Glacier Loon Fuels Reduction and Forest Health Project

United States

Department of Agriculture Forest Service Glacier Loon Fuels Reduction and Forest Health Project

Final Decision Notice and September 2018 Finding of No Significant Impact Swan Lake Ranger District, Flathead National Forest Missoula County, Montana

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected]. USDA is an equal opportunity provider, employer and lender. Data Accuracy - The Forest Service uses the most current and complete data available. GIS data and product accuracy may vary. They may be developed from sources of differing accuracy, accurate only at certain scales, based on modeling or interpretation, incomplete while being created or revised, etc. Using GIS products for purposes other than those for which they were created may yield inaccurate or misleading results. The Forest Service reserves the right to correct, update, modify, or replace GIS products without notification. For more information, contact: Flathead National Forest 650 Wolfpack Way Kalispell, MT 59901 (406) 758-5200 If a map contains contours, these contours were generated and filtered using the Digital Elevation Model (DEM) files. Any contours generated from DEM's using a scale of less than 1:100,000 will lead to less reliable results and should be used for display purposes only.

TABLE OF CONTENTS

FINAL DECISION NOTICE

Summary of Decision ...... 1

Project Area ...... 2

Purpose and Need For Project ...... 2

Project History...... 3

Public Involvement ...... 5

Issues ...... 7

Key Issues For Alternative Development...... 7

Brief description of Alternatives ...... 10

Alternatives Not Considered In Detail ...... 10

Alternatives Considered In Detail ...... 14

Forest Plan Management Area Change ...... 18

Decision ...... 19

Comparison of Alternatives ...... 26

Consideration of Key Issues and Public Comments ...... 28

Summary ...... 40 FINDING OF NO SIGNIFICANT IMPACT

Context ...... 41

Intensity ...... 42

Findings Required by Law, Regulation, or Agency Policy ...... 54

Pre-Decisional Administrative Review Process ...... 64

Contact Person ...... 65

Responsible Official Signature and Date ...... 65

LIST OF TABLES

Table 1. Management Area Descriptions, Emphasis, and Management Area Acres for the Glacier Loon Fuels Reduction and Forest Health Project ...... 24

Table 2. Comparison of Alternatives: How They Respond to the Purpose and Need ...... 27

Table 3. Comparison of Alternatives: How They Respond to the Scenic Value Key Issues ...... 29

Table 4. Comparison of Alternatives: How They Respond to the Water Quality Key Issues ...... 31

Table 5. Comparison of Alternatives: How They Respond to Water Quality Key Issues- Temporary Roads ...... 32

Table 6. Comparison of Alternatives: How They Respond to Wildlife Security Key Issues ...... 35

Table 7. Threatened and Endangered Species Determinations ...... 47

LIST OF MAPS

Map 1. Project Vicinity Map ...... 66 Map 2. Selected Alternative- North Half ...... 67 Map 3. Selected Alternative- South Half ...... 68 Map 4. Selected Alternative- Management Areas ...... 69 LIST OF APPENDICES

Appendix 1. Details of the Selected Alternative ...... Appendix 1-1 through Appendix 1-14

Appendix 2. Design Criteria...... Appendix 2-1 through Appendix 2-13

Appendix 3. Monitoring Plan ...... Appendix 3-1 through Appendix 3-2

Appendix 4. Best Management Practices ...... Appendix 4-1 through Appendix 4-30

Appendix 5. Responses to Public Comments on the Supplemental Environmental Assessment ...... Appendix 5-1 through Appendix 5-81

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Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

GLACIER LOON FUELS REDUCTION AND FOREST HEALTH PROJECT: FINAL DECISION NOTICE

SUMMARY OF DECISION

After careful consideration of the Purpose and Need for the project, issues identified, public comments received, and the potential impacts of the management activities analyzed in the Glacier Loon Fuels Reduction and Forest Health Project (hereafter, the Glacier Loon Project) Environmental Assessment (EA) issued in August 2012, the supplemental EA issued in July 2017 and April 2018, and objections received on the draft decision notice, I have decided to implement Alternative D, with modifications, as my Selected Alternative (see “Decision” section, pages 19 through 24, and Appendix 1 for details of the decision). This decision implements vegetation and road management activities and includes design criteria changes that were made based on public comments and resource concerns to move toward the desired future conditions in the project area. A summary of the actions in my decision include the following: . Fuel reduction and forest health treatment of affected stands on approximately 1,397 acres of National Forest Lands (NFS) lands within the Glacier Loon Project Area. . Harvest activities will be implemented using the tractor, skyline, mechanical, and hand treatments in the summer and tractor and forwarder logging systems during the winter. . Slash will be treated through a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings will be treated by either burning, chipping/masticating, and/or removal from NFS lands. Prescribed fire treatments will include broadcast burning, pile burning, and/or jackpot burning. . Hand planting with desired species will occur on an estimated 305 acres within regeneration treatment units. Where adequate site preparation is achieved, natural regeneration will be expected to occur, and in some cases supplemented with planted seedlings. . Fuels treatment will occur on 1,157 acres within the Wildland Urban Interface (WUI). . Fuels treatment will occur on 240 acres outside the WUI. . Best Management Practices (BMPs) will be implemented on an estimated 29.3 miles of haul routes to meet Timber Sale Requirements and reduce sediment yields. Application of BMPs (Appendix 4) on all temporary roads constructed and roads temporarily opened will also be implemented as requirements of the timber sale.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

. Units would be accessed through an estimated 5.9 miles of temporary road construction. System roads would be used for road haul. These temporary roads would be reclaimed following their use. . Road decommissioning of an estimated 8.4 miles of NFS road. . Implementation of project-specific Design Criteria (Appendix 2), Monitoring Actions (Appendix 3), and BMPs (Appendix 4). . Implementation of Resource Enhancement Projects described in Appendix 1 of this document. . A site specific amendment to the Flathead National Forest land and Resource Management Plan (hereafter, Forest Plan) to change the Management Area (MA) for a portion of the Glacier Loon Project Area along Lindbergh Lake, including the highly visible portions of the project area from the lakeshore to the slope break totaling approximately 221 acres. The proposal would change 213 acres from MA 15, which consists of timberlands where timber management with roads is economical and feasible as currently assigned, to MA 5, which consists of roaded timberlands in areas of high scenic value. The other 8 acres would be changed from MA 15C, timberlands with emphasis on white-tailed deer summer range, to MA 5. More detailed information on the management actions are described in this Decision Notice on pages 19 through 24, and in Appendix 1 (Details of the Selected Alternative) and Appendix 2 (Design Criteria of the Selected Action).

PROJECT AREA

The Glacier Loon project area (37,320 acres) lies within the boundaries of the Glacier Loon and Buck Holland Grizzly Bear Subunits. It extends south and west of Condon on the west side of Montana Highway 83 to the south end of Lindbergh Lake. The project area is located in Missoula County in Sections 2-6 of T18N, R17W; Sections 1-3, 5-9, and 16-17 of T18N, R18W; Sections 01-4, 7-23, 26-35 of T19N, R17W; Sections 2-4, 9- 15, 22-27, and 33-36 of T19N, R18W; Sections 18-19 and 29-32 of T20N R16W; and Sections 1-2, 11-5, 22-37, and 33- 36 of T20N R17W; Swan Lake Ranger District, Flathead National Forest (Map 1 - Vicinity Map). A large acreage of the mechanical fuel treatments in the project area lies within the Wildland Urban Interface (WUI), the highest priority for hazardous fuels treatment in the National Fire Plan, and is within the WUI described in the Seeley Swan Fire Plan.

PURPOSE AND NEED FOR PROJECT

The need for the Glacier Loon Project was based upon the differences between desired landscape conditions and current conditions related to fuels, forest health, and forest products on NFS lands in the project area. Several plans and other regulations also provide context to the management direction for these lands. These include the National Fire Plan, the Missoula County Wildfire Protection Plan, the Seeley Swan Fire Plan, the

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Healthy Forests Restoration Act, and the Forest Plan. The purpose and need for the Glacier Loon Project is discussed in depth in its EA/Supplemental EAs on pages 1-2 through 1-5. Based upon the existing conditions of the project area and consistent with Forest Plan direction and the goals of Forest Service Restoration Policy, the Swan Lake Ranger District’s Interdisciplinary (ID) Team identified the following Purpose and Needs: . Hazardous Fuels Reduction o Reduce the associated risk of high-severity landscape wildfire risk within the WUI as identified in the Seeley Swan Fire Plan.

o Provide for a safer environment for the public and firefighters should a wildfire occur within the proposed treatment areas.

o Increase the probability of stopping wildfires on NFS lands before they burn onto private lands. . Improve Forest Health o Improve and/or maintain the general health, resiliency and sustainability of forested stands.

o Reduce the risk of insect epidemics and severe disease infestations within the project area. . Provide Wood Products for Local Economics o Provide forest products to the local timber industry – contributing to short- term forest products and providing for long-term sustainability of timber on NFS lands.

PROJECT HISTORY

The Glacier Loon Project was initiated in 2011 to reduce the risk of a high-severity landscape within the WUI, as identified in the community wildfire protection plan, improve forest health and resistance to insect epidemics, and provide wood products to local timber industry. Letters, news releases, and field trips to the project area were means to garner public interest in the project. Following the scoping period, the Forest Service received 47 responses. An EA was prepared to analyze the effects of three action alternatives designed to address the objectives mentioned above in different ways, as well as the no action alternative. The EA was released to the public in August 2012 for a 30-day comment period. A total of 31 comments were received on the EA which helped the decision maker shape the Selected Alternative. The Decision Notice and Finding of No Significant Impact was signed by the Forest Supervisor on February 13, 2013, and the selected alternative was a modification of Alternative D. The Forest Service’s 45-day administrative appeal period was initiated at the time the Decision Notice was published in The Daily Inter Lake (newspaper of legal record).

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Five appeals utilizing the 36 CFR 215 regulations were received on the project between March 7 and 28, 2013 (Project File Exhibits W-1 through W-10). These appeals raised a myriad of issues regarding effects to lynx, lynx critical habitat, big game thermal cover, water howellia, grizzly bears, and sensitive species. On May 22 and 23, 2013, the Glacier Loon Decision was affirmed by the Appeal Deciding Officer (Project File Exhibits W-16 through W-25) with instructions to increase buffered distances between vegetation management treatment units and unoccupied water howellia ponds to 300 feet (occupied water howellia ponds were already buffered by 300 feet in the original EA). Vegetation management treatment units were resurveyed to assure they met this instruction before they were implemented. The supplemental EA has been updated with this instruction. Prior to the response of the appeals by the Appeal Deciding Officer, on March 19th, 2013, four of the five people/organizations who filed administrative appeals filed a 60- day Notice of Intent (NOI) to sue under the Endangered Species Act (ESA); in June they filed an amended NOI. In response to the second NOI, the Flathead National Forest gave notice to plaintiffs that the Forest was re-evaluating the project’s compliance with ESA, and was in the process of preparing an amended wildlife biological assessment to be submitted to the US Fish and Wildlife Service (USFWS). Plaintiffs filed an initial complaint in the United States District Court on June 24, 2013 and amended their complaint on September 12, 2013 (CV- 13-129-M-DLC). The Plaintiffs challenged the Forest Service and the USFWS on two separate aspects: . Authorization of the Glacier Loon Project on the Flathead National Forest; and . Failure to conduct environmental analysis and ESA consultation for decisions regarding the “Legacy lands” acquisition, agreed operating procedures, and subsequent logging projects on these lands by TNC. After briefing was completed, two stewardship sales began operation in the summer of 2014. However, on September 25, 2014, the Court granted summary judgement in favor of the government on all of Plaintiffs’ claims except four, two of which relate to the Glacier Loon Project. The other two claims are related to the land acquisition by TNC within the project area as well as other places in the Swan Valley. However, on January 5, 2016, the U.S. Forest Service received a letter announcing that the fiber supply agreement between TNC and Plum Creek had been terminated and that there were no plans for future harvest on Legacy Lands (Project File Exhibit AA-1). The court’s ruling that NEPA analysis and ESA consultation is required for the agreed operating procedures (AOP) is not associated with the Glacier Loon Project and therefore was not be analyzed in the SEA. Regarding the Glacier Loon Project, the Court held the Forest Service improperly reached a “no effect” determination for water howellia and bull trout, and that the Forest Service erroneously determined that numerical objectives under Amendment 19, which provides protections for grizzly bears, did not apply to certain subunits in the Project area. As a result, the Glacier Loon Project was enjoined and the two stewardship sales

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI were suspended. The court specifically concluded that the “matter is remanded to the agencies to perform the necessary analysis and follow the necessary procedures under the ESA for water howellia, bull trout…and to reassess its Section 7 analysis regarding the grizzly bear in light of the application of the correct access objective under Amendment 19.” Following the summary judgement, the Forest Service prepared amended biological assessments for bull trout/bull trout critical habitat (January 29, 2015), water howellia (February 12, 2015), and grizzly bears (February 4, 2015), and re-consulted with the USFWS. The determinations to these species were modified to a “not likely to adversely affect” for bull trout/bull trout critical habitat and water howellia and a “likely to adversely affect” for grizzly bears. The USFWS provided concurrence letters for bull trout/bull trout critical habitat and water howellia, and a biological opinion for effects to grizzly bears (June 15, 2015). After these amended biological assessments were completed, a review was undertaken to consider whether these updated biological assessments raised any new circumstances or information requiring a supplement to the EA. In this new information review the Forest Service determined there were no “significant new circumstances or information relevant to environmental concerns and bearing on the Proposed Action or its impacts” that warranted corrections, supplementation, or revision to the Glacier Loon EA. After completing the ESA consultations, the federal government prepared a motion to the court to dissolve the injunction, and while the court agreed in its January 13, 2016 order that the agencies met their Section 7 ESA obligations, they indicated that NEPA’s statutory obligations required the preparation of a supplemental EA due to the application of the incorrect Forest Plan Amendment 19 access objectives in the original EA. A supplemental EA (SEA) was published in July 2017 (with a 30-day public comment period) to reanalyze the effects of the project on grizzly bears and any new information that may have been identified since the 2012 EA, and to consider potential cumulative effects of the reasonably foreseeable Beaver Creek Landscape Restoration Project.

PUBLIC INVOLVEMENT

Public participation helps the Forest Service identify concerns with possible effects of its proposals. It is also a means of disclosing the nature and consequences of actions proposed for NFS lands. A public involvement strategy was developed for the Glacier Loon Project to ensure that potentially interested members of the public and other government agencies received timely information about the upcoming analysis so they would be able to participate in the process (Project File Exhibit A-14). The Forest Service developed a list of individuals, organizations, and agencies that would likely be interested in the Glacier Loon Project. This included members of the public within these general categories:

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Adjacent landowners Other Federal Agency County governments Montana State Agencies Advocacy or user-group organizations Timber industry groups Tribal governments Local news media Collaborative groups On September 16, 2011, information on the Glacier Loon Project, including a map of the proposal, was mailed out to approximately 100 individuals, agencies, and groups (Project File Exhibit B-2). Because of the interest generated by the initial mailing, information on the project, including a map of the proposal, was mailed to an expanded mailing list on October 13, 2011. On September 8, 2011, a field trip to the Glacier Loon Project Area was conducted. Nine Forest Service employees and seven members of the public attended. A “Request for Comments” on the project was mailed on September 16, 2011 to approximately 188 members of the public, organizations, and/or special interest groups. A “Request for Comments” was published in The Daily Inter Lake on September 21, 2011 (Project File Exhibit B-2). Based upon the public interest in this project, another public meeting was held on October 7, 2011. In addition to Forest Service personnel, 10 members of the public were in attendance. On October 13, 2011, a postcard was mailed out to over 270 individuals notifying the public about a second field trip on October 31, 2011 and an extension of the public comment period to November 7, 2011. A subsequent field trip to the Glacier Loon Project Area was held on October 31, 2011. 31 members of the public, as well as five Forest Service employees attended. Notification of the project was published in the Forest Service’s Schedule of Proposed Actions (SOPA) on October 1, 2011, and has appeared quarterly since that time (Project File Exhibits B-5). The Swan Lake Ranger District received 47 responses on the Glacier Loon Project scoping, either in the form of letters, e-mails, telephone contacts, or comment sheets. On August 24, 2012, a legal notice for the EA was published in the newspaper of record, The Daily Inter Lake, announcing the completion and availability of the Glacier Loon EA and a 30-day public comment period on the EA. Letters and copies of the EA or a summary of the EA were sent to the mailing list to inform recipients of the availability of the EA and to request comments. In addition, an email was sent out to an electronic mailing list notifying those individuals of the availability. The EA was also made available on the Flathead National Forest’s website at: http://www.fs.usda.gov/projects/flathead/landmanagement/projects. A total of 31 comments were received on the EA; two of these comments were received after the public comment period closed. These comments from the public and our responses are included in Appendix 5 of the February 2013 Decision Notice. I considered these comments in my decision and used them to help shape the Selected Alternative.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

On July 24, 2017, a letter announcing the release of the SEA was sent to 197 parties. On July 28, 2017 a legal notice was published in the newspaper of record, The Daily Inter Lake, inviting comments on the project. Seven comment letters were received on the project. Responses to these comments can be found in Appendix 5 of the Draft Decision Notice and Finding of No Significant Impact (FONSI), which was published on April 9, 2018. The Draft Decision Notice was subject to the pre-decisional administrative review process pursuant to 36 CFR 218. The 45 day objection period commenced the day after the publication of the legal notice in the Daily Inter Lake on April 10, 2018. Four objections were received and evaluated by the Acting Deputy Regional Forester. Further information about the objection review is found on pages 64 through 65.

ISSUES

The ID Team reviewed and compiled a list of potential issues based upon comments from the public, organizations, and government agencies. These issues were then evaluated against the following criteria to determine the appropriate method for resolution: . Is the issue relevant to and within the scope of the Purpose and Need, the decisions being made, and does it pertain directly to the Proposed Action? . Is the issue already decided by law, regulation, or existing plans? Is it supported by scientific or factual evidence? . Could the issue be resolved through design and location of activities in the Proposed Action or mitigated by avoiding the impact of not taking action, minimizing the impact by limiting the action, rectifying the impact by rehabilitation, reducing the impact by maintenance, or compensating for the impact by replacement? Issues representing an unresolved conflict with the Proposed Action have been brought forward as “major issues” and were used to help formulate the alternatives to the Proposed Action. Project File Exhibit D-1 provides a detailed description of the issues identified during the scoping process and describes how those issues were accounted for during the analysis process.

KEY ISSUES FOR ALTERNATIVE DEVELOPMENT

The ID Team and I identified the following “key” issues, for which action alternatives were developed. These issues were used to refine design criteria for the project and to develop alternatives to examine the trade-offs of different approaches in meeting the Purpose and Need. 1. SCENIC VALUES AND WATER QUALITY The statements below are examples of comments received during scoping, which articulated issues or concerns relative to Scenic Values and Water Quality (Project File

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Exhibit D-1). . As a full time resident of Lindbergh Lake, and having spent many years working with our Congressional Delegation, the Trust of Public Lands, and many others, we were successful in securing money from the Land and Water Conservation Fund to purchase 2,542 acres around Lindbergh Lake from Plum Creek Timber Company. The specific objective was to protect this land, more specifically: water quality, endangered and threatened species, and the visual plane (Project File Exhibit C-5). . While I know there will be more specific testing with the environmental assessment after the first of the year, I have major concern about maintaining the high integrity of our water quality. Additionally, I am concerned about what erosion of the logged areas might do to lake water quality, as well as the cutting and use of new/temporary roads. Additionally, I am concerned about what erosion of the logged areas might do to lake water quality, as well as the cutting and use of new/temporary roads (Project File Exhibit C-21). . I was an active participant in the effort to protect Lindbergh Lake from development by Plum Creek Timber in the early 1990's and also strongly oppose the proposed logging and road construction on the western slope of Lindbergh Lake. Our past efforts is very accurate and I feel it is imperative you adhere to a thorough review of the effects this will have on our water quality and on one of the most pristine habitats left in this country (Project File Exhibit C-23). . We are also extremely concerned about your proposed logging to within 150 feet from the shores of Lindbergh Lake. In the process of logging so close to the shoreline, you will destroy many old growth Ponderosa and could cause erosion that would be dangerous to the water quality of the lake. Lindbergh Lake is a pristine lake from which we draw our drinking water. We are concerned that aggressive logging and building of roads in this area would be detrimental to the drinking water (Project File Exhibit C-29). . I also have grave concerns about the threat to the quality of our drinking water from the project as it affects the entire lake (Project File Exhibit C-43). . In 1996 portions of Sections 22, 27, 26, and 35 were acquired after much effort on the part of The Lindbergh Lake Community with 15 million dollars in Land and Water Conservation Funds and with the aid of our congressional delegation. The purpose was to preserve what is a unique ecosystem within the lower 48, from development, and logging activities planned by Plum Creek Timber. The water in Lindbergh Lake is our source of drinking water where it is consumed untreated and unfiltered by the lake residents. It represents one of the last remaining sources of natural potable water in the United States. This great effort and subsequent public expenditure was with the intent of protecting the views and watershed from precisely the activities proposed in The Glacier Loon Project. . We specifically will vigorously oppose by whatever means necessary the planned activities in action areas 71, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, and further discussions will be necessary for the planned actions for areas 66-70. We

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

find the clear cut plans for 84-87 on the western shore shocking and unacceptable (Project File Exhibits C-2 and C-15) . I am opposed to the proposed treatments for Sections 84 – 87 as well as potentially Sections 80/81 (I apologize for my uncertainty). At any rate, it is the part of these sections that ‘spills over’ the top of the ridge and shows up as a section of intensively logged forest on the high visual impact west side of the lake. I would additionally wish to exempt the visual section of 80/81 – rather, keep any logging of these sections behind the FS road so it cannot be seen from the Lake (Project File Exhibit C- 21). . I think that the suggested treatments in areas 84-87 and 89 should be completely reassessed. I do not support the proposals in these areas. These areas are a major part of the public view at Lindbergh Lake. Campground users and the general public enjoy the beauty of these spots as do the residents of the lake. Area residents in the Seeley Swan Valley count Lindbergh as one of their favorite recreational lakes, largely due to the immense beauty. Roads added in this area to accomplish the logging will not improve the overall environment, be a great expense and a visual impairment (Project File Exhibit C- 31). . The proposed work in these areas would, first and foremost, have a dramatic effect on the Lindbergh Lake viewshed. This is a concern not only for Lindbergh Lake residents such as myself, but for the many non-residents who use the lake. One of the most important qualities of the lake is the sense of wilderness one gets when paddling or boating on the lake – of an ‘untouched’ lake, particularly the entire west side and south end beyond the few residences. I can think of few lakes where such an experience is available to people who may not be able to hike into, much less get out in a boat onto, a true wilderness lake. Based on the visual simulations provided, the proposed Glacier Loon project work would essentially destroy this quasi-wilderness experience for everyone who lives on or visits the lake (Project File Exhibit C-33). . It is quite clear that proposed roads and logging units on the slopes above Lindbergh Lake are not acceptable from a visual quality perspective, especially to those who recreate on or have homes on the lake (Project File Exhibit C-34). . I wonder whether you have given enough consideration to value of scenic qualities of the hillsides that border Lindbergh Lake. Many people use the campground and go boating on the lake. The lake is also used to get to the trailhead at the head of the lake to get into the Mission Mountains Wilderness. The people who have cabins enjoy the beauty of the forest on the west side of the lake. Logging on those slopes will definitely detract from their beauty. The logging done on Herrick still shows the scar after all those years. Great consideration should be given to the esthetic values of a scenic forest on lands facing the lake. I hope you will change your plan and leave the viewshed slopes as beautiful as possible (Project File Exhibit C-45). 2. WILDLIFE SECURITY The statements below are examples of comments received during scoping, which

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI articulated issues or concerns relative to Wildlife Security (Project File D-1). . Again, having hiked all through the area and many years ago seeing a grizzly bear up close in one of the actual places in which there will be cutting, I am deeply concerned that this will be injurious to those whose lives actually depend on the flora and undisturbed topography of the proposed treatment area (Project File Exhibit C-30). . We are concerned about maintaining minimum threshold habitat and connectivity for wildlife, especially as this relates to forest carnivores. Through our work and experience, we recognize the Glacier Loon project area as one of the few functioning forest carnivore habitats left in the Swan River watershed (Project File Exhibit C-24). . Please examine how this project will affect all ESA listed, MIS, and sensitive species (Project File Exhibit C-1). . All the wildlife species in the project area require corridors to move for foraging, denning, nesting and seasonal habitats. Where are these corridors? What is the habitat quality in them? What size are they? Are they wide enough to protect from edge effects and provide security? Are they fragmented by roads or past logging units? How much canopy cover, thermal cover or hiding cover is in them? How much down woody debris and snags are in them? What type of habitat is considered suitable? Where is the current lynx foraging and denning habitat located? How will it be maintained, how will it be improved, how is it connected or how will it be impacted by this project? What are the effects to critical habitat for lynx? Will it be adversely modified? Lynx avoid clearcuts. This project will expand clearcuts and negatively impact lynx (Project File Exhibit C-3). . In addition, we support liberal buffers around all wetlands, which we know to provide hiding cover; structural complexity; unique vegetative and bird communities; and small rodent diversity occurring within the mixed conifer terrestrial and riparian wetland ecotone (Project File Exhibit C-24).

BRIEF DESCRIPTION OF ALTERNATIVES

Based upon the key issues identified above, several alternatives were developed. This section describes and compares the alternatives considered by the Forest Service for the Glacier Loon Project. The ID Team and I grouped the alternatives into two categories: 1) Alternatives Not Considered in Detail, and 2) Alternatives Considered in Detail.

ALTERNATIVES NOT CONSIDERED IN DETAIL

This section discusses additional alternatives that were considered, but not considered in detail. These alternatives were initially proposed to address issues identified during the public scoping and ID Team process, but were not considered in further detail for the reasons explained in the following narratives.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

INCREASED ACREAGE OF FOREST HEALTH AND HAZARDOUS FUELS REDUCTION TREATMENTS

Based on both public and internal input, an alternative was considered that increased and/or intensified the acreage treated for forest health and hazardous fuel reduction. Both within and outside the WUI, additional treatments were considered in a number of forest stands. However, based on preliminary public input and interdisciplinary team field reconnaissance and analysis, the Proposed Action deferred treatment in areas totaling approximately 4,500 acres. These areas were dropped from further consideration for a variety of reasons including: access and economic issues, riparian areas, old growth stands, lynx habitat, visual impacts, and areas where the existing stand conditions met the project objectives. In addition some areas were deferred primarily due to their proximity to the Crazy Horse Fire which occurred in 2003. This led to a recommendation to defer treatment in this area until more time for recovery from the effects of the fire had occurred. One area specifically identified for consideration through public input included stands in the southwest portion of Section 14, of T19N, R17W. The need for active vegetation management was suggested in this area based on the presence of large diameter mature ponderosa pine. Field reconnaissance identified significant access and logging systems constraints in this area and it was also determined that many of the stands in this area are old growth. For these reasons, an alternative to treat more extensively and intensively within the project area was not considered in detail.

NO TEMPORARY ROAD CONSTRUCTION

Some input was received from the public that, in the opinion of the commenters; no temporary roads should be built. These commenters felt that building roads, even temporary ones within RHCAs and streams within Section 12 would have significant effects on the watershed. The commenters also felt that the impacts of building temporary roads are the same as building permanent roads and that the temporary roads proposed with this project would increase road densities and decrease habitat security in violation of the Forest Plan and the Swan Valley Grizzly Bear Conservation Agreement. Commenters also expressed concern that building temporary road poses risks to water, soils, other wildlife, fish, and increasing noxious weed concerns. Commenters also requested if there may be opportunities to avoid road construction by requiring cut to length and forwarding logging practices as opposed to tractor logging and whole tree yarding systems (Project File Exhibit D-1). In project development, I asked the ID team to design the Proposed Action to limit temporary road construction. In response to public comment, I further asked the ID Team to limit temporary road construction in designing the other action alternatives. These alternatives reduce temporary roads by requiring skidding longer distances that would normally be used under Forest Service guidelines for timber sales. The

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI increased logging cost impairs the economic viability of the alternatives with little environmental gain in this situation. Due to the economic infeasibility of the alternative in current and reasonably foreseeable future market conditions, such an alternative was not considered in detail. We realize that forest vegetation treatments and road building have the potential to produce impacts to water resources. However, effects to water resources can be minimized with appropriate, site specific application of project Design Criteria and Best Management Practices (BMPs). BMPs prevent most management activities from impacting water quality by minimizing sediment-producing disturbance and minimizing the potential for any sediment that is generated to reach a water body. Specific Design Criteria and Best Management Practices to address these concerns are included in this document. Montana has laws and regulations, included in timber sale contracts to protect the environment in and around the potholes and wetlands. Further protection is exercised by project design, both in unit layout and in implementation. INFISH and the Streamside Management Zone Law are two examples of regulations whose focus is to protect water quality and aquatic habitat. Temporary roads would be constructed to the minimum standards necessary for log hauling. No public wheeled motorized access would be allowed on them. All temporary roads would be reclaimed following use (See Design Criteria, Appendix 2). The goal of reclaiming the temporary roads would be to discourage motorized use. Temporary roads will not increase the total road density (TRD) in the bear subunit. Open road densities (ORD) would temporarily increase during sale activities. The proposed activities in the Glacier Loon Project are outside of areas that would be expected to provide potential denning habitat for grizzly bear. There is no proposed activity in known or potential grizzly bear denning habitat. There is no proposed activity in known or potential grizzly bear denning habitat All temporary roads and skid roads would be reclaimed by removing any installed culverts and temporary bridges (or, where they are less impactive, through the use of log crossings to be placed without excavation and removed prior to the wet season), by placing large woody material on the template, and by seeding with the native plant mix as specified by the Forest Botanist. In addition, all newly constructed temporary and skid roads would include re-contouring the entire road template to the natural ground contour, and to the extent feasible, placing the top soil back on the soil surface. However, on this gentle terrain, it is anticipated that little top soil would need to be moved, for the most part, during temporary road construction. Resource specific analyses of the effects to temporary roads on Fisheries, Invasive Plants, and Water Resources are disclosed in the EA. Because specific design criteria are included to address the issues and concerns associated with temporary roads as well as the increased costs of treatments associated with eliminating the use of temporary roads, an alternative to not use temporary roads was not considered in detail.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

KRAFT CREEK FISH BARRIER

Westslope cutthroat trout have greatly declined in number and distribution throughout the Swan River Valley. In 2008, a collaborative group, called the “Swan Native Fish Committee,” reviewed all available data regarding cutthroat trout in the Swan River Valley. Available data indicated that only 17 tributary streams still had genetically pure or nearly pure populations and this represented just 20 percent of the historic distribution. The Kraft Creek population was the largest remaining population in the Swan River Valley. This population consisted of several tributaries (Red Butte, Upper Kraft, Middle Kraft, Hemlock and Frenchy Creeks) that all co-mingled and formed a stronghold population. Available information for the Kraft Creek population was largely based on Forest Service surveys in 2004. The 2004 surveys found 100 percent genetically pure populations in the Red Butte and Upper Kraft Creeks. Middle Kraft Creek was 95 percent pure with slight introgression from rainbow trout alleles. Several migratory rainbow trout were captured in an upstream weir (fish trap) in the spring of 2004. Brook trout had invaded the area but their numbers were relatively low. Based on this information, the Swan Native Fish Committee recommended investigating if it would be desirable to install a barrier on Kraft Creek. The concept was to install a barrier that blocks any further invasion of both rainbow trout and brook trout. There were several factors about Kraft Creek that made it appealing to conserve cutthroat trout by isolation. Kraft Creek was the largest remnant population in the Swan River Valley and unlikely to experience a loss of genetic fitness over time (“inbreeding”). The 2004 fish weir determined the cutthroat trout do not migrate and isolating them would be benign. Kraft Creek also has excellent habitat conditions. The watershed is entirely on NFS lands. Bull trout do not spawn in this system and installing the barrier would not have significant impacts to them. However, it was also understood that the Kraft Creek population would not be 100 percent pure (some rainbow alleles had already been detected in Middle Kraft Area) but still at least 95 percent pure. There was also some concern that brook trout had already invaded the system, although they had remained at low numbers and were not depressing cutthroat trout abundance. The Forest Service identified a possible location for a barrier in Kraft Creek, not far downstream from the Hemlock Creek confluence. The Glacier Loon Proposed Action included the barrier in public scoping. Comments received were supportive although concern was raised about the impact of a short, temporary road needed to install the barrier. An engineering firm was contracted to prepare a design concept for the barrier to aid environmental analysis. Meanwhile, the Swan Native Fish Committee collected more fisheries data in 2011 and also took advantage of recent advancements in conservation genetics. Unfortunately, the 2011 surveys found Kraft Creek had changed a lot since 2004. The area that previously was considered 95 percent pure was now about 88 percent pure. Most of the fish collected there had non-native alleles, indicating hybridization was rapidly increasing and widespread. Upper Kraft Creek and Hemlock Creek were also slightly hybridized. Only Red Butte Creek was still 100

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

percent pure. The 2011 surveys also discovered that brook trout had substantially increased in numbers. Brook trout were now 50 percent of the biomass in Middle Kraft and Lower Hemlock Creeks. Brook trout numbers were also beginning to increase in Upper Kraft Creek. Red Butte Creek had a few brook trout but this tributary was still dominated by cutthroat trout. Based on this information, the Swan Native Fish Committee could not reach consensus if the barrier was still desirable. Some individuals felt that Kraft Creek still represented one of the best opportunities to conserve a large cutthroat trout population, even if it was hybridized. Others felt it would be a poor investment, especially if brook trout continue to expand and dominate Kraft Creek. Brook trout would need to be suppressed or even eradicated. Montana Fish, Wildlife & Parks has no plans for this activity in the near future. The group recommended investigating Red Butte Creek for a barrier. Therefore, the Forest Service removed the Kraft Creek barrier from consideration with this project. In a separate decision, the Forest Service approved a barrier on Red Butte Creek instead and this was constructed in 2014. The Red Butte Creek fish barrier is located just outside of the Glacier Loon project boundary.

ALTERNATIVES CONSIDERED IN DETAIL

ALTERNATIVE A - NO ACTION

This alternative represents the existing condition in the Glacier Loon project area. Under this alternative, none of the activities proposed for the Glacier Loon Project would occur. No fuels reduction or forest health activities, temporary road and access management, and planting activities to aid in vegetation recovery, or other activities associated with the Proposed Action would occur at this time. Ongoing activities, such as recreation, public firewood gathering, fire suppression, and normal road maintenance would continue. Activities identified in Chapter 3 as current and foreseeable actions would occur.

ALTERNATIVE B - PROPOSED ACTION

Intent: Alternative B was developed to respond to the Purpose and Need for the Glacier Loon Project. The Proposed Action focuses on reducing hazardous fuel buildup and improving forest health in the Glacier Loon project area by using various vegetative treatments, both commercial and non-commercial. Features associated with this alternative include the following: . Fuel reduction and forest health treatment of affected stands on approximately 2102 acres of NFS lands within the Glacier Loon project area including: o 240 acres of Clearcut with Reserve Trees; o 463 acres of Seed Tree with Reserve Trees; o 70 acres of Shelterwood with Reserve Trees; o 851 acres of Commercial Thin;

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

o 117 acres of Improvement Cut; o 8 acres of Sanitation/Salvage; o 10 acres of Post and Pole; and o 343 acres of Pre-Commercial Thin. . Harvest activities would be implemented using the tractor, skyline, mechanical, and hand treatments in the summer and tractor and forwarder logging systems during the winter. . Slash would be treated through a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings would be addressed through burning, chipping/masticating, and/or removal from NFS lands. Prescribed fire treatments could include broadcast burning, pile burning and/or jackpot burning. . Hand planting would occur on an estimated 400 acres of desired species within regeneration treatment units. Where adequate site preparation is achieved, natural regeneration would be expected to occur and in some cases supplement planted seedlings. A variety of species would likely become naturally established. . Fuels Treatment would occur on 1,710 acres within the WUI. . Fuels Treatment would occur on 392 acres outside the WUI. . BMPs would be implemented on an estimated 37.7 miles of haul routes to meet Timber Sale Requirements. . Units would be accessed through an estimated 11.5 miles of temporary road construction. NFS roads would be used for road haul. . Road decommissioning was proposed on an estimated 4.1 miles of NFS road. . Minimal harvest activity would occur within Riparian Habitat Conservation Areas (RHCAs) in upland areas. Some temporary road locations would occur within RHCAs and cross streams. Site specific Design Criteria would assure that there would not be any adverse effects to streams, fish, or fish habitat. Portions of Units 19, 24, 57, 61, and 205 totaling acres and a portion of Unit 64 totaling 2.08 acres would occur within RHCAs.

ALTERNATIVE C

Intent: Alternative C was developed to respond to Issue #1, Scenic Values (primarily views from the property owners on the northwest shore of Lindbergh Lake) and Water Quality (reducing sedimentation to streams and water bodies). To address these concerns, treatment units were modified by shape, reduced in acreage, or dropped. Proposed temporary roads were shortened, re-located, or dropped. In addition, an increased number of roads were proposed for decommissioning. Features associated with this alternative include the following: . Fuel reduction and forest health treatment of affected stands on approximately 1909 acres of NFS lands within the Glacier Loon project area including:

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

o 229 acres of Clearcut with Reserve Trees; o 405 acres of Seed Tree with Reserve Trees; o 51 acres of Shelterwood with Reserve Trees; o 624 acres of Commercial Thin; o 117 acres of Improvement Cut; o 11 acres of Sanitation/Salvage; o 10 acres of Post and Pole; and o 343 acres of Pre-Commercial Thin; and o 119 acres of Modified Commercial Thin . Harvest activities would be implemented using the tractor, skyline, mechanical, and hand treatments in the summer and tractor and forwarder logging systems during the winter. . Slash would be treated through a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings would be addressed through burning, chipping/masticating, and/or removal from NFS lands. Prescribed fire treatments could include broadcast burning, pile burning and/or jackpot burning. . Hand planting would occur on an estimated 340 acres of desired species within regeneration treatment units. Where adequate site preparation is achieved, natural regeneration would be expected to occur and in some cases supplement planted seedlings. A variety of species would likely become naturally established. . Fuels Treatment would occur on 1,526 acres within the WUI. . Fuels Treatment would occur on 383 acres outside the WUI. . BMPs would be implemented on an estimated 34.7 miles of haul routes to meet Timber Sale Requirements. . Units would be accessed through an estimated 7.4 miles of temporary road construction. NFS roads would be used for road haul. . Road decommissioning is proposed on an estimated 8.4 miles of NFS road. . No new temporary road construction would occur within riparian areas. . Minimal harvest activity would occur within Riparian Habitat Conservation Areas (RHCAs) in upland areas. Portions of Units 19, 24, 57, 61, and 205 totaling 4.3 acres and a portion of Unit 64 totaling 2.08 acres would occur within RHCAs. Site specific Design Criteria would assure that there would not be any adverse effects to streams, fish, or fish habitat.

ALTERNATIVE D

Intent: Alternative D was developed to respond to Issue #2, Wildlife Security. Wildlife security, retention of hiding cover and habitat connectivity, riparian habitat protection,

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

and retention of recruitment of old growth habitat and lynx forage were the focal points for the development of this alternative. To address these concerns, some units in Alternative B have been retained, modified, or dropped. Proposed road management in Alternative D is also different; there has been a decrease in the amount of temporary road construction and an increase in the amount of road decommissioning as compared to Alternative B. With the reduction in the amount of temporary road construction, longer skidding distances would occur with this alternative. Alternative D proposed treatments of stands that would not continue to provide wildlife habitat in the short-term (5-10 year) without management intervention. Management activities would accelerate conversion to meaningful habitat for some wildlife species in stands proposed for treatment. Forested stands that would likely continue to provide habitat for longer than 5-10 years, without management intervention were deferred from treatment at this time in order to maintain hiding cover, connectivity of habitat, and wildlife security. Features associated with this alternative include the following: . Fuel reduction and forest health treatment of affected stands on approximately 1,150 acres of NFS lands within the Glacier Loon project area including: 217 acres of Clearcut with Reserve Trees; o o 347 acres of Seed Tree with Reserve Trees;

o 31 acres of Shelterwood with Reserve Trees; o 236 acres of Commercial Thin; o 84 acres of Improvement Cut; o acres of Sanitation/Salvage; o 10 acres of Post and Pole; and o 95 acres of Pre-Commercial Thin o 125 acres of Modified Commercial Thin . Harvest activities would be implemented using the tractor, skyline, mechanical, and hand treatments in the summer and tractor and forwarder logging systems during the winter. . Slash would be treated through a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings would be addressed through burning, chipping/masticating, and/or removal from NFS lands. Prescribed fire treatments could include broadcast burning, pile burning and/or jackpot burning. . Hand planting would occur on an estimated 290 acres of desired species within regeneration treatment units. Where adequate site preparation is achieved, natural regeneration would be expected to occur and in some cases supplement planted seedlings. A variety of species would likely become naturally established. . Fuels Treatment would occur on 902 acres within the WUI. . Fuels Treatment would occur on 248 acres outside the WUI.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

. (BMPs would be implemented on an estimated 29.1 miles of haul routes to meet Timber Sale Requirements. . Units would be accessed through an estimated 5.8 miles of temporary road construction. NFS roads would be used for road haul. . Road decommissioning is proposed on an estimated 8.4 miles of NFS road. . Minimal harvest activity would occur within Riparian Habitat Conservation Areas (RHCAs) in upland areas. Some temporary road locations would occur within RHCAs and cross streams. Portions of Units 19, 24, 57, 61, and 205 totaling 4.3 acres would occur within RHCAs. Site specific Design Criteria would assure that there would not be any adverse effects to streams, fish, or fish habitat.

FOREST PLAN MANAGEMENT AREA CHANGE

The Flathead Forest Plan sets management direction for this project area. The Forest Plan provides forest-wide goals and objectives (pages II-1 through II- 57).The Forest Plan also divides the Flathead National Forest into subunits called Management Areas (MAs). Each of these MAs has resource or activity goals and management standards (Forest Plan, pages III-1 through III-126). In keeping with Forest Service Policy on multiple use, the Forest Plan established goals to strike a balance among different resources (Forest Plan, page II-5). Comments were received from the public requesting that the management area designation be changed on the western shore of Lindbergh Lake. The statements below are examples of comments received during scoping, which articulated these concerns (Project File Exhibit D-1). . I would like the management description for these areas to be reclassified. A classification of MA2 would put this area into a category closely representing “Backcountry” designation, which was proposed during the previous ranger’s tenure at Swan Lake. While I am very concerned for the high visual impact of this area, I would not be completely opposed to some thinning due to diseased and dead trees; but would definitely not wish to have it be in what I consider the drastic form of the current proposal (Project File Exhibit C-21). . We would like the management description for these areas to be reclassified. A classification of MA2 would put this area into a category closely representing “Backcountry” designation, which was proposed during the previous ranger’s tenure at Swan Lake (Project File Exhibit C-29). . It is quite clear that proposed roads and logging units on the slopes above Lindbergh Lake are not acceptable from a visual quality perspective, especially to those who recreate on or have homes on the lake. We ask that the underlying Forest Plan Management Area (MA) designation be changed to MA 5 or MA 2 in order to provide retention of the current visual quality and keep management activities from being noticeable – and to make the MA consistent with those on either side of the proposed activities (Project File Exhibit C-34). Based on the above public comment, Alternatives C and D included a proposed

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI change to the Management Area (MA) for a portion of the Glacier Loon project area along Lindbergh Lake, including the highly visible portions of the project area from the lakeshore to the slope break totaling approximately 221 acres. The proposal would change 213 acres from MA 15, which consists of timberlands where timber management with roads is economical and feasible as currently assigned, to MA 5, which consists of roaded timberlands in areas of high scenic value. The other 8 acres would be changed from MA 15C, timberlands with emphasis on white-tailed deer summer range, to MA 5.

