RESEARCH NATURAL AREAS ...... 62

O’Brien Creek RNA ...... 62

Onion Park RNA ...... 63

Joint Management ...... 64

Alternative 1 Effects ...... 64

Alternative 2 Effects ...... 65

Alternative 3 Effects ...... 68

SCENERY ...... 68

Alternative 1 Effects ...... 70

Effects Common to Alternatives 2 and 3 ...... 70

Alternative 2 Effects ...... 71

Alternative 3 Effects ...... 72

SENSITIVE PLANTS ...... 73

Effects Common to All Alternatives ...... 73

Alternative 1 Effects ...... 74

Alternative 2 Effects ...... 74

Alternative 3 Effects ...... 77

SOILS ...... 78

Alternative 1 Effects ...... 79

Alternatives 2 and 3 Effects ...... 79

VEGETATION ...... 81

Effects Common to All Alternatives ...... 81

Alternative 1 Direct and Indirect Effects ...... 81

Alternative 2 Direct and Indirect Effects ...... 82

Alternative 3 Direct and Indirect Effects ...... 82

Cumulative Effects of All Alternatives ...... 82

WILDLIFE ...... 82

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Grizzly Bear ...... 86

Canada Lynx ...... 87

Bighorn Sheep Effects ...... 100

Fisher Effects ...... 100

Wolverine ...... 100

Gray Wolf ...... 105

Townsend’s Big-eared Bat ...... 106

Northern Bog Lemming ...... 106

Bald Eagle ...... 106

Peregrine Falcon ...... 106

Black-backed Woodpecker ...... 107

Burrowing Owl ...... 108

Flammulated Owl ...... 108

Greater Sage-grouse ...... 108

Harlequin Duck ...... 109

Greater Short-horned Lizard ...... 109

Beaver ...... 109

Black bear ...... 109

Bobcat ...... 110

White-tailed deer ...... 110

Mule deer ...... 111

Mountain Goat ...... 111

Mountain Lion ...... 111

Elk ...... 112

Dusky Grouse...... 116

Golden Eagle ...... 116

Prairie Falcon...... 116

Northern Goshawk ...... 117

Northern three-toed woodpecker ...... 131

WILDLIFE DETERMINATIONS...... 132

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Old Growth ...... 132

Migratory Birds ...... 133

ENVIRONMENTAL JUSTICE ...... 137

FEDERAL, STATE, AND LOCAL AGENCIES CONTACTED ...... 137

TRIBES CONTACTED ...... 137

FINDING OF NO SIGNIFICANT IMPACT ...... 138

CONTEXT ...... 138

INTENSITY ...... 138

1. Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial...... 139

2. The degree to which the proposed action affects public health or safety...... 144

4. The degree to which the effects on the quality of the human environment are likely to be highly controversial...... 145

5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks...... 145

6. The degree to which the action may establish precedent for future actions with significant effects or represents a decision in principle about a future consideration...... 145

9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973...... 146

10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment...... 146

WORKS CITED ...... 147

APPENDIX A: PROJECT ANALYSIS AREA AND LIKELY TREATMENT LOCATIONS MAPS ...... 158

APPENDIX B: ROADS AND SITES INCLUDED IN PROJECT ANALYSIS AREA ...... 162

APPENDIX C: PAST, PRESENT, AND REASONABLY FORESEEABLE ACTIVITIES ...... 177 Page | 7

APPENDIX D: LEWIS & CLARK FOREST PLAN CONSISTENCY ...... 188

APPENDIX E: SITE-SPECIFIC FOREST PLAN AMENDMENT ...... 226

APPENDIX F: MOUNTAIN PINE BEETLE PROGRESSION MAPS ...... 234

Introduction We are proposing to remove hazard trees contained within areas adjacent to public roads, recreation and special-use sites, and administrative facilities in the Little Belt Mountains. The area analyzed for potential treatment spans 17,337 acres. Proposed actions would take place on the Judith, Musselshell, Belt Creek and White Sulphur Springs Ranger Districts of the Lewis & Clark National Forest. We prepared this environmental assessment (EA) to determine whether implementation of hazard tree removal may significantly affect the quality of the human environment and thereby require the preparation of an environmental impact statement. By preparing this EA, we are fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA). For more details of the proposed action, see the Alternatives 2 and 3: Proposed Action and Alternative Developed in Response to Public Comments section of this document. Background This project was originally listed as a proposal on the Lewis and Clark National Forest’s schedule of proposed actions in October 2010. Analysis was completed and a decision memo was signed on March 9, 2012. That decision was withdrawn by William Avey, Lewis and Clark Forest Supervisor, on November 15, 2012. The letter of withdrawal stated an environmental assessment would be prepared to provide evidence and analysis for determining whether to prepare an environmental impact statement or a finding of no significant impact. This preliminary environmental analysis articulates those findings. Two action alternatives were considered in the environmental analysis, along with the effects of taking no action. Both action alternatives address concerns associated with public safety and road maintenance issues along forest roads designated open (yearlong, seasonal, or under special use permit) to the public by the 2007 Lewis and Clark Travel Plan Decision; recreation sites; and areas designated under special use permit for recreation or non-recreation related uses (please see Project Analysis Area Map in Appendix A and Roads and Sites included in Project Analysis Area in Appendix B). Existing Condition Insect infestations, primarily the mountain pine beetle (MPB), within the Little Belt Mountains have resulted in higher levels of tree mortality than can be addressed by annual Forest Service maintenance. The presence of dead and dying trees in recreation areas, along roadways, and within special use sites creates a hazard. This hazard arises due to a combination of risk and

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exposure - risk of tree failure and exposure of individuals and infrastructure to this risk (USDA 2011a). Roadways identified for treatment in this proposal currently represent medium and low hazard prioritization. These prioritizations are based on user estimates (exposure) and the percentage of impacted trees in the area (risk). Recreation areas and special use sites are medium priority because exposure rates are so high in these locations. Should any of the proposed treatment areas transition into a high priority, hazard trees would need to be treated immediately or the roads and sites would have to be closed (USDA 2011a). This proposal was developed such that medium and low priority areas could be addressed before they become high priority and present a situation that would inevitably overwhelm Forest Service maintenance capacity. Desired Condition The desired condition is to have felled identified hazard trees in those medium and low priority areas for which MPB impacts have exacerbated conditions beyond Forest Service maintenance capacity. Taking action to eliminate safety concerns due to dead or dying trees in high use public areas would provide for safer travel and accessibility along open roads and in recreation sites within the Little Belt Mountains. As described more below, providing for safe recreation and working conditions is required Forest Service policy. Public Involvement This preliminary analysis was originally listed on the Lewis and Clark National Forest Schedule of Proposed Actions on May 28, 2013. A postcard informing interested parties of the availability of documents for the ’30-day Notice for Comment’ was mailed on May 24, 2013. A legal notice initiating the comment period was posted in the Great Falls Tribune on Wednesday, May 29, 2013. A total of 149 comments were received in response to the preliminary analysis. Four organizations provided input, the Alliance for the Wild Rockies, Native Ecosystem Council, Montana Department of Transportation (MDT), and Montana Fish, Wildlife, and Parks (MFWP). Issues raised included interest in clarification of the purpose and need and existing condition; concern for impacts to threatened, endangered, and sensitive wildlife species, watersheds, and sensitive plants; and concern for noxious weed introduction and management. A few comments indicated confusion regarding the proposal; the Colt Summit Restoration and Fuels Project was incorrectly referenced as the project proposed and multiple comments highlighted concern for impacts from fuels treatments, which were not included in this proposal. Both State agencies expressed concurrence on the project.

Purpose and Need The purpose of this project is to reduce hazardous conditions along roads and within administrative, recreation, and permitted use sites caused by existing or impending tree mortality. Aerial detection surveys of the Lewis & Clark National Forest indicate accelerating rates of tree mortality per acre in the Little Belt Mountains (Mountain Pine Beetle Progression Maps, Appendix F). It is anticipated that many of these hazard trees will fall across roadways

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and within developed recreation and permitted special use sites, creating a threat to public and agency safety either directly (immediate damage or injury) or indirectly (blocked access). The Forest Service Manual (FSM) and Handbook (FSH) explicitly outline the requirement to maintain public roads and recreational areas for user safety (e.g. FSH 2332.11; FSH 7733.02, 7733.03, 7709.59; USDA 2011). Specific procedures outlined under the Road System Operations and Maintenance section of the Forest Service Handbook include prioritization of hazard tree areas along roadways as high, medium, and low priority. Priority levels are to be determined according to the risk of tree failure and the level of public exposure to this risk (FSH 2209.59). The Lewis & Clark Forest Plan also outlines specific management standards regarding safety (e.g. A-2; A-3; L-4).

Alternative Development Process Section 102 (2)(E) of the NEPA requires the Forest Service to study, develop, and describe appropriate alternatives to recommended courses of action for any proposal which involves unresolved conflicts concerning alternative uses of available resources. Three alternatives have been evaluated in detail in this environmental analysis; the No Action Alternative, the Proposed Action (Alternative 2) and an alternative developed in response to public comment (Alternative 3). Design features were incorporated into the action alternatives to address potential environmental effects (please see Alternatives 2 and 3 below for more information). Additionally, resource protection measures, or mitigation measures, incorporated into project implementation are expected to prevent, minimize, or resolve environmental impacts to resource conditions (please see the Resource Protection Measures section below). Alternatives Eliminated from Detail Study The following alternatives were introduced as part of the NEPA process that accompanied the original decision memo. Each of these alternatives has been eliminated from detailed study including: 1. Only treating in units without noxious weeds does not sufficiently address the purpose and need of this proposal, nor does it follow Forest Service policy of maintaining forest infrastructure; resource protection measures ensure a low risk of adverse effects regarding noxious weeds from Alternatives 2 and 3; 2. Closing roads with hazard trees conflicts with the 2007 Lewis and Clark Travel Plan, which decided that these routes would be open for public use; road closures are a likely outcome of the no action alternative; 3. Not treating units within the WSA or RNA does not meet the purpose and need; the focus of this project is on user safety and neither Wilderness Study Act Areas nor Research Natural Areas are excluded from Forest Service policy of maintaining recreational areas and public roads for user safety;

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4. Clearcutting 1-1/2 tree-lengths along 575 miles of road was purported to summarize the proposed action; in fact a clearcut would remove far more trees than proposed including those that do not pose a hazard; and 5. Treating two tree-lengths of roads, which does not meet our purpose and need; treating one and a half tree-lengths is sufficient when addressing most of the routes in this proposal except select roads in recreation sites as detailed in Alternatives 2 and 3. Alternative 1 Alternative 1 proposes no actions that are contained in either action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Alternative 1 provides a baseline for comparison of environmental consequences of Alternatives 2 and 3 to the existing condition. It is a management option that could be selected by the Responsible Official. Alternatives 2 and 3: Proposed Action and Alternative Developed in Response to Public Comments Under Alternatives 2 and 3, the Forest Service proposes removing hazard trees from 58 recreation special use sites, 5 non-recreation special use sites, 157 recreation sites, 1 administrative site, and 575.4 miles of open forest roads. Treatment areas along roadways have been identified as high- and medium-priority hazards as required by the Forest Service Handbook and further defined below. Hazard trees would be felled and removed or felled and left on site depending on management direction (e.g. within the WSA). Please see Appendix A for a map of the project analysis area and likely treatment locations and Appendix B for a list of all potential treatment areas including roads and sites.

Project Analysis Area Analysis contributing to this preliminary environmental analysis spans approximately 17,400 acres as indicated by Table 1 below. Table 1: Analysis Area Summary Analysis Area Summary 17,337 acres Total acres within analysis area in the Little Belt Mountains 13,599 acres Total acres within analysis area that are in a forest type 3,738 acres Total acres within analysis area that are not classified as a forest type (grass, forb, shrub, hardwood)

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While all 17,337 acres were considered in the development and analysis of the proposed action and alternatives, only 13,599 acres actually host forest cover and, of that, only about 8,000 acres are dominated by those species most susceptible to the mountain pine beetle. This includes lodgepole pine, ponderosa pine, limber, and whitebark pine species (see Table 2 below).

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Table 2: Acres of Dominant Forest Type and Acres of Treatment by Forest Type (Dom_Mid_40 R1-VMap class) Acres of Tree Cover by Forest Type & Size Forest Type Total 0-4.9" 5.0-9.9" 10.0-14.9" >15" Subalpine fir 211 24 101 68 18 Whitebark pine 235 15 86 126 7 Lodgepole pine 6,444 1,770 3,313 1,209 153 Engelmann spruce 741 51 256.9 363 70 Limber pine 261 25 165 63 8 Ponderosa pine 975 38 482 383 73 Douglas-fir 4,132 380 1,931 1,494 327 Sparsely vegetated 600 n/a n/a n/a n/a

Insects, mainly mountain pine beetle, are the primary agents currently creating hazard trees in the Little Belt Mountains. Based on Table 2, approximately 46 percent (7,915 acres) of the proposed treatment areas are dominated by mountain pine beetle-susceptible pine species (meaning more than 40 percent of those treatment areas are comprised of a mountain pine beetle-susceptible pine species). About 23 percent (1,847 acres) of the pine-dominated acres are composed primarily of seedling and sapling-sized trees (0-4.9” dbh), a size class not expected to show mortality due to beetle activity (Vegetation Description Report, page 2). Thus, approximately 6,000 acres are those areas most likely to receive treatments based on forest cover. However, all treatments must meet the hazard tree descriptions defined separately according to alternative below. This is further demonstrated by the Likely Treatment Locations Map available in Appendix A. The project analysis area was intentionally developed to incorporate areas where hazards are the most imminent; where we expect to see tree failure that would compromise the safety of Forest Service personnel, the public, or Forest Service infrastructure in the next five to fifteen years (Mitchell and Preisler, 1998). The Proposed Action is an attempt to address this concern in a timely manner with the resources we have available.

Proposal Development – Exposure & Risk As outlined by the Forest Service Handbook, prioritization of hazard trees should be determined according to the risk of tree failure and the level of public exposure to this risk (FSH 2209.59). Public exposure levels were estimated through an interdisciplinary process including team meetings and field verification among Lewis and Clark district rangers and staff. All recreation sites and recreation residence sites indicate public exposure because of their continued use. The 5 non-recreation special use sites represent infrastructure such as repeater towers, which indicate constant hazard exposure in addition to the exposure of maintenance personnel.

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To prioritize roads by exposure, rangers and their staff reviewed open, public roads as designated by the 2007 Travel Plan with maintenance levels of 2, 3, 4, or 51. Roads that met three criteria - open, maintenance level 2-5, and relatively high use - were proposed as priority areas because of exposure levels to hazard trees. A draft list of routes was circulated internally for review to ensure inclusion of frequently traveled routes. The final selection of roadways with potential for treatments are listed in Appendix B. Dominant forest cover within the Little Belt Mountains was used to initially assess areas of tree failure risk. Priority areas as depicted in the Dominant Forest Cover of MPB Susceptible Species Maps in Appendix A were developed using remote sensing, which focused on areas of lodgepole and ponderosa pine across the Jefferson Division (includes the Belt Creek, White Sulphur Springs, Judith, and Musselshell Ranger Districts). Field verification by trained foresters confirmed areas to include or exclude based on actual infestations, as well as areas to prioritize in implementation. This process was completed between August and November 2010, reviewed in 2012, and continues to be confirmed by field-going foresters, silviculturists, and other resource specialists. In accordance with the Forest Service Handbook, these priority areas represent locations where the public and Forest Service personnel are exposed to hazardous conditions. Jumping Creek Campground, an example of a high-priority area, closed for the summer of 2013 because the level of hazard is too great to allow the public to recreate there. Medium-priority areas such as the Moose Creek Road (FS Road #204), Studhorse Road (FS #830), and Jefferson Creek Road (FS #267) where we have numerous dispersed sites are not yet as dire as Jumping Creek but will be soon if proposed treatments are not applied. Identified recreation residence sites are included in this study so that permit holders may use removal methods considered in this analysis to address hazard trees on their tract. After this analysis is completed and a National Environmental Policy Act (NEPA) decision is made, felling or removal of hazard trees on special use permitted areas would still require written approval prior to action.

Proposed Treatments Both Alternatives 2 and 3 propose removing trees considered to be a safety hazard to the public or Forest Service personnel. A tree would only be considered a safety hazard if its failure would be likely to impact a road, Forest Service infrastructure2, or the intended use of either. Proposed treatment areas and activities are the same for both Alternatives 2 and 3; it is the biological criteria for classifying trees as a hazard that varies by alternative and is detailed accordingly in the next section.

1 A maintenance level 2 road is maintained for use by high-clearance vehicles and not suitable for passenger cars. A maintenance level 5 road is intended to provide a high degree of user comfort and convenience for prudent drivers in a standard passenger car during the normal season of use (USFS 2012). 2 Infrastructure includes, as defined by Merriam-Webster, the system of public works of a country, state, or region and the resources (as personnel, buildings, or equipment) required for an activity

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For selected roads, hazard trees that pose a threat to Forest Service personnel or the public within an area spanning up to 1½ tree-lengths (up to 150 feet) on either side of roadways would be felled. For recreation and non-recreation special use sites, hazard trees within up to 2 tree-lengths from sites (up to 200 feet around) would be felled. Treatment areas would also include any hazard trees within or near a recreation or non-recreation special use sites where a forest visitor or employee might frequent or where a facility or structure is located. Additionally, hazard trees within 1½ tree-lengths of roads and routes associated with recreation and non-recreation special use sites would be felled. Examples include immediate access to a recreation residence or campground or a footpath leading out of a campsite to a stream nearby. Under both action alternatives, pre-implementation site reviews by professional foresters would determine which trees should be felled. Within the Wilderness Study Act Area, hazard trees would be felled away from the road and left on site. In all other areas – except when resource protection measures apply as detailed below – hazard trees would be whole-tree yarded to pre- selected landing sites in order to remove slash. All landings would be located within the boundary of proposed treatment areas (up to 150’ along roads, up to 200’ around sites). After de- limbing, slash would be chipped and spread on site, chipped and removed from the site, or piled and burned on site. Merchantable hazard trees would be hauled from landing sites. All other hazard trees would be left for firewood or chipped and spread on site, chipped and removed from the site, or piled and burned on site. No roads would be constructed to implement this project. Hazard trees that cannot be removed via ground-based mechanical means due to geographic limitations (e.g. rock outcrops) or resource protection measures detailed below (e.g. wet areas) would be felled by chainsaw and left on-site or removed in such a way as to minimize potential resource damage (e.g. hand-carried, end-lined, or grappled). Best Management Practices (BMPs) would be applied during implementation. In riparian areas where mechanized entry is precluded by BMPs, those hazard trees that cannot be accessed by equipment reach from outside the riparian area would be hand-felled and left on site. These practices would be applied to both fish- bearing and perennial streams as well as around identified archeological sites. Implementing either action alternative (Alternatives 2 and 3) would preclude the Forest from meeting the snag standard because many of these trees are, or will be, snags, defined as standing dead and downed trees. The Lewis and Clark Forest Plan contains management standards for wildlife trees, including snags (FP pgs. 2-35, 36). Therefore, Alternatives 2 and 3 include an amendment that would provide an exception to Forest-wide Management Standard C-4 for this project. Resource effects analysis for both action alternatives assume activities would take place as proposed, which includes excepting the action from Forest Plan Management Standard C-4. The amendment is included in this document under Appendix E.

Additional Considerations for IRAs, RNAs, the TCEF, and the WSA Hazard trees along Forest roads within Inventoried Roadless Areas (IRAs) would be removed. Forest road #251 borders the northwest boundary of the Middle Fork Judith WSA for approximately seven miles. Hazard tress along this border outside the WSA would be felled and

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removed. Hazard trees within the WSA would be felled and left on site. Table 3 below summarizes those areas of potential treatment within IRAs and the WSA, Table 3: Inventoried Roadless and Wilderness Study Act Area Proposed Treatment Segments Miles of Roads with Potential for Total Acres of Potential Total Potential Treatment Acres Treatment Miles Treatment Big Baldy (#731) 44,000 383 15.7 12.0 Calf Creek (#745) 11,020 67 4.9 1.9 Eagle Park (#746) 6,300 10 0.2 0.2 Middle Fork Judith WSA (#734) 92,000 324 57.5 7.3 North Fork Smith (#744) 8,800 41 6 1.2 Paine Gulch (#728) 8,500 56 0.7 2.7 Pilgrim Creek (#727) 49,500 23 2.2 0.6 Spring Creek (#741) 19,800 16 10.5 0.4 Tenderfoot-Deep Creek (#726) 88,400 224 12.4 6.9 Tollgate-Sheep (#733) 26,800 94 14.5 3.3 Total 355,120 1,238 124.6 34.5

Proposed treatments in the Onion Park RNA, O’Brien Creek RNA, and the Tenderfoot Creek Experimental Forest (TCEF) would include segments of Forest roads #586 (about 1.5 miles), #839 (about 0.5 miles), and #840 (about 0.28 miles). Rocky Mountain Research Station (RMRS) and TCEF representatives would be on site during hazard tree identification and marking in treatment areas. Hazard trees within RNAs would be felled and left in place. Tree removal and slash management options within the TCEF would be determined based on the location of current research projects. Alternative 2: Proposed Action Hazard Tree Definition Alternative 2 proposes to remove dead, dying, and structurally unsound trees within the analysis area. Dead, dying, and structurally unsound trees that are not a hazard to a road, Forest Service infrastructure, or the intended use of either would be retained, except in stands vulnerable to wind-throw, which is explicitly defined below. Pre-implementation site reviews by professional foresters would determine which trees should be felled. The following criteria would be used to make this determination: – Dead trees (yellow, red, or no needles); – Greater than 5” diameter dead top;

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– Greater than 15° lean (indication of soil movement, or lean due to stem, butt, or root failure); – Forked or multiple tops including co-dominant stems greater than 5” with included bark (weak union), cracks, or decay; – Dwarf mistletoe with a Hawksworth Rating of 5 or 6; – Conks on any part of tree; – Decayed wood on more than 40 percent of radius; – Cankers, wounds, freeze injury, lightning injury, or fire damage creating greater than 50 percent of the bole to be girdled (fire scarred trees, especially ponderosa pine, should be evaluated for structural integrity prior to designating for removal); – Severe cracks extending through the stem; weeping, gaping cracks; cracks with movement; or cracks associated with decay; – Greater than 25 percent of root system damaged; – Root disease symptoms (slow growth, thinning or fading crown, stress cone crop, basal resinous); – Healthy-appearing trees adjacent to wind thrown live trees of same species; – MPB-infested green trees with numerous pitch tubes around the bole’s circumference or boring dust around the base of the tree; – Douglas-fir beetle-infested green trees with boring dust on the bole or around the base of the tree and occasionally pitch streamers; or – Douglas-fir or Engelmann spruce trees that show less than 10 percent live crown, little or no intact needles remaining even in the crown’s interior, or greater than 1/3 dead limbs. With a pure lodgepole pine stand where the majority of the stand is infested, the remaining isolated green lodgepole pine will be susceptible to continued bug kill and wind-throw. Their shallow root system combined with increased wind speeds in more open, beetle-killed stands, contribute to residual green tree wind-throw susceptibility. Research shows that dead lodgepole pine killed by the MPB in thinned stands begin falling in three years with the majority of the trees down in 12 years. In un-thinned stands, research shows that dead lodgepole stands begin falling in five years with the majority of the trees down in 14 years (Mitchell and Preisler, 1998). This research and professional observation confirm that these trees will fall, some of them in as early as three years. Therefore, the project would retain healthy, live lodgepole pine if there is >40 square feet of basal area per acre in the residual stand. If the removal of hazard trees creates a stand with <40 square feet of basal area per acre, then all lodgepole pine would be removed. The criteria above would be used to evaluate a tree to determine if it should be felled. The proposal would retain and limit damage to conifers of all sizes that do not meet the above criteria. All live trees that do not meet the above criteria, excluding some live lodgepole pine,

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would be retained including whitebark pine, limber pine, Douglas-fir, Engelmann spruce, subalpine fir, and quaking aspen. On sites with slopes greater than 45 percent, other geographic limitations, or resource concerns (e.g. riparian areas, fish-bearing streams, perennial streams, archaeological sites), trees would be hand-felled and left on site or removed in a way to minimize resource concerns (e.g. hand- carried, end-lined, grappled). Alternative 3: Alternative Developed in Response to Public Comment Regarding Hazard Tree Definition Alternative 3 proposes to remove dead trees only within the analysis area. This alternative addresses a request made through prior public comment on the proposal concerning tree removal prescriptions. Dead trees that are not a hazard to a road, Forest Service infrastructure, or the intended use of either would be retained. As with Alternative 2, pre-implementation site reviews by professional foresters would determine which trees to fell. The following criteria would be used to make this determination: – Dead trees (yellow, red, or no needles); – MPB-infested green trees, which exhibit numerous pitch tubes around the bole’s circumference or boring dust around the base of the tree; or – Douglas-fir beetle infested green trees, which exhibit boring dust on the bole or around the base of the tree and occasionally pitch streamers. The proposal would retain and limit damage to conifers that are not dead. On sites with slopes greater than 45 percent, other geographic limitations, or resource concerns (e.g. riparian areas, fish-bearing streams, perennial streams, archaeological sites), trees would be hand-felled and left on site or removed in a way to minimize resource concerns (e.g. hand-carried, end-lined, grappled). Resource Protection Measures The following resource protection measures would be implemented as a part of treatment activities for either action alternative.

Heritage Complete field surveys and finalize the National Historic Preservation Act, Section 106 review according to Programmatic Agreements, including ‘Hazard Tree and Fuels Reduction Protocol-2011, or with State Historic Preservation Office (SHPO) approval prior to implementation in each area. Phased surveys may be completed according to the 2011 protocol. Avoid or minimize effects to cultural resource, generally archaeology sites, and historic sites, such as cabins or mining locations, by reconfiguring the treatment unit or using non-ground disturbing tree removal methods, such as hand-felling or over snow removal.

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Identify vulnerable sites to the responsible official, project manager, and sale administrator when appropriate in a confidential report. Agree upon how to identify these areas to protect in the field. Apply post-project effectiveness monitoring for these areas. Avoid or minimize effects to ‘linear’ historic sites, such as ditches or railroad beds, where the historic character is important, by minimizing crossings or disturbance by replacement of contours or other salient features per Programmatic Protocol. Consult with SHPO to seek agreement for avoidance or minimization of effects when conditions are outside of the Programmatic Agreements. If a historic property is inadvertently affected during project activity, the project work would cease in that location, a site-damage assessment would be prepared, and SHPO and tribes would be informed. The investigation report and damage repair agreement would be finalized prior to finishing that site’s activities. If unidentified archaeology sites or human burials are discovered during implementation, work would cease in that area and the Forest Archaeologist would be notified. Required legal processes would be invoked.

Noxious Weeds Follow Prevention and Control Measures for noxious weeds as found in FSM 2000 Supplement R-1 2000-2001-1, Sec 2081.2. Implement preventative management measures as referenced by FSM 2000 including post-disturbance seeding with desirable species. Adhere to mitigation requirements as listed in the Record of Decision for the Lewis & Clark National Forest Noxious Weed Control Record of Decision (1994, page 5). Require prompt re-vegetation of areas disturbed by treatment activities, especially cut and fill slopes, to control surface erosion. To stabilize disturbed areas seed with grasses, forbs and deep-rooted native shrubs, where natural establishment of native cover is not expected within two years. Ideally the seedbed should be firm with a roughened surface. Steeper slopes can be benched or terraced. Compacted soils should be ripped from eight to twelve inches. Achieve a minimum of 70 percent vegetative canopy cover or litter cover level on cut and fill slopes and other soil disturbance areas created by treatment activities with two growing seasons or a natural level (when natural community is less than 70% canopy cover) of vegetative and litter cover when it is less than 70 percent.

Recreation Implement harvest and slash clean-up at developed campgrounds as top priority to limit the time those sites may be closed to the public. Use cut tree markings or designate trees to be removed to minimize marking in developed sites and along roads with visual concerns.

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Protect all developed recreation site facilities including: picnic tables, fire-rings, toilets, signs, bulletin boards, hand pumps, fences, etc. Minimize high stumps and untreated slash immediately adjacent to snowmobile trail systems to reduce safety concerns. Piles and decks should be located a minimum 20 feet from edge of snow trail if the trail remains open to snowmobiling during the cutting and hauling operation period during weekends and holidays. Protect healthy, vigorous, live vegetation within developed sites to the extent possible. Retain some hazard trees felled near rental cabins, dispersed campgrounds, and developed campgrounds for site firewood use. Concentrations of slash in developed and dispersed camping sites resulting from hazard tree removal would be removed, chipped, or initially piled and burned in developed and dispersed sites. Slash plies shall be located as far a reasonable possibly from all developed recreation facilities so as not to incur damage from pile burning and to reduce damage to any remaining tree over story and vegetation. Limit roadside hazard tree cutting, removal, and log hauling to weekdays during snowmobile and hunting seasons thereby reducing associated impacts to these high use recreationists; cutting and hauling would not be permitted during holidays and weekends unless the road has been closed to public use for implementation of this project. Coordinate with Recreation Specialist and Public Affairs Officer on hazard tree removal schedule for developed and dispersed sites to ensure facilities are protected and conflicts with public uses and closure times are minimized; specific coordination items include: o When it is deemed necessary to expand the cutting and hauling outside these recommended timeframes; and o When affected snowmobile trails may be closed to public use during the winter. Provide information to the public clearly identifying firewood opportunities and or leave some cut and dry trees along Forest roads for public firewood. No winter logging and hauling December 1 through May 15 on the following forest roads or groomed snowmobile trails: o Forest Road 839 between Junction US Hwy 89 to Junction with Forest Road 839 at Harley Park Forest Road 253; o Forest Road 251 between Junction Forest Road 487 north to Junction with Forest Road 3300; o Forest Road 487 at Junction with Road 251 south to Junction with Forest Road 47 at Ant Park Warming Hut; and o Forest Road 6464 at Junction with Road 487 west to Junction with Forest Road 6467.

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The above listed routes provide critical winter recreational snowmobiling access to the higher elevation snowmobile areas and serve as high use main stem trails to other portion of the trail system. Protect and save all signs such as winter trail markers, route markers, and other associated road, trailhead, traffic and informational signs.

Scenery Project-wide: Mimic natural patterns in treatment design and operations. Create natural appearing, meandering edges, and tie into existing meadows and clearings. Retain smaller, low-branched trees along the back edge of the unit to minimize a "bole- edge effect", where feasible. Unless structurally weakened, retain live, healthy, non-hazard trees where they occur, especially preserving clumps of live trees, young to mature in age classes. Care would be taken to protect them from logging operations. A Landscape Architect would review boundary and treatment marking prior to finalizing contracts or implementing tree removal. Additional measures specific to roads: Flush cut stumps to a height of 8 inches or less above ground. Slash, root wads, and other debris along roads would be burned, removed, buried, chipped or lopped and scattered. Slash piles would be disposed of promptly. When burned, ensure 95% consumption, with the remainder scattered. This may require re-piling and burning.

Limit entry points to the harvest areas from forest roads to minimize ground disturbance and retain as much screening vegetation as possible.

Entry to units would be aligned perpendicular to the road, where feasible. This would minimize viewing duration of disturbance (soil and vegetation compaction) to those traveling on the road. Additional measures specific to US Highway 89, Dry Fork Belt Cr. Road (120), Dry Wolf Road (251), Logging Creek Road (253), Memorial Way 487, and Belt Park 6511: Use cut tree (as opposed to leave tree) marking within treatment units. Boundaries shall be painted with three inter-visible dots and for stump marking to minimize visible paint post-treatment. Stumps shall be flush cut to 6” or less in height. Additional measures specific to recreation sites and recreation residences: Use cut tree (as opposed to leave tree) marking within treatment units.

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Stumps should be flush cut to 6 inches or less in height. Remove, or cut and stack timber in developed campgrounds. Slash, root wads, and other debris would be removed from developed recreation sites for disposal. Boundaries shall be signed. Boundary paint shall only be utilized to mark stumps. This would minimize visible paint upon completion of tree removal. Minimize damage to natural features such as rock outcrops. Minimize damage to young healthy lodgepole pine, spruce/fir and shrub understory.

Sensitive Plants Complete sensitive plant surveys in areas with known populations or potentially suitable habitat prior to project implementation. If site surveys indicate the presence of a healthy whitebark pine understory, trees would be manually felled and left in place or removed in such a way (e.g. end-line or grapple yard) to minimize potential resource damage. To the extent possible, landings would not be located in areas occupied by whitebark pine and mature whitebark pine would not be felled to create a landing. No designated whitebark pine plus-trees in the Northern Region’s tree improvement program would be felled or damaged during implementation of the project. The Forest’s Tree Improvement Coordinator would assist with location and identification of these trees. If currently unknown sensitive plant populations are located prior to or during implementation, operations affecting that population would cease until the population is evaluated and delineated. Appropriate species- and location-specific resource protection measures would be implemented to ensure species viability. Examples of these measures include, in the presence of Northern rattlesnake-plantain populations, retention of all live trees to provide shade, and end-line or grapple yard, or fell and leave, trees to avoid ground disturbance. In the presence of Austin’s knotweed populations, end-line or grapple yard, or fell and leave, trees to avoid ground disturbance.

Watershed (Fisheries, Hydrology, and Soils) All State required streamside management zones3 (SMZs) Rules, State and Federal best management practices (BMPs) would be followed for both action alternatives (Alternatives 2 and 3).

3 "Streamside management zone" means the stream, lake, or other body of water and an adjacent area of varying width where management practices that might affect wildlife habitat or water quality, fish, or other aquatic resources need to be modified. The streamside management zone encompasses a strip at least 50 feet wide on each side of a stream, lake, or other body of water, measured from the ordinary high-water mark, and extends beyond the high-

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Hazard tree removal may occur in areas of previous activity following soil scientist evaluation to determine if and how reentry is possibly while maintaining Regional soil quality standards (SQS). Harvest of these units is possible if all equipment stays on the roads and yarding of trees can be fully suspended as with an extended boom track hoe with grapple head. Hazard tree removal in roadside units without previous timber harvest would occur: o Winter conditions of adequate snow cover or a minimum of 4 inches of frozen soil. Adequate snow cover would be 4 inches or greater based on monitoring data from the Helena NF. o Under dry soil conditions. Ground based equipment should be restricted from operating in areas with more than 35% average slope. Uphill skidding of hazard trees with skidders would be limited to slopes of 20% or less. Wetlands, seeps, springs and poorly drained areas identified within hazard tree units would not be entered with harvest equipment. Parallel skid trails (parallel to roads) in hazard tree units would be implemented when skidding is not allowed on roads or when cut slopes above roads are too steep for safe operation of skidding perpendicular to roads. Skid trails oriented perpendicular to roads and minimized turning of skidding tractors (backing in from roads) would be preferred. Whole tree skidding of hazard trees on roads would require several additional measures depending on the situation: o Gravel surfaced roads would have the surfacing windrowed and protected during skidding operation and respread following use. o Slash from skidding operations would be removed from travel surfaces, adjacent ditch sections and cross-drains or culverts. Slash would be disposed of at landings and processor piles. o Roads used for skidding would be graded and drainage reestablished following skidding operations. Landings would be preferred on road turnouts, on previously disturbed sites adjacent to roads such as borrow areas or old landings and at suitable intersections. Hazard tree landings may also be located on previously undisturbed sites and would be rehabilitated following use. Rehabilitation measures for landings and skid trails would include relieving detrimental soil compaction by ripping to approximately 12 inches in depth where possible, re- water mark to include wetlands and areas that provide additional protection in zones with steep slopes or erosive soils.

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spreading any bermed soil and slash across the impacted area, providing permanent drainage, seeding with native species of grasses and forbs, and scattering slash over the impacted area. Limit burning of slash piles to climatic conditions that minimize detrimental burning of soils and exposed bare soil including 12 inches or more snow cover; frozen ground; or high soil moistures and temperatures of freezing or below. No hauling or other heavy-equipment traffic would take place when roads may rut. When the application of BMPs requires culvert replacement in fish bearing streams (as an example, Rocking Creek crossing on Forest Road #204), the Watershed and Fisheries specialists would be consulted to ensure proper aquatic organism passage. Maintain filtering, vegetated ditches located within 100’ of streams. Minimize disturbance of ditches at equipment crossings; reshape or stabilize disturbed ditch, if needed. When sediment departure points are identified during pre-implementation site preparation, temporary erosion control measures would be installed for the duration of log hauling. Sediment filtering devices (e.g. filter fence and weed-free straw bales) should be used as needed to limit erosion and delivery of disturbed material into streams or ephemeral drainages. Re-vegetate disturbed sites created from this action to a minimum of 70% coverage with native grasses, forbs, and deep-rooted shrubs to control surface erosion and reduce the risk of noxious weed establishment or to a natural level of vegetative cover when natural coverage is less than 70% at a given site. This re-vegetated effort would be applied when natural establishment of vegetation is not expected within two years. The seedbed would be firm with a roughened surface. Slopes must be stable, usually less than 2:1. Compacted soils would be ripped from eight to twelve inches deep. Leave trees within SMZs would come from the largest trees that do not threaten a protected facility. Hazard trees felled within a SMZ would be left if site conditions are not conducive to implementation all BMPs and regulatory standards as detailed above. Felling these trees into an upstream pointing orientation of approximately 45 degrees or greater would be performed when site conditions allow this to be safely accomplished. Herbicide applications along roads and trails would comply with guidelines described in the Lewis and Clark National Forest Noxious Weed Control Final Supplemental Environmental Impact Statement and Record of Decision (USDA Forest Service 1994). Due to the prevalence of hazard trees within the streamside management zone along Jefferson Creek, we are removing the lower segments from mechanized treatment

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Wildlife In areas mapped as potential mature, late successional, or multi-storied lynx habitat, conduct surveys to determine if the areas provide snowshoe hare habitat. If proposed treatments areas provide multi-storied mature or late successional snowshoe hare habitat, limit treatment to removal of dead hazard trees only (Alternative 3 definition of hazard tree). To reduce disturbance to nesting goshawk, do not allow project activities from April 15 to August 15 within ¼ mile of known active goshawk nests in the following designated areas: o Divide Road (FS Road #839) in Section 23, T.16N, R.6E; o Harley Creek (FS Road #834) and the recreation residences along the road in Section 25, T.14N. R.7E. and Section 31, T.14N., R.8E; o Yogo Creek (FS Road #266) in Section 18, T.13N., R.11E; o Stud Horse Creek (FS Road #830) east of the intersection with FS Road #6470 in Section 13, T.11N., R.7E; o Geis Creek System (FS Road #6470) including the roads identified as #6470001, #6470002, #6470003, and #6470010 in Sections 16 and 21, T. 11N., R.8E; and o Memorial Way (FS Road #487) from the Forest Boundary in the North for approximately 1 ½ miles in Sections 1 and 12, T.12N., R.11E. A map would be provided to the contracting officer. Hauling on the above roads between April 15 and August 15 is allowed as long as the activity is intermittent throughout the day and is not likely to result in disturbance. To reduce disturbance to wintering elk, if winter logging is proposed coordinate with Montana Fish, Wildlife and Parks and limit activities to one drainage within an elk herd’s area at a time.

Monitoring Monitor project area for three consecutive years and provide for control of newly established populations of noxious weeds and implement follow-up treatment for previously treated infestations; monitoring would begin in the spring following harvest or ground disturbance; Monitor operations to ensure proper application and effectiveness of BMPs as contained in the following: for weeds FSM 2000 Supplement R1 2000-2001-1, National BMPs FSM 2532 and FSH 2509.19; Monitor treatments to determine the rate of understory growth (herbaceous groundcover and shrubs) recovery, the effectiveness of mitigation measures, and the length of time for visual effects of management activities to blend with surrounding landscapes;

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Monitor sites where treatment is allowed under programmatic protocols to assure proper implementation and anticipated results are accomplished; As required by the Lewis and Clark Forest Plan, soil monitoring would follow project implementation. Known sensitive plant populations will be reviewed during and following treatment to determine what, if any, impacts occurred from management activities; and Complete post-harvest reforestation exams (1st, 3rd, and 5th year) to determine regeneration establishment, progress, and certification for units with prescribed regeneration activities.

Effects Analysis This section summarizes potential environmental effects for each alternative considered in detail and provides the necessary information to determine whether or not to prepare an environmental impact statement. The Finding of No Significant Impact (FONSI) section below discusses whether the proposed action and alternatives have significant effects. More detailed analysis regarding potential effects is available in reports for each resource and other supporting documentation cited in those reports. These documents are available by request to the Lewis & Clark National Forest Supervisor’s Office in Great Falls. For each action alternative, specialists analyzed resource effects due to a one-time entry per treated site with mechanical equipment to (1) fall trees, (2) deck trees at a landing site, and (3) haul trees. All landings would fall within project areas unless excluded in project design (e.g. areas where trees would be felled and left). Resource concerns may limit application of this treatment in some proposed areas. However, specialists analyzed environmental effects according to this level of impact because it would provide an understanding of the greatest potential effects that could occur from the two action alternatives. Air Quality Air quality is managed through a complex series of federal, state, and local laws and regulations designed to ensure compliance with the Clean Air Act. The EPA has the primary role of establishing ambient air quality standards and ensuring compliance to those standards through the Clean Air Act. In Montana, air quality is managed at three levels of government: federal (Environmental Protection Agency [EPA]), state (Montana Department of Environmental Quality [MDEQ]), and local health departments (county rules). The state agency that has federal delegation of authority for meeting the Clean Air Act requirements is the MDEQ Air Quality Program. Air quality for the analysis area is considered good to excellent for most of the year. Smoke from wildland and prescribed fire and dust from native and gravel surfaced roads are the principle factors affecting air quality. To minimize air quality concerns, prescribed fires are scheduled when atmospheric conditions are conducive to smoke dispersal and Montana Airshed Group guidelines are followed during all burning operations.

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The principal factor affecting air quality in the analysis area is wood smoke. Smoke from debris piles would be limited in time and space so as to prevent significant impacts on air quality in any portion of the project area. No broadcast burning is proposed, which generally produces the largest amount of particulates. Dust generated from native and gravel surfaced roads during use by vehicles and maintenance may also temporarily affect air quality. These impacts are generally low in severity and short in duration and would result in no measurable effect to air quality.

Alternative 1 Effects Under Alternative 1, there would be no new actions and therefore no direct or indirect effects. However, Alternative 1 would increase the risk of particulate matter from wildfire smoke. This increase would contribute to cumulative effects on air quality for the project area and the geographic area throughout the normal wildfire season.

Alternatives 2 and 3 Effects Direct and Indirect Effects Pile burning of fuels generated by tree removal would be the only activity contributing to wood smoke under either action alternative. All pile burning activities would be coordinated through the Montana Airshed Group to ensure that atmospheric conditions were conducive for good smoke dispersion and fuel consumption. Prescribed burning would have a temporary, short-term effect on the air quality within and immediately adjacent to the project area. Smoke would tend to settle into the lower elevation drainages during the night, but should be cleared out within a few days depending on air stability and winds. Short-term negative effects on recreation and visual quality could result from smoke. These effects would be minimized by burning under atmospheric conditions conducive to smoke dispersion and during periods of light visitation. Cumulative Effects There are no air quality effects from personal use firewood gathering or grazing, and negligible air quality effects from motorized recreation in the area. All cumulative smoke effects from this project and other burn projects scheduled for implementation in the area would be managed to minimize air quality impacts by following the Montana/Idaho Airshed guidelines and by coordinating with the Airshed Group. Fisheries Fisheries analysis reviewed effects at the subwatershed scale to determine if thresholds for sediment or water yield concerns would be approached. The scale of the proposals within these traditional analysis units were determined to be well below thresholds (Watershed Report, page 12) (Fisheries Report, page 6). Proposed activities within the streamside management zones4

4 "Streamside management zone" means the stream, lake, or other body of water and an adjacent area of varying width where management practices that might affect wildlife habitat or water quality, fish, or other aquatic resources

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(SMZ), especially along westslope cutthroat trout streams, were further reviewed to determine the extent of potential effects at the scale of specific stream segments. Increased water yields from forest mortality episodes are assumed to be part of a natural cycle in the project area. Approximately 1,700 project treatment acres are within a SMZ. Treatment activities within SMZs are minimal and are especially small in those SMZs bordering westslope cutthroat trout- bearing streams. The highest proportion of SMZ acres to be treated within any sub-watershed is 13.3 percent. Approximately 205 SMZ treatment acres – spread across 10 sub-watersheds – are adjacent to westslope cutthroat trout-bearing streams. None of these ten sub-watersheds exceed five percent proposed SMZ acreage treatments and only two exceed two percent. In general, water and sediment yields directly related to tree removal are not likely to be measurably affected. Proposed treatments within SMZ areas are for small-scale removal along short stream segments (see summary table below). Jefferson and Moose Creek are the only streams with longer stream reaches proposed for treatments and are therefore explicitly analyzed below. The Equivalent Clear-cut Acreage (ECA) analysis in the Hydrologist’s report supports this relationship across the project area. Table 4: Summary of Streamside Management Zone (SMZ) Treatments by Sub-Watershed Proposed Proposed Westslope SMZ with Proposed Total Sixth Order HUC Name Treatment Treatment Cutthroat Treatments in WCT (Sub-Watersheds) SMZ in SMZ (acres) in SMZ Trout in SMZ Segments (acres) (percent) (acres) (percent) Belt Cr.-Carpenter Cr. 113.00 1292 8.75 46.4 3.59 Belt Cr.-Hoover Cr. 122.10 1761 6.93 3.6 0.20 Belt Cr.-Jefferson Cr. 149.68 1188 12.60 53 4.46 Belt Cr.-Monarch 19.64 715 2.75 0 0.00 Belt Cr.-Nasen Coulee 0.06 86 0.07 0 0.00 Butte Cr. 0.00 785 0.00 0 0.00 Cleveland Cr. 1.75 2666 0.07 0 0.00 Headwaters Big Otter Cr. 0.00 244 0.00 0 0.00 Judith R.-Pagil Gulch 0.00 286 0.00 0 0.00 Logging Cr. 144.10 1598 9.02 18 1.13 Lone Tree Cr. 5.30 829 0.64 0 0.00 Lost Fork 0.00 1413 0.00 0 0.00 Lower Dry Fork Belt Cr. 88.20 1332 6.62 0 0.00 Lower Dry Wolf Cr. 16.50 501 3.29 0 0.00 Lower Eagle Cr. 0.20 13 1.54 0 0.00 Lower South Fork Judith R. 83.70 1212 6.91 0 0.00 Lower Tenderfoot Cr. 1.90 1212 0.16 0 0.00 Meadow Cr. 0.07 9 0.78 0 0.00 Middle Fork Judith R. 2.94 1691 0.17 0 0.00 Middle North Fork Mussellshell R. 4.30 172 2.50 0 0.00 Middle Sheep Cr. 12.39 997 1.24 0 0.00

need to be modified. The streamside management zone encompasses a strip at least 50 feet wide on each side of a stream, lake, or other body of water, measured from the ordinary high-water mark, and extends beyond the high- water mark to include wetlands and areas that provide additional protection in zones with steep slopes or erosive soils.

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Proposed Proposed Westslope SMZ with Proposed Total Sixth Order HUC Name Treatment Treatment Cutthroat Treatments in WCT (Sub-Watersheds) SMZ in SMZ (acres) in SMZ Trout in SMZ Segments (acres) (percent) (acres) (percent) Middle Tenderfoot Cr. 6.67 1325 0.50 1.4 0.11 Moose Cr. 79.59 1119 7.11 0 0.00 Mud Cr. 0.00 332 0.00 0 0.00 North Fork Smith R.-Lake Sutherlin 6.12 46 13.30 0 0.00 North Fork Smith R.-Stud Horse Cr. 36.10 1045 3.45 0 0.00 Pilgrim Cr. 0.00 1020 0.00 0 0.00 Running Wolf Cr. 90.90 831 10.94 11.9 1.43 Sheep Cr. Headwaters 122.10 1484 8.23 0 0.00 Smith R.-Bear Gulch 1.60 857.00 0.19 0 0.00 Smith R.-Two Cr. 4.40 536 0.82 0 0.00 Spring Cr. 59.20 1717 3.45 0 0.00 Spring Cr. 0.00 167 0.00 0 0.00 Tillinghast Cr. 0.65 930 0.07 0 0.00 Upper Deep Cr. 0.00 739 0.00 0 0.00 Upper Dry Fork Belt Cr. 74.49 1334 5.58 0 0.00 Upper Dry Wolf Cr. 115.20 1860 6.19 12.5 0.67 Upper Eagle Cr. 2.72 388 0.70 0 0.00 Upper East Fork Roberts Cr. 0.00 142 0.00 0 0.00 Upper Hopley Cr. 1.92 1584 0.12 0 0.00 Upper Newlan Cr. 129.30 1185 10.91 0 0.00 Upper North Fork Musselshell R. 16.25 500 3.25 0 0.00 Upper Roberts Cr. 9.34 520 1.80 0 0.00 Upper Sage Cr. 0.00 456 0.00 0 0.00 Upper Sheep Cr. 46.10 949 4.86 8.9 0.94 Upper South Fork Judith R. 66.29 1436 4.62 17.7 1.23 Upper Tenderfoot Cr. 3.60 1071 0.34 0 0.00 Whitetail Deer Cr. 0.12 593 0.02 0 0.00 Willow Cr. 13.40 129 10.39 0 0.00 Yogo Cr. 52.50 2040 2.57 31.1 1.52

The Forest Fisheries Biologist and the Forest Hydrologist spent several days visiting proposed treatment areas. Site visits prioritized locations with more than occasional or small overlaps with SMZ areas and haul routes that closely paralleled streams. Field review indicated that less than ten percent of the proposed SMZ treatment areas had a majority of trees that would qualify for removal. Segments that had a majority of trees that would be treated tended to be less than one- tenth of a mile long. Areas with Best Management Practices (BMP) road departures and high roadside tree mortality in riparian areas were also noted on site visits. Mechanized harvest access would not occur within SMZs and BMPs would be implemented. Specifically, Montana SMZ law requires at least ten standing live trees larger than 8” in diameter per 100 foot section of stream would remain in the SMZ treatment area. If ten live trees are not available, dead and down trees would be retained to make up the balance (see Resource Protection Measures section above for more detail).

Alternative 1 Effects Direct and Indirect Effects – Water Quality

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Without implementation of new actions, no new management-related impacts to fish, amphibian, or other aquatic species and aquatic habitats would occur. Best management practices-related road improvements would occur more slowly than under the proposed action alternative. Fewer improvements to the existing road system would also likely be performed than under the action alternatives. As a result, net sediment inputs to stream and wetland habitats would likely be higher over time than in the action alternatives. Direct and Indirect Effects – Aquatic Habitat There would likely be more non-native trout in stream sections where conservation populations do not exist due to higher levels of woody debris, which would provide more opportunities for anglers. Other unplanned removals of hazard trees, such as firewood cutting outside of permit stipulations, would still limit the amount of wood that would enter the streams in these high use areas which lie immediately adjacent to roadways. Project area streams with westslope cutthroat trout population levels are heavily depressed due to competition with eastern brook trout. Research is inconclusive as to whether increased woody debris is favorable to westslope cutthroat trout in the presence of competition from eastern brook trout. Anecdotal evidence suggests that eastern brook trout in this project area tend to dominate pools created by woody debris. It is unlikely that woody debris levels would be positively correlated with westslope cutthroat trout abundance in the project area streams in which brook trout also exist. Proposed treatment levels are below 5 percent of SMZ areas in streams where westslope cutthroat exist without competition from eastern brook trout. There would likely be a slightly higher increase in future westslope cutthroat abundance in these streams under Alternative 1 due to higher recruitment of trees. Stream temperatures would remain unchanged under Alternative 1. Cumulative Effects There are no new effects to fisheries under Alternative 1 and therefore no cumulative effects.

