United States Department of Agriculture

Forest Service

CP District-wide Salvage Project Final Environmental Impact Statement

Conejos Peak Ranger District, Rio Grande National Forest

March 2018 Conejos and Rio Grande Counties, Colorado

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CP District-wide Salvage Project Final Environmental Impact Statement CP District-wide Salvage Project Final Environmental Impact Statement Conejos and Rio Grande Counties, Colorado

Responsible Agency: USDA Forest Service Responsible Official: Andrea M. Jones, District Ranger Rio Grande National Forest 15571 County Road T.5, La Jara, CO 81120 719-274-6309 For Information Contact: Michael Tooley Rio Grande National Forest 15571 CR T.5; La Jara, CO; 81140 719-274-8971 Abstract This Final Environmental Impact Statement (EIS) evaluates the potential effects of salvage harvest of stands killed by spruce beetles under three alternatives: No Action, Vegetation Management - Proposed Action, and Vegetation Management – Limited Action. The Proposed Action would authorize the salvage harvest of spruce forests on up to 17,000 acres of Forest Service lands, post-harvest planting of conifer seedlings, and implementation of fuel reduction treatments adjacent to developed private lands and infrastructure. The analysis discloses the direct, indirect, and cumulative effects of implementing commercial and non-commercial management activities to meet the purpose and need and move toward desired conditions in the CP District-wide Salvage project area. This document follows the format established in the Council on Environmental Quality regulations (40 Code of Federal Regulations parts 1500-1508). It includes a discussion of the purpose and need for the proposal, alternatives to the proposal, the impacts of the proposed action and alternatives, and a listing of agencies consulted. It is tiered to the 1996 Rio Grande National Forest Revised Land and Resource Management Plan, as amended (Forest Plan), the final environmental impact statement, and record of decision issued for the Forest Plan. As the Rio Grande National Forest is currently undertaking a Forest Plan Revision, this project will be adapted, as needed, to accommodate new information or change associated with the new, finalized plan by utilizing the pre- implementation checklist process. The comment period is closed for this project, and responses to comments can be found in Appendix K of this FEIS. The objection period for the draft decision will end forty-five days from publication of the opportunity to object legal notice in the Valley Courier, Newspaper of Record.

3 CP District‐wide Salvage Project Final Environmental Impact Statement Summary In response to extensive mortality in spruce forests caused by the spruce beetle epidemic, the Conejos Peak (CP) Ranger District proposes to conduct salvage harvest activities on up to 17,000 acres of dead and dying spruce trees in order to move these stands closer to desired conditions in the long-term and capture economic value in the short- term. This proposal also includes performing hazardous fuel treatment activities on up to 1,000 acres of affected lands adjacent to private property and administrative sites, and, to evaluate regeneration needs to meet long-term desired conditions considering stocking requirements, wildlife habitat, and the desired rate of ecological recovery.

The CP District-wide Salvage project area encompasses approximately 332,000 of National Forest System, state, and private lands and is located across the Conejos Peak District in Conejos and Rio Grande Counties. This analysis and work being proposed will only be completed on National Forest System Lands. Legal description for the project area is: T 32 N, R 3-7 E; T 33 N, R 3-7 E; T 34 N, R 3-7 E; T 35 N, R 2-5 E; T 36 N, R 2-5 E; T 37 N, R 3-5 E, New Mexico Prime Meridian.

The purpose and need for this project was developed by comparing objectives and desired conditions described in the Forest’s land management plan relating to forest product use, forest and grassland health and function, and habitat needs for a variety of key wildlife and plant species. The purpose and need also considers the current conditions and expected future conditions of resources resulting from potential changes in climate and the ongoing mortality in the spruce forest across the Conejos Peak Ranger District. Due to the epidemic proportions of the spruce beetle infestation on the Rio Grande National Forest, project analyses were increased in scale to effectively consider larger landscapes.

No major areas of controversy were identified during scoping. Concerns were identified, and how they were addressed is described in section 1.9 of the EIS. The scoping and internal review process identified one issue relating to timber salvage in this landscape: 1) Wildlife impacts specifically relating to Canada lynx and lynx habitat. This issue led the agency to develop the following three alternatives:

1. Alternative 1: No Action

2. Alternative 2: Vegetation Management - Proposed Action

3. Alternative 3: Vegetation Management - Limited Action

Both Action alternatives were designed to be viable, consistent with the direction of the land management plan, and capable of moving resources toward desired conditions, at least to some degree. The action alternatives propose varying acres of commercial harvest treatment activities that would be implemented adaptively to move toward desired conditions.

When evaluating effects between the alternatives, it was found that the No Action alternative would likely have the fewest short-term effects for most resources. The relatively slow rate of forest stand recovery in some areas could be detrimental to some resources. Fuel loadings would continue to increase as snags fall, increasing the potential for longer duration fires and negative soil-heating impacts and increased threat to Forest users, private resources and infrastructure. Under No Action, no National Forest System Roads would be maintained except under regular work orders and as funding allowed. No temporary road construction would be needed under this alternative. No Action would not benefit the local forest products industry.

The action alternatives would have some short-term (approximately 15 years) disturbance effects during harvest activities to soils, watersheds, wildlife and some Forest users. In the long-term (beyond 15 years), there is low risk for adverse effects to resources. Accelerated stand regeneration would be positive in the long-term for all resources. Reducing potential long-term fuel loadings adjacent to private lands would reduce the risk for high-intensity fires in the project area and therefore reduce firefighter safety concerns. The action alternatives would do more to protect existing infrastructure. Positive benefits to local industry would be expected.

4 CP District-wide Salvage Project Final Environmental Impact Statement All proposed management activities for each action alternative would follow Forest Plan standards and guidelines and best management practices, Project Design Criteria (PDC), and the silvicultural guidelines. They would also incorporate the use of a project pre-implementation checklist process and monitoring elements to minimize adverse effects and protect resources. Alternative 2 would have the greatest potential for effects to Canada lynx, as well as an important Rio Grande cutthroat trout fishery. Alternative 3, on the other hand, would reduce the area salvaged by approximately one-half of that proposed by Alternative 2.

Based upon the effects of the alternatives, the responsible official will decide whether or not salvage logging will proceed as proposed, as modified, or not at all; on all or part of the project area; and what monitoring, mitigation or activities will occur if salvage logging is implemented.

5 CP District-wide Salvage Project Final Environmental Impact Statement

Contents Abstract ...... 3 Summary ...... 4 LIST OF TABLES ...... 11 LIST OF FIGURES ...... 13 Chapter 1. Purpose of and Need for Action ...... 15 1.1 Introduction ...... 15 1.2 Project Location/Project Area ...... 15 1.3 Background ...... 17 1.4 Purpose and Need for Action ...... 18 1.5 Forest Plan and Other Direction ...... 19 USDA Forest Service Strategic Plan: 2015-2020 ...... 19 Rio Grande National Forest Land Resource Management Plan ...... 19 Management Area Direction ...... 20 Other Relevant Laws, Policy, and Direction ...... 23 1.6 Proposed Action Summary ...... 23 1.7 Decision Framework ...... 23 1.8 Public Involvement ...... 24 1.9 Issues ...... 24 Issue 1: Effects on Canada Lynx Habitat ...... 24 1.10 Opportunities ...... 25 1.11 Changes made between the Draft and the Final EIS ...... 25 Chapter 2. Alternatives ...... 26 2.1 Alternatives Considered but Eliminated from Detailed Study ...... 27 2.2 Alternatives Considered in Detail ...... 27 Alternative 1 – No Action ...... 28 Activities Common to all Action Alternatives ...... 28 Changed Circumstances or New Information ...... 35 Activities Specific to each Action Alternative ...... 35 Alternative 2 - Proposed Action (preferred alternative) ...... 35 Alternative 3 – Vegetation Management - Limited Action ...... 39 2.3 Comparison of Alternatives ...... 43 Alternative 1- No Action ...... 44 Alternative 2- Proposed Action ...... 44 Alternative 3 – Limited Action ...... 44 2.4 Project Design Criteria for Alternatives 2 and 3 ...... 44 2.5 Monitoring Plan and Adaptive Actions for Alternatives 2 and 3 ...... 48 Chapter 3. Affected Environment and Environmental Consequences ...... 57 3.1 Introduction...... 57 3.2 Silviculture & Forest Products ...... 57 Scope of Analysis ...... 57 Existing Conditions ...... 57 Direct and Indirect Effects ...... 61 Alternative 1 – No Action...... 61 Alternative 2 – Proposed Action ...... 64 Alternative 3 – Vegetation Management – Limited Action ...... 67 Cumulative Effects ...... 69 3.3 Biodiversity ...... 71 Scope of Analysis ...... 71

6 CP District-wide Salvage Project Final Environmental Impact Statement

Existing Conditions ...... 73 Direct and Indirect Effects ...... 75 Alternative 1 – No Action...... 75 Alternative 2 – Proposed Action ...... 77 Alternative 3 – Vegetation Management – Limited Action ...... 78 Cumulative Effects ...... 80 3.4 Wildlife ...... 81 Scope of Analysis ...... 81 Existing Conditions ...... 81 Threatened, Endangered, Proposed and Candidate Species ...... 81 Sensitive and MIS Species ...... 86 Direct and Indirect Effects ...... 90 Threatened, Endangered, Proposed and Candidate Specie...... 90 Alternative 1 – No Action...... 90 Alternative 2 – Proposed Action ...... 91 Alternative 3 – Vegetation Management – Limited Action ...... 97 Cumulative Effects ...... 97 Analysis of Effects to Sensitive Species ...... 108 Effects of Alternative 1 on Sensitive Species ...... 109 Effects of Action Alternatives 2 and 3 on Sensitive Species ...... 110 Effects to Management Indicator Species ...... 110 Migratory Birds ...... 111 Summary of Effects of Alternatives on Migratory Birds ...... 114 Cumulative Effects ...... 114 3.5 Aquatics and Fisheries ...... 115 Scope of Analysis ...... 115 Existing Condition ...... 115 Direct and Indirect Effects ...... 117 Alternative 1 – No Action...... 117 Alternative 2 – Proposed Action ...... 118 Alternative 3 – Vegetation Management – Limited Action ...... 120 Cumulative Effects ...... 121 3.6 Threatened, Endangered and Sensitive Plant Species ...... 122 Scope of Analysis ...... 122 Existing Condition ...... 122 Direct and Indirect Effects ...... 124 Alternative 1 – No Action...... 124 Alternative 2 – Proposed Action and Alternative 3 – Vegetation Management – Limited Action ...... 124 Cumulative Effects ...... 125 3.7 Hydrology and Watershed ...... 126 Scope of Analysis ...... 126 Existing Condition ...... 126 Direct and Indirect Effects ...... 128 Alternative 1 – No Action...... 128 Alternative 2 – Proposed Action and Alternative 3 – Vegetation Management – Limited Action ...... 128 Cumulative Effects ...... 131 3.8 Soils ...... 131 Scope of Analysis ...... 131 Existing Conditions ...... 131 Direct and Indirect Effects ...... 132 Alternative 1 – No Action...... 132 Alternative 2 – Proposed Action ...... 133 Alternative 3 – Vegetation Management – Limited Action ...... 135 Cumulative Effects ...... 135 3.9 Rangeland ...... 136

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CP District-wide Salvage Project Final Environmental Impact Statement

Scope of Analysis ...... 136 Existing Conditions ...... 136 Direct and Indirect Effects ...... 137 Alternative 1 – No Action...... 137 Alternative 2 – Proposed Action ...... 137 Alternative 3 – Vegetation Management – Limited Action ...... 137 Cumulative Effects ...... 137 3.10 Invasive Species and Noxious Weeds ...... 138 Scope of Analysis ...... 138 Existing Conditions ...... 138 Direct and Indirect Effects ...... 139 Alternative 1 – No Action...... 139 Alternative 2 – Proposed Action ...... 139 Alternative 3 – Vegetation Management – Limited Action ...... 140 Cumulative Effects ...... 140 3.11 Air Quality ...... 141 Scope of the Analysis ...... 141 Existing Condition ...... 141 Direct and Indirect Effects ...... 141 Alternative 1 - No Action ...... 141 Alternatives 2 and 3 – Proposed Action and Vegetation Management - Limited Action ...... 141 Cumulative Effects ...... 142 3.12 Fire and Fuels ...... 142 Scope of Analysis ...... 142 Existing Condition ...... 142 Direct and Indirect Effects ...... 142 Alternative 1 – No Action...... 142 Alternative 2- Proposed Action ...... 143 Alternative 3 – Vegetation Management – Limited Action ...... 145 Cumulative Effects ...... 146 3.13 Socio-Economics ...... 146 Scope of Analysis ...... 146 Existing Condition ...... 147 Direct and Indirect Effects ...... 148 Alternative 1 – No Action...... 148 Alternative 2 – Proposed Action ...... 148 Alternative 3 – Vegetation Management – Limited Action ...... 149 Cumulative Effects ...... 149 3.14 Heritage ...... 151 Scope of Analysis ...... 151 Existing Condition ...... 152 Direct and Indirect Effects ...... 153 Alternative 1 – No Action...... 153 Alternative 2 – Proposed Action ...... 153 Alternative 3 – Vegetation Management – Limited Action ...... 153 Cumulative Effects ...... 154 3.15 Recreation Use ...... 154 Scope of Analysis ...... 154 Existing Condition ...... 155 Direct and Indirect Effects ...... 158 Alternative 1 – No Action...... 158 Alternatives 2 and 3 – Vegetation Management - Proposed Action and Limited Action ...... 159 Cumulative Effects ...... 162 3.16 Scenic Resources ...... 162 Scope of Analysis ...... 162

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CP District-wide Salvage Project Final Environmental Impact Statement

Existing Conditions ...... 163 Direct and Indirect Effects ...... 163 Alternative 1-No Action ...... 163 Alternative 2 – Proposed Action ...... 164 Alternative 3 – Vegetation Management – Limited Action ...... 165 Cumulative Effects ...... 166 3.17 Transportation ...... 166 Scope of Analysis ...... 166 Existing Conditions ...... 166 Direct and Indirect Effects ...... 169 Alternative 1 - No Action ...... 169 Alternative 2 - Proposed Action ...... 169 Alternative 3 - Vegetation Management - Limited Action ...... 170 Cumulative Effects ...... 172 3.18 Climate Change...... 172 Scope of Analysis ...... 172 Existing Condition ...... 172 Alternative 1 (No Action) ...... 175 Direct and Indirect and Cumulative Effects ...... 175 Alternative 1 – No Action...... 175 Effects Common to Both Action Alternatives ...... 176 Alternative 2 - Proposed Action ...... 176 Alternative 3 – Vegetation Management – Limited Action ...... 176 Chapter 4. Preparers, Contributors, Distribution Contacts ...... 179 4.1 Interdisciplinary Team Members ...... 179 4.2 Agencies and Tribes Consulted ...... 180 4.3 Distribution of the FEIS ...... 181 4.4 Distribution of the DEIS ...... 182 Index ...... 184 Appendices ...... 185 Appendix A – Commonly Used Terms and Definitions ...... 185 A.1 – Acronyms and Abbreviations...... 185 A.2 – Terms and Definitions ...... 185 Appendix B – References and Literature Cited ...... 191 Appendix C – Project Implementation Checklists ...... 197 Appendix D - Silviculture and Hazardous Fuels Guidelines for Project Implementation ...... 201 Appendix E – Lynx Priority Habitat Descriptions for Alternative 3 ...... 203 Appendix F – Maps ...... 205 Appendix G – Hazardous Fuel Specifications and Guidelines ...... 221 Appendix H – Vegetation and Forest Health Maps ...... 223 Appendix I - Past Silvicultural Activities ...... 227 Appendix J – Recreation Opportunity Spectrum Classes ...... 253 Appendix K – Responses to Comments on DEIS ...... 255 Best Available Science ...... 256 NEPA, NFMA, Forest Plan Revision, Cumulative Effects ...... 258 Adaptive Implementation and Site Specificity ...... 264 Project Design Criteria and Monitoring ...... 269 Range of Alternatives, Purpose and Need, Desired Conditions ...... 271 Timber Operations and Activities ...... 274 Fire, Hazardous Fuels Reduction and Wildland Urban Interface ...... 279 Roads (system and temporary), Transportation and Travel Management ...... 281 Soil, Water and Watersheds ...... 289 Lynx Habitat and Endangered Species Act...... 295 Wildlife (other than lynx), Rare Plants and Fisheries ...... 305 Heritage Resources ...... 309

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CP District-wide Salvage Project Final Environmental Impact Statement

Recreation Management ...... 309 Social - Economics ...... 311 Climate Change and Carbon ...... 313 Chemical Control of Noxious Weeds ...... 320 K.1 Responses to Opposing Views ...... 321 Appendix L – Heritage Checklist Template ...... 323

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CP District-wide Salvage Project Final Environmental Impact Statement

List of Tables Table 1. Forest Plan Desired Conditions and Objectives that pertain to the CP District-wide Salvage Project ...... 19 Table 2. Management area prescriptions in the CP District-wide Salvage Project Area ...... 20 Table 3. Summary of proposed activities under Alternative 2 ...... 35 Table 4. Approximate treatment acres by MAP for Alternative 2, the Preferred Alternative ...... 36 Table 5. Summary of proposed activities under Alternative 3 ...... 39 Table 6. Comparison of alternatives by proposed activities and issue indicators ...... 43 Table 7. Project design criteria for affected resources by alternative ...... 45 Table 8. Comparison between RM-VSS and R2 HSS classifications for forested stands ...... 59 Table 9. Current forest structure across the spruce forest landscape ...... 60 Table 10. Modeled forest structure across the spruce forest landscape in 2066, No Action Alternative ...... 63 Table 11. Modeled forest structure across the spruce forest landscape in 2066, Alternative 2 ...... 66 Table 12. Modeled forest structure across the spruce forest landscape in 2066, Alternative 3 ...... 67 Table 13. Forest Plan standards and guidelines used as resource indicators and measures for biodiversity ...... 72 Table 14. Average and maximum numbers of snags per acre by forest type in 2017 ...... 73 Table 15. Average and total tons per acre of coarse woody debris by diameter class and forest type, 2017 ...... 73 Table 16. Average numbers and ranges in values of large trees per acre by major forest species, 2017 ...... 74 Table 17. Change in acres dominated by aspen due to spruce mortality 2016 and 2017 ...... 75 Table 18. Average and average maximum snags per acre greater than 12 inches diameter for 2017, 2036, 2066, Alternative 1 ...... 75 Table 19. Average tons per acre of CWD by size class and forest type in 2036 and 2066, alternative 1 ...... 76 Table 20. Potential for old growth characteristics in major forest types for 2036 and 2066, alternative 1 ...... 76 Table 21. Acres dominated by aspen in 2016 through 2066, alternative 1...... 76 Table 22. Average snags per acre greater than 12 inches diameter (range of values) for 2017, 2036, 2066, alternative 2 ...... 77 Table 23. Average tons CWD per acre by diameter class (range of values) for 2017, 2036, 2066 in the spruce/fir forest type, alternative 2 ...... 78 Table 24. Trees per acre greater than 16 inches diameter, spruce-fir stands for 2017, 2036, 2066, alternative 2 ..... 78 Table 25. Comparison of alternatives, biodiversity resources in the spruce/fir forest type in 2036 ...... 80 Table 26. Threatened (T), Endangered I, and Proposed (P) species list and habitat descriptions ...... 82 Table 27. Baseline habitat for the LAUs affected by the CP District-wide Salvage Project ...... 86 Table 28. Sensitive species, Rio Grande National Forest (August 29, 2015) ...... 86 Table 29. Summary of the Forest’s MIS species and rationale for their analysis for the CP District-wide Salvage Project ...... 90 Table 30. Acres of lynx habitat affected by the salvage component of Alternative 2 by LAU ...... 92 Table 31. Acres of lynx habitat affected by the hazardous fuels component of Alternative 2 by LAU ...... 92 Table 32. Summary of effects to lynx habitat under each alternative per LAU, including the range up to the maximum treatment scenario for alternative 2 ...... 99 Table 33. Lynx Objectives, Standards, and Guidelines ...... 102 Table 34. Effects determination for Threatened, Endangered and Proposed species ...... 108 Table 35. Effects of Alternatives 2 and 3 on sensitive species where presence is documented or presumed and suitable habitat occurs within or near the proposed action ...... 110 Table 36. Summary of effects to Management Indicator Species by Alternative 2 ...... 111

11 CP District-wide Salvage Project Final Environmental Impact Statement

Table 37. FWS Birds of Conservation Concern for BCR 16 and the anticipated influence of the action and no action alternatives on their conservation needs (USFWS 2008) ...... 112 Table 38. Priority habitats and species of the Southern Rocky Mountains province and their relationship to the CP District-wide Salvage Project Area...... 113 Table 39. Region 2 Sensitive fish species and their relationship to the CP District-wide Salvage Project ...... 116 Table 40. Alternative 2 treatment activities in key RGCT watersheds ...... 119 Table 41. Alternative 3 treatment activities in RGCT watersheds ...... 120 Table 42. Region 2 sensitive plant species known or suspected to occur on the Rio Grande National Forest ...... 123 Table 43. Riparian and stream data for 6th level watersheds with proposed treatment activities ...... 127 Table 44. State of Colorado 303d listed waterbodies in the project area ...... 128 Table 45. Comparison of salvage harvest and treatment activities for 6th level watersheds ...... 129 Table 46. Summary of soil resource inventory units for the project area ...... 131 Table 47. Erosion and mass movement potential in the project area ...... 132 Table 48. Reforest potential and total free harvest within the project area ...... 132 Table 49. Soil Resource Inventory (SRI) units with mass movement potential rating of high and associated acres and percent of the proposed activity areas ...... 135 Table 50. Species list and acreage of known Colorado designated noxious weeds ...... 138 Table 51. Summary of fuel loads within the project area for the No Action Alternative ...... 143 Table 52. Summary of key fuels and fire characteristics for the No Action Alternative ...... 143 Table 53. Summary of fuel loads within the project area proposed for salvage for Alternative 2 ...... 144 Table 54. Summary of key fuels and fire characteristics for the areas proposed for shaded fuel breaks in Alternative 2 ...... 145 Table 55. Summary of fuel loads within the project area proposed for salvage for Alternative 3 ...... 145 Table 56. Summary of key fuels and fire characteristics for the areas proposed for shaded fuel breaks in Alternative 3 ...... 145 Table 57. Financial efficiency for each alternative using a 4% discount rate ...... 150 Table 58. Population information for Conejos, Rio Arriba and Rio Grande Counties (2015) ...... 150 Table 59. Recreation Site Development Scale and Total Capacity ...... 155 Table 60. Recreation special uses on the Conejos Peak District...... 158 Table 61. Description of NFR maintenance levels ...... 166 Table 62. CP District-wide Salvage Project Area Road Mileage by Maintenance Level ...... 167 Table 63. Maintenance Levels and Associated Work Items ...... 168 Table 64. Travel Analysis process report recommendations for decommissioning ...... 171 Table 65. Schedule A agreements within the Project Area ...... 171 Table 66. Summary of gallons of fuel used and metric tons of GHG emissions by alternative ...... 177 Table 67. Core ID Team members with credentials and EIS roles ...... 179 Table 68. List of Agencies and Tribes consulted for the CP District-wide Salvage Project ...... 180 Table 69. Contacts for the FEIS notice of availability ...... 181 Table 70. Contacts for the DEIS notice of availability ...... 182 Table 71. Past Timber Sales within the Spruce Forests of the Project Area ...... 227 Table 72. Other Silvicultural Treatments within the Spruce Forests of the Project Area ...... 244

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List of Figures Figure 1. CP District-wide Salvage Project Vicinity Map ...... 16 Figure 2. Management area prescriptions in the CP District-wide Salvage Project Area ...... 22 Figure 3. Proposed salvage and fuels treatment areas for the northern portion of the project area, Alternative 2 (Preferred Alternative) ...... 37 Figure 4. Proposed salvage and fuels treatment areas for the southern portion of the project area, Alternative 2 (Preferred Alternative) ...... 38 Figure 5. Proposed salvage and fuels treatment areas for the northern portion of the project area, Alternative 3 ..... 41 Figure 6. Proposed salvage and fuels treatment areas for the southern portion of the project area, Alternative 3 ..... 42 Figure 7. District map of roads and trails ...... 156 Figure 8. CDNST district location map ...... 157 Figure 9. CP District-wide Salvage Project Alternative 2 road map ...... 170 Figure 10. Data from NOAA National Climatic Data Center and the Mauna Loa Observatory, from U.S. Forest Service Climate Change Resource Center ...... 173 Figure 11. Forest Carbon summary within Rio Grande National Forest and other regional forests from the 2015 Rio Grande National Forest Carbon Assessment ...... 175 Figure 12. Vegetation Types within the Project Area, North ...... 223 Figure 13. Vegetation Types within the Project Area, South ...... 224 Figure 14. Spruce Beetle Infestation Trends, 1996 to 2016 ...... 225 Figure 15. Western Spruce Budworm Activity, 1996 to 2016 ...... 226

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14 CP District-wide Salvage Project Final Environmental Impact Statement Chapter 1. Purpose of and Need for Action 1.1 Introduction The Forest Service has prepared this Final Environmental Impact Statement (FEIS) in compliance with the National Environmental Policy Act and other relevant federal and state laws and regulations. This Environmental Impact Statement (EIS) discloses the direct, indirect, and cumulative environmental impacts that would result from the proposed action and alternatives.

The document is organized into four chapters:

. Chapter 1. Purpose and Need for Action: This chapter provides background and context for the proposal considering the direction given in the 1996 Rio Grande National Forest Revised Land and Resource Management Plan (Forest Plan), as amended, along with other agency guiding strategies and direction.

. Chapter 2. Alternatives including the Proposed Action: This chapter provides a more detailed description of the agency’s proposed action as well as alternatives for achieving the stated purpose. These alternatives were developed based on the purpose and need as well as the issue raised both internally and by the public.

. Chapter 3. Affected Environment and Environmental Consequences: This chapter describes the environmental effects, organized by resource area, of implementing the proposed action and other alternatives.

. Chapter 4. Consultation and Coordination: This chapter provides a list of preparers and agencies consulted during the development of this EIS.

. Appendices: The appendices provide additional information related to the analysis and proposed implementation process.

Additional documentation, including more detailed analyses of project area resources, may be found in the project planning record located at the Conejos Peak Ranger District or Forest Supervisor’s Office, Rio Grande National Forest.

1.2 Project Location/Project Area The proposed CP District-Wide Salvage (CPDWS) Project is located on the Rio Grande National Forest, Conejos Peak Ranger District in Conejos and Rio Grande Counties, Colorado. The project area ranges in elevation from 8,300 feet to 13,000 feet and encompasses approximately 332,000 total acres of National Forest System lands. Legal description for the project area is: T 32 N, R 3-7 E; T 33 N, R 3-7 E; T 34 N, R 3- 7 E; T 35 N, R 2-5 E; T 36 N, R 2-5 E; T 37 N, R 3-5 E, New Mexico Prime Meridian.

Vegetation within the project area ranges from low-elevation mountain grass and shrubland to mixed-conifer and spruce-fir forest to rocky, alpine tundra at the highest elevations. The majority of forested acres are described as Engelmann spruce-subalpine fir, though aspen is present as a seral species throughout much of the spruce-dominated project area.

15 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 1. CP District-wide Salvage Project Vicinity Map

16 CP District-wide Salvage Project Final Environmental Impact Statement

1.3 Background Since the early 2000’s, extensive spruce beetle mortality has occurred across the Conejos Peak Ranger District. Beetle population build-up was first noted in the southwestern part of the district in 2002 and began to spread to adjacent areas from there. Around 2007, it became evident that beetle populations were reaching epidemic proportions and were no longer behaving as endemic populations. Project analyses were subsequently increased in scale to effectively consider larger landscapes. Similar beetle activity and project responses have been occurring across the entire spruce-fir zone of the Rio Grande National Forest over the last 12 years.

When evaluating the spruce forest across the district, foresters anticipate that all remaining suitable beetle habitat will be infested within the next 2-3 years. Current affected acres are determined through aerial flight reconnaissance and then confirmed with field reconnaissance. Because the spruce beetle-kill signature does not appear in flight data until one year after infestation, it is estimated that a minimum of 85% of the spruce stands within the district (or approximately 126,000 acres) have already been impacted by beetles, far greater than the 67,000 acres observed in flight data. This assessment indicates a need to analyze all spruce beetle habitat across the district as a whole, both infested and anticipated, in consideration of future beetle mortality responses.

The first step in analysis was to determine the full extent of spruce beetle habitat and then define which of these areas have departed or are departing from the desired conditions described in the Revised Land and Resource Management Plan (Forest Plan). Across the district, approximately 149,000 acres of vegetation are mapped as having Engelmann spruce (the preferred food source) as a dominant life form. Most of these forested areas have not departed from desired conditions, due to Management Area Prescriptions (MAPs) such as Wilderness and Backcountry. Such areas would not be treated because they do not present a need for action. In other words, leaving dead spruce trees to deteriorate naturally in these areas meets the desired conditions of those MAP’s. Other areas were also excluded from treatment consideration by the Colorado Roadless Rule. As a result of Forest Plan MAPs and additional Roadless Areas, approximately 109,000 acres of beetle habitat were removed from treatment consideration. Steep slopes and inaccessible areas were also removed from consideration, as well as areas already analyzed for treatment under previous projects. As a result, areas remaining for treatment consideration come to approximately 17,000 acres for salvage potential (11% of the total spruce forest on the district), and 1,000 acres of hazardous fuel treatment potential (less than 1% of the total spruce forest).

Areas expressly analyzed for treatments for this project are in MAPs such as those with an emphasis on wood production, where there is intent to evaluate insect and disease outbreaks against the potential for loss of commercial forest resources and with an emphasis on protecting the commercial resources. In other words, in appropriate MAP’s leaving all of the standing dead trees to their natural deterioration does not meet MAP and Forest Plan objectives, while vegetation treatment would meet the management intent for these areas. Within other MAPs, vegetation composition and structure are managed to meet specific objectives for the area (e.g. recreation) and vegetation management treatments are implemented to accomplish those objectives or contribute to user safety. In additional MAPs within the project area, the plant communities may be managed in a range of successional stages to achieve biological diversity and vegetation management treatments are allowed with resource constraints.

These desired conditions for the MAPs tie to overarching Forestwide Desired Conditions and Objectives. One overarching Desired Condition is to supply wood products while providing for the biological diversity of forested areas. An associated Objective provides an emphasis on long-term sustainable production of resources for economies, communities, and people. Another overarching Desired Condition is that fuel profiles be consistent with land uses and estimates of historic fire regimes. An associated objective provides for using appropriate vegetative-management methods to modify unacceptable fuel profiles, contributing to the protection of human life, property, and resources needed to support long-term industries. 17 CP District-wide Salvage Project Final Environmental Impact Statement

The purpose of this project is to provide an adaptive decision framework for responding to spruce beetle mortality with salvage and hazardous fuel treatment projects in a timely and cost-effective manner in appropriate management emphasis areas, while providing for site-specific protection of biological diversity and other resource management objectives.

1.4 Purpose and Need for Action In areas where forest conditions have departed from desired conditions, action is needed to respond to the widespread tree mortality caused by the ongoing spruce beetle epidemic. The disparity between existing and desired conditions creates a need to utilize available dead and dying trees in a timely manner to meet multiple- use mandates and provide for the protection of firefighters, users, communities, and private resources.

This project considers the landscape as a whole and responds to the desired conditions and objectives as described in the Forest Plan, Rio Grande National Forest Land and Resource Management Plan (USDA Forest Service 1996, as amended). Forest-wide objectives include reducing insect and disease infestations and using a range of silvicultural prescriptions to achieve ecosystem management objectives (Forest Plan p. II-3). The Forest Plan FEIS also addresses the demonstrated and ongoing demand for wood and miscellaneous forest products such as firewood and poles (FEIS p. 3-159). Additional Forest Plan desired conditions and objectives for this analysis are listed in Table 1 below. Objectives are “concise projections of measurable, time-specific intended outcomes. The objectives for a plan are the means of measuring progress toward achieving or maintaining desired conditions (36 CFR 219.7(a) (2) (ii)).”

The purpose of this action is to utilize salvage logging in spruce stands impacted by tree mortality to protect against loss of forest products while perpetuating landscape resiliency and diversity, reducing hazardous fuels near private land and infrastructure, and to meet or move existing resource conditions toward desired conditions. This action will be consistent with Forest Plan direction, including standards and guidelines. Where agency land management plan direction was silent, outdated, or not applicable, the best available science and local knowledge was used. In order to meet the purpose of this action, the following needs have been identified.

In spruce stands heavily impacted by spruce beetle mortality, there is a need to: • salvage dead or dying trees while these trees have economic value; • plant conifer seedlings as needed to meet future forest objectives; and • promote economic sustainability for local communities, including the forest product industry.

To meet hazardous fuel treatment management objectives, there is a need to: • mechanically treat vegetation within 400 feet of private boundaries or 200 feet of administrative sites to increase defensible space; • remove hazard trees within 400 feet of private boundaries or 200 feet of administrative sites; • prune residual trees to lift crown base heights; and • pile and burn or remove activity-generated fuels within timber sale or pre-commercial thinning areas. The indicators for the Purpose and Need are as follows: • acres of salvable timber expected to lose merchantability post mortality; • volume of commercial forest products recovered from insect mortality; • acres of hazardous fuel treatment; and • proportion of spruce forest landscape diversified in stand structure and/or composition as a result of project activities. The purpose and need for this project was developed by comparing objectives and desired conditions 18 CP District-wide Salvage Project Final Environmental Impact Statement described in the Forest Plan relating to multiple-use objectives, forest health and function, biodiversity and sustainability along with considering the current and expected future conditions resulting from the persistent forest mortality due to insects and disease and potential climate changes.

1.5 Forest Plan and Other Direction All land management decisions are governed by laws and policy which direct or provide bounds for project proposals and decisions. Some laws and policy provide constraints; others provide intent and direction for management actions to occur. Direction for this analysis was guided by the following documents: USDA Forest Service Strategic Plan: 2015-2020 The Forest Service develops and publishes five year plans to guide management efforts and establish accountability for making progress toward the goals and objectives stated in these plans. The strategic goal, Sustain our Nation’s Forests and Grasslands, with the following objectives apply to this project area: Objective A – Foster resilient, adaptive ecosystems to mitigate climate change; and Objective B – Mitigate wildfire risk. The Forest Service Strategic Plan, with additional information, can be found online at: http://www.fs.fed.us/strategicplan Rio Grande National Forest Land Resource Management Plan This proposal responds too many of the desired conditions (goals) and objectives described in the Forest Plan and would move the project area toward desired conditions described in the Forest Plan. Table 1 lists the Forest Plan desired conditions and objectives related to this project analysis and proposed management activities.

The Forest Plan can be viewed online at: http://www.fs.usda.gov/main/riogrande/landmanagement/planning

Table 1. Forest Plan Desired Conditions and Objectives that pertain to the CP District-wide Salvage Project

Forestwide Desired Conditions Forestwide Objectives

Vegetative structure on the Forest is capable of 2.2. Manage the Forest to maintain or improve the health sustaining timber harvesting that supplies wood and vigor of all native plant associations. products for humankind while providing for biological diversity of those forested areas.

The amount, arrangement, and continuity of live and/or 2.10 Use appropriate vegetative-management methods to dead material, which would contribute to fire spread (fuel modify unacceptable fuel profiles and reduce potentially profiles), are consistent with land uses and estimates of unacceptable future high-intensity wildfires. historic fire regimes. Special forest products, such as firewood, continue to Emphasize long-term sustainable production of be available from the Forest… resources for economies, communities, and people.

The Forest recognizes the needs of people from the San Use a range of silvicultural prescriptions to achieve Luis Valley and surrounding areas, and strives to meet ecosystem management objectives. These objectives may their needs for forest and wood products, while include supplying forage for wildlife, reducing insect and protecting those resources for future generations. disease infestations, maintaining or improving aspen stands, or enhancing scenery.

Use existing roads, instead of constructing new ones.

19 CP District-wide Salvage Project Final Environmental Impact Statement

Forestwide Desired Conditions Forestwide Objectives

Improve the financial efficiency of all programs and 6.2. Manage, as much as practicable, the Forest’s market projects. oriented programs (timber, range, minerals, and special uses), so that they are financially profitable.

Emphasize cooperation with individuals, organizations, 7.1 Cooperate with all people, including those whose and other agencies while coordinating planning and livelihood is dependent on National Forest resources, in project implementation. the development of plans and projects. 7.2 Cooperate with federal, state, local, and tribal governments, as well as private organizations and individuals, to: promote rural-development efforts…reduce loss of wildlands and structures to wildfires.

Promote rural development. 8.1 Be a leader in working with rural people and communities including American Indian tribes, to develop opportunities and enterprise that contribute to their economic and social vitality.

8.2 Recognize the nature and extent of local economic dependencies on National Forest activities. Give special attention to resources that help diversify rural economies.

General Infrastructure. Facilities are safe, accessible […].as needed to achieve resource management objectives.

This project is also addressing Forest-wide objectives for other resources such as recreation, wildlife and scenery. These are discussed under the individual resource areas in Chapter 3, Affected Environment and Environmental Consequences. Management Area Direction The Forest Plan designated areas to be managed for a particular emphasis or theme known as management area prescriptions (MAPs). Each management area prescription includes a description of the theme and physical setting, along with a description of the desired future conditions. The project area includes sixteen management area prescriptions displayed in Table 2 below. Figure 2 shows the spatial distribution of the management area prescriptions within the project area.

Table 2. Management area prescriptions in the CP District-wide Salvage Project Area

Management Area Management Area Prescription Theme Percentage Treatment Prescription Description Allowance 1.11 - Wilderness, Manage to protect pristine conditions; natural 5% none Pristine processes are not measurably affected by human use. 1.11/1.5 - Inclusion - Manage to protect pristine conditions and Wild 2% none National Wild River in River segments. Pristine Wilderness

1.12 – Wilderness, Manage to protect ecological conditions. 19% none Primitive 1.5 – Eligible Wild Rivers Wild Rivers and adjacent areas are managed to <1% fuels protect and perpetuate eligible river segments. treatment only

20 CP District-wide Salvage Project Final Environmental Impact Statement

Management Area Management Area Prescription Theme Percentage Treatment Prescription Description Allowance 3.1 – Special Interest Manage to protect or enhance areas of unusual <1% fuels Areas – Emphasis on characteristics. treatment only Use or Interpretation

3.3 – Backcountry1 Manage to maintain plant and animal habitats that 33% fuels are shaped primarily through natural processes, treatment only and to provide backcountry experiences to the public where there is little evidence of human activities. 3.4 – National River Manage to protect and perpetuate eligible river 1% salvage & System – Scenic Rivers segments. fuels Designated and Eligible treatment 4.21 – Scenic Byways or Manage adjacent lands to preserve scenic and 3% salvage & Railroads recreation values. fuels treatment 4.3 – Dispersed Manage for recreation opportunities. 5% salvage & Recreation fuels treatment 4.4 – National River Manage to protect eligible Recreation River 2% salvage & System – Recreation segments. fuels Rivers Designated and treatment Eligible 5.11 – General Forest Allow for a variety of management options, such 3% salvage & and Rangelands – as livestock grazing, wildlife habitat, dispersed fuels Forest Vegetation recreation, exploration or development of minerals treatment Emphasis and energy resources, and timber harvest. Management emphasis is on a balance of resource uses. 5.13 – Forest Products Allow a full range of activities, with an emphasis 8% salvage & on the production of commercial wood products. fuels Numerous open roads offer commercial access reduction and roaded recreation opportunities, while restricted roads offer non-motorized recreation opportunities. 5.41 – Deer and Elk Managed to supply adequate amounts of quality 4% salvage & Winter Range forage, cover, and solitude for deer, elk, and fuels other species while on winter range. reduction

5.42 – Bighorn Sheep Managed to maintain or improve bighorn sheep 8% salvage & Area habitat. fuels reduction

6.6 – Grassland Resource Managed to produce forage for livestock, 5% salvage & Production wildlife, and/or recreational stock. fuels reduction

Total project area 100%

1Many of the MAP 3.3 Backcountry areas are now managed under the Colorado Roadless Rule.

21 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 2. Management area prescriptions in the CP District-wide Salvage Project Area

22 CP District-wide Salvage Project Final Environmental Impact Statement Other Relevant Laws, Policy, and Direction Where consistent with other land management plan goals and objectives, there is Congressional intent to allow active vegetation management including timber harvest on suitable lands (Organic Administration Act of 1897, Multiple-Use Sustained-Yield Act of 1960; Forest and Rangeland Renewable Resources Planning Act of 1974; Federal Land Policy and Management Act of 1976; National Forest Management Act of 1976). Intent is also expressed to allow the salvage of dead timber (Forest and Rangeland Renewable Resources Planning Act of 1974), as appropriate. Such actions are also directed and authorized by federal regulation (36 CFR 221.3; 36 CFR 223).

In keeping with these intents, it is Forest Service policy to provide timber resources to the local and regional economy (Forest Service Manual [FSM] 2402; Forest Plan, pp. II-3 through II-4), salvage dead trees (FSM 2435), and treat stands experiencing insect or disease infestations or to prevent infestations (Forest Plan IV-25 through IV-28). 1.6 Proposed Action Summary The Forest Service developed the proposed action (Alternative 2) to meet the purpose and need and move current conditions toward desired conditions in beetle-infested spruce stands. This alternative could implement management activities on up to 18,000 acres on Forest Service lands to meet objectives described in the purpose and need.

Commercial salvage timber harvest would be conducted with ground-based equipment on slopes less than forty percent. All or parts of cut trees could be skidded to designated landings, but slash could be lopped and scattered or piled and burned or removed at landings. Depending on the level of advanced regeneration in the spruce-beetle-impacted stands, tree planting may be required to meet stocking objectives. Landings, skid trails, and old temporary road prisms from previous harvests would be re- used as much as possible to minimize additional disturbance. Some temporary road construction would be necessary. This proposal includes performing hazardous fuel treatment activities on up to 1,000 acres of affected lands adjacent to private property and administrative sites.

The proposed action would be implemented over a ten to fifteen year period. Tree planting would not be implemented until other operations were substantially complete in a treatment area. 1.7 Decision Framework Given the purpose and need, the responsible official will review the proposed action, the other alternatives, and the environmental consequences disclosed in this document in order to make the following decisions:

Will project activities be implemented as proposed, as modified, or not at all?

If project activities proceed, will the PDC, mitigation measures, pre-implementation evaluation process, monitoring items, and adaptive management strategies included provide sufficient protection to minimize or eliminate adverse effects?

This FEIS was prepared after considering the comments on the Draft Environmental Impact Statement (DEIS), in accordance with the National Environmental Policy Act and other relevant federal laws and regulations. The CP District-wide Salvage Project is subject to the objection process pursuant to 36 CFR 218, subparts A and B. The Forest Service will issue a draft record of decision in conjunction with the FEIS that will initiate the 36 CFR 218 objection process. The record of decision will explain the rationale for the decision and disclose how the decision responds to the issues and moves toward desired conditions.

23 CP District-wide Salvage Project Final Environmental Impact Statement 1.8 Public Involvement Opportunities for public engagement have been offered throughout the project development and analysis process. A notice of intent to prepare an environmental impact statement was published in the Federal Register on March 1, 2016, asking for public comment on the proposal by March 31, 2016. In addition, a news article was released; a scoping notice was published in the Valley Courier, the newspaper of record; and a scoping package was mailed to seventy-eight addresses. Eleven comment letters were received and we had twenty-five requests to stay on the mailing list for the project.

A public field trip was held for any interested parties or individuals on October 26, 2016 in the Cumbres Pass area of the Conejos Peak Ranger District. Seven members of the public attended this field trip. The project has also been listed on the Rio Grande National Forest schedule of proposed actions (SOPA) since April 2016. Comments from the scoping process were used to identify issues and develop alternatives to the proposed action.

On October 17, 2017, the 45-day comment period began for the DEIS through publication of the notice of availability in the Federal Register. This was accompanied by legal notice in the newspaper of record and another news release. The DEIS was posted to the project webpage prior the start of the comment period. In addition, the notice of availability as well as specialist reports were posted to the page by October 24. Thirty- nine comment letters were received, and responses to those comments have been included in appendix K of the FEIS. 1.9 Issues Issues are described as follows in Forest Service Handbook (FSH) 1909.10: • Issues are cause and effect statements that serve to highlight effects or unintended consequences that may occur from the proposed action and alternatives. • Issues are used to identify opportunities during the analysis to reduce adverse effects. • Issues are used to compare trade-offs in an understandable and, if possible, quantitative manner. The process used in this project is intended to ensure all issues are identified and other concerns are appropriately addressed in the analysis. Scoping comments were separated into two groups: issues and concerns. Issues were defined as those directly or indirectly caused by implementing the proposed action which cannot be completely mitigated through standard PDC. Concerns were identified as follows: 1. Outside the scope of the proposed action; 2. Already decided by law, regulation, land management plan, or other higher level decision; 3. Irrelevant to the decision to be made; 4. General in nature or not supported by scientific or factual evidence; or 5. Addressed as part of the analysis by Forest Plan standards and guidelines, best management practices, PDC, mitigation measures, or monitoring. The interdisciplinary team, along with consideration of public input, identified one issue and measurement indicators for the analysis. The issue statement and indicator selected was used to develop an additional action alternative, focus the analysis, and compare potential effects of each alternative. The issue analysis process is documented and is part of the project record. Issue 1: Effects on Canada Lynx Habitat Tree mortality from the spruce beetle epidemic has altered habitat conditions for spruce forest associated wildlife species, including the Canada lynx. Project activities may compound beetle impacts by reducing late- successional and future forest habitat components. Canada lynx would be used as a focal species for this

24 CP District-wide Salvage Project Final Environmental Impact Statement issue.

The indicators for issue 1 are as follows: • Percent of suitable lynx habitat affected by treatment per Lynx Analysis Unit (LAU) • Acres of unsuitable lynx habitat improved by planting per LAU • Acres of within-treatment-area movement corridors available

1.10 Opportunities As part of the scoping and analysis process, project activities were developed to provide opportunities to meet a variety of integrated resource improvement objectives. Proposed activities may be implemented that could improve stand growth or reduce insect or diseases, reduce fuels or change the fuel profile to meet specific objectives, and, improve habitat for some species of wildlife. Some projects may be funded with Knutson- Vandenberg monies collected from timber sale receipts, if available, though additional funds will be requested from other sources, as appropriate. Some examples of integrated opportunities include:

• Improve watershed condition by completing road reconstruction and additional road maintenance on several roads to reduce erosion and sedimentation (see the Hydrology section). • Close unauthorized routes to improve watershed condition (see the Hydrology and Transportation sections). • Identify and plan to treat unknown populations of invasive plants and noxious weeds (see Invasive Species and Noxious Weeds section).

1.11 Changes made between the Draft and the Final EIS As a result of comments received on the DEIS, the following changes have been made to the FEIS: • Correction of minor typographical errors and other clarifications to improve consistency throughout the FEIS. • Update to EIS maps (section 2.2, section 3.17, Appendix F) • Throughout the EIS, change from Aquatic Management Zone (AMZ) to the agency-preferred term Water Influence Zone (WIZ). See definitions in Appendix A. • Section 1.5, omitted outdated Western Bark Beetle Strategy (expired in 2016); • Section 2.2, addition of the Adaptive Implementation Process to further illustrate, clarify and explain the adaptive approach to project implementation; • Section 2.4, Project Design Criteria: . Some PDC were edited for clarity . Draft PDCs for Aquatic Resources were omitted and replaced with a new PDC . Addition of a winter recreation PDC under Recreation Resources in response to comments . Addition of three Heritage Resources PDC • Section 2.5, Monitoring, was modified to more clearly display how monitoring fit into the adaptive implementation process. A monitoring measure was also added for fisheries resources. • Addition of Appendix K, Responses to Comments • Addition of Appendix L, Heritage Checklist Template

25 CP District-wide Salvage Project Final Environmental Impact Statement (page intentionally left blank)

26 CP District-wide Salvage Project Final Environmental Impact Statement Chapter 2. Alternatives This chapter describes and compares the alternatives considered in order to meet the purpose and need for the CP District-wide Salvage Project analysis. It includes a description of each alternative considered. This section also presents the alternatives in comparative form, defining the differences between each alternative and providing a basis for choice among options by the decision maker. The official may choose any of the three alternatives in part or whole, or may choose elements from different alternatives and combine them into a modified alternative to be chosen in the decision.

2.1 Alternatives Considered but Eliminated from Detailed Study Federal agencies are required by the National Environmental Policy Act (NEPA) to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR 1502.14). Public comments received in response to the proposed action provided suggestions for alternative methods for achieving the purpose and need. Four other alternatives were considered, but dismissed from detailed consideration for reasons summarized below.

. Focus vegetation treatment only in areas to protect infrastructure – This alternative only addresses hazardous fuels reduction and would not meet the purpose and need of capturing economic value of dead and dying trees while there is still value.

. Mechanical treatments only in wildland urban interface areas with no temporary roads - This alternative would not meet the purpose and need of recovering economic value from dead and dying trees. Furthermore, it would only partially meet the need to reduce hazardous fuels near developed private lands and infrastructure.

. Use pheromones to manage the beetle epidemic – This alternative would not meet the purpose and need of salvaging economic value from timber or reducing hazardous fuels. In addition, the majority of the spruce trees have already been killed by the spruce beetle, therefore pheromones would be of no benefit.

. Decommissioning closed National Forest System Roads – This alternative does not address the vegetation management purpose and need of this project though it does respond to some overall objectives in travel management and watershed health. The Rio Grande National Forest is currently undergoing a forest plan revision process in which travel management will be generally discussed and direction for a Forest-wide, comprehensive review of all system roads will take place post-plan revision. Therefore, addressing extensive travel management in a project-level decision would be inappropriate at this time.

Other suggestions received were outside the scope of this project or duplicative of the alternatives considered in detail.

2.2 Alternatives Considered in Detail The Forest Service developed three alternatives, including the No Action and Proposed Action, in response to issues raised both internally and by the public. Collectively, these alternatives represent a reasonable range of alternatives given the site-specific situation, purpose and need, and issues identified for this project. Table 6 in Section 2.3 of this chapter compares the three alternatives by their effects to resources. For the action alternatives (Alternatives 2 and 3), additional descriptions of actions that could be implemented under different stand conditions can be found in the Silviculture Guidelines in Appendix D.

27 CP District-wide Salvage Project Final Environmental Impact Statement Alternative 1 – No Action The National Environmental Policy Act (NEPA) requires the study of the no action alternative and directs that this alternative be used as a basis for comparing the effects of the proposed action and other alternatives.

The no action alternative assumes no implementation of this proposed action or the other action alternatives would take place in the project area. This alternative represents no attempt to actively respond to the issues, the purpose and need for action, or concerns identified during public scoping. There would be no effort to modify existing conditions, unless authorized by other decisions. Other management or currently permitted uses such as livestock grazing, firewood cutting near open roads, and dispersed and developed recreation would continue. This alternative serves as an environmental baseline for the evaluation of the action alternatives.

Under the no action alternative, natural processes would continue across all proposed treatment areas, except where influenced by firewood gathering and other resource management decisions. No salvage of dead or dying trees would occur beyond those areas open to permitted firewood cutting. Effects on wildlife habitat would be variable depending on species considered. Seedlings would not be planted to reforest understocked stands or to manage stand species composition. Over time, large diameter down fuel and coarse woody debris would continue to increase as trees die and fall. Hazardous fuel treatments would not occur along private boundaries or near administrative sites. System roads would be maintained as funding permits. Activities Common to all Action Alternatives Each action alternative was designed to be viable, consistent with land management plan direction, meet the purpose and need and capable of moving resources toward desired conditions to some degree. The action alternatives propose varying acres of spruce salvage harvest and hazardous fuel treatment activities to adaptively move toward desired conditions that would occur within the defined areas as shown on the alternative maps (Figures 3 - 6).

All proposed management activities for each alternative would follow standards and guidelines/best management practices, PDC, incorporate an adaptive implementation process and the use of a project pre- implementation checklists, silviculture guidelines, and monitoring elements.

Activities associated with spruce salvage harvest common to both action alternatives would include:

• Salvage logging and log hauling operations using ground-based equipment: all or parts of cut trees could be skidded to designated landings, but slash could be lopped and scattered or piled and burned at landings, • National Forest System Road maintenance and reconstruction, • Re-use of old non-system road templates, followed by decommissioning, • New temporary road construction and use, followed by decommissioning, • Identification of areas for public and commercial firewood gathering: firewood gathering would still be permitted along open roads across the district per existing rules. • Planting of native conifer seedlings as needed to meet future forest objectives.

Activities associated with hazardous fuel treatments within spruce mortality zones common to both action alternatives would include:

• Establishment of shaded fuel breaks by thinning within 400 feet of private boundary or 200 feet of administrative sites. This activity would modify fuel profiles to reduce fire behavior and intensity to provide better opportunities for firefighters to engage the fire near structures, both public and private. Treatments would generally involve chainsaw work but may also include mechanical operations and

28 CP District-wide Salvage Project Final Environmental Impact Statement chipping. • Hazard tree removal within 400 feet of private boundary or 200 feet of administrative sites, • Pruning of residual trees within the fuel break to lift crown base height, • Piling and burning or removal of activity-generated fuels within salvage harvest and fuel break thinning areas. Activities would begin the summer of 2018 and continue for 10-15 years.

Adaptive Implementation Process Each action alternatives also includes an adaptive implementation process. This process will be used to:

• Incorporate additional monitoring questions, • Integrate better field-verified information as it is obtained, • Adjust to Forest Plan revisions, as appropriate • Review the effects of previous treatments into future treatment design. Elements of this adaptive strategy will include the iterative and integrated use of: 1) Forest Plan standards and guidelines; 2) PDC (section 2.4); 3) the Project Implementation Checklists; 4) Monitoring Measures and Adaptive Actions (section 2.5); and 5) the Silviculture Guidelines (Appendix D). The goal of adaptive management and implementation is to promote effective decisions for any management activities that are implemented and to continually monitor, learn, and adapt during and after implementation of site-specific projects. This analysis has been developed under the 1996 Rio Grande National Forest Plan. Per 36 CFR 219.15, requirements in a new Forest Plan revision will be incorporated into existing projects as soon as practicable, unless the plan revision ROD specifically states that the project may proceed unchanged. In such case, the decision maker would decide if any direction from the new plan still makes sense to incorporate into future project under this analysis, as long as those changes are within the scope of the project decision. Consistency with a plan revision will be ensured through the checklist process. Prior to individual project implementation, pre-implementation checklists will be completed by resource specialists in order to incorporate adaptive actions, as needed. The pre-implementation checklists may result in additional project-specific design criteria or monitoring being applied to a project, if recommended by a specialist, reviewed by the implementation interdisciplinary team, and approved by the Responsible Official. The first checklist provides the mechanism for incorporating additional environmental mitigation and ensuring activities are within the scope of the Forest Plan, this analysis, and the project decision. At this stage, the completed pre-implementation checklist will be posted to the Rio Grande National Forest website and additional public input will be accepted on the final project design. The public feedback will be used to ensure understanding and communication, and disclose any new information obtained during field verification. The second checklist in the process provides accountability by ensuring that mitigation measures were fully incorporated into subsequent contracts. The Silviculture Guidelines (Appendix D) will be used as a summary guide for desired landscape conditions and provide sideboards for the silvicultural options analyzed for each alternative, including parameters for silviculture activities being proposed and their relationship to suitable lynx habitat and Southern Rockies Lynx Amendment management restraints. Project monitoring is gathering information, observing processes, and examining the results of management activities to provide a basis for evaluation and sharing results. Monitoring includes implementation monitoring and evaluation to ensure that standards and guidelines and/or best management practices are being incorporated properly during project implementation, as well as effectiveness monitoring and evaluation to determine whether project objectives are being met and if PDC and other processes are effective. Effectiveness monitoring and evaluation provides an opportunity for continued learning and adaptation to improve results. Initial monitoring measures and adaptive actions identified for this project are outlined in this chapter, section 2.5. 29 CP District-wide Salvage Project Final Environmental Impact Statement Adaptive Implementation Roadmap The following Adaptive Implementation Roadmap illustrates the adaptive framework from Record of Decision to project completion. Between DEIS and FEIS, an additional public feedback step was added in response to comments to promote collaboration with partners and stakeholders.

30 CP District-wide Salvage Project Final Environmental Impact Statement Project Implementation Checklists CP District-wide Salvage Project Implementation Checklist #1 of 2 Analysis at Project Initiation

This stage of analysis is tiered to the CP District-wide Salvage Project. Refer to the project Final Environment Impact Statement and Record of Decision, available at the Conejos Peak Ranger District office or online at http://www.fs.usda.gov/projects/riogrande/landmanagement/projects, for discussions and analysis permitting this action.

Implementation Project Name: ______Implementation Project Location: ______Proposed activities: ______Proposed treatment area (acres): ______

1. Forest Plan Compliance This project falls within the following Management Area Prescriptions (MAPs) or geographic areas (attach map): ______

1a. Current law, policy and plans have been considered for new information pertaining to these activities. Effects are within the context considered in the project FEIS.* 1b. The treatment activities are allowed within these area prescriptions per current Forest Plan direction. 1c. Standards, guidelines, and handbook direction specific to this activity, which are not already addressed by project design criteria (PDC), are listed below. These are to be included in the project design:

MAP Specify standard, guideline, direction, or NA

* If effects are determined to be outside the scope and range of effects considered in the FEIS, the responsible official will determine the type of additional analysis that is necessary prior to additional implementation.

Analysis completed by Date ______Signature

2. Colorado Roadless Rule Compliance 2a. No timber sale units fall within a CRA. 2b. No hazardous fuel treatments fall within an upper tier CRA. 2c. Hazardous fuel treatments within a CRA (non-upper tier) are within ½ mile from the boundary of an at-risk community. Name of community, or NA: ______2d. Hazardous fuel treatments within a CRA (non-upper tier) are within 1½ miles from the boundary of an at-risk community having a Community Wildfire Protection Plan. Name of CWPP & community, or NA: ______

31 CP District-wide Salvage Project Final Environmental Impact Statement

2e. Hazardous fuel treatments are not otherwise prohibited (by law or Forest Plan prescription).

Analysis completed by Date ______Signature

3. Project FEIS/ROD Compliance 3a. This project falls within the CP District-wide project area boundary and the proposed activities were allowed by the Decision. 3b. This project does not treat areas which were excluded from treatment by the Decision. 3c. Total number of salvage acres previously treated under this decision . Additional proposed salvage acres to be treated with this project . Summed acres do not exceed Decision treatment area for salvage harvest. 3d. Total number of hazardous fuels treatment acres previously treated under this decision . Additional proposed acres to be treated with this project . Summed acres do not exceed Decision treatment area for hazardous fuel treatment. 3e. Total number of miles of temporary road (new & old combined) previously opened under this decision . Additional proposed miles of temporary road (new & old combined) proposed with this project . Summed miles of temporary road do not exceed Decision for temporary road. 3f. This project was considered for public firewood gathering. Areas were designated as appropriate. 3g. Specialist survey and required consultation has been completed. Note remarks under (3f).

Resource Specialist Initial & Date Resource Specialist Initial & Date Fisheries Watershed Wildlife Heritage (See also Heritage Checklist) Scenic Silviculture Soils Old Growth Recreation Range Fuels Hydrology Botany & Rare Plant

3h. The following actions must be added to the project design (in addition to PDC and 1b above) to meet statutory, regulatory, and Forest Plan requirements.

Provision Citation of requirement being met

4. Lynx Conservation Compliance (Southern Rockies Lynx Amendment or superseding agreement) This project falls within the following LAUs (attach map): ______

4a. Standards VEG S1, VEG S2, VEG S5, & VEG S6 (or equivalent) are met or are not applicable to the treatments proposed. 4b. Guidelines VEG G1, VEG G4, VEG G5, VEG G10, & VEG G11 (or equivalent) are met or are not applicable to the treatments proposed. 32 CP District-wide Salvage Project Final Environmental Impact Statement

4c. Impacts to lynx habitat baselines resulting from this project have been recorded in the tracking spreadsheet (see attached) and reported to the USFWS. 4d. The project is in compliance with the terms of the BO.

Analysis completed by Date ______Signature 5. Heritage Resources 5a. Section 106 compliance has been met on this project. (See also Heritage Checklist)

Analysis completed by Date ______Signature

6. District Ranger Certification I have reviewed Implementation Checklist #1 for this project and agree that the analysis herein meets all project planning requirements and that the actions fall within the scope of the CP District-wide Salvage Project Record of Decision. Implementation Checklist #2 will be completed after sale preparation.

______Date ______Signature

33 CP District-wide Salvage Project Final Environmental Impact Statement

CP District-wide Salvage Project Implementation Checklist #2 of 2 Analysis prior to Project Implementation or Contract Solicitation

This stage of analysis is tiered to the CP District-wide Salvage Project. Refer to the project Final Environment Impact Statement, available at the Conejos Peak Ranger District office or online at http://www.fs.usda.gov/projects/riogrande/landmanagement/projects, for discussions and analysis permitting this action.

Implementation Project Name: ______Implementation Project Location: ______Proposed treatment activities: ______Proposed treatment area (acres): ______

1. Management Area Compliance 1a. All standards, guidelines, and handbook direction identified in Checklist #1, Section 1, have been implemented in the project & addressed in the Timber Sale Report (for timber sales) or Silviculture prescription (for Hazardous Fuels management projects), along with the PDC.

2. Project FEIS/ROD Compliance 2a. All stipulations identified in Checklist #1, Section 3, have been implemented in the project & addressed in the Timber Sale Report (for timber sales) or Silviculture prescription (for Hazardous Fuels management projects), along with the PDC. 2b. Public notification has occurred per the Decision direction.

Analysis completed by Date ______Signature 3. Public Notification 3a. Checklist #1 and all supporting documentation has been placed on the Forest website.

4. Recommendations for Travel Management:______

5. District Ranger Certification I have reviewed Implementation Checklist #2 for this project and agree that the analysis herein meets all project planning requirements and that the actions fall within the scope of the CP District-wide Salvage Project Record of Decision. Project implementation may begin immediately.

______Date ______Signature

34 CP District-wide Salvage Project Final Environmental Impact Statement

Changed Circumstances or New Information If new information or changed circumstances relating to the environmental effects of the selected alternative occur after a decision document is signed and during the life of this analysis, the responsible official and interdisciplinary team will review the new information or circumstances and determine if the effects are within the scope and range of effects considered in this environmental impact statement. If the effects are within the context considered in this analysis, this will be documented and included in the project file and any changes to the implementation process will be updated. If effects are determined to be outside the scope and range of effects considered in this analysis, the responsible official will determine the type of additional analysis that is necessary prior to additional implementation (Forest Service Handbook 1909.15, sec. 18.1). As provided in 50 CFR §402.16, re-initiation of consultation is required where discretionary Federal agency involvement or control over the action has been retained (or is authorized by law) and if: (1) the amount or extent of incidental take is exceeded; (2) new information reveals effects of the agency action that may affect listed species or critical habitat in a manner; (3) or to an extent not previously considered the agency action is subsequently modified in a manner that causes an effect to the listed species or critical habitat not previously considered; or (4) a new species is listed or critical habitat designated that may be affected by the action. Activities Specific to each Action Alternative Alternative 2 - Proposed Action (preferred alternative) Under this alternative, salvage of dead and dying spruce from suitable areas across the district would occur. Hazardous fuel treatments would also be utilized to modify forest fuels adjacent to private property and administrative sites that are within areas affected by spruce beetle mortality. Salvage harvest activities would occur on up to 17,000 acres on lands determined appropriate for timber salvage. Hazardous fuels treatment activities would occur on up to 1,000 acres of treatment area. The proposed action also includes development of pre-implementation checklists for later-stage analysis (see Appendix C). The developed checklists would tier to this early-stage decision and allow focus on compliance in relation to 1) project decision, 2) Forest Plan, statute, and regulation, and 3) reporting and notification requirements.

Table 3. Summary of proposed activities under Alternative 2

Activity Alternative Estimate (these are the largest number of treatment acres possible under this alternative) Area salvaged 17,000 acres

Non-system road templates re-opened, followed by 35 miles decommissioning New temporary road construction, followed by 32 miles decommissioning Planting of native conifer species Approximately 860 acres

Fuel break thinning, hazard tree removal, pruning, and pile 1,000 acres burning

Proposed treatment areas and associated road needs are identified within the project geodatabase for site- specific analysis. Adjustments made during later-stage analysis would be kept within the scope of impacts

35 CP District-wide Salvage Project Final Environmental Impact Statement analyzed in this environmental impact statement and Forest Plan through use of the implementation checklists.

Table 4. Approximate treatment acres by MAP for Alternative 2, the Preferred Alternative

MAP MAP Description Approximate MAP MAP Description Approximate Treatment Acres Treatment Acres 4.21 Scenic Byways/Railroads 451 5.41 Deer/Elk Winter 409 Range 4.3 Dispersed Recreation 1,934 5.42 BHS Area 481 5.11 General Forest/Rangeland 86 6.6 Grassland Resource 1,354 5.13 Forest Products 11,984

36 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 3. Proposed salvage and fuels treatment areas for the northern portion of the project area, Alternative 2 (Preferred Alternative) 37 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 4. Proposed salvage and fuels treatment areas for the southern portion of the project area, Alternative 2 (Preferred

38 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 3 – Vegetation Management - Limited Action Under this alternative, salvage of dead and dying spruce from some suitable areas across the district would still occur, as well as hazardous fuel treatment activities. Salvage harvest activities, however, would be focused on areas outside of field-verified, high-quality lynx habitat through implementation of specific PDC and lynx habitat protection elements. Additional explanation and lynx priority area descriptions can be found in Appendix E. Salvage harvest activities would occur on up to 8,500 acres, on lands determined as appropriate for timber salvage. Hazardous fuel treatment activities would occur on up to 1,000 acres of treatment area on lands determined appropriate for fuels management.

Lynx Habitat Elements for Alternative 3 This alternative focuses treatment activities using the following lynx habitat elements:

Element 1: Protection of the Future Forest and Addressing Uncertainties Involving Existing Quality Lynx Habitat in a Changed Landscape Condition • No harvest would occur in lynx habitat priority 4 areas or priority 3 areas where there is >35% DHC at the stand level (i.e. high-quality lynx habitat). Detailed priority area descriptions can be found in Appendix F. • No harvest would occur in areas that overlap more than 20 acres of habitat identified by a local lynx denning habitat model (Topolewski 2017). This model selects forest type and abiotic habitat conditions used by denning lynx based on local research (Merrill and Shenk 2006). Model outputs can be found in the project file.

Element 2: Habitat Connectivity • This element is addressed through PDC relating to movement corridors and leave islands (See design criteria in section 2.4).

Element 3: Lynx Primary Use Areas • Salvage projects will be delayed in the Conejos Canyon and Alamosa Lynx Analysis Units (LAUs) to allow for current research to be integrated. • This element is further addressed through PDC relating to documented lynx reproduction areas and in designing Alterative 3. Like the proposed action, the limited action also includes development of implementation checklists for later-stage analysis (see Appendix C). The developed checklists would tier to this early-stage decision and allow focus on compliance in relation to 1) project decision, 2) Forest Plan, statute, and regulation, and 3) reporting and notification requirements.

Table 5. Summary of proposed activities under Alternative 3

Activity Alternative Estimate (these are the largest number of treatment acres possible under this alternative) Area salvaged 8,500 acres

Non-system road templates re-opened, followed by 34 miles decommissioning New temporary road construction, followed by 23 miles decommissioning

39 CP District-wide Salvage Project Final Environmental Impact Statement

Activity Alternative Estimate (these are the largest number of treatment acres possible under this alternative) Planting of native conifer species Approximately 860 acres

Fuel break thinning, hazard tree removal, pruning, and pile 1,000 acres burning

Proposed treatment areas and associated road needs are identified within the project geodatabase for site-specific analysis. Adjustments made during later-stage analysis would be kept within the scope of impacts analyzed in this environmental impact statement and Forest Plan through use of the implementation checklists.

40 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 5. Proposed salvage and fuels treatment areas for the northern portion of the project area, Alternative 3 41 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 6. Proposed salvage and fuels treatment areas for the southern portion of the project area, Alternative 3 42 CP District-wide Salvage Project Final Environmental Impact Statement

2.3 Comparison of Alternatives This section provides a summary of the effects of implementing each alternative. Information in the following table is a comparison of the alternatives focused on activities or effects that could be distinguished quantitatively or qualitatively among alternatives. Effects to lynx habitat and specific LAUs are discussed based on the issue identified during scoping. Additional discussion in consideration to the issue follows the table. Alternative 3 was primarily developed in response to scoping and proposed excluding timber harvest in high quality lynx habitat.

Table 6. Comparison of alternatives by proposed activities and issue indicators

Resource and Unit of Measure Alt 1 Alt 2 Alt 3 No Action Proposed Limited Action Action Area of salvable timber expected to lose 17,000 0 8,580 merchantability post mortality Volume of commercial forest products recovered 0 Up to 340,337 Up to 189,906 from insect mortality (CCF) Acres of hazardous fuel treatment (acres) 0 1,000 1,000 Proportion of spruce forest landscape diversified in 0% up to 12% up to 6% stand structure and/or composition as a result of project activities (%) Estimated lynx habitat acres treated that would Spruce beetle Spruce beetle Spruce beetle contribute to SRLA exemptions & exceptions11 salvage – 0; salvage – Up to salvage –0 Fuels reduction – 1,000 Fuels reduction – 0 Fuels reduction – 1,000 1,000 Alamosa LAU - lynx habitat2 Acres of spruce/fir salvage/Acres in lynx habitat 0 4,462 2,338 Acres of hazardous fuels treatment 0 419 419 Conejos Canyon LAU – lynx habitat Acres of spruce/fir salvage/Acres in lynx habitat 0 5,729 2,599 Acres of hazardous fuels treatment 0 317 317 La Jara LAU - lynx habitat Acres of spruce/fir salvage/Acres in lynx habitat 0 2,025 767 Acres of hazardous fuels treatment 0 1 1 Rito - Archuleta LAU - lynx habitat Acres of spruce/fir salvage/Acres in lynx habitat 0 2,953 1,935 Acres of hazardous fuels treatment 0 155 155 Victoria - Chama LAU - lynx habitat Acres of spruce/fir salvage/Acres in lynx habitat 0 1,141 564 Acres of hazardous fuels treatment 0 0 0 Miles of non-system road templates re-opened, 0 34 24 followed by decommissioning Miles of new temporary road construction, followed 0 30 23 by decommissioning

1 Lynx habitat acres are estimated based on modeling efforts described in the Wildlife Report. Actual acres may vary and will be tracked in project monitoring and reporting checklists. 2 Most if not all fuels reduction treatments are anticipated to meet WUI exemption.

43 CP District-wide Salvage Project Final Environmental Impact Statement Alternative 1- No Action Issue 1: Effects on Canada lynx habitat –The spruce mortality is not likely to have significant impacts to the primary prey species of the Canada lynx – the snowshoe hare. However, lynx population dynamics might be affected due to potential influences on the lynx’s main alternate prey species, the red squirrel, particularly during periods when hare population cycles are low. Through time, a patchy distribution of coarse woody debris (both standing dead and down trees) and newly regenerating trees and shrubs would develop across the landscape. Alternative 1 would have the least effects on lynx habitat, since there would be no additional human- influenced habitat manipulation impacts on lynx habitat or movement in the analysis area. Existing levels of firewood cutting within 300 feet of open roads would continue. Alternative 2- Proposed Action Issue 1: Effects to Canada lynx – Since Alternative 2 has the most acres proposed for timber management activities in lynx habitat, it would be expected to have the most potential effects on lynx and lynx habitat and is anticipated to have adverse effects to lynx. Alternative 2 could have the most incidental impacts to dense horizontal cover and would most likely convert the most acres to temporarily unsuitable habitat (stand initiation structural stage) for all affected LAUs.

Though this alternative would affect lynx habitat on the most acres, all effects would be in compliance with the Programmatic Biological Opinion completed for the 2008 Southern Rockies Lynx Amendment. As applicable, the documents included in Appendix C will be the primary guidance for ensuring adherence to the Southern Rockies Lynx Amendment standards, objectives, and biological opinion requirements along with ensuring management consistency with conservation measures identified in the Canada Lynx Conservation Assessment and Strategy (LCAS 2013) for vegetation management on federal lands. All forest plan standards and guidelines will apply to all alternatives. Project design criteria, pre-implementation checklist process, and the Silviculture Guidelines were developed for this project to ensure adverse impacts to lynx habitats were minimized and to move toward landscape objectives for lynx habitat, to the extent possible for this project area. Alternative 3 – Limited Action Issue 1: Effects to Canada lynx – Since Alternative 3 has the fewest acres proposed for timber management activities in lynx habitat, it would be expected to have the least potential effects on lynx and lynx habitat of the two action alternatives. Alternative 3 could have the least incidental impacts to dense horizontal cover and would likely convert the fewest acres to temporarily unsuitable habitat (stand initiation structural stage) for each lynx analysis unit (see Wildlife section, Canada lynx analysis, Chapter 3). As with Alternative 2, all effects would also be consistent with the Programmatic Biological Opinion completed for the 2008 Southern Rockies Lynx Amendment. As applicable, the documents included in appendix D will be the primary guidance for ensuring adherence to the Southern Rockies Lynx Amendment standards, objectives, along with ensuring management consistency with conservation measures identified in the Canada Lynx Conservation Assessment and Strategy (LCAS 2013) for vegetation management on federal lands. All Forest Plan standards and guidelines will apply to all alternatives. The PDC, pre-implementation checklist process, and the Silviculture Guidelines were developed for this project to ensure adverse impacts to lynx habitats were avoided or minimized and to move toward landscape objectives for lynx habitat, to the extent possible for this project area. 2.4 Project Design Criteria for Alternatives 2 and 3 These PDC have been found to be effective in reducing potential adverse impacts to the respective resources. Each PDC would apply to all management activities, as applicable to the action taken. They will be applied in addition to the management measures of Forest Service Handbook 2509.25 (Watershed Conservation Practices Handbook), the Forest Plan Standards and Guidelines of the 1996 Forest Plan Revision, and provisions of

44 CP District-wide Salvage Project Final Environmental Impact Statement Forest Service 990a (National Best Management Practices for Water Quality Management on National Forest System Lands), which are also required during project execution.

Table 7. Project design criteria for affected resources by alternative

Protection Measure Alt 2 Alt 3 Wildlife/TES/MIS/Botany • Snags: Retain a minimum of 4 spruce snags per acre in various conditions of decay. x Snags will be retained in groups where possible. Snags are to be selected based on the following criteria: o Wildlife use – Snag groups may be centered surrounding trees with cavities, large cracks, broken tops, and defoliating bark as these provide the greatest use for cavity nesting and roosting species. o Biological legacies – These features take a long time to develop and should be retained whenever possible. For the purposes of this analysis these are to be defined as: . Trees/snags with old growth character or defects . Trees/snags generally larger than the stand average . Snags that occurred prior to the spruce beetle infestation o Live trees – snag groups may be centered surrounding live trees to minimize potential for loss due to windthrow and provide additional cover. o Whenever possible, a Wildlife Biologist will assist with marking. As appropriate, a sample mark will be conducted if a sale will be implemented as Designation by Description (DxD); units will be reviewed to determine if objectives are met before progressing to the next. Examples of when a sample mark would be provided include when a purchaser is new, unfamiliar with DxD operation, or when their performance has been considered inadequate. • Surveys for TES species will occur prior to project design; results of surveys will be x x incorporated into the project design and/or implementation per Forest Plan Standards. If needed, additional conservation measures will be recommended to District Ranger for implementation on that project. • Within salvage treatments, harvest spruce only, except for trees that otherwise need to be x x removed for operational/safety purposes. • District wildlife personnel will be notified of any potential denning, burrowing, or nesting x x activities identified during operations. Upon discovery of a raptor nest location or other TES wildlife species nesting/breeding (or other critical) site, suspend any active logging or other contract operations underway in the immediate vicinity until a wildlife biologist assesses the situation to determine and recommend to District Ranger appropriate action(s) to take for protection of habitat or individual animals. Examples of appropriate actions include seasonal logging restrictions, nest buffers, and habitat protection measures. • Winter logging is encouraged to limit direct disturbance to the fewest number of wildlife x x species, but will cease by May 1. Winter logging would also protect potential buried cultural deposits from ground disturbance, as well as soils and advance regeneration. • As feasible, trees with important wildlife cavities are not to be felled, even if unmarked. x x • Minimize or avoid to the extent practicable impacts to advance regeneration during layout x x and operations. • All temporary roads will be decommissioned post-treatment x x • Focus on protecting high quality advance regeneration (≥35% DHC) where it occurs in x blocks of 0.3 acres or larger. To be applied in lynx habitat priority 1 and 2 areas where stands are essentially single-storied and regeneration is minimal. See appendix F for a detailed description of the lynx habitat priority areas. • Four hundred to six hundred (400-600) foot wide movement corridors will be established x within 6th-level watershed boundaries (HUC12) to provide within and between LAU connectivity and aid in movement across or around large openings created or enhanced by project activities. Openings that are created or enhanced by project activities are those where harvest units or portions of harvest units are separated only by road, WIZ, or open meadow; do not meet forest plan Guideline Silv-4 for big game cover in spruce-fir (RGNF Revised Land and Resource Management Plan, Table III-6); and are of sufficient size to create barriers to lynx and other wildlife movement.

45 CP District-wide Salvage Project Final Environmental Impact Statement

Protection Measure Alt 2 Alt 3 • Snags: Retain a minimum of 8 spruce snags per acre in various conditions of decay. x Snags will be retained in groups where possible. Snags are to be selected based on the following criteria: o Wildlife use – Snag groups may be centered surrounding trees with cavities, large cracks, broken tops, and defoliating bark as these provide the greatest use for cavity nesting and roosting species. o Biological legacies – These features take a long time to develop and should be retained whenever possible. For the purposes of this analysis these are to be defined as: . Trees/snags with old growth character or defects . Trees/snags generally larger than the stand average . Snags that occurred prior to the spruce beetle infestation o Live trees – snag groups may be centered surrounding live trees to minimize potential for loss due to windthrow and provide additional cover. • Whenever possible, a Wildlife Biologist will assist with marking. As appropriate, a sample mark will be conducted if a sale will be implemented as Designation by Description (DxD); units will be reviewed to determine if objectives are met before progressing to the next. Examples of when a sample mark would be provided include when a purchaser is new, unfamiliar with DxD operation, or when their performance has been considered inadequate. • Where needed, leave islands consisting of up to 25% of harvest area will be designated x within 6th-level watershed boundaries (HUC12) by a wildlife biologist or designee. These areas will include patches of advance regeneration, biological legacies, and wildlife movement corridors. Snag retention requirements may be captured in part through this project design criteria. • A wildlife biologist will work with timber staff to designate all harvest units within ½ mile x radius of any location where evidence of lynx reproduction has been documented within the previous 10 years. Range Resources • Forest regeneration will be protected from livestock grazing by using adaptive strategies x x such as reducing livestock concentrations by avoiding salt/supplement placement in regenerating areas, avoid pushing large numbers of livestock into the area, use riders if needed to disperse/move large numbers, and maintaining pasture rotation to avoid season-long grazing. • If current natural barriers are made ineffective by skid trails or tree removal, new fence x x locations would be identified on a sale area basis. Fences would be constructed as necessary to ensure allotment rotations are in compliance with individual Allotment Management Plans and Annual Operating Instructions. • Rangeland management improvements, including fences & developed springs, will be x x protected from damage. • If included within a cutting unit, stock driveways would be treated as protected features x x and coordination between range and timber managers should occur during timber operations and times of use by livestock. Opportunity to remove trees that have fallen or could fall on the driveway, along with hazard trees, should be incorporated into project design. Noxious Weeds • Prior to activities, known sites of noxious weed infestations within the project area will be x x treated, dependent upon funding. • Prior to moving off-road equipment onto a sale, purchasers will identify the location of the x x equipment’s most recent operation. Purchasers will not move any off-road equipment that last operated in an area infested with one or more invasive species onto a sale without having first cleaned the equipment. If the location of prior operation cannot be identified, it will be assumed as being infested with invasive species. • Harvest areas and haul routes will be treated for noxious weed infestations as needed for x x five years following harvest, dependent upon funding. • Road fill and road base material brought in from off-site will come from a borrow source x x free of State Listed Noxious Weeds. The Forest Service will inspect and approve the borrow source location prior to materials being hauled to the project area. Timber/Silviculture Resources • In all salvage units that exceed 50 percent removal of overstory spruce, reforestation x x surveys will be conducted, and if the survey indicates that Forest Plan stocking Standards will not be met, these stands will be artificially reforested to meet or exceed Forest Plan Standards.

46 CP District-wide Salvage Project Final Environmental Impact Statement

Protection Measure Alt 2 Alt 3 Aquatic Resources • No harvest equipment or skid trails will be allowed within the water influence zone (WIZ – x x minimum of 100 horizontal feet from the top of each stream bank) of all intermittent or perennial stream channels. Skid trail crossings within the WIZ of all streams (including ephemeral) will be minimized and must be approved in advance by the Forest Service. • Within the WIZ of ephemeral stream channels, harvest equipment can operate to remove trees. However, no skid trails are allowed in the WIZ and mechanical ground disturbance in or immediately adjacent to channels (within 25 feet) must be avoided. • A no cut buffer of 100 feet will be maintained from each channels edge of perennial and x x intermittent streams. • Within the WIZ of ephemeral channels, trees within the defined channel/swale area may not be harvested. • No heavy equipment will be operated within a minimum 100 foot buffer around field- verified x x wetlands; if trees are designated for harvest in these areas, they will be winched out with one end free from the ground. These buffers can be expanded to ensure protection of subsurface flows and water quality. • Riparian management zones (RMZ’s) will be developed along streams containing core, x x conservation, and recreational populations of cutthroat trout and Rio Grande Sucker. Within RMZ’s, no salvage harvest will occur within 2 tree heights of the stream bank. • Site potential tree height by potential vegetation group Potential Vegetation Group Age 2 Site Tree Height (feet) 1 – Aspen Forest, with and without softwoods 100 120 2 – Bristlecone Pine / Limber Pine 100 100 5 – Mixed Conifer (cool-moist) 100 130 9 – Spruce-Fir 100 170 Soil Resources • Forest Plan Standards for soil productivity (15% detrimental soil impact to activity area), will x x be achieved through careful design of skid trails, operating during dry seasons or frozen soil conditions, and use of existing landings and skid trails where practical. • Units with existing detrimental soil disturbance >15% will be treated as necessary to x x ensure post-treatment forest plan compliance, as determined by a soils or watershed specialist. Treatments would include subsoiling/ripping of skid trails, landings, and temporary road and seeding or covering with slash. • If whole tree yarding is used, limbs and/or tops shall be returned to the unit if 15% or more x x of the unit has exposed mineral soil; this material shall be distributed in areas primarily comprised of bare mineral soils. Coarse woody debris will be retained per Forest Plan standards and guidelines. • Landing and skid trail locations will be agreed to by the Forest Service in advance of x x construction; spacing will be approximately 100 feet apart, allowing for topographic variation and skid trail convergence. Place landings and skid trails away from areas of dense horizontal cover (i.e. >35%) where feasible. • Logs will be skidded with the leading end free of the ground to reduce ground disturbance. x x Skid trails will be water-barred at least every 100 feet on gradients greater than 20 percent, otherwise where needed depending on slope and ground conditions as per BMPs. Slash will be placed on main skid trails as needed to control erosion. • Avoid ground skidding on sustained slopes steeper than 40%. x x • Existing vegetation on cut and fill slopes would be retained as much as possible to limit x x sediment movement away from road. Recreation Resources • Notify the public of logging activity through appropriate media outlets x x • Post caution signs at key intersections along the haul route to alert the public to logging x x activities • No timber sale operations will occur within 200 feet of a yurt or within 200 feet of one x x designated skier access route to it, during the timeframe of December 11 to March 30, unless site conditions are otherwise documented as inadequate for cross-country ski use and approved by the District Ranger. This restriction would not apply to locations where the ski route intersects with a haul route, or where it meets a haul route at the trailhead or parking area. District personnel may work with the yurt permittee to designate an equitable alternative route to satisfy this restriction, if one is available.

47 CP District-wide Salvage Project Final Environmental Impact Statement

Protection Measure Alt 2 Alt 3 Scenic Resources • To the extent possible in sensitive viewsheds (i.e. recreation sites, sensitivity level 1 x x roads, and Scenic Byways): o Locate landing piles away from the observer’s line-of-sight and burn as soon as safe and practical o Locate timber sale unit boundaries along natural openings to mimic the natural patterns of the landscape o Blend silvicultural treatments with characteristic landscapes • Avoid single-spaced trees along ridgelines post-treatment Heritage Resources • Any new temporary road sections will be surveyed for heritage resources prior to x x construction. Specific alignment and lengths of temporary road sections within cutting units may vary as appropriate for logging operational needs after coordination with the Forest Archeologist. • When heritage sites that are evaluated as field eligible historic properties are located during x x the field inventory, no mechanical treatment will occur within the site boundary or within a 50-foot buffer around the site. If treatment is necessary, these sites and the 50-foot buffer will be hand-treated for hazard trees and accumulated fuel build up utilizing the treatment options in Stipulation B of the CO Beetle PA (Appendix). • The Heritage Checklist will be utilized as each tiered undertaking is developed to inform the x x survey strategy, the research design, and design criteria for each specific area. • Eligible and unevaluated sites will be avoided by all ground disturbing activities. The x x Heritage Program will provide the timber program locational data so that operations can easily avoid these sites. • All persons in the area who are associated with this project shall be informed that any x x person who, without a permit, injures, destroys, excavates, appropriates or removes any historic or prehistoric ruin, artifact, object of antiquity, Native American remains, Native American cultural item, or archaeological resources on public lands is subject to arrest and penalty of law (16 USC 433, 16 USC 470, 18 USC 641, 18 USC 1170, and 18 USC 1361). Strict adherence to the confidentiality of information concerning the nature and location of archeological resources would be required of the proponent and all of their subcontractors (Archaeological Resource Protection Act, 16 U.S.C. 470hh). • If subsurface cultural values are uncovered during operations, all work in the vicinity of the x x resource will cease and the Authorized Officer with the Rio Grande National Forest (RGNF) notified immediately. The operator shall take any additional measures requested by the RGNF to protect discoveries in place until they can be adequately evaluated by the Forest Archaeologist. Within three (3) working days of the discovery, the Tribes and the SHPO will be notified of the discovery and consultation will begin to determine an appropriate mitigation measure. RGNF in cooperation with the operator will ensure that the discovery is protected from further disturbance until mitigation is completed. Operations may resume at the discovery site upon receipt of written instructions and authorization by the authorized officer (36 CFR 800.110 & 112, 43 CFR 10.4); San Luis Valley Interagency and Intertribal NAGPRA MOU 2008.

2.5 Monitoring Plan and Adaptive Actions for Alternatives 2 and 3 Monitoring is gathering information, observing processes, and examining the results of management activities to provide a basis for evaluation. Monitoring is done at both the project and Forest Plan level. This includes implementation monitoring and evaluation to ensure that Standards and Guidelines are being incorporated during the project activities, as well as effectiveness monitoring and evaluation to determine whether project objectives are being met and if PDC are effective. Below are the monitoring measures and adaptive actions (adjustments) incorporated into the adaptive implementation process.

48 CP District-wide Salvage Project Final Environmental Impact Statement Monitoring Measures and Adaptive Actions

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods Changed Conditions – New Information New information or New Project Area Implementation Initiation of New information or • Responsible Official Possible new substantially information or Checklist Implementati changed conditions determines additional analysis changed conditions changed on project are outside scope analysis needs; and/or NEPA relating to condition and range of effects • Re-initiate consultation decision environmental analyzed, as w/ FWS; effects determined by IDT • Document analysis and and Responsible rationale in project Official record Forest Plan Changes in Project Area Implementation Initiation of New Forest Plan • Document additional Effects kept Standard & Checklist Implementati revision signed PDC in implementation within the Guidelines on project checklist scope of the affecting FEIS analysis resource conservation Project Design Implementation & Project Design Implementati Implementation Prior to Protection Measure • Redesign project to Effects kept Effectiveness of Criteria is on Project Checklist #2; solicitation not included in incorporate all within the resource protection incorporated area Contract or (Checklist project design; protection measures scope of the measures (e.g. cavity into project Project #2); Specifications not prior to signature of FEIS analysis tree PDC, soil specifications Inspection; During being implemented Checklist #2 productivity PDC, and post-treatment contract • Ensure implementation etc.) implemented review administratio of project specifications n (Inspection) or suspend operations Lynx Habitat High-quality lynx Acres of salvage Stand/Project Pre- Prior to Proposed harvest Work with silviculturist Effects kept habitat harvest area implementation project areas overlap high- and District Ranger to within the proposed in Checklist #1 approval quality lynx habitat prioritize salvage areas scope of the high quality field surveys and/or shift unit FEIS analysis habitat boundaries on a site- specific basis as needed. Multi-storied, Acres of salvage Project Area Annual Prior to Acres of incidental Closely track activities; Effects kept mature, late- harvest & – Acres/LAU reporting to project damage to DHC is at • Prioritize future projects within the successional stands related FWS; pre- approval 70-80% of maximum to ensure maximum

49 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods with DHC (Veg S6) activities in Veg implementation (Checklist incidental damage as approved incidental scope of the damaged by S6 stands Checklist #1 #2); approved in Selected damage acres are not FEIS analysis management field surveys Annually Alternative exceeded activities (report to FWS) Less than 30 percent Acres of Cumulative Annual Annual Acres of mapped & Work with silviculturist & Effects kept of lynx habitat in an mapped & acres in SISS reporting to report to verified lynx habitat IDT to modify salvage units within the LAU is in stand verified lynx due to FWS; pre- FWS & IDT in SISS nearing 30% to avoid additional scope of the initiation structural habitat in SISS natural implementation in an LAU conversion of suitable lynx FEIS analysis stage (VEG S1) that currently disturbances Checklist #1 habitat to SISS does not &/or field provide winter management verification; snowshoe hare activities post-treatment habitat monitoring Less than 15% of Salvage harvest Acres treated Annual Annual Timber management • Closely monitor and limit Effects kept lynx habitat in an that over a 10- reporting to report to has regenerated 10% additional salvage acres within the LAU would be regenerates year period in FWS; pre- FWS of verified lynx in an LAU; scope of the regenerated by stands an LAU implementation habitat in LAU • Adjust project FEIS analysis vegetation Checklist #1 boundaries management (over field 10-year period); (Veg verification; S2) post-treatment monitoring Impacts to Dense DHC at stand Selected Pre- Prior to and Assumptions • Adjust anticipated future Effects kept Horizontal Cover level stands within implementation following regarding impacts to project effects to within the (DHC) project area Checklist #1 implementati DHC exceeded (i.e. suitable habitat scope of the field on stand conversion to • Update project effects to FEIS analysis verification; unsuitable) habitat and baselines in post-treatment FWS report using monitoring monitoring results • Suggest additional PDC as needed Wildlife Other Than Lynx Raptor Nest Raptor Raptor nests Prior to project Prior, during, Not following PDC, or • Adjust raptor nest Effects kept Protections Nests/Active within ½ mile approval; and after PDC not adequate to protection specifications within the of during protect raptor (limited operating

50 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods Territory implementati implementation project nests/territories periods and/or no- scope of the (Territories) on project ; post- completion (nest/territory treatment areas) FEIS analysis area treatment abandonment) monitoring Fisheries Impact to key Ensure PDC and Habitat Electrofishing Prior, during, Not following PDC, or • Suspension of activity, Effects kept Fisheries Sensitive Forest Plan conditions; surveys; Fish and after PDC not adequate to per contract provisions, within the Species (Rio Grande Standards & fish habitat surveys; implementati protect fish or fish until concern rectified scope of the Cutthroat Trout and Guidelines are population Cooperation on project habitat. Biologically • Additional PDC for FEIS analysis Rio Grande Sucker) being met metrics; all with CPW, completion. significant decline in fisheries protection, and habitats within within Lake RGCT and RGS fish population additional monitoring, Lake Fork of Conejos Fork of Conservation metrics and/or and modify/discontinue River. Conejos River Agreements habitat conditions as treatments within Lake a result of project Fork Conejos River watershed, if necessary. implementation. Watershed Watershed and Acres disturbed HUC 6 Annual Prior to ERA surface Additional evaluation of Effects kept stream health in by commercial watershed – reporting to approval of disturbance in stream health needed. within the identified HUC 6 salvage harvest Acres of IDT; pre- Implementati Watersheds of • Identify problem areas scope of the watersheds of activities &/or expected implementation on Checklist Concern is calculated that may need additional FEIS analysis concern temporary disturbance field surveys #2 at 10% PDC or restoration prior roads converted to to approving additional Equivalent disturbance. Roaded Area • Discontinue treatments (ERA) if no mitigation is feasible. Impacts to Acres disturbed HUC 7 Annual Prior to ERA surface Additional evaluation of Effects kept watershed and by commercial watershed – reporting to approval of disturbance in stream health needed. within the stream health in salvage harvest Acres of IDT, pre- implementati Watersheds of • Identify problem areas scope of the identified HUC 7 activities &/or expected implementation on Checklist Concern is calculated that may need additional FEIS analysis watersheds of temporary disturbance field surveys #2 at 10% PDC or restoration prior concern roads converted to to approving additional Equivalent disturbance; Roaded Area • Discontinue treatments (ERA) if no mitigation is feasible.

51 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods Watershed BMP’s Detrimental Cutting Unit USFS BMP Post project, BMP implementation • Improve contract Effects kept are effectively impacts and road monitoring minimum 1 composite score is enforcement within the implemented. observed within stream program (FS monitoring rated as “poor or • Improve PDC or scope of the the WIZ. crossings 990A) evolution per fair”. contract provisions. FEIS analysis year. • Increase monitoring frequency to minimum of 3 monitoring evolutions per year. Soils Soil productivity Past activities Percent DSD Pre- Prior to Pre-implementation Work with IDT to Effects kept and acres of per salvage implementation project review indicates soil determine appropriate within the detrimental soil unit Checklist #1; approval resource inventory action: scope of the disturbance post-treatment through units (SRIs) have • Modify unit by adjusting FEIS analysis (DSD) following monitoring Checklist #2 sensitive boundaries; activity and post characteristics, • Identify additional PDC completion implementati and/or units of or mitigation needed to on concern are maintain soil monitoring as discovered through productivity; necessary pre-implementation • Drop unit from project if monitoring and soil productivity cannot randomly selected be maintained units in course of • Require remediation of regular forest plan detrimentally impacted monitoring units • Preclude units on a more strict basis related to pre-implementation monitoring results Soil Productivity Soil under Cutting Unit Standard During Soil reaches or nears Activities are suspended Effects kept plastic limit method contract plastic limit until soils dry enough to within the established and administratio support activities scope of the accomplished n when FEIS analysis during project project activities activities are scheduled

52 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods Silviculture/Botany/Biodiversity Stands with a Trees per acre Cutting Unit- Stocking First, third, Stocking Artificial regeneration of Effects kept regeneration harvest post-harvest acres surveys and fifth year requirements from native tree species from within the prescription are (if necessary) the stand local seed sources scope of the reforested after sale prescription are not FEIS analysis closure met Sensitive Plants (or Known Treatment Implementation Pre-, during, Unacceptable • Suspension of activity, Effects kept Species of populations are unit and Checklist #1 and post- damage occurring per contract provisions, within the Conservation adequately disturbed surveys; site treatment until concern rectified scope of the Concern) protected areas visits • Additional PDC for FEIS analysis protection, additional monitoring, and modify/discontinue treatments, if necessary.