DECISION

As the Responsible Official for the Flathead National Forest, I have selected the vegetation, management, road management, and associated actions displayed in Alternative D in the supplemental EA, with some modifications. My decision incorporates the changes listed below. Appendix 1 of this Decision Notice contains a detailed description of the features of the Selected Alternative. I have reviewed the modifications and have determined that the changes are minor, and result in the same or reduced environmental impact than that disclosed under Alternatives B and C, and are within the scope and context of the environmental effects disclosed in the SEA, Biological Assessments (BA), Biological Evaluation (BE), and supporting documentation. The features of this alternative were all site-specifically analyzed in the affected environment and environmental consequences sections presented in Chapter 3 of the SEA. Project File Exhibit T-18 provides a narrative by resource section that demonstrates how the environmental consequences of the Selected Alternative are within these ranges. I have also incorporated into my decision Project Design Criteria (Decision Notice – Appendix 2), Monitoring Plan (Decision Notice - Appendix 3), and Best Management Practices (Decision Notice - Appendix 4). The Selected Alternative defers treatment in two units (Units 53 and 83), decreases the size of eight units (20, 66, 67, 68, 70, 79, 81, and 82) and adds eight units or portions of units (Unit 43, the portion of Unit 76 located within the WUI, Unit 80, and Units 200, 201, 202, 203, and 204). The Selected Alternative also modifies the treatment type of Unit 2. These changes are based on additional field validation, the addition of a 50 foot buffer added to the RHCAs totaling 100 foot on each side of the stream in those units where streams exist within the Glacier Creek Watershed, 150 foot buffers adjacent to wetlands over one acre in size, resource concerns displayed in the EA, and public comments (See Appendix 5 for comments received on the EA and our agency’s responses to those comments). Units deferred will need to undergo future site-specific analysis and decision. The Selected Alternative does the following: . Unit 2 – Modifies the type of treatment from Clearcut with Reserves to Commercial Thin/Pre-Commercial Thin. Further field evaluation indicated that thinning would be a better management alternative to maintaining long-term site

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

productivity. . Units 3 and 4 -The majority of units 3 and 4 fell within the 300 foot buffer for unoccupied water howellia ponds, so both units were dropped. . Unit 20 – Reduces the size 2 acres to better protect a wetland occurring on private land. . The primary treatment of this unit is to capture the mortality of mountain pine beetle affected trees, restore resilient stand conditions consisting of early seral species, and reduces fuel continuity within the WUI. An RHCA of 150 feet will be implemented adjacent to the wetland on private land. No harvest activity will take place within this RHCA. . Unit 43 – This unit is included in the decision, though it was evaluated as part of Alternatives B and C in the EA, rather than Alternative D. Treatment of this unit addresses species composition (favor long-lived, fire resistant seral species) and the mid- story Douglas-fir ladder fuels that have encroached. This stand is located within the Wildland Urban Interface and adjacent to the Lindbergh Lake Road. A “Commercial Thin” treatment would be implemented where the purpose is to manipulate the fuel continuity and enlarge the growing space of desirable trees, reduce tree competition allowing for improved tree growth, vigor, and resilience. . Unit 53 – Defers treatment of this Seed Tree unit due to access for the unit dependent upon entering an RHCA. . Unit 66 – Reduces the unit size 4 acres to better protect riparian values. This unit is in the vicinity of the Lindbergh Lake Campground and adjacent to private lands near Lindbergh and Cygnet Lakes. The primary treatment objective of fuels reduction and hazard tree mitigation will be met while ensuring retention/enhancement of the recreational experience and privacy retention/screening for private lands. An RHCA of 100 feet will be implemented along the creek flowing into Lindbergh Lake. No harvest activity will take place within this RHCA. . Unit 67 – Reduces the unit size 1 acre to better protect riparian values. This unit is in the vicinity of the Lindbergh Lake Campground. The primary treatment objective of fuels reduction and hazard tree mitigation will be met while ensuring retention/enhancement of the recreational experience and privacy retention/screening for private lands. An RHCA of 100 feet will be implemented along the creek flowing into Lindbergh Lake. No harvest activity will take place within this RHCA. . Unit 68 – Reduces the unit size 4 acres to better protect riparian values. Treatment of this unit addresses species composition (favor long-lived, fire resistant seral species) ladder fuels, active mountain pine beetle populations, and dwarf mistletoe. This unit is located within the Wildland Urban Interface. A “Commercial Thin” will be implemented where the purpose is to manipulate the fuel continuity and enlarge the growing space of desirable trees, reduce tree competition allowing for improved tree growth, vigor, and resilience. A Riparian

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Habitat Conservation Area of 100 feet will be implemented along the creek flowing into Lindbergh Lake. No harvest activity will take place within this RHCA. . Unit 70 – Reduces the size 2 acres to better protect riparian values. Treatment of this unit captures the mortality of mountain pine beetle affected trees, restores resilient stand conditions consisting of early seral species, and reduces fuel continuity within the WUI. This unit is located within the WUI. A “Seed Tree with Reserves” treatment will be implemented to manipulate the fuel continuity and enlarge the growing space of desirable trees, reduce tree competition allowing for improved tree growth, vigor, and resilience. An RHCA of 100 feet will be implemented along the creek flowing into Lindbergh Lake. No harvest activity will take place within this RHCA. . Unit 76 – A portion of this unit is included in the decision, though it was evaluated in its entirety as part of Alternatives B and C in the EA, rather than Alternative D. Treatment of this unit addresses species composition (favor long- lived, fire resistant seral species) ladder fuels, and mountain pine beetle in the lodgepole pine component. This unit is located within the WUI and adjacent to the Lindbergh Lake Road. A “Commercial Thin” will be implemented where the purpose is to manipulate the fuel continuity and enlarge the growing space of desirable trees, reduce tree competition allowing for improved tree growth, vigor, and resilience. . Unit 79 - Reduces the size 3 acres to better protect riparian values. Treatment of this unit addresses the mountain pine beetle in the lodgepole pine component and regenerate to long-lived early seral species. This unit is located within the WUI. A “Seed Tree with Reserve” treatment will be implemented where the purpose is to manipulate the fuel continuity and enlarge the growing space of desirable trees, reduce tree competition allowing for improved tree growth, vigor, and resilience. An RHCA of 100 feet will be implemented along the wetland located north of the unit. No harvest activity will take place within this RHCA. . Unit 80 – This unit is included in the decision, though it was evaluated as part of Alternatives B and C in the EA, rather than Alternative D. Treatment of this unit addresses the high mountain pine beetle activity, dwarf mistletoe in Western larch, root rot in Douglas-fir and fuels. This unit is also located within the WUI. A “Shelterwood with Reserves” treatment will be implemented where the purpose is to retain portion of the existing overstory long-lived, fire-resistant, shade- intolerant species (typically; western larch, ponderosa pine, western white pine, and occasionally Douglas- fir) and reserved at a density sufficient to facilitate regeneration of these desired species and create a two-aged stand structure (e.g., 10 to 30 trees per acre). This density is designed to provide seed sources, long-term structural diversity, and provide shelter and a moderated micro-climate favorable for regeneration. The acreage is also reduced slightly, based on more accurate field mapping of the slope break when considering an adverse and side- hill ground based mechanized logging system. . Unit 81 – Reduces the unit size 4 acres to better protect riparian values and old growth stand characteristics. After further field examinations, a portion of this

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

stand was deemed more similar in age and structure to the adjacent stand. Therefore this portion was removed from Unit 81 and added to the adjacent stand. In addition, a portion of the remaining Unit 81 stand was set aside as an RHCA, constituting a 100 foot wide buffer along the creek flowing into Lindbergh Lake, and in which no harvest activities will take place. The remainder of the unit is dominated by lodgepole pine severely attacked by mountain pine beetle for which a “Seed Tree with Reserve Trees” treatment will be implemented. This is a regeneration harvest where a portion of the existing overstory (e.g. 5 to 15 trees per acre) will be retained and reserved at a density sufficient to provide adequate seed for re-establishment and long-term structural diversity. Trees retained will be comprised of long-lived, fire-resistant, shade intolerant tree species (western larch, ponderosa pine, western white pine, Douglas-fir) in accordance with the Forest Plan. . Unit 82 – Reduces the size 3 acres to better protect riparian values. This unit is dominated by lodgepole pine infested with mountain pine beetle. A “Seed Tree with Reserve Trees” treatment will be implemented where a portion of the existing overstory long-lived fire-resistant, shade intolerant species (western larch, ponderosa pine, western white pine, Douglas-fir) will be retained and reserved at a density to provide seed sources and long-term structural diversity (e.g. 5 to 15 trees per acre). An RHCA of 100 feet will be implemented along the creek flowing into Lindbergh Lake. No harvest activity will take place within this RHCA. . Unit 83 – Defers treatment of this unit due to the visibility of this treatment seen from Lindbergh Lake and adjacent private land. . Unit 200 – This unit is included in the decision, though it was evaluated as part of Alternatives B and C in the EA, rather than Alternative D. The “Pre-Commercial Thinning” treatment of this unit reduces fuel continuity, adjust species composition, and concentrate growth on the most desirable trees. Treatment will focus on the removal of sapling and pole-sized trees generally not greater than 5 inches DBH. This treatment will be accomplished by hand thinning or mechanized chipping/mastication. This unit is located within the WUI; this fuels treatment provides both short and long term benefits at both the landscape and stand level. . Units 201, 202, 203, 204 – These units are included in the decision, though they were evaluated as part of Alternatives B and C in the EA, rather than Alternative D. These “Pre-Commercial Thinning” treatments are located within the Crazy Horse Fire Area. These units have fuels treatment objective and have both landscape and stand level implications with both short and long term fuels benefits. Given the expanse of tree regeneration in the Crazy Horse Fire, these treatments provide fuel manipulation between the main fire body and unburned areas. Also, the window for treatment temporally is logical given our planning cycle with the Grizzly Bear rotation and fuel loading issues as these trees grow larger. . An estimated 5.9 miles of temporary road construction will be implemented to

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

access harvest units as described in Appendix 1. These temporary roads would be reclaimed following their use. . An estimated 8.4 miles of NFS road will be decommissioned as described in Appendix 1. Roads will meet the reclaim definition from Amendment 19 to the Forest Plan (Amendment 19 Amended EA, page D-2). . Minimal harvest activity would occur within RHCAs in upland areas. Two temporary road locations (Roads #24A and #36C) will occur within RHCAs and cross streams. Portions of Units 19, 24, 57, 61, and 205 totaling 4.3 acres will occur within RHCAs. Site-specific Design Criteria will assure that there will not be any adverse effects to streams, fish, or fish habitat. . All occupied and unoccupied water howellia ponds will have a 300 foot buffer in bordering units. No vegetation management activities will occur within these 300 foot buffers. . Implementation of Resource Enhancement Projects described in Appendix 1 of this document.

PROJECT-SPECIFIC FOREST PLAN AMENDMENT

With this decision, I am authorizing a project-specific amendment to the Flathead Forest Plan related to a change to Management Areas (MA) for a portion of the Glacier Loon Project Area. These changes will occur along Lindbergh Lake (Table 1), and include the highly visible portions of the project area from the lakeshore to the slope break for a total of approximately 221 acres. The proposal would change 213 acres from MA 15 (timberlands where timber management with roads is economical and feasible as currently assigned) to MA 5 (roaded timberlands in areas of high scenic value). The other 8 acres would be changed from MA 15C (timberlands with emphasis on white-tailed deer summer range) to MA 5. The effects of these management area changes were discussed in Chapter 3 of the EA/SEA under each resource section. Table 1 below displays the acreages associated with this amendment. Also refer to Map 3 for a display of the project- specific amendments.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Table 1. Management Area Descriptions, Emphasis, and Management Area Acres for the Glacier Loon Fuels Reduction and Forest Health Project

Acres: Acres: MA Description Management Emphasis Forest Selected Plan Alternative Roaded timberlands in areas Maintain a pleasing, natural 1,233 1,454

5 of high scenic value. appearing landscape in which management activities are not MA evident. Timberlands where timber Emphasize cost-efficient 4,098 3,885 management with roads is production of timber while 15 economical and feasible. protecting the productive

MA capacity of the land and timber resource.

Consists of timberlands where Special consideration will be 7,108 7,100 timber management with given to white-tailed deer 15C roads is economical and summer range within this MA.

MA feasible, and is key white- tailed deer summer range. This project-specific amendment will remain in place pending revision or future amendments of the Flathead Forest Plan. The Forest Plan revision process is expected to be completed in 2018.

SCOPE OF THE DECISION

The Glacier Loon Subunit, where the Glacier Loon Project is proposed, is currently “Inactive” and becomes “Active” again in 2021 through 2023 under the Swan Valley Grizzly Bear Conservation Agreement (SVGBCA). The Buck Holland Subunit is “Active from 2018 through 2020, and becomes “Inactive” again in 2021. When project activities are scheduled to occur in a time when a subunit is “Inactive”, then standards and guidelines for an inactive grizzly bear subunit would be followed, as per the SVGBCA. All roads used would be managed consistent with the requirements of the SVGBCA. Post-harvest activities, such as burning and planting, should be completed 1 year following harvest activities. Reforestation activities would be completed no more than 5 years after logging is completed in each unit.

RATIONALE FOR MY DECISION

In finalizing the Selected Alternative, I have determined that my decision is consistent with all laws, regulations, and agency policy. I have considered the potential cumulative effects and reasonably foreseeable activities. I believe my decision provides the best balance of management activities to respond to the Purpose and Need, issues, and public comments, while complying with all applicable laws and regulations. My decision seeks to balance public interests and ecological desired conditions such as managing forest vegetation reducing the threat of wildfire to Federal and private lands; providing

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

for a diverse and healthy ecosystem; meeting threatened, endangered, sensitive plant and animal habitat needs, and reducing water quality effects to streams, riparian areas, and wetlands; and providing forest products and economic opportunities to contribute to local economies. My criteria for making a decision on this project were based on: . Achievement of the project’s Purpose and Need; and . Relationship to environmental and social issues and public comments received.

MEETING THE PURPOSE AND NEED

The Glacier Loon Area was selected for this project because of existing fuel hazard and forest health conditions and the opportunity it presents to reduce the effects that a future wildland fire may have on property and resource values. Treatment of these conditions also presents the opportunity to utilize the wood products removed from the suitable timber base for social benefit. Relative to the reduction of fuel hazard, the existing condition in the project area is a result of fire suppression and exclusion combined with increasing mortality in some stands due to mountain pine beetle and other natural disturbance processes. I believe that reducing these fuel conditions in specific areas will create a safer environment for the firefighters and the public should a fire occur, and protect human and resource values in the event of a future wildfire on Forest Service Lands within and near the project area. In the Swan Valley, there has been an increase in the number of people living in close proximity to NFS lands. Hazardous fuel reduction is one of the key points of the National Fire Plan, which emphasizes management in dense forest vegetation resulting from decades of fire exclusion, particularly within WUI areas. Approximately 14,539 acres of the Glacier Loon Project Area (37,320 acres) lies within the WUI as identified by the Seeley-Swan Fire Plan (2004 and 2013). The threat to life and property from high forest fuel hazards was unfortunately illustrated once again during the 2012 fire season in forestlands in the Swan Valley, other parts of Montana and other western states. Relative to the existing forest health stand conditions, we know from past analyses (The Upper Swan Valley Landscape Assessment 2004, Crazy Horse III Fire Salvage EA) that forest stands in the project area and throughout the Swan are some of the most highly productive sites found on the Swan Lake Ranger District. Stands in the project area have higher tree densities in multiple canopy layers than what commonly existed historically. This is primarily due to fire exclusion over the last century, but sometimes due to stand age and species composition combined with insect and disease conditions (as in several of the lodgepole dominated stands in the project area). The understory canopy layers are competing with trees in the overstory providing ladder fuels and fuel loadings that have the potential to support stand-replacing fires. Competition for moisture is reducing the vigor and resilience of the dominant overstory trees, resulting in poor growth, increased susceptibility to insects and disease, and increasing mortality.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Insects and disease have also led to mortality and greater fire hazard in many areas in the project area. Mountain pine beetle has been observed in numerous stands within the project area. As designed, the Selected Alternative will help restore forest health in specific stands with benefit to increasing western larch and western white pine presence and heath in some stands. The Selected Alternative will also generally improve the health, resiliency, and sustainability of forest vegetative communities, and reduce the risk of insect and disease infestations within the project area. Relative to the purpose and need to provide wood products to local economies, the Selected Alternative makes reasonable use of such products from the suitable timber base. In weighing the various combinations of alternatives, the Selected Alternative, does defer some areas of treatment, primarily to address other resource concerns, though the Selected Alternative does not provide as much wood product as do Alternatives B and C, it does provide an estimated 6.7 million board feet of timber.

COMPARISON OF ALTERNATIVES

Those units retained in the Selected Alternative have a combination of circumstances that either grow worse over time (such as active pine beetle infestation) or where I think the prescriptions and locations will serve to either reduce fuels or improve forest health, without causing significant offsetting negative impacts. Some of the treatments also provide a degree of timber products from the suitable timber base. I believe the Selected Alternative, as described in this decision, best meets the Purpose and Need for the Glacier Loon Project, while also being responsive to resource issues and public input identified through the analysis process. Additional rationale is provided below. I did not select the No Action Alternative in its entirety because this alternative does not address the concern of the risk of high severity wildfires in the WUI, forest health, nor would it provide forest products to the local economies. No action would mean forest canopies within the project area would continue to become denser and more closed in, and surface and ladder fuels would continue to accumulate. Trees would be less vigorous and less resilient to disturbances. Western larch and western white pine would continue to decline from disease issues, leading to reductions in this forest type. Regeneration of western larch and western white pine would be inhibited due to the increased shading within the stands and lack of disturbance. Trees and stands would continue to experience the effects of mountain pine beetle, white pine blister rust, western larch dwarf mistletoe, and root disease. The risk of larger-scale mountain pine beetle activity would increase. Conditions that favor mountain pine beetle population growth, windthrow, increased residual tree damage, and increased mortality would continue. Increasing insect or disease- related mortality would add to the existing fuel load accumulation. Natural fuels would accumulate faster than they are recycled; increasing the natural fuels hazards near private lands. The risk of stand-replacing fire would increase as long as these stand conditions persisted. Selection of the No Action Alternative would be inconsistent with the Purpose and Need for this project. Based on the environmental analysis, the long-term effect of selection of the No Action Alternative

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI would likely yield greater adverse social and environmental effects than would the Selected Alternative. Some units (as discussed above) were deferred as in Alternative A. The rationale for deferring units that had been in one of the action alternatives is given above in the unit descriptions of the Selected Alternative. I believe the units can be deferred without significantly compromising the purpose and need for the project. The Selected Alternative will create sustainable forest conditions by reducing forest fuel conditions and improving overall stand health. Growing space, individual tree vigor, and the ability to withstand insect and disease will be improved in treated stands. Better opportunities for western larch and western white pine regeneration will result from the creation of more open stand conditions. In addition to creating sustainable forest conditions, I believe my decision will reduce potential fire intensities and improve the opportunity for fire suppression, and lessen the potential for fires on Federal land to ignite private structures. The estimated 6.7 million board feet of timber resulting from these management activities will provide economic opportunities to the local communities. As summarized in the following table, the Selected Alternative is responsive to the Purpose and Need statements for the Glacier Loon Project. Table 2. Comparison of Alternatives: How They Respond to the Purpose and Need

Selected Alt. A Alt. B Alt. C Alt. D Purpose and Need Statement Alternative Hazardous Fuels Reduction Reduce the associated risk of high-severity landscape wildfire risk within the Wildland Urban Interface (WUI) as identified in the 0 1710 1526 902 1157 Seeley Swan Fire Plan (Indicator: Acres treated within the WUI). Reduce the associated risk of high-severity wildfire risk outside the Wildland Urban 0 392 383 248 240 Interface (Indicator: Acres treated outside the WUI). Provide a safer environment for the public and firefighters should a wildfire occur within the No Yes Yes Yes Yes proposed treatment areas. Increase the probability of stopping wildfires on NFS lands before they burn onto private No Yes Yes Yes Yes lands. Forest Health

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Selected Alt. A Alt. B Alt. C Alt. D Purpose and Need Statement Alternative Improve and/or maintain the general health, resiliency and sustainability of forested stands. (Acres treated – Clearcut with Reserve Trees, Seed Tree with Reserve Trees, Commercial 0 2092 1899 1140 1395 Thin, Improvement Cut, Modified Commercial Thin, Pre-commercial Thin, Post and Pole, Shelterwood with Reserves, and Sanitation/Salvage) Reduce the risk of insect epidemics and severe disease infestations within the project area. (Acres treated – Clearcut with Reserve Trees, Seed Tree with Reserve Trees, 0 2092 1899 1140 1395 Commercial Thin, Improvement Cut, Modified Commercial Thin, Pre-commercial Thin, Shelterwood with Reserves, and Sanitation/Salvage) Provide Wood Products for Local Economies Timber Harvest Acres 0 2102 1909 1150 1397 Timber Harvest Volume (MMBF) 0 10.5 9.0 6.7 6.7

CONSIDERATION OF KEY ISSUES AND PUBLIC COMMENTS

In addition to the Purpose and Need, I also considered how well each alternative responds to the issues and comments identified by the public: scenic values, water quality, and wildlife security. The following section summarizes how I believe my decision responds to the issues identified in the supplemental EA and how it responds to more comments and concerns I received on the project. Individual comments received on other specific issues on the project are addressed in the “Response to Comments in Appendix 5 of this Decision.

SCENIC VALUES

As discussed above on pages 7-9, several comments were received how proposed treatments could affect Scenic Values. Some commenters expressed concern that the project would threaten the unique character and a vast area of the viewshed around Lindbergh Lake; commenters requested that the viewshed be retained in a natural state. Other commenters expressed their appreciation for the willingness of the Flathead National Forest to incorporate alternatives into the Environmental Assessment that addressed viewshed issues raised by residents in the Lindbergh Lake Area and said they recognize that if areas near Lindbergh Lake are left untreated the potential for wildfire danger remains high. Some commenters expressed that they appreciate the need to manage the health of our forests over the long run and voiced their support for Alternatives C and D. Commenters also voiced their support for either Alternative C or D which change the Management Area designation for the west shore of the lake. Other

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI commenters also voiced support for Alternatives A and B. I weighed this public input and concerns in coming to the Selected Alternative.

SCENIC VALUES: COMPARISON OF ALTERNATIVES

According to the Scenery Analysis conducted by the Regional Landscape Architect, Units 83, 84, 85, 86, and 87 would create the highest amounts of visual impacts to those views from Lindbergh Lake and shoreline residences. These units were proposed as regeneration harvest using Seed Tree and Shelterwood with Reserve Tree Treatments. As a result foreground and middle ground views associated with these regeneration harvest Units 83, 84, 85, 86, and 87 would be impacted. There would be negative effects from contrasting skyline corridors, skid trails, landing areas, and temporary road construction, as well as unit shape, texture, and form, edge contrast would be dominate, and would show higher contrast in harvest unit edges and shapes during snow covered winter months. Taking this into consideration, Alternatives C and D met these concerns by deferring treatment of these units with the exception of Unit 83. Due to the visual concerns voiced by the public, I also chose to defer treatment of Unit 83 to further reduce visual impacts in designing the Selected Alternative. The Selected Alternative also includes the Modified Commercial Thin Treatments for Units 66 and 67 incorporated from Alternatives C and D. These units are in the vicinity of the Lindbergh Lake Campground and adjacent to private lands near Cygnet Lake. A Modified Commercial Thin is proposed in those portions of Units 66 and 67 which are adjacent to the campground and private lands. The commercial thin treatment would be “modified” so that the primary treatment objectives of fuels reduction and hazard tree mitigation are met while ensuring retention/enhancement of the recreational experience and privacy retention/screening for private lands. Modifications could include, but not limited to, items such as varying residual tree densities near private lands and strategically retaining understory trees for visual/noise screening. During implementation, the Project Silviculturist will work closely with the District Recreation Staff and private land owners on treatment specifics. As a result, the Selected Alternative reduces visual impacts more than Alternatives B, C, and D as shown in Table 3 below with the total number of harvest units seen within viewsheds of high concern. Table 3. Comparison of Alternatives: How They Respond to the Scenic Value Key Issues

Selected Indicator Alt. A Alt. B Alt. C Alt. D Key Issue Alternative Meets Forest Plan Does or does not meet. Visual Quality Meets Meets Meets Meets Meets Objectives Change in Scenic Number of harvest units Integrity seen within viewsheds of 0 23 17 16 16 high concern.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Selected Indicator Alt. A Alt. B Alt. C Alt. D Key Issue Alternative Magnitude of Number of regeneration harvest units within Visual Impact 0 10 4 5 4 viewsheds of high concern. In addition, several acres located on the western slopes of Lindbergh Lake are currently are Management Area (MA) 15 under the Forest Plan. Due to public comments received concerning the Lindbergh Lake Viewshed, Alternatives C and D would propose to change the identified MA 15 acres to MA 5. As discussed above with this decision, I am authorizing a project-specific amendment to the Flathead Forest Plan related to a change to Management Areas (MA) for a portion of the Glacier Loon Project Area along Lindbergh Lake. This will change the VQO from modification/maximum modification to retention which will raise the level of current and future scenic integrity management for that land area. There will be no negative impacts associated with this change and will potentially have a long-term beneficial impact for Scenery Resources. The Selected Alternative will provide maximum protection to the Lindbergh Lake Viewshed and watershed and will incorporate a management area designation for the west shore of the lake.

WATER QUALITY

As discussed above on pages 7-9, several comments were received on how proposed treatments could affect Water Quality. Some commenters expressed concern that harvest and road building would result in sedimentation to streams, wetlands, and Lindbergh Lake and felt that water quality would be degraded. Other commenters expressed support for the decommissioning of roads and removal or replacement of culverts and bridges and stated that this would reduce sedimentation into local streams, would improve water quality, and would have a direct impact to fisheries and indirect impact on the economy of Missoula County. Other commenters expressed concern how proposed treatments within Riparian Habitat Conservation Areas (RHCAs) could affect riparian areas, which could result in impacts to water quality of Lindbergh Lake. I weighed this public input and concerns in coming to the Selected Alternative.

WATER QUALITY: COMPARISON OF ALTERNATIVES

Water Quantity: When considering the water quantities from the action alternatives, Alternative D as selected, resulted in a 0 percent change in annual water yield stream flows in the Glacier Creek Watershed when compared to Alternatives B and C. Alternative D also resulted in the least amount of annual water yield increase for the Swan River Valley Bottom Area when compared to Alternatives B and C (See Table 4). In addition, Alternative D resulted in a lower amount of water yield increase for the Upper Swan River Watershed when compared to Alternative B. Beneficial Uses: With either Alternative C or D there would be less annual change in

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI water quality than with Alternative B. Channel Stability: Channel stability would be retained with all action alternatives Table 4. Comparison of Alternatives: How They Respond to the Water Quality Key Issues

Selected Indicator Alt. A Alt. B Alt. C Alt. D Key Issue Alternative Glacier Creek 5.9% 6.0% 6.0% 5.9% 5.9% Water watershed quantity Upper Swan (water yield River 0.9% 1.2% 1.1% 1.1% 1.1% Increase watershed over Swan River baseline Valley bottom 19.8% 21.4% 21.0% 20.8% 20.8% conditions) area

Sediment Water increase quality compared to (sediment baseline delivery)

conditions mmeasurable Immeasurable I Immeasurable Immeasurable Immeasurable Beneficial Does or does Meets Meets Meets Meets Meets uses not meet Channel Channel stability Maintained Maintained Maintained Maintained Maintained stability maintained Temporary Road Construction: With respect to sediment delivery from temporary roads under Alternative B and C, Temporary Road #12A was needed to access harvest units. The road is a historic road with a culvert already in place. Under Alternatives B and C this road crosses an intermittent channel between two wetlands to access Units 60, 62, and 214. This temporary road was not needed in Alternative D as these units were not proposed for treatment in Alternative D. Nevertheless, this alternative required removal of the culvert to reduce the potential of high sediment delivery in the future. Under Alternative D, the culvert would be removed, the channel restored, and the road reclaimed. This is considered more advantageous to the Hydrologic Resource, and specifically water quality, than leaving the old road along with the potential for the culvert to wash out at some point in the future. The old culvert would be removed when the stream is dry (Resource Enhancement #3). This activity is incorporated into the Selected Alternative. In addition, construction of Temporary Road #22B (access to Units 84 and 85) and Road #15C (access to Units 67 and 69) would not occur in Alternatives C and D. These roads would have to cross two intermittent streams that flow directly to Lindbergh Lake. No new stream crossing would be installed and no disturbance of the stream bed and adjacent ground would occur. There would be no crossing of the high-gradient stream that flows directly into Lindbergh Lake, no sedimentation from this stream crossing

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

would transport to the lake. No temporary roads proposed would cross any stream channels and would not generate sediment within the Upper Swan Watershed. Within the Swan River Valley Watershed, Alternative C does not propose construction of temporary roads that need new stream crossings; Temporary Roads #36C and #24A are not included in Alternative C. Alternative D, however, proposes to construct Temporary Roads #24A and #36C with new stream crossings. These new stream crossings would generate a small amount of sedimentation during culvert installation and again during culvert removal. As discussed in the supplemental EA, Alternatives C and D do not include harvest along the west face of Lindbergh Lake as compared to Alternative B. Any sediment related to that harvest and reconstruction of NFS Roads #10732, #10733, and #10734 will not occur under Alternatives C and D. As displayed in Table 5 below, Alternative D proposes the least amount of temporary road construction of all the action alternatives with 5.9 miles.

Table 5. Comparison of Alternatives: How They Respond to Water Quality Key Issues- Temporary Roads

Key Selected Indicator Alt. A Alt. B Alt. C Alt. D Issue Alt. Miles of new temporary road 0 9.3 5.4 4.5 4.5 Miles of temporary road on historic 0 2.3 2.0 1.4 1.4 templates Miles of road decommissioned 0 4.1 8.4 8.4 8.4 Miles of best management practices 0 37.7 34.7 29.1 29.3 (BMP work) Water Quality Acres of activity within riparian habitat 0 6.4 6.4 4.3 4.3 conservation areas Decommissioning: Alternatives C and D also include obliteration and recontouring of 0.9 miles of NFS Road #9575 and 0.4 miles of NFS Road #9573. National Forest System Roads #10732, #10733, and #10734 (Lindbergh Lake) would be fully recontoured. These activities would install water bars to help water move off of road surfaces, thereby reducing erosion. Modeling (Project File Exhibit M-22) results displayed in the Soils Section found that sediment would not be detectable. There are approximately 2.1 miles of roads designated for decommissioning in Alternatives C and D in the Swan River Valley Bottom Area. This primarily includes NFS Road #79Y that accesses Units 38, 39, and Unit 40. This is an old road with a prism that is basically reclaiming its self. Another road, NFS Road #10567, accessing Units 206, 207, and 208 would have a culvert removed on a small tributary of the Swan River in the valley bottom. This work would occur after the road is used for yarding and access for thinning. Removal of the culvert would improve the channel morphology in this location because the pipe is less than bank full width. In Alternatives C and D the decommissioned roads would be put into the “Historic” status in the Forest Road Database.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

BMPs: The amount of road BMPs is associated with locations of harvest units and the distance of haul routes needed for hauling timber over National Forest System Roads. Because Alternative D has the least amount of acreage treated and consequently the least amount of hauling distance, the miles of BMPs are reduced accordingly. Ultimately, BMPs would reduce the small amount of erosion that occurs annually on area road systems. Additional BMP work would be applied on all haul routes, as well as touch up of those implemented in the past few years. Additional drainage features and touching up of existing drain dips would help minimize or eliminate connection of water running from the transportation system to area streams. RHCAs: Alternative D as selected has the least amount of treatment acres occurring within the RHCAs with 4.3 acres compared to Alternatives B and C with 6.4 acres. Existing roads isolate scattered small slivers of designated RHCAs that are included in six proposed treatment units (Units 19, 24, 57, 61, and 205). The existing roads separate these slivers hydrologically from the main bodies of the designated riparian areas as these slivers are located uphill of the existing roads. The District Fisheries Biologist examined these units and verified that there is no potential for erosion from the harvest activity to reach any of the wetlands. Please refer to Project File Exhibit N-8 for this site specific analysis. When considering all of the above indicators and weighing the public concern and input, I have chosen Alternative D with modifications based on the following rationale: . Alternative D results in the least amount of percent change in annual water yield stream flows within the three watersheds of the project area; . Alternative D does not include harvest along the west face of Lindbergh Lake. Any sediment related to that harvest and reconstruction of NFS Roads #10732, #10733, and #10734 would not occur under this Alternative. . Alternative D proposes the least amount of temporary road construction of all the action alternatives totaling 5.9 miles; even though this alternative proposes new temporary road construction across two stream channels, I feel the amount of sedimentation will be less than the potential sediment produced through the increased miles of road construction associated with the other alternatives. . Alternative D proposes the greatest amount of National Forest System Road decommissioning totaling 8.4 miles. . Beneficial Uses and Channel Stability will be maintained under Alternative D. . Alternative D proposes the least amount of activity within RHCAs totaling 4.3 acres.

WILDLIFE SECURITY

As discussed above on pages 9-10, several comments were received on the EA concerned with how treatments could affect habitat for wildlife, fish, and birds. Some commenters specifically commented on their concern for the project on grizzly bears and Canada lynx. Commenters expressed concern that the project does not result in a

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

net gain in habitat security, but results in a net loss.

WILDLIFE SECURITY: COMPARISON OF ALTERNATIVES

As previously discussed, Alternative D was developed to respond to wildlife concerns. Wildlife security, retention of hiding cover and habitat connectivity, riparian habitat protection, and retention of recruitment of old growth habitat and lynx forage were the focal points for the development of this alternative and discussed in detail in the Environmental Assessment. Hiding Cover: The decrease in hiding cover under Alternative D would be less than Alternatives B or C (See Table 6). As discussed previously, some units were incorporated into the Selected Alternative for treatment due to fuels and forest health concerns I deemed to be of high priority. Under the Selected Alternative there will be a decrease in hiding cover of 1,042 acres, less than Alternatives B and C. This reduction in hiding cover will lower the percentage in the project area from 70% to approximately 68%. Design Criteria identified in this Decision (Appendix 2) stipulate that vegetative screening be retained along open roads and Clearcut, Seed Tree, and Shelterwood Units retain cover such that no point in the unit is 600 feet from hiding cover. These Design Criteria were designed for the grizzly bear, but will benefit deer and elk, other big game species, sensitive species, and migratory birds. The Selected Alternative complies with the cover direction identified in the Swan Valley Grizzly Bear Conservation Agreement and the Flathead Forest Plan. None of the proposed activities under the Selected Alternative are located in areas mapped as deer and elk winter habitat. Wetland Complexes: The amount of acres treated in wetland areas would be greatest with Alternative B, less with Alternative C, and least with Alternative D (See Table 6 below). Under the Selected Alternative, there would be 320 acres of proposed treatment in or adjacent to wetland complexes. Wetland complexes provide important breeding habitat for the toad. The riparian guidelines in place for the Selected Alternative will help protect important riparian breeding habitat for boreal toad. Wetland complexes also have a high potential for providing small mammal habitat as well as ungulate habitat. Activities proposed under the Selected Alternative will have the least potential effect (320 acres) to wolverine. In the Glacier Loon Project Area, Loon Lake has been a successful breeding lake for the common loon, and has been monitored for approximately 10 years. Alternative D proposes no treatment adjacent to Loon Lake; Unit 15 has been dropped from Alternative D. There would be no vegetation removal near the lake shore under Alternative D; the ability for Loon Lake to provide common loon nesting habitat would remain unchanged. The deletion of Unit 15 is incorporated into the Selected Alternative. In Alternative D there would be no proposed treatment in old growth habitats. This design feature is also incorporated into the Selected Alternative. Riparian habitats and wetland complexes are also an important component of both deer

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI and elk habitat. Riparian Habitat Conservation Areas restrict activities within a designated distance from streams, lakes, and wetlands. The riparian guidelines in place for Alternative D would help protect important riparian habitats for deer and elk. Based on the discussion above, the Selected Alternative has the least amount of acreage treated adjacent to wetlands complexes for fisher and fisher prey species, the boreal toad, wolverine, common loon, deer, and elk when compared to Alternatives B and C. Table 6. Comparison of Alternatives: How They Respond to Wildlife Security Key Issues

Key Selected Indicator Alt. A Alt. B Alt. C Alt. D Issue Alt. Decrease in hiding cover 0 1453 1310 888 1042 (acres) Acres treated adjacent to 0 612 597 320 320 wetland complexes Use of restricted 0 23.6 miles 21.6 miles 16.0 miles 16.0 (gated/bermed) roads Miles of temporary road 0 11.5 miles 7.4 miles 5.9 miles 5.9 miles construction High contrast edge created

adjacent to old growth 0 10,400/2.0 8,800/1.7 6,600/1.3 6,600/1.3 stands (feet/miles)

Wildlife Security Acres treated in lynx habitat within wildland urban 0 1587 1473 755 1044 interface (WUI) Acres treated in lynx habitat 0 358 279 238 238 outside WUI Road decommissioning 0 4.1 8.4 8.4 8.4 Restricted Roads: As displayed in Table 6 above, Alternative D uses the least amount of restricted roads for project implementation. As a result, under the Selected Alternative, existing open roads and closed roads (currently bermed or gated) will be used to access treatment units totaling 16.0 miles. Use of open roads will not be a change from the existing condition. Use of gated or bermed roads will increase human activity levels in areas normally more secure for the grizzly bear. The bermed and gated roads are Maintenance Level 1 Roads. They are constructed to the minimum standards necessary and are designed to be re-used for timber management. The gated roads are closed year-long. Between re-entries both the bermed and gated roads are closed to public use. They are currently included in the Total Road Density (TRD) for a grizzly bear subunit. The short-term use of normally restricted roads will not increase the net TRD in a subunit. The following Design Criteria will help to mitigate the potential negative effects to grizzly bear from the use of normally restricted roads: . Roads that are currently closed, but that would be used for access and for hauling, would be closed to the general public during the time that they are utilized for fuel management or forest health treatments.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

. Where berms are removed for access to treatment units, temporary gates would be installed. Berms would be re-installed when sale activities in that area are completed. . Contractors associated with sale operations would be prohibited from carrying firearms on normally closed roads within the project area. . Vegetation and/or rock barriers would be retained around berms and gates, where needed, to maintain closure effectiveness following sale activities. Under Alternative D, approximately 16.0 miles of gated or bermed roads would be used for accessing proposed cutting units; significantly less than under Alternatives B or C. Under the Selected Alternative, road closures designed for grizzly bear security on NFS lands will also provide more security for a variety of wildlife species including lynx, wolverine and migratory birds when compared to Alternatives B and C. Temporary Road Construction: In a comparison of the action alternatives, effects to grizzly bear would be least with Alternative D with 5.8 miles of temporary road construction. Under the Selected Alternative, an estimated 5.9 miles of temporary road construction will occur. This slight increase can be attributed to the added treatment acreage that I decided to include in the Selected Alternative for reasons described on previously. Amendment 19 to the Forest Plan provides direction for grizzly bear habitat management. The A19 direction for the Glacier Loon and Buck Holland Subunits is to have no net increase in total or open motorized road access density and no net decrease in security core habitat. During the activities proposed under the Selected Alternative, there will be a temporary increase in the ORD and TRD in whichever subunit the activities were occurring; the road densities will be changing on a regular basis, both increasing and then decreasing, as restricted roads and temporary roads are utilized, then closed or reclaimed. The changes in ORD and TRD will be temporary; there will be no net increase. TRD will decrease after project completion. There will be no effects to security core. The Selected Alternative meets this direction and achieves A19 numerical objectives before and following implementation of proposed activities. The Selected Alternative also complies with all the direction of the Swan Valley Grizzly Bear Conservation Agreement. There are no temporary roads proposed in lynx forage under the Selection Action. The potential for disturbance and mortality to the black-backed woodpecker during the nesting period if nesting trees are cut down would be less for Alternative D than for Alternatives B and C because fewer acres would be affected. Under the Selected Alternative, Design Criteria for project implementation outside of the spring period (for grizzly bear) will help to mitigate this mortality risk by decreasing the potential for direct disturbance or mortality during the spring season. Road closures in place for the grizzly bear have improved security for potential black- backed woodpecker habitat in the Glacier Loon Area and throughout the Swan Valley. All temporary roads in the Glacier Loon Project Area would be rehabilitated following use. In a comparison of the action alternatives, the direct and indirect effects to gray wolf

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

would be least with Alternative D due to the least amount of miles of temporary road construction. Under the Selected Alternative, Design Criteria in place for grizzly bear will also benefit gray wolf (e.g., spring closures). Road closures in effect for grizzly bear in the Glacier Loon Area will provide security for gray wolf, as well. Alternative D would result in the least amount of short-term displacement for fisher compared to Alternatives B and C due to the least amount of temporary road construction. As discussed above, temporary roads will be rehabilitated, which will keep them from becoming new motorized travel routes. Regarding old growth associated wildlife species, there would be no additional high contrast edge created as a result of temporary road construction in any of the action alternatives due to the temporary roads being located inside the units at the point where they intersect the edge of an existing old growth stand. The potential for migratory bird habitat removal or displacement from temporary road construction would be the least with Alternative D when compared to Alternatives B and C due to the least amount of miles proposed. Under the Selected Alternative, temporary roads will not be open to public use and will be rehabilitated following use which will reduce the risk of old growth, snag dependent and migratory bird species habitat being removed as firewood. High Contrast Edge: New “edge” is created when stands adjacent to old growth habitat are converted from a late or mid-seral structural stage to an early-seral (seedling/sapling) structural stage. Alternative D would have less potential to disturb or displace old growth associated wildlife species than either Alternative B or C, because there are less proposed units adjacent to existing old growth habitat. In Alternative D, high-contrast edge would be created for a total distance of approximately 6,600 feet (1.3 miles). This amount is less than the amount of high contrast edge created with implementation of Alternatives B or C. Under the Selected Alternative, untreated, existing old growth stands in the area will continue to provide potential habitat for old growth associated wildlife species. Acres Treated in Lynx Habitat within the WUI: In a comparison of the action alternatives, effects to Canada lynx would be least with Alternative D with 755 acres compared to 1,587 acres in Alternative B and 1,473 acres in Alternative C. Under the Selected Alternative, 1,044 acres will occur in lynx habitat within the WUI as a result of the added treatment acreage that I decided to include for reasons described in this decision notice. Acres Treated in Lynx Habitat outside the WUI: In a comparison of the action alternatives, effects to Canada lynx would be least with Alternative D with 238 acres compared to 358 acres in Alternative B and 279 acres in Alternative C. Under the Selected Alternative, 238 acres will occur in lynx habitat outside the WUI as a result of the added treatment acreage that I decided to include for reasons described in this decision notice. With the implementation of the Selected Alternative, snowshoe hare habitat would be decreased by approximately 380 acres due to vegetative treatments. The reduction in

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI lynx forage will occur within the Wildland Urban Interface (WUI) boundary. This reduction in lynx forage within the WUI is allowed as an exception in the Northern Rockies Lynx Management Direction. The reduction in lynx forage resulting from implementation of proposed activities will not be permanent; natural regeneration and planted seedlings will eventually grow back and provide snowshoe hare habitat. This decrease in lynx forage would represent approximately 1 percent of existing lynx forage in critical habitat within the Glacier Loon Project Area. There would be no significant large-scale (across the 6 LAU’s) negative cumulative effects on Canada lynx or Canada lynx critical habitat as a result of implementing the Glacier Loon Project because: . Activities proposed are consistent with the standards and guidelines described in the Northern Rockies Lynx Management Direction (Table 3-80). . There are over 12,000 acres of designated wilderness (Mission Mountains Wilderness) within the Glacier Loon Project Area; extensive roadless and wilderness habitat reduces the risks of mortality attributed to humans from vehicle collisions, trapping and predator control needs, and reduces the potential negative effects of fragmenting small populations. . A mosaic of forest stand conditions and successional stages would continue to exist post- project, capable of supporting a viable population of lynx in the Swan/Seeley Valley. Road Decommissioning: Alternatives C and D propose the highest amount of National Forest System Road decommissioning compared to Alternative B with 8.4 miles. Road decommissioning will treat the road to be impassible to motorized vehicles so that the route no longer functions as a road and will remove the road from the system. When the decommissioned roads meet the “reclaimed” definition in Amendment 19, they will no longer be counted in road density calculations. Under the Selected Alternative, these 8.4 miles will increase long term habitat security for the gray wolf, western boreal toad, wolverine and wolverine prey species, fisher and fisher prey species, black-backed woodpecker, white-tailed deer, mule deer, and elk. Under the Selected Alternative, the 8.4 miles of decommissioning work would include 2.4 miles of passive work (no ground disturbance), 2.1 miles of culvert removal and water bar construction, and 3.9 miles of re-contouring. Road decommissioning is beneficial for bears because it improves long-term habitat security; Switalski and Nelson (2011) demonstrated extensive use of decommissioned roads by wildlife. As a result of proposed decommissioning under the Selected Alternative, ORD would decrease 0.1 percent in the Glacier Loon Subunit; TRD would decrease approximately 3 percent in the Glacier Loon Subunit and 0.1 percent in the Buck Holland Subunit. This road decommissioning will also help to improve long-term habitat security for Canada lynx. There are three roads proposed for decommissioning that are located partially in existing old growth stands: A portion of NFS Road #9579 (0.8 miles), NFS Road #10568 (0.3 miles), and NFS Road #10247 (0.3 miles). National Forest System Roads #9579 and #10568 would have passive decommissioning; there would be no ground

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

disturbance within the old growth stands. For NFS Road #10247, the decommissioning work would involve the removal of culverts and the installation of waterbars every 100 to 300 feet, as needed. Under the Selected Alternative, although there would be short- term displacement of old growth associated species during the decommissioning work; the proposed road decommissioning would increase long-term habitat security for old growth associated wildlife species under the Selected Alternative.

OTHER CONCERNS: NOXIOUS WEEDS

Commenters expressed concern about the increase in noxious weed infestations as a result of project implementation. Commenters asked that we take all precautions to reduce potential risks for further spread of noxious weeds. Multiple Design Criteria will reduce or eliminate the risk of weed infestations, including spraying haul routes, washing of machinery, and revegetation of temporary roads. I believe my decision provides sound measures to mitigate for this resource concern. Winter logging is also included in this decision in Units 10, 17, 20, 22, and 34. In addition, Units 2 and 5 will require winter cut-to-length and forwarder logging. The equipment used in forwarder logging, especially on relatively gentle ground should result in less soil disturbance than conventional skidding and will allow purchaser flexibility in scheduling operations while achieving some of the desirable features of winter logging. This will reduce the potential for weed spread.

OTHER CONCERNS: MONITORING

Commenters expressed concern that the Project Monitoring Plan lacks detail about the methods and how unanticipated results will be handled. The commenter stated that general monitoring may be most cost effective, but detailed short and long term monitoring is important in documenting achieved results with this project and gaining support for future proposals. Monitoring on the Swan Lake Ranger District and the Flathead National Forest is documented in the Forest’s 2008 to 2010 Monitoring Report found at: http://www.fs.usda.gov/detailfull/flathead/landmanagement/planning/?cid=stelprd b5365079 &width=full This report addresses 55 items covering Wildlife, Fisheries, Range and Weeds, timber, water, soils, protection, water howellia, vegetation, and Recreation, Heritage, and Wilderness. This report evaluates the field data and information collected and/or available up to the end of September 30, 2010. In some cases monitoring has been conducted by the Forest Service and in other cases monitoring has been conducted by research scientists or personnel from other agencies and private organizations. Information from our monitoring reports and other assessments has been useful in assuring our on-going implementation of the Forest Plan is consistent with applicable law, regulations, and agency policy. The Flathead National Forest developed an Analysis of the Management Situation (January 2004) which serves as a valuable

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

source of monitoring and evaluation information to assist us in identifying what needs to change during the Forest Plan Revision Process. For this project, monitoring and evaluation would be conducted as described in Appendix 3 of this Decision Notice. Those monitoring components not specifically discussed in this appendix tier to the monitoring described in the Forest Plan.

OTHER CONCERNS: CUMULATIVE EFFECTS

During the objection process, several of the objectors indicated concerns with cumulative effects from other past, ongoing, or reasonably foreseeable projects in the vicinity of the Glacier Loon Project. These projects included Cold Jim, Chilly James, Beaver Creek, and Colt Summit. The project areas for Cold Jim, Chilly James, and Colt Summit are not adjacent to the project area for Glacier Loon; additionally none of the analysis areas used by the various resource specialists for these projects overlap any analysis area used in Glacier Loon and therefore there were no cumulative effects. The project area for Beaver Creek is adjacent to the project area for Glacier Loon, but only a few resource analysis areas overlap. Cumulative effects for these resources (e.g. lynx, grizzly bears, and fisheries) were addressed in the Glacier Loon SEAs. I believe that cumulative effects have been adequately considered for these projects mentioned by the objectors as well as any other past, ongoing, foreseeable activities and included them in the scope of the analysis if appropriate.

SUMMARY

The Selected Alternative (Alternative D with modifications) best meets Forest Plan direction while meeting the Purpose and Need for action. At the same time, it responds to public comments and desires and implements direction from the National Fire Plan. It seeks to balance the site-specific stand conditions and wildland urban interface conditions that vary from one treatment unit to the next with the overall scenic values, water quality, wildlife, and other values that add to the complexity and value of the project area. Current fuels and forest health conditions in the Glacier Loon Project Area can move towards desired conditions by applying appropriate management actions. The most cost efficient method of meeting the purpose and need objectives involves commercial timber harvest. A large amount of mechanical treatments will occur within the WUI helping to reduce the risk of fire adjacent to private property. Timber Sales were sold in 2013. Implementation is currently on hold and it is anticipated that timber harvest will be completed within 2 to 3 years after implementation resumes. Implementation of road work associated with timber sales should begin once the project is awarded. Reforestation activities will be completed no more than five years after logging is completed.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

GLACIER LOON FUELS REDUCTION AND FOREST HEALTH PROJECT: FINDING OF NO SIGNIFICANT IMPACT In accordance with CFR 1508.13 and direction provided in the Forest Service Handbook (FSH 1909.15, Chapter 40, Section 43.1), I have determined that the management actions included in the Selected Alternative of the Glacier Loon Project do not constitute a major Federal action, and that the implementation of the Decision will not significantly affect the quality of the human environment. Accordingly, I have determined that an Environmental Impact Statement (EIS) need not be prepared for this project. I have followed the implementing regulation for NEPA (40 CFR 1508.27) and other criteria for determining the significance of effects. Before making my determination, I carefully reviewed and considered the following information: . The direct, indirect, and cumulative effects of these actions as documented in the EA for the Glacier Loon Project; . The analysis documentation in the project file for the Glacier Loon Project; . Comments received during all scoping and after the EA was published for this project; . Past experiences with fuel reduction and forest health projects on the Flathead National Forest. The ID Team and I have “screened” the management actions included in the Glacier Loon Project for “significant impact.” The results of this screen are summarized on the following pages. Significant, as used in NEPA, requires consideration of both context and intensity.

CONTEXT

Context means that the significance of an action must be analyzed in several contexts such as society as a whole (human, national), the affected region, the affected interests, and the locality. Significance varies with the setting of the proposed action. For instance, in the case of a site- specific action, significance would usually depend upon the effects in the locale rather than in the world as a whole. Both short-term and long- term effects are relevant (40 CFR 1508.27). The effects of the proposed actions are limited in context. The proposed treatments encompass a limited area (1392 acres of mechanical treatments and 5 acres of hand treatments) and the activities are limited in duration. The project implementation is anticipated to continue in 2018. Implementation of roadwork associated with timber sales should begin once the project activities are resumed. Reforestation activities will be completed no more than 5 years after logging is completed. Management activities not involving timber harvest (sale layout) could begin again in 2018 Effects are local in

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

nature and are not likely to significantly affect regional or national resources. Some of the treatment units are located adjacent to private property. As such, the forestland surrounding these private lands will be affected by this decision. The people most affected by the project will be the local residents on the adjacent lands. This action is also a continuation of fuel reduction and forest health and projects that have occurred for many years on the Flathead National Forest and elsewhere across the Northern Region and the nation as a whole. Short-term adverse effects will be addressed through implementation of the Standards and Guidelines in the Flathead’s Forest Plan, BMPs (Appendix 4), and the Design Criteria (Appendix 2) developed specifically for this project. The project’s Design Criteria minimize and avoid adverse impacts to the extent that such impacts are almost undetectable and immeasurable, even at the local level. These Design Criteria include, but are not limited to the following: . Protection of the soil resource; . Protection of leave trees, . Control of noxious weed spread; . Protection of sensitive or threatened plant species; . Protection of riparian habitat; . Retention of snags and woody debris for wildlife; . Protection of threatened, endangered, or sensitive wildlife species; . Seasonal and operational restrictions to avoid impacts to wildlife populations and habitat; . Reclamation of temporary roads; and . Protection of heritage resources. Within the context of the landscape as a whole, or at the stand level, the ecological consequences are not found to be significant in the short or long term.