Alternative 2 Effects Direct and Indirect Effects – Water Quality Direct and indirect effects to fish and other aquatic organisms because of water quality impacts are unlikely to occur. In the short-term, sediment delivery from forest roadways is the water quality impact most likely to result from proposed project activities. However, state stream water quality standards for sediment would be met by implementing best management practices and Forest Plan standards and guidelines. In the long-term, a net decrease in sediment delivery to project area streams would occur from BMP work performed on project roadways. Sediment delivery reductions would improve the survival and reproductive success in some stream segments for aquatic species sensitive to chronic levels of elevated in-stream sediment including the westslope cutthroat trout and the western pearlshell mussel. This is substantiated by field inspections, road-related erosion events

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observed during the 2011 flood-year, and road sediment yield modeling efforts performed by the forest hydrologist and forest fisheries biologist. Direct and Indirect Effects – Aquatic Habitat Direct effects to aquatic habitats would occur during BMP road work at stream crossings. Some effects may also occur from BMP related maintenance where roads immediately parallel streams and from site level bank disturbances during stream crossing construction or maintenance activities. Road BMPs application would minimize short-term effects. Any temporarily elevated levels of sediment would be too low to induce mortality or reproductive failure in fish, amphibian, and mussel species. The 1,704 acres of proposed treatments, which occur within SMZ areas, would slightly limit the size of expected increases in the recruitment of large woody debris within most of the affected streams. Recruitment of large woody debris at this light of a level of manipulation has been shown to produce minor or inconsistent population responses (Sweka and others 2010). These responses would be confined to short stream segments or individual habitat units such as a pool or run. For Moose and Jefferson Creeks, the reduction of expected increases could hit moderate levels however impacts would definitely not effect viability because SMZ BMPs would allow for sufficient woody debris recruitment within treatment areas. Proposed activities have the potential to influence stream temperatures by removing stream-side trees. With two exceptions, Jefferson and Moose Creek, the total length of any stream segment in which hazard trees could be removed would be relatively short with potential effects that are too negligible to be measurable. The effects of hazard tree removal in the longer segments of Jefferson and Moose Creek could result in slightly higher daytime conditions for reaches within the project area and for a few hundred meters below. However, these temperatures would still be far below thermal limits observed for distribution and survival of the westslope cutthroat trout, which is the fish species most sensitive to elevated temperatures in the project area (Bear and others 2007). These slight thermal effects would also be short in duration as the trees would start to fall if not removed. Understory vegetation would also grow and increase canopy height and density, thereby contributing to shade cover. Cumulative Effects – Water Quality There are existing effects to water quality from activities including personal use firewood cutting, motorized recreation, and livestock grazing. Effects from actions connected to this project would not decrease the viability of populations of sensitive aquatic species when combined with these impacts. Impacts from past and present land use activities and current infrastructure features such as the road and trail system are present in the proposed project area. Some sediment produced by past harvest projects and wildfires could still be stored in streams. Sediment and water yield have also increase because of high levels of tree mortality occurring on the landscape. Increased flows can scour stream banks which increases the fine sediment in suspension and in the bed load. Road systems can amplify the quantity of sediment and water yields produced by these episodes. Having a landscape that exceeds historical proportions of mature lodgepole pine could also amplify yields above previous levels. The removal of dead

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trees, especially at the low intensity of this project, would not increase water yields and BMP- related road improvements would reduce sediment loads. Cumulative Effects – Aquatic Habitat There are existing impacts to aquatic habitat quality from activities including personal use firewood cutting, motorized recreation, and livestock grazing. Effects from actions connected to this project would not decrease the viability of populations of sensitive aquatic species when combined with these impacts. Noxious weed spread is a potential cumulative effect of this alternative on aquatic habitat units. However, prescribed noxious weed control, prevention, and monitoring activities would effectively reduce and mitigate any effects from noxious weeds. All weed treatment would be in adherence to the Lewis and Clark NF Herbicide Application EIS (1994). Additionally, using certified herbicides in accordance with all label instructions would prevent nearly all effects to aquatic wildlife species (Tatum 2004). A very unlikely event is a cumulative effect to aquatic wildlife from herbicide application in the event of a heavy, un-forecasted rain event following application. Without mechanized harvest entry in SMZs and with restrictions on herbicide use near stream and wetland areas, concentrations which could enter aquatic habitats would be highly reduced regardless of weather events. Livestock grazing is the current activity in the project area that appears to be responsible for stream habitat alterations. However, the three westslope cutthroat trout streams in the project area where grazing related alterations are high enough to create management related concerns do not contain near-stream, parallel road corridors or recreation or administrative facilities. Thus, impacts from proposed SMZ treatment units or near-stream haul routes in these three catchment basins would be minimal in two and non-existent in one such that there would be no measurable cumulative effect to aquatic habitat. Any effect of the treatments on aquatic temperatures would be short in duration and immeasurable for most of the project area streams. In places where temperatures did increase, the level would still be far below thermal limits observed for distribution and survival of the westslope cutthroat trout, which is the fish species most sensitive to elevated temperatures in the project area (Bear and others 2007). Adding this thermal effect to predicted local rates of global climate change would not form a tipping point for survival at the organism level or viability at the population level. This conclusion is based on climatic predictions made by a multitude of scientists with a weighting towards models, which best predict, or most accurately match, historical weather observations (Isaak and Riemen 2012; Isaak and others 2010; Barsugli 2009).

Alternative 3 Effects Direct and Indirect Effects – Water Quality and Aquatic Habitat This alternative is similar in expected effects on fish and aquatic wildlife habitat and populations as Alternative 2. Road maintenance requirements would be the same and therefore proposed activities would be expected to reduce net sediment delivery to the same or nearly the same levels. Effects to stream temperatures from removing dead trees at the project scale would be

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temporary in space and time. These would mostly be too low to be measureable as would any differences between this alternative and Alternative 2. Stream temperatures are currently well below upper thresholds for limiting population numbers and viability in the streams where proposed treatments could cause very small but measurable effects. Differences in woody debris recruitment are also similar except in the case of Moose Creek where retention levels would likely be lower than for Alternative 2. The difference may not be enough to affect fish abundance and definitely not viability because SMZ BMPs would allow for sufficient woody debris recruitment within treatment areas. Cumulative Effects Cumulative effects under Alternative 3 would be the same as those described under Alternative 2. Weed spread in riparian and SMZ habitat areas and herbicide application effects would be nearly identical between Alternative 2 and 3. Differences in bare ground requiring herbicide application would be minor and would not result in different conclusions about effects. Fuels The central concern for managing wildfires is firefighter and public safety. Travel routes and ingress and egress routes are critical to minimizing risk. The Little Belt Mountains Hazard Tree Removal Project focuses on hazards along roads and recreation areas and provides an opportunity for the Lewis and Clark NF to be proactive in providing safer travel corridors and recreational opportunities. Climate change impacts may have contributed to wildfire risk in the analysis area. Climate change and its specific effects to vegetation and fire behavior in the future are uncertain, but there are some general predictions. Westerling et al. (2006) attribute the increase in wildland fire frequency in the west over the last twenty years to alterations in fire regimes due to climate changes over a large geographic area. Throughout the west, more frequent fires are currently burning an extended period of time (average of 5 weeks) compared to the infrequent fires lasting less than one week that were common prior to the mid-1980s (Westerling et al. 2006). To the extent that current climactic warming trends continue, those effects may intensify over time. Community Wildfire Protection Plans (CWPPs) were developed by multiple stakeholders in response to the National Fire Plan for counties within the project area. Approximately 7,877 acres (45 percent) of proposed treatment fall within the wildland-urban interface zone as identified in the Cascade County CWPP, Meagher County CWPP, and HFRA WUI (USDA LCF 2013).

Alternative 1 Direct and Indirect Effects In untreated roadside areas, dead or dying trees would have mostly fallen within fifteen years (Mitchell and Preisler 1998), which would greatly heighten 1000-hr fuel loading. This increase in large, dead wood hinders fire suppression, slows fireline production, and increases residence time - the total length of time that the flaming front of the fire occupies one point - should a fire occur. Long residence time promotes smoldering of duff and litter, which creates high smoke

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emissions and exposes mineral soil. Additionally, fire suppression costs can be very high due to extended clean-ups to extinguish large, dead logs5. This alternative may severely affect ingress and egress due to trees falling across roadways blocking access. Roads play a critical role in fire suppression as access and anchor points. Roads can also be used to burn out from so as to create a defensible space by consuming flammable fuels. Blocked road access would lengthen response time of ground resources and may compromise firefighter safety due to impeded use as an escape route. Because of the urgency related to a wildfire response, if engines or handcrews could not access a fire by road due to blocked routes from fallen trees, access would be limited to hiking or aerial response. In evaluating fire response, safety concerns must be evaluated and eliminated or mitigated. The National Interagency Fire Center’s online records indicate that 34 firefighters were killed by snags during fire suppression between 1910 and 2010 (NIFC 2013). Another 2 deaths have occurred in the past three years. The risk of fighting fires with large numbers of snags or working in conditions with large, woody debris where escape routes are compromised would require mitigating the safety concerns prior to response or possibly not engaging firefighters, which can increase the amount of time and the scale of resources (e.g. mechanized equipment as opposed to fire crews) required for suppression. Alternative 1 may also create hazardous conditions in developed recreation and recreation residential areas as well. Increased fuel loadings created by fallen hazard trees would hamper fire suppression efforts and increase the risk of high intensity fire behavior. Combining the potentially limited ingress and egress routes with the potential for higher intensity fires that could occur directly adjacent to these recreation areas could put the public and firefighting personnel in increased danger in the event of a wildfire.

Alternative 2 Direct and Indirect Effects Implementation of Alternative 2 would maintain effective ingress and egress routes for landowners, recreationists, firefighters, and other Forest Service personnel. Removal of hazard trees as proposed under Alternative 2 would have a positive effect on firefighting access and suppression success. With a serviceable road system, firefighters can better access fires. Quicker response times due to unimpeded travel routes can increase suppression success. Conditions would be safer for firefighters in treated areas because of the reduced potential for hazard trees to fall during response. If windthrow occurs adjacent to proposed roadside treatment areas following implementation, fuel surface loading of 1000-hr fuels, needles, and branchwood would increase. While needles are green, potential fire behavior would generally be low. Once needles turn red and the fuels desiccate, potential fire behavior depends on time of year and weather conditions. Fire behavior may be more active during the summer with high temperature, low relative humidity, low fuel moistures, and wind direction conducive for fire spread than the remainder of the year. After a

5 Professional experience of Fuels Specialist, 18 years in fuels implementation and 9 years in fuels planning.

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number of years, the needles would start decomposing which generally results in less active fire behavior. Additionally, Alternative 2 would reduce hazardous conditions in developed recreation and recreation residential areas. Potential increases in fuel loadings from fallen trees would be mitigated and as well as the likelihood of conditions that would hamper fire suppression efforts and increase the risk of high intensity fire behavior.

Alternative 3 Direct and Indirect Effects Effects from Alternative 3 would be the same as those listed under Alternative 2 but the extent of the benefits realized would be less than described under Alternative 2 because fewer hazard trees would be removed. Additionally, hazard trees not removed by this alternative would present safety hazards to fire suppression resources. These would have to be mitigated or avoided during operations and could potentially limit available suppression options. Ingress and egress routes would still benefit due to the reduced number of hazard trees that could potentially impact the travel routes but the benefits would be less than those described under Alternative 2.

Cumulative Effects of All Alternatives A portion of the National Forest System (NFS) lands within the Little Belt Mountains Hazard Tree Removal Project area have been harvested. Timber harvest has also occurred on private and industrial lands in the project area. Most of this is on private timber lands with some occurring on small private holdings. These past activities have broken up the fuel connectivity on a landscape scale in such a way that is helpful to fuels management. Recent regeneration harvests still function as effective fuel reduction areas. Even in areas where an intermediate harvest occurred, the crown connectivity has been altered enough to affect the sustainability of crown fire within these stands in a manner that aides fire behavior. Past treatments have made the area more defensible for fire suppression activities for decades. Firewood cutting has an annual effect on forests 200 feet adjacent to roads open year round and seasonally. Lodgepole pine and Douglas-fir are the preferred species; however ponderosa pine and any other dead species are removed. This activity can reduce coarse down woody material, snags, and fuels up to 200 feet from roads. However, accumulations of branches and tops are left from these activities causing an increase in <3” woody material. In areas of heavy firewood collection, the removal of dead wood breaks up horizontal and vertical fuel continuity; this action combined with the fuel-free road surface assists in successful suppression operations. Firewood cutting would continue following proposed treatments under Alternatives 2 and 3. This activity could aid in removing hazard trees after the one-time-entry proposed to address the large-scale and more eminent need. Prescribed fire activities also serve to reduce fuel loadings and provide increased potential for successful suppression activities if a wildfire occurs in the project area. Ongoing projects in the Little Belt Mountain range include: 1. Monarch/Neihart Hazardous Fuel Reduction-Phase I, which involves mechanical fuels treatment and prescribed burning in the interface adjacent to Monarch/Neihart;

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2. Ettien Ridge Fuels Reduction, which involves commercial and non-commercial thinning and prescribed burning to reduce hazardous fuels; 3. Fuel treatments around Forest administrative sites, summer homes, radio repeater sites, campgrounds, helispots, and weather stations on the Musselshell RD; and 4. Mass/Geis Hazardous Fuel Reduction, which involves reduction of hazardous fuels in two drainages near the Forest boundary. Wildfires in the area have the same effect in potentially reducing fuel loadings and increasing potential for successful suppression activities. However, wildfires often increase the number of hazard trees depending on the intensity and duration of the fire. These hazard trees can cause increased safety concerns for firefighters and public similar to those caused by the mortality from the pine beetle infestation. Other foreseeable actions include noxious weed control, road maintenance, administrative road use, public recreational use including mororized use, grazing, and small forest products gathering for personal use. These activities would not be expected to contribute to, or inhibit, efforts to achieve desired stand conditions. Heritage

Alternative 1 Effects No direct effects are expected with Alternative 1. Potential indirect or cumulative effects are possible to some cultural resources if no action is taken. When hazardous trees fall naturally, they have the potential to damage standing historic structures.

Alternative 2 Effects Adverse impacts are not anticipated to religious or cultural sites, archaeological sites, or historic properties or areas from the implementation or monitoring of the proposed treatments. Site- specific cultural resource inventories would be completed prior to implementation based on the Forest Site Identification Strategy (SIS) found in Region One’s Programmatic Agreement between the Forest Service and Montana State Historic Preservation Officer. All identified historic properties or unevaluated sites would be avoided, treated, or mitigated to prevent adverse effects according to the Protocols: Bark Beetle Epidemic and Hazardous Tree and Fuel Reduction, USDA Forest Service, Northern Region. This alternative has the potential to have a beneficial effect on some historic properties or unevaluated cultural resources as the removal of the hazardous trees would reduce the potential of trees falling on and damaging standing historic structures.

Alternative 3 Effects No direct effects are expected with Alternative 3. All identified historic properties or unevaluated sites would be avoided, treated, or mitigated to prevent adverse effects according to the Protocols: Bark Beetle Epidemic and Hazardous Tree and Fuel Reduction, USDA Forest Service, Northern Region.

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This alternative also has the potential to have a beneficial effect on some historic properties or unevaluated cultural resources as the removal of the hazardous trees would reduce the potential of trees falling on and damaging standing historic structures. However, the potential benefits would not be as large as those realized under Alternative 2. There would also be the possibility of indirect or cumulative effects to some cultural resources from remaining hazard trees. When hazardous trees fall naturally, they have the potential to damage standing historic structures. Effects to historic properties or unevaluated sites would need to be mitigated in order to prevent adverse effects. Mitigation would be established through consultation with the SHPO and THPOs. Hydrology The analysis area for direct and indirect effects, and cumulative effects to riparian conditions, is defined by 6th-Hydrologic Unit Code (HUC) watersheds which contain treatment areas proposed for tree-removal. Cumulative effects analysis also includes past, present, and reasonably foreseeable management activities that would impact 6th HUC watersheds containing treatment areas. Riparian and stream conditions have been assessed by the Montana Department of Environmental Quality (MTDEQ) to determine water quality limited stream (WQLS) segments. Of the 50 stream segments within the project area, seven are considered to be at high risk for water quality impairment (see table below). Potential impacts to hydrologic resources within the project area include changes in water yield and sediment delivery, and impacts to riparian areas. Stream temperatures are not likely to be affected by the proposed activities based on the small percent of effected watershed area. Other water quality impairments (e.g. increased levels of metals or nutrients change in pH) are not likely to be affected by the proposed activities. Therefore, there will be no further discussion of these issues. Table 5: Water Quality Limited Streams, Little Belt Mountains (1994/2004 Montana Water Quality Integrated Report) STREAM PROBABLE PROBABLE PROBABLE SOURCE OF LOCATION IMPAIRED USES CAUSE OF IMPAIRMENT IMPAIRMENT Belt Creek Aquatic Life (N), Metals, Siltation, Highway/roads/bridge From Carpenter Cold Water Fishery Bank erosion, Fish construction, Resource Creek to Big - Trout (N), Habitat extraction, Acid Mine Otter. Drinking Water degradation, Other drainage, Channelization, (N), Swimming (F) habitat alterations construction, Ag (P), Industry (P) hydromodification, Agriculture, Grazing. Carpenter Aquatic Life (N), Metals, Cadmium, Mine Tailings, Acid Mine Headwaters to Creek Cold Water Fishery Copper, Lead, Drainage, Abandoned mouth (Belt Cr) - Trout (N), Mercury, Mining, Resource extraction. Drinking Water (N), Swimming (X) Ag (X), Industry (X) Galena Creek Aquatic Life (N), Metals, Cadmium, Mine Tailings, Acid Mine Headwaters to Cold Water Fishery Copper, Lead, Drainage, Resource Mouth (Dry Fork - Trout (N), Zinc, Siltation extraction. Belt Creek) Drinking Water

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STREAM PROBABLE PROBABLE PROBABLE SOURCE OF LOCATION IMPAIRED USES CAUSE OF IMPAIRMENT IMPAIRMENT (N), Swimming (N), Ag (N), Industry (N) Dry Fork Belt Aquatic Life (N), Metals, Cadmium, Mine Tailings, Acid Mine Headwater to the Creek Cold Water Fishery Copper, Lead, Drainage, Contaminated Mouth of Belt - Trout (N), Zinc, Siltation Sediment, Resource Creek Drinking Water extraction. (N), Swimming (P), Ag (N), Industry (F) SF Judith Aquatic Life (P), Other Habitat Grazing Related Sources, Headwaters to River Cold Water Fishery Alteration, Fish Logging, Roads, Land Mouth - Trout (P), Habitat Development, Agriculture, Drinking Water Degradation, Silviculture, Construction (X), Swimming (X) Siltation Ag (F), Industry (F) Sheep Creek Aquatic Life (X), Other , Resource Pathogens, Metals, Mercury Headwaters to Cold Water Fishery extraction, Pacer Mouth - Trout (X), Mining Drinking Water (N), Swimming (N) Ag (F), Industry (F)

In general, vegetation management activities have the potential to alter hydrologic processes (Troendle 1996). In certain situations, forest canopy removal can increase snowmelt rates and can decrease transpiration rates, both of which can result in on-site water yield. Additionally, timber harvest involving tractor skidding may cause varying degrees of soil compaction and increases in surface runoff efficiency, which would also increase water yield (Hydrology Report, page 7). Past timber harvest activities in the Little Belt Mountains were converted to an equivalent clearcut area (ECA). ECA calculations reflect different harvest prescriptions that remove various levels of forest canopy. Results standardize these harvest areas to a percentage of a clearcut acre. A cumulative ECA of 20% or less is considered to be a low risk for causing measurable changes in water quantity (Troendle 1983). The effects of tree removal on water yield depend on many factors, the most important of which is the percent watershed area with tree removal. A statistically significant increase in stream flow is generally not measurable until at least 20 to 30 percent of a watershed’s forest cover is removed (MacDonald & Stednick, 2003). Proposed treatments fall well below this range; based on an equivalent clearcut analysis, the most any watershed would be impacted is 14.2% cumulatively. On average, treatment activities are likely to impact only 1.59% of the watershed. Trees to be cut under the proposed action would be dead or dying trees resulting from insect infestation. Dead trees do not transpire and are thus not a primary vector for groundwater leaving the basin. Thus, removing these trees would not affect the water balance in any watershed. Some living trees that are deemed hazardous due to structural defects would also be removed under the proposed action. The loss of these trees from the landscape would represent a reduction in transpiration. However, the number of living trees removed in this project in any given watershed would likely be so small that any increase in water yield would be well below

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detection limits. For these reasons, this analysis concludes that no measurable change in water yield would occur as a result of the proposed activities. Sedimentation is the water-quality impact most likely to result from the proposed activities. The dominant vector for sediment delivery to stream channels in the project area is forest roads. Increased heavy-truck traffic related to log hauling can increase rutting and displacement of road-bed material, creating conditions conducive to higher sediment delivery rates (Reid & Dunne, 1984). For this analysis, all roads adjacent to streams are treated as potential sediment delivery vectors. Road sediment modeling (using WEPP: Road software) was performed by the Forest Hydrologist. The proposed project would meet state stream water quality standards for sediment by implementing resource protection measures listed above and the state-required best management and conservation practices detailed in the Hydrology Report. Best management practices control the extent, kind, and distribution of soil disturbance and resulting sedimentation effects to stream systems and beneficial uses. The most recent Montana Department of Natural Resources (DNRC) Forestry BMP Audit Report determined that “conclusions drawn from audit results over the past 18 years are very straightforward and consistent; when BMPs are applied correctly, they very effectively protect soil and water resources” (Ziesak, 2008, p 31).

Alternative 1 Effects Under Alternative 1, no new management actions are proposed and therefore no new management-related water resource impacts would occur. Past and ongoing management activities, such as road use, road improvements, OHV use, mining, and livestock grazing would continue to affect water resources. No new additions to watershed-scale cumulative effects would be predicted. However, anticipated road maintenance in some drainages would reduce sediment delivery from roads where work is planned and effectively implemented. This road work would likely not be as extensive as under Alternative 2. An additional consequence of the no-action alternative would be that hazard trees are removed in a less-structured manner. Potential effects of this outcome could include increased administrative traffic, and increased trailing and other disturbance from firewood gatherers. Several past and present federal and non-federal activities have affected and continue to affect water quality, water yield, and riparian health and vigor in the project area. Past timber harvest has likely caused temporary increases in water yield and sediment delivery in the past, though these effects generally attenuate over time. Past pulses of elevated sediment can remain in stream channels for many years following deposition. Continued grazing in riparian areas and cattle trailing along streams within grazing allotments would continue to contribute elevated sediment levels to streams in the watershed. In the absence of other reductions to sediment delivery in the watershed, streams in several of the watersheds where treatment is planned would continue to receive elevated levels of sediment. Other activities that would serve to reduce sediment delivery to streams in project watersheds would likely be implemented periodically in the future within the project area. Such activities include watershed improvement projects, culvert upgrades, and effectively implemented

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allotment management plan (AMP) revisions, among others. Additionally, road obliteration work occurs annually on the LCNF.

Alternative 2 Effects Alternative 2 would temporarily expose mineral soil to erosion, and may create new (or exacerbate existing) vectors for sediment transport to stream channels. However, BMP application would minimize erosion from treatment areas (Logan, 2001). Where erosion from a treatment unit occurs, SMZ and Resource Conservation Recovery Act buffers would prevent transport of eroded sediment from treatment areas directly to streams across untreated forest floor (Ice et al., 2004; Montana DNRC, 2008). Sediment eroded from a treatment unit could, however, reach a stream channel via a road. Haul roads are the most likely source of sediment to project area streams, particularly where there are existing sediment delivery points. While results should be considered a best-case scenario of sediment reduction, it is anticipated that project activities would result in a net decrease of sediment delivery to project area streams. Both action alternatives require that all haul roads with known sediment-delivery points be improved to reduce delivery prior to commencement of tree removal and hauling. Several generic road segments were modeled using the roads module of the WEPP model (Elliot, 2000) in order to estimate potential reductions in sediment delivery resulting from project road improvements. Results indicate that sediment delivery would decrease on an annual average basis by roughly 90%. Results similar to these could reasonably be expected at delivery sites on project roads where road maintenance and improvement occurs. Additionally, while the proposed road BMP work would reduce sediment delivery from project roads during project activities and into the future, blading of native-surface roads temporarily exposes higher levels of sediment to erosion and transport (Sugden & Woods, 2007). Compaction of freshly bladed surfaces prior to rainfall, which would occur under the proposed activities, reduces this temporary road surface susceptibility to erosion. Streambank erosion is not expected from project activities as equipment would not operate in SMZs and hand crews would not cut trees along stream banks unless they are determined to be hazard trees (e.g. leaning toward a road). Hand crew work within SMZs is not likely to result in a level of ground disturbance that would lead to any soil erosion or sediment transport. Cumulative Effects In addition to the impacts of sediment delivery from roads and road impacts on riparian area and stream form and function, several past and present federal and non-federal activities have affected and continue to affect water quality, water yield, and riparian health and vigor in the cumulative effects analysis area. Past timber harvest has likely caused temporary increases in water yield and sediment delivery in the past, though these effects generally attenuate over time. Past pulses of elevated sediment can remain in stream channels for many years following deposition. Continued grazing in riparian areas and cattle trailing along streams within grazing allotments would continue to contribute elevated sediment levels to streams in the watershed. Personal

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firewood cutting and motorized recreation may also be contributing to elevated sediment levels. In the absence of other reductions to sediment delivery in the watershed, streams in several of the watersheds where treatment is planned would continue to receive elevated levels of sediment. In the watersheds where tree removal is proposed, water yield most likely has been and would continue to be affected by large-scale tree mortality. As discussed above, large-scale loss of live trees reduces the volume of water removed from a watershed by transpiration. Increases in water yield could result in higher peak flows, which have the potential to increase stream bank and bed scour. The proposed action would not contribute to this process as the vast majority of trees to be removed are already dead. Extensive tree mortality will also affect stream temperature in streams that cross the affected stands. However, understory vegetation, generally unaffected by insect mortality, will continue to provide shade. Furthermore, understory and riparian vegetation exposed to increased levels of sunlight (due to overstory mortality or tree removal) can expand and provide additional shade (Gravelle & Link, 2007). While an increase in incoming short-wave (solar) radiation is generally considered to be the dominant driver of stream temperature increase, numerous factors influence the extent to which a stream exposed to additional direct sunlight will have an increase in water temperature (Johnson, 2004). Thus, the extent of water temperature changes resulting from overstory mortality is difficult to predict. In any case, the likelihood that the proposed action would meaningfully contribute to any stream temperature increase is small, given the relatively short stream segments along which treatment would occur, and given the minimal removal of vegetation in SMZs. Reasonably foreseeable federal and non-federal activities that could affect water quality, water yield, and riparian health and vigor in the cumulative effects analysis area include future timber harvest, continued livestock grazing allotments, roads, and fire. Foreseeable timber harvest activities in the analysis area on the National Forest are not likely to substantially affect water quality or riparian-area viability, because of compliance with the SMZ law and strict adherence to forestry BMPs (Montana DNRC, 2008). Livestock access to streams (within grazing allotments) is unlikely to change since nearly all trees along stream banks would be left standing. Road impacts on water quality would be incrementally reduced due to the road maintenance incorporated into the proposed action. Other activities that would serve to reduce sediment delivery to streams in project watersheds would likely be implemented periodically in the future within the cumulative effects analysis area. Such activities include watershed improvement projects, culvert upgrades, and effectively implemented allotment management plan (AMP) revisions, among others. Additionally, road obliteration work occurs annually on the LCNF.

Alternative 3 Effects Direct and Indirect Effects Impacts from Alternative 3 are, for this analysis, considered equivalent to Alternative 2. Proper application of forestry BMPs (Logan, 2001) should minimize erosion from treatment areas. Haul roads would be the most likely source of sediment to project area streams. All log-haul roads

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with known sediment-delivery points would be improved to reduce delivery prior to commencement of tree removal and hauling. Cumulative Effects Cumulative effects of Alternative 3 would be the same as for Alternative 2 (Hydrology Report, page 21). Inventoried Roadless & Wilderness Study Act Areas There are 14 Inventoried Roadless Areas (IRAs) and one Wilderness Study Act Area (WSA) within the project area but treatments are only proposed within the following nine IRAs: Big Baldy, Calf Creek, Eagle Park, North Fork Smith, Paine Gulch, Pilgrim Creek, Spring Creek, Tenderfoot-Deep Creek and Tollgate Sheep. These IRAs were analyzed using the characteristics of the roadless area inventory (RARE II). The Middle Fork Judith Wilderness Study Area (WSA) is also analyzed (IRA & WSA Report, page 1). The purpose of the analysis on the roadless resource is to disclose potential effects to wilderness attributes and determine if, or to what extent, treatments may affect future consideration for wilderness recommendations. Activities within Inventoried Roadless Areas (IRAs) and the Judith Wilderness Study Act Area (WSA) associated with this project were evaluated while primarily considering the “2001 Wilderness Roadless Rule” for IRAs and the 1977 Montana Wilderness Study Act for the WSA. While the nine IRAs were identified as inventoried roadless areas, they were not recommended as wilderness in the Forest Plan. For more details on each of these IRAs, see Appendix C of the Lewis & Clark National Forest Plan Final EIS (Volume II) . The 2001 Roadless Rule provides management direction for timber cutting, sale, or removal and road construction/reconstruction within designated inventoried roadless areas (36 CFR 294 Subpart B {66 FR 3244} January 12, 2001). Although the Rule has been subject to continuous litigation, at the writing of this report, the Rule remains in effect. The Rule states the following: “Any necessary timber cutting or removal or any road reconstruction in emergency situations involving wildfire suppression, search and rescue operations, or imminent threats to public health and safety in inventoried roadless areas will be reviewed by the Regional Forester.” The table below summarizes IRAs and proposed treatment areas within the Little Belt mountains.

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Table 6: Little Belt IRAs, the WSA, & Proposed Treatment Areas Proposed Proposed IRA Name & Total IRA Total IRA Treatment Treatment Acres Road Miles Forest Plan # Acres in IRA Miles in IRA

Big Baldy (#731) 44,000 383 15.7 12.0 Calf Creek (#745) 11,020 67 4.9 1.9 Eagle Park (#746) 6,300 10 0.2 0.2 North Fork Smith (#744) 8,800 41 6.0 1.2 Paine Gulch (#728) 8,500 56 0.7 0.7 Pilgrim Creek (#727) 49,500 23 2.2 0.6 Spring Creek (#741) 19,800 16 10.5 0.4 Tenderfoot-Deep Creek (#726) 88,400 224 12.4 6.9 Tollgate-Sheep (#733) 26,800 94 14.5 3.3 Middle Fork Judith WSA 90,527 324 64.0 7.3 Total 353,647 1,238 67.1 34.5

In accordance with Forest Service Handbook direction (1909.12{72}), the following wilderness indicators are used to measures effects of proposed treatments on unroaded lands within project areas: Natural, defined as the extent to which long-term ecological processes are intact and operating; Undeveloped, defined as the degree to which the impacts documented in natural integrity are apparent to most visitors; Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation, where solitude is a personal, subjective value defined as the isolation from sights, sounds and presence of others, and from developments and evidence of humans, and primitive recreation is characterized as meeting nature on its own terms, without comfort and convenience of facilities; Special Features, which are unique ecological, geographical, scenic and historical features of an area; and Manageability, which is the ability to manage an area for wilderness consideration and maintain wilderness attributes. In addition to wilderness attributes, IRAs and the WSA may contain roadless characteristics. The IRA & WSA Report outlines a crosswalk between wilderness attributes and roadless area characteristics, which is summarized below. Since potential project effects to roadless values are

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evaluated in other specialist reports as they relate to specific resources, this analysis focuses on wilderness characteristics. The paragraphs below summarize existing conditions for each of the wilderness characteristics according to IRAs and the WSA. Big Baldy IRA (#731) The Big Baldy IRA is a contiguous parcel in central Montana 8 miles south of Monarch and 18 miles southwest of Stanford in Judith Basin and Cascade Counties. Natural – Most of the area is wooded with large parks at the higher elevations and smaller parks interspersed at the lower elevations. Vegetation is typical of the Little Belt Mountains; lodgepole pine and Douglas-fir with sparse ground cover. Undeveloped – Human activity in this area has left some impact. Low standard roads penetrate into Chamberlain Creek, Hoover Ridge, Butcherknife and Snow Creek. Hard rock mining exploration has occurred throughout the area. Remains from miner’s cabins and digging piles are not uncommon. The existing 15.7 miles of road within the IRA do impact the natural character of the area. It should also be noted there are numerous trails located within the IRA. Opportunities for Solitude or Primitiveness – Large enough area with topography such that persons visiting the core of the area feel they are in a natural setting. Peripheral areas give little feeling of naturalness or opportunities for solitude. Special Features and Values – Big Baldy Mountain and Butcherknife Mountain are both located within this IRA. The five acre Rhoda Lake, located in a cirque at the base of Big Baldy Mountain, is a popular recreation destination. Manageability – The Big Baldy is a sizeable unit, although at its narrowest point it is only three miles across. Some boundaries are defined on major terrain features, while other boundaries would be difficult to locate on the ground. Conflicts with adjacent private land cannot be avoided. Calf Creek IRA (#745) The Calf Creek IRA lies in the southwest corner of the Little Belt Mountains, about 20 miles northwest of White Sulphur Springs in Meagher County. Along the northern border an improved dirt road separates the roadless area from the Tenderfoot Creek Experimental Forest to the north. The main body of the IRA is Calf Creek, which begins in the broad parks on the northern boundary and drops gradually into timbered ridges and U-shaped creek bottoms. Natural – Most of the IRA is timbered with lodgepole pine and Douglas-fir, except along the northern boundary. Some of the area is used for livestock grazing. Within the area there is only limited and scattered evidence of past and present human activity. Undeveloped – Drift fences and other signs of livestock grazing and hunting camps along stream bottoms are evident. Currently there are 4.9 miles of road located within the IRA which impacts the undeveloped character. It should also be noted there are three designated trails within the IRA.

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Opportunities for Solitude or Primitiveness – The topographic variation, step-sided creek bottoms, and broad ridges provide visitors an opportunity to get away from Forest roads and experience a variety of recreation activities, primarily for day use. Special Features and Values – There are no special features or values within this IRA. Manageability – The area is accessed by improved dirt and gravel roads on all sides, but no roads which penetrate the interior. Efforts to stop existing motorized use could be very difficult due to the number of roads and lack of natural barriers. Eagle Park IRA (746) Located in the southwest corner of the Little Belt Mountains, 25 miles northwest of White Sulphur Springs, in Meagher County, the Eagle Park IRA is a contiguous parcel of Forest Service land. Natural – The natural integrity of the area is nearly unchanged from past or present human activity. The topography is typical of the foothills in the southwestern Little Belt; gentle benches which drop steeply into the creek bottoms. The natural appearance of the area is hindered by the surrounding development. Undeveloped – There are two two-track roads which access the Forest from private land, but there is no legal right-of-way. Although there has been scattered post and pole cutting along the north and east edge, the cutting has been minimal. Road development, logging, and ranch activity is adjacent to the IRA on all sides. Due to the area’s small size, a visitor would never be far removed from this development. Opportunities for Solitude or Primitiveness – The small size of the area and close proximity to the sights and sounds of development detract from the opportunity for solitude. The higher part of Eagle Creek is the most isolated part of the IRA. Special Features and Values – The only notable feature within this IRA is Eagle Creek. Manageability – The present boundary could be easily defined on-the-ground because it is adjacent to roads or surveyed lines. Adjusting the boundary would not improve the wilderness characteristics. North Fork Smith IRA (744) The North Fork Smith IRA lies in the south central edge of the Little Belt Mountains, approximately 20 miles southwest of White Sulphur Springs in Meagher County. Within a quarter mile of the northeast border is the Middle Fork Judith Wilderness Study Act Area. Natural – Overall the landscape appears natural and unchanged by development. The canyons are timbered with lodgepole pine and Douglas-fir, except at the bottoms, which are grass. The entire area, including the canyon bottoms, is dry with limestone outcroppings scattered in the canyons. Undeveloped – About 20 percent of the north end of the IRA is used for livestock grazing. In the northwest corner some two-track roads cross the area. There are three spring developments for livestock also located in the IRA. Adjacent BLM and private land to the south is used for ranching and logging.

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Opportunities for Solitude or Primitiveness – All sides of the IRA are accessible by dirt roads. Due to the small size of the area and the number of roads along the IRA perimeter, the opportunities for solitude are limited. Given that it’s only four miles across at its widest point, the area can be easily traversed within a day. However, steep drainages do offer some screening from roads on the IRA exterior. Special Features and Values – There are no special features or values within this IRA. Manageability – The northwestern, northeastern, eastern and southern boundaries are definable on the ground by roads, power lines, or surveyed land lines. The western boundary would be difficult to locate because it does not follow any distinctive topographic feature. Controlling motorized access within the IRA could be difficult because there is no natural barrier between the road along the northwest boundary and the expansive parks to the east. Paine Gulch IRA (728) The Paine Gulch IRA is a continuous parcel of FS land along the north-central border of the Little Belt Mountains, about 35 miles south of Great Falls in Cascade County. Natural – Because the long-term ecological processes are undisturbed in most of the area, the natural integrity has been maintained. The topography is moderate to steep, with limestone outcroppings toward the ridge tops. The area is very dry and sparsely timbered throughout with Douglas-fir and some ponderosa and lodgepole pine. The west half, from the top of Cry Ridge to the western border, is a designated Research Natural Area. Undeveloped – The four sides of this small rectangular-shaped IRA are adjacent to roads. U.S. Highway 89 parallels, and in places adjoins, the western boundary. A three mile long trail, beginning at U.S. Highway 89 along the northwest corner, angles southeast along the bottom of Paine Gulch ending at the center of the area. Opportunities for Solitude or Primitiveness – Because the Paine Gulch IRA is small and located between U.S. Highway 89 and a Forest development road, it does not provide great opportunities for solitude. Although the sights and sounds of the adjacent lands are screened, the small size and nearby development detract from the opportunity to find solitude. When within the area, visitors are always within 1½ miles of a road. Special Features and Values – Paine Gulch flows northwest through the center of the IRA and opens into Belt Creek through a steep and narrow canyon. The west half of the area, which includes nine different forest vegetation and aquatic ecosystems, has been designated as a Research Natural Area. Manageability – The area’s small size, with roads on the perimeter and a trail down the middle, make the entire area very accessible for administrative and recreation purposes. The present boundary could be easily defined on the ground because it is adjacent to roads or surveyed lines. Pilgrim Creek IRA (727) The Pilgrim Creek IRA lies along the northwest border of the Little Belt Mountains, about 10 miles northwest of Neihart and 20 miles south of Belt in Cascade County. Nearly all sides of this

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circular area are roaded. The area includes the entire Pilgrim Creek drainage, which begins at the southern end and flows north, emptying into Belt Creek at the northern end of the area. Natural – Pilgrim Creek an isolated drainage with limited access due to the adjacent private land. The area is mostly timbered with interspersed small parks. Elevations range from 7,670 feet on Big Horn Mountain to about 5,000 feet at the northern end. Most of the area is timbered with lodgepole pine, Douglas-fir, and some spruce. The stream banks are mostly steep with very little riparian area. Undeveloped – A gravel Forest road in Logging Creek parallels the northern and northwestern border of the IRA. The southwest side can be accessed by a low standard Forest road. U.S. Highway 89 parallels the northeast border. The east side is bordered by private land. The IRA is accessible from three main trails. A 150 KV power line passes through a portion of the IRA. The IRA is used for livestock grazing, recreation, mining, and post and pole cutting. Overall the area shows little or no disturbance from man because past mining activity was primarily hand work. Opportunities for Solitude or Primitiveness – Opportunities for solitude vary within the area. Pilgrim Creek and side drainages are very isolated from outside sounds, vistas, and development. The fringes of the area are adjacent to and influenced by development. The large size of the area and its screening from other parts of the Forest and adjacent development offer the opportunity for some solitude and primitive recreation. Special Features and Values – Big Horn Mountain and Thunder Mountain form a dome at the center of the IRA. Pilgrim Creek is located (north to south) in the center of the IRA. Manageability – Boundaries for the Pilgrim Creek IRA follow surveyed land lines or parallel existing roads or trails. In places along the northeast and southwest, the boundaries could be difficult to locate on the ground. Spring Creek IRA (741) The Spring Creek IRA lies at the southern tip of the Little Belt Mountains, approximately 30 miles northwest of Harlowton and 15 miles north of Martinsdale. All sides and the interior of the area are well accessed by road and trails. The lesser creeks and coulee, which fan out along the northern border, flow south and funnel into Spring Creek. Natural – Most of the IRA is densely timbered with lodgepole pine. The naturalness of the area is hindered by its convoluted shape, close proximity from all points to development, and past timber harvest. Undeveloped – Most of the surrounding area has been developed for timber management or livestock use. Three trails access this IRA and Spring Creek Campground is adjacent to the southwest corner of the area. Several historic sites from past mining and homesteading are located within the area. An exclusion area is designated adjacent to Forest Service Road # 6993 and the Basin Creek Campground. Most of the southern boundary follows the proclaimed Forest boundary and adjoins private land. The western side takes several jogs to seclude private lands, roads and campgrounds. The north half of the west border follows Whitetail Creek and is adjacent to an intensive timber management area.

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Opportunities for Solitude or Primitiveness – Pockets within the area, particularly the narrows, provide opportunities for solitude. Most of the area is either within hearing range of nearby roads or development in the foreground. Special Features and Values – There are several creeks (as identified above) located within the IRA. Manageability – Due to road access to and within the area, it could become difficult to monitor recreation use within the IRA. Tenderfoot-Deep Creek IRA (726) The Tenderfoot-Deep Creek IRA lies in the northwest corner of the Little Belt Mountains, in Cascade and Meagher Counties. White Sulphur Springs is approximately 35 road miles southeast and Great Falls is about 40 road miles north of the area. Although secondary dirt and gravel roads access all sides, only the east side has public access. Natural – The vegetation is a mosaic of meadow and timber with the majority of the site timbered with lodgepole pine, Douglas fir, and spruce. At the western boundary is the highlight of the area, the Smith River. Undeveloped – On the east side is a network of Forest roads, which are passable by passenger vehicle cars but recommended for trucks. To the south and north, two-track roads cross private land to the area. Two roads penetrate the Tenderfoot-Deep Creek Area. Overall, the area has noted little change based on development. The most extensive livestock use is along Tenderfoot Creek and in Deep Creek Park. Opportunities for Solitude or Primitiveness – The area’s size and isolation from development provide an opportunity for solitude. Although portions of the Tenderfoot-Deep Creek IRA are adjacent to non-forest or agricultural land, the outside land uses are not noticeable from most parts of the area. Special Features and Values – There are several notable features located within this IRA including numerous creeks, Mount Vesuvius, Taylor Hills, Bald Hills, Old Baldy, and Desolation Peak. The Smith River and adjacent land have several recorded cultural sites including teepee rings, pictographs, tools, and projectile points. Manageability – The north and west boundaries follow either surveyed landlines or the Smith River, which are both definable on-the-ground. The south and east boundaries do not always follow topographic features and could be difficult to locate on-the-ground. Steep terrain or cliffs around the perimeter of the IRA create a natural barrier for motorized access. Tollgate-Sheep IRA (733) The Tollgate-Sheep IRA is located in the northeast portion of the Little Belt Mountains, approximately 18 miles south of Stanford in Judith Basin County. Most of the area’s perimeter is accessible by road. The east boundary is adjacent to private and other lands with the balance of the perimeter adjoining other National Forest or interior private land.

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Natural – Topography is mountainous and includes five prominent peaks near 8,000 ft. in elevation: Gibson, Bandbox, Sheep, Tollgate, and Woodhurst. Previous human use includes mining, timber harvest, livestock grazing, and recreation. Approximately 3,000 acres at the center of the area (Bear Park) are excluded from the IRA due to a large timber sale and improved road. Undeveloped – Most of the area’s perimeter is accessible by road. The Yogo Creek Road, Dry Wolf Road, and Running Wolf Road parallel the southern, western, and northern boundaries. The Sage Creek Road provides road access from the east. Many primitive, unimproved travel routes are present in nearly all portions of the IRA. Opportunities for Solitude or Primitiveness – The Tollgate-Sheep area lacks solitude because of its limited size, irregular shape, and visibility to extensive ranching, farming, and rural civilization. Special Features and Values – The southeastern perimeter of the IRA is located adjacent to the Judith River Game Range. This state facility provides winter range to the Judith River elk herd. Other portions of the area along the eastern boundary include some elk winter range. The Bandbox area is locally noted for fossils. A portion of Bandbox Mountain contains a coral reef formation. Other special features located within the IRA include: Gibson Peak, Tucken Mountain, Woodhurst Mountain, Tollgate Mountain, and Bear Park. Manageability – The Tollgate-Sheep IRA is a contiguous but winding area. All but 200 acres are under federal jurisdiction, with private lands scattered throughout the unit. Most of the boundary does not follow distinct cultural or physical features. All portions of the IRA are located within several miles of a road or other primitive access route. Middle Fork Judith WSA The Middle Fork Judith WSA is located in the Little Belt Mountains of central Montana, approximately 25 miles southwest of Stanford and 25 miles northeast of White Sulphur Springs. Most of the study area is in Judith Basin County, although parts of the western edge are in Meagher and Cascade Counties. Originally composed of about 82,000 acres, it was later expanded to approximately 92,000 acres as a result of RARE II. The WSA is bordered by National Forest land. However, state and private lands are less than a mile from parts of the eastern boundary. The state land includes the Judith Game Range, which provides winter range for much of the elk herd found in the Middle Fork during the spring, summer, and fall. Wilderness Attributes Natural – The topography is gentle to moderate rolling, with open parks and stringer type meadows. The watershed condition within the study area is generally good. Compared to other areas in the Little Belt, portions of the Middle Fork Judith rate as average or below for apparent naturalness. Undeveloped – The Middle Fork Judith WSA contains 64 miles of primitive or low standard roads throughout the area. There are 1,154 acres of contiguous private land (multiple owners) in

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the middle of the study area. Three areas have been identified where human activities are readily apparent, including Yogo Creek where sapphire mining was active for many years. The study area also contains 75 miles of trails. Opportunities for Solitude or Primitiveness – Opportunities for solitude are available in the study area. However, these opportunities are impacted by the concentrations of people in the canyon areas, particularly in the Middle and Lost Forks. Additionally, Trail and 4-wheel drive vehicle use is extensive and extremely popular in the area. Special Features and Values – There are several special features located within the WSA including Grendah Mountain, Kelly Mountain, Woodchopper Ridge, Sand Point, numerous creeks, and the Middle Fork Ranch. In the eastern portion of the study area, narrow and picturesque limestone canyons provide a unique geologic feature that cannot be found in the immediate vicinity. Manageability – There are about 64 miles of road within the WSA. The southern and western boundaries of the study area are bordered by public roads. Another factor which limits the feasibility of managing this area as wilderness is the large private land inholding. Contiguous Unroaded Areas Contiguous unroaded areas are described as those National Forest lands located adjacent to designated IRAs, which have no permanent roads. Contiguous, unroaded areas within the project analysis area are narrow, are immediately adjacent to Forest roads, are less than ½ mile wide and therefore would not contribute to existing wilderness attributes associated with the IRAs. Proposed vegetation management activities within 150 feet of existing Forest roads are not expected to alter existing contributions of those lands to any “roadless expanse” that includes unroaded areas and adjacent contiguous inventoried roadless area.

Alternative 1 Effects There would be no vegetative treatments implemented to remove hazard trees under Alternative 1. As a result, the existing condition of wilderness attributes would remain unchanged by Forest Service management practices. Rather, nature itself would alter some of those existing characteristics as the dead trees begin to fall. Direct Effects Natural – Dead and dying trees would remain standing until natural conditions (moisture, wind events, etc.) felled the trees or they were removed by the public for firewood. The removal of hazard trees for firewood could result in several impacts including undesirable slash accumulations and illegal off-route travel. Undeveloped – Hazard trees would not be felled and removed from the IRAs and WSA. While this may contribute to unsafe conditions for public travel, it would not reduce the current undeveloped character of those areas. Rather, dead or otherwise hazardous trees would eventually blow over or snap off.

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Opportunities for Solitude or Primitiveness – There would be little impact to the opportunities for solitude or primitive recreation by retaining existing hazard trees along Forest roads in or adjacent to the IRAs and the WSA. However, some recreationists may choose not to recreate in or near areas with dead and dying trees where safety may be a concern. This would generally not affect those who choose to recreate within an IRA or WSA because those individuals normally attempt to get away from Forest roadsides. Special Features and Values – The retention of hazard trees along Forest roads within and adjacent to IRAs and the WSA would not impact special features and values related to wilderness characteristics. Manageability – Alternative 1 could slightly enhance this wilderness characteristic. As the hazard trees begin to fall naturally, they will temporarily serve as physical barriers to motorized incursions. This benefit would most likely be short-term because the down trees adjacent to Forest roads are usually removed for firewood. It’s also likely some individuals who gather firewood may drive off designated Forest Roads into the IRAs and the WSA to retrieve firewood. Indirect Effects Travel on some Forest road segments in or adjacent to the IRAs and WSA could become increasingly unsafe. If hazard trees are not cut they will eventually fall across the roads and possibly onto passenger vehicles. Forest visitors could be trapped behind roads that have been blocked by naturally falling hazard trees. Some hazard trees that fall naturally could land on visitors or vehicles in dispersed areas located adjacent to Forest roads. The presence of standing hazard trees could discourage visitor use until most of the trees fall naturally. Cumulative Effects There are no past, present, or reasonably foreseeable activities within the treatment analysis areas that would lead to cumulative effects regarding wilderness attributes of the IRAs and WSA.

Effects Common to Alternatives 2 and 3 Under the two action alternatives, some of the wilderness characteristics within the Inventoried Roadless Areas and Wilderness Study Area would be impacted. Specifically, the following three wilderness attributes could be affected, to a limited degree, through implementation of either action alternative: natural, undeveloped, and outstanding opportunities for solitude or primitive unconfined recreation. The extent of those impacts would be greater under the proposed action (Alternative 2) due to the increased number of hazard trees removed.

Alternative 2 Direct and Indirect Effects Under Alternative 2, identified trees within 1½ tree-lengths would be removed from IRAs and felled and left within the Middle Fork Judith WSA. There are approximately 27 miles of National Forest roads within the nine IRAs. In most cases those roads are located adjacent to or weave along the edge of IRA boundaries. Although it’s likely the roads were meant to serve as the IRA boundary, maps have never been revised to reflect that discrepancy.

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There are about 64 miles of road within the Middle Fork Judith Wilderness Study Area. Similar to the other IRAs, most of the roads are located adjacent to or weave along the edge of the WSA boundary. The removal of designated hazard trees along Forest roads would enhance public safety. Currently, individuals who travel those roads face the potential of hazard trees falling across the roads or possibly their vehicles. The impact of implementing this alternative would depend greatly on the number of hazard trees on-site within the IRAs and the WSA. Most of the existing hazard trees are lodgepole pine, heavily impacted by the mountain pine beetle. While other tree species may also be designated as hazard trees, it appears the lodgepole pine stands would be the stands primarily impacted by proposed action. Currently, there are a minimal number of roads in the IRAs and WSA with a predominant component of adjacent lodgepole pine stands. In some areas the removal of hazard trees could result in large openings next to Forest roads. In other locations, there may be fewer hazard trees, which would result in a more natural setting. Implementation of Alternative 2 would result in the felling and, in the IRAs, removal of more hazard trees than Alternative 3. As a result, there would be slightly greater impacts to existing wilderness characteristics under Alternative 2. Direct Effects Natural – The felling, and removal within IRAs, of hazard trees could slightly degrade the natural character of the IRAs and WSA. This impact would be minimal because the treatments would only occur within 150 feet on either side of the roads. Further, proposed management activities may be less of an impact to the natural character than the presence of the roads themselves, which are located within or adjacent to the IRAs and WSA. The removal of hazard trees would initially create stumps and slash within 1½ tree-lengths of Forest roads. The landing areas where slash had been piled and chipped, removed, or burned would also appear unnatural for a period of about five years until new vegetation covers the landscape. Undeveloped – Alternative 2 would only slightly impact the undeveloped character of the IRAs and WSA. That impact would be restricted to those road segments which contain hazard trees located within 1½ tree-lengths from either side of the road. There would be no impact to the undeveloped character of the IRAs or WSA where there are no roads present. The existence of the roads themselves may have a greater impact on the undeveloped character than the removal of adjacent hazard trees. Opportunities for Solitude or Primitiveness – Alternative 2 would allow for greater sight distance from Forest roads into the IRAs and WSA. It might also allow noise to carry further into those areas than if the hazard trees remained standing. Both of these factors could slightly reduce the subjective value of solitude. However, hazard trees are not anticipated to remain standing long- term (greater than 15 years) as they would fall naturally. The undergrowth would begin to mature after the hazard trees have been removed and would eventually create a new over-story providing some level of sight and sound barrier into the IRAs and WSA. The removal of hazard trees would not affect primitive or unconfined recreation because those opportunities are generally provided within the interior of the IRAs, not along the outer boundaries adjacent to roads.