Range Resources/Noxious Weeds Noxious Weed Populations of Cutting Unit Implementation Prior to Populations found • Weed treatments of Effects kept Control designated and disturbed Checklist #1; solicitation; during monitoring known populations prior within the noxious weeds areas- acres annual post- after sale to disturbance scope of the treatment closure • Equipment cleaning FEIS analysis monitoring for before entering a sale 5 years • Use of weed-free materials during activity • Seeding of disturbed areas with native plant seed • Post-disturbance treatments of weeds Regeneration Percent of Cutting unit- Walk-through Annual or Livestock damage is • Implement necessary Effects kept protection from regeneration count surveys; biennial exceeding 10% Range PDC within the livestock damaged or stocking scope of the killed by surveys FEIS analysis livestock

53 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods Prescribed Burning and Fuels Fuel Consumption & Fire Behavior Treatment Weather Pre-planning Burn Plan • Postpone or cease Fuels Smoke Production Unit forecast and and during parameters are not ignitions if Burn Plan reduction fuel moisture pile burning being met objectives are not being objectives are observations; operation met met; Effects Visual kept within the scope of the FEIS analysis Heritage Resources Known eligible, Items Individual Follow pre- Discovery of heritage • Additional PDC for Important unevaluated, and programmatic implementati resource protection, additional resources are undiscovered agreement and on analysis monitoring, and protected; heritage resources Heritage and survey; modify/discontinue Effects kept Checklist (if during treatments, if necessary. within the applicable) activity • Suspension of activity, scope of the stipulations for discovery per contract provisions, FEIS analysis evaluating until concern rectified potential for adverse effects and the need for protective measures Transportation System Roads and Maintenance Individual Implementation Pre- Roads are not safe • Incorporate an Infrastructure Trails Infrastructure Level design road or trail checklist #1; implementati for haul, or engineered road is protected or standards segments timber sale on; during infrastructure could package in the contract; improved; road package contract be damaged by or maintenance Effects kept administratio activities specification to protect within the n infrastructure scope of the • Inspect workmanship FEIS analysis prior to acceptance Illegal Routes Presence of Individual Visual Continuous Activities have • Install additional signs, Effects kept natural or locations observation removed travel barriers, and increase within the constructed barriers, or illegal law enforcement efforts scope of the barriers FEIS analysis

54 CP District-wide Salvage Project Final Environmental Impact Statement

Value Monitored Indicators Scale/Unit of Monitoring Monitoring Trigger for Adaptive Adaptive Implementation Effect of the (measurable Measure Mechanism/ Frequency Action Tools (Adjustments Made) Adjustment value) Methods routes are otherwise discovered

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56 CP District-wide Salvage Project Final Environmental Impact Statement Chapter 3. Affected Environment and Environmental Consequences 3.1 Introduction Council on Environmental Quality regulations direct agencies to succinctly describe the environment that may be affected by the alternatives under consideration (40 CFR 1502.15). As such, this chapter summarizes the physical, biological, social, and economic environments of the project area and the effects of implementing each alternative on that environment.

The following chapter is organized by resource area with each resource section beginning with a description of the Affected Environment, or the existing conditions, then the analysis of direct and indirect effects, or Environmental Consequences, of implementing each alternative. Direct effects are caused by the action and occur at the same time and place. Indirect effects are caused by the action and occur later in time or are removed in distance, but are still reasonably foreseeable. Effects may be either beneficial or detrimental. Cumulative effects result from the incremental impacts of an action when added to other past, present, and reasonably foreseeable future actions regardless of who implements the action (Federal, non-Federal, or individuals); the effects of these actions must overlap in both space and time (considering the duration of effects) for a particular resource for there to be potential cumulative effects.

Two time frames are referred to throughout this analysis, short-term and long-term. Short-term is for a fifteen-year period (the term of the project) and long-term is considered beyond fifteen years. A list of terms, definitions and common acronyms used in the analysis are located in appendix A.

3.2 Silviculture & Forest Products Scope of Analysis This section primarily analyzes the effects of proposed activities upon forest vegetation within the spruce forest portions of the project area boundary. Spruce forests were selected for analysis, due to the impacts of the ongoing disturbance agent (spruce beetle), as well as the subsequent proposed salvage and fuels treatment activities. Quantitative indicators are used to qualitatively evaluate how well each alternative would achieve the project purpose and need with respect to forest vegetation, forest products, and movement toward desired conditions.

Three elements will be addressed: Forest Health and Species Composition, Forest Structural Diversity and Resiliency, and Forest Products. The Timber and Silviculture specialist report can be reviewed for discussions concerning methodology, assumptions, information sources, and limitations of data and models. Existing Conditions The spruce forest landscape within the project area consists primarily of spruce-fir forests at the highest elevations (77% of the subset), with spruce-mixed conifer forests at mid-elevation (23% of the subset). These combined forest types represent 41% of the land cover within the project area and range from 8,400-12,600 feet in elevation. Other vegetation and land cover types represented in the project area can be grouped to include grasses & forbs (26% of the project area); rock, bare ground, & water (5%); cottonwood & shrubs (2%); aspen (17%); pine (2%); and mixed conifer (7%). See Figures 12 & 13 in Appendix H for maps of vegetation cover types and distribution across the project area. All acres are approximate; acres for vegetation cover types and percentage are rounded to the near whole unit. Proposed activity acres are rounded up to the nearest 500 acres to allow the management flexibility intended with this type of landscape-level analysis.

57 CP District-wide Salvage Project Final Environmental Impact Statement Forest Health and Species Composition Forest insects and diseases, along with fire, are important ecological disturbance agents and affect species composition within stands across entire landscapes. The major disturbance agents related to this project are spruce beetle (Dendroctonus rufipennis), western spruce budworm (Choristoneura occidentalis), Armillaria root disease (Armillaria ostoyae), and windthrow. Other native insect and disease agents are also present across the landscape, but without management implications.

As indicated in Chapter 1, the spruce beetle is currently the single greatest disturbance agent within the spruce forest landscape. Increased spruce beetle activity was first noted in the south in the Wolf Creek drainage (Cumbres Pass area) and Neff Mountain areas in 2003. A small salvage sale was implemented on Neff Mountain in 2004 and the County Line Vegetation Management Project was initiated the same year. Spruce beetle activity increased dramatically in the County Line area until 2010 and spread into and across the project area from the west at epidemic rates. Similar population build-up and spread was also noted in the Weminuche Wilderness Area on the Divide Ranger District during the same period.

Field surveys were completed in 2016 by Rio Grande National Forest timber personnel and compared with observations in active timber sale areas. Recent aerial flight data was also reviewed. Heavy spruce beetle activity has been found throughout the entire project area. According to Forest Service Entomologist Tom Eager, mortality of every infested spruce tree is a near certainty because of the immense population of beetles present. Susceptible spruce trees currently not infested are also very likely to become infested for the same reason.

The dramatic increase in spruce beetle activity in the project area highlights the severity of the prior drought conditions across the Forest, as well as extremely high spruce beetle populations. Various indicators of drought severity including water yields, fuel moisture content, and plant physiology all set records in 2002. It is likely that these conditions, as well as the prolonged drought, facilitated the rapid increase in beetle population and activity when this outbreak first began, helping create the existing condition.

Large spruce beetle populations throughout the project area are proving to be detrimental to the mature stands in this analysis. Once a full-blown outbreak is underway, extreme beetle populations can swarm entire landscapes and kill the majority of mature spruce trees. Such intense outbreaks are not unheard of. Landscape- scale outbreaks of spruce beetle have been recorded throughout the range of spruce, including locations in Alaska, New Mexico and Utah as well as numerous examples in Colorado. Due to the predominant presence of spruce stands within the project area, this outbreak has and is expected to continue to have broad impacts across the landscape. See Figure 14 in Appendix H for the spatial extent of spruce beetle activity detected by Forest Health Protection aerial surveys from 1996 through 2016.

Western spruce budworm and Armillaria root disease remain endemic within the spruce forest landscape and as such are not major factors in relation to forest health. Likewise windthrow has not been a noteworthy disturbance process on the analyzed landscape. See Figure 15 in Appendix H for the spatial extent of western spruce budworm activity from 1996 through 2016.

When evaluating existing conditions within the project area in terms of forest health, it is important to understand what standard the conditions are being measured against. A quick review of the Forest Plan definition of forest health will note that it is a condition where influences do not threaten management objectives for a given Forest unit now or in the future (text abbreviated and emphasized for clarity). With this definition, the standard for forest health is determined by the management objectives for the unit under consideration. If the existing condition is in alignment with the objectives for the unit, then forest health meets the standard. If the existing condition is not in alignment with the objectives for the unit, then there is a disparity to be addressed. Some management units within the Forest are intended for events to be heavily managed for certain goals, while other units are intended to be very lightly managed for other goals. This definition does not deny the benefits of natural processes, but tends to the overlap between natural processes 58 CP District-wide Salvage Project Final Environmental Impact Statement and desired conditions.

Within the project area lie fifteen Management Area Prescriptions (MAPs) defined by the Forest Plan. The majority of the spruce forests (89%) fall within MAPs for which forest health is influenced primarily by natural processes; these areas include Wilderness, Special Interest Areas, Backcountry, Scenic Rivers, and Recreation Rivers. No disparity is considered to exist within these MAPs. MAPs 5.11 (General Forest and Intermingled Rangelands) and MAP 5.13 (Forest Products) (7%) fall at the other end of the spectrum and were designed to manage specifically against the loss of forest products to insect and disease outbreaks. Within both of these prescriptions, forest insect or disease infestations are to be evaluated against the potential for loss of commercial forest product resources, with management emphasis on protecting the commercial resources (Rio Grande National Forest 1996). Greater losses of forest products occur over time after mortality, as wood deterioration increases. Within the forest health spectrum lie other MAPs (4%) which allow salvage harvest activity in alignment with those management objectives and are benefitted by the removal of snags and related hazards. These areas include Scenic Byways or Railroads, Dispersed Recreation, Deer and Elk Winter Range, Bighorn Sheep Range, and Grassland Resource Production. Within this 11% of the spruce forest, a disparity is considered to exist.

The effects of disturbance agents upon forest species composition are included in the descriptions of Forest Diversity and Resiliency, as well as the No Action alternative.

Forest Structural Diversity and Resiliency Vegetation structural stage is an important consideration in prescribing management actions to preserve watershed values and wildlife habitat (Thomas 1979). The desired condition is to have an appropriate balance of vegetation structural stages within each vegetation zone to provide for greater forest resiliency and to maintain habitat and landscape diversity over time. The resiliency of a forest landscape to stressors and disturbance agents, such as insect and disease, fire, and climate changes, is closely tied to the diversity of forest structure and species across that landscape. Disturbance agents affect varying age classes and species differently or not at all; and therefore it is beneficial to maintain a balance, checking the movement of a disturbance process across the landscape and maintaining propagules for recovery after a disturbance event. This section will focus on structural diversity, with reference to dominant and codominant species presence within the stands.

Vegetation structural stage is a method of describing forest growth stages, including successional stage (O'Hara & Latham 1996) (Stage, Crookston, Long, & Keane 1995), and provides a tool by which to measure structural diversity. The time it takes for seedlings to become established as well as subsequent tree growth rates, influence forest progression through vegetation structural/seral stages. Tree life expectancy and disturbance regimes affect how long the oldest vegetation structural stage can be maintained.

The Rocky Mountain Vegetative Structural Stage (RM-VSS) post-processor that is incorporated into the FSVeg Spatial Data Analyzer model was used for this analysis to allow for comparison between alternatives into the future. The RM-VSS was developed for use in R3 (Arizona/New Mexico) and uses different size class divisions than the R2 Habitat Structural Stage (R2 HSS) classification system used in Region 2. Table 8 shows a comparison of the size class break downs between the two systems, based on average stand diameter.

Table 8. Comparison between RM-VSS and R2 HSS classifications for forested stands

RM- Description Size class Size class R2 HSS Description Size class VSS Tree Woodland 1 1 Code species species 1 Grass/forb/shrub <1” dbh <1” dbc 1T Grass/forb Non- stocked 2 Seedling/sapling 1-4.9” dbh 1-2.9” dbc 2T Shrub/Seedling <1” dbh

59 CP District-wide Salvage Project Final Environmental Impact Statement

RM- Description Size class Size class R2 HSS Description Size class VSS Tree Woodland 1 1 Code species species 3 Young Forest 5-12” dbh 3-4.9” dbc 3 Sapling/Pole 1-9” dbh 4 Mid-aged forest 12-18” dbh 5-10.9” dbc 4 Mature 9”+ dbh 2 5 Mature forest 18-24” dbh 11+” dbc 5 Old Growth Variable 6 Old forest 24”+ dbh 1Diameter for woodland species are measured at the root collar (drc); 2Old growth is discussed separately in the Biodiversity section.

Prior to spruce beetle outbreak, the structure of the majority of stands within the project area was primarily that of mid-aged or mature forest. Since the outbreak, stands in which Engelmann spruce is the primary species in the overstory have a forest structure of young forest or less (i.e. seedling-sapling or grass- forb/shrub); only 342 acres still model as mid-aged. Residual stocking in these stands range from sparse to dense and likewise have a wide range of dead spruce basal areas, generally between 10 and 260 square feet per acre. Prior to mortality, the age of the dominant and codominant trees within the spruce-fir stands across the district varied between 130 to 250 years. The stand age and high percentage of spruce in the overstory made the majority of these stands susceptible to spruce beetle attack under drought conditions. Spruce- mixed conifer stands in which spruce is not the primary species in the overstory are modeled as ranging from seedling-sapling structure all the way to mature structure. The following table displays forest structure representation across landscape, as modeled post-beetle outbreak.

Table 9. Current forest structure across the spruce forest landscape

RM-VSS Percent of Spruce Dominant/Co-Dominant Species Composition** Code* Forest Landscape

1 19% ES, SAF 2 6% ES, SAF, AS 3SS 35% ES, SAF, AS, DF, BS, LP 3MS 17% ES, SAF, AS, BS, DF, WF, LM 4SS 17% ES, SAF, DF, WF, AS, BS 4MS 4% SAF, ES, AS, BC, DF, LM 5MS 2% SAF, AS, DF, BC * SS=single story structure, MS=two or more story structure **AS=aspen; BC=bristlecone pine; DF=Doug-fir; ES=Engelmann spruce; LM=limber pine; LP=lodgepole pine; SAF=subalpine fir; WF=white fir

Past Silvicultural Activities – Past vegetation management activities have helped shape the existing condition of the spruce forests within the project area and create age, structural, and species diversity. Past harvest activities are listed in Appendix I and include commercial thinning and improvement cuts, shelterwood preparatory cuts (including preparatory and establishment/seed cuts), overstory removal cuts, patch clearcuts, stand clearcuts, salvage cuts, and single-tree selection cuts. Shelterwood preparatory cuts (light partial cuts) make up the largest portion of the previous timber harvest activity that occurred. These treatments opened up the stands (removing about ¼ to 1/3 of the basal area) to create wind-firmness and begin natural regeneration establishment. The shelterwood cuts were essentially thinning that reduced the stand density and improved tree vigor, thus reducing the susceptibility of the residual mature trees to spruce beetle infestation. The sanitation/salvage treatments removed dead or dying trees, which may have reduced the basal area and increased tree vigor in localized areas.

Other silvicultural activities have included reforestation, site preparation for natural regeneration, pre- 60 CP District-wide Salvage Project Final Environmental Impact Statement commercial thinning, tree release and weeding, rearrangement of fuels, broadcast burning, burning of piled material, and yarding of fuels.

These past management activities did reduce the risk of spruce beetle within the managed stands themselves, but could not protect against the elements of high beetle populations and drought-related stress beyond the managed stands. The influences of past activities upon the landscape are incorporated into the existing condition baseline, and existing conditions and potential effects of proposed activities are considered for the spruce forest landscape as a whole. Direct and Indirect Effects Direct and Indirect Effects analysis will address how each alternative influences forest health and species composition, forest structural diversity and resiliency, and forest product management over time. The following measures will be used:

. Vegetation structural stage representation across the spruce forest landscape in 50 years (% of area) . Proportion of the spruce forest landscape diversified in stand structure and/or composition as a result of project activities (% of area) . Area of salvageable timber expected to lose merchantability post-mortality (acres) . Volume of commercial forest products recovered from insect mortality (Ccf)

Alternative 1 – No Action Forest Health and Species Composition As mature stands are killed by spruce beetle, two influences work together to shift species composition both now and into the future. The resulting trajectory of the structural and compositional changes, or forest reorganization, relies at least partly upon the species diversity present on the site prior to outbreak (DeRose & Long 2007). On the Conejos Peak Ranger District, species diversity is limited within the spruce-fir zone of the spruce forest landscape, being mainly restricted to Engelmann spruce and subalpine fir, with minor presence of bristlecone pine and aspen. At lower elevations, in the spruce-mixed conifer stands, there is greater presence of aspen and other conifer species, and reorganization is less noticeable. Because the disturbance event is primarily in the spruce-fir zone, which is the majority of the analysis area, measureable shift in composition is expected.

The first influence affecting reorganization is species-specific mortality, which is expected to shift current overstory composition strongly toward fir, while the predominantly fir understory (advance regeneration) is released to grow. Second, the fir seed sources are sustained for continued propagation, while the Engelmann spruce seed sources are greatly diminished. This aggregate affect is expected to favor a current and future stand composition dominated by fir, especially by subalpine fir within the spruce-fir forest type. Although exact compositional changes will vary from stand to stand, vegetation modeling indicates that the spruce-fir portion of the landscape will have a general combination of 65% fir, 34% spruce, and 1% other species, with fir dominating both the overstory and the understory. This shift in both stand structure and species composition has been observed before and could last as long as 125-175 years (Schmid & Mata, Natural Variability of Specific Forest Insect Populations and Their Associated Effects in Colorado 1996). Stands within the project area having an aspen component may experience an expansion of aspen clones, although this will likely be regulated by ungulate browsing pressure. There is uncertainty related to the exact trajectory of forest reorganization across the spruce-fir landscape. A recent study on the Rio Grande National Forest (Savage, Lawrence, & Squires, 2017) described a process by with land managers may be able to accurately map post-disturbance stand composition across the landscape using readily-available technology. Field data for the study was collected in 2015, and Landsat data from 2015 and 2014 was used in the study. Although the primary purpose of the study was to determine a useful analysis

61 CP District-wide Salvage Project Final Environmental Impact Statement process, conclusions were also drawn concerning forest composition in the spruce-fir zone of the Forest, including this project area. The study indicated that Engelmann spruce was still a dominant species within the overstory of the landscape, and likewise remained a dominant species in the sub-canopy of the same forests. When considered in application to this project, a few observations can be made about the study:

• The epidemic was (and is) still ongoing, and the study couldn’t account for trees that were just infested and/or have been infested since that time. The map on page 16 of the article shows a fairly distinct transition between those areas further advanced in the epidemic vs. more-recently infested. This mid- disturbance evaluation could affect conclusions, and might also help explain why there was still relatively high canopy cover within portions of the study area. The model used in this project takes a post-beetle look at stand data, as imputed across the landscape. This approach moves stands to the end of the disturbance time scale, more similar to the older dead stands of the study. The usefulness of the process described in the study seems greater for short duration disturbance events like fire.

• Sub-canopy data within the study doesn’t appear to be looking at regeneration, but rather intermediate and suppressed trees of the overstory. It would also include a 2nd developing cohort that has grown enough to reach the sub-canopy position, especially in the case of regenerated forest openings. In other words, a tree’s crown had to be tall enough to be part of the overstory and be measured by the canopy measurement instrument (moosehorn). It is logical that these tree would mirror the canopy, because often the intermediate and suppressed trees are of the same cohort as the dominants and co-dominants. Such trees may/may not develop and establish dominance, but are not as likely to do so, due to long- term suppression (100 years plus).

• The dominant presence of a species within the sub-canopy layer doesn’t necessarily represent demographic dominance across the entire population, because these trees are often low in number, when compared to other strata within the stand. Understanding a 30 meter x 30 meter Landsat pixel, with 6.7 trees/pixel, there are only 30 trees per acre of Engelmann spruce in the sub-canopy (on average), as presented by the study. Although these trees are less likely to die from beetle infestation, the Forest has experienced mortality down to 5” dbh fairly frequently, which relates back to the first observation.

• Natural regeneration results will vary by stand, as previously noted. On the Rio Grande National Forest, subalpine fir appears to have greater limitations related to elevation and/or moisture & site productivity, when compared with spruce. In areas that have a ‘pure’ spruce overstory, there will be a pure, or almost pure, spruce understory. As a result, reconnaissance data collected to date has noted several stands that appear to have greater presence of spruce regeneration than fir.

Understanding the uncertainties and limitations with both the model and the study, the model still appears to be the best predictor of the landscape as a whole, based on the above considerations as well as general observations in the field.

Various effects on western spruce budworm and Armillaria root disease occurrence could result from these predicted shifts in species composition. In the short-term, the loss of overstory spruce through mortality would increase dispersal distance of budworm from remaining overstory fir trees, thereby reducing insect survival. This reduction in pest survival, however, is expected to be less noticeable than in the action alternatives, due to snags within the stand limiting the dispersal distance by varying degrees. The overstory mortality would also release the suppressed understory, making the advance regeneration and mid-story more resilient to budworm. In the long-term, future occurrence of budworm could actually be increased in the fir- dominated stands (a preferred food source). Subalpine fir is also less resistant to Armillaria root disease than Engelmann spruce, which could potentially increase the future occurrence of Armillaria root disease within the project area. Windthrow risk would be slightly increased for residual overstory trees in each stand due to the reduction in wind protection resulting from tree mortality.

62 CP District-wide Salvage Project Final Environmental Impact Statement As indicated by Table 10, species presence in the overstory is expected to remain diverse over the next 50 years; this, however is not a measure of species predominance.

Forest Structural Diversity and Resiliency As the mature stands are killed by spruce beetle, their structure and appearance will also change dramatically. The stands will become more open, with limited overstory canopy closure for the next 30 years. Total average post-outbreak canopy closure is expected to drop to about 40% before increasing again, with the majority of canopy being represented by the lowest pre-beetle stand stratum, as indicated by an average stand diameter of 3.9” dbh. Snags will continue to increase, giving the landscape a grey tone. The forest canopy would close in over the next 30-50 years, and an overstory would be re-established within the next 100 years.

Table 10 shows the distribution of vegetative structural stages anticipated across the landscape after 50 years, as well as dominant and codominant species presence within the stands. This distribution indicates a greater presence of stands in the young forest stage (45%), with a shortage of stands in the mature and old-growth stage (14%). This prediction agrees with the outcome anticipated as a result of the large-scale disturbance experienced. Resiliency, as affected by age class distribution, would be moderate within the next 50 years. A long-term trend toward a repeated future widespread disturbance event is expected, however, as the demographics move into mature and old-growth structural stages. Table 10. Modeled forest structure across the spruce forest landscape in 2066, No Action Alternative

Percent of Spruce RM-VSS Code* Dominant/Co-Dominant Species Composition** Forest Landscape

1 2% SAF, ES 2 13% ES, SAF, AS 3SS 28% SAF, ES, BC, AS, DF, WF, LP 3MS 17% ES, SAF, AS, DF, WF, LM 4SS 12% SAF, ES, AS, BS, DF, LM, WF, LP 4MS 14% SAF, ES, AS, BS, DF, WF, LM 5SS 7% AS, BS, CB, DF, LM 5MS 5% SAF, ES, AS, BC, BS, DF, WF, LM 6SS <0.03% AS 6MS 2% BC, CB, AS, DF, ES, *SS=single story structure, MS=two or more story structure **AS=aspen; BC=bristlecone pine; DF=Doug-fir; ES=Engelmann spruce; LM=limber pine; LP=lodgepole pine; SAF=subalpine fir; WF=white fir

The majority of snags are expected to fall within the next 50 years, producing large fuel loads (coarse woody debris). Moderate levels of coarse woody debris are desirable for soil development and regeneration establishment (shading), but excessive amounts of debris can diminish natural regeneration establishment (rooting) and increase burn severity, should a fire occur. For stands within salvage MAPs, the substantial increase in deadfall within the future stand condition is outside of desirable forest health conditions. Additional discussion of coarse woody debris can be found in the Fire/Fuels and Biodiversity sections of the EIS. Forest Plan desired conditions for some MAPs would not be addressed under this alternative, and 0% of the landscape would be diversified in structure and/or composition as a result of harvest, planting, and fuels treatment activities. Hazardous fuels treatments would not occur adjacent to private land or other infrastructure. These areas would retain denser understory vegetation and higher fuel loadings, except where influenced by public firewood gathering.

Forest Products In stands where timber production is the objective, stands dominated by subalpine fir rather than Engelmann 63 CP District-wide Salvage Project Final Environmental Impact Statement spruce are less desirable for the following reasons: 1) fir has a shorter life span than spruce, 2) fir is more susceptible to more insect and disease attacks than spruce, 3) the structural characteristics of the wood fiber are inferior to spruce, and 4) it has less economic value than spruce. The No Action alternative is expected to increase the long-term presence of fir within forest product management areas over the next 100 years.

By not salvaging the dead spruce, up to 17,000 acres of salvageable timber would not be available for harvest and would lose merchantability post-mortality. As a result, approximately 340,337 Ccf of National Forest timber would not be available for utilization as wood products or contribute to sustained yield of forest products. The public would most likely obtain an equivalent amount of wood products from other sources, including private land, state land, other National Forest projects, or other countries. Local and regional forest products industry, however, would be notably affected by loss of this volume from the marketplace. The Rio Grande National Forest comprises approximately 64% of all forestland around the valley, and this project would provide approximately 28% of the total Rio Grande National Forest sale offer over the next five years. Alternative 2 – Proposed Action Alternative 2 represents the proposed action and focuses on maximizing the salvage of dead spruce. It includes harvest on up to 17,000 acres across the project area, with additional hazardous fuels treatments on up to 1,000 acres adjacent to private property and administrative sites. In areas where there is overlap between the two activities, salvage harvest would be utilized to accomplish hazardous fuels reduction objectives. Approximately 330 acres would be treated in this manner under Alternative 2. Salvage includes the removal of dead or infested trees that have been impacted by spruce beetles. Planting of native conifer species is also proposed in areas that are inadequately stocked or in order to diversify species composition. Chapter 2 of the EIS further describes this alternative; see also the Silviculture and Hazardous Fuels Guidelines in Appendix E for additional information.

Forest Health and Species Composition As described in Alternative 1, species composition would shift in the portions of the landscape where harvest does not occur. Where harvest does occur, activity disturbance would promote seral species such as aspen and spruce, especially in areas where planting efforts focus on the retention of spruce in the species mix. Windthrow risk to residual overstory and mid-story trees would be increased by the removal of the snag wind protection, particularly on southwesterly exposures. This risk has been partially mitigated by past management activities but is still anticipated. Trees most susceptible to windthrow are the residual live overstory, which have greater wind resistance than snags. The potential loss of these trees to windfall would be assessed on a project- by-project basis and mitigated to the extent feasible through boundary layout and marking. It would not, however, affect management objectives or future management activities within the project area. Although undesirable, this event would create good microsites for natural and artificial regeneration establishment and would not contribute toward any insect or disease outbreaks.

Under Alternative 2, artificial regeneration by planting Engelmann spruce or other native conifer species is anticipated on approximately 860 acres. Other native species may be selected for ecotones between spruce- fir forest and spruce-mixed conifer forests, in response to climate change concerns. Seed would come from local seed sources, avoiding off-site assisted migration. Actual planting acres would be determined through post- treatment evaluations and be based upon desired species composition, distribution, and stocking levels, in an effort to maintain landscape diversity in composition, structure, and function. Desired stocking levels would likely be higher than, but would not be less than, the Forest Plan restocking standards of 150 trees per acre, unless outside of suitable timber base and meeting specific objectives and prescriptions. See the Silvicultural Findings report for additional information concerning stocking levels.

Stands within harvest areas having an aspen component are anticipated to experience an increase and expansion in aspen sprouting as a result of the harvest-related disturbance. This diversity of species composition is considered beneficial when related to forest health. Unharvested areas may also experience an expansion of aspen clones, but to a lesser degree as described for Alternative 1. 64 CP District-wide Salvage Project Final Environmental Impact Statement The loss of overstory spruce through mortality and removal of snags would increase dispersal distance of western spruce budworm from remaining overstory fir trees, thereby reducing insect survival. This reduction in insect survival is expected to be greater within harvest areas than outside of them, as snags within the stand limit the dispersal distance by varying degrees and reduce predation. The loss of overstory would also release the suppressed understory, making the advance regeneration and mid-story more resilient to budworm impact.

Engelmann spruce is susceptible to Armillaria root disease, but this disease usually does not affect Engelmann spruce until it reaches later seral stages. Engelmann spruce shows greater resistance to Armillaria root disease than subalpine fir, which would otherwise be regenerated on most of these sites. Any increase in Armillaria root disease following salvage harvesting would not be the result of removing beetle infested or beetle killed trees. Root systems of beetle-killed trees would not be affected in their suitability as a food base by removal of the stem. PDC for protecting existing regeneration and establishing new regeneration (EIS, Chapter 2) will be applied to all action alternatives.

Hazardous fuels treatment activities proposed under Alternatives 2 and 3 would focus on thinning or pruning understory trees (<8” dbh) and shrubs, as needed, to modify potential fire behavior, as well as removal of snags that threaten infrastructure. The effects of this action on spruce beetle will be insignificant as the spruce beetles preferred food source is a tree greater than 8 inch dbh, although some trees as small as 4” to 5” inches are being infested and killed by spruce beetle within the project area. Removing some of the dense smaller trees, especially fir, will help reduce western spruce budworm host trees, thereby making these treated areas less susceptible to the insect.

As indicated by Table 11, species presence in the overstory is expected to remain diverse over the next 50 years, similar to Alternative 1.

Forest Structural Diversity and Resiliency Because of the scale of the bark beetle epidemic and resulting mortality, salvage harvesting within each affected unit would generally be extensive and the resulting stand structure would appear open as a result of removing snags. A minimal average of 4 snags per acre would be retained for wildlife habitat, as well as aspen, un-infested spruce, and all other conifer species. The forest structure would close in over the next 30- 50 years, and an overstory would be re-developed within the next 100 years.

Part of the design for Alternative 2 is to set aside areas for public firewood gathering, wherein no commercial harvest would occur. Impacts upon forest vegetation and recovery are expected to be greatest within these areas, due to increased access needs and uncontrolled felling operations. These activities and effects, however, would be identical to the firewood gathering performed under Alternative 1, except that vehicles could be allowed further off the road within designated areas. Activities would remain within the scope of the management objectives for the affected units, and these areas would still be re-established with forest vegetation over time.

Table 11 shows the distribution of vegetative structural stages anticipated across the landscape after 50 years under Alternative 2. Like Alternative 1, this distribution indicates a greater presence of stands in the young forest stage (45%), with a shortage of stands in the mature and old-growth stage (14%). At the landscape level, the only distinction between Alternatives 1 and 2 is Alternative 2 has 1% less representation in VSS 2, and 1% greater representation in VSS 4. Therefore, the same interpretations concerning resiliency and future disturbance in Alternative 1 would also apply to Alternative 2. The primary reason for the close relationship in outcome is the broad and severe disturbance event that has just occurred. Stands across the landscape, primarily the spruce-fir forests, were already moved toward early structural stages due to mortality caused by the spruce beetle. Removal of dead trees at this time does not affect structural stage nearly to the degree that similar volume removal would under green forest conditions. Had these stands been previously undisturbed, an approximate 12% shift in stand structure across the landscape would have occurred.

65 CP District-wide Salvage Project Final Environmental Impact Statement

Table 11. Modeled forest structure across the spruce forest landscape in 2066, Alternative 2

Percent of Spruce RM-VSS Code* Dominant/Co-Dominant Species Composition** Forest Landscape

1 2% ES, SAF 2 12% ES, SAF, AS 3SS 28% LP, ES, DF, SAF, AS, WF, BS, BC 3MS 17% SAF, LM, DF, AS, WF, BS, ES 4SS 13% LP, ES, SAF, WF, DF, AS, LM, BS 4MS 14% ES, SAF, DF, LM, AS, WF, BS 5SS 7% DF, WF, AS, SAF, BC, ES 5MS 5% DF, BC, LM, AS, ES, WF, BS, SAF 6SS <0.04% AS, BS, ES 6MS 2% AS, ES, DF, SAF, BC *SS=single story structure, MS=two or more story structure **AS=aspen; BC=bristlecone pine; DF=Doug-fir; ES=Engelmann spruce; LM=limber pine; LP=lodgepole pine; SAF=subalpine fir; WF=white fir

Future fuel loads and deadfall (coarse woody debris) resulting from snag fall would be greatly reduced within harvest areas, but logging debris would still be evident within the stand. Additional discussion of coarse woody debris can be found in the Fire/Fuels and Biodiversity sections of the EIS. Forest Plan desired conditions for identified MAPs would be addressed under this alternative. Although only minor changes to vegetative structural stages across the landscape would be observed, up to 12% of the landscape would still be diversified in species composition and coarse woody debris retention under Alternative 2 through harvest, planting, and fuels treatment activities.

Forest Products The intent of the salvage harvest is to place timber on the market for the American public in time to capture the value of the beetle-killed spruce trees, before the effects of wood decay eliminates that value. Observations made during ongoing salvage sales indicate that local dead Engelmann spruce loses most of its sawlog value within 5 years of mortality, and nearly all sawlog merchantability within 10 years. A recent wood deterioration study on the Rio Grande National Forest supports that conclusion, showing wood defect to rise to over 30% within a five-year period and over 40% within a ten-year period (Webb 2015). The objective of the silvicultural prescription would be to harvest spruce trees eight inches Diameter at Breast Height (DBH) and larger within the salvage units, which were recently killed by, or are currently infested with, spruce beetle. Harvesting would be accomplished with ground-based (tractor) logging methods through a variety of large and/or small sales, including public/commercial firewood-gathering areas.

Under Alternative 2, up to 340,337 Ccf would be available for harvest from 17,000 acres. Between all alternatives, this alternative would contribute the most to long term sustained yield of forest products. Zero acres of salvageable timber would be unavailable for harvest or lose merchantability post-mortality. Likewise, 0 Ccf of National Forest timber would be unavailable for utilization as wood products or contribute to sustained yield of forest products. The estimation of timber volume that would be removed is derived from three sources: 1) stand exam data stored in FSVeg Spatial, 2) stand exam data imputed across the landscape and projected to 2017 using FSVeg Spatial Data Analyzer (Central Rockies Variant), and 3) calibrations made within Data Analyzer for volume and mortality. All of these sources are subject to error. Therefore, these volumes must be considered a best estimate and subject to change. More precise data would come when the timber is actually cruised during the sale preparation process.

66 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 3 – Vegetation Management – Limited Action This alternative provides the opportunity to salvage dead and dying spruce on up to 8,500acres across the project area, with additional hazardous fuels treatments on up to 1,000 acres adjacent to private property and administrative sites. In areas where there is overlap between the two activities, salvage harvest would be utilized to accomplish hazardous fuels reduction objectives. Approximately 129 acres would be treated in this manner under Alternative 3. Planting of native conifer species is also proposed in areas that are inadequately stocked or in order to diversify species composition. Chapter 2 of the EIS further describes this alternative; see also the Silviculture and Hazardous Fuels Guidelines for additional information.

Forest Health and Species Composition The effects of salvage harvesting would be the same as those described in Alternative 2, but would affect approximately one-half the acres, or 6% of the spruce forest landscape.

Under Alternative 3, artificial regeneration by planting native conifer species is planned for 420 acres of non- stocked or under-stocked areas, based on existing stand data and modeling. Actual planting acres would be determined through post-treatment evaluations based upon desired species composition, distribution, and stocking levels, in an effort to maintain landscape diversity in composition, structure, and function. Desired stocking levels would be established within treatment areas as described in alternative 2. The interaction between management activities and Armillaria root disease, budworm, windthrow, and deadfall would be the same as those described under Alternative 2, but over a smaller area. Outside of harvest areas and across the broader spruce forest landscape, forest health elements would function as described in Alternative 1.

Both hazard tree removal and fuels reduction treatments would be the same as described in Alternative 2, with the same number of acres considered for treatment.

Like Alternatives 1 and 2, species presence in the overstory is expected to remain diverse over the next 50 years.

Forest Structural Diversity and Resiliency Although fewer acres are being treated within this alternative, the effects of salvage harvest upon individual stands would be the same as described under Alternative 2.

Table 12 shows the distribution of vegetative structural stages anticipated across the landscape after 50 years under Alternative 3. Like Alternative 1, this distribution indicates a greater presence of stands in the young forest stage (45%), with a shortage of stands in the mature and old-growth stage (14%). At the landscape level, no real distinction is discernable between Alternative 1 and Alternative 3. Therefore, the same interpretations concerning resiliency and future disturbance in Alternative 1 would also apply to Alternative 3. See Alternative 2 for further discussion concerning how closely the outcomes are related. Had these stands been previously undisturbed, an approximately 6% shift in stand structure across the landscape would have occurred.

Table 12. Modeled forest structure across the spruce forest landscape in 2066, Alternative 3

Percent of Spruce RM-VSS Code* Dominant/Co-Dominant Species Composition** Forest Landscape

1 2% ES, SAF 2 13% ES, SAF, AS 3SS 28% LP, ES, DF, SAF, AS, WF, BC, BS 3MS 17% LM, SAF, ES, DF, WF, LM, AS 4SS 13% LP, ES, SAF, DF, WF, AS, LM, BS

67 CP District-wide Salvage Project Final Environmental Impact Statement

4MS 13% ES, SAF, DF, LM, AS, WF, BS 5SS 7% DF, WF, LM, AS, SAF, BS, 5MS 5% DF, LM, BC, AS, SAF, ES, WF, BS 6SS <0.04% AS, BS, ES 6MS 2% AS, ES, DF, SAF, BC *SS=single story structure, MS=two or more story structure **AS=aspen; BC=bristlecone pine; DF=Doug-fir; ES=Engelmann spruce; LM=limber pine; LP=lodgepole pine; SAF=subalpine fir; WF=white fir

Forest Plan desired conditions for identified MAPs would be addressed under this alternative, but not to the extent of Alternative 2. Logging slash left in the woods would be used to benefit young seedlings by protecting them from excessive sunlight, extremes of temperature, desiccation, and grazing animals (Smith, Larson, Kelty, & Ashton 1997), but would not create the large amounts of coarse woody debris equivalent to Alternate 1. Although only minor changes to vegetative structural stages across the landscape would be observed, up to 6% of the landscape would still be diversified in species composition and coarse woody debris retention under Alternative 3 through harvest, planting, and fuels treatment activities.

Forest Products Under Alternative 3, up to 189,906 CCF would be available for harvest from approximately 8,500 acres. This alternative would contribute to long term sustained yield of forest products, but not as much as Alternative 2. Approximately 8,500 acres of salvageable timber would not be available for harvest and would lose merchantability post-mortality. Likewise 150,431 Ccf of National Forest timber would not be available for utilization as wood products or contribute to sustained yield of forest products. Due to model error, volumes must be considered a best estimate and subject to change. More precise data would come when the timber is actually cruised during the sale preparation process.

Alternative 2 & 3 – Five-year Stocking Assurance The five-year stocking assurance requirement established by the National Forest Management Act of 1976 applies to all regeneration harvest treatments, but not to intermediate stand treatments such as thinning or intermediate sanitation/salvage. In relation to salvage harvesting, Forest Service Manual 2470 directs that “if salvage or sanitation cutting is heavy enough to require regeneration, it is considered a regeneration harvest rather than intermediate cutting, and steps should be taken to adequately restock the stand within five years of final harvest” (Forest Service Washington Office 2014). General guidance for extensive beetle mortality is to assign a final harvest system that would best represent the final stand conditions, taking into account previous management activities. To meet these directions, a Silvicultural Findings of Compliance document was created for the project, describing: 1) which silvicultural systems would be proposed to meet both the stand objective of salvage as well as guidance for addressing extensive beetle mortality and 2) whether or not the 5-year stocking assurance would apply.

All forest lands within the National Forest System are to be maintained in appropriate cover to achieve desired time and stocking level goals in a cost-efficient manner (Forest Service Washington Office, 2014). As a result, stocking standards were set forth in the Forest Plan as a minimum of 150 trees per acre for spruce-fir and mixed conifer stands and 300 trees per acre for aspen. A timber suitability analysis was also conducted within the FEIS of the Forest Plan (p. III-160 to III-165) to determine which lands were suitable for timber production. Part of that analysis considered whether or not irreversible damage was likely to occur to soils and watersheds and whether adequate information was available to insure that areas could be restocked within 5 years.

In most treatment areas, adequate existing regeneration already exists as a result of previous management

68 CP District-wide Salvage Project Final Environmental Impact Statement activities. The requirement to conduct first, third, and (if necessary) fifth year stocking surveys will be accomplished on all required units to assess and document progression toward certification as fully stocked. Areas not on trajectory to be fully stocked within 5 years (i.e. where existing regeneration is lacking or damaged due to logging activities) are planned for planting with Engelmann spruce or other native conifer seedlings. Sowing requests would be made after the first year stocking survey and planting would occur prior to the third year stocking survey. If additional fill-in planting were needed to meet the Forest Plan standards, it would be accomplished prior to the fifth year survey. Adequate seed inventory is currently available to meet all projected planting needs across the district’s spruce zone.

Research, along with experience on the Forest, shows that the technology and knowledge exists to restock these stands within five years after final regeneration harvest. Publications acknowledge that natural regeneration is generally a slow process. However, advance regeneration is already present in many places, and artificial regeneration is effective in the Central Rockies when applied correctly (Shepperd, Jeffers, & Ronco, 1981). Local experience also indicates that project design is adequate and planting is effective in assuring restocking within the spruce zone of the Rio Grande National Forest. This is demonstrated by very local research (Jeffers, Engelmann Spruce Super-Seedling Plantations, Rio Grande National Forest: Thirteenth Growing Season Survival and Height Growth 1995) as well as successful plantation establishment in the Grouse Creek, Twister, and Blowout Mountain areas. Existing advance regeneration within the stands themselves also indicates that the site is conducive to seedling establishment. Old records indicate, however, that restocking of some 1960’s clearcuts in the Elwood Pass area was difficult. Reconnaissance and file research indicates that heavy sheep grazing and lack of coarse wood debris were limiting factors which heavily influenced restocking success. Those factors are not an issue today under current management practices; however, project-level assessments will occur prior to harvest on a stand-by-stand basis to ensure that adequate advance regeneration is present or restocking objectives can otherwise be accomplished. Cumulative Effects The cumulative effects analysis includes all of the spruce forest landscape on public and private lands within and adjacent to the project area. The analysis considers spruce beetle infestations that have been observed in this area during the last 15 years and the potential for continued outbreaks over the next 5 years. The probability for ongoing spruce beetle outbreaks in this area is high, due to current spruce beetle populations, stand conditions, and observed ongoing patterns of tree mortality. It is expected to continue until the majority of mature Engelmann spruce trees on the landscape are dead.

The CP District-wide Salvage project area is bounded on the north by the Divide Ranger District, on the east by Bureau of Land Management, state, and private lands, on the south by the Carson National Forest in New Mexico, and on the west by rugged private property lands and the San Juan National Forest’s portion of the South San Juan Wilderness area. Backcountry and wilderness areas both within and adjacent to the project area would remain untreated and natural processes would continue in these areas without human intervention, while some degree of salvage activity would be expected on private lands.

Ongoing efforts to salvage spruce beetle mortality within the project area include sales and planting activities under the County Line Vegetation Management Project, the Rio de los Pinos Vegetation Management Project, the Cumbres Vegetation Management Project, the Burro Unit 15 Vegetation Management Project, and various small sales. Some hazardous fuels treatments are also occurring next to private property under the Cumbres Vegetation Management Project. All of these activities are captured in the baseline for the CP District-wide Salvage Project and would contribute toward removing spruce beetle from the forest, but the sum total of these efforts would have very little impact on beetle populations. These sales may temper beetle-caused mortality on a localized (stand) level and allow some portions of the older age class spruce to survive the current wave of mortality, but this result is unlikely.

Other foreseeable future activities within the project area include the Fox Creek Vegetation Management Project, which proposes to thin, salvage, and broadcast burn within dry mixed-conifer stands, as well as

69 CP District-wide Salvage Project Final Environmental Impact Statement regenerate aspen stands within the same ecosystem. This project would not affect the spruce forest landscape. Another proposal would be the Trail Gulch project, which is in early planning stages and proposes similar treatments to the Fox Creek project. It would primarily affect the dry mixed-conifer stands of the Osier Mountain area, but would also seek to perform pre-commercial thinning of older spruce plantations on Osier Mountain and begin the process of converting non-native lodgepole pine plantations back to spruce-fir. These plantations were established in the 1960’s, 70’s, and 80’s to reforest the 1879 Osier burn area, and stand- tending activities are needed.

Past silvicultural activities adjacent to the project on the north have been included in the environmental baseline. These include the Burro-Blowout Vegetation Management Project and the Burro Unit 15 Vegetation Management Project. Foreseeable future projects in the spruce forest landscape to the north could include approximately 1200 acres of salvage in the Race Creek drainage, approximately 3-4 miles north of the project area. Other salvage activities would be further away from the CP District-wide Salvage Project, being west of the Del Norte Peak/Hogback Mesa area.

Adjacent foreseeable projects to the south and east include ongoing salvage logging on private property near the southwest corner of the project area. Rancho del Oso Pardo and inholdings are currently salvaging approximately 80 acres of dead spruce per year from their property, and this activity is expected to continue over the next five years. The same private landowners are also performing aspen regeneration cuts at lower elevations on approximately 5-50 acres per year; this activity is expected to continue throughout the life of the CP District-wide Salvage Project. The Colorado State Forest Service is conducting a 50 acre spruce salvage harvest on Osier Mountain, and anticipates performing 140 acres of aspen regeneration cuts, 50 acres of spruce salvage, and 20 acres of ponderosa pine restoration near La Jara Reservoir, over the next 10 year period. The Carson National Forest is tentatively considering 250 acres of spruce salvage harvest adjacent to the southwest corner of the project area.

Forest Health and Species Composition When considering the current major disturbance agent on the spruce forest landscape (the spruce beetle), one underlying cause of widespread mortality is the relatively homogeneous stand structure found throughout project area and surrounding lands. A primary goal of forest management is to increase stand heterogeneity so that large-scale outbreaks are not prevalent in the future forests. The effects of management activity must be viewed in two lights: the effect of salvage on current forest condition, as well as the potential impact upon future forest condition. When combined with other known activities in the spruce forest landscape, neither action alternative is expected to affect any of the current forest condition with either a positive or negative net change. Forest health issues will continue until checked by beetle habitat loss, and resulting species composition will remain the same. The combined actions are, however, expected to improve forest conditions in the future by increasing heterogeneity in species composition within the landscape. This influence would also include the structural element of coarse woody debris but not age class diversity. There are no known efforts on either public or private lands to introduce new tree species into the landscape.

Forest Structural Diversity and Resiliency Because of the close relationship and timing between ongoing disturbance process and the project, no notable impacts to vegetative structural stages across the landscape would be expected as a result of the combined activities. However, in addition to species composition mix, coarse woody debris distribution and loading within the treated areas (both salvage and hazardous fuels) is expected to be improved in the future stand condition. As a result, improved landscape resiliency to insect and plant pathogens and changes in climate pattern is expected. Alternative 2 is expected to have the greatest influence on the spruce forest landscape heterogeneity (up to 12% of the landscape affected) and most effectively address the disparity between existing conditions and Forest unit management objectives. Alternative 1 would have the least influence on heterogeneity and would not address the disparity between existing conditions and management objectives, while Alternative 3 is expected to affect up to 6% of the landscape. None of the combined actions are expected 70 CP District-wide Salvage Project Final Environmental Impact Statement to result in impacts to the general presence and persistence of forest vegetation across the landscape.

Forest Products Two aspects must be considered when evaluating the effects of management activities: the effect of salvage on current forest management goals, as well as the potential impact upon future forest goals. Both action alternatives would contribute toward providing a sustainable supply of forest product to timber industry in the present, as well as into the future. When added to other past, present and future sales, the proposed harvest activities would not affect annual Forest Plan Allowable Sale Quantity (ASQ) for softwoods. Per the National Forest Management Act (NFMA), salvage harvest does not have to count against the Forest ASQ. It can either be considered substitute volume or it can exceed the Plan volume. It is anticipated that salvage volume from this project would be substituted for ASQ volume, as consistent with similar salvage projects over the past 12 years.

When combined with other actions on the spruce forest landscape, Alternative 2 is expected to provide the greatest contribution of forest resources. No activities associated with either alternative would affect the quantity nor type of forest product offered from other state, federal, or private lands. As assessed in the direct and indirect effects, forest products not salvaged under this project would be acquired by the public from other sources or Forest Service projects. Removing these areas from harvest consideration (Alternative 1) would greatly limit the district’s ability to provide forest products into the next 10 years, as the majority of our timber base is within the spruce forest landscape. Unless specific salvage areas were reconsidered under new analysis, Conejos Peak would only be able to offer approximately 5,250 CCF of forest products through firewood permits and the Fox Creek project over the next two years, until new NEPA analysis could be completed for the Trail Gulch project area.

3.3 Biodiversity Scope of Analysis The scope of the analysis for biological diversity is the federally managed, upland forested stands in the Conejos Peak District-wide Salvage Project Area focusing on snags, coarse woody debris, old growth, and aspen as a biodiversity species. More emphasis is place on the Engelmann spruce/subalpine fir (spruce/fir) forest type that would be effected by proposed activities. Other proposed activities such as road maintenance or reconstruction that would have minimal impact on biodiversity are addressed in other sections. Effects on forest biodiversity are considered for the no action alternative and action alternatives.

Desired Conditions Forest-wide desired conditions (FP pg. 1-1) state: habitat composition (including seral stage), structure, pattern (including connection), and disturbance frequencies similar to those that result from natural disturbances (insects, diseases, and fire) are maintained to the extent possible, given legal and policy limitations, and the desired condition for the area.

Resource Indicators and Measures Resource indicators were used to measure change from existing conditions for each of the alternatives. For biodiversity, the indicators used in this analysis follow those described in the Forest Plan Standards and Guidelines (Forest Plan as amended 1996, III-12 to III-14), to the extent permitted by available data.

71 CP District-wide Salvage Project Final Environmental Impact Statement

Table 13. Forest Plan standards and guidelines used as resource indicators and measures for biodiversity

Resource Element Resource Measure and Desired Conditions Forest Indicator(s) Plan Snags Snags/acre Spruce-fir – 2/acre greater than 12 inches Standard diameter Lodgepole pine – 2/acre greater than 10 inches diameter Aspen – 2/acre greater than 12 inches diameter Douglas-fir/mixed conifer – 2/acre greater than 12 inches diameter Ponderosa pine – 3/acre greater than 14 inches diameter Coarse Woody Debris Tons/acre by Spruce-fir – 10 to 15 tons/acre Standard (CWD) greater than 3 inches diameter class Lodgepole pine – 5 to 10 tons/acre diameter Aspen –3 to 5 tons/acre Douglas-fir/mixed conifer – 5 to 10 tons/acre Ponderosa pine – 4 to 9 tons/acre Old Growth Inventory/ Number of Number of live trees/acre greater than 16 inches Standard/ Retention large diameter diameter for ponderosa pine, Douglas-fir, and Guideline trees/acre by Engelmann spruce; 14 inches for lodgepole pine forest type and aspen Aspen Maintenance on the Acres Acres dominated by aspen in the analysis area Guideline Landscape

Methodology, information sources, and analysis process Biodiversity in forested stands for the project area landscape were evaluated using FSVeg field sampled data and outputs from the FSVeg Spatial Data Analyzer. See the Silviculture Report for additional description of this data and the model. For this analysis, the FSVeg Data Analyzer (DA) calculated Forest Type designations were used to describe biodiversity resources and evaluate changes from 2017 (existing conditions) through 2066 for the action alternatives and no action. Acres of the calculated Forest Type for 2016 (pre-spruce beetle) were compared to the acres of each Local Type used in the Forest corporate data layer with the following results: • Non-forest acres – 1.7 percent less than combined Local types; • Pinyon-juniper – DA did not classify this type, likely due to lack of field sampled data and few acres in the analysis area (410 Local type acres); this forest type is not included in this analysis; • Ponderosa pine – 12.5 percent less than the Local type; • Douglas-fir/mixed conifer (combined with white fir & blue spruce to reflect Local Type classification) – 3.9 percent more than Local type; • Lodgepole pine – 6.5 percent less than Local type; • Limber and bristlecone pines (combined to reflect Local Type classification) – 49.5 percent less than Local type (1,430 Local type acres); difference in acres likely due to lack of field sampled data in this Local type as well as the small number of acres; • Spruce/fir (combined Engelmann Spruce, Engelmann Spruce/Subalpine Fir, and Spruce/subalpine fir Forest Types to reflect Local type) – 9.3 percent more acres than Local type; • Aspen – 18.8 percent less than Local types; • Non-stocked Forest Type – 448.3 acres – not reflected in Local type. Since this analysis is focused primarily on the spruce/fir forest type, the greater than 90 percent consistency 72 CP District-wide Salvage Project Final Environmental Impact Statement with the local type acres was considered adequate to assess and describe the effects of the alternatives. Existing Conditions Snags Due to the recent high levels of insect and disease activity across the analysis area, larger diameter snags (10 to 12+ inches diameter at breast height (dbh)) are relatively abundant in most upland forested vegetation types. Based on the data used for this analysis, snags12+ inches dbh range from 0 to over 293 per acre with a landscape average of about 26 per forested acre. As shown in the Table 14 below, on average the most snags per acre are found in the spruce beetle affected Engelmann spruce/subalpine fir (spruce/fir) forest type. Firewood cutting is reducing the number of snags in the vicinity of open roads in areas with gentle slopes, but snags are generally common across the landscape and in most major forest types.

Table 14. Average and maximum numbers of snags per acre by forest type in 2017

Forest type average snags/acre average snags/acre range of snags/acre 10+ inches 12+ inches 12+ inches Ponderosa pine 1.5 0.7 0 to 2.6 Douglas-fir/mixed conifer 7.3 4.6 0 to 43.5 Lodgepole pine 0.5 0.2 0 to 6.5 Bristlecone/limber pine 55.4 6.0 0 to 120 Aspen 38.1 25.2 0 to 144.5 Spruce/fir 104.8 77.3 0 to 293.1 Averages – all forest types 36.5 26.3 -----

Coarse Woody Debris (CWD) Very little field sampled data has been collected on current levels of CWD (surface woody material greater than 3 inches diameter) across the landscape. Based on limited observations, conditions are variable across the analysis area for a variety of reasons. For stands close to open roads, cutting dead trees for firewood limits the accumulation of larger CWD. Away from open roads conditions, are more variable depending on the age, trees per acre, and disturbance history of the stand. Coarse woody debris can be increased or decreased over time by wind, fires, insects, diseases, thinning, or timber harvest. To compare alternatives for this analysis, fuel loading by diameter class data generated by the Fire and Fuels Extension model to the Forest Vegetation Simulator (FFE-FVS) was used. The fuels sub-model dynamically tracks changes in aboveground woody biomass resulting from litter fall, tree breakage, snag fall, and timber harvest with initial fuel levels based on forest type, canopy cover, and other variables. These values are updated at each modeled cycle to account for activities and decay rates (USDA Forest Service 2015). As shown in Table 15, most forest types likely meet the minimum tons per acre set in the Forest Plan Standards, though the size diversity of down material may be limited in some areas, especially the larger diameter down woody pieces that are most valuable for wildlife and as microsites for vegetation establishment.

Table 15. Average and total tons per acre of coarse woody debris by diameter class and forest type, 2017

Forest type Average fuel Average fuel Average fuel Total Desired loading/tons per loading/tons per loading/tons per tons/acre tons/acre acre 3 to 6 inches acre 6 to 12 inches acre 12+ inches Ponderosa pine 1.51 1.50 0.38 3.39 4 to 9 Douglas-fir/mixed 6.54 7.11 0.44 14.09 5 to 10 conifer Lodgepole pine 5.99 6.82 0 12.81 5 to 10 Bristlecone/limber 7.53 8.46 0.1 16.09 NA pine Aspen 9.62 8.51 0.32 18.45 3 to 5

73 CP District-wide Salvage Project Final Environmental Impact Statement

Forest type Average fuel Average fuel Average fuel Total Desired loading/tons per loading/tons per loading/tons per tons/acre tons/acre acre 3 to 6 inches acre 6 to 12 inches acre 12+ inches spruce/fir 9.02 9.57 0.62 19.21 10 to 15

Old Growth Old-growth or old-forest stands are unique ecosystems that occur in the later stages of stand development. As stands approach the old-forest stage, they develop a diversity of functions and interactions that do not exist in earlier stages. The Forest Plan references a paper by Mehl Mehl (1992) as a basis for evaluating the old growth stand characteristics for major forest types in Region 2. This paper identified a variety of stand structural characteristics, tree ages, and other attributes that would indicate a stand is providing old growth/late successional habitat values for the forest type. Many of the desired characteristics or indicators for old growth stands such as tree age, decadence, and crown or bark characteristics need to be evaluated with field surveys. For this analysis, the potential for old growth forests was based on the average number of larger diameter (16 inches dbh for all forest types, except 14 inches aspen and lodgepole pine) trees likely present, based on the available data. There were no characteristics identified in the Mehl publication for bristlecone or limber pine, so these forest types are not included in this section. The number of larger, older trees have been reduced in several forest types by some of the past forest management prescriptions (clearcuts, shelterwood preparation cuts primarily in spruce/fir forest type), large wildfires in the late 1800s (Douglas-fir/mixed conifer; spruce-fir), and most recently the widespread spruce beetle outbreak, and increases in other bark beetle activity levels following the regional drought in the early 2000s. As indicated in the Table 16, considering the average number of large trees per acre across the landscape in context of the Mehl old growth criteria, there are likely ponderosa pine, Douglas-fir, and aspen stands that may have the potential to be evaluated for old growth characteristics, including the presence of old trees, decadence, and other features. Lodgepole pine is not native to this analysis area. It was planted following various wildfires and may not reach the age or develop the other attributes needed for old growth evaluation. Since mature Engelmann spruce has been greatly impacted by the spruce beetle outbreak, it is unlikely that any Engelmann spruce dominated stands would retain old growth potential, though transition stands with substantial mixes of other focus species may have some potential.

Table 16. Average numbers and ranges in values of large trees per acre by major forest species, 2017

Forest type average trees per range of large trees Desired number major species acre greater than 16 per acre large trees per acre inches dbh Ponderosa pine 17.9 1.1 to 38.6 10 Douglas-fir/mixed conifer 22.6 0 to 73.0 10 Lodgepole pine (14 inches) 0.4 0 to 5.3 10 Aspen (14 inches) 22.5 0 to 65.7 20 Spruce/fir 1.5 0 to 27.9 10

Aspen Aspen is a seral stage of many forest types across the analysis area and it remains a persistent component of many conifer stands throughout their development. The largest, most productive aspen clones are found in the spruce/fir and cool moist Douglas-fir/mixed conifer forest types from about 8,500 to 12,000 feet in elevation. Aspen can also be found in drier forest types in favorable microsites or in scattered patches, at much lower densities.

74 CP District-wide Salvage Project Final Environmental Impact Statement The spruce beetle outbreak has resulted in a complex shift in species dominance in heavily impacted stands. The mortality of Engelmann spruce has resulted in an increase in aspen dominance on approximately 26 percent in these acres, as shown in Table 17.

Table 17. Change in acres dominated by aspen due to spruce mortality 2016 and 2017

Forest type 2016 2017 Percent change (pre-spruce beetle) (post spruce beetle) Aspen dominated acres 44,175 59,936 +26%

Direct and Indirect Effects Alternative 1 – No Action Alternative 1 represents the continuation of current forest management activities, including any activities approved under prior NEPA decisions.

Snags As indicated in Table 18, under this alternative, away from open roads accessible to firewood cutting, larger snags would continue to be relatively common in most forest types due primarily to insect or disease activity with the highest numbers in the spruce/fir dominated stands. Over time, snags will fall and move into the coarse woody debris pool. As shown below, based on the stand data used for this analysis, average numbers of snags greater than 12 inches diameter would decline from the current analysis area average of over 26 trees per forested acre to an average of about 10 per acre by 2036 and to an average by 5.7 per acre in 2066, though acres with greater numbers of snags would still be present as indicated by the average maximum snags per acre values.

Table 18. Average and average maximum snags per acre greater than 12 inches diameter for 2017, 2036, 2066, Alternative 1

Forest type 2017- 2036 – 2036 – 2066 – 2066 – average average maximum average maximum snags/acre snags/acre snags/acre snags/acre snags/acre Ponderosa pine 0.7 0.9 5.3 1.7 10.0 Douglas-fir/mixed conifer 4.6 2.6 6.4 14.1 22.9 Lodgepole pine 0.2 0.2 2.0 2.7 17.2 Bristlecone/limber pine 6.0 19.1 30.1 9.4 14.7 Aspen 25.2 10.6 44.3 11.8 38.4 Spruce/fir 77.3 31.2 82.1 11.2 38.7 Average all forest types 26.3 10.0 95.0 5.7 45.1

Under this alternative, it is likely that the minimum Forest Plan standards for desired snag densities would be met for the next several decades.

Coarse Woody Debris (CWD) Under this alternative, the greatest change factor in coarse woody debris levels (CWD) over time would be due to snag deterioration, breakage, and the eventual fall of these trees, especially in spruce beetle mortality areas. Though the fuel loading data used in the table below are modeled values based on forest type, they do indicate the general pattern of snag deterioration and eventual accumulation as coarse woody debris (CWD). For example, in the spruce-fir forest type, by 2036 average CWD would increase by approximately 12 percent in the 3 to 6 inch diameter class, 50 percent in the 6 to 12 inch diameter class and 94 percent in the12+ inch diameter class, compared to existing conditions in 2017. However by 2066, the levels begin to decline in the smaller classes due to decay processes, but continue to increase in the 12+ inch diameter 75 CP District-wide Salvage Project Final Environmental Impact Statement classes, reflecting the slow rate of snag fall of the larger snags.

Table 19. Average tons per acre of CWD by size class and forest type in 2036 and 2066, alternative 1

Forest type Average fuel loading/tons Average fuel loading/tons per Average fuel loading/tons per acre 3 to 6 inches acre 6 to 12 inches per acre 12+ inches 2036 2066 2036 2066 2036 2066 Ponderosa pine 1.29 1.57 1.27 1.41 0.55 0.75 Douglas-fir/mixed 6.00 8.06 7.25 14.16 1.00 2.08 conifer Lodgepole pine 5.87 5.63 7.17 8.11 0.02 0.17 Bristlecone/limber 7.22 6.49 14.71 11.70 4.61 3.81 pine Aspen 12.55 17.16 14.46 19.25 3.62 6.65 Spruce/fir 10.96 9.47 21.16 19.92 9.88 12.55

As indicated in Table 19, most forest types would likely continue to meet or exceed the minimum tons per acre set in the Forest Plan standards for CWD retention over time. Values for the ponderosa pine forest type may be less than desired in some areas, but these numbers may not accurately reflect actual conditions, due to the relative small acreage and less field sampled data for this forest type.

Old Growth As indicated in Table 20 below, considering just the average number and range of values for larger trees per acre across the landscape, potential for old growth characteristics will likely continue to be present in ponderosa pine, Douglas-fir, and aspen forest types. Most Engelmann spruce dominated stands would not likely not begin to redevelop old growth characteristics for 100 to 200 years, depending on current stand conditions. Stands with smaller understory spruce that have not been killed by the spruce beetle or that have other species present, would redevelop complex stand conditions more rapidly than single-storied stands that were dominated only by spruce.

Table 20. Potential for old growth characteristics in major forest types for 2036 and 2066, alternative 1

Forest type average trees per acre greater ranges of larger trees per acre than 16 inches dbh 2036 2066 2036 2066 Ponderosa pine 14.0 17.9 1 to 40.7 3 to 45.7 Douglas-fir/mixed conifer 30.0 33.6 4.0 to 80.9 13.2 to 99.2 Lodgepole pine (14 4.1 37.0 0 to 47.4 0 to 165.1 inches) Aspen (14 inches) 44.6 75.0 0 to 112.5 0 to 145.2 Spruce/fir 8.1 16.4 0 to 49.8 0 to 61.6

Aspen As shown in Table 21 below, aspen would continue to dominate a large portion of the landscape over the next several decades. From 2017 to 2066 there would be approximately a 17 percent increase in acres dominated by aspen due to shifts in species dominance primarily caused by the loss of mature live Engelmann spruce trees due to spruce beetles.

Table 21. Acres dominated by aspen in 2016 through 2066, alternative 1

Forest type 2016 2017 2036 2066 (pre-spruce beetle) (post spruce beetle) Aspen dominated acres 44,175 59,936 70,910 72,285

76 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 2 – Proposed Action Since proposed activities for this project are focused on salvaging spruce beetle killed trees, the effects of this alternative on biodiversity resources will only include the spruce-fir forest type that would be primarily affected by proposed activities.

There may be minor amounts of hazardous fuels thinning adjacent to private lands or infrastructure in the Douglas-fir/mixed conifer or aspen forest types, but these activities would have minimal effects to biodiversity resources in these forest types, since they would occur on relatively small acreages. Therefore, direct and indirect effects to the majority of the Douglas-fir/mixed conifer, aspen, ponderosa pine, lodgepole pine, limber pine, or bristlecone pine forest types would be the same as Alternative 1- No Action. Effects to aspen are described in the context of its presence and changes in dominance across the landscape over time for each action alternative.

Implementation of salvage harvest activities for Alternative 2 could affect up to approximately 14.5 percent of the spruce-fir forest in the analysis area, based on the local type acreages. Effects on the remaining 85.5 percent of the spruce fir forest type would be the same as Alternative 1.

Snags Under this alternative, the number of large, sound snags would be reduced in salvage harvested stands on up to 17,000 acres. To meet Forest Plan snag retention standards or to meet other resource objectives, at least minimum numbers of large snags would be left within harvest units. Hazardous fuels treatments may also reduce the number of large snags near infrastructure or private structures in order to meet objectives to modify fire behavior, though these activities would occur at a much smaller scale.

Outside of salvage harvested areas for this alternative, snags will continue to be abundant as described under Alternative 1.

As shown in Table 22, following salvage harvest, the average number of larger snags will be reduced in this forest type from current conditions (2017), but snag numbers across the landscape would continue to exceed minimum Forest Plan standards for spruce-fir over the next several decades.

Table 22. Average snags per acre greater than 12 inches diameter (range of values) for 2017, 2036, 2066, alternative 2

Forest type 2017 2036 2066 Average snags/acre Average snags/acre Average snags/acre (range) (range) (range) Engelmann spruce/subalpine fir 77.3 (0 to 293.1) 25.7 (0 to 95.0) 10.1 (0 to 45.1)

In salvage harvested units, snag numbers will decline over time as retained trees fall with the larger snags generally remaining standing longer than smaller snags.

Coarse Woody Debris Timber salvage activities affect the levels of coarse woody debris (CWD) primarily by removing a portion of the larger merchantable snags that would contribute to the future down woody material. Slash treatments may also affect CWD. If lop and scatter is used, CWD would be increased over modeled levels. Recently, most salvage operations have included whole tree skidding to the landing areas for later burning, which removes most of the larger portions of snags from harvest units. Existing CWD may also be affected during timber harvest operations by being crushed or moved, but would remain on site. Dead trees less than merchantable size, other tree species present, and any snags left to meet other resource needs would eventually become CWD over time. Forest Plan standards for minimum amounts of CWD retention would be required to be met in all harvested

77 CP District-wide Salvage Project Final Environmental Impact Statement units. Hazardous fuel treatments would also be expected to reduce CWD amounts in order to meet desired fuel loading objectives, but since these activities are proposed on a relatively small portion of the project area, there would be minimal effects to overall levels of CWD. As indicated by modeled data for in Table 23, though the size class of material on the ground may vary through time, the spruce-fir forest type would retain large amounts of CWD. In the spruce-fir forest type, by 2036 CWD increases by 13 percent in the 3 to 6 inch size class, 49 percent in the 6 to 12 inch size class and 93 percent in the12+ inch size class, compared to existing conditions in 2017. However by 2066, the levels begin to decline to some extent in the less than 12 inch classes, but continue to increase in the 12+ inch size classes. Under this alternative, average 12+ CWD levels increase from 2036 to 2066 by 26 percent.

Table 23. Average tons CWD per acre by diameter class (range of values) for 2017, 2036, 2066 in the spruce/fir forest type, alternative 2

Forest type – spruce-fir 2017 2036 2066 Average tons/acre Average tons/acre Average tons/acre (range) (range) (range) 3 to 6 inches diameter 9.02 (8.3 to 9.52) 10.38 (9.22 to 11.98) 9.08 (7.95 to 11.25) 6 to 12 inches diameter 9.57 (9.19 to 9.84) 18.92 (17.04 to 21.43) 18.18 (14.91 to 22.71) 12+ inches diameter 0.62 ( 0.42 to 0.94) 8.38 (5.93 to 10.06) 11.29 (8.04 to 14.83) Total average tons/acre 19.21 37.68 38.55

Old Growth This alternative would be the same as Alternative 1 regarding the long timeframes for the redevelopment of old growth characteristics in Engelmann spruce dominated stands across the landscape. Since old growth characteristics need 100 to 200 years to develop, it is unlikely salvage harvest would have a measurable effect due to the large number of variables that would likely to occur over this long time period. As indicated in Table 24, over the next fifty years the average number of larger trees per acre will increase across the landscape, but the development of decadence, structural complexity, and other old growth characteristics will need longer periods of time. Therefore, this alternative would be expected to have no direct or indirect effects on the development of future old growth characteristics in salvaged units.

Table 24. Trees per acre greater than 16 inches diameter, spruce-fir stands for 2017, 2036, 2066, alternative 2

Forest type – Spruce/fir 2017 2036 2066 Average all trees per acre > 16 inches dbh 1.5 8.3 16.5 Range of values, all trees per acre >16 inches dbh 0 to 27.9 0 to 49.8 0 to 74.0

Aspen Under this alternative from 2017 to 2066 there would be approximately a 17 percent increase in acres dominated by aspen across the analysis area, which is the same as Alternative 1, No Action. On salvaged acres, there may be minor increases in the density of aspen suckering due to ground disturbance and increases in sunlight to the forest floor, but changes in aspen dominance are primarily due to the loss of the mature Engelmann spruce from the spruce beetle outbreak. Implementation of Alternative 2 would be expected to have limited or no direct or indirect effects to the presence and extent of aspen across the landscape.

Alternative 3 – Vegetation Management – Limited Action As with Alternative 2, since proposed activities for this project are focused on salvaging spruce beetle killed trees, the effects of this alternative on biodiversity resources will only include the spruce-fir forest type that would be primarily affected by proposed activities. Any hazardous fuels thinning treatments would have minimal effects to other forest types, since they would occur on small acreages. Effects to other forest types

78 CP District-wide Salvage Project Final Environmental Impact Statement would be the same as alternative 1. Effects to aspen are described in the context of its presence and changes in dominance across the landscape over time.

Implementation of salvage harvest activities for Alternative 3 could affect up to approximately 7.2 percent of the spruce-fir forest in the analysis area, based on the local type acreages. Effects on the remaining 92.8 percent of the spruce fir forest type would be the same as Alternative 1.

Snags Under this alternative, the number of large, sound snags would be reduced in salvage harvested stands on up to 8,500 acres, which is approximately 50 percent fewer acres than Alternative 2. To meet Forest Plan snag retention standards or to meet other resource objectives, at least minimum numbers of large snags would be left within any salvage harvest unit.

Outside of proposed salvage harvested areas for this alternative, snags would continue to be relatively abundant in the spruce/fir forest type and the ranges of average snag numbers per acre across the landscape would be similar to Alternative 2 following completion of salvage operations (0 to 95 per acre). In 2036, this alternative could result in about an average of 10 percent more larger snags per acre (an average of 29 snags vs. 26) across the spruce/fir forest type compared to alternative 2, due to fewer acres being harvested. However by 2066, average snag numbers would be similar to alternative 2, as the additional snags fall over time.

As with Alternatives 1 and 2, implementation of this alternative would meet or exceed the minimum average snag retention standards specified in the Forest Plan, at the landscape scale, over the long term.

Coarse Woody Debris Alternative 3 would result in somewhat higher average levels of CWD in the spruce/fir forest type compared to Alternative 2, due to fewer acres being salvage harvested. As with Alternative 2, Forest Plan standards for minimum amounts of CWD retention would be required to be met in all salvage harvested units. Compared to Alternative 2, in 2036 average CWD amounts would be about 2 percent higher in the 3 to 6 inch diameter class, 7 percent higher in the 6 to 12 inch diameter class and 10 percent higher in the 12+ inch diameter class. However by 2066, the differences begin to decrease to less than 1 percent additional for the total average CWD in the long term, reflecting the snag fall and wood debris decay processes. Implementation of Alternative 3 would also meet or exceed Forest Plan retention requirements for CWD across the spruce-fir forest type over the short and long term.

Old Growth Alternative 3 would be similar to Alternatives 1 and 2 regarding the 100 to 200 year timeframes for the redevelopment of old growth characteristics in Engelmann spruce dominated stands across the landscape. As with Alternative 2, over the next fifty years the number of large trees per acre will continue to increase at similar rates, but the development of decadence, structural complexity, and other old growth characteristics will need longer periods of time. Therefore, this alternative would also be expected to have no direct or indirect effects on the development of future old growth characteristics in salvaged units.

Aspen Implementation of Alternative 3 may result in somewhat less density of aspen across the landscape over the long-term compared to Alternative 2, due to less ground disturbance, but any difference would likely be unmeasurable across the spruce/fir forest type in the analysis area. As with Alternative 2, implementation of Alternative 3 would have no measurable direct or indirect effects on aspen across the landscape.

79 CP District-wide Salvage Project Final Environmental Impact Statement

Comparison of Alternatives Table 25 shows the comparison of the biodiversity resources in the spruce/fir forest type generated from the FVS outputs for 2036 which is the modeled year when all salvage and hazardous fuels implementation activities have been completed for the action alternatives.

Though limited amounts of hazardous fuels reduction treatments may occur in other forest types, since the scope of the activities is very small, there would be no direct and indirect effects to the biodiversity resources in the Douglas-fir/mixed conifer, aspen, ponderosa pine, lodgepole pine, limber pine, or bristlecone pine forest types under any alternative.

In the spruce/fir forest type, as indicated by the FVS data outputs, Alternative 1 would, on average, retain more large snags and coarse woody debris (CWD) per acre than Alternatives 2 and 3. None of the alternatives would likely measurably effect the potential for the future development of old growth in the spruce/fir forest type, since this process may take 100 to 200 years depending on the post-spruce beetle stand composition. There would likely be no measureable difference in effects between the alternatives on the acres of aspen on the landscape. The approximately 26 percent increase in aspen dominated acres has resulted from to the mortality of the mature Engelmann spruce which was incorporated into the existing condition description for 2017.

Table 25. Comparison of alternatives, biodiversity resources in the spruce/fir forest type in 2036

Alternative Average number of Total average Potential for future Aspen snags/acre greater tons/acre CWD old growth acres than 12 inches Alternative 1 – No Action 31.1 42.00 No effect 70,910 Alternative 2 – Proposed 25.7 37.68 No effect 70,399 Action

Alternative 3 29.0 40.26 No effect 70,896

All alternatives would meet Forest Plan standards for biodiversity resources since salvage activities must provide for the effective retention of snags and CWD during implementation.

Cumulative Effects Past, present, and reasonably foreseeable activities were considered for the forested lands within and adjacent to the analysis area boundary for cumulative effects over the next ten to fifteen years. Activities considered include livestock grazing, recreation use, timber harvest, prescribed burning, and firewood collection. Activities on private lands could include road construction, timber harvests, hazard tree removal, or home construction.

There would be no measurable direct or indirect effects to the extent of aspen dominated acres across the landscape or the rate of re-development of old growth characteristics in the spruce/fir from the action alternatives. Prescribed burning in other forest types may increase aspen acres to some level.

Past and current timber management activities have been incorporated into the existing condition for the number of large snags per acre and amounts of coarse woody debris. There are no other reasonably foreseeable vegetation management activities in the spruce/fir forest type, if an action alternative is implemented. Other vegetation management activities, in addition to those listed, may be proposed in other forest types, but are not identified at this time. Firewood cutting is the activity that can have a direct effect on snag numbers and an indirect effect on coarse 80 CP District-wide Salvage Project Final Environmental Impact Statement woody debris. In this analysis area, it is assumed that firewood cutting will continue in accessible areas along open roads, which could incrementally reduce the numbers of large snags and future large coarse woody debris (CWD) in these areas, especially if firewood cutting areas overlap salvage harvest units. It is also likely that snags and future CWD would be reduced on private lands, especially if structures are present, due to the hazard or risk of damage from falling trees. Across the landscape, this would likely be a minor cumulative effect, but there could be measurable reductions in local areas.

3.4 Wildlife Scope of Analysis This section discusses the potential influences of the proposed actions on the Rio Grande National Forest’s Sensitive Species (S), Management Indicator Species (MIS) and Migratory Birds including local Birds of Conservation Concern consistent with the 2670 Manual, R2 Supplement August 23, 2016, Rio Grande Land and Resource Management Plan (1996), and the Migratory Bird Treaty Act. A summary of the Biological Assessment (BA) evaluating the projects potential impacts upon Threatened and Endangered Species (T&E) consistent with the Endangered Species Act (ESA) is included here. The complete BA and Wildlife Report is available in the project file. The spatial analysis area varies by species and reflects the area within which the species could be directly or indirectly affected by the action (see ‘action area’ 50 CFR 402.2). For the purpose of this ESA analysis there are two spatial scales: treatment areas and LAUs (Lynx Analysis Units). The treatment area is defined as the spatial bounds in which treatments are proposed (i.e. unit boundaries). Treatment areas are used to describe and quantify project effects to habitat. Broad analyses such as these are based on estimates of treatment areas in Geographic Information Systems (GIS) and thus, may not be completely accurate to the stand level. The LAU is used to describe the effects to Canada lynx and are intended to reflect an average female lynx home range in size and landscape. LAUs serve as baseline landscape units from which long-term trends in lynx habitat condition and change can be tracked. Potential effects to lynx will be determined based on the impacts to habitat within the treatment area relative to the LAUs associated with this project. The project does not overlap a lynx linkage area. For other species, given the programmatic nature of this project, the analysis consists of the treatment areas and a relevant scale for species viability across the Forest. Site specific analyses are conducted at the time of implementation through implementation checklists contained herein and within the Wildlife Report. Temporal bounding for the analysis is both short-term and long-term. Short-term consists of the time required for project implementation and the time in which vegetation begins to respond to treatments (usually within ten years of project implementation). Long-term extends to as much as 100 years into the future (canopy establishment).

Existing Conditions The current condition of the spruce forest analyzed for this project is a result of the combined past management actions and the spruce beetle outbreak. Current stand conditions are summarized in Section 3.2 and described in detail in the Silviculture/Forest Products Report. Past timber management treatments within the CP District- wide Salvage project area are listed in Appendix I.

Threatened, Endangered, Proposed and Candidate Species A list of threatened, endangered, proposed, and candidate species was requested for this project (IPaC: 06E24000-2017-SLI-0889). No designated critical habitat occurs in the project area for any species. Fish species will be considered in the fisheries report. Those species with no habitat present are not evaluated further in this document.

81 CP District-wide Salvage Project Final Environmental Impact Statement

Table 26. Threatened (T), Endangered I, and Proposed (P) species list and habitat descriptions

Species List Suitable Species General Habitat Description Habitat documented within within or Project near Project Area/Project Area/ Project Site Site

Canada lynx (T) Yes Yes, multiple Primary habitat consists of various age classes of Lynx canadensis years of spruce-fir and spruce-fir/aspen. High-quality habitat detections and consists of late-successional, multi-storied conifer evidence of stands with dense cover underneath. Secondary reproduction habitat consists of cool moist mixed-conifer stands, in the project aspen and riparian-willow. area Mexican spotted owl No No Habitat Steep canyons with adequate caves and ledges that (T) Strix occidentalis provide nesting sites, often in association with late- lucida successional Douglas-fir, white fir, ponderosa pine/pinyon-juniper components in the canyon bottoms for roosting. Southwestern willow No No Habitat Riparian habitats along rivers, streams or other flycatcher I wetlands, where dense growths of willows or other Empidonax trailii shrub and medium sized trees are present, often extimus with a scattered overstory of cottonwood. Primarily occurs below 8500’ in the SLV. Uncompahgre fritillary No No Habitat Alpine habitat above 11,000 with a snow willow butterfly I component. Sites are generally found on north, Boloria acrocnema northeast and east aspects. Gunnison sage-grouse No No Habitat Primary habitat associated with sagebrush – (T) Centrocercus dominated plant communities. Lek sites important minimus to reproduction and characterized by openings and sparse vegetation within sagebrush dominated plant communities usually below 9200’ elevation. Brood rearing habitat characterized by riparian vegetation of intermittent and perennial streams, springs, seeps and meadows within upland vegetation communities. Only population in the SLV occurs near Poncha Pass. New Mexico meadow No No Habitat Primarily associated with tall grass and sedge jumping mouse I Zapus component in riparian areas along perennial streams; hudsonius luteus elevation limit suspected to be about 9000 feet locally. North American Yes No, other than Primarily associated with remote subalpine and Wolverine (P) a dispersing alpine habitats, utilizes large rock talus areas for Gulo gulo luscus individual from denning; may utilize spruce-fir forested areas. Wyoming, not Marmots and carrion possible key food resources known to locally. Utilizes a wide range of upper montane occur in habitat types as it is very mobile. Colorado. Yellow-Billed Cuckoo No No Habitat Valley lowland species locally; primarily associated (T) Coccyzus with deciduous riparian woodland with a well- americanus developed understory; nests in cottonwood and willow riparian woodland.

The pre-field reviews indicated, and field surveys verified, that there is either no habitat present in the proposed treatment areas or the species isn’t present in the project area for the following terrestrial species:

82 CP District-wide Salvage Project Final Environmental Impact Statement Mexican spotted owl, Southwestern willow flycatcher, Uncompahgre fritillary butterfly, New Mexico meadow jumping mouse, yellow-billed cuckoo, or the Gunnison sage grouse. The project, as proposed, will therefore have “no effect” on these species and they are evaluated no further in this document.

There are no known occurrences of wolverine on the RGNF and there is an exceptionally low probability of a wolverine population occurring in the state and much less in the project area. Therefore, the effects of this project to wolverine are considered negligible and will not be considered further in this document.

Canada lynx is the only T&E Species which has suitable habitat and is known to utilize portions of the project area. As a result, it is the only T&E species further evaluated in this document.

Environmental Baseline for Canada Lynx The lynx is a highly specialized predator, adapted to prey on snowshoe hares. Lynx inhabit coniferous forests in the spruce-fir zone that experience cold, snow winters and provide a snowshoe hare prey base. Throughout North America, the distribution of lynx is closely tied to habitats that support an abundant population of snowshoe hare. The Southern Rocky Mountains are at the southern margin of the range of lynx. Historically, there was a record of lynx presence in the Southern Rockies. However, after conducting statewide surveys beginning in 1978, the Colorado Division of Wildlife concluded that the resident population was extremely small, and probably too small to be self-sustaining. In 1999, the Colorado Division of Wildlife initiated a reintroduction project to augment the population (Shenk 2006). To date, 218 lynx have been released into southern Colorado, primarily on the RGNF (85%), and at least 103 kittens have been born in the wild soon after reintroductions (Shenk 2007). Recent efforts have also confirmed successful breeding via tracked individuals and camera traps on the Forest. While success of the reintroduction effort looks promising, whether the lynx population in Colorado will become self-sustaining is still unknown (Colorado Division of Wildlife 2010). The extensive habitat change associated with the recent spruce beetle outbreak adds additional uncertainty to maintaining and managing habitat to support viable populations of lynx and other species that are closely associated with the spruce-fir ecosystem type.

Canada lynx habitat in Colorado primarily occurs in the subalpine and upper montane forest zones, typically between 8,000 and 12,000 feet in elevation. Forests in these zones typically contain deep winter snows and are dominated by subalpine fir, Engelmann spruce, and lodgepole pine although several mixed-conifer species may occur at lower elevations. A preference for these forest types, particularly spruce-fir associations, has been documented by radio-telemetry and tracking techniques associated with lynx reintroduced to Colorado (Shenk 2006). Other habitats used by reintroduced lynx include spruce-fir/aspen associations and various riparian and riparian-associated areas dominated by dense willow. While some lynx established home ranges in other parts of the state, the majority remain in southwestern Colorado.

Canada lynx have been documented within the project area to varying degrees, however survey efforts have not been rigorous enough to rule out presence in any particular area and thus we consider the entire project area occupied. Recent efforts in collaboration with CPW have documented increasing lynx use from the south to the northern portion of the district within the spruce-fir zone. Use diminishes in the eastern portion of the project area based on an elevational gradient associated with lower quality mixed-conifer and ponderosa pine habitats. Telemetry data from the reintroduction has shown core population areas within the project area and breeding has been documented recently in the Lake Fork and Saddle Creek drainages in the northern end of the district. This part of the Forest has more green trees remaining than other areas on the District and Forest as a whole, although beetles are continuing to impact the overstory.

Research is currently being conducted on the RGNF in collaboration with Rocky Mountain Research Station (RMRS) Science Application and Integration staff and CPW to aid in determining lynx use of beetle-killed spruce-fir forests. The study includes two individuals in the lake fork and saddle creek drainages on the district. The results are still preliminary, however one individual lynx made extensive use of the area and have ranged as far (to date) as Hilman Park and south fork Conejos. 83 CP District-wide Salvage Project Final Environmental Impact Statement At the southern end of the district, lynx have been observed on camera in the elk creek and red lake drainages, with several tracks in the past few years observed further south towards Trujillo reservoir and Cumbres Pass. This is likely a north-south movement zone into New Mexico as shown in (Theobald and Shenk 2011). Habitat conditions at the southern end of the District are generally poor, with >90% mortality in the overstory and minimal advanced regeneration in the understory. This area has been the focus of timber management the past decade; however, survey efforts have not been extensive.

Lynx Habitat Conditions Within Project Area Methodology To provide the best available environmental baseline for each LAU affected by the Conejos Peak District-Wide Salvage Project, an estimation of the post-beetle habitat conditions was required. A process was developed to assist in providing the estimate and emphasizes field-verification of habitat suitability where feasible and then estimating conditions within the forest matrix by professional judgement, taking into account common stand exam (CSE) data, aerial photos, and other data to evaluate the habitat suitability for the remaining acres within each LAU. Since the release of the DEIS, forest-level lynx habitat mapping has been updated to reflect the change due to bark beetles. Field-verified stands and monitoring of past projects were then incorporated to develop the current baseline as noted below. To differentiate between alternatives, estimates were derived as described below. Results from ongoing research on the Forest was also incorporated into assessing habitat conditions Forest- wide. While results are still preliminary, lynx are utilizing remnant large green trees, high stem densities (live and dead, particularly larger sizes), increased canopy closure (live and dead), high horizontal cover, and higher snowshoe hare densities. Field surveys completed by wildlife biologists and experienced wildlife technicians helped determine the relative quality of lynx habitat. Following field review, forested stands within the area have been roughly classified into four different categories described below and in Appendix F. Field-verified stands were incorporated into the baseline and were used as reference stands for comparison, using CSE data, aerial photos, and Data Analyzer outputs to perform a meta-analysis to stands that have yet to be field-verified. Where breaks in the data reflected differing habitat suitability, these were modeled across the LAUs to come up with an estimate for post-beetle habitat suitability highlighting the differences between low-quality and high-quality habitat. These categories were meant to differentiate habitat quality more so than ‘suitable’ vs. ‘unsuitable’ and also provide the basis for differentiating treatments between alternatives.* These categories can be grouped into two sets, low-quality (1 and 2) and high-quality lynx habitat (3 and 4).

These categories consist of: • Single story stands (one dead) with little or no advanced regeneration present within the stand and <25% live overstory trees (Currently unsuitable/SISS) • Single or two-story stands (one dead) with patchy regeneration, but overall forested stand does not contain DHC (may or may not be currently suitable). Stands are considered suitable if containing >25% live canopy with or without understory, or if they contain 0-25% live canopy and contain live understory trees that provide at least 20% horizontal density in winter snowshoe hare foraging habitat condition. • Two-story stands (one dead) with >20% horizontal density in winter snowshoe hare foraging habitat condition, but not S6 (Currently suitable, good quality habitat). Most stands may exceed 35% DHC (high quality foraging habitat). • Multistoried stands (2+), 40% canopy and >35% DHC, currently S6 or stands that continue to provide high-quality habitat in a changed condition due to spruce beetle (High-quality stands, Implementation Guide Tab 3 page 23).

84 CP District-wide Salvage Project Final Environmental Impact Statement

LAU Baseline Conditions The current condition of these stands are a result of the combined past management actions and spruce beetle outbreak. Past timber management treatments within the CP District-wide Salvage project area are listed in Appendix B of the Silviculture Report and include commercial thinning and improvement cuts, shelterwood preparatory cuts (including preparatory and establishment/seed cuts), overstory removal cuts, patch clearcuts, stand clearcuts, salvage cuts, and single-tree selection cuts. Other management activities have included reforestation, site preparation for natural regeneration, pre-commercial thinning, tree release and weeding, rearrangement of fuels, broadcast burning, burning of piled material, and yarding of fuels. The shelterwood cuts were essentially thinnings that reduced the stand density and improved tree vigor, with the purpose of reducing the susceptibility of the residual mature trees to spruce beetle infestation. The sanitation/salvage treatments removed dead or dying trees, which may have reduced the basal area and increased tree vigor in localized areas. These past management activities did reduce the risk of spruce beetle within the managed stands, but could not protect against the elements of high beetle populations and drought-related stress, thus have experienced extensive mortality as well. For more information, see the Silviculture Report.

Uneven-aged management at the stand and landscape scales helps retain a diversity of habitat conditions that maintain lynx and snowshoe hare habitat over time (Ruggiero et al. 2000). Some past management activities on the district created relatively young (<50 years old) stands of advanced regeneration, which are currently high-quality hare habitat and may serve as source populations for the surrounding area. Given the severity of beetle impacts, these stands may provide crucial habitat for lynx prey in the coming decades.

The Victoria-Chama LAU primarily consists of wilderness, and thus has been minimally affected by past timber management activities on federal or private lands. Such activities have only been conducted in the south-eastern portion of the LAU on federal lands and minimally on private. The LAU was last impacted by the Cow Camp Salvage Project.

The Rito-Archuleta LAU comprises the southernmost portion of the district and is the most likely to be affected by timber management activities due to close highway access and agreeable terrain. Much of the district’s recent timber management has occurred within the Rito-Archuleta LAU. Some timber management has also occurred on private lands within the LAU. The LAU was last impacted by the Cow Camp Salvage Project.

Victoria-Chama and Rito-Archuleta have had extensive beetle mortality, upwards of 90% of spruce >8”dbh have been affected. Most of these stands could be presumed ‘post-beetle’, with extensive mortality already evident. Due to site conditions, lower proportions of fir, and recent management activities, much of the southern portion of the district is relatively low-quality lynx habitat.

The Alamosa LAU comprises the northernmost portion of the San Juan Mountains on the district and has been minimally impacted by recent timber management activities. The area has evidence of past timber harvest >20 years ago. Habitat quality is considered moderate, however due to the remoteness of the LAU and lack of recent timber management, field-verification of habitat is quite minimal to date. Most recently, the LAU has been impacted by the Burrow Blowout Vegetation Management Project.

The Conejos Canyon LAU comprises some of the best habitat on the district, as evident in current lynx monitoring and research studies. There has not been federal timber management activities in the area in over 10 years, some areas much longer than that. There is evidence of past clearcuts from 20+ years ago and mining activity throughout. Spruce beetles are still working their way through the mature overstory, thus some green spruce currently remain in the canopy. However, it is anticipated that the area will see >90% spruce mortality at >8”dbh in the next few years.

The La Jara LAU comprises the eastern edge of the project area, covering much of our lower-elevation spruce-fir and mixed conifer areas. Because of the preponderance of mixed-conifer, these stands have not been as significantly impacted by spruce beetles as the other LAUs. Thus, habitat conditions are comparatively stable. However, western spruce budworm has been a disturbance agent in the LAU and the 85 CP District-wide Salvage Project Final Environmental Impact Statement mixed conifer stands of the district as a whole. This LAU was last impacted by the Hot Creek/Piederosa Wildlife Habitat and Fire Restoration Project. The Fox Creek Timber Stand and Wildlife Habitat Improvement project is currently being analyzed through the NEPA process.

Table 27. Baseline habitat for the LAUs affected by the CP District-wide Salvage Project

New Total Acres Acres Total Unsuit. Total Total % Un- LAU Old LAU LAU Primary Secondary Suitable Habitat Lynx Non- Suitable Name LAU # # Acres Veg Veg Habitat (SISS) Habitat Habitat Habitat

Victoria 20919 20925 71,806 28,554 11,623 40,177 4,013 44,189 27,617 9.1% Chama Rito 20920 20915 83,778 18,667 15,181 33,848 9,199 43,047 40,731 21.4% Archuleta

Alamosa 20916 20902 53,308 19,424 9,346 28,770 3,139 31,909 21,399 9.8%

Conejos 20918 20906 58,175 27,655 6,498 34,154 2,129 36,282 21,893 5.9% Canyon

La Jara 20917 20912 69,844 14,364 26,859 41,223 1,129 42,352 27,492 2.7%

Note: These are estimates based on the process outlined above to determine effects to post-beetle lynx habitat and are subject to be updated as additional field verifications occurs throughout the life of the project. Updates will be recorded in project monitoring and accountability checklists.

Sensitive and MIS Species

Sensitive Species Pre-field reviews and habitat analysis determined that suitable habitat exists for nine sensitive species within the project area (western bumble bee, boreal toad, northern leopard frog, northern goshawk, boreal owl, flammulated owl, olive-sided flycatcher, wolverine, pine marten and hoary bat). These nine species are further analyzed for the Conejos Peak District Wide Salvage Project. While species specific presence/absence surveys did not occur for most species, surveys will occur as needed prior to implementation in order to inform application of project design features.

Species having no suitable habitat and/or having no reasonable probability of occurring within or near the salvage units are not analyzed in further detail. This project will have “no impact” on these species which include: the Great Basin silverspot butterfly, Monarch butterfly, Ferruginous hawk, northern harrier, sage sparrow, Brewer’s sparrow, Lewis’s woodpecker, peregrine falcon, loggerhead shrike, white-tailed ptarmigan, mountain plover, burrowing owl, black swift, Townsends’s big-eared bat, fringed myotis, Gunnison’s prairie dog, bighorn sheep and river otter.

Table 28. Sensitive species, Rio Grande National Forest (August 29, 2015)

Suitable Species Habitat Species Documented within Basic Habitat Description within the the Project Area? Project Area? INSECTS Great Basin Spring fed and/or subirrigated wetlands at low No No silverspot butterfly (7500 feet or less) elevation; larval food plant Viola

86 CP District-wide Salvage Project Final Environmental Impact Statement

Suitable Species Habitat Species Documented within Basic Habitat Description within the the Project Area? Project Area? Speyeria nephrophylla; wet meadows interspersed with 87gmt.87s willows and other woody wetland species; adult nokomis nectar sources (mostly composites). No, however no Western Bumble The species is associated with meadows and surveys in the Bee openings where they occur in forested areas. Yes project area. Bombus Habitat includes flowering plants for foraging Extremely rare in occidentalis and rodent burrows for nesting. Colorado. The species is associated with grasslands and Monarch openings in forested areas, particularly at lower Butterfly Not documented on Yes elevation. Habitat includes flowering plants for Danaus plexippus the RGNF. foraging and is closely tied to milkweed species plexippus for breeding. AMPHIBIANS No, rare and not documented on the Boreal toad Conejos Peak Bufo boreas Yes Spruce/fir near water and alpine meadows. District. However boreas no species-specific surveys. No, rare on forest and not documented Riparian and wetland areas generally below Northern leopard on the Conejos Peak 9,000 feet. However, breeding population Yes frog Rana pipiens District. However observed near 10,500 feet on the Conejos Peak no species-specific District. surveys. BIRDS Black swift Nests behind or next to waterfalls and wet cliffs. No No Cypseloides niger Forages over forests and open areas. No, however no surveys in the Mature spruce/fir and mixed conifer forested Boreal owl project area. Likely Yes areas with preference for wet situations (bogs or Aegolius funereus present in the streams) for foraging northern end of the project area. Open grasslands associated with prairie dogs. Nests Burrowing owl No No and roosts in burrows dug by mammals or other Athene cunicularia animals. Open grasslands and shrub steppe communities. Ferruginous hawk No No Nests in tall trees or shrubs along streams or on Buteo regalis steep slopes No, however minimal surveys in Depend on cavities for nesting, open forests for the project area. foraging, brush for roosting. Occupy open Flammulated owl Yes May be present at ponderosa pine or forests with similar features Otus flamineolus the peripheries of (dry montane conifer or aspen, with dense the project area in saplings). lower elevations. Grasslands and open situations with scattered brush and riparian scrub; preferring to feed near woody cover; strongly associated with sagebrush for Sage sparrow No No breeding. Positively correlated with big sagebrush, Amphispiza belli shrub cover, bare ground, above-average shrub height, and horizontal patchiness; negatively correlated with grass cover.