INTENSITY

Intensity refers to the severity of impact. Responsible Officials must bear in mind that more than one agency may make decisions about partial aspects of a major action. The following 10 aspects are considered in the evaluation of intensity (40 CFR 1508.27): 1. Impacts may be both beneficial and adverse. A significant effect may exist even if the balance of effects will be beneficial. Both beneficial and adverse effects have been taken into consideration when making a determination of significance. While there will be beneficial effects, this action does not rely on those effects to balance adverse environmental impacts. Detailed Specialist Reports, included in the supplemental EA and Project File, contain comprehensive effects analyses and the findings from these resource specific reports form the basis for

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

my decision. The project includes a range of activities including hazardous fuels reduction, timber harvest, thinning, prescribed burning, road construction, and resource enhancement projects. These activities have varying effects on the physical, biological, or social components of the affected environment. Some of these effects are more favorable to a particular resource component than to another resource component. Below is a synopsis of the more notable effects of the activities; however, none of the effects, whether favorable or unfavorable, beneficial or adverse, are significant. Regeneration of mature forests, particularly those dominated by lodgepole pine, increases both species and age class diversity in the stand and across the landscape. Diversity at these scales improves the resilience of the forest, its ability to adapt and respond in a variety of ways to inevitable future disturbances, such as wildland fire, without experiencing wide-scale detrimental effects. Stands formerly dominated by lodgepole pine will have a much higher percentage of the long-lived larch and Douglas- fir, eventually resulting in stands that exhibit old growth habitat characteristics. Related changes in stand conditions (increased vigor, reduced stress, increased tolerance to mountain pine beetle) will increase long-term timber productivity as well. Thinning treatments will allow more room for individual trees to grow, increasing their vigor, lowering their stress, and therefore improving tree and forest health and resistance to deleterious effects of pathogens through time. By creating the desired stand conditions, we are more assured that forests will be resilient, adaptable, and sustainable over time, providing for the full array of ecosystem functions and processes. The proposed prescribed burns on mixed conifer and lodgepole pine stands (Units 73, 74, 75, 80, and 82) will improve stand species and structural diversity; reduce the amount of down and dead fine fuels that currently exist due to advanced succession and high mortality in the stand; and maintain a host of other ecological functions such as soil microbial activity. Riparian values for all watersheds; including water temperature, filtration of sediment and contaminants, large woody debris recruitment, and stream bank condition will be maintained because of the application of Riparian Habitat Conservation Area Guidelines. In 1995, the Forest Service adopted the Inland Native Fish Strategy with the goal of recovering native fish populations. Activities must not retard the goal. Any activity within a RHCA in non-priority watersheds (such as most of the project area) needs to be analyzed by a site-specific analysis. The Selected Alternative has no activity within RHCAs except for 4.3 acres scattered across five treatment areas. These five units have small “slivers” of designated RHCAs located uphill of existing roads. Harvest activity in these “slivers” does not retard the goal of Inland Native Fish Strategy. A site-specific analysis is available in Project File Exhibit N-8. The Lindbergh Lake Watershed is a priority watershed but no activities are proposed in those RHCAs. The temporary road construction and culvert upgrade portions of this project have the highest risk of impacting fish habitat and water quality in the short-term due to the risk of

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

sediment being deposited into streams. However, I am confident that any short-term impacts will be minimal through the application of timing restrictions and applying proven Best Management Practices. There will be long-term benefits because the likelihood of culvert failures will be reduced and the potential need for repeated road construction and reconstruction over the next several decades is reduced. It is my determination, based on review of these analyses and consultation with Specialists that the Selected Alternative, including fuels management, vegetation management, and road management activities will not have a significant impact on the environment. All effects will be small or short-lived. None are deemed irreversible or irretrievable and do not set in motion further effects. The EA, Specialist Reports, and Biological Assessments and Evaluations evaluated all potential direct, indirect, and cumulative effects. 2. The degree to which the Selected Action affects public health or safety. The fuel reduction and forest health treatments are designed to increase the efficiency of fire suppression efforts and reduce risks to firefighters, local residents, the public, structures, and natural resources. The implementation of these treatments will result in improved community safety because fuel reduction will increase the chance of suppressing a fire before it reaches private property. All burning of thinning slash and natural fuels will comply with State Air Quality Standards and be coordinated through the Montana Airshed Group. Dust from timber hauling activities will be controlled using the dust abatement requirements within the Stewardship or Timber Sale contract provisions. Herbicide treatments of weeds will comply with label directions and in accordance with and under decision authority of the Flathead National Forest Noxious and Invasive Weed Control EA and Decision Notice (USDA May 2001), to which the Glacier Loon Project EA and DN is consistent. Project Design Criteria were developed to address public safety concerns associated with proposed harvest and association actions (See Appendix 2). I believe that the Selected Action is not likely to have any significant impact to public health or safety. 3. Unique characteristics of the geographic area such as proximity to historic or cultural resources, parklands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. In general the design of the Glacier Loon Project avoids such areas. Specific detail in regard to that design follows. The areas receiving treatment in the Glacier Loon Project Area will avoid any unique or special botanical areas (Design Criteria, Appendix 2). Heritage Resource Surveys have been completed and no new historic or prehistoric sites within the proposed treatment units were found (Project File Exhibit P-3). The project area includes wetlands and riparian areas, but impacts to wetlands and riparian areas will be avoided during project layout and under contract provisions for vegetation

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

treatments (See Design Criteria - Appendix 2, Best Management Practices – Appendix 4). Based on this information, I conclude that the Selected Alternative will have no effects on unique resources. There are no prime farmlands, parklands, ecologically critical areas or designated wild and scenic rivers within the project area and therefore the project will not have an impact on these resources. 4. The degree to which the effects on the quality of the human environment are likely to be highly controversial. Based on the limited context (duration and intensity) of the project within the scope of the human environment, my review of comments received during the scoping of this project, the analysis documented in the supplemental EA and project file, and the rationale described in this DN, I do not find any highly controversial effects as a result of implementation of the Selected Alternative. The activities prescribed in the Selected Alternative have been designed to have minimal effects on the quality of the human environment and are therefore not highly controversial. I conclude that the effects of the Selected Alternative are not considered highly controversial by professionals, specialists, and scientists from associated fields of forestry, wildlife biology, soils, fisheries, and hydrology. 5. The degree to which the possible effects on the human environment are highly uncertain or involve unique or unknown risks. Based on my review of comments received during the scoping of this project, the comments received after the publication of the supplemental EA, and the analysis documented in the supplemental EA and project file, I find the possible effects on the human environment that are uncertain or involve unique or unknown risks are minimal or non-existent. The Forest Service has considerable experience in projects similar to Glacier Loon and the consequences of such actions are well established and predictable. The supplemental EA and information contained in the project file discloses potential environmental impacts (which is supportable with use of accepted techniques, reliable data, and professional opinion) and I believe that the impacts of implementing this decision are within the limits that avoid any thresholds of concern. It is my conclusion that there are no uncertain or unique characteristics in the project area that have not been previously encountered or that will constitute an unknown risk to the human environment. 6. The degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration. The Glacier Loon Fuels Reduction and Forest Health Project represents a site-specific project that does not set precedence for future actions or present a decision in principle

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

about future considerations. Any proposed future project must be evaluated on its own merits and effects. The Selected Action is compatible with the Forest Plan and the capabilities of the land. I believe that this action does not represent a decision in principle about a future consideration. 7. Whether the action is related to other actions with individually insignificant but cumulatively significant impacts. Significance exists if it is reasonable to anticipate a cumulatively significant impact on the environment. Significance cannot be avoided by terming an action temporary or by breaking it down into small component parts. Connected, cumulative, and similar actions have been considered and included in the scope of the analysis. The analysis accounts for past, present, and reasonably foreseeable actions of the Forest Service, The Nature Conservancy, Montana Department of Natural Resources and Conservation, private timber companies, and private landowners within and surrounding the project area. Based on my review of the analysis and disclosure of effects in the supplemental EA, Specialist Reports, Biological Assessments and Evaluations, and other analyses in the project file, I conclude that the Glacier Loon Project does not represent potential cumulative adverse impacts (Please refer to Tables 3- 1 and 3-2 of the EA, Chapter 3 Resource Sections and Resource Cumulative Effects Worksheets in the Project File). 8. The degree to which the action may adversely affect districts, sites, highways, structures, or objects listed or eligible for listing in the National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources. My decision to approve this project will not have adverse effects on, nor cause the loss or destruction of, significant scientific, cultural or historic resources. Heritage surveys have been completed in the Glacier Loon Project Area and no previously undiscovered sites within the project area boundaries were found (Project File, Section P, and the Glacier Loon supplemental EA (pages 3-412). The potential for influencing undiscovered sites is mitigated by compliance with Forest Plan standards and guidelines, and through the Design Criteria included as part of the Selected Action (Appendix 2). In the event such resources are discovered during project implementation, they will be evaluated and protected. I believe that this action will not have a significant effect on scientific, cultural, or historical resources. 9. The degree to which the action may adversely affect an endangered or threatened species or its habitat that has been determined to be critical under the Endangered Species Act of 1973. Biological Assessments (BAs) for threatened and endangered species have been completed for this Selected Alternative (Project File Exhibits AA-28, AA-38, AA-40, AA- 41, and AA-88). These BAs and supporting documentation led to the following determinations for listed species. The U.S. Fish and Wildlife Service (USFWS) concurred with these determinations (Project File Exhibits AA-29 and AA-36).

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Table 7. Threatened and Endangered Species Determinations

Species Determination Grizzly Bear May affect – likely to adversely affect Canada Lynx May affect – likely to adversely affect Canada Lynx Critical Habitat May affect – likely to adversely affect Bull Trout May affect – not likely to adversely affect Bull Trout Critical Habitat May affect – not likely to adversely affect Spalding’s Catchfly No Effect Water Howellia May affect – not likely to adversely affect Meltwater lednian stonefly (proposed No effect species) Wolverine (proposed species) Not jeopardize the species

GRIZZLY BEAR: IGBC GUIDELINES AND MANAGEMENT SITUATION 1 LANDS

The Interagency Grizzly Bear Committee (IGBC) developed the Interagency Grizzly Bear Guidelines (IGBG 1986) in order to promote conservation of the grizzly bear. The Flathead National Forest has incorporated the guidelines into its Forest Plan (Appendix OO). The IGBG establish grizzly bear management situations. The Glacier Loon Project is located in MS-1. Management direction for these lands is: “Grizzly habitat maintenance and improvement, and grizzly-human conflict minimizations will receive the highest management priority. Management decisions will favor the needs of the grizzly bear when grizzly habitat and other land use values compete.” Management decisions and Design Criteria (Appendix 2) for this project favor, and make this project compatible with, the needs of grizzly bear recovery and conservation by: . Strict adherence to a grizzly bear subunit rotation by major landowners and cooperators (USDA Forest Service, DNRC, and The Nature Conservancy) that leaves every subunit in the Swan Valley inactive for a minimum of 3 years; . Restriction of commercial activities in spring habitats during the spring period; . Retention of visual screening along open roads; . Open and total road density restrictions; . Proposed road decommissioning of 8.4 miles reducing open road density by 0.1% in the Glacier Loon Subunit; reducing total road density approximately 3% in the Glacier Loon Subunit and 0.1% in the Buck Holland Subunit; . The maintenance of a minimum of 40 percent cover across all ownerships in the affected subunits;

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

. Contributing to security in linkage zones by reclaiming or restricting roads. Reclaimed roads would enhance use of Preferred Habitat or other high quality habitat areas, and complement adjacent areas of secure habitat. . Under all alternatives, the contract for the Glacier Loon Project would include a clause for the temporary suspension or cessation of activities, if needed, to resolve any grizzly bear/human conflict; and . A Special Order (2010) is in effect that requires all users of NFS lands in the Swan Valley, and throughout the Flathead National Forest, to store food, garbage and other bear attractants in a bear-resistant manner. This special order is included in all contracts associated with the project. Further strategies to manage the lands encompassing the proposed Glacier Loon Project in a manner that favors the grizzly bear include active participation in Bear Smart Community Programs, a District Bear Ranger Program, and land acquisition endeavors. In the Glacier Loon Fuels Reduction and Forest Health Project Biological Assessment, a determination of “may affect, likely to adversely affect” was made for the grizzly bear (Project File Exhibit AA-41). This determination was based on the following rationale: . Activities associated with the proposed project could cause short-term displacement, and there would be short-term reductions in hiding cover and forage. . The active subunit management guidelines of the SVGBCA would reduce displacement and disturbance to bears. The Glacier Loon Project would comply with the inactive subunit guidelines in the Glacier Loon and Buck Holland Subunits. . Major forest management activities under Inactive subunit guidelines would be limited to 30 days in aggregate for salvage activities during the summer (during the bear’s active period) and the remainder of commercial activities would occur during the bear’s denning period. . Spring timing restrictions would prevent displacement of grizzly bears when forage is most limited and cover and visual screening and cover guidelines would promote security for the bear. . Open road densities would increase temporarily during proposed activities, but there would be no net increase in open road or total road density. . There would be not net loss of habitat security or increases in motorized access density as a result of project implementation; proposed road decommissioning would improve open and total road densities in the affected grizzly bear subunits. . Proposed temporary roads would be reclaimed following use. . There would be no effect to potential or known grizzly bear denning habitat and no activities in grizzly bear security core . There is a food storage and sanitation order in effect. Contractors and others

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

implementing the project would be required to comply with this order. . The Glacier Loon Projects is in accordance with the Interagency Grizzly Bear Guidelines, the Flathead Forest Plan, and the Swan Valley Grizzly Bear Conservation Agreement. The project activities, including harvest and road use, would not likely result in adverse effects to the grizzly bear due to the impacts discussed above. However, the baseline condition in the Glacier Loon and Buck Holland subunits would continue to be adverse to grizzly bears as the subunits do not meet 19/19/68 road density objectives. Due to this condition, the determination for grizzly bear is May affect – likely to adversely affect. These effects were specifically considered and fall within the range of analyzed activities in the 2014 Amendment 19 Biological Opinion for motorized access and road density objectives for grizzly bear habitat. In terms of the implementation of the proposed Glacier Loon project itself the determination is May affect – not likely to adversely affect for grizzly bear (Amended BA; Project File Exhibit AA-41). The USFWS concurred with the Forest Service determination for grizzly bear, found the “other than access, no activities under the proposed action are likely to adversely affect grizzly bears” and that “adverse effects related to access conditions were adequately analyzed in the 2014 and 1995 programmatic biological opinions and the proposed actions related to access conform to the incidental take statements associated with these opinions.” Additionally, USFWS indicated the Glacier Loon Project is not likely to jeopardize the continued existence of grizzly bears (Project File Exhibit AA-36).

CANADA LYNX

On March 23, 2007, the USFWS issued a biological opinion on the effects of the Northern Rocky Mountains Lynx Amendment on the Distinct Population Segment of Canada lynx (lynx) in the contiguous United States (Project File Exhibit H-133). The biological opinion was identified as the first-tier of a tiered consultation framework, with the review of subsequent projects that may affect lynx as being the second-tier of consultation. Second-tier biological opinions would be issued as appropriate, where proposed actions would result in adverse effects to lynx that were not fully analyzed in the first-tier biological opinion. In the lynx amendment (NLRMD 2007), a limited range of fuel or vegetation management projects conducted within the wildland urban interface (WUI) fell under exemptions and exceptions to amendment standards VEG S1, S2, S5, and S6. In this first-tier biological opinion, the USFWS analyzed the effects of such projects on lynx and also provided an incidental take statement for these activities because the Forest Service provided explicit estimates on the number of acres that will be impacted under the exemptions and exceptions. In the Glacier Loon Fuels Reduction and Forest Health Project Biological Assessment, a determination of “may affect, likely to adversely affect” was made for the Canada lynx. The biological assessment was reviewed by the USFWS and they concurred with the Forest Service determination. The USFWS found that the effects of the project on Canada lynx were adequately analyzed in the first-tier biological opinion and that the

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

project conforms to the first-tier incidental take statement, because: 1) the proposed site-specific project falls within the scope of the first-tier biological opinion, 2) the effects of the proposed action are consistent with those anticipated and analyzed in the first-tier biological opinion, regarding fuels reduction treatments in the WUI that result in snowshoe hare habitat degradation; and 3) the proposed action adheres to the appropriate terms and conditions associated with the reasonable and prudent measures identified in the first-tier biological opinion. Therefore, no second-tier biological opinion is required for this project. (Project File Exhibits AA-41 and AA-36). The determination for Canada lynx is based on the following rationale: . The Selected Alternative will treat 380 acres of lynx winter foraging habitat using the VEGS5 and VEGS6 exceptions for fuels reduction in the Wildland Urban Interface (WUI) in the Northern Rockies Lynx Management Direction (NRLMD). . The NRLMD provides management direction that conserves and promotes recovery of Canada lynx (USDA 2007). The Selected Alternative complies with VEGS1, VEGS2, and is consistent with other direction in the NRLMD; including VEGG1, VEGG4, VEGG10, and VEGG11. . The Selected Alternative will increase the level of human activity in the Glacier Loon project area and has the potential to displace lynx from important habitat during implementation of proposed activities. Disturbance will be short-term. Potential disturbance to lynx will be mitigated by project Design Features to reduce disturbance and displacement of grizzly bears. . The majority of harvest treatment would be focused in stem exclusion stands that are not lynx foraging habitat. Treatment in some stands may promote lynx forage in the future. . The proposed project would decrease lynx denning habitat by 87 acres.

CANADA LYNX CRITICAL HABITAT

A Final Rule for Revised Designation of Critical Habitat for the Contiguous United States Distinct Population Segment of the Canada Lynx became effective on March 27, 2009. On September 12, 2014, the USFWS revised Critical Habitat in the contiguous United States. Northwest Montana is in Critical Habitat Unit 3: Northern Rocky Mountains. On the Flathead National Forest, there are over 2 million acres of designated Critical Habitat for lynx. The USFWS provided the Forest Service with a Biological Opinion (BO) on effects of the Glacier Loon Fuels Reduction and Forest Health Project to Canada lynx critical habitat. The USFWS determined that the project is not likely to result in destruction or adverse modification of designated Canada lynx critical habitat (Project File Exhibit G- 2). In the BO dated June 15, 2015, the USFWS stated: “After reviewing the current status of designated lynx critical habitat, the environmental baseline for the action area, the effects of the action, and the cumulative effects, it is the Service’s biological opinion that the effects of the

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Glacier Loon Project are not likely to result in the destruction or adverse modification of designated Canada lynx critical habitat… “The proposed action has components that will adversely affect lynx critical habitat via reductions in PCE1a (snowshoe hare habitat) in the Glacier LAU. However, the scale of the proposed action will not preclude continued adequate amounts of snowshoe hare habitat needed to sustain lynx in the LAUs, including the Glacier LAU, and thus the critical habitat in each of the LAUs would remain functional. When added to the status of the critical habitat unit, the effects of the project are such that the conservation role of the lynx critical habitat Unit 3 will continue to support its intended conservation role for lynx.” On October 18, 2017, the USFWS completed consultation of the effects of the NRLMD to Critical Habitat. The USFWS determined that the effects of the NRLMD are not likely to result in the destruction or adverse modification of designated Canada lynx critical habitat. The Glacier Loon project was considered as part of the baseline in this programmatic consultation. In the amended Glacier Loon Fuels Reduction and Forest Health Project Biological Assessment, a determination of “may affect, likely to adversely affect” was made for Canada lynx critical habitat (Project File Exhibit AA-41). The determination for Canada lynx critical habitat is based on the following rationale: . The Selected Alternative will not result in permanent loss of Canada lynx critical habitat and will not result in conversion of the boreal forest. The Selected Alternative will not impede lynx movement. The conservation value of the PCE will be maintained because the boreal forest landscape would continue to support a mosaic of differing successional forest stages and thus would support the critical habitat PCE. . The decrease in lynx forage (PCE1a) represents approximately 1% of existing lynx forage in lynx critical habitat in the Glacier Loon Fuels Reduction and Forest Health Project area, a minor amount. Treatment of 815 acres of forest in the stem exclusion structural phase is not likely to adversely affect critical habitat, as it currently lacks the dense understory required for snowshoe hare habitat and treatments provide an opportunity to move the stands toward providing future snowshoe habitat. . Activities would not impact deep fluffy snow conditions providing PCE1b. . The Selected Alternative will treat 87 acres of existing denning habitat (PCE 1c), within the action area and some acres would be affected by treatments in the multi‐story and stem exclusion stands. Any impacts to PCE 1c would be insignificant as denning habitat is well distributed and is not a limiting factor at the broad scale (U.S. Fish and Wildlife Service 2007), and some treatments have potential to create denning sites. The Forest avoided proposing treatments in old growth habitats or other older forest stands with large diameter down woody debris, the highest quality denning habitat for lynx (U.S. Forest Service 2012).

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

. Project related activities would not occur within matrix habitat located within the designated critical habitat boundary, thus PCE 1d would not be affected. In their BO on the Glacier Loon Fuels Reduction and Forest Health Project, the USFWS concluded that although the proposed action would adversely affect areas of critical habitat, the small scale and resulting low severity of effects is not expected to diminish the capacity of the LAU to produce adequate densities of snowshoe hares to support continual lynx presence. Thus the LAUs would continue to serve the intended conservation role for lynx. The physical and biological features would not be altered to an extent that would appreciably reduce the conservation value of critical habitat for lynx and the PCE would continue to function. The adverse effects on lynx critical habitat would occur on a very small portion of critical habitat Unit 3. The proposed action would treat 1195 acres of lynx habitat, which is 0.02 percent of critical habitat in Unit 3. In summary, the project will not have significant adverse effects on grizzly bears, Canada lynx, or Canada lynx critical habitat.

WOLVERINE

On February 4, 2013, the USFWS published a proposed rule to list the North American Wolverine as a Threatened Distinct Population Segment (DPS) in the Contiguous United States. In the proposed listing rule the USFWS assessed a variety of impacts to wolverine habitat including: (1) Climate change, (2) human use and disturbance, (3) dispersed recreational activities, (4) infrastructure development, (5) transportation corridors, and (6) land management. They stated that many of these impact categories overlap or act in concert with each other to affect wolverine habitat, but determined that the primary threat to the wolverine is climate change and its effects on populations as well as changes to the availability and distribution of wolverine habitat due to changing snow and temperature conditions. After further review of all available scientific and commercial information, the U.S. Fish and Wildlife Service subsequently withdrew that proposal, and published their determination on August 13, 2014 (USDI Fish and Wildlife Service, 2014), that adding the North American wolverine occurring in the contiguous United States as a distinct population segment to the Lists of Endangered and Threatened Wildlife and Plants was not warranted (USDI Fish and Wildlife Service, 2014). However, a district court decision on April 4, 2016 found that the U.S. Fish and Wildlife Service conclusion was arbitrary and capricious and the decision was remanded to the U.S. Fish and Wildlife Service for further consideration. On May 24, 2016, the U.S. Fish and Wildlife Service again listed wolverine as a proposed species on the Flathead National Forest. The proposed listing rule assessed the best available science with respect to habitat modeling and effects on wolverine habitat. Wolverines do not appear to specialize on specific vegetation or geological habitat aspects, but instead select areas that are cold and receive enough winter precipitation to reliably maintain deep persistent snow late into the warm season (Copeland et al. 2010, entire). The proposed listing stated, “ Land management activities (principally timber harvest, wildland firefighting, prescribed fire,

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI and silviculture) can modify wolverine habitat, but this generalist species appears to be little affected by changes to the vegetative characteristics of its habitat” (pg. 110). The USFWS used a composite model for deep and persistent snowpack habitat mapping across the U.S. based upon the work of two scientists (Inman et al. 2012, entire; Copeland et al. 2010, entire). The USFWS determined that McKelvey et al. (2011, entire) represents the best scientific information available regarding the impacts of climate change to wolverine habitat. The U. S. Forest Service Northern Region prepared a programmatic biological assessment that analyzed a variety of projects routinely conducted on NFS lands within the Northern Region that are not likely to jeopardize the continued existence of the North American wolverine (Project File Exhibit AA-28). The U.S. Fish and Wildlife Service concurred with the determination on May 23, 2014 (Project File Exhibit AA-29). As part of this programmatic framework, a project biological assessment for wolverine for the Glacier Loon Project is located in the project file (Project File Exhibit AA-88, Appendix B). Supporting documents concerning wolverine as a proposed species are included in the project file. Section 7(a) 2 of the ESA requires that federal agencies must ensure that their activities are not likely to jeopardize the continued existence of any proposed species or result in the destruction or adverse modification of designated critical habitat. The wolverine was analyzed as a sensitive species on the Flathead Forest in the Glacier Loon EA, published in August of 2012. Since that time, the project analyzed effects to wolverine as a proposed species in the July 2017 and April 2018 SEAs as part of the existing consultation framework. The analysis of project activities was found to be consistent with a “no jeopardy” conclusion for wolverine (Project File Exhibit AA-88).

BULL TROUT AND BULL TROUT CRITICAL HABITAT

There are no anticipated direct, indirect, or cumulative effects to bull trout with the Selected Alternative. The Selected Alternative will have “may effect – not likely to adversely affect” on bull trout or bull trout critical habitat (Project File Exhibit AA-40). This determination was based on the conclusion that the only impact of the project was a short-term sediment delivery to Swan River and Lindbergh Lake from applying BMPs to existing roads. The total amount of sediment would be too small to detect or measure. The project would not add to cumulative effects to bull trout and does not change any critical habitat Primary Constituent Elements. The USFWS concurred with these determinations and stated that “the small amount of sediment that may reach areas where bull trout may occur, including areas of designated bull trout critical habitat, impacts to water quality, or fish habitat would be insignificant. Bull trout use of these areas would not be impaired. Therefore, effects to bull trout and bull trout critical habitat as a result of the proposed action would be discountable and/or insignificant (Project File Section AA-36).”

WATER HOWELLIA AND SPALDING’S CATCHFLY

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

The Glacier Loon Project will have “may effect – not likely to adversely affect” on water howellia and “no effect” Spalding’s catchfly (Project File Exhibit AA-38). The amended biological assessment was reviewed by the USFWS and they concurred with the Forest Service determination (Project File Exhibit AA-36).

MELTWATER LEDNIAN STONEFLY

The Glacier Loon Project will have “no effect” to the Meltwater Lednian Stonefly (Project File Exhibit AA-5) because this species is not found in the project area, and has only been found at the outlet of a few mountaintop glaciers where there are no project activities proposed. 10. Whether the action threatens a violation of federal, state, or local law or requirements imposed for the protection of the environment. As described in the EA (Regulatory Framework and Consistency Sections for each resource area in Chapter 3), the Selected Action is consistent with all applicable Federal, state, or local laws or requirements imposed for the protection of the environment, including: . The National Forest Management Act (NFMA) The National Environmental Policy Act . The Endangered Species Act . The Clean Water Act and Montana State Water Quality Standards The Clean Air Act . The Migratory Bird Treaty Act . The National Historic Preservation Act . The American Graves Protection and Repatriation Act . American Indian Religious Freedom Act . The Environmental Justice Act . The Healthy Forests Restoration Act The Selected Action is consistent with Forest Plan direction. I have concluded that the Selected Action does not violate any federal, state or local laws or requirements imposed for the protection of the environment

FINDINGS REQUIRED BY LAW, REGULATION, OR AGENCY POLICY

Numerous laws, regulations, and agency directives require that my decision be consistent with their provisions. I have determined that my decision is consistent with the laws, regulations, and agency policies related to this project. The analysis leading to my decision was developed within the framework of the following laws, regulations, and policies.

THE NATIONAL FOREST MANAGEMENT ACT (NFMA)

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

The NFMA and accompanying regulations require that several specific findings be documented at the project level. These are: 1. Consistency with Forest Plan Standards, Goals, and Objectives The Flathead National Forest Land and Management Plan of 1986 (Forest Plan) establishes management direction for the Flathead National Forest. This management direction is achieved through the establishment of Forest-wide goals and objectives, standards, and guidelines. Additional goals and accompanying standards and guidelines have been established for specific Management Areas across the forest. Project implementation consistent with this direction is the process in which desired conditions described by the Forest Plan are achieved. The NFMA requires that all project-level resource plans, such as this Decision Notice, are to be consistent with the Forest Plan (16 USC 1604 (i)). The supplemental EA displays the Forest Plan and Management Area goals and objectives and the standards and guidelines applicable to the Glacier Loon Project (supplemental EA, Chapters 1, 2, and 3). The alternative development process is detailed in Chapter 2 of the supplemental EA and in the project file, while the management goals and the environmental consequences of the alternatives in relation to the Forest Plan standards and guidelines are displayed in Chapter 3 of the supplemental EA. After reviewing the supplemental EA, I find that my decision is consistent with Forest-wide goals, objectives, standards, and guidelines, and specific MA goals and standards. On April 9, 2012 the Department of Agriculture issued a final planning rule for National Forest System land management planning (2012 Rule) 77 FR 68 [21162-21276]). The Flathead National Forest is undergoing the forest plan revision process but a decision on a revised forest plan has not yet been made and does not apply to this project-level decision. 2. Project-Specific Amendment to the Forest Plan The Forest Plan states on page II-20, “A project-specific amendment of a Forest Plan standard may be undertaken if it is demonstrated during project analysis that it will fulfill the objective of the standard and related goals.” With this decision, I am authorizing one project-specific amendment to the Forest Plan related to the Management Area change from Alternative D. With this decision, I am authorizing a project-specific amendment to the Flathead Forest Plan related to a change to Management Areas (MA) for a portion of the Glacier Loon Project Area along the western portion of Lindbergh Lake, including the highly visible portions of the project area from the lakeshore to the slope break totaling approximately 221 acres. The proposal would change 213 acres from MA 15, which consists of timberlands where timber management with roads is economical and feasible as currently assigned, to MA 5, which consists of roaded timberlands in areas of high scenic value. The other 8 acres would be changed from MA 15C, timberlands with emphasis on white-tailed deer summer range, to MA 5. The effects of these management area changes were discussed in Chapter 3 of the environmental

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

assessment under each resource section. Table 1 above displays the acreages associated with this amendment. Also refer to Map 3 for a display of Project-Specific Forest Plan Amended Management Areas. 3. Finding of Non-Significant Amendment The FSH 1909.12, Land and Resource Management Planning Handbook, 5.32, process to amend the Forest Plan, identify four factors to consider in determining whether a change to the Forest Plan is significant or non-significant, and based on NFMA planning requirements. The following paragraphs document how these factors are considered for the proposed amendment. 1. Timing: This project-specific amendment would be short-term in nature. The proposed changes for the management area changes will remain in effect until the Forest Plan is revised. The Flathead Forest Plan revision began in 2013 with a decision anticipated in 2018. 2. Location and size: This project-specific amendment applies to a portion of the Glacier Loon Project Area along the western portion of Lindbergh Lake, including the highly visible portions of the project area from the lakeshore to the slope break totaling approximately 221 acres. 3. Goals, objective, and outputs: The overall goal of this project-specific amendment is to respond to the public’s concerns over harvest activities that would be evident if harvest activities take place consistent with the current Management Area 15 designation within the Lindbergh Lake Viewshed. This management area designation change will result in less silvicultural activities occurring as scheduling of timber harvest within Management Area 5 will be primarily limited to those treatments which maintain or enhance the scenic quality of the area. 4. Management prescription: This modification is only for the specified area discussed above and referenced on Map 3; it does not apply to other areas on the Flathead National Forest. Based on a review of the four factors, I considered the project-specific amendments to be non-significant. 4. Suitability for Timber Production The NFMA directs that no timber harvesting shall occur on lands classified as not suited for timber production pursuant to 36 CFR 219.14(a) except for salvage sales, sales necessary to protect multiple use values, or activities that meet other resource objectives on such lands if the Forest Plan establishes that such actions are appropriate [36 CFR 219.27(c)(1)]. Stands proposed for harvest treatment in the Glacier Loon Project Area were examined for suitability in accordance with 36 CFR 219.14 by a Certified Silviculturist. Inclusions of non- suitable land were identified within stands proposed for harvest (such as wet areas), and no treatment will occur in these areas. Selected vegetation treatments are located in management areas (MA) suitable for long-term timber production (MA15,

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

15C, 17, and 5) as described in the Forest Plan. Based on the analysis provided in the EA and project record, the vegetation treatments identified in these areas meet these objectives/standards. The silvicultural diagnosis process and the Forest Plan were used to determine that all areas associated with this project are suitable for timber harvest using the following criteria: . Meet the definition of “forestland” as described in 36 CFR 210.3. . Technological feasibility exists to ensure soil productivity and watershed protection. All sites considered for treatment will use established harvesting and site preparation methods. Resource protection standards in the Forest Plan, Project Design Criteria (Appendix 2) and applicable BMPs (Appendix 4) will be sufficient to protect soil and water resource values. . None of the stands considered for harvest have been withdrawn from timber production as specified in 36 CFR 219.14(4). . There is reasonable assurance that all lands can be restocked within 5 years of final harvest. 5. Timber Harvest on National Forest Lands The NFMA directs that site-specific projects and activities to harvest timber on National Forest System lands can only occur where: a) Soil, slope, or other watershed conditions will not be irreversibly damaged. My decision avoids irreversibly damaging soil, slopes, or other watershed conditions. The Selected Alternative will avoid impairment of site productivity. This determination is supported by the effects disclosures in the supplemental EA (Chapter 3 Soils, Hydrology and Fisheries Sections) and Project File (Project File Exhibit Sections L, M, and N), through Design Criteria (Appendix 2 of this DN), and through the application of BMPs (Appendix 4 of this DN). Several units will be monitored to ensure that Region One Soil Quality Standards are met. If after implementing the decision, there is 15 percent or more detrimental disturbance, then restoration activities described in the Design Criteria for the Selected Alternative, Appendix 2, will occur to restore the units to below the 15% threshold. b) There is assurance that the lands can be adequately restocked within five years after final regeneration harvest. Lodgepole pine is the dominant species in most units and is a prolific producer of cones, both serotinous (closed) and non-serotinous. Natural regeneration of lodgepole pine is expected after harvest. Previous regeneration harvests in the analysis area have been successfully stocked within 5 years. Regional reforestation indices also support that reforestation techniques have been successful and the 1980 to 2008 average 3-year survival of trees planted on the Flathead National Forest is 73 percent. In addition, an estimated 305 acres will be planted in Clearcut with Reserves, Seed Tree with Reserves, and Shelterwood with Reserves treatment units. c) Protection is provided for streams, streambanks, shorelines, lakes, wetlands,

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

and other bodies of water from detrimental changes in water temperatures, blockages of water courses, and deposits of sediment, where harvests are likely to seriously and adversely affect water conditions or fish habitat. Upon review of the Glacier Loon supplemental EA, I find that the timber harvest activities associated with the decision will comply with applicable Clean Water Act and Montana State Water Quality standards and the standards and guidelines of the Flathead Forest Plan. As documented in the supplemental EA, Hydrology and Fisheries Sections, timber harvest will not adversely affect water conditions or fish habitat. Application of BMPs and riparian buffers will protect water resources from harvest activities. The Selected Alternative has no activity within RHCAs except for 4.3 acres scattered across five treatment areas. These five units have small “slivers” of designated RHCAs located uphill of existing roads. Harvest activity in these “slivers” does not retard the goal of Inland Native Fish Strategy. d) The harvesting system to be used is not selected primarily because it will give the greatest dollar return or the greatest unit output of timber. My decision to implement the Glacier Loon Project is based on a variety of reasons discussed elsewhere in this Decision Notice. The decision is not based primarily on the greatest dollar return, but rather reducing hazardous fuels and the vulnerability of the forest to large scale, dramatic disturbances. However, tree harvest resulting from the vegetation treatments will generate revenue from the sale of forest products and will help fund several aspects of the project. 6. Clearcutting and Even-Aged Management The NFMA directs that clearcutting, seed tree cutting, shelterwood cutting, and other cuts designed to regenerate an even-aged stand of timber will be used as a cutting method on National Forest System lands only where: a) For clearcutting, it is determined to be the optimum method, and for other such cuts it is determined to be appropriate, to meet the objectives and requirements of the relevant land management plan. Clearcutting is planned under the Selected Alternative. A Certified Silviculturist documented the rationale for this method; this documentation can be found in Project File Section I. Silvicultural site-specific prescriptions for the Glacier Loon Project have been prepared by a Certified Silviculturist and reviewed by the ID Team Members. Target stand conditions were developed based on management objectives and site characteristics. The prescriptions considered existing stand conditions, the target stands, and resource constraints in determining the biological and technological feasibility of all silvicultural systems, including uneven-aged systems, and their appropriateness for the site. I have determined that prescribing even-aged systems under the Selected Alternative is appropriate for those units identified in Table 1-3 of Appendix 1. Clearcut with Reserves, Seed Tree with Reserves, and Shelterwood with Reserves treatments will take place in stands that currently are not meeting target stand objectives. Examples of these types

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

of stands are: . Stands with a high percentage of lodgepole pine which are currently experiencing mountain pine beetle infestation; . Stands with elevated levels of dwarf mistletoe and root disease where intermediate harvest is not appropriate. Regeneration harvest using Clearcut, Seed Tree, and Shelterwood systems, as these treatments are compatible with site-specific stand conditions, will retain the largest healthy trees on site, while allowing regeneration of healthier trees than existing conditions will permit. Where these treatments are used, the species to be regenerated are compatible with the even-aged management methods proposed. After reviewing the silvicultural information for the Glacier Loon Project, along with the site- specific management objectives developed from Forest Plan direction, I have determined that the management practices described in the Vegetation Section of the supplemental EA and supporting documents (Project File Section I) are appropriate methods to achieve the multiple resource objectives on the sites selected for harvest. b) The interdisciplinary review as determined by the Secretary has been completed and the potential environmental, biological, esthetic, engineering, and economic impacts on each advertised sale area have been assessed, as well as the consistency of the sale with the multiple use of the general area. Full interdisciplinary review has been completed for this project. The information presented in the Project File regarding transportation and harvesting requirements indicates that implementation of my decision is feasible and practical (Sections R and S). Standard ground-based and skyline logging systems and log hauling is prescribed for this project and has been determined to be practical for this project. The preparation, logging, and administration are practical for achieving the resource objectives and progress toward the desired future condition in the project area. The economic analysis included in the EA on pages 3-401 through 3-410 along with its supporting documentation in the project file, supports this finding. Economic feasibility is also determined by market conditions, which are currently improving compared to when the analysis was completed. Logging of similarly situated areas has demonstrated the feasibility and practicality of this type of vegetative treatment. All proposed treatments meet a portion of the multiple use goals and objectives in the Flathead Forest Plan for designated Management Areas. c) Cut blocks, patches, or strips are shaped and blended to the extent practicable with the natural terrain. A Landscape Architect completed the scenery analysis for the Glacier Loon harvest units presented in Chapter 3 of the supplemental EA. With the Selected Alternative, there will not be a change in long-term scenic integrity. All units meet the Forest Plan Visual Quality Objectives as a result of their location on the landscape in relation to other past management activities or natural features. d) Cuts are carried out according to the maximum size limit requirements for areas

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

to be cut during one harvest operation, provided, that such limits shall not apply to the size of areas harvested as a result of natural catastrophic conditions such as fire, insect and disease attack, or windstorm (FSM R1 supplement 2400-2001- 2 2471.1, 16 USC 1604(g)(3)(F)(iv)). FSM 2471.1 of the Northern Region clarifies and describes the restrictions on the size of harvest openings created by even-aged silvicultural methods (clearcut, seed tree and shelterwood harvests), as required by FSM 1921.12. All harvest activities in my decision meet the maximum size limitations. e) Such cuts are carried out in a manner consistent with the protection of soil, watershed, fish, wildlife, recreation, and esthetic resources, and the regeneration of the timber resource. The information provided in the project file documents that the vegetation management treatments included in my decision will achieve the desired forest vegetation conditions described in the supplemental EA, Chapter 3 (Vegetation Section) and the Silviculturist Report (Project File Exhibit I-1). Desired conditions for other natural resources are described in the Forest Plan and in the Upper Swan Valley Landscape Assessment (Project File Exhibit T-4). After reviewing the social and environmental effects of the alternatives (EA, Chapter 3), I have determined that my decision is consistent with Forest Plan direction for the management of natural resources, including water quality/quantity, wildlife and fish habitat, recreation uses, and aesthetic values. f) Stands of trees are harvested according to requirements for culmination of mean annual increment (CMAI) of growth or are substantially damaged by fire, windthrow, or other catastrophe, or which are in imminent danger from insect or disease attack. Harvest is occurring on habitat types and in management areas considered suitable for vegetation and timber management. Most of the stands prescribed for a shelterwood, seed tree, or clearcut regeneration method are dominated by lodgepole pine; are greater than 75 years old and mature; and are in imminent danger from insect attack. Some stands are mixed species that contain greater than 75 to 90 year old western larch, lodgepole pine, and Douglas-fir. My decision meets the requirements as stated. 7. Roads The NFMA requires that the necessity for roads be documented, and that road construction be designed to "standards appropriate for the intended uses, considering safety, cost of transportation, and impacts on land and resources [16 USC 1608(c)]. The NFMA also requires that "all roads are planned and designed to re-establish vegetation cover on the disturbed areas within a reasonable period of time, not to exceed 10 years ...unless the road is determined a necessary permanent addition to the National Forest Transportation System" [36 CFR 219.27(11)]. Management actions associated with the Glacier Loon Project do not include the construction of specified permanent roads. An estimated 5.9 miles of temporary roads will be constructed to access harvest units. These roads will be reclaimed after their use

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

(Appendix 1) to prevent motor vehicle use and will be revegetated within 10 years. I believe that we have met the requirements of 16 USC 1608 (c). Additional information regarding the road network in the analysis area can be found in the Roads Analysis (Project File Exhibit R-4). 8. NFMA Diversity The Forest Plan contains an array of components that contribute to the wildlife/fisheries habitat capability of the Flathead National Forest. Each of these components reduces the risk to a reduction of species’ diversity. Based upon consideration of these components of the Forest Plan (as amended), as well as the configuration of the Selected Alternative with its Monitoring Plan and Design Criteria, an analysis of effects of the Glacier Loon Project at the Forest and Regional Scale, and the Biological Assessments and Evaluations, I conclude that my decision will have no impact on some species, or may impact individuals or habitat but are not likely to result in a trend toward federal listing or reduced viability for other populations or species. In addition, my conclusion is based on a review of the project file that shows a thorough evaluation was made of relevant scientific information, a consideration of responsible opposing views, and the acknowledgement of incomplete or unavailable information, scientific uncertainty, and risk.

THE NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

National Environmental Policy Act provisions have been followed as required by 40 CFR 1500. The Glacier Loon Fuels Reduction and Forest Health Project Decision Notice comply with the intent and requirements of NEPA. Scoping for the project included public field trips and meetings, mailings that provided information about the project and solicitation for comments, public notices (legal advertisements), and a public review period. Issues identified during the initial scoping for the Glacier Loon Project assisted the ID Team and me in project design and with the analysis process. Project File Exhibit Sections B, C, and D contain public involvement documentation and news media articles, Exhibit Section C contains materials used to develop alternatives, and Exhibit Section E contains the comments received on this project. Appendix 5 of this DN provides my responses to concerns identified during the review of the EA. This DN describes the decisions I have made and my rationale for making the decisions

CLEAN WATER ACT AND MONTANA STATE WATER QUALITY STANDARDS

The Glacier Loon Project Area does not contain water quality impaired streams; however, streams in the project area are tributary to the Swan River and Swan Lake, which are on Montana’s Clean Water Act Section 303(4) list of impaired waters. A Total Maximum Daily Load (TMDL) and Water Quality Protection Plan for the Swan Lake River Watershed have been prepared by the Montana Department of Environmental Quality. The Glacier Loon Project includes specific Design Criteria and BMPs to ensure beneficial uses are protected. In addition, existing sediment sources have been

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI identified to be treated as funding is available to promote water quality improvement and restoration of full support of beneficial uses for impaired waters (Resource Enhancement Projects, Appendix 1). Upon review of the EA and Project Record, I find that activities associated with my decision will comply with State water quality standards. My decision includes project Design Criteria and measures to protect the water resource (Appendix 2 of this DN) and applicable BMPs (Appendix 4) to achieve water quality standards. Inland Native Fish Strategy Riparian Habitat Conservation Areas (RHCAs) will be established along all wetlands and stream courses that are in or adjacent to treatment areas. The Selected Alternative has no activity within RHCAs except for 4.3 acres scattered across five treatment areas. These five units have small “slivers” of designated RHCAs located uphill of existing roads. Harvest activity in these “slivers” does not retard the goal of Inland Native Fish Strategy.

CLEAN AIR ACT

After reviewing Chapter 3 of the EA, I find that the activities to be implemented will be coordinated to meet the requirements of the State Implementation Plans, Smoke Management Plan, and Federal Air Quality requirements.

NATIONAL HISTORIC PRESERVATION ACT, AMERICAN INDIAN RELIGIOUS FREEDOM ACT, AND NATIVE AMERICAN GRAVES PROTECTION AND REPATRIATION ACT

Cultural Resource Reviews have been completed on all areas to be impacted by ground- disturbing activities. Based upon the analysis in the EA (pages 3-397 thru 3- 400), and material in the project file, no Cultural Resources are expected to be affected by the Selected Alternative. Recognizing that the potential exists for unidentified sites to be encountered or disturbed during project activity, special provisions for their protection will be included in all contracts used to implement this project. These provisions will allow the Forest Service to unilaterally modify or cancel a contract to protect cultural resources, regardless of when they are identified. This provision will be used if a site were discovered after a harvest operation had begun. This project complies with the Region One programmatic agreement (1995) with the State Historic Preservation Office and the Advisory Council on Historic Preservation.

GOVERNMENT-TO-GOVERNMENT RELATIONS

The Forest Service consulted with the Confederated Salish and Kootenai Tribes during the analysis process. The intent of this consultation has been to remain informed about the Tribal concerns regarding the American Indian Religious Freedom Act and other tribal issues. In addition, the Salish (Flathead), Kootenai, and Upper Pend d’Oreilles tribes reserved rights under the Hellgate Treaty of 1855 (July 16, 1855). These rights include the “right of taking fish at all usual and accustomed places, in common with the citizens of the Territory, and of erecting temporary buildings for curing; together with the

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

privilege of hunting, gathering roots and berries, and pasturing their horses and cattle upon open and unclaimed land.” The Federal government has trust responsibilities to Tribes under a government-to-government relationship to insure that the Tribes reserved rights are protected. Consultation with the tribes through the project planning helps insure that these trust responsibilities are met.

THE ENDANGERED SPECIES ACT (16 USC 1531 ET. SEQ.)

Under the provisions of this Act, Federal agencies are directed to seek to conserve endangered and threatened species and to ensure that actions are not likely to jeopardize the continued existence of any of these species. Upon review of the Biological Assessments for wildlife, plants, and fish for the Glacier Loon Project, I find the decision meets the requirements of the Endangered Species Act. The Forest Service consulted with the USFWS on the effects of the project, as required under Section 7.

MIGRATORY BIRD TREATY ACT

On January 10, 2001, President Clinton signed an Executive Order outlining responsibilities of Federal agencies to protect migratory birds. Upon review of the information in the EA, (pages 3- 347 thru 3-358), and the document “Evaluation and Compliance with NFMA Requirements to Provide Diversity of Animal Communities” (Project File Exhibit AA-83), I find my decision complies with this Executive Order.