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Special Features and Values – There are no unique geological, biological, ecological, scenic, or cultural features adjacent to roads within the IRAs or WSA that would be impacted through the removal of hazard trees. Manageability – The removal of hazard trees along Forest roads would not result in changing any IRA or WSA boundaries. However, hazard tree removal could result in increased off-route vehicle violations because some areas adjacent to Forest roads would become more open. Indirect Effects The felling, and removal within IRAs, of hazard trees would reduce the opportunity to gather firewood along some Forest roads in IRAs and the WSA. Roads located closest to communities are those which normally receive the greatest amount of firewood cutting. Temporary landings used for storing logs and removing limbs would be impacted to a greater extent (soils and vegetation). As a result, the landings within IRAs and the WSA may take longer to naturalize than areas where only hazard tree cutting occurred. During those periods when felling, and removal within IRAs, occur opportunities for dispersed recreation (hiking, hunting, fishing, etc.) would be impacted. This would be a short-term impact that would only last until the trees were felled and removed. Some visitors would be displaced to other areas until treatment activities were completed. To ensure safety, some forest visitors may prefer to recreate in areas where hazard trees have been removed. The cutting and removal within IRAs of hazard trees along some road segments may enhance opportunities for dispersed recreation, especially camping. Irreversible or Irretrievable Commitments for Alternatives 2 and 3 There would be no irreversible or irretrievable commitments with either of the two action alternatives because new trees and other vegetation would grow in those areas where hazard trees had been removed.

Alternative 3 Direct and Indirect Effects Under Alternative 3, there would be fewer hazard trees removed (by definition) than under the proposed action. Implementation of this alternative would reduce the impact to existing wilderness characteristics as compared with Alternative 2. Direct Effects Natural & Undeveloped – Impacts to the naturalness and undeveloped character of the IRAs and WSA would be similar as described under Alternative 2 but comparatively less. There would be fewer stumps and less slash created due to the reduction in hazard trees removed. Opportunities for Solitude or Primitiveness – Alternative 3 would diminish visual and sound screens to a lesser extent than Alternative 2. Impacts would be short-term and minimal because the trees would fall eventually.

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Special Features and Values – Although there would be a reduced number of hazard trees felled, and removed within IRAs, under Alternative 3, there would be no effect upon this wilderness characteristic. Manageability – Although there would be a reduced number of hazard trees felled, and removed within IRAs, under Alternative 3 there would be no effect upon this wilderness characteristic. Indirect Effects Because there would be fewer hazard trees felled under Alternative 3, there would be an increased opportunity for individuals to gather firewood along some Forest roads in IRAs and the WSA as compared with Alternative 2. Impacts associated with hazard tree felling, and removal within IRAs, to the recreating public would be very similar to Alternative 2. During those periods of management activity, opportunities for dispersed recreation (hiking, hunting, fishing, etc.) would be impacted. This would be a short-term impact that would only be in effect until the trees were felled, and removed within IRAs. Some visitors could be displaced to other areas until treatment activities were completed. Because fewer hazard trees would be felled under Alternative 3, there would most likely be more hazard trees to remove in the future. This could result in the need for future examination of another larger scale hazard tree removal exercise if the hazard trees that occur in the future exceed the forest’s in-house capacity to mitigate. Any future large scale treatment would undergo environmental analysis. Additionally, trees which are dying or structurally unsound and not currently considered hazardous under Alternative 3 may present a safety hazard within the near future.

Cumulative Effects of Alternatives 2 and 3 Cumulative effects within the area include past, present, and reasonably foreseeable actions. The cumulative effects analysis boundaries used are the same as those identified for the Inventoried Roadless Areas and the Middle Fork Judith Wilderness Study Act Area. The project would remove hazard trees, as defined by alternative, to ensure public safety. The number of hazard trees could greatly expand within the next 5 to 10 years depending upon forest health. Lodgepole pine trees are currently the predominate species affected. The removal of hazard trees along Forest roads within IRAs on the Lewis & Clark Forest and other National Forests in Montana could cumulatively impact several wilderness attributes over a larger landscape. Hazard trees are expected to fall naturally within the next 15 years if they are not felled mechanically. This project would safely facilitate the removal of hazard trees within the short-term. Other activities within the analysis area which may contribute to a cumulative impact include travel planning, timber harvest, fuel treatments, grazing authorizations, motorized recreation, personal use firewood cutting, wildfires, and wildfire suppression. Past management activities within the WSA include about 42 acres of fuel treatments (slash piling and burning). Past management activities within the IRAs include approximately: 38 acres of sanitation (salvage) harvest in the North Fork Smith; 318 acres of commercial thinning in Paine Gulch; 13 acres of

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sanitation harvest in the Spring Creek; 113 acres of commercial thinning in Tollgate-Sheep; 7 acres of single tree harvest in Tollgate-Sheep; and 7 acres of sanitation harvest in Tollgate- Sheep. Proposed activities under each action alternative when considered in conjunction with previous management and ongoing activities would not cumulatively affect wilderness attributes in the long-term. Noxious Weeds The Noxious Weed inventory of the Lewis and Clark National Forest and the Natural Resource Information System databases, FSM 2900 and 2000 Supplement R-1 2000-2001-1, along with site visits were used for this analysis. The presence of noxious weeds at the proposed sites for hazard tree removal is substantial. Livestock, wildlife, recreation use, vegetation treatments, and road construction and maintenance are all agents in the spread of noxious weeds. Invasive Species known to occur within the project include leafy spurge, spotted knapweed, hounds tongue, oxeye daisy and Canada thistle. There are approximately 4,615 total inventoried acres of Noxious Weeds within the analysis area. Leafy spurge is currently treated using biological and chemical control methods. Spotted knapweed, houndstongue, oxeye daisy and Canada thistle are treated using chemical and mechanical control methods. Control methods used are outlined in the Lewis and Clark National Forest Noxious Weed EIS, May 1994. Invasive species have a high probability of invading soils that have been disturbed. Invasive weed seeds can be dispersed from vehicles (e.g., graders, dozers, passenger vehicles, mountain bikes, ATVs, etc) traveling along roads and within these disturbed areas. Noxious weeds are found at a number of proposed treatment sites and along proposed haul routes to the sites. Noxious weed species of greatest concern include knapweed and leafy spurge. These two species are able to exploit soils exposed by logging operations and burning. Leafy spurge (Euphorbia esula) is a deep rooted, long lived perennial that is difficult to control (Lym 1991). It spreads by both seeds and roots and can occupy flood plains to ridges to mountain slopes (Goodwin et al, 2006). Soil disturbance promotes the establishment of leafy spurge (Lym 1991). After leafy spurge invasion, plant species richness decreases often to only other introduced Eurasian species such as smooth brome and Kentucky bluegrass. Similar to spotted knapweed, bare soil can increase and kinds and amounts of roots shift to those of the dominant invader. Following BMPs for noxious weeds (FSM 2000 Supplement R-1, 2000-2001- 1) and herbicide control can be effective in slowing the spread of spotted knapweed and leafy spurge but the risk of noxious weed spread increases when known populations are within or adjacent to planned disturbance. Noxious weed establishment can lead to physical, chemical and biological changes in soils. Heavy invasions of spotted knapweed (Centaurea maculosa) can become nearly monocultures with allelopathic effects on native vegetation (LeJeune and Seastedt 2001). Bare soil amounts can increase, kinds and amounts of roots shift to those of the dominant invader and nutrient balances (specifically phosphorus) are altered. Impacts to soils appear to increase as the degree of spotted knapweed establishment increases. Integrated weed management is a systematic approach to noxious weed control and involves various methods such as education, prevention, biological control, cultural methods, herbicides

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or mechanical methods to contain or control noxious weeds. Noxious weed infestations would be managed using the most effective combination of strategies available (see Resource Protection Measures above). Prompt re-vegetation of disturbed areas is key preventing noxious weed establishment. Obliterating existing non-system and new temp roads will help reduce the spread of noxious weeds in those areas. Weed monitoring within the project area presently includes: mapping all infestations, documentation of all chemical and biological control applications, annual reports of mechanical, chemical and biological control used, follow-up inspections of bio- control sites, and effectiveness evaluations of chemical treatments.

Alternative 1 Effects Direct and Indirect Effects Invasive plant species known to occur within the project area include leafy spurge, spotted knapweed, hounds tongue, oxeye daisy, and Canada thistle. In the absence of disturbance under this alternative, weed populations are expected to remain fairly constant. Populations would continue to persist along roads where they could provide a seed bank and a means for additional seed spread. Known and discovered infestations of invasive species would continue to receive treatment under this alternative. Existing noxious weed prevention, control, and monitoring activities would continue. New infestations within the proposed project area would continue to receive treatment upon discovery. Cumulative Effects There are no new effects to noxious weeds under Alternative 1 and therefore no cumulative effects.

Alternative 2 Direct and Indirect Effects Due to the implementation of noxious weed BMPs and the revegetation of disturbed areas, and the ongoing noxious weed control program, it is anticipated that the overall acreage of noxious weed infestation would remain fairly static. The invasive species infestation rate is related to the amount of acres disturbed through proposed vegetation treatments and their proximity to existing noxious weed populations. There may be an initial increase in the amount of noxious weed infestations within the project area. Monitoring the area for at least three consecutive years following treatment would provide for early detection and control of new infestations. Prescribed noxious weed prevention, control, and monitoring activities would effectively reduce and mitigate any effects. New infestations within the proposed treatment areas may cause an initial decrease in grasses and forbs, but with early detection and control this loss would recover over time and the grasses and forbs would return to normal levels. Proposed BMPs have been shown to be responsive as reflected in the 2008 Forestry BMP Audit Report by the Department of Natural Resource filed in the project record (Montana DNRC, 2008).

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Alternative 3 Direct and Indirect Effects The effects of Alternative 3 are very similar to Alternative 2. Due to fewer trees being removed under Alternative 3, there would be less soil disturbed and consequently, less opportunity for invasion. Following direction contained in FSM 2900 and FSM 2000 Supplement R-1 2000- 2001-1 would limit the likelihood of invasive species spread in the project area. Monitoring the area for at least three consecutive years following treatment would provide for early detection and control of new infestations. Prescribed noxious weed prevention, control, and monitoring activities would effectively reduce and mitigate any effects. New infestations within the proposed treatment areas may cause an initial decrease in grasses and forbs, but with early detection and control this loss would recover over time and the grasses and forbs would return to normal levels.

Cumulative Effects of Alternatives 2 and 3 Cumulative effects for both action alternatives were analyzed together because activities and impacts would be very similar but at a slightly different scale across the project area. The risk of weed spread by domestic livestock is only marginally greater than the no action alternative because wildlife and permitted domestic livestock grazing presently occurs in the analysis area and it is likely that it will continue. There is a risk that areas disturbed by the project could become infested by wildlife and domestic livestock dropping seeds in feces and from their coats. The risk from this would be only marginally greater than under Alternative 1. Monitoring of the project area and treatment of any noxious weed infestations discovered would reduce any long term negative impacts from noxious weeds. The risk of increasing the overall extent of weed infestation has been mitigated to a very low level. Numerous authorized roads and trails currently exist within the analysis area. There are also incidences of user created, unauthorized travel ways. Disturbance created by road and trail use, motorized recreation, personal use firewood cutting, and road and trail maintenance activities carries a risk of introducing noxious weeds due to bare soil, providing an establishment point for invaders. Resource protection measures such as washing of maintenance equipment, prompt successful re-vegetation, and monitoring of disturbed sites for invasive establishment mitigate this risk. Prescribed fire and wildfire both contribute to the spread of noxious weeds through exposure of soil. This may be especially noteworthy if revegetation by desirable species is not achieved promptly. Bare soil may also be created with suppression and management actions necessary for fire management. There exists a great many dispersed camping sites throughout the project area. Recreational activities contribute to the spread of noxious weed through the creation of disturbed soil and transport and dispersion of seeds. Motorized use by off road vehicles and mountain bikes either spread or have the potential to spread weeds into uninfected areas, along with causing soil disturbance and reinvasion of previously treated sites. Implementation of weed BMPS would ensure that the overall acreage of noxious weed infestation would remain fairly static. Additionally, monitoring of any disturbed areas and treatment of any noxious weed

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infestations discovered would further reduce any long term negative impacts from noxious weeds.

Conclusions for Alternatives 2 and 3 By implementing the resource protection measures above and following the direction in FSM 2900 and FSM 2000 Supplement R-1 2000-2001-1, noxious weed impacts would be minimized, the overall acreage of noxious weed infestation would remain fairly static, and Forest Plan Standards met. Hazard tree removal within and adjacent to identified recreation and special use sites, and along selected roads in the Little Belt Mountains range of the Lewis and Clark National Forest would impact noxious weed infestations through vegetation removal, noxious weed seed transport, and bare or disturbed soils. Many sites have a substantial amount of existing noxious weed presence on site or adjacent to and impacts that create bare soil increase the likelihood of non-native vegetation establishment. Both action alternatives mitigate this risk and provide for monitoring to address long-term impacts. Recreation

Alternative 1 Effects Direct and Indirect Effects If Alternative 1 is selected, then no immediate hazard tree removal would be implemented. Without the use of commercial removal to address the large scale hazard tree situation, the forest would examine incremental removal using FS employees as time and funding allow, and as hazard levels mandate. Forest user safety in and near recreation sites and on and near roads would more slowly be addressed because FS employees have limited capacity to identify and fell hazard trees. Road and recreation site closures would need to be considered as hazards were identified. The incremental removal of hazard trees under the no action approach would be more costly in the long-term and result in the closure of more sites for a longer period of time. There would be two notable effects associated with the closure of developed recreation sites: 1) Forest visitors that wish to camp or recreate in a site closed to use would be displaced to other areas on the Forest; and 2) If the closed campgrounds are also fee sites, there would be a corresponding loss of revenue. Furthermore, hazard trees which fall could result in personal injury or damage to vehicles, camping equipment, and facilities such as toilets, picnic tables, water systems, signs, and bulletin boards. Firewood gathering would continue as currently exists across the Lewis and Clark National Forest. The growing number of dead trees adjacent to Forest roads would provide many opportunities for cutting firewood. However, there could be negative impacts associated with the removal of numerous hazard trees by the public along Forest roads including: Travel along popular Forest roads may present unreasonable safety risks because dead and dying trees could fall on roads or vehicles;

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Many dispersed campsites and parking areas adjacent to Forest roads contain hazardous trees, which would represent an increased safety concern; Removal of easily accessible firewood along Forest roads results in illegal off road travel that leads to additional unauthorized spurs in the Forest, which would occur more frequently under Alternative 1; Public firewood cutting in large quantities along Forest roads often results in a greater accumulation of slash, which if not properly disposed of and left along the road way creates an additional hazard; and Dead trees falling on and adjacent to Forest roads would result in additional maintenance needs for those roads in clean up and possible damage to the road bed, culverts, and bridges. Cumulative Effects There are no past, present, or reasonably foreseeable activities within the treatment analysis areas that would lead to cumulative effects regarding recreation under Alternative 1.

Alternative 2 Effects Direct and Indirect Effects Alternative 2 would provide for safer recreation and roadside areas in the Little Belt Mountains. Hazard removal would be uniform and timely, and recreation staff would be more available for required tasks associated with developed sites as compared with Alternative 1. It’s worth noting that spring campground openings could still be delayed even with implementation of the proposed action because not all hazard trees would be able to be addressed at once. Hiring contract fallers and mechanized equipment for tree removal is also more cost effective and ensures a consistent and coordinated implementation of hazard tree removal. This is beneficial to recreational resources because it lessens the impact to Forest users. Given these benefits, Alternative 2 would create a few additional impacts, which are detailed below. Removal of vegetative cover may make recreation (dispersed and developed) sites less desirable, which could result in displacement to other areas where live trees remain. Accumulated slash could cover existing dispersed recreation sites making some of them difficult to identify. Dispersed recreation sites would be temporarily unavailable for recreation use while harvest activities are occurring. Timber hauling on some Forest roads would temporarily increase traffic and may affect the recreation experience for some.

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Trees serving as assurance markers could be cut down and informational signage could potentially be knocked down or destroyed, which would need to be reinstalled prior to the use season. Removal of hazard trees in a few locations may affect snow accumulations and drifting patterns on roads which also serve as snowmobile trails. Hazard tree removal along Forest roads could facilitate development of new dispersed sites by the public. These impacts are minimal in scope and are therefore not significant to recreation opportunities in the Little Belt. It’s also possible that the removal of hazard trees and opening campsites to additional sunshine could attract visitors who seek more light or warmth, which may be especially important during the cooler and colder camping months. This may also open up the campsite for viewing the surrounding countryside, which may have a positive visual effect for some users. It is also expected in the long-term that additional and accelerated growth of understory vegetation would result from removal of the overstory. Hazard tree removal along roads would reduce available firewood opportunities along these routes. However, given the wide-spread nature of the beetle epidemic, it is unlikely there would be any difficulty in finding available firewood. Because trees would be removed along Forest roads and adjacent to existing gate closures, motorized access to those areas may no longer be physically restricted. Indirectly, the cutting and removal of hazard trees could result in additional motorized impacts due to unauthorized access around gates and violations adjacent to Forest roads and existing closure gates. Areas used for landings along road sides which may be conducive also for dispersed camping may temporarily be unavailable for use as dispersed sites. Truck traffic for log hauling and the associated dust and noise may be an inconvenience and potential safety hazard to Forest visitors. Some recreationists may choose to avoid roads with large numbers of logging trucks. If log hauling is conducted during the winter months the truck traffic could prohibit and displace visitors from using the same travel routes. In addition, if log hauling occurred on Forest roads which are also designated as groomed snowmobile trails it would restrict snowmobile travel during periods of hauling and be a displacement to area snowmobilers. Log hauling could also impact residential traffic. However, access and traffic effects would be short-term in impact and would be minimized by resource protection measures outlined above. Finally, hazard tree removal along roads which also serve as groomed snowmobile trails may present some additional safety hazards. Stumps, especially those that may be greater than 6-8” in height, and slash piles which protrude through the snow could become obstructions along or adjacent to groomed snowmobile routes during the winter months. Cumulative Effects The removal of hazardous trees within and around developed and administrative sites is occurring on all National Forests in Region One. Developed sites which undergo large scale

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hazard tree removal may no longer provide the shade and screening desired by many. As a result, National Forests in western Montana may not be able to provide as many campsites in mature lodgepole pine stands. Carbaryl applications in recreation sites would temporally close some campgrounds during the seasonal use period. These closures could coincide with hazard tree removal in developed sites, which would also close some recreation sites during implementation. Cumulatively, this could further limit available recreation sites and displace users to other parts of the Forest. Commercial timber removal projects such as Ettien Ridge and Blankenship would cumulatively add additional traffic to specific routes thus increasing noise, dust, and impacts to residential traffic.

Alternative 3 Effects Direct and Indirect Effects Direct and indirect effects of this alternative would be similar to Alternative 2. Recreation experiences at some developed and dispersed sites would be impacted through the removal of hazardous trees as proposed in this alternative. It’s worth noting that spring campground openings could still be delayed because not all hazard trees would be able to be addressed at once. Although the sites would be safer for public use, the loss of vegetative cover may detract from the recreation experience. The removal of trees from developed recreation sites could affect the recreation experience for visitors until vegetative cover and screening is re-established. Existing users may be displaced to areas where trees have not been removed. The extent of public displacement may be dependent upon the number of trees removed. Areas that might be used for landing sites which are also conducive for dispersed camping sites would be temporarily unavailable for dispersed camping use. More encouragement for off route travel may result due to fewer trees remaining on the landscape. This alternative would encourage and may increase dispersed camping and off road driving in some areas that are opened up and have less tree cover. Log hauling associated with commercial timber harvest would still have the potential to affect recreation opportunities and experiences but to a lesser extent due to fewer hazard trees being removed and hauled from the landscape when compared to Alternative 2. Additionally depending on allowed log hauling dates and time of day the resource protection measures would lessen the potential affects to recreationists especially during high use periods such as snowmobile and hunting seasons. This alternative would not address hazardous trees with obvious indicators of decline, decay and injury that may in the future fall on facilities, public users, and other infrastructure. Removal of hazardous trees not identified for cutting in this alternative at dispersed and developed sites and other recreation sites would have to be conducted by Forest Service crews on a yearly basis prior to opening these sites for public use, which may cause a delay in opening for public use.

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It’s also possible that the removal of hazard trees and opening campsites to additional sunshine could attract visitors who seek more light or warmth, which may be especially important during the cooler and colder camping months. This may also open up the campsite for viewing the surrounding countryside, which may have a positive visual effect for some users. It is also expected in the long-term that additional and accelerated growth of understory vegetation would result from removal of the over-story. Cumulative Effects Cumulative effects would be similar under Alternative 3 to those described under Alternative 2. Because Alternative 3 would remove fewer trees than Alternative 2, cumulative impacts to campsites in mature lodgepole pine stands would be less by comparison. Cumulative impacts from Carbaryl applications and commercial timber removal projects would be the same as those described under Alternative 2. Research Natural Areas Research Natural Areas (RNAs) in the Little Belt Mountains are experiencing tree mortality as a result of an on-going mountain pine beetle epidemic. The analysis area for this project will be the RNAs that intersect proposed treatment areas. The RNAs to be analyzed are O’Brien Creek and Onion Park. The Paine Gulch RNA intersects about 0.01 acre of a proposed treatment area. Based on aerial photography, the RNA consists primarily of wet meadow with two trees at this intersection. The Paine Gulch RNA is not included in this analysis given the small area of impact (0.01 acres), dominant vegetation type (wet meadow), and distance of trees from the road edge (~150 feet). RNAs are special management areas set aside for non-manipulative research, observation, and study due to their unique or undisturbed habitat type or aquatic ecosystems. Based on the regulatory framework described above, the analysis will discuss effects of proposed alternatives to RNA objectives, purpose, natural conditions, and ecological processes.

O’Brien Creek RNA According to the O’Brien Creek RNA Establishment Record (USDA Forest Service 1994c): The purpose in designating O’Brien Creek RNA is to provide a reference location and protection for a relatively undisturbed segment of a subalpine stream basin and associated willow and wet meadow vegetation in the riparian zone. Drummond willow dominated communities are a common riparian type at mid- to upper elevations in the Little Belt Mountains. Wet meadow communities bordering moderate gradient streams are also common, but typically have been altered by grazing. There are few reference locations in the mountains of central Montana available for studying the effects of livestock grazing on the ecotone between willow and wet meadow communities and associated streambanks. O’Brien Creek RNA provides an example of this situation. The objective of O’Brien Creek RNA will be to maintain and protect the riparian and upland vegetation, the stream channel processes, and other natural features and processes for the purposes of non-manipulative research, and ecological

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comparison and monitoring, consistent with the requirements for management of the Neihart domestic watershed (USDA Forest Service 1994c). O’Brien Creek RNA is located at the head of O’Brien Creek (Sec 29 and 30, T13N, R7E) and is 715 acres in size. Forest road 839 (Divide Road) bounds the southern edge and road 6377 (Log Spur Divide 7) the southern portion of the western edge (see Appendix A). The O’Brien Creek drainage has served as a municipal watershed for the Neihart area since 1891. Because of this status, the watershed received special management and protection which was not afforded to other similar drainages on the Forest. The O’Brien Creek RNA is an important ecological reference point for riparian vegetation communities, stream channel conditions, and water quality. It is particularly useful as a comparison with riparian areas which have had a long history of grazing impacts. Drummond’s willow habitat type dominates riparian communities, while the tufted hairgrass-sedge habitat type dominates wet meadows. Pink agoseris and longstyle thistle, sensitive plant species no longer designated for the Lewis and Clark National Forest, occur in the RNA. Forested sections (approximately 76% of the RNA) are represented by subalpine fir habitat types. An Engelmann spruce and subalpine fir forest cover type dominate the headwater region of O’Brien Creek while a lodgepole pine forest cover type dominates the remaining forested areas. At the time of establishment, some lodgepole stands were becoming decadent and no insect conditions were noted. Fifteen acres of lodgepole regenerated clearcuts from 1955 and about 5 acres of historic firewood cutting are within the RNA’s boundaries (USDA Forest Service 1994c). The Forest Service Activity Tracking System (FACTS) and associated geographic information system layer indicate that approximately 40 acres of regenerated clearcuts are present along the RNA boundary.

Onion Park RNA According to the Onion Park RNA Establishment Record (USDA Forest Service 1994d): The primary objective of establishing Onion Park RNA is to maintain the terrestrial and aquatic features of the site in an undisturbed (by humans) condition, for the purposes of non-manipulative scientific research and observation. The primary features are representative examples of minimally disturbed subalpine meadow and adjacent forest types typical of the Little Belt Mountains. The site will allow for the long-term monitoring of ecological processes such as plant succession and stream dynamics. Baseline information collected within the RNA may be useful to assess the effectiveness of management activities performed on similar sites. For example, riparian and grassland communities ungrazed by livestock within the RNA will allow comparisons with similar communities subject to grazing outside the RNA (USDA Forest Service 1994d). Onion Park RNA is located within the Tenderfoot Creek Experimental Forest (Sec 4, 8, and 9, T13N, R7E) and is 1,209 acres in size. Forest road 586 (Williams Park) bisects the RNA, and road 840 (Tenderfoot Creek) (0.28 miles) branches off the main road in the center of the RNA (see Appendix B). Land within the RNA was previously part of the Tenderfoot Creek Experimental Forest, which was established to study hydrologic and soil responses to timber management in the lodgepole pine zone. Because Onion Park did not have a paired watershed

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within the Experimental Forest due to its large meadow acreage, it was moved into the RNA network (USDA Forest Service 1994a). Onion Park provides an ungrazed reference area to compare floristic composition of other meadows (parks) nearby, which have historically been grazed by sheep (USDA Forest Service 1994b). The principle features of the Onion Park RNA are a subalpine mesic meadow (tufted hairgrass-sedge habitat type) and adjacent subalpine fir habitat type (subalpine fir/grouse whortleberry and subalpine fir/bluejoint reedgrass) forests dominated by a lodgepole pine forest cover type. The eastern side of the RNA contains more overstory species diversity than the western side, which is almost pure lodgepole pine. Understory regeneration is primarily subalpine fir and Engelmann spruce. The mesic meadow contains three species of onion (Allium) and three species of agoseris, including pink agoseris, which at the time of establishment was a designated sensitive plant species on the Lewis and Clark National Forest. The RNA also contains a forested scree community on Quartzite Ridge, a Type 2 stream (Tenderfoot Creek), several beaver ponds, and riparian communities dominated by Drummond’s and yellow willow. Some firewood cutting had occurred in the area prior to establishment (USDA Forest Service 1994d). The Forest Service Activity Tracking System (FACTS) and associated geographic information system layer indicate that approximately 18 acres of regenerated clearcuts are present along the RNA boundary.

Joint Management On August 26, 2010, representatives from the Lewis and Clark National Forest (Forest Silviculturist/RNA Coordinator), Regional Office (Regional Botanist/Invasive Species Coordinator/RNA Coordinator), and Rocky Mountain Research Station (RMRS Liaison for Region 1 RNAs) completed a field visit of O’Brien Creek and Onion Park RNAs as part of a larger field review to address issues related to RNA designation and management on the Lewis and Clark National Forest. Mountain pine beetle-caused lodgepole pine mortality was noted in the RNAs during this review. Dialogue was initiated on this date concerning potential hazard tree removal options within road corridors (Forest roads 839, 840, and 586) associated with the O’Brien Creek and Onion Park RNAs (USDA Forest Service 2011). The RMRS RNA Liaison and Scientist-in-Charge of the Tenderfoot Creek Experimental Forest provided suggested project design features in an October 14, 2010, letter (USDA Rocky Mountain Research Station 2010). This letter stated “[t]hough FS 4063.3(2) specifically states that logging is not permitted within RNAs, we agree with NF personnel that public safety along the RNA road corridors is of higher importance, so some form of mitigation of hazardous trees is appropriate” (USDA Rocky Mountain Research Station 2010). After further phone discussion, the Lewis and Clark Forest Supervisor issued a letter containing agreed upon mitigation measures for activities within the RNAs (USDA Forest Service 2010). To comply with FSM 4063.04b, the Forest will write a project-specific management plan for both RNAs prior to project implementation to be approved by the Lewis and Clark Forest Supervisor and RMRS Station Director.

Alternative 1 Effects Direct and Indirect Effects No management actions would occur within the RNAs under Alternative 1. Current vegetation conditions would be modified through natural succession and disturbance factors. The

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objectives, purpose, natural conditions, and ecological processes for which the O’Brien Creek and Onion Park RNAs were established would remain unaltered by management activities. Cumulative Effects Implementation of Alternative 1 would not impact the objectives, purpose, natural condition, or ecological processes for which the O’Brien Creek and Onion Park RNAs were established. Therefore, there would be no cumulative effects between this project and those listed in the Project Record.

Alternative 2 Effects Direct and Indirect Effects Hazard tree identification within the RNAs would be a coordinated effort between the Lewis and Clark National Forest (RNA Coordinator and timber layout crew) and the Rocky Mountain Research Station (RNA Liaison or representative). Trees would be individually evaluated for removal potential considering the alternative’s hazard tree definition and the RNA’s objectives and purpose. Tree felling, therefore, would be on a more restrictive basis than on other portions of the project to meet the need for public safety while maintaining the RNA management standard of “maintenance of natural conditions and processes” (USDA Forest Service 2005 – FSM 4063.3(1)). Hazard trees would be manually felled and left on-site with no branch lopping, bole removal, or slash management (USDA Rocky Mountain Research Station 2010). Within the O’Brien Creek RNA, lodgepole pine and Engelmann spruce greater than five inches diameter are dominant on approximately five and six acres, respectively, of the potential treatment area (1.5% of the RNA acres). The remaining eight acres are composed of lodgepole pine less than five inches diameter (regenerated clearcut) and meadow. The potential treatment area in Onion Park consists of approximately twelve acres of Engelmann spruce and 47 acres of lodgepole pine greater than five inches diameter (4.9% of the RNA acres) and nine acres of wet meadow. The occurrence of trees meeting the hazard tree definition, due primarily from mountain pine beetle-caused tree mortality, would be greatest within the lodgepole pine dominated areas covering roughly 52 acres in both RNAs. However, because lodgepole pine also occurs in spruce dominated areas, tree felling at a lower rate can be expected on an additional 18 acres. Treatment of forested areas in the O’Brien Creek RNA would not substantially alter natural conditions or ecological processes in the stream basin since tree felling would be limited to the road corridor which forms the southern boundary (see Appendix A). O’Brien Creek’s forested stands are also composed of multiple tree species which produce conditions less susceptible to mountain pine beetle, the primary agent for creating hazard trees. Although Alternative 2’s hazard tree definition includes a variety of conditions that would trigger tree felling, forest conditions indicate that a small quantity of trees would be felled. Felling and leaving intact trees on-site mimics natural tree fall, but at an accelerated rate. Therefore, it is possible for more logs to be present in the road corridor at one time than would naturally occur. As directed in FSM 4063.2(2), signs prohibiting firewood collection in the RNA would be posted and maintained. The interior of the RNA containing the features and processes for which the RNA was established would remain unmodified, and tree felling in the road corridor should not detract from the area’s naturalness.

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Unlike O’Brien Creek, Onion Park RNA is dominated by mountain pine beetle-susceptible lodgepole pine stands. Forest stands in the eastern side of the RNA have a mix of species which would ensure that forest cover remains on-site after treatment. The western side of the RNA, however, is composed of pure lodgepole pine. Given the current species composition, stand structure, and windthrow susceptibility, there is a potential for this section of road corridor to be clearcut. Actual tree felling intensity would be determined by the level of mountain pine beetle- caused tree mortality at the time of project implementation. Felled trees would mimic natural tree fall following mountain pine beetle, but at an accelerated rate. As directed in FSM 4063.2(2), signs prohibiting firewood collection in the RNA would be posted and maintained. The presence of cut stumps would detract slightly from the RNA’s naturalness along the road corridor, but lodgepole pine regeneration would rapidly conceal evidence of human activities. Natural disturbance events, such as the mountain pine beetle epidemic and windthrow, in the subalpine fir habitat types represented in Onion Park would create growing space and conditions appropriate for lodgepole pine establishment and growth. Plant succession noted under natural conditions would also occur following the proposed alternative; therefore, this ecological process would not be impacted. Because hazard tree felling is limited to forested areas and because there would be no equipment or ground disturbance within the streamside management zone, implementation of this alternative would not alter O’Brien Creek’s riparian vegetation communities (willow community and wet meadows), stream channel conditions, or water quality. Proposed treatment in the Onion Park RNA would not occur in Onion Park proper; therefore, there would be no effect to the natural conditions or ecological processes associated with the meadow. Streamside management zones within potential treatment areas (i.e. forest stands adjacent to stream channels or wet meadows) total about 0.35 and 2.5 acres, respectively, for the O’Brien Creek and Onion Park RNAs. According to the Forest Hydrologist, the proposed treatment would produce non-detectible changes to water quality (Green pers. comm. 2013). Natural conditions and ecological processes for which the RNAs were established would remain essentially intact for the non-forested areas. Onion Parks’ primary feature of minimally disturbed forest adjacent to a subalpine meadow would be slightly impacted with potential tree felling adjacent to about one-quarter of the meadow. However, selective hazard tree designation with the RNA’s objectives and purpose in mind would limit potential impacts. The interior of both RNAs will be essentially unmodified due to treatments that only occur in the road corridors and resource protection measures coordinated with the Research Station. No adverse direct or indirect effects to natural conditions or processes would be expected in either RNA. Cumulative Effects The Establishment Record for each RNA (USDA Forest Service 1994c; USDA Forest Service 1994d) describes resource conditions at the time of establishment. Past activities present within each RNA are described below. No current or reasonably foreseeable activities are proposed for the RNAs. There is a potential for wildfire to occur within the RNAs in the future. However, the effects of a fire on all or part of the RNAs are difficult to determine at this time. If “catastrophic circumstances significantly alter the conditions for which a Research Natural Area was originally created such that it no longer may serve that function, the designation” as an RNA may be removed (USDA Forest Service 2005 – FSM 4063.03).

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O’Brien Creek RNA Forest Road 839 and 6377 – Based on the Little Belt, Castle, and North Half Crazy Mountains Travel Management Plan Record of Decision (USDA Forest Service 2007), these roads are open yearlong to highway vehicles with snowmobile access between December 1 and May 15. These roads were in existence at the time the RNA was established and do not negatively impact the RNA’s objectives or purpose. No additional road or trail construction are permitted within the RNA. Powerline – An 80-foot wide cleared easement for a powerline exists along the northeast boundary of the RNA. The Establishment Record (USDA Forest Service 1994c) noted that “[u]nless additional easement is granted or the existing widened, this should have no effect on the management objectives or natural features of the RNA.” Timber Harvest – Approximately 40 acres of stand clearcut were completed between 1950 and 1970. All of the acres have naturally regenerated to lodgepole. The Establishment Record (USDA Forest Service 1994c) noted that clearcuts were present and “surrounded by oldgrowth subalpine fir/bluejoint reedgrass habitat type, which is a valuable contribution to the research values and biodiversity in the RNA.” Excluding the harvested areas would have reduced protection to these values. Firewood cutting also occurred on about 5 acres of ground adjacent to roads. Since establishment, signs have been posted prohibiting firewood cutting with the RNA. Timber harvest is not permitted within the RNA (USDA Forest Service 1986; USDA Forest Service 2005 – FSM 4063.3(2)). Onion Park RNA Forest Roads 586 and 840 - Based on the Little Belt, Castle, and North Half Crazy Mountains Travel Management Plan Record of Decision (USDA Forest Service 2007), these roads are open yearlong to highway vehicles with snowmobile access between December 1 and May 15. These roads were in existence at the time the RNA was established and do not negatively impact the RNA’s objectives or purpose. No additional road or trail construction are permitted within the RNA. Timber Harvest – Approximately 18 acres of stand clearcut occurred along the southeastern boundary of the RNA in 1963 (10 ac) and 1990 (Crossroads Timber Sale – 8 acres). These areas have naturally regenerated to lodgepole pine. The Establishment Record (USDA Forest Service 1994d) did not address harvested acres, but did note that some firewood cutting of snags had occurred along the road. Since establishment, signs have been posted prohibiting firewood cutting within the RNA. Timber harvest is not permitted within the RNA (USDA Forest Service 1986; USDA Forest Service 2005 – FSM 4063.3(2)). Although these past activities are no longer allowed within the RNAs, their existence does not negatively impact the objectives, purposes, or ecological processes for which the RNAs were established. The O’Brien Creek RNA Establishment Record indicated that the small stand clearcuts detracted from the area’s naturalness, but that the significant value of the adjacent resource precluded their exclusion from the RNA. There are no past, present, or reasonably foreseeable activities that impact the objectives, purposes, naturalness, or ecological processes

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for which the RNAs were established. Therefore, implementation of Alternative 2 would not produce cumulative effects to the O’Brien Creek and Onion Park RNAs.

Alternative 3 Effects Direct and Indirect Effects Implementation of this alternative would only remove dead trees and trees hazardously leaning toward a road or Forest Service infrastructure6. This alternative’s more restrictive hazard tree definition would lead to felling of fewer trees within the RNA than under Alternative 2. The direct and indirect effects described for Alternative 2 also apply to this alternative with the following exceptions listed below. Fewer trees would be felled. Cut stumps would detract less from the areas’ naturalness. Depending upon mountain pine beetle intensity at the time of implementation, pure lodgepole pine stands with residual live trees may be susceptible to windthrow. This natural process may eventually add green trees to the forest floor with the future outcome and surface fuel load similar to Alternative 2. Tree felling immediately adjacent to Onion Park proper would be less than under Alternative 2. The interior of both RNAs will be essentially unmodified due to treatments that only occur in the road corridors and resource protection measures coordinated with the Research Station. No adverse direct or indirect effects to natural conditions or processes would be expected in either RNA. Cumulative Effects The Cumulative Effects section for Alternative 2 also applies to Alternative 3. There are no past, present, or reasonably foreseeable activities that impact the objectives, purposes, naturalness, or ecological processes for which the RNAs were established. Therefore, implementation of Alternative 3 would not produce cumulative effects to the O’Brien Creek and Onion Park RNAs. Scenery The NEPA directs agencies to develop methods and procedures “which will insure that [scenery and other] unquantified environmental amenities and values may be given appropriate consideration in decision making along with economic and technical considerations.” The Scenic Resources of National Forest system lands are regulated by the rules of Title 36 of the Code of Federal Regulations, Part 219, Subpart A, National Forest System Land and Resource Management Planning (36 CFR part 219, subpart A). Requirements include the consideration, treatment, and protection of intangible resources such as scenery and aesthetics.

6 Infrastructure includes, as defined by Merriam-Webster, the system of public works of a country, state, or region and the resources (as personnel, buildings, or equipment) required for an activity

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Management activities are further guided by the Forest Service Manual and the Forest Service Handbook. Volume 2, Chapter 1, AH-462 defines the framework for the Visual Management System (VMS), including the establishment of Visual Quality Objectives (VQO). VQOs define the degree to which management activities are visible to the average forest visitor. Definitions for each of the VQOs are provided below. Retention - Management activities may be present but repeat the form, line, color, texture and pattern of the surrounding natural landscape. Deviations to the landscape are not evident to casual forest visitors. Partial Retention - Management activities are noticeable but visually subordinate to the surrounding natural landscape. Landscapes appear slightly altered to the average forest visitor. Modification - Management activities may be dominant but will borrow from naturally occurring landscape elements (line, form, color, and texture). The landscape appears moderately altered to the average forest visitor. Maximum Modification - Management activities dominate the landscape. To the average forest visitor, the landscape appears heavily altered. All treatments are within the VQO of either Retention or Partial Retention. This is based on the proximity (foreground) of proposed activities and high concentrations of use. In addition, proposed treatments are along corridors and areas where recreation is a dominant use. As such, users are sensitive to the condition of the natural settings in which they are recreating. Identified roads cross multiple Management Areas. Several of the roads in the Little Belt Mountains are in both MA A and MA H and are listed as having high scenic value. These roads include: US Highway 89, Dry Fork Belt Cr. Road (#120), Dry Wolf Road (#251), Logging Creek Road (#253), Memorial Way 487, and Belt Park 6511. As such the VQO is Retention and additional resource protection measures (see Resource Protection Measures section above) have been developed to address potential impacts from proposed activities. Management areas and their associated VQO are detailed in the Scenery Report (pages 4-7). Due to the high use, high sensitivity, and proximity (foreground areas) of proposed treatments, remaining roads proposed for treatment are also assigned the VQO of either Retention or Partial Retention. This is consistent with the Visual Management System for determining Visual Quality Objectives and with Forest Plan direction, both Forest-wide and MA-specific. Developed recreation sites proposed for treatment include: campgrounds, picnic areas, and trailheads. They are scattered throughout the project area and occur in MAs: B, C, E, F, G, H, I, and S. Dispersed Recreation sites are also included in this proposal and occur in MAs: A, B, C, E, F, G, H, and L. Recreation Residences are located in MAs: A, B, C, G, and H. One administrative site, the Judith Guard Station, is included in the project area and is located in MA H. Short-term in this analysis refers to those effects that last from the point of implementation up to 5 years. Long-term in this analysis refers to those effects greater than 5 years.

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Alternative 1 Effects Direct and Indirect Effects Natural disturbance regimes and events such as wildfires, winds, insects, and disease would continue to shape and change the vegetation of the Little Belt. Many dead and dying trees could remain standing for several years. As trees fall, there would be an increase in woody material on the ground and a reduction in forest canopy. Increased woody debris, combined with continued spread of insect infestations, could increase the potential for high intensity fires (see Fuels section). If a high intensity fire burned through the area, recovery times for vegetation and soil (see Soils section) would have a negative impact on scenic resources. Short term, Alternative 1 would comply with the VQOs of the Lewis and Clark National Forest Land and Resource Management Plan. Long term effects may be less desirable due to increased woody debris, continued spread of beetle infestation, increased occurrence of dead and dying trees, and the potential for high intensity fire events. Cumulative Effects Under this alternative, cumulative effects would be limited to the anticipated continuation of existing trends within the project area and the past, present, and future management activities.

Effects Common to Alternatives 2 and 3 Proposed treatments are limited to specified developed recreation sites, special use sites, and along identified Forest roads. All areas contain high concentrations of recreation use and scenic resources deliver quality settings for visitors. Identified sites and corridors will serve as viewing locations from which effects will be assessed. The visual condition of developed sites would change as hazardous trees either fall or are removed. This loss of mature trees would reduce screening between individual camping units and use areas. In addition, there would be a reduction in overhead canopy that currently provides shade and cover to campsites. Sites would appear more open and exposed. The reduction in mature trees would increase sun to the understory, potentially resulting in accelerated growth of seedlings, shrubs, and other low growing vegetation. Along roads, the density of trees would also be reduced and in some areas, openings would be created. The diversity in both species and age classes would affect the degree of beetle infestation present. This, in turn, would create varying degrees of tree mortality. Where a more mixed species forest occurs, the resulting forest would appear more open with increased spacing between mature trees and a more open and robust understory. Where beetle infestations are more concentrated and existing forested areas are primarily even-aged lodgepole, openings would be created. Past, present and future management activities that may affect the scenic resources of the project area include: timber harvest, fuels activities, prescribed burning, road construction, and reconstruction, trail construction, and fire activity. Cumulative effects of these activity types and the activities proposed under the various alternatives are considered below.

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Alternative 2 Effects Direct and Indirect Effects As with Alternative 1, created openings and a reduction in overhead canopy and screening would result. In addition, cut stumps would be visible. Slash would be removed or used to protect and rehabilitate disturbed areas. These short term impacts would decrease over time as stumps and mulch weather, and young trees and herbaceous understory vegetation re-establishes. By implementing resource protection measures (see Resource Protection Measures section above) long term impacts to the scenic resources would be minimized. Immediately adjacent to roads, forested areas would be less dense and have fewer snags and downed wood than untreated areas further from roads and campgrounds, and openings would be created. Where existing forests are even-aged lodgepole pine, there would likely be more clearings created. Where the existing forest is comprised of more variety in both species and age class, the treatment would be more of a thinning and result in a more open appearing forest. Where natural openings exist behind proposed treatments, views to more distant landscapes may result. Cut stumps would be visible and slash, where chopped and scattered, would be apparent short term. The slash would weather and settle over time. Cut ends of stumps would also weather and turn grey over time. Long term, contrasts created from slash and stumps would diminish and blend into the natural setting. Some felled trees may remain on the ground to protect sensitive plants and soils. Selected standing dead or felled trees may also be left on site to provide wildlife habitat. Tree removal within stands that serve to screen recreation and administrative sites may result in those sites becoming more visible from travel corridors and other vantage points. Removal of dead and dying trees would allow remaining young healthy trees to grow faster due to lessened competition for light and moisture. In ten to twenty years, a more diverse mix of species and age classes would be established. Long term, the VQOs would be met under this alternative with the implementation of the Scenery resource protection measures. In developed sites, vegetation management planning efforts could be completed to identify needs and strategy for managing the vegetation to help maximize the recreation experience into the future. In general, stands that are primarily lodgepole pine would require more intensive tree removal. The north, northwest, east and southeast boundaries of the Little Belt contain a more diverse mix of species while the interior being predominately lodgepole pine. Resource protection measures have been developed to ensure impacts to the scenic resources are minimized and regeneration is accelerated. Natural disturbances regimes would continue to have a dynamic effect on the landscapes of the Forest. Since management activities are relatively small in relationship to the mosaics created naturally, no indirect effects of any significance are anticipated to the visual resources. At a smaller scale, indirect impacts could include accelerated growth of understory vegetation. This can, depending on site-specific conditions, increase the variety of color and texture seen in the landscape and result in positive long term effects to the scenic quality.

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Cumulative Effects Past timber harvest has occurred within the project area and the effects of this activity may be visible from the surrounding area. Much of the past timber harvest has been clearcut, with reserves, shelterwood, and seed tree prescriptions, which remove a majority of the stand and have a visual effect of a created opening. Much of the past harvest activity as measured by acres occurred in the decades prior to 2000 – 2009, and regeneration has progressed to a point where the effects no longer dominate the viewshed, but remain subordinate to the landscape character. The proposed project could result in these effects being more visible under this alternative. The effects of roads and trails, including construction and reconstruction, are also visible from the surrounding area and the identified sensitivity level 1 roads. It is anticipated that some stretches of roads that are currently screened from view by vegetation might become more visible as a result of this alternative. These stretches would likely remain subordinate to the landscape character. The effects of past fuels activity, including broadcast burning, underburning, and thinning, has affected scenic resources. Typically, the effects of burning activities are visible as burned areas on the landscape which may persist for 2-3 seasons, depending on the intensity of the burn. As such, the cumulative effect of these activities and the proposed action is limited to those that have been burned in the last 2 to 3 years. Some of the more recent fuels activities that include burning might contribute to cumulative effects when combined with the effects of this alternative, but are not expected to persist in the long term. Thinning activities such as conifer encroachment treatments are not expected to be visible once the effects associated with slash have dissipated, or slash is removed, and groundcover (grasses, etc.) have recovered.

Alternative 3 Effects Indirect and Direct Effects Under Alternative 3, created openings would likely be smaller in size and remaining areas would be denser as compared to Alternative 2. As with Alternative 2, natural disturbances regimes would continue to have a dynamic effect on the landscapes of the Forest. Since management activities are relatively small in relationship to the mosaics created naturally, no indirect effects of any significance are anticipated to the visual resources. At a smaller scale, indirect impacts could include accelerated growth of understory vegetation. This can, depending on site-specific conditions, increase the variety of color and texture seen in the landscape and result in positive long term effects to the scenic quality. Cumulative Effects Under this alternative, cumulative effects would be similar to those described above for Alternative 2. However, it is anticipated that the effects would be reduced as compared to Alternative 2 as fewer live trees would be removed under this alternative.

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Sensitive Plants There are 25 designated sensitive plant species that either occur or are suspected to occur on the Lewis and Clark National Forest. Six of these species are known to occur or have potentially suitable habitat within the proposed treatment areas, or a plant’s habitat requirements overlap with some component of the proposed treatment areas. The Sensitive Plants report and associated analysis covers these six designated species which include Short-styled columbine, Northern rattlesnake-plantain, Northern wildrye, Missoula phlox, Austin’s knotweed, and whitebark pine. Presence of a sensitive species or its habitat is determined using a combination of resources including the Montana Natural Heritage Program (MNHP 2006) and the Lewis and Clark National Forest plant atlas, the potential habitat as displayed in the Forest’s geographic information system (GIS) sensitive plant model, and current site conditions from site inventories. About 380 acres of sensitive plant surveys were completed in 2012. Additional surveys would be completed prior to project implementation. Although some species are not included in this analysis, all 25 sensitive species would be searched for during field surveys. Roads and recreation, administrative, and recreation residence sites in proximity to concentrations of known sensitive plant populations or to areas identified as providing potentially suitable habitat would be surveyed prior to implementation. These roads include: Divide road (FS road 839), Dry Fork Belt Creek road (120), Dry Wolf road (251), Memorial Way road (487), Moose Creek road (204), Running Wolf road (264), Studhorse road (830), Willow Creek – Bear Park road (3303), Willow Park – Haymaker road (189), Wolf Creek Divide road (6328), and Yogo Creek road (266). Although surveys would search for all sensitive plant species, Northern rattlesnake-plantain, short-styled columbine, and Northern wildrye have the greatest potential to be located. Other species may be located along the road, but the habitat to be treated generally does not support these species. Small yellow lady’s-slipper and sparrow’s-egg lady’s-slipper populations have not been located in the Little Belt Mountains, but potential habitat exists in the project area.

Effects Common to All Alternatives Sensitive plant populations may experience habitat degradation or temporary loss of individuals (extent and density) under all alternatives. The best method of prevention is to minimize ground disturbance and reestablish desirable vegetation promptly when ground disturbance leaves bare soil, which would occur under both action alternatives. Similarly, under all alternatives wildfire events have the potential to detrimentally affect sensitive plant species and habitat in the short- term. Fire with a high soil severity rating could have long-term impacts on sensitive plant populations. Additionally, invasive plant species are strong competitors with native vegetation and are most likely to establish in disturbed locations. None of the alternatives would affect the threats (fire suppression, climate change, white pine blister rust, and mountain pine beetle) that have led to whitebark pine’s listing as a sensitive species. Fire, ranging from small and isolated to large and stand-replacing, is the primary disturbance factor in the high elevation environment that renews whitebark pine. In the absence of fire, whitebark pine is eventually replaced by shade-tolerant species (Keane and Parsons

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2010). Under all alternatives, white pine blister rust would continue to infect new trees of all sizes and existing infections would intensify. Mountain pine beetle-caused tree mortality would continue at high rates. Both mountain pine beetle and white pine blister rust would kill mature whitebark, thus reducing seed availability for reforestation.

Alternative 1 Effects Direct and Indirect Effects Effects to sensitive plants of taking no management action under this project are described in the above Effects Common to All Alternatives section. Cumulative Effects The cumulative effects area for each sensitive plant is based on its occupied territory within the Little Belt Mountains. Because this alternative would not impact sensitive plants, there would be no cumulative effects between this project and those listed in the Project Record.

Alternative 2 Effects Direct and Indirect Effects Potential treatment areas overlap known populations of short-styled columbine, Northern rattlesnake-plantain, Northern wildrye, Missoula phlox, Austin’s knotweed, and whitebark pine. Implementation of the proposed action alternative has the potential to modify sensitive plant habitat through ground disturbance and removal of cover provided by dead trees. Resource protection measures would minimize impacts to individual plants or the population as a whole through protection from ground disturbance or herbicide application. Although Missoula phlox and Austin’s knotweed are known within the project area, their habitat requirements limit the potential that Alternative 2 would disturb the populations or potentially suitable habitat. Missoula phlox populations in the analysis area are restricted to wind-swept meadows. Even though the populations are located within the project analysis area, management actions would not occur in these locations due to lack of trees. Three of the thirty known Austin’s knotweed populations in Montana are located within or adjacent to the Fawn Creek Road (FS Road 6393, T10N, R10E). Management actions may lead to a loss of individuals, but actions would be limited in the open, gravelly habitat that Austin’s knotweed prefers due to lack of trees. Northern wildrye populations located along a short stretch of Divide Road (FS Road 839) occur within riparian meadows and in conifer habitat on either side of Logging Creek. Northern wildrye would not be impacted within riparian meadows where no trees would be harvested or in occupied habitat on the far side of the stream where the most intensive management would consist of trees felled and left in place (see Resource Protection Measures). Based on available vegetation data, treatment areas within and adjacent to Northern wildrye support a limited quantity of trees that would be considered for removal under Alternative 2. Loss of individual plants or habitat is expected to be minimal, if at all.