87 CP District-wide Salvage Project Final Environmental Impact Statement

Suitable Species Habitat Species Documented within Basic Habitat Description within the the Project Area? Project Area? Strongly associated with sagebrush in areas with scattered shrubs and short grass; to lesser extent in Brewer’s sparrow No No mountain mahogany, rabbit brush, and bunchgrass Spizella breweri grasslands with shrubs or large openings in pinyon- juniper. Northern Mature forest generalist. On the Rio Grande, goshawk Accipter Yes Yes gentiles often found in mixed conifer/aspen stands. Lewis’s Open pine forests, burnt over areas with snags and woodpecker No No stumps, riparian and rural cottonwoods, and pinyon- Melanerpes juniper woodlands. lewis Loggerhead shrike Grassy pastures that are well grazed. Nests in Lanius ludovicianus No No shrubs or small trees, preferably thorny such as hawthorn. Mature spruce/fir or Douglas-fir forests with Olive-sided preference for natural clearings, bogs, stream flycatcher Contopus Yes Yes and lake shores with water-killed trees, forest borealis burns and logged areas with standing dead trees. Marshes, meadows, grasslands, and cultivated fields. Nests on the ground, commonly near low Northern harrier shrubs, in tall weeds or reeds, sometimes in bog; or No No Circus cyaneus on top of low bush above water, or on knoll of dry ground, or on higher shrubby ground near water, or on dry marsh vegetation. American peregrine falcon Cliff habitat over 200 feet high with suitable ledges No No Falco peregrinus for nest construction. anatum No, harvest is Alpine tundra, especially in rocky areas with sparse White-tailed not proposed vegetation. Summer habitats – moist, low-growing ptarmigan No in alpine alpine vegetation. Canopy cover of willow at winter Lagopus leucurus tundra feeding sites preferred. Bald eagle Nests and roosts are usually found in open- Haliaeetus No No branched trees near larger lakes, streams, rivers and leucocephalus reservoirs. High plains/short grass prairie habitats, often Mountain Plover associated with prairie dog towns. Nesting areas Charadrius No No characterized by very short vegetation with montanus significant areas of bare ground. MAMMALS Yes, however limited surveys in American marten Spruce/fir and mixed conifer forests with complex Yes the project area. Martes Americana physical structure. Presumed present in all mature stands. Towsend’s big- eared bat Forages in semi-desert shrublands, pinyon-juniper Corynorhinus No No woodlands and open montane forests. Roosts in caves, townsendii mines and mature forests. townsendii

88 CP District-wide Salvage Project Final Environmental Impact Statement

Suitable Species Habitat Species Documented within Basic Habitat Description within the the Project Area? Project Area? No. All observations have occurred below 9600’, all lower than Desert, grassland, and woodland habitats. Roosts in Fringed myotis Yes proposed activities. caves, mines, rock crevices, buildings, and other Myotis thysanodes Presence not protected sites. assumed around project activities. Yes. Presumed Primarily a solitary tree-foliage roosting bat; Hoary Bat Yes presence wherever may be associated with any habitat type that Lasiurus cinereus there are trees. contains trees, up to timberline. Gunnsion’s prairie High mountain valleys and plateaus at 1830-3660 dog Cynomys m; open or slightly brushy country, scattered No No Gunnison junipers and pines. Burrows usually on slopes or in (Candidate) hummocks. Rocky Mountain High-visibility habitat dominated by grass, low Bighorn Sheep Yes Yes shrubs, and rock cover, areas near open escape Ovis Canadensis terrain, and topographic relief. Major river drainages, larger perennial streams with River Otter No No at least 10 cfs of stream flow (generally 4th order or Lontra canadensis larger); lakes and reservoirs.

Both the monarch butterfly and the Rocky Mountain bighorn sheep have habitat within the project area, however, because the effects to these species and their habitat are anticipated to be negligible, they will not be discussed further in this document. See the Wildlife Report in the project file for the complete effects analysis.

MIS Species Evaluated For avian MIS, project level population information is an estimate of potential densities, based on species biology and suitable habitat that is presumed to be occupied. Because MIS were fairly recently amended into the Forest Plan and avian MIS surveys specific to the Forest were only initiated in 2004, available trend data is derived from existing sources, such as the Rocky Mountain Bird Observatory (RMBO) Monitoring Colorado Birds (MCB) program, the Colorado Land Bird Conservation Plan, and the Colorado Breeding Bird Atlas project, which are currently the primary sources of multi-year monitoring data. Until Forest-wide trend data are established via Forest-wide monitoring protocols, avian MIS population data at the Forest level are of necessity, estimated from known acreages and distributions of habitat types and structural associations, and species habitat affinities, but are considered within the context of available trend data at larger scales. Project level surveys documented species presence and habitat occupancy for all four of these species. For deer and elk, population trends are tracked by the Colorado Division of Wildlife at the Data Analysis Unit level. Specific habitat, risk factors and project potential effects for the four selected MIS is as follows.

89 CP District-wide Salvage Project Final Environmental Impact Statement

Table 29. Summary of the Forest’s MIS species and rationale for their analysis for the CP District-wide Salvage Project

Rationale for Detailed Rationale for Habitats Rationale for Selection in Evaluation for the Analysis Dismissal From MIS Represented Forest Plan Area Detailed Analysis Brown creeper Mature to late Species has a close association with To assist in monitoring Further Analyzed successional structural elements that occur under whether Forest Plan spruce/fir and older forest conditions, including large standards and guidelines for mixed conifer tree diameters and older snag biodiversity are being met, (LTAs 1, 3, 13; component. May respond to certain with an emphasis on snag threats, management, and conservation management. activities in spruce/fir forests (Colorado Bird Conservation Plan). Hermit thrush Mature to late Species primarily associated with To assist in monitoring Further Analyzed successional spruce/fir and is commonly associated whether Forest Plan spruce/fir and with, but not restricted to, older forest standards and guidelines for mixed conifer structure. May respond to certain biodiversity are being met, (LTAs 1, 3, 13; threats, management, and conservation with an emphasis on coarse activities in spruce/fir forests (Colorado woody debris and understory Bird Conservation Plan). Tied to vegetation. complex structural forest elements; may represent mature to late successional forest floor characteristics. Timber and/or fire management may affect quantity and/or quality of habitat, such as coarse woody debris. Elk Forest-wide Special interest locally (i.e., economic To assist in monitoring Further Analyzed (All LTAs) and recreational value). May be whether Forest Plan competing with other native ungulates standards and guidelines are and livestock. Sensitive to roads and being met for wildlife, with related disturbance. an emphasis on roads. Mule deer Forest-wide Special interest locally (economic and To assist in monitoring Further Analyzed (All LTAs) recreational value). Sensitive to roads and whether Forest Plan standards related disturbance. A habitat generalist and guidelines are being met but also associated with early for wildlife, with an emphasis successional stages for forage. on forest management issues that influence the early successional stages of plant communities.

Direct and Indirect Effects

Threatened, Endangered, Proposed and Candidate Specie Alternative 1 – No Action The stands identified for treatment are composed predominantly of Engelmann spruce. The degree of beetle infestation in the area is generally 90-100% mortality for spruce trees greater than 8” DBH. A reduction in canopy closure is occurring regardless if salvage occurs or not and is resulting in more open stand conditions that will release existing understory vegetation (shrubs, seedlings, and aspen). The species-specific mortality may shift current live overstory composition towards increasing subalpine fir and some aspen components; however, a recent study on the forest suggests persistence of Engelmann spruce in the understory, so future stand composition is anticipated to be more variable depending on existing understory composition and limited spruce cone crop in the coming decades (Kulakowki and Veblen 2003, Savage et al. 2017).. In general, species other than spruce comprise up to 25% of the dominant species composition pre-beetle and thus, live overstory would be limited for some time within and outside of the proposed treatment units. (Schmid et al. 1974). Observed average Engelmann spruce snag fall rates are between 1.3% and 3.0% per year over the first 25 to 30 years after initial mortality, though the longevity of standing spruce snags is uncertain. As the spruce overstory declines, advanced regeneration composed predominantly of subalpine fir and Engelmann spruce would be released to grow. Engelmann spruce seed sources would be substantially diminished until advanced 90 CP District-wide Salvage Project Final Environmental Impact Statement regeneration reaches cone bearing age. An overstory is anticipated to be established within the next 100 years. The resulting stand in the long-term would be more variable and composed with a greater proportion of subalpine fir than current conditions. For more information on future expected stand conditions, refer to the Silviculture and Biodiversity Reports.

Lynx prefer to forage in spruce-fir forests with dense horizontal cover, abundant hares and secondary prey, deep snow and large diameter trees during the winter (Ruggiero et al. 2000). Red squirrels make up a sizable proportion of prey items when snowshoe hare abundance is low, as high as 66% of prey items found (Shenk 2009). Red squirrels are experiencing a decline due to the bark beetle outbreak, however snowshoe hares appear less affected (Ivan and Seglund 2015). Based on the stand conditions described above, late- successional spruce-fir habitat is anticipated to decline within the project area. It is anticipated that the southern portion of the district (Rito Archuleta and southernmost part of Victoria Chama LAUs) would continue to be of lesser value to lynx for several decades due to current stand conditions until regeneration reaches >35% dense horizontal cover (DHC). The northern LAUs (Alamosa, Conejos Canyon) may have enough advanced regeneration and green stem densities to provide enough refugia such that lynx will continue to persist as stands regenerate.

Alternative 2 – Proposed Action The effects presented here are analyzed under the assumption that all project design features will be in place and final layout of treatment units are within the scope of the project as described herein.

The project proposes to salvage up to 17,000 acres of spruce-fir forest, of which approximately 16,529 acres are currently identified in GIS. Additionally, the proposed action includes up to 1,000 acres of hazardous fuels treatments, of which 941 acres are currently identified. Differences may be made up in the implementation phase including during unit layout, however it is not currently anticipated that all of the proposed areas would be feasible to salvage and therefore represents the maximum allowable harvest under this EIS. All proposed treatments occur within mapped lynx habitat on the Conejos Peak Ranger District and would affect up to 5 LAUs, except for three acres that overlap the Trout-Handkerchief LAU due to mapping error (Tables 30, 31). These three acres are included in the effects to the Alamosa LAU. No treatments are proposed in a lynx linkage area.

Though project harvest objectives are to salvage dead and dying spruce, the extent of mortality in most stands would resemble a regeneration harvest. Following removal of the dead or dying spruce, the Forest Service would plant seedlings on those areas where post-sale reforestation surveys indicate that stocking is below desired levels. The desired species mix and stocking levels will be determined by existing density on a stand- by-stand basis, but will be not less than the minimum Forest Plan standard of 150 trees per acre and is anticipated to be predominantly spruce. However, not every acre is uniformly stocked; some areas are moderate, some areas are low. In such cases, spot planting may be an option at the unit level if recommended by the Silviculturist. Additionally, 150 trees per acre would not become high-quality hare habitat until the stands naturally fill in further, which may take several decades.

Treated stands are expected to have susceptibility to windthrow as a result from this treatment due to the extensive nature of the mortality and resulting salvage of dead spruce. Trees most susceptible to windthrow would be residual live overstory fir, which have greater wind resistance due to the live crown. The snag retention Project Design Feature may be used to provide shelter to residual trees where wildlife objectives may be met simultaneously.

91 CP District-wide Salvage Project Final Environmental Impact Statement

Table 30. Acres of lynx habitat affected by the salvage component of Alternative 2 by LAU

LAU Primary Suitable Unsuitable (SISS) Secondary Suitable Total

Acres Acres Acres Acres

ALAMOSA 1828.1 509.7 0 2337.8

CONEJOS 1885.8 663.3 50.2 2599.3 CANYON

LA JARA 558.4 209.0 0 767.4

RITO- 1404.9 524.1 6.2 1935.2 ARCHULETA

VICTORIA- 144.0 420.4 0 564.4 CHAMA

Total 5821.2 2326.4 56.5 8204.1

Table 31. Acres of lynx habitat affected by the hazardous fuels component of Alternative 2 by LAU

LAU Primary Suitable Unsuitable (SISS) Secondary Suitable Total

Acres Acres Acres Acres

ALAMOSA 321.5 95.6 1.6 418.8

CONEJOS 236.9 24.4 56.0 317.3 CANYON

LA JARA 1.3 0 0 1.3

RITO- 113.1 40.2 1.2 154.5 ARCHULETA

VICTORIA- 0 0 0 0 CHAMA

Total 672.8 160.1 58.9 891.8

The effects to habitat suitability are dependent on the quality of habitat pre-treatment (density of regeneration, preponderance of green trees, etc.). To qualify these effects, see habitat categories described in the Wildlife Report. Because field-verification of such a large amount of area cannot occur in a timely manner prior to completing NEPA, habitat quality has been modeled where not already accounted for either by monitored past projects or field verification (Wildlife Report). Habitat conditions on the ground will be assessed prior to implementation and reflected in project-level monitoring and reporting checklists.

92 CP District-wide Salvage Project Final Environmental Impact Statement Effects to Lynx Direct impacts may range from temporary disturbance/displacement and possible but highly unlikely direct mortality resulting from salvage or fuels activities (i.e. trees or machinery crushing individuals). Lynx kittens are vulnerable when very young. Project design features are in place to protect lynx kittens when they are most vulnerable from May 1 to July 15th, however locating lynx dens without collar data is nearly impossible. It is unlikely that lynx would den within the treatment area given the habitat components preferred by denning lynx. Those areas most likely to provide denning habitat (high amounts of DHC, heavy downed wood component, and steeper slopes) are typically not harvested due to slope and they are not harvested during denning time periods due to access and wet soils. While some areas are close, no past known denning location on the district is within a proposed treatment area. However, project design features to prevent direct impacts to newly borne lynx are in place and will be used where needed based on field verification during implementation.

Disturbance is possible, particularly within the Alamosa and Conejos Canyon LAUs, due to recent evidence of occupancy and breeding. Lynx are generally tolerant of human disturbance, however high noise levels present during harvest activities may preclude use of an area (Ruggiero et al. 2000). Additionally, manipulation of foraging habitat close to den sites may reduce foraging ability and the potential for future, short-term use, reducing the occupancy and subsequent breeding capacity in the area. In collaboration with CPW, remote cameras have documented breeding success within the Lake Fork and Saddle Creek areas of the Conejos Canyon LAU. This area is overlapped with proposed timber harvest areas under this alternative and thus is likely to negatively affect breeding success in the area by reducing cover and foraging resources within the core home range of known breeding individuals before research on lynx use of post-beetle stands on the forest is completed. Preliminary reports determined that high amounts of regeneration and higher stem densities (live or dead) are important components of lynx habitat post-beetle, which is currently abundant in this area. Temporary roads are may have minor impacts to lynx or lynx habitat, as most are within timber harvest units and the effects are considered within the effects of the unit as a whole. Little is known of the impacts of temporary roads on lynx, however it is not anticipated to impact lynx and lynx may actually use them as movement zones during the winter (Ruggiero et al. 2000). Temporary roads outside of harvest units are approximately 12ft wide and therefore can be less than average tree spacing in some areas. Additionally, PDC minimize the impacts of temporary roads through placement away from dense horizontal cover and pockets of advanced regen, where feasible. Impacts to lynx and lynx habitat are therefore anticipated to be negligible. Temporary roads may last for several years during normal harvest operations and will be decommissioned after use.

Effects of Salvage to Lynx Habitat Lynx habitat categories 1 and 2 (i.e. low-quality lynx habitat)

The effects to habitat described in this section applies to those areas modeled or field-verified as low-quality lynx habitat, which represents approximately half of the proposed treatment areas (8, 204 acres). Field verification of stand conditions will occur prior to implementation, however because the majority of the LAUs have not been field-verified modeling was used as a tool to aid in the effects analyses and represents the best available information at this time for post-beetle habitat conditions. Information from ongoing research would be incorporated as feasible through the life of the project.

As described above, the proposed treatment areas are dominated by Engelmann spruce (80% or more of trees >8” DBH) and the vast majority of the these areas lack sufficient large green trees to leave an intact overstory, particularly taking into account incidental damage from harvest activities and wind effects post- treatment. It is therefore anticipated that, other than in small pockets of mature aspen or subalpine fir, the overstory would be largely removed in treatment areas within habitat categories 1 and 2 and stands would resemble a shelterwood or seed tree with reserve snags prescription. Post-treatment canopy closure is expected to drop to about 7% before increasing again (Silviculture Report). These areas lack sufficient advanced regeneration to

93 CP District-wide Salvage Project Final Environmental Impact Statement be currently suitable (SISS, category 1) or have some regeneration but are low- quality suitable habitat that does not contain dense horizontal cover at the stand scale (DHC, category 2). Regeneration in these conditions is typically patchy and based on field observations there is sparse evidence of snowshoe hare use.

The salvage harvest would reduce habitat attributes preferred by lynx and their primary prey species (snowshoe hare) including future coarse woody debris and some advanced regeneration. Red squirrel densities would be expected to decrease in abundance due to the spruce beetle influence and lack of mature overstory trees, with the addition of incidental damage to residual trees during harvest activities. Red squirrels may already be absent in some areas of category 1 stands. Small pockets and strips of regeneration that reach DHC conditions may provide holdover areas for snowshoe hares or squirrels within treatment areas and are a focus of project design features (Fisher and Bradbury 2006). Lynx habitat is not expected to be suitable post- treatment at the stand scale and category 2 habitat stands would be converted to stand initiation structural stage (SISS, unsuitable) primarily due to the lack of advanced regeneration in the majority of the treatment area, incidental damage impacts to regeneration from harvest activities, and blow- down of remaining green trees (Figure 6). However, at the LAU scale these impacts are anticipated to be minimal, as habitat quality is low and thus less likely to be used by, or critical, for lynx.

Benefits of harvesting in low-quality lynx habitat include subsequent planting of conifer seedlings, such that stand conditions preferred by snowshoe hares would return faster than natural regeneration in these areas, thus promoting future lynx habitat consistent with the intent of the Southern Rocky Lynx Amendment (SRLA). The stands would require further natural seeding over time to reach sufficient densities for high- quality hare habitat.

Effects of Salvage to Lynx Habitat Categories 3 and 4 (i.e. high-quality lynx habitat) These stands represent the higher quality lynx habitat, those that contain DHC and greater diversity in canopy layers and species. As evident in current research on the forest, these are the stands lynx are utilizing post- beetle and are thus important to the persistence of lynx on the Forest. As currently modeled, these areas represent approximately 8, 105 acres of the identified 16,529 acres of proposed salvage area. As mentioned before, field verification will occur prior to implementation for all lynx habitat.

These areas are anticipated to have greater amounts of advanced regeneration and mixed-aged trees than categories 1 and 2. Based on post-project monitoring, incidental damage to advanced regeneration from harvest activities is approximated to be up to 30%. These stands, too, have a high proportion (>80%) of spruce in the overstory, such that with salvage the majority of the overstory would be removed. Some damage may occur to remaining fir or other green trees, however equipment operators have been quite good at minimizing damage due to PDC. Blowdown is anticipated here, as remaining green trees are not wind- hardened and easier to blow down when the dead spruce are removed.

In some cases, blowdown, incidental damage to the understory, or height of understory may result in insufficient cover post-harvest to remain suitable habitat for lynx or lynx prey. In other cases, the understory is of sufficient height and density such that even with these negative effects the stand remains suitable habitat post-treatment, albeit reduced in quality. Therefore, salvage effects on these stands is highly dependent on pre- harvest conditions and operator skill in avoiding damage to green trees and regeneration. A range of potential effects is provided in Table 30. Based on post-project monitoring and discussions with other biologists on the Forest, it is assumed that approximately 70% of stands remain suitable post-harvest depending on preexisting site conditions. Project monitoring will occur and baseline adjustments made accordingly. Information from ongoing research on the Forest will also be incorporated as appropriate.

Effects of Salvage Harvest to Secondary Habitat Approximately 340 acres of mapped secondary habitat is overlapped by proposed harvest units. Effects to secondary habitat are determined by the amount of dead spruce occurring within the stand, which can be quite variable between stands, and the surrounding habitat’s quality. Where aspen are dominant, it is not 94 CP District-wide Salvage Project Final Environmental Impact Statement anticipated that salvage harvest would occur, due to the lower volume available. However, where more evenly mixed, salvage harvest could occur, as is the anticipated condition in these 340 acres. It is anticipated that habitat quality within the stand would be reduced to a point where snowshoe hare use, and subsequently lynx, would be minimal due to activity damage to residual aspen and conifers. If the surrounding area of spruce-fir stands are converted to SISS, a secondary habitat stand would not be anticipated to continue to provide suitable habitat, but may be sufficient for movement corridors. The majority of these affected stands occur in the periphery of larger spruce-fir stands also identified within proposed harvest areas, such that their value to lynx is determined by these stands. For the purposes of this analysis, it is assumed that secondary habitat would also be converted to unsuitable within salvage harvest areas. These stands would be likely maintained as aspen-dominant for the next several decades, however are not anticipated to receive notable lynx use until surrounding stands also regenerate.

Summary of Effects from Salvage Harvest For snowshoe hare, red squirrel, and consequently lynx, harvest impacts could last until understory conditions once again provide security, forage and overall quality winter snowshoe hare habitat (generally 30-50 years), depending on site conditions (Thompson et al. 1989). The effects from harvesting combined with the spruce beetle influence are expected to cause a reduction in lynx prey resources. Improvements in red squirrel densities are also not expected for up to 40 years, or until sufficient trees reach the reproductive capacity to bear cones. Overall, this potential reduction in prey abundance (primary and secondary) could result in reduced lynx use within treatment areas particularly during low snowshoe hare population cycles when lynx are more reliant on red squirrels, which could be absent from areas due to beetles, incidental damage, and blowdown.

Project design features act to minimize incidental damage to the advanced regeneration and provide for future habitat characteristics. Project design features for snags will retain pockets of snags, providing for future CWD recruitment and potential denning sites. Additionally, these retention pockets can be used around existing advanced regeneration sites, where they exist, protecting them further from damage during logging operations and keeping legacy features in the stands. Areas with higher regeneration densities would be expected to have some incidental damage from harvest activities.

Effects of Fuels Treatments to Lynx Habitat Hazardous fuels treatments would occur within 200 feet of administrative sites and facilities or within 400ft of private lands within the project area and include hazard tree felling, some thinning of dense saplings (approximately 20ft spacing), pruning to approximately 5ft, and pile-burning of slash, where needed. These non-commercial mechanical treatments will impact habitat, but will not have the same magnitude as commercial salvage treatments. Incidental loss of saplings and pole size trees will be minimal as will impacts to soils, shrub, and herbaceous vegetation except where deemed necessary for hazard fuels management. Thinning and pruning of saplings and advanced regeneration will reduce habitat quality, particularly during fall and spring transitions when snow depths preclude use of herbaceous vegetation but is not deep enough for pruned trees to provide cover. Habitat will therefore be reduced in quality, but is not expected to result in a complete loss of habitat. Effects of fuels treatments are a reduction of cover for hares and security cover for lynx movement. Since public safety is the primary objective, retention of understory vegetation will occur to the greatest extent practicable that would meet shaded fuelbreak objectives. While some cover will be retained, hare habitat retained will generally be of low quality following harvest. In areas that support a mixture of spruce and aspen (secondary habitat, ~60 acres), removal of hazard trees will disturb the soils through mechanical operations and increase sun exposure to the forest floor. Aspen is expected to be regenerated in such circumstances, creating dense stands of young aspen. It is not anticipated that hazardous fuels treatments would convert secondary habitat to SISS. Hazard tree removal may occur in some areas and would result in a loss of large down wood, if removed. In some cases, particularly in low-quality habitat, felling hazard trees could create an opening 400 feet across. However, retention of understory vegetation will

95 CP District-wide Salvage Project Final Environmental Impact Statement provide some cover allowing lynx movement in these areas. Forest Plan standards for big game cover requirements will also help maintain connectivity in these areas, as suitable big game cover in spruce-fir habitats may facilitate lynx movement. While impacts to lynx movement could occur at a small scale with fuels treatments, it is not anticipated to be measureable at a LAU scale.

Effects on Habitat Connectivity Of the action alternatives, Alternative 2 has the greatest potential impact on connectivity. Lynx require cover for security and for stalking prey and typically avoid large, open areas (Ruggiero et al. 1994). While lynx will cross openings <100m in width, they would not hunt in these areas (Koehler 1990). Suitable travel cover consists of coniferous or deciduous vegetation >2m in height with a closed canopy close to foraging habitats (Ruggiero et al. 1994). Alternative 2 has the potential to create large openings through salvage harvest, particularly in habitat categories 1 and 2 (low-quality lynx habitat). Since these stands have limited regeneration, they may be sporadically used already and further degradation through harvest may further limit connectivity. Lynx movements during the reintroduction documented core areas and movement zones on the district that may be affected by the project, see Figure 4 in (Theobald and Shenk 2011).This particularly may affect the Rito Archuleta LAU as it has a higher proportion of low-quality habitat and the spatial arrangement of suitable habitat and past and proposed timber harvest units may limit connectivity into New Mexico. While still poorly understood, anthropomorphic effects on lynx occupancy of an area may be mediated by the relationship between pre-existing habitat conditions and intensity of habitat loss, but the beetle influence in this relationship is unclear (Hornseth et al. 2014). One benefit of harvesting in these areas is to promote future forests through subsequent planting providing connectivity in the future through re- establishing foraging habitat faster than would occur naturally. Stands that retain suitable habitat characteristics post-harvest are not anticipated to measurably impact connectivity, such as some category 3 or 4 stands.

The spatial arrangement of harvest units within Conejos Canyon and Alamosa LAUs may also have an effect on connectivity, particularly between the two LAUs, however these LAUs have greater amounts of high- quality lynx habitat (i.e. more advanced regeneration, categories 3 and 4) and may leave some harvest areas suitable post-harvest. Where these conditions meet those described in (Koehler 1990) above, impacts to connectivity are fewer. Additionally, several potential corridors exist that don’t have proposed harvest units that may aid in movement between the two LAUs.

The spatial arrangement of harvest units within the La Jara LAU are not anticipated to impact connectivity within or across the LAU, given that the proposed sale areas are smaller and of the lower-quality habitats that make up the majority of the LAU. Also, the LAU is along the periphery of high lynx use on the district, with higher use areas to the west in the Alamosa, Conejos Canyon, and Victoria Chama LAUs (Theobald and Shenk 2011). Thus impacts to connectivity are less in this LAU.

The Victoria Chama LAU is primarily composed of either wilderness area or backcountry, such that the only proposed harvest is an area of lower-quality habitat along the southern border of the LAU (See map, Appendix C). Thus, within- LAU connectivity is not limiting and between-LAU connectivity may have some impacts, mostly from current habitat suitability, in combination with the proposed harvest in the Rito Archuleta LAU.

Under both action alternatives all live conifers and aspen where present, will not be harvested except where safety and operational conditions warrant. Riparian buffers are in place to protect riparian areas but may also help to facilitate movement, however are questionable whether they are sufficient as movement corridors across larger openings. These measures will help to provide additional cover and security for movement across the project area. Patches of regeneration should not only provide for snowshoe hare holdover habitat, but will help to provide some level of cover and habitat connectivity.

96 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 3 – Vegetation Management – Limited Action

Effects of Salvage Logging to Lynx Habitat The effects to lynx habitat under Alternative 3 are similar to those under Alternative 2, however only low- quality lynx habitat would be salvaged under this alternative, approximately 8,500 acres. This alternative was modeled after Vegetation Objective O4 of the SRLA, balancing between providing opportunities for salvage harvest and prioritizing salvage harvest within areas that are currently poor snowshoe hare habitat that could benefit from harvest and subsequent conifer planting. A denning model was developed and applied to further identify blocks of 20 acres or greater with habitat elements used by denning lynx (steep slopes, northerly aspects, high elevations, spruce-fir habitats (Topolewski 2017)). This had minor impacts to proposed salvage units, however, as most areas were already precluded due to steep slopes. Because activities are emphasized outside of high-quality lynx habitat, the potential for impacts to lynx are therefore significantly less, as crucial habitat components and stands that lynx are utilizing post-beetle would be retained. Additional project design features would also ensure greater protections of advanced regeneration and snags, promoting important future forest characteristics including biological legacies along with promoting greater connectivity within and between LAUs. Impacts from temporary roads would also be less.

This alternative provides further retention emphasis to the Conejos Canyon and Alamosa LAUs where the most recent evidence of breeding lynx has occurred, thus providing known refugia into the future. Proposed harvest in these LAU’s is approximately half of what is proposed under Alternative 2. This is due to the large amount of high quality habitat in these LAU’s that would not be harvested under Alternative 3.

Differences in potential salvage harvest acres between Alternatives 2 and 3 are reduced in the Rito-Archuleta and Victoria Chama LAUs given the amount of lower quality habitat (category 1, currently unsuitable) and less lynx use. Emphasis for harvest would occur within these LAUs to promote future lynx habitat through planting.

Effects to Lynx Effects to lynx are similar under Alternative 3 given that the same prescriptions would occur in the areas identified for harvest, however the probability of direct impacts would be notably less since lynx are not expected to use lower quality habitat areas as heavily. Additional project design features, as well as only harvesting within low-quality lynx habitat would notably reduce potential impacts to lynx using the area. Disturbance is still possible, particularly within the Alamosa and Conejos Canyon LAUs, due to recent evidence of occupancy and breeding. However, additional protections and reduced harvest act to ensure sufficient habitat refugia for lynx to persist in the area. Additionally, as forest-wide research into lynx use of post-beetle spruce-fir stands is completed and integrated, both action alternatives allows time for understanding and incorporating the information prior to planning projects within the Alamosa and Conejos Canyon LAUs, which appear to be key LAUs on the district. Cumulative Effects Baseline conditions for lynx habitat have been described previously in the No Action Alternative and Environmental Baseline sections in this analysis. Baseline conditions have been updated as possible to incorporate changes associated with the spruce beetle outbreak on the district. It is anticipated that baseline conditions due to the spruce beetle will continue to change over the life of this project, however, the amount, distribution, and site-specificity of this change is unknown. From a Forest-wide perspective, the spruce beetle outbreak has already influenced all of the spruce-fir ecosystem type, sometimes dramatically. Uncertainties associated with the effects of this change have been incorporated into the implementation and monitoring checklists so that baseline conditions can be updated for each project as applicable prior to implementation. These updates will need to be coordinated at the Forest level for assessing a broader array of cumulative effects including adjacent LAUs. Outcomes from on-going studies involving lynx and prey species on the Forest are anticipated to be finalized and incorporated into this project as they become available in the near future.

97 CP District-wide Salvage Project Final Environmental Impact Statement Foreseeable future activities within the project area include the Fox Creek Vegetation Management Project, which proposes to thin, salvage, and broadcast burn within dry mixed-conifer stands, as well as regenerate aspen stands within the same ecosystem. This project would not affect the spruce forest type. Another upcoming proposal is the Trail Gulch project, which is very early in the planning stages. It proposes similar treatments to the Fox Creek project and would likely begin implementation in 2022. It is currently premature to include in this analysis, however, given how far into the future project planning would occur. Fuelwood gathering, grazing, recreation, and other previously permitted activities are expected to continue, but have negligible impacts to lynx. These are federal proposed projects that will be subject to individual section 7 consultation in the future.

Foreseeable activities adjacent the project area include ongoing salvage logging on private lands within the Chama Basin. Rancho del Oso Pardo and inholdings are currently salvaging approximately 80 acres of dead spruce per year from their property, and this activity is expected to continue over the next five years. The same private landowners are also performing aspen regeneration cuts at lower elevations on approximately 5- 50 acres per year; this activity is expected to continue throughout the life of the CP District-wide Project. However, all these areas are outside of any LAU affected by the Project.

The Colorado State Forest Service is conducting a 50 acre spruce salvage harvest on Osier Mountain, and anticipates performing 140 acres of aspen regeneration cuts, 50 acres of spruce salvage, and 20 acres of ponderosa pine restoration near La Jara Reservoir, over the next 10 year period. Only the 50 acre spruce salvage harvest may occur within the same LAU as the CPDWS project, the Rito Archuleta LAU. This area is spatially isolated and fragmented from much of the lynx habitat within the LAU and thus is likely to only receive light use by lynx as they disperse or have exploratory movements through the area. Salvage harvest in this area would therefore have negligible cumulative impacts to lynx.

Summary of Effects to Lynx Habitat

Under alternative 2, a maximum of 17,000 acres could be salvaged and 1,000 acres of hazardous fuels treatments could occur. These effects are distributed across several LAUs and are described as identified in GIS (Table 32). It is anticipated that >30% of categories 3 and 4 may be converted to SISS through harvest and/or fuels activities, given observed post-project monitoring on the forest. The tables below take into account the assumed conversion of low-quality suitable habitat (category 2) to SISS from salvage activities and describes the range of conversion, including an approximately 30% incidental damage estimate through the maximum treatment scenario (30% conversion to 100% conversion) of high-quality habitats (categories 3 and 4) to SISS from salvage activities under alternative 2. For this analysis, the maximum treatment scenario was included to show that even if 100% conversion to SISS within identified primary and secondary habitats occurred within all salvage harvest and only conversion to SISS where fuels treatment units overlap primary habitat, all LAUs are anticipated under current modeling to meet SRLA standards S1 and S2.

Standard S5 is also anticipated to be met as well (see 2.3 Southern Rockies Lynx Amendment, below) and S6 will be monitored through the project’s lifespan to ensure compliance with the SRLA. It must be noted that effects to high-quality habitat are anticipated to be significantly less than the maximum treatment scenario as areas may retain suitable habitat characteristics post-harvest. Similarly, the effects to lynx habitat from hazardous fuels treatments is described under the maximum treatment scenario, although as described above, actual effects are anticipated to be less. Fuels treatments in mapped secondary habitat are assumed to not convert to unsuitable given that aspen stands are a desired condition post-treatment.

Similarly, under alternative 3 the table assumes conversion of low-quality habitat (category 2) to SISS and the worst-case scenario of 100% conversion of fuels treatments in primary habitat to SISS. Project monitoring and compliance checklists will ensure that all standards and guidelines would be met through the life of this project.

98 CP District-wide Salvage Project Final Environmental Impact Statement

Table 32. Summary of effects to lynx habitat under each alternative per LAU, including the range up to the maximum treatment scenario for alternative 2

Alternative 2 Impacts to Alternative 3 Impacts to Alamosa LAU Existing Baseline Suitable Habitat Suitable Habitat

Description Acres (%) Acres (%) Acres (%)

Total Acres 53,308 (100%) 53,308 (100%) 53,308 (100%)

Total Acres of Lynx Habitat 31,909 (59.9%) 31,909 (59.9%) 31,909 (59.9%)

The project may convert The project may convert 2,334.8 – 3,516.9 acres to SISS 1,828.1 acres to SISS (5.7% of (7.3% – 11% of lynx habitat) 29,388 (90.2% of lynx lynx habitat) and up to Acres of Suitable from salvage and up to habitat) approximately 321.5 acres approximately 321.5 acres (1%) from hazardous fuels (1%)1 from hazardous fuels treatments treatments

Acres of Unsuitable (SISS) Post- 5,473.5 – 6,977.2 (17.5% - 5,288.4 (16.6% salvage and 3,138.8 (9.84%) Project 21.9%, salvage and fuels) fuels)

Alternative 2 Impacts to Alternative 3 Impacts to Conejos Canyon LAU Existing Baseline Suitable Habitat Suitable Habitat

Description Acres (%) Acres (%) Acres (%)

Total Acres 58,175 (100%) 58,175 (100%) 58,175 (100%)

Total Acres of Lynx Habitat 36,282 (62.4%) 36,282 (62.4%) 36,282 (62.4%)

1 Hazardous fuels treatments depicted in this table include both WUI and non-WUI areas. 99 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 2 Impacts to Alternative 3 Impacts to Alamosa LAU Existing Baseline Suitable Habitat Suitable Habitat

The project may convert The project may convert 1,936 2,780.2 – 4,749.9 acres to SISS acres to SISS (5.3% of lynx (7.7% – 13.1% of lynx habitat) 34,153.8 (94.1% of habitat) and up to Acres of Suitable from salvage and up to lynx habitat) approximately 236.9 acres approximately 236.9 acres (0.7%) from hazardous fuels (0.7%) from hazardous fuels treatments treatments

Acres of Unsuitable (SISS) Post- 5,473.5 – 7,115.4 (13.7% - 4,301.5 (11.9% salvage and 2,128.6 (5.9%) Project 19.6%, salvage and fuels) fuels)

Alternative 2 Impacts to Alternative 3 Impacts to La Jara LAU Existing Baseline Suitable Habitat Suitable Habitat

Description Acres (%) Acres (%) Acres (%)

Total Acres 69,844 (100%) 69,844 (100%) 69,844 (100%)

Total Acres of Lynx Habitat 42,352 (60.6%) 42,352 (60.6%) 42,352 (60.6%)

The project may convert 868.9 The project may convert 558.4 – 1,593.4 acres to SISS (2.1% – acres to SISS (1.3% of lynx 3.8% of lynx habitat) from 41,223 (97.3% of lynx habitat) and up to Acres of Suitable salvage and up to habitat) approximately 1.3 acre approximately 1.3 acre (<0.01%) from hazardous fuels (<0.01%) from hazardous fuels treatments treatments

Acres of Unsuitable (SISS) Post- 1,998.2 – 2,724.0 (4.7% - 6.4%, 1,129.4 (2.7%) 1,689 (4% salvage and fuels) Project salvage and fuels)

100 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 2 Impacts to Alternative 3 Impacts to Alamosa LAU Existing Baseline Suitable Habitat Suitable Habitat

Alternative 2 Impacts to Alternative 3 Impacts to Rito-Archuleta LAU Existing Baseline Suitable Habitat Suitable Habitat

Description Acres (%) Acres (%) Acres (%)

Total Acres 83,778 (100%) 83,778 (100%) 83,778 (100%)

Total Acres of Lynx Habitat 43,047 (48%) 43,047 (48%) 43,047 (48%)

The project may convert The project may convert 1,700.7 – 2,376.3 acres to SISS 1,411.1 acres to SISS (3.3% of (4% – 5.5% of lynx habitat) 33,848 (78.6% of lynx lynx habitat) and up to Acres of Suitable from salvage and up to habitat) approximately 113.1 acres approximately 113.1 acres (0.3%) from hazardous fuels (0.3%) from hazardous fuels treatments treatments

Acres of Unsuitable (SISS) Post- 10,900– 11,688.7 (25.4% - 10,723.5 (24.9% salvage and 9,199.3 (21.4%) Project 27.2%, salvage and fuels) fuels)

Alternative 2 Impacts to Alternative 3 Impacts to Victoria Chama LAU Existing Baseline Suitable Habitat Suitable Habitat

Description Acres (%) Acres (%) Acres (%)

Total Acres 71,806 (100%) 71,806 (100%) 71,806 (100%)

101 CP District-wide Salvage Project Final Environmental Impact Statement

Alternative 2 Impacts to Alternative 3 Impacts to Alamosa LAU Existing Baseline Suitable Habitat Suitable Habitat

Total Acres of Lynx Habitat 44,189 (61.5%) 44,189 (61.5%) 44,189 (61.5%)

The project may convert 269.5 The project may convert 144 – 562.3 acres to SISS (0.6% – 40,177 (90.9% of lynx acres to SISS (0.3% of lynx Acres of Suitable 1.3% of lynx habitat) from habitat) habitat) and no hazardous fuels salvage and no hazardous fuels treatments proposed treatments proposed

Acres of Unsuitable (SISS) Post- 4,282.1 – 4,574.9 (9.7% - 4,012.7 (9.1%) 4,156.7 (9.4%) Project 10.4%)

There are negligible differences between alternatives for salvage within currently unsuitable (SISS) stands.

Southern Rockies Lynx Amendment (SRLA) In October of 2008, the Southern Rockies Lynx Amendment (SRLA) was finalized (USDA Forest Service 2008). The purpose and need for the amendment was to establish management direction that conserves and promotes the recovery of lynx, and reduces or eliminates potential adverse effects from land management activities and practices on national forests in the Southern Rockies, while preserving the overall multiple-use direction in existing plans.

The amendment (SRLA) allows for some possible adverse effects on lynx to occur. By placing certain limits on the activities that could have adverse effects to lynx, the amendment provides for long-term persistence of lynx while accommodating other multiple uses (USDA Forest Service 2008).

The vegetation management direction set forth in the SRLA focuses on conserving the most important components of lynx habitat: a mosaic of young and mature multistory forests with high levels of horizontal cover and coarse woody debris. These components will sustain lynx habitat and the snowshoe hare prey base across all seasons. The standards will be applied for all vegetation management actions in lynx habitat, with exceptions that may be applied. Collectively, application of the standards for vegetation management is expected to minimize adverse effects on lynx and promote the survival and recovery of lynx populations.

Objectives and Standards in the SRLA pertaining to the CP District Wide Salvage Project and how they are addressed are included in Table 33 below:

Table 33. Lynx Objectives, Standards, and Guidelines

Objectives Description Alternative 2 Alternative 3 and Standards

Objective Manage vegetation to mimic or Proposed salvage activities occur Proposed salvage activities occur VEG O1 approximate natural succession in areas close to roads with >80% in areas close to roads with >80%

102 CP District-wide Salvage Project Final Environmental Impact Statement

Objectives Description Alternative 2 Alternative 3 and Standards

and disturbance processes while mortality of the overstory and mortality of the overstory and maintaining habitat components represents approximately 11% of represents approximately 6% of the necessary for the conservation of the spruce-fir on the district. It will spruce-fir on the district. It will lynx. provide a mosaic of habitat ages provide a mosaic of habitat ages and patterns across the landscape. and patterns across the landscape. Tree planting post-harvest will Tree planting post-harvest will promote hare habitat where it promote hare habitat where it

would otherwise be insufficient to would otherwise be insufficient to support snowshoe hare for decades support snowshoe hare for decades or centuries. The small patches that or centuries. The small patches that have regeneration will be protected have regeneration will be protected through the application of PDCs. through the application of PDCs. Additionally, course woody debris Additionally, course woody debris would be maintained within both would be maintained within both the project area and landscape the project area and landscape scales through snag and woody scales through snag and woody debris PDC and minimal potential debris PDC and minimal potential for salvage harvest in the for salvage harvest in the surrounding areas. surrounding areas.

Objective Provide a mosaic of habitat Tree planting post-harvest will Tree planting post-harvest will VEG O2 conditions through time that promote hare habitat where it promote hare habitat where it support dense horizontal cover, would otherwise be insufficient to would otherwise be insufficient to and high densities of snowshoe support snowshoe hare. The support snowshoe hare. The hare. Provide winter snowshoe combination of existing openings combination of existing openings hare habitat in both the stand that support healthy immature that support healthy immature initiation structural stage and in trees, the proposed treatment areas, trees, the proposed treatment areas, mature, multi-story conifer and the existing untreated spruce- and the existing untreated spruce- vegetation. fir stands in the project area fir stands in the project area suggest that a mosaic of habitat suggest that a mosaic of habitat conditions will be provided through conditions will be provided through time. time.

Objective Focus vegetation management in DOES NOT FULLY MEET: While Meets: Alternative 3’s design is VEG O4 areas that have potential to salvage harvest represents 11% of based on this objective, where focus improve winter snowshoe hare the spruce-fir forest in the project is placed on low-quality habitats habitat but presently have poorly area and some project design across the district and subsequent developed understories that lack features are included to aid in the planting will promote future dense horizontal cover. protection of snags and understory habitat. components, alternative 2 represents salvage harvest in all feasible areas and does not

document a design that focuses unit

103 CP District-wide Salvage Project Final Environmental Impact Statement

Objectives Description Alternative 2 Alternative 3 and Standards

placement on lower quality habitats.

Standard If more than 30% of the lynx No LAU is anticipated to exceed This alternative has even less VEG S1 habitat in an LAU is currently in a 30% SISS under this alternative potential to exceed 30% in SISS stand initiation structural stage given estimated post-beetle habitat given that there are fewer proposed that does not yet provide winter conditions and proposed activities salvage activities (Table 32). snowshoe hare habitat, no (Table 32). Monitoring checklists Monitoring checklists will ensure additional habitat may be will ensure compliance with S1 as compliance with S1. regenerated by vegetation more field verification occurs. management projects.

Standard Timber management projects shall Meets: Even assuming under the Meets: Alternative 3 proposes VEG S2 not regenerate more than 15% of maximum treatment scenario of approximately half the salvage lynx habitat on NFS lands within 100% conversion of all proposed harvest as alternative 2 and an LAU in a ten-year period. * salvage in suitable habitat, Conejos similarly will meet this standard. Salvage harvest within stands Canyon LAU would have the Additionally, monitoring and killed by bugs does not add to the highest percentage at compliance checklists will ensure 15%, unless the harvest treatment approximately 14.1% of lynx compliance with S2 changes the habitat to unsuitable. habitat converted in a 10 year period, however no other notable projects have occurred in the prior 10 years and actual regeneration from salvage would be less. Second most is the Alamosa LAU with approximately 13.4% (Table 32). Alamosa LAU was last affected by the Burrow Blowout project, with 330 acres or 1% converted to date. All other LAUs would be well below the standard. Project compliance and monitoring checklists will ensure compliance with S2.

Precommercial thinning is being Precommercial thinning is being conducted under the hazardous conducted under the hazardous Standard Precommercial thinning practices fuels component of the project. fuels component of the project. VEG S5 and similar activities intended to Suitable habitat exists in most of Suitable habitat exists in most of reduce seedling/sapling density are the proposed fuel treatments, the proposed fuel treatments, subject to limitations from the however is not anticipated to however is not anticipated to stand initiation structural stage exceed the 3% WUI exemption or exceed the 3% WUI exemption or until the stands no longer provide additional 1% under exception 5 in additional 1% under exception 5 in winter snowshoe hare habitat. (see any LAU. Of the identified areas, any LAU. Of the identified areas, SRLA implementation guide for approximately 488 acres would approximately 488 acres would exceptions and exemptions). count towards the WUI exemption, count towards the WUI exemption, leaving approximately 403 acres leaving approximately 403 acres

104 CP District-wide Salvage Project Final Environmental Impact Statement

Objectives Description Alternative 2 Alternative 3 and Standards

spread across several LAUs, well spread across several LAUs, well under the 1% cap per LAU under under the 1% cap per LAU under exception 5. Many of the non-WUI exception 5. Many of the non-WUI areas are anticipated to receive areas are anticipated to receive WUI status in future evaluations. WUI status in future evaluations. Monitoring and compliance Monitoring and compliance checklists will ensure compliance checklists will ensure compliance with S5. with S5.

Standard Vegetation management projects Meets: The primary component of Meets: No salvage harvest would VEG S6 that reduce winter snowshoe hare this project is spruce salvage, occur in stands that meet VEG S6. habitats in multi-story mature or which would meet exception 3. late successional conifer forests Hazardous fuels treatments meet Hazardous fuels treatments meet may occur only(VEG S6 the WUI exemption and exceptions the WUI exemption and exceptions Exceptions): would include #1, within 200ft of would include #1, within 200ft of administrative sites or other administrative sites or other structures. structures.

1. Within 200 feet of administrative sites, dwellings, outbuildings, recreation sites, and special use permit improvements, including infrastructure within permitted ski area boundaries; or

2. For research studies or genetic tree tests evaluating genetically improved reforestation stock; or

3. For incidental removal during salvage harvest (e.g., removal due to location of skid trails); or

4. Where uneven-aged management (single tree and small group selection) practices are employed to maintain and encourage multi-story attributes as part of gap dynamics. Project design must be consistent with VEG O1, O2 and O4, except where impacts to areas of dense horizontal cover are incidental to activities under this exception (e.g., construction of skid trails).

105 CP District-wide Salvage Project Final Environmental Impact Statement

Objectives Description Alternative 2 Alternative 3 and Standards

Objective Maintain or restore lynx habitat May meet: Timber harvest Meets: Timber harvest represents ALL O1 connectivity in and between LAUs, represents approximately 11% of approximately 6% of the available and in linkage areas. the spruce-fir on the Conejos Peak spruce-fir forest on the district. RD. While within-LAU connectivity Less harvest in combination with may be limited in some areas, additional connectivity and leave overall the available untreated island PDC’s act to ensure forest should retain sufficient sufficient connectivity within and connectivity across the district. between LAUs. Designated lynx Designated lynx linkage areas are linkage areas are not involved in not involved in the project. the project.

Guideline Vegetation management projects Meets: Due to bark beetles, the Meets: Emphasis of this alternative VEG G1 should be planned to recruit a high spruce-fir zone is experiencing a is in areas where advanced density of conifers, hardwoods, shift towards stand initiation regeneration is scarce. Due to bark and shrubs where such habitat is structural stage. Salvage logging beetles, the spruce-fir zone is scarce or not available. Priority for may have some impacts to existing experiencing a shift towards stand treatment should be given to stem- regeneration where higher initiation structural stage. Salvage exclusion, closed-canopy structural densities occur within these stands, logging would aid in assisting to stage stands to enhance habitat however it would aid in assisting to pay for subsequent planting where conditions for lynx or their prey pay for subsequent planting where needed. Minimal, if any, salvage (e.g. mesic, monotypic lodgepole needed. Minimal, if any, salvage would occur in older plantations stands). Winter snowshoe hare would occur in older plantations that currently provide high-quality habitat should be near denning that currently provide high-quality hare habitat. habitat. hare habitat.

Guideline Prescribed fire activities should Not Applicable: Apart from pile Not Applicable: Apart from pile VEG G4 not create permanent travel routes burning, there are no prescribed burning, there are no prescribed that facilitate snow compaction. fire activities described as part of fire activities described as part of Constructing permanent this project. Pile burning would not this project. Pile burning would not firebreaks on ridges or saddles should be avoided. influence travel routes. influence travel routes.

Guideline Habitat for alternate prey species, Meets: While some impacts to red Meets: While some impacts to red VEG G5 primarily red squirrel, should be squirrels is anticipated due to squirrels is anticipated, emphasis provided in each LAU. incidental damage or blowdown, of the alternative is on stands that salvage harvest focuses on dead do not provide quality red squirrel trees. Sufficient refugia is likely to habitat while protecting areas that occur outside of the harvest units do. Areas excluded from harvest and in residual green trees would provide refugia for red throughout the project area. squirrels while other stands regenerate.

106 CP District-wide Salvage Project Final Environmental Impact Statement

Objectives Description Alternative 2 Alternative 3 and Standards

Guideline Fuel treatment projects within the Meets: Fuels treatments within the Meets: Fuels treatments within the VEG G10 WUI as defined by HFRA should WUI are anticipated to minimally WUI are anticipated to minimally be designed considering Standards impact lynx habitat and the SRLA impact lynx habitat and the SRLA VEG S1, S2, S5, and S6 to promote Standards. Standards. lynx conservation.

Guideline Denning habitat should be Meets: Denning habitat is not Meets: Beyond Alternative 2, this VEG G11 distributed in each LAU in the limiting on the RGNF (Squires, J., alternative excludes from harvest form of pockets of large amounts Pers. Comm.). Much of the modeled areas that may be used by denning of large woody debris, either down denning habitat occurs outside of lynx and limits harvest in high- logs or root wads, or large piles of proposed harvest units, largely due quality foraging areas on which small wind thrown trees (“jack- to slope limits on equipment. denning females may rely upon. strawed” piles). If denning habitat Additionally, this project would appears to be lacking in the LAU, only affect a small portion of the then projects should be designed to available spruce-fir stands on the retain some coarse woody debris, district, leaving much of the spruce- piles, or residual trees to provide fir zone unaffected. CWD would be denning habitat in the future. retained in abundance in these areas.

Effects Determination Summary It is my determination that the proposed action under Alternative 2 “May affect, and is likely to adversely affect” Canada lynx for the following reasons:

• Habitat within the proposed treatment units includes high-quality lynx habitat that may be converted to lower quality habitat. • Presence of lynx is determined to be likely or otherwise known. • Although effects on lynx are expected, Standards and Guidelines within the SRLA will continue to be met within the LAU. • Potential human disturbance associated with implementation of the project will occur for a limited period of time (weeks or months depending on size of unit and harvesting efficiency). • The project is not located within a lynx linkage area. • There will be a change to the Environmental Baseline within the LAUs as the result of the project, however, all LAUs are anticipated to meet the Conservation Measures and management direction within the SRLA and the conditions of the programmatic concurrence.

It is my determination that the proposed action under Alternative 3 “May affect, and is likely to adversely affect” Canada lynx for the following reasons:

• Habitat within the proposed treatment units are of lower quality, suggesting that potential effects to lynx from silvicultural treatments may be reduced as compared to Alternative 2. • Evidence of snowshoe hares is rare within low-quality lynx habitat suggesting that potential effects on primary prey species from silvicultural treatments may be reduced. • Lynx use of the proposed treatment units is likely to occur but concentrated use is presumed to be low. • Standards and Guidelines within the SRLA will continue to be met within the LAU.

107 CP District-wide Salvage Project Final Environmental Impact Statement

• Potential human disturbance associated with implementation of the project will occur for a limited period of time (weeks to months), however the effects are presumed to be less as concentrated use areas would have reduced silviculture treatments. • The project is not located within a lynx linkage area. • There will be a change to the Environmental Baseline within the LAUs as the result of the project, however, all LAUs will continue to meet the Conservation Measures and management direction within the SRLA and the conditions of the programmatic concurrence.

As provided in 50 CFR §402.16, re-initiation of consultation is required where discretionary Federal agency involvement or control over the action has been retained (or is authorized by law) and if: (1) the amount or extent of incidental take is exceeded; (2) new information reveals effects of the agency action that may affect listed species or critical habitat in a manner or to an extent not previously considered; (3) the agency action is subsequently modified in a manner that causes an effect to the listed species or critical habitat not previously considered; or (4) a new species is listed or critical habitat designated that may be affected by the action.

Table 34. Effects determination for Threatened, Endangered and Proposed species

Species Determination Rationale PDFs Canada lynx (T) May Affect, >8,000 acres of lynx habitat may be affected by See App. Lynx canadensis Likely to the project, including in areas known to harbor A Adversely Affect breeding lynx. However, the project only proposes to harvest in 11% of the spruce forest type on the district as a maximum under Alternative 2. Mexican spotted owl (T) No Effect No habitat within project area. N/A Strix occidentalis lucida Southwestern willow No Effect No habitat within the project area. N/A flycatcher I Empidonax trailii extimus Uncompahgre No Effect No habitat within the project area. N/A fritillary butterfly I Boloria acrocnema New Mexico Jumping No Effect No habitat within the project area. N/A Meadow Mouse I Zapus Hudsonius Luteus Yellow-Billed Cuckoo No Effect No habitat within the project area. N/A (T) Coccyzus americanus Gunnison Sage-Grouse No Effect No habitat within the project area. N/A (T) Centrocercus minimus North American No Effect Not known to occur in Colorado, let alone the N/A Wolverine (P) project area. Gulo gulo luscus

Analysis of Effects to Sensitive Species Pre-field reviews and habitat analysis determined that suitable habitat exists for nine sensitive species within the project area (western bumble bee, boreal toad, leopard frog, northern goshawk, boreal owl, flammulated owl, olive-sided flycatcher, American marten, and hoary bat). These nine species are further analyzed for the Conejos Peak District Wide Salvage Project. While species specific presence/absence surveys did not occur

108 CP District-wide Salvage Project Final Environmental Impact Statement

for most species or in all areas, surveys will occur prior to implementation in order to inform application of project design features. Survey results will be documented on project checklists and in the project file.

Species having no suitable habitat and/or have no reasonable probability of occurring within or near the salvage units are not analyzed in further detail. This project will have no impact on these species which include: the Great basin silverspot butterfly, Monarch butterfly, Ferruginous hawk, Northern harrier, Sage sparrow, Brewer’s sparrow, Lewis’s woodpecker, Peregrine falcon, Loggerhead shrike, White-tailed ptarmigan, Mountain plover, Burrowing owl, Black swift, Townsends’s big-eared bat, fringed myotis, Gunnison’s prairie dog, Bighorn sheep and River otter.

Spatial and Temporal Context The spatial analysis area varies by species and reflects the area within which the species could be directly or indirectly affected by the action (see ‘action area’ 50 CFR 402.2). For the goshawk, for instance, the analysis area consists of the treatment areas (footprint of project activities) plus a distance representing a median home range (1.0 miles around known goshawk nests).

Temporal bounding for the analysis is both short-term and long-term. Short-term consists of the time required for project implementation and the time in which vegetation begins to respond to treatments (ten to fifteen years of project implementation). Long-term extends to as much as 100 years into the future (canopy establishment).

Effects of Alternative 1 on Sensitive Species Effects to species are dependent on habitat needs and the timeframe involved. Species requiring mature, late- successional spruce-fir habitat are anticipated to decline in abundance and distribution forest-wide as a result of the beetle outbreak and other subsequent timber salvage projects. These include species such as the boreal owl, brown creeper, and American marten. Species experiencing negligible or minor effects may include the northern goshawk and olive-sided flycatcher. The northern goshawk rarely nests within the spruce-fir zone and nest trees are typically in aspen. While some negative effects to foraging habitat and some prey species may occur over time, the goshawk is a mature-forest generalist and is anticipated to adapt to the changed condition. The olive-sided flycatcher prefers openings within the spruce-fir zone, and thus may benefit from the changing conditions. While the forest structure is anticipated to close in the next 30-50 years, species that require forest openings or open canopy stands would generally benefit in the short- to mid-term as sunlight hitting the forest floor increases. Species such as the western bumble bee may benefit from the increase in flowering plants. Other species like elk or deer may benefit from the increased available forage in the short- to mid-term.

One important consideration for the effects of no action is timeframe. While the beetle outbreak spread quickly across the forest, impacts to stand structural conditions are more gradual. Individuals and populations have time to adapt, and over time the stand conditions are anticipated to be more varied in age classes, structural complexity, and species composition than current conditions.

109 CP District-wide Salvage Project Final Environmental Impact Statement

Effects of Action Alternatives 2 and 3 on Sensitive Species Table 35. Effects of Alternatives 2 and 3 on sensitive species where presence is documented or presumed and suitable habitat occurs within or near the proposed action

Species Determination Rationale INSECTS May Impact Individuals, but is Project activities could result in limited short- not likely to cause a trend towards Western Bumble Bee term loss of flowering plants during harvest Federal listing or result in loss of Bombus occidentalis activities. Net gain in understory productivity viability in the planning area. and flowering plants the long-term. Long-term beneficial. AMPHIBIANS No known populations nearby and treatment Boreal toad No measurable effect. areas are not in close proximity to standing Bufo boreas boreas water. Incredibly rare on district, though one known Northern leopard frog population close to a proposed treatment area. No measurable effect. Rana pipiens Project design and PDC would result in negligible impacts to the species. BIRDS There is a remote possibility that nesting birds May Impact Individuals, but is could be temporarily displaced and may possibly Boreal owl not likely to cause a trend towards abandon nests due to project activities. Some Aegolius funereus Federal listing or result in loss of loss of nesting and foraging opportunities within viability in the planning area. the treatment area. May Impact Individuals, but is Flammulated owl not likely to cause a trend towards Project activities could result in limited Otus flamineolus Federal listing or result in loss of disturbance to this species. viability in the planning area. There is a remote possibility that nesting birds May Impact Individuals, but is could be temporarily displaced and may possibly Northern goshawk not likely to cause a trend towards abandon nests due to project activities. Some Accipter gentiles Federal listing or result in loss of loss of nesting and foraging opportunities within viability in the planning area. the treatment area. May Impact Individuals, but is Olive-sided flycatcher not likely to cause a trend towards Project activities could result in limited Contopus borealis Federal listing or result in loss of disturbance to this species. viability in the planning area. MAMMALS May Impact Individuals, but is There is a remote possibility that denning American marten not likely to cause a trend towards individuals could be impacted. Some loss of Martes Americana Federal listing or result in loss of denning and foraging opportunities within the viability in the planning area. treatment area. May Impact Individuals, but is Hoary Bat not likely to cause a trend towards Project activities could result in limited Lasiurus cinereus Federal listing or result in loss of disturbance to this species. viability in the planning area.

Effects to Management Indicator Species The Forest Plan, as amended, contains nine Management Indicator Species (MIS). All MIS with habitat in the analysis area that could be potentially impacted by the project were evaluated. MIS species not addressed either have no habitat in the area or have limited habitat and are not expected to be impacted by the project. Such species include pygmy nuthatch, Wilson’s warbler, Lincoln’s and vesper sparrows. The rationale for level of analysis of MIS for this project is summarized below, followed by a more detailed discussion in the Wildlife specialist report.

110 CP District-wide Salvage Project Final Environmental Impact Statement

Table 36. Summary of effects to Management Indicator Species by Alternative 2

SPECIES Proposed Action

BIRDS Mature to late successional spruce/fir and mixed conifer Brown Creeper To assist in Disturbance and displacement could occur from human activities on monitoring whether Forest Plan 18,000 acres (2.8%) of the Forests potential habitat. Some nest destruction standards and guidelines for could also occur. Some mature green trees will remain. Individuals may biodiversity are being met, with disperse into other nearby habitat due to significant structural change in an emphasis on snag the treatment area. No discernable effect on population persistence or management. viability at the Forest Level. Hermit Thrush To assist in Disturbance and displacement could occur from human activities on monitoring whether Forest Plan 18,000 acres (2.8%) of the Forests potential habitat. Some nest destruction standards and guidelines for could also occur. Some mature green trees will remain, however, biodiversity are being met, with individuals may disperse into other nearby habitat due to significant an emphasis on coarse woody structural change in the treatment area. No discernable effect on debris. population persistence or viability at the Forest Level. MAMMALS Elk – To assist in monitoring Activities will most likely result in temporary displacement or temporary whether Forest Plan standards and changes in elk behavioral patterns. This displacement is expected to be guidelines are being met for short term with elk use returning to the same level or even greater level wildlife, with an emphasis on due to an increase in forage quality and quantity. Open road density under roads. the proposed action will remain the same as if no action were taken; therefore the proposed action is not expected to have any lasting effect on habitat effectiveness. There would be no discernable change in population trends at the DAU level. Mule Deer – To assist in Activities will most likely result in temporary displacement or temporary monitoring whether Forest Plan changes in mule deer behavioral patterns. This displacement is expected standards and guidelines are to be short term with use returning to the same level or even greater level being met with an emphasis on due to an increase in early successional forage quality and quantity. There management issues that influence would be no discernable change in population trends at the DAU level. the early successional plant communities.

Migratory Birds Neotropical migratory land birds (NTMB) are those that breed in the U.S. and winter south of the border in Mexico, Central and South America. Resident landbirds include those that remain during the winter period, or move to winter habitats that occur primarily within the U.S. border. Direction concerning land bird conservation in Forest Service Region 2 is to reference the 2008 Birds of Conservation Concern list produced by the U.S. Fish and Wildlife Service for Bird Conservation Regions (BCRs) when completing National Environmental Policy Act (NEPA) evaluations for project activities. Furthermore, Forest Service units are encouraged to interface with the State and Bird Conservation Region working groups for actions and objectives to pursue concerning migratory bird conservation. Bird Conservation Regions consist of a hierarchical framework of nested ecological units that allow for the use of multiple scale-specific approaches to on-the-ground management. Bird Conservation Regions encompass areas that become progressively more ecologically similar as the units are stepped-down to a smaller scale. At the smallest and most local scale, the physiographic area is used for bird conservation efforts. State groups such as local Partners-In-Flight Chapters are the primary workforce involved with translating the BCR information into conservation action at the local scales. 111 CP District-wide Salvage Project Final Environmental Impact Statement There are 37 BCRs in North America with four of these occurring at least partially in Colorado. The Rio Grande National Forest occurs within the Southern Rockies Colorado Plateau Bird Conservation Region (BCR 16), which encompasses portions of Colorado, New Mexico, Arizona, Utah and Wyoming. Information from BCR 16 was synthesized for use in Colorado through the development of the Birds of Conservation Concern list and the Colorado Landbird Conservation Plan (Beidleman 2000, Rich et al. 2004). Thus, at the finest scale of analysis, the Rio Grande National Forest occurs within the Southern Rocky Mountains Physiographic Area (Area 62) of the Southern Rockies Colorado Plateau Bird Conservation Region. The following table displays the Birds of Conservation Concern for BCR 16, their status within the project area, and projected influence from the Conejos Peak District Wide Salvage Analysis.

Table 37. FWS Birds of Conservation Concern for BCR 16 and the anticipated influence of the action and no action alternatives on their conservation needs (USFWS 2008)

Species General Habitat Occurrence in Effect of Alternatives Analysis Area Northern Harrier Grasslands Yes (observed Evaluated as an R2 sensitive species; No during fall Effect (No habitat present). migration @ Red Lake) Swainson’s Hawk Grasslands Yes, several Several known high-elevation known territories may be impacted by territories @ project activities. record high elevations Ferruginous Hawk Prairie No Evaluated as an R2 sensitive species; No Effect (No habitat present) Golden Eagle Cliffs/grasslands Possible, No Effect; No known nests in the area. wide ranging Only spruce-fir zone impacted. Peregrine Falcon Cliffs No Evaluated as an R2 sensitive species; No Effect. Prairie Falcon Cliffs No No Effect. (No known nests near project areas). Gunnison sage- Sagebrush No Evaluated as an R2 sensitive species; No grouse Effect (No habitat). Snowy Plover Shorelines No No Effect (No habitat present) Mountain Plover Prairie No Evaluated as an R2 sensitive species; No Effect. (No habitat present). Solitary Sandpiper Shorelines No No Effect (No habitat present). Marbled Godwit Wetlands No No Effect (No habitat present). Wilson’s Waterbodies/Shorelines No No Effect (No habitat present). Phalarope Yellow-billed Deciduous Riparian No Evaluated as an FWS TEP species; No Cuckoo Effect. (No habitat present). Flammulated Ponderosa pine/snags Possible Evaluated as an R2 sensitive species; Owl May Affect. Burrowing Owl Plains/grasslands No Evaluated as an R2 sensitive species; No Effect. (No habitat present) Short-eared Owl Parks/grasslands No No Effect. (No habitat present). Black Swift Waterfalls/wet cliffs No Evaluated as an R2 sensitive species; No Effect. (No habitat present) Lewis’s Riparian Cottonwood No Evaluated as an R2 sensitive species; No Woodpecker Effect (No known occurrences. Williamson’s Montane forests/snags Possible May Effect. Potential for direct Sapsucker mortality and disturbance. Gray Vireo Oak woodlands/scrub No No Effect. (No habitat present). Pinyon Jay Pinyon/Juniper No No Effect. (No habitat present).

112 CP District-wide Salvage Project Final Environmental Impact Statement

Species General Habitat Occurrence in Effect of Alternatives Analysis Area Bendire’s Rare spp of arid areas No No Effect. (No habitat present). Thrasher Crissal Thrasher No records in CO. No No Effect. (No habitat present). Sprague’s pipit No records in CO. No No Effect. (No habitat present). Virginia’s warbler Riparian shrub No No Effect. Species occurrence unlikely and no impact upon this habitat type. Black-throated Oak scrub/riparian No No Effect. (No habitat present). gray warbler Grace’s warbler Ponderosa pine No No Effect. (No habitat present). Sage sparrow Sagebrush No No Effect. (No habitat present). Chestnut-collared Plains No No Effect. (No habitat present). longspur

The Colorado Landbird Conservation Plan identified priority species and habitats for each physiographic area in the state based on the Partners-In-Flight Species Prioritization Process (Beidleman 2000, Rich et al. 2004). Priority habitats identified for the Southern Rocky Mountains Physiographic Area include alpine tundra, aspen, cliff/rock, high elevation riparian, lowland riparian, mixed-conifer, mountain shrubland, ponderosa pine, sagebrush shrubland, spruce-fir, and wetlands. Several of these habitat types occur within the project area (aspen, high elevation riparian, mixed conifer, spruce fir, alpine tundra, cliff/rock, etc.), with only spruce-fir and a minor aspen occurring within the treatment area. The priority habitats and species that occur within the project area are included below.

Table 38. Priority habitats and species of the Southern Rocky Mountains province and their relationship to the CP District-wide Salvage Project Area

Priority Habitat BCP Priority Species BCP Potential Issues(s) Potential Effect of Type Influence Alternatives from Project Activities Alpine Tundra White-tailed ptarmigan Fragile habitats; N/A Priority habitat is not present in American pipit Specialized Species. the proposed treatment areas. Brown-capped rosy finch Aspen Red-naped sapsucker Grazing, snag habitat, YES Decrease in snags surrounding Purple martin Altered disturbance aspen and potential for direct Violet-green swallow regimes mortality in spruce snags. Project will benefit aspen in the long- term. Cliff/Rock Peregrine falcon Rock climbing; mining N/A Priority habitat is not present in Black swift the proposed treatment areas. High Cordilleran flycatcher Grazing, Recreation No major Minimal influences anticipated Elevation American dipper impacts issues overall because riparian areas are Riparian MacGillivray’s identified protected by PDC’s and are not proposed for treatment. Some warbler Wilson’s from the edge influence from nearby warbler proposed harvest areas. project. Lowland Lewis’ woodpecker Development, roads, N/A Priority habitat is not present in Riparian Lazuli bunting grazing, recreation the proposed treatment areas. Mixed Conifer Dusky grouse Altered disturbance Possible Decrease in snags in nearby Williamson’s regimes, snags, timber spruce-fir, no anticipated impacts sapsucker 113gmt.. to mapped mixed-conifer stands. Mountain Virginia’s warbler Recreation, development, N/A Priority habitat is not present in shrubland Green-tailed towhee fire, grazing. the proposed treatment areas.

113 CP District-wide Salvage Project Final Environmental Impact Statement

Priority Habitat BCP Priority Species BCP Potential Issues(s) Potential Effect of Type Influence Alternatives from Project Activities Ponderosa Band-tailed pigeon Timber 114gmt.., snags, N/A Priority habitat is not present in Pine Flammulated owl altered disturbance the proposed treatment areas. Mexican spotted owl regimes, prescribed fire Lewis’s woodpecker Grace’s warbler Sagebrush Sage-grouse Conversion of sagebrush, N/A Priority habitat is not present in Shrubland Brewer’s sparrow grazing. the proposed treatment areas. Sage sparrow

Spruce/Fir Boreal owl Timber 114gmt.., snags, YES Boreal Owl and Flycatcher Olive-sided flycatcher altered disturbance Evaluated as R2 sensitive species; Hammond’s flycatcher regimes May Impact individuals. Hammonds flycatcher = decrease in snags/mature spruce-fir and potential for direct mortality. Wetland Willet Wetland loss, N/A Priority habitat is not present in Short-eared owl development the proposed treatment areas.

Summary of Effects of Alternatives on Migratory Birds There are no major issues identified to the High Elevation Riparian group as a result of the Project as most project activity does not occur in this habitat type and existing Project Design Features are in place protecting riparian areas. Forest Plan Standards and Guidelines are in place to further protect and provide guidance for migratory birds including Forest Plan Standard 21: “Consider the effects of proposed management activities (forest and rangeland management, prescribed and wildland fire use, recreation, etc.) on resident and migratory birds. Incorporate conservation measures and principles, as appropriate, from local bird conservation plans (NABCI) and/or other references into project designs so that adverse effects are minimized.”

The Red-Naped sapsucker, Purple martin, Violet Green swallow, Dusky grouse, Williamson’s sapsucker and Hammond’s Flycatcher are species of migratory birds not already addressed in the Wildlife Report under another wildlife grouping. These species are typically found in aspen (Red-naped, purple martin and violet green swallow) mixed conifer (Dusky grouse) and spruce fir (Hammond’s flycatcher) habitat types.

A decrease in snag habitat, decrease in post-disturbance structural complexity, and potential for direct mortality mainly upon nestlings is likely for these species from salvage logging. However, project design features are in place to protect snags and protect known active bird nests/cavities to reduce this potential threat. Some benefits of spruce beetle include the potential for additional forage for some species (Dusky grouse) as reduced cover means increased light hitting the forest floor with a subsequent flush in vegetation. Activities associated with the project – May Impact Individuals, but is not likely to cause a trend towards Federal listing or result in loss of viability in the planning area. There may be beneficial impacts to ground- nesting birds, such as grouse, due to an increase in understory shrub cover and blowdown or slash creating increased nesting opportunities.

These species will continue to be tracked in the Monitoring Colorado’s Birds (MCB) Program, which includes transects on the Rio Grande National Forest, to determine population trends over time. Cumulative Effects Foreseeable future activities within and adjacent to the project area are discussed in detail in the Direct and Indirect Effects to Threatened and Endangered Species subsection of section 3.4, Wildlife. Future federal activities include: Fuelwood gathering, grazing, recreation, and other minor permitted activities. The CP7 Cattle and Horse Allotment Project is concurrently moving forward and the proposed action will be adaptive

114 CP District-wide Salvage Project Final Environmental Impact Statement and respond to resource conditions on the ground. It is expected that allotment conditions would improve with this project. Another upcoming proposal is the Trail Gulch project, which is very early in the planning stages. As previously stated for Threatened and Endangered species, including lynx, foreseeable future activities and activities adjacent to the project area are anticipated to have negligible impacts on sensitive species, management indicator species and migratory birds.

3.5 Aquatics and Fisheries Scope of Analysis The proposed activities associated with the CPDWS Project require a Biological Evaluation (BE) and Management Indicator Species (MIS) report to determine potential effects on endangered, threatened, proposed, and sensitive aquatic species (FSM 2672.42). The BE is intended to document the steps necessary to ensure a proposed management action will not likely jeopardize the continued existence or cause adverse modification of habitat for aquatic species listed or proposed to be listed as endangered or threatened by the US Department of Interior (USDI) Fish and Wildlife Service nor contribute to the loss of viability for species listed as sensitive by the USDA- Forest Service Region 2; nor cause any species to move toward federal listing (FSM 2672.41 and R2 Supplement 2600-2015-1). The BE also ensures that recommendations to reduce negative impacts for sensitive aquatic species are incorporated into the NEPA process, as well as opportunities for habitat enhancement. There are no federally listed or proposed fish species present in the project area so no Biological Assessment (BA) or Section 7 consultation is needed.

The Management Indicator Species (MIS) Report evaluates the potential effects of vegetative management treatments on aquatic MIS within the project area in relationship to the diversity objectives and Standards & Guidelines in the Rio Grande National Forest Land and Resources Management Plan (Forest Plan). Input required to meet MIS objectives and Forest Plan Management direction is provided in more detail within the Fisheries Specialist Report and can be found in the project record. Existing Condition Major perennial streams within the project area include the Conejos River, Alamosa River, and the Rio de Los Pinos. Many other smaller streams are within the analysis area and have varying fisheries values depending on flows and elevation. There are numerous other small intermittent/ephemeral channels within the analysis area that do not sustain adequate flows to support a viable fishery but may have other riparian habitat values.

Access into and through the analysis area is via the primary Level 3 roads that are considered suitable for passenger cars and Level 2 roads more suitable for high-clearance vehicles. Both road levels are comprised of native surface material although Level 3 roads also often contain gravel. There are approximately 365 miles of system roads within the project area. Road systems in the project area often follow stream channels and are a primary concern for sedimentation delivery to stream systems. The road density for each watershed varies from 0.4 miles/square mile in the Elk Creek watershed to 2.5 miles/square mile in the Bighorn Creek and Fox Creek watersheds.

Riparian areas that support aquatic habitats occur on approximately 14% of the CPDWS project area. Many of these areas in particular have a history of grazing and road-related impacts to aquatic habitats (see Watershed section). However, current baseline information suggests that most perennial streams and riparian areas within the project area are considered to be in fair to good condition, with an upward improving trend noted in most areas. Still, current impacts are evident with grazing and sediment-related road issues a primary concern.

Species information is based on the Update to the 1996 Revised Forest Plan Biological Evaluation in Support of the MIS Amendment (USDA Forest Service 2003a), Rio Grande Cutthroat Trout Species Assessment (USDA

115 CP District-wide Salvage Project Final Environmental Impact Statement Forest Service 2003b; USFWS 2014); USFS Technical Conservation Assessments and other information for Rio Grande Cutthroat Trout (Oncorhynchus 116larkia virginalis), Rio Grande Sucker (Catostomus plebeius), and Rio Grande Chub (Gila 116larkia) (CPW 2017; Bestgen, et al. 2003; Fausch, et al. 2006; Reese et al. 2005; Reese and Miller 2005; Zuckerman and Langlois 1990); Conservation Agreement for Rio Grande Cutthroat Trout (RGCT Conservation Team 2013a); Rio Grande Cutthroat Trout Conservation Strategy (RGCT Conservation Team 2013b); Colorado Division of Wildlife Fisheries Inventories; Range-wide Status of Rio Grande Cutthroat Trout (Alves, et al. 2007); Inland Cutthroat Trout Viewer/Editor database (2017) and internal records, documents, and field surveys.

Three USFS Region 2 sensitive fish species occur on the Rio Grande National Forest. The status of these species in relationship to the CPDWS Project is displayed below in Table 39.

Table 39. Region 2 Sensitive fish species and their relationship to the CP District-wide Salvage Project

Suitable Species habitat documented Sensitive Fish Species within the within the Basic Habitat Description analysis analysis area? area? Rio Grande Cutthroat Yes Yes Streams, rivers and lakes. Most frequently Trout found in headwater streams. Oncorhynchus 116larkia virginalis Rio Grande Chub No No Flowing pools of headwaters, creeks and Gila pandora small rivers, often near inflow of riffles and in association with cover such as undercut banks and plant debris. Rio Grande Sucker Yes Yes Pools, runs and riffles of small to moderately Catostomus plebeius large streams; usually over gravel and/or cobble.

Existing information indicates that two R2 sensitive fish species – the Rio Grande Cutthroat Trout and Rio Grande Sucker – occur within the analysis area and may be influenced by activities associated with the action alternatives. These species will be analyzed in detail in the biological evaluation. The Rio Grande Chub is not present and the analysis area is outside the estimated historical range for this species. Therefore, there will be No Impact on Rio Grande Chub or its habitat and no further evaluation is warranted. Self-sustaining non-native trout populations are also found in the perennial streams throughout the analysis area. When not in conflict with native fish objectives, these populations are of high-value to local communities from a recreational fishery standpoint.

Local Survey/Occurrence Information – Rio Grande Cutthroat Trout Core and Conservation populations of RGCT are typically restricted to smaller 6th and 7th-level streams and occupy approximately 154 miles in 30 streams and 14 surface acres in 3 lakes on the Rio Grande National Forest (Alves et al. 2007). Core populations are >99% genetically pure and represent the historic genome of the native trout. Conservation populations are self-sustaining RGCT populations that are >90% genetically pure and are managed at the same conservative level as core populations. Several recreational RGCT populations also occur within the CPDWS, but are not part of conservation planning for the species and are not discussed in detail further. There are seven Core RGCT populations and one Conservation RGCT population within the CPDWS project area. Core Conservation populations of RGCT are found in Jim Creek, Torsido Creek, Lake Fork Conejos River, Rio de Los Pinos, Wolf Creek, Cascade Creek, and Osier Creek. One Conservation population of RGCT

116 CP District-wide Salvage Project Final Environmental Impact Statement is found in Rhodes Gulch. A full discussion of these occurrences is in the Aquatics and Fisheries Report for this project. Some fish populations within the project area appear to be affected by alterations in habitat conditions resulting in changes in population numbers, density, and biomass. Populations in Lake Fork Conejos River, Wolf Creek, and Rhodes Gulch may have been impacted by timber management. Roads, permitted livestock, and other large ungulate use (i.e. elk, moose, and deer) have impacted some sections of the riparian areas leading to increased stream sedimentation from runoff and bank degradation in all populations. Concerns for Jim Creek, Torsido Creek, and Wolf Creek continue because of the presence of non-native trout and/or failed barriers, while overall stream condition in these streams appear to be good with only isolated areas of concern and habitat does not appear to be a limiting factor for their continued existence. Baseline conditions for RGCT in the analysis area also involve the presence of nonnative trout that had been stocked historically. Brook Trout and/or brown Trout currently can be found co-existing with Core RGCT populations in Jim, Torsido, and Wolf creeks. These nonnatives can pose a threat to RGCT existence due to competition for space and food. Fish stockings and angling can also increase the risk of introduction of various fish diseases (whirling disease, bacterial kidney disease, etc.) and invasive species (e.g., zebra mussels). The CPDWS Project do not have applicability to interactions between RGCT and non-native species, and other focused fisheries related projects will be required to address this issue in the future. Concerns for Jim Creek, Torsido Creek, and Wolf Creek continue because of the presence of non-native trout and/or failed barriers, while overall stream condition in these streams appear to be good with only isolated areas of concern and habitat does not appear to be a limiting factor for their continued existence.

Local Survey/Occurrence Information – Rio Grande Sucker Rio Grande Sucker (RGS) are known to occur in 12 streams within the Rio Grande Basin in Colorado. Only three of these streams are historic self-sustaining populations (none on Forest), the remaining populations were initially reestablished through stockings. Historic populations rarely occurred higher than 8,200 feet in elevation. Eight of the attempts for reestablishment were located on the Rio Grande National Forest, including Cascade Creek, Osier Creek, and Lake Fork Conejos River. Of these, only the population in the Lake Fork Conejos River remains. Rio Grande Sucker have been introduced into Lake Fork Conejos River within the CPDWS project area. Rio Grande Sucker have been stocked into this stream in 2005, 2007, 2015, and 2016, with another stocking in 2017. Rio Grande Sucker are only present between Big Lake and the barrier just above Rock Lake. Multiple age classes have been observed, including young of year indicating successful spawning and recruitment. Similar to RGCT, RGS in Lake Fork Conejos River have been or potentially impacted by many of the same issues including livestock grazing, mining and road construction/maintenance, which negatively impact riparian habitat and increases sedimentation (CPW 2003, 2005, 2017). Impacts to riparian and instream habitat from grazing, mining and road construction/maintenance can reduce instream and overhead cover and increase sedimentation, which in turn can reduce food availability, impact instream habitat and increase stream temperatures (Reese, et al. 2005). Direct and Indirect Effects Alternative 1 – No Action Under the No Action alternative, an improving trend in aquatic habitat is likely to continue assuming that grazing management improvements and road drainage projects continue to be implemented and are successful. However, issues involving aquatic habitats remain in some areas and have the potential to prolong impacts to existing RGCT reproduction and population recruitment.

Native surface roads along the streams and within the riparian corridors are a primary influence on aquatic habitats in the CPDWS project area. Existing culverts and stream crossings also contribute to aquatic habitat issues within the analysis area, and can be estimated by existing road density. Existing road density by watershed varies from a low of 0.7 miles/square mile in the Headwater La Jara Creek watershed (Jim Creek

117 CP District-wide Salvage Project Final Environmental Impact Statement and Torsido Creek) to 1.7 miles/square mile in the Lake Fork of Conejos River watershed, the latter of which is of primary concern for both RGCT and RGS. The No Action alternative would not contribute to these issues through additional disturbance associated with timber harvest and log haul. From a spatial and temporal point of view, this alternative may have both positive and negative influences on aquatic habitats for fisheries. For example, the amount and distribution of standing dead and dying trees in various forest cover types may have the potential to influence physical attributes involving water flow and timing, thus increasing stressors on the fisheries resource during times of drought and late season flows. However, the potential effects associated with the loss of live tree basal area may be somewhat offset by increased growth in forest understory vegetation and riparian vegetation. Also, dead and dying trees along the riparian corridor will provide a source for large wood contributions to the stream and floodplain which is important for many aquatic species including trout and macroinvertebrates. Very high stand-level mortality rates can lead to increased runoff and higher flows which can increase streambank instability and rates of soil erosion if streambanks are not in good condition, although as stated in section 3.7, Hydrology and Watershed, detectable changes in water yield are generally, not of concern. Increased sediment loading in the streams could lead to loss of spawning and overwintering pool habitat which could be detrimental to trout and aquatic insects which are important as a food source (Samman and Logan 2000). Thus, streambank stability as related to on- going activities and background sediment transport from native surface roads is important to aquatic habitat resiliency in response to forest health changes from insect and disease outbreaks and/or management responses. Baseline conditions associated with existing forest vegetation concerns noted in section 3.2, Silviculture and Forest Products, also have implications for increased fuel loads that may be considered uncharacteristic for lower to mid-elevation fire regimes.

Thus, although downed wood contributions to streams and floodplains can be beneficial to aquatic habitat values for fisheries, high tree densities and fuel loads can contribute to increased wildfire severity. Wildfires are a natural disturbance in the watersheds and their behavior and intensity can have a detrimental effect on stream conditions and fish populations. Floods following fires can contribute large amounts of ash and debris into stream channels resulting in fish kills and changes in stream channel geomorphology. Current baseline conditions suggest that a large portion of the analysis area may contribute to a moderate to high risk for wildfire and debris flows (see Appendix A: RGCT Wildfire Risk Assessment in the Fisheries BE and project folder (Nature Conservancy 2013)). Under the No Action alternative, fuel load trends associated with these risks may be expected to continue until a wildfire eventually does occur on a landscape scale. Alternative 2 – Proposed Action Project design does not allow mechanical treatments to take place on slopes steeper than 40%, and most proposed harvest activities are outside of the Water Influence Zone (WIZ) of most of the fish bearing streams and should therefore have minimal direct effect on the fishery resources, or potential RGCT habitat, within the project area. However, the potential for indirect effects from sedimentation that may influence aquatic habitats and fish-bearing streams is considered moderate under this alternative. This is due to the increase in activities in some watersheds, especially those with RGCT including Lake Fork Conejos River, which is estimated to have up to 39% of the watershed planned for treatment. In addition, disturbance will increase due to previously closed roads that will be opened to access the harvest areas, landings, log haul, burn areas, and other activities associated with Alternative 2. Forest Plan Standards & Guidelines and PDC associated with Alternative 2 (and all action alternatives) are intended and expected to minimize potential influences. However, the amount of activity proposed under Alternative 2 suggest a higher risk of negative influence which in turn will require increased sale administration, monitoring, and quick mitigation response in various weather conditions over several years of activity. A primary means of meeting riparian and aquatic habitat objectives in Alternative 2 and all action alternatives involves the protections expected to be provided by buffers associated with the WIZ. For example, no commercial timber harvest or skid trails will occur within 100 feet of perennial and intermittent streams within the WIZ unless certain exceptions such as designated stream crossings apply.

118 CP District-wide Salvage Project Final Environmental Impact Statement Approximately 1,000 acres of fuels reduction is associated with Alternative 2. The fuel reduction treatments being proposed in WUI’s are typically outside of WIZ areas and should have minimal if any effect on aquatic habitats or fisheries resources. The intent of these treatments is to reduce the potential for high-intensity wildfires near private or administrative sites, which typically would not impact watershed and aquatic habitats. Road work is included in all action alternatives and some surface disturbances would occur during pre-haul road maintenance, during old road reconstruction, and construction and/or relocation of new temporary roads. Potential impacts associated with increased road use are a primary concern associated with the action alternatives. Negative impacts are expected to be controlled and minimized by implementing PDC’s and Forest Plan standards; however, risks associated with sedimentation issues could be moderate to high depending on site-specific conditions and will need to be closely monitored. Any stream crossings needed for access will be coordinated with the forest hydrologist and/or fish biologist to minimize impacts to the stream/riparian areas and designed to provide aquatic species passage. There are opportunities to meet a variety of integrated resource improvement objectives with the CPDWS Project, including completing additional road maintenance to reduce erosion and improve watershed condition. Some projects may be funded with Knutson-Vandenberg monies collected from timber sale receipts, if available, though additional funds will be requested from other sources as appropriate. All potential impacts associated with Alternative 2 are intended to be minimized to the extent that any negative influences on aquatic habitats and fisheries are non-measureable or short-term. Table 40 displays the level of treatment activities associated with Alternative 2 within key fisheries watersheds.

Table 40. Alternative 2 treatment activities in key RGCT watersheds

Total Watershed Salvage Fuels Percentage of Watershed (key Acreage in Harvest Treatment Watershed stream) Analysis (acres) (acres) Treated Area French Creek – Alamosa River 18,302 2,106 160 12.4% (Rhodes Gulch) Headwaters La Jara Creek (Jim and Torsido 9,6645 0 0 0% creeks) Lake Fork (Lake Fork 6,222 2,400 27 39.0% Conejos River) Headwaters Rio de Los Pinos (Rio de Los 16,356 1,189 31 7.5% Pinos) Toltec Creek – Rio de Los Pins (Cascade and 18,055 929 46 5.4% Osier creeks) Wolf Creek (Wolf 4,824 176 74 5.1% Creek

The percentage of watershed acres treated in Alternative 2 is larger than Alternative 3 and may therefore require more administration and monitoring to ensure potential influences on streams and aquatic habitats are minimized as intended. Given the amount of area and activity proposed, at least moderate short-term risks might be associated with Alternative 2. However, effects are expected to be acceptable if Forest Plan standards and guidelines, PDC, and Watershed Conservation Practices Handbook practices are fully implemented and complied with, with response taken to mitigate unanticipated impacts or needs such as summer storm events or soil freeze/thaw conditions. Alternative 2 provides an opportunity to salvage timber while reducing existing road impacts, improving stream/riparian habitat, and sustaining and/or improve habitat for fish populations. Therefore, although short-term risks may be highest with Alternative 2, the long-term risks can be minimized 119 CP District-wide Salvage Project Final Environmental Impact Statement with focused administration of PDCs and RMZs, along with monitoring in RGCT and RGS streams, particularly in Lake Fork Conejos River. Alternative 3 – Vegetation Management – Limited Action Proposed harvest activities associated with Alternative 3 include activities on approximately 8,500 acres with similar erosion potential as Alternative 2. Alternative 3 also reduces the amount of the currently closed NFSR roads and old non-system roads that will need to be reopened for activities, thereby reducing the risk associated with required stream crossings and potential sedimentation issues. In Alternative 3, 31% fewer or 23.0 miles of old non-system road templates will need to be reopened, compared with 33.5 miles in Alternative 2. In addition, 22.5 miles of new temporary roads will need to be constructed, compared with 29.4 miles in Alternative 2. Thus, potential disturbances are reduced 27% overall from those proposed under Alternative 2. Potential effects from Alternative 3 on aquatic habitats and fisheries values are expected to be less than Alternative 2, and involve much less risk of contributing to some of the negative baseline conditions associated with some aquatic habitats and fisheries resources in the CPDWS project area. A primary benefit of Alternative 3 is the reduction in salvage within key lynx habitats, which also includes key fisheries watersheds, while still addressing the need to move stand densities and fuel loads towards conditions associated with the historic fire regime in mid to lower elevation forest cover and vegetation types. In regards to management activities, all potential impacts associated with Alternative 3 are subject to the same design criteria and standards and guidelines as discussed for Alternative 2. Thus, potential impacts are expected to be controlled and minimized to the extent that any negative influences on aquatic habitats and fisheries are non-measureable or short-term in nature. However, given the reduced amount of activity area, the risk associated with potential negative influences is lower for Alternative 3. Table 41 displays the level of treatment activities associated with Alternative 3 within key RGCT watersheds.

Table 41. Alternative 3 treatment activities in RGCT watersheds

Total Salvage Fuels Percentage of Watershed Watershed (key stream) Harvest Treatment Watershed Acreage in (acres) (acres) Treated Analysis Area French Creek – Alamosa River 18,302 1,028 160 6.5% (Rhodes Gulch) Headwaters La Jara Creek (Jim and Torsido 9,645 0 0 0% creeks) Lake Fork (Lake Fork 6,222 851 27 14.1% Conejos River) Headwaters Rio de Los Pinos (Rio de Los 16,356 1,057 31 6.7% Pinos) Toltec Creek – Rio de Los Pins (Cascade and 18,055 183 46 1.3% Osier creeks) Wolf Creek (Wolf 4,824 110 74 3.8% Creek

The percentage of watershed acres treated is much less than Alternative 2, thus fewer short-term risks to aquatic systems may be associated with alternative 3. However, effects are expected to be similar if Forest Plan standards and guidelines, PDC, and Watershed Conservation Practices Handbook practices are fully implemented, provide the intended effectiveness, and successfully complied with. As in Alternative 2, this alternative provides an opportunity to reduce wildfire risk, reduce road impacts, improve stream/riparian habitat, and sustain and/or improve fish populations.

120 CP District-wide Salvage Project Final Environmental Impact Statement

Rio Grande Sucker Extensive activity is proposed for the Lake Fork Conejos River watershed (up to 39%), which could impact RGS as well as RGCT as mentioned previously. This is the only RGS population within the Conejos Peak Ranger District and one of only a few on the Rio Grande National Forest. No effect is anticipated from the No Action alternative, but it is likely that this watershed will undergo some amount of impacts related to the timber salvage activity. With PDC and the development of RMZs and conservation measures in place, it is possible that impacts can be mitigated to the RGS population in Lake Fork Conejos River. The overall effects of all action alternatives are expected to be similar to those described for the RGCT. Cumulative Effects Cumulative effects on aquatic habitats within the planning area are analyzed in the context of potential incremental impacts of the project alternatives when considered in addition to other past, present and reasonably foreseeable future actions on all federal and non-federal lands regardless of whom undertakes the action. Timber harvest activities have occurred in the area for many years. Some remnant of those old harvest activities and also recreational activities remains on the land. These activities have created some detrimental soil conditions in locations, especially the older timber harvests. Increased sedimentation in areas that have high erosion potential can impact fisheries habitat, especially in key RGCT streams such as Rio de los Pinos and Wolf Creek. Baseline conditions for aquatic habitats in the planning area have been influenced by various natural and human-caused disturbances since settlement in the late 1800’s. Although not extensive, there has been a long history of timber harvest within some portions of the planning area. Timber sales have resulted in some surface disturbance, and necessitated the development of an extensive road system which opened many miles of native surface roads to motor vehicle traffic and recreation. Some existing roaded areas have altered the hydrologic cycle of the watersheds. There has also been a much longer history of livestock grazing, which is a primary activity affecting riparian areas and aquatic habitats in the planning area. Other activities affecting baseline conditions for aquatic systems include beaver removal, non-native fish introductions, and various recreational pursuits. Camping, hiking, horseback riding, hunting, and firewood collection are on-going practices which have some effect in the analysis area. Cattle grazing has occurred and will continue to occur in the area. Riparian and open areas will see the most use by cattle. Usually, these uses have minor influences on riparian zones and stream health. However, concentrated use areas involving these activities do contribute to impacts to riparian vegetation, soil compaction and stream bank degradation in some areas. Forest and range management activities can also contribute to the impact and spread of diseases and invasive species by conducting activities within and near stream zones that increase the potential for stream sediment. Sediment creates habitat for many hosts and vectors which can then be spread by direct transfer of spores/species in mud and water that may be on vehicles, equipment, and anglers gear that have crossed or have been used in infected waters. Through state stocking programs, viable self-sustaining nonnative trout populations occur throughout the perennial streams within the analysis area. These stocking contribute recreational value for human uses but can also impact native trout populations where emphasized. Brook trout currently can be found co-existing with RGCT in Jim, Torsido, and Wolf creeks. These nonnative salmonids pose a threat to RGCT existence due to competition for space and food. Fish stockings and angling can also increase the risk of introduction of various fish diseases (whirling disease, bacterial kidney disease, etc.) and invasive species (e.g., zebra mussels), particularly when combined with the incremental impacts of sedimentation facilitated by activities associated with the CPDWS Project.

121 CP District-wide Salvage Project Final Environmental Impact Statement Currently, most impacts within the analysis area are considered to be localized to individual stream sections with most streams and riparian areas exhibiting stable banks and that are in fair to good condition. However, sedimentation from native surface roads are a primary issue affecting aquatic habitats in the planning area, and some existing RGCT populations are decreasing and/or suppressed due to these potential impacts. The action alternatives associated with the CPDWS have the potential to contribute short-term additional incremental impacts to aquatic habitats, particularly in relationship to surface disturbances involving roads and road use. Under the action alternatives, re-opening and use of closed and (closed) temporary road prisms and construction of temporary roads may involve approximately 63.1 miles (Proposed Action Alt. 2) to 45.8 miles (Alternative 3). These roads would be in addition to the use of the existing open road system. PDC have been established that are intended to eliminate and/or minimize any additional impacts to stream areas. However, extensive monitoring of activities and quick corrective responses will be required to ensure potential impacts remain within or decrease from existing baseline conditions. Post- activity conditions on federal lands are expected to decrease potential impacts over time. Long-term impacts are expected to be minimalized by following Forest Plan standards and guidelines, PDC and Watershed Conservation Practices Handbook practices, in conjunction with focused project administration and monitoring.

3.6 Threatened, Endangered and Sensitive Plant Species Scope of Analysis This analysis is a summary of the biological evaluation prepared for the proposed CP District-wide Salvage Project EIS and complies with Forest Service Manual (FSM) 2600-2016-1 direction. The objectives of a biological evaluation are 1) to ensure that Forest Service actions do not contribute to loss of viability of threatened, endangered, proposed, or sensitive plant and animal species, or contribute to loss of viability of threatened, endangered, proposed, or sensitive plant and animal species, or contribute to a trend towards Federal listing under the Endangered Species Act, and, 2) to incorporate concerns for sensitive species throughout the planning process, identifying opportunities for enhancement and reducing any potential negative impacts. The species addressed in this document are from the August 23, 2016 Rocky Mountain Region Sensitive Plant list signed by the Regional Forester and include only those species known or suspected to occur on the Rio Grande National Forest. The threatened, endangered and proposed species considered in this document were confirmed through the U.S. Fish and Wildlife Service There are no threatened, endangered or proposed (TES) species known or suspected to occur on the Forest so the preparation of a biological assessment was not necessary for this project. The project area is approximately 332,000 acres and is the specific boundary evaluated for direct, indirect and cumulative effects for TES plant species.