ENVIRONMENTAL JUSTICE

Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations," requires that Federal agencies make achieving environmental justice part of their mission by identifying and addressing, as appropriate, disproportionately high adverse human health and environmental effects of their programs, policies, and activities on minority populations and low-income populations. I conclude that the risk of such disproportionate effects on minority or low- income populations from this action is very low. My decision does not pose any significant socio-economic risks that disproportionately affect low income or minority populations in communities where timber producing employment opportunities and workers are located. The implementation of the Glacier Loon Fuels Reduction and Forest Health Project will not cause a significant change in local employment or revenue sharing with local communities. Thus, this decision should not disproportionately affect low-income or minority populations and communities. The action alternatives were assessed to determine whether they would disproportionately impact minority or low- income populations, in accordance with Executive Order 12898 (supplemental EA, page 3-420). No impacts to minority or low-income populations were identified during scoping or the comment period.

COMPLIANCE WITH OTHER LAWS, REGULATIONS, AND POLICIES

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Compliance with other laws, regulations, and policies are listed in various sections of the project file, the Forest Plan, and the EA (primarily in the “Regulatory Framework and Consistency” discussions at the end of the resource sections of Chapter 3.

PRE-DECISIONAL ADMINISTRATIVE REVIEW PROCESS

The Draft Decision Notice and Finding of No Significant Impact was published on April 9, 2018, which was subject to the pre-decisional administrative review process pursuant to 36 CFR 218. The 45 day objection period commenced the day after the publication of a legal notice in the Daily Inter Lake on April 10, 2018. Four objections to the decision were received from the following organizations: Native Ecosystems Council, Swan View Coalition, Alliance for the Wild Rockies, and Friends of the Wild Swan. A panel was convened to review the objections, Supplemental EAs, Draft DN/FONSI, and contents of the project file. On July 10, 2018, the Acting Deputy Regional Forester determined the project to be in compliance with all applicable laws and the Forest Plan. In her determination, the Acting Deputy Regional Forester instructed the Responsible Official to address the following items prior to signing a final decision notice for this project: Canada lynx instruction: Review the Holbrook et al. publications relative to Canada lynx and clearly display how those publications were considered in the analysis. Response: The recent science by Holbrook et al. (2016, 2017, and 2018), as well as other recent science e.g. and Kosterman et al. (2018) has been considered in the analysis of effects on Canada lynx for the Glacier Loon Project. A detailed review of the literature and consideration of the recommendations are included in Project File Exhibit AA-143. To consider the recommendations from this science, the Glacier Loon project’s wildlife biologist revisited the Canada lynx habitat geographic information system mapping and the stand field visits to identify stands that meet the descriptions of “mature” as defined in the recent science. The forest structural classes described in Holbrook et al. and Kosterman et al. are not consistent with structural classes used to define and develop objectives, standards, and guidelines in the Northern Rockies Lynx Management Direction, which was used for the Glacier Loon analysis. The wildlife biologist reviewed proposed vegetation management in these additional “mature” areas to derive post-implementation acres. In the project lynx analysis units, the total acres that meet the description of “mature” are below 50 percent before and after implementation of the project. While the project would impact multistory lynx foraging stands, the project is working to reestablish inherent disturbance regimes; the natural distribution of patch sizes, tree clump, and gap patterns within patches; and more natural landscape patterns. The Glacier Loon treatments would maintain a mosaic of various structural stages for lynx and would reduce fuel conditions that promote uncharacteristic wildfires and that allow for safe and effective fire management.

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI

Map 1. Project Vicinity Map

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Map 2. Selected Alternative- North Half

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Map 3. Selected Alternative- South Half

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Map 4. Selected Alternative- Management Areas

Glacier Loon Fuels Reduction

and Forest Health Project

Appendices

Swan Lake Ranger District, Flathead National Forest Missoula County, Montana

GLACIER LOON FUELS REDUCTIONAND FOREST HEALTH PROJECT FINAL DECISION NOTICE AND FONSI APPENDIX 1- DETAILS OF THE SELECTED ALTERNATIVE

Specific vegetation management treatments and associated activities of the Selected Alternative authorized in this Decision Notice consist of the following: • Fuel reduction and forest health treatment of affected stands on approximately 1,397 acres of NFS lands within the Glacier Loon Project Area including:

o 197 acres of Clearcut with Reserve Trees; o 325 acres of Seed Tree with Reserve Trees; o 51 acres of Shelterwood with Reserve Trees; o 258 acres of Commercial Thin; o 84 acres of Improvement Cut; o 3 acres of Sanitation/Salvage; o 10 acres of Post and Pole; o 337 acres of Pre-Commercial Thin; o 120 acres of Modified Commercial Thin; and o 12 acres of Commercial Thin/Pre-Commercial Thin. • Harvest activities will be implemented using the tractor, skyline, mechanical, and hand treatments in the summer and tractor and forwarder logging systems during the winter. • Slash will be treated through a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings will be treated by either burning, chipping/masticating, and/or removal from National Forest lands. Prescribed fire treatments will include broadcast burning, pile burning and/or jackpot burning. • Hand planting with desired species will occur on an estimated 305 acres within regeneration treatment units. Where adequate site preparation is achieved, natural regeneration will be expected to occur and in some cases supplement planted seedlings. • Fuels treatment will occur on 1,157 acres within the Wildland Urban Interface (WUI). • Fuels treatment will occur on 240 acres outside the WUI. • Best Management Practices (BMPs) would be implemented on an estimated 29.3 miles of haul routes to meet Timber Sale Requirements and reduce sediment yields. Application of BMPs (Appendix 4) on all temporary roads constructed and roads temporarily opened will also be implemented as requirements of the timber sale. • Units will be accessed through an estimated 5.9 miles of temporary road

Appendix 1-1 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

construction as shown in Table 1-1 below. System roads will be used for road haul. These temporary roads will be reclaimed following their use. • Road decommissioning will occur on an estimated 8.4 miles. • Minimal harvest activity will occur within Riparian Habitat Conservation Areas (RHCAs) in upland areas. Some temporary road locations will occur within RHCAs and cross streams. Portions of Units 19, 24, 57, 61, and 205 totaling 4.3 acres will occur within RHCAs. Site specific Design Criteria will assure that there will not be any adverse effects to streams, fish, or fish habitat. • The Selected Alternative vegetation treatments and associated activities are summarized in the following table. Table 1- 1. Summary of Proposed Treatment Activities for the Selected Alternative

Total Acres* Acres* Clearcut with Reserve Trees 197 1,397 Seed Tree with Reserves 325 Shelterwood with Reserves 51 Commercial Thin 258 Improvement Cut 84 Sanitation/Salvage 3 Acres Post and Pole 10 Pre-Commercial Thin 337

Harvest Treatment Modified Commercial Thin 120 Commercial Thin/Pre-Commercial Thin 12

Tractor 1043 1,397 Mechanical 349 Acres System Logging Hand 5 Chip/Excavator Pile/Burn 17 1,397

Chip/Pile Remove 332 Lop & Scatter/Pile/Burn 5 Lop & Scatter/Hand Pile/Burn 10 Whole Tree Yarding 227 WTY- Chip/Pile/Remove 12 WTY- Broadcast Burn 84 WTY- Excavator Pile/Burn Piles 539 Slash Treatment WTY- Excavator Pile/Burn/Chip 130 WTY- Hand Pile/Burn/Chip 41 Road Management Miles Haul Routes (BMPs) to be applied to meet Timber Sale Requirements 29.3 Temporary Road Construction 5.9 Roads Proposed for Decommissioning 8.4

*Acres will likely be slightly less due to change in buffer (Management Requirement and Design Criteria) for unoccupied water howellia habitat from 150 feet to 300 feet.

Appendix 1-2

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Table 1- 2. Proposed Treatment Activities for the Selected Alternative

Forest Unit Unit Logging Alt. D Treatment Slash Treatment Plan MA Acres* System No. Direction Commercial Thin/Pre- 2 12 Tractor WTY, Chip/Pile/Remove 15C Commercial Thin Seed Tree with WTY, Excavator Pile, Burn 5 15 Tractor 15C Reserves Piles WTY, Excavator Pile, Burn 6 29 Clearcut with Reserves Tractor 15C Piles Seed Tree with WTY, Excavator Pile, Burn 7 3 Tractor 15C Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 8 2 Tractor 15C Reserves Piles WTY, Excavator Pile, Burn 9 15 Clearcut with Reserves Tractor 15C Piles Seed Tree with WTY, Excavator Pile, Burn 10 5 Tractor 15C Reserves Piles 12 22 Commercial Thin Tractor WTY 15C 13 13 Commercial Thin Tractor WTY 15C 14 20 Commercial Thin Tractor WTY 15C Seed Tree with WTY, Excavator Pile, Burn 17 21 Tractor 15C Reserves Piles WTY, Excavator Pile, Burn 19 11 Clearcut with Reserves Tractor 15C Piles WTY, Excavator Pile, Burn 20 12 Clearcut with Reserves Tractor 15C Piles WTY, Excavator Pile, Burn 22 31 Clearcut with Reserves Tractor 15C Piles WTY, Excavator Pile, Burn 24 17 Clearcut with Reserves Tractor 15C Piles 25 20 Commercial Thin Tractor WTY 15C 26 24 Commercial Thin Tractor WTY 15C 31 26 Improvement Cut Tractor WTY 15C 32 23 Commercial Thin Tractor WTY 5 33 24 Commercial Thin Tractor WTY 5 WTY, Hand Pile/Burn, 34 16 Improvement Cut Tractor 5 Chip 35 41 Commercial Thin Tractor WTY 5 WTY, Hand Pile/Burn, 36 4 Improvement Cut Tractor 5 Chip WTY, Hand Pile/Burn, 37 21 Improvement Cut Tractor 5 Chip 38 11 Commercial Thin Tractor WTY 5 39 14 Improvement Cut Mechanical Chip, Excavator Pile, Burn 5 40 3 Improvement Cut Mechanical Chip, Excavator Pile, Burn 5

Appendix 1-3

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Forest Unit Unit Logging Alt. D Treatment Slash Treatment Plan MA Acres* System No. Direction WTY, Excavator Pile, Burn 43 16 Commercial Thin Tractor 15C Piles WTY, Excavator Pile, Burn 44 4 Commercial Thin Tractor 15C Piles WTY, Excavator Pile, Burn 48 76 Clearcut with Reserves Tractor 15C Piles WTY, Excavator Pile, Burn 49 6 Clearcut with Reserves Tractor 15C Piles Seed Tree with WTY, Excavator Pile, Burn 52 34 Tractor 17 Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 57 18 Tractor 15C Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 58 2 Tractor 17 Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 59 10 Tractor 15C Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 61 20 Tractor 15C Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 63 9 Tractor 15C Reserves Piles 65 3 Sanitation/Salvage Tractor WTY 17 Modified Commercial WTY, Excavator Pile, 66 92 Tractor 5 Thin Burn, Chip Modified Commercial WTY, Excavator Pile, 67 28 Tractor 5 Thin Burn, Chip WTY, Excavator Pile, Burn 68 30 Commercial Thin Tractor 5 Piles Seed Tree with WTY, Excavator Pile, Burn 70 16 Tractor 15C Reserves Piles Seed Tree with 73 17 Tractor WTY, Broadcast Burn 15C Reserves Seed Tree with 74 23 Tractor WTY, Broadcast Burn 15C Reserves Seed Tree with 75 6 Tractor WTY, Broadcast Burn 15C Reserves WTY, Excavator Pile, 76 10 Commercial Thin Tractor 15C Burn, Chip Seed Tree with WTY, Excavator Pile, Burn 77 18 Tractor 15 Reserves Piles 78 10 Post & Pole Tractor L&S, Hand Pile/Burn 15 Seed Tree with WTY, Excavator Pile, Burn 79 8 Tractor 15 Reserves Piles Shelterwood with 80 20 Tractor WTY, Broadcast Burn 15 Reserves Seed Tree with WTY, Excavator Pile, Burn 81 19 Tractor 15 Reserves Piles

Appendix 1-4

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Forest Unit Unit Logging Alt. D Treatment Slash Treatment Plan MA Acres* System No. Direction Seed Tree with 82 18 Tractor WTY, Broadcast Burn 15 Reserves Seed Tree with WTY, Excavator Pile, Burn 88 9 Tractor 15 Reserves Piles Shelterwood with WTY, Excavator Pile, Burn 89 31 Tractor 15 Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 90 17 Tractor 15 Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 92 10 Tractor 15 Reserves Piles Seed Tree with WTY, Excavator Pile, Burn 94 25 Tractor 15 Reserves Piles 200 8 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 201 133 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 202 44 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 203 4 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 204 53 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 205 6 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 206 3 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 207 5 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 208 5 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 209 2 Pre-Commercial Thin Mechanical Chip/Pile/Remove 17 210 4 Pre-Commercial Thin Mechanical Chip/Pile/Remove 17 211 8 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 212 14 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 213 17 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 215 7 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 216 5 Pre-Commercial Thin Hand Lop & Scatter, Pile/Burn 15C 217 6 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15C 218 5 Pre-Commercial Thin Mechanical Chip/Pile/Remove 5 219 8 Pre-Commercial Thin Mechanical Chip/Pile/Remove 15 Total Acres: 1,397*

*Acres will likely be slightly less due to change in buffer (Management Requirement and Design Criteria) for unoccupied water howellia habitat from 150 feet to 300 feet.

Appendix 1-5

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

VEGETATION MANAGEMENT

Silvicultural treatments are often defined as either regeneration or intermediate treatments. Regeneration methods are those that purposefully establish a new age class. Conversely, intermediate treatments are meant to enhance growth, quality, vigor, and composition of a stand prior to a regeneration treatment. Associated fuel treatments, site preparation and reforestation treatments are also proposed. Descriptions of the proposed treatments follow. Please refer to Appendix C in the Supplemental EA for detailed illustrations of the Silvicultural Treatments.

REGENERATION TREATMENTS

• Clearcut with Reserves - This treatment will remove nearly all trees from the site to facilitate regeneration of a new age class and increase species diversity. Although limited, all long lived, fire resistant, shade intolerant species (western larch, ponderosa pine, western white pine, and occasionally Douglas-fir) would be retained, where feasible and where not acting as an insect or disease vector. Reserve trees would be retained to provide long term structural diversity. These treatment areas consist of primarily even- aged lodgepole pine with little species or structural diversity and are either experiencing mountain pine beetle mortality or are at risk of being affected. Regeneration of trees would result from natural seeding, planted seedlings, or a combination of both. Mechanical treatments and/or prescribed fire could be used to reduce fuels, recycle nutrients and prepare the site for regeneration. • Clearcutting - The National Forest Management Act and Forest Service Handbook direction dictate that clearcutting must be justified as the optimum method to meet management objectives when prescribed. Fourteen areas are proposed for clearcutting in this project. Clearcutting was determined to be the optimum regeneration method for meeting management objectives for each of these areas by the Project Silviculturist. Criteria used to make this determination included; species composition relative to management direction and availability of desired species for seed sources, species susceptibility to observed insect agents, presence of disease infections which would be transmitted to the regenerated stand or where non- susceptible species conversion is necessary, and stands subject to windthrow if residual trees were retained. Appendix A of the Silviculture Report (Project File Exhibit I-1) discusses the criteria which applied to specific treatment areas. • Seed Tree with Reserves - A portion of the existing overstory long-lived, fire- resistant, shade intolerant species (western larch, ponderosa pine, western white pine, and occasionally Douglas-fir) would be retained and reserved at a density sufficient to facilitate regeneration of these desired species and create a two-aged stand structure (e.g., 5 to 15 trees per acre). This density is designed to provide seed sources and long-term structural diversity, while not interfering with the successful regeneration of desired species. The majority of these areas are dominated by lodgepole pine infested with mountain pine beetle or at risk. In addition, some proposed areas are affected by dwarf mistletoe and/or root diseases. Regeneration of trees would result from

Appendix 1-6

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

natural seeding, planted seedlings, or a combination of both. Mechanical treatments and/or prescribed fire could be used to reduce fuels, recycle nutrients and prepare the site for regeneration. • Shelterwood with Reserves - A portion of the existing overstory long-lived, fire-resistant, shade-intolerant species (typically; western larch, ponderosa pine, western white pine, and occasionally Douglas-fir) would be retained and reserved at a density sufficient to facilitate regeneration of these desired species and create a two-aged stand structure (e.g., 10 to 30 trees per acre). This density is designed to provide seed sources, long-term structural diversity, and provide shelter and a moderated micro-climate favorable for regeneration. Although similar to Seed Tree Treatments, the number of trees retained in Shelterwood Treatments would be greater. Again, these areas are currently affected by mountain pine beetle, dwarf mistletoe, and/or root diseases. Regeneration of trees would result from natural seeding, planted seedlings, or a combination of both. Mechanical treatments and/or prescribed fire could be used to reduce fuels, recycle nutrients and prepare the site for regeneration.

INTERMEDIATE TREATMENTS

• Commercial Thin - Existing tree density would be reduced from current levels to a target residual density ranging from 60 to 120 square feet of basal area per acre. This equates to approximately 50 to 150 trees per acre depending on tree species and site variables. Long- lived, fire-resistant, shade-intolerant species (typically; western larch, ponderosa pine, western white pine, and occasionally Douglas-fir) would be favored for retention. The purpose of this treatment is to enlarge the growing space of desirable trees and reduce tree competition for limited site resources allowing for improved tree growth, vigor, resilience, and manipulation of fuel continuity. Mechanical treatments and/or prescribed fire would be used to reduce fuels and recycle nutrients. • Modified Commercial Thin - This treatment is specific to Units 66 and 67 as these units are in the vicinity of the Lindbergh Lake Campground and adjacent to private lands near Cygnet Lake. A modified commercial thin is proposed in those portions of Units 66 and 67 which are adjacent to and which would directly impact the campground and private lands. The commercial thin treatment would be “modified” so that the primary treatment objectives of fuels reduction and hazard tree mitigation are met while ensuring retention/enhancement of the recreational experience and privacy retention/screening for private lands. Modifications could include, but not limited to, items such as varying residual tree densities near private lands and strategically retaining understory trees for visual/noise screening. During implementation, the Project Silviculturist would work closely with the District Recreation Staff and private land owners on treatment specifics. • Improvement Cut - These treatments would be designed to achieve one of two objectives. Where mature ponderosa pine trees exist, the purpose would

Appendix 1-7

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

be to reduce impacts from mountain pine beetle by altering the stand micro- environment and enlarging the growing space of desirable trees. The existing tree density would be reduced from current levels either through thinning (residual densities ranging from 60 to 80 square feet of basal area per acre) or “Daylighting.” Daylighting Treatments are applied on an individual tree basis and involve clearing vegetation within a specified distance (~30 feet) of a target tree. Ponderosa pine and non-susceptible species (e.g. western larch and Douglas-fir) would be favored for retention in all treatments. In addition to the thinning of live trees, dead trees and pine trees currently infested with mountain pine beetle would be salvaged from these areas if encountered. Alternatively, improvement cutting is also proposed in immature stands with high existing tree densities and designed to manipulate fuel continuity and reduce mountain pine beetle hazard. Here, tree density would be reduced from current levels to a target residual density ranging from 50 to 200 trees per acre. Many of the trees to be removed would be smaller than the minimum Forest Service sawlog specifications of 7 inches DBH; however larger trees are also likely to be removed. Mechanical treatments would be used to reduce fuels and recycle nutrients. • Sanitation/Salvage - In these treatment areas the existing stand structure would generally remain intact following treatment. However, these areas would be modified by removal of dead, dying, or damaged trees. Primarily this includes lodgepole pine trees affected by mountain pine beetle. Where concentrations of affected trees exist, stand structure would be more significantly modified. The purpose of this treatment is to improve stand health, recover economic value, and manipulate fuel loadings and continuity. Mechanical treatments would be used to reduce fuels and recycle nutrients. • Post and Pole - Areas identified as “Post and Pole” would be established as personal use post and pole areas. In these areas permitted individuals would be allowed to harvest live lodgepole pine trees less than 5 inches DBH. Areas would be identified on the ground and all specified permit conditions would apply, including limits on material harvested. • Pre-Commercial Thin - In this treatment the existing immature tree density would be reduced to a target residual density (e.g., 50 to 300 trees per acre). The primary purpose of this treatment is to reduce fuel continuity, adjust species composition, and concentrate growth on the most desirable trees. This treatment would focus on the removal of sapling and pole-sized trees generally not greater than 5 inches DBH. Mechanical treatments and/or pile burning would be used to reduce fuels and recycle nutrients. This treatment is typically accomplished through hand thinning methods or through mechanized chipping/mastication.

FUEL TREATMENTS

A number of prescribed treatments are designed to reduce natural and activity generated fuels within the proposed treatment areas. These treatments include mechanical methods and the use of prescribed fire. Mechanical treatments could

Appendix 1-8

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

include a combination of the following; whole tree yarding (or possibly yarding of tops), lop and scatter, masticating, and/or excavator piling. Fuel accumulations at landings would be addressed through burning, chipping/masticating, and/or removal from National Forest lands. Prescribed fire treatments could include broadcast burning, pile burning and/or jackpot burning.

SITE PREPARATION

Depending on existing vegetation and ground conditions, site preparation may be prescribed to create favorable conditions to help ensure adequate regeneration. These treatments are often prescribed in both artificial and natural regeneration situations and typically address competing vegetation, seed bed preparation, fuel accumulations, and duff reduction. Site preparation can be accomplished through hand, mechanical, or prescribed fire methods. Hand methods usually involve creating favorable conditions at the time of planting using hand tools. Mechanical treatments are often accomplished during harvest operations or shortly afterwards and involve scarification and seed bed preparation through the use of mechanized equipment. Prescribed fire can also be used to recycle nutrients, consume excess fuels, reduce competing vegetation, and create a favorable seedbed.

REFORESTATION

Where regeneration treatments are proposed, a combination of natural and artificial reforestation is planned (specifically, hand planting of desired species). Where planting occurs, species selection would be based on management direction and site characteristics. Emphasis would be placed on establishing long-lived shade intolerant species such as western larch, ponderosa pine, western white pine, and occasionally Douglas-fir. It is expected that some level of natural regeneration would occur in all regeneration units.

ROAD MANAGEMENT

• Road Maintenance (Best Management Practices): The objectives of road maintenance are to reduce the concentration of sub-surface and surface water runoff, minimize road surface erosion, filter ditch water before entering streams, and decrease the risk of culvert failures during peak runoff events. Maintenance work could include culvert installation, replacement of existing culverts with larger culverts, installation of drainage dips and surface water deflectors, placement of rip-rap to armor drainage structures, aggregate surface replacement, aggregate placement to reinforce wet surface areas, ditch construction and cleaning where needed, and surface blading to restore drainage efficiency of the road surface. These actions would bring the roads up to current BMP Standards and provide benefits to the streams in the project area. Best Management Practices are required under Timber Sale Contracts prior to hauling of timber over these roads. • Road Construction: The Glacier Loon Transportation Plan identified several

Appendix 1-9

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

areas that would need to be accessed by temporary roads. The proposed road construction would allow temporary access to proposed treatment areas through historic road templates and new temporary roads.

o Historic Road Template: An historic template can be defined as a constructed road surface that was once used for a transportation need but is not currently a part of the National Forest Road System. It has an overall template that has not been recontoured, and is in a state that is impassible to full sized motor vehicles due to waterbars and culvert removals and/or closure by vegetation, earth berm, or other natural features.

o Temporary Roads: Temporary roads will be constructed to the minimum standards necessary for log hauling on National Forest System (NFS) roads. Temporary road surface width will be limited to truck bunk width plus 4 feet. Temporary roads will be reclaimed following their use using drain dips, outsloping, scarifying, seeding, and recontouring. Table 1- 3. Temporary Road Needs for the Selected Alternative

Temporary Unit Access Miles Road Name 2 14A Access via NFS Road #9591 0.07 5, 6, 7, 8 23A Access via NFS Road #91306 & #91305 0.76 9 14D Access via NFS Road #9591 0.35 9, 10 23B Access via NFS Road #9591 and #91306 0.10 12, 13, 14 24A Access via NFS Road #9780 0.79 17 26A Access via NFS Road #561 0.45 22 36C Access via NFS Road #9579C 0.43 26 36B Access via NFS Road #9579C 0.30 48 11A Access via NFS Road #11648B 0.44 48 02D Access via NFS Road #9578 0.12 59 12D Access via NFS Road #79 0.34 52 12D Access via NFS Road #79 0.40 61, 63 12A Access via NFS Road #10566 0.12 61, 63 12B Access via NFS Road #10566 0.20 66 14B Access via NFS Road #90243 0.10 66 11C Access via NFS Road #90243 0.27 68, 70 15C Access via NFS Road #90241 & #90242 0.24 80 22C Access via NFS #10728 0.05 89 27A Access via NFS Road #10734 0.08 90 22C Access via NFS Road #10728 0.30 Total Temporary Road Miles 5.9 • Road Decommissioning: Road decommissioning is defined as activities that result in the stabilization and restoration of unneeded roads to a more natural

Appendix 1-10

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

state (36 CFR 212.1), (FSM 7703). Decommissioning removes roads from the landscape that are no longer needed for current or future resource management or which pose a threat to water quality or wildlife security. This action would restore the natural drainage patterns interrupted when the roads were constructed. These methods for decommissioning include active and passive restoration. Active treatment may include total re-contouring that would restore the road template to the natural hill slope, partial re-contouring to fill ditches or remove unstable road shoulders, removing culverts (stream- aligned culverts will be removed) and other drainage structures, ripping the roadbed to reduce compaction, installing water bars, out-sloping the road prism, seeding and fertilizing disturbed soil, and blocking the road entrance and abandoning the road to allow re-vegetation. Passive treatment would not involve any ground disturbing work. Table 1- 4. Glacier Loon Project Area Road Decommissioning Activities1

Passive or Active NFS BMP EMP Selected Existing Condition Restoration/Type of Work Road # (mile) (mile) Alternative Anticipated2 9573 0.000 0.400 Road not Active: Construct water bars 0.400 revegetated. every 100- 300 feet as needed. Remove culverts if scour is evident 100 feet above or below crossings. 9575 1.098 2.000 Road has ruts and Active: Re-contour. 0.902 rilling. 9579 0.715 1.500 Completely Passive: No ground disturbing 0.785 revegetated with work anticipated. vegetation past jct. with Road 9579C. Road crosses several wet areas. 10247 0.000 0.270 Road not Active: Construct water bars 0.270 revegetated. every 100- 300 feet as needed. Remove culverts if scour is evident 100 feet above or below crossings. 10566 0.230 0.310 Road revegetated. Passive: No ground disturbing 0.080 work anticipated. 10568 0.000 0.300 Majority of road Passive: No ground disturbing 0.300 revegetated. work anticipated.

1 Decommissioning activities will meet the “reclaim” definition in Amendment 19 (see Flathead National Forest Amendment 19 Amended EA, Appendix D-2). 2 There could be further work necessary than identified here to meet the reclaim definition– e.g. removal of stream-aligned culverts, recontouring, placement of natural debris, or revegetation with shrubs or trees. See design features in Appendix 2.

Appendix 1-11

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Passive or Active NFS BMP EMP Selected Existing Condition Restoration/Type of Work Road # (mile) (mile) Alternative Anticipated2 10730 0.000 0.450 Road has major Active: Construct water bars 0.450 erosion concerns. every 100- 300 feet as needed. Remove culverts if scour is evident 100 feet above or below crossings. First 350 feet of road needs eroded section reshaped. 10731 0.000 0.400 Road revegetated. Passive: No ground disturbing 0.400 work anticipated. 10732 0.300 2.300 Road was Active: Re-contour. 2.000 waterproofed in 2009 and has water bars in place with stream culverts removed. Slump located at M.P. 0.65. 10733 0.000 0.850 Road was Active: Re-contour. 0.850 waterproofed in 2009. 10734 0.000 0.150 Road was Active: Re-contour. 0.150 waterproofed in 2009. 11648 0.000 0.180 Road is completely Passive: No ground disturbing 0.180 A revegetated. work anticipated. First half of road has Active: Construct water bars 0.370 ruts and rilling. every 100- 300 feet as needed. 561F 0.000 0.370 Several culverts Remove culverts if scour is undersized. Last evident 100 feet above or below 300 feet is located crossings. Last 300 feet of road in floodplain, which needs eroded section reshaped. washed out in 2009. Severe erosion source. 561G 0.000 0.200 Road not Active: Construct water bars 0.200 revegetated. every 100- 300 feet as needed. Remove culverts if scour is evident 100 feet above or below crossings. 79B 0.000 0.200 Majority of road is Passive: No ground disturbing 0.200 revegetated. work anticipated. 79Y 0.000 0.750 Road has Active/Passive: Construct water 0.750 compacted drainage bars every 100-300 feet as and has converted needed. The first 800 feet shall stream to a wetland. have the road surface scarified and have seed and mulched placed on the roadbed. Brush shall be placed on the roadway at the entrance to prevent future unauthorized use. No ground

Appendix 1-12

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Passive or Active NFS BMP EMP Selected Existing Condition Restoration/Type of Work Road # (mile) (mile) Alternative Anticipated2 disturbing work is anticipated after the first 800 feet.

79Z 0.000 0.150 Majority of road Passive: No ground disturbing 0.150 revegetated. work anticipated. Total 8.437

RESOURCE ENHANCEMENTS PROJECT

Resource enhancement projects identified during project design are shown in the table below. These projects were identified to improve other resource values within the project area. Please refer to Maps 2A and 2B for a display of the project locations. These projects, while in the project analysis area, are not needed to mitigate effects of the proposed action or any of the alternatives. These projects represent site specific resource enhancement opportunities that, through this decision, would be authorized to occur. The implementation of these projects could occur as stand-alone projects and or could be associated with the proposed actions through stewardship contracting. Additional detail on the projects and potential funding sources follow.

Table 1- 5. Resource Enhancement Projects

Project # Ground Location Project Description on Map End of Road 1 A historic road (unmapped, no number) or skid trail was #9591Y in T20N, discovered about 0.25 miles from the end of FSR 9591Y. R17W, Section 14 This road was built in the bottom of a small draw and not reclaimed. This draw now collects water into a stream that runs down the middle of the old road. The stream is small and not substantially eroding but it may have slightly altered the groundwater input of the wetland it flows into, which happens to be occupied by Howellia. This project would plant approximately 400 shrubs and seedlings on about 250’ length of the stream. As the plants mature, they should be able to restore natural groundwater movement and help the stream fade away. Road #9552 in 2 The existing road is poorly designed where it crosses the T19N, R17W, unnamed stream that flows between Meadow Lake and Sections 33 Bunyan Lake. The culvert is a seasonal fish migration barrier and the road surface erodes into the creek. Both Bunyan and Meadow Lake have wild (self-sustaining) cutthroat trout and the barrier is not desirable. This project will replace the culvert with either a larger culvert that provides fish passage or a bridge. The road will be reconstructed so that it does not erode into the stream.

Appendix 1-13

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 1- Details of the Selected Alternative

Project # Ground Location Project Description on Map Minor work would also take place at the trailhead to reduce erosion. (Please see Design Criteria, Appendix 2, page 2-5 for more details).

Temporary Road 3 Temporary Road #12A (access to Units 60, 62, and 214) is #12A in T19N, located on a template of an old historic road built in the early R17W, Section 12 1980s. The culvert across the intermittent stream is still in place, is poorly aligned and could eventually wash out. The culvert will be removed, the channel restored, and the road reclaimed. Removal of the culvert will occur during the dry period to minimize channel disturbance. (Please see Design Criteria, Appendix 2, page 2-5 for more details). Several sources of funding exist for resource enhancement projects. Many items have the potential to be funded through timber sales, while other items could be funded with Congressionally-approved funds (Collaborative Forest Landscape Restoration Program) or Stewardship dollars. Implementation would be based on annual budgets and program direction. It is anticipated that this project may be offered under a Stewardship Contract. Actual authority to offer under such a contract comes from the Regional Forester on a case-by-case basis. If approved as a Stewardship offering, these items will be included in Stewardship Projects, but inclusion of projects in the final award will depend on the bid value received for the project. Some, none, or all of the projects may be implemented through Stewardship contracting depending on market conditions at the time of offer. Implementation through direct project funding will be based on annual budgets and program direction. If funding were not available, the improvements from these projects would not be accomplished.

DESIGN CRITERIA

Appendix 2 of this Decision Notice describes the Design Criteria applied to this project to protect resources.

MONITORING

Monitoring and evaluation compared the results being achieved to those projected in the Forest Plan. Monitoring is conducted on a sample basis to evaluate the overall progress in implementing the Forest Plan, the assumptions on which the Forest Plan is based, and to provide a feedback loop for determining effectiveness of project and mitigation implementation (USDA Forest Service 1987). For this project, monitoring and evaluation would be conducted as described in Appendix 4 of this document. Those monitoring components not specifically discussed in this appendix tier to the monitoring described in the Forest Plan.

Appendix 1-14

GLACIER LOON FUELS REDUCTIONAND FOREST HEALTH PROJECT FINAL DECISION NOTICE AND FONSI APPENDIX 2- DESIGN CRITERIA FOR THE SELECTED ALTERNATIVE

MANAGEMENT REQUIREMENTS AND DESIGN CRITERIA

The measures identified in the following table serve to further reduce impacts to the specific resources identified. Most are considered Design Criteria and are included in the Selected Alternative. Several abbreviations are used in the responsibility section of Table 2-1. The following explains those abbreviations: AFMO: Assistant Fire Mgmt Officer HYD: Hydrologist SILF: Silviculturist ARCH: Archeologist IDT: Interdisciplinary Team SP: Sale Prep BT: Botanist LA: Landscape Architect SS: Soils Scientist DR: District Ranger LEO: Law Enforcement Officer TMC: Timber Marking Crew DRC: District Road Coordinator NWM: Noxious Weed Manager TP: Timber Sale Purchaser ENG: Engineer RA: Range Administrator WB: Wildlife Biologist FISH: Fisheries Biologist RF: Resource Forester FMO: Fire Management Officer SA: Sale Administrator

Appendix 2-1 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Table 2- 1. Management Requirements and Design Criteria

Objective Task Responsibility Due Date

Grizzly Bear Security The Glacier-Loon Grizzly Bear Subunit was “active” 2012 through 2014 and is WB, SA, SP Pre- and Post- and SVGBCA currently “inactive.” Standards and guidelines for an inactive grizzly bear Sale Compliance subunit will be followed, as per the Swan Valley Grizzly Bear Conservation Agreement during the “inactive” period. The subunit is “active” again in 2021 through 2023 under the SVGBCA. The Buck Holland Subunit is “Active from 2018 through 2020, and becomes “Inactive” again in 2021.

Grizzly Bear Security In order to avoid the potential disturbance of grizzly bear in important Spring SP, SA, TMC, Pre- and Post- and SVGBCA Habitat, management activities that are planned in Spring Habitat, which is WB Sale Compliance defined as areas within designated Linkage Zones, below 5,200 feet, will not occur within the spring period (April 1 through June 15). This timing restriction would apply to all units except Units 2, 5-14, 19, 20, 22, 24-26, 31-34, 90, 92, 94, 200, and 205.

Grizzly Bear Security Seed Tree with Reserves, Clearcut with Reserves, and Shelterwood with SP, WB Pre- and Post- and SVGBCA Reserves will be designed so that no point in the unit is more than 600 feet Sale Compliance from cover; in other words, a bear in the unit would be able to find cover anywhere in the unit within 600 feet or less.

Grizzly Bear Security Visual screening will be retained adjacent to open roads in proposed cutting SP, SA, TMC, Pre- and Post- (SVGBCA units. WB Sale Compliance) General Wildlife Security

Wildlife- TES Provisions will be included in the contract to cease activity or otherwise protect WB, SA, SILV Contract Prep, populations and individuals of threatened or endangered species. This allows During Harvest for modification of the project should an unforeseen issue(s) be identified Activities during operations. Standard contractual requirements used in all contracts provide for modification or termination of the contract to avoid impacts and protect TES.

Wildlife- TES Public motorized access will be restricted on temporary roads and skid trails WB, SA, DRC Pre- and Post- normally closed to use. Sale, During

Appendix 2-2 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date Harvest Activities

Wildlife- TES Contractors working under contract on NFS lands are prohibited from carrying SA, LEO, WB Pre- and Post- firearms on roads within the project area that are normally closed to public use Sale, During (Swan Valley Grizzly Bear Conservation Agreement). Harvest Activities

Wildlife- Security Vegetation and/or rock barriers will be retained around berms and gates, DRC, SA, WB Pre- and Post- where needed, to maintain closure effectiveness. Sale, During Harvest Activities

Wildlife- Security If berms are removed for access to treatment units, temporary gates will be SB, SA, DRC Pre- and Post- installed. Berms will be re-installed when sale activities are complete. Sale, During Harvest Activities Contract Prep, Wildlife- Security No harvest activity will take place within 330 feet of Meadow Lake to protect WB, SA, SP During Harvest Northern Bog Lemming Habitat. Activities

Wildlife- Security Decommissioned roads will be treated so that they are impassable to WB, SA, DRC During Harvest motorized vehicles and meet the minimum criteria for a “reclaimed road” as Activities, Post- defined by Forest Plan Amendment 19 (Amendment 19 Amended EA, Sale Appendix D pg. 2). When the decommissioned roads meet the “reclaimed” definition in Amendment 19, they will no longer be counted in road density or security core calculations. All decommissioned roads will receive the following treatments: • The first portion of the road (typically 200 to 600 feet) will be treated in such a manner to preclude its use as a motorized or non-motorized travelway – this could include one or more of these options: recontouring the road surface, placement of natural debris, placement of rock barriers or berms, or revegetation with shrubs or trees. • Culverts aligned with stream channels will be removed. • The entire road will receive treatment such that maintenance or entries to maintain road drainage is not needed.

Appendix 2-3 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date • Road related sediment sources will be repaired and road reworked to eliminate ditch water flow without the aid of cross drain culverts. Typically this is achieved by cutting waterbars into the ditch line every 200 feet. Waterbars can be placed closer or further apart depending on site specific conditions and are typically installed 50ft above grade or near existing cross drains. Beyond the first portion of the road (200 to 600 feet), the roadway will be treated to discourage use including sporadic placement of natural debris where available and seeding or planting to encourage re-vegetation. Recontouring all or a portion of the remaining roadway is also an option.

Snag Retention for In treatment units, where available, a minimum average of 6 snags per acre SILV, WB, SP, Pre- and Post- Snag Associated that are 12-20 inches DBH would be left, and all snags greater than 20 inches SA, TP Sale, During Wildlife Species would be left. If existing snag densities are below these densities, substitute Harvest live trees would be left. All standing dead cull western larch, ponderosa pine, Activities and Douglas-fir trees 16 inches DBH or greater may be retained. Generally, snags to be left would be further than 150 feet from open roads and private land boundaries. Snags that pose a safety hazard to the Contractor’s operation would be removed.

Retention of Down The minimum retention for down woody material will be approximately 10 tons SILV, WB, SP, Pre- and Post- Woody Material for per acre, where available. To achieve the tonnage required, retain (where it SA, TP Sale, During Down Woody Habitat exists) down woody material which includes the longest material available Harvest Associated Wildlife (e.g.,16 feet long or longer) and retain the woody debris with the largest Activities Species diameters available (e.g., 15 inches DBH or greater), sufficient to achieve the tons per acre. Pre- and Post- Hardwood Retention All hardwood trees will be reserved where feasible. SILV, SA, TP, Sale, During for Associated SP Wildlife Species Harvest Activities

Public Safety Contracts would require the contractor to clearly post signs warning the public SA, DRM Pre- and Post- of nearby activities and truck hauling traffic associated with the treatments. Sale, During Harvest Activities

Appendix 2-4 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date Pre-Sale, Public Safety The District Assistant Fire Management Officer (Fuels) or designated liaison FAFMO During Harvest would notify nearby landowners prior to fuel reduction activities commencing on NFS lands that are adjacent to their properties. Activities

Special Use Permits All permitted improvements, including power and phone service lines and SA, TMC, IF, Pre- and Post- water transmission lines (authorized by special use permits) would be clearly FMO, SP, RF Sale marked and protected during project implementation. During Harvest Protect Site and Soil All mechanized units that remove commercial products would be logged using SA Productivity designated skid trails. Equipment would occasionally leave the trails to access Activities trees or accomplish other activities. Pre- and Post- Protect Site and Soil Skid trail spacing width must average at least 75 feet in all tractor harvest SA, SP, SS Sale, During Productivity units. The goal is to occupy less than 15 percent of the treatment area including soil disturbance from skid trails, temporary roads and landings Harvest associated with past and proposed activities. Activities

Protect Site and Soil Winter harvest is required to meet the Region 1 soil quality standard and/or SA, SP, SS During Harvest Productivity protect sensitive soils in the following units by alternative: Activities Alternative Winter Tractor Unit Winter CTL/Forwarder Unit Selected 10, 17, 20, 22, 34 2, 5 Alternative Winter logging requires that there be enough snow to prevent muddy water from mixing into the snow where equipment operates. This would require about ten inches of snow. The depth of snow varies with the snow conditions. It takes more dry powder snow than wet dense snow to protect the soil surface. Soils must be frozen enough to prevent deformation of the soil surface where equipment operates. Pre- and Post- Protect Site and Soil All existing roads and skid trails would be reused to the extent feasible unless SA, SP, SS Sale, During Productivity doing so would adversely affect soil, water or other resources. If roads or trails Harvest cannot be reused, their extent and location must be considered when laying out additional skid trails. Activities

Protect Site and Soil Logging would occur when soils are dry as determined by the hand feel SA During Harvest Productivity method (Project Record Exhibit 21). Activities

Appendix 2-5 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date

Protect Site and Soil Sale administrators will monitor soil moisture conditions prior to allowing SA Pre-Sale Productivity equipment to begin operations in summer. This monitoring must be documented in the Timber Sale Daily Report.

Protect Site and Soil All mechanical fuel reduction will be accomplished with excavators. Excavators SA During Harvest Productivity will, to the extent feasible, remain on skid trails. Activities

Protect Site and Soil Prescribed burning prescriptions would be prepared and implemented to not FMO, AFMO Post-Sale Productivity exceed moderate burn severity conditions.

Improve Soil All newly constructed temporary roads and extended log skidding corridors SA, SS, TP, BT, Post-Sale Condition, Protect would be reclaimed after timber harvest is completed or as soon as logistically NWM Fish and Wildlife practical. The reclamation of new temporary roads would include: Habitat, and Protect Re-contouring the entire road template to the natural ground contour Water Quality Where re-contouring is unnecessary, scarify with excavator teeth to a depth equal sufficient to ameliorate the presence of detrimental soil compaction (usually between 2 and 12 inches) Removing any installed culverts or temporary bridges. Installing erosion control features where needed. Revegetation with native shrubs or native seed mix (specified by the Forest Botanist) after soil is replaced as soon as feasible after disturbance to provide for site protection until native species are established. Placing woody material on the template

Improve Soil All temporary roads re-constructed for this project that utilize historic road SA, SS, TP, BT, Post-Sale Condition, Protect templates would be reclaimed by any site-appropriate combination of the NWM Fish and Wildlife following: Habitat, and Protect Water Quality Removing any installed culverts or temporary bridges. Installing erosion control features where needed. Scarification with excavator teeth to a depth equal sufficient to ameliorate the presence of detrimental soil compaction (usually between 2 to 14 inches). Revegetation with native shrubs or native seed mix (specified by the Forest Botanist) after soil is replaced as soon as feasible after disturbance to provide for site protection until native species are established. Placing woody material on the template.

Appendix 2-6 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date

Roads should be reclaimed as soon as access is no longer required, before the close of the project. During Harvest Protect Water Quality Skid Trail crossings of scoured channels will require drainage protection SA measures as required by State BMPs. BMPs will be followed for harvest, Activities temporary road and system road management.

Protect Fish Habitat With the exception of Units 19, 24, 57, 61, and 205; no harvest activity will take SA, SP, FISH, Pre- and Post- and Protect Water place in Riparian Habitat Conservation Areas (RHCAs). Lindbergh Lake is a AFMO Sale, During Quality priority watershed. The RHCAs in Lindbergh Lake Watershed are: Harvest • 300’ from fish-bearing streams Activities • 150’ from perennial, non-fish-bearing streams 100’ from intermittent streams • 150’ from lakes or wetlands greater than 1 acre 50’ from wetlands less than 1 acre • All other watersheds are not priority watersheds. The RHCAs in all other watersheds are: 300’ from fish-bearing streams • 150’ from perennial, non-fish-bearing streams • 50’ from intermittent streams 150’ from lakes or wetlands greater than 1 acre 50’ from wetlands less than 1 acre

Protect Fish Habitat All temporary roads that cross streams will have culverts or temporary bridges SA, FISH, HYD Pre- and Post- and Water Quality installed, there will be no fords. Culverts will be installed when the channel is Sale, During Protection dry (intermittent streams) or the stream will be diverted during low flow periods Harvest (perennial streams). The culvert will be removed during dry or low flow periods Activities with appropriate sediment reduction devices (Straw bales) in place. Stream channels will be reshaped to natural contours after the culvert is removed. All fill material will be removed by equipment from stream channels to restore the natural channel contours after the culvert is removed.

Protect Fish Habitat, Any culverts replaced for BMPs will be adequately sized for 100 year flood FISH, HYD, Pre-Sale BMP Compliance, events. ENG, DRC and Protect Beneficial Uses

Appendix 2-7 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date

Protect Fish Habitat The new culvert on Road #9552 at Meadow Lake outflow will be designed for FISH, HYD, Post-Sale aquatic fish passage and will be sized for 100 year flood event. During project ENG, DRC implementation, the stream will be de-watered at the worksite. Sediment retention devices will be installed immediately below the terminus of the de- watering pipe. This may be either 2 straw bales staked into the streambed or one commercially-manufactured burlap fence called “Sedimat” (provided by the Forest Service). After stream flow is resumed, a hand crew shall shovel out trapped sediments and dispose the straw bales on adjacent ground. If a “Sedimat” is used, the excavator shall remove and dispose the soiled mat.

Protect Fish Habitat The old culvert on temporary Road #12A will be removed (when the stream is FISH, HYD, Post-Sale dry) even though no haul is anticipated on this portion of the road. ENG, DRC

Protect Fish Habitat Mechanical equipment would not utilize Road #79Y if there is any water on the FISH, HYD, During Harvest road. The culverts on this road were removed years ago. When the road is dry, ENG, DRC Activities equipment may use the road. If not, equipment will need to find alternative access across private ground or defer work out of away from any wet area. Prior to Forest Vegetation Prepare detailed site specific silvicultural prescription for all treatment areas SILV Pre-Sale requiring vegetation manipulation Activities

Forest Vegetation Consult with Project Silviculturist where treatment deviations are required SILV, TSA, SP, Pre- and Post- during contract execution, as a result of changed or unidentified conditions that FMO Sale, During materially affect the intended treatment as described in the detailed site Harvest specific silvicultural prescription. As needed, the silvicultural prescription will be Activities modified and re-approved by a Certified Silviculturist.

Forest Vegetation Contractor will take all reasonable care to avoid damage to the roots, bole, and TP, TSA, SILV Pre- and Post- (Leave Tree crown of trees to be reserved from cutting. No more than 5 percent of the trees Sale, During Protection) designated to be reserved should be damaged beyond recovery by the Harvest Contractor’s operations. Any tree damaged beyond recovery, (will die within Activities one year due to damage), can be removed or otherwise treated by the Contractor as instructed by the Forest Service.

Appendix 2-8 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date

Forest Vegetation The minimum retention for down woody material will be approximately 10 tons SILV, SA, TP, Pre- and Post- (Down Woody per acre, where available. To achieve the tonnage required, retain (where it SP Sale, During Material) exists) down woody material which includes the longest material available Harvest (e.g.,16 feet long or longer) and retain the woody debris with the largest ActivitieS diameters available (e.g., 15 inches DBH or greater), sufficient to achieve the tons per acre.

Forest Vegetation In treatment units, where available, a minimum average of 6 snags per acre SILV, SA, TP, Pre- and Post- (Snag Retention) that are 12-20 inches DBH would be left, and all snags greater than 20 inches SP Sale, During would be left. If existing snag densities are below these densities, substitute Harvest live trees would be left. All standing dead cull western larch, ponderosa pine, Activities and Douglas-fir trees 16 inches DBH or greater may be retained. Generally, snags to be left would be further than 150 feet from open roads and private land boundaries. Snags that pose a safety hazard to the Contractor’s operation would be removed.