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Short-styled columbine and Northern rattlesnake-plantain are present in the project analysis area. Implementation of resource protection measures would minimize impacts to individual plants or the population as a whole through protection from ground disturbance or herbicide application. Although individual plants or habitat may be impacted, this alternative would not likely contribute to a trend towards federal listing or loss of viability to the population or species. Northern rattlesnake-plantain is very sensitive to disturbances, such as timber harvest and fire, which open or reduce canopy cover and physically disturb or remove the forest floor’s organic (duff) layer (Dyrness et al. 1988; USDA Forest Service 1995a; White 1996; MNHP 2011). Likewise, short-styled columbine does not survive when the duff layer is removed (Roe 1992). Because specific light requirements are currently unknown for short-styled columbine, although partial overstory or shade from adjacent forest is common in known populations, it is unknown how plants will respond to loss of shade from salvage harvest (Roe 1992). Tree removal within and adjacent to known sensitive plant populations has the potential to further modify suitable habitat conditions beyond that of insect-caused mortality alone (warmer and drier site conditions). Whitebark pine defined as a hazard tree under this alternative have the potential to be felled on about 235 acres. Hazard tree characteristics that would most often pertain to whitebark pine in the Little Belt Mountains are: dead tree, dead top, bark beetle infested green trees (copious amounts of frass or pitch tubes), dead/dying crown, bole cankers (>50% of circumference girdled), and forked or multiple tops. Felling dead whitebark pine would not affect the species’ viability because these trees are not contributing to the next generation. Likewise, bark beetle infested green trees would be dead within the next year. Although these trees may be capable of producing cones prior to their death, their removal would not detrimentally impact the species. If adequate crown is present to produce cones and bole cankers are less than 50 percent of the circumference, a whitebark would be considered for retention. Although removal of infected mature trees would reduce the source of blister rust infection for smaller, adjacent whitebark, this effect would be negligible given the abundant source of infection in the adjacent, untreated landscape. Structurally weak trees with the potential to cause property damage or personal injury if they fail would be felled regardless of the tree’s capability to produce cones. Very few whitebark pine with forked or multiple tops would be selected for felling since this is the natural growth form of whitebark, especially at high elevations. Removing dead, dying, and hazardous whitebark pine would not produce a noticeable reduction in the landscape-level mountain pine beetle epidemic population in the Little Belt Mountains due to the small extent (scattered, linear units less than 300-feet wide on less than 235 acres) of treatment compared to the acres of suitable and susceptible pine beetle host. Removal of newly infested trees prior to beetle flight, however, could reduce localized beetle populations and may make some residual trees less susceptible to beetle-caused mortality. In areas with a healthy whitebark pine understory, trees would be manually felled and left in place or removed in such a way (e.g. end-line or grapple yard) to minimize potential resource damage (see Resource Protection Measures section). Additionally, resource protection measures would minimize impacts from invasive species regardless of sensitive species occupancy to prevent the loss of sites for future sensitive species establishment.

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Tree felling, especially if mechanized, and whole-tree yarding have the potential to detrimentally damage existing whitebark pine seedlings and saplings. Extensive damage would inhibit the tree’s ability to survive to cone-bearing age. To the extent possible, landings would not be located in areas occupied by whitebark pine (see Resource Protection Measures section above). Mature whitebark pine would not be felled to create a landing. Depending upon landing location there is a potential that incidental whitebark pine seedlings and saplings may be damaged or killed at landings, and landing pile burning has the potential to scorch adjacent whitebark pine. Site clearing, however, may also create suitable sites for whitebark pine regeneration. Although individual trees may be impacted, landing location and activity would not likely contribute to a trend towards federal listing or loss of species viability. If site surveys indicate the presence of a healthy whitebark pine understory, hazard trees would be manually felled and left in place or removed in such a way (e.g. end-line or grapple yard) as to minimize potential resource damage. Cumulative Effects Road and trail construction, rerouting, or decommissioning and timber harvest have the potential to impact sensitive plant populations. Past and current projects either had no impact or could impact individuals or habitat without contributing towards federal listing or loss of species viability. Tree mortality and associated environmental changes from the mountain pine beetle outbreak in combination with tree felling and potential removal would cumulatively impact sensitive plant populations and habitat through individual plant mortality and modification or removal of essential habitat requirements. Impacts due to mountain pine beetle-caused tree mortality are natural and the primary force influencing changes to sensitive plant populations in pine dominated locations. Implementation of this project’s resource protection measures would limit the loss of individuals and ground disturbance within known populations while still achieving the project’s purpose to provide for safer conditions. Verbenone installation and carbaryl application in recreation and administrative sites across the project area minimized the number of lodgepole, ponderosa, limber, and whitebark pine killed by mountain pine beetle and, therefore, reduced the degree of treatment necessary in these sites. Future verbenone and carbaryl treatments would assist with maintenance of green trees at high value sites. Protection of whitebark pine from mountain pine beetle is a beneficial effect to the species because these trees would not be removed during implementation of the Hazard Tree Removal project. Several wildfires have burned within areas proposed for hazard tree removal. Although these acres are included in the R1-VMap class for whitebark pine, they currently contain an overstory of dead trees that would be felled due to their hazardous nature. Removal of trees killed during past wildfires would not cumulatively affect whitebark pine’s viability or its habitat because these trees are currently dead and the habitat has not been unsuitably modified. Porphyry Lookout is situated within a whitebark pine forest where dead, dying, or hazardous trees were felled, hand-piled, and burned at this location in 2010 under the Showdown Hazard Tree Removal decision. Alternative 2 would remove additional hazard trees from the site and in addition to the previous activity, would cumulatively result in fewer live whitebark pine.

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However, the cumulative effects would occur on less than 3 acres (<0.02%) of whitebark in the Little Belt Mountains and would therefore not negatively impact the species overall. The Deadman-Memorial Way Road Capital Investment Project, with decisions in September 2009 and April 2011, proposes to construct (re-route) about one mile of road through whitebark pine dominated forest. All trees, regardless of species, size, or condition, would be felled and removed for 25 feet either side of centerline. This action would permanently remove about 6 acres of whitebark pine and its habitat. The current road alignment (#487) is also situated within whitebark pine and would have hazard trees felled. Implementation of Alternative 2 along this road would remove unhealthy, mature whitebark and could damage seedlings and saplings. However, once the Deadman-Memorial Way project is completed, the re-routed segment of road would be rehabilitated. Although implementation of these projects would cumulatively reduce the number of whitebark pine and the acres of suitable habitat in the short-term, the rehabilitated road would provide suitable whitebark pine habitat for either natural or planted regeneration resulting in no overall impact on the species.

Alternative 3 Effects Direct and Indirect Effects The direct and indirect effects to sensitive plants described under Alternative 2 are similar to the effects under Alternative 3 with the following exceptions. Under this alternative, Austin’s knotweed populations adjacent to Fawn Creek Road (6393) and Northern wildrye populations in Logging Creek that have conifer cover have a lower potential for ground disturbance if only dead trees are removed. The more restrictive hazard tree definition under Alternative 3 also has the potential to retain more canopy cover and intact forest floor organic matter with associated cooler and moister conditions. These conditions would better support Northern rattlesnake- plantain and short-styled columbine survival as compared with Alternative 2. Less habitat modification under this alternative would also benefit other sensitive plant species that may be present. Felling dead whitebark pine would not affect the species’ viability because these trees are not contributing to the next generation through seed production. Live whitebark, regardless of their condition or disease status, would remain on site to contribute to species viability. Cumulative Effects Cumulative effects for sensitive plants are similar to those described under Alternative 2 with the following exceptions. Additional treatment at Porphyry Lookout would only remove dead trees or those hazardously leaning toward the road or lookout. As a result, Alternative 3 would retain more live whitebark pine on the approximately 3 acres of potential treatment area compared to Alternative 2. Likewise, hazard tree removal along sections of the existing Deadman-Memorial Way road would retain more live whitebark pine and produce less understory tree damage on less than 6 acres than would occur under Alternative 2.

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Soils In keeping with the Region 1 Approach to Soils NEPA Analysis Regarding Detrimental Soil Disturbance in Forest Areas - Technical Guide (2011), field evaluations targeting previous activities from the FACTS database paired with best available science and monitoring of similar activities from the Beaverhead-Deerlodge and Helena NFs were used to anticipate the resulting soil impacts from removal of hazard trees. During the 2010 field season, soil quality assessments were conducted on 44.3 miles of proposed roadside hazard treatment areas. Past activity areas (harvest and fire) were targeted for this analysis (see D13b-2010FieldworkSummary.pdf in project record). These areas were evaluated for existing detrimental soil disturbance using criteria consistent with the Forest Soil Disturbance Monitoring Protocol (Page-Dumroese et al., 2009). Field observations produced 350 field evaluations characterizing existing soil conditions commonly found in these activity areas. Areas that had previous management activities usually showed greater than 15 percent detrimental soil disturbance. Areas with no previous activities showed existing detrimental soil disturbance of 1 percent on average. A summary table of pre- activity data can be found in the soils portion of the project file. This analysis was updated to reflect multiple alternatives and to incorporate newly acquired and directly applicable monitoring information in the fall of 2012 and the winter of 2013. Analysis included reviewing the field data collected from 2010 and overlaying the data with FACTS database and NAIP imagery to verify field data coincided with previous activities. Records of past management activities (e.g. timber harvest or prescribed burning) contained in FACTS provided the basis for analysis of potential soil cumulative effects in areas where proposed hazard tree removal may overlap with previous management activities. Additionally, information from the Soil Resource inventory of the Lewis and Clark National Forest, interim in-service report for non-wilderness portions, (Holdorf, 1981) was used as the basis for land type information and to analyze potential soil environmental effects. Forest Service management policy (known as the Region 1 Soil Quality Standards found in Forest Service Manual (FSM) 2500—Watershed and air management, USDA Forest Service 1999), states that new vegetation management activities should not result in detrimental soil conditions on more than 15% of an activity area. When operations are planned in areas that do not meet Soil Quality Standards resulting from prior activities, new vegetation management activities should be planned to meet current standards and designed to ameliorate past detrimental soil conditions, where feasible. For this project, Region 1 Soil Quality Standards will serve as threshold values for determining compliance with legal mandates to sustain site productivity with implementation of management activities. However, Soil Quality Standards do not apply to intensively developed sites such as developed recreation sites, administrative sites, and recreational residence sites (R1 Supplement 2500-99-1). Effectiveness of Best Management Practices (BMPs) and resource protection measures have been investigated in research studies and monitored by the Lewis and Clark NF as well as by the State of Montana. These studies and evaluations demonstrate that BMPs and resource protection measures can be effective at preventing erosion and sedimentation and have been implemented effectively by the Lewis and Clark NF (Han-Sup et al., 2005; Reeves et al., 2011; Helena Timber

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Sale Monitoring, 2012). Appendix A of the Hydrology report describes the Forest Service's BMP process in detail, lists the key Soil and Water Conservation Practices (comparable to BMPs) that have been selected to be used on this project, and describes each BMP. Additional monitoring on the Lewis and Clark National Forest found units harvested under winter conditions were right in line with predicted disturbance percentages of 4% (Reeves et al., 2011). The temporal scope for this analysis includes both short- and long-term impacts. Short-term effects are defined as those that occur approximately within 1–10 years following proposed vegetation treatments. Long-term effects are defined as those that occur approximately within 10–20 years, or more, following proposed vegetation treatments.

Alternative 1 Effects Direct and Indirect Effects With no new actions proposed, no new quantifiable soil effects would occur. Unquantifiable soil effects would likely results from the following: ongoing insect and disease caused mortality of trees within the proposed analysis area, which is unlikely to cause detrimental soil effects because the forest floor and soil are not disturbed (Romme et al, 2006); firewood cutting may occur along system roads with minor impacts to soils anticipated; grazing impacts would likely continue within the proposed treatment analysis area with minor areas of vegetation removal; and soil compaction and displacement are anticipated where livestock trail, bed, and loaf. If the proposed treatment analysis area were to be burned by wildfire in the future, a mix of burn severities would be anticipated depending on the topography, fuels, and climatic conditions. Moderate to high burn severities would likely result in an increase amount of bare soil, accelerated erosion, slow recovery of effective vegetation cover and loss of soil nutrients and soil microbes. Cumulative Effects With no new proposed activities, there would be no cumulative effects.

Alternatives 2 and 3 Effects Direct and Indirect Effects The direct and indirect effects for Alternative 2 and 3 would be similar for the soil resource since tree removal mechanisms would be the same. Ground-based equipment would impact the soil resource similarly for removal of trees under Alternative 2 and 3. Pre-activity field data collected showed an average of greater than 15 percent detrimental soil disturbance in old activity units. In areas where past activities have not occurred, field data showed existing detrimental soil disturbance averaged 1 percent. Monitoring on the Lewis and Clark National Forest found units harvested under winter conditions were right in line with predicted disturbance of 4 percent (Reeves et al., 2011). Monitoring data from the Lewis and Clark National Forest, Blank Ant Salvage during winter harvest showed an average of 4 to 5 percent detrimental soil impacts before mitigation for ground based harvest with landings (Hamann 2007; 2009; Page-Dumroese et al., 2006).

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Post-hazard tree removal monitoring on similar forest types and soils on the Beaverhead Deerlodge National Forest and the Helena National Forest found that units harvested with ground based methods did not exceed R1 Soil Quality Standards following implementation (USDA, 2008; Fletcher and Ruppert, 2011). The Beaverhead-Deerlodge monitoring in 2009 documented detrimental soil disturbance levels ranging from 4 percent for summer conditions. Monitoring of hazard tree removal projects on the Helena NF spanning two years and over 40 sites (2011 and 2012) resulted in logging during winter conditions having 4 percent detrimental soil disturbance and logging during summer conditions leaving 7 percent detrimental soil disturbance. These values account for detrimental soil disturbance resulting from skid trails and landings. Applying this data to Alternatives 2 and 3, hazard tree removal in areas with previous harvest may cause detrimental soil disturbance to exceed R1 Soil Quality Standards. Therefore, these units would not be reentered with ground based equipment (see resource protection measure for soils, page 22). In hazard tree treatment analysis areas with no previous activities, detrimental soil disturbances are anticipated to be below R1 Soil Quality Standards, averaging 5 percent detrimental soil disturbance for winter logging (1 percent existing DSD plus 4 percent predicted DSD) and 8 percent for summer logging (1 percent existing DSD plus 7 percent predicted DSD). Under all action alternatives, detrimental soil disturbance would occur with operation of ground- based equipment for tree harvest, primarily in areas where logging equipment traffic is concentrated, such as main skid trails. Soil would be detrimentally disturbed by compaction, displacement, rutting, and erosion in the areas affected by skid trails in the short-term. Over the long-term, soils affected by detrimental disturbance on main skid trails would recover through natural processes, such as frost heave, bio-perturbation, and soil organic material cycling. However, recovery of soils to pre-disturbance conditions would likely take 100 years or longer. In the short-term, soils at log landings sites would be detrimentally disturbed during operation of heaving equipment for log processing. Upon completion of harvest activities, reclamation of log landings through soil scarification, seeding, placement of woody debris, and recontouring (if needed), would promote recovery of soils in the long-term. If the proposed treatment analysis area were to be burned by wildfire in the future, a mix of burn severities would be anticipated depending on the topography, fuels, and climatic conditions. Moderate to high burn severities would likely result in an increase amount of bare soil, accelerated erosion, slow recovery of effective vegetation cover and loss of soil nutrients and soil microbes. Cumulative Effects Areas that are anticipated to exceed Regional 1 Soil Quality Standards were removed from treatment areas with ground-based mechanical means. Therefore, any known potential for cumulative effects resulting from the Little Belt Mountains Hazard Tree Removal Project has been accounted for and mitigated for this project.

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Vegetation Vegetation management activities are guided by the National Forest Management Act (NFMA) and the Lewis and Clark National Forest Land and Resource Management Plan (Lewis & Clark Forest Plan). Proposed activities under both action alternatives are in compliance with NFMA and Forest Plan standards and management areas. The analysis below addresses windfall potential under each alternative.

Effects Common to All Alternatives Potential windfall in forested stands is dependent upon tree species, stand density, topographic location, and soil conditions (Tackle 1961; Alexander 1986; Koch 1996a). While ponderosa pine, Douglas-fir, and whitebark pine are generally considered windfirm, lodgepole pine, Engelmann spruce, and subalpine fir are generally considered susceptible to windfall due to shallow root development, especially after partial cutting. Low windfall risk situations are generally valley bottoms and flat areas, lower and gentle middle north- and east-facing slopes, and lower and gentle middle south-and west-facing slopes that are protected by considerably higher ground on the windward edge. Moderate windfall risk situations include valley bottoms parallel to the prevailing winds, lower and gentle middle south- and west-facing slopes not protected on the windward edge, moderate to steep middle and all upper north-and east-facing slopes, and moderate to steep middle south- and west-facing slopes protected by higher ground on the windward edge. High windfall risk situations include ridgetops, saddles in ridgetops, moderate to steep middle south- and west-facing slopes not protected on the windward edge, and all upper south- and west-facing slopes. Topographic conditions that funnel winds increase windthrow susceptibility (Alexander 1986; Koch 1996a). Dead tree (snag) fall rates vary based on tree species, cause of mortality, surrounding stand conditions, and topographic location. Although the tops of bark beetle-killed trees are relatively dry, moisture at ground line often remains appropriate for fungal decay. The amount of decay at ground line, which is driven by temperature, influences when a tree would fall (Koch 1996b; Mitchell and Preisler 1998). Alexander (1986) reported that in low and moderate windfall risk situations, removal of about 20 to 30 percent of the basal area on an individual tree basis in single-storied, lodgepole pine dominated stands should result in minimal windfall. Basal area removal in multi-storied stands can be increased to 30 to 40 percent of the stand’s total basal area. Removal of more than 60 percent of the total basal area in various Central, Northern and Canadian Rocky Mountain studies indicated heavy windfall tree mortality (Alexander 1986). Windfall can be expected to occur on both the windward and leeward edges of harvest units (Koch 1996a). Tree fall in harvested and unharvested areas has the potential to release understory trees.

Alternative 1 Direct and Indirect Effects Windfall potential in the untreated forest would be variable based on the information provided above. As trees fall within stands, the windfirmness of residual live and dead trees would be decreased due to exposure to additional wind. Stem decay rates in mountain pine beetle-killed

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trees and subsequent tree fall rates would also increase as ground line temperatures increase in naturally thinning stands. Tree fall timing may be slightly delayed and drawn out over many years in Alternative 1 compared to the action alternatives.

Alternative 2 Direct and Indirect Effects A minor quantity of trees are expected to meet the hazard tree definition or contribute to windfall in R1-VMap polygons classified as less than five inches diameter (about 17% of forested acres), especially in non-pine dominated areas. Pine trees in this classification are generally too small to sustain mountain pine beetle. However, these polygons may contain some pine greater than five inches diameter, which would be susceptible to mountain pine beetle-caused mortality and subsequent tree fall, if not harvested. There is a low to moderate probability of windfall in non-pine dominated stands greater than five inches diameter (approximately 38% of forested acres) since these areas are anticipated to retain at least 40 percent of the basal area (based on R1-VMap dominance type classification). Based on the hazard tree definition of Alternative 2, higher levels of basal area removal (e.g. severe western spruce budworm defoliation) could lead to greater windfall potential of residual trees. Windfall potential would increase if harvest units were located in moderate or high windfall risk situations. Windfall in pine dominated stands over five inches diameter (about 45% of forested acres) would range from low to high depending upon quantity of trees meeting the alternative’s hazard tree definition, percentage of original basal area removed, post-treatment stand structure and species composition, and topographic location. Removal of hazard trees under Alternative 2 could result in conditions similar to a clear-cut. This treatment would eliminate or greatly reduce windfall potential within the unit. If pine trees are retained based on the hazard tree definition, they would be susceptible to future mountain pine beetle-caused mortality and subsequent tree fall. Windfall could be expected along the edges of adjacent untreated stands, especially on the leeward side (Koch 1996a).

Alternative 3 Direct and Indirect Effects Effects from Alternative 3 would be the same as those described in the No Action Alternative because there would no treatment in anticipation of windfall.

Cumulative Effects of All Alternatives Windfall, depending upon its intensity and scale, has the potential to reduce stand density, release individual understory trees from competition, or regenerate a stand. Potential forest vegetation changes, along with past harvest, would cumulatively add to structural and age class diversity in the Little Belt Mountains. Because mature forest structure is predominant in the Little Belt Mountains, creating additional diversity would be beneficial. Wildlife The mountain pine beetle is having a far reaching effect on habitat in the Little Belt Mountains. For species that require snags, such as woodpeckers and bats, these changes are

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creating habitat. For species that require forested areas, these changes are reducing habitat. While both action alternatives will remove habitat or habitat components for some of the species considered here, the major change agent in the project area is mountain pine beetle. The future impacts of the mountain pine beetle epidemic are likely to be complex. Regeneration is likely to occur in many impacted areas, while others may remain in a different habitat type than currently exists. Two Threatened (T), and 14 Sensitive (S) wildlife species (Table 2) are known or suspected to occur on the Forest (USDI Fish and Wildlife Service 2013, USDA Forest Service 2011). A November 8, 2013 list of Threatened, Endangered and Candidate Species for the Lewis and Clark National Forest lists Canada lynx (Lynx canadensis) as a Threatened species on the Jefferson Division, where this project is located. A Biological Assessment and consultation with the USDI Fish and Wildlife Service will be completed for this project. Wolverine was proposed for listing as Threatened on February 4, 2013 (Federal Register 2013a). On August 13, 2014, the USFWS withdrew its proposal to list the wolverine under the Endangered Species Act (Federal Register 2014). As a result of this action, the wolverine automatically returns to the Region 1 Sensitive Species list. Twenty Management Indicator Species (MIS) are identified for the Forest, with 6 of those also designated as Threatened, Endangered, Proposed or Sensitive. Background information for all species is found in the document “Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities” (USDA Forest Service 2011a). Species ranges were determined from the Montana Field Guide (http://fieldguide.mt.gov/) and from professional knowledge of the wildlife biologist. A determination of habitat within the analysis area was made using aerial photos, Timber Stand Management and Record System (TSMRS), Region 1 Vegetation Mapping (R1 VMAP), and professional knowledge. Species occurrence was determined from forest records, surveys, and the Natural Heritage Tracker database (http://mtnhp.org/tracker/NHTMap.aspx). Table 7 summarizes this information. Table 7: Threatened, Endangered, Proposed, Sensitive, and Management Indicator Species on the Lewis and Clark National Forest Project occurs Habitat found Species known Species and status7 within species within analysis to occur within Range? area? analysis area? Grizzly Bear (Ursus arctos horribilis) (T) Yes Yes No (MIS for Endangered and Threatened)

Canada Lynx (Lynx canadensis) Yes Yes No

7 T = Threatened, E = Endangered, CH = Critical Habitat, P = Proposed, S = Sensitive, MIS = Management Indicator Species.

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Project occurs Habitat found Species known Species and status7 within species within analysis to occur within Range? area? analysis area? (T, CH) (MIS for special interest) Wolverine (Gulo gulo) (S, MIS Yes Yes Yes for special interest) Bighorn Sheep (Ovis canadensis) Yes No No (S, MIS for commonly hunted) Fisher (Martes pennanti) (S) No No No Gray Wolf (Canis lupus) (S, MIS Yes Yes Yes for Endangered and Threatened) Townsend's Big-Eared Bat Yes Yes Yes (Corynorhinus townsendii) (S) Northern Bog Lemming No No No (Synaptomys borealis) (S) Bald Eagle (Haliaeetus leucocephalus) (S) Yes Yes Yes (MIS for Endangered and Threatened) Peregrine Falcon (Falco peregrinus) (S) Yes Yes Yes (MIS for Endangered and Threatened) Black-backed Woodpecker Yes Yes Yes (Picoides arcticus) (S) Burrowing Owl (Athene Yes No No cunicularia) (S) Flammulated Owl (Otus No No No flammeolus) (S) Greater Sage Grouse Yes No No (Centrocercus urophasianud) (S) Harlequin Duck (Histrionicus Yes Yes Yes histrionicus) (S)

Greater Short-Horned Lizard Yes No No

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Project occurs Habitat found Species known Species and status7 within species within analysis to occur within Range? area? analysis area? (Phrynosoma hernandesi) (S) Beaver (Castor canadensis) Yes Yes Yes (MIS for commonly trapped) Black Bear (Ursus americanus) (MIS for commonly hunted and Yes Yes Yes fished) Bobcat (Lynx rufus) (MIS for Yes Yes Yes commonly trapped) Whitetail Deer (Odocoileus virginianus) (MIS for commonly Yes Yes Yes hunted and fished) Mule Deer (Odocoileus hemionus) (MIS for commonly Yes Yes Yes hunted and fished) Mountain Goat (Oreamnos Yes americanus) (MIS for commonly No No (introduced) hunted and fished) Mountain Lion (Puma concolor) (MIS for commonly hunted and Yes Yes Yes fished) Elk (Cervus canadensis) (MIS Yes Yes Yes for commonly hunted and fished) Dusky (Blue) Grouse (Dendragapus obscurus) (MIS Yes Yes Yes for commonly hunted and fished) Golden Eagle (Aquila chrysaetos) (MIS for special Yes Yes Yes interest) Prairie Falcon (Falco mexicanus) Yes Yes Yes (MIS for special interest) Northern Goshawk (Accipiter gentilis) (MIS for old growth Yes Yes Yes forest)

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Project occurs Habitat found Species known Species and status7 within species within analysis to occur within Range? area? analysis area? Northern Three-Toed Woodpecker (Picoides dorsalis) Yes Yes Yes (MIS for tree cavity - conifer)

This section of the Preliminary environmental analysis will proceed by species as introduced in the table with alternative-specific summaries following at the end of the wildlife section.

Grizzly Bear The project is within the historical range, but is currently unoccupied. The November 8, 2013 Threatened, Endangered and Candidate Species list for the Lewis and Clark National Forest indicates grizzly bear does not occur on the Jefferson Division, where the project is located (USDI Fish and Wildlife Service 2013). Additionally, threats to grizzly bear are identified in the “Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities” (USDA Forest Service 2011a). Of the identified threats, those that cause displacement are not of concern in this project because the Little Belts are not currently occupied by grizzly bear. Furthermore, vegetation management activities can result in elimination of cover for resting, security, and thermal regulation, short term changes in food availability, displacement of bears, and increased human-bear interactions. As the area is not currently occupied, these potential effects would not result in impacts to individual bears. Because the project is outside the occupied range of the species, is outside the recovery area, and is outside the area we currently manage for grizzly bear, the project would have no effect on grizzly bears.

Alternative 1 Effects Under the No Action Alternative there would be no activities and therefore no direct, indirect, or cumulative effects on grizzly bears.

Alternatives 2 and 3 Effects Under both Action Alternatives (Alternative 2 and 3) trees would be removed consistent with the hazard tree definitions of each alternative. Because the project is outside the occupied range of the species, is outside the recovery area, and is outside the area we currently manage for grizzly bear, the Little Belt Hazard Tree Removal project would have No Effect on grizzly bears. As a result, there would be no direct, indirect, or cumulative effects on grizzly bears. Obtaining a list of Threatened, Endangered and Proposed Species on the Lewis and Clark National Forest that shows no grizzly bear within the project area completes informal consultation for this species.

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Canada Lynx

Background In 2000, the FWS determined that the contiguous United States Distinct Population Segment of the Canada lynx is threatened by the inadequacy of existing regulatory mechanisms. Specifically, Forest Service Land and Resource Management Plans “include programs, practices, and activities… that may threaten lynx or lynx habitat” (Federal Register 2000). In 2005, the Recovery Outline was released, identifying the Little Belt Mountains as secondary habitat (USDI Fish and Wildlife Service 2005, Figure 1 page 21). Secondary areas are those with historic records of lynx presence with no record of reproduction, or areas with historical records and no recent surveys (USDI Fish and Wildlife Service 2005 page 4). One objective of the Recovery Outline is to ensure “that habitat in secondary areas remains available for continued occupancy by lynx” (USDI Fish and Wildlife Service 2005, page 12). The project area, the Little Belt Mountains, is currently considered unoccupied habitat (USDA Forest Service and USDI Fish and Wildlife Service 2006). Occupancy is determined when there are at least two verified lynx observations or records since 1999 on national forests, unless they are verified to be transient individuals, or when there is evidence of lynx reproduction on the national forest (USDA Forest Service 2007a). There are verified historic sightings of lynx in the Little Belt Mountains from 1979 to 1981, over 30 years ago, from trapping records. Additionally, there are observations of tracks identified as lynx from 1981 to 1997. There are no current sightings in the Little Belt Mountains. Devineau (2010) reported movements of lynx reintroduced in Colorado that were tracked into Montana. Eight of Colorado’s 218 reintroduced lynx made 10 forays into Montana, lasting from 1 to 217 days (J. Ivan e-mail to A. Rohbacher dated July 26, 2011). Three of the individuals traveled through the Lewis and Clark National Forest. In 2005 one individual spent 70 days in Montana, including, traveling in the Crazy Mountains, then went back into Yellowstone National Park via the Absaroka Mountains. In 2006, two individuals traveled around Montana before heading back in to Yellowstone National Park at the west entrance. One spent 98 days in Montana, including travelling from the Absaroka Mountains across the steppe to the Snowy Mountains, west into the Little Belt Mountains, and further west into the Big Belt Mountains. The other individual spent 217 days in the state, including travelling through the Little Belt Mountains and spending two weeks in the Madison Range before heading back into Yellowstone. These individuals are considered transient, “a lynx moving from one place to another within suitable habitat” (definition from Federal Register 2000 page 16052). In addition, these lynx are not immigrants from a naturally reproducing population, but are individuals who, after being displaced from their home ranges in Canada and released in Colorado, traveled extensively. Critical Habitat for lynx was designated in 2006 (Federal Register 2006) and revised in 2009 (Federal Register 2009). On the Lewis and Clark National Forest, Designated Critical Habitat includes the Rocky Mountain Ranger District. The remainder of the Forest, including the Little Belt Mountains where this project is located, is not within Designated Critical Habitat USDI Fish

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and Wildlife Service 2013). The proposed rule to revise the designation of critical habitat (Federal Register 2013b) 2006 and 2009, revised Designation of Critical Habitat 2013 proposed rule does not alter the critical habitat designation on the Lewis and Clark National Forest. As such, critical habitat will not be discussed for the Little Belt Mountain Hazard Tree Removal project. In 2007 the Forest Plan was amended by the Northern Rockies Lynx Management Direction (NRLMD) (USDA Forest Service 2007a) to include standards and guidelines specific to lynx in areas that are occupied. The NRLMD ROD further states that in areas of unoccupied, mapped lynx habitat, the National Forest “should consider the management direction that is now incorporated into their Forest Plans when developing projects, but are not required to follow the management direction until such time as they are occupied by Canada lynx.” (USDA Forest Service 2007a, page 29). In 2009 Regional Forester Tom Tidwell issued a memo (USDA Forest Service 2009) that directed forests currently considered unoccupied, including the Lewis and Clark National Forest, to “consider the management direction found in Attachment 1 of” the 2007 NRLMD ROD. Appendix 1 to the Biological Evaluation (available in the project record) identifies the relevant standards and guidelines that apply and were considered for the Little Belt Mountains Hazard Tree Removal Project, which includes: Standard ALL S1, Standard VEG S1 – Stand initiation structural stage limits, Standard VEG S2 – Limits on regeneration from timber management projects, Standard VEG S6 – Multi-storied stands and snowshoe hare horizontal cover, and Guideline VEG G10 – Fuel treatments in the WUI. According to the NRLMD ROD (USDA Forest Service 2007b), lynx productivity is dependent on winter snowshoe hare habitat. This habitat may be found where trees protrude above the snowline in young forests, or where limbs of the overstory touch the snowline in multistoried forests. Vegetation management activities that affect these features have the potential to affect lynx productivity. Timber harvest can be beneficial, benign, or detrimental depending on the harvest method, spatial and temporal arrangement of habitats and treatments, and the inherent vegetation potential of the site. Vegetation management objectives described in the NRLMD include providing a distribution of age classes within an LAU, maintaining a minimum quantity of relatively high-quality winter snowshoe hare habitat by limiting the amount and distribution of activities that may remove such habitat, and creating lynx/snowshoe hare habitat where it may be lacking. Since the NRLMD ROD, several research papers have been published related to Canada lynx populations in the Northern Rockies. Much of this research has been conducted by Dr. John R. Squires of the Rocky Mountain Research Station. In 2013 the Northern Region completed a discretionary review of some of the recent information (USDA Forest Service 2013c). Squires and others (2010) reported that in winter lynx used regenerating forests that were old enough to have developed a multi-storied structure with high horizontal cover that supported snowshoe hares, while in summer they also used early succession forest with high horizontal cover from abundant shrubs and small-diameter trees and dense spruce-fir saplings. Olson (and others 2011) reported on female lynx use of denning sites and effects of direct disturbance. This study is not applicable to the Little Belts Hazard Tree Removal Project, as there are no known den sites in the Little Belt Mountains. In 2012, Squires (and others) published data indicating that winter snow

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track surveys have a very high detection probability regarding the presence of lynx. Work published in 2013 (Squires and others 2013) focused on lynx movement through the landscape, particularly movement corridors that connect lynx habitat and fragmentation of habitat. They found that connectivity with the Canadian lynx population is primarily through a north-south corridor along the west side of the Bob Marshall Wilderness along the western front of the Swan Range. Because this corridor is approximately 100 miles west of the Little Belt Mountains this paper is not relevant to the project. A complete summary of the above literature can be found in the Canada Lynx – Recent Information and Papers, A Review in Relation to the Northern Rockies Lynx Management Direction, September 19, 2013 enclosure to the Northern Region’s discretionary review (USDA Forest Service 2013c).

Monitoring On March 19, 2007, the United States Fish and Wildlife Service transmitted the Service’s biological opinion on the effects of the Northern Rocky Mountains Lynx Amendment on the Distinct Population Segment (DPS) of Canada lynx (Lynx candensis) (lynx) in the contiguous United States. The biological opinion included Term and Condition #4, wherein the Forest Service shall work with the Service to develop and complete an acceptable protocol to survey currently unoccupied lynx habitat in secondary areas. In 2008, a draft lynx monitoring protocol was developed. That protocol indicates using the established USFS protocol (Squires and others 2004) during winter in more accessible areas or the established USFS protocol (McDaniel and others 2000) during the summer period in areas that are unavailable for winter sampling. Lynx surveys were conducted in the Little Belt Mountains in February and March of 2010 using the established USFS protocol for use during winter. Lynx were not detected during the surveys. A report of the survey results was completed (USDA Forest Service 2012a). Because the surveys did not meet protocol, as described in the survey report, the forest again conducted surveys in the Little Belt Mountains from February to April, 2013. A report of those surveys concluded that based “on the conditions at the time of survey, the quality of the habitat surveyed, and the species detected during the survey other than lynx, the surveys conducted in the western portion of the Little Belt Mountains are adequate in determining that lynx were not present at the time the surveys were conducted in 2013. The drier, lower quality habitat in the eastern portion of the Little Belt Mountains would need further surveys to determine lynx presence, either using the snow-track protocol if conditions became amenable, or the summer survey protocol described in McDaniels and others (2000)” (USDA Forest Service 2013b).

Methodology Analysis Area The Little Belt Mountains include 21 Lynx Analysis Units (LAUs) comprised of 547,800 acres, or 61 percent of the land base. The lynx analysis was carried out at the scale of the Little Belt Mountains, with direct and indirect effects analyzed within each impacted LAU. The Little Belt Mountains is the appropriate cumulative effects analysis area for lynx because it is a sufficient size to consider how effects from the project could, when considered with other actions within the LAUs, cumulatively affect the species. It also includes all of the proposed treatment areas.

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The Canada Lynx Conservation Assessment and Strategy recommended that LAUs be identified for all areas with lynx habitat “to provide analysis units of the appropriate scale with which to begin the analysis of potential direct and indirect effects of projects or activities on individual lynx, and to monitor habitat changes” (Ruediger and others 2000 page 73). Table 8 displays the habitat in each LAU by ownership and habitat category. Non-habitat within LAUs, consisting of natural openings, cliffs, rock slides and sparsely vegetated areas lacking significant understory, is displayed. Definitions of the habitat categories are located in the glossary of the NRLMD ROD (USDA Forest Service 2007b, Attachment 1, pages 10-15).

Table 8: Existing Habitat in LAUs within the Little Belt Mountains by Ownership

Total LAU owner

acres

stand

Acres Acres

storied

habitat

initiation initiation

exclusion

Acres non Acres

Acres stem stem Acres

Acres early early Acres

mature/late mature/late

Acres stand stand Acres

successional Acres multi Acres

LB1 Private 30.4 0.8 4.4 0 19.0 0 6.2 USFS 25778.1 4319.0 0 758.0 14439.6 1491.9 4769.5 Total 25808.5 4319.8 4.4 758.0 14458.6 1491.9 4775.7 LB2 Private 5040.3 3201.1 146.9 0 1413.1 0 279.0 State 319.3 229.4 0 0 61.1 0 28.8 USFS 27590.1 2007.0 175.5 1401.1 17159.4 126.4 6720.7 Total 32949.7 5437.5 322.4 1401.1 18633.6 126.4 7028.5 LB3 Private 3376.8 2621.2 31.4 0 621.8 0 34.7 USFS 16027.4 1474.4 13.9 0.1 10164.5 32.7 4341.6 Total 19404.3 4095.6 45.3 0.1 10786.3 32.7 4376.3 LB4 Private 1601.2 408.0 54.9 0 866.9 0 271.4 USFS 30403.3 4587.2 1.4 1477.1 13072.3 212.1 11053.2 Total 32186.7 5170.5 59.7 1477.1 13942.0 212.1 11325.2 LB5 Private 1247.8 887.7 27.9 0 153.4 0 178.8 USFS 14797.3 3219.6 367.1 268.6 8093.1 512.5 2336.4 Total 16045.1 4107.3 395.0 268.6 8246.5 512.5 2515.3 LB6 Private 3090.2 192.4 213.4 0 2138.0 0 472.2 USFS 15984.4 1871.2 3.2 20.8 9495.3 2138.5 2515.7 Total 19074.7 2063.7 216.6 20.8 11633.2 2138.5 2987.8 LB7 Private 242.1 68.6 19.8 0 134.7 0 18.8

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Total LAU owner

acres

stand

Acres Acres

storied

habitat

initiation initiation

exclusion

Acres non Acres

Acres stem stem Acres

Acres early early Acres

mature/late mature/late

Acres stand stand Acres

successional Acres multi Acres

USFS 25908.6 822.7 709.6 769.6 15900.2 82.4 7623.9 Total 26150.7 891.3 729.4 769.6 16035.0 82.4 7642.8 LB8 Private 4344.5 991.2 279.8 0 2988.5 0.2 84.7 USFS 21771.5 1375.5 488.0 2233.2 10601.4 2680.3 4393.0 Total 26115.9 2366.7 767.8 2233.2 13589.9 2680.5 4477.7 LB9 Private 39.4 36.7 2.6 0 0 0 0 USFS 20761.1 1156.7 685.3 3295.6 4221.7 4126.9 7274.9 Total 20800.5 1193.5 687.9 3295.6 4221.7 4126.9 7274.9 LB10 Private 1072.8 572.7 22.3 0 172.0 0.1 305.7 USFS 25179.8 4738.4 378.1 183.4 11648.1 3298.2 4933.6 Total 26252.6 5311.1 400.4 183.4 11820.1 3298.3 5239.3 LB11 Private 473.8 55.7 38.8 0 265.0 0 114.2 USFS 26988.7 4515.0 976.6 45.3 15853.5 666.5 4931.8 Total 27462.5 4570.6 1015.4 45.3 16118.5 666.5 5046.0 LB12 Private 2569.8 1272.7 421.1 0.1 746.3 0 118.9 USFS 18477.6 1245.3 389.8 774.6 13799.9 13.0 2255.2 Total 21047.4 2518.1 810.9 774.7 14546.1 13.0 2374.1 LB13 Private 2739.4 1522.6 284.2 0.1 568.8 0 315.4 USFS 32971.3 1102.0 5241.1 5627.1 14170.4 2069.7 4761.0 Total 35710.7 2624.6 5525.3 5627.3 14739.1 2069.7 5076.4 LB14 Private 816.7 535.9 59.5 0 151.4 0 70.0 USFS 26914.9 1721.6 671.3 4112.4 8963.5 2795.6 8650.6 Total 27731.6 2257.6 730.8 4112.4 9114.9 2795.6 8720.6 LB15 Private 228.3 17.8 20.5 0 57.2 0.1 132.8 USFS 31160.9 4678.1 238.5 1153.2 10899.6 4896.9 9294.7 Total 31389.2 4695.9 259.0 1153.2 10956.7 4896.9 9427.5

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Total LAU owner

acres

stand

Acres Acres

storied

habitat

initiation initiation

exclusion

Acres non Acres

Acres stem stem Acres

Acres early early Acres

mature/late mature/late

Acres stand stand Acres

successional Acres multi Acres

LB16 USFS 24047.1 2084.7 3776.3 1773.1 8924.4 1122.4 6366.1 LB17 USFS 34793.1 5302.6 8387.2 160.7 9876.9 2179.5 8886.0 LB18 Private 405.8 307.3 2.6 0 39.8 0 56.2 USFS 31367.0 4112.1 4810.9 3146.0 10296.4 2723.1 6278.3 Total 31772.9 4419.3 4813.5 3146.0 10336.3 2723.1 6334.5 LB19 Private 47.3 38.2 0 0 6.1 0 3.0 USFS 20138.2 2501.5 1453.5 1561.1 7654.2 1947.9 5020.1 Total 20185.6 2539.7 1453.5 1561.1 7660.3 1947.9 5023.1 LB20 USFS 21105.6 2082.0 23.8 1.5 16853.7 410.8 1733.7 LB21 USFS 27958.3 6777.2 0 0 19458.2 247.9 1475.0

Analysis Methods Habitat within the Little Belt Mountains was analyzed using Geographic Information Systems (GIS) software, based on vegetation information recorded in the Timber Stand Management and Record System (TSMRS) database and VMap. Using protocols established at the Regional level and based on information derived from Reudiger et al. (2000), potential lynx habitat was identified for the entire Jefferson Division. The Wildlife Vegetation Jefferson Division (WildVeg) data set (project record) was developed from queries of the TSMRS database. Those queries identified cover classes which were then used to determine early stand initiation, stand initiation, mature or late successional, multi-storied, stem exclusion, or non-habitat categories as defined by the NRLMD ROD. The NRLMD ROD defines ‘habitat in an unsuitable condition’ as habitat in the stand-initiation structural stage, habitat with trees generally less than 30 years old, or other habitat in which trees are not tall enough to protrude above the snow during winter. Such habitats have the potential to develop into snowshoe hare habitat over time. Information regarding recent harvest and fire activity that may have affected lynx habitat was considered, and the estimated acreage of lynx habitat that is currently suitable was adjusted accordingly. The existing, WildVeg-based habitat map represents the best available means by which to estimate lynx habitat over a relatively broad scale, such as the scale of a Lynx Analysis Unit (LAU), a ranger district, or an entire National Forest. Additional stand information obtained from VMap allows refinement of the map and inclusion of data on private lands. Field data collection, however, is the best way to identify specific stands of foraging habitat within mapped denning habitat, and to identify mature, multi-story snowshoe hare habitat at the scale of the project unit.

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Field data collection using horizontal cover boards also remains the best method by which to determine compliance with the NRLMD VEG S6 Standard where it is applicable.

Existing Condition Table 8 displays lynx habitat, based on the cover class coding from the WildVeg data set and data from VMap, within LAUs in the Little Belt Mountains (data from LBMLynxAnalysisData2013.pdf). Habitat not currently suitable includes stands in the early stand initiation structural stage where the vegetation is not yet tall enough to provide habitat for snowshoe hare. Non-habitat includes natural openings, dry forest types, and other areas that are not now and are not expected to ever provide lynx habitat due to their inherent vegetation potential. Existing Condition relative to the applicable NRLMD Standards and guidelines Standard VEG S1 - Table 8 displays the type and acreage of existing lynx habitat on National Forest System lands in the Little Belt Mountains. Habitat that is not currently suitable (in the early stand initiation structural stage that does not provide winter snowshoe hare habitat) was determined from the lynx habitat map and from information about recent vegetation management and wildfire activity. Lynx habitat is not mapped on the state and privately owned lands within the LAU. Vegetation on these lands, however, are included in the VMAP vegetation map. The VMAP data includes information on tree size (diameter at breast height), canopy closure, and dominant species, but does not have information on tree height, horizontal cover, or other understory characteristics. Areas mapped with a tree size of 0-4.9” diameter at breast height (dbh) were included in the early stand initiation stage. This likely overestimates the actual acres in stand initiation structural stage. All of the Little Belt Mountain LAUs are currently consistent with Standard VEG S1 (see BE Little Belts Appendix 1 in the project record for the full text of standards and exceptions). Standard VEG S2 – Within the last 10 years there have been 1789 acres of regeneration harvest activities across the Little Belt Mountains, in seven different LAUs (Data of past activities from FACTS). LAU LB16 has the most acres of past regeneration (1296 acres or 5.9 percent, see LBMLynxAnalysisData2013.xlsx). All of the Little Belt Mountain LAUs are currently consistent with Standard VEG S2 (see BE Little Belts Appendix 1 for the full text of standards and exceptions). Standard VEG S6 – Proposed treatment areas were reviewed to determine if they contained mature, late successional forest, or multi-storied forest (see LBMLynxAnalysisData2013.xlsx). There are a total of 3,422 acres of potential mature, late successional or multi-storied habitat in proposed treatment areas. Horizontal cover board surveys will be conducted in these areas prior to treatment to determine if they provide snowshoe hare habitat. Fuels Treatment exceptions for VEG S1, VEG S2, and VEG S6 - Table 9 displays the total acres of mapped lynx habitat at different scales on the forest. Six percent of the total lynx habitat on the Lewis and Clark National Forest is 59,884 acres. Use of fuel treatment

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exceptions for VEG S1. VEG S2, VEG S5 and Veg S6 should not exceed 59,884 acres forest-wide (see BE Little Belts Appendix 1 for the full text of the NRLMD standards). The table includes information for the Little Belt Mountains, the Jefferson Division of the Forest (Little Belt, Castle, Crazy, Highwood, and Snowy Mountains), and the planning unit (Lewis and Clark National Forest) in order to show potential impacts at varying scales of reference. In the Little Belt Mountains, 37.1 acres of exception were applied in the Blankenship Project. The Benchmark Fuels Reduction Project on the Rocky Mountain Division included 43 acres of WUI exception. Table 9: Acres of Lynx Habitat by Planning Unit Little Belt Jefferson Lewis and Clark Mountains Division National Forest Total Acres 547,996.5 792,279.3 1,482,024.9 Acres Lynx habitat 458,324.8 619,427.4 998,072.9 6 percent of lynx Not applicable Not applicable 59,884.4 habitat Acres WUI exception 37.1 37.1 80.1

Alternative 1 Effects Under the no action alternative, natural processes will continue. Trees across the Little Belt Mountains will continue to be killed by mountain pine beetle and spruce budworm. The greatest impact will be in pure pine stands, which because of their dryer conditions generally do not provide lynx habitat. In mixed stands loss of pine trees will reduce overstory canopy, increase the number of snags, and increase the amount of downed logs as the trees fall beginning 3 to 5 years from death. Loss of canopy would allow sunlight to reach the forest floor, and may result in increased regeneration of shade intolerant species such as lodgepole and white bark pine. This may increase habitat for snowshoe hare over time. Spruce budworm activity has resulted in loss of understory trees in spruce and fir stands. This would reduce snowshoe hare habitat. It is not possible to predict where losses of hare habitat would occur. Changes due to natural processes would be cumulative to other vegetation projects in the Little Belt Mountains (such as Blankenship, Ettien Ridge, and Belt Creek Range). All of these projects maintain lynx habitat in the Little Belts.

Alternatives 2 and 3 Effects Table 10 displays the acres of lynx habitat within proposed treatment areas by LAU. Please see the Biological Assessment completed for this project for additional information on the project effects to lynx and lynx habitat.

Direct and Indirect Effects Under Alternative 3 only dead hazard trees will be felled. Removal of dead trees will not alter available lynx habitat. Late successional or mature multi-storied stands that provide snowshoe

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hare habitat, as used by lynx in the winter (Squires and others 2010) that maintain a live overstory will remain. Only individual snags will be removed. Removal of snags will not alter snowshoe hare habitat in winter or summer, as snowshoe hare use dense green forests. Removal of snags will reduce nesting cavities for lynx’s alternate prey, red squirrel, in treatment areas. However this will occur on only 1.9 percent of the mapped lynx habitat in the Little Belt Mountains distributed across 21 LAUs. In addition, snag levels across the Jefferson Division of the forest average 861 snags per 100 acres over 10 inches diameter at breast height, and 201 snags per 100 acres over 15 inches in breast height (Table 12). Snag levels will remain adequate to provide nesting cavities for red squirrel across the Little Belt Mountains. Removal of the hazard trees will not regenerate forest (Standards VEG S1 and VEG S2), or remove existing snowshoe hare habitat (Standard VEG S6). Table 10: Acres of lynx habitat within proposed treatment areas and NRLMD Standard and Guidelines Results post-implementation LAU Acres habitat VEG S1 – VEG S2 – percent VEG S6 – acres within proposed percent early LAU regenerated potential mature, treatments stand initiation last 10 years late successional, or multi-storied habitat in treatment areas LB1 263.3 (1.2%) 0.2 % 0.2 % 218.9 LB2 344.4 (1.3%) 1.9 % 0.8 % 35.0 LB3 246.7 (1.6%) 0.9 % 0.7 % 87.6 LB4 660.8 (2.4%) 0.8 % 0.6 % 309.8 LB5 53.3 (0.4%) 3.4 % 0.1 % 10.1 LB6 67.8 (0.4%) 1.5 % 0.3 % 34.8 LB7 466.3 (1.8%) 4.6 % 1.7 % 140.2 LB8 679.2 (2.9%) 5.0 % 2.0 % 140.6 LB9 1301.2 (6.6%) 8.1 % 4.6 % 598.2 LB10 459.2 (2.2%) 2.4 % 0.5 % 150.6 LB11 220.3 (1.0%) 4.6 % 0.2 % 17.2 LB12 380.4 (2.1%) 6.0 % 2.0 % 70.8 LB13 1479.6 (4.5%) 19.1 % 3.4 % 347.5 LB14 1677.2 (6.6%) 5.2 % 2.6 % 536.9 LB15 184.8 (0.7%) 1.3 % 0.3 % 116.3 LB16 889.0 (4.0%) 19.1 % 7.8 % 195.9

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LAU Acres habitat VEG S1 – VEG S2 – percent VEG S6 – acres within proposed percent early LAU regenerated potential mature, treatments stand initiation last 10 years late successional, or multi-storied habitat in treatment areas LB17 44.4 (0.2%) 28.6 % 0.2 % 9.7 LB18 808.9 (3.0%) 3.2 % 1.5 % 248.0 LB19 431.3 (2.4%) 9.2 % 1.3 % 154.3 LB20 0 0.1 % 0 % 0 LB21 0 0 % 0 % 0

Under Alternative 2 hazard trees are defined more broadly and include trees with dead tops, dwarf mistletoe, structural defects, and in lodgepole stands, green trees if the removal of hazard trees results in less than 40 square foot basal area remaining. This definition would result in more trees being felled, although still would not result in large scale changes to the stand structure. In lodgepole pine stands, removal of the overstory if the stand is reduced below 40 square foot basal area will not remove snowshoe hare habitat. Four representative lodgepole pine stands were run through the Forest Service’s FVS (Forest Vegetation Simulator) program to simulate a removal of trees greater than 5 inches diameter with a resulting basal area in larger trees of 40 square foot or less (see project record HazTreeFVS_121313.docx). The program provides a visual depiction of the stands before, immediately after and ten years after treatment. These indicate that multi-storied stands (such as 006 and 020) with an understory that provides snowshoe hare habitat will continue to provide hare habitat post treatment, as the understory will not be treated. Single storied stands (such as 001 and 009) will not provide snowshoe hare habitat as the basal area of green trees approaches 40 square feet because the trees are too widely spaced and do not provide high horizontal cover. There is a potential for removal of lodgepole pine stands to regenerate forests. For this analysis, it was assumed that all lodgepole stands with greater than 5” dbh size class within proposed treatment areas would be clear cut (a total of 5,243 acres). Over time (15 to 40 years) these stands would provide habitat for snowshoe hare where it might not currently exist as they regenerate. Table 10 shows the resulting percentages of early stand initiation and forest regenerated (also taking cumulative effects into account). In actuality, not all stands would be removed. The proposed action is to remove hazard trees within campgrounds, recreation residence and administrative sites and along roadsides. These sites have a long history of human use, with associated clearing of trees and removal of downed wood and snags for fuelwood. Project implementation would result in a reduction in large woody debris recruitment for denning habitat. Loss of future downed woody debris near roads and campgrounds is not expected to greatly alter the potential of the treated areas to be used by lynx in the future, as roadside areas and areas with high human use are not considered high quality habitat. Removal of the hazard

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trees may result in faster natural regeneration of the areas, by allowing more sunlight to the forest floor. This can also increase forb and grass growth which can suppress seedling establishment. No verified lynx records have been reported in the Little Belt Mountains since 1982, or for over 30 years. Surveys in 2013 of the western portion of the mountain range did not detect lynx. Therefore the probability of lynx occurring in this area during the project, or being affected by the project is low. However unlikely, if transient lynx were to come into the project area during implementation, lynx may be affected by the noise and activity generated by the Project. Because these lynx are traveling and would use very large areas for foraging they would be able to move to an undisturbed area of the project area, or portion of the Little Belts mountain range. For these reasons, this potential disturbance is not expected to result in significant effects to transient lynx or reduce an individual’s ability to move through the area. NRLMD compliance Standard ALL S1 - The Northern Rockies Lynx Planning Area map (USDA Forest Service 2007, Figure 1-1) displays linkage zones. For the Little Belt Mountains, those linkage zones are to the Big Belt Mountains to the west, to the Castle and Crazy Mountains to the south, and to the Big Snowy Mountains to the east. The proposed treatment areas maintain lynx habitat (Table 8 and Table 10) within the Little Belt Mountains. Movement between LAUs, if lynx again occupy the Little Belt Mountains, is maintained as proposed treatments are along roads where vegetation is already impacted and the project will result in irregular openings at irregular intervals along the roads, thereby also leaving irregular patches of forest cover for movement. The project will not result in large tracks of widely spaced trees that could impede lynx movement through an area (Squires and others 2013). Standard VEG S1 - As previously discussed, the Little Belt Hazard Tree Removal Project, Alternative 2, would result in up to 5,243 acres of regeneration of lodgepole pine stands. If all these acres are regenerated, the 21 LAUs in the Little Belt Mountains would have from 0 to 28.6 percent of lynx habitat in an early stand initiation stage (Table 10 and LBMLynxAnalysisData2013.xlsx available in project record). This is less than 30 percent limitation in an LAU and is consistent with Standard VEG S1. Standard VEG S6 – The Little Belt Hazard Tree Project proposed treatment areas include 12,586.7 acres of LAUs, of which 10,659.5 acres (85%) is mapped lynx habitat (Table 10). Of this, 3,422.4 acres (32%) is mapped as potential mature, late successional, or multi-storied habitat. Prior to treating in these areas, horizontal cover board measurements will be taken and in stands that are currently providing snowshoe hare habitat, only dead hazard trees will be removed (Alternative 3 definition). Therefore, no snowshoe hare habitat will be removed under this proposed action. Guideline VEG G10 – This project does not propose any treatments within the WUI that do not meet Standards. Standards VEG S1, VEG S2, and VEG S6 will be met with this proposed action.