Assumptions • Use of project design features will minimize or reduce direct and indirect impacts to resources. • Fens and wetlands will be avoided during project activities and no proposed actions will occur in these delicate, unique habitats.

Existing Condition Threatened and Endangered plants are determined and listed by the USDI Fish and Wildlife Service (50 CFR §17). A review of the current FWS list confirmed that there are no reported records or suspected occurrences of threatened or endangered plants on the Rio Grande National Forest. Threatened and endangered plants in Colorado have unique habitats or ranges that do not occur on this Forest. There are also no plants proposed for

122 CP District-wide Salvage Project Final Environmental Impact Statement listing or candidates for listing that occur on the Forest. Documented occurrences of sensitive plants on the Forest came from Forest files, Forest Service personnel, pertinent literature and records from the Colorado Natural Heritage Program (CNHP 2017). An evaluation was conducted on the remaining species on the current Regional sensitive species list to judge the likelihood of occurrence on the Forest. Local forest data and GIS data from the Colorado Natural Heritage Program (CNHP 2017) were analyzed to determine known populations of sensitive species within the project area. Some field surveys were conducted for this project; however, the entire project area has not been surveyed for sensitive plants.

There are twenty-three sensitive plant species known to occur or with the potential to occur on the Rio Grande National Forest (Table 42). Of those, there are documented occurrences of three sensitive species (CNHP 2017) and sixteen species were determined to have habitat that would fall within the elevational and distributional ranges of the project area.

Table 42. Region 2 sensitive plant species known or suspected to occur on the Rio Grande National Forest

Species Habitat Known Potential to Occur Habitat in on the the RGNF Project Area

Stonecrop gilia gravelly, talus alpine slopes >11,700 feet Yes Yes Aliciella sedifolia Rydberg's golden columbine shady and moist canyons near riparian areas <8,500 feet Yes Aquilegia chrysantha var. rydbergii Missouri milkvetch Gambel oak communities on shale soils <8,600 feet No Astragalus missouriensis var. humistratus Aztec milkvetch Gambel oak communities on shale soils <7,500 feet No Astragalus proximus Ripley's milkvetch open ponderosa pine/ Arizona fescue <9,540 feet Yes Yes Astragalus ripleyi Winding mariposa lily desert flats <7,300 feet No Calochortus flexuosus Lesser panicled sedge calcareous wetlands < 9,600 feet Yes Carex diandra Yellow lady's slipper aspen/ponderosa pine/Douglas-fir forests 7,400-9,800 feet Yes Cypripedium parviflorum Gray's draba gravelly alpine slopes and fellfields 11,500-14,000’ Yes Yes Draba grayana Smith's draba rock crevices and talus slopes 8,000-11,000 feet Yes Yes Draba smithii Brandegee's buckwheat Volcanic soils containing bentonite clay, Elev. 5800 – 9600’ Yes Eriogonum brandegeei Chamisso's cottongrass peaty wetlands 10,500-12,500 feet Yes Eriophorum chamissonis Slender cottongrass fens, wetlands, & pond edges 8,000-12,000 feet Yes Eriophorum gracile Colorado tansyaster gravelly grassland slopes 8,500-12,500 feet Yes Yes Machaeranthera coloradoensis Bill's neoparrya rocky cliffs and rock outcrops <9,200 feet Yes Yes Neoparrya lithophila Degener's beardtongue pinyon-juniper woodlands and grasslands 6,000-9,500 feet Yes Penstemon degeneri Ice cold buttercup exposed alpine rock and scree slopes 12,000-14,000 feet Yes Ranunculus karelinii

123 CP District-wide Salvage Project Final Environmental Impact Statement

Species Habitat Known Potential to Occur Habitat in on the the RGNF Project Area

Arizona willow streamside meadows 10,300-10,700 feet Yes Yes Salix arizonica Sageleaf willow nutrient-rich birch (Betula glandulosa) fens and pond/river No Salix candida edges 8,900-10,040 feet Autumn willow wetlands 7,800-9,720 feet Yes Salix serissima Fine Bog-moss iron fens (pH < 5.8) 9,600 – 11,483 feet Yes Yes Sphagnum angustifolium Baltic Bog-moss iron fens (pH < 5.8) around 10,200 feet Yes Sphagnum balticum Lesser bladderwort fens, shallow ponds, lakes, and slow streams usually below Yes Utricularia minor 10,000 feet and often alkaline

Direct and Indirect Effects The entire project area was considered as the spatial context for this analysis. Both action alternatives are analyzed collectively as the proposed activities for each of these alternatives propose the same effects on sensitive plants and only differ in spatial area and extent in which they may occur. Some species will be dropped from further effects analysis because their specific habitat requirements are not found within the project area nor is the species or its habitat suspected to occur near roads or proposed temporary roads for the action alternatives.

PDC and the project-specific checklist process is integral to the effects analysis and determination for sensitive plants. The design criteria and checklist development were formed with an emphasis on reducing, if not eliminating, adverse effects to sensitive plant species and their habitat.

The following PDC will be employed for both action alternatives: Surveys for TES species will occur prior to design of a project; Results of surveys will be incorporated into the project design and/or implementation per applicable Forest Plan Standards. Known occurrences of sensitive species will be flagged with a buffer for avoidance from salvage harvest and fuels reduction activities.

Alternative 1 – No Action Under the No Action Alternative, there would be no new impacts to sensitive plant species based on proposed activities. Therefore, under Alternative 1, there is a “no impact” determination for Region 2 sensitive plant species.

Alternative 2 – Proposed Action and Alternative 3 – Vegetation Management – Limited Action Though they have never been found in the project area, there is overlap in the project area with potential habitat for the following species: Aliciella sedifolia, Aquilegia chrysantha var. rydbergii, Carex diandra, Cypripedium parviflorum, Draba grayana, Draba smithii, Eriogonum brandegeei, Eriophorum chamissonis, Eriophorum gracile, Neoparrya lithophila, Penstemon degeneri, Ranunculus karelinii (R. gelidus ssp. grayi), Salix serissima, Sphagnum angustifolium, Sphagnum balticum, Utricularia minor

124 CP District-wide Salvage Project Final Environmental Impact Statement Direct effects could occur from proposed salvage activities causing plants to be burned in piles, uprooted, crushed/trampled or skidded off by logs. Indirect effects could arise from changes in nearby canopy cover of associated forest vegetation from tree removal or changes in litter and duff layers from tree-removal, pile- burning or movement of machinery. Indirect effects could also be caused by compaction of soil and the reduction in plant cover, which can lead to the introduction of invasive plant species and an increase in erosion. Most of these plants occur within specific and unique habitats (fens and wetlands, open, shale-based meadows, mesic, rocky crevasses) and not in spruce-dominated forests. Because activities associated with the action alternatives will not occur in these areas (see PDC), the determination for the aforementioned sixteen sensitive species is “may adversely impact individuals, but not likely to result in a loss of viability on the Planning Area, nor cause a trend to federal listing”. With the implementation of the PDC and the pre-implementation checklist, effects to sensitive plant species are expected to be minor and of short duration. Three sensitive species are known to occur within the project area: Astragalus ripleyi, Machaeranthera coloradoensis and Salix arizonica. Direct effects could occur from proposed salvage activities causing plants to be burned in piles, uprooted, crushed/trampled or skidded off by logs. However, during the pre- implementation field review and checklist process, if it is determined that there could be direct impacts to these populations due to proposed activities, maps of these areas will be provided with the appropriate mitigation. That mitigation could include buffered areas flagged for avoidance of activities particularly vehicle or machinery operations, temporary road building or locations of skid trails and landings. Indirect effects could arise from changes in nearby canopy cover of associated forest vegetation or changes in litter and duff layers from tree-removal, pile-burning or movement of machinery. Indirect effects could also be caused by compaction of soil and the reduction in plant cover, which can lead to the introduction of invasive plant species and an increase in erosion. Indirect effects may be monitored throughout the implementation process in the vicinity of these populations. With the employment of the PDC and project implementation checklist with associated mitigation (as necessary), the determination for Astragalus ripleyi, Machaeranthera coloradoensis and Salix arizonica is “may adversely impact individuals, but not likely to result in a loss of viability on the Planning Area, nor cause a trend to federal listing”.

Per forest plan and FSM 2670 direction, site-specific evaluations and surveys for sensitive plant species will be conducted as project spatial data becomes available. The results of project specific analysis may trigger additional mitigation during the pre-implementation process based on the results of the field review. Cumulative Effects The relevant past, present, and foreseeable future activities for consideration in cumulative effects analysis for this specific project area includes consideration of past timber harvesting/thinning and wood gathering, wildlife herbivory, grazing, recreation, roads and trails and fire suppression and use.

There has been past timber cutting and wood gathering in the project area and there are current and foreseeable future plans for both of these activities neither of which specifically target sensitive species habitat. The spruce beetle outbreak in the Engelmann spruce is currently causing extensive spruce mortality and the subsequent opening of the forest might have a positive effect on early-seral sensitive species. Effects on sensitive plants from past big game grazing are not clear and they are not documented. Palatable, sensitive plants have likely evolved with wildlife over time, and there is no information to suggest that past, current, and foreseeable wildlife populations would be expected to have any appreciable effects on sensitive plants or their habitat. Additionally, livestock grazing has occurred in this area since the late 1800s and continues today. Effects on sensitive plants from past livestock grazing, if any, are not documented and are not well understood.

Roads and trails as well as dispersed recreation impact localized areas in potential sensitive species habitat. However, no new system roads or trails are proposed in the project area and dispersed recreation use is mostly confined to designated routes (i.e., existing disturbance) and disturbance areas tend to be reused and 125 CP District-wide Salvage Project Final Environmental Impact Statement are extremely small (i.e., camp sites, fire rings, etc.).

In the past, there has been widespread fire suppression activity, especially at the lower elevations and particularly in the last 50 years or so. Effects on sensitive plants from past fire suppression, if any, are not documented or well understood. Currently, and in the foreseeable future, there may be more use of prescribed fire to mimic natural fire regimes. This management action could open the canopy and increase crown base heights and have a potential positive effect on early seral sensitive plant species.

3.7 Hydrology and Watershed Scope of Analysis The spatial extent of this analysis is the approximately 332,000 acre project area.

Assumptions During the completion of project implementation checklists and associated field work, critical areas such as wetlands, streams, and riparian areas will be identified and protected through a variety of measures and PDC will be employed to reduce effects to wetland resources.

Existing Condition The project area is positioned immediately to the east of the continental divide and exhibits a hydrologic cycle that is dominated by mountain snowpack, which results in streamflow runoff patterns that have a pronounced snowmelt-driven spring peak with a recession to base flows by late summer. Monsoonal storms have potential to generate high, localized discharges from basins receiving precipitation. Additionally, early fall snowpack that is subsequently subjected to rainfall has the potential to generate discharges similar in magnitude to spring peak flows. Precipitation trends across the analysis area show a strong west to east trend, which closely follows elevation gradients. In the west, along the continental divide, mean annual precipitation can exceed 50 inches, while lower elevation areas in the eastern portion of the analysis area receive less than 20 inches. Most of the proposed salvage areas are in mid to upper elevations (9,500 ft. to 11,500 ft.) and receive approximately 35 to 45 inches per year of mean annual precipitation, the majority of which comes as snowfall. The project area contains all, or substantial portions of 27 6th level watersheds (12 Digit Hydrologic Unit Code), shown in Table 43. However, of these 27 watersheds, only 16 have salvage activities within their boundaries under either the proposed or Alternative 3 actions. The remainder of this analysis will focus on the attributes of, and potential impacts to, the resources of these 16 watersheds. The density of ephemeral, intermittent, and perennial streams identified in the National Hydrography (NHD) dataset ranges from a high of 9.0 miles per square mile in the upper northwestern corner of the project area (Wightman Fork) to a low of 2.3 miles per square miles in the Saddle Creek watershed. Stream density generally follows the same trend as precipitation with the northwest corner of the project area have the highest stream densities, while the southeastern watersheds tend to be drier. Stream densities for all watersheds are shown in Table 43. Due to a variety of factors associated with soils, climate, and topography, the distribution of riparian vegetation across the project area does not necessarily follow the same trends as stream density. In general, riparian vegetation in the project area occurs along valley bottoms next to perennial streams, or in large open wet meadows, particularly in the higher and wetter portions of project area. Based on Region 2 FSVeg data, riparian vegetation comprises between 2.8% (Bighorn Creek) and 10.9% (Wightman Fork) of watershed area, for those watersheds where salvage activities will occur (Table 43). In addition to stream and riparian areas, the project area also hosts a wide variety of seeps, springs, and wetlands that are sustained via both ground and surface waters. Owing the difficulty of mapping wetlands, particularly fens, at a large scale, the National Wetland Inventory data for the project area substantially under represents the 126 CP District-wide Salvage Project Final Environmental Impact Statement actual occurrence of wetlands in the project area and is not included in this discussion. During the completion of project implementation checklists for individual projects, field inventories of streams, wetlands, and riparian areas will be undertaken so as to inform project area boundaries and Existing Conditions. The Forest Service utilizes the Watershed Condition Framework (WCF) to assess and characterize the health and condition of watersheds at the 6th level hydrologic unit code (HUC). Of the 16 6th level watersheds that have salvage harvest or fuels treatments in the action alternatives, 4 are rated as Class 1, and 12 are rated as Class 2. Class 1 or Good condition watersheds are functioning properly because they exhibit high geomorphic, hydrologic, and biotic integrity relative to their natural potential condition. Class 2 or Fair condition watersheds are functioning at-risk because they exhibit moderate geomorphic, hydrologic, and biotic integrity relative to their natural potential condition. Class 3 or Poor condition watersheds are at impaired function because they exhibit low geomorphic, hydrologic, and biotic integrity relative to their natural potential condition. There are no Class 3 rated watersheds in the area of any proposed salvage harvest or fuels treatments. No salvage activities are proposed for priority watersheds as identified under the Watershed Condition Framework, or watersheds of high concern from the 1996 Forest Plan Revision.

Table 43. Riparian and stream data for 6th level watersheds with proposed treatment activities

General HUC Data Riparian Analysis NHD Stream Analysis WCF Rating Acres % within Stream Wate Total Acres of Riparian Miles of Watershed Hydrologic within the the Density rshed HUC R2FSVeg % of NHD Unit Code Analysis Analysis (miles/sq. Class Name Area Riparian HUC Streams Area Area mile) Bighorn Creek 130100050404 7854 11,289 69.6% 223 2.8% 57 4.6 2 Elk Creek 130100050402 27568 27,585 100.0% 2,917 10.6% 124 2.9 2 Fox Creek 130100050403 12664 21,175 59.8% 715 5.6% 58 2.9 2 French Creek- 130100020304 18302 23,160 79.0% 765 4.2% 146 5.1 2 Alamosa River Headwaters 130100020302 24161 24,193 100.0% 1,877 7.8% 268 7.1 2 Alamosa River Headwaters Rio 130100050201 16356 16,362 100.0% 1,480 9.0% 96 3.8 2 de Los Pinos Jasper Creek- 130100020303 11252 11,288 100.0% 237 2.1% 155 8.8 2 Alamosa River Lake Fork 130100050104 6222 6,224 100.0% 372 6.0% 31 3.1 1 Platoro 2 Reservoir- 130100050103 6695 6,697 100.0% 280 4.2% 41 3.9 Conejos River Rough Creek- 130100050401 17888 17,898 100.0% 2,107 11.8% 89 3.2 2 Conejos River Saddle Creek 130100050105 4742 4,743 100.0% 116 2.4% 17 2.3 1 Sheep Creek- 130100050405 27386 28,595 95.8% 1,471 5.4% 105 2.5 2 Conejos River Toltec Creek- 1 Rio de Los 130100050203 18055 32,784 55.1% 1,063 5.9% 110 3.9 Pinos Trail Creek- 130100050109 21187 21,195 100.0% 1,483 7.0% 138 4.2 2 Conejos River Wolf Creek 130201020203 4824 18,012 26.8% 154 3.2% 40 5.3 1 Wightman Fork 130100020301 10124 10,239 100.0% 1,098 10.9% 143 9.0 2

The most common causes of watersheds being downgraded from Class 1 to Class 2 include poor riparian conditions, invasive aquatic species, and reduced flows due to diversions on public lands. Additionally, several watersheds received reduced scores due to poor water quality in the Alamosa River downstream of the Summitville Mine Site. However, water quality within the project area is generally good, with one waterbody listed as impaired on the State of Colorado’s 303(d) monitoring and evaluation list (Table 44). 127 CP District-wide Salvage Project Final Environmental Impact Statement

Table 44. State of Colorado 303d listed waterbodies in the project area

Clean Water Act Section 303(d) WBID Segment Description 303(d) Priority Portion Impairment

Alamosa River, from Ranger Creek to Terrace CORGAL03d all Al High Res.

Direct and Indirect Effects Impacts to watershed resources from the activities analyzed in this document generally fall into three broad categories: 1) impacts from canopy removal, 2) impacts from roads, skid trails, and landings 3) impacts to riparian and wetland areas. This disclosure of potential environmental impacts will first discuss each of these categories, followed by a discussion of ways to mitigate these impacts; finally, the various alternatives will be compared.

Alternative 1 – No Action In the no action alternative, no new ground disturbing activities would occur and, therefore, there would be no impacts to riparian or wetlands based on proposed salvage harvest activities.

Alternative 2 – Proposed Action and Alternative 3 – Vegetation Management – Limited Action

Effects of Salvage Harvest Major reductions in the forest canopy can increase water yield in high-elevation forested watersheds such as spruce-fir forests or cool moist mixed conifer forests. These increases can be large in some regions. However, in the hydro-climatic regime of the project area, annual climate variations are typically much more important than alterations from timber harvest. If observed, flow increases occur mostly during spring runoff and during the summer; and are not measurable until about 25% of the live basal area of a forested watershed is cut (USFS 1980). Given that the majority of the trees to be removed under this analysis are already dead, it is likely that many of the impacts that would typically be associated with harvest have already been observed. Namely, the trees have stopped transpiration, and other impacts such as canopy interception and shading have been altered from the green state. The removal of these dead trees and the subsequent creation of large openings can enhance or create localized areas of snow scour that can reduce site moisture and water yield (USFS 2006a).

Based on the relatively limited portions of each watershed that have the potential for salvage harvest (0.5% to 38.6%, mean of 9.2%) detectable changes in water yield would generally, not be of concern. In general, fuels treatments are not expected to result in measurable impacts to water yield because such treatments (including mechanical treatments and prescribed burns) primarily target the understory and small-diameter trees; therefore, they may not measurably alter basal area, and do not impact appreciable portions of any individual watershed (Table 45).

128 CP District-wide Salvage Project Final Environmental Impact Statement

Table 45. Comparison of salvage harvest and treatment activities for 6th level watersheds

Alternative 2 - Proposed Action Alternative 3 - Alternative Action Watershed Acres of Salvage Acres of Fuels Acres of Salvage Acres of Fuels Salvage Harvest % Fuels Treatment Salvage Harvest % Fuels Treatment Name Harvest of HUC Treatment % of HUC Harvest of HUC Treatment % of HUC Bighorn Creek 1 0.0% 0 0.0% 1 0.0% 0 0.0% Elk Creek 1,126 4.1% 0 0.0% 560 2.0% 0 0.0% Fox Creek 601 4.7% 0 0.0% 198 1.6% 0 0.0% French Creek- 2,106 11.5% 160 0.9% 1,028 5.6% 160 0.9% Alamosa River Headwaters 2,041 8.4% 147 0.6% 1,274 5.3% 147 0.6% Alamosa River Headwaters Rio 1,189 7.3% 31 0.2% 1,057 6.5% 31 0.2% de Los Pinos Jasper Creek- 529 4.7% 104 0.9% 397 3.5% 104 0.9% Alamosa River Lake Fork 2,400 38.6% 27 0.4% 851 13.7% 27 0.4% Platoro Reservoir- 817 12.2% 0 0.0% 251 3.7% 0 0.0% Conejos River Rough Creek- 84 0.5% 0 0.0% 2 0.0% 0 0.0% Conejos River Saddle Creek 762 16.1% 0 0.0% 536 11.3% 0 0.0% Sheep Creek- 836 3.1% 11 0.0% 662 2.4% 11 0.0% Conejos River Toltec Creek- Rio de Los 929 5.1% 46 0.3% 183 1.0% 46 0.3% Pinos Trail Creek- 2,174 10.3% 295 1.4% 1,387 6.5% 295 1.4% Conejos River Wolf Creek 176 3.6% 74 1.5% 110 2.3% 74 1.5% Wightman Fork 1,728 17.1% 0 0.0% 825 8.1% 0 0.0%

Water Quality Impacts – Sediment is the primary pollutant associated with salvage harvest and fuels reduction activities. Surface disturbances and the removal of ground cover have the ability to generate erosion and subsequent sediment introduction into waterbodies and sensitive riparian and wetland areas. Additionally, there is the potential for spills of fuel and other chemicals that are frequently used harvest and fuel reduction operations.

The 303(d) impairment for the Alamosa River from Ranger Creek to Terrace as well as other portions of the Alamosa River are related to dissolved metals and low pH conditions, which are typically the result of legacy mine operations (TMDL Assessment Alamosa River, CDPHE 2005). The proposed vegetation management activities are very unlikely to exacerbate water quality concerns related to dissolved metals and low pH conditions in the analysis area.

Effects of Forest Roads, Skid Trails, and Landings The construction and maintenance of roads, skid trails, and landings has long been recognized as a potential and major source of sediment in forested watersheds (Meaghan and Kidd 1972; Reid and Dunne 1984). This infrastructure can change natural runoff patterns by increasing the amount of impervious surface in a watershed, and/or by intercepting overland flow or shallow subsurface runoff. The network of road drainages often routes this water, and the associated sediment, directly into streams (MacDonald and Stednick 2003). Sediment is the major pollutant associated with roads on public lands. Sedimentation in streams impacts water quality, which can, in turn, impact aquatic life. Sediment can also alter channel morphology, which can subsequently impact aquatic habitat. Road construction and maintenance activities can result in physical changes to streams, including floodplain and riparian habitat modifications, channel degradation, and fish passage reduction.

Poorly designed and maintained road/stream interactions can necessitate increased road stabilization and maintenance costs, and lead to rapid sedimentation and filling in of water storage reservoirs and ponds. 129 CP District-wide Salvage Project Final Environmental Impact Statement Ecological impacts commonly associated with stream/road interactions include aquatic, riparian, and wetland habitat degradation (USFS 2005). The magnitude of impacts to watershed resources from roads, skid trails and landings will depend primarily on miles to be constructed or reconstructed, and the number of truck passages necessary to remove the timber products.

Under all action alternatives, portions of existing National Forest System Roads will be reconstructed to accommodate new or increased utilization from the analyzed activities. Additionally, both new temporary roads, as well as old, non-system road templates that are re-used, will be decommissioned when salvage or fuels activities are completed. Given this fact, and the long time scale of this project, the actual increase in road construction and utilization at any given time is anticipated to be somewhat limited. This means that watershed impacts will be distributed, and mitigated, in both time and space as various salvage projects move forward across the project area.

Effects on Riparian and Wetland Areas Salvage harvest and fuels treatments within riparian and wetland ecosystems are generally prohibited or constrained sufficiently such that these activities will not remove riparian vegetation or cause direct manipulation of wetlands. The primary exception to this practice is the placement and construction of roads necessary to complete timber harvest and vegetation management activities. Roads directly alter riparian vegetation when, by necessity, they cross the riparian corridors associated with streams. These alterations come by means of both riparian vegetation removal at the site of the stream crossing, and via alteration of surface and subsurface flow patterns, which can subsequently alter riparian vegetation communities. Roads are not permitted within wetland ecosystems, but do have the potential to alter surface and subsurface flow patterns near these areas. Other impacts include the alteration of the hydrologic cycle in the immediate vicinity of the harvest, which may modify the timing and magnitude of runoff, and change the amount of water available to riparian and wetland areas. The impacts on riparian and wetland ecosystems from salvage harvest will depend primarily on miles and layout of Maintenance Level-1 and temporary roads employed during salvage harvest and fuels treatment; impacts from Maintenance Level-2 and 3 roads would remain static between all alternatives.

Management Actions to Reduce Impacts to Watershed Resources All salvage harvests and fuels treatments on National Forest System lands are subject to conditions and restrictions that are employed to mitigate impacts to watershed resources from authorized activities. These measures are variously referred to as Standards and Guidelines (1996 Forest Plan Revision), Best Management Practices (BMPs, FS990-A), and Management Measures (FSH2509.25). Actions taken under all alternatives will comply with the requirements of these documents, as a minimum, to provide adequate protection for watershed resources. Additionally, action alternatives are subject to the pertinent PDC (Table 7) that have been set forth in this document to provide unique mitigations specific to the physical characteristics of the project area. The management actions set forth in this document and mentioned previously in this paragraph have proven effective in mitigating watershed impacts and reducing the introduction of sediment into waterbodies. The effectiveness of these measures, particularly the BMPs, will be monitored as part of an ongoing effort to improve salvage harvest and fuels treatments (section 2.5, FS990-A).

Comparison of Alternatives Alternative 1 would result in the fewest impacts to watershed resources due to the fact that no ground disturbing activities would occur. There would be no new and additive impacts to riparian and wetland areas, and erosion or sedimentation issues associated with salvage harvest activities would not occur. Of the action alternatives, Alternative 2 would have the greatest impacts to watershed resources due to having the highest number of acres available for salvage harvest, and the greatest number road miles to be

130 CP District-wide Salvage Project Final Environmental Impact Statement constructed/reconstructed and subsequently decommissioned. Alternative 2 would result in a large percentage (36.8%) of the Lake Fork watershed (HUC 130100050104) undergoing salvage harvest, depending on the timing and exact layout of these salvage operations, significant watershed impacts could occur, which would likely result in the WCF rating changing to non-functional. Under Alternative 3, the percentage of Lake Fork harvested is reduced to 13.7%, which would reduce potential watershed impacts, and would be likely to maintain the existing WCF rating. Under both action alternatives, the remainder of watersheds have between 0.5% and 16.9% of watershed area available for salvage, these relatively low percentages, combined with effective monitoring and consistent implementation of standards, guidelines, BMPs, and mitigation measures, would maintain long term watershed health and function. All alternatives would comply with applicable laws, such as the Clean Water Act, and would avoid detrimental impacts to Municipal Supply Watersheds Cumulative Effects Cumulative effects are the effects on the environment, which result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions. The most influential past actions in the analysis area that have impacted watershed resources include grazing, mining, vegetation management, roads, travel management, and recreation. These activities have resulted in localized areas of riparian, wetland, and stream degradation, frequently resulting from grazing and road maintenance or construction practices. All past activities can reasonably be assumed to carry forward into the future, with the potentially exception of mining. These activities, when combined with any of the alternatives would be unlikely to combine to create new significant impacts.

3.8 Soils Scope of Analysis The scope of the analysis on forest soils is the approximately 332,000 acre project area. Existing Conditions There are 36 different soil resource inventory (SRI) units present within stands identified as potential for harvest (USDA 1996). SRI 151 accounts for the largest single soils unit at approximately 2,593 acres or ~15% of the acres and range down to SRI 166, which accounts for less than an acre. There are also approximately 6 acres of surface water mapped within the designated stands. Table 46 summarized the SRI units present and their relative amounts.

Table 46. Summary of soil resource inventory units for the project area

SRI % Range Cumulative % 127, 137, 151, 167 10 + 50 149, 150, 160 5 – 9 20 108, 124, 125, 135, 140, 141, 1 – 4 24 161, 168, 170 107, 110, 111, 112, 121, 126, 1 6 128, 129, 139, 145, 152, 153, 154, 157, 158, 159, 162, 165, 166, 169, W Numbers in italics represent SRIs that are assigned Range Ecological sites and do not traditionally have large timber stands. The majority of these inclusions are due to GIS error because of scale at which soil layers are drawn and possibly changes in tree extent or projection differences.

Erosion is potentially an issue from land management actions. Soil units are given an erosion hazard rating of low, moderate, high or N/A for miscellaneous units such as rock outcrops or talus slopes, etc. Inclusive of approximately 17,000 acres identified for possible management activities 92.5 percent are rate as having a 131 CP District-wide Salvage Project Final Environmental Impact Statement moderate erosion potential hazard (see Table 47), with six percent having high potential, and the other 1.5 percent in the n/a and low hazard range. Soil mass movement potential is more evenly distributed across the different ratings. Approximately 83 % of the area will be of little concern for mass movement. The remaining 17 % that is listed as high potential risk, is primarily located in the La Manga/Cumbres Pass area, which according to the soil survey (USDA, 1996), allow timber harvest in the area due to local conditions such as level terrain. Care will need to be taken to ensure that soils sensitive to mass movement are identified within a project area and appropriate BMPs and PDC are applied to protect these areas from adverse effects.

Table 47. Erosion and mass movement potential in the project area

Erosion Potential Hazard (% Mass Movement of total acres) Potential (% of total Acres low 0.5 very low 23 moderate 92.5 low 34 high 6 moderate 26 n/a 1 high 17

Soil interpretations important for timber harvest beyond land stability (erosion and mass movement) are related to soil productivity. They are the reforestation potential and the limitations for total tree harvest. Approximately 74% of the acres fall in the good or fair ratings with 12% in the poor rating. Limitations of total tree harvest show approximately 38% in the slight to moderate and 23% in the severe with 40% in the N/A category (see Table 48).

Table 48. Reforest potential and total free harvest within the project area

Reforestation Potential (% Total Tree Harvest (% Total of total acres) Acres) Good 54 Slight 10 Fair 20 Moderate 28 Poor 12 Severe 23 n/a 13 n/a 40 @ acres are rounded to the nearest whole number so may not add up to 100% exactly

As discussed in the context of soil resource inventory (SRI) units, many of these units are assigned Range Ecological sites. If a unit is assigned a range ecological site then it would not be assigned a rating for limitations for total tree harvest. This most likely accounts for the relatively high N/A rating of 40% for limitations for total tree harvest. Areas where hazardous fuels treatments may occur covers approximately 943 acres. Of these areas about 84 % fall within the moderate or N/A erosion potential hazard, while about 87 % of soils are in the very low, low and moderate mass movement potential hazard. Generally, soil condition across the district is in acceptable to good condition. Some areas, especially around high use recreation areas, and riparian areas impacted through grazing, have detrimental impacts associated with them but these areas are not the normal condition across the forest. Direct and Indirect Effects Alternative 1 – No Action Natural processes will continue at a natural rate. Compacted soils will continue to improve slowly over time. No additional soil disturbing activities will occur beyond current permitted activities previously described. Indirect effects will be related to existing conditions not mitigated by activities like reforestation and temporary road and skid trail closures and decommissioning, which were foregone by the No Action Alternative. They

132 CP District-wide Salvage Project Final Environmental Impact Statement also include a more natural recovery process which may take longer, but would not add disturbance due to harvest activities.

Alternative 2 – Proposed Action Soils analysis of the different activities are generally analyzed by activity unit (e.g. timber cutting unit, hazardous fuels treatment area, etc.). The specific units are not yet known, but would be located within the areas identified on the alternative map. As conditions change due to bark beetle mortality or if a wildfire occurs the units can be adjusted and objectives adjusted or changed to meet the new conditions on the ground. As a result, only a discussion of general effects can be made at this time. As project units are delineated and finalized, site specific soil analysis will occur to confirm soil type and current disturbance levels as needed. PDC will be finalized at that time which will prevent further detrimental disturbance or require mitigation or restoration activities which will protect, maintain or improve soil resources.

Treatment activity descriptions can be found described in detail with in chapter 2 of the NEPA document, which also include potential acres for these activities, however in brief they are as follows:

Activities associated with salvage harvest: 1. Commercial Logging and log hauling operations 2. National Forest System Road maintenance and reconstruction 3. Re-use of old, non-system road templates, and new temporary road construction 4. Decommissioning of non-system and temporary roads 5. Identification and establishment of areas for public and commercial firewood gathering 6. Reforestation activities (generally performed by hand) 7. Possibility of closure of system roads, with possible decommissioning activities as appropriate and where funding and workforce are available in relation to project units Activities associated with Hazardous fuels treatments: 1. Establishment of shaded fuel breaks by hand thinning or removal of hazard trees (chainsaw) with in 400 ft. of public boundary and 200 ft. of administrative site 2. Pruning of residual tress within the fuel break to lift crown base height 3. Piling and burning or removal of activity generated fuels within timber sale area and fuel break thinning area.

The typical soil disturbance activities associated with harvest are temporary roads, skid trails, landings and mechanical harvester operation. Temporary roads, skid trails and landings can create large areas of disturbance. Top soils are removed in leveling, soils are compacted in the creation of roads, skid trails and landings, and exposed soils are subject to accelerated erosion. Mechanical harvester operations can compact soils by driving over them, and can disturb and remove top soil where they turn. This is especially true on steep hill slopes.

Up to 34 miles of non-system road templates could be re-opened and maintained within the scope of this project, as well as up to 29 miles of new temporary roads could be created during this project life span. Since the life of this analysis is 10 to 15 years, not all segments of new temporary or non-system roads will be opened at the same time. Standard BMPs and PDCs require decommissioning of temporary roads at the completion of use. As a result, only a small portion of the temporary or non-system roads re-opened will be open at the same time. This will limit impacts to streams and erosion, and spread the effects across the landscape and over several years. Initial reopening and maintenance can lead to a short term increase in erosion, and sedimentation into streams, this is due to ground disturbance as well as removal of vegetation which may be growing on the road prism. The best management practices (BMPs) associated with road construction and maintenance, which are applied to this activity will mitigate and reduce erosion. In addition, road maintenance may improve road drainage and help to improve current conditions.

PDC will require the use of old skid trails whenever possible to help reduce additional disturbance, especially compaction. Recommended skid trail spacing and placement of fine woody debris on skid trails, if needed, will 133 CP District-wide Salvage Project Final Environmental Impact Statement help limit compaction throughout the unit and will also help reduce and prevent erosion, as well as maintaining soil nutrients. Soil nutrients will be maintained in a large degree due to the fact that most of the spruce trees will lose their needles and thus returning nutrients back to the soil.

Landings are similar to skid trails. The amount of new compaction and disturbance is limited by reusing existing landings, treating landings when finished, water barring skid trails, and spreading fine slash, to prevent erosion when finished, as needed.

Mechanical harvesting equipment can potentially cause damage to soil. Current PDCs and BMPs help to mitigate and protect the soil resource. Limitations of slope steepness and operational conditions (i.e. soil moisture level, frozen or snow covered soil), protect the soil resource from conditions where operation of harvesters would cause unacceptable levels of soil disturbance.

Fuels reduction along private and administrative boundaries outside of Colorado Roadless Areas will occur as part of this project. Thinning activities done by hand (chainsaws) have very low potential to disturb soils. WUI is largely a public safety and infrastructure protection issue. It is not anticipated that the soil will be detrimentally influenced by fuel reduction activities.

Burning of piles from fuels reduction and from salvage harvest operations are planned. Burning piles has the potential to detrimentally disturb soils. When conditions are such that high intensity fires and/or long residence times exist within the fire, soil heating can occur which creates adverse conditions in the soil leading to loss of nutrients .Physical changes also occur, which lead to hydrophobicity and accelerated erosion. Localized affects are common after a pile is burned. In some instances associated with harvest activities piles become large enough that when burned detrimental soil effects are present. Effects are localized and limited in the area of impact. Best management practices (BMPs) and PDCs dictate that piles are not burned within a riparian area, but away from water. Overall detrimental disturbance after harvest and burning are still expected to remain below 15% of the unit. Impacts from burning piles is usually an insignificant part of the overall disturbance and is not expected to create a significant soil resource impact.

As discussed above, there are large areas of overlap between timber stands mapped layers and SRI layers. Meadows and riparian areas could be impacted due to this overlap; however, BMPs and PDCs are established to protect riparian zones and meadows. The activities are not planned for meadows and riparian zones and will be largely restricted to timber stands. As a result these activities are not anticipated to cause significant detrimental disturbance to the soil resource.

Roads can be one of the largest contributors to erosion and sedimentation in a watershed. Soils disturbed at construction or during maintenance, can erode and contribute sediment to waterways. Unmaintained and user created roads can contribute large amounts of sediment delivery to streams throughout the life of the road. Standard practices prescribed primarily through FSH 2509 and BMPs serve to protect water and soils from significant impacts during these activities and can be monitored through the use of the National BMP monitoring program (USDA 2012).

Soils with high erosion hazards are of greater concern for detrimental soil disturbance due to erosive traits. These traits could be due to slope or due to soil characteristics. These are generally addressed by implementation of BMPs which mitigate this issue, for example spreading fine slash on skid trails helps to prevent erosion. Approximately 1,000 acres or ~ 6 percent of the area proposed for salvage harvest activities falls under the ‘high’ erosion hazard potential. The majority of soils are rated as ‘moderate’ or 92.5%. These soils are rated as high erosion potential due primarily to slopes, meaning as slope increase the potential for erosion increases. Project design does not allow mechanical treatments to take place on slopes steeper than 40%.

134 CP District-wide Salvage Project Final Environmental Impact Statement

Table 49. Soil Resource Inventory (SRI) units with mass movement potential rating of high and associated acres and percent of the proposed activity areas

SRI unit Acres % Acres 151 2,593 15.5 162 128 0.7 129, 139, 145 67 0.4 Total 2,788 16.6

All but 1.1 percent of the soils rated as high are in SRI 151. Of the remaining 1.1 percent, 0.7 percent is in SRI 162 which is a non-vegetate rock outcrop and rubble land unit. The Soil Resource and Ecological Inventory (USDA 1996) indicates that SRI 151 is unsuitable for timber production activities except in the Cumbres Pass area. This is mostly due to the relatively level slope and depth of soil to under lying Mancos shale deposits. Standard BMPs and PDCs will work to prevent situations that may increase the risk of mass movement, in addition to site-specific investigation that will be verified through the implementation checklists developed under this alternative. Timber harvest has occurred in the Cumbres area over the years with appropriate measures it can be done in such a way as not to impact soil resource values. Treatment types generally cover a number of soil types, where each soil has a different erosion hazard rating. Treatments have different types of hazards associated with them. Salvage and other tree harvest activities generally have a higher risk of detrimental disturbance than pile burning or hand thinning. As discussed previously the majority of erosion concern comes from slope. Since harvest activities do not occur on slopes greater than 40% the erosion hazard is mitigated. In addition PDCs are set forth to mitigate other activities such as skid trails which may also contribute to detrimental soil disturbance. Non-treatment areas can be considered the same as a no action alterative. No activities will occur in these areas so no further analysis is needed. For further discussion see Alternative 1 the no action alternative. Erosion is used in part as a surrogate for other soil characteristics which may be problematic; however, erosion potential hazard is the most far reaching of those characteristics and PDCs are designed to account for all foreseeable soil disturbance characteristics. As specific activity units are delineated, a review will be conducted to determine extent of site-specific evaluation needed for each activity unit. Best Management Practices (BMPs) are also used to protect resources and at times are monitored to track effectiveness. BMPs have been shown to be very effective when implemented (Cristan 2016). Monitoring of PDC can be done through the National BMP monitoring program (USDA 2012).

Alternative 3 – Vegetation Management – Limited Action Impacts on individual activity units will be the same as described in Alternative 2, though overall impact will be less. Alternative 2 has 17,000 acres of potential salvage harvest, while Alternative 3 only proposes 8,500 acres. This reduction in acres, will lead to less ground impacted overall along with potentially less temp roads constructed or old road templates re-opened. Alternative 3 will be less impactful to the soil resource than Alternative 2, since only about half of the acres are proposed for harvest; however, established BMPs and PDC will protect soil and water resources and mitigate potential impacts from harvest activities in both alternatives. Cumulative Effects Past Actions Timber harvest activities have occurred in the area for many years. Practices have become ‘lighter’ on the soil resource over the years. Some remnant of those old harvest activities and also recreational activities remains on the land. These activities have created some detrimental soil conditions in locations, especially the older timber harvests. Current PDCs, practices and equipment make it possible that harvest can occur with minimal

135 CP District-wide Salvage Project Final Environmental Impact Statement increases in detrimental soils effects.

On-going present actions Recreation, including camping, hiking, horseback riding, hunting, and firewood collection are on-going practices which have some effect in the analysis area. Cattle grazing has occurred and will continue to occur as the in the area. Riparian and open areas will see the most use by cattle.

Future Actions Grazing will continue into the foreseeable future. Adjustments may be made to improve forage use and stream/riparian protection. As trees die and are cleared it may increase forage and grazing area on a temporary basis which may reduce grazing pressure in other areas. In the long run it is expected that the grazing program will remain the same into the future with similar effects. Timber harvest activities are likely to increase and result in increased soil disturbance overall in the short term; however into the future timber activities are likely to slow and shift out of the spruce zone for an extended period, perhaps as long as 100 to 150 years. This will affect the timber program and related activities within the analysis area into the future.

3.9 Rangeland Scope of Analysis This analysis considers the effects to rangeland and rangeland management from the proposed vegetation management activities. Because there will be no effect to range management in areas where there are no activities proposed, this analysis will only focus on those rangeland management allotments where activities are proposed to occur. Existing Conditions Proposed treatment areas are located within thirteen range allotments: seven sheep and goat allotments and six horse and cattle allotments. Of the thirteen allotments, eleven are active and two are vacant (both sheep allotments). An active allotment is currently managed under a grazing permit and regular livestock use occurs. Vacant allotments have no current permitted grazing but they are open for consideration to future permitted grazing through a term (up to 10 years) or temporary (short-term) grazing permit. Range management is analyzed through a separate NEPA analysis. Most of the allotments within the project area have current and active NEPA. The Alamosa allotment is part of a current rangeland management NEPA effort (CPRD current). There are no range decisions associated with this analysis. Acres currently classified as unsuitable or incapable for grazing are not being proposed for conversion to suitable or capable. Overall, current conditions of rangeland resources within the project area are healthy and vigorous. There are areas of concern due to activities associated with permitted livestock grazing. These areas are vulnerable due to livestock use, existence of invasive and noxious weeds or lack of an effective grazing rotation. However, these areas exist primarily in rangeland and open meadows and will be minimally or not at all affected by the proposed action. There are a variety of range improvements in the project treatment areas, including pasture and allotment boundary fences, corrals and water developments including spring developments, pipelines, ponds and stock tanks. These improvements will be considered and, in most cases, protected during project-level analysis and layout.

136 CP District-wide Salvage Project Final Environmental Impact Statement Direct and Indirect Effects Alternative 1 – No Action No timber salvage or tree planting activities would occur under the No Action Alternative. There would also be no hazardous fuels mitigation. Multiple-use activities such as firewood gathering, recreational travel, dispersed recreation and wildlife use would continue. These activities serve as vectors for the introduction and spread of nonnative, invasive plant species, which can impact the quality and quantity of forage. Current invasive species management would continue to be implemented. Under the No Action Alternative, there would be no additional opportunity for release of desirable forage species based on the immediate canopy opening caused by timber removal.

Alternative 2 – Proposed Action Mechanical treatments and pile burning may reduce forage in the short-term due to soil disturbance and removal of vegetation during timber removal operations. Selection of either action alternatives would likely have beneficial results for rangeland management in that increasing the penetration of light to the forest floor and available precipitation from canopy removal would likely release desirable forage species and provide for an increase in movement corridors for domestic livestock to access secondary range areas that were inaccessible prior to implementation. Some resource conflicts may occur in areas where natural barriers no long keep livestock out of regenerating stands and temporary fencing, salting and additional herding is needed to protect these stands. PDC is considered adequate for successfully managing this conflict. Another direct effect could occur if range improvements (fences, cattle guards, corrals, water developments, pipelines, troughs, stock driveways, etc.) are inadvertently damaged during project implementation. Permitted livestock could be displaced during proposed treatment activities and affect permittee operations in the short-term. Additionally, short-term impacts to grazing operations could occur in the following ways: shorter grazing seasons, fewer permitted livestock, alterations in grazing rotation, timing, season of use, total deferment of pastures, increased riding and salting (i.e. work) for the permittee and riders and increased range improvement maintenance. These actions may be needed and could be implemented in order to allow for unimpeded and safe salvage harvest operations and/or vegetation recovery following treatments.

Alternative 3 – Vegetation Management – Limited Action The proposed treatment activities for this alternative are the same as in the proposed action they only differ in spatial area and extent. The effects would be similar to those discussed for Alternative 2. Cumulative Effects Proposed activities, in combination with other foreseeable vegetation management could change forage conditions and can concentrate livestock use or affect livestock distribution patterns. Ongoing and increased recreation use and visitor travel can influence the distribution of wildlife and domestic livestock on the landscape. Management actions that facilitate the introduction and spread of invasive and noxious plants cumulatively impact the quality and quantity of forage for grazing animals. Climate change is likely to alter plant communities and precipitation patterns in a way that affects plant growth, herbaceous canopy cover, distribution of species and vegetation types, and annual productivity (Finch et al. 2012). Anticipated change in temperature and precipitation will likely result in a shift of species distribution and the potential reorganization of rangeland communities in the long-term.

137 CP District-wide Salvage Project Final Environmental Impact Statement 3.10 Invasive Species and Noxious Weeds Scope of Analysis This analysis focuses on the effects to noxious and invasive weeds from the proposed activities within the project area boundary though the existing conditions expand to the entire Conejos Peak Ranger District boundary.

Existing Conditions The Rio Grande National Forest utilizes the Colorado state noxious weed list to guide management on invasive plants. The State of Colorado Department of Agriculture ranks invasive plants species by their priority for treatment as List A, B and C (CWMA 2015). List A species are designated and managed for eradication whereas the management for List B species focuses on containment of known populations. List C species management focuses on an integrated approach to manage populations.

The Forest Invasive Species Action Plan (2016) provides strategy and direction for control, prevention and management of invasive species. The Plan’s strategy and direction tiers to previous guidance and decisions including:

• Forest Service National Strategic Framework for Invasive Species Management, August 2013 • Forest Service Handbook and Manual direction contained in 2900-Invasive Species • Rocky Mountain Region Invasive Species Management Strategy (FY 2005-2010), March 2005 • Revised Land and Resource Management Plan for the Rio Grande National Forest (as amended), November 1996 • Environmental Assessment for the Management and Control of Noxious Plants on the San Juan/Rio Grande National Forest, July 1996 • Management and Control of Noxious Plants on the San Juan/Rio Grande NFs – Sufficiency Determination and Supplemental Information Report, July 17, 2012

When discussing the risk of spread of invasive and noxious weeds there is a relative level of uncertainty given the number of factors that influence densities and distribution of weeds. Discussion of effects on invasive and noxious weeds is qualitative based on current knowledge of the primary weed species of concern within the project area.

Existing populations of noxious and invasive weeds on the Conejos Peak Ranger District were compiled from the most current GIS data derived from survey, treatment and inventory files collected in the field. Table 50 shows the results of a compilation of this data for the district.

Table 50. Species list and acreage of known Colorado designated noxious weeds

State Designation Species common & scientific name Acres* List A Orange hawkweed <1 Hieracium aurantiacum List B Canada thistle 883 Cirsium arvense Hoary cress 1 Cardaria draba Musk thistle 3 Carduus nutans Oxeye daisy 515 Leucanthemum vulgare

138 CP District-wide Salvage Project Final Environmental Impact Statement

State Designation Species common & scientific name Acres* Perennial pepperweed 3 Lepidium latifolium Russian knapweed 6 Acroptilon repens Scotch thistle <1 Onopordum acanthium Yellow toadflax 10 Linaria vulgaris List C Downy brome/cheatgrass 17 Bromus tectorum Field bindweed 3 Convolvulus arvensis Total 1,441 *Number of acres are approximate and derived from forest GIS noxious weed inventory files collected in the field.

The intent of invasive and noxious weed management within the project area consists of the following:

• Restrict the possibility of invasive plant propagules entering the project area; • Pre-treat known populations within the treatment areas to reduce the potential for spread of these species through project activities; • Apply PDC to reduce the potential for noxious weeds to establish or spread within recently disturbed areas; • Monitor recently disturbed areas for new invasive plant establishment so immediate action can be employed to eradicate or control new infestations; • If new infestations are discovered, they are added to annual treatment plans and inventory maps.

Direct and Indirect Effects Alternative 1 – No Action The No Action Alternative is used to compare the Proposed Action to other alternatives. Under Alternative 1 there would be no direct effect to invasive and noxious weed populations from project activities. Weeds would continue to be introduced and spread by common vectors such as wildlife, permitted livestock, and recreational travel and use. Efforts to eradicate and control noxious weed species would continue through the implementation of the Invasive Species Action Plan (RGNF 2016). Effects of introduction, establishment and spread of invasive plant species within the project area include:

• Negative changes to native plant abundance, density and species richness due to the invasiveness of noxious weeds to establish and aggressively compete for resources; • Displacement of native plants and animals; • Reduction in forage capability for wildlife and domestic livestock; • Potential increase in soil erosion due to the decrease in potential canopy cover and to the shallow rootstock of some invasive plants; • Increased cost of mitigation and treatment of invasive and noxious weeds.

Alternative 2 – Proposed Action Under the proposed action, the direct effects of introduction, establishment and spread of invasive plant species within the project area are the same as in Alternative 1. Direct effects from project implementation, specifically timber salvage activities, could include an increase in the spread of noxious weed populations caused by the movement of propagules on machinery, vehicles and equipment into, between, and within the treatment units. Disturbances such as skidding logs, building temporary roads, road maintenance and driving cross-country,

139 CP District-wide Salvage Project Final Environmental Impact Statement increase bare soil and remove competitive native plant cover creating more suitable habitat for invasive plant species (Birdsall et al. 2012). Areas at highest risk for the spread and increase of invasive plants are those with known populations in or near treatment units, roads and proposed temporary roads. Additional ground disturbance in these areas could cause an increase in pre-existing populations due to the germination of noxious weed seeds or the stimulation of roots and suckers.

Disturbance, soil exposure and the removal of litter and duff reduce a plant community’s resistance to invasion (D’Antonio et al. 2001). Variability in canopy cover and, more specifically, the reduction of canopy cover increases the opportunity for invasive plant cover to increase (Kelley and McGinnis 2007, Merriam et al. 2006, Gibson 2002). The overstory in the proposed project area has already been reduced by beetle activity and subsequent tree mortality. Though the impact wouldn’t be as great on salvage removal as it would if the activities were proposed in green-tree stands, there is still a subsequent reduction to canopy cover when dead stems are removed. This increases the availability of light and nutrients to understory plants including invasive species. Pile burning activities associated with hazardous fuels mitigation can remove native vegetation therefore creating bare soil and opportunity for invasive plants (Keeley 2006). Fire, depending on intensity and duration, can also reduce native seed banks.

A review of literature found that most vegetation treatment activities would in fact result in increases in nonnative plant species (Thysall and Carey 2001, McGlone et al. 2009). However, it is likely with pre and post-treatment of known populations that some of these populations would remain stable or decrease, particularly in the long-term. Additionally, with the adherence to forest plan standard and guidelines, PDC (Table 7), the pre-implementation checklist process and control methods outlined in the Invasive Species Action Plan, there should be no net gain in nonnative invasive plant populations in the project area in the long- term.

Alternative 3 – Vegetation Management – Limited Action The effects to invasive and noxious weeds from selecting this alternative would be the same as the effects described for the Alternative 2; however, the effects would be on a smaller scale since the acreage proposed for treatment under this alternative is less than in Alternative 2. Cumulative Effects Studies conclude that the increase in invasion of exotic plants includes a frequent disturbance regime. Areas of multiple or prolonged disturbance have an increased susceptibility to invasive plants (MacDougall 2005). Multiple-use activities associated with but not limited to silviculture and timber harvest, recreation, permitted grazing, wildlife use and visitor travel continue to serve as potential vectors for the spread of invasive and noxious weed species on the Forest.

Over time, the combination of proposed salvage treatments including revegetation activities should increase the overall plant species diversity in affected stands. A proportion of the species diversity could be composed of invasive plants but it is likely the majority of plant diversity would be composed of native species present on- site prior to treatment (Griffis 2001, Fule et al. 2005). Another study describing an increase in invasive species following controlled mechanical and prescribed fire treatments indicates that the ecological impacts of these species may not be severe. In this study, natives outnumbered non-native invasive plants following treatment by an almost thirteen to one ratio (Dodson 2004). In the long-term, as areas revegetated with native understory cover species, there would be fewer available areas of light and growing space where invasive plant species would establish.

140 CP District-wide Salvage Project Final Environmental Impact Statement 3.11 Air Quality Scope of the Analysis This section describes the effects to air quality in the vicinity of the CP District-wide Project area including nearby private land and the South San Juan Wilderness Area, a Class I airshed. The nearest town is the Village of Chama, New Mexico, which is about 12 miles south.

Past Actions that have Affected Existing Condition Current land ownership patterns, wilderness designations, relatively low population, and lack of industrial development have minimized the sources of sustained air pollutants. Pulses of emissions that do occur are generally small, localized, and short-lived and therefore seldom overlap in time and space.

Existing Condition Current conditions of air quality in Colorado are detailed in the Colorado Air Quality Control Commission: Report to the Public 2015-2016 (CAQCC 2015). The project area is located in the Colorado’s Central Mountains Air Quality Region which includes many of the mountains and mountain valleys areas of the state. Skiing, tourism, ranching, mining, and correctional facilities are the primary industries in this region. All of the area complies with federal air quality standards (Colorado Dept. of Public Health 2011).

Information on air quality within the United States is available through the Visibility Information Exchange Web System (VIEWS”) website (http://views.cira.colostate.edu/web/Default.aspx), an on-line database for air quality information and analysis. There are no air quality monitoring stations in the vicinity of the project area.

Direct and Indirect Effects Alternative 1 - No Action No logging operations or pile burning would occur, so no additional emissions would occur.

Alternatives 2 and 3 – Proposed Action and Vegetation Management - Limited Action Proposed project activities in the action alternatives that could directly affect air quality would include the combustion of fuel from equipment use in cutting, transporting, and hauling logs, burning slash piles at landings following harvest completion, and, if used, burning hand-piled slash as part of hazardous fuel reduction treatments.

Vehicle emissions from harvest operations would occur. Emissions would be a short-term, but would occur on an intermittent basis for several years. Depending on the season of logging (winter vs. summer), some amount of dust could be generated during harvest activities, which could be more visible than vehicle emissions.

The two action alternatives identify pile burning as a likely way to dispose of slash generated by both the WUI fuel treatments adjacent to private property and the large slash piles at landing areas. Pile burning usually occurs after the slash has cured for at least one season and is in the red-needled stage; piles are typically burned in the winter with adequate snow cover (minimum of 2 inches of continuous snow) to prevent the fire from spreading. Due to the seasonal nature of most residency within and adjacent to the project area, as well as the dispersed nature of the landing and pile burning (both in space and time), the minor amounts of smoke generated would be unlikely to impact any residences. Due to prevailing wind direction, the limited scale of winter burning operations would be unlikely to impact nearby summer residences or the Village of Chama.

141 CP District-wide Salvage Project Final Environmental Impact Statement Qualitatively, Alternative 3 would generate less vehicle emissions and dust, since fewer acres would be harvested and fewer landing slash piles would be burned, but neither alternative would be expected to have a measurable impact on local air quality.

All pile burning operations would also require smoke permits issued by the Colorado Air Pollution Control Division (CAPCD). Prescribed burn permits include specific parameters that must be met to limit short term air quality impacts from smoke. Prescribed burns also require burn plans that consider smoke dispersal and impacts to local residences and visitors to the area to ensure that adverse effects are minimized. No other types of permits are identified as necessary to implement the proposed actions. Cumulative Effects Emissions generated by implementing an action alternative would contribute somewhat to local pollution, especially if activities overlapped in time with other logging activities in the vicinity, but all affects would be short-term and limited. Once project activities are completed in a particular area, any additional dust or smoke impacts would cease and have no further overlap in time or space with other pollution sources. As a result, the CP District-wide Salvage Project Area is expected to remain classified as in attainment for National Ambient Air Quality Standards throughout all alternatives and would meet the national goal of preventing any future impairment of visibility in mandatory federal Class I airsheds.

All alternatives, therefore, would comply with the Clean Air Act. This conclusion is additionally supported by the Forest Plan FEIS (USDA Forest Service 1996a), pages 3-151 through 3-154 that air quality on the Forest is good for all air pollutants and all Forest Plan approved activities would meet National Ambient Air Quality Standards.

3.12 Fire and Fuels Scope of Analysis The scope of the fire and fuels analysis is the approximately 332,000 acre project area. Existing Condition The Conejos Peak District-wide project area would be generally categorized as Fire Regime V or infrequent fire occurrence (200+ years) and stand replacement in nature. The area is dominated by Engelmann spruce (Picea engelmannii) and subalpine fir (Abies lasciocarpa) with a very minor component of aspen (Populus tremuloides) in portions of the analysis area. Climate and weather conditions generally play a greater role in large fire development than fuel loading in this type of fire regime. However increased surface fuel accumulation increases the fire’s resistance to control and increases soil heating impacts. Direct and Indirect Effects Alternative 1 – No Action The extensive spruce beetle mortality within the Conejos Peak District-wide project area will increase surface fuel accumulation over time as the dead trees fall over. Recently modeled stand data show stands in the project area currently have an average fuel loading of 18.4 tons per acre in dead surface fuel larger than 3 inches in diameter. These larger fuels have a direct effect on fire residence time and soil heating impacts (DeBano 2000) if a wildfire occurs. Using Forest Vegetation Simulation (FVS) modeling over a thirty year timeframe the majority of the standing dead trees will have fallen and increased the dead surface fuels load (3”+) to an average of 44.9 tons per acre. Over a fifty year timeframe the dead surface fuel load (3”+) is projected to still be 43.6 tons per acre. These larger diameter fuels will persist on the landscape for a long period of time due to the slow decomposition rate of these large logs. The smaller diameter fuels (0-3”) will increase in the first 20 years as the dead trees lose their fine branch wood, but will start to decrease over time as these smaller fuels decompose.

142 CP District-wide Salvage Project Final Environmental Impact Statement

As the large diameter surface fuels accumulate the potential for more intense, longer duration fires and associated soil impacts also increase.

Table 51. Summary of fuel loads within the project area for the No Action Alternative

No Action Fuel Load Fuel Load Fuel Load Fuel Load Total Surface Alternative- Year 0-3” 3-6” 6-12” 12”+ Fuel Load 3”+ (tons/acre) (tons/acre) (tons/acre) (tons/acre) (tons/acre) 2016 4 8.5 9.1 0.8 18.4 2026 10.6 9.4 14.9 6.1 30.4 2036 8 10 20.1 10.9 41 2046 6.4 9.9 21.1 13.9 44.9 2056 5.8 9.5 20.1 14.4 44 2066 5.8 9.2 19.4 15 43.6

Under this alternative no shaded fuel break thinning treatments would be done along private property or around existing infrastructure. As a result the canopy base height or canopy bulk density adjacent to these areas would not be altered. The following measures of fire spread potential are expected under this alternative. • The torching index is the 20 ft. wind speed which would increase surface fire intensity to the level at which individual tree torching could occur. Under this alternative the torching index would vary between 10.9 and 26 mph over the next fifty years. • The crowning index is the 20 ft. wind speed at which active crown fire is possible for the specified fire environment. Under this alternative the crowning index would vary between 21.3 and 30.8 mph over the next fifty years. • Canopy base height is the lowest height above the ground at which there is a sufficient amount of canopy fuel to propagate fire vertically into the canopy. Canopy base height is an effective value that incorporates ladder fuels such as shrubs and understory trees. The higher the canopy base height the lower the probability of tree torching. Under this alternative the canopy base height would vary from 5.5 ft. to 7.6 ft. over the next fifty years. • Canopy bulk density is the weight of available canopy fuel per unit volume of canopy space (kg/m3). It is the bulk property of the stand, not of an individual tree. The higher the canopy bulk density the more easily crown fires will spread. Under this alternative the canopy bulk density varies from 0.1045 to 0.1838 kg/m3 over a fifty year time period.

Table 52. Summary of key fuels and fire characteristics for the No Action Alternative

No Action Torching Index Crowning Canopy Base Canopy Bulk Alternative - (mph) Index Height Density Year (mph) (ft.) (kg/m3) 2016 21.7 25.1 5.9 0.1404 2026 18.6 30.8 5.8 0.1045 2036 10.9 26.4 5.5 0.1311 2046 12.4 23.8 5.7 0.1533 2056 18.5 22.2 6.7 0.1699 2066 26.0 21.3 7.6 0.1838

Alternative 2- Proposed Action The proposed action would reduce the large diameter surface fuel accumulation in the harvested areas by

143 CP District-wide Salvage Project Final Environmental Impact Statement removing the majority of the dead trees and lessen the potential risk of long duration, high intensity fires in the those areas. FVS modeling for this alternative over a thirty year timeframe show a surface fuels loading of 3” and larger material of 20.4 tons per acres which is 24.5 tons per acre less than the No Action Alternative. Over a fifty year timeframe FVS modeling show a surface fuel loading (3”+) of 18.8 tons per acre which is 24.8 tons per acre less than the No Action Alternative. In the future the estimated surface fuel loadings of 3 inch and larger diameter material, 20.4 tons/acre in 2046 and 18.8 tons/acre in 2066, are much closer to the desired Forest Plan down wood requirements of 10-15 ton per acre than the No Action Alternative. A project design feature requires treatment of the slash so that surface fuel build up can be minimized. In the harvest units, tree limbs and other woody slash that remain would be lopped to less than 2 feet in length and scattered to assist with the decomposition process. Until this slash less than 3” in diameter has decomposed there could be an increase in the potential rates of spread if a fire did occur within the harvest units (as modeled in Behave Plus using fuel model SB1). For hand thinning piles the materials to be piled are less than 4” in diameter and lopped to less than 4’ in length. Pile size is generally less than 8’ in diameter and 8’ in height. Boles larger than 4” in diameter will be lopped to less than 6’ in length and scattered. All landing slash would be piled for later burning by the Forest Service. Piles shall be reasonably compact and free of soil to facilitate complete burning. Piles will not be less than 6 feet in height. Piles shall be of a size and location which will not impair road use or result in damage to residual timber. Piles shall be located at least 30 feet from residual timber. Changes in species composition, age classes, and structure stages over the long term would create a patchier mosaic of fuels across the analysis area, which should help to limit large fire spread and severity.

Table 53. Summary of fuel loads within the project area proposed for salvage for Alternative 2

Proposed Fuel Load Fuel Load Fuel Load Fuel Load Total Surface Action 0-3” 3-6” 6-12” 12”+ Fuel Load Alternative- (tons/acre) (tons/acre) (tons/acre) (tons/acre) 3”+ Year (tons/acre) 2016 4 8.5 9.1 0.8 18.4 2026 9.8 8.7 10.4 2.6 21.7 2036 6.7 8.6 10.2 2.7 21.5 2046 5.4 8.1 9.7 2.6 20.4 2056 4.8 7.7 9.2 2.6 19.5 2066 4.8 7.4 8.8 2.6 18.8

Under this alternative shaded fuel break thinning treatments would be done along private property and around existing infrastructure to increase canopy spacing, reduce stand density, and increase canopy base height. The following measures of fire spread potential are expected in shaded fuel break areas under this alternative: • The torching index in 2036 would be raised from 10.9 mph under the No Action Alternative to 42.7 mph under this alternative. In 2066 the difference would be 26 mph under the no action alternative versus 58.7 mph under this alternative. • The crowning index in 2036 would be raised from 26.4 mph under the No Action Alternative to 31.5 mph under this alternative. In 2066 the difference would be 21.3 mph under the No Action alternative versus 28.1 mph under this alternative. • The canopy base height in 2036 would be raised from 5.5 feet under the No Action Alternative to 14.3 feet under this alternative. In 2066 the difference would be 7.6 feet under the No Action Alternative versus 18.1 feet under this alternative.

144 CP District-wide Salvage Project Final Environmental Impact Statement

• The canopy bulk density in 2036 would be reduced from 0.1311 kg/m3 under the No Action Alternative to 0.0745 kg/m3 under this alternative. In 2066 the difference would be 0.1838 kg/m3 under the No Action Alternative versus 0.0969 kg/m3 under this alternative.

Table 54. Summary of key fuels and fire characteristics for the areas proposed for shaded fuel breaks in Alternative 2

Proposed Action Torching Crowning Canopy Base Canopy Bulk Alternative – Index Index Height Density Year (mph) (mph) (ft.) (kg/m3) 2016 18.9 23.5 5.6 0.1435 2026 34.1 38.1 12.3 0.0661 2036 42.7 34.3 14.3 0.0745 2046 48.3 31.5 15.9 0.0828 2056 52.2 29.4 17.1 0.0905 2066 58.7 28.1 18.1 0.0969

Alternative 3 – Vegetation Management – Limited Action This alternative would achieve similar surface fuel reductions to Alternative 2 over a smaller footprint area. There are some slight variations in the projected fuel loads between this alternative and Alternative 2 due to the differences in the number of stands modeled and their individual stand data. Similar changes in species composition, age classes, and structure stages over the long-term would create a patchier mosaic of fuels across the analysis area, which should help to limit large fire spread and severity over a smaller treated area than Alternative 2.

Table 55. Summary of fuel loads within the project area proposed for salvage for Alternative 3

Limited Fuel Load Fuel Load Fuel Load Fuel Load Total Surface Action 0-3” 3-6” 6-12” 12”+ Fuel Load Alternative- (tons/acre) (tons/acre) (tons/acre) (tons/acre) 3”+ Year (tons/acre) 2016 4 8.4 9.1 0.8 22.3 2026 10 8.5 10.1 2.3 21.6 2036 6.7 8.3 10.3 2.8 21.2 2046 5 7.8 9.6 2.8 20.2 2056 4.2 7.4 9.1 2.7 19.2 2066 3.8 7 8.7 2.7 18.4

This alternative would allow for the same shaded fuel break thinning treatments as Alternative 2 and have similar effects the torching and crowning indices, canopy base height and crown bulk density.

Table 56. Summary of key fuels and fire characteristics for the areas proposed for shaded fuel breaks in Alternative 3

Limited Torching Crowning Canopy Base Canopy Bulk Action Index Index Height Density Alternative – (mph) (mph) (ft.) (kg/m3) Year 2016 18.9 23.5 5.6 0.1435 2026 34.1 38.1 12.3 0.0661 2036 42.7 34.3 14.3 0.0745 2046 48.3 31.5 15.9 0.0828 145 CP District-wide Salvage Project Final Environmental Impact Statement

Limited Torching Crowning Canopy Base Canopy Bulk Action Index Index Height Density Alternative – (mph) (mph) (ft.) (kg/m3) Year 2056 52.2 29.4 17.1 0.0905 2066 58.7 28.1 18.1 0.0969

Cumulative Effects Alternative 1- No Action The project area is broken by many natural barriers to surface fire spread such as open grass meadows, rock scree fields and cliff bands. However much of the fire spread potential in spruce/ fir ecosystems comes from short- and long-range spotting. The timber stands within the analysis area and the surrounding area have seen extensive vegetation management over the past several decades. Much of the area was treated with some type of timber harvest or timber stand improvement thinning in previous decades. These treatments reduced stand density in many areas which has help reduce crown fire spread potential, but the recent spruce beetle mortality has increased surface fuel accumulation from the dead spruce falling. FVS modeling show that this snag fall will continue over the next 20-50 years and will peak with a surface fuel accumulation of almost 45 tons per acre by 2046. These increased surface fuel loads would support long duration, high intensity surface fires which could have detrimental soil heating effects and could potentially cause more short and long-range spotting.

Alternative 2- Proposed Action Past harvest treatments within and/or adjacent to the analysis area have reduced stand density in many areas which has help reduce crown fire spread potential. Further harvest of standing dead will further help lower crown fire potential, surface fire intensity, and spotting potential.

Alternative 3- Limited Action This alternative would have similar cumulative effect to Alternative 2, but would not treat as many acres.

3.13 Socio-Economics Scope of Analysis Cost efficiency is a measure of how well inputs (activities) are used in a production process to produce a fixed set of outputs. It is only a partial measure because not all benefits and costs to society can be readily quantified. Costs to implement defined activities such as hazardous fuels reduction projects have been assigned dollar values based on known costs and are quantifiable. Other resources values such as watershed or riparian health, wildlife habitat and diversity, social benefits, and scenic resources cannot easily be assigned dollar values. This economic efficiency analysis does not consider ecosystem services or non- market goods that are not required at the project level by the National Forest Management Act (NFMA). Ecosystem services and non-market goods are addressed in the Forest Plan (refer to pages 3-445 through 3- 469 of the Final Environmental Impact Statement 1996). Alternatives that meet the requirements and intents of the Forest Plan, achieve net public benefits as stated in NFMA. The analysis area includes portions of three counties: Conejos (84 percent), Rio Grande County (9 percent), and Archuleta (7 percent). No activities are proposed in Archuleta County since the portion of project area in this county is mostly in designated wilderness or roadless areas. Therefore, Archuleta County is not included in the discussion. The social effects discussion includes Conejos County, Rio Grande County, Colorado and Rio Arriba County,

146 CP District-wide Salvage Project Final Environmental Impact Statement New Mexico. These counties are all primarily rural with relatively small communities and populations. Communities within the analysis area include Jasper and Platoro; nearby communities include Antonito and La Jara to the east, Del Norte to the north and Chama, New Mexico to the south. The social aspect of the report briefly describes potential qualitative effects based on known local social habits and uses of the Forest in or near the analysis area. These uses and trends were also described in the Rio Grande National Forest Plan Revision in Assessments 6, 7, 8, and 8.1.. This information helps to consider the project in the local context. The economic analysis focuses on the financial efficiency associated with commercial timber harvest and fuels reduction treatments proposed with the Conejos Peak District-wide Salvage Project. The purpose of this analysis is not to determine exact costs associated with a project or determine if alternatives are above or below cost, but rather to compare the relative differences in financial efficiency between the alternatives. Assumptions were made in the financial efficiency analysis concerning the timing of activities. For each action alternative, all proposed commercial timber harvest acres and hazardous fuels treatment acres were assumed to be divided into equal annual increments with timber sales being sold and acres being contracted for thinning over the course of ten years. Timber sale contract administration, tree planting, or pile burning activities could continue for an additional five years. These assumptions may not be reflective of how project units would actually be divided or implemented, but provides a reasonable, comparative estimate of expected costs and benefits for each alternative. Specific costs and benefits used in the economic analysis were based on recent, local experience and specialist input. Existing Condition Culturally, the rural analysis area counties continue to represent a mix of Anglo, Hispanic, and Native American cultures. Southern Colorado has been utilized and inhabited to varying extents by all these cultures over hundreds of years and new migrants continue to add to the local cultural identity. The Forest lands in the analysis area are used by local populations and visitors for hunting, fishing, hiking, livestock grazing, firewood cutting, scenery and wildlife viewing, water sources, spiritual reasons, and other personal and commercial ventures related to natural resources. Firewood is an important source of household heating in Conejos and Rio Arriba Counties (US Department of Commerce 2013e, as cited in Assessment 6, pgs. 28-30) and is a resource potential to be directly affected by proposed activities. Socially and culturally, residents of Conejos and Rio Grande Counties each identify farming, fishing, and forestry occupations as their industry of employment for about 13.5% of their local populations, which is higher than the average of 7.7% for the non-metro portion of Colorado; Rio Arriba County is less with about 2.1% employed in these industries. Much of the saw-timber cut on the Forest is processed in the San Luis Valley mills located in La Jara, Del Norte, and Saguache (Forest Stewardship Concepts Ltd 2014). Some additional saw timber from the Forest is also processed in Chama, New Mexico. Since the 2015 EPS (Economic Profile System) data was compiled, additional wood process/milling employers have become established near La Jara and Blanca (in Costilla County east of the analysis area) and may also provide some additional opportunities for future employment. All three counties have over 20 percent (21.1 to 25.3%) of their populations employed in the Education/Health/Social Assistance occupations. Retail trade and construction are also important occupations in these counties. Based on EPS Demographics data (2015), poverty levels for individuals are identified at 18.3, 19.2, and 23.7 percent for Conejos, Rio Grande, and Rio Arriba Counties, respectively. All of these percentages are substantially higher than the 9.7 percent average for individuals in Colorado, outside of metro areas, but are only slightly higher than the 21.9 percent for individuals in non-metro areas in New Mexico. Percent of full time employment (greater than 35 hours/week, more than 50 weeks/year) ranges from about 45 to 58 percent, with Rio Grande county seeming to have the highest full time employment.

147 CP District-wide Salvage Project Final Environmental Impact Statement Direct and Indirect Effects Alternative 1 – No Action Under Alternative 1, firewood for personal use would continue to be abundant and accessible in the spruce- fir vegetation type, since additional areas would not be sold to commercial timber companies. This alternative would avoid any potential negative short-term social effects such noise, dust, or traffic concerns that may affect uses of the area. However, this alternative would not modify fuels adjacent to private properties or near infrastructure which would leave these structures at higher risk to damage from wildfires, should one occur, or at risk from falling dead trees in the spruce-fir forest type which could result in increased financial risks. The large numbers of standing or eventually down dead trees may also change uses of the spruce-fir forest due to safety or access concerns. Alternative 1, the No Action Alternative, does not generate revenues through the sale of commercial forest products, nor does it provide for active forest management adjacent to private lands or infrastructure that would also result in non-quantified potential benefits. This alternative does not incrementally contribute to economic sustainability for local communities or the commercial forest products industry. Additionally, this alternative would not help facilitate reforestation in any non-stocked or understocked stands in the spruce-fir forest where the overstory has been killed by spruce beetles and that lack understory advance regeneration. It also would not assist with road maintenance or other identified road improvement needs. Because costs have been incurred to complete the Environmental Impact Statement and no revenues are derived from this alternative, the benefit to cost ratio is 0.00. Alternative 2 – Proposed Action Under Alternative 2, firewood availability for personal use in the spruce-fir forest type would likely be reduced over time compared to Alternative 1, since dead trees on up to 17,000 acres would be sold to commercial timber companies. This would reduce personal use firewood gathering in accessible areas as implementation proceeds, though since operations would occur over several years, the reduction in acres available may not be apparent for several years for most permit holders. Opportunities to cut firewood from slash piles would be increase in availability over several years, which would still supply the needed material, though it may not be a favored source of wood collection for some individuals. This alternative would likely have the highest levels of potential for noise, dust, traffic conflicts, or other social conflicts (see Recreation section). This alternative would have the most potential to reduce the numbers of standing or eventually down dead trees which may reduce safety concerns and improve or maintain access and usability of the spruce-fir forest. This alternative would also have the highest potential to assist with road maintenance or other identified road improvement needs. Alternative 2 would generate a benefit-to-cost ratio of 1.21, which is the highest of the three alternatives analyzed. The net present value of this alternative is $414,257 which includes the cost of the hazardous fuel treatments, pre-implementation reviews, contract administration, timber sale preparation, timber sale administration and reforestation costs. Recent average bid rates for commercial timber values were included as the benefits. The present value of the benefits (forest products) being offered under this alternative and present value costs associated with this alternative are $(-1,969,296) and +$2,383,553 respectively, which would result in a positive net present value. Under this alternative, an estimated 340,337 CCF of wood fiber could be offered, and approximately 1,000 acres could be treated to reduce hazardous fuels adjacent to private land and/or to protect infrastructure, which could provide potential resource benefits that were not quantified. Alternative 2 has the largest benefit-to-cost ratios of all the alternatives analyzed since it would offer the greatest volume of commercial sawtimber which provides the economic benefit. This alternative would likely have a positive incremental effect on local economic conditions including the forest products industry. It would also help accelerate forest regeneration, as needed, in understocked spruce stands to meet future objectives. Making resources available to local and regional industry has potential to help sustain or boost the social structure of local counties which have some reliance on forestry and construction jobs which combined account for 22.6% of the employment in Conejos, 19.9 percent in Rio Grande, and about 10.5 percent in Rio Arriba

148 CP District-wide Salvage Project Final Environmental Impact Statement Counties (EPS Demographics 2015). Since sawtimber volume is offered under an existing Forest timber management program with a goal of selling a steady and sustainable volume of sawtimber, this alternative would likely have the most potential to contribute to a sustained economic impact over the next ten to fifteen years.

Alternative 3 – Vegetation Management – Limited Action Under Alternative 3, firewood availability for personal use in the spruce-fir forest type would likely be reduced more than Alternative 1, but less than Alternative 2, since approximately 51 percent fewer acres would be sold to commercial timber companies for salvage harvest. As with Alternative 2, there may be some incremental effects on firewood gathering as project implementation proceeds, it may not be apparent for several years or until a timber sale effects an area that is favored by an individual. Firewood gathering opportunities from slash piles would be less than Alternative 2. Compared to Alternative 2, this alternative would likely have somewhat less potential for noise, dust, traffic conflicts or other social conflicts (see the Recreation section). This alternative would also reduce the numbers of standing or eventually down dead trees that would help address safety or access concerns, but on about half the number of acres. This alternative would have less potential to assist with road maintenance or other identified road improvement needs, compared to Alternative 2. Alternative 3 generates a benefit-to-cost ratio of 0.95, which is lower than Alternative 2. The net present value (benefits minus costs) of Alternative 3 is $64,050, which includes the cost of the hazardous fuel treatments, pre-implementation reviews, timber sale preparation, and timber sale administration, and reforestation costs; recent rates for commercial timber values were included as the benefits. The present value of the forest products being offered under this alternative and present value costs associated with this alternative are $(- 1,329,884) and $+1,393,934, respectively. This alternative has a lower commercial product value (benefits) and a lower present value cost of the two action alternatives, since fewer acres are proposed for salvage harvest. Net present value would be slightly negative compared to Alternative 2. This alternative could produce an estimated 189,906 CCF of sawtimber volume which would be about 56 percent less than Alternative 2. As with Alternative 2, approximately 1,000 acres could be treated to reduce hazardous fuels adjacent to private land and/or to protect infrastructure, which could provide potential resource benefits that were not quantified. This alternative would also likely have a positive incremental effect on local economic conditions, including the forest products industry, though not as great as Alternative 2. It would also help accelerate forest regeneration in understocked spruce stands to meet future objectives, though reforestation would occur on about 49% fewer acres compared to Alternative 2. This alternative would also contribute to the Forest goal of selling a steady and sustainable volume of sawtimber over the next ten to fifteen years, but at a lesser extent than Alternative 2. Cumulative Effects Past actions that have affected the existing condition in the analysis area include a variety of management decisions and activities. Many of the stands in the analysis area have previously been harvested to some extent, while other stands have remained relatively unmanaged. Past activities and timber harvests have created access roads, which have improved the financial feasibility of proposed salvage activities. There are other forest management activities ongoing and planned in the analysis area and on nearby private lands. These activities would also incrementally support the local economy and communities to some level over the next several years by contributing to the wood products and related industries and also supporting the local retail sales and service industries. Forest management activities that promote the long-term sustainability of the forested landscape also help contribute to the sustainable use of the area for recreation, wildlife habitat, and meeting other future needs.

Comparison of Alternatives Table 57 shows a comparison of the financial efficiency of the three alternatives considered in detail for this 149 CP District-wide Salvage Project Final Environmental Impact Statement project. As indicated, Alternative 2 would have the highest benefit to cost ratio and Alternative 1 the least. Alternative 2 would also have the highest potential to benefit local communities with workers in the forestry employment sectors. Alternative 3 would provide more benefits than Alternative 1, but less than Alternative 2. Table 57. Financial efficiency for each alternative using a 4% discount rate

PV – Benefits PV – Costs Benefit: Cost Net Present Value ratio Alternative 1 $0.00 $150,821 0.0 $(-150,821) Alternative 2 $2,383,553 $1,969,296 1.21 $414,257 Alternative 3 $1,329,884 $1,393,934 0.95 $(-64,050)

Compliance with RGNF Land and Resource Management Plan and Other Relevant Laws, Regulations, Policies and Plans

Executive Order 12898 - Environmental Justice Act Executive Order 12898 and for the Forest Service, USDA departmental regulations (1997), direct federal agencies to focus attention on human health and environmental conditions in minority and low income communities and evaluate the effects of federal actions on these populations. The purpose is to identify and address, as appropriate, disproportionately high adverse human health or environmental effects on minority, low income populations, or American Indian tribes. The San Luis Valley is comprised of six local Colorado counties and is used as the geographic area of comparison for the counties considered in this analysis. The median household income in the San Luis Valley is $35,634 (U.S. Census Bureau, 2009-2013). The median household income in Conejos County is $36,652 with 13.9% of the families below the poverty level. In Rio Grande County the median household income is $39,672 with 15.3% of families below the poverty level. For Rio Arriba County the median household income is $36,098 with 17% of families below the poverty level. The median household income in the three counties considered are slightly higher than the San Luis Valley as a whole. The population composition by racial affiliation of Conejos and Rio Grande Counties are similar to the entire San Luis Valley and do not likely have a distinctly different minority population. Rio Arriba County may have a distinctly different minority population compared to the other two counties and the San Luis Valley. Based on the information available, the local counties would not be considered low income, but do have minority populations, as defined by Executive Order 12898 (CEQ 1997; Romero et al. 2001). Based on scoping and public involvement process (chapter 1), there are no indications that the proposed action or any of the alternatives would have a disproportionate adverse effect any low-income or minority populations or American Indian tribes. Based on information provided in the Social-Economics, Air Quality, Heritage, and other sections in this document, no adverse impacts are expected on any populations. No concerns have been identified by any minority populations. Table 58. Population information for Conejos, Rio Arriba and Rio Grande Counties (2015)

Ethnicity Conejos Rio Grande Rio Arriba San Luis County County County Valley Hispanic or Latino 54.4% 44.2% 71.5% 50.1% White 43.3% 53.1% 13.1% 47.3% Other races 0.7% 1.6% 1.4% 2.6% American Indian 1.6% 1.1% 14.0% <1% Total population 8,249 11,745 39,949 46,027

Sources: EPS Demographics for each county. Produced by Economic Profile System (EPS) in June 2017. http://headwaterseconomics.org/tools/economic-profile-system; San Luis Valley Statistical Profile, April 2015. San Luis Valley Development Resources Group and San Luis Valley Council of Governments

150 CP District-wide Salvage Project Final Environmental Impact Statement

The action alternatives would provide more potential for economic benefit and diversity that could benefit local populations in a variety of ways (Social-Economics, Recreation sections). The No Action Alternative might not provide direct or indirect benefits, but it would be unlikely to cause measurable harm. Notwithstanding, there may be additional financial risk for those that may have homes adjacent to the analysis area that could benefit from proposed fuels reduction treatments. Cumulatively, the additional commercial forest products and continued availability of local firewood, both in the form of either standing dead snags or in slash piles created during salvage harvest in the analysis area would continue to help provide economic opportunities to area residents and provide low income individuals with an economical source of local wood for home heating, as needed.

3.14 Heritage Scope of Analysis Several thousand acres within the analysis area have been previously surveyed for heritage resources from the late 1970’s to the present. The results suggest an overall low density of heritage resources that represent the entire spectrum of human occupation in the San Luis Valley; 12,000 Before Present (BP) to 50 BP. These include small ephemeral prehistoric camps, historic logging sites and historic grazing sites to name a few. The latter include cow camps, stock driveways, cairns and arborglyphs. The low density of archaeological sites is attributed to the high elevation and rugged terrain. The Conejos Peak District-Wide Salvage Project has the potential to affect historic properties; heritage resources eligible to the National Register of Historic Places. Due to the scale of the project, the Rio Grande National Forest will sign a Record of Decision (ROD) without full assessment of project effects on potential historic properties. Instead, a Programmatic Agreement (PA) between the Rio Grande National Forest and the Colorado State Historic Preservation Office (SHPO) will be used to comply with the legal mandates of the National Historic Preservation Act (NHPA) that requires federal agencies to take into account the effects of their undertakings on historic properties. The PA outlines step-by-step procedures the FS will use to comply with the NHPA during project implementation through time (available in the project record at Rio Grande National Forest website). Key components of the PA are as follows: 1. The Rio Grande National Forest (Forest) became a signatory to the Colorado Bark Beetle PA in 2017 in order to phase in the NHPA’s Section 106 process for large landscape-scale bark beetle salvage projects, which allows the ROD to be signed before heritage resource surveys are completed for each tiered undertaking. 2. This agreement also (a) allows the Forest to implement undertakings in areas in which no cultural resource sites are located prior to sending the report to the State Historic Preservation Office (SHPO); (b) identifies specific activities having no potential to effect historic properties; (c) identifies areas of potential effect and survey strategies for specific undertakings having the potential to affect historic properties; and (d) allows for implementing off-site mitigation if conditions are too dangerous for heritage resource surveys. 3. The PA does not eliminate requirements to conduct heritage resource inventories and effects analysis prior to implementation. 4. Consultation with the SHPO will not be necessary for exempted undertakings listed in Appendix B of the PA. 5. A pre-implementation checklist will be employed to ensure the PA is followed through the life of the project (Appendix L – Heritage Checklist Template). The legal framework also requires that the agencies consider cultural resources as they relate to the

151 CP District-wide Salvage Project Final Environmental Impact Statement Archeological Resources Protection Act (ARPA) of 1979, the American Indian Religious Freedom Act (1979) and the Native American Graves Protection and Repatriation Act (1992). In addition, the FS is a signatory to the San Luis Valley Intra-tribal and Intra-agency Memorandum of Understanding (MOU) that provides procedures for compliance with the Native American Graves and Repatriation Act of federal lands within the San Luis Valley of southern Colorado (SLV NAGPRA MOU 2008). Existing Condition A Class I literature review utilized the records of the Colorado State Historic Preservation Office, the heritage resource atlases of the Rio Grande National Forest and all relevant heritage resource inventory reports (Reiser 2017). This overview revealed that proposed treatment areas for Alternative 2 (proposed action) have a total of 8,147 acres previously surveyed (46%) for heritage resources. Proposed treatment areas for Alternative 3 have a total of 4,541 acres previously surveyed (48%) for heritage resources. Previous inventories have resulted in data that serve to inform the current project analysis in terms of sites of significance (eligible to the National Register of Historic Places or not eligible), the site types and site distribution across the landscape as well as high potential vs. low potential areas, based on a predictive model vetted by the State Historic Preservation Office. The predictive model aids in identifying high site probability areas that consider proximity to water, slope, vegetation and aspect. Some of the older surveys conducted in the late 1970s and early 1980s were not done to current standards. The predictive model, in addition to a summary of existing sites and surveys, goes far in helping archaeologists build research designs for each tiered undertaking and to understand the nature and scope of the potential for heritage resources across a large landscape. During the 2017 field season, two areas within the proposed Alternative 2 were surveyed for heritage resources in order to test the predictive model. A total of 84 acres were surveyed for heritage resources with negative results. A second area of ‘moderate potential’ received 140 acres of heritage resource survey, also with negative results. The collective 224 acres suggests that acres deemed moderate potential are more likely in the low range. When project activity areas are identified for implementation, a Heritage Checklist will be employed that will guide how project activities will comply with the Colorado Bark Beetle PA (Appendix L). Inventory data gathered within the analysis area since the mid-1970s suggests, not surprisingly, that most archaeological sites are organized around water. Outliers include a few prospect pits, tie-hack cutting areas, and aboriginal ‘chipping stations’ perched high on saddles or other promontories far from water. Low potential areas include the heavily timbered areas interior to the tree lines (which changes over time) and on slopes greater that 25%. It is also assumed that many heritage resources within the analysis have been impacted by historic logging events and/or have been collected upon and/or vandalized through time. However, it is also expected that some intact buried cultural deposits could remain. Within the proposed treatment units in Alternative 2, thirty-five heritage sites have been previously documented. Three are eligible to the National Register of Historic Places (NRHP), including Cumbres & Toltec Scenic Railroad; a National Historic Landmark. Ten sites remain unevaluated to the NRHP. Within the proposed treatment units in Alternative 3, sixteen sites have been previously documented. Two are eligible to the NRHP, including the Cumbres & Toltec Scenic Railroad, and six remain unevaluated. The literature search suggests variable degrees of site density across the analysis area depending especially on proximity to water. Previous inventories do suggest that heavily timbered areas (spruce-fir) exhibit very low potential for heritage resources while tree lines along watercourses exhibit more moderate potential. The unevaluated sites represent ‘deferred maintenance’ for the Heritage Program that is mandated to evaluate as many sites for significance as possible through the life of this project. All eligible and unevaluated heritage resources will be avoided by all project activities. Some sites have likely been negatively impacted by historic and unmanaged livestock grazing, wild ungulate grazing, unmitigated soil erosion, illegal roads, and/or dispersed recreational activities for decades. In addition, some of the analysis area may have been subjected to intensive logging activities that occurred between the

152 CP District-wide Salvage Project Final Environmental Impact Statement 1920s through the 1960s prior to the advent of the National Historic Preservation Act (NHPA) of 1966 or the National Environmental Policy Act (NEPA) of 1970. Direct and Indirect Effects Alternative 1 – No Action Since this alternative includes no ground-disturbing activities, the potential for inadvertent discoveries of and damage and destruction to surficial and buried cultural deposits or aboriginal human remains would be negligible. This alternative would have no direct effect on significant heritage resources and no design criteria or monitoring activities would be necessary. However, the fuel loading that would continue to occur under the No Action Alternative could result in negative direct effects to significant fire sensitive heritage resources if large scale catastrophic wildfires sweep over the region. Fuel loadings would continue to increase as snags fall, increasing the potential for longer duration fires and negative soil-heating impacts that can negatively impact archaeological features and artifacts.

Alternative 2 – Proposed Action Under this alternative, the potential for effects to heritage resources is highest of the action alternatives because it proposes the greatest number of acres to be potentially treated. However, the potential to effect heritage resources is low within areas proposed for commercial activities in higher elevation spruce-fir stands as they contain the lowest potential for heritage resources. If landings and skid trails are reused from past harvests, the potential of effect to heritage resources is reduced. If design criteria, the Heritage Checklist and the stipulations outlined within the PA are followed, there should be no adverse effects to significant heritage resources.

Alternative 3 – Vegetation Management – Limited Action Under this action alternative, the potential for effects to heritage resources is lowest of the action alternatives as there are fewer acres of treatments proposed. As with Alternative 2, proposed units are within low potential areas for heritage resources (high elevation spruce-fir). If landings and skid trails are reused from past harvests, the potential of effect to heritage resources is reduced. If the Colorado Bark Beetle PA, the Heritage Checklist and the design criteria outlined below are followed, there should be no adverse effects to significant historic properties.

Effects Common to All Action Alternatives Sanitation/salvage, fuels reduction treatments (mechanical thinning), tree planting, landings, and new road construction all have the potential to directly affect heritage resources. Direct negative effects to heritage resources of certain commercial and non-commercial treatments could include the potential destruction and/or alteration of unidentified heritage resources through ground disturbance and inadvertent impacts to standing structures. Indirect effects to cultural resources could include erosion potential from the removal of vegetation and increased resource visibility, which may make the resource vulnerable to vandalism. Conversely, vegetation removal can allow resources to be more easily inventoried and understood by researchers. Beneficial indirect effects from fuels reduction around fire sensitive heritage resources can result in greater protection from increasingly intense wildfires. Fuels reduction can therefore mitigate the potential negative effects to heritage resources from potential future suppression activities associated with a wildfire. Activities such as road maintenance and the opening of old roads would not be expected to directly impact heritage resources if maintenance is relegated to the original road foot print. Temporary road construction has the potential to have negative direct effects on unidentified buried cultural deposits for all action alternatives. Indirect effects from project activities can include the erosion of buried cultural deposits precipitated by temporary road construction and the removal of trees. Potential indirect effects from vandalism to heritage resources perpetrated by individuals associated with project activities is possible under the action alternatives.

153 CP District-wide Salvage Project Final Environmental Impact Statement Finally, action alternatives have the potential to negatively affect stands of the ethnobotanically significant oshá plant (Ligusticum porteri) in the short term. However, salvage operations would likely have a positive effect on plant populations over the long term. Preliminary research suggests and visual observation confirms that oshá responds well to overstory removal, precipitated by fire, beetle kill, and salvage logging alike (Kindscher et al 2017). While locally abundant, the plant is reported to be disappearing at lower elevations and in popular collecting locations in the southwest region likely due to climate change and over-harvesting by illegal commercial operations. Therefore, salvage activities will likely have positive direct effects on wild oshá populations in the analysis area and the southwest region. This increase could continue to drive discussions and research toward the limited commercial harvest of the plant as an alternative forest product. That said, tribal consultation has revealed that most Tribes affiliated with the project area are adverse to any commercial harvest of the plant. Cumulative Effects The loss of heritage resources has happened in the past and will happen in the future. The cumulative effect is that over time fewer heritage resources will be available to learn about past human lifeways, to study changes in human behavior through time, and to interpret the past to the public. Heritage resource inventory, recording, evaluating and archiving basic information about each site for future reference serves to partially mitigate potential cumulative effects to heritage resources. In conjunction with the proposed project, previous logging activities, recreation activities such as hunting, and livestock grazing have the potential to cause ground disturbance (erosion) and lead to cumulative, long term, irreversible adverse effects to heritage resources.

Past Actions that have likely negatively affected heritage resources within the analysis area include historic and unmanaged livestock grazing, wild ungulate grazing, unmitigated soil erosion, illegal roads, and dispersed recreational activities. In addition, some of the analysis area may have been subjected to intensive logging activities that occurred between the 1920s and 1950s prior to the advent of the National Historic Preservation Act (NHPA) of 1966. As such, it is also possible that heritage resources have been previously impacted by past logging within the project area.

Unmanaged recreation still continues within the analysis area. Grazing is managed much better than in the 20th century, however the cumulative effects of domestic grazers along with wild ungulates can continue to negatively impact heritage resources, especially within or near riparian areas.

Grazing will continue into the foreseeable future. Adjustments may be made to improve forage use and stream/riparian protection. In the long run it is expected that the grazing program will remain the same into the future with similar effects unless continued drought demands changes in livestock numbers and seasons of use. Timber activities are likely to increase and perhaps increase soil disturbance overall in the short term; however into the future as the spruce die the timber activities are likely to slow and shift out of the spruce zone for an extended period, perhaps 100+ years. Recreation use is likely to remain constant or to increase. While there may be changes in the distribution of activities, due to dead trees, which may affect wildlife distribution and areas open for firewood cutting, it is anticipated that recreation levels will be largely unchanged into the future.

3.15 Recreation Use Scope of Analysis This section addresses recreational and travel management within the CP District-wide Salvage Project Area as shown in Chapter 1.

The national recreational opportunity spectrum (ROS) and the Forest Plan are used to define and manage the expected recreation experience in this analysis. The Forest Plan provides the management framework for the recreation resource. The Forest Plan designated each part of the Forest into management area (MA) direction (see Chapter 1, section 1.5, and Table 2). These MA’s include standards and guidelines for managing recreation

154 CP District-wide Salvage Project Final Environmental Impact Statement and other Forest resources. The ROS is an inventory tool used to describe the existing condition of recreation opportunities. The Forest Plan assigned a range of appropriate recreation settings using the ROS. These are used to guide management activities in order to maintain or attain a defined range of recreation opportunities. The ROS classes are defined in detail in Appendix J. Existing Condition Past Actions that have affected the Existing Condition Recreation use on the Conejos Peak Ranger District has varied and fluctuated over time with changes in land use, federal land management, economic drivers and socio-cultural influences. In the early 1900’s, livestock grazing was prevalent and consisted of thousands of sheep moving from the valley low lands following the receding snow up to the high mountains. Since the late 1900’s, a more modern grazing rotation of shorter seasons and mostly cattle grazing has been utilized. Fire prevention programs have evolved into fire management programs that focus on integration of wildfire into natural forest processes. In the past, roadways were not planned but were user-created by primitive and later motorized vehicles. As management of this area advanced, user-created trails and two-tracks were replaced by engineered, graded roadways. Game management has progressed to provide new experiences in hunting and fishing by introducing and promoting a variety of animals to harvest and pursue. Advancements in technology (GPS, geo-locators, cell phones, etc.) and in transportation (ATV, UTV, high-clearance vehicles, etc.) have made it easier to access and navigate primitive areas that were once inaccessible except by foot or horseback. Past activities that affect the existing conditions include livestock grazing, timber harvest, road construction, and various forms of dispersed recreation, all within the project area boundary.

Recreation National Forest System (NFS) lands within the project area have been used for a diverse array of recreational activities for over 100 years. Recreation opportunities within the project area include but are not limited to: driving for pleasure, viewing scenery and wildlife, camping in campgrounds, backpacking, hiking, hunting, fishing, horseback riding, picnicking, firewood gathering, snow shoeing and cross-country skiing to a system of yurts, use of all-terrain-vehicles (ATV) on roads, and snowmobiling. There are several priority and temporary outfitters who are authorized to provide services to hunters and fishermen on NFS lands within the project area.

The project area includes nine developed campgrounds, one group area, sixteen trailheads, three cabin rentals and multiple dispersed camping areas.