Forest Vegetation In those areas of Units 66 and 67 which would directly impact the adjacent SILV, SP, Pre-Harvest (Implementation in recreation site or private land, the Project Silviculturist and Presale Forester RS,FS Activities Units 66 and 67) will coordinate layout and prescriptive parameters with the Recreation Staff, Fuels Specialist, and private land owners (if they are interested).

Preserve TES Plant Protect occupied howellia ponds located near haul routes and in treatment SILV, SA, TP, Pre- and Post- Populations and Their units. No vegetation management activities may be conducted within 300 feet SP Sale, During Habitats of occupied howellia ponds. If ground disturbing BMP-related activities occur Harvest within 300 feet to the north and south of these ponds, natural filtration zones, Activities sediment retention structures, or straw bales would be applied to ensure limited sediment deposition into these ponds. No vegetation treatments would occur within 300 feet from occupied ponds. See Project File Exhibit J-84 for specific locations of ponds.

Preserve TES Plant Protect unoccupied howellia ponds located near haul routes and in treatment SP, SA, BT, Pre- and Post- Populations and Their units. No vegetation management activities may be conducted within 300 feet ENG Sale, During Habitats of unoccupied howellia ponds. If ground-disturbing BMP activities occur in the Harvest vicinity of these ponds, natural filtration zones, sediment retention structures, Activities or straw bales would be applied to ensure limited sediment deposition into

Appendix 2-9 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date these ponds. No treatments would occur within 300 feet from unoccupied ponds. See Project File Exhibit J-86 for specific locations of ponds.

Preserve TES Plant Howell’s gumweed occurs in Units 34-37 along Highway 83. Common camas SP, SA, BT, Pre- and Post- Populations and Their occurs in Units 2, 14, 61, 57, 219. Adder’s tongue occurs adjacent to Units 51 Sale, During Habitats and 215. Sites will be flagged by the Forest Botanist or certified botany Harvest technicians ahead of pre-sale prior to implementation to be avoided by Activities equipment and other disturbance.

Preserve TES Plant Several wetlands and ponds support sensitive species in the project area. See SP, SA, BT, Pre- and Post- Populations and Their Project Exhibit J-8 for species information. Avoid all wetlands with all ground- Sale, During Habitats disturbing activities, including lakes, ponds, marshes, fens, and streams. Harvest Establish buffers around wetlands – 150 feet for areas greater than 1 acre and Activities 50 feet for areas less than 1 acre. Buffers should begin where riparian vegetation ends.

Preserve TES Plant If unknown populations of sensitive plants are found during project SILV, SP, TP, Pre- and Post- Populations and Their implementation, they will be evaluated and protected as necessary to retain SP Sale, During Habitats population viability. A contract clause would incorporate this into any timber Harvest sale contract and would specify that the contract would be modified to protect Activities these plants if located. Control Spread and Re-establish vegetation on bare ground created by road decommissioning or SA, BT, DRC Post-Sale Reduce Potential timber harvest activity. Seed landings, decommissioned roads, and roadsides spread of Noxious with soil disturbance with a Montana-Certified grass ground cover (seed mix of Weeds native plants will be specified by the Forest Botanist), as soon as feasible after disturbance to provide for site protection until native species are established. Control Spread and Equipment use associated with timber harvest and road maintenance SA, TP Pre-Harvest Reduce Potential (excluding pickups and trucks used to remove forest products) would be power Spread of Noxious scrubbed or steam cleaned on the undercarriage and chassis before transport Weeds to the project area. This cleaning shall remove all soil, plant parts, seeds, vegetative matter, or other debris that could contain or hold seeds. All subsequent entries of equipment to the project area shall be treated in the same manner as the initial entry. “Off-road equipment” includes all logging and construction machinery, except for log trucks, chip vans, service vehicles, water trucks, pickup trucks, cars, and similar vehicles. Contractors will be required to adhere to C6.351#- Washing Equipment, or similar contract provision which specifies the above washing criteria. Appendix 2-10 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date Control Spread and Spray weeds along designated Forest Road haul routes (prism) and disturbed NWM Post-Sale Reduce Potential areas. Existing roads within the project boundary would be identified for Spread of Noxious noxious weed treatment. Specific roads and mileage to be treated would be Weeds prepared in consultation with the Forest Weeds Coordinator. Road prism is the road and associated toe of the fill to the top of the cut slope, including the running surface and turnouts. However, when a contiguous patch of weeds extends beyond the road prism, it shall be treated via force account or other means. Spraying of appropriate herbicides would occur pre- and post-haul, during the periods from June 1 to July 15 or September 1 to September 30. Pre- and post-haul treatment shall be the responsibility of the contractor and specified in contract clause C6.27#- Noxious Weed Treatment. Roads would be monitored after initial treatment, and future treatments would be the responsibility of the Forest. Treatment of invasive plants would be consistent with the strategy outlined in the Noxious and Invasive Weed Control Environmental Assessment (March 2001). Control Spread and When the use of a temporary road is no longer needed for the project, the first SA, TP Post-Sale Reduce Potential 100 feet where the temporary road or skid trail meets a traveled road should Spread of Noxious be more heavily brushed and blocked with large woody debris to discourage Weeds unauthorized entry and any resulting spread of weeds. Control Spread and The Noxious Weeds Manager or Forest Botanist will, if necessary, provide NWM, BT Post-Sale Reduce Potential noxious weed material to sale administrators and contractors identifying the Spread of Noxious Forest’s target species and recommended control measures. Weeds Protect Heritage Modify contractual requirements to provide for protection of heritage resources SA, ARCH, SP Pre- and Post- Resources and modify the contract to avoid impacts to heritage resource if cultural Sale, During resources are discovered during ground disturbing activities. Harvest Activities Reduce Immediate Units 32, 33, 34, 36, 37, 43, 44, 57, 58, 61, 65, 66, 67, 212, 218 SP, SA, LA Pre-Sale Foreground View • No more than 12 ton per acre of slash (favoring course material) would Effects to Scenery remain within 150’ of road (Highway 83, Lindberg Lake Road and Resources Lindbergh Lake Campground campsites). Slash, root wads, and other debris will be removed, buried, burned, chipped or lopped to a height of 2 feet or less. • Maintain 8” or less stumps (flush cut if feasible) within 150’ of road (Highway 83, Lindberg Lake Road and Lindbergh Lake Campground campsites).

Appendix 2-11 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date • Mask any boundary or leave tree marking that is clearly visible from sensitive viewing locations (Highway 83, Lindberg Lake Road and Lindbergh Lake Campground campsites). It would generally not be necessary to extend this treatment further than about 150 feet from the viewpoints. Other options to • mitigate for this visual impact include using Cut Tree Marking or other methods of designating leave trees - for example using spacing clauses in a stewardship contract, or using removable "tags" to designate leave or boundary trees. • Site landing offset from road to reduce visual impact if feasible. Do not locate landings immediately adjacent to the road unless limited by terrain. Extend short "jump up" road spurs into unit to landings, with vegetative screening between roads and landing location left where possible. • Landing clean up should be more thorough than may ordinarily occur, specifically the burning of the debris in landing piles should be nearly complete, with repiling/reburning occurring if it burned poorly the first time and left unsightly "bones". Slash piles visible from roadside shall be removed or burned upon unit completion. Where new access roads and skid trails meet a primary travel route or trail, they should intersect at a right angle and, given the physical limitations of expected truck traffic, should curve to the extent feasible after the junction to minimize the length of route seen from the primary travel route or trail. Reduce Immediate Units 66 and 67 SP, SA, LA Pre-Sale Foreground View All slash shall be removed within 50’ of campsites. Effects to Scenery Resources Reduce Immediate Units 66, 67, 73, 74 SP, SA, LA Pre-Sale Foreground View All slash shall be removed from trails (Lindbergh Lake Campground and Effects to Scenery Glacier Slough Trail #481). Resources Reduce Immediate Units 73 and 74 SP, SA, LA Pre-Sale Foreground View • Maintain 8” or less stumps (flush cut if feasible) within 50’ of trail (Glacier Effects to Scenery Slough Trail #481). Resources Where new access roads and skid trails meet a primary travel route or trail, they should intersect at a right angle and, given the physical limitations of

Appendix 2-12 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 2- Design Criteria for the Selected Alternative Objective Task Responsibility Due Date expected truck traffic, should curve to the extent feasible after the junction to minimize the length of route seen from the primary travel route or trail.

Reduce Immediate Units 32, 33, 34, 36, and 37) SP, SA, LA Pre-Sale Foreground View As seen from Highway 83, along edge of unit apply transition zones that would Effects to Scenery be left along north and south edge of unit where tree retention would be Resources modified to create a more gradual visual transition of the treated stand to the adjacent stand and soften unit edges. This may mean progressively decreasing the leave tree density in this zone (such as if next to an existing opening) or progressively increasing the leave tree density in this zone (such as if next to a dense uncut forest). *A Forest Service Staff Member trained in Visual Resource Management will review visual Design Criteria with Presale Forester and Sale Administrator before implementation of the project. A portion of the Design Criteria was selected from the Northern Region Scenic Resource Mitigation Menu & Design Considerations for Vegetation Treatments, March 1, 2011.

Appendix 2-13 GLACIER LOON FUELS REDUCTIONAND FOREST HEALTH PROJECT FINAL DECISION NOTICE AND FONSI APPENDIX 3- MONITORING PLAN The following monitoring matrix describes monitoring associated with the Glacier Loon Project and summarizes the purpose, methods, and expected results and uses of the proposed monitoring activities. The Forest Service is currently seeking opportunities for multi- party monitoring of post treatment conditions. Table 3- 1. Summary of Monitoring Activities

When/ Expected Results What Where Why Who Duration and Use Wildlife Monitor temporary Units. Post-Sale. To determine if roads Wildlife Biologist Determine if temporary road reclamation and and skid trails are left road closure potential post sale use in an adequate expectations are of temporary roads condition and to see if correct. and skid trails. they are receiving post sale use. Invasive Plants Monitor the contracted Haul Routes. Post-Sale. To ensure proper COR or Forest Weed Monitor for noxious spraying along the spraying techniques Coordinator. weed acres of haul routes after and compliance with infestation, spraying is completed. the NIWC DN. effectiveness of control, containment, and prevention measures, and spread and existence of new populations of noxious weeds. Forest Roads Monitor and oversee Temporary roads. Throughout duration of Insure road Contracting Officer, Routinely determine temporary road project construction activities Forest Service compliance with construction. implementation. comply with contract Representative, and contract specifications. specifications. Timber Sale Administrator.

Appendix 3-1 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 3- Monitoring Plan

When/ Expected Results What Where Why Who Duration and Use Forest Vegetation Review and Document All or a sample of During sale Ensure compliance Silviculturist. Assure project tree marking and treatment preparation. with NEPA and FS implementation prescription Units. policy. complies with the compliance. NEPA decision. Develop NEPA to SLRD. Prior to contract Ensure layout Presale Forester Assure layout Implementation development. complies with NEPA complies with NEPA crosswalk. decision decision. Review contract prior SLRD. Prior to contract Ensure contract TMO, Presale Assure project to advertisement. advertisement. complies with NEPA Forester, IDT implementation decision members, Line complies with the Officer, Contracting NEPA decision. Officer, TSA, ER Monitor and oversee All treatment units Throughout project Ensure treatment CO, FSR, TSA, HI, Assure compliance vegetation treatments. implementation. activities comply with and with contract contract specifications. Silviculturist. specifications. Conduct post All treatment units. Immediately following Determine how well Silviculturist, Culturist, Determine the treatment surveys to treatment and objectives were met or designated effectiveness of monitor changes in periodically thereafter and gather data Representative. treatments, the need forest structure, as specified in the needed to assess to conduct follow-up composition, and silvicultural possible follow-up treatments, and to insect and disease prescription. treatments. make future treatment conditions and to decisions. determine in the silvicultural prescription was met. Conduct reforestation All regeneration units. First, third, and fifth Determine Silviculturist, Culturist, Assure adequate surveys to determine year after harvest. regeneration success or designated stocking of desired regeneration success and needs. Representative species occurs. and needs.

Appendix 3-2

GLACIER LOON FUELS REDUCTIONAND FOREST HEALTH PROJECT FINAL DECISION NOTICE AND FONSI APPENDIX 4- BEST MANAGEMENT PRACTICES

INTRODUCTION

Federal agency compliance with pollution control is addressed through Section 313 of the Clean Water Act, EO 12580 (January 23, 1987), National Nonpoint Source Policy (December 12, 1984), USDA Nonpoint Source Water Quality Policy (December 5, 1986) and the EPA in their guidance "Nonpoint Source Controls and Water Quality Standards" (August 19, 1987). In order to comply with State and local non-point pollution controls, the Forest Service will apply BMPs to all possible nonpoint sources resulting from management activities proposed in this EA. These BMPs are the Soil and Water Conservation Practices described in the FSH 2509.22. Best Management Practices are the primary mechanism for achievement of water quality standards (EPA 1987). This appendix describes the Forest Service's BMP process in detail, and lists the key Soil and Water Conservation Practices that have been selected to be used in the action alternatives analyzed in this EA. Best Management Practices include, but are not limited to, structural, and non-structural controls, operations, and maintenance procedures. Best Management Practices can be applied before, during, or after pollution-producing activities to reduce or eliminate the introduction of pollutants into the receiving watershed (40 CFR 130.2, EPA Water Quality Standards Regulation). Best Management Practices are usually applied as a system of practices rather than a single practice. They are selected based on site- specific conditions that reflect natural background conditions and political, social, economic, and technical feasibility. The Flathead National Forest emphasizes the application of BMPs “to protect or improve the quality of the water resource” (Forest Plan, page II-40). Practices compiled from the Flathead Drainage 208 Project (May 1980), Flathead National Forest Hydrologic Guidelines (1980), and other sources are listed in the Water and Soils Sections of Chapter II, Forest-Wide Standards portion of the Flathead Forest Plan (pp. II-40 thru II-46). Additional BMPs are listed with the descriptions of individual management areas and in Appendix Q, Landtype Guidelines (pp. Q-1 through Q-9). The Water Standards section further states: “Water quality limits listed in the State Water Quality Standards are coordinated with BMPs” (p. II-40).

ROAD MAINTENANCE ASSOCIATED WITH THE PROJECT

Best Management Practices would be applied on 29.3 miles of haul routes prior to the beginning of logging activities. Completion of BMPs would be required the first season during dry operating conditions. All BMPs required under the Timber Sale Contract would be met following completion of sale activities. As summarized in the following table, road maintenance (application BMPs) would occur on specified road used for haul of commercial products.

Appendix 4-1 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices

Table 4- 1. Road Maintenance Associated with the Project

Road Number Miles Road Number Miles 79 7.80 10741 0.91 561 0.72 11648 0.18 9552 1.00 90240 0.74 9575 0.41 90244 1.80 9578 4.18 91239 0.71 9579 0.69 91240 0.39 9591 2.70 91305 0.47 9773 0.64 10157Y 0.16 9780 0.04 11648B 0.75 10563 0.48 79A 0.33 10566 0.22 79C 0.70 10728 1.26 79L 0.43 10732 0.32 9579C 0.86 Total Miles of Road Maintenance: 29.3

STATE REQUIREMENTS FOR PROTECTION OF WATER QUALITY

Montana State Water Quality Standards require the use of reasonable land, soil, and water conservation practices (similar to BMPs) as the controlling mechanism for nonpoint pollution. The use of BMPs is also required in the MOU between the Forest Service and the State of Montana as part of the agency's responsibility as the designated water quality management agency on NFS lands.

BEST MANAGEMENT PRACTICES IMPLEMENTATION PROCESS

In cooperation with the State, the Forest Service's primary strategy for the control of non-point sources of pollution is based on the implementation of preventive practices (i.e. BMPs). The BMPs have been designed and selected to protect the identified beneficial uses of the watershed. The Forest Service non-point source management system consists of the following steps:

1. BMP SELECTION AND DESIGN

Water quality goals are identified in the Forest Plan. These goals meet or exceed applicable legal requirements including State water quality regulations, the Clean Water Act, and the NEPA. Environmental assessments for projects are tiered to

Appendix 4-2

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices

Forest Plans using the NEPA process. The appropriate BMPs are selected for each project by an ID Team. In each new location, there is flexibility to design different BMPs depending on local conditions and values and downstream beneficial uses of water. The BMP selection and design are dictated by the proposed activity, water quality objectives, soils, topography, geology, vegetation, and climate. Environmental impacts and water quality protection options are evaluated, and alternative mixes of practices are considered. A final collection of practices is selected that not only protect water quality, but also meet other resource needs. These final selected practices constitute the BMPs for the project.

2. BMP APPLICATION

The BMPs are translated into contract provisions, special use permit requirements, project plan specifications, and so forth. This ensures that the operator or person responsible for applying the BMPs actually is required to do so. Site-specific BMP prescriptions are taken from plan-to-ground by a combination of project layout and Resource Specialists (hydrology, fisheries, soils, etc.). This is when final adjustments to fit BMP prescriptions to the site are made.

3. BMP MONITORING

When the resource activity begins (e.g., timber harvest or road building), Timber Sale Administrators, Engineering Representatives, Resource Specialists, and others ensure the BMPs are implemented according to plan. Best Management Practices implementation monitoring is done before, during, and after resource activity implementation. This monitoring answers the question: Did we do what we said we were going to do? Once BMPs have been implemented, further monitoring is done to evaluate if the BMPs are effective in meeting management objectives and protecting beneficial uses. If monitoring indicates that water quality standards are not being met or beneficial uses are not being protected, corrective action will consider the following: • Is the BMP technically sound? Is it really best or is there a better practice that is technically sound and feasible to implement? • Was the BMP applied entirely as designated? Was it only partially implemented? Were personnel, equipment, funds, or training lacking which resulted in inadequate or incomplete implementation? • Do the parameters and criteria that constitute water quality standards adequately reflect human-induced changes to water quality and beneficial uses?

4. FEEDBACK

Appendix 4-3

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices

Feedback on the results of BMP evaluation is both short and long term in nature. Where corrective action is needed, immediate response will be undertaken. This action may include modification of the BMP, modification of the activity, ceasing the activity, or possibly modification of the State Water Quality Standard. Cumulative effects over the long term may also lead to the need for possible corrective actions. Effectiveness of BMPs is based on audit results. Audit results specific to the Swan Lake Ranger District of the Flathead National Forest are on file at the District Office.

BEST MANAGEMENT PRACTICES EFFECTIVENESS

In looking at the effectiveness of BMPs for the Flathead National Forest, it is reasonable to group BMP audit results for the Kootenai and Flathead National Forests together since they have similar soils. Both Forests are dominated by soils formed in the glacial till formed in material weathered from Belt rocks. This material is topped with wind blown volcanic ash from west coast eruptions up to 6000 years ago. Best Management Practice audits have occurred on the Flathead and Kootenai National Forests since 1988. Audits are done to determine if BMPs were properly applied and, if so, if they were effective at maintaining soil and water quality. Since 1988, individual BMPs have been audited or monitored 2,232 times on the Flathead and Kootenai National Forests. They were effective 2,211 times. In order to analyze the results of the BMP audits, they were grouped according to the soil type on which they occurred. The simplest way is to group them by two classes: • Residual soils that formed from the underlying bedrock, or • Soils formed from glacial till. Looking at these soil criteria, BMPs were effective when properly applied on glacial soils 1,585 times out of 1,596 applications. Best Management Practices were effective when properly applied on residual soils 154 out of 156 applications. An additional 480 BMPs were monitored without reference to the soil types on which they are applied. Of these, 472 were effective at protecting soil and water quality. In summary, BMPs were effective 99.3 percent of the time they were properly applied on glacial till soils. Lumping the entire audit results together regardless of their soil types and including the earliest audits that were not specific to soil type, BMPs were effective 99 percent of the time that they were properly applied on the Flathead and Kootenai National Forests.

ITEMS COMMON TO ALL SOIL AND WATER CONSERVATION PRACTICES

1. RESPONSIBILITY FOR IMPLEMENTATION

The Swan Lake District Ranger is responsible for ensuring that all applicable SWCPs are applied and implemented. The Timber Management Assistant is

Appendix 4-4

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices

responsible for ensuring that the objectives of the SWCPs identified in this appendix are incorporated into the Timber Sale Contract by use of the appropriate Timber Sale Contract CT provisions. The Timber Sale Administrator and Engineering Representative/Contracting Officer’s Representative (ER/COR) is responsible for ensuring that contract provisions are properly administered on the ground.

2. MONITORING

The Timber Sale Administrator, ER/COR, Forest Soil Scientist, and Forest Hydrologist, as needed, will monitor the effectiveness of the applied SWCPs. If the practice is not effective in meeting State or Forest Plan Standards, the practice or project activity will be redesigned, rescheduled, or dropped. Feedback of the results of the site-specific SWCP monitoring to the Forest Soil Scientist will ensure that the best practices are incorporated into all projects impacting water quality. This requirement conforms to the objectives of Practice 11.02 - Soil and Water Resource Monitoring and Evaluation.

SITE-SPECIFIC BEST MANAGEMENT PRACTICES

Description of the soil and water conservation practices from the Forest Service Soil and Water Conservation Handbook (FSH 2509.22) will be applied in all alternatives. The location where the practices will be applied is specified in the following table. For a more detailed description of a specific BMP, refer to the Soil and Water Conservation Handbook. Abbreviations used in this table include: COR = Contracting Officer’s SMZ = Streamside Management Representative Zone EA = Environmental Assessment SPS = Special Project Specifications ER = Engineering Representative SWCP = Soil and Water Conservation Practice FMO = Fire Management Officer TSA = Timber Sale Administrator FNF = Flathead National Forest TSC = Timber Sale Contracts IDT = Interdisciplinary Team INFISH = Inland Native Fish Strategy PSF = Pre-Sale Forester RHCA = Riparian Habitat Conservation Area SAM = Sale Area Map

Appendix 4-5

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Table 4- 2. Site-Specific Best Management Practices

Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision 14.01 IV. A- TIMBER SALE All Activities 1. Unit design, IDT has evaluated IDT, PSF N/A N/A C PLANNING - To mitigation, and watershed incorporate soil effects analysis was characteristics and and water done by IDT. estimated response resource 2. TSC will be to proposed considerations prepared by PSF activities. EA into Timber Sale that will include identifies Design Planning. management Criteria to protect constraints and soil and water Design Criteria from resources. Timber EA. sale contracts will 3. Use standard interim include provisions RHCA widths unless to meet water modified through quality, soils, and watershed analysis. other resources as 4. Use exiting skid directed by the trails where feasible. Decision. 14.02 IV. A TIMBER All Activities 1. Cumulative effects Proposed activities IDT N/A N/A HARVEST UNIT analysis and unit were evaluated to DESIGN - To design were estimate the insure that timber performed by IDT. potential watershed harvest unit 2. The prescriptions response. design will secure and unit design are Prescriptions will be favorable consistent with designed to assure conditions of direction outlined in an acceptable level water flow, the considerations of protection for soil maintain water for BMPs. and water quality and soil 3. Use standard interim resources. productivity, and RHCA widths unless Management will reduce soil protect soil/water

Appendix 4-6

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision erosion and modified through values by avoiding sedimentation. watershed analysis. sensitive areas, 4. Use exiting skid adjusting unit trails where feasible. boundaries, adding specific BMPs to meet specific SWCPs, applying mitigation, and applying implementation/effe ctiveness monitoring. 14.03 N/A USE OF SALE All Activities 1. Water courses The IDT will identify IDT, PSF, B(T)1.1 B.1 AREA MAPS identified and water courses to be TSA B(T)6.5 G.5 (SAMs) FOR protected using protected, unit C(T)6.50# K-G.5.0# DESIGNATING SMZ buffers as a boundaries, and C(T)6.4# K-G.4# SOIL AND minimum. other features. WATER 2. Skidding on soil Ground verification PROTECTION when moisture is and preparation of NEEDS - To <18%. SAMs to be delineate the 3. Use designated included in TSC will location of skid trails agreed to be done by PSF. protected areas by TSA. TSA reviews areas and available 4. Use standard of concern with water sources interim RHCA purchaser before and insure their widths unless operations. recognition, modified through proper watershed analysis. consideration, and protection on the ground.

Appendix 4-7

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision 14.04 IV. A- LIMITING THE All Activities 1. Units located on If limited operating IDT, PSF, B(T)6.31 G.3.1 2, B- OPERATION soils sensitive to periods are TSA B(T)6.311 G.3.1.1 1,2 PERIOD OF compaction and/or identified and B(T)6.6 G.6 VI. A TIMBER SALE displacement has recommended C(T)6.6 K-G.6 ACTIVITIES - To been identified. during the analysis C(T)6.316# K-G.3.1.6# minimize soil 2. Designate units by the IDT, the PSF C(T)6.4# K-G.4# erosion, needing harvest on will prepare a sedimentation, frozen or snow contract that and a loss in soil covered ground. includes productivity by 3. All other ground appropriate insuring that the disturbing activities provisions. purchaser will occur during dry, conducts his/her frozen, or snow- operations in a covered conditions. timely manner. 4. Be prepared to suspend operations if conditions change rapidly and when the erosion hazard becomes high. 5. Consult with operators experienced with winter logging techniques. 6. In wet unfrozen soil areas, use tractors or skidders to compact the snow for skid road locations only when adequate snow

Appendix 4-8

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision depth exists. Avoid steeper areas where frozen skid trails be may subject to erosion next spring. 14.05 IV. A- PROTECTION All Activities 1. Unstable landtypes If the NEPA IDT, PSF, C(T)6.316# K-G.3.1.6# B OF UNSTABLE will be identified analysis concluded TSA C(T)6.4# K-G.4# III A- AREAS - To during the planning that soils/geology in 2-4 protect unstable process. the area were areas and avoid 2. Units found to need unstable, BMPs triggering mass further protection will would be designed movements of the use alternative to prevent soil mantle and yarding techniques, irreversible soil and resultant erosion seasonal water effects. and restrictions, and/or sedimentation. unit boundary adjustments. 14.06 II RIPARIAN AREA All Activities 1. Identify areas with or All streams and IDT, PSF B(T)1.1 B.1 DESIGNATION - adjacent to wet wetlands in the B(T)6.5, G.5 To minimize the areas. project area will C(T)6.4# K-G.4# adverse effects 2. Default RHCA comply with FNF C(T)6.41# K-G.4.1# on riparian areas widths will be Forest Plan as C(T)6.50# K-G.5.0# with prescriptions adhered to unless amended by that manage modified through INFISH. The width nearby logging watershed analysis. of the riparian areas and related land SMZ widths will be will be decided disturbance used as a minimum upon by the IDT. activities. if modification is These widths will proposed. be included on the 3. Areas found during SAM, marked on sale layout will be the ground and reported to the Appendix 4-9

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision Hydrologist and included in the afforded the same TSC. protections as those identified earlier. 14.07 IV. A- DETERMINING All Activities 1. Tractor loggable IDT has identified IDT, PSF B(T)1.1 B.1 2 TRACTOR- units have been tractor-loggable B(T)6.42 G.4.2 B-1 LOGGABLE identified during the ground (in C(T)6.4# K-G.4# GROUND - To planning process. conjunction with C(T)6.316# K-G.3.1.6# protect water 2. Those areas found personnel from quality from not to be tractor timber operations) degradation loggable were during caused by tractor designated as transportation and logging ground alternative logging timber sale disturbance. systems or were planning process. dropped form the The results have unit. been used to determine intensity of and restrictions for land disturbance activities. TSC and SAM indicate areas and conditions under which tractors can operate. 14.08 IV. A- TRACTOR All Activities 1. Identify units with IDT has identified IDT, TSA B(T)6.422 G.4.2 B SKIDDING designated or sensitive areas C(T)6.4# K-G.4# DESIGN - To dispersed skid trails. during the planning minimize erosion 2. TSA and purchaser process. The TSA and protect soil agree on proposed will execute the productivity by locations before plan on the ground designing operation. by locating the skid Appendix 4-10

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision skidding patterns trails with the timber to best fit the purchaser or by terrain. agreeing to the purchaser's proposed locations prior to operation. 14.09 IV. A- SUSPENDED Cable Logging 1. Units that have IDT recognizes the IDT, PSF B(T)6.42 G.4.2 2 LOG YARDING Units slopes that are hazards associated C(T)6.4# K-G.4# IN TIMBER unsuitable for or with operating on C(T)6.50# K-G.5.0# HARVESTING - sensitive to ground steep and/or rocky To protect the soil base skidding will slopes. Areas found from excessive be identified. to be of concern will disturbance and 2. Units with sustained use appropriate accelerated slopes >35% will be harvest systems erosion and designated cable that provide for a maintain the harvest units. safe work integrity of the environment and riparian areas and protect natural other sensitive resources. areas. 14.10 IV. A- LOG LANDING All Activities 1. TSA and purchaser TSA must agree to TSA B(T)6.422 G.4.2.2 5,6 LOCATION AND agree on landing landing locations C(T)6.422 K-G.4.2.2 B-4 DESIGN - To locations before proposed by the locate in such a operation. purchaser. way as to avoid 2. Use minimum size Approved landing soil erosion and and least locations will meet water quality excavation the criteria of degradation. needed. minimal size, least 3. No side-cast excavation needed, material into minimum skid roads sensitive areas or necessary, no side- waterways. cast material into Appendix 4-11

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision 4. Install proper sensitive areas, and drainage. have proper drainage. 14.11 IV. A- LOG LANDING All Activities 1. Proper drainage will PSF and TSA PSF, TSA B(T)6.6 G.6 5,6 EROSION be installed and assess what is B(T)6.64 G.6.4 B-4 PREVENTION maintained during necessary to C(T)6.6 K-G.6 AND CONTROL- operation. prevent erosion C(T)6.632# K-G.6.3.2# To reduce erosion 2. Landings will be from landings and C(T)6.633# K-G.6.3.3# and subsequent scarified, seeded, to ensure sedimentation and fertilized upon stabilization. It is up from log landing completion of to the TSA to through the use of harvest activities. request technical mitigating 3. TSA will assess assistance as measures. conditions and take needed. necessary steps to ensure soil and water protection. 14.12 IV. EROSION All Activities 1. Designate units with PSF and TSA sets PSF, TSA A16 A.16 A-C PREVENTION seasonal purchaser's B(T)6.6 G.6 AND CONTROL restrictions. responsibility to B(T)6.64 G.6.4 MEASURES 2. Do not operate prevent soil/water C(T)6.6 K-G.6 DURING THE during wet periods resource damage in C(T)6.601# K-G.6.6.1 TIMBER SALE including spring TSC. TSA ensures C(T)6.316# K-G.3.1.6# OPERATION - To snowmelt and/or that erosion control ensure that the intense or long- is kept current and purchaser's duration rain storms. prevents operation operations shall 3. TSA ensures that when excessive be conducted erosion control is impacts are reasonably to kept current and possible. minimize soil prevents operation erosion. when excessive

Appendix 4-12

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision impacts are possible. 14.13 IV. B- SPECIAL All Activities 1. Waterbar, slash, IDT identifies IDT, TSA C(T)6.601# K-G.6.0.1# 5, 6 EROSION seed, and/or fertilize locations needing C(T)6.32# K-G.6.3.2# PREVENTION skid trails and special stabilization C(T)6.633# K-G.6.3.3# MEASURES ON landings. measures. If any AREAS 2. Rehabilitate such areas are DISTURBED BY constructed skid identified, BMPs HARVEST trails and temporary may be adjusted by ACTIVITIES - To roads. the TSA to meet prevent erosion 3. BMPs may be operational and adjusted by the TSA requirements. sedimentation on to meet operational disturbed areas. requirements. 14.14 IV. REVEGETATION All Activities Seed and fertilize areas IDT has established IDT, TSA C(T)6.01# K-G.6.0.1# B-5 OF AREAS of exposed soil with vegetation and C(T)6.633# K-G.6.3.3# DISTURBED BY FNF approved fertilizer mix to be HARVEST vegetative and fertilizer used in the project ACTIVITIES - To mix. area with outlines establish a on the extent to vegetative cover which it should be on disturbed used. TSA is areas to prevent responsible for erosion and seeing that sedimentation. revegetation work required by purchaser is done correctly and in a timely manner. The purchaser will be responsible for revegetation Appendix 4-13

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision immediately after the completion of harvest. Funds will be collected for the District to do follow- up seeding/fertilizing in years two and three after harvest. 14.15 IV. A- EROSION All Activities 1. Ensure proper skid Erosion control TSA B(T)6.6 G.6 4, 5 CONTROL ON trail location. measures may be B(T)6.65 G.6.5 B- 5, SKID TRAILS - 2. Ensure proper recommended by B(T)6.66 G.6.6 6 To protect water drainage on skid the IDT, but site C(T)6.6 K-G.6 quality by trails. specifically adjusted C(T)6.633# K-G.6.3.3# minimizing 3. Rehabilitate by the TSA. TSA erosion and constructed skid will ensure erosion sedimentation trails and temporary control measures derived from skid roads. are applied prior to trails. 4. Ensure maintenance expected hydrologic of erosion control events (spring structures by runoff, high- purchaser. intensity storms, etc.). Maintenance of erosion control structures by the purchaser may be necessary and requested by the TSA. 14.16 IV. B- WET MEADOW All Activities 1. Identify units with or IDT has identified IDT, PSF, B(T)1.1 B.1 2 PROTECTION adjacent to wet areas needing TSA B(T)6.422 G.4.2.2 DURING TIMBER meadows. special protection. B(T)6.61 G.6.1 Appendix 4-14

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision HARVESTING - 2. Units with PSF will verify the C(T)6.4# K-G.4# To avoid damage unmapped wet areas needing C(T)6.62# K-G.6.2# to the ground areas will be protection and cover, soil, and reported to prepare the water in Hydrologist and contract to prevent meadows. afforded the same damage to protection as those meadows. The TSA identified during the will be responsible planning process. for on-the-ground 3. Standard interim protection of RHCA widths will be meadows. If adhered to unless meadows are found modification is in by the TSA during place. operations, it is 4. SMZ law will be met their responsibility or exceeded. to either afford them the proper protection or pursue a contract modification. 14.17 V. A- STREAM All Activities 1. Standard interim IDT has identified IDT, PSF, B(T)1.1 B.1 C CHANNEL RHCA widths will be the location of TSA B(T)6.5 G.5 PROTECTION adhered to unless channels in the B(T)6.6 G.6 (IMPLEMENTATI modification is in decision area. PSF C(T)6.50# K-G.5.0# ON AND place. will prepare a SAM C(T)6.6 K-G.6 ENFORCEMENT) 2. SMZ widths will be locating the - Protect natural used at a minimum if channels needing stream flows; modification in protection. Layout provide place. crew marks unobstructed 3. SMZ law will be met boundaries and passage of flows; or exceeded. trees according to reduce sediment HB-731 and FP

Appendix 4-15

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision input; and restore guidelines. TSA will flow if diverted by see that TSC items timber sale are carried out on activity. the ground. Technical assistance will be consulted as needed. 14.18 IV. EROSION All Activities 1. During the period of During the period of TSA B(T)6.66 G.6.6 A-C CONTROL the TSC, the the TSC, the B(T)6.67 G.6.7 STRUCTURE purchaser is purchaser is MAINTENANCE - responsible for responsible for To insure that maintaining their maintaining their constructed erosion control erosion control erosion control features. features. If work is structures are needed beyond this stabilized and time, the District will working pursue other effectively. sources of funding. 14.19 IV. ACCEPTANCE All Activities 1. TSA reviews erosion A careful review of TSA B(T)6.36 G.3.6 A-C OF TIMBER prevention work erosion prevention SALE EROSION before each harvest work will be made CONTROL unit is considered by the TSA before MEASURES complete. each harvest unit is BEFORE SALE 2. The inspection will considered CLOSURE - To determine if the complete. The assure the work is acceptable inspection will adequacy of and will meet the determine if the required erosion objective of the work is acceptable control work on erosion control and will meet the timber sales. feature. objective of the erosion control

Appendix 4-16

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision feature. A feature is considered not acceptable if it does not meet standards or is not expected to protect soil/water values. Technical assistance will be used as necessary. 14.20 IV. C SLASH All Activities 1. Where harvest is All activities will TSA, FMO B(T)6.5 G.5 TREATMENT IN proposed within comply with the B(T)6.7 G.7 SENSITIVE riparian areas, either FNF Forest Plan as C(T)6.50# K-G.5.0# AREAS - To slash should be amended by C(T)6.7 K-G.7# protect water removed with the INFISH. Where C(T)6.71 K-G.7.1 quality by tree or scattered and harvest within C(T)6.753 K-G.7.5.3 protecting not treated. riparian areas is sensitive tributary 2. Mechanical fuels proposed, either the areas from treatments should slash would be degradation that not be used on removed with the would result from sensitive land types. tree or scattered using mechanized and not treated. equipment for slash disposal. 14.22 N/A MODIFICATION All Activities Environmental If TSC is not TSA B(T)8.33 i.3.3 OF THE TSC - To modification procedure. adequate to protect modify the TSC if soil/water new resources, the TSA circumstances or and Contracting conditions Officer are indicate the responsible for timber sale will recommending cause irreversible

Appendix 4-17

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision damage to soil, modification of the water, or TSC. watershed values. 15.01 III. A- GENERAL All Roads 1. Complete a roads The IDT has IDT, ER N/A E GUIDELINES analysis. evaluated FOR 2. Transportation plans watershed TRANSPORTATI include installation characteristics and ON PLANNING - and maintaining estimated the To introduce soil proper drainage. response of soil and water and water resource resources to considerations proposed into transportation transportation planning. alternatives and activities. 15.02 III. A- GENERAL New Road and 1. Follow INFISH The IDT has IDT, ER B GUIDELINES Trail Standards and ensured that the FOR THE Construction Guidelines for road location and design LOCATION AND management. of roads and trails DESIGN OF 2. Identify sensitive are based on ROADS AND land types, riparian multiple resource TRAILS - To areas, and wetlands objectives. locate and design during planning. Mitigation roads and trails 3. Use the minimum measures have with minimal soil amount of roads and been designed to and water impact trails necessary. protect the soil and while considering water resources all Design identified in the Criteria. NEPA process. Contract provisions will be prepared by the ER that meets

Appendix 4-18

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision the soil and water resource protection requirements. 15.03 III. A- ROAD AND New Road and 1. Seed and fertilize IDT has established IDT, ER B(T)6.31 G.3.1 E TRAIL EROSION Trail disturbed areas. soil/water B(T)6.312 G.3.1.2 CONTROL PLAN Construction 2. Install proper conservation B(T)6.6 G.6 - To prevent, limit, ditching and road objectives and C(T)6.601# K-G.6.0.1# and mitigate slope. mitigation erosion, 3. Install proper measures. ER will sedimentation, drainage. then prepare a and resulting 4. Incorporate road contract that water quality grade breaks. reflects the degradation prior 5. Use minimum road objectives. ER will to the initiation of or trail length/width see that erosion construction by necessary. control measures timely 6. Avoid wet areas or are approved and implementation of areas of sensitive completed in a erosion control soil types. timely manner. IDT practices. reviews projects to check effectiveness of erosion control features. 15.04 III. D TIMING OF New Road and Avoid construction IDT has outlined IDT, ER B(T)6.31 G.3.1 1, 4 CONSTRUCTION Trail during wet periods. detailed erosion B(T)6.312 G.3.1.2 ACTIVITIES - To Construction control measures in B(T)6.6 G.6 minimize erosion NEPA process. ER SPS 204 by conducting puts these operations during measures into minimal runoff contract provisions. periods. Compliance is assured by

Appendix 4-19

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision Contracting Officer or ER. 15.05 III. A- SLOPE New Road and 1. Avoid construction Road and trail IDT, ER N/A N/A E STABILIZATION Trail across unstable construction in AND Construction areas. mountainous terrain PREVENTION 2. Construct requires cutting and OF MASS embankments loading natural FAILURES - To following approved slopes which may reduce engineering lead to landslides sedimentation by practices. and/or embankment minimizing the 3. Use minimum road failures. In areas chances for road- or trail length/width with intrinsic slope related mass necessary. stability problems, failures, including appropriate landslides and technical resource embankment personnel must be slumps. involved in an interdisciplinary approach to route location. 15.06 III. A- MITIGATION OF All Haul Roads 1. Seed and fertilize IDT has outlined IDT, ER SPS 203, F.3 E SURFACE cut and fill slopes. detailed erosion 204, 206A G.6 EROSION AND 2. Install proper control measures in 210, 412 G.6.3 STABILIZATION ditching and road the NEPA process. 619, 625, G.6.6 OF SLOPES - To slope. Stabilization 626 630 G.3.1.2 minimize soil 3. Install proper techniques are B(T) K-F.3.1.4# erosion from road included in contract drainage. 5.3 B(T)6.6 K-G.6 cut slopes, fill provisions. 4. Incorporate road B(T)6.63 K-G.6.0.1# slopes, and travel grade breaks. Compliance is B(T)6.66 ways. 5. Install ditch relief assured by B(T)6.312 culverts before/after Contracting Officer C(T)5.314# or ER. stream crossings. C(T)6.6 Appendix 4-20

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision C(T)6.601# 15.07 III. E- CONTROL OF All Haul Roads 1. Avoid long, steep IDT has identified ER B(T)5.3 F.3 2 PERMANENT grades. locations, Design B(T)6.6 G.6 ROAD 2. Maintain adequate Criteria, drainage C(T)5.31# K-F.3.1# DRAINAGE - To surface drainage. control features, C(T)6.6 K-G.6 minimize the 3. Prevent erosion of and mitigation. erosive effects of culvert fills. Compliance will be concentrated 4. Maintain ditches. assured by the water and 5. Ditch relief culverts ER/Contracting degradation of before/after stream Officer. water quality by crossings. proper design and construction of road drainage systems and drainage control structures. 15.08 III. D PIONEER ROAD New Road and 1. Ensure stable ER/Contracting ER B(T)5.23 F.2.3 CONSTRUCTION Trail slopes during Officer will be B(T)6.31 G.3.1 - To minimize Construction construction. responsible for B(T)6.311 G.3.1.1 sediment 2. Seed and fertilize enforcing contract B(T)6.312 G.3.1.2 production and exposed soil. specifications. The B(T)6.6 G.6 mass wasting 3. Avoid construction purchaser is C(T)6.601# K-G.6.0.1# associated with responsible for during wet periods. SPS 204 pioneer road 4. Use slash filter submitting an construction. windrows. operating plan that includes erosion control measures. 15.09 III. E- TIMELY All Road 1. Avoid construction IDT has identified IDT, TSA B(T)5.23 F.2.3 7,8 EROSION Construction, during wet periods. project location and B(T)6.31 G.3.1 CONTROL Reconstruction, 2. Use slash filter mitigation B(T)6.6 G.6 MEASURES ON windrows or silt fence. measures in NEPA Appendix 4-21

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision INCOMPLETE and 3. Seed and fertilize process. Protective B(T)6.66 G.6.6 ROADS AND Maintenance disturbed areas. measures will be C(T)6.6 K-G.6 STREAM kept current on all C(T)6.601# K-G.6.0.1# CROSSING areas of disturbed, PROJECTS - To erosion-prone minimize erosion areas. TSA ensures of and contract sedimentation compliance. from disturbed ground on incomplete projects. 15.10 III. D- CONTROL OF All Road 1. Do not side-cast into IDT has identified IDT, TSA B(T)5.3 F.3 8 ROAD Construction, waterways or project location and C(T)5.31# K-F.3.1# CONSTRUCTION Reconstruction, sensitive areas. mitigation SPS 203 , EXCAVATION, and 2. Use slash filter measures in NEPA SPS 204 AND SIDE-CAST Maintenance windrows or silt process. Protective MATERIAL - To fence. measures will be reduce kept current on all sedimentation areas of disturbed, from erosion-prone unconsolidated areas. TSA ensures excavated and contract side-cast material compliance. caused by road construction, reconstruction, or maintenance. 15.11 VII. SERVICING AND All Activities 1. Ensure proper fuel ER/TSA/Contractin ER, TSA B(T)6.222 G.2.2.2 A- 1,2 REFUELING storage and g Officer will B(T)6.34 G.3.4 EQUIPMENT - To transportation. designate the B(T)6.341 G.3.4.1 prevent location, size, and

Appendix 4-22

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision contamination of 2. Keep fuel from uses of service waters from streams, wetlands, refueling areas. All accidental spills ponds, and lakes. projects will adhere of fuels, to the FNF lubricants, Hazardous bitumens, and Substance Spill other harmful Plan in case of materials. accidents. 15.12 III A. CONTROL OF New Road and 1. Follow INFISH Proposed new and ER, TSA B(T)6.5 G.5 4 CONSTRUCTION Temporary Standards and temporary roads B(T)6.62 G.6.2 IN RIPARIAN Road Guidelines for will adhere to C(T)6.50# K-G.5.0# AREAS - To Construction construction within guidelines in the SPS 206 minimize the riparian areas. Montana SPS 206A adverse effects 2. Use slash filter Streamside on riparian areas windrows or silt Management Zone from roads. fence. Law (HB-731). All 3. Install ditch relief road activities will culverts and surface follow INFISH water deflectors Standards and before/after stream Guidelines for road crossings. management. 15.13 V. C- CONTROLLING All Road 1. Use silt fence to BMP improvements ER, TSA B(T)6.5 G.5 1 IN-CHANNEL Construction, minimize introduced at crossings would SPS 204 EXCAVATION - Reconstruction, sediment adhere to the SPS 206 To minimize and 2. Use minimum guidelines in 206A stream channel Maintenance amount of road. Montana disturbances and 3. Construct minimum Streamside related sediment number of Management Zone production. crossings. Law (HB-731) and the INFISH Standards and

Appendix 4-23

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision Guidelines for road management. 15.14 V. A, DIVERSION OF All Work at 1. Divert stream flow The IDT has IDT, ER B(T)6.5 G.5 C FLOWS Stream around construction. determined, where B(T)6.31 G.3.1 AROUND Crossings 2. Use silt fence to stream crossings C(T)6.50# K-G.5.0# CONSTRUCTION minimize introduced meet multiple C(T)6.6 K-G.6 SITES - To sediment. resource objectives, minimize 3. Construction during the crossings would downstream low-flow. require a State 124 sedimentation by permit. This would insuring all require the State stream diversions Fish, Wildlife, and are carefully Parks to review the planned. adequacy of the proposed mitigation. Compliance with contract provisions would be done by the ER. 15.15 V. A- STREAM All Roads 1. Consult Hydrologist The IDT identifies PSF, ER, N/A C CROSSINGS ON on placement of areas in need of a TSA TEMPORARY crossing. temporary road ROADS - To keep 2. Use minimum during the NEPA temporary roads number of stream process. Proposed from unduly crossings. stream crossings damaging 3. Construct during would adhere to the streams, low-flow. guidelines in disturbing 4. Follow INFISH Montana channels, or Standards and Streamside obstructing fish Guidelines for Management Zone passage. Law (HB-731).