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Cumulative Effects Within the Little Belt Mountains, other ongoing vegetation management projects include Monarch-Neihart, Mass Geis, Showdown Hazard Tree, Sheep Creek Aspen, Ettien Ridge, Whitetail, and Blankenship. These projects either are consistent with the Northern Rockies Lynx Management Direction (USDA Forest Service 2007a) or are not within LAUs. The Blankenship project is expected to alter approximately 1.4 percent of LB4, and therefore up to 4.0 percent of that LAU would be altered cumulatively. The other projects have equally small areas impacted, and none would cumulatively create more than 30% of any LAU in a stand initiation structural stage (Table 10). Past activities such as harvest, fire, wind damage and broadcast burning altered habitat for lynx. Those alterations are accounted for in the existing condition. Potential mountain pine beetle mortality may result in the loss of denning and foraging habitat in the Little Belt Mountains, as well as loss of potential red squirrel habitat. The pine beetle epidemic may also increase lynx foraging and denning habitat in the future as regeneration occurs, and by creating pockets of downed timber suitable for denning. The extent of habitat change due to mountain pine beetle-caused mortality cannot be quantified or predicted at this time. Firewood gathering can result in loss of downed wood in the project area. Most firewood gathering occurs close to roads, where access is easier. It is unlikely that lynx would use down wood near roads for denning, however firewood gathering can add to the loss of downed woody debris due to hazard tree removal. The Block P mine tailings reclamation project, travel management, grazing, Bender Creek Trailhead development, Oti Park Trail, and recreation do not result in a changes to lynx habitat, therefore do not contribute to cumulative effects to lynx habitat. NRLMD Compliance All standards and guidelines of the NRLMD (USDA Forest Service 2007a) are met under the proposed action (see BE Little Belts Appendix 1). Standard ALL S1 – Within the Little Belts, other vegetation treatment projects include the planned Belt Creek Range project, Mass-Geis, Blankenship, and other projects listed in the past, present, and reasonably foreseeable spreadsheet in the project record. These projects, taken cumulatively with the proposed Little Belt Hazard Tree Removal Project, do not alter lynx linkage areas (USDA Forest Service 2007, Figure 1-1). Movement between LAUs would be maintained as forested habitats are maintained. There are no large scale clearcuts, or blocks of habitat, removed and habitat connectivity is maintained. Standard VEG S1 – As stated previously in this document, Standard VEG S1 requires the lynx analysis to consider past actions, primarily regeneration harvest and stand replacing fire, to determine how much of the LAU is in a stand initiation structural stage that does not yet provide winter snowshoe hare habitat. The analysis considers past regeneration harvest, prescribed burning, and wildland fire where vegetation has not yet regrown tall enough to provide winter snowshoe hare habitat. As such, Standard VEG S1 is an integral component of a cumulative effects analysis for lynx and lynx habitat. Table

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10 displays the amount of each LAU in an early stand initiation structural stage. All LAUs in the Little Belt Mountains are below the 30 percent threshold of Standard VEG S1. Standard VEG S2 - The proposed Alternative 2 would regenerate up to 5,243 acres. Other regeneration (Blankenship Project, Mass Geis, Monarch, etc.) is considered in Table 10 (further detail available in LBMLynxAnalysisData2013.xlsx in the project record). Standard VEG S2 is met. Standard VEG S6 – All potential mature, late successional or multi-storied habitat will be surveyed to determine if it provides snowshoe hare habitat prior to implementation. No hare habitat will be removed with the proposed action, therefore it will not add cumulatively to the 37.1 acres treated from the Blankenship Project within the WUI in LAU LB4 under the fuels exception of Standard VEG S6. Nor would it add to the forty- three acres proposed for treatment in the Benchmark Fuels Reduction Project on the Rocky Mountain Division (outside the cumulative effects analysis area), which would bring the total exceptions to this standard to 80.1 acres, well below the 6 percent allowed, as displayed Table 9 above.

Conclusion I have determined implementation of the proposed Federal Action may affect, but is not likely to adversely affect Canada Lynx. The proposed action will have no effect on lynx Designated Critical Habitat. Guidance provided in the Endangered Species Consultation Handbook (USFWS and NMFS 1998, page 3-12) indicates that this is the appropriate conclusion when effects on listed species are expected to be discountable, or insignificant, or completely beneficial. Discountable effects are those that are extremely unlikely to occur. Insignificant effects relate to the size of the impact and should never reach the scale where take occurs. Beneficial effects are positive effects without adverse effects to the species. My determination is based on the following rationale: Lynx have not been verified in the action area in over 30 years and are not likely to be found in the action area during project activities If lynx enter the action area during project activities they would be transient lynx The project occurs in secondary lynx habitat Although disturbance is possible, the transient nature of lynx in the mountain range and the fact that no lynx have been found in over 30 years in the project area indicate the likelihood of this effect to be unlikely (discountable effect) There would be no reduction in mature or late successional, multi-storied habitat with high horizontal cover from the project. The project occurs on a small area of the landscape (less than 2 percent of the project area) (insignificant effect) Over time (15 to 40 years) the amount of snowshoe hare habitat will be increased in the project area over existing conditions as up to 5,243 acres of lodgepole pine would be regenerated (beneficial effect) The project maintains connectivity of lynx habitat in the Little Belt Mountains

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There are no proposed actions within lynx linkage areas Although downed woody debris recruitment for denning habitat would be reduced near roads and recreational areas, these areas provide low quality habitat for lynx denning due to the proximity of human uses. Recruitment of downed woody debris for denning habitat away from roads and reacreational sites is increasing due to the mountain pine beetle epidemic (beneficial effect) The project would not remove snowshoe hare or red squirrel habitat. In the short term (5 to 15 years) prey levels would be unchanged for transient lynx should they occur in the project area Per Forest Service direction (USDA Forest Service 2009) the standards and guidelines of the NRLMD are met within the project (see BE Little Belts Appendix 2) providing suitable habitat in secondary areas (USDI Fish and Wildlife Service 2005) for available use by transient lynx. This determination is a conservative estimate of the projects potential to effect Threatened Canada lynx as surveys did not detect lynx in the project area, there have been no verified lynx sightings in the project area since 1982, and the effects, as shown above, are beneficial, discountable, or insignificant.

Bighorn Sheep Effects Bighorn sheep occur on the Rocky Mountain Front of the forest. Bighorn sheep are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Populations do not occur in or near the Little Belt Mountains. As such, there would be No Impact on bighorn sheep from the Little Belt Mountains Hazard Tree Removal Project.

Fisher Effects There are no records of fisher in the Little Belt Mountains and the project area is outside the known range of this species. Therefore, there would be No Impact on fisher.

Wolverine On February 4, 2013 the USFWS proposed to list the distinct population segment of the North American wolverine in the contiguous Unites States as a threatened species under the Endangered Species Act (ESA) (Federal Register 2013). The wolverine is managed as a furbearer by MFWP, and has been documented in the Little Belt Mountains. On August 13, 2014, the USFWS withdrew its proposal to list the wolverine under the Endangered Species Act (Federal Register 2014). Recent literature indicates that persistent snow cover through the reproductive season is the most reliable predictor of wolverine presence (Copeland and others 2010, Federal Register 2013 pages 7867, 7880). This habitat is found at high elevations near the coniferous forest tree line and in rocky alpine habitats (Federal Register 2013, page 7867). It is noted that wolverines may occupy lower elevation forested habitats seasonally, although they never den in these locations (Federal Register 2013, page 7867). Schwartz and others (2009, figure 4) display the wolverine dispersal routes that correspond to habitat suitability in the northern Rocky Mountains (Federal Register

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2013 page 7878). Two-lane highways or roads with less improvement are not absolute barriers to wolverine movement and dispersal (Federal Register 2013 page 7879), although development of transportation corridors in linkage areas may inhibit wolverine movements between habitat patches. Ninety-four percent of the total wolverine habitat is in Federal ownership, primarily managed by the Forest Service (Federal Register 2013 pg. 7874). Because a systematic population census over the entire current range of wolverines in the contiguous United States does not exist, the current population level and trends are not known with certainty (Federal Register 2013 pg. 7868). The current population is estimated at 250 to 300 individuals, which is believed to be close to the density found in these same areas prior to European settlement (Federal Register 2013, page 7868). Early genetic work in Montana identified three wolverine subpopulations (Cegelski and others 2003 page 2913). Schwartz and others (2009) suggest that Montana has one population that is genetically structured by both distance and ecological factors. This results in occasional exchanging of individuals between areas, but with a limitation on interbreeding due to the large distances and frequent unsuitable habitat that separates populations (Federal Register 2013 pages 7884-7885). This work suggests that the population of wolverine in the Little Belt and Crazy Mountains has some degree of isolation from other populations. The Proposed Listing for wolverine (Federal Register 2013) addressed the five factors for determining if a species is threatened or endangered and identified threats to wolverine in the contiguous United States. Table 11 displays the potential threats considered in the Proposed Listing. Table 11: Potential Threats to the Contiguous United States Wolverine Population and Results of the 12-Month Finding (Federal Register 2013, pages 7874-7886) Threat (Factor) Finding Climate Change (Factor A) Primary threat Habitat Impacts Due to Human Use and Disturbance (Factor A) – four categories (1) dispersed recreation activities with primary impacts to wolverines Not a threat through direct disturbance (e.g. snowmobiling and heli-skiing); (2) disturbance associated with permanent infrastructure such as Not a threat residential and commercial developments, mines and campgrounds); (3) disturbance and mortality associated with transportation corridors; Not a threat and (4) disturbance associated with land management activities such as Not a threat forestry, or fire/fuels reduction activities. Harvest (Factor B) (i.e. trapping) Secondary threat

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Threat (Factor) Finding Disease and Predation (Factor C) Not a threat Inadequacy of Existing Regulatory Mechanisms to climate change (Factor Primary threat D) Small Population Size (Factor E) Secondary threat

As shown in Table 11, one primary threat to the wolverine distinct population segment (DPS) was identified: climate change. Other threats are secondary and only rise to the level of threats to the DPS as they may work in concert with climate change to affect the conservation status of the species (Federal Register 2013 page 7885-7886). Because wolverine are not dependent on specific vegetation or habitat features, land management activities such as grazing, timber harvest, and prescribed fire were determined not to be a threat to wolverine (Federal Register 2013 page 7879). Occupied wolverine habitat supports a number of uses that may contribute to disturbance. Available information suggests that wolverine can co-exist with some level of human disturbance and will adjust to moderate habitat modification, infrastructure development, and human disturbance (Federal Register 2013 pages 7877, 7880, and 7883). Human disturbances are also present in habitat used for dispersal and exploratory movements (Federal Register 2013 page 7883). Small population size and inbreeding depression were identified as potential threats to wolverines in the contiguous United States. Evidence indicates that genetic diversity is lower in wolverines in the DPS than in the more contiguous habitat in Canada and Alaska (Federal Register 2013 page 7885). The island mountain ranges of central and southwestern Montana, including the Little Belt Mountains, have smaller populations and available habitat is more isolated (Federal Register 2013, page 7876). Forest Plan monitoring item C-7 requires monitoring of “Furbearer Special Interest (Lynx and Wolverine) distribution” from sightings reports; further evaluation is to occur when no sighting information is reported for 3 years (USDA Forest Service 1986, page 5-11). In 2010, during lynx surveys in the Little Belt Mountains, wolverine tracks were observed at Monument Lookout (2/27/2010) and Logging Creek (2/26/2010). In 2012, wolverine tracks were observed in the vicinity of Kings Hill (B. Gliko, personal communication 1/9/2013). On the Rocky Mountain Front, the Natural Heritage Tracker database identifies a wolverine harvested during the 2010-11 trapping season, and an individual observation from July 2010 (see project record). No further evaluation of the Forest Plan is required for wolverine at this time. The Wolverine Habitat Map (available in the project record) displays the proposed Hazard Tree Removal Project treatments in relation to Copeland and other’s (2010) model of persistent snow cover. In total, there are approximately 241,500 acres (27 percent) of potential habitat in the Little Belt Mountains as indicated by the persistent snow cover. Of those acres, there are 6,759 acres of proposed treatment areas that are within potential wolverine habitat, or 3 percent of the potential habitat. In the Little Belt Mountains there are 1,514 acres of modeled denning habitat.

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The proposed roadside treatment areas include 12 acres (less than 1 percent) of modeled denning habitat.

Alternative 1 Effects Under the no action alternative mountain pine beetle activity would continue to create snags and spruce budworm would continue to defoliate trees, both of which would result in the death of smaller trees and dead tops in some larger trees. Firewood cutters would likely remove some dead trees along roads, particularly in areas closer to towns and residences. Disturbance associated with firewood cutting is sporadic and short term, and considered a low level disturbance. This activity could result in any wolverine in the area of the activity adjusting their use away from the activity temporarily; although, it is expected that wolverine would use areas of previous disturbance again. As wolverine are not limited by specific vegetation or geologic features, and as wolverine can co-exist with moderate human disturbances, the no action alternative would not jeopardize the wolverine.

Alternatives 2 & 3 Direct and Indirect Effects Under both action alternatives, three percent of potential wolverine habitat, and less than 1 percent of modeled natal denning habitat are within proposed treatment areas. The treatment areas are not large blocks of habitat, but occur in strips along roads. Under both alternatives trees would be felled along roads and some trees will be decked and hauled. Removal of large trees would result in a loss of future potential denning habitat (large downed wood) however wolverine den sites are typically found in secluded areas away from roads so the value of the removed material as future den habitat is quite low. Under both action alternatives disturbance levels in the Little Belt Mountains would be increased by felling, decking and hauling activities. The disturbance will not occur across the whole mountain range at once. Activities have been grouped in areas, and work within each area will proceed at different times. Within each area disturbance during the winter months is limited to a single drainage at a time where elk wintering habitat occurs. This project does not propose any new roads. Under Alternative 2 there will be some areas along the roads where all vegetation (i.e. certain lodgepole pine stands) would be removed. Openings along roads would occur in an irregular pattern and would be no more than 300 feet wide. Wolverine may avoid crossing these wider openings, depending on conditions such as other activities present and time of year. As indicated above, two-lane highways or roads with less improvement are not absolute barriers to wolverine movement and dispersal (Federal Register 2013 page 7879). Alternative 2 would not create barriers to dispersal and movement. Under Alternative 3, only dead trees would be removed. This alternative is not expected to result in wider openings along the roads. The Little Belt Mountains is an isolated mountain range where small population size, in concert with climate change, can pose a threat to wolverine. In the case of the Little Belts, connectivity to other habitat islands is necessary for exchange of genetic information. Individuals will

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preferentially travel in year round habitat, but are known to travel in valley bottoms, across transportation corridors, and through human-dominated landscapes (Federal Register 2013, pages 7868, 7879 and 7890). Project related activities are not expected to interfere with dispersing individuals. Disturbance does not seem to be a concern to dispersing wolverine (Federal Register 2013), and any activities occurring during an individual’s dispersal or exploratory movements are not expected to result in avoidance of an area or a change in dispersal path. Cumulative Effects Past vegetation projects (such as Mass Geis, Monarch-Neihart, and Whitetail Salvage) resulted in changes in vegetation in the Little Belt Mountains. These vegetation changes are cumulative to the changes currently occurring as a result of mountain pine beetle and spruce budworm. Additional vegetation changes will also occur from firewood gathering, slashing and burning in Sheep Creek Aspen, Musselshell Range, and Belt Creek Range projects, as well as implementation of projects such as Blacktail Hills and Whitetail Salvage. Please see Appendix C for a complete list of projects occurring in the Little Belt Mountains that are considered under cumulative effects. Removal of hazard trees in this project also adds to the vegetation changes. Because wolverine are not dependent on specific vegetation characteristics, these cumulative changes are not expected to result in a loss of habitat for the species. Travel planning completed in 2007 for the Little Belt Mountains limited snowmobile use in some mapped natal denning habitat to reduce potential disturbance to wolverine. Other wolverine habitat, such as that in the vicinity of Showdown Ski Area, experiences moderate to, at times, heavy, concentrated human disturbance. Wolverine continue to be observed in the vicinity of Showdown (B. Gliko, personal communication 1/9/2013) and elsewhere in the Little Belts as described above. Disturbance will also occur from implementation of other vegetation projects, such as slashing and burning associated with Sheep Creek Aspen, Musselshell Range, Belt Creek Range, and Ettien Ridge, as well as implementation of trail projects such as Bender Creek Trailhead Development and Oti Park Trail. Disturbance from project implementation would add to the existing level of disturbance in the Little Belts, however it is expected that the wolverine would adjust to the added disturbance. Implementation of this project would contribute to the ongoing disturbance in the project area due to mining and mine reclamation, firewood gathering, summer and winter dispersed and developed recreation, and use of private inholdings. Disturbance is concentrated in some areas and seasons (e.g. Showdown Ski Area and Silvercrest Winter Recreation area), and spread out in other seasons (e.g. big game hunting season). However, because wolverine co-exist with human disturbance and adjust to moderate levels of disturbance, and their home ranges are large with available connecting year-round habitat (see Wolverine Habitat Map), the potential disturbance is not expected to impact wolverine populations. The Little Belt and Crazy Mountain populations of wolverine experience a certain level of isolation from other, larger wolverine populations in the state of Montana due to distances and the isolated nature of suitable habitat in the area. Schwartz and others (2009, Figure 4) have shown the potential dispersal routes between wolverine populations in Montana. These routes

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follow the areas of persistent snow cover and are found at the western and southern edges of the Little Belt Mountains. The Little Belt Mountains Hazard Tree Removal Project, as well as other planned, proposed and ongoing uses in the Little Belt Mountains, does not limit or inhibit use of these paths for dispersal of individuals. Concluding Summary The Little Belt Hazard Tree Removal Project was analyzed for effects to wolverines based on vegetation changes, movements across the landscape, and disturbance from other human activities. Implementation of the proposed project May Impact Individuals Or Habitat, But Will Not Likely Contribute To A Trend Towards Federal Listing Or Cause a Loss of Viability To the Population1 or Species (MIIH). This is based on the following rationale, consistent with current science. Current science indicates: “Wolverines are not thought to be dependent on specific vegetation or habitat features that might be manipulated by land management activities, nor is there evidence to suggest that land management activities are a threat to the conservation of the species” (Federal Register 2013a, page 7879). “The available scientific and commercial information does not indicate that other potential stressors such as land management, recreation, infrastructure development, and transportation corridors pose a threat to the DPS” (Federal Register 2013a, page 7880). This project would not jeopardize wolverine because the project: Occurs on less than three percent of potential wolverine habitat, as evidenced by the persistent snow cover data. Occurs on less than 1 percent of the modeled natal denning habitat. Would alter vegetation which may impact individuals use of the project area. The Little Belt Hazard Tree Removal Project and cumulative actions would result in small scale disturbance in relation to the large wolverine home range size, and wolverine adjust to and co-exist with moderate levels of disturbance. The project and cumulative effects would not result in disturbance to dispersing individuals.

Gray Wolf Gray wolf habitat occurs within the analysis area and occasionally individuals may be in the project area. In recent years reports of wolves in the Little Belt Mountains have increased, although den and rendezvous sites are not known to occur. Threats to the species include conflicts with livestock and land management practices that effect prey species. There have been no conflicts with livestock reported in recent years in the Little Belt Mountains. Neither Alternative 2 nor 3 would alter the potential for livestock conflicts in the project area. The primary prey species for wolves in the project area are large ungulates. Neither Alternative 2 nor 3 would be expected to alter ungulate populations in the project area (see below). As such, the project would have No Impact on gray wolf.

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Townsend’s Big-eared Bat Communal roosts are generally in caves, abandoned mines, and buildings but have also been observed in large hollow snags. Although they exist in the project area, no caves, abandoned mines, or buildings would be affected by the proposal. Few verified occurrences of this species are documented within the Lewis and Clark National Forest; the species is known to occur at Lick Creek Cave and Dry Wolf Creek Cave in the Little Belt Mountains. Potential foraging habitat exists across the Little Belt Mountains. The State of Montana identifies this bat as an S2 species - at risk because of very limited and/or potentially declining population numbers, range and/or habitat, making it vulnerable to global extinction or extirpation in the state. There are 5 maternity colonies known in the state. None of these occur on the Lewis and Clark National Forest. Under the No Action Alternative, large snags created by mountain pine beetle and other agents (disease, other insects, fire, etc.) would continue to be available in the Little Belt Mountains. Under Alternatives 2 and 3, large snags (dead trees) would be removed from potential treatment areas. Under Alternative 2, recruitment snags would also be removed. Although this would reduce the number of large snags available to Townsend’s big-eared bat, large snags would continue to be available outside of the project analysis area. Appendix F shows the progression of mountain pine beetle mortality across the Little Belt Mountains. The action alternatives May Impact Individuals or Habitat, but would Not Likely Contribute to a Trend Toward Federal Listing or Loss of Viability to the Population or Species (MIIH).

Northern Bog Lemming The Little Belt Mountains Hazard Tree Removal Project is outside the known range of this species (USDA Forest Service 2011a). There are no records of bog lemming in the Little Belt Mountains. The Project would have No Impact on Northern bog lemming.

Bald Eagle Bald eagle nest and forage in forested areas along large reservoirs or rivers. Wintering habitat includes upland sites and bald eagles are often observed on the prairie during the winter. The majority of the proposed treatment areas occur along small rivers and creeks, where roads and recreation sites occur. There are no known nesting eagles in the Little Belt Mountains near the proposed treatments. It is possible that an occasional individual flies over the project area, and winter foraging on carrion may occur in the area. Bald eagle are ranked by the state of Montana as an S3 species - potentially at risk because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Under the action alternatives, nesting habitat would not be removed. Because of the potential for disturbance to any eagles foraging in the project area during implementation, the action alternatives MIIH.

Peregrine Falcon Nests of this species are typically found on ledges of vertical cliffs in undisturbed areas with a wide view, near water and plentiful prey. There are two known peregrine falcon eyries along the Smith River in the Little Belt Mountains. There are no proposed treatments near the nest locations. Peregrine are ranked by the state of Montana as an S3 species - potentially at risk

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because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Because proposed treatments do not occur near the known peregrine falcon eyries, and treatments would not alter availability of prey species (primarily medium- sized song birds and small waterfowl) near the eyries, the action alternatives would have No Impact on peregrine falcon.

Black-backed Woodpecker Snag densities for the Beaverhead-Deerlodge, Custer, Gallatin, Helena, and Lewis & Clark National Forests are estimated using Forest Inventory and Analysis data (USDA Forest Service 2008c). Estimates for the Lewis and Clark National Forest were based on FIA data collected in 1996-1997. From 2003 to 2007, 152 FIA plots were re-measured to provide updated estimates, which are displayed in Table 12 below. Management Standard C-4 (1) (USDA Forest Service 1982, page 2-35) recommends size and number of hard snags by timber type. For black-backed woodpecker in mixed conifer types, the recommended level is 135 snags per 100 acres with a 10 inch dbh minimum. The highest recommended level outside of riparian areas is 158 snags per acre at least 10 inch dbh. Within riparian areas, recommended levels are 300 snags per acre with a 6 inch dbh minimum. Management Standard C-4 also contains the following sections: (3) locate wildlife trees adjacent to natural openings, near water, in valley bottoms, or in aspen groves, if possible, (4) cluster wildlife trees in important habitat, rather than spacing them uniformly in an area, and (6) concentrate wildlife trees in areas away from roads, because firewood cutters remove most deadwood adjacent to roads. Table 12shows that these recommended levels are exceeded outside wilderness and roadless areas on the Lewis and Clark National Forest based on 2013 estimates.

Table 12: Snag Densities (snags per 100 acres) on the Lewis and Clark National Forest Snags per 100 acres 10” dbh + Snags per 100 acres 15” dbh + (95% confidence interval) (95% confidence interval) Forestwide 754 (585-933) 174 (113-231) Jefferson Division* 861 (628-1115) 201 (105-292) Inside Wilderness/Roadless 711 (523-924) 168 (101-235) Outside Wilderness/Roadless 858 (529-1223) 182 (70-308) * does not include the Big Snowy Mountains

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The project analysis area contains potential habitat for black-backed woodpecker; snag habitat created by the mountain pine beetle. A total of 13,599 acres of forested habitat have been analyzed for potential treatment under the proposed action dispersed across the Little Belt Mountains (Appendix A: Project Analysis Area and Likely Treatment Locations Maps, Figures 2 and 4). Proposed activities would treat less than 2% of the acres within the mountain range. Due to the small amount of habitat removed over the larger area, treatments would be expected to cause loss of habitat in localized areas only. Mountain pine beetle activity in adjacent areas will continue to contribute to habitat for the species. Appendix F displays snags per acre across the Little Belt Mountains. These snags are in addition to those estimated through FIA inventory (Table 12). Although the project would reduce snags in localized areas along roads and near recreation and administrative sites, snags would continue to occur in clumps and in areas away from roads. The State of Montana ranks black-backed woodpecker as an S3 species - potentially at risk because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Because of the small area proposed for treatment relative to the Little Belt Mountains, the proposed treatment areas’ dispersal across the mountain range, and the existing and increasing number of snags available outside the project analysis area, the project MIIH.

Burrowing Owl Burrowing owls are found in open grasslands, where abandoned burrows dug by mammals such as ground squirrels (Spermophilus spp.), prairie dogs (Cynomies spp.) and badgers (Taxidea taxus) are available. Open grassland habitat does not occur within the project analysis area. The State of Montana ranks burrowing owl as an S3B species - potentially at risk during the breeding season because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Because habitat for the species does not occur within the project analysis area, the project would have No Impact on burrowing owl.

Flammulated Owl The project area is outside the known range of this species (USDA Forest Service 2011a); there are no records of flammulated owl in the Little Belt Mountains. Surveys conducted in the highest probability habitats on the Rocky Mountain Front of the forest in 2005 did not detect this species. The Little Belt Mountains Hazard Tree Removal Project would have No Impact on flammulated owl.

Greater Sage-grouse Sage grouse prefer sagebrush habitat. Potential habitat does not occur within the project analysis area. Greater sage-grouse are ranked by the state of Montana as an S2 species - at risk because of very limited and/or potentially declining population numbers, range and/or habitat, making it vulnerable to global extinction or extirpation in the state. The project would have No Impact on greater sage-grouse or its habitat.

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Harlequin Duck The project is outside the known breeding range of this species (USDA Forest Service 2011a). There are records of male harlequin duck on the Smith River, but no pairs or breeding activity has been recorded in the Little Belt Mountains. Harlequin duck are ranked by the state of Montana as an S2B species - at risk during the breeding season because of very limited and/or potentially declining population numbers, range and/or habitat, making it vulnerable to global extinction or extirpation in the state. The project occurs outside the known breeding range of this species in Montana, therefore the action alternatives would have No Impact on harlequin duck.

Greater Short-horned Lizard The Little Belt Mountains Hazard Tree Removal Project is within the known range of this species (USDA Forest Service 2011a); however, there are no records of short-horned lizard in the Little Belt Mountains. Habitat for this species (ridge crest between coulees and sparse, short grass and sagebrush with sun-baked soil) may occur at the lower elevations in the project area, but would not be altered by the action alternatives. The State of Montana ranks greater short- horned lizard as an S3 species - potentially at risk because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Because potential habitat would not be altered and the species has not been documented on the forest, the project would have No Impact on greater short-horned lizard.

Beaver Beaver is a Management Indicator Species (MIS) for commonly trapped species. Beaver occur in all areas of the forest with ideal habitat described as ponds, small lakes, meandering streams, and rivers. Important foods include alder, aspen and willow. Loss or modification of riparian habitat is the biggest threat for beaver on the forest. Potential habitat exists within the project analysis area. Some trees may be removed, however riparian areas will be maintained (as required in Management Area R of the Forest Plan, USDA Forest Service 1986, pages 3-88 to 3-91) and food species will remain. In addition, the number of acres proposed for treatment in relation to the acres of habitat available is small. The State of Montana ranks beaver as S5 - common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range. Viability is not a concern for this species (USDA Forest Service 2011).

Black bear Black bear is a MIS for commonly hunted species. Black bear occur across the forest. Habitat is described as dense forests, riparian areas, and open slopes or avalanche chutes during spring green-up. Habitat use is tied to seasonal food availability. Dry mountain meadows are used in early spring; snow slides, stream bottoms, and wet meadows are used in early and mid-summer. In the fall bears may concentrate in berry and whitebark pine areas. Proposed treatments would result in very localized changes in bear habitat, although the proximity to human use of these areas makes them low quality habitat. Proposed activities would result in disturbance and displacement in the short term, and would not result in long term detrimental effects. The State of Montana ranks black bear as S5 - common, widespread, and abundant (although it may be rare

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in parts of its range). Not vulnerable in most of its range. Viability is not a concern for this species (USDA Forest Service 2011, page 163).

Bobcat Bobcat is a MIS for commonly trapped species. Threats to this species include over harvest and removal of prey species (snowshoe hare, jackrabbits, medium-sized rodents, grouse) habitat. Bobcat are known to occur in the project area. This species utilizes a wide variety of habitats and is known to be an animal of "patchy" country. Bobcat prefers rimrock and grassland/shrubland areas, and is often found in areas with dense understory vegetation and high prey densities. Natural rocky areas are preferred den sites. This is a solitary animal that is difficult to observe in the wild. The State of Montana ranks bobcat as S5 - common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range. Viability is not a concern (USDA Forest Service 2011, page 171). The project would not alter the amount of denning habitat available to bobcat across the forest. The preferred prey of bobcat, snowshoe hare and jackrabbit, would not be impacted by this project as they do not use snag habitat. Removal of snowshoe hare habitat is limited by the Northern Rockies Lynx Management Direction Standard VEG S6. The primary effects to this species would be disturbance. Disturbance and displacement would be temporary and short term, and would not result in long term detrimental effects.

White-tailed deer White-tailed deer is a MIS species for commonly hunted species. White-tailed deer occur within the lower elevations of the forest in the summer. In the Little Belt Mountains there is no mapped white-tailed deer winter range. Montana Fish, Wildlife and Parks (MFWP) maps winter range for this species in the low elevation areas between the Little Belt and Castle Mountains. Treatments would occur within the range of this species. Under the No Action alternative a loss of canopy cover has occurred in areas where trees have died from mountain pine beetle or spruce budworm. This has resulted in increased light reaching the forest floor. This could potentially result in increased forage and browse, as well as regeneration of trees in some areas. Removal of hazard trees would not reduce effective hiding cover based on the PI type methodology required by the forest plan. The loss of canopy cover from pine beetle activity changes the PI type. The existing effective hiding cover is displayed in Table 13. Standing dead trees can provide cover for deer, and this would be removed along treated roads. This cover would be removed from three to five years sooner than it would naturally be reduced from falling dead trees. The potential removal of green lodgepole stands under Alternative 2 (on just under 5,000 acres) could increase forage and browse production near roads. A further discussion of big game habitat is found under elk. The State of Montana ranks white-tailed deer as S5 - common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range. Recent declines in the population (USDA Forest Service 2011, page 163) in eastern Montana are attributed to weather related limitations in their summer food supply (see mule deer discussion in Supplemental Environmental Assessment, Blankenship Vegetation Project, January 2013; and USDA Forest Service 2013), as well as disease (Epizootic Hemorrhagic Disease). The proposed actions, removal of hazard trees along roadsides and within administrative and recreation sites, would not

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alter the viability of white-tailed deer in the Little Belt Mountains. MFWP manages white-tailed deer populations, adjusting hunting regulations in response to population fluctuations. Viability of the species in Montana is not of concern.

Mule deer Mule deer is a MIS species for commonly hunted species. Mule deer are found in the Little Belt Mountains where there are 115,709 acres of winter range within the national forest boundary. The actual MFWP mapped winter range extends beyond the forest boundary. A total of 1762 acres of winter range is proposed for treatment; approximately 1.5% of the winter range found on national forest lands in the Little Belt Mountains. Fawning can occur across the analysis area. Due to the solitary nature of mule deer when fawning (as opposed to elk who tend to concentrate), fawning habitat is not identified and mapped on the forest. As described under white-tailed deer, under the no action alternative forage and browse may have increased in localized areas where trees have died. Under the action alternatives, removal of hazard trees would not be expected to alter habitat for mule deer as described for white-tailed deer. Additional information can be found under the discussion of elk. The State of Montana ranks mule deer as S5 - common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range. In January 2013, a monitoring report for mule deer (USDA Forest Service 2013) was completed, discussing the low population numbers in eastern Montana and potential causes. MFWP manages mule deer populations, adjusting hunting regulations in response to population fluctuations. The lower population levels observed have resulted in conservative hunting regulations for this species since 2010. This project would not add to mule deer population declines. Mule deer viability is not a concern in Montana.

Mountain Goat Mountain goat is a MIS for commonly hunted species. Mountain goat habitat is found on the Rocky Mountain Front, Big Snowy Mountains, southern portion of the Crazy Mountains, and the Highwood Mountains (USDA Forest Service 2011a). The species is indigenous to the Rocky Mountains and was transplanted elsewhere. Mountain goat are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Populations and habitat do not occur in or near the analysis area. The Little Belt Mountains Hazard Tree Removal Project would have no effect on viability of mountain goat populations on the Lewis and Clark National Forest.

Mountain Lion Mountain lion is a MIS for commonly hunted species. Mountain lion are found across the forest. Habitat is described as mostly mountains and foothills, but any habitat with sufficient food, cover and room to avoid humans is used. In Montana, deer, elk, and porcupine are the most important prey species, but lions may take prey ranging in size from grasshoppers to moose. Due to the small proposed treatment areas and their distribution across the Little Belt Mountains, the abundance of prey species would not be expected to change with the project. The distribution of prey may be temporarily shifted during project implementation. This shift is not expected to impact mountain lion populations, as lions will move to where the prey are available or shift to

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forms of prey available at their location. Mountain lion are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Mountain lion populations on the Lewis and Clark National Forest are viable (USDA Forest Service 2011a). The project would not reduce viability of mountain lions.

Elk The Forest Plan (USDA Forest Service 1986, pages 2-30 to 2-31) includes the following Management Standards: C-1 (4): “Incorporate recommendations from the Montana Cooperative Elk- Logging Study in the planning of timber sales and road construction projects. These recommendations are listed in Appendix F.” C-1 (5) “Require a big game cover analysis of projects involving significant vegetation removal to ensure that effective hiding cover is maintained. The cover analysis should be done on a drainage or elk herd unit basis. Drainages or elk herd units containing identified summer range/fall range will be maintained at 30 percent or greater effective hiding cover.” Effective hiding cover is defined as vegetation capable of essentially hiding an adult elk from view at a distance equal to or less than 200 feet (USDA Forest Service 1986, Glossary, page 5). The Forest Plan further states that effective “hiding cover is based on the percentages of PI types which meet this definition as determined by the Montana Cooperative Elk/Logging Study.” The forest began using the prescribed big game cover analysis methodology in the fall of 2008 (USDA Forest Service 2009b). C-1 (6) “Manage motorized use on National Forest system lands through the Forest Travel Plan, in cooperation with the public, State of Montana, and other Federal agencies, to reduce the effects on wildlife during periods of high stress (hunting seasons and wintering periods). Also see Chapter III and Appendix O. The Montana Fish and Game Commission Road Management Policy and the Forest Service Road Regulations are shown in Appendix G. In addition to these standards, elk habitat is described in terms of habitat effectiveness and security. Habitat Effectiveness refers to the percentage of available habitat that is usable by elk outside the hunting season (Lyon and Christensen 1992). The Little Belt, Castle, North Half Crazy Mountain Travel Management Plan Final Environmental Impact Statement (USDA Forest Service 2007g, pages 255-263) utilized the habitat effectiveness model developed by Lyon (1983) based upon road densities. Based on recent scientific findings (Wisdom and others 2005) and recommendations from researchers and biologists (Wisdom 2006, Rowland 2006); all motorized routes (including ATV and motorcycle trails) open during the period from June 30 to August 31 were used to calculate habitat effectiveness. Elk Security is defined by Lyon and Christensen (1992) as “the protection inherent in any situation that allows elk to remain in a defined area despite an increase in stress or disturbance associated with the hunting season or other human activities.” When security is inadequate, elk become increasingly more vulnerable to harvest. Hillis and others (1991) provided guidelines for managing elk security and limiting

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elk vulnerability during the hunting season. The key concept is to provide secure areas for elk during the hunting season where they are less vulnerable to harvest. Secure habitats are defined as non-linear areas of hiding cover greater than 250 acres in size and greater than ½ mile from an open road. Hillis (and others 1991) recommended that secure elk habitat comprise greater than or equal to 30 percent of an analysis unit; although they caution that “unquestioning adherence to these guidelines may lead to serious misapplications and should be avoided.” Both habitat effectiveness and elk security were addressed in the Little Belt, Castle, and North Half Crazy Mountains Travel Plan Final Environmental Impact Statement (USDA Forest Service 2007g) and Record of Decision (USDA Forest Service 2007b). For the purposes of this analysis, big game habitat numbers were derived from ArcGIS using data queries of the Timber Stand Management Record System (TSMRS), VMAP and base data from our GIS library. Data was exported to a Microsoft Office 2007 Excel spreadsheet, where pivot tables derived acres. A full description of the methodology for completing the big game cover analysis is found in USDA Forest Service (2009b). This is a summary of the methodology as it was applied to the project. The Forest Plan states (USDA Forest Service 1986, Glossary page 5) that effective hiding cover is based on percentages of PI types which meet this definition as determined by the Montana Cooperative Elk/Logging Study (Elk/Logging Study). The Elk/Logging Study measured effective hiding cover in the field using a cut out of an elk (USDA Forest Service 1982, pages 72 to 89). Stand characteristics were noted where hiding cover measurements were taken. The study then developed rules that equated PI types (from stand characteristics) to effective hiding cover percentages. For the Little Belt Mountains Hazard Tree Removal Project, VMAP base data was queried to determine PI type. The PI type is determined from stand characteristics regarding tree height, roughness, and canopy cover. The Montana Rule (USDA Forest Service 2009b) was developed to estimate the percent of a stand in a given PI type with effective hiding cover. Effective hiding cover for the analysis area is determined by multiplying the acres of each PI type by the percent cover in the Montana Rule, adding up the acres with cover, and dividing by the total acres in the analysis area. This project is proposed on acres where mountain pine beetle activity has resulted in dead and dying trees; trees with little to no canopy cover. As such, the PI type on the proposed treatment acres was reduced to 0 percent for the existing condition. This assumes there is no canopy remaining due to the pine beetle. In actuality, over 50 percent of the proposed acres will maintain some canopy cover. Hydrologic Unit Code (HUC) watersheds equate to a drainage for the purposes of a big game cover analysis. Both Sixth and Seventh HUCs were used to fully cover the summer and fall range in the Little Belt Mountains, and to eliminate winter range from the analysis area. Only those HUCs with proposed treatments were analyzed (Table 13). Table 13: Effective Hiding Cover by PI Type in Watersheds with Proposed Treatments HUC6 watershed HUC7 Total Acres Acres Hiding Cover Effective Hiding Cover 100301030102 01 8328.8 3562.4 43%

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HUC6 watershed HUC7 Total Acres Acres Hiding Cover Effective Hiding Cover 100301030102 04 870.9 275.5 32% 100301030102 06 1281.1 295.8 23% 100301030401 27663.0 12454.5 45% 100301030403 23244.6 9913.3 43% 100301030404 06 2181.4 967.5 44% 100301030801 26104.5 14034.0 54% 100301030802 03 2648.3 1266.7 48% 100301030802 05 1378.3 570.5 41% 100301030903 11267.4 4555.2 40% 100301050101 20792.8 9703.0 47% 100301050102 03 6735.5 2989.0 44% 100301050102 04 5809.2 2653.1 46% 100301050103 18511.7 7818.9 42% 100301050104 01 4341.2 1748.7 40% 100301050104 03 1094.0 545.9 50% 100301050104 04 717.6 319.8 44% 100301050104 05 988.1 448.8 45% 100301050104 06 776.7 331.9 43% 100301050104 09 5768.9 1691.6 29% 100301050105 03 1186.2 455.5 38% 100301050105 04 8358.8 4028.5 48% 100301050105 06 1525.5 232.4 15% 100301050105 08 11775.0 4305.7 37% 100301050301 02 1212.3 531.5 44% 100301050301 03 1858.3 715.6 39% 100301050302 18258.7 8301.1 45% 100301050303 03 434.7 162.6 37% 100301050303 04 3878.2 1743.6 45% 100301050303 05 966.1 362.9 38%

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HUC6 watershed HUC7 Total Acres Acres Hiding Cover Effective Hiding Cover 100301050303 07 3836.0 1533.6 40% 100301050303 08 2593.3 1015.4 39% 100301050303 09 983.1 411.2 42% 100301050303 14 3968.5 1445.9 36% 100401030301 32866.0 15295.6 47% 100401030303 29275.1 12430.3 42% 100401030304 24116.2 10386.8 43% 100401030401 35257.7 14680.2 42% 100401030402 21777.4 9319.9 43% 100401031101 28732.2 11550.0 40% 100402010101 01 7468.5 2547.9 34% 100402010101 02 4871.9 2323.4 48% 100402010104 03 2922.5 1338.0 46% 100402010104 04 5596.2 2305.3 41% 100402010104 05 6806.9 2760.8 41%

Elk occur across the Little Belt Mountains with proposed treatments in both identified calving habitat and winter range. Of the 83,651 acres of elk calving habitat, 1581 acres (1.9 percent) is proposed for treatment. Proposed treatment of winter range occurs on 885 acres (0.9 percent) of the 99,082 acres of mapped winter range. Habitat effectiveness will not be altered as no roads will be built for the project. Road densities will not change for calculating open road densities or Fish and Wildlife Commission Road densities. The cooperative elk logging study recommendations will be followed, however winter logging within winter range may be necessary due to soil concerns. Montana Fish Wildlife and Parks will be consulted if winter logging in winter range is planned. Removal of hazard trees will not reduce effective hiding cover based on the PI type methodology required by the forest plan. The loss of canopy cover from pine beetle activity changes the PI type. The existing effective hiding cover is displayed in Table 13. Standing dead trees can provide cover for elk, and this will be removed along treated roads. This cover would be removed from three to five years sooner than it would naturally be reduced from falling dead trees. Because of the widespread locations of treatment areas, their locations adjacent to roads, and their relatively small size, treatments will not alter security habitat for elk. The State of Montana ranks elk as S5 - common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range. Because of the small acreage of calving range and winter range treated, and no change to effective hiding cover,

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elk security, habitat effectiveness, and road densities, this project is not expected to impact elk viability.

Dusky Grouse Dusky Grouse is a MIS for commonly hunted species. Dusky grouse is a year-long resident across the forest. They prefer forest edges and openings during early spring, and broods may be found away from timber during summer and early fall. They winter in high elevation conifer stands. Habitat for this species occurs within the project analysis area. Forbs are an important food item for broods during the summer. In areas where trees have died, forb production may increase due to increased light availability. Harvest activities could disturb the sites. Some forb species would increase with disturbance and some would decrease, but overall forb abundance is expected to be higher in more open areas. Minimal and short term disturbance is expected during project implementation. Dusky grouse are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Dusky grouse populations on the Lewis and Clark are cyclic, as in other areas (USDA Forest Service 2011a). This is largely due to chick survival, which is largely due to cool wet springs, dry summers, and harsh winters (USDA Forest Service 2011a). The project may increase brood rearing habitat, and result in a slight increase in the population in the Little Belt Mountains. The project would have no effect on dusky grouse viability.

Golden Eagle Golden Eagle is a special interest MIS. According to the Montana Field Guide, golden eagles nest on cliffs and in large trees, and hunt over prairie and open woodlands. Cliff nests are selected for south or east aspect, less than 200 inches of snowfall, low elevation, and availability of sagebrush/grassland hunting areas. No known nest sites would be affected by the proposal. In Montana, golden eagles eat primarily jack rabbits, ground squirrels, and carrion (dead animals). Implementation would not result in habitat changes affecting the availability, abundance, and distribution of those prey species. Golden eagle are ranked by the state of Montana as an S3 species - potentially at risk because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Because the project would not affect the availability, abundance, and distribution of prey species, and no known nest sites are within the project analysis area, the project would not affect golden eagle viability.

Prairie Falcon Prairie falcon is a special interest MIS. According to the Montana Field Guide, prairie falcons use cliffs for nesting, and grassland and prairie habitats for hunting. Most nests are on cliffs averaging 125 feet in height. Almost 3/4 of eyries faced south or east and almost all nests overlooked at least some grassland. On the east side of the Forest the majority of prairie falcon observations are along cliffs and bluffs at the head of tributaries to the Musselshell River (USDA Forest Service 2011a). The project analysis area does not include cliffs, although cliffs may occur in the vicinity. There are no known nest sites in or near the treatment areas. Implementation would result in habitat changes affecting the availability, abundance, and distribution of snag dependent prey species (primarily birds) in a small area relative to an

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individual’s range, and on less than 2 percent of the Little Belt Mountains. Prairie falcon are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Because there are no known nesting areas within the project analysis area and the treatments occur on a small area of the Little Belt Mountains, the project would not be expected to affect viability of prairie falcon.

Northern Goshawk Background and Methodology The Lewis and Clark National Forest Plan (USDA Forest Service 1986) identified northern goshawk (Accipiter gentilis) as a Management Indicator Species (MIS) for old growth. In 2007, goshawk was removed from the Region 1 sensitive species list (USDA Forest Service 2007d, USDA Forest Service 2011b). The State of Montana considers goshawk a Species of Concern (Montana Natural Heritage Program and Montana Fish, Wildlife and Parks 2009). Forest-wide management standard C-5 provides that population levels of MIS be monitored and evaluated as described in the Forest Plan monitoring plan as shown in Chapter V (USDA Forest Service 1986, page 2-37). Forest Plan monitoring item C-8 provides that for the goshawk “Old Growth Habitat” is monitored by sampling active nesting goshawk territories. Increased efforts to monitor all known nest sites were begun in 2006 in order to comply with the Forest Plan. In June 2007 (USDA Forest Service 2007e) and September 2007 (USDA Forest Service 2007f), the forest completed monitoring reports for item C-8 Old Growth Habitat for Goshawk (project file). These reports summarize the goshawk monitoring efforts over time. Monitoring was completed and summarized for 2008, 2009 and 2010. Monitoring was also completed in 2011 and 2012, but results are not yet summarized in a published monitoring report; however, they can be found in the project file. The following table (Table 14) summarizes the monitoring results for 2006 through 2010. In 2008 there was a wet, cold spring that likely contributed to a lower number of active nests (as discussed in USDA Forest Service 2007e). As can be seen in the table below, the number of known territories has increased every year due to survey and monitoring efforts, and the number of occupied territories and active nests fluctuates year to year. This fluctuation is natural in goshawk populations (as discussed in USDA Forest Service 2007e). No conclusions on population trend are available from monitoring data at this time.

Table 14: Goshawk Monitoring Results for 2007-2010 Results of Monitoring 2006 2007 2008 2009 2010 Number of known territories 40 42 43 53 57 Number of monitored territories 25 (63%) 41 (98%) 42 (98%) 50 (94%) 55 (96%) (%) Number of occupied territories (%) 16 (64%) 24 (59%) 16 (38%) 27 (54%) 31 (56%) Number of active nests (%) 13 (52%) 17 (41%) 7 (17%) 25 (50%) 29 (53%) Yearly difference + 52% -11% -25% 33% 3 %

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Reynolds (and others 2005) reported that as many as 8 years of repeated nest searching were required to identify the population of breeders in their goshawk study on the Kaibab Plateau in Arizona. They found that temporal and spatial variation in breeding and a high degree of movements to alternate nests within territories made finding and monitoring goshawks difficult. Accordingly, insufficient samples of territories results in underestimates of breeding densities and habitat occupancy. Patla (2005) reported a decline in occupancy from monitoring of goshawk nests on the Caribou- Targhee National Forest (CTNF) in the Greater Yellowstone Ecosystem. In the study 16 nesting areas were monitored each year, randomly picked from a list of 34 nesting areas total. The study found both a decrease in occupancy overall from the two monitoring periods (1992-1995 and 1998-2002), and significantly lower occupancy at nesting areas located in past timber-harvest areas compared to those in less disturbed areas. The past timber-harvest activities occurred prior to the 1998-2002 monitoring period, although the exact timing of harvest activities was not reported. Patla also states that whether “the decline in occupancy measured at known nesting areas on the CTNF reflects a response to decline in quality of primary habitat, a shorter term response to variation in weather and prey, or sampling error due to shifting of pairs outside of surveyed sites cannot be determined using the current monitoring study plan…” Patla’s results may also be attributable to insufficient sampling as described by Reynolds (and others 2005). Fairhurst and Bechard (2005) found declines in occupancy of nesting territories associated with colder February and March temperatures and increased April precipitation in their study area in northern Nevada. They found that for each 1oC increase in combined February and March mean daily temperature, the odds of nesting territory occupancy by a goshawk pair increased by 55.8 percent. For every cm increase in total April rainfall, the odds of occupancy increased by 7.7 percent. Fairhurst and Bechard (2005) conclude that it is unlikely that direct weather effects were responsible for reported reproductive trends on this study area; indirect effects through changes in hunting behavior or food supply may explain the observed differences. Intensive goshawk monitoring on the Lewis and Clark National Forest (LCNF) has been done for seven years, with results available for five years (Table 14). Based on Reynolds (and others 2005) observations in Arizona, more years of monitoring is needed before accurate conclusions can be drawn. Patla (2005) reported a decline in occupancy in her study, as described above, based on sampling known nesting areas each year as required by the CTNF Plan. The LCNF Plan requires a 100 percent sample of active nesting territories, with further evaluation required for a decrease of 10 percent or more in active nesting territories. Table 14 shows that for the 2006-2010 monitoring period, occupancy, as compared to Patla, was from 54 to 64 percent, except in the year with a wet, cold spring (2008) when occupancy was at 38 percent. The 2008 data corresponds to information from Fairhurst and Bechard (2005), Patla (1997) and Kostrzewa and Kostrzewa (1990) that cold, wet springs can result in a decrease in goshawk reproduction or occupancy. For the purposes of this analysis, goshawk habitat numbers were derived from ArcGIS using data queries as described in the Northern Goshawk Northern Region Overview – Key Findings and Project Considerations (Brewer and others 2009). The queries were based on the Northern

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Region Vegetation Mapping Program (VMap) (USDA Forest Service 2009c), which is based on satellite imagery collected in 2005. Potential nesting habitat was modeled using the LCNF model, as described in the Goshawk Potential Nesting and Foraging Metadata for the Lewis and Clark National Forest (Appendix 2). This model queries the Timber Stand Management Record System (TSMRS) for timber stand conditions found around known nest sites on the forest. Existing Environment – Regional Context Northern goshawk is considered globally secure, and in Montana, the population is considered potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas (Montana Natural Heritage Program and Montana Fish, Wildlife and Parks 2009). In its 12-month status review of the species, the Fish and Wildlife Service concluded “that the goshawk population is well distributed and stable at the broadest scale” (USDI Fish and Wildlife Service 1998). Based on habitat and goshawk detection estimates, breeding goshawks and their habitat appear abundant and well distributed across the Region (Kowalski 2006, Samson 2005 as amended 2006). Each National Forest appears to have more than enough habitat to maintain a minimum viable population of goshawks (Samson 2006, as amended by USDA Forest Service 2008b). Existing Environment – Forest Context Samson (2006, as amended by USDA Forest Service 2008b) estimated that a minimum viable population of northern goshawk required 30,147 acres of habitat across all of Region 1. Goshawk habitat across both the Forest and the Jefferson Division well exceed Samson’s estimate (Table 15).