Table 59. Recreation Site Development Scale and Total Capacity

Number of Sites Development Scale Total Capacity 2 0 50 6 1 246 5 2 191 18 3 1799 3 4 24 34 2310

Trails and Travel Management Forest travel regulations restrict motorized travel to designated roads and trails. Additionally, forest regulations

155 CP District-wide Salvage Project Final Environmental Impact Statement allow vehicles to leave roads for a distance of 300 feet to access a suitable campsite or for gathering firewood, as long as no damage is caused to the resources. Game retrieval is allowed in some areas on the district during the big game hunting seasons. Game retrieval is allowed in the afternoons and only low tire pressure ATVs under 48 inches in width are permitted.

Roads and trails within the project area provide travel access and corridors for motorized and non-motorized uses (Figure 7). The majority of trails within the project area are single track trails, with trails 740.1 and 741 being the only ATV trails on the district. The district has a total of 283 miles of trails with approximately 71 miles designated as motorized and approximately 212 miles designated as Non-motorized within the project area.

Figure 7. District map of roads and trails

Continental Divide National Scenic Trail Approximately 54 miles of the Continental Divide National Scenic Trail (CDNST) exists on the Conejos Peak Ranger District. The CDNST is a congressionally-authorized trail and has national management direction.

For this project, salvage harvest treatment is proposed near approximately 1.5 miles of the CDNST near

156 CP District-wide Salvage Project Final Environmental Impact Statement Cumbres Pass and on the south side of approximately 0.8 of a mile of the CDNST near Elwood Pass.

Figure 8. CDNST district location map Wilderness Although the South San Juan Wilderness area falls within the project area boundaries, under any of the project alternatives harvest activities would not occur within congressionally designated wilderness areas. Therefore wilderness resources will not be discussed in further detail as part of the recreation analysis.

Recreation Special Uses The district administers multiple recreation special use permits that fall within the project area. These special use permits consist of priority and temporary use permits, recreation residences, non-commercial and recreation events. These permits consist of activities such as hunting, fishing, camping, hiking, backpacking, horseback riding, weddings, reunions, and competitions. The district manages the following special use permits within the project area:

157 CP District-wide Salvage Project Final Environmental Impact Statement

Table 60. Recreation special uses on the Conejos Peak District

Number of Permits Activity

9 Recreation Residences 7 Priority Outfitter and Guides 2 Shelter 5 Yurt Rentals Annually 4-12 Temporary Outfitting and Guiding Annually 4-8 Non-Commercial Group Uses Annually 2-5 Recreation Events

Direct and Indirect Effects Direct and indirect effects will be discussed in four sections specific to the recreation activity for the No Action Alternative and the action alternatives. Those activities are: Recreation (Developed and Dispersed), Trails and Travel Management, Continental Divide National Scenic Trail, and Recreation Special Uses (permitted use). Alternative 1 – No Action Recreation Under the No Action Alternative, vegetation management could still occur as user safety and access are deemed necessary. Typical vegetation management activities such as force-account chainsaw crews, saw training classes, or site-specific hazard tree removal could continue in areas of concentrated forest use (administrative sites, campgrounds, roadways, etc.). This would not be a concerted effort as in the action alternatives and would likely not be completed in the proposed timeframe of 1-15 years. These activities would occur as-needed and as funding and priorities allowed. Most of the beetle killed hazard trees in developed sites have been managed or are currently being managed at a site-specific level due to safety concerns. Remaining dead trees would continue to fall potentially impacting the infrastructure in and around developed sites. This alternative would not be expected to have a large impact on developed recreation sites.

Dispersed camping and dispersed recreation could change with the No Action alternative. Sites used in the past could become increasingly hazardous. People may choose to use previously unused sites in order to avoid these hazards. This could result in new sites being created in previously undisturbed areas. Pristine areas and open grasslands (areas devoid of hazard trees) could be some of the only places to recreate due to their lack of dead or dying spruce.

Travel within forested areas could continue to be more difficult due to falling dead trees. Roads that would be improved or maintained under the action alternatives may be left unmanaged or blocked by downed trees impeding motorized and non-motorized recreational travel. This could result in user-created paths that could cause increased erosion and resource damage. System trails could continue to be damaged or blocked by dead and downed trees and debris.

Cross-country foot and horseback travel within the project area could be more difficult and dangerous under the No Action alternative since dead trees could fall and likely not be removed. Additionally, more obstacles may be hidden under snow in winter therefore obstructing over-snow travel and potentially increasing accidents to winter recreationists.

Under the No Action alternative, calculated timber harvests and removal will not occur or be planned by timber managers. Hazards may need to be mitigated one tree at a time and trips to remote areas may be needed in order to ensure open, public access. These activities cause an increase in overall cost and impact to the District’s recreation program. Additionally, common occurrences such as wind events and heavy snow that typically bring down a large number of trees at once would still likely occur at a higher rate causing potentially

158 CP District-wide Salvage Project Final Environmental Impact Statement dangerous safety issues to forest users and emergency response personnel.

Trails and Travel Management Due to an increase in dead, dying trees falling across roadways or to the increase in perceived hazards from dead trees, users may form new, unplanned routes of forest travel. Braiding, routes parallel to one another, may occur due to numerous people avoiding obstacles on the way to popular destinations. Trail braiding and new route creation typically leads to an increase in resource damage and erosion. Trails and roads are usually engineered to insure proper drainage in order to decrease erosion. It is directed in a way that its force does not take the road bed or trail bed away. Once travelers start using alternate routes, water tends to follow those routes. The erosion, itself, then becomes an obstacle in the form of ruts and gullies.

Combining the issues of unmanaged hazards, erosion, and path obstruction may lead to trail closures. Trail crews, if present, could have a hard time keeping up with the pace needed to keep trails safe. Decisions to close trails could be made if it is determined that the liability of keeping them open is too great.

It could be more difficult for people to enter system trails and roads. Roads and trails that lead to recreational opportunities could be blocked by down trees or hazards may discourage travel to and from forest destinations. As a result of fewer people in these areas, solitude experienced by some visitors would likely increase.

Continental Divide National Scenic Trail Under the No Action alternative, there would be no effect to the CDNST from proposed treatments. Dead trees would continue to fall and greater funds to keep this trail open could be needed as more trees block the trail. Crews with specialized skills in removing large diameter trees are needed to clear the Continental Divide trail however, travel to the CDNST from the district office is long and difficult. This makes trail work and maintenance on the CDNST logistically difficult, which may decrease service to the public.

Recreation Special Uses Under Alternative 1, trails and infrastructure outside of harvestable areas that are used by outfitters and guides would continue to experience large amounts of downed trees, hindering travel and causing an access and workload impact to the permittees.

The presence of dead, dying and falling trees could be costly to holders of special use permits. The fire danger to recreation residence owners may increase. If fires occur, their momentum may be greater if dry fuel is present and downed fuel gives a continuous path for the fire to travel. Temporary use proponents may be less likely to apply for special use days if the area is not easily accessible. And, current priority use outfitters may have expenses in clearing their paths into areas they are permitted to operate. Wind events and heavy snow would continue to down trees on yurts, trails and snow routes. Dangerous conditions and hazards may create a situation where holding a special use permit is no longer economically feasible due to the risk and liability to customers.

Alternatives 2 and 3 – Vegetation Management - Proposed Action and Limited Action It is assumed that the types of impacts that have the potential to affect recreation use are the same to both action alternatives. The effects could be dependent on the location where the treatments occur and to what spatial degree. Both action alternatives could likely reduce some of the recreation impacts compared to Alternative 1 but could create other impacts to Forest users.

Recreation Under the action alternatives, hazard tree removal would be authorized and there would be positive safety effects on developed sites such as campgrounds, picnic areas, trailheads and access roads. Some treatment

159 CP District-wide Salvage Project Final Environmental Impact Statement areas may be closed temporarily while proposed activities occur, causing negative impacts to users and the concessionaire authorized to manage the site. However, systematic closures for treatment would likely be rare and of shorter duration than if closures were to occur due to safety concerns where no treatments were scheduled. User experience in developed recreation sites would likely be more positive post-treatment due to enhanced safety and scenic quality of live, residual trees. The action alternatives would likely provide for safer and easier access to trails. Openness of trailheads and roads would be more consistent for users.

Infrastructure could be preserved and protected by the action alternatives. Controlling the paths in which trees fall could avoid toilets, signs, tables, and other recreation features. Professional timber harvest could prevent the random falling of trees as they dye. Shelter permits, such as the yurt rentals, could benefit by having these professionals keep trees in the surrounding areas from hitting their structures.

The action alternatives could have temporary impacts to recreation. Hazards in developed areas can be eliminated through harvest, instead of on a case by case basis. An example would be harvesting many of the trees in a campground over a summer, instead of using forest personnel or concessionaires to fall one tree at a time. Developed areas could be closed for these operations, preventing use for short periods of time.

Depending on their proximity to the treatment areas, dispersed recreation sites may be enhanced by clearing the dead and dying trees. Increasing user safety, access, and scenic quality may be a benefit. However, salvaging dead trees may also decrease the amount of cover and privacy in some dispersed sites. Timber harvest activities may temporarily degrade the user’s experience due to noise. Additionally, sites, roads, trails and trailheads may be temporarily closed during implementation of the action alternatives.

Harvest and hazard fuels mitigation activities including chainsaw operations and temporary road-building may impede or close forest access in some locations. Harvest may affect typical animal movement and therefore hinder hunting. Snow trails for skiing and snowmobiling may be affected by winter operations.

Trails and Travel Management Temporary closures could prevent people from accessing areas for the time it takes to remove hazards and dead and down trees. The roads could then offer safer and easier travel to all destinations within the analysis area. Safer and easier access to trails could allow contract and volunteer labor the ability to clear trails for both motorized and non-motorized users.

Improved access to the area may result in a higher visitor use. Trails even in non-motorized areas could be cleared more efficiently because crews may have easier access to trail heads. There could be more demand for permitted use. With the action alternatives, logging traffic may impact Forest users. Equipment and logging trucks may affect user’s experience with noise, dust and diesel exhaust. Because timber contracts require a higher level of road maintenance, road conditions may be better for all users.

Continental Divide National Scenic Trail Under the action alternatives, approximately 1.7 miles of the CDNST could be affected by salvage harvest treatments. Where these treatment units exist, the project-level checklist would be the instrument to ensure compliance with the CDNST regulatory direction including the National Trail System Act, 2009 Comprehensive Plan and the applicable best management practices. Design features for project-level consideration near the CDNST would include the following:

 Shape of Individual Units • The goal is natural appearing opening(s) when viewed individually and a natural appearing mosaic when viewed within the broader landscape.  Edges of Individual Units • The goal is a natural appearing transition between treated and untreated vegetation.  Pattern Created by Multiple Units • The goal is a natural appearing mosaic of vegetation across the landscape. 160 CP District-wide Salvage Project Final Environmental Impact Statement

 Composition of Vegetation • The goal is to maximize diversity of species and age class that are within the landscape’s natural range of variation/Forest Plan Desired Condition.  Road, Skid Trail, and Landing Construction • The goal is to minimize long-term visual impacts of access roads, skid trails, and landings.  Slash Treatment • The goal is to minimize slash piles and residue that appears man-made.  Unit Marking • The goal is to minimize the visibility of tree markings post treatment.  Related Recreation and Trail Mitigation • The goal is to minimize both short term and long term impacts to recreation infrastructure and use.

People traveling on our trails and roads could view a landscape that is impacted by both machinery and insects. Even with the implementation of the CDNST direction, views from the continental divide could be altered. Experiencing solitude could be more of a challenge in any area where salvage is occurring.

Where the CDNST is in close proximity to the salvage area, travelers may find altered conditions. Camping sites may be cleared of trees. Roads, machinery, and timber sale areas may be visible for a considerable distance along their trek. Safer travel routes could exist simply due to the removal of dead and dying trees. Dust, diesel exhaust, and noise may be present during the same time people are using the trail.

Recreation Special Uses Salvage harvest and hazardous fuels reduction activities could temporarily affect organized camps and other facility-based special use permits during implementation. The effects could include closing areas permitted for use by shelter permits, as well as those used more traditional outfitters and guides. Outfitting and guiding as well as special events may be cancelled for safety reasons (possibly to avoid logging traffic). An example could be a recreation event involving cyclists on a heavily traveled road. If not cancelled or postponed, these activities could be relocated to mitigate project implementation. The long-term impacts of continually falling trees and visual impact of dead and dying trees would likely be a greater impact to these users. Cancellations, relocations, and special accommodations needed for the action alternatives could cause short- term financial losses to outfitters and guides as well as other special use permit holders. The need to alert customers of activities in the area could become necessary. The owners of these operations may likely share some of the financial burden of notifying people. Customers may only have certain times they are able to visit the area, and they may not be able to adjust to postponed seasons or times. Over-snow travel may need new routes defined. The yurt operators may need to place markers or signs in new locations to define these routes. This takes time, effort, and money that may not be readily available to these businesses.

Areas previously not accessible could become new areas of exploration for visitors. Trees that once blocked snowmobiles may be removed. This may allow for easier travel within the harvested area. Motorized game retrieval, allowed in the area, may be possible in areas that were forested prior to timber harvest. Hunters may choose areas for this reason alone.

Salvage areas would be marked for timber harvest, but selected areas, such as buffers to trails and scenic roads, could be left alone through the implementation checklist process. Closed roads would be used temporarily, but would remain closed to recreation vehicle traffic. These roads would remain open to foot traffic, however. Temporary roads would be created, and timber harvest activities and machinery could be near trails, campgrounds and roads. New trees would be planted in areas and new rules may follow in order to protect seedlings, such as over-snow use being limited to times when enough snow covers tree tops to allow for healthy growth.

The action alternatives could remove hazards within recreation residences, over-snow routes, and yurt locations. Reducing fuels through salvage may prevent fires from reaching these structures. Commercial 161 CP District-wide Salvage Project Final Environmental Impact Statement harvest may lessen the burden of hazard removal, on both the owners of recreation residences and yurt operators.

Customers may enjoy a safer stay knowing dead trees do not exist close to their shelters and some businesses may benefit by having new areas available for visitation. Snowmobiles may be able to reach areas they could not reach before. Direct routes to popular sites, like reservoirs, may allow for quicker trips for ice fishing. Cumulative Effects A combination of all of the proposed treatments could temporarily impact the user experience in localized areas of the district. However, these effects would be short-term (less than 15 years) and, over the landscape and over time, user safety, recreation and visual experience could be enhanced through the reduction of standing, dead stems, the continuity of localized forest access, release of residual regeneration and the planting of new trees. Vegetation treatments could alter big game foraging and movement, which could impact hunters though in the long-term salvage harvest treatments could create for favorable forest conditions and could increase animal forage and hunting opportunities. Implementing the outlined PDC and Forest-wide standards and guidelines should address these temporary impacts, and could provide for the continuation of accessible and safe recreational opportunities within the project area.

Irreversible and Irretrievable Commitment of the Resources There would be no irreversible or irretrievable commitment of resources if the proposed action is implemented.

3.16 Scenic Resources Scope of Analysis The project area boundary is located on the west side of the San Luis Valley, from the northern end of the Conejos Peak District to the southern end of the Conejos Peak District and the New Mexico border.

Past Activities that have affected Existing Conditions The Conejos Peak District has large areas of spruce beetle infestation with evidence of dead trees across the District covering many of the viewsheds seen by visitors. This includes areas of heavily used Forest Service roads, Scenic Byways, Scenic Railroads, and popular recreation destinations. The forest canopy has been changing over the last 15-20 years with many of the canopy changing from dark green to red to grey in color. Most visitors will notice large viewsheds that contain standing dead grey trees mixed with sparse green fir or aspen trees. Many of the locations proposed for harvest have had some previous harvesting activities or disturbance. However, this analysis includes areas that have not had previous harvesting. RIS sites were identified in 1990 during Forest Planning that identified most of the Conejos Peak District in the Existing Visual Condition of Level I or II (which is defined as naturally appearing or nearly naturally appearing). Many viewsheds would still be considered natural appearing however, the large amount of beetle killed trees have changed the color and texture of this landscape from heavily forested and green to gray with missing canopy.

Recent Harvesting that affects the Scenic Resources Trujillo Meadows Campground has recently been harvested due to beetle kill trees in the campground. This has reduced the canopy cover in the campground to approximately ½ of the original canopy cover. Adjacent to the analysis boundary is the County Line/Wolf Timber Sale which has very little canopy due to a previous a Forest Service and private land timber sale and large scale blowdown event that left roughly 5-10 trees per acre. The County Line/Wolf Timber Sale also harvested around the Flat Mountain Yurt. The private

162 CP District-wide Salvage Project Final Environmental Impact Statement land that sits on the west side of the Cumbres Vegetation analysis boundary was also harvested 15 years ago and left approximately 30-40 trees per acre.

Existing Conditions All of these events have altered the Trujillo Meadows Viewshed and Landscape Character from forested to nearly non-forested. Viewers can expect to see harvesting activities from current harvesting and dead and dying trees in the remaining viewsheds. Many of these past activities as well as the current spruce mortality can be seen along the Los Caminos Antiguous Scenic and Historic Byway, the Cumbres and Toltec Scenic Railroad, the Sangre de Cristo National Heritage Area, Forest Development Road (FDR 250) and may recreation sites. District personnel determined that many of the roads including FDR 250 and FDR 118 is a Level 1 Road (viewers have a high concern for scenic resources) during Forest Plan Revision. Most of the areas identified for harvesting within the analysis area is mapped as “High” which means all harvesting activities on the landscape must borrow from the form, line, color, texture, and landscape patterns so completely that viewers are not aware of landscape deviations. These deviations must not dominate the landscape and remain visually subordinate. However, the Rio Grande Forest Plan Forestwide Standards and Guidelines identify several categories which the Scenic Integrity Objective can be changed to the next lower objective.

Forestwide Standards and Guidelines Scenic Resources Standards

1. The Scenic Integrity Level(s), based on current landscape character, are usually accepted as the Scenic Integrity Objective(s) unless highly unusual or special circumstances identify a need to change, and will be limited to:

*Treatment of small-diameter/suppressed lodgepole pine stands. *Harvest as a result of a disturbance such as fire, windthrow, or insect and disease infestations. Variations in the Scenic Integrity Objectives may dominate the valued landscape Character, but must borrow from the valued attributes such as size, shape, edge, effect, and pattern of natural openings, and still meet the minimum requirements of the next lower Objective chosen.”

The CP District-wide Salvage management activities would then have to meet the “Moderate” landscape objective. When the objective is changed to “Moderate,” the landscape will “appear slightly altered” after harvesting activities. “Moderate” is defined as landscapes where the valued landscape character “appears slightly altered.” Noticeable deviations must remain visually subordinate to the landscape character being viewed. It is important to note that landscape Scenic Integrity Objectives only apply to human activities on the ground and not natural conditions. Changes to the landscape character from forested to non-forested are considered natural and fall within the range of natural landscape variability.

Direct and Indirect Effects Alternative 1-No Action The No Action Alternative will have no to very little impacts to scenic resources as large scale bug events are considered part of the overall landscape dynamic. These events would only be considered a change in cover type or change to landscape character only. However, visitors’ response to these dynamic and changing landscapes may be dramatic as most visitors are attached to static (unchanging environments) especially in locations where people participate in recreational activities. Visitors can expect to see more dead or dying trees 163 CP District-wide Salvage Project Final Environmental Impact Statement with the canopy opening and exposing more of the ground plane. Eventually a portion of these trees will begin to fall. There will still be texture on the landscape with standing dead trees, however, if trees have not turned gray already, trees will begin to turn red and gray changing the overall color of the viewshed. As the canopy opens up, it is expected that visitors may be able to see more of the ground cover. Seedlings and saplings will provide color and texture on the ground but the landscape will still look dramatically different than it did over a decade ago. During the winter months even more of the ground will be visible in the background viewing distances as the canopy recedes. There would be changes to the overall scenery for the Los Caminos Antiguous Scenic and Historic Byway, the Cumbres and Toltec Scenic Railroad, and recreation sites. Viewers would see dead and dying trees similar to the characteristic landscape that has been changing over the last 15 years.

Because this project is a large landscape level analysis, the visuals are looked at on a larger picture. Viewsheds are expected to move toward a change in character from forested to non-forested in areas of dead and dying trees, however, standing dead trees under this alternative will provide texture on the landscape. Evidence of dead and dying trees are recognizable due to the gray color of the landscape during the summer and fall months. Over the last 15 years, more of the ground plane is visible due to the absence of canopy and the ground plane will be more visible in the winter months. Alternative 2 – Proposed Action If this alternative is implemented, visitors can expect to see changes to the surrounding landscape character as trees are harvested. Visitors will see evidence of stumps and harvest activities, but these activities will not dominate the landscape character. Visitors will notice changes to the landscape, however, relative to the large beetle killed trees with little or no foliage, visitors may not notice harvesting activities as much as if harvesting was completed in a green stand of trees. During the winter months the background becomes more pronounced as snow accentuates loss of canopy, however this would also be the case with areas of non- harvesting, as most of the canopy is already open due to the amount of dead trees. In the immediate foreground, the snow will cover most of the evidence of harvesting activities for winter visitors. It is expected that visitors on the heavily used Forest Road 250 will see activities related to harvesting, however, they are expected to be in the middleground to background and on the top of benches. The areas being harvested around Platoro and the 3 Forks trailhead will be viewable in the foreground and middleground. Visitors traveling within the Silver Lakes area on the northeast portion of the District will view harvesting activities in the foreground and middleground. The area adjacent to the Summitville will be viewable by visitors along roads that get heavy to moderate use. Many of these areas have recreation areas and trails; however, it is expected that within areas of high recreation use, harvesting activities will be mitigated to minimize the evidence of harvesting activities and may include lower stump heights, angle cutting away from viewer’s line of sight, and blending harvesting activities with natural openings.

Visitors would expect to see harvesting activities under both alternatives, however, they would be gradual as timber sales were implemented over the next 8 years.

Activities such as thinning and lifting canopy heights to prevent wildfire risks will have little impact on the overall landscape for Scenic resources unless these activities happen directly adjacent to a trail or recreation site (within the immediate foreground-100-200’ feet). The overall scale of this activity (roughly 1000 acres) over the entire District (roughly 500,000 acres) minimizes the impact. The expected results of canopy lifting will be pile burning in various locations; however, these piles will be mitigated away from recreation sites or along heavily used trails and roads frequented by visitors.

There is expected to be road reconstruction that could impact scenic resources; however, most of the salvage areas will be accessed by existing roads, closed roads that will be opened, or connector roads that may have revegetated over time. Some of these roads will be seen by visitors, others will be obscured by topography and vegetation.

The majority of impacts are expected to be from commercial timber harvest through salvage activities as new road construction and thinning are expected to be small. This may leave large openings on the landscape with 164 CP District-wide Salvage Project Final Environmental Impact Statement missing trees and reduced amounts of color and texture on the landscape. These activities can fit within the landscape character if handled on a viewshed basis-or on a large scale. Contiguous activities that are implemented across large viewsheds can have less impacts than small pockets of heavily managed harvest activities that can draw the observer’s attention to it. However a combination of smaller and larger activities can be mitigated on the landscape to minimize visual impacts with careful planning and mitigation measures. Alternative 3 – Vegetation Management – Limited Action This alternative includes less acres of harvesting and therefore visitor may see less impacts from commercial timber harvesting activities. This alternative has roughly half the harvested acres of Alternative 2. This alternative would leave more texture on the landscape from standing dead trees. Visitors can expect to see less activities in the foreground, middleground and background from commercial timber harvesting. This would include less slash and fewer stumps. During the winter months the background would become more pronounced as snow accentuates loss of canopy, however this may be less in areas that are not harvested. However, visitors would still see more of the ground plane, as most of the canopy is already open due to the amount of dead trees. In the foreground, the snow will cover most of the evidence of harvesting activities in the immediate foreground for winter visitors. It is expected that visitors on the heavily used Forest Road 250 will see less activities related to harvesting in the middleground to background and on the top of benches. The areas being harvested around Platoro and the 3 Forks trailhead will be viewable in the foreground and middleground but to a lesser degree. Visitors traveling within the Silver Lakes area on the northeast portion of the project will view harvesting activities in the foreground and middleground. The area adjacent to the Summitville will be viewable by visitors along roads that get a heavy to moderate use. Many of these areas have recreation areas and trails; however, it is expected that within areas of high recreation use, harvesting activities will be less and the remainder will be mitigated to minimize the evidence of harvesting activities and may include lower stump heights, angle cutting away from viewer’s line of sight, and blending harvesting activities with natural openings. Visitors would expect to see harvesting activities under both alternatives, however, they would be gradual as timber sales were implemented over the next 4 years.

The activities such as thinning and lifting canopy heights to prevent wildfire risks will have little impact on the overall landscape for Scenic resources because these activities will be less under this alternative. The expected results of canopy lifting will be pile burning in various locations, however, these piles will be mitigated away from recreation sites or along heavily used trails and roads frequented by visitors.

There is expected to be less road reconstruction that could impact scenic resources, however, most of the salvage areas will be accessed by existing roads, closed roads that will be opened or connector roads that may have revegetated over time.

The impacts from this alternative will be less than Alternative 2. Depending upon how harvesting is achieved, smaller more intense harvesting can create more impacts, however, through mitigation, these impacts can be mitigated.

The majority of impacts are expected to be from commercial timber harvest through salvage activities as new road construction and thinning are expected to be small. This may leave large openings on the landscape with missing trees and reduced amounts of color and texture on the landscape. These activities can fit within the landscape character if handled on a viewshed basis-or on a large scale. Contiguous activities that are implemented across large viewsheds can have less impacts than small pockets of heavily managed harvest activities that can draw the observer’s attention to it. However a combination of smaller and larger activities can be mitigated on the landscape to minimize visual impacts with careful planning and mitigation measures.

Effects Common to All Action Alternatives It is expected that the entire landscape will have a more open canopy appearance regardless of the harvesting.

165 CP District-wide Salvage Project Final Environmental Impact Statement Harvesting under a more open canopy will lessen the impacts of overall harvest rather than harvesting against a dark background canopy. This is due to the current open nature of the characteristic landscape. In many areas, there are a large number of seedlings and saplings that provide additional texture and color on the landscape where salvage activities will occur.

However, many of the areas identified for harvest are near areas of recreation activities, especially in the Platoro area and along Forest Development Road 250 which provides the major access for visitors into the Conejos Peak District.

Given past harvesting activities, there is a high probability that remaining trees may fall due to blowdown potential. The trees that remain may not have the appropriate wind firmness needed to withstand a high wind event. This would further reduce the trees per acre and reduce the amount of texture on the landscape. Cumulative Effects There is the potential for these proposed harvesting activities to actually rehabilitate the residual timber activities on the landscape. This is due to the fact that previous harvesting has occurred in the Silver Lakes area and near Summitville. New harvesting activities can add to the negative effects of human made activities on the landscape, but also mitigate them.

3.17 Transportation Scope of Analysis This analysis inventories and evaluates the existing National Forest System Roads (NFSRs) and evaluates roads managed by other entities within the 332,000 acre (519 sq. miles) project area. This report focuses on road treatments within the project area. Road maintenance needed to accomplish the proposed vegetation management activities will be discussed. Existing Conditions Geographic information systems tools were used to analyze road location and mileage within the project area. Mileages given in this report should be considered precise to approximately ±10% (unless otherwise specified) after accounting for the precision of available 2017 ArcGIS® roads layers. On-the-ground reconnaissance was completed on most project routes to observe current conditions and determine needs for short- and long-term treatments.

An extensive road network was built within the project area for many reasons, including, but not limited to: supporting past timber management activities, supporting recreation opportunities, and providing access to private in-holdings. These roads are categorized by maintenance level (ML) ranging from ML-1 to ML-5 (Table 61). The project area contains 348.0 miles of existing National Forest System Roads (NFSR) under various maintenance levels (Table 62).

Table 61. Description of NFR maintenance levels

Maintenance Description Level ML 1 Basic Custodial Care (Closed) ML 2 High Clearance Vehicles ML 3 Suitable for Passenger Cars ML 4 Moderate Degree of User Comfort ML 5 High Degree of User Comfort

166 CP District-wide Salvage Project Final Environmental Impact Statement

Table 62. CP District-wide Salvage Project Area Road Mileage by Maintenance Level

Maintenance Level Miles in Project Area ML 1 66.8 ML 2 71.7 ML 3 209.6 Total Miles in Project Area 348.0* *Discrepancy due to rounding

The following list of system roads describes their current conditions and an example of some of the unique maintenance needs that would affect the cost per mile.

Fox Creek (NFSR 101) is 19.2 miles in length. However, this road is maintained by multiple entities. The first 1.3 miles is a ML-3 road, which will require light maintenance. Mile post (MP) 1.3 to 18.2 is a ML-2 road with both crushed aggregate and native surface material. The remaining mile is a ML-1 road with a native surface. There are approximately 7.0 miles within the ML-2 section of this road that will require heavy blading and dozer work. A substantial amount of drainage features, including ditching, will be required.

Fox Creek Spur (NFSR 101.3A) is approximately 3.1 miles long. This is a ML-2 road with native surface material. This road is currently not suitable for log truck traffic due to its narrow construction. This road will need to be widened, which will require a sizeable amount of bulldozer and blade work. Furthermore, the road was built on bedrock, and has a few steep areas.

Osier Park Plantation (NFSR 103.3C) measures 2.7 miles in length. The first mile of this road is a ML-2 road with native surface material. MP 1.0 to 2.7 is included in the project area and is a ML-1 road with native surface material. This road is located in a rather flat area, and has water flows that create a boggy surface. Therefore, substantial ruts are found throughout the roadbed, and will require a corrugated metal pipe (CMP) to be installed. This will necessitate at least 30 cubic yards of pit run to be hauled up in order to build up the roadbed for installation. Furthermore, this road will need significant blade work, and moderate clearing and grubbing.

Pinorealosa (NFSR 107) measures approximately 9.0 miles. It is a ML-2 road with native surface material. The majority of the length of this road is in need of heavy maintenance. Beginning at the 108.1A intersection, the road is in rough condition, narrow, steep, and rocky in places. Extensive work will be required to allow access for log trucks.

Cumbres (NFSR 119.1D) is about 1.5 miles in length. It is a ML-1 road with native surface material. This road is narrow, with heavy vegetation throughout, which will require significant clearing and grubbing, and extensive construction efforts. This will include installing several drainage features, such as culverts, drainage dips, and ditches.

Other roads within the project area, including, but not limited to: approximately MP 0.0 to 1.9 of NFSR 234, MP 0.0 to 4.6 of NFSR 244, and MP 0.0 to 4.1 of NFSR 280 were evaluated for similar needs. These roads will require at a minimum: clearing and grubbing, catch basin cleaning, and road reconditioning to improve drivability for all vehicles, equipment, and log trucks. Additionally, NFSR 234 will require the replacement of a deeply buried CMP, which is located at Prospect Creek.

Desired Conditions According to 36 CFR 212.5, the desired minimum road system is that which is “needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands”.

167 CP District-wide Salvage Project Final Environmental Impact Statement The RGNF Forest Plan (Rio Grande National Forest, 1996) states that the desired future condition is: “The road system continues to serve as adequate access for the public to enjoy the Forest. Road construction is limited, and the amount of reconstruction has decreased. Road closure is emphasized in some areas to enhance wildlife habitat, soil, and water resources.”

The Rio Grande National Forest has created a Forest-wide Travel Analysis Process (TAP) report, which “is a set of science-based recommendations for the forest transportation system, and is intended to inform subsequent National Environmental Policy Act (NEPA) processes, allowing individual projects to be site- specific and focused, while addressing cumulative impacts.” (USDA) Through this science-based process, the RGNF staff recommended a minimum road system and also identified unneeded roads, in accordance with 36 CFR 212.5 (US Government). Each road within the analysis area was recommended for either keep/maintain, storage, or decommissioning (see Appendix A for terms and definitions).

Construction Activities for all Action Alternatives All NFSRs identified to be used during vegetation management activities in the project area will require maintenance completed in order to ensure the safe passage of all vehicles, equipment, and log trucks. Table 63 displays the typical work items that will be completed based on the road ML.

Table 63. Maintenance Levels and Associated Work Items

Maintenance Level Typical Work Item Pre-Haul: • Remove slumps and slides 1 - Closed • Replace non-functional culverts • Clearing and grubbing • Clean catch basins • Scarify, re-shape, and grade surface • Compact surface Post Haul: • Out-slope road • Clean catch basins • Temporary turf establishment • Install or repair gate Pre-Haul: • Replace non-functional culverts • Clearing and grubbing 2 – High Clearance Vehicles • Clean catch basins • Scarify, re-shape, and grade surface Post Haul: • Clean catch basins Pre-Haul: • Clearing and grubbing • Clean catch basins 3 – Suitable for Passenger Cars • Spot gravel • Scarify, re-shape, and grade surface Post Haul: • Clean catch basins

Road reconditioning costs have been estimated to be approximately $1,430 - $1,770 per mile; however, this amount can vary greatly depending on the condition of the road. This was calculated using the Cost Estimating

168 CP District-wide Salvage Project Final Environmental Impact Statement Guide for Road Construction developed for the Forest Service (US Forest Service).

Direct and Indirect Effects Colorado Forestry Best Management Practices Water Quality Protection Guidelines are followed for road maintenance and construction/reconstruction activities. All roads within the project area will be designed using the Standard Specifications for Roads and Bridges on Federal Highway Projects (US Department of Transportation), and the Forest Service Supplemental Specifications (USDA Forest Service).

Alternative 1 - No Action Under the No Action Alternative, no changes would be made to the existing transportation network in the project area. Closed roads in the project area will not be opened and will continue to be monitored for critical issues. Natural grass and forb establishment would continue to occur, which may help stabilize roads. Also, tree seedling establishment can make vehicle travel more difficult over time. System roads would have normally scheduled maintenance but no additional maintenance or improvements would be funded or authorized for project activities.

Alternative 2 - Proposed Action Road treatments for vegetation treatment implementation under the proposed action alternative would include up to 281.2 miles of existing open (ML-2 & 3) and 66.8 miles of closed (ML-1) routes. Where necessary, ML- 1 roads would have gates opened, berms removed, and would be brushed-out to provide personnel, vehicle, and equipment access to harvest units. During use, ML-1 roads will remain closed to public travel. The only exception would possibly be a short-term opening for public firewood gathering following harvest. After use, the closed roads would be returned to storage using an authorized closure method, and seeding would occur. Figure 9 illustrates the road system being used for Alternative 2 in the project.

For a more detailed transportation maps, see Appendix F.

169 CP District-wide Salvage Project Final Environmental Impact Statement

Figure 9. CP District-wide Salvage Project Alternative 2 road map

Alternative 3 - Vegetation Management - Limited Action Road treatments for vegetation treatment implementation under the limited action alternative would include up to 280.0 miles of existing open (ML-2 & 3) and 61.2 miles of closed (ML-1) routes. Similarly to the proposed action alternative, ML-1 roads would have gates opened, berms removed, and would be brushed- out as necessary to provide personnel, vehicle, and equipment access to vegetation treatment units. During use, the closed roads will remain closed to public travel. The only exception would possibly be a short-term opening for public firewood gathering following harvest. After use, the closed roads would be returned to storage using an authorized closure method, and seeding would occur. Figure 9 illustrates the road system being used for Alternative 3 in the project.

Effects Common to All Action Alternatives Any construction of new temporary roads on previously undisturbed land would result in the irretrievable loss of virgin ground. The use and maintenance of existing system roads would have no effect since these corridors have been impacted by past activities and will return to current conditions after project activities are done. The following direct and indirect effects apply to all action alternatives. All ML-1 roads, including those listed in the TAP, will be assessed on a road by road basis to determine their continued need following completion of

170 CP District-wide Salvage Project Final Environmental Impact Statement all vegetation treatment activities. This will be accomplished by utilizing the project implementation checklists, which can be found in Appendix D of the EIS. A comprehensive evaluation of all Forest roads will occur after the Forest Plan Revision (FPR) concludes (RGNF in progress). The information gathered during this project will serve to inform travel management decisions in the future. No decisions that will change the Minimum Road System are proposed in this project. Table 64 was created using the TAP report’s decommissioning recommendations in conjunction with the transportation network within the project area.

Table 64. Travel Analysis process report recommendations for decommissioning

TAP Recommendation Road Numbers Miles System Roads 100.2F, 242, 250.6L, 260.1A, 280, 330.5A, 330.5B, 330.5C, 14.7 recommended for 330.5D, 330.5E, 330.5F, 335.1A, 336.1A, 380.3C, 380.5A, Decommissioning 380.6A, 380.6C, 380.6D, 380.6E, 380.6F, 380.6G

The TAP’s purpose is to provide recommendations and is not an official decision document. If any ML-1 roads are confirmed to be unneeded for management activities for the long-term timeframe they have the potential to be recommended for decommissioning following use and the completion of the FPR and subsequent processes. It was assumed that decommissioning would generally consist of all defined typical activities short of full obliteration and recontouring, though these more intensive operations may be used to meet specific resource objectives, if approved by the Responsible Official. Roads used in this project needed for long-term access, but not in the immediate to near future, would be returned to storage (ML-1). Storage treatments would put these roads into an environmentally benign condition until future needs warrant reopening. Storage treatments could include a combination of obstructing or gating the entrance, installing water bars, and seeding. Roads needed for long-term vehicular access would be maintained under this project to provide safe, efficient access, and to meet water quality BMP’s. Maintenance activities would include surface grading, ditch reshaping, installation of drain dips and cross drains for surface erosion control, minor culvert cleaning or installation, roadside brushing, and seeding of disturbed areas. Recurrent road maintenance is expected to continue annually for select NFSRs under an agreement between the Forest Service and Rio Grande and Conejos Counties. A list of these roads may be found in Table 65.

Table 65. Schedule A agreements within the Project Area

County Road Number Conejos 101, 103, 105, 117, 118, 250, 255

Rio Grande 250, 329, 330 (CO 14), 380

All other NFSRs are maintained by the Forest Service on a 5 year cycle for the Conejos Peak District, and for other non-NFS routes by the applicable owner and users. As described under the action alternatives, additional road maintenance would occur on roads used for timber hauling operations. The needed work to allow safe passage of logging trucks is completed by the timber purchaser and the roads used are maintained by the purchaser for the period of use. This additional work does result in a general improvement in the condition of open roads and provides opportunities to fix some known problems, which can be beneficial to several resources. The benefit of additional maintenance is usually most apparent on the roads maintained infrequently due to limited agency budgets. On roads maintained more frequently, the additional work may also help improve conditions to some extent and temporarily reduce maintenance costs for the Forest or County during

171 CP District-wide Salvage Project Final Environmental Impact Statement the life of the timber sale(s). Cumulative Effects Historically, the project area was developed for mining and railroad building activities beginning in the 1880’s. The main driver for the development of the southern area was the construction of the railroad, which still operates today as the Cumbres & Toltec Scenic Railroad. The construction of the railroad led to grazing activities in the area and extensive logging. Gold and silver were discovered in the late 1870’s leading to mining activities in the Summitville area. The San Luis Valley continues to be an agricultural hub, and as such, grazing activities have continued in the area. Logging activities are also still occurring in the area along with hazardous fuel reduction. Moreover, many recreation activities such as hunting, fishing, camping, hiking, horseback riding, and off highway vehicle (OHV) use are currently occurring. These activities will likely continue on into the foreseeable future. Road condition affects many activities in the project area. Frequent road grading, ditch and culvert cleaning, spot gravel surfacing, and other road treatments allow safer and easier travel into forest areas. Lack of maintenance may lead to certain roads becoming less accessible and prohibit traffic with horse trailers, or other larger vehicles, which may lead to less visitors to these areas. Lack of maintenance can also lead to more sedimentation from the road water interaction. The amount of road maintenance activities will likely be substantial for a length of time during project activities and drop to a minimal level upon project completion. Activities in the area, such as logging and recreation, affect the roads in direct proportion to the amount of use on the roads. Increased road use wears surfacing away, increases sediment /dust production, and develops ruts or mud holes during wet weather. Road maintenance is usually concentrated on arterial routes. However, collector and local routes are maintained as needed for resource protection, or as forest management activities direct. Typically, roads used for log hauling are maintained in accordance with the timber sale contract requirements commensurate to the use by the timber purchaser. Forest travel management activities will continue in order to provide for the useful need in the area.

3.18 Climate Change Scope of Analysis Evidence of human-caused climate change continues to grow, and is widely accepted throughout the scientific community. The fifth Intergovernmental Panel on Climate Change (IPCC) assessment recognizes both human and non-human contributions to climate change. Anthropogenic influences contributions have likely made substantial contributions to observed warming since the 1950s (IPCC, 2014). As stated: Human influence on the climate system is clear, and recent anthropogenic emissions of greenhouse gases are the highest in history. Recent climate changes have had widespread impacts on human and natural systems (p. 2; IPCC).

Carbon Dioxide (CO2), the most common greenhouse gas (GHG) accounts for approximately 76% of annual global emissions that are attributable to human activity. CO2 comes from a variety of anthropogenic and natural sources. Elevated concentrations of GHGs are largely attributable to human activities, such as fossil fuel combustion and land-use change. The following analysis includes both qualitative and quantitative discussion that is commensurate with Climate Change Consideration in Project Level NEPA Analysis (USFS, 2009). Existing Condition Temperature Trends and Greenhouse Gases Temperature and precipitation patterns continue to be impacted by climate change. Impacts are variable throughout the world, and the United States. In the lower 48 United States, 7 of the 10 warmest years have all 172 CP District-wide Salvage Project Final Environmental Impact Statement occurred since 1998 (U.S. Forest Service, 2014) (Figure 1). The 10 warmest years globally, have all occurred since 1998. There is a close correlation between temperature rise and atmospheric concentrations of greenhouse gases.

Figure 10. Data from NOAA National Climatic Data Center and the Mauna Loa Observatory, from U.S. Forest Service Climate Change Resource Center

Climate researches use historical temperature and precipitation data, as well as models to predict trends into the future. Projection models vary based on many assumptions, including future concentrations of greenhouse gases (GHGs) in the atmosphere. Current concentrations of CO2 in 2017 are approximately 406 ppm (NOAA, 2017); pre-industrial era (late 1700s) concentrations were approximately 280 ppm. As concentrations of GHGs increase, temperature is expected to also increase. Vegetation management activities associated with the action alternatives for this project will initially add to atmospheric concentrations. However, as trees re-establish and stands mature, carbon sequestration will reduce atmospheric concentrations of GHGs. Both processes are described qualitatively throughout this section. While the carbon cycle is considered here, the purpose of this project is more relevant to climate change adaptation, creating healthier stands more resilient to climate change impacts.

Climate Change Impacts Climate change effects vary greatly depending on location and impact. For example, sea-level rise is a more direct threat to low-lying countries in the South Pacific, than to National Forests in Colorado. However, warmer temperatures and the proliferation of destructive insects are important management concerns to National Forests in Colorado. The Colorado Climate Change Vulnerability Study (Gordon and Ojima, 2015) summarized observed and predicted impacts specific to Colorado including, but not limited to: • Increased average annual temperatures by 2 degrees Fahrenheit over the past 30 years, projecting an additional increase of 2.5 to 5.5 degrees by mid-century; • Peak runoff has shifted 1-4 weeks earlier over the past 30 years; projecting an additional 1-3 weeks earlier are expected by mid-century; and • Observed and projected more frequent drought conditions

The report continues by assessing vulnerability in key sectors, including agriculture, transportation, outdoor

173 CP District-wide Salvage Project Final Environmental Impact Statement recreation and tourism, and public health. Forest health and resiliency are important considerations on the Rio Grande National Forests and forested stands have become increasingly susceptible to insects and disease, exacerbated by climate change impacts. Smoke from wildfires affects public health; watershed conditions impact tourism and drinking water; and precipitation and snowpack affect water availability for downstream agriculture. Climate change, forest management, and human health and economy are all interrelated. The U.S. Forest Service and other land management agencies are developing and implementing strategies to adapt to climate change. Land managers often respond to drought, floods, fire, and destructive insects; many climate change adaptation tactics are responses to these events. The proposed activities, described in detail in chapter 1 and the Silviculture, Forest Products, and Biodiversity Reports, promote forest health; and timber harvesting reduces hazardous fuels, reducing the risk of wildfire.

Adapting to Climate Change The CPDWS Project is largely in response to impacts, either caused, or worsened by climate change. The proposed activities are consistent with the Climate Project Screening Tool: An Aid for Climate Change Adaptation (Morelli et. al, 2012). Some of the forest types analyzed under CPDWS have been severely affected by insects or disease. While these insects are native to these forests, many have expanded to epidemic levels, as noted in the vegetation report of this analysis. Sudden Aspen Decline (SAD), for example, is likely attributable to drought conditions and higher summer temperatures. Droughts and temperature fluctuations are natural events, but are well-documented as being exacerbated by climate change. The purpose and need of this project details objectives that promote forest health, diversity and resilience to insects, disease, and other stressors. It also recognizes that most of spruce-fir or spruce-mixed conifer forest across the district have already been heavily impacted and identified a need to salvage trees for timber production where there is still economic value. Both commercial timber sales and non-commercial treatments facilitate thinning, reforestation (both planting and natural regeneration), and increasing stand vigor, and better position individual trees to be less susceptible to insects, disease, and drought – all worsened by climate change - in the future. Another aspect of the project focuses on reducing fuels around private land and administrative sites to increase defensible space for fire suppression efforts. These are also climate change adaptation techniques. Reducing stressors to watersheds facilitates landscape resilience and is also considered an adaptation strategy for climate change.

Carbon Sequestration and Greenhouse Gases Forest carbon sequestration has recently been estimated for the Rio Grande National Forest and this information has been incorporated into this analysis (USDA Forest Service, 2015) on a baseline and cumulative analysis level. The Rio Grande National Forest carbon assessment is based on forest inventory and analysis (FIA) data and uses a 1990 – 2013 baseline, which does not completely reflect changes due to the current extent of spruce beetle mortality. At the national scales, uncertainty of carbon flux is between 20- 30 percent. Therefore, at the forest-level, the uncertainty can be much higher. Although uncertainty is high, ongoing research is focused on reducing these uncertainties over time. As time goes on, better carbon estimates for the Forest will be developed. Uncertainty around the carbon estimates should not prevent local managers from using this as a baseline and engaging the public around this non- market benefit of sequestered carbon. Carbon uptake by forests in the United States, offsets about 13 percent of our national CO2 emissions each year, including the approximately 75 teragrams (1 teragram equals one million metric tons) of carbon stored in the Forest (Figure 11). Carbon stored in U.S. forests is projected to peak between 2020 and 2040 and then decline through 2060, although the Rio Grande National Forest, and other western forests, may emit greater amounts of carbon dioxide if wildfire and insect disturbances increase as expected, due to climate change and other stressors. Growth rates may increase in high-elevation forests during years with earlier spring snowmelt, abnormally

174 CP District-wide Salvage Project Final Environmental Impact Statement warm annual temperatures, and longer growing seasons. These results suggest that projected changes in regional climate will likely result in increased productivity and carbon stocks of high-elevation forest, otherwise this project will likely have little effect on the overall carbon sequestration changes for the Forest overall.

Figure 11. Forest Carbon summary within Rio Grande National Forest and other regional forests from the 2015 Rio Grande National Forest Carbon Assessment

Alternative 1 (No Action) Climate change is part of the environmental baseline and will continue to happen in the absence of this project. Under the No Action Alternative, forest health conditions would continue to deteriorate, limiting the adaptive capacity of these forest types. Carbon dioxide would gradually be released through decomposition and decay of dead and dying trees. Without management, stands will likely be at higher risk to wildfire. In the case of wildfire, stands would burn causing an immediate release of stored carbon. As stands re-establish post- wildfire, carbon sequestration would increase as trees grow. Some intense wildfires result in damaged soil conditions that severely limit reforestation. While highly speculative, the potential for carbon sequestration would be very limited. Direct and Indirect and Cumulative Effects Alternative 1 – No Action Apart from ongoing road maintenance and firewood collection, there would be no direct effects of GHG emissions associated with the No Action alternative. However, indirect effects would continue to occur as stands emit CO2 and sequester carbon through the succession and stand development. Emissions from fire are speculative, but are also worth mentioning as a possible indirect effect. Both emissions and sequestration have a cumulative effect on atmospheric concentrations of GHGs.

175 CP District-wide Salvage Project Final Environmental Impact Statement

Effects Common to Both Action Alternatives Forest management activities for CPDWS are intended to increase resiliency over the long term. Although there will be short term increase in GHG emissions, as summarized below, these will be buffered by longer term carbon sequestration. Increased stand resiliency correlates with an ability to better withstand climate change impacts and sequester carbon. Timber harvesting, slash piling and burning, and reforestation all change the amount of carbon sequestered in forest vegetation and soil. Timber harvests result in reduced carbon in forests as biomass is removed. This reduction may come from either living biomass carbon pool, or standing dead carbon pool. Some of the carbon will continue to be stored in wood products (Nunery and Keeton, 2010), or may be used as a source of energy that could range from wood pellets, to firewood. Both forms have the potential to offset energy from traditional fossil fuels. Many of the lower elevation stands analyzed for treatment under CPDWS are at risk for uncharacteristically large or intense wildfires that could release large amounts of CO2. In 2008, wildfire on 931,000 hectares resulted in approximately 143 million metric tons (MMT) of CO2, as compared to prescribed fire on 783,000 hectares that resulted in about 20 MMT (Heath, et. al, 2010). This large discrepancy is not surprising because prescribed fires – including pile burning and the prescribed broadcast burns – are controlled and usually result in lower emissions on a per area basis. Road maintenance and firewood collection would continue under all alternatives and are included for comparison. Emissions from harvesting activities considered under the action alternatives are qualitatively considered in the context from potential emissions from uncontrolled wildfire and quantitatively considered by estimating GHG emissions by alternative (Table 66).

Alternative 2 - Proposed Action The proposed action analyzes treatment up to 17,000 acres of commercial harvest and 1,000 acres of fuels treatments. Both commercial and fuels treatments will result in the initial loss of stored carbon through vegetation loss, soil disturbance, and emissions associated with equipment and machinery. However, as stands re-establish and grow, both as a result of thinning or planting, carbon will be sequestered as part of the typical terrestrial carbon cycle. These stands could burn and trees will still die, or decompose and release carbon in the future. The capacity to adapt to stressors associated with climate change is central to the purpose and need for this project. This can be accomplished through commercial and non-commercial activities. Adaptation would be maximized under this alternative. While this decision does not compel action on all acres of the CPDWS Project, it allows management that will facilitate resiliency and increase stand vigor, while still allowing commercial harvest of trees with economic value. Greenhouse gas emissions, including CO2, would occur directly from tree cutting, soil disturbance, and machinery associated with mechanical treatments and harvest operations including needed road work. These direct emissions would be greater than Alternatives 3. Indirectly, more carbon would be retained in wood products or biomass, than under alternatives with few acres for commercial operations. Wood products would continue sequestering carbon for the life of the product and biomass could displace emissions from other fuel sources. All GHG emissions would cumulatively add to atmospheric concentrations. However, as trees re- establish and thinned stands continue to grow, carbon would be sequestered, reducing atmospheric concentrations. Alternative 3 – Vegetation Management – Limited Action The alternative analyzes treatment up to 8,500 acres of commercial harvest and 1,000 acres of fuels treatments. Both commercial and fuels treatments would result in the initial loss of stored carbon through vegetation loss, soil disturbance, and emissions associated with equipment and machinery. Fewer commercial harvest acres

176 CP District-wide Salvage Project Final Environmental Impact Statement would also result in few emissions from machinery, skid trails, and other activities associated with a commercial timber harvest operation. While this decision does not compel action on all acres, it allows forest management that will facilitate resiliency and increase stand vigor, while still allowing commercial harvest of trees with economic value. Greenhouse gas emissions, including CO2, would occur directly from tree cutting, soil disturbance, and machinery associated with mechanical treatments and harvesting, although less than Alternative 2. Indirectly, more carbon would be retained in wood products or biomass, than under alternatives with few acres for commercial operations, but probably less than Alternative 2, which maximizes the commercial aspects of harvesting. Wood products would continue sequestering carbon for the life of the product and biomass could displace emissions from other fuel sources. All GHG emissions would cumulatively add to atmospheric concentrations. However, as trees re-establish and thinned stands continue to grow, carbon would be sequestered, reducing atmospheric concentrations.

Comparison of alternatives for GHG emissions Site specific GHG emission factors and fuel consumption was estimated using values from several sources within the San Luis Valley, and within and outside Colorado (Dubinsky and Karunanithi, 2016; TSS Consultants, 2001; USDA-Forest Service, 2005) and incorporated into the Forest Service CarbonPlus Calculator (USDA-Forest Service 2016). Of all alternatives, Alternative 2 represents the highest estimate of total GHG emissions (50,628 CO2e Metric Tons), relative to the increased acres proposed for treatment over the life of the project. The amount of GHG for the No Action Alternative (1,335 CO2e Metric Tons) represents ongoing road maintenance and some level of harvest for firewood collections.

Table 66. Summary of gallons of fuel used and metric tons of GHG emissions by alternative

Alt1 Alt2 Alt3 Road maintenance maintain roads 556 696 696 New temp road construction 0 128,000 128,000 Forest management Commercial (salvage/thinning) 0 3,934,296 2,195,313 Fuels thinning/WUI 0 231,429 231,429 Firewood Collection 115,715 115,715 115,715 Total gallons of fuel 116,271 4,410,135 2,671,153 Total GHG CO2e Metric Tons (Mg) emissions 1,335 50,628 30,665 Economic Cost in $ $30,433 $1,154,326 $699,158

177 CP District-wide Salvage Project Final Environmental Impact Statement

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178 CP District-wide Salvage Project Final Environmental Impact Statement Chapter 4. Preparers, Contributors, Distribution Contacts 4.1 Interdisciplinary Team Members

Table 67. Core ID Team members with credentials and EIS roles

Core ID Team Education Years Position Title Professional Team Role Experience M. Beth Davis MS Forestry, Southern 17 Rangeland Management Illinois University Specialist/Botanist BS Botany, Eastern TES Plants, Invasive Illinois University Species, IDT Leader Armando De La Cruz MS Civil Engineering, 5 Civil New Mexico State Engineer/Transportation University Specialist BS Civil Engineering, New Mexico State Transportation University Kelly Garcia BS Environmental 27 Rangeland Management Science/Biology, Adams Specialist State College Rangelands Ivan Geroy MS Civil Engineering, 7 Hydrologist Boise State University BS Fisheries & Wildlife Management, Oregon State University Hydrology & Watershed Sid Hall Technical Fire 16 Fuels Management Management- Specialist Washington Institute; Applied Science- Animal Health, Fire & Fuels Colorado Mountain College Angie Krall MA Applied 24 Heritage Program Anthropology, Northern Leader/Archaeologist Arizona State University BA Anthropology, Colorado College Heritage Antonio Lucero BA Biology, Adams State 16 Natural Resource Specialist College Recreation Use Diana McGinn BS Range-Forest 31 Silviculturist Management Biodiversity, Socio-

179 CP District-wide Salvage Project Final Environmental Impact Statement

BS Wildlife Economics Biology, Colorado State University Kelly Ortiz BA Literature, Syracuse 22 Landscape Architect University

MLA Landscape Architecture, Scenic Resources State University N.Y. Jason Remshardt BS Wildlife and Fisheries 24 Forest Fisheries Biologist Ecology

MS Fisheries Ecology, Aquatics & Fisheries, Oklahoma State Climate Change University Vaughn Thacker MS Soil Fertility and Plant 11 Soil Scientist Nutrition and Ag System Technology, Utah State Soils, Air Quality University BS Environmental Soil and Water Science, Utah State University Michael Tooley BS Forestry, Oklahoma 20 Forester State University Silviculture, Forest Products

David Topolewski B.S. Wildlife Management 7 Wildlife Biologist and Zoology, Humboldt State University M.S. Biology, in progress Wildlife University of Nebraska, Kearney

4.2 Agencies and Tribes Consulted Table 68. List of Agencies and Tribes consulted for the CP District-wide Salvage Project

Agencies Tribes Colorado Parks and Wildlife Southern Ute Indian Tribe Environmental Protection Agency The Hopi Tribe US Fish and Wildlife Service Ute Mountain Ute Tribe Colorado State Historic Preservation Office Uintah & Ouray/Northern Ute Tribe Conejos County Commissioners Pueblo of Nambe Tribes Jicarilla Apache Nation Navajo Nation Pueblo of San Ildefonso Pueblo of Santa Ana Pueblo of Picuris Santa Clara Pueblo Ohkay Owingeh Taos Pueblo Pueblo of Zuni Pueblo of Santo Domingo Pueblo of Laguna Pueblo de Cochiti Pueblo of Acoma

180 CP District-wide Salvage Project Final Environmental Impact Statement

Comanche Nation Kewa Pueblo Pueblo of Pojoaque

4.3 Distribution of the FEIS The FEIS, or notification of the availability of the FEIS, has been sent to the following individuals, agencies, organizations, and elected officials.

Table 69. Contacts for the FEIS notice of availability

Contact Format Contact Format Allpine Lumber & Log Home Co. Email David Kenvin, CO Trout Unlimited Email Antonito Chamber of Commerce Email Jim Kessler Dick Artley Email Paige Lewis, Nature Conservancy Email Jerry Babbitt, Silver Lakes Trout Club Letter Neal Lummus Email Rick Basagoita, Colorado Parks and Wildlife Email Lauren McCain, Defenders of Wildlife Email Cathy Bear, Chama Valley Outdoor Club Email Doug MacLennan, Southwest Nordic Center Email Joanie Berde Email Roz McClellan, Rocky Mountain Email Recreation Initiative Norm Birtcher, Montrose Forest Products Email John Mellgren, Western Environmental Law Email Center Kristie Borchers, RWEACT Email Adam Moore, Colorado State Forest Service Email Allison Jehly, USFWS Email Molly Pitts, Pitts Resource Consulting, LLC Email Bonnie Brown, Colorado Wool Growers Email Office of Honorable Michael Bennett Letter Association Jimbo Buickrood, San Juan Citizens Alliance Email Office of Honorable Larry Crowder Letter Robyn Cascade, Great Old Broads for Email Office of Honorable Cory Gardner Letter Wilderness Chama City Hall Letter Office of Honorable Scott Tipton Letter Chama Valley Chamber of Commerce Email Office of Honorable Donald Valdez Letter Conejos County Commissioners Letter Matt Reed, High Country Conservation Email Advocates Nathan Coombs, Conejos Water Email Rio Grande County Commissioners Email Conservation District Costilla County Commissioners Email Brian and Ann Rue Email Ralph Curtis, Rio Grande Water Conservation Letter Lynn Rutland, San Juan Mountain Church Email District Mary Ann Deboer, Cumbres Nordic Adventure Email Rod Ruybalid, Colorado Parks and Wildlife Letter Emily Hohman, Chama Peak Land Alliance Email Matthew Sandler, Rocky Mountain Wild Email Cleave Simpson, Rio Grande Water Email San Luis Valley Cattlemen’s Association Email Conservation District Greg Dyson, WildEarth Guardians Email San Luis Valley Ecosystem Council Email Chris Furr, Tres Piedras Ranger District Email Rocky Smith Email Bill Getz Tom Sobal, Quiet Use Coalition Email Heather Dutton, Rio Grande Basin Email Kevin Terry, CO Trout Unlimited Email Roundtable Garrett Hanks, Trout Unlimited Letter Ben Wudtke, Intermountain Forest Email Association Bentley Henderson, Archuleta County Letter Jim Webb Email Administrator Marty Jones, SLV Trout Unlimited Email Advisory Council on Historic Preservation Letter APHIS Letter National Environmental Coordinator, NRCS Letter National Agricultural Library Letter NOAA Office of Policy and Strategic Planning Letter U.S. Navy Energy and Environmental Letter U.S. Coast Guard Office of Environmental Letter Readiness Division Management U.S. Army Corp of Engineers Letter U.S. EPA Region 8 Letter 181 CP District-wide Salvage Project Final Environmental Impact Statement

Department of Energy Director of NEPA Letter Regional Director of Federal Aviation Letter Policy & Compliance Administration Division Administrator of the Federal Highway Letter Administration

4.4 Distribution of the DEIS

Notification of the availability of the DEIS has been sent to the following individuals, federal agencies, federally recognized Tribes (see above), State and local governments, elected officials, and organizations representing a wide range of views.

Table 70. Contacts for the DEIS notice of availability

Contact Format Contact Format Allpine Lumber & Log Home Co. Email David Kenvin, CO Trout Unlimited Email Antonito Chamber of Commerce Email Jim Kessler Dick Artley Email Page Lewis, Nature Conservancy Email Jerry Babbitt, Silver Lakes Trout Club Letter Neal Lummus Email Rick Basagoita, Colorado Parks and Email Lauren McCain, Defenders of Wildlife Email Wildlife Cathy Bear, Chama Valley Outdoor Club Email Doug MacLennan, Southwest Nordic Email Center Joanie Berde Email Roz McClellan, Rocky Mountain Email Recreation Initiative Norm Birtcher, Montrose Forest Products Email John Mellgren, Western Environmental Email Law Center Kristie Borchers, RWEACT Email Adam Moore, Colorado State Forest Email Service Kurt Broderdorp, USFWS Email Molly Pitts, Pitts Resource Consulting, Email LLC Bonnie Brown, Colorado Wool Growers Email Office of Honorable Michael Bennett Letter Association Jimbo Buickrood, San Juan Citizens Email Office of Honorable Larry Crowder Letter Alliance Robyn Cascade, Great Old Broads for Email Office of Honorable Cory Gardner Letter Wilderness Chama City Hall Letter Office of Honorable Scott Tipton Letter Chama Valley Chamber of Commerce Email Office of Honorable Edward Vigil Letter Conejos County Commissioners Letter Matt Reed, High Country Conservation Email Advocates Nathan Coombs, Conejos Water Email Rio Grande County Commissioners Email Conservation District Costilla County Commissioners Email Brian and Ann Rue Email Ralph Curtis, Rio Grande Water Letter Lynn Rutland, San Juan Mountain Email Conservation District Church Mary Ann Deboer, Cumbres Nordic Email Rod Ruybalid, Colorado Parks and Letter Adventure Wildlife Monique DiGiorgio, Chama Peak Land Email Matthew Sandler, Rocky Mountain Email Alliance Wild Heather Dutton, SLV Water Conservancy Email San Luis Valley Cattlemen’s Email District Association Greg Dyson, WildEarth Guardians Email San Luis Valley Ecosystem Council Email Chris Furr, Tres Piedras Ranger District Email Rocky Smith Email Bill Getz Tom Sobal, Quiet Use Coalition Email

182 CP District-wide Salvage Project Final Environmental Impact Statement

Contact Format Contact Format Mike Gibson, Rio Grande Basin Email Kevin Terry, CO Trout Unlimited Email Roundtable Garrett Hanks, Trout Unlimited Letter Tom Troxel, Intermountain Forest Email Association Bentley Henderson, Archuleta County Letter Jim Webb Email Administrator Marty Jones, SLV Trout Unlimited Email

183 CP District-wide Salvage Project Final Environmental Impact Statement Index Affected Environment, 40 Issues, 19

Biological legacies, 33, 34 leave islands, 26, 34

CFR, 12, 18, 21, 30, 36, 40, 64, 85, 86, 101, 147, Lynx Habitat Elements, 26

164, 166, 167, 168 Management Area Prescriptions, 11, 42, 174

Council on Environmental Quality regulations, i, MAPs, 11, 15, 42, 46, 49, 51, 174

40 MIS, 33, 64, 69, 87, 88, 94, 164

Cumulative effects, 40 Monitoring, 30, 36, 83, 88, 93, 114, 171

Designation by Description, 33, 34 Project Design Criteria, 30

Direct effects, 40 purpose and need, i, 1, 9, 13, 18, 21, 22, 40, 81,

Endangered Species Act, 64, 101 153, 155

Forest Plan, i, 2, 9, 11, 12, 13, 14, 15, 18, 19, 23, record of decision, i, 18, 164

26, 27, 30, 33, 35, 36, 37, 38, 41, 42, 47, 49, 51, salvage logging, 2, 12, 53, 79, 93, 133

52, 54, 73, 77, 87, 88, 89, 90, 93, 94, 97, 98, 99, seral stage, 54, 58, 168, 178

103, 109, 121, 123, 125, 126, 133, 140, 142, spruce beetle, 1, 11, 12, 20, 21, 23, 33, 34, 40, 41,

147, 150, 164, 172, 173, 174, 175 43, 44, 46, 48, 49, 50, 52, 53, 64, 66, 67, 75, 76,

forest reorganization, 44, 45 79, 105, 121, 125, 142, 153

Forest Service Handbook, 19, 30, 117 USDA Forest Service Strategic Plan: 2015-2020,

Habitat Connectivity, 26, 77

Indirect effects, 40

184 CP District-wide Salvage Project Final Environmental Impact Statement Appendices Appendix A – Commonly Used Terms and Definitions A.1 – Acronyms and Abbreviations

AMP – allotment management plan GIS – geographical information system AMZ – aquatic management zone HRV – historical range of variability AOI – annual operating instructions HUC – hydrologic unit code BA – basal area IDT – interdisciplinary team BMPs – best management practices IRA – inventoried roadless area CCF – hundreds of cubic feet LTA – landtype association CEQ – Council on Environmental Quality LAU – lynx analysis unit CFR – Code of Federal Regulations MAP – forest service management area prescription CPDWS – CP District-wide Salvage MBF – thousand board feet CPW – Colorado Parks and Wildlife MIS – management indicator species CRA – Colorado Roadless Area MMBF – million board feet CWD- coarse woody debris NEPA – National Environmental Policy Act CWPP – Community Wildfire Protection Plan NFMA – National Forest Management Act DAU – data analysis unit (big game) NFSR – National Forest System Road DBH – diameter at breast height PDC – project design criteria DSD – detrimental soil disturbance PFC – properly functioning condition DEIS – draft environmental impact statement RGCT - Rio Grande Cutthroat Trout DHC – dense horizontal cover RGNF – Rio Grande National Forest DSD – detrimental soil disturbance ROD – record of decision EIS – environmental impact statement ROS – recreation opportunity spectrum FEIS – final environmental impact statement SISS –stand initiation structural stage FS - Forest Service SHPO – State Historic Preservation Office FSDMP – forest soil disturbance monitoring SRLA – Southern Rockies Lynx Amendment FSH – Forest Service handbook TES – threatened, endangered, and sensitive species FVS – forest vegetation simulator WIZ – water influence zone GHG - greenhouse gas WUI – wildland urban interface

A.2 – Terms and Definitions

Term Definition Artificial Regeneration A group or stand of young trees created by direct seeding or by planting seedlings or cuttings Basal area (BA) Cross-sectional area, in square feet, of a tree measured at dbh, diameter at breast height (4.5 feet above ground). Board Foot (BF) Measure of an amount of timber equivalent to a piece of lumber 12 inch by 12 inch by 1 inch. Coarse Woody Debris Woody materials greater than 3 inches in diameter. (CWD): Commercial Forest Sawlogs, small roundwood, biomass, and other forest products removed in the process Products of harvesting or cutting trees from NFS lands. Cover Type A taxonomic unit of vegetation classification referencing existing vegetation. Cover type is a broad taxon based on existing plant species that dominate, usually within the tallest layer. Desired Conditions A set of ideal conditions established for a Management Area Prescription within the Forest Plan. These conditions are the goals for the Management Area and the intended end results for all actions taken within it. Desired Conditions for each specific

185 CP District-wide Salvage Project Final Environmental Impact Statement

Management Area Prescription are outlined in Chapter IV of the Revised Land and Resource Management Plan of the Rio Grande National Forest.

Endangered plant: A plant that is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range. Even-aged management The application of a combination of actions that results in the creation of stands in which trees of essentially the same age grow together. The difference in age between trees forming the main canopy level of a stand usually does not exceed 20 percent of the age of the stand at harvest rotation age. Regeneration in a particular stand is obtained during a short period at or near the time that a stand has reached the desired age or size for regeneration and is harvested. Existing Scenic Represents the status of the landscape and the degree to which it has been altered. Integrity This is a baseline measurement for Scenic Resources. The following is a list of the Scenic Integrity Levels: • Type I (Natural Appearing Landscapes)-areas in which on ecological change has taken place except for trails needed for access. They appear untouched by human activities. This included wilderness and primitive areas. • Type II (Slightly Altered Appearing Landscapes)-areas where some human activity has occurred. Usually these areas can be described as near natural appearing or slightly altered. Type III (Altered Appearing)-areas where human modification has occurred and is obvious. Usually these areas are described as altered. Fine Slash Branches, leaves and limbs less than 3 inches diameter.

Fire Behavior The manner in which a fire reacts to the variables of fuel, weather, and topography

Fuel Break A wide strip or block of land on which the fuels have been modified so that fire burning into it can be more readily contained. Fire Intensity The rate of energy or heat release per unit time, per unit length of fire front, regardless of its depth. Fuel Loading The amount of fuel on site expressed in Tons per Acre.

Fuel Profile The representation of various fuel characteristics (size class, loading, volatility, density, etc.) in terms of vertical and horizontal arrangement, amount, and continuity. Fire Regimes The nature of fires occurring over extended period of time. Fire Regimes reflect the fire environment, and influence the type and abundance of fuel, thereby affecting fire behavior and fire effects through time. Fire Severity A qualitative indicator of the effects of fire on an ecosystem, whether it affects the forest floor, canopy, or some other part of the system. Fuels Available vegetation, both live and dead that is capable of combustion and can contribute to fire spread. Group Selection An uneven-aged harvest system in which trees are removed and new age classes are Harvest established in small groups, rather than evenly-spaced individual trees. Natural regeneration is thereby established in pockets, but still under the protection of a partial forest canopy. Hazard Tree A standing tree with the potential to fall which would cause injury or damage to people or property due to conditions that affect the integrity and/or stability of the tree. These conditions include but are not limited to deterioration or physical damage to the roots system, trunk, stem, or limbs, and/or the direction and lean of the tree Heritage Resources These are sites, features, and values having scientific, historical, educational, and/or cultural significance. They include concentrations of artifacts, structures, landscapes, or settings of for prehistoric or historic events.

186 CP District-wide Salvage Project Final Environmental Impact Statement

Heritage Resource A systematic on-the-ground search designed to identify the locations of heritage Inventory resources. Heritage resources identified in such inventories are recorded on State of Colorado cultural resource site forms which includes determination of the significance of individual sites. Historical Range of A method to understand the dynamic nature of ecosystems; the processes that sustain Variability and change ecosystems; the current state of the ecosystem in relationship to the past; and the possible ranges of conditions that are feasible to maintain. Indicator A measurement of a resource quantity or quality, which is linked to a cause-and- effect relationship and responsive to an issue. Indicators are used to compare the effects among alternatives, and are most generally quantitative, rather than qualitative, in measure. Intermediate One intermediate step of the shelterwood harvest system in which the canopy cover Shelterwood Harvest is opened up through the removal of mature trees to promote natural regeneration and stand vigor. This step is prior to final harvest. Issue A concern expressed over the potential effects of a proposed action on the human environment, due to the geographic extent, duration, or intensity of interest or resource conflict. Issues are used to develop and compare alternatives, prescribe mitigation measures, and analyze the environmental effects. For a concern to be considered an issue, it must be relevant to the specific project and appropriately addressed at that level. Ladder Fuels Intermediate height fuels

Landtype Association An ecological mapping unit based on similarities in geology, soils, and plant associations. Repeatable patterns of soil complexes and plant communities are useful in delineating map units. LTAs are an appropriate ecological unit to use in Forest- or area-wide planning and watershed analysis. On the RGNF, soil mapping units were aggregated into 13 distinct LTAs. Long-Butt A section cut from the bottom log of a tree and culled because of rot or other defect.

Natural Regeneration The establishment of a plant or a plant age class from natural seeding, sprouting, suckering, or layering. National Forest System A forest road other than a road which has been authorized by a legally documented road ~ right-of-way held by a State, county or other local public road authority. Non-system Road Also termed “Unclassified Roads.” Roads on National Forest System lands that are not managed as part of the forest transportation system, such as unplanned roads, abandoned travelways, and off-road vehicle tracks that have not been designated and managed as a trail; and those roads that were once under permit or other authorization and were not decommissioned upon the termination of the authorization (36 CFR 212.1). Noxious Weeds A plant specified by law as being especially undesirable, troublesome, and difficult to control. Operational The maintenance level currently assigned to a road considering today’s needs, road maintenance level condition, budget constraints, and environmental concerns. It defines the level to which the road is currently being maintained (FSH 7709.59, 62.3). Maintenance levels ~ Defines the level of service provided by, and maintenance required for, a specific road, consistent with road management objectives and maintenance criteria. Level 1. Closed roads that have been placed in storage between intermittent uses. The period of storage must exceed 1 year. Basic custodial maintenance is performed to prevent damage to adjacent resources and to perpetuate the road for future resource management needs. These roads are not shown on motor vehicle use maps. Level 2. Roads open for use by high clearance vehicles. Passenger car traffic, user comfort, and user convenience are not considerations. Motorists should have no expectations of being alerted to potential hazards while driving these roads. Traffic is normally minor. Level 3. Maintained for travel by a prudent driver in a standard passenger car. User 187 CP District-wide Salvage Project Final Environmental Impact Statement

comfort and convenience are not considered priorities. Warning signs and traffic control devices are provided to alert motorists of situations that may violate expectations. Prescribed fire Planned ignitions, implemented in accordance with approved burn plans that are designed to meet specific objectives. Preparatory cut An optional type of cut that enhances conditions for seed production and establishment applied under the shelterwood regeneration methods. Riparian Management RMZs pertain specifically to those streams providing habitat for cutthroat trout and Zone (RMZ) Rio Grande Sucker. This habitat provides a linkage and transitional zone between hillslopes and upland terrestrial areas and the aquatic habitats within stream channels. They can be defined by specific distances or by vegetation types or a combination of the two (i.e., 2 site tree heights). Reforestation The re-establishment of forest cover, either naturally or artificially. This process usually maintains the same forest type and is done promptly after the previous stand or forest was removed. Regeneration method Cutting procedure by which a new age class is created. The major methods are clearcutting, seed-tree, shelterwood, selection, and coppice. Regeneration methods are grouped into: coppice, even-aged, two-aged, and uneven-aged. Road decommissioning Activities that result in the stabilization and restoration of unneeded roads to a more natural state." (36 CFR 212.1, FSM 7705- Transportation System) The Forest Service Manual (7712.11- Exhibit 01) identifies five levels of treatments for road decommissioning which can achieve the intent of the definition. These include the following: 1) Block entrance; 2) Revegetation and waterbarring; 3) Remove fills and culverts; 4) Establish drainage ways and remove unstable road shoulders; 5) Full obliteration recontouring and restoring natural slopes. Equivalent Road During Forest planning, Disturbance Area Factors (DAF) or values were established Disturbance for different types of surface disturbances that may occur in watersheds (i.e. road building, livestock grazing, clearcuts, partial timber harvests, pipelines, railroads, impoundments, etc.) in order to evaluated the percent disturbance for each watershed.

Each type of disturbance was given a relational DAF value that compared the disturbance to roads, generating an “equivalent road disturbance” factor. Since roads were considered the most impacting disturbance due to the elimination of vegetation and compaction they were given a DAF of 1.0 along with other similar impact disturbances such as ditches, railroads, milling sites, impoundment, etc. Clearcuts were given a factor of 0.3 and partial timber harvests were given a factor of 0.19. When all disturbance acreage is multiplied by the appropriate DAF and added together to give a total road equivalent disturbance acreage for each watershed. Road Maintenance The ongoing upkeep of a road necessary to retain or restore the road to the approved road management objective (FSM 7712.3). Road Construction Activity that results in the addition of forest classified or temporary road miles (36 (New) CFR 212.1). Road Reconstruction Activity that results in improvement or realignment of an existing classified road Road Improvement. Activity that results in an increase of an existing road’s traffic service level, expands its capacity, or changes its original design function. Road Realignment. Activity that results in a new location of an existing road, or portions of an existing road, and treatment of the old roadway (36 CFR 212.1). Road Spot Road reconstruction activities on very short sections of road. Generally involve Reconstruction activities such as culvert replacement and surface rock replacement Salvage Removal of dead trees or trees being damaged or dying due to injurious agents other than competition, to recover value that would otherwise be lost. Sanitation Removal of trees to improve stand health by stopping or reducing actual or anticipated spread of insects and disease. Seral The stage of succession of a plant or animal community that is transitional. If left alone, the seral stage will give way to another plant or animal community that

188 CP District-wide Salvage Project Final Environmental Impact Statement

represents a further stage of succession.

Shelterwood Harvest The removal of a stand in a series of usually three cuts over a period of time. Regeneration of the new stand occurs under the cover of a partial forest canopy. A final harvest cut removes the shelterwood and permits the new stand to develop in the open as an even-aged stand. Silvicultural system A planned series of treatments for tending, harvesting, and re-establishing a stand. The system name is based on the number of age classes (i.e. even-aged, two-aged, uneven- aged) or regeneration method (i.e. clearcutting, seed tree, shelterwood) used. Soil Compaction Soil that has a 15% increase in bulk density over natural undisturbed conditions.

Soil Erosion Hazard A rating of a soils potential to erode.

Stand A community of trees or other vegetation sufficiently uniform in composition, constitution, age, spatial arrangement, or condition to be distinguishable from adjacent communities and so form a silvicultural or management entity. Stand Initiation Vegetation stage that develops after a stand-replacing disturbance by fire, insects, or Structural Stage regeneration timber harvest. A new single-story layer of shrubs, tree seedlings, and saplings develop and occupy the site. Stocking The degree to which trees occupy the land, measured by basal area or number of trees by size and spacing, compared with a stocking standard such as the basal area or number of trees required for full utilization of the land’s growth potential Structure Class A classification of forested cover types which aggregates Habitat Structural Stage into broader categories. Succession The process of vegetative and ecological development whereby an area becomes successively occupied by different plant communities. System Roads Also termed “Classified Roads.” Roads wholly or partially within or adjacent to National Forest System lands that are determined to be needed for long-term motor vehicle access, including State roads, county roads, privately owned roads, National Forest System roads, and other roads authorized by the Forest Service (36 CFR 212.1). Temporary Road A road necessary for emergency operations or authorized by contract, permit, lease, or other written authorization that is not a forest road or a forest trail and that is not included in a forest transportation atlas. Threatened plant A plant that is in danger of extinction throughout all or a significant portion of its range. Uneven-aged stand A stand of trees of three or more distinct age classes, either intimately mixed or in groups. Trap Tree A log or tree felled or treated in a manner to invite insect infestation, particularly bark beetles. Water Influence Zone For the purposes of this document the Water Influence Zone (WIZ), defined in FSH (WIZ) 2509.25 is functionally the same as the Aquatic Management Zone (AMZ) used in FS- 990A (National Best Management Practices for Water Quality Management on National Forest System Lands). These definitions are different than the Riparian Management Zone (RMZ). Weeding The removal of competing vegetation from a stand that is still in sapling stage in order to increase tree survival and vigor. Wildfire A fire that burns uncontrollably in a natural setting (e.g., a forest, or grassland).

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190 CP District-wide Salvage Project Final Environmental Impact Statement Appendix B – References and Literature Cited

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Coulter, C.T., D. Southworth & P.E. Hosten. 2010. Prescribed fire and post-fire seeding in brush masticated oak-chaparral: Consequences for native and nonnative plants. Fire Ecology 6(2): 60-75.

Cristan, R, W.M. Aust, M.C. Bolding, S.M. Barrett, J.F. Munsell, and E. Schilling. 2016. Effectiveness of forestry best management practices in the United States: Literature review. Forest Ecology and Management. 360: 133-151.

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DeBano, L.F. 2000. The Role of Fire and Soil Heating on Water Repellency in Wildland Environments. Journal of Hydrology, 2000, pgs. 195-206. Dixon, G. E. 2002. Essential FVS: A User's Guide to the Forest Vegetation Simulator. Fort Collins, CO: USDA Forest Service.

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Forest Service Washington Office. 2014. Forest Service Manual 2400- Forest Management, Chapter 2470- Silvicultural Practices, Amendment No. 2400-2014-1. Washington, D.C.: USDA Forest Service.

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Forest Stewardship Concepts Ltd. 2014. Rio Grande Basin Watershed Heath and Forest Biomass Opportunities Evaluation Report prepared for the Rio Grande Watershed Emergency Action Coordination Team (RWEACT), 28 pgs.

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Gordon, E. and D. Ojima, eds. 2015. Colorado Climate Change Vulnerability Study – A Report Submitted to the Colorado Energy Office. University of Colorado, Boulder and Colorado State University. 175 pp. Accessed online at http://fsweb.r2.fs.fed.us/strategic_planning/climate_change/CO%202015.pdf. Great Sand Dunes NP and Preserve, et al. (GSRA). 2008. The San Luis Valley NAGPRA MOU. Report on file at the Rio Grande NF Supervisors Office, Monte Vista, CO and on the O drive at: O:\NFS\RioGrande\Program\2300Recreation\2360HeritageRestricted\1TRIBAL\Interagency_MO U Gunnison Service Center. 2015. Activities of forest insects and diseases on the Rio Grande National Forest for 2015. Gunnison, CO: USDA Forest Service.

Hadley, K. S., & Veblen, T. T. 1993. Stand response to western spruce budworm and Douglas-fir bark beetle outbreaks, Colorado Front Range. Canadian Journal of Forestry, 479-491.

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Jeffers, R. M. 1995. Engelmann Spruce Super-Seedling Plantations, Rio Grande National Forest: Thirteenth Growing Season Survival and Height Growth. USDA Forest Service.

Keeley, J.E. & T.W. McGinnis. 2007. Impact of prescribed fire and other factors on cheatgrass persistence in a Sierra Nevada ponderosa pine forest. International Journal of Wildland Fire 16: 96-106.

Kindscher, K., J. Yang, Q. Long, R. Craft, and H. Loring. 2013. Harvest Sustainability Study of 2013 Wild Populations of Oshá, Ligusticum porteri. Open-File Report No. 176. Kansas Biological Survey. Lawrence, KS. 20 pp.

MacDougall, A.S. & R. Turkington. 2005. Are invasive species the drivers or passengers of change in degraded ecosystems? Ecology 86(1): 42-55.

Mask, R., & Worrall, J. 2011. Spruce Beetle and Root Disease Observations; Trujillo Meadows Campground, RGNF. Gunnison, CO: USDA Forest Service.

McGlone, C.M., J.D. Springer & W.W. Covington. 2009. Cheatgrass encroachment on a ponderosa pine forest ecological restoration project in northern Arizona. Ecological Restoration 27(1): 37-46.

Merriam, K.E., J.E. Keeley & J.L. Beyers. 2006. Fuel breaks affective nonnative species abundance in Californian plant communities. Ecological Applications 16(2): 515-527.

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Morelli, T. S. Yeh, N. Smith, M. Hennessy, and C. Millar. 2012. Climate Project Screening Tool: An Aid for Climate Change Adaptation. Pacific Southwest Research Station Research Paper PSW-RP-263. Fort Collins, CO. 29 pp. Accessed online at https://www.fs.fed.us/psw/publications/documents/psw_rp263/psw_rp263.pdf.

Nature Conservancy. 2013. Rio Grande Cutthroat Trout Wildfire Risk Assessment. Prepared for New Mexico Department of Game and Fish. 76 pp. Accessed online at http://www.wildlife.state.nm.us/download/fishing/rio-grande-cutthroat-trout-wildfire- risk%20/Assessment-Part_1.pdf

Neary, Daniel G.; Ryan, Kevin C.; DeBano, Leonard F., eds. 2005. (Revised 2008). Wildland fire in ecosystems: effects of fire on soils and water. Gen. Tech. Rep. RMRS-GTR-42-vol.4. Ogden, UT: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 250 p.

NOAA. 2017. Vital Signs of the Planet – Carbon Dioxide. Accessed online at https://climate.nasa.gov/vital- signs/carbon-dioxide/.

Nunery, J. and W. Keeton. 2010. Forest carbon storage in the northeastern United States: Net effects of harvesting frequency, post-harvest retention, and wood products. Forest Ecology and Management 259 (2010) 1363–1375. Accessed online at https://www.uvm.edu/giee/pubpdfs/Nunery_2010_Forest_Ecology_and_Management.pdf.

O'Hara, K. L., & Latham, P. A. 1996. A Structural Classification for Inland Northwest Forest Vegetation. Western Journal of Applied Forestry, 97-102.

Page-Dumroese, D.S. et al. 2009. Forest Soil Disturbance Monitoring Protocol, USDA Forest Service General Technical Report WO-82a and 82b.

Reiser, Marcy. 2017. A Class I Literature Review for the Conejos Peak District-wide Salvage. On file at the Rio Grande NF Supervisors Office, Monte Vista, CO and on the O Drive at: O:\NFS\RioGrande\Program\2300Recreation\2360HeritageRestricted\000_2016\Projects\Timber\ Conejos_Peak_District-Wide

Rio Grande National Forest. 1996. Final Environmental Impact Statement for the Revised Land and Resource Management Plan. Monte Vista, CO: USDA Forest Service.

Rio Grande National Forest. 1996. Revised Land and Resource Management Plan, Rio Grande National Forest. Monte Vista, CO: USDA Forest Service.

Rio Grande National Forest – draft Assessment 6. 2016. Social, Cultural and Economic Conditions. 47 pgs. https://www.fs.usda.gov/detail/riogrande/landmanagement/projects/?cid=stelprd3819044

Rio Grande National Forest – draft Assessment 7. 2016. Ecosystem Services. 9 pgs. https://www.fs.usda.gov/detail/riogrande/landmanagement/projects/?cid=stelprd3819044

Rio Grande National Forest – draft Assessment 8. 2016. Multiple Uses. 34 pgs. https://www.fs.usda.gov/detail/riogrande/landmanagement/projects/?cid=stelprd3819044

Rio Grande National Forest – draft Assessment 8.1 2016. Scenic Character. 28 pgs. https://www.fs.usda.gov/detail/riogrande/landmanagement/projects/?cid=stelprd3819044

Romme, W., Clement, J., Hicke, J., Kulakowski, D., MacDonald, L., Schoennagel, T., & Veblen, T. 2006. Recent Forest Insect Outbreaks and Fire Risk in Colorado Forests: A Brief Synthesis of Relevant Research. Fort Collins, CO: Colorado State University. 24p.

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Romme, W.H.; Floyd, M.L.; Hanna, D. 2009. The Forests of Southwestern Colorado and Northwestern New Mexico: How the Past and Present Inform our Choices for the Future, Colorado Forest restoration Institute.

Ryerson, Daniel E, Thomas W. Swetnam, Ann M. Lynch. 2003. A tree-ring reconstruction of western spruce budworm outbreaks in the San Juan Mountains, Colorado, U.S.A. Can. J. For. Res. 33: 1010-1028, 2003.

Schmid, J., & Frye, R. 1976. Stand Ratings for Spruce Beetles. Fort Collins, CO: USDA Forest Service Research Note RM-309 4pp.

Schmid, J., & Mata, S. 1996. Natural Variability of Specific Forest Insect Populations and Their Associated Effects in Colorado. USDA Forest Service General Technical Report: GTR-275. Fort Collins, CO. 22pp.

Shepperd, W. D., Jeffers, R. M., & Ronco, F. J. 1981. An Engelmann Spruce Seed Source Study in the Central Rockies. Fort Collins, CO: USDA Forest Service, Rocky Mountain Forest and Range Experiment Station.

Smith, D. M., Larson, B. C., Kelty, M. J., & Ashton, P. M. 1997. The Practice of Silviculture: Applied Forest Ecology, Ninth Edition. John Wiley & Sons, Inc.

Stage, A. R., Crookston, N. L., Long, D., & Keane, R. E. 1995. Calibrating a forest succession model with a single-tree growth model: and exercise in meta-modelling. Moscow, ID: USDA Forest Service.

Sutherland, S. & C.R. Nelson. 2010. Nonnative plant response to silvicultural treatments: A model based on disturbance, propagule pressure and competitive abilities. Western Journal of Applied Forestry 25(1): 27-33.

Thysall, D.R. & A.B. Carey. 2001. Manipulation of density of Psuedotsuga menziesii canopies: Preliminary effects on understory vegetation. Canadian Journal of Forest Restoration 31: 1513-1525.

TSS Consultants. 2011. Wood Fuel Availability Analysis for the Roaring Fork Valley, Colorado. Prepared for Roaring Fork Biomass Consortium Roaring Fork Valley, Colorado. 25 pp. Accessed online 12/23/2016 (http://tssconsultants.com/reports/2011-3-31-Wood-Fuel-Availability-Analysis- Roaring-Fork-Valley.pdf).

USDA Forest Service. 1996. Soil Resource and Ecological Inventory of the Rio Grande National Forest- West part, Colorado.

USDA Forest Service. 1996. Revised Land and Resource Management Plan (as amended) Forest Plan and Final Environmental Impact Statement for the Revised Land and Resource Management Plan, Rio Grande National Forest. USDA Forest Service. Rocky Mountain Region. Rio Grande National Forest. Monte Vista, CO. December 13, 1996.

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USDA Forest Service. 2003. Forest Service Supplemental Specifications to FP-03.

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USDA Forest Service. 2012. Technical Guide FS-990a. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. April 2012. http://fsweb.wo.fs.fed.us/wfw/watershed/national_bmps/assets/fs_national_core_bmps_april2012.p df

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USDA Forest Service. 2015. Assessment 4, Rio Grande National Forest Plan Revision – Carbon. 11 pages. Accessed online at (https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd493827.pdf).

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USDA Forest Service. 2012. Technical Guide FS-990a. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. April 2012. http://fsweb.wo.fs.fed.us/wfw/watershed/national_bmps/assets/fs_national_core_bmps_april2012.p df

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Webb, J. 2015. Spruce Sawlog Quality Changes Due to Spruce Bark Beetle Mortality, Rio Grande National Forest. Rio Grande Watershed Emergency Action Coordination Team.

Webb, R. H., McCabe, G. J., Hereford, R., & Wilkowske, C. 2004. Climatic Fluctuations, Drought, and Flow in the Colorado River. Retrieved from water.usgs.gov: http://water.usgs.gov/preview/pubs/fs/2004/3062

Webb, Robert H. et al. 2004. Climatic Fluctuations, Drought, and Flow in the Colorado River. USGS Fact Sheet 3062-04. 16p.

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196 CP District-wide Salvage Project Final Environmental Impact Statement Appendix C – Project Implementation Checklists

CP District-wide Salvage Project Implementation Checklist #1 of 2 Analysis at Project Initiation

This stage of analysis is tiered to the CP District-wide Salvage Project. Refer to the project Final Environment Impact Statement and Record of Decision, available at the Conejos Peak Ranger District office or online at http://www.fs.usda.gov/projects/riogrande/landmanagement/projects, for discussions and analysis permitting this action.

Implementation Project Name: ______Implementation Project Location: ______Proposed activities: ______Proposed treatment area (acres): ______

1. Forest Plan Compliance This project falls within the following Management Area Prescriptions (MAPs) or geographic areas (attach map):

1a. Current law, policy and plans have been considered for new information pertaining to these activities. Effects are within the context considered in the project FEIS.* 1b. The treatment activities are allowed within these area prescriptions per current Forest Plan direction. 1c. Standards, guidelines, and handbook direction specific to this activity, which are not already addressed by project design criteria (PDC), are listed below. These are to be included in the project design: MAP Specify standard, guideline, direction, or NA

* If effects are determined to be outside the scope and range of effects considered in the FEIS, the responsible official will determine the type of additional analysis that is necessary prior to additional implementation.

Analysis completed by Date Signature

2. Colorado Roadless Rule Compliance 2a. No timber sale units fall within a CRA. 2b. No hazardous fuel treatments fall within an upper tier CRA. 2c. Hazardous fuel treatments within a CRA (non-upper tier) are within ½ mile from the boundary

of an at-risk community. Name of community, or NA: 2d. Hazardous fuel treatments within a CRA (non-upper tier) are within 1½ miles from the boundary of an at-risk community having a Community Wildfire Protection Plan. Name of CWPP & community, or NA: 197 CP District-wide Salvage Project Final Environmental Impact Statement

2e. Hazardous fuel treatments are not otherwise prohibited (by law or Forest Plan prescription).

Analysis completed by Date Signature

3. Project FEIS/ROD Compliance 3a. This project falls within the CP District-wide Project Boundary and the proposed activities were allowed by the Decision. 3b. This project does not treat areas which were excluded from treatment by the Decision. 3c. Total number of salvage acres previously treated under this decision . Additional proposed salvage acres to be treated with this project . Summed acres do not exceed Decision treatment area for salvage harvest. 3d. Total number of hazardous fuels treatment acres previously treated under this decision . Additional proposed acres to be treated with this project . Summed acres do not exceed Decision treatment area for hazardous fuel treatment. 3e. Total number of miles of temporary road (new & old combined) previously opened under this decision . Additional proposed miles of temporary road (new & old combined) proposed with this project . Summed miles of temporary road do not exceed Decision for temporary road. 3f. This project was considered for public firewood gathering. Areas were designated as appropriate. 3g. Specialist survey and required consultation has been completed. Note remarks under (3f). Resource Specialist Initial & Date Resource Specialist Initial & Date Fisheries Watershed Wildlife Heritage (See also Heritage Checklist) Scenic Silviculture Soils Old Growth Recreation Range Fuels Hydrology Botany & Rare Plant

3h. The following actions must be added to the project design (in addition to PDC and 1b above) to meet statutory, regulatory, and Forest Plan requirements. Provision Citation of requirement being met

4. Lynx Conservation Compliance (Southern Rockies Lynx Amendment or superseding agreement) This project falls within the following LAUs (attach map): 4a. Standards VEG S1, VEG S2, VEG S5, & VEG S6 (or equivalent) are met or are not applicable to the treatments proposed. 4b. Guidelines VEG G1, VEG G4, VEG G5, VEG G10, & VEG G11 (or equivalent) are met or are not applicable to the treatments proposed. 4c. Impacts to lynx habitat baselines resulting from this project have been recorded in the tracking spreadsheet (see attached) and reported to the USFWS.

198 CP District-wide Salvage Project Final Environmental Impact Statement

4d. The project is in compliance with the terms of the BO.

Analysis completed by Date Signature

5. Heritage Resources 5a. Section 106 compliance has been met on this project. (See also Heritage Checklist)

Analysis completed by Date Signature

6. District Ranger Certification I have reviewed Implementation Checklist #1 for this project and agree that the analysis herein meets all project planning requirements and that the actions fall within the scope of the CP District-wide Salvage Project Record of Decision. Implementation Checklist #2 will be completed after sale preparation.

Date Signature

199 CP District-wide Salvage Project Final Environmental Impact Statement

CP District-wide Salvage Project Implementation Checklist #2 of 2 Analysis prior to Project Implementation or Contract Solicitation

This stage of analysis is tiered to the CP District-wide Salvage Project. Refer to the project Final Environment Impact Statement, available at the Conejos Peak Ranger District office or online at http://www.fs.usda.gov/projects/riogrande/landmanagement/projects, for discussions and analysis permitting this action.

Implementation Project Name: ______Implementation Project Location: ______Proposed treatment activities: ______Proposed treatment area (acres): ______

1. Management Area Compliance 1a. All standards, guidelines, and handbook direction identified in Checklist #1, Section 1, have been implemented in the project & addressed in the Timber Sale Report (for timber sales) or Silviculture prescription (for Hazardous Fuels management projects), along with the PDC.

2. Project FEIS/ROD Compliance 2a. All stipulations identified in Checklist #1, Section 3, have been implemented in the project & addressed in the Timber Sale Report (for timber sales) or Silviculture prescription (for Hazardous Fuels management projects), along with the PDC. 2b. Public notification has occurred per the Decision direction.

Analysis completed by Date ______Signature

3. Public Notification 3a. Checklist #1 and all supporting documentation has been placed on the Forest website.

4. Recommendations for Travel Management:______

5. District Ranger Certification I have revi ewed Implementation Checklist #2 for this project and agree that the analysis herein meets all project planning requirements and that the actions fall within the scope of the CP District-wide Salvage Project Record of Decision. Project implementation may begin immediately.