Appendix 4-24

Appendix 4-25

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision 15.18 III. D- DISPOSAL OF All Road 1. Debris and slash Proposed road ER Std Spec 8 RIGHT-OF-WAY Construction, generated during construction will 201 AND ROADSIDE Reconstruction, road construction adhere to the SPS 201 DEBRIS - To and should not be side- guidelines in the insure that debris Maintenance cast into streams. Montana generated during Streamside road construction Management Zone is kept out of Law (HB-731). streams and prevent slash and debris from subsequently obstructing channels. 15.19 III. A STREAM BANK All Road 1. Take precautions to IDT has identified IDT, ER, Std Spec PROTECTION – Construction, minimize or project location and TSA 619 To minimize Reconstruction, eliminate mitigation sediment and disturbance to measures during production from Maintenance stream banks. NEPA process. stream banks and 2. Maintain in-stream Protective structural structures. measures will be abutments in kept current on all natural areas of disturbed waterways. soils. TSA and ER ensure contract compliance. 15.20 N/A WATER N/A N/A N/A ER, FMO Std Spec SOURCE 207 DEVELOPMENT CONSISTENT WITH WATER QUALITY Appendix 4-26

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision PROTECTION - To supply water for road construction and maintenance and fire protection while maintaining water quality. 15.21 III. E MAINTENANCE All Road Maintain all roads in a Road maintenance ER, TSA B(T)5.12 F.1.2 OF ROADS - To Construction, manner that provides associated with a B(T)5.3 F.3 maintain all roads Reconstruction, for soil and water timber sale is the B(T)6.6 G.6 in a manner that and protection. responsibility of C(T)6.6 K-G.6 provides for soil Maintenance purchaser. The C(T)5.31# K-F.3.1# and water ER/TSA will ensure protection by that the purchaser minimizing rutting, maintains roads failures, side-cast, according to the and blockage of appropriate drainage facilities. maintenance level. 15.22 III. E- ROAD SURFACE All Haul Roads 1. Maintenance of road Protective IDT, ER B(T)5.3 F.3 1 TREATMENT TO surface should measures will be C(T)5.31# K-F.3.1# PREVENT LOSS include proper kept current on all C(T)5.314# K-F.3.1.4# OF MATERIALS - blading and/or dust areas of disturbed, To minimize the abatement. erosion-prone erosion of road 2. Use crush-gravel areas. ER ensures surface materials where necessary. contract and, compliance. consequently, reduce the likelihood of sediment production.

Appendix 4-27

Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 4- Best Management Practices Standard Stewardship TSC Mt Applicable Recommended BMPs Considerations for Person(s) SWCP Objective Contract Contract SWCP BMP Units/ Roads By IDT/TSA BMPs Responsible Provisions Provision 15.23 III. E- TRAFFIC All Haul Roads Avoid hauling during Road restrictions ER, TSA B(T)6.6 G.6 6 CONTROL wet periods. and traffic control C(T)6.6 K-G.6 DURING WET measures will be C(T)5.316# K-F.3.1.6# PERIODS - To implemented on all C(T)5.41# K-F.4.1# reduce the haul roads when potential for road damage would surface occur during spring disturbance breakup. The during wet decision to restrict a weather and road is made by the reduce ER. Hauling sedimentation. restrictions would be controlled by the TSA. 15.24 III.E-4 SNOW All Winter Haul 1. Be careful not to Snow removal will IDT, TSA C(T)5.316# K-F.3.1.6# VI. A- REMOVAL Roads leave snow berm at be kept current on Std Spec B CONTROLS - To edge of road. all roads associated 203.09 minimize the 2. Ensure proper with winter logging impact of snow drainage by opening operations. The melt on road sections of berm to TSA ensures surfaces and allow water to leave compliance with embankments road surface. contract provisions. and reduce the 3. Ensure no side cast probability of material enters sediment waterways. production 4. Consider hauling resulting from only during frozen snow removal periods. During cold operations. weather, plow any snow cover off the roadway to facilitate

Appendix 4-28

Appendix 4-29

Appendix 4-30

GLACIER LOON FUELS REDUCTIONAND FOREST HEALTH PROJECT FINAL DECISION NOTICE AND FONSI APPENDIX 5- RESPONSE TO COMMENTS Seven letters were received that commented on aspects of the Supplemental Environmental Assessment dated July 2017. This section provides a summary of the comments received and responses to those comments. The comments and responses have been organized according to comment subject matter: Aquatics ...... 5-2 Climate Change ...... 5-7 Economics ...... 5-9 Fire/Fuels ...... 5-10 General/Other ...... 5-16 Invasive Plant Species ...... 5-25 Old Growth ...... 5-27 Roadless ...... 5-37 Soils ...... 5-38 Transportation ...... 5-40 Vegetation ...... 5-41 Vegetation: Water Howellia ...... 5-43 Wildlife: Grizzly Bears ...... 5-44 Wildlife: Snags ...... 5-55 Wildlife: Flammulated Owl ...... 5-60 Wildlife: Canada lynx and lynx critical habitat ...... 5-61 Wildlife: Fisher ...... 5-74 Wildlife: Wolverine ...... 5-77 Wildlife: Ungulates ...... 5-79 Where similar comments were received, a single response was provided for multiple comments or representative comments were chosen for a single response. At the end of each comment is a reference to a “BB” letter number. The comment letter that it corresponds to each respective commenter as follows: BB-1: Dan Stone BB-2: Jessy Coltrane, Leo Rosenthal, Montana Fish, Wildlife and Parks BB-3: Pat O’Herren, Missoula County Community and Planning Services BB-4: Keith Hammer, Swan View Coalition BB-5: Arlene Montgomery, Friends of the Wild Swan BB-6: Michael Garrity, Alliance for the Wild Rockies BB-7: Sarah Johnson, Native Ecosystems Council

Appendix 5-1 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

AQUATICS

Comment: The EA does not characterize or evaluate the project area watersheds based on the Watershed Condition Framework or the baseline condition developed for bull trout. (BB-5) (BB-6)

Response: The Watershed Condition Framework was a 2011 national prioritization effort to identify watersheds needing restoration. It is not intended as an analysis tool or measurement indicator. The 2011 Watershed Condition Framework classified each watershed for health or integrity into three possible categories: Class 1 – Functioning Properly Class 2 – Functioning at Risk Class 3 – Impaired Function. As described in the project’s 2013 Decision Notice, Appendix 5, Response to Comments E- 10, all watersheds in the Glacier Loon project area are classified as “Functioning Properly”. The baseline condition for bull trout is disclosed in the bull trout Biological Assessment (Project File Exhibit Z-2). In summary, baselines are not considered adverse or “functioning at unacceptable risk”. This information was utilized in the determination of “May Affect, not likely to Adversely Affect” for bull trout and bull trout critical habitat. The US Fish and Wildlife Service concurred with this determination (Project File Exhibit Z-5).

Comment: Logging will take place in Riparian Habitat Conservation Areas (RHCA) which is not consistent with INFISH. The EA does not disclose why there is only a 150 foot RHCA on Lindbergh Lake. (BB-5)

Response: As reviewed in the Fisheries Analysis, approximately 4.3 to 6.4 acres of harvest is proposed (varies by alternative) within RHCA uphill of roads. The Inland Native Fish Strategy (INFISH) does allow timber management in RHCA where appropriate (Standard TM-1b). However silvicultural practices can only take place when they do not retard attainment of Riparian Management Objectives are met. As noted on page 3-215 in the supplemental EA, INFISH also requires (for non-priority watersheds such as where the activity is proposed) a site specific analysis of how the silvicultural practices comply with INFISH. This site-specific analysis is provided in project file exhibit N-9. Lindbergh Lake is an 815 acre lake. All lakes larger than 1 acre have a 150 feet RHCA buffer (page 2-42, supplemental EA). Thus the Lindbergh Lake 150 foot RHCA buffer is not considered unusual or deficient. As reviewed on page 3-206 of the supplemental EA, a 150 foot buffer precludes any sediment from the harvest areas from reaching the lake.

Comment: BMPs fail to protect and improve water quality because of the allowance for “naturally occurring degradation.” In Montana, “naturally-occurring degradation” is

Appendix 5-2 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

defined in ARM 16.20.603(11) as that which occurs after application of “all reasonable land, soil and water conservation practices have been applied.” In other words, damage caused directly by sediment (and other pollution) is acceptable as long as BMPs are applied. The result is a never-ending, downward spiral for water quality and native fish…..The downward spiral continues with disastrous cumulative effects on bull trout, westslope cutthroat trout and most aquatic life. BMPs are not “reasonable.” Clearly, beneficial uses are not being protected. In Montana, state water quality policy is not being followed. § 75-5-101 et seq. and ARM 16.20.701 et seq. (BB-5)

Response: As described on page 3-155, the Forest Service has gone beyond the “voluntary” nature of best management practices (BMP) and now makes it standard practice. Auditing of recent Flathead National Forest BMP work found it to be effective in conserving water quality 99.3 percent of the time (Project File Exhibit M-3). The supplemental EA also reviews how BMP application from other recent projects within area watersheds have substantially reduced chronic road erosion (pages 3-201 and 203, supplemental EA). This certainly does not match your characterization of a “never- ending, downward spiral”. The supplemental EA never purports that damage is acceptable as long as BMP are applied. Rather the supplemental EA provides a careful review of all BMP and their location (both vegetation management and transportation management). Transportation BMP are especially detailed for their short-term impacts and long-term effectiveness to curtain sedimentation in streams on supplemental EA pages 3-167, 169, 171, 173-174, 203, 205, 208-213. The cumulative effects to bull trout and westslope cutthroat trout are reviewed in the Fisheries analysis (pages 3-204 to 216, supplemental EA). As reviewed in the Hydrology analysis, all beneficial uses are maintained (pages 3-181 to 182, supplemental EA). The project complies with all state and federal water quality regulations (pages 3-181 to 182, supplemental EA).

Comment: The Ninth Circuit Court of Appeals recently ruled that sediment from culverts and ditches on Forest Service roads are a point source pollutant and require a permit a NPDES from the E.P.A. Do you have this permit? The analysis for whether there are such culvert and ditch point sources in the project area must be done before the project is approved so that the public can be engaged and notified of the process. (BB-6)

Response: The EPA has determined not to regulate stormwater discharges from forest roads for regulation under the Clean Water Act, Section 402(p)(6), as noted in 2016 Federal Register Vol 81.No 128. 43492-43510. Therefore, NPDES permitting is not required. However, even though NPDES permitting is irrelevant, the EA discloses information on the existing sedimentation from Forest Service roads on supplemental EA pages 3-195 to 196, 3-198 to 199, 3-200 and 3-201.

Comment: The EA failed to analyze the effects to wetlands and wetland complexes. Temporary roads will contribute sediment to wetlands. Roads are already within 300 feet of wetlands. Seedtree and commercial thin logging will occur around wetlands and

Appendix 5-3 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

the wetland complex in Section 12 as will temporary road construction yet there is no analysis of how this will affect the hydrology of the wetlands or whether it will dry them out. Sediment from road construction will settle out in some wetlands yet there is no analysis of how this will affect their integrity. The EA failed to analyze whether this project will minimize the destruction, loss or degradation of wetlands. Or how it will enhance the natural and beneficial values of wetlands as required under EO 11990. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted in the project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #14 and #15, the requested analysis was displayed in the EA in various places. Although wetlands are not itemized in a stand-alone analysis, the supplemental EA discloses effects of the project to wetlands in numerous places in Hydrology and Threatened and Sensitive Plant Species analysis. As noted on supplemental EA page 2-22, the project does not construct any roads within RHCA buffers by wetlands. RHCA buffers by wetlands vary from 50 feet for wetlands less than an acre, 150 feet for wetlands larger than an acre and 300 feet for wetlands that contain Howellia aquatilis or their potential habitat (page 2-42 and 2-43, supplemental EA). Only 4.3 to 6.4 acres of vegetation management (varies by alternative) is proposed within these wetland RHCA (none of the acres are water howellia occupied or unoccupied ponds). Supplemental EA pages 3-109, 3-167, 3-169, 3-171, 3-174, disclose a small amount of sediment delivery to a few wetlands is possible due to timber haul on existing roads within RHCA, the removal of a culvert on temporary road 12A, and temporary culvert installation on temporary roads 15C, 24A and 36C that cross inlet channels. Supplemental EA pages 3-107 note how the vegetation treatment will not affect the wetland hydrology. Supplemental EA pages 3-175 and Project File Exhibit N-9 detail how the vegetation treatment would not cause sedimentation to wetlands, even those within wetland RHCA and meet INFISH objectives. Supplemental EA page 3-170 notes how Resource Enhancement Project #1 would restore an inlet stream to a wetland which in turn benefits the wetland’s hydrography. The supplemental EA concludes that wetland resources are adequately protected and comply with EO 11990 (page 3-182, supplemental EA).

Comment: We request a careful analysis of the impacts to fisheries and water quality, including considerations of sedimentation, increases in peak flow, channel stability, risk of rain-on-snow events, and increases in stream water temperature. Please disclose the locations of seeps, springs, bogs and other sensitive wet areas, and the effects on these areas of the project activities. Where livestock are permitted to graze, we ask that you assess the present condition and continue to monitor the impacts of grazing activities upon vegetation diversity, soil compaction, stream bank stability and subsequent sedimentation. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted in this project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #141, the EA discloses this information. A comprehensive analysis of

Appendix 5-4 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

impacts to fisheries and hydrology starts on supplemental EA page 3-149 and concludes on page 3-216.

Comment: Please disclose in the NEPA document the results of up-to-date monitoring of fish habitat and watershed conditions and how this project will affect the fish in the project area. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted in the project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #142, the EA discloses this information. The current condition of fish habitat is disclosed on supplemental EA pages 3-185 to 3-195. The current conditions of hydrology measurement indicators are disclosed on supplemental EA pages 3-153 to 3-162. The analysis of how the action alternatives could impact native fish in the project area begins on supplemental EA page 3-203 and concludes on page 3-216.

Comment: It is extremely important the FS disclose the environmental baseline for watersheds. Generally, this means their condition before development or resource exploitation was initiated. For example, the baseline condition of a stream means the habitat conditions for fish and other aquatic species prior to the impacts of road building, logging, livestock grazing, etc. Therefore, proper disclosure of baseline conditions would mean estimates of stream stability, pool frequency conditions, and water temperature range— essentially the values of Riparian Management Objectives along with such parameters as sediment levels. When such information is provided, comparison with the current conditions (after impacts of development) will aid in the assessment of cumulative effects of all alternatives. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted in the project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #143, the EA discloses the existing (baseline) condition of aquatic resources. Baseline data prior to any development (circa 1880) does not exist. However a landscape assessment prepared by the Swan Ecosystem Center does provide some historic characterization of geology, hydrology and fisheries resources of the project area (Project File Exhibit T-4). As reviewed on supplemental EA page 3-184, the oldest available quantifiable data is 1972. In lieu of historic quantifiable data, the Fisheries and Hydrology analyses disclose the existing condition of those attributes that could be affected by the project, specifically water quantity, channel stability, sedimentation (water quality), fish habitat complexity, fish barriers and native species. Pool frequency and water temperature could not be affected by the project and thus not reviewed (Project File Exhibit N-10). The Fisheries and Hydrology analyses also describe how past land management actions may have impacted aquatic resources and review any direct or indirect effects of this project. These factors are the basis of cumulative effects analysis. The descriptions of all information sources, measurement indicators, existing conditions, environmental consequences and cumulative effects for hydrology and fisheries begin on supplemental EA page 3-149 and conclude on page 3-126.

Appendix 5-5 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Comment: Please disclose the link between current and cumulative soil disturbance in project area watersheds to the current and cumulative impacts on water quantity and quality. Please disclose if there are any WQLS streams or TMDL streams in the project area. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted repeatedly in the project’s first Decision Notice (2013), Appendix 5, Response to Comments E-11 #32, #68, and #149, there are no streams in the project area considered impaired on Montana 303(d) list and no TMDL is needed. This is also disclosed in the supplemental EA on page 3-161. Furthermore, as noted in previous Responses to Comments, RHCAs and BMPs prevent most soil disturbing activities from resulting in any sediment delivery to a water body. Both the Fisheries and Hydrology analysis disclose potential impacts of sediment delivery to water bodies. Another mechanism whereby soil disturbance could affect water quality is through soil compaction affecting infiltration and runoff patterns. The greatest potential is from forest roads. On supplemental EA pages 3- 165 to 166, the hydrology analysis considered the impact of forest roads to water quantity in the ECA modeling.

Comment: Disclose the baseline condition, and expected sedimentation during and after activities, for all streams in the area. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). As noted in the project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #105, the EA discloses the page numbers where baseline conditions for hydrology were discussed. Both the Fisheries and Hydrology analyses review the baseline conditions and potential sediment delivery caused by the projects. The Hydrology analysis reviews sediment delivery (called Water Quality) for each analysis area and each alternative from Supplemental EA page 3-152 to 3-180. The Fisheries analysis reviews sedimentation in streams (the end product of sediment delivery) for each analysis area and each alternative from supplemental EA page 3-185 to 3-214.

Appendix 5-6 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

CLIMATE CHANGE

Comment: The EA does not include an analysis of climate change and how that will impact the project. (BB-5)

Response: Climate change is mentioned in several places in the supplemental EA; page 3- 96, 3-100, 3-187, 3-284, 3-287, and 3-325. Additionally, the Forest Carbon Cycling and Storage Report (Project File Exhibit T-16) also includes analysis of the project’s effects on climate change and vice versa.

Comment: Published scientific reports indicate that climate change will be exacerbated by logging due to the loss of carbon storage. Additionally, published scientific reports indicate that climate change will lead to increased wildfire severity and warmer conditions that may render obsolete the proposed effects of the Project. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #154, mentions that the impacts of the Glacier Loon Project on climate change, and vice versa are fully discussed in the Forest Carbon Cycling and Storage Report (Project File Exhibit T-16). The Forest Carbon Cycling and Storage Report includes a review of the literature mentioned in the complete comment which is only summarized here.

Comment: Disclose the impact of climate change on the efficacy of the proposed treatments; disclose the impact of the proposed project on the carbon storage potential of the area. (BB- 6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #103, mentions that the impacts of the Glacier Loon Project on climate change, and vice versa are fully discussed in the Forest Carbon Cycling and Storage Report (Project File Exhibit T-16). Forests can help mitigate the effects of greenhouse gas emissions by removing carbon from the atmosphere and sequestering it in biomass. The proposed treatments would remove some carbon currently stored within live and dead trees. A portion of the carbon removed would remain stored for a period of time in wood products (Depro, Murray, Alig, & Shanks, 2008; United States Environmental Protection Agency, 2009). Harvest of live trees could temporarily convert some stands from a carbon sink that currently removes more carbon from the atmosphere than it emits to a carbon source that emits more carbon through biomass decomposition than it absorbs through tree growth. Regeneration harvest units would experience the greatest change. Thinned and prescribed burn units would experience the least and perhaps would retain enough biomass to still remain a net carbon sink. These stands would remain a source of carbon to the atmosphere until carbon uptake by new and remaining trees again exceeds the emissions from decomposing dead organic material. As stands continue to

Appendix 5-7 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

develop the strength of the carbon sink would increase until peaking at an intermediate age and then gradually decline but remain positive (Pregitzer & Euskirchen, 2004). Carbon stocks would continue to accumulate, although at a declining rate, until impacted by future disturbances. Over the long-term (centuries) net carbon storage is often zero if stands regenerate, because re-growth of trees recovers the carbon lost in the disturbance and in decomposition of trees killed by the disturbance (Kashian, Romme, Tinker, Turner, & Ryan, 2006) Management actions designed to maintain or restore forests to healthy and productive conditions would help maintain carbon stocks and sequestration rates. Increases in disturbance events such as wildfires and insect outbreaks can release large amounts of carbon to the atmosphere (short- and long-term) and reduce carbon stocks (Fields et al., 2007). Carbon sequestration could be enhanced by promoting reforestation, manipulating stocking to favor more rapid growth, and sequestering carbon in wood products (Millar et al., 2007). These approaches include maintaining vigorously growing trees, minimizing severe disturbance and promoting diversity. Birdsey (Birdsey, Pregitzer, & Lucier, 2006) indicate that forest management technologies that may reduce CO2 emissions or increase productivity include nutrient management, residue management and utilization, thinning and better utilization of the resulting wood products, low-impact harvesting, and species or genotype selection Ultimately, it is not possible to specifically determine the cumulative impact on global carbon sequestration and atmospheric concentrations of CO2 from the proposed project activities. What is apparent is that these effects would be miniscule, particularly in the context of the 66,600 teragrams of carbon currently contained in U.S. forests. The short- term change in carbon stocks and sequestration rates resulting from the proposed action are imperceptibly small on global and national scales, as are the potential long- term benefits.

Appendix 5-8 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

ECONOMICS

Comment: The Flathead does not disclose the future costs to maintain the thinning in the WUI…..The economics analysis has not been updated to reflect current conditions, it is still based on 2012 dollars. (BB-5)

Response: Maintenance costs for treatments that would be needed in the future to maintain the desired conditions achieved by implementation of project activities are beyond the scope of this analysis. The economic analysis was reviewed and given that delivered log and lumber prices have improved and demand has continued to outpace supply since the time of completion, economic measures (sale feasibility, financial efficiency, and economic impacts) used in the analysis would all be positively affected. However, the relative difference amongst the action alternatives would remain largely the same.

Appendix 5-9 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

FIRE/FUELS

Comment: The EA fails to evaluate and consider whether the proposed treatments to reduce fire and fuel hazard will actually have the desired effect during the timeframe before vegetation regrows. The EA makes statements such as “Under these alternatives, the proposed harvest and associated activity fuels (slash) treatments would reduce the fire hazard and fire severity risk through reduction of fuel loading. …harvest treatments would reduce the potential of surface fires and crown fires.” However, unless the Flathead has a crystal ball showing that the Glacier Loon area will burn before the vegetation grows back then statements like these are just blowing smoke. The EA also fails to consider that in order to maintain this so called “fire proof” condition on the ground it entails repeated entries that have negative consequences for water quality, fish, wildlife and weed spread. This was not analyzed as a cumulative effect. (BB-5)

Response: Fire models show that the action alternatives will be effective in meeting the purpose and need of the project. Reducing crown fire potential and reducing flame lengths will be effective in reducing the associated risk of high-severity landscape wildfire risk within the WUI and provide a safer environment for the public and firefighters should a wildfire occur within proposed treatment areas. Although we do not know when and where wildfires will occur, we do know where accumulations of fuels are present that will likely contribute towards a problematic wildfire in the future. If fire managers determine that fuels must be treated in the future, they will go through the analysis process again. This project will not “fire proof” the area, nor will it prevent a wildfire. It will, however, reduce the potential for crown fire and reduce flame lengths so that firefighters will have a much higher probability in containing a wildfire before it reaches private lands. Fire will continue to play its role on the landscape and in areas where there is a mixed-severity fire regime there will continue to be areas where high-severity fire effects occur, playing an important role for wildlife and ecological resilience.

Comment: Will the fuels treatments involve a second entry? If so, how much time will pass between logging activities and subsequent fuels treatments? Will fuels treatments essentially result in 2 entries into unit, one for logging in the winter, and one for summer fuels treatments? If so, this impact needs to be addressed in the SEA. The SEA at 2-12 notes that fuels treatments may include mechanical treatments such as whole tree yarding. Does this mean that these treatments involved logging? Please provide a map of all proposed fuels treatments. (BB-7)

Response: Fuels treatments do involve a second entry. The timeline for commercial harvest and fuels treatments varies due to many factors such as timing of harvest treatments, timing of contractual obligations, treatments prescribed, weather conditions, and smoke permitting through the Montana Idaho Airshed Group. The timeline for commercial harvest under most conditions occurs during winter or summer months. Landing pile burning activities typically takes place the year the harvest is completed but sometimes occurs the following year depending on timing of the harvest and if the slash

Appendix 5-10 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

has had enough time to cure to meet fuels reduction objectives. Excavator pile burning sometimes occurs the same year as the commercial harvest but typically occurs within the second year of activities due to slash curing. Broadcast burning activities are constrained by the previously listed factors and treatments since piles created must be burned prior to implementing broadcast burning activities to help minimize the potential for burn escape. Broadcast burning activities typically take place one to two years following commercial harvest. Depending upon the activities prescribed for each treatment unit, the overall disturbance period may last one year up to four years. The description of fuels treatments on supplemental EA page 2-12 list examples of both mechanical and non-mechanical methods for fuels treatment. Table 2-5 on supplemental EA pages 2-18 through 2-21 lists the proposed fuels treatment activities for all units under Alternative B-Proposed Action. Table 2-8 on supplemental EA pages 2-24 through 2-27 lists the proposed fuels treatment activities for all units under Alternative C. Table 2-11 on supplemental EA pages 2-29 through 2-32 lists the proposed fuels treatment activities for all units under Alternative D. Maps 2-1 and 2-2 display the proposed action for both the north and south half of the project. Maps 2-3 and 2-4 display Alternative C for both the north and south half of the project. Maps 2-4 and 2-6 display Alternative D for both the north and south half of the project.

Comment: Since the project’s goals are to reduce the chances that fire will destroy private structures, and harm people, the current fuel/fire hazard situation on land of all ownerships within the WUI (at least the WUI that’s relevant to this area) must be displayed on a map. More importantly, the fuel/fire hazard situation post-project on land of all ownerships within the WUI must also be displayed on a map. Based on this mapping of current and projected conditions, please accurately disclose the threats to private structures and people under those scenarios, for all alternatives. It must be discernable why some areas are included for treatment and others are not. The FS must have a detailed long-term program for maintaining the allegedly safer conditions, including how areas will be treated in the future following proposed treatments, or how areas not needing treatment now will be treated as the need arises. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #120, responds to this comment. Below is what the 2013 response stated including some additional discussion: The Purpose and Need of the project is explained in Chapter 1 of the supplemental EA. Reducing the associated risk of high-severity landscape wildfire risk within the Wildland Urban Interface is one of the goals. The Seeley-Swan Fire Plan 2004 (revised 2013) identifies portions of the project area within the WUI (Project File Exhibit T-14). Please refer to Project File Exhibit K-43 for a map of Glacier Loon Project Area, WUI and Structures. The specifics of how areas were identified for treatment is described in the supplemental EA on pages 3-120 thru 3-132. The existing fuels data set was compiled using a combination of common stand exams, field visits, fire regimes data from Steve

Appendix 5-11 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Barrett, and the Landscape Fire and Resource Management Planning Tools Project (LANDFIRE Project). The LANDFIRE Project was initiated by a request from Federal land agencies asking the principal investigators to develop maps needed to prioritize areas for hazardous fuel reduction (supplemental EA, Chapter 3, page 3-121 thru 3- 122). The objective of the LANDFIRE Project is to provide the spatial data needed by land and wildland fire managers to accurately identify the amount and locations of lands or communities with hazardous fuel build-up or extreme departure from historical conditions. This data also facilitates the prioritization of ecosystem restoration and hazardous fuel reduction treatments to protect ecosystems, property, and people. Moreover, this data may be used during specific wildland fire incidents to maximize firefighter safety, pre-position resources and evaluate fire behavior under a variety of fire weather conditions. These spatial data and predictive models have been hierarchically designed so that they can be used at the national, regional and local levels (supplemental EA, page 3-121). Please reference the Fire and Fuels Section of EA on pages 3-120 thru 3-137 for more detailed information. Please also refer to Project File Exhibits K-43, K-44, K-45, K-46, and K-47 (Glacier Loon Project Area, WUI, & Structures; Glacier Loon 40 Fuel Models Pre and Post Project; Glacier Loon Crown Fire Pre and Post Project; and Glacier Loon Flame Length Pre and Post Project). We assume that more treatments of low-intensity prescribed fire, along with thinning, would be needed in the future to maintain a low fire hazard risk and continue with the goals stated in the purpose and need of the EA. National direction, Forest direction, and funding continue to change, therefore there is no way of predicting the institutional ability to maintain these treatments or that future actions will occur on the landscape. If no future actions occur, it is expected that in the absence of any kind of human- caused or natural disturbance, indirect effects would occur from the natural progression of forest growth and change. This means that over time, surface fuels would likely increase, trees and shrubs would continue to grow leading to an increasing likelihood of severe wildfire behavior. Based on the silvicultural findings, stands are already at risk to insects and disease. Yes it is assumed that these treatments would help set the stage to introduce more low-intensity prescribed fire in future and to maintain current fire regimes. It is difficult to predict to what extent fire risk will increase exponentially, and how long will those elevated risk levels might last. However, most literature seems to support that if no treatment occurs then fire hazard and risk will likely increase (J. Agee, C. Skinner: Basic Principles of Forest Fuel Reduction Treatments, 2005.)

Comment: Since the scientific literature (Graham, et al 1999a) suggests that your thinning activities will actually increase the rate of fire spread, you need to reconcile such findings with the contradictory assumptions expressed in your scoping letter. (BB- 6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to

Appendix 5-12 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Comment E-11 #122, responds to this comment. Additionally, Table 3-46 (supplemental EA page 3-132) shows fire behavior indicators by fuel treatment. This table shows a reduction in post-treatment crown fire potential and post- treatment flame length. By reducing crown fire potential and reducing flame lengths, firefighters will have a higher probability of containing a wildfire before it reaches non-NFS lands. Fuel reduction treatment proposals are thoroughly discussed on pages 3-132 thru 3- 135 of the supplemental EA. Please also refer to Project File Exhibits K-43, K-44, K-45, K-46, and K-47 (Glacier Loon Project Area, WUI, & Structures; Glacier Loon 40 Fuel Models Pre and Post Project; Glacier Loon Crown Fire Pre and Post Project; and Glacier Loon Flame Length Pre and Post Project).

Comment: The description of fuels treatments, such as 2-12, says these treatments can include logging; why isn't there a more specific description of what will happen in each fuels unit? What will be the timeline for logging and fuels treatments that will occur on the same acres? What will be the overall disturbance period when these 2 separate activities are implemented? (BB-7)

Response: The description of fuels treatments on page 2-12 of the supplemental EA list examples of both mechanical and non-mechanical methods for fuels treatment. Table 2-5 on pages 2-18 through 2-21 lists the proposed fuels treatment activities for all units under Alternative B-Proposed Action. Table 2-8 on supplemental EA pages 2-24 through 2-27 lists the proposed fuels treatment activities for all units under Alternative C. Table 2-11 on supplemental EA pages 2-29 through 2-32 lists the proposed fuels treatment activities for all units under Alternative D. The timeline for commercial harvest and fuels treatments varies due to many factors such as timing of harvest treatments, timing of contractual obligations, treatments prescribed, weather conditions, and smoke permitting through the Montana Idaho Airshed Group. The timeline for commercial harvest under most conditions occurs during winter or summer months. Landing pile burning activities typically takes place the year the harvest is completed but sometimes occurs the following year depending on timing of the harvest and if the slash has had enough time to cure to meet fuels reduction objectives. Excavator pile burning sometimes occurs the same year as the commercial harvest but typically occurs within the second year of activities due to slash curing. Broadcast burning activities are constrained by the previously listed factors and treatments since piles created must be burned prior to implementing broadcast burning activities to help minimize the potential for burn escape. Broadcast burning activities typically take place one to two years following commercial harvest. Depending upon the activities prescribed for each treatment unit, the overall disturbance period may last one year up to four years.

Comment: Disclose when and how the Flathead National Forest made the decision to suppress natural wildfire in the Project area and replace natural fire with logging and prescribed burning; disclose the cumulative impacts on the Forest-wide level of the

Appendix 5-13 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Flathead National Forest’s policy decision to replace natural fire with logging and prescribed burning. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #100 and 101, responds to this comment. Below is what the 2013 response stated: The project area is located in the Full Suppression and Modified Suppression FMU (Fire Management Unit). These FMU’s are derived from the Flathead National Forest Land and Resource Management Plan and provide direction on suppression/fire management strategy. This area is identified as Full and Modified Suppression due to the values at risk in the area and the specific Management Area (MA) objectives. Reference the Flathead National Forest Land and Resource Management Plan (Project File Exhibit T-1) for additional information. Ending fire suppression would have undesired consequences, and would not be socially acceptable. Reducing the risk of wildfire, and the loss of these desired stand characteristics is the intent of these treatments. Using prescribed burning only, with limited slashing of small trees would not meet the purpose and need, nor would it be practical given the limitations regarding smoke management, manpower and time.

Comment: Disclose the actions being taken to reduce fuels on private lands adjacent to the Project area and how those activities/or lack thereof will impact the efficacy of the activities proposed for this Project. (BB-6) (BB-5)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #98, responds to this comment. Below is what the 2013 response stated:

The Glacier Loon EA and supplemental EA discloses all of the known fuels treatments that are or have occurred in the past, or present and foreseeable future in Tables 3-1 and 3-2 on both federal and private lands. The cumulative effects of these activities are disclosed in the Fire and Fuels Section of the [Supplemental] EA on pages 3-135 and 3- 136 and in Project File Exhibit K-2. The effect of private land development has been to convert some forested land to low density forest or grassland and roads. There has been a recent response to fire prevention education involving effective fuel reduction within some of these private in- holdings. Although in most cases, the desire of the landowners has been to maintain a forested setting, on one or more aspects, in the immediate vicinity of dwellings and structures that is contiguous with forested public lands. In many cases, small private forested areas have not been managed and forests have become densely stocked stands with large quantities of dead trees. These sites are highly vulnerable to insect and disease

Appendix 5-14 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

outbreaks and wildland fire. The intent with proposed treatments with the Glacier Loon Project is to move the landscape toward more sustainable conditions that allow natural processes to occur. Future treatments in these areas would be determined based upon specific needs at the appropriate time. Without treatment, the risk of losing these ecosystem components continues to increase. Allowing natural processes to return to the landscape is unrealistic, given the amount of human occupancy and property values within the area. For more information on the fire risk situation on private lands in this area please refer to the Seeley-Swan Fire Plan 2004 (Revised 2013; Project File Folder AA).

Comment: Disclose the efficacy of the proposed activities at reducing wildfire risk and severity in the Project area in the future, including a two-year, five-year, ten-year, and 20-year projection. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #99, responds to this comment. Below is what the 2013 response stated: Additional treatments of low-intensity prescribed fire, along with thinning, would be needed in the future to maintain a low fire hazard risk and continue with the goals stated in the purpose and need of the EA. If no future actions occur, it is expected that in the absence of any kind of human- caused or natural disturbance, indirect effects would occur from the natural progression of forest growth and change. This means that over time, surface fuels would likely increase, trees and shrubs would continue to grow leading to an increasing likelihood of severe wildfire behavior.

Appendix 5-15 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

GENERAL/OTHER

Comment: I support Alternative B. I’m concerned about huge fires in the Valley. My wife and I went to the megafire presentation in Seeley Lake. We agreed with the presentation. Fire is going to be on the landscape. Thinning, and controlled burns could it more manageable and a benefit. (BB-1)

Response: We appreciate your comments regarding the purpose for the project and the support for Alternative B. The Responsible Official is tending toward selecting Alternative D with some modifications in the decision for this project – see the draft decision rationale in this document.

Comment: Alternative D reduces the potential impact to wildlife populations by constructing fewer temporary road miles, decreasing the amount of hiding cover treated, and maintaining a larger proportion of habitat adjacent to wetland complexes. In addition, Alternative D proposes less acreage of lynx habitat and has the potential to increase some habitat value for certain wildlife species, including white-tailed deer. We do recognize that the overall project will inherently have some negative impacts on wildlife in the area and encourage the Forest Service to evaluate any new data during the project. Furthermore, we recommend that the Forest Service explore the potential to decommission additional road miles in conjunction with this project. (BB-2)

Response: We appreciate your comments regarding Alternative D and the Responsible Official will consider them when making his final decision for this project. Comment: The proposed project area contains populations of both westslope cutthroat trout as well as bull trout, as species as listed as threatened under the Endangered Species Act. While the treatments will result in some construction and upgrading of roadways, the potential threats to important fish species are minimal in all three proposed alternatives….We expect that no matter which alternative is chosen all appropriate measures will be taken to protect and enhance habitat for these species (e.g grizzly bears, Canada lynx, bull trout, water howellia (as well as others that are not listed). (BB-3) Response: Our intent was to minimize impacts to wildlife, fisheries, and threatened plants as much as possible with the design of this project. The project is consistent with Forest Plan direction under Amendment 19 and MS-1 direction to “favor the bear” as well as consistent with direction under the Swan Valley Grizzly Bear Conservation Agreement. The Chapter 3 grizzly bear analysis in the SEA descriptions these measures and how the project adheres to them. Further the project is consistent with the Northern Rockies Lynx Management Direction which was designed to promote recovery and conservation of lynx. The Lynx section in the SEA describes how the project follows this direction.

Comment: We support treatments to reduce fuels and potential for wildfire risk in the Wildland Urban Interface, including mechanical thinning and prescribed burns, which result in improved forest composition and restore fire-adapted systems. We appreciate

Appendix 5-16 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments the work of the district to keep the public informed in advance and during prescribed burning activities. We expect this type of information sharing will occur again during the Implementation of prescribed burning treatments with the Glacier Loon project. We appreciate the willingness of the Flathead National Forest to incorporate alternatives that address issues raised by residents in the Lindbergh Lake area about their viewshed and we recognize that if areas near Lindbergh Lake are left untreated the potential for wildfire danger remains high. (BB-3)

Response: Thank you for support of this project.

Comment: The decommissioning of roads and removal or replacement of culverts will benefit the overall water quality of Missoula County's streams. We support the restoration work being proposed in Alternatives B, C, and D to reduce sedimentation into local streams thus improving water quality, which will have a direct impact on the fisheries and indirect impact on the economy of Missoula County.

We support access to public lands and do not believe that the decommissioning of roads within this project area will impact the access opportunities that have been provided to residents of Missoula County in the past. (BB-3)

Response: Thank you for support of this project.

Comment: Some of the management activities being proposed in the Glacier Loon Fuels Reduction and Forest Health Project are designed to achieve the restoration criteria set forth in the CFLRP and the landscape strategy developed by the SWCC; however, the proposed timber harvesting activities do not appear to meet the desired goals set forth under CFLRP funding. While Missoula County supports timber management activities that benefit its residents, we feel that it may not be appropriate to use CFLRP funding for this specific project (BB-3)

Response: The Glacier Loon Project, while not developed under the auspices of the Southwestern Crown Collaborative or CFLRP, due to the project planning beginning prior to CFLRP, nevertheless, addresses the three primary objectives of both the CFLRP program and the Southwestern Crown: (1) fuels mitigation; (2) forest restoration; and (3) watershed improvement. Fuels mitigation will be accomplished through (a) Regeneration of dead or dying stands weakened by abnormal insect and disease outbreaks occasioned by historic fire suppression; (b) thinning to reduce ingrowth of shade-tolerant species that create ladder fuels, thus reducing risk of crown fires; and (c) reducing high concentrations of dead and down fuels in conjunction with stand thinning. Forest restoration will be accomplished through (a) re-establishment of important early seral species (western larch, ponderosa pine, white pine) in some areas now occupied by low vigor, high density lodgepole pine; (b) thinning from below to remove encroaching shade-tolerant species and shift stand structures in favor of larger, early seral species; (c) releasing larger trees with old-growth attributes; and (d) re-introducing

Appendix 5-17 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments fire to the landscape where practicable in conjunction with stand treatments. Watershed improvement will be accomplished through implementing road decommissioning, resource enhancement projects, best management practices, and management area changes as discussed below. Under the Selected Alternative, an estimated 8.4 miles will be decommissioned. Included in this decommissioning is the full recontouring of Roads #9575, #10732, #10733, and #10734 totaling 3.9 miles. In addition, decommissioning of NFS Road #561F will halt erosion on the single largest known sediment point-source in Glacier Loon Analysis Area. Decommissioning will contribute to the restoration efforts of the watersheds and reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas. Decommissioning these road corridors will also restrict human vectors from moving existing weed infestations and allowing the native vegetation to grow back over the corridor. Resource Enhancement Projects: One Resource Enhancement Project (Resource Enhancement Project #1 on Map 2) will re-establish vegetation on an historic road (unmapped, with no number) or skid trail that was discovered about 0.25 miles from the end of NFS Road #9591Y. This travelway is located in the bottom of a small draw and now collects enough water to scour a stream channel that runs down the middle of the draw bottom. Although the amount of water is small and does not appear to cause much erosion, it is likely to be affecting the groundwater by flowing on the surface before it connects with the wetland. The wetland is an occupied Howellia pond whose habitat should be protected. This project will plant approximately 400 shrubs and seedlings on about 250 feet of the valley bottom to diffuse water flow so it can to go back into the ground. A new culvert on NFS Road #9552 at Meadow Lake outflow will be designed for aquatic fish passage and will be sized for 100-year flood event. This work is also a restoration project and not a road concern (Resource Enhancement #2 – Map 3). The culvert is undersized and has developed about one foot high waterfall on the outlet. The existing road is poorly designed where it crosses the unnamed stream that flows between Meadow Lake and Bunyan Lake. The culvert is a seasonal fish migration barrier and the road surface erodes into the creek. Both Bunyan and Meadow Lake have wild (self- sustaining) cutthroat trout and the barrier is not desirable. This project will replace the culvert with either a larger culvert that provides fish passage or a bridge. The road will be reconstructed so that it does not erode into the stream. In the long- term, addressing the chronic erosion at the fish barrier on Road #9552 will reduce sedimentation to fish habitat. Minor work will also take place at the trailhead to reduce erosion. Please see the Hydrology and Fisheries Sections of this document for more information. Temporary Road #12A is a historic road with a culvert already in place. The culvert was poorly installed in early 1980s, and the stream almost breached the road in the prolonged 2011 runoff. Under the Selected Alternative, this road is not needed to

Appendix 5-18 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

access harvest units but Design Criteria (Appendix 2) for this alternative will require removal of the culvert, the channel restored, and the road reclaimed. This is considered more advantageous to the Hydrologic Resource, specifically water quality, than leaving the old road along with the potential for the culvert to wash out at some point in the future resulting in potential sediment delivery. Under the Selected Alternative, an estimated 29.3 miles of road will have Best Management Practices (BMPs) installed Given there are currently 101.4 miles of road in the Glacier Loon Project Area, this means 29 percent of the total road network would receive BMPs. BMPs will reduce the small amount of erosion that occurs annually on area road systems. All planned road-related work in the project area will contribute to the restoration efforts of the watersheds within the Glacier Loon Project Area. The Selected Alternative will reduce erosion, provide fish passage and reduce road densities. The Selected Alternative will cumulatively reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas, and road maintenance costs. CFLRP funding is appropriate for project work that meets the intent of the Forest Landscape Restoration Act. Please see Project File Exhibit T-14 for further description of what restoration work is discussed in the Act. The Forest Service does not make timber sales simply for generating volume. Timber sales are the means of implementing forest health and fuel reduction treatments. They do this in two main ways: (1) by applying the vegetation treatments necessary to accomplishing the objective; and (2) by paying for the cost of treatment. Without timber sales, many restoration treatments would not get accomplished.

Comment: The EA fails to analyze the cumulative effects of the adjacent Beaver Creek Project. (BB-5)

Response: The Beaver Creek project is acknowledged in the Glacier Loon supplemental EA for cumulative effects (supplemental EA pg. 3-8) and cumulative effects are analyzed in: Vegetation (supplemental EA pg. 3-72), Hydrology (supplemental EA pg. 3-177 to 3-180), Fisheries (supplemental EA pg. 3-200 to 3-216), Wildlife (supplemental EA 3-224, 3-241, 3-246, 3-264, 3-280, 3-292 to 3-374). Updated Cumulative Effects worksheets which include the Beaver Creek project are located in Project File section AA.

Comment: We request the FS design a restoration/access management plan for project area streams that will achieve recovery goals. The task of management should be the reversal of artificial legacies to allow restoration of natural, self-sustaining ecosystem processes. If natural disturbance patterns are the best way to maintain or restore desired ecosystem values, then nature should be able to accomplish this task very well without human intervention (Frissell and Bayles, 1996). (BB-6)

Response: Within the project area, nonnative fish species are the primary impediment

Appendix 5-19 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

to recovery. During the preparation of the Glacier Loon Project, the Interdisciplinary Team considered restoring/conserving a valuable native cutthroat trout fishery on Kraft Creek as part of the proposed action. Initial project scoping included constructing a barrier on Kraft Creek so to block nonnative fish. However, as described on pages 2-9 of the supplemental EA, this proposal was removed from the project and carried out on Red Butte Creek for the reasons described in the supplemental EA. As reviewed from pages 3-183 to 3-215, there is no evidence that fish habitat in the project area is impaired. Watershed improvement will be accomplished through implementing road decommissioning, resource enhancement projects, best management practices, and management area changes as discussed below. Under the Selected Alternative, an estimated 8.4 miles will be decommissioned. Included in this decommissioning is the full recontouring of Roads #9575, #10732, #10733, and #10734 totaling 3.9 miles. In addition, decommissioning of NFS Road #561F will halt erosion on the single largest known sediment point-source in Glacier Loon Analysis Area. Decommissioning will contribute to the restoration efforts of the watersheds and reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas. Decommissioning these road corridors will also restrict human vectors from moving existing weed infestations and allowing the native vegetation to grow back over the corridor. Resource Enhancement Projects: One Resource Enhancement Project (Resource Enhancement Project #1 on Map 2) will re-establish vegetation on an historic road (unmapped, with no number) or skid trail that was discovered about 0.25 miles from the end of NFS Road #9591Y. This travelway is located in the bottom of a small draw and now collects enough water to scour a stream channel that runs down the middle of the draw bottom. Although the amount of water is small and does not appear to cause much erosion, it is likely to be affecting the groundwater by flowing on the surface before it connects with the wetland. This project will plant approximately 400 shrubs and seedlings on about 250 feet of the valley bottom to diffuse water flow so it can to go back into the ground. A new culvert on NFS Road #9552 at Meadow Lake outflow will be designed for aquatic fish passage and will be sized for 100-year flood event. This work is also a restoration project and not a road concern (Resource Enhancement #2 – Map 3). The culvert is undersized and has developed about one foot high waterfall on the outlet. The existing road is poorly designed where it crosses the unnamed stream that flows between Meadow Lake and Bunyan Lake. The culvert is a seasonal fish migration barrier and the road surface erodes into the creek. Both Bunyan and Meadow Lake have wild (self- sustaining) cutthroat trout and the barrier is not desirable. This project will replace the culvert with either a larger culvert that provides fish passage or a bridge. The road will be reconstructed so that it does not erode into the stream. In the long-term, addressing the chronic erosion at the fish barrier on Road #9552 will reduce sedimentation to fish habitat. Minor work will also take place at the trailhead to reduce erosion. Please see

Appendix 5-20 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments the Hydrology and Fisheries Sections of this document for more information. Temporary Road #12A is a historic road with a culvert already in place. The culvert was poorly installed in early 1980s, and the stream almost breached the road in the prolonged 2011 runoff. Under the Selected Alternative, this road is not needed to access harvest units but Design Criteria (Appendix 2) for this alternative will require removal of the culvert, the channel restored, and the road reclaimed. This is considered more advantageous to the Hydrologic Resource, specifically water quality, than leaving the old road along with the potential for the culvert to wash out at some point in the future resulting in potential sediment delivery. Under the Selected Alternative, an estimated 29.3 miles of road will have Best Management Practices (BMPs) installed Given there are currently 101.4 miles of road in the Glacier Loon Project Area, this means 29 percent of the total road network would receive BMPs. BMPs will reduce the small amount of erosion that occurs annually on area road systems. All planned road-related work in the project area will contribute to the restoration efforts of the watersheds within the Glacier Loon Project Area. The Selected Alternative will reduce erosion, provide fish passage and reduce road densities. The Selected Alternative will cumulatively reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas, and road maintenance costs. Management Area Change: The Selected Alternative will change 221 acres from Management Area 15 and 15C to Management Area 5. This change would generally result in less silvicultural activities occurring as scheduling of timber harvest within MA 5 would be primarily limited to those treatments which maintain or enhance the scenic quality of the area. Timber harvest designed as such would typically be less frequent, at a lower intensity with less of a potential impact to water resources. Roads are permissible if they are in harmony with visual objectives; but since this would be unlikely in such steep countryside, it is reasonable to assume that no roads would be built. Deferring any new roads in the area would avoid any stream crossings and eliminate potential sedimentation to water quality.

Comment: The SEA at 2-4 and 2-26, as examples, claims that many of the stands proposed for treatment were selected for such because they will not retain their wildlife values without intervention; however, the specific problems that untreated stands will create for wildlife, and for which wildlife species, was never addressed; since this is one rationale for logging, the agency needs to provide the data on which this rationale is based. (BB-7)

Response: It is unclear what the comment means by “specific problems that untreated stands will create for wildlife.” The Chapter 3 analysis discusses the effects of no action on insects and disease (Forest Vegetation), and wildfire potential (Fuels section) as well as discussion in the wildlife section of the no action alternative and the habitats that would be both affected and unaffected by proposed treatments. The data for which these ecological effects are based come from forest data, monitoring and the best

Appendix 5-21 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments available science all disclosed in the SEA Chapter 3 analysis.