Table 15: Goshawk nesting, Post-Fledging Area (PFA), and foraging habitat across the Forest and Jefferson Division Area Nesting Habitat8 Possible Nesting Foraging/PFA10 Habitat9 Habitat

8 Minimum value reflecting only stands of USFS ownership for which all of the attributes used in the query were available. USFS ownership missing some of the required attributes was not included. State, BLM, or private lands within the administrative boundary were not included as data used for analysis was not available for these ownerships. 9 This number reflects possible nesting habitat which met some of the attributes used for the query, but for which some attributes necessary for the query were missing.

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Area Nesting Habitat8 Possible Nesting Foraging/PFA10 Habitat9 Habitat Lewis and Clark 359,153 85,263 163,891 National Forest Jefferson Division 296,121 84,439 unknown

Home Range and Project Context The analysis area for direct, indirect, and cumulative effects encompasses the Little Belt Mountains. The Little Belts is approximately 900,958 acres. The entire Little Belt Mountain range was selected because proposed treatments are spread across the mountain range as shown on Map 1. Using an average size of 5,000 acres per home range, the Little Belt Mountains could potentially support 180 goshawk pairs. Due to habitat and prey availability, it is likely that the number of goshawks actually supported is lower. Foraging Habitat The foraging area may approximate the typical home range size (1,200 to 10,000 acres). The area occurs in an irregular polygon influenced by factors such as competition, forest structure, and prey availability. Annual changes to the foraging area may occur, and be influenced by factors such as precipitation and fluctuations in prey species. Beier and Drennan (1997) found that goshawks selected foraging sites that had higher canopy cover and density of trees than on contrast plots. Foraging habitat is often described as mature to late-seral stands with at least 40 percent canopy cover in dominant trees and an open understory. They also forage in forest with less than 40 percent canopy cover, a variety of forest types, forest ages, structural conditions, and successional stages, including edge habitat and openings within and adjacent to forested areas. The goshawk is considered a generalist, opportunistic predator throughout its range. Prey items are taken on the ground, on vegetation, and in the air. Goshawks also feed on carrion. Reynolds and others (1992) indicated a wide variety of prey with no single species dominating the diet. Within the foraging area available habitats are used opportunistically to hunt a wide variety of prey. A study in south-central Wyoming found a variety of prey species including red squirrels, northern flickers, American robins, golden-mantled ground squirrels, and chipmunks (Squires 2000). Expected prey in the analysis area include the aforementioned items as well as cottontail rabbits, multiple ground squirrel species, snowshoe hares, woodpeckers, gray jays, Clark’s nutcrackers, ruffed and dusky grouse, crows and ravens, and multiple passerine species. Given the wide range of goshawk prey, some species are most abundant in older productive forests, some in grass/forb/shrub stages, and others in the wide range of habitats in between. Habitats which goshawks appear to use relatively seldom; such as dense spruce and fir forest, or small diameter, dense lodgepole pine, or larger openings, may be important areas for producing

10 Minimum value reflecting only USFS ownership, data used for analysis was not available for state, BLM, or private lands within the administrative boundary nor for just the Jefferson Division for the updated estimate.

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particular prey species. In the southwest Reynolds (and others 1992) described pine landscapes with older forests and small openings as the desired condition. Reynolds and others (1992) recommended habitat diversity for northern goshawk in the southwest (Table 16, copied from Brewer and others 2009). Other researchers (Moser 2007, McGrath and others 2003, Clough 2000, Patla 1997, and Desimone 1997) reported this information for study areas in the northwestern United States (Table 11, copied from Brewer and others 2009). Clough’s (2000) study was located in the same ecological province as the Little Belt Mountains, and is most similar in vegetation types and precipitation. The existing condition of the foraging habitat within the analysis area is displayed in Table 17. These numbers are based on habitat mapping from a 2005 census. Mountain pine beetle activity has altered the existing condition by killing large pine species. This alters the relative abundance of available foraging habitat types, and can result in changes in the available prey base. Details and methodology for conducting the habitat analysis in GIS are provided in Brewer and others (2009).

Table 16: Vegetation composition of PFAs in the northwestern United States compared with Reynolds and others (1992) recommendations for the southwestern United States.

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Stand Size Patla Desimon Clough McGrath Moser Reynolds Class11 and (1997)12 e (2000)14 and others and and others Canopy Southeast (1997)13 West- (2003: Garton (1992)17 Cover Idaho/ Eastern central Table 15)15 (2009)16 Southwester Western Oregon Montana Northeaster Norther n United Wyoming n Oregon n Idaho States % (std % (std and Central % (std err) err) err) % (std % (std err) Washington err) % (std err) 0.0-4.9” dbh 17.0 (4.0) 4.2 (1.7) 9.3 (2.9) 3.6 (0.9) 10 (VSS1,2: 0-5” dbh) 5.0-9.9” dbh 6.0 (2.0) 15.3 (2.9) 65.7 (5.0) 26.6 20 (VSS3: 5- 12” dbh) 10.0” + dbh 66.0 (4.0) 44.8 11.3 (2.6) 62.0 39 (>12” 60 (VSS 4, dbh) 5, 6: >12”dbh)

> 5.0” dbh 36.5 (4.9) 69.0 55.5 39 (>12” 60 (> 12” with > 50% dbh, dbh) canopy >70% cover canopy cover) Opening 11.0 (~2.0) 7.3 8.3 10 (VSS1) (grass/ forb/shrub)

11 Stand Size Class is based on basal area weighted average diameter (USDA Forest Service 2009c). 12 Patla 1997, southeastern Idaho and western Wyoming including portions of the Middle and Northern Rocky Mountain Provinces. Goshawk nests were found in Douglas-fir, lodgepole pine, or mixed conifer forests between 6102 and 7923 feet elevation that averaged 16 to 24 inches of precipitation per year at the lower elevations. 13 Desimone (1997), eastern Oregon, Blue Mountains Province. Nests found in ponderosa pine, mixed-conifer, and lodgepole pine at 1200-2200 meters elevation (no precipitation reported). 14 Clough (2000), west central Montana, Middle Rocky Mountain Province. Nests were found in Douglas-fir, lodgepole pine, and mixed conifer forests between 5000 and 6601 feet elevation that averaged 14 inches of precipitation per year at lower elevations. 15 McGrath et al. (2003), northeastern Oregon and central Washington in the Blue Mountains and Eastern Cascade Provinces. Nests found in mixed conifer, Douglas-fir, ponderosa pine, western larch, lodgepole pine between 2388 and 6991 feet elevation that averaged 22 inches of precipitation per year. 16 Moser and Garton (2009). northern Idaho, Northern Rocky Mountain Province. Numbers reported are recommended amounts derived from experimentally testing the impacts of clearcutting nest areas on goshawk re- occupancy rates 1 to 2 years post-harvest. 17 Reynolds et al. (1992), southwestern United States, management recommendations for ponderosa pine, mixed conifer, and spruce-fir forests.

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Nesting Habitat Nesting habitat is often stands with dense canopy and late forest structure (Daw and DeStefano 2001, Beier and Drennan 1997, Squires 2000, Reynolds and others 1992, Graham and others 1997). Hayward and Escano (1989) found nest sites in northwest Montana were often located in even-aged, single-storied, mature forest stands with a high canopy cover of widely spaced large trees. Squires and Ruggiero (1996) agreed with this description, adding that nest stands generally had clear forest floors. Goshawks are more likely to occupy areas with relatively low amounts of stand initiation, shrub, or sapling habitat (Finn and others 2002) with a low density of small trees in nest stands (Squires and Ruggiero 1996). Table 17: Habitat within the Little Belt Mountains Stand Size Class and Existing Proposed for Post Canopy Cover (percent of total Treatment Implementation acres) (percent of (percent of total existing acres) acres) Openings 143431.0 acres 4387.5 acres 156845.2 acres 16 % 3.1% 17% Tree/0.0” – 4.9” 66054.9 acres 2331.0 acres 63723.9 acres 7 % 3.5 % 7 % Tree/5.0” – 9.9” 399479.1 acres 6597.6 acres 392881.5 acres 44 % 1.7 % 44 % Tree/10.0” plus 284565.9 acres 4466.5 acres 280099.4 acres 32 % 1.6% 31% 5.0” and canopy 578668.6 acres 7984.3 acres 570684.3 acres cover >40% 64 % 1.4% 63% Nesting habitat 296693.7 acres 3944.2 acres 292749.5 acres 33% 1.3% 33% Old Growth 80834.7 acres 1307.6 acres 79527.1 acres 9% 1.6% 9%

A nesting habitat model was developed by LCNF biologists, the Timber Stand Management and Record System (TSMRS) database manager and the Forest GIS specialist in 2006. Parameters that best describe habitat surrounding actual nests on the LCNF were used to query the TSMRS database. This query focused on canopy cover, elevation, tree species, trees per acre, and average DBH. Table 12 displays the results of the nesting habitat model in the project area. Again, pine beetle activity has resulted in a loss of nesting habitat in the existing condition due to the reduced canopy in affected stands.

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Reynolds and others (1992 at Table 1, p. 7) recommends maintaining six nest areas (three suitable and three replacements), each at least 30 acres in size, and totaling 180 acres per 5,000- acre foraging area in the southwestern United States. In west-central Montana, Clough (2000) found nest areas averaged 40 acres in size. If the analysis area included 180 home range/foraging areas, a minimum of 32,420 acres of nesting habitat (180 acres times 180 areas) would be needed in the analysis area. The analysis area currently has over 290,000 acres of nesting habitat well distributed across the area (Table 17). Brewer (and others 2009) recommend that a minimum 40-acre no activity buffer be maintained around recently occupied goshawk nests to maintain existing conditions in the nest stand. Recently occupied refers to use of a nest area, post-fledging area, or home range by a breeding pair of goshawks and its young during the breeding season. Within the Little Belt Mountains there are five nest territories where the project analysis area is within the 40-acre buffer around the nest. The impacted territories are Beldon Flats, Harley Creek, Logging Creek, Mass Creek, and Yogo Creek. Home ranges were mapped for these territories based on watershed boundaries (Brewer and others 2009). Table 18 provides the existing habitat in these five territories home ranges.

Table 18: Northern Goshawk habitat acres within impacted nesting territories Beldon Flats Harley Logging Mass Creek Yogo Creek Creek Creek

Total acres 3596.0 6735.5 3426.6 3592.5 4844.7 Acres proposed 66.4 (1.8%) 328.8 (4.9%) 106.9 (3.1%) 422.3 (11.8%) 116.8 (2.4%) treatment Nesting total 1114.8 (31%) 841.6 (12%) 1632.6 (48%) 1079.3 (30%) 581.5 (12%)

Nesting treated 33.6 (3.0%) 28.1 (3.3%) 55.2 (3.4%) 155.0 (14.4%) 13.9 (2.4%) Nesting remaining 1081.2 (30%) 813.5 (12%) 1577.4 (46%) 924.3 (26%) 567.6 (12%) >5” dbh & 40% total 2577.5 (72%) 3705.6 (55%) 1922.9 (56%) 1689.6 (47%) 4238.2 (87%)

>5” dbh & 40% treated 49.1 (1.9%) 104.4 (2.8%) 78.4 (4.1%) 207.3 (12.3%) 38.2 (0.9%) >5” dbh & 40% 2528.4 (70%) 3601.2 (53%) 1844.5 (54%) 1482.3 (41%) 4200.0 (87%) remaining Openings total 515.1 (14%) 692.5 (10%) 679.6 (20%) 1021.7 (28%) 130.3 (3%)

Openings treated 4.6 (0.9%) 62.3 (9.0%) 7.1 (1.0%) 103.1 (10.1%) 51.8 (39.8%) Openings remaining 577.0 (16%) 959.0 (14%) 779.4 (23%) 1340.9 (37%) 195.2 (4%) Size class >10” total 2728.0 (76%) 1143.0 (17%) 758.5 (22%) 1017.7 (28%) 3556.8 (73%)

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Beldon Flats Harley Logging Mass Creek Yogo Creek Creek Creek

Size class >10” treated 34.0 (1.2%) 51.7 (4.5%) 38.0 (5.0%) 126.1 (12.4%) 48.9 (1.4%) Size class >10” 2694.0 (75%) 1091.3 (16%) 720.5 (21%) 891.6 (25%) 3507.9 (72%) remaining Size class 5-9” total 348.8 (10%) 3875.3 (58%) 1792.9 (52%) 915.3 (25%) 1085.5 (22%)

Size class 5-9” treated 25.9 (7.4%) 138.7 (3.6%) 54.5 (3.0%) 122.8 (13.4%) 15.6 (1.4%) Size class 5-9” 322.9 (9%) 3736.6 (55%) 1738.4 (51%) 792.5 (22%) 1069.9 (22%) remaining Size class 0-4” total 4.2 (0.1%) 1024.8 (15%) 195.6 (6%) 637.8 (18%) 72.1 (1%)

Size class 0-4” treated 2.0 (47.6%) 76.1 (7.4%) 703 (3.7%) 70.3 (11.0%) 0.4 (0.6%) Size class 0-4” 2.2 (0.1%) 948.7 (14%) 188.3 (5%) 567.5 (16%) 71.7 (1%) remaining Size class 0-4” in 3- 5 64.1 (2%) 1215.2 (18%) 288.1 (8%) 886.7 (25%) 136.6 (3%) year

Because goshawk is identified as a management indicator species for old growth, the amount of old growth habitat within the goshawk analysis area was determined (Table 17). As the table shows, the amount of potential nesting habitat and old growth habitat in the analysis area differs. Potential nesting habitat is based, in part, on stands with greater than 60 percent canopy cover, an average diameter at breast height (dbh) of 7 inches or greater and at least 100 trees per acre. Old growth was determined using definitions from Green (and others 1992) that consider, in part, a minimum number of trees per acre greater than a specified dbh and age. The differences in characteristics used to define nesting habitat and old growth results in the different acres as shown in Table 17. As described in the June 2007 C-8 Old Growth Habitat for Goshawk Monitoring Report (USDA Forest Service 2007e, Goshawk Habitat Analysis), goshawks on the LCNF appear to select for old growth habitat within an 800 meter buffer (496 acres) surrounding the nest at the same rate it occurs on the landscape. In other words, goshawk on the LCNF do not appear to require old growth habitat around the nest site. Goshawk were found to select nest areas with a higher percentage of mature forest than the landscape. Mature forest was defined as trees larger than 7” dbh. This is reflected in the LCNF nesting habitat model. Post-Fledging Area The Post-Fledging Area (PFA) provides hiding cover and foraging practice for the young from the time of fledging until they are no longer dependent on the adults for food. The exact acreage and shape varies with many factors, some of which may include habitat requirements, geographic location of the territory, specific habitats/forest types available in that area, prey

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abundance, risk of predation, and number of fledglings. Radio telemetry is the only way to determine an exact PFA for any given territory. For the five impacted territories, a circular, 420 acre PFA was established around each nest and habitat within that circle was described using VMap. Table 19 displays the existing habitat, by size class and dominant species, for the PFA around the most recent nest for each of the five territories. A comparison of the habitat composition around these known, successful nests (Table 19) with values reported by various researchers in the United States (Table 16) shows the variability of habitat composition used by goshawk. Table 19: Habitat composition, by dominant species and size class, in a 420-acre circular PFA around the most recent nest Territory Dominant species Total 0-4.9” 5-9.9” >10” dbh dbh dbh

Beldon Flat (2009 Ponderosa pine 89.9 % 0 % 0 % 89.9 % fledged 2) Douglas-fir 10.1 % 0 % 0 % 10.1 % Grass 1.0 % Lodgepole 79.0 % 1.6 % 68.4 % 9.0 % Harley Creek (inactive nest Engelmann spruce 3.9 % 0 % 2.0 % 1.9 % located 2010) Ponderosa pine 1.5 % 0 % 1.5 % 0 % Douglas-fir 14.6 % 1.6 % 11.8 % 1.3 % Grass 7.7 % Lower Logging Creek (2010 Ponderosa Pine 60.8% 0 % 51.0 % 9.8 % fledged 1) Douglas-fir 31.5% 0 % 16.1 % 15.4 % Grass 1.4 %

Mass Creek (2010 Shrub 22.7 % fledged 1) Lodgepole pine 53.5 % 14.7 % 8.1 % 30.7 % Douglas-fir 22.4 % 2.5 % 15.8 % 4.1 % Grass 3.4 % Shrub 4.4 % Yogo Creek (2009 Limber pine 4.3 % 0 % 0 % 4.3 % fledged 2) Ponderosa pine 36.1 % 7.0 % 0.7 % 28.4 % Douglas-fir 51.8 % 0 % 12.4 % 39.3 %

Alternative 1 Effects Direct and Indirect Effects

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Under the No Action Alternative habitat would continue to be impacted by mountain pine beetle and spruce budworm. Mountain pine beetle preferentially attack the largest pine trees in a stand. When beetle densities are high, they will continue to attack smaller diameter trees until the point when the size of the tree no longer allows successful overwintering. The Beldon Flats PFA is composed of trees in the 10” dbh plus size category only, with 90 percent of the PFA dominated by pine species. Insect activity has been noted in the vicinity of this territory (pers. observation). It is likely that most of the pine trees in this PFA will be killed by beetle activity. Harley Creek PFA is 80 percent pine species (primarily lodgepole pine). Most of the trees are in the 5-9.9” dbh size class and are moderately susceptible to beetle kill. Lower Logging Creek is 61 percent ponderosa pine, mostly in the 5-9.9” dbh size class. Mass Creek and Yogo Creek both have approximately 30 percent of their acres in pine species greater than 10” dbh that will likely be killed by pine beetle activity. Yogo Creek would maintain some larger Douglas-fir trees (about 40 percent of the area) although some of these trees may be impacted by spruce budworm. Mass Creek has a smaller component of Douglas-fir (22 percent) that is expected to continue to provide habitat for goshawk. In areas where beetle kill is extensive, as seen in large tracts of forest on the Beaverhead-Deerlodge and Helena National Forests, habitat for goshawk would be of poor quality. The exact impact on the habitat is dependent on the current stand structure and composition, and the level of beetle activity. Goshawk with territories with a large component of ponderosa pine, such as Beldon Flats, would be at increased risk of predation due to lack of cover and increased risk of nest failure from weather. Territories with a mix of species and size classes, such as Yogo Creek, will be less impacted. Cumulative Effects Changes to goshawk habitat from beetle and spruce budworm activity would be cumulative to habitat changes from vegetation projects. The Ettien Ridge and Blankenship projects both plan to remove large trees of all species, reducing some available habitat. The cumulative loss of habitat may impact individual goshawks (particularly those with pine dominated territories), but is not expected to decrease goshawk viability on the Lewis and Clark National Forest due to the large areas where species other than pine are found on the landscapes (Rocky Mountain Front and areas on the north and east of the Little Belt Mountains, see map of treatment areas by dominant vegetation type in the project record).

Alternatives 2 and 3 Effects Direct and Indirect Effects Table 17 displays the amount of goshawk habitat within the Little Belt Mountains, and the acres proposed for treatment in each habitat category. Table 18 shows the amount of habitat within the home ranges of the five nesting territories with proposed treatments near the known nest tree. For each of the action alternatives, trees meeting the hazard tree definition specific to each alternative would be removed in proposed treatment areas. In order to provide a conservative analysis of effects, post implementation acres were calculated assuming all areas proposed for treatment under either alternative would no longer provide habitat. This over estimates the effect

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of the proposed actions because in many areas proposed for treatment, habitat would remain (non-pine species such as Engelmann spruce and Douglas-fir). Effects to Foraging Habitat Both action alternatives are designed to remove hazard trees. Treatment would not appreciably alter foraging habitat as the pine beetle has already altered the habitat by reducing the component of green trees and creating snags. Foraging habitat would remain foraging habitat, although some prey species (such as woodpeckers) may have reduced amounts of habitat in small localized areas where the snags are removed. Across the Little Belt Mountains, the acres of openings would increase at most by just under 4400 acres. As these openings are regenerated the treated acres would return to tree habitat (0-4.9” dbh) within a three to five year period. Within the five impacted nesting territories the acres of openings increases from between 62 acres and 319 acres. In the Mass Creek Territory this results in a 9% increase in area of openings. The mosaic of habitats resulting from implementation and pine beetle activity would provide for a wide variety of prey species. With the northern goshawk’s broad variety of prey items, there would be an increase in the abundance and availability of some individual prey species and a decrease in others. Maintaining habitat diversity, and a variety of niches, results in a greater combined abundance of the entire suite of prey species for goshawk. According to Hargis and others (1994) “emphasis should be placed on creating or maintaining vegetation diversity” and "that timber harvests be designed to create a juxtaposition of seral stages, including mature timber, rather than large tracks of homogeneous, mid-seral stages". Alternative 2 would slightly alter the foraging habitat percentages within stand size class and canopy cover (Table 20). Acres of openings are currently above that indicated by Reynolds and others (1992), and are also above the range found in the Northwestern United States. Beetle activity and the proposed treatments increase the acres of openings by 4387.5 acres, from 16 percent to 17 percent. The 0 to 4.9 inch DBH size class is within the range of that found in the Northwestern United States, and would not be changed. In the 5.0 to 9.9 inch DBH size class the percentages remain the same at 44 percent; within the range of that found in the Northwestern United States. For trees greater than 10” DBH the analysis area is well below that indicated by Reynolds and others (1992), but above that reported by Clough (2000). The proposed action removes 4466.5 acres of this size class. For habitat with trees greater than 5.0 inches dbh and canopy closure greater than 40 percent, the reduction from 64 percent to 63 percent maintains this habitat category within the range reported in the Northwestern United States, and maintains the percent above the 60 percent recommended by Reynolds and others (1992). Habitat diversity within the project area is increasing and niches for a wide variety of prey species and populations in the foraging area are maintained. Effects to Nesting Habitat Hazard tree removal would not alter available nesting habitat, as the actions of the mountain pine beetle have already reduced the nesting habitat available. For the purposes of analysis it was assumed that treatment on the 3944.2 acres of nesting habitat removes that habitat for nesting. This does not alter the percentage of nesting habitat across the Little Belt Mountains. In the five

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impacted nesting territories the amount of nesting habitat not treated ranges from 567 acres to 1577 acres, or 3-8.8 times that recommended to maintain by Reynolds (and others 1992). The acres of trees greater than 5”dbh and greater than 40% canopy also was already reduced by pine beetle, although the extent is not known. In all, the amount of each habitat category treated is extremely small compared to the overall amount of habitat available (Table 17 and Table 18). Timber harvest, which does not retain larger size classes of trees in nesting habitat, can have a negative impact on goshawk productivity (Crocker-Bedford 1990). Both action alternatives would reduce the largest size classes of trees on 4466.5 acres. Treatments are proposed on 3944.2 acres of modeled nesting habitat, or 1.3 percent of the analysis area. The limited nature of the proposed treatments in relation to the analysis area would have a small effect on nesting habitat (Table 17 and Table 18). One identified conservation concern for northern goshawk is the movement of red-tailed hawks into goshawk territories (Samson 2006, as amended by USDA Forest Service 2008b). Daw and Destefano (2001) found that a “mix of age structures was important to protect young against predators, such as the great horned owl and red-tailed hawk.” La Sorte and others (2004) studied habitat associations of red-tailed hawks and northern goshawks living in the same geographic location (Kaibab Plateau in northern Arizona). They found that red-tailed hawks are associated with non-forested areas, steep slopes, and shrub habitat while goshawks are associated with regions of continuous forest and gentle slopes. Neither Alternative 2 nor 3 create larges openings that would be preferred by red-tailed hawks as the treatments are parallel to roads. Nor do the proposed treatments fragment the continuity of the forest within the analysis area (create tracts of forest land surrounded by openings) such that goshawk would not continue to use the area. Proposed treatments would maintain over 290,000 acres of nesting and potential nesting habitat in the analysis area (Table 17). The project analysis shows that following treatment, adequate amounts of nesting habitat would be well distributed across the analysis area to support the estimated number of breeding pairs that could occur. The proposed action would remove dead and dying trees on 1295.3 acres of old growth habitat. As described in the June 2007 C-8 Old Growth Habitat for Goshawk Monitoring Report (USDA Forest Service 2007e, Goshawk Habitat Analysis), goshawks on the Lewis and Clark National Forest appear to select for old growth habitat at the same rate it occurs on the landscape. In other words, goshawk on the Lewis and Clark National Forest do not appear to require old growth habitat for nesting. After implementation, old growth habitat would continue to be well distributed across the landscape. Implementation activities in the project can result in disturbance to nesting and foraging goshawk. It is expected that foraging birds would be displaced away from the disturbance; however as their foraging areas are large (1,200 to 10,000 acres) this is not expected to affect their ability to find prey. Disturbance near the nest can result in nest abandonment early in the nesting season (May and June). Soil conditions are generally too wet to allow logging activities at this time. Short term disturbance would likely not result in nest abandonment, although it is a possibility. The limited operating period from April 15 until August 15 would reduce the impact of disturbance on any nesting goshawk (see Resource Protection Measures above). Effects to Post-Fledging Area

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Table 19 displays the habitat composition within a 420-acre circular PFA centered on the most recent nest for each territory. Table 20 displays the changes in habitat parameters within the PFAs from the proposed action. The analysis assumes treatment would remove all trees, although in actuality only those trees that meet the definition of a hazard under each alternative would be felled. In many cases the trees that would be felled do not currently provide habitat. The trees do still provide foraging habitat and habitat for prey species. In Beldon Flats PFA approximately 3 acres (0.7 percent) of ponderosa pine trees greater than 10” dbh will be felled. In Harley Creek PFA on the 29 acres proposed for treatment, 11 acres (2.6 percent) are dominated by lodgepole pine greater than 5” dbh that would all be felled under Alternative 2. Seventeen acres (4.0 percent) are dominated by Engelmann spruce and Douglas-fir and will likely continue to provide habitat after treatment. There are 51 (12 percent), 40 (10 percent), and 4 acres (1 percent) dominated by large pine species proposed for treatment in the Logging Creek, Mass Creek, and Yogo Creek PFAs, respectively. The proposed treatments occur on relatively few acres of the PFAs and are not expected to result in territory abandonment or nest failure. Table 20: Northern Goshawk habitat acres within impacted Post Fledging Areas surrounding the most recent nest Beldon Flats Harley Logging Mass Creek Yogo Creek Creek Creek

Total acres 419.9 419.9 419.9 419.9 419.9 Acres proposed 2.7 (0.6%) 28.9 (6.9%) 52.2 (13.4%) 85.4 (20.3%) 10.6 (2.5%) treatment >5” dbh & 40% total 412.9 (98%) 318.8 (76%) 340.7 (81%) 213.1 (51%) 340.8 (81%)

>5” dbh & 40% treated 2.7 (0.7%) 14.6 (4.6%) 45.1 (13.2%) 46.9 (22.0%) 2.3 (0.7%) >5” dbh & 40% 410.2 (98%) 304.2 (72%) 295.6 (70%) 166.2 (40%) 338.5 (81%) remaining Openings total 0 (0%) 4.0 (1%) 32.2 (8%) 101.3 (24%) 32.6 (8%)

Openings treated 0 (0%) 0.2 (9.0%) 1.8 (5.6%) 11.1 (11.0%) 5.1 (15.6%) Openings remaining 2.7 (0.6%) 32.9 (8%) 88.4 (21%) 186.7 (44%) 43.2 (10%) Size class >10” total 419.9 (100%) 51.2 (12%) 105.8 (25%) 146.1 (35%) 303.0 (72%)

Size class >10” treated 2.7 (0.6%) 14.1 (27.5%) 11.3 (10.7%) 34.0 (23.3%) 4.6 (1.5%) Size class >10” 417.2 (99%) 37.1 (9%) 94.5 (23%) 112.1 (27%) 298.4 (71%) remaining Size class 5-9” total 0 (0%) 351.5 (84%) 281.9 (67%) 100.2 (24%) 55.1 (13%)

Size class 5-9” treated 0 (0%) 14.2 (4.0%) 43.1 (15.3%) 29.2 (29.1%) 0 (0%) Size class 5-9” 0 (0%) 337.3 (80%) 238.8 (57%) 71.0 (17%) 55.1 (13%)

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Beldon Flats Harley Logging Mass Creek Yogo Creek Creek Creek remaining Size class 0-4” total 0 (0%) 13.3 (3%) 0 (0%) 72.2 (17%) 29.3 (7%) Size class 0-4” treated 0 (0%) 0.5 (3.8%) 0 (0%) 11.1 (11.0%) 0.9 (0.6%)

Size class 0-4” 0 (0%) 13.3 (3%) 0 (0%) 72.2 (17%) 29.3 (7%) remaining Size class 0-4” in 3- 5 2.7 (0.6%) 42.2 (10%) 56.2 (13%) 157.6 (38%) 39.9 (10%) year

Cumulative Effects The mountain pine beetle epidemic within the Little Belt Mountains is impacting goshawk habitat, as described under the no action alternative. Canopy cover is being reduced and large pine trees are dying. In nest territories with a high pine component, goshawk may become more vulnerable to predation. The changes can also affect the prey species available to goshawk, although goshawk are opportunistic and will hunt what is available. The magnitude of these habitat changes and resulting impacts to goshawk cannot be predicted at this time. The Little Belt Mountains Hazard Tree Removal Project would not cause a decline in habitat (the pine beetle has already accomplished that) so there are no cumulative effects from the project. The proposed action alternatives and cumulative loss of habitat from insect activity and other vegetation projects may impact individual goshawks (particularly those with pine dominated territories), but is not expected to decrease goshawk viability on the Lewis and Clark National Forest due to: – The large areas where species other than pine are found on the landscapes (Rocky Mountain Front and areas on the north and east of the Little Belt Mountains, see map of likely treatment locations by dominant vegetation type in Appendix A); – The small amount of acres actually likely to receive treatment across the landscape; and – The limited operating period reducing disturbance in the vicinity of active goshawk nests.

Northern three-toed woodpecker This is the management indicator for tree cavity – conifer, special habitat needs (Forest Plan, p. 2-37). Habitat occurs within the project analysis area. The project would remove potential foraging habitat. Pine beetle activity across the forest will continue to increase foraging habitat. Removal of snags on the approximately 13,599 acres of forested habitat under either action alternative (less than 2 percent of the mountain range) would not appreciably alter available snag habitat on the Little Belt Mountains. See the discussion under black-backed woodpecker for an analysis of current snag levels on the Forest, and the progression of mountain pine beetle activity in the Little Belt Mountains. The Forest Plan recommended snag level for Northern three-toed woodpecker is 72 snags per 100 acres. That level is exceeded under the existing condition and

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would continue to be met across the Little Belt Mountains after implementation of either action alternative. Northern three-toed woodpecker are ranked by the state as S4 – apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining. Due to the small area involved for proposed treatments, as well as the anticipated increase in habitat from the Mountain pine beetle epidemic, the project would not alter viability for Northern three-toed woodpecker.

Cumulative Effects to All Species Due to the widespread nature of this proposed action, there are many past, present, and reasonably foreseeable projects (see list in project record). Forest Health Protection projects within the Little Belt Mountains include verbenone installation and carbaryl application. In addition, this analysis considered the following harvest activities: Mass Geis, Sheep Creek Aspen, Monarch-Neihart, Ettien Ridge, Blankenship, and Showdown Hazard Trees. These projects are removing merchantable and submerchantable trees. The analysis also considered the 2007 Little Belt, Castle and north Half Crazy Mountain Travel Plan decision. In addition to the projects listed above, mountain pine beetle activity across the forest is killing lodgepole and ponderosa pine trees. Fuelwood gathering is removing some of these hazard trees. The primary impact to all species habitat currently is the pine beetle activity. Canopy cover is decreasing, snags and downed wood is increasing, and areas are opening up. Removal of the hazard trees would add cumulatively to the disturbance of species from ongoing project implementation, and to removal of snags for snag dependent species. Wildlife Determinations The proposed Hazard Tree Removal Project would have no effect on threatened grizzly bear. The project may affect, but is not likely to adversely affect threatened Canada lynx and there will be no effect to critical habitat. The proposed actions would not jeopardize proposed wolverine. There would be no impact to bighorn sheep, fisher, gray wolf, northern bog lemming, peregrine falcon, burrowing owl, flammulated owl, greater sage grouse, harlequin duck and greater short-horned lizard. Proposed treatments within action alternatives may impact individuals or habitat for Townsend’s big-eared bat, bald eagle, and black-backed woodpecker, but would not likely result in a trend toward federal listing or reduced viability for the population or species.

Old Growth Management Standard E-4 (9) of the Forest Plan (USDA Forest Service 1986 page 2-44) states that a minimum of 5 percent of the commercial forest land within a timber compartment should be maintained in an old forest condition. Appendix 3 in the Wildlife Report (available in the Project Record) displays the existing acres of old growth by compartment in total (column D), and for those acres on commercial lands (column G). These acres were derived from a database of existing old growth inventory, new old growth survey data, and photo interpretation of vegetation in timber compartments where an inventory has not been completed.

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Treatment activities under the Little Belt Mountains Hazard Tree Removal project are proposed within mapped old growth on approximately 1295 acres within 44 timber compartments. Of these acres, approximately 1130 acres occur on commercial lands. Appendix 4 in the Wildlife Report (available in the Project Record) displays information about proposed treatments by compartment and post-treatment old growth in total and on commercial lands. It was assumed that all old growth would be removed in the project analysis area, although in actuality not all trees would be considered a hazard and some trees would remain after treatment. This table shows that after proposed treatments all Timber Compartments would meet Forest Plan Standard E-4(9) post-treatment except for Timber Compartment 782. Compartment 782 includes a large portion of the Tenderfoot Creek Experimental Forest. Appendix 3 shows that 14.6 percent of the compartment (1087.1 out of 7471.1 acres) is old growth. Within the compartment 613.8 acres are commercial lands. Only 10.9 acres of the old growth within the compartment is on commercial lands (1.8 percent). Appendix 4 shows that 62.5 acres of old growth are proposed for treatment. None of this old growth is on commercial lands. After treatment the compartment would contain 13.7 percent old growth, and there will be no change to the existing 1.8 percent of old growth on commercial lands. The purpose of the Hazard Tree Removal project is to improve public safety through mitigation of hazardous conditions in and around recreation and administrative sites and along open roads. Hazardous conditions are primarily a result of mountain pine beetles (pine species) and spruce budworm (spruce and fir species). Mountain pine beetle preferentially infests and kills older, larger diameter trees. In addition, the hazard and intensity of infestation increases as the quantity of large diameter pine trees increases in a stand. With the current mountain pine beetle epidemic, live pine trees meeting the Green and others (1992) criteria for old growth are highly susceptible to mortality. Spruce budworm defoliates trees, and several years of activity can result in loss of smaller understory trees and damage to the tops of larger, older trees. Under both action alternatives, hazardous trees would be felled. What constitutes a hazardous tree varies by alternative as defined above; under Alternative 2, a tree with a dead top of greater than 5” diameter is considered hazardous. Within the project analysis area, the number of acres in a predominantly pine type was determined, as well as the number of acres in other types. Within the project analysis area there are 590 acres of pine dominated old growth, or 46 percent of the proposed acres of treated old growth. It is likely that mountain pine beetle has killed all of these old growth trees and they may be removed as hazards. On the remaining 54 percent of the acres, other tree species dominate. Some of these acres may remain as old growth after treatment if enough trees that meet the Green and others (1992) definition remain.

Migratory Birds This section summarizes the means by which the project meets USDA Forest Service obligations under the Executive Order 13186 (66 Fed. Reg. 3853, January 10, 2001), Responsibilities of Federal Agencies to Protect Migratory Birds, and the Memorandum of Understanding Between

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the U.S. Department of Agriculture Forest Service and the U.S. Fish and Wildlife Service (USFWS) To Promote the Conservation of Migratory Birds. Executive Order 13186 “directs executive departments and agencies to take certain actions to further implement the (Migratory Bird Treaty) Act.” Pursuant to its MOU, each agency shall “(e)nsure that environmental analyses of Federal actions required by the NEPA evaluate the effects of actions and agency plans on migratory birds, with emphasis on species of concern.” Species of concern refers to those species listed in the periodic report Birds of Conservation Concern (BCC), published by the USFWS Division of Migratory Bird Management; priority migratory bird species as documented by established plans (such as Bird Conservation Regions in the North American Bird Conservation Initiative or Partners in Flight physiographic areas), and those species listed in 50 C.F.R. 17.11 (Threatened and Endangered species). In 2008, the USDA Forest Service and the USFWS entered into a Memorandum of Understanding to Promote the Conservation of Migratory Birds, as directed by Executive Order 13186. Under the MOU, the Forest Service shall: Consult the current USFWS BCC, state lists, and comprehensive planning efforts for migratory birds when developing the list of species to be considered in the planning process. Within the NEPA process, evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors. Birds of Conservation Concern (BCC) was last updated in December of 2008 (USDI Fish and Wildlife Service 2008). Bird Conservation Regions (BCRs) are the smallest geographic scale discussed in the BCC. The BCR lists are most useful to Federal land-managing agencies and their partners in their efforts to abide by the bird conservation principles embodied in the MBTA and Executive Order 13186. The Lewis and Clark National Forest occurs in two BCRs. BCR 10 (Northern Rockies) includes the Rocky Mountain Front, Little Belt Mountains, Castle Mountains, and Crazy Mountain portions of the forest. BCR 17 (Badlands and Prairies) includes the Highwood Mountains, Big Snowy Mountain and Little Snowy Mountain portions of the forest. The Little Belt Mountains Hazard Tree Project occurs within BCR 10. Appendix 2 (datasheet available within the project record) shows the species listed for BCR 10, their status, habitat, and indicates how each species is addressed. Species within BCR 10 with relevance to this project are explicitly discussed below. Calliope Hummingbird According to Calder and Calder (1994) habitat for this species is open montane forest, mountain meadows, and willow and alder thickets. The nest is built on old dead pinecone base so it appears to be a cone. In Montana the species is ranked as S5B, or secure on its breeding habitat. The proposed project will not alter willow and alder thickets or meadows. Under the no action alternative, mountain pine beetle and spruce budworm activity has resulted in more open

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montane forest in some areas, and loss of forested cover in others. The action alternatives would remove dead and hazardously leaning trees, and under Alternative 2 may remove the forest patch if it is a true pine type (ponderosa pine or lodgepole pine). The habitat changes due to the action alternatives occur on a small area relative to the Little Belt Mountains, and are not expected to result in impacts to calliope hummingbird populations. Lewis’s Woodpecker Lewis’ woodpecker is a summer, breeding resident in Montana. Habitat is open forest and woodland; often logged or burned; primarily ponderosa pine. Distribution is closely associated with open ponderosa pine forest and is strongly associated with fire maintained old growth ponderosa pine with a shrub understory. Lewis’ woodpecker primarily forages on insects during the summer, and catch insects in the air. There is no burned ponderosa pine forest in the the project analysis area. The treatment areas include 975 acres of ponderosa pine stands (7 percent of the treatments and 0.1 percent of the Little Belt Mountains). In Montana the species is ranked S2B, on breeding habitat at risk because of very limited and/or potentially declining population numbers, range and/or habitat, making it vulnerable to global extinction or extirpation in the state. Under the no action alternative, mountain pine beetle have killed pine trees, particularly the larger, old growth trees in areas were the beetle is active, thereby increasing potential nest cavity habitat for this species. In areas where all trees have died, beetle activity decreases available habitat, as this woodpecker is found in forested areas. Under the action alternatives, dead pine trees and hazardously leaning trees (live and dead) would be removed, thereby removing some potential nesting habitat for Lewis’s woodpecker. Under Alternative 2 green lodgepole pine, as well as other species that meet the definition of a hazard tree (dead topped, mistletoe infected, etc.), would be removed. Snags for this species would be provided outside of the the project analysis area by current mountain pine beetle activity on the Forest, as well as current snag levels in the Little Belt Mountains (see Mountain Pine Beetle progression maps in Appendix F). The small area treated in relation to the Little Belt Mountains, the increasing amount of cavity habitat provided by current mountain pine beetle activity, as well as the limited acres of ponderosa pine type in the treatment areas (see Table 2) indicate this project would not reduce potential foraging habitat for this species, nor contribute to notable loss of cavity nest habitat for Lewis’s woodpecker in the Little Belt Mountains. Olive-sided Flycatcher The Olive-sided flycatcher generally breeds in the montane and boreal forests. Most often associated with post-fire habitat but may also be found in other forest openings such as clear cuts and other disturbed forested habitat. Olive-sided flycatcher is common in spruce and aspen; uncommon in mixed-conifer, ponderosa pine, pine-oak, and cedar-hemlock; rarely present in lodgepole pine or pinyon-juniper. In Montana, the species is ranked S4B, meaning it is apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining on its breeding range. As described under Calliope hummingbird, forested types in the Little Belts Mountains are being disturbed by mountain pine beetle and spruce budworm activity. Under the action alternatives, only 741 acres of spruce forest (see Table 2), where olive-sided

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flycatcher are common, occurs within proposed treatments. Forty-two percent of the project analysis area (5,814 acres) occur in mixed-conifer or pine types where the species is uncommon. Another 47 percent (6,444 acres) of the proposed treatments areas occur in lodgepole pine, where the species is rarely found. Although spruce budworm and other agents have killed some spruce across the Little Belts, proposed treatments under both action alternatives would not be expected to remove large areas of preferred habitats and therefore would not impact populations of olive- sided flycatcher. Willow Flycatcher This species is strongly tied to brushy areas of willow and similar shrubs. Threats include factors that destroy or degrade shrubby riparian vegetation. Habitat loss and alteration is principle cause of decline. The project does not propose to treat brushy areas of willow and similar shrubs in riparian areas. Habitat for willow flycatcher would not be altered or destroyed. Loggerhead Shrike Loggerhead shrike breed in open country with scattered trees and shrubs. Year-round habitat is found on the Little Belt Mountains. Treatments would open the areas more, leaving scattered trees outside the treatment areas or areas with scattered fir. It is unlikely the proposed treatments would make the treated area unsuitable for loggerhead shrike, and may provide habitat for shrike in some areas. Cassin’s Finch Cassin’s finch prefers open coniferous forests along with mature forests of lodgepole pine. This is a Montana Species of Concern with a state rank of S3, potentially at risk because of limited and/or declining numbers, range and/or habitat, even though it may be abundant in some areas. Since pine beetle attack larger sized trees, it is likely that mature forests of lodgepole have already become unsuitable for this species. The project proposes to remove dead and dying lodgepole pine killed by mountain pine beetle that pose a hazard to recreation and administrative users. In addition, some live lodgepole would be removed under Alternative 2 if the density of the stand is reduced to where wind-throw of remaining trees is likely. Approximately 6,444 acres (less than 1 percent of the Little Belt Mountains) of Lodgepole pine are proposed for treatment. Due to the small area treated in relation to the Little Belt Mountains, and the impact mountain pine beetle activity has already had on the preferred habitat of this species, removal of hazard trees would not be expected to impact Cassin’s finch populations.

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Environmental Justice It is unlikely that implementation of either action alternative would adversely affect minority or low-income populations.

Federal, State, and Local Agencies Contacted Montana Department of Fish, Wildlife, and Parks State Historic Preservation Office Cascade County Commissioner Meagher County Commissioners Wheatland County Commissioners Judith Basin County Commissioners

Tribes Contacted Confederated Salish Kootenai Tribes Arapaho Business Council Northern Arapaho Tribal Historic Preservation Office Blackfeet Tribal Business Council & Historic Preservation Office Chippewa Cree Business Committee, Cultural Committee, & Historic Preservation Office Crow Cultural Committee, Tribal Council, & Historic Preservation Office Eastern Shoshone Business Council, Cultural Director, & Historic Preservation Office Fort Belknap Tribe Gros Ventre Treaty Committee, Fort Belknap Tribe Assiniboine Treaty Committee, Fort Belknap Tribe Assiniboine: White Clay Society, Fort Belknap Tribe Fort Peck Cultural Representative Little Shell Band Cultural Representative Northern Cheyenne Tribal Council & Historic Preservation Office Nez Perce Tribal Historic Preservation Office Sho-ban Chairperson & Cultural Committee Wind River – Eastern Shoshone Business Council Northern Cheyenne Tribal Council President

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Finding of No Significant Impact It is my duty as the responsible official to evaluate the effects of the project relative to the definition of significance established by the CEQ Regulations (40 CFR 1508.13). I have reviewed and considered the EA and documentation included in the project record, and I have determined that the proposed action and alternatives will not have a significant effect on the quality of the human environment. As a result, no environmental impact statement will be prepared. My rationale for this finding is as follows, organized by sub-section of the CEQ definition of significance cited above. Context For the proposed action and alternatives the context of the environmental effects is based on the environmental analysis in this EA. This project analysis area spans 17,337 acres and proposes felling hazard trees in 58 recreation special use sites, 157 recreation sites, 5 non-recreation special use sites, and along 575.4 miles of open forest roads. The project analysis area was intentionally developed to incorporate areas where hazards are the most imminent; where we expect to see tree failure that would compromise the safety of Forest Service personnel, the public, or Forest Service infrastructure in the next five to fifteen years (Mitchell and Preisler, 1998). In particular, the Proposed Action is an attempt to address this concern in a timely manner with the resources we have available. Hazard trees would be felled and removed or felled and left on site depending on management direction (e.g. within the WSA). Approximately 46 percent (7915 acres) of the project analysis area is dominated by mountain pine beetle-susceptible pine species. About 23 percent (1847 acres) of the pine-dominated acres are composed primarily of seedling and sapling-sized trees (0- 4.9” dbh), a size class not expected to show mortality due to beetle activity (Vegetation Description Report, page 2). Thus, approximately 6,000 acres, within the 17,337 acre analysis area, are those areas most likely to receive treatments based on forest cover. Within these acres, only hazard trees would be removed. The project involves actions that are routinely performed on the Lewis and Clark and other national forests nationwide. No roads will be constructed for this project. The Little Belt Mountains Hazard Tree Removal Project Environmental Assessment documents effects, detrimental and beneficial, derived from project implementation. Short-term adverse effects would be mitigated through implementation of Best Management Practices, resource protection measures, and project design features. Intensity Intensity is a measure of the severity, extent, or quantity of effects, and is based on information from the effects analysis of this EA and the references in the project record. The effects of this project have been appropriately and thoroughly considered with an analysis that is responsive to concerns and issues raised by the public. The agency has taken a hard look at the environmental effects using relevant scientific information and knowledge of site-specific conditions gained

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from field visits. My finding of no significant impact is based on the context of the project and intensity of effects using the ten factors identified in 40 CFR 1508.27(b).

1. Impacts that may be both beneficial and adverse. A significant effect may exist even if the Federal agency believes that on balance the effect will be beneficial.

Beneficial Effects Fisheries: Water and sediment yields directly related to tree removal are not likely to be measurably affected (page 26). In the long-term, a net decrease in sediment delivery to project area streams would occur from BMP work performed on project roadways (page 29). Fuels: Implementation of Alternative 2 would maintain effective ingress and egress routes for landowners, recreationists, firefighters, and other Forest Service personnel (page 32). Heritage: Alternative 2 has the potential to have a beneficial effect on some historic properties or unevaluated cultural resources as the removal of the hazardous trees would reduce the potential of trees falling on and damaging standing historic structures (page 34). Hydrology: It is anticipated that project activities would result in a net decrease of sediment delivery to project area streams. Both action alternatives require that all haul roads with known sediment-delivery points be improved to reduce delivery prior to commencement of tree removal and hauling. Several generic road segments were modeled in order to estimate potential reductions in sediment delivery resulting from project road improvements. Results indicate that sediment delivery would decrease on an annual average basis by roughly 90% (page 38). Inventoried Roadless Areas: Some forest visitors may prefer to recreate in areas where hazard trees have been removed. The cutting and removal within IRAs of hazard trees along some road segments may enhance opportunities for dispersed recreation, especially camping (page 51). Recreation: Both action alternatives would provide for safer recreation and roadside areas in the Little Belt Mountains. Hazard removal would be uniform and timely, and recreation staff would be more available for required tasks associated with developed sites. Hiring contract fallers and mechanized equipment for tree removal is also more cost effective and ensures a consistent and coordinated implementation of hazard tree removal (page 56). Scenery: At a smaller scale, indirect impacts could include accelerated growth of understory vegetation. This can, depending on site-specific conditions, increase the variety of color and texture seen in the landscape and result in positive long term effects to the scenic quality (page 62).

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Sensitive Plants: Removal of newly infested whitebark pine trees prior to beetle flight, however, could reduce localized beetle populations and may make some residual whitebark pine trees less susceptible to beetle-caused mortality (pages 65-66). Vegetation: Windfall, depending upon its intensity and scale, has the potential to reduce stand density, release individual understory trees from competition, or regenerate a stand. Potential forest vegetation changes, along with past harvest, would cumulatively add to structural and age class diversity in the Little Belt Mountains. Because mature forest structure is predominant in the Little Belt Mountains, creating additional diversity would be beneficial (page 72). Wildlife: Alternatives 2 would regenerate up to 5,243 acres. This could create habitat for the Canada lynx’s primary prey species, snowshoe hare, in the future.

Adverse Effects Air Quality: Pile burning would have a temporary, short-term effect on the air quality within and immediately adjacent to the project area. All pile burning activities would be coordinated through the Montana Airshed Group to ensure that atmospheric conditions were conducive for good smoke dispersion and fuel consumption (page 25-26).

Fisheries: Direct effects to aquatic habitats would occur during BMP road work at stream crossings. Some effects may also occur from BMP related maintenance where roads immediately parallel streams and from site level bank disturbances during stream crossing construction or maintenance activities. Road BMPs application would minimize short-term effects. Any temporarily elevated levels of sediment would be too low to induce mortality or reproductive failure in fish, amphibian, and mussel species.

In Moose and Jefferson Creeks, the reduction of expected increases in woody debris could hit moderate levels. However impacts would not affect viability because SMZ BMPs would allow for sufficient woody debris recruitment within treatment areas. Hazard tree removal in the longer segments of Jefferson and Moose Creek could also result in slightly higher daytime conditions for reaches within the project area and for a few hundred meters below. However, these temperatures would still be far below thermal limits observed for distribution and survival of the westslope cutthroat trout, which is the fish species most sensitive to elevated temperatures in the project area.

Hydrology: Both action alternatives would temporarily expose mineral soil to erosion, and may create new (or exacerbate existing) vectors for sediment transport to stream channels. However, best management practices application would minimize erosion from treatment areas. Furthermore, where erosion from a treatment unit occurs, streamside management zone (SMZ) protection measures and buffers would prevent transport of eroded sediment from treatment areas directly to streams. Additionally, blading of native- surface roads temporarily exposes higher levels of sediment to erosion and transport.

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Compaction of freshly bladed surfaces prior to rainfall, which would occur under proposed activities, reduces this temporary road surface susceptibility to erosion (page 38). The likelihood that the proposed action would meaningfully contribute to any stream temperature increase is small, given the relatively short stream segments along which treatment would occur, and given the minimal removal of vegetation in SMZs.