______Date ______Signature

200 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix D - Silvicult–re and Hazardous Fuels Guidelines for Project Implementation Note: Actual use of these guidelines and acres of management will depend on the selected alternative. The following table includes the full range of potential activities as described in chapter 3. Vegetation Desired Lynx habitat Silvicultural Treatment(s) Options – mechanical 5 Zone/ Type Condition status Engelmann Short- midterm: A Silvicultural Rx: Salvage dead and dying spruce to recover economic value and reduce long-term fuel accumulation. Depending spruce – healthy mix of mostly on the level of stand mortality, salvage harvest may be recorded as a regeneration harvest activity since the residual stand will be subalpine fir young conifers, aspen at an early seral stage with a causal agent of bark beetles. Perform stocking surveys following harvest completion; Allow stands regeneration, and or portions of stands to convert to aspen or plant Engelmann spruce or other suitable native conifer seedlings in understocked 6 Spruce-mixed residual live trees stands following harvest to speed forest recovery & meet desired stocking levels. conifer Stand Condition Description Action(s) Snags and CWD levels meet resource Multi-storied stand Stand is multi-storied (>2 live layers), mature or late Alternative 2- Only limited salvage harvest-related activities and incidental needs with DHC successional (>40% live canopy closure), and damage8 to DHC would occur in true VEG S6 stands; any incidental damage contains Dense Horizontal Cover (DHC; i.e., ≥ 35% to DHC from salvage activities is counted against Forest VEG S6 caps. Meet

horizontal cover) providing winter snowshoe hare SRLA standards and guidelines by minimizing or avoiding impacts to any Long term: More habitat7 (VEG S6). healthy advance regeneration and green trees contributing to overstory closed canopy; two or canopy cover to the extent feasible, through avoidance during unit layout, more canopy layers [Lynx habitat priority area 4] designated skid trails & landings, flagging or painting on the ground, or other with dense understory measures. cover to provide

winter snowshoe hare Alternative 3- No salvage harvest-related activities. habitat Single-storied Stand is no longer multi-storied (≥2 live layers), Alternative 2- Salvage harvest; Incidental damage to advance regeneration Maintain 5 to 15 stand with DHC mature or late successional due to spruce beetle providing ≥ 20% horizontal cover is counted against LAU VEG S1/VEG S2 9 percent seral aspen mortality (≥ 75% overstory mortality ), but caps if overstory cover is reduced to 25% or less or understory cover is component on the understory trees provide DHC within the stand. reduced to <20%. Meet SRLA standards and guidelines by minimizing or landscape avoiding impacts to any healthy advance regeneration and green trees OR OR contributing to overstory canopy cover to the extent feasible, through Moderate future fuel avoidance during unit layout, designated skid trails & landings, flagging or loading to reduce Multi-storied stand Stand is multi-storied (≥2 live layers), mature or late painting on the ground, or other measures. future fire severity lacking DHC successional (>40% live canopy closure); contains an established understory providing 20-35% Alternative 3- No salvage harvest related activities. horizontal cover.

[Lynx habitat priority area 3] Single-storied Stand is single-storied &/or not mature or late Alternative 2- Salvage harvest; Meet SRLA standards and guidelines by stand lacking DHC successional; live overstory provides <25% cover minimizing or avoiding impacts to any healthy advance regeneration and and understory provides 20-35% horizontal cover. green trees contributing to overstory canopy cover to the extent feasible, through avoidance during unit layout, designated skid trails & landings, OR flagging or painting on the ground, or other measures.

Stand is single-storied &/or not mature or late Alternatives 3- Salvage harvest; Blocks (patches) of DHC >0.3 acres 4 Refers to stands mapped as lynx habitat, based on the Forest lynx habitat map. 6 Residual ve trees are those expected to live at least 2-3 years beyond a given mortality event, such as bark beetle outbreak or wildfire. 7 11 For the purposes of quantifying snowshoe hare habitat, if the horizontal cover measurement is ≥ 35%, it should be considered “Dense Horizontal Cover” (DHC) unless more site-specific information suggests a different value. If DHC occurs from the surface of the actual or average snow depth and up to approximately two (2) meters above that surface, the site should be considered to have winter snowshoe hare habitat (SRLA Implementation Guide, Page 10). For the purposes of this analysis, DHC refers to horizontal cover ≥ 35% providing winter snowshoe hare habitat. 8 For this oject, incidental damage of winter snowshoe hare habitat is estimated to affect an average of 30% of understory DHC in a given VEG S6 treatment unit while averaging < 20% within the context of the immediate analysis area. 9 11 Ivan, J. rs. comm.

201 CP District-wide Salvage Project Final Environmental Impact Statement

11 Ve Desired Lynx habitat Silvicultural Treatment(s) Options – mechanical 5 get Condition status ati on Zo ne/ Ty pe successional; live overstory provides >25% cover would be protected. but understory provides <20% horizontal cover. Stands are not anticipated to remain suitable post-harvest, counted towards [Lynx habitat prior 2] VEG S1 and S2. Currently 75% or more of the overstory is dead or projected Alternatives 2 and 3 - Salvage h–rvest: Not subject to SRLA LAU VEG unsuitable to be dead in two years due to high levels of beetle S1/VEG S2 caps; minimize or avoid impacts to healthy advance infestation AND understory trees provide less than regeneration to meet silvicultural objectives. 20% horizontal cover above the snow during 10 winter.

[Lynx habitat priority area 1] Hazardous Fuels Treatments – all action alternatives

Engelmann Ladder and surface Silvicultural Rx: Thin conifers from below, up to 8” dbh, to create shaded fuel break conditions; favor aspen where it occurs by spruce – fuels are reduced to cutting understory conifers to maintain a natural fuel break. Use combinations of thinning understory conifers to an average of 25 subalpine fir levels that would to 150 trees per acre, pruning (limbing) residual conifers from 5 ft. or < ½ total tree height, along with hand piling activity slash decrease flame and burning piles, as needed to meet objectives. Evaluate and cut hazard trees with high potential to fall and damage property. Spruce-mixed lengths and reduce Habitat is suitable; WUI11 (Wildland Urban Interface) counted against the Forest-wide Exemptions cap to VEG S1, VEG S2, VEG S5, or VEG S6 conifer the potential for crown seedling/saplings Non-WUI treatments counted against VEGS S5, exception 5. fire initiation within provide winter hare Aspen 400 ft. of private habitat property or a Currently Not subject to SRLA LAU VEG S1/VEG S2 caps, however still subject to WUI and SRLA S5 caps community at risk unsuitable

Ladder and surface Habitat is suitable; Permitted under VEG S5 and S6, exceptions 1. fuels are reduced to seedling/saplings levels that would provide winter hare decrease flame habitat lengths and reduce the potential for crown fire initiation within Currently Permitted under VEG S5, exception 1. 200 ft. of an unsuitable administrative site

10 Definitiof unsuitable habitat (Southern Rockies Lynx Amendment (SRLA) Implementation Guide, Page 16) specifies that a stand with 0-10% overstory canopy cover and an understory where trees generally are not tall enough to protrude above the snow during winter is considered unsuitable. Berg et al. (2012) report snowshoe hare use in stands with 20-34% horizontal cover. However, based on preliminary information concerning red squirrel response to bark beetle mortality (Ivan, pers. comm.), the overstory density threshold for suitability in this analysis is assessed at ≥25% canopy cover. 11 11 If no Community Wildfire Protection Plan is in place, the WUI is defined as the area 0.5 miles from an at risk community (group of homes with basic infrastructure and services that is within or adjacent to federal lands in which conditions are conducive to a large scale fire event (SRLA Implementation Guide: Vegetation Management, pgs. 9-10).

202 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix E – Lynx Priority Habitat Descriptions for Alternative 3 Lynx Definition Rationale Habitat Priority Rating 1 Single story stands (one dead) These stands typically have small populations of snowshoe hare with little or no advanced and are of little value to lynx. Habitat conditions could be regeneration present within improved in these stands through harvest and subsequent conifer the stand and <25% live planting. Snag and course down wood requirements are higher in overstory trees (Currently these areas as these key biological legacies are important habitat unsuitable/SISS) characteristics for a number of species. Live overstory tree percentage here derives from the Salvage Guidelines outlined and from Berg et al. (2012) where few snowshoe hare pellets were found with less than 20% canopy closure, and from Ivan and Seglund (2015) describing significant declines in red squirrel occupancy in heavily impacted stands. The 0-10% canopy closure described in the SLRA Implementation Guide (IG) may underestimate the requirements of lynx and their prey in beetle-impacted stands. 2 Single or two-story stands These stands may fit what we call low-quality suitable habitat. (one dead) with patchy Hare densities in these areas are low, however it may meet the regeneration, but overall minimal habitat definitions described. These areas are second in forested stand does not priority as they would have lower use by lynx and additional contain DHC (may or may not conifer planting would be beneficial. Movement corridors would be be currently suitable). Stands necessary and could overlap with advanced regeneration are considered suitable if protection PDCs. containing >25% live canopy with or without understory, or if they contain 0-25% live canopy and contain live understory trees that provide at least 20% horizontal density in winter snowshoe hare foraging habitat condition. Not likely to meet minimum timber stocking levels. 3 Two-story stands (one dead) These stands consist of suitable lynx habitat and, given the with >20% horizontal density change in conditions, are likely to make up a sizable portion of a in winter snowshoe hare lynx home range. They provide adequate snowshoe hare winter foraging habitat condition, but foraging habitat and likely meet minimum timber stocking levels not S6 (Currently suitable). due to advanced regeneration in the understory. Lynx are Some patches may exceed anticipated to persist in these stands. 35% DHC (good quality foraging habitat). 4 Multistoried stands (2+), 40% These stands represent the best quality habitat given the changed canopy and >35% DHC, conditions. They contain ample advanced regeneration and are currently S6 (High-quality anticipated to persist absent human alterations. Lynx currently stands, Implementation Guide breed in these conditions where they occur on steep northerly Tab 3 page 23). slopes, as shown in CPW and USFS camera stations. It is also anticipated that these areas, in sufficient quantity, make up the core of lynx home ranges.

203 CP District-wide Salvage Project Final Environmental Impact Statement

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Appendix F – Maps

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220 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix G – Hazardous Fuel Specifications and Guidelines Each individual hazardous fuel treatment will require a silvicultural prescription. The following provides general specifications and guidelines tied to desired conditions within areas deemed necessary and appropriate for hazardous fuels mitigation activities in the spruce-fir zone.

Desired Future Condition (DFC): The future stand has a more open structure dominated by aspen with minor amounts of other species. The stand will continue to have dead/dying Engelmann/blue spruce that will provide snags to the stand structure but will no longer be a hazard to the property owners in terms of fire behavior. Slow recruitment of aspen and other species is maintained and encouraged to ensure the stand will be maintained well into the future. Desirable understory vegetation includes various native grasses, forbs, shrubs, and scattered trees.

Stand-level Objectives

• Maintain aspen dominance as a natural fuel break adjacent to private land by cutting all conifers < 9 inches DBH within aspen stands, • Reduce ladder fuels to limit opportunity for initiation of crown fire, • Reduce canopy bulk density to limit potential for active crown fire activity, and • Cut dead Engelmann/blue spruce hazard trees that are within 400 feet of private boundary or 200 feet of administrative sites. Desirable Leave Trees

1. Aspen 2. All Conifers over 9.0 inches DBH 3. Dead Engelmann/blue spruce over 9.0 inches DBH more than 1.5 tree lengths from property boundary. Thinning Objectives

Tree cutting specifications:

1. Thin conifers < 9.0 inches DBH (diameter breast height). 2. Within aspen stands, no conifers < 9.0” DBH should be left. Outside of aspen stands, spacing of residual conifers < 9.0 inches will be established by the prescription in accordance with Appendix D. 3. Stump heights should be less than 12 inches in height on the uphill side and cut at less than a 30% angle from horizontal. 4. Buck tree boles that will not be piled and burned into 4 foot to 6 foot lengths and scatter to minimize the potential for additional insect activity. 5. Cut dead/dying Engelmann/blue spruce ≥ 9.0 inches DBH that pose a hazard to private property, administrative sites, or other infrastructure. Focus on snags less than 1.5 tree lengths from an improvement with high potential to eventually fall onto the improvement. Limb and buck so that boles lay flat on the ground and slash height is less than 18 inches.

221 CP District-wide Salvage Project Final Environmental Impact Statement

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Appendix H – Vegetation and Forest Health Maps

Figure 12. Vegetation Types within the Project Area, North 223

Figure 13. Vegetation Types within the Project Area, South

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Figure 14. Spruce Beetle Infestation Trends, 1996 to 2016

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Figure 15. Western Spruce Budworm Activity, 1996 to 2016

226 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix I - Past Silvicultural Activities

The following tables show past timber management activities that have occurred within the project area and influence the existing condition within the landscape.

Table 71. Past Timber Sales within the Spruce Forests of the Project Area

Year Sale Name Treatment Type Units UOM Area Treated Affected 1946 Legacy Migration Sale Shelterwood Preparatory Cut 39 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 23 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 27 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 21 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 45 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 76 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 106 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 28 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 4 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres Cumbres Pass

1946 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Cumbres Pass

1950 Legacy Migration Sale Shelterwood Preparatory Cut 11 Acres Cumbres Pass

1950 Legacy Migration Sale Shelterwood Preparatory Cut 67 Acres Cumbres Pass

1950 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 165 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 194 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 194 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 59 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 36 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 47 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Preparatory Cut 40 Acres Cumbres Pass

1957 Legacy Migration Sale Shelterwood Establishment Cut (with or without 6 Acres Cornwall leave trees) Mountain 1957 Legacy Migration Sale Shelterwood Establishment Cut (with or without 26 Acres Cumbres Pass leave trees) 1957 Legacy Migration Sale Shelterwood Establishment Cut (with or without 17 Acres Cumbres Pass leave trees)

227 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1957 Legacy Migration Sale Shelterwood Establishment Cut (with or without 90 Acres Cumbres Pass leave trees) 1960 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres Cornwall Mountain 1960 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Cornwall Mountain

1960 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Cornwall Mountain

1960 Legacy Migration Sale Shelterwood Preparatory Cut 41 Acres Cornwall Mountain

1960 Legacy Migration Sale Shelterwood Preparatory Cut 18 Acres Cornwall Mountain

1962 Legacy Migration Sale Stand Clearcut 10 Acres La Manga Pass

1963 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Platoro

1963 Legacy Migration Sale Shelterwood Preparatory Cut 301 Acres Platoro

1963 Legacy Migration Sale Shelterwood Preparatory Cut 101 Acres Platoro

1963 Legacy Migration Sale Seed-tree Final Cut 147 Acres Platoro

1964 Legacy Migration Sale Stand Clearcut 6 Acres Platoro

1964 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 20 Acres Osier Mountain

1964 Legacy Migration Sale Single-tree Selection Cut 7 Acres Osier Mountain

1964 Legacy Migration Sale Single-tree Selection Cut 15 Acres Osier Mountain

1964 Legacy Migration Sale Single-tree Selection Cut 10 Acres Osier Mountain

1965 Legacy Migration Sale Stand Clearcut 117 Acres Platoro

1965 Legacy Migration Sale Stand Clearcut 138 Acres Platoro

1965 Legacy Migration Sale Single-tree Selection Cut 35 Acres Osier Mountain

1965 Legacy Migration Sale Single-tree Selection Cut 13 Acres Osier Mountain

1965 Legacy Migration Sale Stand Clearcut 125 Acres Platoro

1966 Legacy Migration Sale Stand Clearcut 13 Acres Cumbres Pass

1966 Legacy Migration Sale Stand Clearcut 8 Acres Platoro

1966 Legacy Migration Sale Stand Clearcut 20 Acres Platoro

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 76 Acres Osier Mountain

228 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 55 Acres Osier Mountain

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 17 Acres Osier Mountain

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 181 Acres Osier Mountain

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 100 Acres Osier Mountain

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 26 Acres Osier Mountain

1966 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 3 Acres Osier Mountain

1966 Legacy Migration Sale Stand Clearcut 20 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 143 Acres Cumbres Pass

1967 Legacy Migration Sale Stand Clearcut 27 Acres Cumbres Pass

1967 Legacy Migration Sale Stand Clearcut 2 Acres La Manga Pass 1967 Legacy Migration Sale Stand Clearcut 8 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 50 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 4 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 13 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 8 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 10 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 10 Acres Platoro

1967 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 89 Acres Cumbres Pass

1967 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 35 Acres Osier Mountain 1967 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 11 Acres Osier Mountain 1967 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 12 Acres Osier Mountain 1967 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 21 Acres Osier Mountain 1967 Legacy Migration Sale Permanent Land Clearing 5 Acres Chama Basin

1967 Legacy Migration Sale Permanent Land Clearing 7 Acres Chama Basin

1967 Legacy Migration Sale Permanent Land Clearing 3 Acres Chama Basin

1967 Legacy Migration Sale Stand Clearcut 6 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 5 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 38 Acres Platoro

229 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1967 Legacy Migration Sale Stand Clearcut 50 Acres Platoro

1967 Legacy Migration Sale Stand Clearcut 23 Acres Platoro

1968 Legacy Migration Sale Stand Clearcut 18 Acres La Manga Pass 1968 Legacy Migration Sale Stand Clearcut 38 Acres Platoro

1968 Legacy Migration Sale Stand Clearcut 12 Acres La Manga Pass 1968 Legacy Migration Sale Stand Clearcut 9 Acres Platoro

1968 Legacy Migration Sale Stand Clearcut 16 Acres Platoro

1968 Legacy Migration Sale Stand Clearcut 13 Acres Platoro

1968 Legacy Migration Sale Stand Clearcut 40 Acres Platoro

1968 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Cumbres Pass

1968 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 20 Acres Cumbres Pass

1968 Legacy Migration Sale Stand Clearcut 18 Acres La Manga Pass 1968 Legacy Migration Sale Stand Clearcut 12 Acres La Manga Pass 1969 Legacy Migration Sale Stand Clearcut 18 Acres Platoro

1969 Legacy Migration Sale Stand Clearcut 15 Acres Platoro

1969 Legacy Migration Sale Stand Clearcut 23 Acres Platoro

1969 Legacy Migration Sale Stand Clearcut 10 Acres Platoro

1973 Legacy Migration Sale Single-tree Selection Cut 6 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 40 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 13 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 20 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 26 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 50 Acres Osier Mountain 1973 Legacy Migration Sale Single-tree Selection Cut 34 Acres Elk Creek

1975 Legacy Migration Sale Single-tree Selection Cut 70 Acres Elk Creek

1975 Legacy Migration Sale Single-tree Selection Cut 104 Acres Elk Creek

1975 Legacy Migration Sale Single-tree Selection Cut 15 Acres Elk Creek

1975 Legacy Migration Sale Sanitation Cut 7 Acres Platoro

1975 Legacy Migration Sale Sanitation Cut 14 Acres Platoro

230 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1976 Legacy Migration Sale Patch Clearcut 5 Acres Chama Basin

1976 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Cumbres Pass

1976 Legacy Migration Sale Shelterwood Preparatory Cut 35 Acres Cumbres Pass

1976 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Cumbres Pass

1976 Legacy Migration Sale Shelterwood Preparatory Cut 110 Acres Platoro

1976 Legacy Migration Sale Single-tree Selection Cut 30 Acres Elk Creek

1976 Legacy Migration Sale Single-tree Selection Cut 120 Acres Elk Creek

1976 Legacy Migration Sale Sanitation Cut 42 Acres Chama Basin

1976 Legacy Migration Sale Sanitation Cut 38 Acres Chama Basin

1976 Legacy Migration Sale Sanitation Cut 28 Acres Chama Basin

1976 Legacy Migration Sale Shelterwood Preparatory Cut 85 Acres Jasper

1976 Legacy Migration Sale Shelterwood Preparatory Cut 152 Acres Jasper

1977 Legacy Migration Sale Shelterwood Preparatory Cut 291 Acres Cumbres Pass

1977 Legacy Migration Sale Sanitation Cut 31 Acres Chama Basin

1977 Legacy Migration Sale Sanitation Cut 6 Acres Chama Basin

1977 Legacy Migration Sale Sanitation Cut 3 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 10 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 3 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 6 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 4 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 7 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 6 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 1 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 3 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 2 Acres Platoro

1977 Legacy Migration Sale Sanitation Cut 4 Acres Platoro

1978 Legacy Migration Sale Commercial Thin 13 Acres Cumbres Pass

1978 Legacy Migration Sale Commercial Thin 7 Acres Cumbres Pass

1978 Legacy Migration Sale Commercial Thin 16 Acres Cumbres Pass

231 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1979 Legacy Migration Sale Shelterwood Preparatory Cut 69 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 69 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 22 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 85 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 21 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Cumbres Pass

1979 Legacy Migration Sale Shelterwood Preparatory Cut 44 Acres Cumbres Pass

1979 Legacy Migration Sale Commercial Thin 30 Acres Cumbres Pass

1979 Legacy Migration Sale Commercial Thin 70 Acres Cumbres Pass

1979 Legacy Migration Sale Sanitation Cut 255 Acres Cumbres Pass

1979 Legacy Migration Sale Permanent Land Clearing 7 Acres Chama Basin

1979 Legacy Migration Sale Permanent Land Clearing 1 Acres Chama Basin

1979 Legacy Migration Sale Permanent Land Clearing 6 Acres Chama Basin

1979 Legacy Migration Sale Permanent Land Clearing 1 Acres Chama Basin

1981 Legacy Migration Sale Shelterwood Preparatory Cut 23 Acres Cumbres Pass

1981 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Cumbres Pass

1981 Legacy Migration Sale Shelterwood Preparatory Cut 180 Acres Cumbres Pass

1981 Legacy Migration Sale Sanitation Cut 100 Acres Cumbres Pass

1982 Legacy Migration Sale Shelterwood Preparatory Cut 3 Acres Cumbres Pass

1982 Legacy Migration Sale Shelterwood Preparatory Cut 57 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 17 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 26 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 36 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 17 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 103 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 33 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 27 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 6 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 9 Acres Cornwall Mountain

232 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1982 Legacy Migration Sale Shelterwood Preparatory Cut 103 Acres Cornwall Mountain 1982 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Cornwall Mountain 1983 Legacy Migration Sale Shelterwood Preparatory Cut 45 Acres Cumbres Pass

1983 Legacy Migration Sale Single-tree Selection Cut 60 Acres Fox Creek

1984 Legacy Migration Sale Single-tree Selection Cut 10 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 19 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 24 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 15 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 124 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 38 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 30 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 45 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 25 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 48 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 136 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 120 Acres La Manga Pass 1984 Legacy Migration Sale Single-tree Selection Cut 26 Acres La Manga Pass 1985 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Chama Basin

1985 Legacy Migration Sale Shelterwood Preparatory Cut 89 Acres Chama Basin

1985 Legacy Migration Sale Shelterwood Preparatory Cut 96 Acres Chama Basin

1985 Legacy Migration Sale Sanitation Cut 85 Acres Jasper

1985 Legacy Migration Sale Sanitation Cut 152 Acres Jasper

1986 Legacy Migration Sale Single-tree Selection Cut 46 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 105 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 37 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 70 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 42 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 66 Acres Osier Mountain 1986 Legacy Migration Sale Single-tree Selection Cut 132 Acres Osier Mountain

233 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1986 Legacy Migration Sale Stand Clearcut 10 Acres Platoro

1987 Legacy Migration Sale Patch Clearcut 5 Acres Osier Mountain 1987 Legacy Migration Sale Patch Clearcut 10 Acres Osier Mountain 1987 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Platoro

1987 Legacy Migration Sale Shelterwood Preparatory Cut 12 Acres Platoro

1987 Legacy Migration Sale Shelterwood Preparatory Cut 36 Acres Platoro

1987 Legacy Migration Sale Single-tree Selection Cut 76 Acres Osier Mountain 1987 Legacy Migration Sale Single-tree Selection Cut 34 Acres Osier Mountain 1987 Legacy Migration Sale Single-tree Selection Cut 59 Acres Osier Mountain 1987 Legacy Migration Sale Single-tree Selection Cut 17 Acres Osier Mountain 1987 Legacy Migration Sale Shelterwood Preparatory Cut 23 Acres Summitville

1987 Legacy Migration Sale Shelterwood Preparatory Cut 27 Acres Summitville

1987 Legacy Migration Sale Shelterwood Preparatory Cut 3 Acres Summitville

1987 Legacy Migration Sale Shelterwood Preparatory Cut 71 Acres Summitville

1987 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Summitville

1987 Legacy Migration Sale Seed-tree 38 Acres Summitville

1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 76 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 95 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 99 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 8 Acres Summitville leave trees) 1987 Legacy Migration Sale Improvement Cut 84 Acres Summitville

1987 Legacy Migration Sale Seed-tree Final Cut 45 Acres Cumbres Pass

1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 83 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 82 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 100 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 14 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 125 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 102 Acres Summitville leave trees) 1987 Legacy Migration Sale Shelterwood Establishment Cut (with or without 85 Acres Summitville leave trees)

234 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1988 Legacy Migration Sale Seed-tree Preparatory Cut 57 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 27 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 6 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 17 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 17 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 9 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 21 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 7 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 36 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 33 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 103 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 26 Acres Cornwall Mountain 1988 Legacy Migration Sale Seed-tree Preparatory Cut 103 Acres Cornwall Mountain 1988 Legacy Migration Sale Patch Clearcut 20 Acres Fox Creek

1989 Legacy Migration Sale Shelterwood Preparatory Cut 110 Acres Platoro

1989 Legacy Migration Sale Shelterwood Preparatory Cut 17 Acres La Manga Pass 1989 Legacy Migration Sale Shelterwood Preparatory Cut 48 Acres La Manga Pass 1989 Legacy Migration Sale Shelterwood Preparatory Cut 43 Acres La Manga Pass 1989 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Cornwall Mountain 1989 Legacy Migration Sale Shelterwood Preparatory Cut 21 Acres Cornwall Mountain 1989 Legacy Migration Sale Shelterwood Preparatory Cut 85 Acres La Manga Pass 1989 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres La Manga Pass 1989 Legacy Migration Sale Shelterwood Establishment Cut (with or without 60 Acres Cumbres Pass leave trees) 1990 Legacy Migration Sale Shelterwood Preparatory Cut 3 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 57 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 20 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 33 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 14 Acres Platoro

235 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1990 Legacy Migration Sale Shelterwood Preparatory Cut 11 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 3 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 6 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 9 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 6 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 3 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 4 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Platoro

1990 Legacy Migration Sale Shelterwood Preparatory Cut 6 Acres Platoro

1991 Legacy Migration Sale Patch Clearcut 5 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Establishment Cut (with or without 66 Acres Cumbres Pass leave trees) 1991 Legacy Migration Sale Shelterwood Establishment Cut (with or without 88 Acres Cumbres Pass leave trees) 1991 Legacy Migration Sale Patch Clearcut 6 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Preparatory Cut 71 Acres Cumbres Pass

1991 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Preparatory Cut 45 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Preparatory Cut 52 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres La Manga Pass 1991 Legacy Migration Sale Shelterwood Preparatory Cut 40 Acres La Manga Pass 1991 Legacy Migration Sale Sanitation Cut 122 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Establishment Cut (with or without 63 Acres Cumbres Pass leave trees) 1992 Legacy Migration Sale Patch Clearcut 2 Acres La Manga Pass 1992 Legacy Migration Sale Patch Clearcut 9 Acres La Manga Pass 1992 Legacy Migration Sale Patch Clearcut 4 Acres La Manga Pass 1992 Legacy Migration Sale Patch Clearcut 7 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 4 Acres Fox Creek

1992 Legacy Migration Sale Overstory Removal Cut (from advanced regeneration) 24 Acres Fox Creek

1992 Legacy Migration Sale Patch Clearcut 4 Acres La Manga Pass

236 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1992 Legacy Migration Sale Patch Clearcut 6 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 86 Acres Cumbres Pass

1992 Legacy Migration Sale Shelterwood Preparatory Cut 12 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 38 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 9 Acres La Manga Pass 1992 Legacy Migration Sale Shelterwood Preparatory Cut 16 Acres La Manga Pass

1992 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres La Manga Pass

1992 Legacy Migration Sale Shelterwood Preparatory Cut 69 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 38 Acres Cumbres Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Cumbres Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 43 Acres Cumbres Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 45 Acres Cumbres Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 34 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 60 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 19 Acres Jasper

1993 Legacy Migration Sale Shelterwood Preparatory Cut 14 Acres Jasper

1993 Legacy Migration Sale Shelterwood Establishment Cut (with or without 38 Acres Jasper leave trees)

1993 Legacy Migration Sale Shelterwood Establishment Cut (with or without 47 Acres Jasper leave trees)

1993 Legacy Migration Sale Shelterwood Preparatory Cut 66 Acres La Manga Pass

1993 Legacy Migration Sale Patch Clearcut 2 Acres La Manga Pass

1993 Legacy Migration Sale Patch Clearcut 9 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 53 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 30 Acres La Manga Pass

237 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1993 Legacy Migration Sale Shelterwood Preparatory Cut 30 Acres La Manga Pass

1993 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres La Manga Pass

1994 Legacy Migration Sale Shelterwood Preparatory Cut 15 Acres Jasper

1994 Legacy Migration Sale Shelterwood Establishment Cut (with or without 55 Acres Jasper leave trees)

1994 Legacy Migration Sale Shelterwood Establishment Cut (with or without 59 Acres Jasper leave trees)

1994 Legacy Migration Sale Shelterwood Preparatory Cut 58 Acres Cumbres Pass

1994 Legacy Migration Sale Patch Clearcut 20 Acres Osier Mountain

1994 Legacy Migration Sale Patch Clearcut 5 Acres La Manga Pass

1994 Legacy Migration Sale Patch Clearcut 9 Acres La Manga Pass

1994 Legacy Migration Sale Patch Clearcut 14 Acres La Manga Pass

1994 Legacy Migration Sale Shelterwood Preparatory Cut 50 Acres Cumbres Pass

1994 Legacy Migration Sale Shelterwood Preparatory Cut 121 Acres La Manga Pass 1994 Legacy Migration Sale Shelterwood Preparatory Cut 39 Acres La Manga Pass 1994 Legacy Migration Sale Shelterwood Preparatory Cut 59 Acres La Manga Pass 1994 Legacy Migration Sale Shelterwood Preparatory Cut 24 Acres Red Mountain

1994 Legacy Migration Sale Shelterwood Preparatory Cut 144 Acres Platoro

1994 Legacy Migration Sale Shelterwood Preparatory Cut 56 Acres Red Mountain

1994 Legacy Migration Sale Shelterwood Preparatory Cut 119 Acres Platoro

1994 Legacy Migration Sale Shelterwood Preparatory Cut 11 Acres Platoro

1994 Legacy Migration Sale Shelterwood Preparatory Cut 19 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 82 Acres Cumbres Pass

1995 Legacy Migration Sale Shelterwood Preparatory Cut 24 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 41 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 21 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 12 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 13 Acres Red Mountain

238 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1995 Legacy Migration Sale Shelterwood Preparatory Cut 7 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 8 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 24 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 58 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 38 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 34 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 60 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 82 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 8 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 18 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 30 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 29 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 16 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 73 Acres Red Mountain

1995 Legacy Migration Sale Shelterwood Preparatory Cut 39 Acres Red Mountain

1995 Legacy Migration Sale Patch Clearcut 4 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 42 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 48 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 63 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 49 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 80 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 33 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 10 Acres La Manga Pass 1995 Legacy Migration Sale Shelterwood Preparatory Cut 9 Acres La Manga Pass 1996 Legacy Migration Sale Patch Clearcut 7 Acres La Manga Pass 1996 Legacy Migration Sale Patch Clearcut 3 Acres La Manga Pass

239 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 1996 Legacy Migration Sale Patch Clearcut 4 Acres La Manga Pass 1996 Legacy Migration Sale Shelterwood Preparatory Cut 34 Acres La Manga Pass 1996 Legacy Migration Sale Shelterwood Preparatory Cut 6 Acres Red Mountain

1996 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Red Mountain

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 3 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 7 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 57 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 20 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 33 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 14 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 11 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 3 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 6 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 9 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 6 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 3 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 4 Acres Platoro

2000 Legacy Migration Sale Shelterwood Preparatory Cut 5 Acres Red Mountain

2000 Legacy Migration Sale Shelterwood Preparatory Cut 52 Acres Red Mountain

2000 Legacy Migration Sale Shelterwood Preparatory Cut 16 Acres Red Mountain

2000 Legacy Migration Sale Shelterwood Preparatory Cut 18 Acres Red Mountain

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 10 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 7 Acres Platoro

2000 Legacy Migration Sale Seed-tree Seed Cut (with and without leave trees) 6 Acres Platoro

2005 Neff Mountain Beetle Salvage Sanitation Cut 88 Acres Cumbres Pass

2005 Neff Mountain Beetle Sanitation Cut 16 Acres Cumbres Pass Mountain Salvage 2005 Grouse Creek Salvage Timber Sale Sanitation Cut 166 Acres La Manga Pass 2005 Grouse Creek Salvage Timber Sanitation Cut 157 Acres La Manga Pass 2005 Grouse Creek Salvage Timber Sanitation Cut 86 Acres La Manga Pass

240 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 2005 Grouse Creek Salvage Timber Sanitation Cut 84 Acres La Manga Pass 2005 Grouse Creek Salvage Timber Sanitation Cut 167 Acres La Manga Pass 2005 Grouse Creek Salvage Timber Sanitation Cut 150 Acres La Manga Pass 2005 Spruce Hole Beetle Salvage Sanitation Cut 77 Acres La Manga Pass 2006 Wolf Beetle Salvage Sanitation Cut 97 Acres Cumbres Pass

2006 Wolf Beetle Salvage Sanitation Cut 75 Acres Cumbres Pass

2006 Wolf Beetle Salvage Sanitation Cut 95 Acres Cumbres Pass

2006 Wolf Beetle Salvage Sanitation Cut 20 Acres Cumbres Pass

2006 Wolf Beetle Salvage Sanitation Cut 1 Acres Cumbres Pass

2006 La Manga Beetle Salvage Sanitation Cut 140 Acres La Manga Timbet Sale Pass 2006 Grouse II Salvage Sanitation Cut 119 Acres La Manga Pass 2006 Grouse II Salvage Sanitation Cut 27 Acres La Manga Pass 2006 Grouse II Salvage Sanitation Cut 88 Acres La Manga Pass 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 20 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 22 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 2 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 17 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 10 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 23 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 4 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 1 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 4 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 3 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 3 Acres Cornwall Mountain 2008 Cerro Rojo Salvage Timber Sale Sanitation Cut 22 Acres Cornwall Mountain 2008 Neff II Salvage Sanitation Cut 75 Acres Cumbres Pass

2008 Neff II Salvage Sanitation Cut 23 Acres Cumbres Pass

2009 Grouse III Salvage Salvage Cut 51 Acres La Manga Pass 2009 Grouse III Salvage Salvage Cut 61 Acres La Manga Pass

241 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 2009 Grouse III Salvage Salvage Cut 12 Acres La Manga Pass 2009 Cerro Rojo Salvage Timber Sale Sanitation Cut 67 Acres Red Mountain

2009 Cerro Rojo Salvage Timber Sale Sanitation Cut 6 Acres Red Mountain

2009 Cerro Rojo Salvage Timber Sale Sanitation Cut 12 Acres Red Mountain

2009 Cerro Rojo Salvage Timber Sale Sanitation Cut 10 Acres Red Mountain

2009 Cerro Rojo Salvage Timber Sale Sanitation Cut 45 Acres Red Mountain

2011 El Gato Salvage Salvage Cut 80 Acres Cumbres Pass

2011 El Gato Salvage Salvage Cut 123 Acres Cumbres Pass

2011 El Gato Salvage Salvage Cut 56 Acres Cumbres Pass

2011 El Gato Salvage Salvage Cut 110 Acres Cumbres Pass

2011 El Gato Salvage Salvage Cut 58 Acres Cumbres Pass

2011 TM Campground Salvage Salvage Cut; assigned as Stand Clearcut (w/ leave trees) 4 Acres Cumbres Pass

2011 TM Campground Salvage Salvage Cut; assigned as Stand Clearcut (w/ leave trees) 23 Acres Cumbres Pass

2011 TM Campground Salvage Salvage Cut; assigned as Stand Clearcut (w/ leave trees) 17 Acres Cumbres Pass

2012 Snowshoe Salvage Salvage Cut 45 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 30 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 43 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 14 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 43 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 36 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 8 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 2 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 0 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 2 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 8 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 35 Acres Cumbres Pass

2012 Spruce Park Salvage Salvage Cut 1 Acres Cumbres Pass

2013 Boomerang Salvage Salvage Cut; assigned as Stand Clearcut (w/ leave trees) 143 Acres Cumbres Pass

2014 Chihuahua Salvage Salvage Cut 13 Acres Cumbres Pass

242 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 2014 Jasper Creek Salvage Salvage Cut; assigned as Overstory Removal Cut 2 Acres Jasper (from advanced regeneration) 2014 Jasaper Creek Salvage Salvage Cut; assigned as Overstory Removal Cut 16 Acres Jasper (from advanced regeneration) 2014 Jasper Creek Salvage Salvage Cut; assigned as Two-aged 101 Acres Jasper Shelterwood Establishment and Removal Cut (w/ res) 2014 Jasper Creek Salvage Salvage Cut; assigned as Two-aged 57 Acres Jasper Shelterwood Establishment and Removal Cut (w/ res) 2014 Jasper Creek Salvage Salvage Cut; assigned as Two-aged 28 Acres Jasper Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 16 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 30 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 56 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 19 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 7 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 18 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 12 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Reservoir Salvage Salvage Cut; assigned as Two-aged 40 Acres Cumbres Pass Shelterwood Establishment and Removal Cut (w/ res) 2015 Lobo Salvage Salvage Cut; assigned as Overstory Removal Cut 92 Acres Cumbres Pass (from advanced regeneration) 2015 Cobra Salvage Salvage Cut; assigned as Overstory Removal Cut 43 Acres Cumbres Pass (from advanced regeneration) 2015 Cobra Salvage Salvage Cut; assigned as Overstory Removal Cut 21 Acres Cumbres Pass (from advanced regeneration) 2015 Rendezvous US Beetle Salvage Cut; assigned as Overstory Removal Cut 14 Acres Cumbres Pass Salvage (from advanced regeneration) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 117 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 26 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 9 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 23 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 52 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2015 Rendezvous US Beetle Salvage Cut; assigned as Two-aged 9 Acres Cumbres Pass Salvage Shelterwood Establishment and Removal Cut (w/ res) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 33 Acres Cumbres Pass (from advanced regeneration)

243 CP District-wide Salvage Project Final Environmental Impact Statement

Year Sale Name Treatment Type Units UOM Area Treated Affected 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 104 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 21 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 76 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 20 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 27 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 3 Acres Cumbres Pass (from advanced regeneration) 2016 Monarch Beetle Salvage Salvage Cut; assigned as Two-aged 84 Acres La Manga Shelterwood Establishment and Removal Cut Pass (w/ res) 2016 No Name Beetle Salvage Salvage Cut; assigned as Two-aged 98 Acres La Manga Shelterwood Establishment and Removal Cut Pass (w/ res) 2017 Yurt Beetle Salvage Salvage Cut; assigned as Two-aged 13 Acres La Manga Shelterwood Establishment and Removal Cut Pass (w/ res) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 25 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 59 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 54 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 38 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 20 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 26 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 42 Acres Cumbres Pass (from advanced regeneration) 2017 Hog Nosse Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 38 Acres Cumbres Pass (from advanced regeneration) 2017 Cow Camp Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 95 Acres La Manga (from advanced regeneration) Pass 2017 Cow Camp Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 29 Acres La Manga (from advanced regeneration) Pass 2017 Cow Camp Beetle Salvage Salvage Cut; assigned as Overstory Removal Cut 9 Acres La Manga (from advanced regeneration) Pass

Table 72. Other Silvicultural Treatments within the Spruce Forests of the Project Area

Year Treatment Type Units Treated UOM Area Affected 1927 Plant Trees 6 Acres Cumbres Pass 1928 Plant Trees 5 Acres Cumbres Pass 1929 Plant Trees 6 Acres Cumbres Pass 1930 Plant Trees 4 Acres Cumbres Pass 1931 Plant Trees 3 Acres Cumbres Pass 1931 Plant Trees 1 Acres Cumbres Pass 1933 Plant Trees 1 Acres Cumbres Pass 1936 Plant Trees 9 Acres Cumbres Pass 1940 Plant Trees 29 Acres Cumbres Pass

244 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1941 Plant Trees 7 Acres Cumbres Pass 1941 Plant Trees 14 Acres Cumbres Pass 1958 Seed (Trees) 3 Acres Platoro Area 1962 Plant Trees 11 Acres Osier Mountain 1962 Plant Trees 3 Acres Osier Mountain 1962 Plant Trees 38 Acres Osier Mountain 1962 Plant Trees 41 Acres Osier Mountain 1963 Plant Trees 40 Acres Osier Mountain 1963 Plant Trees 79 Acres Osier Mountain 1963 Plant Trees 40 Acres Osier Mountain 1963 Plant Trees 20 Acres Osier Mountain 1963 Fill-in or Replant Trees 41 Acres Osier Mountain 1964 Plant Trees 5 Acres Osier Mountain 1964 Plant Trees 25 Acres Osier Mountain 1964 Plant Trees 28 Acres Osier Mountain 1964 Plant Trees 3 Acres Osier Mountain 1964 Plant Trees 3 Acres Osier Mountain 1964 Plant Trees 15 Acres Osier Mountain 1964 Plant Trees 50 Acres Osier Mountain 1964 Plant Trees 30 Acres Osier Mountain 1964 Plant Trees 20 Acres Osier Mountain 1964 Plant Trees 7 Acres Osier Mountain 1965 Plant Trees 200 Acres Osier Mountain 1965 Plant Trees 5 Acres Osier Mountain 1965 Plant Trees 5 Acres Osier Mountain 1965 Plant Trees 70 Acres Osier Mountain 1965 Plant Trees 20 Acres Osier Mountain 1965 Plant Trees 30 Acres Osier Mountain 1965 Plant Trees 5 Acres Osier Mountain 1965 Plant Trees 5 Acres Osier Mountain 1965 Plant Trees 25 Acres Osier Mountain 1965 Plant Trees 20 Acres Osier Mountain 1965 Fill-in or Replant Trees 50 Acres Osier Mountain 1965 Precommercial Thin 10 Acres Osier Mountain 1966 Plant Trees 100 Acres Osier Mountain 1966 Tree Release and Weed 20 Acres Osier Mountain 1967 Plant Trees 5 Acres Osier Mountain 1967 Plant Trees 5 Acres Osier Mountain 1967 Plant Trees 5 Acres Osier Mountain 1967 Plant Trees 25 Acres Osier Mountain 1967 Plant Trees 15 Acres Osier Mountain 1967 Plant Trees 15 Acres Osier Mountain 1967 Plant Trees 5 Acres Osier Mountain 1967 Plant Trees 10 Acres Osier Mountain

245 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1967 Plant Trees 15 Acres Osier Mountain 1967 Plant Trees 50 Acres Platoro Area 1967 Plant Trees 50 Acres Platoro Area 1967 Fill-in or Replant Trees 60 Acres Osier Mountain 1967 Precommercial Thin 10 Acres Osier Mountain 1969 Plant Trees 14 Acres Cumbres Pass 1969 Plant Trees 12 Acres Osier Mountain 1969 Fill-in or Replant Trees 50 Acres Platoro Area 1969 Fill-in or Replant Trees 35 Acres Platoro Area 1969 Fill-in or Replant Trees 50 Acres Platoro Area 1969 Fill-in or Replant Trees 90 Acres Platoro Area 1969 Fill-in or Replant Trees 12 Acres Platoro Area 1969 Precommercial Thin 15 Acres Fox Creek 1970 Plant Trees 110 Acres Cumbres Pass 1970 Plant Trees 50 Acres Cumbres Pass 1970 Plant Trees 90 Acres Osier Mountain 1970 Plant Trees 40 Acres Osier Mountain 1970 Plant Trees 10 Acres Osier Mountain 1970 Precommercial Thin 10 Acres Osier Mountain 1970 Precommercial Thin 30 Acres Fox Creek 1971 Plant Trees 160 Acres Osier Mountain 1971 Plant Trees 20 Acres Osier Mountain 1971 Plant Trees 20 Acres La Manga Pass 1971 Precommercial Thin 5 Acres Osier Mountain 1971 Precommercial Thin 31 Acres Osier Mountain 1971 Precommercial Thin 40 Acres Osier Mountain 1972 Plant Trees 200 Acres Osier Mountain 1972 Precommercial Thin 25 Acres Osier Mountain 1972 Precommercial Thin 7 Acres Osier Mountain 1972 Precommercial Thin 50 Acres Osier Mountain 1972 Precommercial Thin 12 Acres Platoro Area 1973 Plant Trees 30 Acres Osier Mountain 1973 Plant Trees 70 Acres Osier Mountain 1973 Plant Trees 100 Acres Osier Mountain 1973 Precommercial Thin 20 Acres Osier Mountain 1973 Precommercial Thin 44 Acres Osier Mountain 1973 Precommercial Thin 70 Acres Osier Mountain 1973 Precommercial Thin 64 Acres Elk Creek 1973 Precommercial Thin 13 Acres Platoro Area 1973 Precommercial Thin 15 Acres Platoro Area 1974 Plant Trees 200 Acres Osier Mountain 1974 Precommercial Thin 50 Acres Osier Mountain 1974 Precommercial Thin 20 Acres Fox Creek 1974 Precommercial Thin 138 Acres Elk Creek

246 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1974 Precommercial Thin 35 Acres Elk Creek 1974 Precommercial Thin 20 Acres Platoro Area 1975 Tree Release and Weed 20 Acres Red Mountain 1975 Tree Release and Weed 28 Acres Red Mountain 1975 Tree Release and Weed 5 Acres Red Mountain 1975 Tree Release and Weed 6 Acres Red Mountain 1975 Tree Release and Weed 6 Acres Red Mountain 1975 Tree Release and Weed 2 Acres Red Mountain 1975 Tree Release and Weed 20 Acres Red Mountain 1975 Precommercial Thin 33 Acres Fox Creek 1975 Precommercial Thin 50 Acres Fox Creek 1975 Precommercial Thin 9 Acres Osier Mountain 1975 Precommercial Thin 13 Acres Osier Mountain 1975 Precommercial Thin 57 Acres Osier Mountain 1975 Precommercial Thin 20 Acres Osier Mountain 1975 Precommercial Thin 20 Acres Osier Mountain 1975 Precommercial Thin 20 Acres Osier Mountain 1975 Precommercial Thin 10 Acres Osier Mountain 1975 Precommercial Thin 10 Acres Osier Mountain 1975 Precommercial Thin 12 Acres Osier Mountain 1975 Precommercial Thin 73 Acres Red Mountain 1975 Precommercial Thin 5 Acres Red Mountain 1975 Precommercial Thin 10 Acres Red Mountain 1975 Precommercial Thin 39 Acres Red Mountain 1975 Precommercial Thin 9 Acres Red Mountain 1975 Precommercial Thin 3 Acres Red Mountain 1976 Plant Trees 6 Acres Platoro Area 1976 Plant Trees 50 Acres Platoro Area 1976 Plant Trees 5 Acres Platoro Area 1976 Precommercial Thin 22 Acres Elk Creek 1976 Precommercial Thin 128 Acres Elk Creek 1977 Plant Trees 120 Acres Osier Mountain 1979 Plant Trees 72 Acres Osier Mountain 1979 Plant Trees 100 Acres Osier Mountain 1979 Plant Trees 20 Acres Platoro Area 1979 Plant Trees 10 Acres Platoro Area 1979 Plant Trees 90 Acres Platoro Area 1979 Plant Trees 49 Acres Platoro Area 1979 Plant Trees 85 Acres Platoro Area 1980 Plant Trees 11 Acres Cumbres Pass 1980 Plant Trees 400 Acres Osier Mountain 1980 Plant Trees 36 Acres Platoro Area 1982 Plant Trees 200 Acres Osier Mountain 1982 Plant Trees 25 Acres Osier Mountain

247 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1982 Plant Trees 30 Acres Osier Mountain 1982 Plant Trees 15 Acres Platoro Area 1982 Plant Trees 10 Acres Platoro Area 1982 Plant Trees 7 Acres Platoro Area 1982 Plant Trees 5 Acres Platoro Area 1982 Fill-in or Replant Trees 400 Acres Osier Mountain 1982 Plant Trees 10 Acres Platoro Area 1982 Plant Trees 3 Acres Platoro Area 1982 Plant Trees 48 Acres Platoro Area 1982 Plant Trees 6 Acres Platoro Area 1982 Plant Trees 5 Acres Platoro Area 1982 Plant Trees 15 Acres Elwood Pass 1982 Plant Trees 8 Acres Elwood Pass 1982 Plant Trees 50 Acres Elwood Pass 1982 Plant Trees 73 Acres Elwood Pass 1982 Plant Trees 8 Acres Elwood Pass 1982 Plant Trees 6 Acres Elwood Pass 1982 Plant Trees 20 Acres Elwood Pass 1982 Plant Trees 14 Acres Platoro Area 1982 Fill-in or Replant Trees 3 Acres Platoro Area 1982 Fill-in or Replant Trees 42 Acres Platoro Area 1982 Fill-in or Replant Trees 6 Acres Platoro Area 1982 Fill-in or Replant Trees 5 Acres Platoro Area 1982 Fill-in or Replant Trees 353 Acres Platoro Area 1982 Fill-in or Replant Trees 9 Acres Platoro Area 1983 Tree Release and Weed 50 Acres Summitville 1984 Tree Release and Weed 50 Acres Cornwall Mountain 1985 Plant Trees 70 Acres Osier Mountain 1985 Fill-in or Replant Trees 40 Acres Osier Mountain 1985 Fill-in or Replant Trees 50 Acres Osier Mountain 1985 Tree Release and Weed 10 Acres Cornwall Mountain 1985 Tree Release and Weed 7 Acres Cornwall Mountain 1985 Site Preparation for Natural Regeneration - Other 15 Acres Osier Mountain 1985 Site Preparation for Natural Regeneration - Other 33 Acres Osier Mountain 1985 Precommercial Thin 3 Acres Red Mountain 1986 Yarding - Removal of Fuels by Carrying or Dragging 102 Acres Cumbres Pass 1986 Yarding - Removal of Fuels by Carrying or Dragging 50 Acres Cumbres Pass 1986 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres Cumbres Pass 1986 Yarding - Removal of Fuels by Carrying or Dragging 10 Acres La Manga Pass 1986 Yarding - Removal of Fuels by Carrying or Dragging 2 Acres La Manga Pass 1986 Precommercial Thin 21 Acres La Manga Pass 1986 Precommercial Thin 25 Acres La Manga Pass 1986 Precommercial Thin 22 Acres Cornwall Mountain 1987 Precommercial Thin 25 Acres La Manga Pass

248 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1987 Tree Release and Weed 37 Acres Summitville 1987 Tree Release and Weed 45 Acres Summitville 1987 Precommercial Thin 6 Acres La Manga Pass 1987 Site Preparation for Natural Regeneration - Other 12 Acres Summitville 1987 Site Preparation for Natural Regeneration - Other 24 Acres Summitville 1987 Site Preparation for Natural Regeneration - Other 30 Acres Summitville 1987 Site Preparation for Natural Regeneration - Other 31 Acres Summitville 1987 Tree Release and Weed 18 Acres Summitville 1987 Tree Release and Weed 47 Acres Summitville 1987 Tree Release and Weed 16 Acres Summitville 1987 Precommercial Thin 4 Acres La Manga Pass 1988 Tree Release and Weed 20 Acres Fox Creek 1988 Precommercial Thin 1 Acres Cumbres Pass 1988 Precommercial Thin 7 Acres Cumbres Pass 1988 Tree Release and Weed 90 Acres Cumbres Pass 1988 Precommercial Thin 23 Acres Cumbres Pass 1988 Precommercial Thin 4 Acres Cumbres Pass 1988 Precommercial Thin 36 Acres Cumbres Pass 1988 Tree Release and Weed 18 Acres Cornwall Mountain 1989 Tree Release and Weed 15 Acres Fox Creek 1989 Tree Release and Weed 2 Acres Fox Creek 1989 Tree Release and Weed 10 Acres Fox Creek 1989 Tree Release and Weed 32 Acres Fox Creek 1989 Tree Release and Weed 15 Acres Fox Creek 1989 Tree Release and Weed 21 Acres Fox Creek 1989 Precommercial Thin 7 Acres Cornwall Mountain 1990 Burning of Piled Material 5 Acres Cumbres Pass 1990 Burning of Piled Material 3 Acres Cumbres Pass 1990 Burning of Piled Material 3 Acres La Manga Pass 1991 Yarding - Removal of Fuels by Carrying or Dragging 46 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 92 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 155 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 49 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 22 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 3 Acres La Manga Pass 1991 Yarding - Removal of Fuels by Carrying or Dragging 1 Acres La Manga Pass 1991 Yarding - Removal of Fuels by Carrying or Dragging 31 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 8 Acres Cornwall Mountain 1991 Yarding - Removal of Fuels by Carrying or Dragging 72 Acres Cornwall Mountain 1991 Burning of Piled Material 5 Acres La Manga Pass 1992 Burning of Piled Material 25 Acres Cumbres Pass 1992 Burning of Piled Material 20 Acres La Manga Pass 1992 Burning of Piled Material 20 Acres La Manga Pass 1992 Burning of Piled Material 10 Acres Cornwall Mountain

249 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 1992 Burning of Piled Material 20 Acres Cornwall Mountain 1992 Yarding - Removal of Fuels by Carrying or Dragging 15 Acres Cumbres Pass 1992 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres Cumbres Pass 1992 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres Cornwall Mountain 1992 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres Cornwall Mountain 1992 Yarding - Removal of Fuels by Carrying or Dragging 10 Acres Cornwall Mountain 1993 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres Cumbres Pass 1993 Yarding - Removal of Fuels by Carrying or Dragging 6 Acres Cumbres Pass 1993 Yarding - Removal of Fuels by Carrying or Dragging 7 Acres Cumbres Pass 1993 Yarding - Removal of Fuels by Carrying or Dragging 6 Acres La Manga Pass 1993 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres La Manga Pass 1993 Yarding - Removal of Fuels by Carrying or Dragging 18 Acres Cornwall Mountain 1994 Burning of Piled Material 4 Acres Cumbres Pass 1994 Plant Trees 10 Acres Cumbres Pass 1994 Yarding - Removal of Fuels by Carrying or Dragging 10 Acres Cornwall Mountain 1994 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres La Manga Pass 1994 Yarding - Removal of Fuels by Carrying or Dragging 4 Acres La Manga Pass 1994 Yarding - Removal of Fuels by Carrying or Dragging 10 Acres Cornwall Mountain 1994 Burning of Piled Material 2 Acres Cumbres Pass 1994 Burning of Piled Material 5 Acres La Manga Pass 1994 Burning of Piled Material 6 Acres La Manga Pass 1994 Burning of Piled Material 3 Acres Platoro Area 1996 Yarding - Removal of Fuels by Carrying or Dragging 2 Acres La Manga Pass 1996 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres La Manga Pass 1996 Yarding - Removal of Fuels by Carrying or Dragging 5 Acres La Manga Pass 1996 Yarding - Removal of Fuels by Carrying or Dragging 2 Acres La Manga Pass 1999 Fill-in or Replant Trees 4 Acres Cumbres Pass 1999 Fill-in or Replant Trees 4 Acres La Manga Pass 1999 Fill-in or Replant Trees 9 Acres La Manga Pass 1999 Fill-in or Replant Trees 9 Acres La Manga Pass 1999 Fill-in or Replant Trees 4 Acres La Manga Pass 1999 Broadcast Burning - Covers a majority of the unit 50 Acres La Manga Pass 1999 Broadcast Burning - Covers a majority of the unit 30 Acres La Manga Pass 1999 Broadcast Burning - Covers a majority of the unit 20 Acres La Manga Pass 1999 Burning of Piled Material 1 Acres Platoro Area 2000 Fill-in or Replant Trees 3 Acres Cumbres Pass 2000 Fill-in or Replant Trees 5 Acres La Manga Pass 2000 Fill-in or Replant Trees 2 Acres La Manga Pass 2000 Fill-in or Replant Trees 3 Acres La Manga Pass 2000 Fill-in or Replant Trees 14 Acres La Manga Pass 2000 Fill-in or Replant Trees 5 Acres La Manga Pass 2000 Burning of Piled Material 1 Acres Platoro Area 2000 Burning of Piled Material 1 Acres Platoro Area 2000 Fill-in or Replant Trees 6 Acres Cumbres Pass

250 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 2000 Fill-in or Replant Trees 3 Acres Cumbres Pass 2000 Fill-in or Replant Trees 6 Acres Cumbres Pass 2000 Fill-in or Replant Trees 2 Acres Cumbres Pass 2000 Fill-in or Replant Trees 3 Acres Cumbres Pass 2000 Fill-in or Replant Trees 4 Acres Fox Creek 2000 Fill-in or Replant Trees 7 Acres La Manga Pass 2000 Fill-in or Replant Trees 4 Acres La Manga Pass 2000 Fill-in or Replant Trees 6 Acres La Manga Pass 2000 Fill-in or Replant Trees 7 Acres La Manga Pass 2000 Site Preparation for Natural Regeneration - Other 25 Acres Platoro Area 2000 Site Preparation for Natural Regeneration - Other 25 Acres Platoro Area 2000 Tree Release and Weed 12 Acres Platoro Area 2000 Tree Release and Weed 13 Acres Platoro Area 2000 Precommercial Thin 4 Acres Fox Creek 2002 Broadcast Burning - Covers a majority of the unit 100 Acres La Manga Pass 2002 Burning of Piled Material 88 Acres Cumbres Pass 2002 Burning of Piled Material 101 Acres Cumbres Pass 2002 Burning of Piled Material 82 Acres Cumbres Pass 2002 Burning of Piled Material 45 Acres Cumbres Pass 2002 Burning of Piled Material 45 Acres La Manga Pass 2002 Burning of Piled Material 66 Acres La Manga Pass 2002 Burning of Piled Material 85 Acres La Manga Pass 2002 Burning of Piled Material 43 Acres La Manga Pass 2002 Burning of Piled Material 52 Acres La Manga Pass 2002 Burning of Piled Material 17 Acres La Manga Pass 2002 Burning of Piled Material 7 Acres La Manga Pass 2002 Burning of Piled Material 7 Acres La Manga Pass 2007 Burning of Piled Material 1 Acres Cumbres Pass 2012 Burning of Piled Material 7.5 Acres Cumbres Pass 2013 Rearrangement of Fuels 4 Acres Cumbres Pass 2013 Rearrangement of Fuels 23 Acres Cumbres Pass 2013 Rearrangement of Fuels 17 Acres Cumbres Pass 2014 Burning of Piled Material 3.5 Acres Cumbres Pass 2015 Plant Trees 75 Acres Cumbres Pass 2015 Plant Trees 4 Acres Cumbres Pass 2015 Plant Trees 23 Acres Cumbres Pass 2015 Plant Trees 17 Acres Cumbres Pass 2015 Plant Trees 24.1 Acres Cumbres Pass 2015 Plant Trees 3.2 Acres Cumbres Pass 2015 Plant Trees 29 Acres Cumbres Pass 2015 Plant Trees 42.9 Acres Cumbres Pass 2015 Plant Trees 10.8 Acres Cumbres Pass 2015 Plant Trees 11.7 Acres Cumbres Pass 2015 Plant Trees 0.9 Acres Cumbres Pass

251 CP District-wide Salvage Project Final Environmental Impact Statement

Year Treatment Type Units Treated UOM Area Affected 2015 Plant Trees 2.3 Acres Cumbres Pass 2015 Plant Trees 3.4 Acres Cumbres Pass 2015 Plant Trees 1.4 Acres Cumbres Pass 2015 Plant Trees 44.8 Acres Cumbres Pass 2016 Plant Trees 29.6 Acres Cumbres Pass 2016 Plant Trees 17.5 Acres Jasper 2016 Plant Trees 4.3 Acres Jasper 2016 Rearrangement of Fuels 100.6 Acres Jasper

252 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix J – Recreation Opportunity Spectrum Classes Defining recreation opportunities is used as a tool to help recreation managers create and maintain the appropriate recreation experiences that suits various types of land and visitors. The ROS continuum characterizes recreation opportunities in terms of setting, activity, and experience. The spectrum contains six classes: semi-primitive non-motorized, semi-primitive motorized, roaded natural, rural, and modern urban. ROS Class Descriptions Primitive Opportunity for isolation from man-made sights, sounds, and management controls in an unmodified natural environment. Only facilities essential for resource protection are available. A high degree of challenge and risk are present. Visitors use outdoor skills and have minimal contact with other users or groups. Semi-primitive non-motorized Some opportunity for isolation from man-made sights, sounds, and management controls in a predominantly unmodified environment. Opportunity to have a high degree of interaction with the natural environment, to have moderate challenge and risk and to use outdoor skills. Concentration of visitors is low, but evidence of users is often present. On-site managerial controls are subtle. Facilities are provided for resource protection and the safety of users. Motorized use is prohibited. Semi-primitive motorized Some opportunity for isolation from man-made sights, sounds, and management controls in a predominantly unmodified environment. Opportunity to have a high degree of interaction with the natural environment, to have moderate challenge and rise and to use outdoor skills. Concentration of visitors is low, but evidence of other area users is present. On-site managerial controls are subtle. Facilities are provided for resource protection and the safety of users. Motorized use is permitted. Roaded Natural Mostly equal opportunities to affiliate with other groups or be isolated from sights and sounds of man. The landscape is generally natural wit modifications moderately evident. Concentration of users is low to moderate, but facilities for group activities may be present. Challenge and risk opportunities are generally not important in this class. Opportunities for both motorized and non-motorized activities are present. Construction standards and facility design incorporate conventional motorized uses. Roaded Modified Similar to the Roaded Natural setting, except this area has been heavily modified (roads or recreation facilities). This class still offers opportunity to have a high degree of interaction with the natural environment and to have moderate challenge and risk and to use outdoor skills. Rural Area is characterized by a substantially modified natural environment. Opportunities to affiliate with others are prevalent. The convenience of recreation sites and opportunities are more important than a natural landscape or setting. Sights and sounds of man are readily evident, and the concentration for users I often moderate to high. Developed sites, roads, and trails are designed for moderate to high uses. Urban Area is characterized by a substantially urbanized environment, although the background ma have natural-appealing elements. High levels of human activity and concentrated development, including recreation opportunities are prevalent. Developed sites, roads and other recreation opportunities are designed for high use.

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254 CP District-wide Salvage Project Final Environmental Impact Statement

Appendix K – Responses to Comments on DEIS Each comment was reviewed and identified as either being substantive or non-substantive. Substantive comments are within the scope of the proposed action; specific to the proposed action; have a direct relationship with the proposed action; and, include supporting reasons for the Responsible Official to consider (36 CFR 215.2). The following letters have substantive comments to be addressed by the Interdisciplinary Team.

Letter Organization Email Name Address City State Zip # Individual; [email protected] 1, 1a Dick Artley 415 NE 2nd St. Grangeville ID 83530 Wildlands Defense Intermountain 2218 Jackson Blvd, Ste 2 Thomas Troxel Rapid City SD 57702 Forest Association 10 Normand Montrose Forest 81402- 3 PO Box 1149 Montrose CO Birtcher Products 0812 4 Garrett Hanks, Trout Unlimited [email protected] 1309 E. 3rd Avenue, Durango CO 81301 et al. Suite 109

5 Jerry R. Babbitt [email protected] PO Box 123 Medicine Park OK 73557 USDOI Office of the Secretary, Denver Federal Center, Courtney 80225- 6, 6a Environmental Building 67, Rm 118 Denver CO Hoover 0007 Policy and PO Box 25007 (D-108) Compliance [email protected] Colorado 7 David Bruson 2506 E Dale St. CO 80909 Springs Forest Health [email protected] 8 William Ceisla Management Fort Collins CO International Cameron [email protected] 9 27696 Road S Dolores CO 81323 Draper 10 James Free [email protected] 14920 6000 Rd. Montrose CO 81403 11 John Gardner [email protected] 559 E 6th Ave. Durango CO 81301 Karen [email protected] 12 20421 Road U Cortez CO 81321 Harbaugh Richard [email protected] 13 PO Box 131 Lake City CO 81235 Hernandez Todd [email protected] Grand 14 246 Silverton Ct. CO 81503 Mickelsen Junction 15 Donald Seagren [email protected] 302 Bishop Rd. Bailey CO 80421 16 Kathy Welt [email protected] PO Box 821 Paonia CO 81428 Margaret [email protected] Grand 17 227 Meeka Ct. CO 81503 Lurvey Junction 18 Ron Miller [email protected] 4091 Easley Way Golden CO 80403 Steven [email protected] 19 3039 Sherman Ave. Monte Vista CO 81144 Rothermich Western [email protected] Environmental Law Center; WildEarth Guardians; Rocky Smith; Rocky John Mellgren, 20 Mountain 1216 Lincoln Street Eugene OR 97401 et al. Recreation Initiative; San Luis Valley Ecosystem Council; Defenders of Wildlife; Quiet Use Coalition

255 CP District-wide Salvage Project Final Environmental Impact Statement

Letter Organization Email Name Address City State Zip # Donovan [email protected] 21 8221 Green Tower Ln Rye CO 81069 Burress Richard [email protected] 22 3612 Kenyon Dr. Fort Collins CO 80524 Edwards 23 Teri Munson [email protected] 170 Corral S Cotopaxi CO 81223 [email protected] Ranchos de 24 Mark Schuetz PO Box 2529 NM 87557 Taos Michael [email protected] 25 43 Arapahoe Trl. South Fork CO 81154 McQuitty Michele [email protected] 2020 Shorebird Dr. Apt 26 Fort Collins CO 80525 Vanoordt 306 [email protected] Colorado 27 Dave West 190 Chamberlin Ave CO 80906 Springs 28, Doug Southwest Nordic [email protected] PO Box 3212 Taos NM 87571 28a MacLennan Center 29, Phillip Strobel, USEPA Region 8 1595 Wynkoop Street Denver CO 80202 29a Angelique Diaz Pamela [email protected] Colorado 30 4112 Lupine St. CO 80918 Patterson Springs 31 Adam Mengle [email protected] Richard [email protected] 32 1612 Palm Dr. Fort Collins CO 80526 Cannady [email protected] Colorado 33 Dave Cipriani 1430 Golden Hills Rd. CO 80919 Springs Christopher [email protected] 1935 Grays Peak Dr. 34 Loveland CO 80538 Murphy Unit 104 35 Ruth Remple [email protected] 2954 Spinnaker Pl. Longmont CO 80503 36, Carson Forest Joanie Berde PO Box 15 Llano NM 87543 36a Watch

The following table provides a summary of the comments received on the Draft EIS. Interdisciplinary team responses to the comments are organized by general topic area. Letter number and comment number refer to the letters and associated substantive comments. Where comment responses were the same for multiple comments only one response is stated. Best Available Science Letter # - Comment and Response to Comment Comment # 20-17 Spruce beetles are natural components of spruce-fir forests, and those forests have evolved with periodic beetle infestations. And there is no scientifically supportable need for forest health treatments, fuels reduction, or insect and disease prevention within the spruce-fir ecotype (which is within the historic range of variability for fire, insects, and disease)… We challenge the Forest Service’s assumption that forest health and resiliency must be promoted with active management. What scientific support does the Forest Service rely on that active management is needed to promote forest health and resiliency? Response: The Forest Service agrees that spruce beetles are natural components of spruce-fir forests (see EIS section 3.2). The Forest Service also agrees that, at least within the scale of the project area, the ecosystem has not departed historic range of variability. The EIS does not propose treatments based upon a need to promote forest health and resiliency. Rather, the purpose and need for the project in section 1.4 clearly states, ‘In areas where forest conditions have departed from desired conditions, action is needed to respond to the widespread tree mortality caused by the ongoing spruce beetle epidemic. The disparity between existing and desired conditions creates a need to utilize available dead and dying trees in a timely manner to meet multiple-use mandates and 256 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # provide for the protection of firefighters, users, communities, and private resources.’ In this manner the EIS clearly ties the project to Forest Plan direction and objectives rather than to scientific claims of ecosystem needs and vulnerabilities. The EIS is also very clear that insect and disease prevention is not even considered possible, when related to the spruce beetle (see section 1.3-Background, and section 3.2 under Existing Condition, Forest Health and Species Composition). When considering forest health and resiliency as measures for the impact of alternatives upon forest vegetation across the landscape, the EIS makes the following statement in section 3.2: ‘When evaluating existing conditions within the project area in terms of forest health, it is important to understand what standard the conditions are being measured against. A quick review of the Forest Plan definition of forest health will note that it is a condition where influences do not threaten management objectives for a given Forest unit now or in the future (text abbreviated and emphasized for clarity). With this definition, the standard for forest health is determined by the management objectives for the unit under consideration. If the existing condition is in alignment with the objectives for the unit, then forest health meets the standard. If the existing condition is not in alignment with the objectives for the unit, then there is a disparity to be addressed. Some management units within the Forest are intended for events to be heavily managed for certain goals, while other units are intended to be very lightly managed for other goals. This definition does not deny the benefits of natural processes, but tends to the overlap between natural processes and desired conditions.’ In this manner, the EIS clearly discloses the relationship between forest condition, natural processes, and Forest Plan desired condition. 20-71 Post-disturbance or salvage logging is a long practiced yet scientifically unsupported method of forest management as a tool for aiding in forest restoration following a wildfire, insect outbreak, or disease. What best available scientific information (BASI) has the Forest Service used to make the assumption that it helps restore areas affected by these natural disturbances? Response: This project was never billed as a forest restoration project; it is expected to plant only limited areas as needed (860 acres under the proposed action); and does not address a post-fire forest condition. 20-72 Several studies have shown that salvage logging can and often does accomplish the opposite result through by increasing the fire hazard, degrading water quality and soils, and impairing the habitat and 20-74 ecological function of the forest. Natural tree regeneration can be abundant after fire, and postfire logging may actually reduce regeneration by as much as 71 percent. Shatford et al. 2007. Salvage logging can negatively impact snag dependent species such as woodpeckers (primary cavity nesters) and other birds. Flammulated owls are secondary cavity nesters and need a high density of large snags. They may prefer snags >25 inches at dbh, and the low threshold may be 2-8 snags per acre at >13 inches at dbh. See Manley, I., P. Ohanjanian, and M-A. Beaucher. 2004. Inventory of Flammulated Owls Breeding in the East Kootenay 2003. October. Nelson et al. (2009) found that a minimum threshold for snag dbh may be 12 inches, but the average is 20 inches. This calls into question whether uncertain levels of post-disturbance salvage logging at uncertain sites is a management tool that supports sufficient snag retention and density for a variety of snag-dependent species and, thus, ecological integrity. According to some of the best available science, the snag density targets may not be sufficient to maintain viability for all snag-dependent species that occur in the forest. For instance, Hutto (2006) proposed that Forest Service snag retention guidelines (about .3-3 per acre and consistent with the PA) in managed forests were inadequate and recommended targets closer to 80-120 snags per acre (without regard to snag size in dbh). Response: Affects to other resources are fully acknowledged and evaluated in the EIS, including project design criteria to minimize impacts to the extent possible. There are no uncertain levels of salvage logging proposed, and no uncertainty to where activities will occur, as acres and spatial extent of proposed actions have been disclosed to both project specialists and the public. Ecological integrity has been ensured, especially for snag-dependent species in the context of the 88% of the spruce forest on the district untouched by this project, the majority of which hasn’t even been logged in the past. Neither action alternative proposes the snag retention rate cited, but proposes 4 snags per acre. Furthermore, the recommended target of 80-120 snags per acre would imply that a green, or even partially green, forest condition (i.e. having only endemic levels of tree mortality or recent infestation) is not adequate for snag-dependent wildlife species, since the FSVeg Spatial data 257 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # shows 2016 forest landscape condition as averaging only 70 snags per acre, with only 30 of those snags in the overstory. 20-75 and Natural succession is an ecological process that often begins with disturbance and proceeds through 20-76 multiple stages of forest development, in various degrees throughout the forest, depending upon fire severity and pre-existing forest composition (Franklin et al. 2002). Disruption of this process through logging and planting results in simplified forests and reduced biodiversity (Lindenmayer and Franklin 2008). The rarity of naturally evolving complex early successional forests due to past management practices is now recognized by leading research scientists, for example, “Young forests growing within a matrix of un-salvaged snags and logs may be the most depleted forest habitat type in regional landscapes, particularly at low elevations.”15 And “Currently, early-successional forests (naturally disturbed areas with a full array of legacies, i.e., not subject to post-fire logging) and forests experiencing natural regeneration are among the most scarce habitat conditions in many regions” (Noss et al. 2006). In sum, the body of scientific literature finds that, overall, intensive logging and reforestation produce greater adverse impacts on recovering ecosystems, rather than contributing to recovery (see Lindenmayer et al. 2008; Hutto et al. 2016). Response: See response 20-71 and 20-72, concerning project intent and reforestation, as well as effects from salvage activity.

NEPA, NFMA, Forest Plan Revision, Cumulative Effects Letter # - Comment and Response to Comment Comment # 1a-33 The DEIS does not discuss the items shown below required by 40 CFR 1502.16: (e)Energy requirements and conservation potential of various alternatives and mitigation measures. (f)Natural or depletable resource requirements and conservation potential of various alternatives and mitigation measures. (g)Urban quality, historic and cultural resources, and the design of the buil environment, including the reuse and conservation potential of various alternatives and mitigation measures. Response: 40 CFR 1502.16 states: “This section forms the scientific and analytic basis for the comparisons under §1502.14. It shall consolidate the discussions of those elements required by sections 102(2)(C)(i), (ii), (iv), and (v) of NEPA which are within the scope of the statement and as much of section 102(2)(C)(iii) as is necessary to support the comparisons.” The components of 40 CFR §1502.16 that you reference (e, f and g) were not discussed in this analysis, with the exception of historic and cultural resources, because they are not within the scope of this EIS. The project will not have an impact on energy requirements, non-renewable resources or the urban environment. Furthermore, the project does not propose building, altering or removing any components of the built environment. Heritage resources are discussed in EIS, section 3.14. 1a-34 Ranger Jones, you hide important documents related to this project as hardcopies in the project file through 1a- located in La Jara. Most of these documents were created on your computer. Even a child has the 37 computer skills to post electronic documents online. If the document was not created on the computer these children would know how to scan them and create a PDF file that could be posted online. Obviously, you do not want the public to read these documents. Why? Either they don’t exist or they don’t support this project. Please tell the public why you didn’t hire an 8th grader to do the computer work for this project. Important information that would help the public understand the proposed project analysis disclosed in your draft EA is hidden away in the project file. It’s sad you use this illegal and unethical scheme to hide information from the public you claim to serve. There is absolutely no reason to keep information from the public by hiding important documents in the project file. You could scan information and post the PDF files online. All information on file can be made available to the public as attachments. Especially relevant documents should be included in their entirely in an Appendix.

258 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Request for changes to be made to the final NEPA document: Make ALL the documents that currently reside in the Project Record available as 1) online Appendices to the NEPA document, or 2) attach them to the EA. Response: The Forest Service fully supports and utilizes the best available science, information and data (peer reviewed, objective, relevant, and timely) available to the team at the time the analysis occurs as part of project planning as shown in the EIS, specialist reports and supporting documentation. References appropriate for this analysis are listed in References and Literature Cited (EIS, Appendix B). Data sources applicable to project analysis are disclosed in the EIS and specialist reports and are available in the project record. 1a-38 Please respond to all quotes that express opposing views contained in the Opposing Views Attachments. I have included 5 Opposing Views Attachments with these comments. Please comply with the law by responding to each responsible opposing view quote contained in the Opposing Views Attachments. Request for changes to be made to the final NEPA document: Comply with the request described above. Response: Responses to the Opposing Views Attachments are in Appendix K.1. 5-8 It should be noted that the late availability and volume/complexity of the document inhibits a thorough and detailed assessment by most individuals. Response: Concerning the availability of the DEIS, we disagree that it was late. The DEIS was posted on the Forest website on October 6, 2017, well before the comment period began. A letter was sent to interested parties on October 12, 2017, notifying them of the project Notice of Availability (NOA) in the Federal Register and explaining the 45 day comment period from date of publication of the NOA. Legal notice of the comment period was published in the Valley Courier on October 13, 2017. A news release was sent to the Valley Courier on October 16, announcing the availability of the DEIS for review. Publication in the Federal Register occurred on October 17, rather than the expected date of October 13, giving extra time for public access and comment. A copy of the NOA and specialist reports were also posted on the Forest website on October 24. Concerning the volume and complexity of the DEIS, the Forest Service complied with the Council of Environmental Quality (CEQ) standards and recommended format for preparing an EIS. This included a document summary, table of contents, and index, as well as effort in using plain language or explaining technical terms. It was also written in a concise format, at 149 pages for the body of the document (Purpose and Need through Environmental Consequences). This is within CEQ’s rule-of-thumb of 150 pages; the rule-of-thumb for unusually complex proposals is 300 pages. Appropriate graphics were used to aid in understanding the proposal and analysis. Because of these efforts, we disagree that the EIS was not transparent. 5-2 It appears that the baseline for this timber salvage project is the 1996 RGNF Revised Land and Resource Management Plan, as amended, the final environmental impact statement, and record of decision issued for the Forest Plan. The Forest Plan is shaped by the FORPLAN model and methodology which was found to be flawed by a Federal Court in 1984. Were the deficiencies causing the FORPLAN methodology to be flawed ever subsequently corrected to the satisfaction of the Federal Court? If not, all Forest Plan decisions growing out of FORPLAN are expected to be just as flawed. ISSUE Response: The 1996 Rio Grande National Forest Revised Land and Resource Management Plan (Forest Plan) is the current and legal direction for all management actions on the Forest, until replaced with a new revision. Because this revision was performed in 1996, all issues related to a 1984 ruling were resolved at that time. Additionally this project is not a Forest Plan decision, but rather implementation of Forest Plan direction, which has not been set aside by either court injunction or agency direction. Finally, growth and yield modeling for this project is not reliant upon the FORPLAN model, but upon current vegetation data modeled through FSVeg Spatial Data Analyzer, as described in section 3.2 of the EIS and the Timber and Silviculture specialist report for the project. 20-1 The Forest Service must explain how the proposed action relates to the Rio Grande National Forest 20-2 Plan revision process. We noted in our scoping comments that the Forest Service should avoid 20-4 finalizing a decision on this project until the revised Rio Grande Forest Plan is complete. The DEIS 20-5 states that the project will comply with all components of the Rio Grande National Forest Plan; 259 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 20-10 however the Rio Grande National Forest is in the middle of a forest plan revision process. The 20-12 forest released its DEIS assessing the revised draft Forest Plan in September 2017 and expects to release a final plan and final EIS to conclude the revision process in2018. The Forest Service should explain how the revised Forest Plan will affect implementation of this project. Instead the Forest Service states, without explaining how, the project will be adapted as needed to accommodate new information or changes associated with the revised Forest Plan based on the pre- implementation checklist. See DEIS, page i. Given that the revised Forest Plan must comply with the 2012 planning rule—which includes many new substantive standards—there are likely to be numerous changes to plan components in the revised Forest Plan, as compared to the existing 1996 Forest Plan. The Forest Service must explain how the proposed project will be consistent with the revised Rio Grande Forest Plan. It [NFMA Compliance report] makes no attempt to explain how the project will be consistent with the revised Forest Plan. Instead the Forest Service states, without explaining how, the project will be adapted as needed to accommodate new information or changes associated with the revised Forest Plan based on the pre-implementation checklist. See DEIS, page i….The Forest Service must explain how the proposed project will be consistent with the revised Rio Grande Forest Plan. Deferring to future analysis under a pre-implementation checklist fails to provide sufficient information during the NEPA process and precludes meaningful public comment. It makes more sense to wait until the Rio Grande National Forest’s Forest Plan revision process is complete to propose a long-term project like this. The Rio Grande National Forest’s Forest Plan revision process, which must comply with the 2012 planning rule requiring social, economic, and ecological sustainability on the forest, is already well underway.1 The Forest Service has already completed the Assessment phase and developed a preliminary list of Species of Conservation Concern (SCC).2 The agency released its draft plan and draft EIS in September 2017, incorporating new policies, priorities, and the latest information from monitoring reports and scientific research. It expects to finalize the plan and EIS in 2018, directly overlapping with the decision-making timeline for this project. Waiting to complete this 10 to 15 year-long project will ensure it is consistent with and informed by the latest, science-based revised Forest Plan, and will give the public a meaningful opportunity to review the project against the proposed new provisions for the Forest Plan. The Forest Service should not rush to salvage log at the expense of forest resource protection until there is additional clarity about the direction the Forest as a whole intends to take when the final revised Forest Plan is released. Response: As described in section 2.2 of the EIS under the Adaptive Implementation, Project Design Criteria, and Monitoring heading, an element of the adaptive management approach will include the ability to update the project implementation process, within the scope of this analysis, to reflect changes in land management plan direction and/or new information, as needed. If a “changed circumstance” or a change in management area direction is part the Forest Plan Revision Selected Alternative, as per FSH 1909.15, section 18, the new management area direction or circumstances would be reviewed to determine if the new circumstances are within the scope and range of environmental effects considered in this EIS. If the environmental effects are within the context considered in this analysis, this will be documented and included in the project file and any changes to the implementation process will be updated. If effects are determined to be outside the scope and range of environmental effects considered in this analysis, the Responsible Official will determine the type of additional analysis that is necessary prior to additional implementation. Additional citation: 36 CFR 219.15(a) states: Application to existing authorizations and approved projects or activities. Every decision document approving a plan, plan amendment, or plan revision must state whether authorizations of occupancy and use made before the decision document may proceed unchanged. If a plan decision document does not expressly allow such occupancy and use, the permit, contract, and other authorizing instrument for the use and occupancy must be made consistent with the plan, plan amendment, or plan revision as soon as practicable, as provided in paragraph (d) of this section, subject to valid existing rights.

260 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # The current outlook for the date of finalization of the RGNF Forest Plan Revision EIS and decision is uncertain. One purpose for this action is to salvage dead or dying trees while they still retain economic value. Though time is of the essence to recover economic value of these trees, the Forest Service has not rushed into this action. To the contrary, the recognition of the extraordinary circumstances based on the spruce beetle outbreak and subsequent spruce mortality, the deviation of current forest conditions from overall desired forest conditions, and the potential effects of the action alternatives on resources drove the Forest’s decision to analyze the proposed action with an environmental impact statement. The thorough public and internal scoping and collaboration, and, the analysis provided in the EIS, specialist reports, and supporting documentation illustrates our integrity in and adherence to the law and intent of NEPA. 20-3 The findings in the National Forest Management Act Compliance specialist report appear to assess the project’s compliance with the current 1996 Forest Plan, although the report fails to provide details necessary to demonstrate compliance. The report refers broadly to “goals, desired conditions, or objectives,” “applicable standards,” and “applicable guidelines” without identifying those plan components from the 1996 Forest Plan or explaining how the project is consistent with them. Response: The CPDWS project responds to many Forest Plan goals and objectives. A list of these desired conditions and objectives are in Chapter 1, section 1.5 of the EIS. 20-6 The agency expects actions authorized under this project to occur over a ten to fifteen year time 20-7 span. DEIS at 18. This time frame is almost as long as the intended applicable scope of a Forest Plan. This really feels more like a Forest Plan amendment. But according to the DEIS, the Forest Service claims it is subject to the site-specific project planning rules, 36 CFR 218. Response: According to CFR §219.13, a plan amendment is required to add, modify, or remove one or more plan components, or to change how or where one or more plan components apply to all or part of the plan area. Since this project adheres to the current 1996 Forest Plan and does not propose to add, modify, remove or change any of the current plan components, a plan amendment is not applicable. 20-13 The proposed action is inconsistent with Rio Grande Forest Plan. Even assuming that this project is properly categorized as a site-specific project, various aspects of this project are inconsistent with the 1996 Forest Plan. It therefore violates the National Forest Management Act (NFMA). As one example, the 1996 Rio Grande Forest Plan includes a forest-wide standard to control sediment: Limit roads and other disturbed sites to the minimum feasible number, width, and total length consistent with the purpose of specific operations, local topography, and climate.

Forest Plan at III-8. A guideline further directs the Forest Service to use existing roads unless other options will produce less long-term sediment, and to reconstruct for long-term soil and drainage stability. Id. But the Forest Service’s proposal to re-open 35 miles of old, non-system road templates, and construct 32 miles of new temporary roads (for use by log hauling trucks throughout the 10 to 15 year project period) runs directly contrary to these standards and guidelines. Other examples are listed throughout this comment, including inconsistency with the 1996 Forest Plan’s standards to protect soils (see section six, below). Response: The proposed action did limit the roads and disturbances to the minimum feasible number, area, and length consistent with the purpose of specific operations. No more Maintenance Level 1 roads were proposed for use than necessary to harvest the proposed locations. All ML 2 and 3 roads identified by the project are already part of the open road system and under constant use. No more temporary roads were proposed than necessary to harvest the proposed locations, whether as re-opened old templates or new construction. All roads proposed for use are based off of local topography, equipment limitations, and climate considerations. Furthermore, the proposed action uses existing roads as guided and established the temporary road needs according this existing infrastructure. BMPs, standards, and guidelines will be applied to all roadwork, as committed to in the EIS. The commenter does not demonstrate how fewer miles of roads could be used to accomplish the harvest of proposed locations, using a ground-based logging system. Therefore the proposed action is not in violation of the Forest Plan or NFMA. 20-25 Failure to take a “hard look” at the direct, indirect, and cumulative impacts as required by NEPA.

261 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: NEPA’s “hard look” doctrine requires a thorough investigation into the environmental impacts of its actions and a candid acknowledgement of the risks of those impacts. The “hard look” helps the Responsible Official make decisions based on understanding those consequences. The CPDWS project ID Team has clearly disclosed the impacts of the proposed action on their resources and provided sufficient evidence and analysis to support their conclusions, therefore adhering to the “hard look” doctrine of NEPA. The ID Team has thoroughly considered the issues involved with the proposed activities and used sound judgement through accurate data analysis based on reliable and scientifically justified models, methodologies and data sets in their analyses of issues and potential impacts of project activities to support their conclusions (see specialist reports, summaries in Chapter 3 of the EIS, supporting documentation and cited literature). The adaptive process outlined in Chapter 2, section 2.2 of the EIS allows for consideration of new information or changed conditions to be integrated into project design prior to implementation. This additional step, including field verification, provides yet another “hard look” into environmental conditions to ensure disclosed assumptions were appropriate and correct. This process allows the agency to adjust to unforeseen circumstances, if necessary, and provides for publication of such findings for public information and to ensure transparency. 20-29 Here, the Forest Service must provide site-specific details and analysis of what is contemplated by the Project and what impacts the project will have. The DEIS talks about effects generally, and talks about project implementation on the ground generally, but fails to provide any relevant and helpful site-specific information. The Forest Service refers in extremely vague terms to “proposed activities that may be implemented” and projects that may be funded with Knutson-Vandenberg monies, if available. DEIS at 20. These “opportunities” that the Forest Service fails to commit to are largely mitigation actions, including improving watershed condition through road reconstruction and additional road maintenance, closing unauthorized routes to improve watershed condition, and treating invasive plans and noxious weeds. Id. By failing to commit to these activities, it is impossible for the public to fully assess the impacts of the project. Response: This section describes resource benefits that are accomplished by the proposed actions discussed in Chapter 2. Reconstruction and maintenance are committed to in section 2.2, under “Activities Common to all Action Alternatives.” Treatment of weeds are committed to in section 2.4, “Project Design Criteria,” and closure of unauthorized routes post-treatment is committed to by standard contract provisions (see response 20-66). See also responses in the next table concerning site-specificity of analysis. This comment seems to imply that it can’t be known if repairing and maintaining roads would improve watershed condition; if closing unauthorized routes would improve watershed condition; and if locating and treating unknown populations of invasive plants and noxious weeds would benefit plant communities; without exact known locations across the project area. Yet commonly- accepted research and BMP’s indicate otherwise. 20-37 “Controversy in the NEPA context does not necessarily denote public opposition to a proposed action, but a substantial dispute as to the size, nature, or effect of the action.” Middle Rio Grande Conservancy Dist. v. Norton, 294 F.3d 1220, 1229 (10th Cir. 2002). Substantial dispute may be found when other information in the record “cast[s] substantial doubt on the adequacy of the agency’s methodology and data.” Hillsdale Envtl. Loss Prevention, Inc. v. U.S. Army Corps of Eng’rs, 702 F.3d 1156, 1181 (10th Cir. 2012). As follows, there is a substantial dispute about the effects of the action. In particular, we are concerned about the Forest Service’s failure to fully acknowledge effects of the action on Canada lynx, lynx habitat, big game winter range, other wildlife, wildlife connectivity, water quality, heritage resources, soils, air quality, roads (system and temporary), noxious weeds, climate change, and cumulative effects. Without the site-specific baseline data highlighted above, there is a substantial dispute as to the size, nature and effect of the project. Response: Effects on lynx habitat was identified as the issue following scoping for this project. Alternative 3 was developed primarily to respond and address this issue by reducing salvage harvest activities in areas considered high-quality lynx habitat or important places such as denning areas. Summaries of the effects of this project on Canada lynx and other wildlife, water quality, heritage resources, soils, air quality, roads (system and temporary), noxious weeds, climate change, 262 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # and cumulative effects are found in Chapter 3 of the EIS. Additional analysis and details can be found in the specialist reports and supporting documentation within the project record. 20-91 The Forest Service has announced, is analyzing, or has authorized numerous logging projects on the Rio Grande National Forest recently, including the Del Norte Peak Salvage Project, the Groundhog Park Salvage Project, the La Garita Hills Project, and others. The Forest Service must consider the cumulative impact of all of these projects across the forest on various resources, but in particular on Canada lynx and its habitat not just in the project area, but also across the Conejos Peak Ranger District and the Rio Grande National Forest. As noted above, this analysis ignores the ongoing Forest Plan revision process.29 Response: Past projects are incorporated into the environmental baseline and non-federal actions in the cumulative effects section of the BA. Forest wide caps under the SRLA are also addressed, as are Forest Plan standards and Guidelines for suitable vs. unsuitable habitat (S1 and S2). Refer to BA section 2. None of the action alternatives are anticipated to result in jeopardy, i.e. jeopardizes the continued existence of T&E species. 20-142 The chosen alternative is likely to be more environmentally damaging than current conditions under the no action alternative, especially in terms of impacts to the watershed, soil, and wildlife. NEPA regulations require the agency to identify the environmentally preferred alternative. 40 C.F.R. § 1505.2; 46 Fed. Reg. 18,026 (March 23, 1981) (Council on Environmental Quality, Memorandum to Agencies: Forty Most Asked Questions Concerning CEQ’s National Environmental Policy Act Regulations) (explaining the “environmentally preferred alternative” “[o]rdinarily . . . means the alternative that causes the least damage to the biological and physical environment,” and that “best protects, preserves, and enhances historic, cultural, and natural resources.”). From the three alternatives considered in detail, Alternative 1 should be the environmentally preferred alternative. Response: As per CEQ direction, the discussion of the environmentally preferred alternative will be included as part of the Record of Decision. The environmental effects of the proposed activities are disclosed in chapter 3 of the EIS. 29-1 Based on our review of the Draft EIS, the EPA has rated the Preferred Alternative as “LO”, Lack of Objections. The LO rating means that the EPA’s review has not identified any potential environmental impacts requiring substantive changes to the Preferred Alternative. A full description of the EPA’s rating system can be found at: http://www2.epa.gov/nepa/environmental - impact-statement-rating-system-criteria Response: Thank you for your support of the Forest Service’s Preferred Alternative. 36-1 We are concerned with the cumulative effect of so many projects upon lynx and other wildlife and through on the watershed of the Upper Rio Grande and Chama Rivers… There have been numerous large 36-3 “salvage” sales conducted in just the past several years directly to the north on the Divide Ranger 36a-4 District near Wolf Creek Pass, ear Creede, hear Del Norte and South Fork. All of these areas are of critical importance to Canada lynx in southern Colorado and the combination of acres and acres of habitat affected and modified on the Divide District and the Conejos Peak District really raise concerns regarding the future of the Canada lynx in Colorado. NEPA requires such a full cumulative affects analysis especially upon a federally listed species. Response: See 20-91 response. 36a-1 Please note that Carson Forest Watch never received the scoping letter for this project – despite being involved with timber sales on the Conejos Peak District for over 28 years (p. 161 – not on list also). Response: It may have been longer ago than hoped, but you were sent a scoping letter for the project (to your email address), to which you responded by letter on March 7, 2016. Your name is also on the list on DEIS page 161 with those who were contacted concerning the DEIS notice of availability. 36a-3 Under the list of past projects for cumulative effects, there is no mention of volume from all these projects (only amount of acres treated). There needs to be a clear review and analysis of how many millions of board feet (MMBF, not CCF) of trees have been harvested in adjacent areas of forest and in connecting areas to the north and west on the Divide District.

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Letter # - Comment and Response to Comment Comment # Response: The acres disturbed by past management activities, as well as the acres planned for disturbance under the alternatives, are considered to be the appropriate measure for defining environmental impacts, along with distance of road disturbance. As a result, the summary of each alternative displays area salvaged, miles used, acres planted, and acres of hazardous fuels treatments. Each resource specialist considers the impacts cumulatively within the analysis boundary of appropriate scale for their resource and determines the effects of the combined disturbances. Volume is used as a measure for how well an alternative meets part of the project purpose and need. Because volume grows back and can be harvested again from the same area, it is not used as a measure of environmental impact to the landscape. It often does not overlap in both time and space. Where it does, the analysis is already based upon disturbed area and connectedness or upon the present composition and structure of the stands, the extent of the composition and structure across the analysis area, and the interconnectedness of the composition and structure across the analysis area. Secondly, volume does not serve as a good measure of environmental impact because the capacity for volume is tied to site productivity, which varies widely from site to site across the project area and across the Rio Grande National Forest. Greater area can be impacted on the Saguache Ranger District, but with much less volume. Finally, volume data is not available for many of the legacy sales on record, nor on the active sales that have not yet closed.

Adaptive Implementation and Site Specificity Letter # - Comment and Response to Comment Comment # 1-1 I expect more from professionals than I see in your DEIS. Between 1997 and 2000 I taught the 1-2 1900-1 beginning NEPA course in R-1. I repeatedly told my classes NEPA requires a site specific analysis. If this DEIS were available back then, I would have handed it out to show what not todo. You propose to log 26 square miles and construct 32 miles of road. You have hundreds of cutting units!!!!!!!!!!!!!!!!!!!! Only a fool would claim its possible to do a site specific NEPA document across an entire ranger district. You could have saved money by telling the public you plan to log a large area and there will be environmental effects that will be disclosed later after the decision is signed. The env effects disclosures are general and clearly will not pass muster in court. Response: The analysis has been performed in accordance with NEPA requirements. See additional responses concerning site-specificity and effects analysis. 5-6 On page 12 of the EIS an “…adaptive decision framework for responding…” phrase is used. This appears to imply that changes in the decisions made today for this project may be changed as conditions change unexpectedly over time. Howe will the public good be preserved in instances where changes are made to the Project as described in the EIS? Will the public be informed of any changes and be permitted to review any change decisions? Concern Response: The adaptive decision framework consists of the implementation checklists, which 1) ensure that actions remain within the scope of the project analysis, 2) allow additional site-specific restrictions based on of new information, and 3) maintain accountability. See section 2.2 of the EIS for additional review of this framework. According to this process, the checklist and supporting documentation will be published on the Forest website for public information, prior to implementation or contract solicitation, whether for hazardous fuels treatment projects or salvage timber activities. This framework does not allow changes that are outside of the scope of the actions analyzed in the EIS and selected in the Record of Decision. Additional information has been added to section 2.2 of the EIS to better explain how the adaptive decision framework will be used.

264 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 20-5 Deferring to future analysis under a pre-implementation checklist fails to provide sufficient 20-8 information during the NEPA process and precludes meaningful public comment. 20-28 Given the long time frame of 10-15 years, throughout its analysis the Forest Service forgoes the 20-143 necessary site-specific analysis under the assumption that on-the-ground conditions will change. This demonstrates the broad nature of the proposal and how it is inappropriate for a site-specific project. Recognizing this overly broad, excessively long timeframe, and lack of site-specific data, the Forest Service relies on adaptive management approaches, highlights that it will reconsider new information or changed circumstances as they arise, and consistently avoids committing to any site- specific details or providing the necessary site-specific baseline information. NEPA requires the hard look assessment take place at the site-specific level if there are no additional NEPA processes yet to occur in the future to fully implement the project and the environmental impacts are reasonably foreseeable… the Forest Service must provide site-specific details and analysis of what is contemplated by the Project and what impacts the project will have. The DEIS talks about effects generally, and talks about project implementation on the ground generally, but fails to provide any relevant and helpful site-specific information. For all actions considered in this proposal the Forest Service has a duty to “[u]se all practicable means . . . to restore and enhance the quality of the human environment and to avoid or minimize any possible adverse effects of [its] actions upon the quality of the human environment.” 40 C.F.R. § 1500.2(f). To justify the long timeframe proposed for this action (10-15 years) the Forest Service relies on adaptive implementation. See DEIS at 30. As explained above, the Forest Service should more narrowly tailor this project to make it a site-specific project, addressing the immediate need aspects with the current proposal. It should save the longer term, more aspirational aspects of this proposal for separate site-specific projects that can be assessed based on the latest information at that future time, as well as a revised Forest Plan. Relying on adaptive management as a way to forgo the necessary site-specific studies and disclose details at this stage of the NEPA process is inappropriate. Response: The analysis of effects was based on field sampled Common Stand Exam data, imputed to provide an analysis area-wide dataset for 5,427 forested stands (including 3,725 spruce stand) using a nearest neighbor process to evaluate no action and proposed treatment activities modelled into the future using the Forest Vegetation Simulation and Fire and Fuels model (see section 3.2 and the Silviculture and Forest Products specialist report for additional details). All proposed treatment units and treatment types are shown on the alternative maps in the EIS; any approved activities would remain within the areas indicated in the Selected Alternative map of the Record of Decision. The implementation timeframe reflects the time needed to complete proposed management actions considering the need to complete many activities in a specific order over several years (i.e. adaptive management pre-implementation process, field validation, salvage harvest, stocking surveys, sow and plant seedlings). Refer also to response 20-25 on the NEPA “hard look”. Additionally, CFR §1508.28, Tiering, states that tiering refers to coverage of general matters in broader EISs with subsequent narrower statements. Tiering is appropriate when the sequence of statements is: “From an environmental impact statement on a specific action at an early stage (such as need and site selection) to a supplement (which is preferred) or a subsequent statement or analysis at a later stage (such as environmental mitigation). Tiering in such cases is appropriate when it helps the lead agency to focus on the issues which are ripe for decision and exclude from consideration issues already decided or not yet ripe.” The adaptive process, which includes the pre-implementation checklists, serve as a level under (or tier) the CPDWS project analysis and is proposed to aid in determining site-specific effects to address and mitigate within the broader EIS and Record of Decision.