Comment: Disclose maps of the area that show the following elements: 1. Past, current, and reasonably foreseeable logging units in the Project area; 2. The cumulative effects of past, current, and reasonably foreseeable logging units; 3. Past, current, and reasonably foreseeable logging units in the Project area; 4. The cumulative effects of past, current, and reasonably foreseeable grazing; 5. Past, current, and reasonably foreseeable grazing allotments in the Project area; 6. Density of human residences within 1.5 miles from the Project unit boundaries; 7. Hiding cover in the Project area according to the Forest Plan definition; 8. Old growth forest in the Project area; 9. Big game security areas; 10. Moose winter range. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #106, mentions where these maps are located in the project file or in the EA (maps did not change in the supplemental EA).

Comment: Disclose and address the concerns expressed by the ID Team in the draft Five- Year Review of the Forest Plan regarding the failure to monitor population trends of MIS, the inadequacy of the Forest Plan old growth standard, and the failure to compile data to establish a reliable inventory of sensitive species on the Forest. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #97 responded to it by stating: “The Flathead National Forest Evaluation and Compliance with NFMA Requirements to Provide for Diversity of Animal Communities (Project File Exhibit H-16) provides information on population, habitat, and distribution; threats; conservation; and an evaluation of the current situation on NFS lands for threatened, endangered, and sensitive wildlife, management indicator species, and other wildlife, incorporating the best available science and accepted scientific information and techniques. As stated in this document: “The Forest Service is required by National Forest Management Act (NFMA) to “provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple- use objectives” 16 U.S.C. 1604(g)(3)(B).” The EA (Chapter 3 - Wildlife) [or Supplemental EA] discloses project-specific information relative to wildlife species and the quality and quantity of their habitats. Observation and monitoring data for threatened, endangered, sensitive, management indicator species, and other wildlife in and near the Glacier Loon Project Area are provided in project file exhibits H-8, H-9, H-10, H-24, and H-25. Items 20a and 20b of the Flathead National Forest Monitoring Report (1999- 2007), incorporated into this EA by reference, have the stated objective “To monitor changes in the population status of forest carnivores including Canada

Appendix 5-22 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

lynx, wolverine, and fisher, on the forest.” As stated in this document, “Montana FWP annually collects harvest data from several furbearer species through mandatory trapper pelt registration and carcass or skull turn-ins. This information is analyzed and used to estimate population trends for these species to manage harvest quota levels. Carnivore population trend is estimated for the period 1997 – 2002 using MDFWP trap data.” In addition, this document reports on snow track surveys which are used to determine species occurrence and distribution, trends from detection rates, and relative abundance. Results are reported for watersheds across the Flathead National Forest from 2000-2004. By selecting MIS, the Forests in the Region have recognized and are committed to assimilating more detailed population and habitat information on a number of species. In addition, these Forests are committed to contributing to the recovery of Federally Listed Species. Presence of MIS and sensitive species is documented in the EA within the “Existing Condition” for each analysis (MIS: EA, page 3-335 and in the Supplemental EA on page 3-335 and 336; Sensitive Species: EA, pages 3-267 thru 3-304 and in the Supplemental EA on pages 3-288 thru 3-324). We rely on Montana Fish Wildlife & Parks (MTFWP) survey data, communication with local MTFWP Biologists for information on white-tailed deer, mule deer, elk and other big game. Winter carnivore surveys were conducted using snow track detection and DNA amplification to detect fisher, lynx and wolverine (Project Exhibit H-24). Common loon surveys are conducted on annually within the Swan Valley on all viable loon nesting lakes. Flammulated owl surveys were conducted in 2005 using call back methods across the Swan Valley (Project Exhibit H-9). Transects were conducted of each stand of all the action alternatives and observations were taken on wildlife sign, habitat characteristics, and quantity/quality of snags and downed woody material (Project Exhibit H-25).”

Comment: Disclose the funding source for non-commercial activities proposed. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #84 responded to it by stating: “Several sources of funding exist for non-commercial activities. Many items have the potential to be funded through timber sales, while other items could be funded with Congressionally-approved funds (Collaborative Forest Landscape Restoration Program) or Stewardship dollars. It is anticipated that this project may be offered under a Stewardship Contract. Actual authority to offer under such a contract comes from the Regional Forester on a case-by-case basis. If approved as a Stewardship offering, these items will be included in Stewardship Projects, but inclusion of projects in the final award will depend on the bid value received for the project.

Appendix 5-23 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Some, none, or all of the projects may be implemented through Stewardship contracting depending on market conditions at the time of offer. Implementation through direct project funding will be based on annual budgets and program direction. If funding were not available, the improvements from these activities would not be accomplished. CFLRP funding is appropriate for project work that meets the intent of the Forest Landscape Restoration Act. Please see Project File Exhibit T-14 for further description of what restoration work is discussed in the Act.”

Comment: Disclose the timeline for implementation. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012) (see first Decision Notice (2013), Appendix 5, Response to Comment E-11 #83). However, that response is no longer relevant since it is now 5 years beyond the first decision signed in 2013. The commercial harvest is expected to occur over the first three years following the decision. Post-harvest activities, such as burning and planting, will likely be completed 1 year following harvest activities. Reforestation activities should be completed no more than 5 years after logging is completed in each unit.

Comment: Why does the project area boundary exclude the cabins on Lindberg Lake? They are in the Wildland Urban interface. Drawing the project boundary down the middle of Lindberg Lake seems like an attempt to gerrymander the cabins out so the Forest Service doesn’t have to include the impacts of the cabins in the project analysis. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #118 responded to it by stating: “The cabins on Lindbergh Lake are located in the Beaver Creek Project Area. This private land will be considered in the Beaver Creek Project. The project area boundaries were set to coincide with the Grizzly Bear Subunit boundaries identified in the Swan Valley Grizzly Bear Conservation Agreement. The subunits approximate the size of a female grizzly bear’s home range. The project area is also large enough to include the home ranges of several individuals or pairs of a wildlife species, and is representative of the effects of fire, natural tree mortality, timber harvest, road management, and other potential effects across the landscape.”

Appendix 5-24 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

INVASIVE PLANT SPECIES

Comment: We expect that the Forest Service will take great precautions to reduce all potential risks for further spread of noxious weeds in Missoula County. (BB-3)

Response: The project includes design criteria for the prevention of weed spread into the project area from project-related activities.

Comment: Controlling weeds and preventing their spread is a huge issue that the Flathead does not have a grip on. Current methods are obviously not working, weeds spread on forest roads, in cutting units, landings, burn piles, and on to private property. The best way to prevent weeds from spreading out of control is not to disturb the native vegetation…..Washing equipment does not work, please do not attempt to dupe the public into believing that the same past failed mitigation measures to control weeds will somehow miraculously work in this project. Instead of addressing the problem the Flathead just resigns itself to the fact that there will be an invasive species problem in the project area indefinitely. (EA at page 3-94) This is not adequate. (BB-5)

Response: We disagree that washing equipment or the other project design features for weeds do not work. These practices are for prevention of new invaders to the project area as a result of project activities, and not for the eradication or control of established infestations. While project activities do not provide comprehensive weed control, other weed control efforts continue across the forest. Approximately 4000 acres were treated for weeds in FY2017, with nearly 2800 acres restored on the landscape. This is the work of the forest weeds program, timber sale weed contracts, and other contracts as funded with CFLR, KV funds, stewardship funds, and various grants and agreements. However, with continued budget reductions, control activities (personnel, supplies, contracts) are impacted. Weeds will continue to figure prominently on the landscape, and ecologically, they are here indefinitely. The Forest Service will continue to prioritize species that would have extreme negative ecological and economic impacts, such as Dyer’s woad and rush skeletonweed, ahead of other invasive species, such as knapweed and thistle.

Comment: Please disclose the results monitoring of weed treatments on the FNF that have been projected to significantly reduce noxious weed populations over time, or prevent spread. This is an ongoing issue of land productivity. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #151 responded to it by stating: “The most recent Invasives Performance Report run by the Regional Office for FY12 shows that the Flathead NF treated almost 5100 acres with an average control of 93% for 3590 acres restored on the forest (Project Exhibit J-15).” The following is information from are activity tracking database pulled October 17, 2017:

Appendix 5-25 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

FY 2017: Flathead NF

Activities Acres Acres Average Acres District Accomplished Accomplished Monitored Controlled Restored

Swan Lake 103 1891.3 4816.5 75% 1403.5

Spotted Bear 73 612.5 559.6 74% 453.3

Hungry Horse 60 557.6 452.0 76% 423.8

Glacier View 39 265.5 102.3 76% 0.0

Tally Lake 45 675.0 538.0 77% 519.8

Total/Average 320 4001.9 6468.1 75% 2800.4

Appendix 5-26 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

OLD GROWTH

Comment: Old growth occurs in many different habitat types. What habitat types are present, and how will the proposal affect the various habitat types in the project area? The EA fails to disclose the various habitat types impacted by the project. (BB-5) (BB-6)

Response: The Glacier Loon project does consider different types of old growth communities that are present within the project area. As stated in the supplemental EA, Green et al. is used to classify old growth stands verified in the project. Exhibit I-1x lists the stand IDs of the verified old growth in the project area by habitat type code, by forest type and by old growth habitat group. Habitat types that overlapped old growth included the following: ALBA/CLUN- MEFE, ABLA/MEFE, ABLA/XETE-VAGL, ABLA/XETE- VASC, and ABLA/CLUN-XETE. This habitat type information was used during project development and analysis in the supplemental EA.

Comment: The agency will violate the NEPA and the NMFA by failing to inventory and map old- growth forest habitats in the project area. In addition, the agency failed to evaluate how current amounts, patch size, connectivity and distribution of old-growth habitat are maintaining wildlife in old-growth habitats….There is no qualitative analysis, no before-and- after comparison, that encourages, or supports, increasing the quantity or quality of old- growth habitat, or increasing size and vigor of wildlife populations associated with old growth. (BB-5) (BB-6)

Response: The Glacier Loon project does not treat any old growth stands. Verified old growth stands are identified and mapped in the project area. Project file H-11 includes stand numbers and a map of verified stands in the project area. Map 3-6 of the supplemental EA also shows old growth verified stands. Qualitative and quantitative habitat conditions for old growth associated wildlife species in the analysis area, including the existing condition for old growth habitat, were analyzed and discussed in the supplemental EA on pages 3-329 thru 3-319. Old growth species disturbance/displacement, interior integrity of existing old growth, old growth recruitment, and the effects of temporary road construction were analyzed. Stands proposed for treatment were surveyed to assure that no treatment was proposed in old growth habitat. In regards to some older stands (not old growth) being logged – The different alternatives address the Purpose and Need to differing degrees. Many older stands, as well as designated old growth stands, may contain hazardous fuels conditions, or may be affected by insects or disease. There are trade-offs to be considered; hence, a range of alternatives and analysis of effects to different resources, including old growth habitats.

Comment: The EA produced no evidence to support the agency assumption that the project will not adversely impact recruitment of future old growth. The agency uses insufficient and inaccurate (FIA) old-growth data to make unsubstantiated assumptions about old growth. There is no old growth inventory. (BB-5)

Appendix 5-27 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Response: Field examination and common stand exams, not FIA data, were used to identify old growth stands in the project area. Verified old growth stands are not to be treated in the Glacier Loon project. Old growth recruitment is discussed on pages 3-331 and 3-332 of the supplemental EA. The old growth habitat section discussed that proposed intermediate treatments will keep the non-old growth stands on a trajectory towards providing future old growth habitat conditions as the long-lived, fire-resistant, shade-intolerant species would be favored for retention, stand health would be improved, growing space would be increased and competition decreased to allow trees to grow larger over time. Intermediate treatments would also reduce ladder fuels and protect leave trees from potential future wildfire increasing forest resiliency to disturbance. The Vegetation section of the SEA discusses effects to old growth, seral structural classes and states that “intermediate treatments would result in immediate larger average stand diameters” (supplemental EA pg.3-65) and that “intermediate treatments would “accelerate the time required for an area to shift from early-seral to mid-seral or from mid-seral to late- seral stages” (supplemental EA pg. 3-67) supporting that treatments would keep non-old growth stands on the trajectory to providing future old growth habitat conditions. The EA does not use FIA data for project old growth stand verification. An inventory of old growth verified stands in the project area is listed in project file exhibit H-11. FIA data provides statistically reliable estimates at the Regional and Forest levels down to geographic areas of approximately 60,000 acres in size. Estimates of habitat from FIA data provide broad-level cumulative effects information as directed by NFMA. This information is useful in setting the context for the possible effects of a project especially because FIA data is sampled across ownerships and management areas (private property, in Wilderness, outside Wilderness etc.) (Samson 2006, Bush and Lundberg 2008). The Glacier Loon project uses FIA data for amount of old growth at larger levels than the project area (forestwide and fifth code hydrologic unit) to provide context to the project effects. Application of FIA data in this way is the appropriate use of the data for the project.

Comment: The EA fails to disclose how elevation often determines the quality of old growth. Old-growth habitat effectiveness declines as elevation increases. Elevational distribution of old growth was casually addressed by stating: “As would be expected, conversion of old growth forest has occurred at a higher rate in the valley bottoms. Lower elevation old growth forest is less prevalent than higher elevation old growth forest throughout most of the drainages in the Swan Valley.” The EA fails to analyze how the loss of low elevation old growth may affect moose, pine marten, northern goshawk, pileated woodpecker, brown creeper and flammulated owl. Liquidation of low elevation old growth threatens the viability of these species. (BB-5)

Response: The comment does not provide any science for the claim “old growth habitat effectiveness declines as elevation increases.” Old growth of different terrestrial forest community groups occur at different elevations. These different groups are selected

Appendix 5-28 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

based on a species habitat preferences. As a result, quality of old growth by elevation will differ depending on the preferences of the old growth associated species in question. Different wildlife use a variety of habitats that occur at different elevation ranges. For instance, flammulated owl are known to be associated with xeric ponderosa pine and Douglas fir habitats. In the Swan Valley, these habitats occur predominately in the low elevations of the valley bottom (Table 3-87 supplemental EA pg. 3-326). Whereas species like marten, typically use mixed conifer stand types with spruce and fir more prominent at the mid-to higher elevations. Just because these habitat types are distributed at different elevations does not mean that habitat effectiveness decreases by elevations for all old growth associates. For example, marten have been observed in MT between 2,500 and 8,500 feet of elevation (http://fieldguide.mt.gov). This elevation range would include potential use of the entire elevation range of suitable habitat conditions from the valley bottom throughout the Wilderness in the project area. The supplemental EA does not fail to analyze the distribution of old growth or fail to consider viability of old growth associated species. The supplemental EA considered the historic reduction of old growth at low elevation (supplemental EA pg. 3-328). The supplemental EA identifies old growth associated species and their habitat cover types. The supplemental EA analysis acknowledges that in the Swan Valley all community sub-groups for late seral forest is estimated to be below the minimum (supplemental EA pg. 3-328). The wildlife old growth associated species, MIS, TES, sensitive, snag and down woody and migratory bird species analyses based viability conclusions on distribution of habitats, habitats forestwide, species monitoring in the project area and across the forest and the best available scientific information. The viability determinations are supported by the rationale and conclusions in project exhibit H-18.

Comment: Moose are old growth associated species, and really don’t fit neatly under the big game umbrella concept imagined by the Flathead National Forest. No analysis of moose, moose habitat, or old growth habitat relating to moose appears in the EA. (BB-5)

Response: The habitat needs of moose are met by considerations in the project for big game species. Moose have a similar habitat needs as deer and elk considering foraging areas, hiding cover, security from predators, hunters etc. There is no science available for moose dependence or reliance on old growth forest. The Glacier Loon project would maintain a mosaic of forest types and seral stages in the project area providing for big game habitat including moose. Potential effects to moose are analyzed in the supplemental EA in the Management Indicator Species - Commonly Hunted Big Game portion of the Wildlife Section (pages 3-351 thru 3-363). White-tailed deer, mule deer, and elk are Management Indicator Species (MIS) for commonly hunted big game species on the Flathead National Forest (USDA 1985). At the forest level, meeting the habitat needs for white-tailed deer, mule deer, and elk would indicate that the habitat needs for other commonly hunted big game species, such as black bear, mountain lion, and moose, would also be met. Potential impacts to big game species, including moose, particularly impacts to riparian and wetland habitats are discussed in the supplemental

Appendix 5-29 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

EA on pages 3-355, 3-358, and 3-360.

Comment: There was no EA analysis of how old growth is currently distributed by drainage. There has been no project-level inventory of old growth. The agency also failed to provide a map depicting all undisturbed forest stands, which will be needed for old growth recruitment to meet future habitat needs to maintain viable populations of old-growth associated wildlife populations. The EA discloses that old growth patches range between 20 acres to 272 acres, these are small and fragmented yet logging units and roads are adjacent to old growth. How will old growth associated wildlife remain viable when the patch sizes are too small, fragmented and scattered? And will become more so after this project. There is no analysis of blowdown to old growth post logging. (BB-5) (BB-6)

Response: A map of verified old growth stands and the project area drainages is located in H-11 and in Map 3-6 of the supplemental EA. Project file exhibit H-11 also contains a list of verified old growth stands in the project area. The Vegetation section of the supplemental EA discusses distributions of tree sizes and seral stage and old growth (supplemental EA pg. 3- 46). Late seral stands contain potential old growth, but also large tree dominated areas that may not meet Green et al. definitions (supplemental EA pg. 3-46). These late seral areas can provide old growth recruitment over time to meet Green et al. definitions. Maps of Potential Vegetation Groups, cover type and mean tree size, which combine for late seral stand characteristics are located in the silvicultural specialist report (project file exhibit I-1). Historical information regarding past forest disturbance was considered in the project and provided in the project file including: Historic fire disturbance (project file exhibit I-1; supplemental EA Map 3-1), Aerial detection surveys for insect and disease disturbance (project file exhibit I-1d), Legacy and non-legacy activities (project file exhibits I-1o, I-1p, I- 1v). Past regeneration units from 2003 to 2012 are mapped in project file exhibit H-26. The wildlife analysis considered the vegetation information from the project, the habitat needs of old growth associated species, the effects of the project and concluded that viability for old growth associated species would remain after project implementation (supplemental EA pg. 3-325 – 3-338).

Comment: Old growth associated species such as the pine marten need old growth in stand sizes of 250 to 500 acres to be effective. Pileated woodpeckers, another old growth associated species, require 100-250 acre stands. Goshawks, another old growth associated species, require an average nesting stand size of 40 acres in west-central Montana, plus additional acres for post-fledgling habitat. Where is the site-specific analysis? (BB-5) (BB-6)

Response: Marten and pileated woodpecker are not MIS species on the Flathead Forest. Northern goshawk is no longer listed as a sensitive species on the Flathead National Forest. Northern goshawk is discussion in the SEA on pg. 3-329. The analysis concluded the project area would maintain habitat for 2 nesting goshawk pairs. Consideration for marten is included as an old growth associated species (Table 3-87).

Appendix 5-30 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

The old growth analysis discusses edge effects, old growth recruitment and integrity of old growth. Project File Exhibit H-16 and updated in Project File section AA, “Flathead National Forest Evaluation and Compliance with NFMA Requirements to Provide for Diversity of Animal Communities,” which addresses the natural history, population, habitat, and distribution of wildlife species which can be found on the Flathead National Forest. This document discusses the threats to the different species, conservation measures in place to address those threats, and an evaluation of the current situation for the different species at the Forest and Regional level to maintain species viability.

Comment: The EA also fails to address the issue that old growth sequesters more carbon than younger, even-aged, “managed” stands. The agency ignored the issue. (BB-5) (BB-6)

Response: Carbon sequestration is fully discussed in the Forest Carbon Cycling and Storage Report (Project File Exhibit T-16). No old growth stands will be treated in the Glacier Loon Project, consequently, there will be no impacts on carbon sequestration by old growth within the project area. Stands not yet old growth will be made to move more rapidly on a trajectory towards old growth through thinning treatments designed to improve vigor of the large-tree components of these stands.

Comment: The EA did not analyze old growth habitat. The data used to calculate old growth acreage and percentages, allegedly using the Green et al. definition, came from unreliable sources that do not measure the minimum criteria required by a proper analysis using accepted Region -1, Green et al. definition and procedures. The EA makes no claim to the accuracy or appropriateness of the data, or the qualitative effectiveness of the old growth analysis. The effects of the project cannot be accurately assessed. (BB-5)

Response: There would be no old growth treated with this project. It is not clear from the comment why the stand exams used to verify old growth are “unrealible,” or how the exams were improper. The vegetation section of the supplemental EA (pg 3-35) states “areas identified as old growth in this report are only those areas that meet specifications and descriptions in Old- Growth Forest Types of the Northern Region [Green et al. 1992 (errata corrected 2011)] for the Western Montana Zone.” Project file exhibit I-1 includes the minimum and associate characteristics to determine old growth (supplemental EA pg. 3-47). The supplemental EA also discusses how FIA data can be used to statistically estimate old growth at large scales (supplemental EA pg. 3-47). PF Exhibit I-1t contains the Regional old growth reports (which uses Region 1 accepted definitions and procedures) for the project area. Old growth habitat was discussed for old growth associated species in Chapter 3 of the EA.

Comment: The EA did not disclose what the 75% range around the median of historical variability is in the project or cumulative effects area. How much old growth does that

Appendix 5-31 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments equate to? How this project is moving the Flathead towards or away from the goal to maintain and recruit old growth forests…. The project will degrade the old growth there is by increasing high contrast edge effects, displacement, logging recruitment old growth, and building temporary roads on the edge of old growth stands. (BB-5)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #9 responded to it by stating: The EA states on page 3-309 that “Based on Regional FIA Data for the Glacier Loon Area (fifth code watershed 1701021101), the estimate for percent old growth in the watershed is 9.09 percent, with lower and upper bounds of 0.0 to 20.0 percent (Bush and Leach 2004). There is no proposed treatment in old growth habitat under the Glacier Loon Project Decision. An extensive survey of old growth forest habitat outside of the treatment area was not conducted due to the fact that all existing old growth habitat will remain; the amount of old growth across the Glacier Loon Project Area landscape will not be affected by this Decision. Old growth recruitment is discussed on pages 3-311, 3- 314, and 3-317 of the EA. As discussed, proposed intermediate treatments will, in most cases, keep the stands on a trajectory towards providing old growth habitat conditions for old growth associated wildlife species in the future; many of the larger trees will be retained. The stands proposed for clearcut or seed tree treatment do not currently provide old growth habitat and, due to existing stand characteristics including high mountain pine beetle mortality, will likely not provide potential old growth habitat for a very long time regardless of whether they are treated. For further response, the Vegetation section explains the Amendment 21 analysis which uses late seral forest to approximate historical variability of old growth (supplemental EA pg. 3-46). The 75% range around the median for 3 seral stages calculated by Amendment 21 is disclosed in Table 2 of project file exhibit I-1. The distribution of these seral stages in the project area is included in Tables 6 and 7 of project file exhibit I-1. Effects to old growth stands including edge, displacement, and recruitment are discussed in the supplemental EA beginning on pg. 3-325. As discussed, proposed intermediate treatments will, in most cases, keep the stands on a trajectory towards providing old growth habitat conditions for old growth associated wildlife species in the future; many of the larger trees will be retained. The stands proposed for clearcut or seed tree treatment do not currently provide old growth habitat and, due to existing stand characteristics including high mountain pine beetle mortality, will likely not provide potential old growth habitat for a very long time regardless of whether they are treated.

Comment: The EA lacks any analysis for old growth forests. It does not disclose how much old growth there is in the analysis area. Map 3-6 identifies where it is but it is very fragmented, has lots of edge, is in small patches. The EA does not disclose whether

Appendix 5-32 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments there is recruitment old growth (except that some units with lodgepole pine are on a trajectory towards old growth but will never be allowed to get there because they’ll be at the mill). The EA does not disclose whether the project is in compliance with Amendment #21. (BB-5)

Response: Analysis to old growth forest is located in the vegetation and old growth associated species sections of the supplemental EA. Recruitment of future old growth is discussed in the old growth associated species section regarding recruiting larger diameter trees over time and allowing for other characteristics such as snags, larger diameter down woody debris as the stands age. The lodgepole pine stands (dominated by pole size trees in a stem exclusion state) do not have old growth characteristics and do not meet the criteria set in Green et al. These stands treated in the Glacier Loon decision are affected by mountain pine beetle (supplemental EA pg. 3-305). Many of these trees are dead are no longer growing and do not have potential of progressing towards old growth. Further, the supplemental EA discusses how lodgepole stands have high mortality risk from beetle or from windthrow (supplemental EA pg. 3-75). The project does not treat verified old growth stands, consistent with Amendment 21. The old growth associated species section discusses consistency with Amendment 21 (supplemental EA, page 3-338).

Comment: The Flathead has failed to conduct the monitoring required in A21: Occupancy of old growth habitat by old growth associated wildlife species, forest bird distribution, productivity and survivorship; forest carnivore distribution, nesting territories and productivity of bald eagles and peregrine falcons,; vegetation composition structure and pattern in relation to the historical range of variability; proportion of old growth forest and patch sizes by subbasin and watershed; and success in implementing the structural retention standards (large live trees, snags, and coarse woody debris.) (A21 ROD at page 5). (BB-5)

Response: The Flathead has not failed in the monitoring associated with Amendment 21. Amendment 21 monitoring plan elements are included in the Amendment 21 decision notice pg. 29 (PF Exhibit T-8a). The Flathead Forest has fulfilled these requirements (Project File Exhibits H-18, T-9, and T-9a). Ongoing monitoring continues on the Forest. Bald Eagle and peregrine monitoring are conducted annually with partners (MT Audubon, MT Fish, Wildlife and Parks). Carnivore distribution has been monitored for the past 5 years in the Swan Valley and across the forest (SWCC monitoring Team progress report 2015; PF Exhibit H-9). Forest bird monitoring has occurred through MAPS and is ongoing through the Intermountain Bird Conservancy. Monitoring for vegetation pattern, snags, coarse woody debris and other forest attributes is located in T-9 and T-9a. The region maintains databased for common stand exams and FIA data on the Flathead. This data is used for both project level analysis and Forest-level summary data and monitoring. For the project area, the forest vegetation section discusses the existing condition of structural stages in context the historical range of variability. Snag monitoring is also discussed in T-9 and T-9a. Further

Appendix 5-33 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

information for snag monitoring on the Flathead Forest includes the FIA data analysis used for the snag and down woody species associated species.

Comment: Please disclose how stands to be treated compare to Forest Plan or Regional old- growth criteria. In order to disclose such information, please provide all the details, in plain language, of these areas’ forest characteristics (the various tree components’ species, age and diameter of the various tree components, canopy closure, snag density by size class, amounts of down logs, understory composition, etc.). (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #136 responded to it by stating something very similar as below. Data for stands to be treated is summarized in the supplemental EA beginning on page 3-31. Desired conditions and Forest Plan direction are outlined beginning on page 1-3 of the supplemental EA. Detailed data regarding stands meeting regional old growth criteria (Green and others 1992) is located in the project file (I-1x, I-1t, H-11). Stand diagnosis from field work is located in project file I-3. Stand walk through notes (H-25) for wildlife have information on snags such as cavity nester presence and other information that was used to develop the project and complete the analysis.

Comment: The SEA at 3-327 states that there are field surveys of snags and old growth; this survey data was not provided in the SEA for either snags or old growth, however; why not? (BB-7)

Response: The list of old growth stands is located in the project file (I-1x, I-1t, H-11). Stand diagnosis from field work is located in project file I-3. Stand walk through notes (H-25) for wildlife have information on snags such as cavity nester presence and other information that was used to develop the project and complete the analysis.

Comment: There is no actual analysis of cumulative impacts of past and planned management activities (i.e., logging and fuels treatments) on old growth wildlife; all the SEA does is provide a broad estimate of old growth as per FIA data; this is reported to be 9%; since this 9% is far below the recommended levels of 20-25% for wildlife, there must be some significant cumulative impacts of past logging on 57% of the landscape in the project area outside of wilderness; without any analysis, the agency cannot claim these impacts have not been significant. (BB-7)

Response: The cumulative effects section for old growth associated species is located in the supplemental EA pgs. 3-332, 3-335 and 3-338. The Vegetation section discusses the difference in definitions between late seral classes used by Amendment 21 and the Green et al. definition for old growth (supplemental EA pg. 3-46). The broad scale estimate for old growth on the Flathead National Forest is 11.63% with a 90% CI from 9.56 to 13.77 (supplemental EA pg. 3-47). The FIA data derived estimate of old growth (supplemental EA pg. 3-47) is made at scales larger than the project area and is not

Appendix 5-34 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

separated like the HRV estimates of late seral by the 3 elevation classes; subalpine, montane and lower montane, in Amendment 21. Simply because an area of the project is located outside of the wilderness does not mean it necessarily received past logging or even recent logging or stand management. Further, forests are dynamic and change over time. The cumulative effects analysis considered old growth associated species, their associated habitat conditions in the project area, and considered past, present and foreseeable conditions. This analysis determined there were no significant cumulative impacts.

Comment: The SEA at 3-333 suggests that logging will create old growth; the science behind this claim was never provided; without documentation, this claim is very misleading to the general public, as it implies logging will benefit old growth. (BB-7)

Response: Characteristics and definitions of old growth are explained by Green et al. (1992) (H-46). Based on a review of forest disturbance ecology of the Northern Rockies and stand attributes, the authors established minimum criteria for old growth. Part of this minimum criteria includes trees per acre at a given diameter level. The SEA discusses how treatments in the Glacier Loon project would keep stands on track to provide future old growth and how treatments would produce larger diameter, long-lived trees faster over time (supplemental EA pg. 3-332). The analysis states: “In the proposed units where Intermediate Treatments are proposed (e.g., Improvement Cut, Commercial Thin, Sanitation, Salvage), many dominant and co-dominant trees would be retained. Long-lived, fire-resistant, shade-intolerant species (typically; western larch, ponderosa pine, western white pine, and occasionally Douglas-fir) would be favored for retention; smaller trees would be removed to improve stand health, enlarge the growing space of desirable trees, and reduce tree competition for limited site resources. In most cases, the proposed intermediate forest health treatments would keep the stands on a trajectory towards providing old growth habitat conditions for old growth associated wildlife species in the future.” Age of trees and other associated attributes to old growth forest (listed by Green et al. (1992)) would occur over time. The project would maintain snags and down woody debris.

Comment: Table 3-13 in the SEA at 3-41 notes that late seral forests, or old growth, is defined by a minimum 15 inch dbh; the SEA at 3-46 also states that the analysis used seral stage of evaluate old growth; this would provide an invalid measure of old growth acreage, since lodgepole pine old growth has a minimum dbh of only 10 inches as per Green et al. (1991); it seems highly likely that most of the proposed regeneration harvest units for the project, which include up to 773 acres (Table 3-27 at 3-71), are actually lodgepole pine old growth; in addition, an unknown acreage of the intermediate harvest units, or up to 968 acres, may also actually be lodgepole pine old growth. (BB- 7)

Response: Table 3-13 in the SEA at page 3-41 does not provide any information

Appendix 5-35 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

relative to tree diameters and old growth. The supplemental EA on page 3-46 makes distinction between late seral stage, as defined in Amendment 21, and old growth as used in the Glacier Loon Project: “Of note is the fact that Amendment 21 uses the term Late Seral to describe Old Growth. However, in the Glacier Loon Analysis, Old Growth is defined by meeting the criteria of Green et al. as mentioned previously. Therefore, Late Seral in this analysis would likely contain Old Growth areas, but it also contains large tree dominated areas, which do not meet the Green et al. old growth definitions.” Table 3-17 in the supplemental EA at page 3-47 portrays the distributions by Amendment 21 seral stages and therefore contains large tree dominated areas that don’t meet the Green et al. criteria. There were no lodgepole pine stands in the project area meeting old growth criteria (see Project File Exhibit I-1x).

Comment: Disclose the current level of old growth forest in each third order drainage in the Project area; disclose the method used to quantify old growth forest acreages and its rate of error based upon field review of its predictions; disclose the historic levels of mature and old growth forest in the Project area; disclose the level of mature and old growth forest necessary to sustain viable populations of dependent wildlife species in the area; disclose the amount of mature and old growth forest that will remain after implementation; disclose the amount of current habitat for old growth and mature forest dependent species in the Project area; disclose the amount of habitat for old growth and mature forest dependent species that will remain after Project implementation; disclose the method used to model old growth and mature forest dependent wildlife habitat acreages and its rate of error based upon field review of its predictions. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #85 to 92 responded to these same comments. Due to the length of the responses provided in the first decision notice, we have decided not to repeat them here, but rather incorporate those responses with the following: Both the Vegetation analysis in the supplemental EA (pg. 3-31) and the Silviculturalist report (PF Exhibit I-1) discuss differences between late seral forest and old growth defined by Green et al. (1992), discloses the estimated historic range of variation for the Swan Geographic unit for later seral forest as determined by Amendment 21, discloses the current estimated distribution of later seral in the project area and the effects of the project activities to a variety of seral stages. The supplemental EA discloses the estimated old growth at a 5th code HUC and at the Forest Level and the rates of precision associated with this estimate (supplemental EA pg. 3-328). Old growth associated species and the effects of the project are discussed in the Chapter 3 analysis of the supplemental EA pg. 3-325.

Appendix 5-36 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

ROADLESS

Comment: Please utilize the NEPA process to clarify any roadless boundary issues. It is not adequate to merely accept previous, often arbitrary roadless inventories— unroaded areas adjacent to inventoried areas were often left out. Additionally, there is a lot of public support for adding unroaded areas as small as 1,000 acres in size to the roadless inventory…disclose how the project complies with the Roadless Rule (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #140 responded to it by stating: “The Glacier Loon Project Area does not contain any Inventoried Roadless Areas. An unroaded analysis was completed for the project area (Project File Exhibits O-8 and O-9).” This unroaded analysis evaluated the project area for potential effects to unroaded resource values. A block of land of approximately 1770 acres does occur in and near the analysis area (portions of Sections 9, 10, 15, 16, 21, 28) that has no identifiable roads or motorized trails. An analysis was performed to determine the effect of proposed activities on the wilderness characteristics of these 1770 acres. The analysis concluded that: “Proposed management activities (timber harvest) would impact the unroaded area for a short period of time until trees are re-established as the dominant feature on the landscape. The impact of harvest activities of 9-21 acres within the 1770 unroaded acres is not expected to have a significant impact on the areas ability to be recommended for wilderness due to the limited effect of activities, (no permanent roads, small acreage) as well as due to the unroaded areas small configuration and proximity to areas that are not suited for roadless area management.”

Appendix 5-37 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

SOILS

Comment: Please provide estimates of current detrimental disturbance in all previously established activity areas in the watersheds affected by the proposal. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #148 responded to it by stating: “The cumulative impacts of all disturbances were considered in assessing detrimental soil disturbance in proposed activity areas. Since no activities would occur outside of the treatment units, no cumulative effects would occur. There is no need to display the existing condition of soils outside of proposed activity areas or treatment units. Evaluation of watershed-level effects is more appropriately done on a watershed basis using models and other watershed analysis techniques. Effects to the watershed resource as a whole are discussed in the Hydrology Section of the EA on pages 3-149 thru 3-182.” In addition to that response, existing condition detrimental soil disturbance for each proposed unit is displayed in the supplemental EA on pages 3-14 and 3-15 (Table 3-4). Only units with existing detrimental soil disturbance are displayed in this table.

Comment: Please disclose measures of, or provide scientifically sound estimates of, detrimental soil disturbance or soil productivity losses (erosion, compaction, displacement, noxious weed spread) attributable to off-road vehicle use. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #150 responded to it by stating: “Quantification of existing detrimental soil disturbance was conducted on all proposed units in the Glacier Loon Project regardless of source (e.g. past- logging, livestock grazing, and off-road vehicle use). Detrimental soil disturbance values were collected in a manner consistent with the Forest Service Soil Disturbance Monitoring Protocol and the Region 1 Approach to Soils NEPA Analysis Regarding Detrimental Soil Disturbance In Forested Areas.” In addition to that response, the Soils Section of the supplemental EA on pages 3-24 thru 3- 27, Table 3-10 displays cumulative detrimental soil disturbance for each unit. The project does not rely on any proposed soil mitigation/remediation.

Comment: Please disclose how the proposed “treatments” would be consistent with Graham, et al., 1994 recommendations for fine and coarse woody debris, a necessary consideration for sustaining long-term soil productivity. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #152 responded to it by stating:

Appendix 5-38 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

“Graham et al. 1994 refined the recommendations for coarse woody debris found in Harvey et al. 1981 where the material was related to occurrence of ectomychorrhizal fungi, not to increased soil productivity. Coarse woody debris has no effect on soil nitrogen or other nutrients regardless of decay stage and it can compete with vegetation for limited nutrients through immobilization (Busse 1994; Prescott and Laiho 2002). Specific direction is for coarse woody debris is provided by the Flathead Forest Plan Amendment 21. The Selected Alternative will comply with this standard for downed wood. Coarse woody debris (tons/acre) is specified by potential vegetation group as follows:

Potential Vegetation Group Tons/Acre Range Dry 4-12 Moist 8-21 Cold 7-20

Comment: Disclose the analytical data that supports proposed soil mitigation/remediation measures. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #82 responded to it by stating: “The project does not rely on any proposed soil mitigation/remediation measures”

Appendix 5-39 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

TRANSPORTATION

Comment: No temporary roads should be built… The EA does not disclose how the Flathead intends to maintain the road system in the Glacier Loon area. What is the road budget? (BB-5)

Response: A no temporary road construction alternative was studied and not considered in detail due to economic infeasibility (supplemental EA pg. 2-7). Approximately 29.3 miles of NFS roads will receive best management practices prior to project activities. The project also proposes to install one aquatic organism passage structure on NFS road 9552. These activities will address the capital improvement needs identified in the project area. The average CMRD (construction and maintenance for roads) funding the past 4 years (2014- 2017) on the Flathead National Forest has been approximately $810K. A more detailed analysis for the budget and maintenance of roads on the Flathead National Forest can be found in the Travel analysis Report for the Flathead National Forest (pgs. 18-21) and within the Forest Plan Assessment of the Flathead National Forest, Part 2, April 2014 (pages 198- 201).

Comment: Many, if not most, of the new temporary roads for the Glacier Loon project access logging units that are classified as "intermediate harvest". The SEA does not identify that there will be no further management of these stands, and thus, no future use of the new roads being constructed to provide access to them. Please clarify what the long-term management of these new roads will be; if they will never be used for timber management again, then this should be clearly identified in the SEA. (BB-7)

Response: The forest plan temporary road definition defines temporary roads used for a single, short-term use: e.g., to haul timber from landings to Forest development roads. The stated temporary roads are planned for single short term use and additional future access needs for management of these stands is beyond the scope of this analysis.

Appendix 5-40 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

VEGETATION

Comment: The SEA on page 2-10 states cutting unit 48 will exceed 40 acres and hence needs approval from the Regional Forester and 60 days notification of the public, which it claims is being provided via the SEA. Why then is the comment period for the SEA only 30 days? (BB- 4)

Response: The Swan Lake District Ranger has determined that during project layout, the combined units #47 and #48, which are adjacent and the subject of the “opening greater than 40 acres”, will be broken into several subunits separated by buffers resulting in no opening being greater than 40 acres in size. The supplemental EA discusses this in more detail on pp. 3-74 and 3-75. The 60-day public notice of openings over 40 acres in size required by Regional direction is being accomplished through the public review of both the Glacier Loon Project EA and supplemental EA as stated on p. 3-75 of the supplemental EA.

Comment: The EA fails to consider new science regarding thinning and mountain pine beetle by Six, et al. Management for Mountain Pine Beetle Outbreak Suppression: Does Relevant Science Support Current Policy? (BB-5)

Response: Overall, the intent of the article by Six et al. (2014) was to dispel misconceptions within the public policy arena that may have contributed to recent federal legislation. The points presented in the article argue against indiscriminate applications of direct and indirect mountain pine beetle control treatments to halt severe and widespread mountain pine beetle infestations. Points were also raised about the extensive application, and efficacy of, direct and indirect control treatments. While the issues discussed within the article are appropriate, some of the conclusions are not applicable to conventional management strategies implemented by the Forest Service. This is primarily because Forest Service treatments are not implemented to stop ongoing mountain pine beetle infestations that are severe and widespread. Rather, the Forest Service’s indirect control treatments are implemented prior to severe infestations to enhance tree survival and resilience to multiple disturbances. The Forest Service’s direct control treatments are implemented as only one component of an integrated pest management (IPM) strategy to provide short-term protection for high-value trees. Best-available science and the project monitoring by Forest Service professionals indicate direct and indirect control treatments can reduce future mountain pine beetle- caused tree mortality, and augment other resource benefits, when they are applied properly at appropriate spatial scales (Fettig et al. 2007; Fettig et al. 2014a; Fettig et al. 2014b; Gillette et al. 2014; Progar et al. 2014). The USFS response to recent bark beetle activity within the western United States, including mountain pine beetle infestations, is outlined within the Western Bark Beetle Strategy (WBBS) (USDA 2011). This strategy does not include directives to stop severe and widespread mountain pine beetle infestations with direct control. Rather, Forest Service priorities are to provide for public safety, restore ecological function, and

Appendix 5-41 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments increase resilience to multiple disturbances. It is true that resistance, resilience, and adaptation concepts are applicable to other natural processes in the forest ecosystem. These concepts have been incorporated into the supplemental EA.

Comment: What surveys have been conducted to determine presence and abundance of whitebark pine re-generation? If whitebark pine seedlings and saplings are present, what measures will be taken to protect them? Please include an alternative that excludes burning in the presence of whitebark pine regeneration (consider ‘Daylighting’ seedlings and saplings as an alternative restoration method). Will restoration efforts include planting whitebark pine? Will planted seedling be of rust-resistant stock? Is rust resistant stock available? Would enough seedlings be planted to replace whitebark pine lost to fire activities? Have white pine blister rust surveys been accomplished? What is the severity of white pine blister rust in proposed action areas? (BB-6)

Response: The cold potential vegetation group (PVG) comprises 16% of the project area. This group is typified by even-aged and multi-aged stands of primarily shade- intolerant whitebark pine and occasionally subalpine larch in a naturally functioning ecosystem. Stands can be dominated by shade tolerant subalpine fir and Engelmann spruce. This PVG occurs at high elevations on severe sites. White pine blister rust and mountain pine beetle are causing extensive mortality in whitebark pine. No treatments are proposed in whitebark pine ecosystems in the Glacier Loon Project and no whitebark pine planting is being considered.

Appendix 5-42 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

VEGETATION: WATER HOWELLIA

Comment: The Project and SEA violate the Forest Plan as amended because it allows for harvest activities to occur within 300 feet of ponds if a road bisects the buffer. Amendment 20 requires ““Retain a forested buffer of a minimum width of 300 feet from the margin of ponds (both occupied and unoccupied) that provide Howellia aquatilis habitat.” Amendment 20 provides no exception for narrowing the 300’ buffer where roads unfortunately violate it. (BB- 4)

Response: The project does not violate the Forest Plan. The project will follow Amendment 20 and not allow ground disturbing activities that are inconsistent with natural processes. As was disclosed in the supplemental EA in a number of places, there will be no vegetation treatments within 300 feet of howellia occupied or unoccupied ponds even if a road bisects the buffer.

Appendix 5-43 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: GRIZZLY BEARS

Comment: The 2014 A19 BiOp (p. 71) requires that each project make progress to reduce OMAD, TMAD, and increase security core. The operative word “and” does not mean “or”. The Project does not comply with the 2014 BiOp and it’s in part because it does not reduce OMAD and TMAD and increase Core in both subunits. The Project would reduce total road densities in both subunits and would decrease open road densities in the Glacier Loon subunit. (BB-4)

Response: Based on the contextual reading of Amendment 19 and the 2014 Biological Opinion, the “and” is not to be interpreted as propositional logic, but rather is listing the three metrics for which Amendment 19 has objectives. Amendment 19 does not state that “each project” or that progress must be made for all OMAD, TMAD and security core calculations. Amendment 19 of the Flathead LRMP states; “Forest Service actions will result in a net gain towards the objectives on National Forest System lands” (A19 Decision Notice Pg. 4). The Objectives (plural) for subunits great than 75% National Forest Systems lands are listed as three distinct separate objectives (A19 Decision Notice Pg. 4). Discussion throughout the 2014 Amendment 19 Biological Opinion provides important context that the different objectives are independent of each other and progress does necessarily need to include all three metrics (OMAD, TMAD and Security core). The 2014 Biologic Opinion discusses each of these metrics separately as independent objectives (pgs. 45-47 and Tables 6, 7). Further, the Biological Opinion discusses different projects where only OMAD and/or TMAD was decreased, not necessarily that progress is made in all 3 metrics simultaneously (pgs. 75-83).

Comment: The 2014 BiOp’s Appendix C misstates that the listed subunits “meet A19 objectives of no net gain in OMAD or TMAD and no net loss of core.” Based on our analysis, the Forest Service increased TMAD and/or decreased Core on its own lands in 10 of the 11 subunits, including Buck Holland and Glacier Loon. The increased OMAD and TMAD since 2010 and the decreased Core are not allowed the Forest Service under the terms of the Swan Valley Grizzly Bear Conservation Agreement (SVGBCA), nor are they allowed the Forest Service since 1995 under A19. (BB-4)

Response: Forest Service actions have not led to an increase in OMAD/TMAD or a decrease of Security Core. Annual monitoring for Amendment 19 accounts for changes in the baseline condition for subunits which may include changes in road alignment, changes in road layout on Plum Creek Timber or State lands, land transfers, updates to the road database to better reflect ground conditions etc. These fluctuations affect the numbers reported for subunit calculations without any USFS actions. The Flathead Forest reports these accounting adjustments and the cause annually to the USFWS. For example, in the Glacier Loon subunit TMAD appeared to increase from 39% to 45% in 2005 (See A19 2005 monitoring report). These changes were due to corporate updates in the Plum Creek Timberlands roads database. The Moving Window approach

Appendix 5-44 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

is sensitive to spatial changes of road features. As a result, making the database more accurate to better reflect on the ground road contours, curves or intersections can affect calculations without any physical changes on the ground. Annual A19 monitoring is submitted to the USFWS and addresses these spatial updates, land ownership changes in the baseline condition. This information provides transparency that the Flathead Forest is abiding by the “no net increase” standard in A19.

Comment: The Flathead cannot simultaneously fail to fully achieve its A19 objectives and not apply the “3 and 7” rule required until the A19 objectives are achieved. Additionally, the SEA incorrectly defines “no net increase” to mean a comparison between before and after the Project, rather than the simultaneous offsetting of opening or building roads during the Project by closing or decommissioning nearby roads. The Flathead knows better; the SEA is fatally flawed and not in compliance with A19 and the overall requirement that decisions must favor the grizzly bear in MS-1 habitat. Determinations of “may affect, likely to adversely affect” (SEA at 2-35) do not favor the grizzly bear. (BB-4)(BB-5)

Response: While the 3 and 7 timber activity rule for MS-1 was recommended by the USFWS in their biological opinion on the Forest Plan (1989) and was mentioned in the terrestrial biological assessment for Amendment 19 (1994) and in the subsequent biological opinion (1995), the environmental assessment and the decision notice for Amendment 19 did not address this timing rule. Additionally, the “3 and 7” and “5 and 5” (MS-2) recommendations were subsequently dropped by the USFWS in future biological opinions on Amendment 19 (2005 A19 BiOp and 2014 A19 BiOp). Amendment 19 standards state “there will be no net increase in total motorized access density great than 2 miles per square mile, no net increase in open motorized access density greater than 1 mile per square mile and no net decrease in the amount or size of security core area” (A19 DN pg. 4). There is no direction in Amendment 19 that requires “simultaneous offsetting” of opening or building roads. Throughout the history of implementation of Amendment 19, the implementation of the “no net increase” standard is based on pre and post project results. This calculation is clearly analyzed in the SEA and in consultation for the Glacier Loon project. Further, The USFWS has provided programmatic consultation for this approach in the Amendment 19 Biologic Opinions supported by annual monitoring using this pre/post calculation. The “may affect, likely to adversely affect” rationale is described in the Updated Glacier Loon BA and is based on the baseline motorized access habitat condition, not the project level effects. The Glacier Loon project would improve the motorized access density (which the determination is based on) at the end of project activities. How the project favors grizzly bear recovery and conservation is described in response to comments #18 in Appendix 5 of the previous decision notice (pg. 268). Additionally, the draft decision notice also provides rationale for how the project favors the needs of the grizzly bear when grizzly bear habitat and other land uses compete.