Inventoried Roadless Areas: The felling, and removal within IRAs, of hazard trees could slightly degrade the natural character of the IRAs and WSA. The landing areas where slash had been piled and chipped, removed, or burned would also appear unnatural for a period of about five years until new vegetation covers the landscape. Both action alternatives would slightly impact the undeveloped character of the IRAs and WSA. The existence of roads may have a greater impact on the undeveloped character than the removal of adjacent hazard trees. Action alternatives would allow for greater sight distance from Forest roads into the IRAs and WSA as well as for noise to carry further into those areas than if the hazard trees remained standing. Both of these factors could slightly reduce the subjective value of solitude. However, hazard trees are not anticipated to remain standing long-term (greater than 15 years) as they would fall naturally. There are no unique geological, biological, ecological, scenic, or cultural features adjacent to roads within the IRAs or WSA that would be impacted through the removal of hazard trees. The removal of hazard trees along Forest roads would not result in changing any IRA or WSA boundaries. However, hazard tree removal could result in increased off- route vehicle violations because some areas adjacent to Forest roads would become more open.

During those periods when felling, and removal within IRAs, occur opportunities for dispersed recreation (hiking, hunting, fishing, etc.) would be impacted. This would be a short-term impact that would only last until the trees were felled and removed. Some visitors would be displaced to other areas until treatment activities were completed.

Noxious Weeds: Due to the implementation of noxious weed BMPs and the revegetation of disturbed areas, and the ongoing noxious weed control program, it is anticipated that the overall acreage of noxious weed infestation would remain fairly static. Prescribed noxious weed prevention, control, and monitoring activities would effectively reduce and mitigate any effects.

Recreation: Removal of vegetative cover may make recreation (dispersed and developed) sites less desirable, which could result in displacement to other areas where live trees remain; accumulated slash could cover existing dispersed recreation sites making some of them difficult to identify; dispersed recreation sites would be temporarily unavailable for recreation use while harvest activities are occurring; log hauling on some Forest roads would temporarily increase traffic and may affect the recreation experience for some; trees serving as assurance markers could be cut down and informational

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signage could potentially be knocked down or destroyed, which would need to be reinstalled prior to the use season; Removal of hazard trees in a few locations may affect snow accumulations and drifting patterns on roads which also serve as snowmobile trails; and hazard tree removal along Forest roads could facilitate development of new dispersed sites by the public. These impacts are minimal in scope and are therefore not significant to recreation opportunities in the Little Belt Mountains (page 56).

Indirectly, the cutting and removal of hazard trees could result in additional motorized impacts due to unauthorized access around gates and violations adjacent to Forest roads and existing closure gates. Truck traffic for log hauling and the associated dust and noise may be an inconvenience and potential safety hazard to Forest visitors. However, access and traffic effects would be short-term in impact and would be minimized by resource protection measures (page 57).

Hazard tree removal along roads which also serve as groomed snowmobile trails may present some additional safety hazards. Stumps, especially those that may be greater than 6-8” in height, and slash piles which protrude through the snow could become obstructions along or adjacent to groomed snowmobile routes during the winter months (page 57).

Scenery: Created openings and a reduction in overhead canopy and screening would result from implementation of action alternatives. In addition, cut stumps would be visible. These short term impacts would decrease over time as stumps and mulch weather, and young trees and herbaceous understory vegetation re-establishes. Resource protection measures have been developed to ensure impacts to the scenic resources are minimized and regeneration is accelerated (page 61-62).

Sensitive Plant Species: Potential treatment areas overlap known populations of short- styled columbine, Northern rattlesnake-plantain, Northern wildrye, Missoula phlox, Austin’s knotweed, and whitebark pine. Although Missoula phlox and Austin’s knotweed are known within the project area, their habitat requirements limit the potential that either action alternative would incur negative impacts. Missoula phlox populations in the analysis area are restricted to wind-swept meadows where management actions would not occur due to lack of trees. Three of the thirty known Austin’s knotweed populations in Montana are located within or adjacent to the Fawn Creek Road (FS Road 6393, T10N, R10E). Management actions may lead to a loss of individuals, but actions would be limited in the open, gravelly habitat that Austin’s knotweed prefers due to lack of trees (page 64).

Based on available vegetation data, treatment areas within and adjacent to Northern wildrye support a limited quantity of trees that would be considered for removal under either action alternative. Loss of individual plants or habitat is expected to be minimal, if

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at all. Short-styled columbine and Northern rattlesnake-plantain are present in the project analysis area. Implementation of resource protection measures would minimize impacts to individual plants or the population as a whole through protection from ground disturbance or herbicide application. Although individual plants or habitat may be impacted, this alternative would not likely contribute to a trend towards federal listing or loss of viability to the population or species (page 65).

Whitebark pine defined as a hazard tree under this alternative have the potential to be felled on about 235 acres. Felling dead whitebark pine would not affect the species’ viability because these trees are not contributing to the next generation. Likewise, bark beetle infested green trees would be dead within the next year (page 65).

Soils: Under both action alternatives, detrimental soil disturbance would occur. Soil would be detrimentally disturbed by compaction, displacement, rutting, and erosion in the areas affected by skid trails in the short-term. Over the long-term, soils affected by detrimental disturbance on main skid trails would recover through natural processes. However, recovery of soils to pre-disturbance conditions would likely take 100 years or longer. In the short-term, soils at log landings sites would be detrimentally disturbed during operation of heaving equipment for log processing. Upon completion of harvest activities, reclamation of log landings through soil scarification, seeding, placement of woody debris, and recontouring (if needed), would promote recovery of soils in the long- term (page 70).

Hazard tree removal in areas with previous harvest may cause detrimental soil disturbance to exceed R1 Soil Quality Standards. Therefore, these units would not be reentered with ground based equipment (see resource protection measure for soils, page 22). In hazard tree treatment analysis areas with no previous activities, detrimental soil disturbances are anticipated to be below R1 Soil Quality Standards, averaging 5 percent detrimental soil disturbance for winter logging and 8 percent for summer logging (page 70).

Vegetation: Removal of hazard trees under Alternative 2 could result in conditions similar to a clear-cut. This treatment would eliminate or greatly reduce windfall potential within the unit.

Wildlife: Two Threatened and 14 Sensitive wildlife species are known or suspected to occur on the Lewis & Clark National Forest. A Biological Assessment was completed for the project and is included in the project file. Action alternatives may affect, but are not likely to adversely affect threatened Canada lynx and would have no effect on grizzly bear and Canada lynx critical habitat. Implementation of the proposed project may impact individuals or habitat, but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population1 or species for wolverine.

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There would be no impact to bighorn sheep, fisher, the gray wolf, northern bog lemming, peregrine falcons, burrowing owl, flammulated owl, greater sage-grouse, harlequin duck, or the greater short-horned lizard. Action alternatives may impact individuals or habitat, but would not likely contribute to a trend toward federal listing or loss of viability to the population or species for Townsend’s big-eared bat, the bald eagle, and the black-backed woodpecker.

2. The degree to which the proposed action affects public health or safety. The proposed action, which would reduce the risk and exposure of the public, personnel, and infrastructure to hazard trees, would improve public safety. Furthermore, by following resource protection measures for air quality; the proposed action will have no significant adverse effects on public health and safety. Most activities—including the use of mechanical equipment to remove trees from units—will be completed during periods of low visitor use. Routine signing, minimal traffic control, and public outreach will educate visitors about the presence of equipment and activities.

3. Unique characteristics of the geographic area such as the proximity to historical or cultural resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. Treatment activities will improve safety conditions along US Highway 89, the Kings Hill Scenic byway, by removing trees whose failure would be likely to impact a road, Forest Service infrastructure18, or the intended use of either. Short-term impacts such as openings will be minimized by resource protection measures and will diminish with time (see Scenery section above). Site-specific cultural resource inventories would be completed prior to implementation based on the Forest Site Identification Strategy (SIS) found in Region One’s Programmatic Agreement between the Forest Service and Montana State Historic Preservation Officer. All identified historic properties or unevaluated sites would be avoided, treated, or mitigated to prevent adverse effects according to the Protocols: Bark Beetle Epidemic and Hazardous Tree and Fuel Reduction, USDA Forest Service, Northern Region. There are no parklands, prime farmlands, wild and scenic rivers, or ecologically critical areas in the project area. Wetlands do occur in the project analysis area; however, no activities are planned to occur on wetlands.

18 Infrastructure includes, as defined by Merriam-Webster, the system of public works of a country, state, or region and the resources (as personnel, buildings, or equipment) required for an activity

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4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. The effects on the quality of the human environment are not likely to be highly controversial. The effects analysis was conducted using scientific methodologies and did not indicate that the effects of this project would be highly controversial. Public comments received also did not indicate that effects of project implementation would be highly controversial given feedback from partner agencies. Furthermore, neighboring forests have successfully implemented similar treatment activities under categories that are excluded from initiating an environmental assessment. Finally, the analysis area, which is a thin boundary along roads and within administrative and special use sites, represents less than 2% of forested acres in the Little Belts Mountains.

5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. Treatment applications would only affect those trees that qualify as a hazard, determined by a professional forester. Furthermore, hazard tree removal is a common practice on the Lewis & Clark National Forest and on national forest lands nationwide. Activities associated with this project are at a small scale and are unlikely to have uncertain, unique, or unknown risks.

6. The degree to which the action may establish precedent for future actions with significant effects or represents a decision in principle about a future consideration. The selected alternative does not set a precedent for future actions with significant results. The proposed action represents routine risk management and is consistent with Forest Plan direction including the snag amendment detailed below. The action does not represent a decision in principle about a future condition.

7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. The effects of the selected action along with other past, present, or reasonable foreseeable activities will not have significant cumulative effects. Resource-specific analysis and conclusions are discussed in the Environmental Assessment for Air Quality (page 26), Fisheries (pages 28-30), Fuels (page 33), Heritage (no effects, therefore no cumulative effects), Hydrology (page 38 & page 40), Inventoried Roadless Areas (page 49 &52), Noxious Weeds (page 53 & 54), Recreation (page 56, 57, & 58), Scenery (page 60, 62, & 63), Sensitive Plants (page 64, 66, & 67), Soils (page 69 & 70), Vegetation (page 73), and Wildlife (organized by species, begins on page 73).

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8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. Site-specific cultural resource inventories would be completed prior to implementation based on the Forest Site Identification Strategy (SIS) found in Region One’s Programmatic Agreement between the Forest Service and Montana State Historic Preservation Officer. All identified historic properties or unevaluated sites would be avoided, treated, or mitigated to prevent adverse effects according to the Protocols: Bark Beetle Epidemic and Hazardous Tree and Fuel Reduction, USDA Forest Service, Northern Region. Consultation with the SHPO will be finalized prior to project implementation.

9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. A Biological Assessment was completed for the project and is included in the project file. The proposed action May Affect but is not likely to adversely affect threatened Canada lynx and will have No Effect on Canada lynx critical habitat. In addition, wildlife analysis concluded that the proposed action will have No Effect to threatened grizzly bears.

10. Whether the action threatens a violation of Federal, State, or local law or requirements imposed for the protection of the environment. The selected action meets Federal, State and local requirements for heritage resources (page 34); threatened, endangered and sensitive species and fisheries (Project Record and pages 26 & 72); soil resources (page 67); and complies with the Lewis and Clark Forest Plan with the Forest Plan amendment included. It also meets National Environmental Policy Act requirements for disclosure

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Vanderzanden, D.; Brown, S.; Ahl, R.; and Barber, J. 2010. Eastside R1-VMap Accuracy Assessment (Lewis and Clark, Helena, Custer and Gallatin National Forests). Region One Vegetation Classification, Mapping, Inventory and Analysis Report, Numbered Report 10-6.

Westerling, A.L., H.G. Hidalgo, D.R. Cayan, and T.W. Swetnam. 2006. Warming and earlier spring increase western U.S. forest wildfire activity. Science 313: 940-943.

White, D. M. 1996. Microhabitat conditions of Goodyera repens populations at Burley Peak, Lewis and Clark National Forest, Judith Ranger District, Judith Basin County, Montana. University of Great Falls, Department of Biology.

Wisdom, M.J. 2006. Personal communication. Research Wildlife Biologist, Pacific Northwest Research Station, U.S. Department of Agriculture, La Grande, Oregon. February 27, 2006.

Wisdom, M.J., A.A. Ager, H.K. Preisler, N.J. Cimon, and B.K. Johnson. 2005. Effects of off- road recreation on mule deer and elk. In: Wisdom, M.J., tech. ed. The Starkey Project: a synthesis of long-term studies of elk and mule deer. Reprinted from the 2004 Transactions of the North American Wildlife and Natural Resource Conference. Lawrence, KA: Alliance Communications Group. Pages 67-80.

Ziesak, R., 2008. Montana Forestry Best Management Practices Monitoring: 2008 Forestry BMP Audit Report. Forestry Division, Montana DNRC, Missoula. 66 pp.

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Appendix A: Project Analysis Area and Likely Treatment Locations Maps Figure 2 : Project Area Analysis Map – Eastern Half of Project Area

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Figure 3: Likely Treatment Areas based on Dominant Forest Cover – Eastern Half of Project Area

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Figure 4: Project Analysis Area Map – Western Half of Project Area

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Figure 5: Likely Treatment Areas based on Dominant Forest Cover – Western Half of Project Area

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Appendix B: Roads and Sites included in Project Analysis Area Table 21: Roads with potential for treatment based on presence of hazard trees Miles Management Road Name Road ID County USFS District Analyze Area d Adams Creek 6414 Cascade Belt Creek B 0.01 White Sulphur Adams Creek 6414 Cascade B 0.76 Springs White Sulphur Adams Creek 6414 Meagher A, B 6.50 Springs White Sulphur Allen Gulch 1036 Meagher A, B 3.60 Springs White Sulphur Allen Park 6416 Meagher B, H 0.64 Springs Anderson Road White Sulphur 260 Cascade F 1.04 Easement Springs Anderson Road White Sulphur 263 Cascade F 2.16 Easement Springs Ask Road Permit 1049001 Cascade Belt Creek H 0.13 Aspen Camp 1076 Cascade Belt Creek H 0.19 Balsinger Creek 839-E Cascade Belt Creek F 0.08 Balsinger Creek 839-E Meagher Belt Creek F 0.04 White Sulphur Balsinger Creek 839-E Cascade F 0.07 Springs White Sulphur Balsinger Creek 839-E Meagher F 0.02 Springs Barry Nolan Permit 3360 Cascade Belt Creek E, F, H 2.38 Basin Creek 6429 Meagher Musselshell B 2.51 Belt Creek Info. Station 1122 Cascade Belt Creek H 0.40 Belt Park Connector 6511 Cascade Belt Creek B, H 2.51 White Sulphur Bills Gulch Road 6483 Meagher B 0.88 Springs White Sulphur Bonine Creek 6494 Meagher A, B 2.79 Springs White Sulphur Buffalo Springs 6472 Meagher A, B 3.20 Springs Judith Butcherknife 2000 Judith Basin B 3.92 Basin Judith Butcherknife-Snow 2001 Judith Basin B 1.08 Basin C-839267 839-J Cascade Belt Creek B 0.11 Camp Rotary 1049 Cascade Belt Creek H, S 1.37 Judith Campsite-Villars 6366 Belt Creek B 0.33 Basin

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Miles Management Road Name Road ID County USFS District Analyze Area d Carpenter Creek 3323 Cascade Belt Creek H, L 2.60 Chamberlain 3328 Cascade Belt Creek B, G, H 9.57 Judith Chamberlain 3328 Belt Creek B, G 7.12 Basin White Sulphur Charcoal Gulch System 1 6474 Meagher A 1.94 Springs White Sulphur Charcoal Gulch System 2 6475 Meagher A, B 1.97 Springs Charles Jennings Permit 6384001 Cascade Belt Creek B 1.70 White Sulphur Coyote Creek 6406 Meagher B 2.42 Springs Cund839264 839-I Cascade Belt Creek B 0.21 Cund839266 839-H Cascade Belt Creek B 0.53 White Sulphur Deadman Creek 837 Meagher A, B 4.98 Springs Deep Creek Trailhead 839-A Cascade Belt Creek H 0.12 Deep Creek Trailhead 839-A1 Cascade Belt Creek H 0.04 Spur Loop Deer Creek Landowners White Sulphur 839067 Meagher B, F 0.20 Permit Springs Dennis & Terry Vidic White Sulphur 6470 Meagher B, C 1.71 Permit Springs Dennis & Terry Vidic White Sulphur 6470004 Meagher C 0.43 Permit Springs B, E, F, H, K, Divide Road 839 Cascade Belt Creek 25.48 M Divide Road 839 Meagher Belt Creek B, F 8.77 White Sulphur Divide Road 839 Meagher B, F 3.03 Springs White Sulphur Dry Creek System 1 6467 Meagher B, F 7.38 Springs Dry Fork Belt Creek 120 Cascade Belt Creek A, H, L 17.47 Judith Dry Fork Belt Creek 120 Belt Creek A, B, L 10.66 Basin Judith Dry Fork Belt Creek 120 Judith Basin A, B, L 14.09 Basin Dry Fork Dispersed 6363-A Cascade Belt Creek A, L 0.18 6363-A Dry Fork Dispersed A 120-A Cascade Belt Creek H 0.07 Dry Fork Dispersed B 120-B Cascade Belt Creek H 0.05 Dry Fork Dispersed C 120-C Cascade Belt Creek H 0.17

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Miles Management Road Name Road ID County USFS District Analyze Area d Dry Fork Dispersed D 120-D Cascade Belt Creek A 0.06 Dry Fork Dispersed E 120-E Cascade Belt Creek A 0.06 Dry Fork Dispersed F 120-F Cascade Belt Creek A 0.04 Dry Fork Dispersed G 120-G Cascade Belt Creek A 0.29 Dry Fork Dispersed G1 120-G1 Cascade Belt Creek A, H 0.09 Dry Fork Dispersed H 120-H Cascade Belt Creek A 0.09 Dry Fork Dispersed I 120-I Cascade Belt Creek A 0.07 Dry Fork Dispersed J 120-J Cascade Belt Creek A 0.16 Dry Fork Dispersed J 120-J1 Cascade Belt Creek A 0.02 Dry Fork Dispersed J 120-J2 Cascade Belt Creek A 0.03 Dry Fork Dispersed J 120-J3 Cascade Belt Creek A 0.04 Dry Fork Dispersed J 120-J4 Cascade Belt Creek A 0.02 Dry Fork Dispersed J 120-J5 Cascade Belt Creek A 0.14 Judith Dry Fork Dispersed K 120-K Belt Creek A 0.39 Basin Judith Dry Fork Dispersed K1 120-K1 Belt Creek A 0.05 Basin Dry Fork Dispersed L 120-L Cascade Belt Creek A 0.07 Dry Fork Dispersed M 120-M Cascade Belt Creek A 0.17 Dry Fork Dispersed N 120-N Cascade Belt Creek A 0.13 Dry Fork Dispersed N1 120-N1 Cascade Belt Creek A 0.13 Dry Fork Dispersed O 120-O Cascade Belt Creek A 0.11 Dry Fork Dispersed P 120-P Cascade Belt Creek A 0.11 Dry Fork Dispersed Q 120-Q Cascade Belt Creek A 0.35 Dry Fork Dispersed Q1 120-Q1 Cascade Belt Creek A 0.13 Judith Dry Fork Dispersed R 120-R Belt Creek L 0.09 Basin Judith Dry Fork Dispersed R1 120-R1 Belt Creek L 0.08 Basin Judith Dry Fork Dispersed R2 120-R2 Belt Creek L 0.13 Basin Judith Dry Fork Dispersed S 120-S Belt Creek B 0.06 Basin Dry Park 253 Cascade Belt Creek B 1.38 Dry Park 253 Meagher Belt Creek B, K 0.84 Dry Wolf 251 Cascade Judith Basin B, H 4.93 Judith B, E, F, G, H, Dry Wolf 251 Judith Basin 27.04 Basin L Judith Dry Wolf Campground 9184 Judith Basin H 0.54 Basin

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Miles Management Road Name Road ID County USFS District Analyze Area d Judith Dry Wolf Trailhead 9184-A Judith Basin B, H 0.14 Basin White Sulphur East Deadman Creek 2054 Meagher A, B 0.56 Springs Judith East Villars 6362 Belt Creek B, F 1.64 Basin Judith Ettien Ridge 821 Judith Basin B, C, I 2.28 Basin Fawn Creek 6393 Meagher Musselshell B, E, G 4.50 Judith Gary & Diana Grassel 3348-A Judith Basin G 0.25 Basin White Sulphur Geis Creek System 6470 Meagher B, C 2.16 Springs Judith Gold Run 3302 Belt Creek B, L 3.92 Basin White Sulphur Green Mtn. Road System 6484 Meagher A, B 1.29 Springs Harley Creek 834 Cascade Belt Creek B, H 3.18 Hay Canyon Judith 2097 Judith Basin H 0.05 Campground Basin White Sulphur Higgins Park 6464 Meagher A, B, C, F 11.89 Springs Wheatlan High Mountain 382 Musselshell C, E, G 1.81 d Judith Holiday Camp 821-A Judith Basin B 0.17 Basin Judith Hoover Mountain 2049 Judith Basin B 2.43 Basin Hoover Mountain 2049 Meagher Musselshell B 0.96 Judith Hoover Springs 6394 Judith Basin C 1.10 Basin Judith Hoover Springs 6394 Musselshell C 0.07 Basin Hoover Springs 6394 Meagher Musselshell B, C 3.03 Hughesville 6403 Cascade Belt Creek L 0.40 Judith Hughesville 6403 Belt Creek L 0.71 Basin Hunter Spring G.S. 2035 Meagher Musselshell B 0.15 Hwy 89 US 89 Cascade Belt Creek H, S 23.06 White Sulphur Hwy 89 US 89 Meagher A, H, S 19.01 Springs Indian Hill Campground 9210 Judith Judith Basin H 0.17

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Miles Management Road Name Road ID County USFS District Analyze Area d Basin White Sulphur Island Park 6407 Meagher B, F 4.87 Springs James & Cindy Kulish Judith 3303-B Judith Basin B 0.11 Permit Basin Jamison Trail Road 47 Meagher Musselshell B 3.63 Jeep Road 6 Df 6363 Cascade Belt Creek A, L 0.26 Jeep Road Carpenter 6352 Cascade Belt Creek L 1.30 Jefferson Cr Dispersed A 267-A Cascade Belt Creek H 0.04 Jefferson Cr Dispersed B 267-B Cascade Belt Creek H 0.07 Jefferson Cr Dispersed C 267-C Cascade Belt Creek H 0.04 Jefferson Cr Dispersed D 267-D Cascade Belt Creek G 0.07 Jefferson Cr Dispersed E 267-E Cascade Belt Creek G 0.05 Jefferson Cr Dispersed F 267-F Cascade Belt Creek B 0.08 Jefferson Cr Dispersed G 267-G Cascade Belt Creek B 0.28 Jefferson Cr Dispersed H 267-H Cascade Belt Creek B 0.03 Jefferson Cr Dispersed I 267-I Cascade Belt Creek B 0.01 Jefferson Cr Dispersed J 267-J Cascade Belt Creek B 0.12 Jefferson Cr Dispersed K 267-K Cascade Belt Creek B 0.04 Judith Jefferson Cr Dispersed L 267-L Belt Creek B 0.06 Basin Jefferson Cr Dispersed Judith 267-M Belt Creek B 0.06 M Basin Judith Jefferson Cr Dispersed N 267-N Belt Creek B 0.20 Basin Jefferson Creek 267 Cascade Belt Creek B, G, H 2.76 Judith Jefferson Creek 267 Belt Creek B 0.80 Basin Jellison Campsite 382-B Wheatland Musselshell E 0.08 Jellison Trailhead 382-A Wheatland Musselshell E 0.11 Johannesburg Gulch 89014 Meagher Belt Creek H 0.09 Permit John Fletcher Suber Judith 264-A Judith Basin B 0.29 Permit Basin John Fletcher Suber Judith 264A001 Judith Basin B 0.07 Permit Basin White Sulphur Jumping Creek 6413 Cascade B, H 2.37 Springs White Sulphur Jumping Creek 6413 Meagher A, B, H 6.95 Springs Jumping Creek Camp 1077 Meagher White Sulphur H 0.67

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Miles Management Road Name Road ID County USFS District Analyze Area d Springs Kings Hill Campground 9203 Cascade Belt Creek S 0.18 Kings Hill Campground 9203 Meagher Belt Creek S 0.33 White Sulphur Lake Creek 828 Meagher B, C 4.26 Springs White Sulphur Lamb Creek 836 Meagher A 4.31 Springs Leonard & Helen 89027 Cascade Belt Creek H 0.06 Gerhart Permit Lick Creek 67 Cascade Belt Creek E 3.39 Judith Lion Creek 829 Judith Basin C 0.17 Basin Lion Creek 829 Meagher Musselshell B, C 0.80 Lion Creek Camp 829-A Meagher Musselshell B 0.04 Lion Creek Corral 829-B Meagher Musselshell B 0.07 Log Spur Divide 20 6378 Cascade Belt Creek B 1.46 Logging Creek Camp 9168 Cascade Belt Creek H 0.56 Judith Lonetree 262 Judith Basin B, G 1.34 Basin White Sulphur Lower Pilgrim Trailhead 839-F Meagher B 0.26 Springs Lower Spring Cr. C.G. 6438-B Meagher Musselshell E 0.11 North Lower Spring Creek 6438 Meagher Musselshell E 0.43 Camp Judith Lui Salina Permit 251-A Judith Basin H 0.02 Basin Many Pines Campground 3411 Cascade Belt Creek H 0.23 Many Pines Campground 3411-A Cascade Belt Creek H 0.27 Memorial Falls Trhd 1101-D Cascade Belt Creek H 0.05 Judith Memorial Way 487 Judith Basin B, C, H, S 20.43 Basin A, B, C, F, H, Memorial Way 487 Meagher Judith Basin 1.43 S Judith A, B, C, F, G, Memorial Way 487 Judith Basin 12.12 Basin H Michael Mcdonald White Sulphur 3423007 Meagher A 0.02 Permit Springs Mill Creek 2019 Meagher Musselshell B, E 6.14 White Sulphur Miller Gulch 831 Meagher A, B, C 7.95 Springs

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Miles Management Road Name Road ID County USFS District Analyze Area d White Sulphur Miller Ridge 6478 Meagher B 3.96 Springs White Sulphur Monument 3497 Meagher F 0.59 Springs Monument Ridge 268 Cascade Belt Creek B, F 1.18 White Sulphur Monument Ridge 268 Cascade B, F 0.62 Springs White Sulphur Monument Ridge 268 Meagher F 1.50 Springs White Sulphur Moose Cr Dispersed A 204-A Meagher H 0.05 Springs White Sulphur Moose Cr Dispersed A1 204-A1 Meagher H 0.02 Springs White Sulphur Moose Cr Dispersed B 204-B Meagher H 0.11 Springs White Sulphur Moose Cr Dispersed C 204-C Meagher H 0.07 Springs White Sulphur Moose Cr Dispersed D 204-D Meagher H 0.10 Springs White Sulphur Moose Cr Dispersed E 204-E Meagher H 0.01 Springs White Sulphur Moose Cr Dispersed F 204-F Meagher H 0.02 Springs White Sulphur Moose Creek 204 Meagher B, H 11.29 Springs Moose Creek White Sulphur 9202 Meagher H 0.50 Campground Springs White Sulphur Moose Mountain 6412 Meagher A, B 7.40 Springs Moose Park 6408 Cascade Belt Creek B 0.12 White Sulphur Moose Park 6408 Meagher B 1.78 Springs White Sulphur N. Fork Deadman 746 Cascade H 0.00 Springs Neimark Property 89016 Cascade Belt Creek G, H 0.35 Owners Permit No. Fk. Deadman Spur White Sulphur 2027 Meagher B 0.19 #1 Springs White Sulphur North Deadman 4402 Meagher A, B 2.51 Springs North Fork Hoover 613-A Cascade Belt Creek G 0.09 Trailhead

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Miles Management Road Name Road ID County USFS District Analyze Area d Northwestern Corp Judith 15839 Judith Basin G, E 0.03 Permit Basin Northwestern Corp 1583900 Judith Judith Basin E 0.33 Permit 1 Basin Judith Oti Park 3339 Belt Creek B, F 1.53 Basin White Sulphur Paul Prociv Permit 89094 Cascade A 0.02 Springs Porphyry Peak 838 Cascade Belt Creek B, H, S 0.16 White Sulphur Porphyry Peak 838 Cascade B, H, S 0.54 Springs White Sulphur Porphyry Peak 838 Meagher H, S 0.15 Springs Powerline 3412 Cascade Belt Creek B, H, J 4.96 White Sulphur Quartzite Ridge 745 Cascade B 0.42 Springs White Sulphur Quartzite Ridge 745 Meagher B 3.06 Springs White Sulphur Ranch Creek 3423 Meagher A, B 4.83 Springs Richard Holzheimer 89129 Meagher Belt Creek H 0.09 Permit Roberts Cr - Rough Lock 584 Wheatland Musselshell B, G 0.71 Ruby Henn Dispersed G 613-G Cascade Belt Creek G 0.11 Ruby Henn Dispersed G 613-G1 Cascade Belt Creek G 0.04 Ruby Henn Dispersed G 613-G2 Cascade Belt Creek G, H 0.06 Ruby-Henn 613 Cascade Belt Creek A, B, F, G, H 5.83 Judith Running Wolf 264 Judith Basin B, G 19.70 Basin White Sulphur Sheep Creek 119 Meagher A 16.29 Springs Judith Smith Cr West A 2085-A Judith Basin B 0.11 Basin Judith Smith Cr West A1 2085-A1 Judith Basin B 0.02 Basin Judith Smith Creek West 2085 Judith Basin B 0.10 Basin White Sulphur Smokey Mountain 9185 Meagher A, B 7.39 Springs Snow Creek 116 Cascade Belt Creek L 1.09 South Charcoal Gulch White Sulphur 2040 Meagher A, B, C 3.11 Ridge Springs

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Miles Management Road Name Road ID County USFS District Analyze Area d White Sulphur South Fork Tenderfoot 6424 Meagher B, F 10.66 Springs South Ridge 3356 Cascade Belt Creek B, H 1.58 Judith South Ridge 3356 Judith Basin B 0.44 Basin Judith Spring Creek 274 Judith Basin B, C 4.25 Basin Spring Creek 274 Meagher Musselshell B, E 10.80 White Sulphur Spruce Gulch 6469 Meagher A, C 3.97 Springs White Sulphur Spruce Gulch Road 6482 Meagher A 1.83 Springs Stanley Holland Permit 67005 Cascade Belt Creek E 0.44 White Sulphur Stud Horse Creek 830 Meagher A, B, C 11.27 Springs White Sulphur Taylor Hills Trailhead 839-B Meagher B 0.19 Springs White Sulphur Tenderfoot Creek 840 Meagher K, M 0.28 Springs Tenderfoot Dispersed White Sulphur 840-A Meagher M 0.04 Camping Springs Und1049003 1049003 Cascade Belt Creek H 0.09 Und120095 120095 Cascade Belt Creek A 0.07 Und382016 382016 Wheatland Musselshell E 0.01 Und382017 382017 Wheatland Musselshell E 0.02 White Sulphur Und6468003 6468003 Meagher C 0.36 Springs White Sulphur Und6470001 6470001 Meagher C 1.69 Springs White Sulphur Und6470002 6470002 Meagher C 0.16 Springs White Sulphur Und6470003 6470003 Meagher C 0.44 Springs White Sulphur Und6470004 6470004 Meagher C 0.43 Springs White Sulphur Und6470010 6470010 Meagher C 0.21 Springs Upper Whitetail 2033 Meagher Musselshell B 1.45 Judith Villars Creek 3350 Belt Creek B 2.23 Basin Judith Villars Dispersed A 3350-A Belt Creek B, L 0.16 Basin

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Miles Management Road Name Road ID County USFS District Analyze Area d White Sulphur Weatherwax Creek 2056 Meagher A, B 2.89 Springs White Sulphur Williams Park 586 Meagher B, E, F, K, M 13.50 Springs Judith Willow Cr - Bear Park 3303 Judith Basin B 2.31 Basin Judith Willow Park Haymaker 189 Judith Basin B, C 9.28 Basin Willow Park Haymaker 189 Meagher Judith Basin B 2.72 Winter Sports Area 9201-A Cascade Belt Creek B, H 0.32 Loop Winter Sports Area Loop 9201 Cascade Belt Creek H 0.57 Judith Wolf Creek Divide 6328 Judith Basin B 1.54 Basin Judith Yogo Creek 266 Judith Basin B, G, I, L 9.47 Basin 1049500 1049500 Cascade Belt Creek H 0.01 1049502 1049502 Cascade Belt Creek H 0.02 1049503 1049503 Cascade Belt Creek H 0.01 1049504 1049504 Cascade Belt Creek H 0.01 1049505 1049505 Cascade Belt Creek H 0.02 4Wd Power Line 6436 Cascade Belt Creek H 2.13 839503 839503 Cascade Belt Creek H 0.06 Total Road Miles Analyzed 575.37

Table 22: Recreation sites with potential for treatment based on presence of hazard trees Sites Ownershi Management Site Name Type District Analyze p Area d Belt Creek & Ant Park Warming USFS Winter Rec White Sulphur F 1 Hut Springs Belt Creek & Aspen USFS Campground White Sulphur H 1 Springs Belt Creek & Balsinger Creek USFS Trailhead White Sulphur F 1 Springs Basin Creek USFS Campground Musselshell B 1 Basin Creek- USFS Campsite Musselshell B 1 disperesed

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Sites Ownershi Management Site Name Type District Analyze p Area d Belt Creek & Calf Creek Cabin USFS Cabin Rental White Sulphur F 1 Springs Daisy Dean USFS Trailhead Musselshell C 1 Belt Creek & Deadman extended USFS Campsite White Sulphur 4-A, 1-B 5 hunting Springs Belt Creek & Deep Creek USFS Trailhead White Sulphur H 1 Springs Belt Creek & Dry Fork- 41-A, 6-B, 2- USFS Campsite White Sulphur 53 dispersed H, 4-L Springs Dry Pole Canyon USFS Campground Judith H 1 Dry Wolf USFS Campground Judith H 1 Dry Wolf Cabin USFS Cabin Rental Judith B 1 Dry Wolf Group USFS Group Camp Judith H 1 Belt Creek & End of spur off USFS Campsite White Sulphur B 1 Divide Road Springs Fawn Creek NW USFS Campsite Musselshell B 2 Hay Canyon USFS Campground Judith H 1 Holiday Camp USFS Trailhead Judith B 1 Belt Creek & Hunter camp USFS Campsite White Sulphur H 1 Springs Hunters Camps USFS Campground Musselshell B 1 Point of Hunters Spring USFS Musselshell B 1 Interest Hunters Spring USFS Cabin Rental Musselshell B 1 Cabin Indian Hill USFS Campground Judith H 1 Belt Creek & Jefferson Creek USFS Trailhead White Sulphur B 1 Springs Jefferson Creek Belt Creek & 18-B, 2-G, 3- USFS Campsite 23 Dispersed White Sulphur H

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Sites Ownershi Management Site Name Type District Analyze p Area d Springs Jellison Place USFS Campground Musselshell E 1 Judith Guard USFS Administrative Musselshell H 1 Station Judith Station USFS Cabin Rental Judith H 1 Judith Station USFS Campground Judith H 1 Belt Creek & Jumping Creek USFS Campground White Sulphur H 1 Springs Belt Creek & Kings Hill USFS Campground White Sulphur S 1 Springs Belt Creek & Kings Hill Cabin USFS Cabin Rental White Sulphur S 1 Springs Belt Creek & Logging Creek USFS Campground White Sulphur B 1 Springs Lower Lion Creek USFS Campground Musselshell B 1 M Fork Judith USFS Trailhead Judith I 1 Belt Creek & Many Pines USFS Campground White Sulphur H 1 Springs Belt Creek & Mass Geis USFS Campsite White Sulphur C 3 extended hunting Springs Belt Creek & Memorial Falls USFS Trailhead White Sulphur H 1 Springs Belt Creek & Monument Peak USFS Cabin Rental White Sulphur F 1 Lookout Springs Belt Creek & Moose Creek USFS Campground White Sulphur H 1 Springs Belt Creek & Moose Creek Road USFS Campsite White Sulphur H 10 Springs Musselshell USFS Winter Rec Judith B 1 Warming Hut

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Sites Ownershi Management Site Name Type District Analyze p Area d Belt Creek & N Fork Hoover USFS Trailhead White Sulphur G 1 Springs Near Hunters USFS Campsite Musselshell B 1 spring Belt Creek & Near N Fork USFS Campsite White Sulphur 2-G, 1-H 3 Hoover Springs Belt Creek & Nugget Creek USFS Campsite White Sulphur A 4 extended hunting Springs Belt Creek & On Ruby Creek USFS Campsite White Sulphur G 1 Road Springs Belt Creek & On spur off Divide USFS Campsite White Sulphur B 2 Road Springs Pierce Park USFS Trailhead Judith B 1 Pierce Park USFS Campsite Judith B 1 Campsite Russian Flat USFS Campground Judith B 1 Belt Creek & South Pilgrim USFS Trailhead White Sulphur B 1 Springs Spring Creek USFS Campground Musselshell E 1 Belt Creek & Taylor Hills USFS Trailhead White Sulphur B 1 Springs Upper Lion Creek USFS Campground Musselshell B 1 Upper Whitetail USFS Campsite Musselshell B 2 Road Whitetail USFS Campground Musselshell B 1 Whitetail TH #613 USFS Campsite Musselshell B 1 Whitetail/Spring USFS Campsite Musselshell E 1 Creek Junction Window Rock USFS Picnic Area Musselshell E 1 Picnic Total Sites Analyzed 157

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Table 23: Special Use Sites (recreation and non-recreation) with potential for treatment based on presence of hazard trees Management # of Site Name Ownership Type District Area Sites Allen Gulch Belt Creek & White USFS Rec Residence A 2 Tract Sulphur Springs Barthol-Wyman USFS Rec Residence Judith B 1 Cabin Big Timber Belt Creek & White USFS Rec Residence H 4 Tract Sulphur Springs Blossom Cabin USFS Rec Residence Judith B 1 Brady Cabin USFS Rec Residence Judith H 1 Organizational Belt Creek & White Camp Rotary USFS H 1 Camp Sulphur Springs Cascade County Cascade Solid waste Solid Waste Belt Creek H 1 County site Site Deadman Creek Belt Creek & White USFS Rec Residence A 4 Tract Sulphur Springs Dry Gulch Belt Creek & White USFS Rec Residence H 1 Cabin Sulphur Springs Graveyard Belt Creek & White USFS Rec Residence H 6 Gulch Tract Sulphur Springs Griffin Coulee Belt Creek & White USFS Rec Residence H 4 Tract Sulphur Springs Harley Creek Belt Creek & White USFS Rec Residence H 4 Tract Sulphur Springs Harney Cabin USFS Rec Residence Judith C 1 Hoover Creek Belt Creek & White USFS Rec Residence H 1 Cabin Sulphur Springs Little Flower Belt Creek & White USFS Rec Residence H 1 Cabin Sulphur Springs Middle Fk USFS Rec Residence Judith C 1 Cabin - Hill Middle Fk USFS Rec Residence Judith C 1 Cabin - Shaver US Air Missle Site A5 Missile site Belt Creek A 1 Force US Air Missle Site C9 Missile site Judith B 1 Force Nugget Creek Belt Creek & White USFS Rec Residence A 1 Cabin Sulphur Springs Park Summer USFS Rec Residence Musselshell B 4 Homes Porphyry Peak Meacher Electronic site White Sulphur H 1

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Management # of Site Name Ownership Type District Area Sites Radio Site County Springs Sheriff Power Coulee Belt Creek & White USFS Rec Residence H 6 Tract Sulphur Springs Ranger Station Belt Creek & White USFS Rec Residence H 2 Tract Sulphur Springs Ruby Creek Belt Creek & White USFS Rec Residence G 1 Cabin Sulphur Springs Russian Flat MT Pilots Outhouse, Judith B 1 Airstrip Association parking Short Creek Belt Creek & White USFS Rec Residence A 2 Tract Sulphur Springs Upper Logging Belt Creek & White USFS Rec Residence H 2 Cr Tract Sulphur Springs Wagner Gulch Belt Creek & White USFS Rec Residence H 4 Tract Sulphur Springs Wood Gulch Belt Creek & White USFS Rec Residence H 2 Tract Sulphur Springs Total Special Use Sites Analyzed 63

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Appendix C: Past, Present, and Reasonably Foreseeable Activities Table 24: Past, Present, and Reasonably Foreseeable Activities within the Little Belt Mountains Year/ Resource Area Activity Project Location Decade Musselshell RD fuel Ongoing Fuels Fuels treatments District-wide treatments Ongoing Vegetation Grazing Not applicable Forestwide Ongoing Recreation Motorized recreation Not applicable Forestwide Special Use Personal use Ongoing Not applicable Forestwide Permits firewood Interface Mechanical fuel Monarch/Neihart 2008- adjacent to Fuels treatment and Hazardous Fuel ongoing Monarch/Neih prescribed burning Reduction-Phase I art Commercial and 2010- non-commercial Ettien Ridge Fuels Fuels ongoing thinning and Reduction prescribed burning Two drainages 2011- Reduction of Mass/Geis Hazardous Fuels near the Forest ongoing hazardous fuels Fuel Reduction boundary Little Belt, Castle, and North Half Crazy 2007 Travel Mountains Travel Management Plan (ROD) Mountain pine beetle anti-aggregation Many Pines, pheromone packets Aspen, & 2009 Silviculture Verbenone Installation on lodgepole, Moose Creek ponderosa, limber, Campgrounds and whitebark pine Ground-based Kings Hill spraying of 2009 Silviculture Carbaryl Application Campground lodgepole, limber, & Cabin and whitebark pine

2010 Silviculture Mountain pine beetle Verbenone Installation Many Pines,

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Year/ Resource Area Activity Project Location Decade anti-aggregation Aspen, & pheromone packets Moose Creek on lodgepole, Campgrounds ponderosa, limber, and whitebark pine Ground-based Logging spraying of 2010 Silviculture Carbaryl Application Creek lodgepole, limber, Campground and whitebark pine Many Pines, Ground-based Logging spraying of Creek, Thain 2011 Silviculture Carbaryl Application lodgepole, limber, Creek, & and whitebark pine Kings Hill Campgrounds Kings Hill Cabin, Spring Ground-based Creek & spraying of 2012 Silviculture Carbaryl Application Moose Creek lodgepole, limber, Campgrounds, and whitebark pine Judith Guard Station Planting lodgepole pine seedlings to Taylor Hills 2012 Silviculture Lodgepole planting reforest following area 2007 wildfire Includes commercial harvesting, pre-burn slashing, prescribed Northwestern 2012 Vegetation burning, road Blankenship Project Little Belt reconstruction, and Mountains temporary road construction

Ground-based Retreatment of spraying of 2013 Silviculture Carbaryl Application 2011 sites plus lodgepole, limber, any new sites and whitebark pine analyzed for

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Year/ Resource Area Activity Project Location Decade treatment Treat 31 existing Sheep Creek Aspen Sheep Creek 2013 Silviculture aspen stands Project watershed 1940-1949 Fuels Suppression Hogback 1940-1949 Fuels Suppression McReynolds 1940-1949 Fuels Suppression Toll Gate Haymaker 1940-1949 Fuels Suppression Creek 1950-1959 Fuels Suppression Smith River 1950-1959 Fuels Suppression Big Timber 1950-1959 Fuels Suppression Kents Gulch 1950-1959 Fuels Suppression Cow Coulee 1960-1969 Vegetation Commercial Thin Forestwide 1960-1969 Vegetation Sanitation (Salvage) Forestwide 1960-1969 Vegetation Stand Clearcut Forestwide 1960-1969 Vegetation Strip Clearcut Forestwide Stand Clearcut with 1960-1969 Vegetation Forestwide Reserves Shelterwood 1960-1969 Vegetation Forestwide Establishment Cut Single Tree Selection 1960-1969 Vegetation Forestwide Cut Overstory Removal 1960-1969 Vegetation Forestwide Cut Higgins Park 1960-1969 Fuels Suppression #1 Jumping 1960-1969 Fuels Suppression Creek Adams Creek 1960-1969 Fuels Suppression #2 1960-1969 Fuels Suppression Whitetail

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Year/ Resource Area Activity Project Location Decade Mill Creek 1960-1969 Fuels Suppression Sale 1960-1969 Fuels Suppression Miller Gulch Smokey 1960-1969 Fuels Suppression Mountain 1970-1979 Vegetation Commercial Thin Forestwide 1970-1979 Vegetation Sanitation (Salvage) Forestwide Salvage 1970-1979 Vegetation Forestwide (Intermediate) 1970-1979 Vegetation Stand Clearcut Forestwide Seed Tree Seed Cut 1970-1979 Vegetation (with or without Forestwide Reserves) Shelterwood 1970-1979 Vegetation Forestwide Establishment Cut Single Tree Selection 1970-1979 Vegetation Forestwide Cut Overstory Removal 1970-1979 Vegetation Forestwide Cut Whitetail 1970-1979 Fuels Suppression Creek Anderson 1970-1979 Fuels Suppression Peak 1970-1979 Fuels Suppression Cross Creek 1970-1979 Fuels Suppression Wilson Park 1970-1979 Fuels Suppression Burris Trail 1970-1979 Fuels Suppression Weatherwax 1970-1979 Fuels Suppression Lucky Boy 1970-1979 Fuels Suppression Jamison Trail 1970-1979 Fuels Suppression Lyon Creek

1970-1979 Fuels Suppression Thornquist

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Year/ Resource Area Activity Project Location Decade Gulch 1970-1979 Fuels Suppression Blacktail Hills 1970-1979 Fuels Suppression Picnic Canyon 1980-1989 Vegetation Commercial Thin Forestwide 1980-1989 Vegetation Sanitation (Salvage) Forestwide 1980-1989 Vegetation Patch Clearcut Forestwide 1980-1989 Vegetation Stand Clearcut Forestwide Stand Clearcut with 1980-1989 Vegetation Forestwide Reserves 1980-1989 Vegetation Seed Tree Prep Cut Forestwide Seed Tree Seed Cut 1980-1989 Vegetation (with or without Forestwide Reserves) Seed Tree Final Cut 1980-1989 Vegetation (with or without Forestwide Reserves) Shelterwood 1980-1989 Vegetation Forestwide Preparation Cut Shelterwood 1980-1989 Vegetation Forestwide Establishment Cut Shelterwood Staged 1980-1989 Vegetation Forestwide Removal Cut Single Tree Selection 1980-1989 Vegetation Forestwide Cut 1980-1989 Vegetation Liberation Cut Forestwide Overstory Removal 1980-1989 Vegetation Forestwide Cut 1980-1989 Fuels Suppression Mill Creek 1980-1989 Fuels Suppression Tenderfoot 1980-1989 Fuels Suppression Newlan Creek 1980-1989 Fuels Suppression Deep Creek

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Year/ Resource Area Activity Project Location Decade 1980-1989 Fuels Suppression Sand Point 1980-1989 Fuels Suppression Ant Park Smokey 1980-1989 Fuels Suppression Mountain 1980-1989 Fuels Suppression Lion 1980-1989 Fuels Suppression Iron Claim 1980-1989 Fuels Suppression Spring Creek 1980-1989 Fuels Suppression Lick Creek Broadcast Burn – 1980-1989 Fuels majority of unit Underburn – low 1980-1989 Fuels intensity Rearrangement of 1980-1989 Fuels Fuels Thinning for 1980-1989 Fuels Hazardous Fuels 1990-1999 Vegetation Commercial Thin Forestwide 1990-1999 Vegetation Improvement Cut Forestwide 1990-1999 Vegetation Sanitation (Salvage) Forestwide 1990-1999 Vegetation Patch Clearcut Forestwide 1990-1999 Vegetation Stand Clearcut Forestwide Stand Clearcut with 1990-1999 Vegetation Forestwide Reserves Seed Tree Seed Cut 1990-1999 Vegetation (with or without Forestwide Reserves) Seed Tree Final Cut 1990-1999 Vegetation (with or without Forestwide Reserves) Shelterwood 1990-1999 Vegetation Forestwide Preparation Cut

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Year/ Resource Area Activity Project Location Decade Shelterwood 1990-1999 Vegetation Forestwide Establishment Cut Shelterwood Seed 1990-1999 Vegetation Forestwide Cut with Reserves Shelterwood Staged 1990-1999 Vegetation Forestwide Removal Cut Two-age Shelterwood Final 1990-1999 Vegetation Forestwide Removal Cut with Reserves Single Tree Selection 1990-1999 Vegetation Forestwide Cut 1990-1999 Vegetation Liberation Cut Forestwide 1990-1999 Vegetation Group Selection Cut Forestwide 1990-1999 Fuels Suppression Turkey Harrison 1990-1999 Fuels Suppression Creek 1990-1999 Fuels Suppression Sawmill 1990-1999 Fuels Suppression Willow Park Logging 1990-1999 Fuels Suppression Creek 1990-1999 Fuels Suppression South Fork 1990-1999 Fuels Suppression Coyote 1990-1999 Fuels Suppression Tollgate 1990-1999 Fuels Suppression Placer Creek 1990-1999 Fuels Suppression Spring Creek 1990-1999 Fuels Suppression Lucy Park 1990-1999 Fuels Suppression Jellison Place Broadcast Burn – 1990-1999 Fuels majority of unit

1990-1999 Fuels Underburn – low

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Year/ Resource Area Activity Project Location Decade intensity Rearrangement of 1990-1999 Fuels Fuels Thinning for 1990-1999 Fuels Hazardous Fuels 2000-2009 Vegetation Commercial Thin Forestwide 2000-2009 Vegetation Sanitation (Salvage) Forestwide Salvage 2000-2009 Vegetation Forestwide (Intermediate) 2000-2009 Vegetation Patch Clearcut Forestwide 2000-2009 Vegetation Stand Clearcut Forestwide Stand Clearcut with 2000-2009 Vegetation Forestwide Reserves Seed Tree Seed Cut 2000-2009 Vegetation (with or without Forestwide Reserves) Seed Tree Final Cut 2000-2009 Vegetation (with or without Forestwide Reserves) Shelterwood 2000-2009 Vegetation Forestwide Preparation Cut Shelterwood 2000-2009 Vegetation Forestwide Establishment Cut Shelterwood Seed 2000-2009 Vegetation Forestwide Cut with Reserves Two-age Shelterwood Final 2000-2009 Vegetation Forestwide Removal Cut with Reserves 2000-2009 Vegetation Group Selection Cut Forestwide 2000-2009 Fuels Suppression Studhorse 2000-2009 Fuels Suppression Antelope

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Year/ Resource Area Activity Project Location Decade Lost Fork 2000-2009 Fuels Suppression Ridge 2000-2009 Fuels Suppression Taylor Hills II McGuire 2000-2009 Fuels Suppression Ranch 2000-2009 Fuels Suppression Taylor Hills 2000-2009 Fuels Suppression High Springs 2000-2009 Fuels Suppression Monarch 2000-2009 Fuels Suppression Lost Fork 2000-2009 Fuels Suppression Sheep Creek Long 2000-2009 Fuels Suppression Mountain 2000-2009 Fuels Suppression Iron Butte 2000-2009 Fuels Suppression Betsy 2000-2009 Fuels Suppression Burnt Ridge Rickard 2000-2009 Fuels Suppression Coulee 2000-2009 Fuels Suppression Haymaker 2000-2009 Fuels Suppression Ant Park 2000-2009 Fuels Suppression Pioneer Ridge 2000-2009 Fuels Suppression Tender Johnston 2000-2009 Fuels Suppression Gulch Thunder 2000-2009 Fuels Suppression Mountain 2000-2009 Fuels Suppression Blankenbaker 2000-2009 Fuels Suppression Taylor Hills 2000-2009 Fuels Suppression Sheep Creek 2000-2009 Fuels Suppression Middle Fork

2000-2009 Fuels Suppression Rimrock

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Year/ Resource Area Activity Project Location Decade Ridge 2000-2009 Fuels Suppression Rugby Creek 2000-2009 Fuels Suppression Stiner 2000-2009 Fuels Suppression Harley Creek 2000-2009 Fuels Suppression Russian Flats 2000-2009 Fuels Suppression Indian Hill 2000-2009 Fuels Suppression Monument 2000-2009 Fuels Resource Benefit South Deep 2000-2009 Fuels Resource Benefit Temple Gulch Broadcast Burn – 2000-2009 Fuels majority of unit Underburn – low 2000-2009 Fuels intensity Rearrangement of 2000-2009 Fuels Fuels Thinning for 2000-2009 Fuels Hazardous Fuels Salvage 2010-2013 Vegetation Forestwide (Intermediate) Stand Clearcut with 2010-2013 Vegetation Forestwide Reserves Shelterwood 2010-2013 Vegetation Forestwide Establishment Cut Broadcast Burn – 2010-2013 Fuels majority of unit Underburn – low 2010-2013 Fuels intensity Rearrangement of 2010-2013 Fuels Fuels Thinning for 2010-2013 Fuels Hazardous Fuels

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Year/ Resource Area Activity Project Location Decade 2010-2019 Fuels Control Elk Park 2010-2019 Fuels WFFRB Taylor Hills 2010-2019 Fuels Contain Allan Park 2010-2019 Fuels Control Hoover Moose 2010-2019 Fuels Control Mountain 2010-2019 Fuels Control Goblin Gulch

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Appendix D: Lewis & Clark Forest Plan Consistency

Resource Section Number Standard Project Compliance Area

Conduct a biological evaluation of each program or activity which is Forest Service funded, There are no threatened or authorized, or endangered aquatic species in carried out on the project area. There were occupied T&E biological evaluations species and sensitive C-2 (2) Fisheries performed for the sensitive species habitat. This fish and amphibian species evaluation will with occurrences or potential determine whether habitats within the project or not informal or area. formal consultation with the US Fish and Wildlife Service on T&E species is appropriate. The forest soil scientist was consulted on soil modeling parameters for WEPP:Road model runs. The forest Fish Habitat -- hydrologist was consulted Increase the with on numerous effects coordination of the analysis, BMP and mitigation fisheries resource questions. The range with other forest program manager was C-3 (1) Fisheries activities and consulted on weeds and programs…timber herbicide use. The forest mgmt, range mgmt silviculturalist was consulted and oil and gas on tree insect and disease and development. forestry questions. These specialists and line officers were also briefed on fisheries and aquatic wildlife needs and concerns.