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Letter # - Comment and Response to Comment Comment # 20-9 The adaptive management approach outlined in the analysis fails to provide the measures and feedback verifications necessary to ensure changes will be implemented, and not just considered, based on new or more detailed information that is expected in the future. Response: Additions were made to Chapter 2, section 2.2 of the EIS in order to ensure clarity and transparency of the adaptive implementation approach. This includes an Adaptive Implementation Roadmap, which illustrates the process post-decision. The roadmap includes publication of the results of field verification and the Pre-Implementation Checklists #1 and #2, and provides for additional opportunities for public feedback prior to project implementation in order to address changes to the design of the project or additional protections needed for resources. Adaptive implementation includes integration of results from resource monitoring and allows for an iterative process as we verify findings. No modifications of actions may be proposed or implemented that are outside the scope of what was proposed and analyzed in the EIS and outlined in the Record of Decision. 20-26 NEPA statutory standards found in Council on Environmental Quality (CEQ) regulations recognize that intelligent decision-making can only derive from high quality information. See 40 C.F.R. §§ 1500 et seq. “Agencies shall insure the professional integrity, including scientific integrity, of the discussions and analyses in [EISs].” 40 C.F.R. § 1502.24. Information included in NEPA documents “must be of high quality. Accurate scientific analysis . . . [is] essential to implementing NEPA.” 40 C.F.R. § 1500.1(b). If an agency has outdated, insufficient, or no information on potential impacts, it must develop information as part of the NEPA process or in the very least explain the lack of information. Here, the Forest Service should not rely on the lack of information to conclude impacts do not exist. See, e.g., DEIS at 66 (“There are no known occurrences of wolverine on the RGNF and there is an exceptionally low probability of a wolverine population occurring in the state much less in the project area” and, “[t]herefore, the effects of this project to wolverine are considered negligible and will not be considered further in this document”). See also DEIS at 69-70 (noting the Western Bumble Bee, Boreal toad, Northern leopard frog, and Boreal owl are not documented in the project area, but no surveys were conducted for these sensitive species in the project area). Response: See responses to 5-6, 20-5, 20-8, 20-9, 20-28 and 20-143 20-27 Site-specific analysis is crucial. We are pleased that the Forest Service completed an EIS for this project. A project of this size and scope clearly contemplates significant effects that are best analyzed in an EIS. Response: Thank you for your support of our decision to prepare an EIS for this project. 20-34 Numerous times throughout the DEIS, the Forest Service references studies it will conduct or data it will collect prior to implementing the project. For example, the DEIS states: Surveys for TES species will occur prior to design of a project; Results of surveys will be incorporated into the project design and/or implementation per applicable Forest Plan Standards. Known occurrences of sensitive species will be flagged with a buffer for avoidance from salvage harvest and fuels reduction activities. DEIS at 103. Deferring site-specific analysis and collection of relevant, necessary information until well after the public comment period is unacceptable, and violates NEPA. Response: The sentence referred to here (DEIS at 103) pertaining to a “flagged buffer for avoidance” of FS sensitive species was removed from the EIS. It is impractical and, in some cases, unnecessary to avoid all areas where FS sensitive species exist or may exist. If FS sensitive species are discovered during field verification or any other time during the life of this project, the appropriate protection measures will be implemented as determined by the species conservation assessment and plan and as directed by the Responsible Official. See also responses to 20-5, 20-8, 20-9, 20-28 and 20-143. 20-28 The Forest Service must conduct site-specific analysis as a part of its analysis, which the agency has failed to do. This includes explicitly delineating what type of logging will occur where, where roads will be re-opened or new temporary roads will be constructed, and the resulting impacts of such activity on important Forest resources. Response: An appropriate level of site specificity was provided to 1) discover, disclose, and draw conclusions about all reasonably foreseeable impacts; 2) mitigate impacts to an acceptable level through development and application of site-specific project design criteria; 3) contrast impacts of 266 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # the proposed action and any alternatives with the current condition and expected future condition; and 4) make an informed decision about a selected course of action. No reasonably foreseeable impact was brought forward by comments that has not been examined nor can be examined by this type and scale of analysis. The Forest Service did delineate what type of logging (and other activities) would occur and where it is planned. Polygons and linear features were provided on the alternative maps and in the project geodatabase. Only one type of logging was proposed, as described in section 2.2-Alternatives Considered in Detail. See also responses to 20-25 and 20-30. 20-35 As another example, the Forest Service assumes in the DEIS that fens and wetlands will be avoided during project activities and no proposed actions will occur in these delicate, unique habitats. DEIS at 101. But it fails to disclose the locations of fens and wetlands in relation to the proposed activities. See DEIS at 106 (deferring to completion of project implementation checklists for individual projects for details as to field inventories of streams, wetlands, and riparian areas to inform project area boundaries). Response: The locations of all known fens/wetlands are mapped and disclosed in the EIS. Site- specific identification of wetlands, fens, WIZ, and RMZ areas will be completed during the pre- implementation checklist process. Methods used to identify fens, wetlands, and streams during checklist completion will include: Overhead imagery, model outputs, available GIS datasets, and on the ground field investigations by IDT members. Management direction provides for protection measures of fens and wetlands (Forest Plan, BMPs). Additional protection measures are proposed under both action alternatives for this project (see section 2.4, Project Design Criteria for Aquatic Resources). Effects to resources are disclosed in chapter 3 of the EIS. 20-36 The Forest Service must conduct these analyses, data collection, and field reviews prior to or during the NEPA process so that the public has a reasonable opportunity to comment on the efficacy and results of such studies, data, collection, or field exams, and so that the decision-maker can legitimately consider all of the effects of the project prior to making a final decision. A federal court in Idaho recently addressed a very similar proposal and process from the Forest Service related to the collection of data for a specific rare plant. See Idaho Conservation League v. U.S. Forest Serv., Case No. 1:16-cv-25-EJL, 2016 WL 3814021 (D. Idaho July 11, 2016). There, the Court found the Forest Service’s proposal to conduct studies and collect data to assess baseline conditions until project implementation violated NEPA. Id. at *8-12. Related to mitigation measures, which the present project relies on to avoid impacts during project implementation, the Court noted that it “must be able to review, in advance, how specific measures will bring projects into compliance with environmental standards…Without accurate baseline data before the Project begins, it is impossible to know whether and to what extent the Project’s activities will impact [a rare plant] even with the proposed design features, monitoring, and mitigation features.” Id. at *11. Failure to conduct the required site-specific analysis of impacts under NEPA prevents the public from meaningfully participating in this process. This defect in the DEIS cannot simply be cured by releasing an FEIS disclosing this information. Rather, disclosure must occur and the public must be given an additional comment opportunity to review and address the site-specific implementation information. Without that opportunity, the Forest Service will frustrate NEPA’s purpose, and effectively shut the public out of participating in the NEPA process for the project. The Forest Service fails to provide site-specific analysis for many important aspects of the project, including: • What kind of logging (hand treatments, chainsaws, or heavy machinery) will occur in each location (DEIS at 23-29); • Length, location, and rehabilitation plans for re-opened non-system roads (DEIS at 23); • Length, location, and rehabilitations plans for temporary roads (DEIS at 23); • When specific project design criteria apply to certain management activities (DEIS at 33) (“as appropriate”). This type of information is necessary up front to ensure informed and meaningful public comment. Deferring a full analysis to some later, undefined date based on a checklist as a proxy for site- specific analysis is insufficient under NEPA. Response: See response 20-77 for discussion concerning the presence, use, and adequacy of baseline data. Inaccuracies within baseline data do not preclude action or define a set scale of 267 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # analysis within the National Environmental Policy Act; it only must be disclosed along with the associated risks, which the EIS has done throughout, including acknowledgement of database limitations. Concerning mitigation measures, the public has had the opportunity to adequately consider the effectiveness of all project design criteria, which are incorporated in the alternative and analyzed in the EIS as part of the alternative, and to dispute any rationale or science used in support of the analysis. No reasonably foreseeable impacts have been brought forward which have not already been addressed through project design criteria or otherwise analyzed in the EIS. Likewise no irretrievable commitment of resources would occur through the selection of an action alternative, which is required to abide by Forest Plan direction concerning the protection of TES and other resources. Furthermore, the Forest Service did provide an adequate level of site-specific analysis concerning method and location of logging; length, location, and rehabilitation of roads; and when/where specific pdc apply. See response 20-30. Any additional mitigation measures introduced during the checklist process would either be additional exclusions from treatment, incorporation of new Forest Plan standards and guidelines which will have already been considered in NEPA analysis, or measures otherwise made available for public review during the public input phase of the implementation process. ‘As appropriate’ in the DEIS section 2.4 introductory paragraph means as applicable to the implementation project activities. If no salvage harvest activity is proposed within a specific implementation project, then application of salvage-related pdc would not be appropriate. If no temporary roads are used in an implementation project, then no temporary road decommissioning would occur post-treatment. As a result of this comment, language was changed in the FEIS to ‘as applicable,’ for clarification. Additional steps were also added to the implementation process to ensure opportunity for public review and input. 20-77 The Forest Service states that proposed treatment areas and associated road needs are identified in the project geodatabase for site-specific analysis, but they are subject to adjustments made during later-stage analysis through the use of implementation checklists. DEIS at 23. Baseline information based on accurate field verification is precisely the type of information that should have been provided in this analysis. Yet because of the long-term nature of the project, the Forest Service inappropriately glosses over these details and defers to some future time when the information is likely to be more accurate. Response: The comment missed an important part of the paragraph which states, ‘Adjustments made during later-stage analysis would be kept within the scope of impacts analyzed in this environmental impact statement and Forest Plan through use of the implementation checklists.’ The checklist analysis process would allow additional environmental mitigations, but would not allow any of the protection measures in the EIS to be deleted, nor allow activities or activity locations outside of that describe in the EIS, nor allow activity disturbance quantities to exceed those analyzed and incorporated in the ROD. Baseline information has been provided throughout the document. Precedence for this type of landscape analysis was established by Tennessee Creek and accepted by the federal courts in July 2017. The use of adaptive management alternatives and analysis is also codified in federal regulations in 36CFR220. An adequate level of site-specificity was provided to move forward with the analysis, and baseline information is adequate for the following reasons: 1) Analysis was performed in identifying proposed actions (both primary and associated), as well as activity disturbance locations and quantities (see EIS section 1.3-Background). These actions were fully described in the proposed action and action alternatives, including quantities. Location of activity disturbances determined through this process are recorded in the project geodatabase, which was used for environmental impacts analysis as well as public scoping and disclosure. It was also displayed by alternative in section 2.2-Alternatives Considered in Detail. 2) project-specific field reconnaissance was performed to extent possible. 3) Data collection within the project area has been performed over decades and recorded in various agency records and databases. These include soil inventories and mapping, road inventories and mapping; vegetation inventory, mapping, and modeling (including sensitive plants); stream and

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Letter # - Comment and Response to Comment Comment # wetlands inventories and mapping; wildlife observations, inventories, and mapping; wildlife habitat modeling, mapping, and verification; topography mapping (including slope, aspect, and elevation); insect and disease inventory and mapping; management area delineation and mapping; heritage resource inventory, mapping, and modeling; past fire disturbance inventory and mapping; and past management activity inventory and mapping (including fire suppression activities). All of these data collection sources were considered at appropriate levels in the analysis of this project, with conclusions recorded in the specialist reports and summarized in chapter 3 of the EIS. 4) Modeling of activity influences on resources, as informed by the previously mentioned datasets, are adequate to provide reasonable assessments of outcomes. 5) Previous environmental analyses and activities have been conducted recently within the same project area, at smaller scales, for the same forest type and same disturbance event. These analyses and activities are briefly described in section 1.3-Background, in section 3.2- Silviculture & Forest Products, under Forest Health and Species Composition, and recorded in appendix I of the EIS. These ongoing analyses and observations provide a strong basis for the evaluations made in this project. Uncertainly does not preclude action or define a set scale of analysis within the National Environmental Policy Act; it only must be disclosed along with the associated risks, which the EIS has done throughout, including acknowledgement of database limitations. See response 20-28 for additional discussion concerning site-specific analysis. 20-144 The adaptive management approach relied on in this analysis is inconsistent with the agency’s own rules defining adaptive management. The Forest Service describes adaptive management in this analysis as a process to monitor, learn, and adapt during and after implementation of specific projects. But here the Forest Service fails to provide clearly identified outcomes, explaining for many resources it will determine the intended outcomes at the time of individual project implementation. The Forest Service fails to outline sufficient monitoring to determine if its actions are meeting those outcomes, or provide a mechanism to facilitate management changes when needed. Response: Intended outcomes are ultimately based upon the direction in the RGNF Forest Plan in statements of desired conditions, goals and objectives, which are identified specific to the CPDWS project in the EIS, section 1.5, Forest Plan and Other Direction. The adaptive implementation process allows for desirable outcomes by adapting to changed conditions, integrating information as it is obtained or is approved and providing for internal and public feedback during the life of project implementation, all within the scope of this analysis and the Record of Decision (EIS, section 2.2). This is consistent with the definition and intent of adaptive management (36CFR220.5). As a result of this comment, monitoring measures, adaptive actions (adjustments), and the effects of the adjustments have been placed in a table (EIS, section 2.5) for clarity. An adaptive implementation roadmap has also been added to the EIS (section 2.2) to explain how monitoring and feedback will be incorporated into the adaptive management process.

Project Design Criteria and Monitoring Letter # - Comment and Response to Comment Comment # 2-6 While we agree with adaptive management, we are concerned that the pre-implementation checklist 3-6 may result in additional specific design criteria that will not be subjected to a public review process. Design criteria can significantly affect project feasibility; therefore, we request the opportunity to review any new design criteria before they are approved are included in a contract (DEIS, p. 23). Response: As a result of this comment, additional steps were added to the adaptive implementation process to ensure opportunity for public feedback. 2-10 Snags: Alternative 2 requires a minimum of 4 spruce snags per acre in various conditions of decay. 3-10 We request this design criteria be changed to reflect the standard as written in the Rio Grande NF Forest Plan, which is a minimum of 2 snags. Based on Table 22, reducing the snag requirement to 2

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Letter # - Comment and Response to Comment Comment # will still allow snag numbers across the landscape to exceed the minimum Forest Plan standards by at least double. Response: You are correct in that the current snag retention requirements are “minimums”, not targets. The minimums can therefore be exceeded where desired and needed based on various site conditions or other information updates. Wildlife require specific stand characteristics at various spatial scales. Within the multiple-use mandate, timber production areas should also provide habitat values for wildlife species. The 1996 Forest Plan relied on Balda (1975) which reflects needs of cavity nesters in mature (live) ponderosa pine forests, not beetle-killed spruce-fir. Abundant research since 1975 has since suggested higher snag retention guidelines, particularly after a large disturbance event. 2-13 Soil Resources: we recommend the 3rd design criteria be changed to reflect the standard as written in 3-13 the Rio Grande NF Forest Plan, which is 10 – 15 tons/acre of coarse woody debris for spruce/fir. We disagree with using the coarse woody debris requirement as justification to require limbs and or tops to be returned if 15% or more of the Unit has exposed mineral soil. In some instances, having bare minimum soil will be necessary to establish regeneration and given the over 90% mortality in most units, there will be more than enough coarse woody debris in a unit following salvage. Response: The Coarse woody debris standard is not the justification for this project design criteria. It is derived from the Soil Productivity standard 2:’ Maintain or improve long-term levels of organic matter and nutrients on all lands,’ and guideline 1: ‘On soils with topsoil thinner than 1 inch, topsoil organic matter less than 2%, or effective rooting depth of less than 15 inches, retain 90% or more of the fine (less than 3 inches in diameter) logging slash in the stand after each clear-cut and seed tree harvest, and retain 50% or more of such slash in stand after each shelter-wood and group selection harvest, considering existing and projected levels of fine slash.’ It also helps with erosion control, but is primarily a soil nutrient/productivity protection as much of the nutrients are present in the fine slash and are more readily available to reforestation than are coarse woody debris. 20-130 In its project design criteria, the agency states that if any threatened, endangered or sensitive species are discovered in the project area during implementation, they will be protected pursuant to the Forest Plan or, at that later time, the Forest Service will initiate consultation with FWS as necessary. As noted above, whether a listed species or its habitat is present in the project area is the type of information that must be provided to the public as part of the environmental baseline. Response: This discovery PDC is specific to any new observations or designations that occur during the implementation phase, i.e. after the decision document is signed and surveys are ongoing. The Forest Service cannot provide information that does not yet exist. Refer to the BA for information on listed species present in the project area, implementation checklists, as well as the re- initiation criteria for consultation with FWS. 36a-8 We fail to see the results of monitoring from all the recent salvage sales on the Conejos Peak District –especially post-project regarding suitable lynx habitat. Has this been done, as required in every NEPA document? (i.e. areas near La Manga, Grouse, Trujillo Reservoir, Cumbres Pass, Neff Mountain, etc.–Country Line and many other projects). What is the result of monitoring of these projects? We are concerned that post-sale monitoring has not been done and violates the NEPA decisions of several projects. Please respond to this concern (Effected acres monitoring, etc.). Response: Post-project monitoring is an ongoing process and the results of post-harvest lynx habitat monitoring, including site visits and monitoring plots, have been incorporated into the baseline for the CP District Wide Salvage. Post-project monitoring can be limited by the speed in which the purchaser operates, such that it could take several years to incorporate. However, at the moment the decision is signed, the anticipated post-project impacts are incorporated into an updated environmental baseline such that each future project is using the most updated information.

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Range of Alternatives, Purpose and Need, Desired Conditions Letter # - Comment and Response to Comment Comment # 1a-1 The public (who own the Conejos Peak Ranger District) asked Ranger Jones to seriously consider 1a-2 and analyze the following alternative in detail. “Focus vegetation treatment only in areas to protect infrastructure – This alternative only addresses hazardous fuels reduction and would not meet the purpose and need of capturing economic value of dead and dying trees while there is still value.” (pg. 21) “Mechanical treatments only in wildland urban interface areas with no temporary roads – This alternative would not meet the purpose and need of recovering economic value from dead and dying trees. Furthermore, it would only partially meet the need to reduce hazardous fuels near developed private lands and infrastructure.” (pg. 21) “Use pheromones to manage the beetle epidemic – This alternative would not meet the purpose and need of salvaging economic value from timber or reducing hazardous fuels. In addition, the majority of the spruce trees have already been killed by the spruce beetle, therefore pheromones would be of no benefit.” (pg. 21) Response: Explanations for why these alternatives were considered but eliminated from detailed study are found in Chapter 2, section 2.1 and restated in this comment. See also the response to 20- 23. 1a-4 The P&N should have been rewritten to eliminate the spruce salvage which is not ecologically justified. Response: See response to 20-17 2-1 Overall, we concur with the Purpose and Need and we recommend that you implement 3-1 Alternative 2, the preferred alternative, with the caveat that our comments below are incorporated into the Selected Alternative. Response: Thank you for your support of the project. 2-2 Alternative 2 is our preferred alternative. Alternative 2 best meets the needs for sawtimber supply, 3-2 while still also providing important protections for public health and safety, implementation flexibility and protection for Canada lynx by staying below the lynx caps set forth in the Southern Rockies Lynx Amendment. The reasons to choose the proposed action are: Salvages the most acres (17,000) as well as provides opportunities for hazardous fuels work (1,000 acres); provides 340,337 ccf compared to 189,906 ccf in Alternative 3; Alternative 2 is the most cost effective, has the highest benefit to cost ratio, and is the only alternative with a positive net present value; by treating twice as much of the spruce forest, Alternative 2 provides the greatest ability to move the forest towards desired conditions such as species diversity, age-class diversity, and structural diversity. Response: Thank you. The decision maker will consider all assessments and input in determining the selected alternative. 5-1 Alternatives are stated to have been developed to address one issue found after public scoping the project in February, 2016. The one issue appears to be Lynx habitat preservation. In addition the analysis in the EIS discloses “the cumulative effects of implementing commercial and non- commercial management activities to meet the purpose and need and move forward desired conditions in the project area.” What are the desired conditions, who developed them, and how were they developed? What are the criterion of goodness for these desired conditions? Response: Desired conditions, as well as the location and extent of each Management Area Prescription (MAP) to which they apply, are defined by the Revised Land and Resource Management Plan for the Rio Grande National (Forest Plan). The Forest Plan is the guiding document which is the basis for all management activities that occurs on national forest lands. Desired Conditions are specific to each (MAP) within the project boundary. They were developed by the Forest Service, through the Forest Plan revision process, with the assistance and input from an involved public. The criterion for ‘goodness’ was established through the public process and is not determined or established by a specific project. For a review of the desired conditions that are addressed by the project, as well as those that are not, see sections 1.3-1.5 of the EIS. 5-4 In the Summary section of the EIS, under the No Action alternative it is stated “No Action would not benefit the local forest products industry.” This statement implies that benefiting the local forest products industry is a criteria of goodness. Yet, in no section of the EIS is there an evaluation of how local industry benefits are balanced against other public good criterion. This seems contrary to 271 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # the Forest Services’ overall goal of managing our National Forests to maintain long term flow of lumber materials balanced against the public good criteria. How does this project benefit the balance? ISSUE Response: In a project environmental analysis, each alternative is measured against specific elements to give the decision maker a comparison between them. Those elements include tangible measures for 1) meeting the project purpose and need and 2) affecting the identified issues. The effects of the proposed action and alternatives on other resources are also evaluated and disclosed in chapter 3 and encapsulated in the document summary. The reference text addresses how the No Action alternative compares to the project purpose and need. Another statement in the summary says, “The action alternatives would have some short-term (approximately 15 years) disturbance effects during harvest activities to soils, watersheds, wildlife and some Forest users.” A project can only address a portion of the broader management direction for the Forest, which is provided by the Forest Plan. The Forest Plan provides the balance for how one piece of the providing for public good (in this case, providing forest products and performing hazardous fuel treatments) fits in with other pieces of providing for public good. The Forest Plan does so by providing Management Area Prescriptions, Desired Conditions, Standards & Guidelines, and Allowable Sale Quantities, among other things. The evaluation of how local industry benefits are balanced against other public good criterion is addressed in the FEIS of the Forest Plan. This project contributes toward that balance by addressing some portion of the management direction and staying within the parameters established by the Forest Plan. As a result, it is not contrary to the Forest Service’s overall goals. 20-14 An agency may not “define a project so narrowly that it forecloses a reasonable consideration of alternatives.” Fuel Safe Washington v. Fed. Energy Regulatory Comm’n, 389 F.3d 1313, 1324 (10th Cir. 2004); Citizens’ Comm. to Save Our Canyons v. U.S. Forest Serv., 297 F.3d 1012, 1030 (10th Cir. 2002). Here, the Forest Service’s statements of purpose and need for this project are too narrowly drawn, impermissibly limiting the range of alternatives considered. The agency also fails to provide support for its claimed needs. Response: The Purpose and Need for Action for the CPDWS project is explained in Chapter 1 of the EIS. The range of alternatives considered to meet the purpose and need for this project are defined in Chapter 2, section 2.1, Alternatives Considered but Eliminated from Detailed Study, and section 2.2, Alternatives Considered in Detail. See response to 20-23. 20-15 The Forest Service states the purpose of the project is “to utilize salvage logging in spruce stands impacted by tree mortality to protect against the loss of forest products while perpetuating landscape resiliency and diversity, reducing hazardous fuels near private land and infrastructure, and to meet or move existing resource conditions toward desired conditions.” DEIS at 12. The overarching statement of purpose and need is based on what seems to be a very speculative assumption about future conditions on the forest, unsupported by evidence. Response: The purpose and need for the CPDWS project was developed based on recent experiences with the high occurrence of spruce mortality activity and effects, and, the uncharacteristic large, severe wildfires that have resulted from the regional drought in the early to mid-2000s. The forest-wide spruce beetle outbreak has affected over 500,000 acres on the RGNF and the 2013 West Fork Fire complex burned over 90,000 acres. Similar large disturbances and extensive tree mortality have occurred in response to the drought in other western forests in Colorado and surrounding States. The evidence required to support the need to respond already exists and continues to occur in spruce forests on the RGNF (see Silviculture and Forest Products specialist report). The deviation between current conditions and desired conditions for a number of resource benefits, based on Forest Plan and management area direction, drove this proposal. 20-19 The alternatives analysis is the “heart” of NEPA, and therefore “an agency must on its own initiative study all alternatives that appear reasonable and appropriate for study at the time, and must also look into other significant alternatives that are called to its attention by other agencies, or by the public during the comment period afforded for that purpose.” Dubois v. Dep’t of Agriculture, 102 F.3d 1273, 1291 (1st Cir. 1996), quoting Seacoast Anti-Pollution League, v. Nuclear Reg. Comm’n, 598 F.2d 1221, 1231 (1st Cir. 1979) (emphasis from Dubois court) (internal citations omitted). An 272 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # agency “should present the environmental impacts of the proposal and the alternatives in comparative form, thus sharply defining the issues and providing a clear basis for choice among options by the decisionmaker and the public.” See 40 C.F.R. § 1502.14. Thus, an agency must “[r]igorously explore and objectively evaluate all reasonable alternatives.” See 40 C.F.R. § 1502.14(a). Here, the Forest Service considers three alternatives: the no action alternative (Alternative 1) and two action alternatives (Alternatives 2 and 3). Alternative 2, the proposed action, would include vegetation management on up to 17,000 acres, reopen 35 miles of non-system road templates, and construct 32 miles of new temporary roads. DEIS at 23. Alternative 3 would include vegetation management treatment on up to 8,500 acres, reopen 34 miles of non-system road templates, and construct 23 miles of new temporary roads. DEIS at 26. Response: The Forest Service did study all alternatives that appeared reasonable and appropriate, and explains why other alternatives were not considered in detail (FEIS, section 2.1). The agency did present the impacts of alternatives in a comparative form, with a well-defined issue and clear basis for choice (FEIS, sections 1.9, section 2.3, chapter 3). Therefore the agency did rigorously explore and objectively evaluate all reasonable alternatives. 20-20 The Forest Service fails to consider an action alternative that would decommission unneeded forest roads, reopen less than 34 miles of non-system roads, or construct less than 23 miles of new temporary roads. The agency fails to consider a reasonable range of alternatives, especially considering the road activities proposed under each of the action alternatives. Response: The CPDWS project proposal is focused on vegetation management, not travel management, and therefore did not analyze forest system road needs or decommissioning. The temporary road construction proposed in the action alternatives for this project may need to be constructed in order to achieve project objectives. As stated in chapter 2 of the EIS, no new system roads would be constructed under any action alternative and all roads currently closed to public motorized travel would remain closed. Temporary roads would be appropriately closed following project activities (see EIS, section 3.17, Transportation). A process associated with the RGNF Forest Plan Revision will occur to address potential changes in travel management forest-wide. The CPDWS project pre-implementation checklist provides for specialists’ recommendations into future travel management decisions to achieve forest-wide goals and objectives for watershed health, etc. See also a summary of resource effects from project activities in chapter 3 of the EIS. 20-21 The Forest Service also impermissibly eliminates certain reasonable alternatives as not meeting all 20-23 of the extremely narrow objectives stated in the purpose and need. For example, the Forest Service eliminates the proposal to use mechanical treatment only in wildland urban interface (WUI) areas and to not use temporary roads because it would not meet some of the objectives. DEIS at 21. But this alternative would meet some of the objectives, and therefore should be considered at least as a component of one of the reasonable alternatives. The Forest Service should consider a full range of alternatives with the proposal, including but not limited to: A genuine forest health proposal that would decommission or close roads and promote natural regeneration; A proposal that only proposes mechanical treatment in a reasonably defined WUI; and, an alternative that requires no road construction or reconstruction. Response: The range of alternatives evaluated was determined adequate to meet the purpose and need identified for this project and address the issue identified (EIS, sections 1.4, 1.9). The range of alternatives considered are found in Chapter 2, section 2.1, Alternatives Considered but Eliminated from Detailed Study, and section 2.2, Alternatives Considered in Detail. Collectively, these represent a reasonable range of management options for this project and therefore comply with NEPA direction. The Responsible Official may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 36-6 …Provide an alternative that does more to promote lynx, the watershed and reduce the miles of road network needed for this project to comply with water and soil and wildlife protections in the Forest Plan and NEPA and ESA. Response: Alternative 3 provides additional protections for lynx while still meeting the purpose and need and providing timber products. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public 273 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives.

Timber Operations and Activities Letter # - Comment and Response to Comment Comment # 1a-5 Insect activity in mature lodgepole pine LPP (80+ years) is part of the natural cycle of this tree through species. Given that LPP has serotinous cones, insect activity and subsequent fire is the natural 1a-9 process that allows LPP regeneration. Stands of LPP contain key habitat for a variety of birds and mammals unavailable in other forest ecosystems. LPP is a native species. Harvesting dead and dying LPP will not stop the spread of the Mountain Pine Beetle. Harvesting dead and dying LPP increases the fire hazard. Harvesting dead and dying LPP creates unacceptable natural resource damage within the cutting units. Response: See Appendix K.1 for responses to opposing views comment letter attachments. No lodgepole pine treatment is proposed in this project. 1a-13 It’s clear that the line-officers on the Rio Grande National Forest did not learn from the Agriculture 1a-21 Department's inspector general’s findings based on a 1999 audit of the USFS timber program. The first sentence of the New York Times article describing the audit findings says this: “Federal auditors have found that the Forest Service frequently fails to assess, prevent or correct environmental damage from logging on the national forests.” The complete text of the NYT disclosure can be read at the following link: http://www.nytimes.com/1999/02/05/us/audit-faults-forest-service-on-logging-damage-in-us- forests.html Here’s the same information reported by the National Center for Policy Analysis: http://www.ncpa.org/sub/dpd/index.php?Article_ID=12468 Here’s the text of the audit: https://www.usda.gov/oig/webdocs/088011.pdf This DEIS smoothes-over and is sometimes silent about the environmental damage caused by logging and roading the CP Salvage timber sale. Response: This 1999 Office of Inspector General Evaluation Report reviewed 12 environmental assessments (EAs) and field checked 12 timber sales; at least some of the projects selected were the result of complaints submitted to a “hotline”, so did not necessarily represent an unbiased cross section of USFS projects. However, one of the primary findings discussed included environmental mitigation measures that were not implemented as stated in the EA and other disconnects between the EAs/Decision Notices and implementation to ensure resources are protected. For the CPDWS project, resource specialists have evaluated project effects for each alternative, assuming that all project design criteria, and standards and guidelines would be implemented along with all the other elements included in the adaptive implementation process described in section 2.2, EIS. There is an administrative control process in place with defined areas of responsibility to reduce the likelihood of projects being implemented inconsistently with the environmental analysis or decision document. For example, the Responsible Official must certify that all timber sale contract clauses for environmental protection are included in the contract as specified in the environmental analysis (see pre-implementation checklists, EIS, appendix C). This process, along with other administrative controls and implementation monitoring has generally been effective to ensure resource protection during implementation. 1a-39 Harvesting Dead Lodgepole Pine to Eliminate Mountain Pine Beetle Activity in the Project Area is not Effective and Eliminates the Beneficial Resource Benefits Caused by this Natural Disturbance Event. The same is true for spruce.

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Letter # - Comment and Response to Comment Comment # Insect activity in mature lodgepole pine LPP (80+ years) is part of the natural cycle of this tree species. Given that LPP has serotinous cones, insect activity and subsequent fire is the natural process that allows LPP regeneration. It’s supposed to happen! Stands of LPP contain key habitat for a variety of birds and mammals unavailable in other forest ecosystems. LPP is a native species in the area of the proposed project. Response: See Responses to Opposing Views at the end of this appendix. No lodgepole pine treatment is proposed in this project. 1a-40 The CP District Wide Salvage sale will take away more undeveloped national forest acres from the legacy the unborn kids of the future should inherit. Which is most important: the future kids of America seeking solitude and quietness, or another summer home and yacht for the CEO of the timber extraction corporation that purchases this timber sale? Do the IDT members have the courage to ask themselves why the USFS defies the wishes of the American public by logging and roading-up the precious national forest land? How can an agency mandated to serve the public do so by taking action the public does not want or like? There is a reason the USFS euphemizes the word logging. They think using the terms “timber harvest” and “treatment” will trick the public into believing that ravaging the forest with skidders, tractors, chainsaws and poison herbicides is what should be done to “manage” the forest. Are you proud to also contribute to this plunder? Response: This comment has no basis in truth. No further action was taken based on this comment. 2-5 While we understand the completion of all the activities associated with this project may take 10-15 3-5 years (DEIS, p. 23), we urge you to implement the salvage portion of the project much faster, by selling all timber sales in the next two years. Response: Thank you for your recommendation. If any sales result from this project, they will be prepared as quickly as possible, in order to capture salvage value while it exists. 2-8 While we understand the need and desire to set areas aside for public firewood gathering, wherein 3-8 no commercial harvesting will occur (DEIS, p. 48), we ask that you carefully choose these areas and consider the impacts to the purchaser(s). Blocking off all the areas closest to roads will make the project less feasible because the purchaser ends up with longer skid distances. We ask that you consider waiting until a unit is complete and then opening up the area for 3 firewood gathering. Due to the nature of the stands being harvested, a lot of material in the units ends up not being utilized and put into piles. These units would make a great area for the public to gather firewood. Response: The district will be careful in choosing where to designate public firewood gathering areas and acknowledges the availability of secondary products after commercial timber sales close. 2-9 P. 49 – please change the DEIS to acknowledge that Engelmann spruce will lose much of its sawlog 3-9 value within 5 years of mortality. Response: Clarification was added to the paragraph concerning the deterioration and merchantability of dead spruce. 2-11 While we agree that winter logging is important, not all logging can be done in the winter. We ask 3-11 that you include language in the DEIS that states that logging during other seasons may be necessary based on conditions, and modify the dates in the Design Criteria to allow summer and fall logging. Response: We affirm that logging in spring, summer, and fall will be necessary. Neither of the action alternatives (Project Design Criteria included) preclude logging in those seasons. The only date restriction is on winter logging activity (i.e. over snowpack or frozen ground conditions) after May 1, unless within 200 feet of a yurt or yurt access ski route. Winter logging is not required by the PDC, but encouraged, due to its multiple resource benefits. 4-1 Trout Unlimited supports responsible timber harvest on public lands and the Conejos Peak District -wide Salvage Project specifically. We commend the Rio Grande National Forest for their efforts to analyze the impacts, positive and negative, to watershed health, hydrology, and fisheries in the draft specialist reports. Response: Thank you for your supporting the project’s objective of responsible timber harvest, as well as our efforts to analyze the impacts of the proposed activities. 5-3 The phrase “commercial harvest treatment activities” is used often in the EIS. How does such activities differ from standard commercial logging, cutting, transport and sale operations? CONCERN 275 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: ‘Commercial harvest treatment activities’ was used once in the document summary and is equal to all activities associated with standard commercial logging. ‘Commercial harvest’ was used throughout the document to distinguish the activity from ‘pre-commercial thinning’ and ‘fuel break thinning,’ from which no commercial product is derived. ‘Commercial harvest’ does not differ from standard logging operations. 5-7 It is noted that the private property of Silver Lakes is located below and northeast of proposed significant Red Mountain salvage and hazardous fuels treatment areas. Silver Lakes’ water supply is from mountain springs located in that part of Silver Lakes’ property closest to Red Mountain. How will the salvage and hazardous fuels treatment under either Alternative 2 or 3 impact the quantity or quality of the spring water supply at Silver Lakes? ISSUE Response: No harvest or fuels treatment areas are proposed within one mile of the Silver Lakes property. Project design criteria have also been incorporated in the project to protect streams, wetlands, and hydrology, as well as prevent erosion and sedimentation. As a result, no impacts to the quality or quantity of Silver Lakes’ spring water supply are expected. 7-1, 8-1, I am writing in support of CP District‐wide Salvage Project and the preferred alternative 9-1, 10-1, (Alternative 2), with the request that additional requirements as outlined in Alternative C will NOT 11-1, 12- be included. I believe this project is critical to recovering economic value while at the same time 1, 13-1, reducing fire risk and protecting infrastructure. Salvaging dead and dying trees will protect the area 14-1, 15- protected from uncharacteristically large and intense wildfires. Additionally, being able to complete 1, 16-1, necessary road work and maintenance will help address the water quality issues associated with 17-1, 18- poorly maintained roads. This project will also truly benefit the local economies in terms of jobs and 1, 19-1, supply to the local forest product companies. 21-1, 22- Response: Thank you for your support of the project, as well as the feedback concerning your 1, 23-1, preferred alternative and the benefits of implementation. 24-1, 25- 1, 26-1, 27-1, 30- 1, 31-1, 32-1, 33- 1, 34-1, 35-1 7-2, 8-2, Unfortunately, much of the Rio Grande National forest has experienced a widespread spruce beetle 9-2, 10-2, epidemic, which has killed the majority of the mature Englemann spruce across the forest. It is 11-2, 12- critical that salvage operations be implemented quickly (within the next 1‐2 years) so as to capture 2, 13-2, some economic value from the dead and dying trees, and to aid in the removal of fuels that will 14-2, 15- likely increase the intensity and severity of wildfire if it occurs. 2, 16-2, Response: Thank you for your recommendation. If any sales and fuels treatment activities result 17-2, 18- from this project, they will be prepared as quickly as possible, in order to capture opportunities 2, 19-2, while they exist. 21-2, 22- 2, 23-2, 24-2, 25- 2, 26-2, 27-2, 30- 2, 32-2, 33-2, 34- 2, 35-2 20-78 The Forest Service should consider the potential for windthrow and subsequently exacerbated spruce-beetle infestations, as well as potential for the proposed management activities to spread noxious weeds. Response: Windthrow and the potential for subsequent spruce-beetle infestations was considered and addressed in section 3.2-Silviculture & Forest Products, under Alternative 2 Forest Health and Species Composition. The comment missed the assessment in sections 1.3 and 3.2 that a minimum of 85% of the spruce stands within the district are already impacted by beetles, and that remaining habitat will be infested within the next 2-3 years. The potential for the spread of noxious weeds is 276 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # also acknowledged and addressed within the EIS, in section 3.10, as well as the project design criteria. Anywhere soil disturbance occurs, whether man-caused or natural, there is a risk for noxious weed spread. As a results, environment consequences can be reasonably assessed at this level of analysis. 20-145 This project is not realistic, given the likely condition of wood to be offered for sale. through Response: Wood condition is at varying stages of deterioration across the project area, and even 20-148 within individual stands, as beetle populations have generally moved across the landscape in a northeasterly direction, but have also hit individual stands over multiple years. In general, wood condition is best at the northern end of the district and most deteriorated at the southern end of the district. Discussion of the outbreak timeline is addressed in section 3.2, as well as wood deterioration rates post-mortality. Salvage sales are currently viable, and deterioration rates into the near future could foreseeably be balanced by demand and market value in the currently strong economy. Either way, the action alternatives will address the purpose and need for the project by protecting to the extent possible against the loss of forest products and reducing hazardous fuels near private land and infrastructure. Alternative 2 provides the greatest capacity to do so. It should be noted that project completion includes post-harvest activities, such as planting. It actually is possible to cut wood in all of the areas within the time spans noted in the EIS. It is currently expected that most of sales that could come out of this project could be sold within the next 4 years. 20-149 Who would buy the wood offered for sale from the proposed project? The DEIS (p. 12) cites a study in the current (1997) Forest Plan as demonstrating the “ongoing demand for wood and miscellaneous forest products such as firewood and poles”. However, much has changed since that analysis was conducted. A major mill in South Fork, CO and several smaller ones have closed. Spruce beetle attacks and the subsequent deterioration of wood quality was not an issue then. Thus this analysis cannot be used for any future projects. Indeed, it appears a new demand analysis is being done for the proposed revised forest plan. See more below. Even assuming that desirable product(s) is/are made available, there may be only one mill that could purchase any large sales from the project area. And even it, the mill in Montrose, CO, is likely to be saturated with opportunities to buy dead standing Englemann spruce. Much dead spruce exists on the GMUG NF, which is closer to the Montrose mill than anything on the RGNF. Also, most of the dead spruce on the GMUG, some of which will be offered from the SBEADMR Project, has probably not been dead for as long as the timber in the Conejos Peak area, so anything on the GMUG might be more attractive to any potential buyers. Response: There are approximately 7 purchasers from southern Colorado and northern New Mexico that are currently bidding on salvage sales on the Conejos Peak Ranger District. They market a variety of products; primary products include sawlogs and house logs, secondary products include firewood (often sold by the log truck load), animal bedding and pellets from the waste. The district has not had a salvage sale go ‘no-bid’ since 2008 when the recession hit. Only one ‘no-bid’ sale occurred then. These facts confirm that the assertions from the analysis questioned are still correct, even if the parties involved have changed. It is appropriate for a new demand analysis to be performed during a forest revision process, because that is what the revision process is all about- maintaining currency. 20-150 Id. at 128. Demand for housing is uncertain. Given the current efforts to reduce overall federal through spending, it is unlikely there will be sufficient money to prepare and offer anywhere near all of the 20-152 timber that it would be theoretically possible to offer if projects like CP (Conejos Peak) Districtwide Salvage and Del Norte Peak are approved at their current proposed volumes. If the project proceeds, the EIS must: a) document that the wood salvageable from the project area can be made into one or more a commercial products; b) that the demand for such products is strong enough that a project the size proposed here is justified; c) that money will likely be available to prepare and offer the proposed volume, or at least a majority of it; and d) analyze the cumulative impacts of all of these projects. For (b), (c), and (d), you must consider other projects under analysis or already being implemented that would probably provide a large volume of similar-quality wood and potential finished products, including, but not limited to, the Del Norte Peak and Groundhog Park Projects. The DEIS lists numerus ongoing salvage projects in the project area. Id. at 52-53. It is hard to 277 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # imagine how the wood from all of these projects, plus the CP project and others like the Del Norte Peak and Groundhog Park projects could be used by existing mills, even if all of it is sound, which it likely won’t be. Response: The Forest Service will do the best it can with what it’s given. We expect to be able to prepare the sales that could come out of this project, having Region Office support. See response 20-77 concerning uncertainty, which also pertains to markets and budgets. See response 20-149 concerning industry demand and products. Concerning cumulative effects, this project plus other similar projects across the Forest, both on-going and under analysis, will ensure that an adequate supply of forest products is available to the forest products industry. Providing an adequate supply will not have a negative socio-economic impact on the industry of concern. Purchasers are expected to become more selective in which sales they bid on (dependent upon demand and market prices), but such choices are outside the purview of the Forest Service. Sales from this district are expected to fare well among other sales offered from the Forest, due to larger volume per tree and volume per acre available on our sites. The influx of salvage offer now will have no effect on out-year wood supply from the Forest, because as noted in comment 20-146, there is a set window of opportunity, after which value will be lost, whether offered through this project or not. Offer of dead and dying forest products now postpones, to a great extent, the offer of live forest products, ensuring as much continuity in forest products availability over time as the Forest Service has control over. 20-153 There is no point in spending taxpayer dollars to prepare large commercial wood that won’t sell. It seems very doubtful that there is sufficient demand to justify the large projects being proposed. Given the likelihood that most of the timber offered under the proposed action would not be merchantable, the Forest Service should consider an alternative that would cut only in areas to protect infrastructure, an alternative that the DEIS dismisses from detailed consideration (id. at 21). Given the circumstances, this is a reasonable alternative that must be examined to fulfill the mandate that “agencies shall…rigorously explore and objectively evaluate all reasonable alternatives”. 40 CFR 1502.14(a). Response: See responses 20-145 through 20-152 concerning the likelihood of selling. The alternative mentioned as not being considered in detail does not offer any forest products. The sentence referenced states, ‘Focus vegetation treatment only in areas to protect infrastructure – This alternative only addresses hazardous fuels reduction and would not meet the purpose and need of capturing economic value of dead and dying trees while there is still value.’ This alternative is not responsive to one of the two needs for the project; see response 20-70. The incorporation of logging into that dismissed alternative (i.e. logging only in protection areas, in addition to hazardous fuels treatments) is studied within the range of alternatives. The EIS discloses the overlap between the two activities as 330 acres within Alternative 2 and 129 acres in Alternative 3. Other areas cannot be added to this scenario due to topography, vegetation type, Management Area Prescription, or Colorado Roadless Area. From the analysis provided, the decision maker can choose all, parts, or none of activities proposed. It should be noted that comment 20-70 argues against the use of logging to protect against fire, but here argues that it is a reasonable alternative. 36a-11 Page 76 notes that salvage effects upon stands is highly dependent on pre-harvest conditions and operator skill in avoiding damage. This is a significant concern. I have photographed and monitored numerous past problems with logging contractors in the Trujillo Reservoir and Red Lake sale areas – including residual tree damage riparian damage, soil damage, trespass, etc. in the past 25+ years. How will the Forest Service ensure that logging operators comply with resource protection measures? We have seen a failure of over-sight in the past – what assurance do we have that there will be adequate Forest Service monitoring of the logging operators – especially since this project will last for at least 10-15 years? Response: Contracts have changed significantly over the past 25 years and provide a lot more “teeth” in incorporating and enforcing protection measures, including breaches and fines. Most of the contracts used today are over 150 pages long; having a great deal of mandatory stipulations. We are now also required to complete Timber Sale Reports for each sale, showing how each project design criteria was addressed by the contract or otherwise. We currently have two timber sale administrators on the Forest, whose full-time jobs are to monitor and manage timber sale activity and enforce the contracts. We are adding a third member to this team before the end of the year. We

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Letter # - Comment and Response to Comment Comment # also have one or more harvest inspector(s) on each district to help keep ‘eyes and ears” on the ground. These efforts are expected to maintain accountability and minimize infractions. 36a-12 Green tree blow down has been a problem in this District in the past (near Trujillo Reservoir, Grouse and other sales) there needs to be more done to minimize blowdown by not treating areas adjacent to stands of green trees or trees in exposed areas. Response: Green tree blowdown is a disturbance agent in all stands at these elevations, due largely to the shallow root systems on spruce and fir as well as exposure to high winds. Stands on northerly and easterly slope and at lower elevations generally tend to be less affected by the event. The influence of logging on blowdown is addressed in section 3.2 of the EIS. Efforts will be made during implementation projects to minimize blowdown to the greatest extent feasible. Not treating areas adjacent to stands of green trees is not usually feasible, because green fir is frequently a component of the forest overstory.

Fire, Hazardous Fuels Reduction and Wildland Urban Interface Letter # - Comment and Response to Comment Comment # 1a-12 Some IDT members understand the natural resources in the forest enjoy a splendid symbiotic relationship with each other. A few of them know (but won’t acknowledge to their peers) that natural disturbance events are beneficial to the countless resources in the forest in spite of the fact trees will die as a result of the fires, windstorms or insect activity etc. A few IDT members know wildfires in the general forest far from the WUI are not “catastrophic” as the agency portrays to the public. Response: The Forest Service acknowledges and agrees that natural disturbance events are important to the health and composition of our forest resources (See EIS, section 3.2). This proposal responds to the epidemic proportion of the current spruce beetle outbreak on the Forest and to Forest-wide desired conditions (FP pg. 1-1 states: habitat composition (including seral stage), structure, pattern (including connection), and disturbance frequencies similar to those that result from natural disturbances (insects, diseases, and fire) are maintained to the extent possible, given legal and policy limitations, and the desired condition for the area). It is the disparity between existing and desired conditions that drove this project proposal. In the EIS, wildfire risk is analyzed based on the increase in fuel loading from spruce overstory mortality and subsequent falling dead trees in spruce forests. This increase in fuel load on the forest floor and how it relates to fire intensity and severity are discussed in EIS, section 3.12, Fire and Fuels. 1a-17 The research conclusions of Dr. Jack Cohen (a USFS employee) explaining why and how logging is through an ineffective way to reduce fire intensity and rate of spread are contained in Opposing Views 19 Attachment #11. The USFS could hold workshops and distribute written information to WUI residents to explain Dr. Cohen’s methods so they could apply them to their property. The USFS could offer to remove fine fuels near homes in the WUI owned by handicapped and/or elderly residents with written permission. Ranger Jones, one of your fellow USFS employees’ research conclusions indicates fine fuels removal is far superior to commercial hazardous fuels logging farther away from the WUI than 100 yards, yet your draft EIS doesn’t mention Dr. Cohen’s research conclusions. Dr. Cohen states several times in the many scientific papers he authored that commercial fuels removal farther than “100 to 200” feet from the WUI in ineffective. Why then do you propose widespread fuels logging? Response: Responses are addressed in Appendix K.1 Responses to Opposing Views 1a-20 Request for changes to be made to the final NEPA document: Assure the Purpose & Need states this: “reduce the chance that homes will burn in the WUI should a wildfire start in the area.” This

279 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # would require you to include other effective fire risk reduction methods in the Proposed Action besides fuels reduction. Response: See Responses to Opposing Views, Attachment #11, response #1. Primary and ultimate responsibility for home wildfire protection lies with private homeowners. The Forest Service is mitigating hazards where and how it can. 5-5 It is common knowledge that Bark Beetle infestations in forests throughout Colorado and other States have produced extreme fire hazards through continuing annual accumulation of forest floor fire fuels from dead trees caused by natural phenomenon and Bark Beetle infestations where they have occurred. Yet, there is no explicit discussion of priority on Fire Hazards in this EIS. Fire hazard reduction is certainly a public and private good. Why has a priority on fire hazard reduction not been a focus in this EIS? The EIS document is so voluminous and complex that a reader is unable to audit a given issue or concern throughout the document. If this is the purpose of a comment phase in its production, the EIS is hardly transparent to even an informed reader. CONCERN Response: The fact that hazardous fuels treatment areas were identified across the project area, and that hazardous fuels treatment was identified as one of two prongs in the purpose and need for the project, does provide explicit discussion of priority on managing fire hazard. See section 1.4 of the EIS for additional discussion. ‘Acres of hazardous fuels treatment’ by alternative is included as an issue indicator in section 2.3, and hazardous fuels treatment guidelines are provided in appendix D of the EIS. Section 3.12 provides analysis of potential effects of tree mortality on fuel loading, torching index, crowning index, and canopy bulk density, as well as how fuels treatment activities might influence those factors adjacent to private lands. No priority must be given to fuels treatments projects over salvage projects, because both can and will be accomplished concurrently. Fuels treatments across the broader landscape were not proposed because: 1) The fire regime for the affected environment (spruce-fir) denotes that climate and weather conditions play a greater role in large fire development in this ecosystem than fuel loading (see section 3.12). This is different than the bark beetle infestations in other places. 2) Fuel treatments within this fire regime need to be completely mechanical (i.e. broadcast burning is not safe or feasible). Mechanical treatments have very high costs and must be focused around high-value assets. 3) Forest Plan standards preclude large-scale treatments of understory vegetation in this affected landscape, which is primary lynx habitat. 4) The insect which is causing wide-spread mortality on our district is the spruce beetle. It is a specialist which does not affect the majority of the tree species found within the more fire-adapted ecosystems on our district. Concerning the volume and complexity of the DEIS, as well as transparency, see response 5-8. 20-70 The Forest Service proposes salvage harvests for up to 17,000 acres under Alternative 2. The agency’s rationale is to retain economic value of dead and dying trees affected by spruce bark beetle 16 while perpetuating landscape resilience and diversity, reducing hazardous fuels near private land and infrastructure, and to meet or move existing resource conditions toward desired conditions. See, e.g., DEIS at 12. The Forest Service states that reducing long-term fuel loadings adjacent to private lands would reduce the risk for high intensity fires, DEIS at 2, and that using available dead and dying trees will provide for the protection of firefighters, users, communities, and private resources, DEIS at 12. But it presents no scientific information that supports the notion that salvage harvest reduces high-severity fire due to an increase in tree mortality from beetle-kill. Furthermore, research has shown that fire severity is not necessarily influenced by beetle infestations. Andrus, R.A, T.T. Veblen, B.J. Harvey, and S.J. Hart. 2016. Fire severity unaffected by spruce beetle outbreak in spruce-fir forests in southwestern Colorado. Ecological Applications. 26(3): 700-711. Response: The sentence referenced from the DEIS Summary at page 2 does not speak to reducing high-intensity fires across the landscape, but rather reducing high-intensity fire behavior within fuel break areas adjacent to private lands, so that target resources can be more safely protected. The associated activities are tied to Forest Plan direction related to firefighter safety and structure protection. This is stated more specifically in the body of the document in section 2.2, under 280 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Activities Common to all Action Alternatives: ‘…Establishment of shaded fuel breaks by thinning within 400 feet of private boundary or 200 feet of administrative sites. This activity would modify fuel profiles to reduce fire behavior and intensity to provide better opportunities for firefighters to engage the fire near structures, both public and private. Treatments would generally involve chainsaw work but may also include mechanical operations and chipping.’ This is reemphasized in section 3.5- Aquatics and Fisheries: ‘The fuel reduction treatments being proposed in WUI’s are outside of AMZ areas and should have minimal if any effect on aquatic habitats or fisheries resources. The intent of these treatments is to reduce the potential for high-intensity wildfires near private or administrative sites, which typically would not impact watershed and aquatic habitats.’ The effectiveness of the proposed treatments were modeled through FSVeg Spatial and discussed in section 3.12- Fire and Fuels. In relation to salvage logging, the EIS focuses on long term impacts from soil heating, fire duration, and the severity associated with large accumulations of surface fuels from dead spruce falling over the next 20-50 years. The referenced paper by Andrus, et al. talks about how burn severity related to live tree mortality (measured by Normalized Burn Ratio done through remote sensing) is more determined by climatic conditions rather than recent bark beetle activity (gray stage). In the discussion portion of the paper they did talk about the expected increase in surface fire severity in the “old stage” when more canopy fuel and snags have fallen to the forest floor. The sentence referenced at page 12 does not state that using available dead and dying trees will provide for the protection of firefighters, users, communities, and private resources, but rather, ‘The disparity between existing and desired conditions creates a need to utilize available dead and dying trees in a timely manner to meet multiple-use mandates and provide for the protection of firefighters, users, communities, and private resources.’ As written, it states two needs which the proposed action hopes to address: 1) a need to utilize dead trees in a timely manner to meet multiple-use mandates; and 2) a need to provide for the protection of people and private resources. In such a statement, the needs are distinct and tied to the Forest Plan direction; not to scientific claims of ecosystem needs and vulnerabilities. The effectiveness of how each alternative addresses the identified needs and the scientific basis for such conclusions are addressed in chapter 3 of the EIS as well as specialist reports. It should be noted that salvage harvest is intended to address one need, and hazardous fuels treatments are intended to address a separate need. This is articulated in both section 1.4- Purpose and Need for Action (see bullet statements) and section 2.2-Alternatives Considered in Detail, under Activities Common to all Action Alternatives (see bullet statements). In few instances would logging be used to reduce fuel loading within a fuels treatment area; overlap between the two activities is proposed on only 330 acres within Alternative 2. For additional discussion related to the purpose and need for the project, see response 20-17. 29a-2 It would also be useful for the Final EIS to include some information about the requirements for burn piles. Response: Information about burn piles was added to section 3.12, Fire and Fuels, under the direct and indirect effects analysis for Alternative 2 as a result of this comment.

Roads (system and temporary), Transportation and Travel Management Letter # - Comment and Response to Comment Comment # 1a-10, 1a- Temporary roads are constructed to allow log haul from a certain number of cutting units. When the 30 units are logged the temporary road(s) should be obliterated. The fact that you have 35 miles of 20-66 sediment producing “Non-system road templates” (a.k.a. old “temporary” roads) that currently exist 20-117 shows you plan to re-open and reuse your so-called “temporary” roads again, and again, and again... Clearly, line-officers on the Rio Grande National Forest do not construct temporary roads that are really temporary. You tell the public you will decommission your temporary roads after use. Your 281 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # decommissioning still leaves the running surface in place. You lie to the public by calling these roads “temporary” because you plan to use them again, and again, and again etc. The public knows you do this to avoid the construction and maintenance costs of system roads. You feel it’s justified to inflict aquatic resource damage to same money. Your IDT members who know better obediently sit on their hands and play the volume at any cost game. What assurances does the Forest Service provide that all temporary roads will in fact be decommissioned once logging activities are complete? How will this information be tracked, and will it be available to the public? Given the realities of declining funding for the Forest Service, and specifically for the enforcement of Forest Service regulations and other laws, the NEPA analysis must provide assurances that the Forest Service actually has the ability, money, and personnel to ensure that unauthorized use of temporary roads will not occur, and that the Forest Service will ultimately have the funds to address closure, decommissioning, and obliteration of any roads. With a full and fair disclosure of this information, the public and the decision maker will have a clear understanding of what exactly the Forest Service is proposing, and what steps it will be taking to remove the roads from the landscape. Road decommissioning can be done in a responsible way that returns habitat to its native form with time, however it can also be done in an irresponsible and environmentally destructive manner. Leaving it to chance at a later, undetermined time does not meet NEPA’s requirements. Further, a map must be produced showing where exactly these roads (whether new road, temporary road, or formerly closed recommissioned roads) are located. Response: No temporary road use is planned for the hazardous fuels treatment activities, and the majority of temporary roads used during timber sales are closed before contract termination by the purchaser through contract provision C5.35#- Closure of Temporary Roads. Standard closure methods include removal of culverts, in addition to placement of water bars at a given interval (based on slope) or pull back of stumps and slash onto the whole road surface, construction of earthen mounds at the entrance, and seeding with native grasses at a rate of 16.8 pounds per acre. In this scenario, no closure cost is incurred by the Forest Service. This method of temporary road decommissioning is effective in stabilizing the disturbed area to allow natural revegetation. During timber sale operations, all temporary and Maintenance Level 1 roads are closed to public use through contract provision C5.41#- Closure to Use by Others. This generally involves keeping gates closed at all times, but may also include use of road barricades. In some rare cases, a temporary road may not be decommissioned by the timber sale itself, for the purpose of providing planting crew access. For this to occur, the timber sale contract must specifically designate a temporary road in reference to contract provision B6.631- Temporary Roads to Remain Open. If a road has not been designated to remain open, it must by default be closed by the purchaser. In cases where the Forest Service will close the road after administrative use, it is done by method of subsoiling, waterbarring, and construction of earthen mounds. This method is also effective in stabilizing the disturbed area. On the various timber sales on the district that have been completed since the beginning of the spruce beetle epidemic, approximately twenty temporary roads have been used. Of those twenty roads, only one remains open for administrative reasons and is closed by gate. These protocols provide assurance that unauthorized use of temporary roads will not occur. There is no attempt to leave road decommissioning to chance or undetermined timeframes. A map was provided showing where these roads are located; see response 20-30. The Rio Grande National Forest has created a Forest-wide Travel Analysis Process (TAP) report, which “is a set of science-based recommendations for the forest transportation system, and is intended to inform subsequent National Environmental Policy Act (NEPA) processes, allowing individual projects to be site-specific and focused, while addressing cumulative impacts.” (USDA) Through this science-based process, the RGNF staff recommended a minimum road system and also identified unneeded roads, in accordance with 36 CFR 212.5 (US Government). Each road within the analysis area was recommended for either keep/maintain, storage, or decommissioning (see Appendix B for definitions). 1a-32 Request for changes to be made to the final NEPA document: Tell the public all temporary roads will be obliterated such that the terrain where the road was constructed “to a more natural state” 282 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # which means returning it to the condition it was before the road was constructed. This means the running surface will no linger exist except on flat ground. Also, please assure the final NEPA document includes a road obliteration monitoring plan to assure the sediment is being reduced as expected. The resulting draft decision documents should indicate the USFS will provide funding for monitoring and evaluation. Response: Effects analysis for roads, temporary and system, is in Chapter 3 of the EIS. Additional information can be found in the transportation specialist report in the project record. 7-3, 8-3, Public lands should be more open to the public with more roads and trails. Not lock it up and watch 9-3, 10-3, it burn like they did in the north west. Keep public lands public! 11-3, 12- Response: The purpose and need for this project focuses upon responses to the beetle epidemic and 3, 13-3, does not include decisions on opening or closing system trails and roads. Those decisions will be 14-3, 15- made through a forest-wide travel management process after completion of the Forest Plan revision. 3, 16-3, Non-system roads used during the project will be closed after use, because they are intended and 17-3, 18- designed for only the purposes expressed and therefore do not have a long-term need. 3, 19-3, 21-3, 22- 3, 23-3, 24-3, 25- 3, 26-3, 27-3, 30- 3, 32-2, 33-3, 34- 2, 35-3 1a-3, …Her [Ranger Jones’] decision to delay the decommissioning of roads that are closed and no longer 20-11, 20- used until FP revision is insane! She clearly has so comprehension of the sediment that will be 18, 20-22, generated between now and when the Plan is revised. 20-24 The Forest Service refuses to consider decommissioning roads as a part of this Project (discussed in sections 4, 5, 7 and 13, below) using the logic that the Forest Plan revision process will impact motor vehicle use on the Forest, so it would be “inappropriate” to address travel management issues as a part of this project. The Forest Service has a substantive duty to address its over-sized road system… The Rocky Mountain Region sent out guidance this year emphasizing that compliance with subpart A was not complete with publication of the travel analysis reports, but that forests should update their travel analysis reports as road management decisions evolve and the transportation system incrementally moves toward the desired social, economic, and environmentally sustainable road system. …Just as the commercial logging activities would achieve only part of the stated purpose and need, decommissioning closed forest system roads would achieve part of the stated purpose and need to perpetuate landscape resiliency and diversity and meet or move existing resource conditions toward desired conditions. Thus decommissioning closed forest roads should be considered in detail as at least a component of a viable, reasonable alternative.

The Forest Service should consider an alternative that would decrease total road system miles, consistent with the agency’s substantive duties under subpart A of its own road rules. Response: The purpose and need of this project is to salvage dead and dying spruce trees for economic value and to mitigate for hazardous fuels. The project does identify road maintenance opportunities to aid in overall watershed health (section 3.7, Hydrology and Watershed, section 3.17, Transportation). The decision to not address travel management in this project is consistent with the Rio Grande National Forest planning direction. The Forest has clearly expressed intent to complete the travel management process subsequent to the Forest Plan Revision process, after land-use decisions have been made (see Forest Plan Revision Draft EIS, pg. 12). Neither Regional nor Washington Office policy requires road decommissioning decisions to be made under this vegetation management

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Letter # - Comment and Response to Comment Comment # project. As a result of these comments, Implementation Checklist #2 has been updated to record recommendations for post-project travel management. 20-30 In terms of road activities, the Forest Service’s map of roads for Alternative 2 shows only the existing system roads. It fails to identify where logging will occur, what type of logging will occur where, and where roads will be re-opened or new temporary roads will be constructed [Figure 9 map insert, DEIS at 149]. Other maps of Alternative 2 show only existing and proposed new temporary roads, but fail to indicate system road numbers in relation to temporary roads. DEIS at 24-25. It is also unclear whether all existing temporary roads shown on the maps are proposed for use under Alternative 2. Between the map in Figure 9, DEIS at 149, and the maps in Figures 3 and 4 (DEIS at 24-25), it is unclear which existing system roads, existing temporary roads, and new temporary roads will be used as haul routes for this project. Response: The maps which display all activities associated with Alternative 2 are in the EIS chapter 2-Alternatives, under section 2.2-Alternatives Considered in Detail. They are Figures 3 and 4 which do include temporary roads and their relationship to national forest system roads. Although the system roads were not listed in the legend, they are displayed and labeled on the background map. The activities associated with Alternative 3 and their relationship to national forest system roads are in the same section, as Figures 5 and 6. These maps do display where logging will occur and where old roads templates will be re-opened or new temporary roads will be constructed. All temporary roads associated with the alternative, whether new or reopened old road templates, are displayed on these maps. The label at the top of each map states, ‘Proposed Salvage and Fuels Treatment Areas with old, Non-system Road Templates and Proposed New Temporary Roads.’ These maps have been re-edited for the FEIS to increase their quality, and additional maps have included in Appendix F. The type of logging that will occur is also described in section 2.2 under ‘Activities Common to all Action Alternatives.’ Only one type of logging is proposed for the whole project: salvage logging using ground-based equipment. The Figure referenced by the comment (Figure 9) comes from EIS chapter 3-Affected Environment and Environmental Consequences, section 3.17-Transportation. This section clearly states in the scope of analysis, ‘This analysis inventories and evaluates the existing National Forest System Roads (NFSRs) and evaluates roads managed by other entities within the 332,000 acre (519 sq. miles) project area. This report focuses on road treatments within the CPDWSP area. Road maintenance needed to accomplish the proposed vegetation management activities will be discussed.’ This figure was not intended to display all of the proposed activities, but the parts of the national forest transportation system that would be affected by the project. As such, it discloses which system roads will be used as haul routes. The sentence preceding the figure states, ‘Figure 7-1 [of the specialist report; displayed in the DEIS as Figure 9] illustrates the road system being used for Alternative 2 in the CPDWSP.’ The Alternative 3 discussion also notes, ‘Figure 9 illustrates the road system being used for Alternative 3 in the CPDWSP.’ Temporary roads are created and decommissioned by a project and are not part of the road system. As a result of this comment, minor edits have been made to section 3.17 and Figure 9 to correct typographical errors and add clarification. 20-31 and What previous NEPA decisions authorized the existing temporary roads? Why are they still on the 32 landscape, how long have they been on the landscape, and what assurances does the Forest Service provide here to confirm the same roads will be decommissioned within a time certain and not be used in future projects? Response: In only two places in the DEIS were some roads referred to as ‘Existing Temp [Temporary] Roads,’ which could be misunderstood as existing roads which were created by past management actions and never actually closed. This language was used in the map legends for both Alternatives in section 2.2- Alternatives Considered in Detail. As a result of this comment, edits have been made to the FEIS to clarify the map legends. The phrase otherwise used throughout the document is ‘re-use of old non-system road templates’ or ‘non-system road templates re-opened,’ which pretty clearly describes them as decommissioned features. In two places the phrase ‘old road’

284 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # was used; in section 1.6- Proposed Action Summary and section 3.5- Aquatics and Fisheries. In both instances the sentence was very clear that they were decommissioned features being re-opened. These non-system road templates include decommissioned temporary roads from past harvest activity; decommissioned system roads that were previously a part of the National Forest Road System; and some forest-user created routes. The majority of these features are no longer roads and are vegetated elements of the landscape; however the template is still distinguishable and it makes sense to strategically place activity upon these previously disturbed locations, thus re-opening them. Approximately 1.5 miles of road fall under the category of forest-user created routes. This project would provide the opportunity and mechanism for closing them. See response 20-117 for discussion concerning assurances of decommissioning. 20-33 The Forest Service fails to provide a map of system roads in relation to proposed treatments for Alternative 3 at all. See DEIS at 148-150. Other maps of Alternative 3 do not indicate all road numbers, which roads are system and which would be re-opened old roads or where new temporary roads would be constructed. DEIS at 28-29. Response: The Alternative 3 discussion in section 3.17 of the DEIS states, ‘Figure 9 illustrates the road system being used for Alternative 3 in the CPDWSP.’ This map showed system roads in relation to proposed treatments. See also response 20-30. As a result of this comment, additional maps have been added to Appendix F of the FEIS to more clearly display roads. 20-68 The agency must consider the effects of its proposal to use temporary roads when combined with the effects of its existing, official road system. Response: The EIS does consider the effects of proposed temporary roads when combined with the effects of its existing road system. Impacts of the alternatives on open road density, in relation to Management Indicator Species, are discussed in section 3.4-Wildlife. Both temporary and system road impacts in relation to aquatic habitats are discussed throughout section 3.5-Aquatics and Fisheries. Potential for impacts from temporary roads and system roads are discussed within section 3.6-Threatened, Endangered and Sensitive Plant Species. The Hydrology and Watershed report in section 3.7 discusses impacts and potential for impacts from all roads in the Direct and Indirect Effects assessment, as well as cumulative effects. GHG emissions (p 156). Estimates of impacts on greenhouse gas emissions as a result of existing road maintenance and new temporary road construction under each alternative are provided in Table 66 of section 3.18-Climate Change. Additional analysis was added to chapter 3 of the FEIS as a result of this comment. 20-132 It is very important that roadless area characteristics be maintained. We support the Forest Service’s approach of avoiding management activities in all un-roaded areas to protect the roadless characteristics. Response: Thank you for your comment. 20-134 The Forest Service should identify the minimum road system for particular forest segments by analyzing whether the road activities proposed under this project are consistent with the relevant portions of the travel analysis report and considering the minimum road system factors under 36 CFR 212.5(b)(1) for each road the agency decides to keep as part of the specific project.34 Response: The 2015 TAP report is not a NEPA decision, it represented the current information from when it was published regarding system roads on the RGNF; this report is expected to evolve following additional internal and external review. This project is primarily focused on salvage harvest activities, though it does identify some road maintenance-related opportunities (section 1.10 and section 3.7, Hydrology and Watershed) to improve watershed or stream health. None of the alternatives propose any changes to national forest system roads currently open to motorized travel. If non-system (temporary) roads are needed to implement timber harvest operations as part of the Selected Alternative, the roads would be remain temporary and be effectively decommissioned following use. Since CPDWS project implementation could be extend over several years and is expected to overlap future travel management planning as discussed in section 3.17 Transportation, an additional item was added to the pre-implementation Checklist #2 (section 2.2) as a reminder to check for any changes or updates and coordinate on road information prior to individual project implementation. The Forest Service must prioritize unneeded roads for decommissioning or other uses. Road decommissioning may temporarily increase sediment to streams but has dramatic reductions in the 285 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 20-136 long run. The Forest Service’s Rocky Mountain Research Station has spent over a decade through monitoring the effectiveness of road treatments. A 2012 report evaluating pre and post treatment of 20-141 roads showed an 80% reduction in sediment delivery to streams when roads were decommissioned. In addition, the 20-year monitoring report of the Northwest Forest Plan confirmed that watersheds that showed the most improvement in condition were those that completed road decommissioning. Decommissioned roads, when seeded with native species, can reduce the spread of invasive species and help restore fragmented forestlands. See Attachment F at 11. Closed roads remain on the landscape and therefore would still present a risk to the ecosystem. Little to no maintenance is planned for roads while in storage. In contrast, returning expensive, deteriorating, and seldom used forest roads to the wild would significantly reduce the risks those roads pose to the ecosystem. Response: The purpose and need of this project is to salvage dead and dying spruce trees for economic value and to mitigate for hazardous fuels where and when effective and deemed necessary. The project does identify road maintenance opportunities to aid in overall watershed health (section 3.7, Hydrology and Watershed, section 3.17, Transportation). None of the alternatives propose changes to currently-open National Forest system roads. If non-system, temporary roads are needed to implement harvest activities, those roads would remain temporary and would be effectively decommissioned following use (see Transportation section for decommissioning actions). 20-62, 20- The best available science shows that roads cause significant adverse impacts to National Forest 64, and resources. A 2014 literature review from The Wilderness Society surveys the extensive and best 20-65 available scientific literature—including the Forest Service’s General Technical Report synthesizing the scientific information on forest roads (Gucinski 2001)—on a wide range of road-related impacts to ecosystem processes and integrity on National Forest lands. See The Wilderness Society, Transportation Infrastructure and Access on National Forests and Grasslands: A Literature Review (May 2014) (Attachment F). Erosion, compaction, and other alterations in forest geomorphology and hydrology associated with roads seriously impair water quality and aquatic species viability. Roads disturb and fragment wildlife habitat, altering species distribution, interfering with critical life functions such as feeding, breeding, and nesting, and resulting in loss of biodiversity. Roads facilitate increased human intrusion into sensitive areas, resulting in poaching of rare plants and animals, human-ignited wildfires, introduction of exotic species, and damage to archaeological resources. Response: We do our best to circumvent some of the negative impacts that additional roads might have on our resources. In order to move towards desired conditions, the addition of a minimal amount of roads, which would later be decommissioned, is necessary. Other methods for harvesting timber, such as helicopter logging, are not feasible. Additionally, every effort is given to ensure that a temporary road is absolutely critical for the salvage of certain timber BEFORE it is included in the logging plan. Furthermore, if a minor section of temporary road is added, it will be designed to mitigate some of these negative impacts using BMP’s and best engineering practices. Detailed analysis of all potential impacts, including temporary roads, are included in the wildlife, hydrology, and fisheries specialists reports located in the project record. Finally, preventative measures such as the installation of barricades, and law enforcement patrol are implemented to reduce unauthorized use and disturbance. 20-63 The Forest Service states that open road density will remain the same. DEIS at 90. But as noted above in discussing impacts to elks, this assumption ignores the more than 60 miles of new and reopened temporary, non-system roads proposed for use over a 10 to 15 year project period. The Forest Service must explain how the new roads do not change open road density. It also must assess the impacts from log hauling on the proposed new temporary roads and re-opened existing roadbeds. It fails to provide that detail here. Response: Temporary road systems are not counted under open road densities as they are not, nor will they be, open to public motorized use and are limited to the period of operations in which they are needed. All temporary roads would be decommissioned post-activities and thus not constitute a change to the permanent or open road system. This is different from total road densities, which may include temporary roads. As a result of this comment, some additional clarification was made in regards to road impacts to elk and mule deer.

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Letter # - Comment and Response to Comment Comment # 20-67 For each of the old non-system (temporary) roads proposed to be reused, what management actions did the original decision documents authorizing the creation of these roads call for? Response: See responses 20-13 and 20-117. 20-69 It must also consider how construction or re-opening of temporary roads will detract from the purpose of subpart A of the agency’s own rules, to “identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of the National Forest System lands.” 36 C.F.R. § 212.5(b). This is especially true if the Forest Service fails to provide assurances that the proposed temporary roads will in fact be closed within 10 years of completion of the relevant project. Response: The RGNF has completed the Forest-wide Travel Analysis Process report (TAR), which fulfills the subpart A requirements; see response 20-133. Temporary roads are not part of the national roads system. See response 20-117 for discussion concerning assurances of decommissioning. 20-133 We again urge the Forest Service to consider the proposed road activities in light of its travel analysis report, attached here as Attachment K, and explain any changes to those recommendations and the reasoning. Here, the Forest Service references the travel analysis report but fails to provide sufficient information for the public to understand the recommendations form that report as they relate to the road segments proposed for use under this project. It lists the road numbers recommended for decommissioning under the travel analysis report. DEIS at 150. But it fails to show where those roads are located in relation to the proposed vegetation management activities, or the risks or benefits of those roads. Because the project will take place over the next 10 to 15 years, this decision essentially identifies the roads as needed and therefore must comply with subpart A. See DEIS at 147 (noting that all system roads identified for use during vegetation management activities will require maintenance to ensure safe passage). Response: The Forest Service has considered the road activities in light of the TAR. However, because the TAR is not a decision document, and this project does not propose changes to the road system based upon the TAR, an adequate level of analysis and disclosure has been completed in relation to the TAR. Per the Regional Forester memo on Travel Management Rule (TMR) Implementation, dated March 17, 2017, the subpart A requirements have already been met for the Rio Grande National Forest by completion of the TAR, which was published on 2015. Additional steps of the TMR are not required under this vegetation management project. See also response 20- 18. 20-135 …the Forest Service defers an evaluation of its road system until after the Forest Plan revision process. DEIS at 150. Because of the harmful impacts from forest roads identified above and recognized in the analysis (see, e.g., DEIS at 101), and the staggering number of road miles in the project area, the Forest Service must consider its road system under this landscape restoration project. Response: The evaluation and recommendations for the minimum road system was performed in the TAR, which was published in 2015. This EIS further evaluates the road system in relation to the proposed action and alternatives in accordance with NEPA requirements. Adoption of recommendations from both will be considered in the Forest-wide Travel Management process after the Forest Plan Revision process; see response 20-18. As a sidebar, it should be noted that landscape restoration is not the intent of this project. 20-137 Road decommissioning may temporarily increase sediment to streams but has dramatic reductions in the long run. The Forest Service’s Rocky Mountain Research Station has spent over a decade monitoring the effectiveness of road treatments. A 2012 report evaluating pre and post treatment of roads showed an 80% reduction in sediment delivery to streams when roads were decommissioned. 37 In addition, the 20-year monitoring report of the Northwest Forest Plan confirmed that watersheds that showed the most improvement in condition were those that completed road decommissioning. 38 Decommissioned roads, when seeded with native species, can reduce the spread of invasive species and help restore fragmented forestlands. See Attachment F At 11. Closed roads remain on the landscape and therefore would still present a risk to the ecosystem. Little to no maintenance is planned for roads while in storage. In contrast, returning expensive, deteriorating, and seldom used forest roads to the wild would significantly reduce the risks those roads pose to the ecosystem. 287 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: The IDT understands the watershed benefits of road decommissioning and is familiar with the references provided by the commenter. Consequently, all temporary and non-system roads associated with a particular project will be decommissioned when their use is complete. Decommissioning of current system roads, including closed system roads, would certainly improve watershed health, however these actions are not proposed as part of the current project. 29-3 The DEIS provides PDC for each affected resource and indicates that all temporary roads will be decommissioned post-treatment. The document also indicates that the 15-year timescale of the project would result in watershed impacts from forest roads being “distributed and mitigated, in both time and space as various salvage projects move forward across the project area.” In order to further ensure that watershed impacts from roads are minimized during the life of the project, the EPA recommends expanding PDC for roads and suggests the following: • Locate roads away from streams and riparian areas where possible; • Locate roads away from steep slopes, landslide prone areas, and erosive soils; • Minimize the number of road stream crossings; • Construct unavoidable road stream crossings during periods of low flow to avoid fish spawning and incubation periods, and/or dewater relevant stream segments prior to construction; plan for the failure of stream crossings to reduce the amount of sediment that would enter the stream channel should a crossing fail; use bottomless or embedded culverts; and place the culvert inlet on the same level as the stream bottom; • Provide adequate road drainage and erosion control to avoid routing sediment to streams; • Design roads to allow for natural drainage patterns; and • Develop a monitoring plan and schedule to assess the effectiveness of road decommissioning/rehabilitation after project completion. Response: The proposed design criteria are incorporated by reference in the 1996 Forest Plan Revision, the Watershed Conservation Practices Handbook (FSH 2509.25), and the BMP handbook (FS 990A), which when taken as a whole achieve the same functional impact as the proposed PDC from the commenter. 20-138 Decommissioning forest roads would be consistent with Forest Service’s road rules, which direct the agency to prioritize unneeded roads for decommissioning or other uses. Decommissioning road miles is consistent with the Forest Service’s long-standing policy to “manag[e] access within the capability of the land.”39 Allowing formerly closed roads to remain on the landscape instead of removing those roads from the system allows the risk that those roads pose to natural resources to remain, and fails to achieve the policy goals of subpart A of the agency’s own rules. Response: See response 20-18. 29-2 Our comments focus on project design criteria for roads and suggestions for additional information to include related to protecting water resources. Our detailed recommendations are provided for your consideration in the enclosure. We appreciate the opportunity to review this project and hope our recommendations help the Forest Service when finalizing the EIS. Response: Thank you for the review and comments; they will be specifically addressed in responses 29-3 through 29-7. 29a-1 As mentioned, in addition to what will be provided in our formal comment letter, the EPA suggests the following: 1. Include the 303(d) listed stream on the map of the project area. 2. Provide figures at a larger scale in an Appendix. Figures 1 and 2 are difficult to read and Figure 2 does not provide details on the legend. Figures contain a lot of important information and providing larger scale maps (even electronically) would add to the ease of understanding to the reader. Response: See response 20-30.

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Soil, Water and Watersheds Letter # - Comment and Response to Comment Comment # 1a-11 Alternative #3 (so-called “limited action”) still destroys the aquatic resources on your district with 1a-31 57 miles of temporary road. We have all walked short sections of “temporary” roads that were constructed and located by employees working for the purchaser. Their goal was to minimize cost … not reduce aquatic damage by eliminating the possibility that sediment might enter streams. Your IDT hydrologist and fisheries biologist should know Temporary roads are outsloped, thus they are linear sediment generators each time it rains and when the snow melts in the spring. It appears we have a competency problem here. You propose to build 67 miles of so-called temporary road. You cannot comprehend the aquatic damage these roads will cause. Response: The effects of temporary roads on aquatic resources are disclosed in section 3.5, Aquatics and Fisheries, and section 3.7. Hydrology and Watershed, of the EIS. 2-12 Aquatic Resources: we request the first design criteria be changed to state, “no harvest equipment or 3-12 skid trails will be allowed within the aquatic management zone (AMZ-50 horizontal feet from the top of each stream bank) of all intermittent or perennial stream channels. The current Forest Plan does not require a ‘no-harvest’ zone, nor does it specify a specific distance. Colorado State Best Management Practices recommends 50 feet. Response: We follow the Rio Grande National Forest Revised Plan, including standards and guidelines referencing the Watershed Conservation Practices Handbook to provide protection for watershed resources. The comment is incorrect, the current forest plan specifies the “WIZ” which for the purposes herein is interchangeable with the “AMZ”. This area (WIZ or AMZ) is defined in FSH 2509.25 as: “The water influence zone (WIZ) includes the geomorphic floodplain (valley bottom), riparian ecosystem, and inner gorge. Its minimum horizontal width (from top of each bank) is the greater of 100 feet or the mean height of mature dominant late-seral vegetation. The WIZ protects interacting aquatic, riparian, and upland functions by maintaining natural processes and resilience of soil, water, and vegetation systems (Reid and Ziemer 1994).” The 100’ no cut buffer has been used successfully in previous salvage projects on the Forest. In salvage units, a no cut buffer is preferred, since no stand or watershed resource objectives would be gained by the cutting. The 200’ corridors (100’ buffer on each side of stream) assist in providing habitat for riparian obligate species and connectivity for wildlife across the landscape. As a reminder, the decision maker (District Ranger) does have the right to select such PDC for additional protections, even if the Forest Plan and Watershed Conservation Practices Handbook doesn’t require it. Additional clarification has been added to the PDC for Aquatic Resources. Also see responses to 20-55 through 20-57 on RMZ use. 4-2 Watershed health is of primary importance to TU. As defined in our mission, we place our value and expertise in a holistic approach to coldwater fisheries management and individual population’s dependence on a watershed as a whole rather than just reaches or stream segments. Headwater health, surface/ groundwater interactions, forest health, soil health, and connectivity are all a part of healthy watersheds in our opinion, and that scale of analysis is urged in the project management of the Conejos Peak District-wide Salvage Project. Response: The fisheries analysis included the watershed analysis and as suggested, is a key piece of the approach to overall watershed health. As mentioned in Response to 4-3 below (and elsewhere) the use of project implementation checklists will allow project specific monitoring and mitigations to be used. 4-3 The draft Hydrology and Watershed Specialist report notes that in the proposed project footprint, 12 of 16 HUC level 6 watersheds are functioning at risk. It also indicates wetlands, fens, and important groundwater sources are not sufficiently documented or mapped in the CP District. Trout Unlimited strongly urges the Forest to take these facts into consideration when evaluating the extent and intensity of salvage extraction and corresponding disturbances when making a final decision. When possible, TU would prefer to see positive watershed health projects come from this District-wide Salvage Project. 289 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: During the completion of project implementation checklists for individual projects, field inventories of streams, wetlands, and riparian areas will be undertaken so as to inform project area boundaries and Existing Conditions to reduce effects to wetland resources. See response 4-4 below for positive watershed projects. See also response to comment 20-52 and 20-53. 4-4 As outlined in the Hydrology and Watershed Specialist report, Trout Unlimited supports the use of various funding sources to go above and beyond regarding pairing forest treatments with watershed health treatments including but not limited to; road maintenance, road decommissioning, erosion control, instream restoration, and wet meadow restoration and creation. Our preference is to see mitigation in creative ways that are not only site specific, but are as widespread and cumulatively impactful to watershed health as a watershed scale timber salvage sale. Response: As mentioned in action alternatives, as funding becomes available portions of existing National Forest System Roads will be reconstructed to accommodate new or increased utilization from the analyzed activities. Additionally, both new temporary roads, as well as old, non-system road templates that are re-used, will be decommissioned when salvage or fuels activities are completed to improve watershed health. 4-5 The Upper Chama watershed and the neighboring Archuleta Creek watershed have been identified for Priority Watershed designation in the RGNF draft forest plan revision. Trout Unlimited feels this a prime opportunity to accomplish many of the goals stated above, and encourages the Forest and the CP District to evaluate the timber operations under this new designation, if carried forward in the final Revised Rio Grande Forest Plan. Response: Although the Upper Chama and Archuleta Creek watershed are within the Conejos Peak Ranger District, they were removed from treatment consideration for the Conejos Peak District- Wide Salvage Project. These areas are within current Backcountry/Colorado Roadless Rule and/or Wild and Scenic River designations and withdrawn from Timber harvest. They would only be subject to fuels treatments. If in the future there is a need for fuels treatments in these areas, a separate NEPA decision process would be required. 4-6 Trout Unlimited strongly urges the use of Riparian Management Zones (RMZ) when dealing in watersheds with RGCT populations, be they recreational or conversation populations. We also encourage the use of RMZ’s as proposed in the Rio Grande Forest Plan Revision under the 2012 planning rule rather than the 1996 definitions. Response: Riparian Management Zones are already proposed as a Project Design Criteria in all RGCT streams as suggested. The criteria for defining RMZ widths are similar to those being proposed in the current Forest Plan Revision. See response to 2-12 and 3-12 for additional information. 4-7 Site specific recommendations: As identified in the Hydrology and Watershed and Fisheries Specialists reports, the Lake Fork of the Conejos and its tributaries is of great importance for its outstanding RGCT resources. Both for recreational fishing and species conservation, TU urges the RGNF to further examine the watershed impacts of intense forest operations in that watershed specifically. Response: Thank you for highlighting this portion of the analysis. This resource will certainly be taken into consideration by the decision maker as an alternative is selected. 4-8 Partnership: Trout Unlimited would like to be considered a partner to the Forest Service in the on 4-9 the ground implementation of forestry and watershed health related projects over the course of the Conejos Peak District-wide Salvage Project. TU has technical expertise to assist in mitigation and project planning where hydrology and watershed resources can be paired with forest treatments for the mutual benefit of these sometimes at odds management prescriptions. Wet meadow restoration projects on the neighboring Carson National Forest can serve as an example of where TU and the Forest Service can compile various funding sources to meet many different management goals. TU has been participant to regional stakeholder groups concerned with wildlife and forest health. Groups like the Upper Rio Grande Wildlife Connectivity collaborative, and the 2-3-2 Forest Health Initiative are two groups who should be notified and included during project implementation under the Conejos Peak District-wide Salvage Project, and Trout Unlimited would like to offer to assist in that messaging when possible.

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Letter # - Comment and Response to Comment Comment # Response: As noted in Table 1, Desired Conditions for this project include “Emphasize cooperation with individuals, organizations, and other agencies while coordinating planning and project implementation.” and the associated Forestwide Objective 7.1 “Cooperate with all people, including those whose livelihood is dependent on National Forest resources, in the development of plans and projects.” Rio Grande National Forest staff, including Conejos Peak Ranger District are also actively engaged in both the Upper Rio Grande Wildlife Connectivity Collaborative and the 2-3-2 Forest Health Initiative along with the individuals and groups involved. These relationships allow us to collaborate and share information across projects and boundaries. We will continue to engage our partners and collaborate to effectively manage RGNF lands and we appreciate the input and the engagement as this Project is implemented. 20-52 The Forest Service must accurately disclose the impacts on water quality. Here the Forest Service 20-53 proposes salvage activities within 16 of the 27 6th level watersheds in the project area. DEIS at 106. Of the 16 watersheds with salvage activities, 12 are rated as functioning at - risk, due largely to poor riparian conditions, invasive aquatic species, and reduced flows. DEIS at 106-107. The Alamosa River, from Ranger Creek to Terrace Reservoir, is listed as impaired on the State of Colorado’s 303(d) list. DEIS at 107. The Forest Service provides very little analysis about the scope of sediment impacts to receiving waters as a result of the salvage harvest and fuels reduction activities proposed for this project. See DEIS at 108. At bottom, it is not worth putting these 16 watersheds, 12 of which are already functioning at risk, at greater risk of disturbance from sediment. This project will greatly increase the negative impacts watersheds in the area. Logging within watersheds of concern or sensitive watersheds necessarily will put water quality at a greater risk, and the agency improperly downplays and fails to take a hard look at these risks. Response: The 303(d) impairment for the Alamosa River from Ranger Creek to Terrace as well as other portions of the Alamosa River are related to dissolved metals and low pH conditions, which are typically the result of legacy mine operations (TMDL Assessment Alamosa River, CDPHE 2005). The proposed vegetation management activities are very unlikely to exacerbate water quality concerns related to dissolved metals and low pH conditions in the analysis area. The condition of the watersheds within the project area, as discussed in the EIS, are provided as background information. Project activities are very unlikely to degrade conditions with respect to either aquatic invasive species (primarily fisheries related) or further reduce flows in reaches that are impacted via diversion, which are the frequent cause of lowered WCF condition class in the project planning area. Project activities will have impacts to riparian resources, and will provide for increased levels of erosion and sedimentation. However, implementation of project design criteria, BMPs, etc. will likely mitigate these impacts to acceptable levels. 20-54 To accurately identify water quality impacts, the agency should identify, map, and display in the through analysis all perennial, intermittent, and ephemeral stream courses, as well as wetlands, wet areas, 20-57 and fens. Buffer zones required by the Water Conservation Practices Handbook must be adopted. Additional buffers of 300 feet surrounding any fen wetlands should also be adopted, as recommended by Jones (2003). A buffer of two tree heights in riparian areas, as outlined in the project design criteria, is insufficient to protect water quality and not supported by best available science. Response: As a result of the comment maps were added to Appendix F. During the analysis of this project the best available geographic datasets of water features were employed, including the National Hydrography Dataset and the National Wetlands Inventory, as well as various vegetation databases. The provided discussions of riparian vegetation and stream densities were used to represent watershed resources at the programmatic/planning area scale. Field experience working in the planning area has shown that intensive field surveys are required to be conducted at the individual project level in order to accurately identify and avoid these water features. The results of these field surveys are included in the Project Checklists, and appropriate project design criteria will be applied to these features during project implementation. It was clearly stated several times during the EIS, that the Watershed Conservation Practices handbook (FSH 2509.25) would be followed as a condition of project implementation. The PDC table was updated to reflect this. In response to the citation Jones (2003), a blanket 300-ft buffer on 291 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # fens does not necessarily provide protection of fens, and can be unnecessary. IDT members will determine appropriate buffers during individual project layout, with the WCP and Forest Plan Standards and Guidelines as minimums to be followed. The two tree height buffer described in the PDC is associated with Rio Grande Cutthroat Trout and is supported by the following references: Megahan, W.F., and J. Hornbeck. 2000. Lessons Learned in Watershed Management: A Retrospective View USDA Forest Service Proceedings Rocky Mountain Research Station – P – 13. Naiman, R.J., R.E. Bilby, and P.A. Bisson. 2000. Riparian Ecology and Management in the Pacific Coastal Rain Forest Bioscience November 2000 Vol. 50, No. 11, pp. 996-1011. Quigley, T.M., and S.J. Arbelbide (eds.) 1997. An Assessment of Ecosystem Components in the Interior Columbia Basin and Portions of the Klamath and Great Basins, Volume III (PNW-GTR- 405, 1997): An Ecosystem Approach to Salmonid Conservation (NMFS TR-4501-96-6057, 1996). Spence, B.C., and R.M. Hughes. 1996. An Ecosystem Approach to Salmonid Conservation December 1996 TR-4501- 96-6057. USDA Forest Service. 1997. Riparian Reserve Evaluation Techniques and Synthesis, Supplement to Section II of Ecosystem Analysis at the Watershed Scale: Federal Guide for Watershed Analysis. Version 2.2. USDA Forest Service. 2015. Forest Service Handbook 1909.12, Land Management Planning Handbook. Chapter 20 – Land Management Plan. Amendment 1909.12-2015-1. Effective 01.30.2015. 20-58 Healthy soils are essential to plant life, wildlife, and to the protection of streams from erosion and 20-60 sediment deposition. The drafters of NFMA recognized the importance of healthy soils, as reflected by the inclusion of statutory provisions designed to protect soils and other forest resources dependent upon healthy soils. See, e.g., 16 U.S.C. § 1604(g) (3) (requiring continuous monitoring and assessment to prevent “substantial and permanent impairment of the productivity of the land.”); id. § 1604(g) (3) (E) (i) (allowing logging only where “soil, slope, or other watershed conditions will not be irreversibly damaged”). See also 36 C.F.R. § 219.11(d) & id. § 219.12(k) (2) (monitoring requirements for impacts to soils); id. § 219.27 (requirements for protection of soils). The 1996 Rio Grande Forest Plan also reflects an understanding of the role that healthy soils play in maintaining the ecological vigor of the forest. The Forest Plan includes a standard requiring the Forest Service to “limit the sum of severely burned and detrimentally compacted, eroded and displaced land to no more than 15% of any land unit.”9 Rio Grande Forest Plan III-10. The 15% soil standard is intended to ensure compliance with NFMA’s soil provisions and to protect the forest from projects that severely impair forest soils. Ecology Center, Inc. v. Austin, 430 F.3d 1057, 1070 (9th Cir. 2005) (“the purpose of the [soil standard] is to ensure compliance with the substantive mandates of NFMA”). Compliance with this standard is mandatory and the Forest Service must ensure that the standard will be met prior to project approval. It would also be inconsistent with the Watershed Conservation Practices Handbook to: “Manage land treatments to limit the sum of severely burned soil and detrimentally compacted, eroded, and displaced soil to no more than 15% of any activity area.” Response: National guidelines and forest plan standards are designed to protect soil health. It is the intent to protect soils while also fulfilling the multi-use aspect of the forest. Section 2.4 of the DEIS includes the project design criteria. The Soil resource section (section 3.8) lists the soils criteria, which are developed with national and forest standards in mind. These standards establish guidelines for protecting soil productivity, including limiting detrimental soil impacts to 15% or less. 20-59 The Forest Service should conduct a thorough analysis of soil conditions in the analysis area, including, but not limited to, soil impacts from past timber harvest activities. Conducting the proposed action could, in combination with past and recently approved timber harvest in the project area, exceed authorized thresholds for detrimentally compacted soils, violating the Forest Plan and thereby violating NFMA. 292 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: Unit monitoring will occur pre and post-harvest on representative units. Prior to harvest activities, site visits will be made and units assessed for current disturbance levels. Following harvest selected units will be assessed to determine if standards are met. In addition, Best Management Practices (BMPs) assessments will be done to determine if all standards and criteria are being implemented in an effective manner. 20-89 The analysis must disclose soil types in the project area, and provide an assessment of landslide risks throughout the project area. The analysis must identify potential landslide risk areas by determining, at a minimum, the following: pre- and post-proposed harvest canopy cover, increase in ground water saturation, slope, and soil type. Response: See general discussion of soil characteristics under the Soil section of the EIS (section 3.8). A more in depth discussion of mass movement and soils can be found in the soil specialist report. Also see the Soil Resource Ecological Inventory of the Rio Grande National Forest – West Part Colorado (USDA 1996) which gives soils information by SRI or soil map unit. This information can also be accessed using the NRCS Web Soil Survey system with is available to the public at https://websoilsurvey.sc.egov.usda.gov/App/HomePage.htm Additionally, forest plan standards require that vegetation on unstable slopes be retained and new roads and heavy equipment use on unstable slopes be avoided. This is typically done in design and layout of units so is addressed throughout the process. 20-90 The analysis must also identify the construction of any new roads and reconstruction of skid trails or previously obliterated roads, and identify the level of reconstruction necessary. Road construction and reconstruction should not be permitted in areas of landslide-prone soils. Response: No new system roads will be constructed (see table 3, page 23 and table 5, page 26 of the DEIS). Road layout and level of reconstruction will be determined on a unit basis and be analyzed prior to harvest activities. See response to comment 20-89 for discussion of road construction on land slide prone areas. Forest plan standards are in place to protect unstable/landslide prone areas. See comment response 20-89 for a more in-depth discussion of landslide prone soils and measures to protect them. 20-131 Under the Clean Water Act (CWA), states are responsible for developing water quality standards to protect the desired conditions of each waterway within the state’s regulatory jurisdiction. 33 U.S.C. § 1313(c). Water bodies that fail to meet water quality standards are deemed “water quality-limited” and placed the CWA’s § 303(d) list. The CWA requires all federal agencies to comply with water quality standards, including a state’s anti-degradation policy. 33 U.S.C. § 1323(a). The Forest Service must ensure all activities in this proposal comply with the CWA. In particular, it must ensure its proposal to authorize logging and associated road reconstruction, maintenance, and ongoing use, will not cause or contribute to a violation of water quality standards. Response: Past experience has shown that implementation of Standards and Guidelines (1996 Forest Plan Revision), Best Management Practices (BMPs, FS990-A), and Management Measures (FSH2509.25), will allow the proposed activities to occur within the project area without violations of the Clean Water Act. 20-137 Road decommissioning may temporarily increase sediment to streams but has dramatic reductions in the long run. The Forest Service’s Rocky Mountain Research Station has spent over a decade monitoring the effectiveness of road treatments. A 2012 report evaluating pre and post treatment of roads showed an 80% reduction in sediment delivery to streams when roads were decommissioned.37 In addition, the 20-year monitoring report of the Northwest Forest Plan confirmed that watersheds that showed the most improvement in condition were those that completed road decommissioning.38 Decommissioned roads, when seeded with native species, can reduce the spread of invasive species and help restore fragmented forestlands. See Attachment F at 11. Closed roads remain on the landscape and therefore would still present a risk to the ecosystem. Response: The ID T understands the watershed benefits of road decommissioning and is familiar with the references provided by the commenter. Consequently, all temporary and non-system roads associated with a particular project will be decommissioned when their use is complete. Decommissioning of current system roads, including closed system roads, would certainly improve watershed health, however these actions will be considered in the future during a Forest-wide travel management review. 293 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 29-4 The DEIS provides riparian and stream data on 6th level (i.e., basin level) watersheds with proposed treatment activities, including watershed acreage within the analysis area. A discussion of Class 1 and Class 2 rated watersheds is also included. The information in Tables 43 and 45 does not identify which watersheds listed are wither Class 1 or Class 2, which is important in understanding the discussion around the percentages of each watershed that have potential for salvage harvest. The EPA recommends that the Final EIS identify the watershed rating of each watershed and identify the watersheds on a map with proposed activities. Response: The EIS, section 3.7, Hydrology and Watershed, Table 43 was modified to exhibit Watershed Condition Class. WCF watershed class maps are available at: USDA Forest Service Watershed Condition Class and Prioritization Information. 29-5 The Forest Service indicates that fens and wetlands will be avoided during project activities and the 29a-3 National Wetland Inventory data for the project areas under-represents the occurrence of wetlands in the project area and therefore is not included for discussion. Field inventories of streams, wetlands, and riparian areas will be undertaken to inform project area boundaries for individual projects through the use of Project Implementation Checklists. The EPA recommends that the Final EIS elaborate on the process for identifying critical areas such as wetlands, streams and riparian areas and discuss what measures and project design criteria may be employed to minimize impacts as identified during the checklist process. Response: Additional language was added to section 2.2 of the EIS to further explain the adaptive implementation process employed for any action alternative selected. Field verification of known and unknown fens and wetlands will occur prior to implementation of individual projects. At that time, project design may be adapted, within the scope of this analysis, to add or modify appropriate protection measures for fens and wetlands, where necessary, as guided by law, policy, Forest Plan direction and best management practices. Project design criteria will be adopted for any action alternative to help mitigate potential effects to fens, riparian areas and water sources (See EIS, section 2.4, PDC for Alternatives 2 and 3). 29-6 Public Drinking Water Supply Sources: Source water protection is a key issue to address in vegetation management activities. In order to ensure that public drinking water supply sources (e.g., surface water sources, including groundwater under the direct influence of surface water sources, and groundwater sources) are protected from potential impacts associated with USFS-authorized activities in the project area, it is important to identify where these sources are located. Therefore, the EPA recommends that the Final EIS include a map depicting municipal supply watersheds1 and source water protection areas for public water supply wells and surface water intakes (streams, rivers and reservoirs) in accordance with state data security requirements (if none exist in the project area, then so state in the Final EIS). Once these resources are identified, we recommend including an analysis of potential impacts to drinking water sources from USFS-authorized activities in the project area and mitigation options for protecting these high value drinking water resources. Note that more specific maps, available from the CO Dept. of Public Health and Environment (CDPHE) should be utilized by the USFS when locating future project activities. Please contact CDPHE Source Water Protection Program for more information and these Geographic Information System (GIS) layers. 1 Forest Service Manual (FSM 2542) defines Municipal Supply Watersheds to include: “surface supply watersheds, sole source aquifers, and the protection zones around wells and springs.” Response: The most up-to-date CDPHE shapefiles were used, confirmed by talking with CDPHE and receiving new data in January, we (USFS) have an MOU to recognize CDPHE Source Water Areas as municipal supply watersheds for planning purposes, this was done. We are prohibited from publically disclosing these areas by the State of Colorado for security purposes. 29-7 Effects to Impaired Water Bodies: The DEIS includes a brief discussion of water quality within the project area and identifies the only Clean Water Act 3303 (d) listed waterbody in the project area in Table 44. We recommend that the Final EIS identify the 303 (d) listed stream on a map with project activities and provide a discussion on potential impact to the impaired water body identified. If impacts are anticipated, then coordination with CDPHE will be necessary to avoid causing or contributing to the exceedance of water quality standards.

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Letter # - Comment and Response to Comment Comment # Response: The 303(d) impairment for the Alamosa River from Ranger Creek to Terrace as well as other portions of the Alamosa River are related to dissolved metals and low pH conditions, which are typically the result of legacy mine operations (TMDL Assessment Alamosa River, CDPHE 2005). The proposed vegetation management activities are very unlikely to exacerbate water quality concerns related to dissolved metals and low pH conditions in the analysis area. This due to the nature of the project activities, project mitigation measures, and relatively large distance from project areas to the beginning of the listed reach. The closest proximity is several miles and approximately 1500 vertical feet of separation. 36-5 We are also concerned regarding cumulative impact on the watersheds in this project and how it meets forest plan standards for watershed protection. The DEIS fails to adequately show how a large salvage sale of this size combined with large recent sales will not adversely affect watershed function in this area. Response: In Table 45 and the preceding paragraphs there is a discussion of the maximum potential disturbance by 6th Level watershed for the proposed activities. As can be seen, many watersheds will have limited overall disturbance (an average of roughly 9% of total watershed area). Based on these percentages of disturbance, past know activities, and implementation of Standards and Guidelines (1996 Forest Plan Revision), Best Management Practices (BMPs, FS990-A), and Management Measures (FSH2509.25), adverse cumulative impacts to watershed health are anticipated be successfully mitigated in most cases.

Lynx Habitat and Endangered Species Act Letter # - Comment and Response to Comment Comment # 1a-28 Ranger Jones you aren’t aware that it’s illegal to knowingly harm occupied habitat for ESA listed species (in this case Lynx) in any way for any reason. Who knows, perhaps you understand the ESA and think you won’t get caught violating that law. Response: No response was necessary to address this comment. 1a-29 Request for changes to be made to the final NEPA document: Identify the logging units identified in the DEIS that are in lynx habitat. The FEIS will announce those units have been dropped from the timber sale. Response: Refer to the Wildlife Specialist Report, ROD 2-3 We recommend not selecting Alternative 3 for the following reasons: 3-3 Alternative 3 will treat fewer acres and supply significantly less volume. Alternative 3 proposes additional lynx requirements, which are above and beyond the existing Forest Plan, as amended by the Southern Rockies Lynx Amendment (SRLA), based on ongoing research that has not been released for public review; the additional requirements include: Two additional categories of lynx habitat – Suitable and Unsuitable, yet Alternative 3 proposes to have four different categories, which is really based on Snowshoe Hare habitat. No harvest would occur in areas that overlap more than 20 acres of habitat identified by a “local” denning habitat model, which has not been peer reviewed or amended into the SRLA. Further, as stated in the DEIS, “no past known denning location on the district is within a proposed treatment area.” (p. 74). Would delay salvage in the Conejos Canyon and Alamosa LAUs to allow for current research to be integrated. Yet, the DEIS clearly states that “approximately 70% of stands remain suitable post- harvest depending on preexisting site conditions. Additionally, all of the LAUs stay well below the 30% unsuitable threshold as allowed in the SRLA. Consequently, there is no reason to delay treatment. Response: Prior to selecting a course of action, the Responsible Official will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other

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Letter # - Comment and Response to Comment Comment # factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. The SRLA provides the current Management Direction for Canada lynx conservation on the RGNF, however it does not function as an updated body of science-based information nor does it limit additional considerations in regards to lynx conservation. The use of outside proprietary or draft information given to the RGNF under data-sharing agreements is important to aid in lynx conservation, particularly those that are applicable to local conditions. Both alternatives were analyzed using 4 habitat categories, however only alternative 3 differentiates treatments based on category. These were developed based on Interim Salvage Guidelines developed by the forest biologist in conference with FWS. They were created to aid in differentiating the spectrum of habitat quality and needs of the species. Refer to BA Appendix B. Peer review is not a requirement for unpublished documents intended to function as management or estimation tools for implementing the SRLA locally within the framework of the original decision. That said, peer review was requested and provided for further refinement prior to the FEIS. Remaining suitable habitat may not be equivalent to equal habitat quality post-salvage as pre- salvage. Habitat quality can be degraded by salvage, therefore a more conservative analysis was used. 2-4 We disagree with the finding in Table 32 that Alternative 2 only partially meets Objective VEG 04. 3-4 The SRLA Implementation Guide clearly states that “the intent of VEG 04 is to focus vegetation treatment in areas that could improve snowshoe hare habitat. It does not mean that it requires 100% of treatments to be in poorly-developed understory.” (p. 13 SRLA Implementation Guide). Response: It is recognized that VEG O4 is not required to be met in every circumstance and can be met to varying degrees. We have analyzed whether or not it is met and included the rationale. This conclusion was made in consultation with FWS. Refer to the BA, section 2.3. Newly available preliminary data regarding lynx habitat use combined with project level ground truthing show that approximately half of the proposed for treatment areas are currently poor lynx habitat and would likely become improved lynx habitat at some point following treatment, particularly when re- planting and tree establishment occurs. 6-1 The preferred alternative, Alternative 2, describes many of the prescribed salvage acres to be some of the best lynx habitat on the district with breeding and rearing occurring, as well as functioning as sources of snowshoe hare. The forest overstory is also described as being more than 80 percent dead from spruce beetle infestation. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 6-2 Guidance for Federal land managers is provided by the 2013 Lynx Conservation Assessment and Strategy as well as the 2008 Southern Rockies Lynx Amendment (SRLA). Guidance includes maintaining the amount and distribution of lynx foraging habitat over time, so that no more than 30 percent of the lynx habitat in a Lynx Analysis Unit (LAU) is in an early stand initiation structural stage (SISS). The proposed action occurs in five LAU's that contain dead overstory and minimal understory, which is effectively SISS. Without assessing the extent of the beetle kill, there is significant uncertainty in analyzing the district-wide and LAU-wide current conditions. Response: Estimates were made for post-beetle SISS using the data available at that time, refer to BA section 2.1. While uncertainty remains, based on experience in the field, the District Wildlife Biologist determined that some stands with extensive beetle kill yet retain suitable habitat characteristics due to the proportion of subalpine fir and advanced regeneration in these stands. The amount of suitable or unsuitable habitat in the baseline will change as updated information is acquired. Field verification will occur and update baseline numbers on the implementation checklists. This would change salvage area layout as SRLA standards limits are approached. 6-3 Interim Salvage Guidelines were designed and drafted by the Forest to maintain salvage activities while addressing the uncertainty of how those activities and spruce beetle mortality may impact 296 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # lynx. The guidelines call for retaining pockets of dense horizontal cover (even if the overstory is over 75 percent dead), snags, advanced regeneration, and maintaining movement corridors. The preferred alternative proposes to harvest in these stands, which are a source of snowshoe hare and near to lynx kitten rearing and foraging areas. Response: Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors (e.g. study results from Squires et al.), and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. As a point of clarification, even if the proposed alternative were selected, it includes the option to harvest those acres, but does not imply that all acres will definitely be harvested. 6-4 In our November 27, 2017 letter, we stated that, “The Service believes that Alternative 2 does not 6a-1 provide adequate conservation for the Canada lynx and that Alternative 3 will deliver a higher level of conservation.” We wish to clarify the statement as follows: The U.S. Forest Service developed Interim Salvage Guidelines with the objective to “provide guidelines to promote salvage activities while providing for biological uncertainty and legal defensibility.” In presenting a range of alternatives for the DEIS, Alternative 2 does not include the Interim Guidelines. However, Alterative 3 does include the Interim Guidelines and provides a better framework for the conservation of the Canada lynx compared to Alternative 2. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Alternative 2 did not include the guidelines in order to show maximum management flexibility under the Forest Plan. However, many of the project design criteria proposed under alterative 2 satisfy the intent of the suggested guidelines and conservation of lynx habitat in general. Prior to selecting a course of action, the Responsible Official will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 6a-2 Section 7 (a) (l) of the Endangered Species Act (Act) [as amended] states that all Federal agencies...shall use their authorities in furtherance of the purposes of the Act by carrying out programs for the conservation of endangered and threatened species... As stated in our previous letter, many of the proposed treatment areas in Alternative 2 are described as some of the best lynx habitat on the District with breeding and rearing occurring in these areas. Table 7 in the DEIS displays the following design criteria: “Focus on protecting high quality advance regeneration (≥35% DHC) where it occurs in blocks of 0.3 acres or larger. To be applied in lynx habitat priority 1 and 2 areas where stands are essentially single-storied and regeneration is minimal. See appendix F fora detailed description of the lynx habitat priority areas” (DEIS pg. 33). This criterion is designed to minimize effects to, among other things, the Canada lynx; however this criterion is not specified for Alternative 2. Furthermore, the term "focus" implies some level of uncertainty in regards to application of the design criteria. We believe this criterion should simply state that areas meeting the described conditions should be avoided. By replacing the term "focus on protecting" with "will be avoided," any ambiguity regarding implementation of the design criteria will be eliminated. Salvage operation within stands that meet the criteria reduces horizontal cover, which reduces the ability of these areas to support the Canada lynx's primary prey. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available and the levels of 7(a) 1 opportunities implemented vary by alternative due to the stated purpose and need. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. The terms ‘Focus on protecting’ is used to provide flexibility in the alternative such that not every patch within a low-quality stand is protected, given that higher quality stands are already excluded from alternative 3. Under either alternative, the District Wildlife Biologist will likely identify important areas to avoid during layout, in combination with PDCs avoiding impacts to dense

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Letter # - Comment and Response to Comment Comment # horizontal cover. This PDC does not apply to alternative 2, although other conservation measures focused on avoiding damage to dense horizontal cover do apply. 6a-3 In addition to our recommended changes to the design criteria terminology, we recommend Alternative 3 be selected for implementation, because the Interim Salvage Guidelines are included as project design criteria and will assist the Forest Service in meeting their ESA responsibilities under the Act and meet the objective of the criteria. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 20-38 The Forest Service should adequately consider and disclose likely impacts to wildlife and aquatic life from this project. The project is likely to have negative impacts on Canada lynx, its habitat and habitat connectivity. Response: Detailed analyses are provided in the Wildlife and Fisheries Reports. 20-92 As the Forest Service considers the efficacy of this proposal, it is imperative that impacts to Canada lynx are thoroughly disclosed, analyzed, and vetted before any final decision is made. Additionally, the Forest Service must ensure that the project complies with all aspects of the Southern Rockies Lynx Amendment (SRLA). The DEIS remains deficient in several respects. Response: All SRLA requirements would be met under all alternatives. A detailed analysis of the effects to Canada lynx is provided, refer to the BA. 20-93 As an initial matter, DEIS page 67 has a sentence with an asterisk, however there is no corresponding note associated with the asterisk. Please clarify whether this is an errant asterisk, or if there is a missing explanatory phrase. Response: Asterisk deleted, refer to BA for more information. 20-94 Importantly, the Forest Service should publicly post–and discuss in the EIS the importance of–the Rio Grande’s annual report that it must provide to the U.S. Fish and Wildlife Service under the Southern Rockies Lynx Amendment (“SRLA”). That report is to include information on timber harvest on the Forest, including how much logging has occurred and how much more is allowed under the SRLA. Because this report is supposed to contain both qualitative and quantitative discussion of logging in lynx habitat, and should be completed on a regular basis by the Forest Service, it should be easy to incorporate such data into the EIS. Response: These data are incorporated and reflected in the environmental baseline, BA section 2.1 A. Clarification referring to forest-level SRLA allowances for exemptions and exceptions (caps) were included in the BA. 20-95, The baseline conditions analysis provides some useful information, however ultimately fails to 20-96 provide sufficient information. Additionally, while there is some qualitative analysis that could be augmented, there is an insufficient amount of qualitative analysis. It is essential that the Forest Service complete both types of analysis. For example, in the LAU Baseline Conditions section on DEIS page 68, several LAUs are mentioned and there are notations indicating that it was last impacted by a particular logging project: “The [Victoria-Chama] LAU was last impacted by the Cow Camp Salvage Project.” While this level of detail is helpful, it raises additional questions relevant to the baseline analysis. To what extent was the LAU impacted by this salvage logging project? When did this salvage logging project occur? Did the Forest Service use any SRLA exceptions to conduct this logging? What percentage of the LAU was impacted by the prior salvage logging project? These questions must be answered in the DEIS for each LAU to properly give the public an opportunity to comment on this salvage logging project. Furthermore, for many of the LAU’s referenced in this section of the DEIS, there is mention that timber harvest has occurred on private lands within the LAU, however there is no discussion of how much or where such logging has occurred. This information should be provided in a quantitative manner as well as on a map. A simple statement that private land logging has occurred is not

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Letter # - Comment and Response to Comment Comment # sufficient to meet the Forest Service’s obligation to disclose and analyze past, present, and reasonably foreseeable future impacts under NEPA. Response: The information on past projects is provided in the project file for each of the projects listed, which were available for public review and some of which are still available on the Forest’s website. The effects of the actions and results of post-project monitoring are incorporated into the environmental baseline and therefore are already accounted for, see BA section 2.1 A. The Forest Service does not collect information on individual landowner’s planned actions on their private lands. Assessments were done via aerial photographs for noticeable harvests to incorporate into the environmental baseline, however small operations can be indistinguishable from the surrounding landscape. Available information from larger landowners is provided as part of the cumulative impacts section, BA section 2.2 Cumulative Effects. 20-97 Additionally, the Forest Service should include a map in the DEIS showing the locations of the LAUs in or near the project area, as well as the locations of past timber harvest (noting when the harvest occurred) and the locations of the proposed logging units for this project (and road locations). Response: Maps are included in the BA and Wildlife Report. 20-98 Table 27 in the DEIS should also be replaced with an updated table showing actual data, and not estimated data. It is inappropriate for the Forest Service to move forward without actually knowing the on-the-ground situation with regards to the landscape, especially when dealing with a threatened species such as Canada lynx. NEPA requires that actual baseline data be provided, and table 27 falls well short of that requirement. At a minimum, additional explanation should be provided in terms of which data is an estimate and which is not, as well as explanation of what the various column labels mean. Interestingly, on page 67 of the DEIS, the Forest Service creates a four category system for differentiating habitat that it asserts is better than “suitable” and “unsuitable.” While that may be true, the Forest Service has an obligation to then use that category system and provide the relevant data for each of the four categories of lynx habitat on page 67. Table 27 does not do so, and uses the “unsuitable habitat” designation that was described as problematic just two pages prior. At a minimum, the Forest Service must explain what it means by unsuitable, given its use of a four category habitat classification system, but the better course of action would be to disclose how much of each of the habitat category types occur on the Forest to augment table 27. Response: This table reflects actual baseline numbers as they can best be described at this date and time. It is not feasible with current staff and funding levels to field-verify all lynx habitat in a reasonable timeframe prior to completion of NEPA given the limited time that beetle-killed trees retain value for purchasers. Refer to BA section 2. In addition, not all areas will be harvested. Each area that will be harvested will be field-verified (ground-truthed) by resource specialists prior to harvest. The four habitat categories were designed not to distinguish suitable vs. unsuitable but rather as a description of the range of suitable habitat. Category 1 = unsuitable habitat, 2-4 describe the range of suitable habitats from marginal to high quality, refer to BA section 2. 20-99 The Forest Service must describe in complete detail –using numeric quantification and detailed maps –what lynx habitat exists in the Project area. This should not just identify mapped lynx habitat, or occupied lynx habitat, but should also include the different types of lynx habitat, including denning, foraging, and winter habitat, as well as linkage areas and connectivity corridors. Response: Detailed analyses are provided in the BA section 2. In agreement with the USFWS, the USFS no longer differentiates winter foraging or denning habitats, however, habitat analyses has been completed, including the denning model in an effort to try and identify the best denning habitat. 20-100 The DEIS states that much of this information is not yet known because the Forest Service has not conducted the requisite field work in planning this project. For example, the DEIS states: “This area has been the focus of timber management the past decade; however, survey efforts have not been extensive.” DEIS at 67. This is but one example of several types of information that are lacking from the DEIS, with the Forest Service asking the public to trust that it will conduct the analysis during implementation. NEPA demands more.

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Letter # - Comment and Response to Comment Comment # Response: The USFS is limited by budgetary, personnel, and time constraints and therefore cannot conduct focused inventories of the whole area in such a short time span. This is not to be mistaken for having not conducted surveys ever, for instance we utilized over 700 recorded wildlife observations in the project area, however some species require more focused efforts than others. Where this is the case, the area is considered occupied until additional surveys are conducted to inform project design criteria during implementation. See analyses contained within the Wildlife Report for more information. 20-101 At page 68, the DEIS notes: “Given the severity of beetle impacts, these stands may provide crucial habitat for lynx prey in the coming decades.” But no additional information is provided. Are these stands mapped? Are they included in treatment units? Where are they geographically located in relation to logging units? More information about these “crucial” habitat areas for lynx must be provided to the public and not just mentioned in passing. Response: This is a general statement that refers to older plantations interspersed within the project area which may provide snowshoe hare refugia and source populations as neighboring areas with heavy beetle kill regenerate. These areas are mapped as field-verification allows, some of which are still considered stand initiation structural stage, however are not included in the logging units as the trees are not yet of merchantable size. Some partial cuts may have some salvageable trees, however may not be feasible or desirable for management due to snag retention and other habitat requirements. 20-102 At page 34, the DEIS states that a “wildlife biologist will work with timber staff to designate all harvest units within ½mile radius of any location where evidence of lynx reproduction has been documented within the previous 10 years.” Again, this is exactly the type of information that must be included in a NEPA document. There is no excuse for the Forest Service not including a map of containing this information, along with additional qualitative and quantitative information, for the mapped logging units. Response: The USFS in practice does not make specific locations of endangered species public where there are concerns over illegal or other activities that may harm the species. We also do not know where most lynx denning occurs or might occur in the future. 20-103, Of particular concern is that the Project area is in the middle of very important lynx habitat in 36-4 Colorado, both for resident populations, and serving as a corridor for lynx movement into northern New Mexico. Theobald and Shenk (2011) show that the Project area appears to overlap with areas of high, moderate, and low intensity lynx use (based on data generated from 1999-2010). See Theobald, David and Shenk, Tanya, AREAS OF HIGH HABITAT USE FROM 1999-2010 FOR RADIO COLLARED CANADA LYNX REINTRODUCED TO COLORADO (MARCH 31, 2011) at 11 (Attachment G). Ivan (2012) similarly shows that predicted winter and summer use by lynx in the Project area is incredibly high. Ivan, Jake et al., PREDICTIVE MAP OF CANADA LYNX HABITAT USE IN COLORADO (2012) (Attachment H). Response: Theobald and Shenk (2011) was considered in the analysis and during the development of alternative 3. We also included updated information regarding observations, tracks, and telemetry. Recently available preliminary information resulting from a recent lynx habitat use study on the Forest indicates that much of the project area may receive significantly less use by lynx in its current state. Regardless of predicted use, each alternative has measures in place to protect important lynx habitat. 20-104 … The LCAS also recognizes that managing forests to the extent that the canopy is opened discourages use of those stands by lynx. LCAS at 73. Further, reduction in horizontal cover, one of the potential results of the project, degrades the quality of winter habitat for lynx… Dr. John Squires, a leading lynx researcher, also emphasizes the importance of maintaining and recruiting lynx winter habitat as opposed to winter hare habitat because that is what is most important to conserve lynx, especially in winter when lynx are most taxed. Response: Logically,⎯ winter lynx habitat significantly⎯ overlaps winter snowshoe hare habitat given the close predator-primary prey relationship. There is no direction in the SRLA specific to lynx winter habitat because it closely synonymous with winter hare habitat. The main focus of the analysis of effects to lynx is on lynx habitat, particularly where salvage activities may occur. Snowshoe hares do make greater use of older plantations than lynx. Management impacts to these plantations are limited given the lack of merchantable trees. Refer to BA section 2.2. 300 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 20-105 The Forest Service should prioritize retention and recruitment of abundant and spatially well distributed patches of mature, multi-storied forest stands. The Project should be designed to conserve lynx winter habitat and manage stands in a manner that would allow younger stands to eventually become good lynx winter habitat. Young stands in the stand initiation stage may be decent habitat for snowshoe hares (once tree seedlings and saplings grow above the snow) but they are not good lynx winter habitat. Response: This was the basis for Alternative 3. It must be noted, however, that mature multi-storied forest stands are limited in spruce-fir stands post-beetle and thus so is our ability to provide them. This is also the reason behind the emphasis in field-verification, such that these areas could be identified prior to layout under any action alternative. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. Every alternative accounts for the retention and recruitment of multi-storied forest stands across the landscape. 20-106 Although lynx winter habitat is of great importance, the Forest Service still must analyze the effects of the project on snowshoe hare densities, including an analysis of the baseline, and anticipated effects. Further, because lynx in Colorado tend to consume greater proportions of secondary prey in their diets than elsewhere, the Forest Service must thoroughly examine potential effects to lynx secondary prey, including red squirrel. Response: Effects to lynx prey were considered as part of the analysis, refer to BA section 2.2. As mentioned in the BA and Wildlife Report, all green trees that are not safety hazards will be retained and available for red squirrels and other wildlife. 20-107, To comply with the SRLA, the Forest Service cannot merely conclude that it is meeting all SRLA 20-110 standards, guidelines, and objectives, but rather must fully explain how it will do so. Response: Refer to BA, section 2.3 for an explanation as to how we’re meeting the SRLA and how we will track and report impacts throughout the implementation of this project. 20-108 We are concerned about the implications of the beetle kill to how SRLA vegetation standards and guidelines are applied to different types of lynx habitat, especially given existing exceptions and exemptions. We are concerned that baseline conditions have changed since the 2011 habitat and LAU mapping30 to the extent that there is a shaky basis for making judgements about appropriate types and levels of commercial timber harvesting and other vegetation treatments in lynx habitat within the parameters of SRLA. For example, can Forest staff determine when an LAU has reached the 30 percent unsuitable threshold when applying Standard VEG S1? Response: Field work to date suggest that many areas on the district remain suitable habitat, however of degraded quality post-beetle. Estimates of post-beetle habitat suitability were made with the best available data at that time and allows for incorporation of updated information, such as habitat mapping conducted for the new Forest Plan and ongoing research (Squires et al.). Habitat mapping updates to reflect beetle influences have occurred, and SRLA standards and guidelines are still anticipated to be met. Further field-verification will also occur during the life of the project to verify the accuracy of habitat mapping. 20-109 Stands that have transitioned out of the defined habitat under Standard VEG S6 may require additional provisions to protect habitat. Are exceptions and exemptions to vegetation Standard VEG S6 (as well as VEG S1) still appropriate and applicable? There has been uncertainty as to whether lynx would use areas transitioning and transitioned out of multi-story, late successional conditions as trees die and fall. This mature forest condition has been considered by experts to be the highest quality winter snowshoe hare habitat, and thus, lynx habitat. Standard VEG S6 was implemented to protect multi-story stands. This state is becoming less prevalent in beetle-affected areas, and significant areas that were once in this state may no longer be meeting the SRLA policy definition for this high-quality habitat. However, rapid regeneration occurring in “formerly” high-quality, suitable habitat may be providing conditions—dense vegetation from re-growth—that are conducive to hare persistence. It is quite possible, but yet unknown, hares thrive under these conditions in the Southern Rockies. Response: We recognize that the classic VEG S6 stands as defined under the SRLA Implementation Guide are in transition due to bark beetle mortality and becoming rare on the 301 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # landscape. How hare and lynx utilize current and former VEG S6 stands are a focus of the current lynx study on the forest (J. Squires et al). The action alternatives address the change in S6 and other stand attributes in various ways. Based on current information, we suspect that lynx continue to use beetle-killed stands in similar ways (See BA, section 2). See also response to 20-122. Updated Standards and Guidelines are currently being developed for the 2018 Forest Plan to address the change in VEG S6, however these have yet to be finalized. As it becomes available, data from the Squires study and any new Forest Plan Standards and Guidelines will be considered in management. 20-111 The DEIS discusses the forest wide SRLA logging caps, but fails to actually disclose what those caps are, how much logging has been conducted under those caps, how much logging under those caps has been authorized but not yet implemented, and how much of the logging authorized by the Project would contribute to those caps. The Forest Service should also disclose whether or not it has been meeting its reporting obligations under the SRLA, and how often (and when) such reports have been submitted to the U.S. Fish and Wildlife Service. Response: Clarification is provided for the forest-wide SRLA exemptions and exceptions (caps). SRLA reporting to FWS is done on an annual basis and all obligations have been met. 20-112, Of particular concern is compliance with SRLA Guideline VEG G11 –pertaining to lynx denning 20-113 habitat…The Forest Service should analyze whether or not such areas of dead trees within the project area provide greater benefit to lynx if left on the landscape, as opposed to being removed through salvage harvest. Response: Denning habitat is not considered limiting on the Rio Grande NF, refer to BA section 2. Additionally, a local denning model was created to assess denning conditions on the Forest and how projects may affect future denning habitat. Under both alternatives, large acreages of suitable denning habitat will be left undisturbed across the landscape. 20-114 Importantly, the NEPA analysis must disclose the locations of any lynx analysis units (“LAU”) in or near the project area, and what percentage of each LAU is made up of lynx denning habitat, how much coarse woody debris currently exists within the denning habitat in each LAU, or what anticipated changes to coarse woody debris in each LAU’s denning habitat would result from the Project’s implementation. Response: Currently, the USFS does not differentiate habitat by denning, foraging, or other habitats but by suitable and unsuitable primary and secondary habitats. Please also refer to response to 20- 112. 20-115 The NEPA analysis should discuss and analyze how lynx movement through the project area would be affected by the project, and what impacts to lynx travelling to other areas would see. Particular attention should be given to both official lynx linkage areas as well as other known travel corridors in the project area. Response: Lynx movement is discussed in the BA, section 2.2, Effects on Connectivity. There are no Lynx Linkage Areas in the project area. 20-116 The NEPA analysis should fully discuss the effects of the construction of temporary roads, the recommissioning of previously closed roads, and the construction of new roads on lynx and fragmentation of lynx habitat, as well as snow compaction and the potential for recreational use of those roads. Response: Temporary and level 1 roads used for the project are not open to the public for motor vehicle use, however may be used for over-snow recreation. All temporary and level 1 roads would be closed at the completion of activities. See BA section 2.2 and refer to other responses to comments on temporary roads. 20-118 The DEIS must also take a hard look at the indirect and cumulative impacts to lynx, and specifically how the project will, in conjunction with other activities (including private, state, and federal activities), climate change (which poses a significant threat to the species, as stated in the 2013 LCAS), and other natural events cumulatively impact lynx in the immediate area of the project and the larger sub-population in the Southern Rockies. Response: The effects of the action are described in the BA, section 2.2. 20-119 Further, the DEIS relies on personal communications with Dr. Jake Ivan to support certain conclusions. See, e.g. DEIS at 178-79. These personal communications should be disclosed to the public so that it can review what Dr. Ivan actually stated and why it supports the Forest Service

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Letter # - Comment and Response to Comment Comment # conclusions. At a minimum, and given that some of these communications may not have been in writing, the Forest Service should disclose the nature of these communications, when they took place, and what was actually communicated. Response: Various on-going or recently completed studies, including some conducted primarily by Jake Ivan (CPW), were used as a foundation for the development of the Interim Salvage Guidelines which were reviewed by the FWS and subsequently used for creating the four habitat quality definitions used in this project. 20-120, Much of the Forest Service’s analysis focuses on impacts to LAU’s in the project area, but this is 20-121 too narrow… Forest Service of its obligation to assess impacts to lynx under NEPA throughout the entire project area. Limiting the effects analysis to only the two LAUs violates NEPA and prevents the public and the decision maker from being able to truly review the impacts of the Project. Response: LAU’s were created to represent average female home ranges in representative configurations, and were developed and approved in conjunction with the FWS. See BA section 2 and Mapping Rationale (2011). The 5 LAUs analyzed in the BA represent all treatment areas in the entire project area, see maps in BA Appendices. As recommended in the 2013 LCAS and the SRLA, LAUs are the standard for evaluating effects to lynx. Discussion of between LAU connectivity is provided in BA section 2.2. 20-122 Finally, in comments dated July 28, 2015 on the GMUG National Forest’s SBEADMR project, Patricia Dorsey (attached as Attachment M), the Southwest Region Manager for Colorado Parks and Wildlife (CPW)… We encourage the Forest Service to fully disclose the nature of these monitoring efforts, in particular those being led by Dr. John Squires of the Forest Service’s Rocky Mountain Research Station… The Forest Service should not proceed until this research is published and then incorporate the findings into the NEPA analysis, project design, and ESA consultation for the project. Response: We agree and analyzed that lynx continue to use beetle-killed stands in similar ways (See BA, section 2). Preliminary results being finalized by Dr. John Squires were considered during the analysis. Much of the report verified previous professional opinion regarding lynx use of post- beetle forests. We will continue to incorporate information from the local lynx study as it becomes available. 20-123 …The stands with advanced regeneration, which are the most likely to be used by lynx, will suffer 36a-7 considerable damage from activities under the proposed project. Felling, skidding, and clearing areas for landings would damage and/or destroy lynx habitat. This would include some areas where breeding has been confirmed. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. Under either alternative, a site specific assessment will be conducted to help protect critical habitat components for each project area. 20-124 The proposed action would violate the Southern Rockies Lynx Amendment Standard VEG S6, which prohibits actions that reduce winter snowshoe hare habitat, with four exceptions. The only one of the exceptions that could apply to the CP project is “for incidental removal during salvage harvest (e.g., removal due to location of skid trails)”. SRLA Record of Decision at Attachment 1-4. Under the project, habitat would be degraded or destroyed. This would not be “incidental”, it would be by design, i. e., an intended part of the project. Stated yet another way, the issue is not the placement of the skid trails, but rather the adverse impacts to habitat that would be caused by the project as a while, including use of the skid trails to cut trees which would degrade and destroy lynx habitat. Response: Under the SRLA damage due to skid trails, felling, etc. are considered incidental under the exception. PDC’s specific to these actions act to reduce, to the amount feasible, the incidental damage from these operations. Refer to BA/PDC. 20-125 Implementation of the project would likely violate Standard All S1, which requires that “vegetation management projects must maintain habitat connectivity in an LAU and/or linkage area”. Id. at Attachment 1-1. The proposed scale of cutting –18,000 acres, and the fact that cutting would occur 303 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # in the highest quality habitat and maybe in the remaining strands of higher quality habitat in the southern part of the project area -indicates that between-LAU connectivity and connectivity between Colorado and New Mexico is likely to at least be degraded. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. The SRLA provides direction for connectivity. During implementation of individual projects in lynx habitat, the wildlife biologist (and other IDT members) will evaluate the spatial distribution and habitat characteristics of proposed timber harvest boundaries in relation to features such as stream and wetland buffers, unharvested areas, or other areas that would provide movement zones across or between LAUs. Adjustments to proposed harvest would be made, as needed to ensure connectivity is maintained. In some cases, lynx habitat would improve in the long-term, possibly increasing habitat connectivity in some areas. 20-126 Under Alternative 3, operations would not occur in any category 3 or 4 stands (those with 20 or 35 percent or more dense horizontal cover, respectively, at the stand level31), nor in areas that could be denning habitat. DEIS at 26. Two LAUs likely to have the highest quality habitat would not be entered at all. Ibid. In general, “only low-quality lynx habitat would be salvaged” under this alternative. DBA at 35. These limitations should be applied to any action alternative. We are surprised and concerned that they are not proposed for use in the proposed action, as described in the DEIS. Without these limitations on the siting of activities, lynx habitat and its connectivity would suffer strong and unnecessary adverse impacts. Response: Under alternative 3 the Alamosa and Conejos Canyon LAUs would have salvage harvest, however as you mentioned alternative 3 only harvests in low-quality or unsuitable lynx habitat. The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 20-127 The Forest Service must ensure that its actions comply with the Endangered Species Act (ESA)… The Forest Service must consult with the U.S. Fish and Wildlife Service (FWS) under section 7 of the ESA as to the impacts of the project on species listed under the ESA and designated critical habitat. Response: FWS has been consulted as part of this project, refer to BA section 2.1 Consultation to Date. The effects of the project have been fully analyzed in the BA. FWS will continue to be consulted/conferenced with, as needed, throughout the life of this project. 20-128 Where a species is proposed for listing (like the wolverine), or critical habitat is proposed, the 20-129 process is different. Section 7(a) (4) of the ESA requires a Federal action agency to conference with the Services if a proposed action is likely to jeopardize a proposed species, or destroy or adversely modify proposed critical habitat. 16 U.S.C. § 1536(a) (4); 50 C.F.R. § 402.10(a). The agency fails to provide any information regarding consultation efforts related to the wolverine, instead concluding without any reference to recent science or studies that impacts to wolverine from this project are likely negligible. Response: See BA Consultation to Date section 2.1. Should FWS designate or propose critical habitat in the project area, consultation on the project would be reinitiated. Wolverine are considered extirpated from the state and thus were analyzed as not being present in the project area. Should verifiable observations occur on the forest, consultation would be reinitiated. 20-130 We encourage the Forest Service to be transparent about the consultation process and affirmatively post all consultation documents, including any Forest Service Biological Evaluations or Assessments, any letters seeking concurrence, and any responses or Biological Opinions from FWS. Response: FWS formal comments to the DEIS are available on the project’s website and Final EIS. The FWS BO and final USFS BA will be made available with the Record of Decision. 36a-5 We are concerned regarding Alt. 2 being the proposed action as compared to Alt. 3. We fail to see a justification or rationale for Alt. 2 being the preferred action – especially regarding Canada lynx. It is clear from statements in the DEIS that Alt. 2 will result in a greater loss of high quality habitat 304 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # and harvests twice the amount of spruce-fir compared to Alt. 3 (p. 85, 84, 74, 75, 78, 79). It is clear that Alt. 3 has significantly less negative impacts to lynx, ad crucial habitat components would be retained. Response: Alternative 2 is the preferred alternative because it best meets the purpose and need for the project, while still providing adequate protection measures for all other resources, including lynx. The EIS is required to identify the preferred alternative, and the Record of Decision will identify which alternative(s) were considered environmentally preferable. 36a-6 It is clear that Alt. 3 has significantly less negative impacts to lynx, ad crucial habitat components would be retained. There are additional project design features to ensure greater protection for regeneration, and temp road miles would be less. Also –Alt.3 does more to provide retention in Conejos Canyon and Alamosa LAU areas and protect important breeding areas. Response: Alternative 3 was designed to incorporate more protections for lynx and other species. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 36a-10 Also –research regarding lynx use of beetle-kill forests has not been completed (pg. 66) and we believe this DEIS should have waited until completed to make determinations regarding project impacts to lynx. Response: The project is open to receiving and incorporating additional information and incorporating this information as appropriate. However, waiting for research to be completed may not meet the purpose and need for this project which includes salvaging dead and dying trees while these trees still have economic value. Potential effects to lynx and lynx habitat are disclosed in the wildlife BE/BA for this project and are summarized in the EIS, section 3.4, Wildlife. 36a-13 Page 76 notes that it is 30-50 years before understory conditions provide quality prey and lynx habitat. Beetle-kill, climate change and harvesting effects will reduce prey –and thus reduce lynx. That is why Alt. 2 is far too great in negative effects for lynx and other species and should not be the proposed action, and violates the ESA. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. All alternatives will at minimum meet SRLA and Forest Plan Standards. Lynx studies conducted on the Rio Grande National Forest are currently being synthesized, preliminary reports and maps have been provided, and all information suggest lynx and snowshoe hare appear to be persistent in the post-beetle forest condition. Areas used by lynx before beetle mortality still tend to be used by lynx post-mortality, however some shifts in use over time is an appropriate assumption as stands regenerate. Alternative 2 was designed to meet the requirements of the SRLA and remain in compliance with ESA.

Wildlife (other than lynx), Rare Plants and Fisheries Letter # - Comment and Response to Comment Comment # 1a-15, M. Beth Davis is not listed in the USFS email directory. Therefore she is not a USFS employee. 1a-16 Why was she chosen to lead the IDT? Who does she represent? Chapter 3 contains a 30-page section describing the effects of sale implementation to wildlife, yet there is no wildlife biologist listed as an IDT member. Request for changes to be made to the final NEPA document: Add a Wildlife biologist to the IDT and have him/her re-write and modify the analysis of effects to wildlife. Tell the public M. Beth 305 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Davis is not a USFS employee, yet she was IDT leader and wrote the noxious weed eradication section. Tell the public who she represents. Response: All specialists that contributed to this EIS, including Mary E. “Beth” Davis, are Forest Service employees and are listed in chapter 4, section 4.1. No changes were made to the EIS based on this comment. 20-39 The Forest Service should consider impacts to wolverine based on the best available science. Response: Refer to BA section 2, consultation to date. 20-40 The agency should also consider impacts to species of conservation concern, identified according to the 2012 planning rule. The Rio Grande National Forest has completed its pre-assessment of the forest, in which it identified species of conservation concern as required by the 2012 planning rule. Response: The list of Species of Conservation Concern (SCC) is yet to be finalized, with a final list selected with the final ROD associated with the plan revision. The Forest is therefore required to utilize the current Regional Forester sensitive species list. However the list of proposed SCC considerably overlaps the current list of sensitive species and therefore those species are considered within the analyses. The three remaining species currently proposed as SCC are thought to occupy areas primarily outside of spruce-fir habitats and would thus be minimally affected by the action. 20-41 The project will have negative impacts on marten that are not adequately addressed in the analysis. See, e.g., DEIS at 87.Marten are a mature and old growth spruce-fir forest species that require protection and consideration from the Forest Service. Although some impacts are listed, there is no discussion of the impacts to marten prey, including the southern red-backed vole, and the impacts of salvage logging on them. There is no discussion about how the logging and hazard tree activities proposed under alternatives 2 and 3 will affect marten or its prey. Indeed, scientific literature suggests that red-backed voles have a negative association with salvage logging following insect outbreak events. See Saab, Victoria, ECOLOGICAL CONSEQUENCES OF MOUNTAIN PINE BEETLE OUTBREAKS FOR WILDLIFE IN WESTERN NORTH AMERICAN FORESTS (2013) (attached as Attachment L). This issue deserves further consideration by the Forest Service. Response: Detailed analyses are provided in the Wildlife Report, section 3.2. 20-42 The project will have negative impacts on big game, including elk and deer, as well as ungulates such as moose. Response: Analyses are provided in the Wildlife Report, section 3.3. 20-43 Over 400 acres of Management Area 5.41, deer and elk winter range, is proposed for treatment. But despite recognizing that deer and elk are sensitive to roads and related disturbance, DEIS at 88, the project design criteria do not address the 1996 Forest Plan standards for protecting big game like elk and deer or maintaining habitat connectivity. See, e.g., III-26 (directing the Forest Service to “[p]rovide adequate cover to maintain screening along roads that are kept open for human use and around openings, so as to minimize disturbance and harassment of deer and elk”). Instead, the Forest Service defers these types of protections to a future analysis under the project pre- implementation checklist, which asks the agency to list any standards, guidelines, or handbook direction specific to the activity that is not addressed by the project design criteria. DEIS at 174. Response: All Forest Plan Standards are incorporated into the project design. Impacts to advanced regeneration (screening cover) will be minimized to the extent feasible for big game as well as lynx habitat. No new open roads would be created through the project. 20-44 The location of the 400 acres of Management Area 5.41 proposed for treatment should be disclosed to fully assess the effects of this project on deer and elk. Response: A map of this area is contained within the Wildlife Report. 20-45 The Forest Service discounts these impacts as “temporary.” DEIS at 141. But since the project is proposed over a 10 to 15 year period, it is difficult to understand how these impacts will be temporary. The agency also states that open road density will remain the same, thus having little impact on deer and elk. DEIS at 90. But this must ignore the proposed new temporary roads and re- opening of existing roads in its calculation —which together under Alternative 2 will add more than 60 miles of new roads, the use of which is certain to have lasting impacts on deer and elk. Response: The impacts of roads to big game is almost exclusively tied to disturbance from motorized vehicles and road hunting. Temporary roads are not open to the public during operations and will be closed afterwards. No new roads would be created that are open to the public. Thus the

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Letter # - Comment and Response to Comment Comment # effects to big game from temporary roads is limited to the operating period (approx. 1-5 years). Once closed (decommissioned) temporary roads have minimal impact to big game. 20-46 This is precisely the type of site-specific information that the Forest Service must provide up front in its NEPA analysis to allow for meaningful public comment. Response: See responses 20-44 and 20-45. Also see response 20-63 concerning open road density. This information has been provided for meaningful public comment. Additional public feedback opportunities have also been incorporated into the adaptive implementation process as an extra measure of responsiveness to this and similar comments. 20-47 …the project will likely have harmful impacts on cutthroat trout, but the agency states broadly that the project is not expected to impact cutthroat trout. DEIS at 87-88.The analysis must provide site- specific analysis and details to fully identify the impacts to cutthroat trout. Without more details, the agency’s approach precludes meaningful analysis here. Response: Error, reference to Rio Grande Cutthroat Trout as not expected to be impacted removed from Wildlife Section 3.4. Impacts to fisheries including Rio Grande Cutthroat Trout are evaluated in Section 3.5 including by-watershed analyses. Both action alternatives are expected to have potential impacts, but with implementation of PDC’s, Forest Plan Direction, and monitoring are expected to be controlled and minimized to the extent that any negative influences on aquatic habitats and fisheries are non-measureable or short-term in nature. 20-48 The Forest Service must consider and analyze areas important for wildlife movement and connectivity. Modeling data shows there are a number of potential wildlife corridors within the Rio Grande National Forest, and between the forest and adjacent units. Because of the importance of the Rio Grande National Forest to wildlife movement, particularly the area south of the San Juan Wilderness, we request that you analyze the impacts of the logging project on species movement and the potential for disruption and fragmentation of these known movement corridors between the Carson and Rio Grande National Forests. The BLM’s Taos Field Office (FO) identified big game corridors in its 2012 Resource Management Plan (RMP). 6 While the corridors identified on this map are restricted to New Mexico, they do speak to the area in the northern part of the Carson National Forest’s Tres Piedres Ranger District proximal to the Rio Grande National Forest. See Attachment D (map showing the BLM’s Taos FO Big Game Corridors overlaid with the Rio Grande National Forest and other units in the Upper Rio Grande Basin). The BLM’s (2014) San Luis Valley –Taos Plateau Ecoregion Landscape Pre- assessment identifies preliminary big game migration corridors in Colorado and New Mexico as part of the larger landscape assessment. 7 The data used to identify these corridors is from the BLM and Colorado Department of Parks and Wildlife. Response: Habitat connectivity can be considered at the landscape level through such areas as existing wilderness, specially designated areas, and Colorado roadless areas which are designated in a large portion of the Forest and are exempt from large mechanical vegetation treatments, these aid in providing connectivity for some species at these scales. Wide ranging species, such as deer and elk, evolved within a mosaic of habitats and would be less sensitive to patterns associated with created openings. Other species, such as lynx, would be more sensitive to created openings at smaller scales. Refer to BA section 2.2, Effects on Habitat Connectivity and the Wildlife Report, section 3.3. 20-49 The Forest Service should also consider how this project may impact the proposed Spruce Hole Osier Toltec Landscape Connectivity Zoological Area. Response: The proposed Spruce Hole Osier Toltec Landscape Connectivity Zoological Area is associated with Alternative D of the draft plan revision. If associated with the final ROD of the plan revision, it would be incorporated during the implementation phase through implementation checklists. 20-50 Raw focal species telemetry and genetic data will help identify key sites supporting focal species movement at fine scales and confirm that a focal species does indeed utilize a particular site predicted to be important for movement by models. The Forest Service should consider radio- collared data related to lynx, as well as any telemetry data from Colorado Parks and Wildlife related to lynx and other species.

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Letter # - Comment and Response to Comment Comment # Response: Telemetry data were considered as part of the lynx effects analysis, refer to BA section 2.1 A. Focal species are part of the 2012 rule and revision process and are not currently part of our 1996 Forest Plan. That said, focal species would be considered in our updated Forest Plan and considered once that is finalized. 20-51 In partnership with the Colorado Department of Transportation, the Federal Highway Administration, The Nature Conservancy, and Colorado State University, the Southern Rockies Ecosystem Project launched Linking Colorado’s Landscapes in fall 2003. The purpose was to identify and prioritize wildlife linkages across the state of Colorado to promote safe passage for wildlife. This report8 documents the process used to define the locations of important wildlife linkages and to prioritize these areas for further assessment, and describes the decision-making process that led to the selection of high priority linkages, including several species linkages on the Rio Grande National Forest. Response: Terrestrial species linkages that may be affected by the action are currently high functioning according to the report (Map 4). There are no high priority linkages identified in Map 26 that may be affected by the action. Our current Lynx Linkage Areas were derived from information contained within this report. There are no Lynx Linkage Areas designated in the project area. Connectivity for lynx is considered in the BA, section 2.2 and elk in the Wildlife Report, section 3.3. 20-73 Salvage logging can negatively impact snag dependent species such as woodpeckers (primary cavity nesters) and other birds.12 Flammulated owls are secondary cavity nesters and need a high density of large snags. They may prefer snags >25 inches at dbh, and the low threshold may be 2-8 snags per acre at >13 inches at dbh. See Manley, I., P. Ohanjanian, and M-A. Beaucher. 2004. Inventory of Flammulated Owls Breeding in the East Kootenay 2003. October. Nelson et al. (2009) found that a minimum threshold for snag dbh may be 12 inches, but the average is 20 inches. This calls into question whether uncertain levels of post-disturbance salvage logging at uncertain sites is a management tool that supports sufficient snag retention and density for a variety of snag-dependent species and, thus, ecological integrity. 13 Response: Snags meeting the criteria outlined in the PDC would be retained at levels above Forest Plan standards within timber sale areas and would be in abundance outside of timber sale areas and RMZ’s. Flammulated owls occupy mixed-conifer, ponderosa pine, and aspen habitats on the district that generally occur at lower elevations than considered for the district salvage project. We currently have more local information regarding flammulated owls, their use of snags in the area, and also support ongoing research on the district. Refer to the Wildlife Report section 3.2 for more information. 36a-2 We were involved in a past timber sale near the Silver Lakes Trout Club area about 20 years ago – and there was a listed plant species of concern in that area – a Botrychium (fern species) – and there is no mention of this rare plant in the DEIS. Please refer to past project files and address the threat to this rare plant in the FEIS. Response: Botrychium lineare was removed from the Regional Forester for the Rocky Mountain Region’s sensitive species list in 2015 because it no longer met the criteria for designation as sensitive based on new information (FSM 2600, 2672.11 Exhibit 01, August 29, 2015). There are three known occurrences of Region 2 sensitive plants in the 332,000-acre project analysis area. Effects to TES plant species are summarized in the EIS, chapter 3, section 3.6 and discussed in detail in the TES Plants Specialist Report in the CPDWS project record. 36a-9 Because the DEIS acknowledges an approx.30% incidental damage estimate, and blow-down of remaining green trees, along with decrease in red squirrel prey densities, etc. –we are concerned regarding Alt. 2 and the justification for this alternative. Response: The alternatives provide a range of actions from No Action to maximum management flexibility to analyze the breadth of potential actions available. Prior to selecting a course of action, the Responsible Officials will review and consider the effects described in chapter 3, the resource specialist’s reports, public comments, and other factors, such as those mentioned, and may choose to implement any of the action alternatives, no action, or a combination of the analyzed alternatives. 36a-14 The Forest Service needs to survey for Boreal own in the project area. We documented Boreal owls in the Cumbres and La Manga Pass areas over 25+ years ago –and there are reports of Boreal own nearby on the Tres Piedras District of the Carson National forest just south of this project area. 308 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # Response: The FS has conducted boreal owl surveys in recent salvage sales (Spruce hole, cow camp, etc., refer to those project records). Surveys will continue as a part of this project (See Wildlife Report, section 3). The District Biologist would love to receive reports of any observations you may have for boreal owls or other sensitive/species of conservation concern.

Heritage Resources Letter # - Comment and Response to Comment Comment # 20-61 No site-specific information is provided about heritage resources. Instead, the Forest Service relies on its project design criteria (DEIS at 35-36) and pre-assessment checklist, deferring the gathering of any specific information to some future undisclosed date. See, e.g., DEIS at 39, 130-131. This shields the action from full analysis and fails to disclose information necessary for meaningful public review, contrary to the purpose of NEPA. Response: A Programmatic Agreement (PA)* between the Rio Grande NF and the Colorado State Historic Preservation Office (COSHPO) allows for site-specific Section 106 cultural resource surveys required by the National Historic Preservation Act (NHPA) to be completed after the DEIS is signed but before implementation of tiered undertakings (Appendix L of the EIS). Tiered undertakings will be fully analyzed for cultural resources under Section 106 with full review by the COSHPO for determination of effect and site eligibility before project implementation. To become a signatory on the PA the Forest consulted with the Advisory Council on Historic Preservation (ACHP) in Washington D.C., the COSHPO, nineteen affiliated Tribes, and several municipalities and certified local governments within the influence area of the Rio Grande NF. *A Programmatic Agreement among the Advisory Council on Historic Preservation, the Colorado State Historic Preservation Office and the U.S.D.A. Forest Service, the Medicine Bow-Routt National Forests, the Arapaho and Roosevelt National Forests, the White River National Forest, the Pike and San Isabel National Forests, the Grand mesa, Uncompahgre and Gunnison National Forests and the Rio Grande National Forest Regarding the Implementation of Bark Beetle Management, Hazardous Fuel and Tree Reduction Programs and Management of Cultural Resource Programs within Hazardous Tree Environments

Recreation Management Letter # - Comment and Response to Comment Comment # 1a-23 Why do you reject the findings and conclusions of Undersecretary of Agriculture Jim Lyons who 1a-26 states “recreation revenues from national forests significantly exceed timber revenues.” Elsewhere 1a-27 in these comments are the results of public survey information indicating the public is less likely to recreate near areas that have been logged, thus logging diminishes recreation revenue. Since recreationists avoid areas that have been logged the many “ma and pa” businesses that depend on recreation & tourism dollars are harmed. How do you justify harming the revenues of motels, gas stations, restaurants etc. to increase the profits of a large corporations? Ranger Jones, I have presented you with verified information showing outdoor recreation generates 790 billion dollars and 65 million jobs annually. Most of this benefits local economies. The fact is, the CP District Wide Salvage timber sale will harm the economy of the communities near it. People seek out areas that have not been logged for their recreation. I hope you get the chance to tell the judge this isn’t true.

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Letter # - Comment and Response to Comment Comment # Your P&N tells the public one of your timber sale purposes is to “promote economic sustainability for local communities, including the forest product industry.” If this is really your goal, you would keep large mills from areas that aren’t near local communities with lumber mills, from bidding on the sale if it were offered under the small business authority Response: Analysis of amounts of revenue produced or collected from various uses of National Forest System lands is outside the scope of this analysis. No major concerns were identified during scoping regarding the potential for diminished visitation or a decrease in recreational use following implementation of proposed management activities; the adaptive implementation process (EIS, section 2.2) provides an opportunity prior to implementation to identify mitigation to lessen any short or long-term adverse effects, including near developed recreation sites. Part of the purpose and need is to protect infrastructure and reduce hazards in areas where there are extensive numbers of dead trees adjacent to developed recreation facilities or other infrastructure. Effects of the proposed activities on recreational uses and scenic resources in the project area were considered in sections 3.15 (Recreation Use) and 3.16 (Scenic Resources) of the EIS. 2-14 We support the proposed salvage harvest near the CDNST. We recommend that you not use “maximize” or “minimize” in the design features as those are ambiguous; for example, does “minimize slash piles” mean that no slash piles will be allowed? Response: The use of these words is consistent with many documents used in timber management, and it is purposely used in addressing the CDNST. “Minimize” shall mean to have in the least amount in volume and number. Quantifiable numbers can be determined at a project specific level. 28-1 I am writing as an interested party with regards to the portion of the logging project near FR 114 through and the Grouse Creek drainage. I own and operate a recreational business that includes the Grouse 28-7, Creek Yurt, www.SouthwestNordicCenter.com. This winter represents the thirtieth year that I have 28a-1 operated in the Rio Grande National Forest. My business has already been detrimentally affected by through previous and still ongoing logging operations in the Trujillo Meadows and Neff Mountain areas. 28a-3 The EIS for the Trujillo Meadows logging stated that effects would be negligible for the Yurts I operate and recreation in general. I want to assure you that this has not been the case. The most significant impact has been a result of "winter" logging. From both a safety and aesthetic perspective it is contrary to the recreational offering presented by the Yurts. Response: The balance between differing resource uses is often difficult to attain, as attested by the multiple conversations we’ve had over the years in effort to meet needs of both the yurt special-use permit and other resource protections. As discussed within the EIS, logging over snow or frozen ground conditions is predominantly beneficial for all natural resources. The primary source of winter recreation conflict comes from the use of logging roads as cross-country ski routes, when they are also needed as haul routes. A secondary source of conflict is the location of yurts within forest products Management Area Prescriptions (5.11 & 5.13). Effort has been made by the Forest Service to alleviate these issues by independently locating, discussing with the permit holder, and mapping alternate ski routes to avoid the need for dual road uses. Safety concerns have been limited by the following elements: 1) A skier has opportunity to hear log truck approaching from a distance and can move to a safe location; 2) The alternative route has been provided as an option for the avoidance of most, if not all log truck traffic, and a safe working distance has been maintained off of this route for skier protection; 3) No wintertime harvest activity has occurred adjacent to yurts. Only one yurt was situated within a harvest unit, which was cut during the summer of 2008. Other yurts have been located away from harvest units. Concerning aesthetics and noise, it is not feasible to keep yurt clients from hearing or seeing a harvest operation within Management Area Prescriptions 5.11 and 5.13. As with summer recreation within these areas, the Forest Plan states that visitors can expect to see managed but natural- appearing stands of trees, and recently cut areas will show tree stumps, slash, skid trails, and soil disturbance. The reference made to accommodations for the Spruce Hole yurt is close, but not completely accurate. No logging operations were allowed over the Thanksgiving weekend because of a clearly defined reoccurring client use during that timeframe. Otherwise, operations were to cease after December 1. As the commenter is aware, the December 1 date restriction was equally applied to all sales that could impact access to and use of the Neff Mountain yurt, which was

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Letter # - Comment and Response to Comment Comment # described as the most heavily-used yurt. These concessions were made to provide equity between operators, even though not required by the Cumbres EIS. As a result of this comment, additional analysis was conducted for this project to assess the potential for impact to the Grouse Creek yurt use as a result of winter operations. Use records submitted by the permittee indicate that, within the last ten year period, this yurt has been used a total of four times on dates earlier than December 15. These uses resulted in a total revenue of $310, equaling an average annual profit risk of $31/year. Consistent client use begins during the Christmas holiday season. Because of this comment and research, a project design criteria was added to the FEIS to minimize, to the extent feasible, impacts to yurt special-use permit holder profit and customer safety by restricting logging activity adjacent to yurts and on or adjacent to specific access ski routes after December 10 of each year. 28-8 The proposal states that the logging operation will likely take only a couple of years but the permit period will be for 10‐15 years. This means the area is shut off to other uses such as summer yurting. It also implies that there will be no hurry to remove the large debris piles left during logging activity. Anyway the time periods could be more in line with each other? Response: Summer Yurt operations are not currently permitted. No areas are “shut off” to summer use. Special use proposals are independent of this project. The timeframe given in the analysis includes all activities (including planting) across the entire project area, not specific locations. 28-9 Finally I have had difficulty obtaining information regarding the CP Salvage project. I have left Mike Tooley several phone messages over the past 2+ weeks and also on for Beth Davis Graham to no avail. I have not been able to locate the actual proposal on-line as indicated in the interested party letter I received. Hopefully, it is not too late for my comments to be considered. Response: We regret that you had difficulty locating the information and corresponding with us. At least two efforts were made on our part to contact you back. As mentioned in the letter, a paper copy or CD could have been requested, and an e-mail address was also provided as an additional correspondence option.

Social - Economics Letter # - Comment and Response to Comment Comment # 1a-22 Dr Power makes the following conclusions from his research findings: “Even within relatively isolated areas, such as the northeastern tier of counties, there was considerable economic vitality despite the declines in federal timber harvests.” “The relatively high unemployment rates in many of the eastern Washington counties adjacent to National Forests cannot be attributed to the decline in federal harvests. Those counties had even higher unemployment rates at the time of peak harvests in the late 1980s.” Response: The referenced study was published following large declines in timber harvests off national forests in the 1980s and 1990s and the 1999 Clinton Administration’s Roadless Area Initiative. It focused, in part, on whether the economic benefits would be greater; along with the local economic trade-offs, if national forest inventoried roadless areas (IRAs) in Washington State were managed for commercial timber products compared to restricting commercial activities and focusing on the non-commercial, natural forest values and services. The study also analyzed how increases in population and other demographic changes offset reductions in forestry jobs following declines in federal harvests. For the CPDWS project there was no attempt or identified need to include a full economic impact analysis related to jobs and incomes for any of the alternatives considered in detail. As directed by FSM 1971, section 3.13, Social-Economic is focused on the comparative financial efficiency of the alternatives, considering quantitative costs and benefits of the alternatives. Some benefits, such as increased forest resiliency are not readily quantified, so are described qualitatively. There is also no commercial timber harvest activities proposed in any designated Colorado Roadless Area/IRA. All proposed activities would be consistent with the Forest Plan and the 2012 Colorado Roadless Rule. 311 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # 1a-24 You reject the research conclusions of 241 Ph.D. scientists quoted in Opposing Views Attachment #1 who demonstrate how logging-related harm (and in a few cases destruction) is inflicted on multiple natural resources in and near the sale area. Incredibly, you rely on the advice of 3 or 4 timber employees financially motivated to sell timber. You know the log for community stability P&N statement appears in at least 80% of all timber sale NEPA documents. This has become the commonly used excuse by USFS line-officers to sell unneeded timber sales and you use it here. Response: Review of the submitted references and opposing views was completed by the interdisciplinary team (IDT), responses are located in section K.1 of Appendix K. Consideration of local community needs and uses for forest products are part of the RGNF Forest-wide Goals and Objectives. Assisting and contributing to rural communities in a variety of ways is also a strategic goal identified in the USDA Strategic Plan 2014-2018. These factors, along with consideration of other resource values and any tradeoffs, will be done in the Records of Decision completed by the Responsible Official. 1a-25 If you were really concerned about local community stability and local job creation you would offer this sale as an SBA sale to prevent a large timber corporation from logging it using their own labor. This would prevent the logs from being hauled many miles to be processed at a mill far removed from the small communities you claim need economic help. Of course your motivation to sell this timber sale has nothing to do with community stability. We both know “local community stability” and “local job creation” is part of the USFS dishonest script to trick the public into accepting tragic timber sales. Response: All timber purchasers for RGNF commercial timber sales are classified as small businesses according to the SBA definition. Based on the October 2017 Small Business computation for the Forest, 80% of the commercial timber volume offered by the Forest is currently set aside for small business. 2-7 We disagree with the statement on page 47 that states that if this project does not move forward, 3-7 the public would most likely obtain an equivalent amount of wood products elsewhere. That statement is simply not true; we request the DEIS acknowledge the importance of timber from this project to several forest products companies, both in the valley and outside. Response: Because the statement speaks broadly to the supply of forest products to the general public, this statement is true. It includes the availability of products from other states, as well as imports from other countries (which includes Canada). No shortage of wood products has been noted in the American market, and thus supply will balance with demand. Language has been added to the paragraph to note the importance of this wood to local forest products industry. 5-4 In the Summary, under the No Action alternative, it is stated “No Action would not benefit the local forest products industry.” This statement implies that benefiting the local forest products industry is a criteria of goodness. Yet, in no section of the EIS is there an evaluation of how local industry benefits are balanced against other public good criterion. This seems contrary to the Forest Services’ overall goal of managing our National Forests to maintain long-term flow of lumber materials balanced against the public good criteria. How does this project benefit that balance? ISSUE Response: In a project environmental analysis, each alternative is measured against specific elements to give the decision maker a comparison between them. Those elements include tangible measures for 1) meeting the project purpose and need and 2) affecting the identified issues. The effects of the proposed action and alternatives on other resources are also evaluated and disclosed in chapter 3 and encapsulated in the document summary. The reference text addresses how the No Action alternative compares to the project purpose and need. Another statement in the summary says, “The action alternatives would have some short-term (approximately 15 years) disturbance effects during harvest activities to soils, watersheds, wildlife and some Forest users.” A project can only address a portion of the broader management direction for the Forest, which is provided by the Forest Plan. The Forest Plan provides the balance for how one piece of the providing for public good (in this case, providing forest products and performing hazardous fuel treatments) fits in with other pieces of providing for public good. The Forest Plan does so by providing Management Area Prescriptions, Desired Conditions, Standards & Guidelines, and Allowable Sale Quantities, among other things. The evaluation of how local industry benefits are 312 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # balanced against other public good criterion is addressed in the FEIS of the Forest Plan. This project contributes toward that balance by addressing some portion of the management direction and staying within the parameters established by the Forest Plan. As a result, it is not contrary to the Forest Service’s overall goals. 7-4 Finally, to make this project effective and efficient, the Forest Service should partner with the private sector to reduce fuel loads while supporting local jobs and the economy. Please resist efforts by some to reduce the size of the project or incorporate limitations. We need to treat as many acres as we can and have the flexibility to treat where it is the highest priority. Response: The Forest Service will seek out partnership opportunities wherever available for best implementation of the decision. Thank you for the feedback concerning the preferred decision. 20-16 The Forest Service cannot support the suggestion that logging beetle-affected trees will promote long-term economic sustainability for local communities. Response: The appropriate levels of management, types of activities permitted, and the social and economic trade-offs of these uses and management activities in the CPDWS project area were analyzed during the land management planning process for the RGNF. As reflected in the Forest Plan EIS and Record of Decision, the Forest Service placed a high value on clean water, fish and wildlife habitat, recreation, and other goods and services supplied by federal lands. It was determined that these values can be maintained in active management areas with careful project planning and the inclusion of the standards, guidelines, and other project design criteria as needed to protect resources (see EIS, section 1.5 Forest Plan and Other Direction for specific Forestwide desired conditions and objectives pertaining to the CPDWS project).

Climate Change and Carbon Letter # - Comment and Response to Comment Comment # 20-79 The Forest Service must discuss and analyze the effects of climate change on the project area, but must also discuss and analyze the direct, indirect, and cumulative effects of the project on climate change. Climate change is already affecting the Rio Grande, and future impacts are likely to increase in severity. For example, the DEIS for the Rio Grande’s revised draft forest plan identifies climate change as one of the “drivers and stressors” affecting the forest, and notes that climate projections for the Rio Grande indicate likely increases in temperature, increased tree mortality, increased fire risk, precipitation changes, earlier snowmelt, and habitat shifts for both plants and animals. Rio Grande National Forest Plan Revision, Draft Environmental Impact Statement (Sept. 2017), at 63-64, https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd560187.pdf. A number of species such as Canada lynx are also adversely impacted by climate change, and the climate change analysis must also analyze climate-related impacts to species. ⎯ ⎯ The Forest Service recognizes the importance of proactively addressing climate change, and this recognition should be reflected in the agency’s NEPA analysis. Numerous agency publications and guidance materials emphasize the need to effectively manage national forests and grasslands to increase their resilience to climate impacts and other stressors, using the principles of adaptive management. The Forest Service also recognizes the importance of establishing practices that help mitigate climate change by reducing atmospheric levels of greenhouse gas (GHG) emissions. For example, the Forest Service Global Change Research Strategy notes that forests “play an important role in reducing the buildup of greenhouse gases in the atmosphere by sequestering carbon.” The Forest Service Global Change Research Strategy, 2009-2019, at 5. The Forest Service National Roadmap for Responding to Climate Change also addresses the importance of climate change adaptation and mitigation in national forests. It identifies several adaptive management strategies that the Forest Service will use to address climate change, including building resistance to climate-related stressors, increasing ecosystem resilience, and when necessary, facilitating large-scale ecological transitions. USFS National Roadmap for Responding to Climate Change, 19-20 (2010). The roadmap notes a connection between climate 313 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # mitigation and adaptation, stating that healthy, resilient forest ecosystems are better able to store carbon. Id. at 21. Response: In the DEIS, (Section 3.2, page 40) the project scope and existing conditions are described generally as to how the project is in response to climate change. The project effects, including all alternatives and cumulative effects, are included in each resource with a more detailed analysis with their impacts on GHG emissions and carbon sequestration related to climate change in Section 3.18 (page 151). Site specific GHG emission factors and fuel consumption was estimated using values from several sources within the San Luis Valley, and within and outside Colorado (Dubinsky and Karunanithi 2016; TSS Consultants, 2001; USDA-Forest Service 2005) and incorporated into the Forest Service CarbonPlus Calculator (USDA-Forest Service 2016). Of the action alternatives, Alternative 2 represents the highest estimate of total GHG emissions (50,628 CO2e Metric Tons), relative to the increased acres treated over the life of the project. The amount of GHG for the no action alternative (1,335 CO2e Metric Tons) represents ongoing road maintenance and some level of harvest for firewood collections. 20-80 The Forest Service must also analyze the impacts of this project on carbon sequestration in the Rio Grande National Forest, which stores a significant amount of carbon (largely in vegetation, including living and dead trees, and in the soil).Carbon sequestration is the primary mitigation strategy of the Forest Service, which has committed to “[p]romoting the uptake of atmospheric carbon by forests and the storage of carbon.” Id. It is undisputed that deforestation contributes to climate change by impacting carbon sinks in both soil and vegetation, and by releasing stored carbon from harvested trees. As part of this analysis, the Forest Service must also analyze the social cost of any carbon that will be released or any sequestration capability that will be diminished as a result of the project. Response: Section 3.18 of the DEIS, pg. 153 includes a summary of carbon sequestration for the Forest, including discussion on the Project impacts of alternatives on general carbon sequestration for the Forest. For response to the comment on the social cost of carbon, see response R20-83_88. 20-81 Independent from NEPA, the Forest Service has a substantive duty under its own Forest Service Manual (FSM) to establish resilient ecosystems in the face of climate change. See, e.g., FSM 2020.2(2) (directing forests to “[r]estore and maintain resilient ecosystems that will have greater capacity to withstand stressors and recover from disturbances, especially those under changing and uncertain environmental conditions and extreme weather events”); FSM 2020.3(4) (“[E]cological restoration should be integrated into resource management programs and projects . . . Primary elements of an integrated approach are identification and elimination or reduction of stressors that degrade or impair ecological integrity.”). The Forest Service should consider the risk of increased disturbances related to climate change when analyzing this proposal. For example, as the warming climate alters species distribution and forces wildlife migration, landscape connectivity becomes even more critical to species survival and ecosystem resilience. See USDA, Forest Service, National Roadmap for Responding to Climate Change at 26 (2011), available at http://www.fs.fed.us/climatechange/pdf/Roadmapfinal.pdf (recognizing importance of reducing fragmentation and increasing connectivity to facilitate climate change adaptation). Response: As this is a project-level NEPA document, the primary responsibility is to follow NEPA guidance and regulations. The inclusion of qualitative and quantitative discussions, (GHG, e.g.) is commensurate with the Climate Change Consideration in Project Level NEPA Analysis (USFS, 2009). (Complete citations available in DEIS.) In the DEIS, p. 1, It is stated that “The purpose and need also considers the current conditions and expected future conditions of resources resulting from potential changes in climate and the mortality in the spruce forest across the Conejos Peak Ranger District. Objective A (DEIS, p. 13) also states “Foster resilient, adaptive ecosystems to mitigate climate change. In addition, the analysis for Silviculture (3.2) include discussion on the need to create resiliency and the analysis for Wildlife (3.4) and Aquatics and Fisheries (3.5) include a discussion of project impacts on habitat connectivity.

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Letter # - Comment and Response to Comment Comment # Specifically, the Lake Fork of Conejos River is acknowledged as important for Wildlife (Lynx) and Fisheries (Rio Grande Cutthroat Trout and Rio Grande Sucker) and Alternative 3 along with Project Design Criteria relating to connectivity that will provide resiliency in the face of climate change are suggested (DEIS, Section 2.4). 20-82 Climate change is also expected to lead to more extreme weather events, resulting in increased flood severity, more frequent landslides, altered hydrographs, and changes in erosion and sedimentation rates and delivery processes. Many National Forest roads are poorly located and designed to be temporary, making them particularly vulnerable to these climate alterations. Even those designed for storms and water flows typical of past decades may fail under future weather scenarios, further exacerbating adverse ecological impacts, public safety concerns, and maintenance needs. The Forest Service should analyze in detail the impact of authorizing activities that will use forest system roads and temporary roads in combination with impacts from climate change on forest roads and forest resources. The Forest Service’s 2014 adaptation plan recognizes that the wide range of environmental and societal benefits provided by our national forests “are connected and sustained through the integrity of the ecosystems on these lands.” See USDA Forest Service, Climate Change Adaptation Plan, page 58 (2014). The plan highlights USDA’s 2010-2015 Strategic Plan Goal 2 of “[e]nsur[ing] our national forests . . . are conserved, restored, and made more resilient to climate change, while enhancing our water resources.” Id. at 58.The plan identifies numerous climate change risks –including increased wildfire, invasive species, increasing water temperatures, extreme weather events, and fluctuating precipitation and temperature –that “pose challenges to sustaining forests and grasslands and the supply of goods and services upon which society depends, such as clean drinking water, forest products, outdoor recreation opportunities, and habitat.” Id.at 60-64. With respect to transportation infrastructure specifically, the adaptation plan recognizes that, “[w]ith increasing heavy rain events, the extensive road system on NFS lands will require increased maintenance and/or modification of infrastructure (e.g. larger culverts or replacement of culverts with bridges).” Id.at 62. Response: Under the current Forest Plan, some areas are designated for timber production, while other areas are designated as wilderness, roadless, wildlife winter range, or forage production. These designations make the forest multiple-use. Authorized activities are mitigated by adhering to Forest Plan Standards and Guidelines and applying best management practices (BMPs) to protect soil and water resources. The NEPA process requires an interdisciplinary process to review projects and make suggested alterations to proposed projects and require additional project design criteria (PDC) that limit and direct activities on the ground. Some soil and watershed effects are expected when these activities occur and are mitigated through a number of mechanisms like BMPs and PDCs. Discussions of minimum road system and system road closures will be comprehensively addressed forest-wide in a future separate process in Travel Management analysis, which will include climate change considerations. 20-83 Additionally, the Forest Service must analyze the ecosystem services provided by the natural through 20- resources of the project area, how those ecosystem services have changed in recent years as a result 88 of beetle kill, and how the implementation of the Project would impact those ecosystem services. To properly assess this integrated and holistic approach, we recommend the Forest Service use a Total Economic Valuation framework (Peterson and Sorg 1987) to prepare any benefit-cost analysis for the Project.16 The White House Office of Management and Budget, CEQ, and Office of Science and Technology Policy released a memorandum, M-16-01, on October 7, 2015 directing federal agencies to incorporate ecosystem services into their decision-making, including through “monetization” and “ecosystem-services assessment methods” where “an agency’s analysis require consideration of costs.” M-16-01 at 2. Total Economic Valuation recognizes that the public goods and services produced by public lands, such as the Rio Grande National Forest, have characteristics that are not necessarily profitable if exploited by private enterprise. The aesthetic value of a viewshed, for example, is difficult to divide up and sell to individual consumers. It is also difficult to exclude “free riders” that enjoy the scenic beauty but are unwilling to pay for it. In these situations, private firms have little economic incentive to produce viewsheds and market forces fail to produce an 315 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # adequate supply, despite the fact that additional, protected viewsheds may be economically rational and socially desirable. Without adequate protection of public goods and services, society as a whole is less wealthy, and many of us as individuals are worse off (Peterson and Sorg, 1987, Morton 1999). While the value of rival and excludable commodities, such as fossil fuels, livestock grazing, or other commercial activities, can be measured with market data, there are externalities (negative public goods, or public “bads”) that often result from these activities (such as water quality degradation) that are not traded in markets and whose values are not reflected in market prices. Exclusive reliance on measures of value based on the market prices of commodities is thus incomplete. Put simply, the value of non-market public goods and services produced by public lands, including the Rio Grande National Forest, are not reflected in market transactions and therefore lack prices. The fact that non-market goods are not priced does not mean they have no value, only that market indicators of the value do not exist. Economists have developed methods for estimating non-market values when consumers are unable to express their preferences and willingness-to-pay via the marketplace. Non-market values are estimated by economists using two main methods: (1) stated preference; and (2) and revealed preference. Stated preference relies on surveys that ask respondents to state their maximum willingness to pay for a non-market good or to choose from among a set of nonmarket goods with varying attributes and price levels. Revealed preference methods derive the value of non-market goods through actual behavior, including expenditures on travel and medical care, property values, and wage rates. Stated preference methods are the only way to estimate passive-use benefits (e.g. option, bequest, and existence values). Several choice experiment applications have examined passive use values from the management of public land. Garber-Yonts, et al. studied the preferences of Oregonians regarding the management of Oregon’s Coast Range, including large acreage of BLM land. Adomowicz, et al. (1998) and Boxall and Macnab (2000) studied stakeholders’ preferences regarding industrial forest management and other use and passive use values. Both studies find evidence of high valuations for passive-use values. To complete a reasoned and informed benefits-cost analysis, we therefore recommend that the Forest Service, using Total Economic Valuation, fully assess the non-market benefits and costs associated with the proposed action. As Field and Field (2009) point out, “[b]enefit-cost analysis is for the public sector what a profit-and-loss analysis is for a business firm” (p. 118). Economic efficiency takes the perspective of all of society, and examines all the costs and benefits associated with development and resource extraction on the Rio Grande National Forest, including non- market values. The Forest Service’s socio-economic analysis should, as part of using a total economic valuation framework, specifically assess the social cost of carbon to assess the project area’s existing carbon sequestration value and the predicted or foreseeable net changes to its carbon sequestration capacity as a result of the cumulative impact of climate change and the specific activities that would flow from the proposed action. The Rio Grande has already analyzed carbon sequestration in the forest as a whole during the forest planning revision process. Rio Grande National Forest Assessment 4 –Carbon, https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd493827.pdf. Federal courts have ruled that agencies must include the climate benefits of a significant regulatory action in federal cost-benefit analyses: [T]he fact that climate change is largely a global phenomenon that includes actions that are outside of [the agency’s] control ... does not release the agency from the duty of assessing the effects of its actions on global warming within the context of other actions that also affect global warming. Ctr. for Biological Diversity v. Natl. Highway Traffic Safety Admin., 538 F.3d 1172, 1217 (9th Cir. 2008) (quotations and citations omitted); see also Border Power Plant Working Grp. v. U.S. Dep’t of Energy, 260 F. Supp. 2d 997, 1028-29 (S.D. Cal. 2003) (finding agency failure to disclose project’s indirect carbon dioxide emissions violates NEPA). Using the Social Cost of Carbon, put simply, measures the benefit of reducing greenhouse gas emissions now and avoiding costs in the future.17 The charts below depict, (A) dramatically

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Letter # - Comment and Response to Comment Comment # increasing damages from global warming over time, as well as (B) the social cost of these carbon emissions based on 2013 TDS values.

The importance of assessing the Social Cost of Carbon is obvious. Leading economic models all point in the same direction: that climate change causes substantial economic harm, justifying immediate action to reduce emissions.19 The interagency process to develop social costs of carbon estimates—originally described in the 2010 interagency Technical Support Document (“TSD”), and updated in 2013—developed four values based on the average SCC from three integrated assessment models (DICE, PAGE, and FUND), at discount rates of 2.5, 3, and 5 percent,20 as well as a fourth value demonstrating the cost of worst-case impacts.21 These models are intended to quantify damages, including health impacts, economic dislocation, agricultural changes, and other effects that climate change can impose on humanity. While these values are inherently speculative, a recent GAO report has confirmed the soundness of the methodology in which the IWG’s carbon costs estimates were developed, therefore underscoring the importance of integrating this analysis into the agency’s decision-making process, even if the authority to do so is grounded in other duties, such as the National Forest Management Act and NEPA.22 In fact, certain types of damages remain either unaccounted for or poorly quantified in IWG’s estimates, suggesting that the social cost of carbon values are conservative and should be viewed as a lower bound, in particular given the Rio Grande National Forest’s expansive mandates pursuant to the National Forest Management Act and NEPA.23 The SCC provides an important tool for establishing the dollar value of future climate impacts and its use should catalyze agency action to reduce climate pollution and avoid or mitigate climate costs. The social cost of carbon, properly harnessed to the NEPA process, thus advances the CEQ’s admonitions against “boilerplate” by providing an easily understood metric to “to foster excellent action” and to “take actions that protect, restore, and enhance the environment. 40 C.F.R. § 1500.1(c); 77 Fed. Reg. 77802, 77824. Furthermore, by providing a quantitative, monetized estimate of the actual costs—i.e., impacts—of the proposed action, social cost of carbon analysis helps puts to rest the notion that agencies need not act to reduce climate pollution or to ameliorate climate change impacts because their actions “represent only a small fraction of global emissions....” (77 Fed. Reg. 77802, 77825). We recommend the Forest Service use the Social Cost of Carbon as follows. First, the Forest Service should ensure that the Social Cost of Carbon is applied to all greenhouse gas (GHG) pollutants, not just carbon dioxide. This can be done, simply, by multiplying the social cost of carbon by the global warming potential of the particular GHG. This analysis should, notably, account for the differing warming potentials of certain GHGs, such as methane, over differing time frames (in particular 100-and 20-year time frames). For example, the Intergovernmental Panel on Climate Change, in its Fifth Assessment Report, states that methane is

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Letter # - Comment and Response to Comment Comment # 34 times more potent than CO2 over a 100-year time frame and upwards of 86 times more potent than CO2 over a 20-year time frame (accounting for climate-carbon feedbacks).24 Second, the Forest Service should explicitly recognize that the social cost of carbon —and, more broadly, Total Economic Valuation—is a tool to quantify the climate impacts of a proposed action and to compare alternatives, and thus has far broader relevance to the NEPA process then just cost-benefit analysis. Indeed, in some instances, the social cost of carbon/total economic valuation analysis may be the best way to take a hard look at climate impacts to comply with 40 C.F.R. § 1502.22, depending on the availability of other tools to understand climate pollution and climate change impacts.25We emphasize this point because NEPA analyses often rely heavily on quantification of GHG pollution as a proxy for understanding climate impacts. However, using GHG pollution levels as a proxy for impacts has limited utility value, especially as compared to a social cost of carbon analysis. Unlike GHG pollution levels, the social cost of carbon offers a simple, straightforward, and easily understood metric to understand cumulative impacts and, specifically, the present dollar value of the incremental impact of GHG pollution increases caused cumulatively by a proposed action. 40 C.F.R. § 1508.7. Use of the social cost of carbon—rather than just quantification of climate pollution levels—can therefore help better inform the design, consideration, and selection of alternatives (including the no action alternative) and mitigation measures, “sharply defining the issues and providing a clear basis for choice among options by the decision maker and the public.” 40 C.F.R. § 1502.14. Third, the Forest Service should recognize that uncertainties pertaining to the social cost of carbon do not cut both ways and certainly do not warrant exclusion of the social cost of carbon from NEPA analyses. In fact, any uncertainties warrant recognition that the social cost of carbon underestimates—perhaps significantly—the climate impacts of GHG pollution. As the U.S. Environmental Protection Agency has concluded: given current modeling and data limitations, [the federal SCC values] do [] not include all important damages. As noted by the IPCC Fourth Assessment Report, it is “very likely that [SCC] underestimates” the damages. The models used to develop SCC estimates, known as integrated assessment models, do not currently include all of the important physical, ecological, and economic impacts of climate change recognized in the climate change literature because of a lack of precise information on the nature of damages and because the science incorporated into these models naturally lags behind the most recent research.26 We encourage the Forest Service to treat social cost of carbon values as a lower bound to a project’s impacts of climate change and to account for peer-reviewed scientific and economic literature pointing to far higher social cost of carbon values. 27 Fourth, the Forest Service should explain that the express purpose of assessing the social cost of carbon is to provide an apples-to-apples basis for comparing a project’s economic benefits with climate pollution impacts (costs). Where the social cost of carbon is not assessed, these impacts (costs) are hidden from the public and, reflecting our comments regarding the broader use of Total Economic Valuation, in fact “paid for” by the broader environment and public in the form of degraded ecological resiliency, public health impacts, and more. Comparing the dollar benefits estimated to be produced by a proposed action to the dollar costs expected to be imposed by the project is a wholly defensible and necessary exercise. A dollar of income or tax revenue in the short term in the project area is no more important than, and could be negated by, the costs imposed by flooding in a coastal area, wildfire consuming a drought-stricken area, or people stricken by tropical diseases elsewhere in the country and experienced in the future—impacts that current science says are highly likely. Of course, the Forest Service may consider both quantitative and qualitative factors in selecting an alternative. Large, significant industrial operations, for example, should not be authorized simply because their monetized benefit exceeds their monetized cost. For, taken to its logical conclusion, it would mean that the largest operations could, for example, effectively always be justified so long as they reap significant economic benefits that exceed the economic costs to the relatively poor or powerless. See Exec. Or. 12,898 (Feb. 16, 1994). By completing a social cost of carbon analysis, agencies should still consider

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Letter # - Comment and Response to Comment Comment # qualitative factors, like environmental justice, to protect against inequities and to comply with conservation mandates. 25 Regardless, the social cost of carbon provides a quantitative basis for gauging, in conjunction with qualitative factors, whether a Federal agency—representing the broad public interest rather than the narrow and insular interest of a project proponent—should or should not approve a project or impose conditions to mitigate harm. It is notable that the social cost of carbon is already being taken into account (if imperfectly) by federal agencies and that its use has been upheld by the federal courts. In both Idaho and Montana, the BLM has prepared Social Cost of Carbon estimates in conjunction with the leasing of oil and gas.28 The U.S. District Court for the District of Colorado also found social cost of carbon analysis appropriate, and chided both the U.S. Forest Service and BLM for rejecting its use. See High Country Conservation Advocates v. U.S. Forest Serv., 52 F.Supp.3d 1174 (2014). The Forest Service should prepare a social cost of carbon analysis as a component of its Total Economic Valuation benefits-costs analysis as an appropriate and useful means of analyzing and assessing climate impacts under NEPA. Fundamentally, use of a Total Economic Valuation framework—inclusive of the social cost of carbon—will help the agency internalize non-market benefits and costs, and thereby improve any socio-economic analysis prepared for the project. For more information on benefit-cost analysis we recommend the following references: Chapter 6 in Field and Field (2009) lays out the various types of analyses very clearly; EPA, “Guidelines for Preparing Economic Analyses” (U.S. EPA 2000) is also a good reference and serves as a standard reference for the many benefit-costs analyses conducted by EPA and required by the Office of Management and Budget. We recognize that the project does not contemplate oil and gas development or coal extraction, traditional activities where the social cost of carbon has been employed in the past. However, it is equally appropriate here. Timber harvesting releases greenhouse gas emissions, and the carbon sequestration ability of the Forest may be compromised through the intensive logging proposed by the project. The Rio Grande National Forest must fully assess the climate impact of these activities by conducting a social cost of carbon analysis as part of a broader Total Economic Valuation analysis. References: 16 Our comments regarding Total Economic Valuation are liberally appropriated—in certain instances, virtually word-for-word, from the excellent June 2015 comments submitted by the Conservation Economics Institute to the U.S. Bureau of Land Management regarding proposed oil and gas rules. See http://www.conservationecon.org/#!og/kl7ht. 17See Ruth Greenspan and Dianne Callan, More than Meets the Eye: The Social Cost of Carbon in U.S Climate Policy, in Plain English, WORLD RESOURCES INSTITUTE (July 2011). 18 See Richard Revesz, et al., Global warming: Improve economic models of climate change, NATURE 508, 173-175 (April 10, 2014). 19See Nature 508 at 174. 20The choice of which discount rate to apply—translating future costs into current dollars—is critical in calculating the social cost of carbon. The higher the discount rate, the less significant future costs become, which shifts a greater burden to future generations based on the notion that the world will be better able to make climate investments in the future. The underlying assumption of applying a higher discount rate is that the economy is continually growing. The IWG’s “central value” of three percent is consistent with this school of thought—that successive generations will be increasingly wealthy and more able to carry the financial burden of climate impacts. “The difficultly with this argument is that, as climate change science becomes increasingly concerning, it becomes a weaker bet that future generations will be better off. If they are not, lower or negative discount rates are justified.” WRI Report, at 9. “Three percent values an environmental cost or benefit occurring 25 years in the future at about half as much as the same benefit today.” Id. 21See 2013 TSD at 2. 22GAO-14-663, Social Cost of Carbon (July 24, 2014).

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Letter # - Comment and Response to Comment Comment # 23See Peter Howard, et al., Omitted Damages: What’s Missing From the Social Cost of Carbon, Environmental Defense Fund, Institute For Policy Integrity, Natural Resources Defense Council (March 13, 2014), (providing, for example, that damages such as “increases in forced migration, social and political conflict, and violence; weather variability and extreme weather events; and declining growth rates” are either missing or poorly quantified in carbon cost models) 24IPCC Fifth Assessment Report, Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (accepted September 26, 2013). 25IPCC Fifth Assessment Report, Contribution of Working Group I to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change (accepted September 26, 2013). 26EPA, The Social Cost of Carbon, https://19january2017snapshot.epa.gov/climatechange/social- cost-carbon_.html. 27Moore, Frances C. and Diaz, Delavane B., Temperature Impacts on Economic Growth Warrant Stringent Mitigation Policy, Nature Climate Change 5, 127–131 (2015), http://www.nature.com/nclimate/journal/v5/n2/full/nclimate2481.html. 28See e.g. BLM, Little Willow Creek Environmental Assessment, DOI-BLM-ID-B010-2014-0036- EA at p. 81-83 (Feb. 10, 2015) (https://www.blm.gov/epl-front- office/projects/nepa/39064/55133/59825/DOI-BLM-ID-B010-2014-0036- EA_UPDATED_02272015.pdf) and BLM, Environmental Assessment for October 21, 2014 Oil and Gas lease Sale, DOI-BLM-MT-0010-2014-0011-EA (May 19, 2014) at 76, http://www.blm.gov/style/medialib/blm/mt/blm_programs/energy/oil_and_gas/leasing/lease_sales/ 2014/oct__21_2014/july23posting.Par.25990.File.dat/MCFO%20EA%20October%202014%20Sal e_Post%20with%20Sale%20(1).pdf. Response: For the CPDWS project there was no attempt or identified need to include a full economic impact analysis related to jobs and incomes for any of the alternatives considered in detail. As directed by FSM 1971, section 3.13, Social-Economic is focused on the comparative financial efficiency of the alternatives, considering quantitative costs and benefits of the alternatives. Also noted in Section 3.13 of the DEIS, “This economic efficiency analysis does not consider ecosystem services or non-market goods that are not required at the project level by the National Forest Management Act (NFMA).” The social cost of carbon (SCC) protocol was developed to assist agencies in meeting Executive Order 12866 requirements to assess costs and benefits during the development of regulations that may impact cumulative global emissions. The CPDWS project is not a regulation, so a SCC analysis is not required in evaluating the alternatives. Forest Service Manual 2380.2 states an objective for the Forest “To manage National Forest System lands to attain the highest possible quality of landscape aesthetics and scenery commensurate with other appropriate public uses, costs, and benefits.” In addition, the value of Scenic Resources are taken into consideration through Forest Plan forest-wide Standards and Guidelines that determine the level of concern viewers have for viewsheds. Standards and Guidelines and Design Criteria address what level of human caused activities are appropriate based upon the viewing angle, sensitivity of the road or viewing distance. These Standards and Guidelines will be applied to the project activities.

Chemical Control of Noxious Weeds Letter # - Comment and Response to Comment Comment # 1a-14 Request for changes to be made to the final NEPA document: Clearly indicate herbicides that contain glyphosate will not be used anywhere, at any time, for any reason. Response: The Forest Service uses an integrated approach to controlling and eradicating noxious weeds, which includes hand-pulling, biological controls and the use of approved herbicides. Herbicides containing glyphosate are allowable to use within the analysis area and are registered by the Environmental Protection Agency (EPA) for use in vegetation treatments. The environmental 320 CP District-wide Salvage Project Final Environmental Impact Statement

Letter # - Comment and Response to Comment Comment # effects of herbicides or other control methods for invasive species on the Rio Grande National Forest were evaluated in a separate analysis (Management and Control of Noxious Plants on the San Juan and Rio Grande National Forests, 2012). The evaluation of specific herbicide use on all public lands is outside the scope of this analysis.

K.1 Responses to Opposing Views Additional responses to references cited in comments and opposing views are available for public review in the project record, located at the Rio Grande National Forest website.

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Appendix L – Heritage Checklist Template

This checklist documents the HERITAGE input into the adaptive NEPA process for the [insert name of tiered undertaking] within the [insert original NEPA project name] analysis. Fill out checklist form, sign and file for future reference and documentation of this process.

Project Name: ______Type of activity: ______

Upon receiving project unit maps/shapefiles with proposed treatment activities and associated infrastructure needs, if any (roads, landing locations, etc.), review the area within and adjacent to the proposed project area. Review approved PDC in Final EIS & relevant LMP guidance or BMPs- Complete the checklist & document any findings, concerns, or additional project design criteria for Line Officer Review in areas provided.

Heritage Tiered Undertaking Checklist

1. Does the project proposal qualify as an exempt undertaking under the Bark Beetle PA (Appendix E) No, proceed to next question and chronicle in annual report Yes, no additional Section 106 compliance is necessary

2. Define and describe the Tiered Undertaking Area of Potential Effect (APE) Attach map(s) that clearly illustrates the APE

3. Identify all cultural resources and previously surveyed areas in the APE (Attach Class I):

4. Have NRHP evaluations been adequately completed for all cultural properties in the APE? No, determine NRHP significance for all cultural properties Yes, proceed to next question

5. Determine potential effects on all historic properties within the APE. Have potential adverse effects to historic properties been identified? No. Historic properties have not been identified in the APE. Proceed to next step No. Historic properties have been identified in the APE, but no potential adverse effects have been identified. Proceed to next step Yes, but protective measures can be prescribed to eliminate the potential for adverse effects. Follow PA and clearly identify all stipulations in the summary page at the end of this checklist Yes, and protective measures cannot be prescribed to eliminate the potential for adverse effects. An MOA will be developed in concert with the SHPO to resolve the adverse effect

6. When National Register of Historic Places (NRHP) evaluations and effects assessments have been completed for all heritage resources within the APE, project reports shall be written and submitted for SHPO consultation prior to project implementation. When consulting under the Project/Tiered Undertaking, be certain to reference this fact in all project reports and the first paragraph of consultation correspondence.

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7. The recommendation of effect for this project is: No Historic Properties Affected No Adverse Effect Adverse Effect

8. TIERED UNDERTAKING MONITORING NEEDS/RECOMMENTATIONS (Include who, what, when, where, as needed)

9. Analysis of Indirect and Cumulative Effects Tiered to Prior [insert original project name] Undertakings (Attach):

In accordance with the provisions of Section 106 of the National Historic Preservation Act of 1966, as amended (Public Law 89-665; 54 U.S.C 300101) and its regulations (36 CFR 800), the recommended determination for the proposed action is [insert recommended determination of effect]. The Line Officer has been notified of these findings and this recommendation. The project may be implemented pending concurrence from the Colorado State Historic Preservation Officer (COSHPO) on the determination of effect for the proposed project. Sites considered not eligible or non-supporting to the NRHP may be directly affected once adequately recorded, evaluated, and concurrence is received from the State Historic Preservation Office regarding NRHP eligibility. If any new improvements or actions outside of the project boundaries described herein are planned, additional cultural resource assessment is required.

Specialist Signature______Date ______

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