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Increase coordination with Fishery, mussel and the Montana amphibian biologists from Department of Fish, the Montana Department of Wildlife and Parks Fish, Wildlife and Parks C-3 (2) to adequately Fisheries Fisheries were consulted with address issues and about species status in the concerns related the project area, project effects Forest’s overall and desired mitigation. annual program of work. Emphasize the maintenance or enhancement of habitat supporting populations of The project would utilize Upper Missouri Water Quality BMPs For River (blackspotted) Montana Forests and the C-3 (4) Fisheries cutthroat trout (note: Montana Streamside westslope cutthroat Management Zone Laws and trout is the proper Rules. common name for the blackspotted cutthroat mentioned in the forest plan). The management of The project would adhere to soil and vegetation the Montana Streamside in riparian areas is Management Zone Laws and essential to fisheries Rules. Leave trees would not C-3 (5) habitat management. Fisheries only be above minimum (See Management sizes, but they would also Standards D3, F3, E- come from the largest 4, G-1, L-4, and P- diameter portion of trees in 2). the SMZ.

Manage the timber The project would utilize E-4 (2) resource to enhance Fisheries Water Quality BMPs For riparian values. Montana Forests and the Streamside Management

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Resource Section Number Standard Project Compliance Area

Zone Laws and Rules.

Use all necessary Appendix to Hydrology measures to report lists appropriate soil minimize soil E-4 (3) Fisheries and water BMPs that were damage and soil analyzed and would be erosion on timber applied for this project. sale areas. Utilize adequate soil and water Appendix to Hydrology conservation report lists appropriate soil practices to protect and water BMPs that were soil productivity and analyzed and would be to control nonpoint applied for this project. F-1 (1) water pollution from Fisheries Noxious weed BMPs (FSM project activities, 2000 Supplement R-1 2000- using as a minimum, 2001-1) and herbicide control practices specified in incorporated into affects any State-developed analysis as well. “Best Management Practices.” Appendix to Hydrology Require application report lists appropriate soil of Best Management and water BMPs to be Practices to project applied for this project and activities to ensure BMPs are incorporated into F-3 (1) Fisheries meeting or affects analysis. Noxious exceeding State weed BMPs as found in FSM water quality 2000, Sup. R-1 2000-2001-1 standards. also analyzed and would be applied. Develop additional Appendix to Hydrology Best Management report lists appropriate soil F-3 (2) Practices during the Fisheries and water BMPs to be environmental applied for this project and analysis process and BMPs are incorporated into incorporate them affects analysis. Noxious

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into all land uses and weed BMPs as found in FSM project plans as a 2000, Sup. R-1 2000-2001-1 principal mechanism also analyzed and would be for controlling non- applied. point sources and meeting soil and water quality or other resource goals. Meet State water Quality standards as required by the Clean Water Act (33 U.S.C. 1323), and as detailed in the Memorandum of Understanding to Implement the 208 Analysis of the proposed Program on National project has indicated there is Forests in the State a low probability of F-3 (3) Fisheries of Montana. detectable increases to runoff Coordinate with the and sediment delivery to State of Montana water ways. concerning stream channels as agreed to in the Memorandum of Understanding with the State of Montana Fish and Game Commission. Require a watershed analysis of projects Analysis of the proposed involving significant project has indicated there is vegetative removal a low probability of F-3 (4) Fisheries to ensure that the detectable increases to runoff project, considered and sediment delivery to with other activities, water ways. would not increase water yields or

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sediment beyond acceptable limits. The analysis should identify any opportunities for mitigating adverse effects on water related beneficial uses, including capital investments for fish habitat or watershed improvements. Conduct an environmental analysis for all management actions Analysis of the proposed planned for flood project has indicated there is plains, wetlands, a low probability of riparian zones, or detectable increases to runoff bodies of water prior and sediment delivery to F-3 (5) Fisheries to implementation. water ways. Mitigation Adopt the necessary measures have been proposed mitigation measure and would further reduce to minimize risk of impacts from the proposed flood loss, restore action. and preserve flood plain values, and to protect wetlands. Require drainage Included in the recommended structures on mitigation during the P-2 (8) disturbed areas Fisheries construction and use of the where it is necessary proposed temporary stream to control erosion. crossing on the middle Fork. Protect and preserve For the Little Belts Hazard H-2 (1) for Native Heritage Tree Removal project, the Americans their forest heritage staff inherent right of considered American Indian

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Resource Section Number Standard Project Compliance Area

freedom of belief, traditional use, belief expression, and systems, religious practices exercise their and life-way values as traditional religions. directed by the Archaeological Resources Protection Act of 1979 (ARPA), the National Historic Preservation Act (NHPA), the Native American Graves Protection and Repatriation Act (NAGPRA), the American Indian Religious Freedom Act (AIRFA) and the Religious Freedom Restoration Act (RFRA). Identification of Cultural Resources - For the Little Belts Hazard - A cultural survey, Tree Removal project, the will be conducted to forest heritage staff is identify and record identifying cultural resources cultural properties as directed by Section 106 of within the area of the NHPA through environmental consultation with the MT impact. Sites, SHPO and THPOs and A-7 (1) Heritage building, districts utilizing the following and objects which approaches/agreements: may qualify for the Phased NHPA compliance National Register of per 36CFR800.4(b), Region Historic Places will One Programmatic be nominated in Agreement & Forest SIS, and accordance with Bark Beetle and Haz Tree established Protocols. procedures. For the Little Belts Hazard Protection of Tree Removal project, the A-7 (2) Heritage Cultural Resources forest heritage staff is protecting cultural resources by complying with Section

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106 of the NHPA through consultation with the MT SHPO and THPOs and utilizing the following approaches/agreements: Phased NHPA compliance per 36CFR800.4(b), Region One Programmatic Agreement & Forest SIS, and Bark Beetle and Haz Tree Protocols. For the Little Belts Hazard Tree Removal project, the Evaluate, according forest heritage staff is to criteria which evaluating cultural resources determine eligibility as directed by Section 106 of for the National the NHPA through Register of Historic consultation with the MT Places, and in SHPO and THPOs and A-7 (2)(a) consultation with the Heritage utilizing the following SHPO, any approaches/agreements: identified Phased NHPA compliance archaeological or per 36CFR800.4(b), Region historical site, One Programmatic building, structure, Agreement & Forest SIS, and or district. Bark Beetle and Haz Tree Protocols. Consult with the For the Little Belts Hazard SHPO and together Tree Removal project, the determine the forest heritage staff is project's effect on assessing project effects as significant cultural directed by Section 106 of A-7 (2)(b) properties. If no Heritage the NHPA through effect is identified, consultation with the MT the Forest proceeds SHPO and THPOs and with the project. If utilizing the following an effect is approaches/agreements: identified, the Forest Phased NHPA compliance and the SHPO per 36CFR800.4(b), Region

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Resource Section Number Standard Project Compliance Area

determine whether One Programmatic the effect will be Agreement & Forest SIS, and adverse or not. Bark Beetle and Haz Tree Protocols.

For the Little Belts Hazard Tree Removal project, the forest heritage staff is creating an implementation/monitoring A schedule will be plan through consultation developed for with the MT SHPO and visiting known sites THPOs and utilizing the A-7 (2)(c) Heritage to determine what following protection, if any, is approaches/agreements: necessary. Phased NHPA compliance per 36CFR800.4(b), Region One Programmatic Agreement & Forest SIS, and Bark Beetle and Haz Tree Protocols. For the Little Belts Hazard Management of Tree Removal project, the Cultural Resources- forest heritage staff is Cultural resources working with project are not renewable. planners & project Therefore, the Forest proponents to avoid any will make every potential adverse effects. effort to design Final avoidance strategies, A-7 (3) projects without Heritage site treaments, site adversely affecting mitigations, and project cultural resources. effects analysis will be Normally, slight determined through project modification consultation with the MT will avoid any SHPO and THPOs and potentially adverse utilizing the following effects. approaches/agreements: Phased NHPA compliance per 36CFR800.4(b), Region

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Resource Section Number Standard Project Compliance Area

One Programmatic Agreement & Forest SIS, and Bark Beetle and Haz Tree Protocols.

Interpretation of Through the Phased NHPA Cultural Resources- Compliance process, if any The decision to cultural resources are provide identified as needing to be A-7 (4) Heritage interpretative mitigated, then interpretation information will will be considered through consider the consultation with the MT following criteria: SHPO and THPOs. Unknown at this time. May Can the site provide be considered through the A-7 (4)(a) Heritage visitor information? Phased NHPA Compliance process. Unknown at this time. May Is the site near other be considered through the A-7 (4)(b) recreation Heritage Phased NHPA Compliance attractions? process. Unknown at this time. May How easily can be considered through the A-7 (4)(c) visitor impact on the Heritage Phased NHPA Compliance site be monitored? process. Is the site representative of Unknown at this time. May cultural resources be considered through the A-7 (4)(d) Heritage elsewhere on the Phased NHPA Compliance Forest and process. surrounding areas?

Can interpretation be Unknown at this time. May coordinated with the be considered through the A-7 (4)(e) Heritage protection, Phased NHPA Compliance preservation, process. maintenance, and

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Resource Section Number Standard Project Compliance Area

interpretation of other resources?

Public Education- Educational efforts will be made to Through the Phased NHPA increase public Compliance process, if any understanding of the cultural resources are importance of these identified as needing to be A-7 (5) Heritage identified cultural mitigated, then public resources and education will be considered thereby mitigate through consultation with the damage and MT SHPO and THPOs. maintenance problems. Protect and preserve Native American rights of for Native freedom of belief, expression, Americans their and exercise their traditional inherent right of H-2 (1) Heritage religions are being freedom of belief, considered through the expression, and ongoing Tribal Consultation exercise their process. traditional religions. Identification of Native American spiritual/sacred Assess impacts of sites is currently ongoing Forest Service through the Tribal H-2 (2) activities on Native Heritage Consultation process. If American spiritual these sites are identified, then sites and objects. an assessment of impacts will be conducted. Implement a special- use permit system If these temporary area for needed closures requests are made H-2 (3) temporary area Heritage during the ongoing Tribal closures, to enable Consultation process, then Native Americans to they will be considered. exercise their

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Resource Section Number Standard Project Compliance Area

religious rights without interference.

Expand Forest programs which H-2 (4) promote Heritage Not applicable to this project. employment for Native Americans. Consult with the Blackfeet Tribe regarding the establishment of proper procedures to implement the American Indian H-2 (5) Heritage Not applicable to this project. Religious Freedom Act. The Forest Service will negotiate an agreement with the Blackfeet Tribe on this issue. The project would utilize Manage the timber Water Quality BMPs For E-4 (2) resource to enhance Hydrology Montana Forests and the riparian values. Streamside Management Zone Laws and Rules. Use all necessary Appendix to Hydrology measures to report lists appropriate soil minimize soil E-4 (3) Hydrology and water BMPs that were damage and soil analyzed and would be erosion on timber applied for this project. sale areas. Limit equipment use Appendix to Hydrology E-4 (4) where ground Hydrology report lists appropriate soil conditions are such and water BMPs that were that excessive analyzed and would be

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Resource Section Number Standard Project Compliance Area

damage would applied for this project. result.

Limit tractor Appendix to Hydrology skidding to slopes of report lists appropriate soil E-4 (6) 45% or less Hydrology and water BMPs that were depending on soils analyzed and would be types. applied for this project. Give consideration to limitations on land types as Incorporated into the Soils E-4 (7) described in Lewis Hydrology report and soils analysis. and Clark Soil Resource Inventory (Holdorf, 1981). Utilize adequate soil and water Appendix to Hydrology conservation report lists appropriate soil practices to protect and water BMPs that were soil productivity and analyzed and would be to control nonpoint applied for this project. F-1 (1) water pollution from Hydrology Noxious weed BMPs (FSM project activities, 2000 Supplement R-1 2000- using as a minimum, 2001-1) and herbicide control practices specified in incorporated into affects any State-developed analysis as well. “Best Management Practices.”

Require application Appendix to Hydrology of Best Management report lists appropriate soil Practices to project and water BMPs to be activities to ensure applied for this project and F-3 (1) Hydrology meeting or BMPs are incorporated into exceeding State affects analysis. Noxious water quality weed BMPs as found in FSM standards. 2000, Sup. R-1 2000-2001-1 also analyzed and would be

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Resource Section Number Standard Project Compliance Area

applied.

Appendix to Hydrology Require application report lists appropriate soil of Best Management and water BMPs to be Practices to project applied for this project and activities to ensure BMPs are incorporated into F-3 (2) Hydrology meeting or affects analysis. Noxious exceeding State weed BMPs as found in FSM water quality 2000, Sup. R-1 2000-2001-1 standards. also analyzed and would be applied. Meet State water Quality standards as required by the Clean Water Act (33 U.S.C. 1323), and as detailed in the Memorandum of Understanding to Implement the 208 Analysis of the proposed Program on National project has indicated there is Forests in the State a low probability of F-3 (3) Hydrology of Montana. detectable increases to runoff Coordinate with the and sediment delivery to State of Montana water ways. concerning stream channels as agreed to in the Memorandum of Understanding with the State of Montana Fish and Game Commission.

Require a watershed Analysis of the proposed F-3 (4) analysis of projects Hydrology project has indicated there is involving significant a low probability of

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Resource Section Number Standard Project Compliance Area

vegetative removal detectable increases to runoff to ensure that the and sediment delivery to project, considered water ways. with other activities, would not increase water yields or sediment beyond acceptable limits. The analysis should identify any opportunities for mitigating adverse effects on water related beneficial uses, including capital investments for fish habitat or watershed improvements. Conduct an environmental analysis for all management actions Analysis of the proposed planned for flood project has indicated there is plains, wetlands, a low probability of riparian zones, or detectable increases to runoff bodies of water prior and sediment delivery to F-3 (5) Hydrology to implementation. water ways. Mitigation Adopt the necessary measures have been proposed mitigation measure and would further reduce to minimize risk of impacts from the proposed flood loss, restore action. and preserve flood plain values, and to protect wetlands. Require drainage All alternatives are in P-2 (8) structures on Hydrology compliance with this standard disturbed areas through implementation of where it is necessary State required BMPs, SMZ

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Resource Section Number Standard Project Compliance Area

to control erosion. rules and watershed resource protection measures; see corresponding sections above. Emphasize All alternatives are in preventing noxious compliance with this standard weeds by reseeding, through implementation of Noxious D-2 (2) with desirable plant prescribed noxious weeds Weeds species, mineral soil resource protection measures; exposed by Forest see corresponding sections activities. above. Require application All alternatives are in of Best Management compliance with this standard Practices to project through implementation of activities to ensure Noxious F-3 (1) prescribed noxious weeds meeting or Weeds resource protection measures; exceeding State see corresponding sections water quality above. standards. All alternatives are in Require prompt compliance with this standard revegetation of through implementation of disturbed areas, Noxious F-3 (11) prescribed noxious weeds especially cut and Weeds resource protection measures; fill slopes, to control see corresponding sections surface erosion. above. Maintain facilities to All alternatives are in their original compliance with this standard standard. Replace or through implementation of rehabilitate worn A-2 (1) Recreation prescribed recreation and substandard resource protection measures; facilities and sites, in see corresponding sections accordance with the above. Regional Guide.

Maintain facilities to All alternatives are in A-2 (2) protect investment Recreation compliance with this standard and provide safe, through implementation of

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Resource Section Number Standard Project Compliance Area

sanitary, and prescribed recreation reasonably attractive resource protection measures; sites. see corresponding sections above. Manage campgrounds at full administrative and All alternatives are in operation levels. compliance with this standard Increase through implementation of maintenance and A-2 (4)(a) Recreation prescribed recreation education to protect resource protection measures; the investment and see corresponding sections provide safe, above. sanitary, and reasonably attractive facilities and sites. Administer recreation-residence permits according to Forest Service Manual 2720. Termination can All alternatives are in occur where compliance with this standard permittees will not through implementation of A-3 (1) or cannot correct Recreation prescribed recreation existing or resource protection measures; anticipated see corresponding sections unacceptable above. resource degradation, safety hazards or unsanitary conditions. Landscape Landscape management management principles as identified in A-8 (1) principles will be Scenery Agriculture Handbook No. applied to all 462 and subsequent Forest activities on the Service direction have been

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Resource Section Number Standard Project Compliance Area

Forest (FSM 2380). applied to this project. All This will be alternatives are in compliance accomplished by with this standard; see implementing the Scenery section above. procedures defined in National Forest Landscape Management, Volume 2, Chapter I, The Visual Management System (Agriculture Handbook No. 462). A VQO (visual quality objective) is stated for each management area (see Chapter III). These VQOs provide the guideline for altering the landscape. If the VQOs of affected VQO conflicts with management areas are the management identified in the Scenery prescription, then Report. All alternatives are in compliance with this A-8 (2) the prescription will Scenery prevail, unless the standard through scenery area is within the resource protection measures seen areas of the intended to minimize impacts roads or trails and meet VQOs; see Scenery identified on Forest section above. Plan maps. These roads and trails are in sensitivity level I; all recreation use areas included in Management Area H are also assigned sensitivity level 1.

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Seen areas from these designated roads and trails, and recreation use areas will be managed for the protection or enhancement of scenic values. The seen areas associated with these roads, trails, and use areas occur in different management areas with different prescriptions. In these seen areas visual resource management principles will be emphasized and visual impacts mitigated to meet the VQO. The mitigation is described in terms of existing visual condition. Emphasis will be given to acquaint the See Agriculture Handbook public with and No. 462 for information explain the Forest regarding the Forest Service Service visual visual management system. Scenery resource protection A-8 (3) management system. Scenery The Forest adjacent measures have been to or as seen from all developed for the identified or segments of the roads to ensure compliance following roads and with this standard; see trails, as shown on Scenery section above. Forest Plan maps,

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will be managed for its visual resource. Only roads and trails that may be affected by development are identified. National Recreation Trails are discussed in L-4, Maintenance and Construction of Roads, Trails, and Other Facilities. Conduct biological evaluations of each program or activity carried out on occupied sensitive species habitat to determine whether the activity may affect sensitive All alternatives are in species. compliance with this standard Assessments of through completion of the suitable habitats for Sensitive Sensitive Species Report and C-2 (2) sensitive plants will Plants implementation of resource be conducted before protection measures; see surface disturbing corresponding sections activities are above. permitted. This evaluation will determine whether or not informal or formal consultation with the US Fish and Wildlife Service on T&E species is appropriate.

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There are sensitive plants, as listed by the Regional Forester, of limited distribution that occur on the Forest All alternatives are in and may require compliance with this standard special consideration through completion of the in land management Sensitive Sensitive Species Report and C-2 (13) to maintain diversity Plants implementation of resource within the species protection measures; see gene pool. corresponding sections Assessments of above. suitable habitats for sensitive plants will be conducted before surface disturbing activities are permitted. Use all necessary All action alternatives would measures to meet this standard through minimize soil implementation of soils E-4 (3) Soils damage and soil resource protection measures; erosion on timber see corresponding sections sale areas. above. Limit equipment use All action alternatives would where ground meet this standard through conditions are such implementation of soils E-4 (4) Soils that excessive resource protection measures; damage would see corresponding sections result. above. To further ensure, this project Limit tractor will follow Montana’s skidding to slopes of Streamside Management E-4 (6) 45 percent or less Soils Zone Laws and Rules, depending on soil Ground based equipment type. should be restricted from operating in areas with more

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than 35% average slope.

Give consideration All action alternatives would to limitations on meet this standard through landtypes as implementation of soils E-4 (7) described in Lewis Soils resource protection measures; and Clark Soil see corresponding sections Resource Inventory above. (Holdorf, 1981). Utilize adequate soil and water conservation practices to protect All action alternatives would soil productivity and meet this standard through to control nonpoint implementation of soils F-1 (1) water pollution from Soils resource protection measures; project activities, see corresponding sections using as a minimum, above. practices specified in any State-developed “Best Management Practices.” Require application of Best Management All action alternatives would Practices to project meet this standard through activities to ensure implementation of soils F-3 (1) Soils meeting or resource protection measures; exceeding State see corresponding sections water quality above. standards.

Develop additional All action alternatives would Best Management meet this standard through Practices during the implementation of soils F-3 (2) Soils environmental resource protection measures; analysis process and see corresponding sections incorporate them above. into all land use and

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project plans as a principal mechanism for controlling nonpoint sources and meeting soil and water quality or other resource goals. In accordance with NFMA, RPA and All action alternatives would Multiple Use- meet this standard through Sustained Yield Act, implementation of soils F-3 (10) Soils all management resource protection measures; activities will be see corresponding sections planned to sustain above. site productivity. Require prompt revegetation of disturbed areas, especially cut and fill slopes, to control surface erosion. To stabilize disturbed areas, seed with All action alternatives would grasses, forbs and meet this standard through deep-rooted native implementation of soils shrubs, where resource protection measures; see corresponding sections F-3 (11) natural Soils establishment of above. There would be no native cover is not construction of temporary expected within two roads under any alternative years. Ideally the and therefore no discussion seedbed should be of cut and fill slopes. firm with a roughened surface. The slope must be stable, usually less than 2:1. Steeper slopes can be benched or terraced.

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Compacted soils should be ripped from eight to twelve inches. Achieve a 70 All action alternatives would percent vegetative or meet this standard through litter cover level on implementation of soils cut and fill slopes resource protection measures; and other soil see corresponding sections F-3 (13) disturbance areas Soils above. There would be no with 2 seasons or a construction of temporary natural level of roads under any alternative vegetative and litter and therefore no discussion cover when it is less of cut and fill slopes. than 70 percent. Design, construct and maintain roadways and other facilities to All action alternatives would minimize surface meet this standard through runoff. Avoid implementation of soils L-4 (16) Soils construction during resource protection measures; runoff periods, to see corresponding sections minimize stream above. sedimentation. Revegetate disturbed soil. Construction equipment service areas shall be All action alternatives would located and treated meet this standard through to prevent gas, oil implementation of soils L-4 (21) Soils and other resource protection measures; contaminants from see corresponding sections washing or leaching above. into streams or lakes.

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Resource Section Number Standard Project Compliance Area

Leave approximately 10 tons of fuel per acre, Region 1 Soil Quality where available. Standards require a minimum This should be of 5 to 10 tons per acre of material over four woody debris greater than 3 P-2 (4) inches in diameter, Soils inches. Lewis and Clark which is randomly Forest Plan Standards require scattered over the more; therefore requirements area. Material of the Forest Plan are should touch the prescribed. ground for faster decomposition. The silvicultural prescription for each harvest unit would prescribe whether or not The basic approach regeneration is required in all regeneration based on the silvicultural harvest cuts on the treatment of the stand. If Lewis and Clark regeneration is required, the National Forest is to prescription would describe specify state-of-the- the appropriate method art treatments that (natural recovery, natural will assure natural regeneration, planting) and regeneration desired species composition wherever feasible. E-3 (1) Vegetation and density. Examinations Site preparation would be appropriately must commence as scheduled for each soon after the regeneration method to regeneration cut as ensure that management feasible. This is objectives were being met. If immediately after examinations indicate that the clearcutting and the stand is not progressing seed cut of the seed toward adequate restocking tree and shelterwood and certification, additional systems. treatments would be prescribed. In some cases, seedlings would be planted to meet the reforestation

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requirement. Natural regeneration is the preferred regeneration method where it is feasible. Historically about 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The silvicultural prescription for each harvest unit would prescribe whether or not regeneration is required based on the silvicultural treatment of the stand. If regeneration is required, the prescription would describe The first-year stand the appropriate method examination will (natural recovery, natural certify that the regeneration, planting) and ground conditions desired species composition E-3 (2) necessary for natural Vegetation and density. Examinations regeneration are would be appropriately present and that scheduled for each adequate restocking regeneration method to should occur. ensure that management objectives were being met. If examinations indicate that the stand is not progressing toward adequate restocking and certification, additional treatments would be prescribed. In some cases, seedlings would be planted to

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meet the reforestation requirement. Natural regeneration is the preferred regeneration method where it is feasible. Historically about 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The silvicultural prescription for each harvest unit would Intermediate stand prescribe whether or not examinations will be regeneration is required scheduled at the based on the silvicultural appropriate intervals treatment of the stand. If for the individual regeneration is required, the sites to monitor prescription would describe seedling the appropriate method establishment. If the (natural recovery, natural regeneration process regeneration, planting) and E-3 (3) is not working and Vegetation desired species composition will not occur under and density. Examinations existing site would be appropriately conditions, evaluate scheduled for each the stand to regeneration method to determine if ensure that management additional treatment objectives were being met. If is needed to bring examinations indicate that the the regeneration to a stand is not progressing satisfactory level. toward adequate restocking and certification, additional treatments would be prescribed. In some cases,

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seedlings would be planted to meet the reforestation requirement. Natural regeneration is the preferred regeneration method where it is feasible. Historically about 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The 5th-year stand The silvicultural prescription examination will for each harvest unit would certify the stand prescribe whether or not regeneration is regeneration is required completed by based on the silvicultural meeting the treatment of the stand. If following criteria: regeneration is required, the that the required prescription would describe natural regeneration the appropriate method has survived at least (natural recovery, natural three full growing regeneration, planting) and E-3 (4)(a) seasons, is in a Vegetation desired species composition healthy condition, and density. Examinations and is at least 6 would be appropriately inches high; that scheduled for each planted stock has regeneration method to survived two ensure that management growing seasons and objectives were being met. If is in a healthy examinations indicate that the condition (healthy stand is not progressing leaders and buds); toward adequate restocking that at least 90% of and certification, additional the reforestable land treatments would be

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area in the stand prescribed. In some cases, meets the prescribed seedlings would be planted to stocking level; and meet the reforestation that the District requirement. Natural Silviculturist has regeneration is the preferred determined the stand regeneration method where it is satisfactorily is feasible. Historically about stocked. 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The silvicultural prescription for each harvest unit would prescribe whether or not regeneration is required based on the silvicultural treatment of the stand. If regeneration is required, the The 5th-year stand prescription would describe examination will the appropriate method identify those stands (natural recovery, natural not meeting all E-3 (4)(b) Vegetation regeneration, planting) and certified standards, desired species composition but progressing and density. Examinations satisfactorily toward would be appropriately certification. scheduled for each regeneration method to ensure that management objectives were being met. If examinations indicate that the stand is not progressing toward adequate restocking and certification, additional

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treatments would be prescribed. In some cases, seedlings would be planted to meet the reforestation requirement. Natural regeneration is the preferred regeneration method where it is feasible. Historically about 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The silvicultural prescription for each harvest unit would prescribe whether or not regeneration is required based on the silvicultural treatment of the stand. If regeneration is required, the The 5th-year stand prescription would describe examination will the appropriate method schedule for (natural recovery, natural E-3 (4)(c) retreatment those Vegetation regeneration, planting) and stands not desired species composition progressing to and density. Examinations certification. would be appropriately scheduled for each regeneration method to ensure that management objectives were being met. If examinations indicate that the stand is not progressing toward adequate restocking

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and certification, additional treatments would be prescribed. In some cases, seedlings would be planted to meet the reforestation requirement. Natural regeneration is the preferred regeneration method where it is feasible. Historically about 88 percent of the acres prescribed for natural regeneration on the Lewis and Clark National Forest have successfully established. The remaining 12 percent were subsequently planted to meet management objectives, and regeneration was successfully established. The Lewis and Clark National Forest has been experiencing an outbreak of mountain pine beetle (Dendroctonus ponderosae) since about 2004. The intent of Alternative 2 is to remove Limit tractor dead, dying, and structurally skidding to slopes of weak trees, primarily E-4 (4)(6) 45 % or less Vegetation lodgepole, ponderosa, limber, depending on soil and whitebark pine due to type. mountain pine beetle-caused mortality, from recreation and administrative sites, recreation residences, and along roadsides to reduce the hazard for forest users. Alternative 3 would only remove dead or hazardously leaning trees. Harvest units

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for both alternatives would be located in areas that have the potential to experience or have already experienced mountain pine beetle-caused mortality. Harvest prescribed in Alternatives 2 and 3 is not designed to create a break in the vegetation or fuel component, although it could occur along the linear road feature depending upon the number of trees that met the hazard tree definition. Alternatives 2 and 3 are also not designed to create species, size, or age class diversity across the landscape in an attempt to prevent a mountain pine beetle outbreak. The hazard tree project is intended to address hazardous conditions created by the bark beetle. Therefore, treatment would not control or change the current bark beetle outbreak. Anti-aggregation pheromones (verbenone) and insecticide (Carbaryl) have been utilized in recreation and administrative sites across the Little Belt Mountains for the past several years in an attempt to maintain healthy, green conifers within these high value areas. Pheromone and insecticide use are not prescribed in Alternative 2

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and 3.

The Lewis and Clark National Forest has been experiencing an outbreak of mountain pine beetle (Dendroctonus ponderosae) since about 2004. The intent Emphasize harvest of Alternative 2 is to remove of stands that exhibit dead, dying, and structurally characteristics of weak trees, primarily high risk for lodgepole, ponderosa, limber, mountain pine beetle and whitebark pine due to attack. Locate mountain pine beetle-caused timber sales in order mortality, from recreation to break-up and administrative sites, continuous natural recreation residences, and fuel accumulations. along roadsides to reduce the Systems will hazard for forest users. P-1 (1)(a&b) emphasize Vegetation Alternative 3 would only treatments that remove dead or hazardously reduce losses to leaning trees. Harvest units other insects and for both alternatives would diseases by: (a) be located in areas that have improving species the potential to experience or diversity, growth have already experienced and vigor for stands, mountain pine beetle-caused and (b) increasing mortality. Harvest prescribed the size diversity in Alternatives 2 and 3 is not and class diversity designed to create a break in between stands; and the vegetation or fuel component, although it could occur along the linear road feature depending upon the number of trees that met the hazard tree definition. Alternatives 2 and 3 are also not designed to create

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species, size, or age class diversity across the landscape in an attempt to prevent a mountain pine beetle outbreak. The hazard tree project is intended to address hazardous conditions created by the bark beetle. Therefore, treatment would not control or change the current bark beetle outbreak. Anti-aggregation pheromones (verbenone) and insecticide (Carbaryl) have been utilized in recreation and administrative sites across the Little Belt Mountains for the past several years in an attempt to maintain healthy, green conifers within these high value areas. Pheromone and insecticide use are not prescribed in Alternative 2 and 3. During ongoing The Lewis and Clark infestations, control National Forest has been insects and disease experiencing an outbreak of through silvicultural mountain pine beetle and biological (Dendroctonus ponderosae) practices. Chemical since about 2004. The intent controls will be of Alternative 2 is to remove P-1 (2) limited to high value Vegetation dead, dying, and structurally areas or used on a weak trees, primarily broader scale only lodgepole, ponderosa, limber, when all other and whitebark pine due to measures have failed mountain pine beetle-caused and other resource mortality, from recreation values can be and administrative sites, protected. recreation residences, and

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Emphasize along roadsides to reduce the cooperative control hazard for forest users. measures between Alternative 3 would only Federal, State, and remove dead or hazardously private landowners. leaning trees. Harvest units for both alternatives would be located in areas that have the potential to experience or have already experienced mountain pine beetle-caused mortality. Harvest prescribed in Alternatives 2 and 3 is not designed to create a break in the vegetation or fuel component, although it could occur along the linear road feature depending upon the number of trees that met the hazard tree definition. Alternatives 2 and 3 are also not designed to create species, size, or age class diversity across the landscape in an attempt to prevent a mountain pine beetle outbreak. The hazard tree project is intended to address hazardous conditions created by the bark beetle. Therefore, treatment would not control or change the current bark beetle outbreak. Anti-aggregation pheromones (verbenone) and insecticide (Carbaryl) have been utilized in recreation and administrative sites across the Little Belt Mountains for the past several years in an

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attempt to maintain healthy, green conifers within these high value areas. Pheromone and insecticide use are not prescribed in Alternative 2 and 3. The Soils Report addresses Leave coarse woody debris and the approximately 10 quantities recommended by tons of fuel per acre, Graham and others (1994). where available. Coarse woody debris would This should be naturally be added to sites material over four over time as trees or parts of P-2 (4) inches in diameter, Vegetation trees within or adjacent to which is randomly harvest units die and fall. In scattered over the addition, hazard trees in some area. Material locations would be felled and should touch the left in place, thus adding to ground for faster the site’s coarse woody decomposition. debris. Following are the recommended sizes and numbers of hard snags by timber type. The management level percentage relates to the optimum number Excepted from this standard of hard snags for the based on the site-specific C-4 (1) Wildlife various timber types, Forest Plan amendment based on cavity detailed in Appendix E. nesting species present, territory sizes, and other habitat parameters. The primary excavator (woodpecker) species most

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representative of the type is also listed.

Douglas fir ponderosa pine - Excepted from this standard 70% Management based on the site-specific C-4 (1)(a) Level: Hairy Wildlife Forest Plan amendment woodpecker, 10 inch detailed in Appendix E. dbh minimum, 158 snags/100 acres Riparian/Aspen -- 100% Management Excepted from this standard based on the site-specific C-4 (1)(b) Level: Downy Wildlife woodpecker, 6 inch Forest Plan amendment dbh minimum, 300 detailed in Appendix E. snags/l00 acres Lodgepole Pine -- 40% Management Excepted from this standard Level: Northern based on the site-specific C-4 (1)(c) three-toed Wildlife Forest Plan amendment woodpecker, 10 inch detailed in Appendix E. dbh minimum, 72 snags/100 acres Subalpine Fir/Whitebark Pine - Excepted from this standard 60% Mgmt Level: based on the site-specific C-4 (1) Wildlife 10 inch dbh Forest Plan amendment minimum, 108 detailed in Appendix E. snags/100 acres Mixed Conifer -- 63% Management Excepted from this standard Level: Black backed based on the site-specific C-4 (1) three-toed Wildlife Forest Plan amendment woodpecker, 10 inch detailed in Appendix E. dbh minimum, 135 snag/l00 acres

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Excepted from this standard Keep all soft snags, based on the site-specific C-4 (2) which are not a Wildlife Forest Plan amendment safety or fire hazard. detailed in Appendix E. Emphasize harvest of stands that exhibit characteristics of high risk for mountain pine beetle attack. Locate timber sales in order to break-up Prescribed fire is not being continuous natural applied throughout the units fuel accumulations. proposed for treatment, so Systems will management standards for P-1 (1)(a&b) emphasize Fuels appropriate use of prescribed treatments that fire per management area are reduce losses to not applicable for this other insects and project. diseases by (a) improving species diversity, growth and vigor for stands, and (b) increasing the size diversity and class diversity between stands. During ongoing infestations, control insects and disease through silvicultural All action alternatives would and biological meet this standard through implementation of resource P-1 (2) practices. Chemical Fuels controls will be protection measures and limited to high value adherence to regulations; see areas or used on a Fuels & Air Quality Report. broader scale only when all other measures have failed

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and other resource values can be protected. Emphasize cooperative control measures between Federal, State, and private landowners. Use prescribed fire as appropriate to achieve land Prescribed fire is not being management goals, applied throughout the units including proposed for treatment, so improvement or management standards for P-1 (3) Fuels maintenance of appropriate use of prescribed vegetation diversity fire per management area are Management area not applicable for this direction indicates project. the appropriate use of prescribed fire. All action alternatives would Burn debris meet this standard through according to the implementation of resource P-2 (2) Montana Fuels protection measures and Cooperative Smoke adherence to regulations; see Management Plan. Fuels & Air Quality Report.

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Appendix E: Site-specific Forest Plan Amendment Site-specific amendment proposed The proposed action alternatives for the Little Belt Mountains Hazard Tree Removal project would remove dead and dying trees along roadways and within identified recreation and permitted use facilities to address hazardous conditions due to tree mortality. Many of these trees are, or will be, snags, defined as standing dead and downed trees. The objective of the action alternatives is to remove these types of trees to address risk from falling trees in public areas. The Lewis and Clark Forest Plan contains management standards for wildlife trees, including snags. Implementing the Little Belt Mountains Roadside, Recreation, and Administrative Sites Hazard Tree Removal project’s action alternatives would require a project-specific amendment to the Lewis and Clark National Forest Plan (1986). Therefore, the action alternatives include an amendment that would provide an exception to Forestwide Management Standard C-4 for this project (FP pgs. 2-35, 36). Management Standard C-4 Wildlife Trees in the Lewis and Clark National Forest Plan includes the following: (1) Following are the recommended sizes and numbers of hard snags by timber type. The management level percentage relates to the optimum number of hard snags for the various timber types, based on cavity nesting species present, territory sizes, and other habitat parameters. The primary excavator (woodpecker) species most representative of the type is also listed. Douglas Fir/Ponderosa Pine -- 70% Management Level Hairy woodpecker 10 inch dbh minimum 158 snags/100 acres Riparian/Aspen-- 100% Management Level Downy woodpecker 6 inch dbh minimum 300 snags/100 acres Lodgepole Pine -- 40% Management Level Northern three-toed woodpecker 10 inch dbh minimum Subalpine Fir/Whitebark Pine-- 60% Management Level Mixed Conifer -- 60% Management Level Black backed three-toed woodpecker 10 inch dbh minimum

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135 snag/100 acres (2) Keep all soft snags, which are not a safety or fire hazard. (3) Locate wildlife trees adjacent to natural openings, near water, in valley bottoms, or in aspen groves, if possible. It is in these areas that wildlife trees are utilized most often. (4) Cluster wildlife trees in important habitat, rather than spacing them uniformly in an area. (5) Retain larger diameter wildlife trees where possible, because they provide for more species than do smaller trees. (6) Concentrate wildlife trees in areas away from roads, because firewood cutters remove most deadwood adjacent to roads. To limit firewood cutting, develop and implement educational programs to inform the public about the importance of snags to wildlife. Use area closures, road closures, or sign essential snags and “wildlife trees” where necessary. (7) Leave deformed, cull, and spike-topped trees during timber harvest, to provide future wildlife trees. These trees should be girdled or otherwise killed so they stop producing seed. (8) Use timber sale contract “C” clauses, as needed, to retain deadwood. (9) Snags could be provided where there are too few, by killing mistletoe infested, and cull trees. (10) Where feasible, consider protecting snags when using prescribed fire by clearing brush or applying retardant. (11) Keep down trees for wildlife feeding sites. To reduce fire hazard, keep logs instead of windrows, slash piles, and root wads. It is preferable to have two logs with bark per acre and some deteriorated logs. Purpose and Need for Forest Plan Amendment The project’s purpose and need is to effectively address hazardous conditions due to existing or impending tree mortality along open roads and facility investments as identified in Appendix B of the EA. This site-specific amendment would except the project from maintaining snags in the treated areas. Treatment could take place in areas 150 feet either side of open roads and up to 200 feet around identified facility investments. There is not a way to retain snags (dead/dying trees) while still meeting the project’s purpose and need. In addition, applying the concept of snags per/100 acres for linear activities such as hazard tree removal adjacent to roads is difficult to determine spatially. And while many of the aspects of Standard C-4 would continue to be met during project implementation, removal of wildlife trees (snags) would be necessary in order to address potential safety risks. As such, it is proposed that the be excepted from the requirements of Forestwide Standard C-4. Affected Environment The Silviculture report for this project (Project records C02a01 and C02a02) shows the progression of mountain pine beetle-caused tree mortality across the Little Belt Mountains for the past 11 years. Mortality in the past 3-4 years has notably increased (see Appendix C Progression Maps). Mountain pine beetle causes tree mortality in lodgepole, ponderosa, limber,

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and whitebark pine. About 7,915 acres, or 46 percent of the proposed treatment units, are dominated by mountain pine beetle susceptible pine species. Treatment units dominated by subalpine fir, Engelmann spruce, and Douglas fir (29 percent of the treatment area) would remain in a forested condition following treatment since a greater percentage of the tree species within the treatment units are not mountain pine beetle hosts. Non-pine trees that meet the hazard tree definition would be felled, but the number of such trees is expected to be lower. Dead and dying trees can provide snag habitat for wildlife species. In the Little Belt Mountains, in general, there are sufficient wildlife trees to meet Forest Plan standards. Table 25 below, from a January 25, 2004 report titled “Detailed Estimates of Old Growth and Large Snags on the Lewis and Clark National Forest” (Project Record K40) estimated 1,016 snags over 10” dbh per 100 acres in the Little Belt Mountains. This data was generated using Forest Inventory and Analysis data from 1996-1997. Since that time, beetle mortality could be expected to result in significantly more dead or dying trees, so this number is considered to be on the low end. Table 25: Estimates of snag density and associated 90% confidence interval by landscape Average Number of Snags/Acre > or = 10” DBH Landscape 90 percent CI 90% CI Point Estimate Lower Bound Upper Bound Big Snowy Mountains 0.00 3.14 6.86 Castle Mountains 0.00 4.36 16.34 Crazy Mountains 1.57 10.08 19.81 Highwood Mountains 0.00 0.00 0.00 Little Belt Mountains 6.98 10.16 10.39 Little Snowy Mountains 0.00 4.89 0.00 Rocky Mountains 9.91 14.29 10.17

As displayed in Table 26 below, a 2008 report showed that, forestwide, the Lewis and Clark National Forest averaged 670 snags per 100 acres over 10 inches diameter at breast height in areas outside wilderness and roadless area, and 1,030 snags per 100 acres within wilderness and roadless areas.

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Table 26: Snag Densities (snags per 100 acres) on the Lewis and Clark National Forest (from USDA Forest Service 2008c, Table 2) In Outside Wilderness/Roadless Areas Wilderness/Roadless Areas Snags per 100 acres 10”+ dbh 1030 (770 – 1320) 670 (360 – 1060) Snags per 100 acres 15”+ dbh 220 (150 – 310) 90 (30 – 160) Snags per 100 acres 20”+ dbh 40 (20– 70) 10 (0 – 30)

The lower confidence limit of the estimate was 360 snags per 100 acres over 10 inches diameter at breast height, well over the highest recommended level, in riparian areas, of 300 snags per 100 acres greater than 6 inches diameter at breast height in the Forest Plan. In addition, Figures 1 and 2 in the Biological Evaluation display more recent data on the cumulative mountain pine beetle-caused mortality, which shows a marked increase in the number of snags since 2009. Direct, Indirect and Cumulative Impacts of Site Specific Amendment Direct, indirect and cumulative effects of the proposed action and alternatives, by resource, are discussed in this environmental analysis. The discussion of effects assumes the action would take place as proposed, which includes excepting the action from Forest Plan Management Standard C-4. Direct and Indirect Effects to Snag-Dependent Species The impacts of the proposal on wildlife species is addressed in the Wildlife Report and Biological Evaluation (March 20, 2013). Under an extreme scenario in which all proposed treatment acres in forested types (13,599) would be snags, either currently useful or potentially useful in the future as wildlife trees, approximately 1.6 percent of the 800,000 acres Little Belt landscape would be treated. More likely, dead and dying trees less than 10 inches will never become important wildlife trees (the Forest Plan snag standard identifies trees a minimum of 10” dbh as being most useful as wildlife trees). The most likely tree type to be removed during project implementation is lodgepole pine. Approximately 1,362 acres of lodgepole pine forest type of this size could be treated. This is about 0.10 percent of the Little Belt Mountains landscape. In addition, because of the abundance of snags outside of the proposed action area, potential project impacts results in determinations of: the proposed action may impact individuals and habitat but will not lead to federal listing of Townsend’s big-eared bat or black-backed woodpecker, the proposed action will not alter viability of Northern three-toed woodpecker, and the proposed action will not reduce potential foraging habitat for Lewis’ woodpecker, nor contribute to notable loss of cavity nest habitat for this species in the Little Belt Mountains. The project is following management standard C-4 (6) that states “concentrate wildlife trees in areas away from roads, because firewood cutters remove most deadwood adjacent to roads.”

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The provisions of Management Standard C-4 are being met across the Little Belt Mountains, as shown under the affected environment section. In addition, standard C-4 is in place to ensure that wildlife trees are available to species requiring snags. It gives direction as to preferred location and configuration of wildlife trees for optimum use. This standard is largely intended to ensure preservation of important wildlife trees during traditional timber harvest. The wildlife analysis shows that the action alternatives will not reduce habitat for snag dependent species below that which would be a viability concern for any of the species analyzed. Cumulative Effects Management Standard C-4 has not been excepted in any other projects since the Forest Plan was implemented in 1986. There are no other present or reasonably foreseeable actions that propose a site specific amendment to except standard C-4. Information for wildlife species dependent on snags (wildlife trees), that are found on the Forest is located in the Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities (USDA Forest Service 2011) and summarized below.

Northern three-toed woodpecker is identified by the Forest Plan as the management indicator species for special habitat needs of tree-cavity-conifer. According to the Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities (USDA Forest Service 2011, page 12) there appears to be little risk of population loss for Northern three-toed woodpecker and the LCNF should maintain a viable population where the capability of the natural habitat permits. Forested habitat on the Lewis and Clark Forest contributes towards the viability of the species regionally due to habitat availability and management requirements. This is based on known species abundance and trend and the amount of available habitat across the Forest. The project analysis found that for this species the loss of foraging habitat from this project along roads and near administrative and recreation sites will not appreciably alter available snag habitat in the Little Belt Mountains due to the current level of snags and continuing mountain pine beetle activity, as displayed in the forestwide snag information in Table 26 above. Other planned and proposed projects are meeting the requirements of standard C to maintain wildlife trees.

Black-backed woodpecker is a sensitive species on the Lewis and Clark National Forest. According to the Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities (USDA Forest Service 2011, page 29), “management actions taken on the LCNF will provide the habitat composition, structure and processes for the black-backed woodpecker according to the suitability and capability of NFS lands and contribute to the overall Regional needs. While factors outside of Forest Service control (such as global climate change) may have effects on this species, there appears to be little risk of population loss and the LCNF should maintain a viable population where the capability of the natural habitat permits and contribute towards the viability of the species regionally due to habitat availability and management requirements.” The project analysis found that black-backed woodpecker habitat will be

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removed by the project in localized areas; however adequate habitat will remain across the Little Belt Mountains, and Forestwide, due to the existing and increasing number of snags. The project may impact individuals or habitat, but would not likely contribute to a trend toward Federal listing or loss of viability to the population or species. Other planned and proposed projects are meeting the requirements of standard C-4 to maintain wildlife trees. Townsend’s big-eared bat is a Sensitive Species on the Lewis and Clark National Forest. On the LCNF, this species is conserved through forest management standards associated with protection of caves and riparian resources, and old-growth and snag retention management. There appears to be little risk of population loss and species viability will be maintained. The project analysis found that the project would reduce the number of large snags available to Townsend’s big-eared bat, however large snags would continue to be available outside of the proposed treatment areas, in the Little Belt Mountains, and across the Forest. The action alternatives May Impact Individuals or Habitat, but would Not Likely Contribute to a Trend Toward Federal Listing or Loss of Viability to the Population or Species (MIIH). Other planned and proposed projects are meeting the requirements of standard C-4 to maintain wildlife trees. NFMA Significance/Non-Significance Finding The National Forest Management Act (NFMA) provides that forest plan may be amended in any manner, but if the management direction results in a significant change in the plan, additional procedures must be followed. In April 2012, the Forest Service adopted new planning regulations at 36 CFR 219, Subpart A and Subpart B, which replaced the final 2000 land management planning rule (2000 rule) as reinstated in the Code of Federal Regulations on December 18, 2009 (74 FR 67062). The 2012 rule includes a transition period during which plan amendments may be initiated under the provisions of the prior planning regulation for three years after May 9, 2012 and may be completed and approved under those provisions. This amendment is being completed under the requirements of the 1982 regulations. It is, however, subject to the objection process in 36 CFR 219 Subpart B. The 1982 regulations at 219.10(f) require the agency to determine whether or not a proposed amendment would result in a significant change in the plan. If the change resulting from the proposed amendment is determined to be significant, the same procedure as that required for development and approval of a plan shall be followed. If the change resulting from the amendment is determined not to be significant for the purposes of the planning process, then the agency may implement the amendment following appropriate public notification and completion of the NEPA procedures. Forest Service Manual section 1926.5 identifies factors to consider in determining whether an amendment is significant or non-significant for those plans using planning regulations in place before November 9, 2000.

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Changes to the Land Management Plan Management Standard C-4 Amendment That are Not Significant 1. Actions that do not significantly alter the This site specific amendment is consistent with the multiple-use goals and objectives for long-term goals and objectives of the Forest Plan, including long land and resource management. range goals to promote high quality wildlife habitat to ensure a desired mixture of well-distributed species and numbers for public benefit (Forest Plan page 2-2)`. Effects to habitat are limited and impact a small portion of the overall Forest habitat for snag-dependent species. Forestwide objectives also include efforts to control mountain pine beetle outbreaks by harvesting susceptible stands (Forest Plan, page 2-8). 2. Adjustments of management area The amendment does not adjust management area boundaries of management prescriptions boundaries or management prescriptions. resulting from further on-site analysis when the adjustments do not cause significant changes in the multiple-use goals and objectives for long- term land and resource management. 3. Minor changes in standards and guidelines. The amendment is a one-time, site-specific and project- specific exception for the application of Standard C-4. Excepting this project from the standard does not impact viability of wildlife species that use this type of habitat, including black-backed woodpecker, northern three-toed woodpecker, or Townsend’s big-eared bat; nor does it reduce snag densities across the Little Belt Mountains below the Forest Plan standard. 4. Opportunities for additional projects or For this specific project, maintaining snags per acre activities that will contribute to achievement of standards within 150 feet of open Forest Service Roads the management prescription. and within 200 feet of administrative and recreation sites cannot be achieved while working towards and maintaining roads and sites where safety hazards are to be removed. The purpose and need of this project is consistent with the goals and objectives of the Forest Plan. As displayed in Table 25, even following removal of specific hazard trees along roadways and recreation sites, the Little Belt Mountains would continue to meet provisions of Management Standard C-4 (Forest Plan pages 2-35 to 2-36), to provide wildlife trees.

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This site-specific amendment will not alter the long-term relationship between levels of multiple- use goods and services originally projected in the Forest Plan for wildlife habitat, Allowable Sale Quantity, or other resource outputs, nor does it have an important effect on the entire land management plan or affect land and resources throughout a large portion of the planning area during the planning period. Based on consideration of the four factors identified in the Forest Service Manual, 1926.51, and considering the Forest Plan in its entirety, I have determined that exception to Standard C4 of the Lewis and Clark National Forest Plan for the Little Belt Mountains Roadside, Recreation, and Administrative Sites Hazard Tree Removal project would not be a significant change under NFMA to the Lewis and Clark Forest Plan. This amendment is fully consistent with, but further refines and clarifies the means to achieve, current Forest Plan goals and objectives.

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Appendix F: Mountain Pine Beetle Progression Maps Figure 6: Progression of cumulative mountain pine beetle-caused tree mortality in the Little Belt Mountains from 1999 to 2010

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Figure 7: Cumulative mountain pine beetle-caused tree mortality observed in Lewis and Clark National Forest Aerial Detection Surveys between 1999 and 2010

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