Appendix 5-45 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Comment: It appears the Project would decommission roads before omitting them from calculations of TMRD; however, in order to be consistent with A19 and the best available science, the Supplemental EA must include in all calculations of TMRD throughout the cumulative effects area all roads that are not adequately revegetated in order to no longer function as a road or trail. (BB-4)

Response: Amendment 19 does not require a road to be revegetated before being omitted from TMAD (Total Motorized Access Conditions). Amendment 19 Appendix DD states that; “reclaimed roads that fully satisfy the definition of a reclaimed road will not be included in calculations of open motorized access density, total motorized access density or security core. Amendment 19 defines reclaimed roads as a road that “has been treated in such a manner so as to no longer function as a road or trail or has a legal closure order until reclamation treatment is effective. This may be accomplished “through one or a combination of treatments including: re-contouring to original slope, placement of natural debris, or revegetation with shrubs or trees” (Amendment 19, page D-2). Additionally, culverts or other water passage structures aligned with stream channels are removed. Amendment 19 and the best available science speak to motorized access on road for grizzly bears. The Amendment 19 DN speaks directly to “limitations on motorized access” (DN pg. 7). The Glacier Loon project discloses cumulative effects effecting motorized access calculations in the Glacier Loon and Buck Holland subunits in the grizzly bear cumulative effects sections (supplemental EA pgs. 3-219 to 3-247). Road decommissioning and its effects to road density are discussed in this analysis as well.

Comment: The agency is violating the NEPA and ESA by providing false claims in the SEA; the agency claims that there will be a net decrease in TRD after project completion; this is clearly false, as there will be a significant increase in new temporary roads; as is noted in the SEA, if a road is planned for re-use, it is considered in the TRD density; to note just a few of the proposed units, seed tree units that involve new temporary roads that will be used again in the future for additional management include units 5, 10, 17, 45, 52, 53, 57, 58, 59, 60, 61, 62, 70 and 90; future use of the new temporary roads will be required for these units; in addition, the shelterwood units that require new temporary roads include units 80, 84, and 85, for example; for the commercial thin units that will require future reuse of new temporary roads, this includes units 66, 67 and 76, for example; the agency's claim that the new temporary roads built to these units will never be used again in the future is clearly false; if these roads have planned future motorized use, they have to be included in the total road density, as the IGBC Task Force Committee recommendations (1998). (BB-7)

Response: The Glacier Loon Project does not propose building any permanent roads (supplemental EA pg. 3-238). Temporary roads would be rehabilitated after construction. After proposed activities are completed, including temporary road rehabilitation, no future foreseeable proposal exists to rebuild these roads again. Temporary roads are considered in the “during” activity OMAD, TMAD and security core calculations (supplemental EA Table 3-27 pg. 3-245). TMAD would not be increased

Appendix 5-46 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments after completion of project activities because temporary roads would be reclaimed (SEA pg. 3- 239). The project is consistent with Amendment 19 direction for roads included in TMAD. Temporary roads would be rehabilitated after project activities and would not be included in TMAD after activities are completed.

Comment: Amendment 19 is not being met because core habitat is below the required 68% in this subunit, and core will not be increased with this project; Table 3- 73 shows existing core to be 40% in the Glacier Loon subunit, and 41% in the Buck Holland unit; these will not be increased with this project; the agency is not meeting the requirement of Amendment 19 that they improve towards Amendment 19 requirements. (BB-7)

Response: The Glacier Loon project is consistent with Amendment 19 direction. The project would not result in a net increase in OMAD, TMAD or a net decrease in security core. At the end of project activities, the project would result in a decrease in net decrease in TMAD in the Glacier Loon subunit moving towards A19 objectives. Amendment 19 include 3 different road density objectives toward which “FS Actions” (A19 DN) can make progress towards. The supplemental EA discusses the progress toward these objectives on page 3-246. Based on A19 direction, the Glacier Loon project itself, is not required to increase security core to 68% of either project subunit.

Comment: The impact of hunter use on reclaimed roads was not assessed in the SEA; this is one of the biggest increases in grizzly bear mortality risk; this impact needs to be measured for all roads after implementation. (BB-7)

Response: There is no science that directly speaks to non-motorized hunter effect on grizzly bear mortality risk in the NCDE. These effects are unknown. Schwartz et al. (2010) indicates that open motorized access affects grizzly bear mortality risk, not human use on roads that are closed to public motorized access (TMAD). The supplemental EA discusses grizzly bear mortality risk to human activity on roads and other routes closed to public motorized use (pg. 3-240).

Comment: The SEA did not define specifically how logging traffic will negotiate the many gates that will be on all the project roads that will be closed to the public; if the gates will not be closed when logging occurs, then how can the SEA claim that there will be no public use on them? (BB-7)

Response: Where a restricted road (gated or bermed) intersects with a road open to public motorized travel, gates would be installed (in the case of a berm) or be maintained. These gates would remain shut while activates occur and would be closed behind contractors as they enter or exit for project activities. This is common practice for implementation on the Flathead National Forest which follows as a contractual item from the design criteria (supplemental EA Table 2-16).

Appendix 5-47 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Comment: There is no information on firewood collection from the new roads; please define if there will be any public use of these new roads, or other restricted roads that will be opened for logging, for firewood harvest. (BB-7)

Response: Public firewood collection on the Flathead National Forest is allowed from open motorized routes with a valid permit. Project temporary roads, skid trails or other restricted roads not open to public motorized access will remain closed to public firewood collection during the Glacier Loon project.

Comment: We added up the units where spring exemptions for logging are being applied (SEA 3-231), and this includes 32 units at 535 acres in spring habitat; these exemptions include about a third of all logging units for Alternative B. This seems like a huge number of units and acres being exempted from spring bear habitat; why are these exemptions needed, and why are they consistent with MS-1 habitat, where the bear is to be emphasized? (BB-7)

Response: Spring habitat guidelines defined in the Swan Valley Grizzly Bear Agreement are discussed in the supplemental EA (pg. 3-230). Units located in Spring Habitat have spring operating limitations applied. Units not included in the timing restricts are not located within Spring Habitat. Specific impacts of units, their timing and effects of displacement to grizzly bears are addressed in the grizzly bear section of the supplemental EA.

Comment: There is no map of grizzly bear spring habitat; why not? There is no map of grizzly bear linkage areas; why not? (BB-7)

Response: Maps of linkage zones and the low elevation area used to define spring habitat for the SVGBCA were added as exhibits under section AA of the project file. Spring habitat is defined in the supplemental EA as well as in exhibit H-124. The supplemental EA identifies which units are located in Spring Habitat as defined by the Swan Valley Grizzly Bear Agreement.

Comment: There is no analysis in the SEA about the current effectiveness of core habitat in this bear subunit; this core does not meet the recommended guidelines for core, where habitat should be distributed across all elevational gradients; the SEA makes the lack of good habitat distribution in the current core habitat by noting that "some" of the important spring bear habitat will have to be protected during logging; why isn't this important spring habitat located within a core area? (BB-7)

Response: It is not clear what source the comment uses for “recommended guidelines for core, where habitat should be distributed across elevational gradients.” The 1998 IGBC Task Force Grizzly Bear/Motorized Access Management report recommends for the identification of core: “Consideration should be given, when information is available to do so, to ensure that core area(s) meet seasonal bear habitat needed by assuring that spring, summer, fall and denning habitats in the entire analysis area” Objectives for security core are defined by Amendment 19. Neither Amendment 19 nor the Swan

Appendix 5-48 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Valley Grizzly Bear Conservation Agreement contain guidelines for distributing Security Core across elevational gradients. It should be noted that grizzly bear core (defined by Amendment 19) and Spring Habitat (defined by the Swan Valley Grizzly Bear Conservation Agreement) are two different distinctions. Effectiveness and effects to seasonal components of grizzly bear habitat are considered throughout the analysis. The Glacier Loon project would not affect grizzly bear security core or denning habitat (supplemental EA pg. 231). The project considers grizzly bear throughout the analysis. Displacement, habitat security and mortality risk affect grizzly bear habitat effectiveness and are discussed in the supplemental EA (Chapter 3 grizzly bear section). The project would “avoid potential disturbance in important spring habitat” by restricting activities in Spring Habitat until after June 15th (supplemental EA pg. 3-230). Further, while a subunit is inactive, no commercial or salvage activities would occur after August 31, limiting disturbance to fall habitats.

Comment: There can be extensive logging activity in the summer within any unit that contains salvage; please define which units there include. There can only be an aggregate of 30 days of summer logging in units that include salvage; please provide a description of the estimated identification of units per summer season that this 30 days would generally allow logging within; the public has no means of understanding what the actual level of disturbance this criteria allows, and this needs to be explained. (BB-7)

Response: Project file exhibit (AA-4) identifies salvage units in the Glacier Loon project. Those units that qualify as salvage are: 6-10, 19-20, 24, 48, 49, 52, 57-59, 61, 63, 70, 73-74, 77, 79-82, 88-90, 92, and 94. The Swan Valley Grizzly Bear Conservation Agreement states that salvage activities “shall not continue for periods of more than two consecutive weeks or for more than 30 days in the aggregate during a calendar year in the non-denning period” (SVGBCA pg. 4). A unit map is available in the supplemental EA (Maps 2-1 through 2-6). Disturbance for project effects for all units was analyzed in the supplemental EA for grizzly bears. This potential for disturbance including effects to habitat, project design criteria to mitigate potential disturbance by implementing work on the proposed units was disclosed to the public in the supplemental EA. The grizzly bear analysis in the supplemental EA determined the project was compatible with the needs of grizzly bear recovery and conservation (pg. 3-247).

Comment: The SEA fails to provide specific information as to how roads open to the public in this project will have vegetative screening for grizzly bears; simply stating that this mitigation measure will reduce displacement impacts to grizzly bears is insufficient; there needs to be a map of where these screens will be provided; also, what are the criteria for a vegetative screen? What is the width, and what should the site distance be? Does it have to be on both sides of the road? How does the proposed distribution of screening compare to a 100% screening level? Please list the roads where screening will be provided, as well as provide a map of these roads. (BB-7)

Appendix 5-49 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Response: Visual screening means that sufficient vegetation be able to hide an animal at one site distance (SVBCA pg. 4). The distance for the Flathead National Forest is 200 feet. If an opening will be created by project activities on both sides of an open road, visual screening will be retained on both sides of an open road. It is not clear what is meant by the comment means by “proposed distribution of screening compare to a 100% screening level.” All existing visual screening will be retained along all open roads in the project area within units and outside of proposed units. A map of roads that are open to public motorized travel is located in project file R-7. Open roads existing in the project area are all or portions of #561, 9780, 9576, 79, 79C, 9575, 9590, 9587, 79A, 79L, 561F, 9579 and 561Q. The Swan Valley Grizzly Bear Conservation Agreement states that visual screening will be left adjacent to all open roads.

Comment: The SEA notes that treatment adjacent to riparian areas will range from 597 to 612 acres; it is also noted that these riparian areas have a high value to grizzly bears; it is unclear why this displacement of bears from important limited habitat is consistent with MS-1 habitat (BB-7)

Response: Rationale for how the project is consistent with MS-1 direction to favor the needs of the bear is located in the supplemental EA on page 3-247. Potential displacement for grizzly bears was described in the supplemental EA as “short term” (pg. 3-238) and forage production would increase again in approximately 5 years (supplemental EA pg. 3-237). The selected alternative has relatively low impacts adjacent to riparian habitat relative to the other alternatives in the supplemental EA. Further, the project does not propose any treatments in important avalanche chute or shrubland habitats (supplemental EA pg. 3-237).

Comment: Amendment 19 is a violation of the ESA because it allows unlimited open road densities during any given project; for the Glacier Loon project, the open road density is already above the 19% limit, and will almost double, depending upon alternative; why is this consistent with MS-1 habitat; why is this considered a valid conservation strategy for grizzly bears, as it allows a huge increase in displacement and mortality risk? There is no limit to the periods when open road densities can be increased as well. So why is this a valid conservation strategy for this threatened species? (BB-7)

Response: The USFWS determined that Amendment 19 direction was “not likely to jeopardize the continued existence” of grizzly bears (2014 Biological Opinion on Amendment 19 Pg. 109). The Glacier Loon project “during” road density calculations are consistent with Amendment 19 direction and consultation with the USFWS. After project completion, the project will result in a net decrease in total road density. It should be noted, that public motorized access will not change during project activities. Increases in open road density was calculated from contractor and USFS administrative use for project activities. Timing restrictions for when units may be active are described in the supplemental EA in the grizzly bear section. These timing restrictions including spring habitat restrictions, inactive/active subunit guidelines and winter harvest, all limit

Appendix 5-50 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments the actual increase in open road density that would occur from implementation of project activities (supplemental EA pg. 3-245). The project analyzed displacement/mortality risk and consulted with the USFWS under Section 7 of the ESA. The USFWS determined that the project is “not likely to jeopardize the continued existence of grizzly bears” (Glacier Loon 2015 Biological Opinion pg. 6).

Comment: The mitigation measure that hiding cover will remain within 600 feet of openings (SEA 2-39) is never actually verified; for example, it appears that all intermediate treatments will have hiding cover removed due to fuels treatments; there are many units adjacent to one another, both clearcuts and intermediate treatments; it does not seem possible that these vast expanses of treatment areas are within 600 feet of cover; it seems that the agency is providing a false claim as per mitigation. (BB-7)

Response: The grizzly bear hiding cover section (SEA pg. 2-237) describes the assumptions and analysis for intermediate treatments that would continue to provide hiding cover. The design criteria for distance to cover is not false. The units all of the action alternatives were designed and laid to ensure no opening created would be more than 600 feet to hiding cover to be consistent with Forest Plan direction.

Comment: The SEA at 3-228 claims that the portion of temporary roads within harvest units is not counted as road mileage (mortality risk); as a result, these new roads are discounted by 80%o for Alternative B, by 74% for Alternative C, and by 75% for Alternative D; the published science that allows for eliminating road impacts on roads through harvest units was never cited; this documentation needs to be provided. (BB-7)

Response: The supplemental EA (3-228) states: “Temporary roads that are constructed within a unit boundary do not have additional displacement effects to grizzly bear above the effects of the unit treatment; the ground disturbance within the treated unit would include the temporary road construction.” This means that the mechanical motorized activity in a unit may encompass the motorized use effects and ground disturbance over just the temporary road itself. This statement does not mean that the effects of temporary roads were not considered in the analysis. The temporary roads are clearly counted in road mileage and in the grizzly bear analysis (e.g. Table 3-65).

Comment: The SEA does not actually provide any information, such as in an appendix, as to how open and total road densities were measured for this project; for example, as noted above, were all the new roads counted, or just portion? The baseline information as to how road density analyses were done needs to be provided to the public. (BB-7)

Response: Assumptions for the “during” project road density calculations are described on pg. 3-245 of the supplemental EA. Haul routes, and temporary roads are included as open roads in open road density calculations and temporary roads are added to total road density calculations. All units are assumed to be active simultaneously, though as described in the supplemental EA, this is highly unlikely. For post-project calculations, temporary roads are rehabilitated (supplemental EA pg. 3-239) and no longer count towards road densities.

Appendix 5-51 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Decommissioned roads in the project are not counted toward road densities after completion of project activities (supplemental EA pg. 3-240).

Comment: The SEA needs to identify that the project area outside of wilderness is currently "sink habitat" for grizzly bears, as it exceeds the 19-19-68 measure considerably; and the agency needs to identify that the project will further exacerbate this sink habitat impact. Managing this MS-1 habitat as sink habitat is a violation of the Forest Plan as well as the ESA. (BB-7)

Response: The subunit area is identified as the appropriate scale to analyze effects the grizzly bear (supplemental EA pg. 3-220). The Glacier Loon subunit includes the Wilderness. “Sink habitat” is an area were death rates and emigration exceed birth rates and immigration. There is no local information to suggest that lands outside the Wilderness are “sink habitat” for grizzly bears. The best available science (Mace et al. 2011; Costello et al. 2015) indicates that the grizzly population is growing (SEA pg. 3- 222) illustrating that the habitat in the NCDE is not a sink, but a source. Mace et al. (2011) found high survival rates for grizzly bears which include grizzly bear known to use the Glacier Loon and Buck Holland Subunits. Rational for how the project is consistent with MS-1 is located in the supplemental EA on pg. 3-247. The Regulatory consistency section discusses Forest Plan direction (supplemental EA pg. 4-243).

Comment: The SEA at 1-5 states that all alternatives comply with the Swan Valley Grizzly Bear Conservation Agreement; however, the open road density during the restricted summer period during project activities is never provided to demonstrate that this does not exceed the 33% maximum of 1 mile per square mile; Table 3-71 lists this criteria, but does not say what the open road densities (percentage over 1 mile per section) will be; Table 3-72 shows that during project activities, this level will reach 40% or greater; where is the information on why this won't exceed 33%? (BB-7)

Response: Table 3-69 clarifies that that open road densities would increase temporarily but there would be no net increase at project completion. The Forest Service has achieved an open road density of less than 33% during the restricted period in both the project subunits (Table 3-71). The 33% open road density guideline in the SVGBCA does not refer to “during project” road density changes as clarified by Amendment 19. The SVGBCA states “The Forest Service will continue to adhere to all Objectives, Standards and Guidelines found in the Flathead Forest LRMP, as amended” (SVGBCA pg. 5).

Comment: The SEA needs to provide a detailed description of what the ORD and TRD will be during the restricted period to demonstrate how the SVGBCS meets the management needs of the grizzly; simply stating that this conservation agreement will benefit the grizzly bear as applied is a violation of the NEPA unless the actual effectiveness and results of this conservation agreement are defined to the public. (BB- 7)

Appendix 5-52 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Response: The analysis describes how following the guidelines of the SVGBCA benefit the bear. The supplemental EA discusses the assumptions used for the “during” project road density analysis as a “worst case scenario” analysis meaning all the units are assumed to be active simultaneously during the restricted period. The supplemental EA discusses how the SVGBCA guidelines relate to mitigating disturbance and mortality risk for the grizzly bear. Spring habitat restrictions favor spring habitat, inactive subunits limit work during the bear’s active season etc.

Comment: The incidental take statement (ITS) from the FWS in 2014 does not specifically address the Glacier Loon project; a site-specific biological opinion is required for this project, given that the ORD will essentially double from the allowed ITS. (BB-7)

Response: Project specific consultation for Glacier Loon was provided by the USFWS on 6/15/2015. In this document, the USFWS tiers to the analysis conducted in the 2014 Biological Opinion. The USFWS found that the “existing access condition of the Buck Holland and Glacier Loon grizzly bear subunits and the road use associated with the proposed action are consistent with our analysis of effects on grizzly bears in both the 1995 and the 2014 programmatic biological opinions and that the proposed action would be in compliance with the incidental take statements associated with those biological opinions” (pg. 5). The second tier portion of the consultation also determined that the project effects fell within the scope of the 1995 and 2014 Biologic Opinions (pg. 5).

Comment: Since almost all of the proposed project is within management area 20 (MA- 20) which is to be managed to maintain and enhance grizzly bear habitat, please show how this project will benefit grizzlies bears and how it will negatively impact them. Please do the same for lynx. Please examine how this project will affect all ESA listed, MIS and sensitive species. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #137 responded to it by stating: “This project does not propose any activities within Management Area 20. Your comment must be, once again, referring to another project.” On the Flathead National Forest, MA-20 is for the Big Mountain Winter Sports Area, north of Whitefish, MT more than 75 miles from the project area. None of the proposed units for any action alternative are located in MA-20 (supplemental EA Tables 2-5, 2-8, 2-11). Project effects to grizzly bears, lynx, MIS and sensitive species are disclosed in the supplemental EA Chapter 3.

Comment: Why did the Supplemental EA on page 3-228 and 3-229 replace the previous language in the 2012 EA and provide a more optimistic impression that human use on rehabilitated temporary roads would be low? (BB-4)

Appendix 5-53 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Response: The wording was revised to better describe the intent of the rehabilitation action for temporary roads. Rehabilitation activity on temporary roads would prohibit the impacted area to function as a road in the future and would not have motorized use.

Comment: SEA page 3-75 states that the openings created by units 47 and 48 “will meet grizzly bear hiding cover requirements such that no point in the unit is greater than 600 feet to cover.” It continues, however, to state the area stands “would likely become forest openings in the future due to high mortality from MPB or windthrow.” If this is so and given the odd shape of the units to accommodate the 600’-to-cover requirement, how will the 600’- to-cover requirement be met if adjacent stands indeed succumb to MPB or windthrow? (BB-4)

Response: The statement on pg. 3-75 is: “Without treatment these areas would likely become forest openings in the future due to high mortality from MPB or windthrow” (emphasis added). The decision would include treatments to reduce the potential of future mortality and windthrow in lodgepole pine thereby better maintaining other mature forest cover for grizzly bears. Tree boles of dead lodgepole pine would likely still provide visual concealment for bears as would windthrown or “jackstrawed” lodgepole pine.

Comment: The analysis of project impacts on hiding cover are a violation of the NEPA because the wilderness lands were included, and private lands were excluded; the direct impact of logging and fuels treatments WITHIN the impact area need to be provided to display the actual impact of the project on hiding cover for grizzly bears; the agency is washing out direct impacts by included over 12,000 acres of adjacent wilderness, and excluding the loss of hiding cover on intermingled private lands. (BB-7)

Response: The subunit area is identified as the appropriate scale to analyze effects the grizzly bear (supplemental EA pg. 3-220). The Glacier Loon subunit includes the Wilderness. Activities on private lands were included in the cumulative effects in the supplemental EA pg. 3-224. It would be inappropriate not to include the adjacent wilderness area in the discussion of potential effects, because adjacent areas of security (e.g. refugia) are important for wildlife. Large, secure areas for wildlife are an integral part of several of the forest’s key operational standards and guidelines for wildlife (Amendment 19 Security Core and Subunit Rotation in the Swan Valley).

Comment: The assessment of hiding cover losses to the grizzly bear were invalid because the impact of up to 2000 acres of fuels treatments were never identified; the only reductions in hiding cover considered for grizzly bears was the commercial logging, or trees per acre; the claim that only half of the intermediate logging treatments will eliminate hiding cover for the grizzly bear is false, because it appears that every single acre of intermediate logging

Appendix 5-54 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: SNAGS

Response: Fuels reduction (removal of slash) was included in the hiding cover assumptions for Glacier Loon prescriptions as part of the effects of the mechanical or hand treatments. The hiding cover assumptions were based on residual density of trees in the unit which would result after implementation of the full prescription including both commercial and non- commercial work. The analysis does not just consider commercial logging as precommercial treatments and post and pole treatments were considered as well (supplemental EA pg. 3-226).

Comment: We are also attaching a research paper finding that 86-96% of snags are too hard for woodpeckers to make cavities in, indicating that some 100 snags must be left in an area if 4-14 suitable snags are desired (Lorenz et al. 2015). (BB-4) (BB-5) (BB- 6)

Response: Lorenz et al. (2015) used quantitative measures to gauge if wood hardness of snags was limiting nesting opportunities for woodpeckers and other primary cavity excavators. The authors compared wood hardness between selected primary cavity excavator nests and other snags in the area. The study found that interior wood hardness was the most influential model criteria in nest site selection at two scales, nest site (11 meter radius) and territory (250 meter radius). The study also correlated snag classes to hardness and did not find that standard decay were a good predictor of wood hardness. The study did say “The only significant predictor of wood hardness for random sites was the presence of old woodpecker nest cavities and stars, and for each cavity or start observed on a tree.” The study suggested that higher densities of snags should be provided because past research studies that did not consider wood hardness, overestimated the number of snags required for primary cavity excavator populations. For the Glacier Loon project, snag were considered at a different scale than the two relatively fine scale measurements (nest site and territory) presented in Lorenz et al. (2015). Throughout the project area, there is potential hundreds of potential primary cavity excavator territories. These territories overlap forest stands in areas with existing snags. During stand walk-throughs for the project, the wildlife biologist noted snags in stands as well as snags with existing excavations and cavities. As Lorenz et al. (2015) noted, this is a valid means of identifying if a snag is suitable for cavity nester excavation and foraging. Considering this information consistent with Lorenz et al. (2015) (snag presence and cavity excavation which is indicative of suitability for cavity nesters) was included in the conclusion that the project would not impact viability of snag associated species on the Flathead Forest. Much of the project area is not proposed for any activities in the project area. These untreated forest stands can with high densities of snags such as the Crazy Horse fire area, old growth and RHCAs. The design criteria in the project would still retain snags throughout the project area will still retain snags within treated units and live trees for future snag recruitment to provide

Appendix 5-55 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

sufficient local snag densities across the landscape. Design Criteria for the Glacier Loon Project will meet the Flathead National Forest’s Forest Plan Amendment 21 standards for snag retention; where available, a minimum average of 6 snags per acre that are 12- 20 inches DBH will be left, and all snags greater than 20 inches will be left. If existing snag densities are below these densities, substitute live trees will be left. The Glacier Loon project area includes the Crazy Horse fire area, which was a mixed severity fire across part of the project area. As noted by Lorenz et al. (2015), this fire produced an abundance of snags in the project area suitable for use by cavity nesting birds.

Comment: The current best science by the Forest Service identifies the critical need of bark beetles and fire to create snags for wildlife; only 4-14% of snags surveyed in research were soft enough to have cavities created in them; thus without a huge supply of localized snags on the landscape, snag habitat for wildlife will be severely limited. (BB-7)

Response: While the proposed action may decrease the potential for bark beetle infestation and reduce the intensity/severity of potential wildfire, its effects will not eliminate bark beetle or the potential for fire in the project area. As stated in the above response to comment, the project will retain snags within treated units. Untreated units throughout the project area will still retain snags and live trees for future snag recruitment to provide local snags across the landscape. Additionally, the analysis in the supplemental EA notes that no harvest will occur in Old Growth habitats (which often have abundant old snags), and minimal effects to RHCAs areas which have high amounts of snags. In addition to snags retention in units, snag retention in untreated forest, the Crazy Horse Fire area from 2004 includes an abundance of snags part of the project area. As noted by the supplemental EA (pg.3-349), snag habitat in the project area is not limited.

Comment: There is no effective management strategy in the Glacier Loon project to maintain viable populations of snag-associated wildlife by providing the natural processes on the landscape that provide large numbers of snags; in fact, the objective of the project is to severely restrict snag habitat created by fire and insects, which is a strategy to eliminate snag-associated wildlife; this strategy to eliminate 52 species of wildlife on the Forest that are dependent upon snags in the Glacier Loon landscape was never identified or evaluated in the SEA. The agency is violating the NFMA by implementing conservation strategies for snag- associated wildlife that in fact is leading to their demise within areas this strategy is applied. (BB-7)

Response: There is no strategy to eliminate “52 species of wildlife”. The Snag and Down woody associated species section summarizes the habitat needs of various species associated with snags. Based on the effects of the project, project design, the baseline habitat condition and Forest Plan direction, the assessment concludes that the Glacier Loon Project would maintain viability and diversity for these species (supplemental EA pg. 3-349). Project file exhibit H-18 describes how Flathead Forest

Appendix 5-56 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Plan direction provides for diversity and viability for snag-dependent species. The Glacier Loon project is consistent with both Forest Plan and NFMA direction.

Comment: The Forest Plan snag direction does not actually require any given number of snags per acre in harvest units; green trees can be substituted as snags; any number of snags can be removed due to safety concerns; there are also no requirements that snags be hard (still have a commercial value) versus soft; as such, how can this conservation strategy actually be a measure for ensuring viability of snag-associated species? (BB-7)

Response: The snag and down woody associated species analysis discusses how snag habitat will be maintained within the project area (supplemental EA pg. 3-349). Snags and trees for future snag recruitment will be maintained, no old growth areas are treated, and part of the project area has an abundance of snags due to prior mixed- severity fire. Further information on how the Flathead National Forest plan direction maintains viability of snag associated species can be found in Project File exhibit H-18.

Comment: The SEA does not provide any results from any snag monitoring on the Flathead Forest; how does the agency know that this strategy has been working in order to justify continued application to projects? Why haven't there been any snag inventories on Forest Service lands within the Glacier Loon project area, outside of wilderness? What is the current level of snag habitat on the Forest Service acres that have been logged in the past? (BB-7)

Response: Forest Plan monitoring reports (project file exhibit T-9 and T-9a) discuss monitoring and compliance with snags and Amendment 21 direction. The documentation in the supplemental EA discusses forest inventories and baseline habitat conditions in the project area. This information was collected in the field and used by specialists to conduct effects analyses for the Glacier Loon project. Wildlife surveys are located in project file exhibit H-12. Other information regarding linked to snag presence is located in the Vegetation project file exhibit including silvicultural diagnosis documents, beetle hazard rating and the silviculturalist’s report (project file exhibits I-1, I-1a, I-1b, I-3). Continued monitoring of snag-associated species such as birds and mammals mentioned in the supplemental EA occurs in cooperation with MTFWP, the Rocky Mountain Bird Observatory, the Avian Science Center, MT Natural Heritage Program and other partners.

Comment: The SEA at 3-346 cites survey data identifying that snags were 19 times more abundant in unlogged versus logged forest; at the same time, the SEA at 3-344 provides a table showing that snag habitat is almost as abundant in wilderness as non- wilderness areas; how is this possible, since logging does not occur in wilderness areas? (BB-7)

Response: The comment assumes that in an area occurs outside of Wilderness, it must be recently logged. This assumption is incorrect. Many forest areas outside of Wilderness/Roadless are not recently logged. Further, forests are dynamic. Trees grow

Appendix 5-57 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

and respond to disturbances not just from logging, but to fire, disease, insects, etc. The vegetation section of the supplemental EA describes the baseline condition of the various forest stages in the project area and how this relates to the historic range of variability. The Glacier Loon project does not propose to treat every forested stand outside of Wilderness in the project area. The snag and down woody species analysis in the supplemental EA discusses the impacts to snags within treated units, how snags will be retained or that live trees will be maintained for future snag recruitment. Other mature stands outside wilderness will continue to have snags including those in old growth stands or in RHCA area, or the Crazy Horse Fire area. The FIA data used to compare snag densities between inside/outside Wilderness/Roadless provides data coarse scale for a comparison of snag densities across the Flathead Forest. Wisdom and Bate (2008) cited in the supplemental EA compared snag densities between forest stands based on their recent history of harvest and proximity to roads. This scale of analysis and comparison is a much smaller scale than that of the Flathead National Forest.

Comment: The snag inventory for the project area is identified as the FIA data for the Swan River Watershed; what is the acreage of this watershed? Are the snags that will be left hard or soft snags? (BB-7)

Response: The Swan River Watershed is approximately 27,100 acres (supplemental EA pg. 3-150). The snag retention design criteria will be met in the project activities as per Amendment 21 direction. A minimum of 6 snags per acre will be left between 12 and 20 inches and all snags greater than 20 inches will be left (supplemental EA, Table 2-12). If existing snag densities are lower than this level, then live trees will be substituted. A diverse range of snags will be retained after project implementation including large snags that have existing cavities (indicative of softer snags) deformities creating unique nesting spaces and cavities for snag associated wildlife. The wildlife surveys (project file exhibit H-12) indicate this type of information during the wildlife biologist’s field review of the project during planning.

Comment: Snag densities recommended by experts to support cavity-nesting birds range from 2.1 to 11 snags per acre of greater than 9” dbh. Please note that the fact that more recent science has called into question the lower snag densities cited in the earlier research, and the more recent science implies that about 4 snags per acre may be the minimum required to insure viability. (BB-6)

Response: Estimates for snag densities in the project area are 14.2 snags greater than 9” DBH per acre (90% CI: 9.1-20 snags/acre). Analysis regarding viability of snag- associated species is located in the supplemental EA under snag and down woody associated species.

Comment: The acres in the Glacier Loon project area outside wilderness is approximately 25,000 acres; thus 57% of this landscape has been logged; this equates to at a minimum, a 57% loss of snag habitat as well; there is no analysis as to why this

Appendix 5-58 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments loss of snag habitat has not significantly reduced local populations of snag-associated species, of which the SEA at 3-339 identifies 42 bird species and 10 mammal species that are associated with snags in some manner. The proposed additional logging will remove most or all snags on up to another 1,749 acres (SEA 3-346); this would increase the lack of snag habitat from the current level of 57% to 15,919 acres, or 64%; the agency needs to provide the specific criteria by which a lack of snag habitat on 64% of the local landscape will not significant reduce snag- associated wildlife. (BB-7)

Response: The comment assumes that in an area occurs outside of Wilderness, it must be recently logged. This assumption is incorrect. Further, the comment assumes that all past logging areas are devoid of snags. This assumption is also incorrect. The assertion that snags are reduced over 64% of the project area (“focal landscape”) is inaccurate. Many forest areas outside of Wilderness/Roadless are not logged. Further, forests are dynamic. Trees grow and respond to disturbances not just from logging, but to fire, disease, insects, etc. The vegetation section provides baseline forest and structural information for the project and along with discussion on how it relates to the historic range of variability. The analysis regarding snags in the supplemental EA shows that snags will be retained inside units were available, outside treated units snags will continue to exist.

Appendix 5-59 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: FLAMMULATED OWL

Comment: The FS has not developed a conservation strategy for the flammulated owl in the FNF, or in the Northern Rockies. Absent an appropriate landscape management strategy for insuring their viability, based upon the best available science, it is arbitrary and capricious to dismiss potential impacts on the ground where the FS has failed to conduct the kind of comprehensive surveys that would reveal their presence. (BB-6)

Response: This comment was raised by the same commenter on the first Glacier Loon EA (2012). The following response is very similar to the response provided in the project’s first Decision Notice (2013), Appendix 5, Response to Comment E-11 #134: The Glacier Loon project uses specific project information as well as forest and regional data to provide for Flammulated Owl conservation. The project file includes references to the following documents: “A Conservation Assessment of the Northern Goshawk, Black-backed Woodpecker, Flammulated Owl, and Pileated Woodpecker in the Northern Region, USDA Forest Service” Samson (2006), demonstrate that the Northern Region and the Flathead National Forest provide for the diversity of plant and animal communities for those species listed above. “Habitat estimates for maintaining viable populations of the northern goshawk, black-blacked woodpecker, flammulated owl, pileated woodpecker, American marten and fisher” also cited as Samson (2006) clearly demonstrate that the Northern Region and the Flathead National Forest provide more than enough habitat to meet the threshold to maintain minimum viable populations of the Management Indicator and Sensitive species analyzed in that report. The Flathead National Forest document “Flathead National Forest Evaluation and Compliance with NFMA Requirements to Provide for Diversity of Animal Communities,” addresses the natural history, population, habitat, and distribution of wildlife species which can be found on the Flathead National Forest. This document discusses the threats to the different species, conservation measures in place to address those threats, and an evaluation of the current situation for the different species at the Forest and Regional level. This information is useful in the analysis of impacts to species and populations from proposed activities to determine whether impacts may be significant or not. An updated version of this document is located in the Project File section AA. Finally, the project is not treating old growth stands in the project area and is consistent with Forest Plan direction under Amendment 21 which includes snag retention and snag recruitment across the forest.

Appendix 5-60 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: CANADA LYNX AND LYNX CRITICAL HABITAT

Comment: The EA lynx analysis does not differentiate between mature multi-story habitat and multi-story habitat. Nor does the EA identify the distribution of lynx habitat in the project area, i.e., where are the stand initiation, mature multi-story, multi-story habitat, winter foraging etc. How is it connected before and after the project is implemented? (BB-5)

Response: The supplemental EA describes “multistory hare habitat” (supplemental EA Table 3-75 pg. 3-253). This delineation is the same as “mature multi-story hare habitat” as defined in the NRLMD. Other forest with multiple forest strata, but that doesn’t have the components (understory density, understory height above the snow in winter) to serve as winter snowshoe hare habitat (winter lynx foraging habitat) is included under “stem exclusion (non- forage; includes multistory that is non-feeding)” in Table 3-75. Squires et al. (2010) found that during winter, lynx foraged in mid-to high elevation forest with large trees and an understory with high horizontal cover and with boughs touching the snow surface. In other words, stands with a short understory not tall enough to protrude above the snow or a sparse understory with minimal horizontal cover, may structurally have multiple stories, but these do not meet the best available science for multi-story foraging for lynx. The lynx analysis discusses the effects to various structural stages of lynx habitat and discloses that the distribution of lynx foraging habitat would remain capable of supporting lynx. Specifically, the supplemental EA lynx analysis concluded that after project implementation considering cumulative effects, the project LAUs “would continue to provide a mosaic of forest structural stages including lynx foraging habitat that is well- distributed through the LAUs capable of supporting lynx.”

Comment: The Flathead cannot rely on the Northern Rockies Lynx Management Direction until it has undergone re-consultation with the U.S. Fish and Wildlife Service on the critical habitat designation… Projects in lynx critical habitat should not proceed until reconsultation on the NRLMD is completed. (BB-5) (BB-6)

Response: Consultation has been completed on the Northern Rockies Lynx Management Direction (NRLMD) for critical habitat. The USFWS provided a Biological Opinion on October 18, 2017.

Comment: The Project is likely to adversely affect lynx critical habitat. Why isn’t the proposed burning areas mapped in the Supplemental EA? How will the prescribed burning affect lynx? (BB-6)

Response: The Glacier Loon project does not propose any prescribed fire outside of proposed vegetation units. The project identifies that broadcast burning, pile burning or jack pot burning may be used to treat slash (supplemental EA pg. 2-16). Tables 2-5, 2- 8, 2-11 disclose which units, by alternative, would use these fire techniques to treat slash. Maps of the proposed units, by alternative, are located in Chapter 2, as Map 2-1

Appendix 5-61 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

through Map 2-6. The lynx analysis in the supplemental EA considers effects of slash disposal within proposed units including broadcast burning, pile burning or jackpot burning. For example, the supplemental EA at pg. 3-255 states, “Under Alternative B, there would be a decrease of 517 acres of existing lynx forage due to proposed vegetative treatments, including regeneration and intermediate treatments, as well as non-commercial treatment and proposed slash disposal.” The slash disposal and associated methods are included in the effects discussed for various lynx structural stages.

Comment: There is no analysis of travel corridors through the project area. For example, the SEA at 3-250, 251 notes that lynx travel habitat was "considered" in the analysis, but this analysis cannot be located. Please map and summarize the acres of suitable connected lynx travel corridors, or contiguous areas with at least a 60% canopy cover, as per the 2013 Squires paper, within the project area acres that are outside the wilderness. How much of the landscape needs to provide suitable travel corridors, how much currently provides that, and how much will provide this after project implementation. A good measure of habitat connectivity is Kosterman (2014) who defines suitable productive lynx habitat as areas with at least 50% dense, mature forest habitat. Is this current best science met in this project area outside the wilderness? (BB- 7)

Response: The lynx analysis in Glacier Loon considers changes to forest structure and creation of openings consistent with the findings of Squires et al. (2013). The analysis in the supplemental EA states: “the mosaic of forest openings and lynx forage through the project LAUs were considered in regard to habitat distribution and lynx travel when designing the proposed project” (supplemental EA pg. 3-250). This consideration was based on the wildlife biologist’s expert opinion, knowledge of the Swan Valley and a review of the best available science regarding lynx movement including Squires et al. (2013) for lynx travel requirements (supplemental EA pg. 3-250). Squires et al. (2013) evaluates lynx travel patterns at large scales, identifies putative travel corridors at the scale of the Northern Rockies, and concludes that preferences for travel may vary by season (winter vs. summer). Squires et al. (2013) illustrates canopy cover is reflective of lynx home range selections, while landscape connectivity is an additional analysis. Using 60% canopy cover as a stand-alone threshold for lynx movement between forest stands is not an appropriate interpretation of this variable. Squires et al. (2013) states: “that lynx selected home ranges at mid-elevations with low surface roughness, high canopy cover and little open grassland vegetation. Squires et al. (2013) continues to evaluate lynx movement and connectivity in the discussion concludes (pg. 193): “Our prediction that lynx would exhibit seasonal differences in their response to environmental heterogeneity was only partially supported. In addition to consistent selection for high NDVI and greenness regardless of season, lynx appeared to conserve

Appendix 5-62 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

energy by preferentially selecting travel routes with low topographic heterogeneity, as observed for other mammals (Bruggeman et al.,2007), including carnivores (Dickson et al., 2005). We found no selection (P = 0.127) for areas with increased PCA values during summer; however, lynx avoided these areas during winter (Table4).” Specifically, Squires et al. (2013) discusses habitat fragmentation and states that “although lynx are capable of crossing hundreds of kilometers of unsuitable habitat… lynx in Northern Rockies are sensitive to changes in forest structures and tend to avoid forest openings” (pg. 194). Kosterman (2014) does not use the criteria “dense” when defining “mature forest”. Kosterman (2014) delineated forest patches from satellite imagery and did not inventory forest understories for densities. Specifically, Kosterman (2014) defines “mature forest” as: “large trees, continuous canopy, and no evidence of recent disturbance” (pg. 6). Like Squires et al. (2013), the supplemental EA considered the findings of Kosterman (2013) and other science to determine that the distribution and spatial pattern of lynx habitats in conjunction with the effects of the Glacier Loon project that the project LAUs would continue to support lynx and lynx movement (supplemental EA pg. 3-263). The supplemental EA discloses the effects to lynx habitat based on the alternatives throughout the lynx section of the supplemental EA. The Lynx Analysis Unit has been determined to be the appropriate scale to evaluate project effects to lynx (SEA pg. 3-248). The Wilderness is included within these LAUs and therefore included in the analysis. Further, it would be arbitrary to remove Wilderness from the analysis based on political distinction alone or the comment preferences, as the area provides suitable habitat for lynx and is a part of the ecological context.

Comment: The analysis in the Glacier Loon project is invalid for lynx because it does not use the current best science for managing lynx habitat within a female home range, which is 10,000 acres, as per Kosterman (2014). Please provide a valid analysis of lynx dense older forest habitat, and young dense stands that currently provide winter hare habitat, within what is likely 2 average lynx home ranges in the 25,000 acres of the project area that are outside of the wilderness. The SEA (e.g., 3-251, 3-272-73) notes that this landscape is some of the best lynx habitat in Montana, and special management of critical habitat may be essential to conservation of lynx; as such, why would the agency use outdated recommendations from 2007, or from 10 years ago, when the current best science by Kosterman (2014) is much more specific for habitat recommendations; in the Lynx Amendment, there are actually no habitat standards for lynx; there are only limitations to areas that can be logged per given decade. (BB-7)

Response: The Glacier Loon analysis uses the best available science for lynx and lynx habitat and considers the Kosterman (2014) thesis (supplemental EA pg. 3-251). The USFWS acknowledged that the NRLMD is consistent with the best available science which is cited in the lynx section of the EA (USDA (2013), USDI-FWS (2013) and SEA pgs. 3-248 to 3-264). Habitat standards for lynx from the Northern Rockies Lynx Management Direction (“lynx amendment) are identified in the Regulatory Consistency

Appendix 5-63 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

section (supplemental EA pg. 3-265). The lynx analysis in the supplemental EA identifies winter lynx foraging habitat as “multistory hare” and “stand initiation hare” habitat (supplemental EA pg. 3-253) which is a valid analysis consistent with the best available science. The Lynx Analysis Unit has been determined to be the appropriate scale to evaluate project effects to lynx (supplemental EA pg. 3-248). The 6 project LAUs used for project analysis are consistent with this determination. Kosterman (2014) evaluates home ranges (pg. 5): “Because core areas represent the most intensively used portions of a home range (Bingham and Noon 1997, Seaman et al. 1999), we estimated home ranges at two spatial extents to determine whether 50% annual core areas (hereafter core areas) were potentially more predictive of lynx reproductive success than 90% annual home ranges (hereafter home ranges).” Kosterman (2014) does not report calculated home range sizes. It is unclear where the 10,000 acres reported by the comment is drawn from. The Wilderness is included within the project LAUs and therefore included in the analysis. Further, it would be arbitrary to remove Wilderness from the analysis based on political distinction alone or the comment preferences, as the area provides suitable habitat for lynx and is a part of the ecological context. The Kosterman (2014) Thesis is currently in the process of scientific publication. Kosterman et al. (in press – Project File section AA) uses 50% core annual area which are a selected area of lynx use within an annual home range. It is important to note this is note that an annual home range that an LAU approximates is not the same as a core area. A core area a level of selection within the annual estimated home range area. Kosterman et al. (in press) found that connected mature forest was positively related to producing a litter. Additionally, the publication states that small diameter regenerating forest aids reproductive success of female lynx. The Glacier Loon project is consistent with these findings. The project effects very little multistory story habitat leaving a connected mosaic of mature, multistory foraging habitat and maintains a proportion of sapling winter foraging (stand initiation class) in each of the project LAUs.

Comment: The SEA claims that the VMap used for Kosterman is different from the VMap used for the Glacier Loon project; it is not clear that these 2 methodologies are different; if these 2 methods are actually different, the agency needs to demonstrate specifically why there are 2 VMAP methods, one for agency general use and the one used by Kosterman. (BB-7)

Response: The supplemental EA does not claim Vmap for Kosterman and the project are different. The analysis in the supplemental EA (pg. 3-251), describes that the Glacier Loon analysis did not only rely on remotely mapped vegetation classes which can only approximate understory density. The Glacier Loon project went to all the

Appendix 5-64 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments project units and additional stands on the ground to classify lynx structural stages (project file exhibit H-25). The analysis states (supplemental EA Pg. 3-251): “the habitat analysis included in this report represents a more detailed and accurate classification of lynx habitat as it includes representation of types of lynx foraging habitats, is consistent with the best available science and is not based solely on simplified forest structure classes from remotely sensed imagery.” The project analysis did use Vmap to model lynx structural stages not visited in the field to approximate the remainder of lynx habitat structural stages in the field (project file exhibit H- 3 and H-4).

Comment: The application of the Lynx Amendment, with the 6% habitat exemption in the WUI, has never been validated, either for general lynx habitat or for lynx critical habitat; this arbitrary measure is a violation of the NEPA, the NFMA, and the ESA as a result of this analysis failure. (BB-7)

Response: The 6% exemption for the WUI as part of the NRLMD was determined by the USFWS to “not jeopardize” Canada Lynx (project file exhibit H-133). The supplemental EA discusses lynx viability for the Seeley Lake area and the Yaak in associated with the NRLMD (pg. 3-252). Consultation under section 7 of the ESA, for this exemption has occurred and the documents are located in the project file (Section AA of the Project File). The project is consistent with NRLMD guidelines and NFMA direction for lynx (supplemental EA pg. 3- 265). The effects of the project on lynx foraging successional stages inside the WUI (NRLMD exemption) and lynx potential habitat throughout the project LAUs is disclosed, consistent with NEPA, in the lynx and lynx Critical Habitat section in Chapter 3 of the supplemental EA.

Comment: The SEA claims that logging will create new hare habitat in about 20 years; this is actually a NEPA violation, because there are no guarantees of 2 key factors; the first is that many harvest units will not develop very dense stands of young saplings, which are required for winter hare habitat; this is most likely to occur after fires; the SEA does not provide any data on what percentage of young logging units will actually develop winter hare habitat; the assumption that all logged units will develop this dense winter hare habitat is clearly false.

Table 3-75 includes all acres of stand initiation as winter hare habitat, but there is no documentation provided as to how these acres were sampled and verified. Secondly, as with this current project where up to 343 acres of precommercial thinning of identified winter hare habitat, the agency clearly does not actually intend to maintain these unthinned areas for hares and lynx; the acres of past precommercial thinning in this project area, and the dates the thinning occurred, need to be provided so that the public can understand how precommercial thinning is being managed in this landscape for hares and lynx. (BB-7)

Response: The supplemental EA states (pg. 3-256): “However, it should be noted that where regeneration harvest is proposed, lynx foraging opportunities may not increase for 20 years or more; Squires (Squires et al. 2010)(USDA 2010) found that in Montana, hares are not using regenerated stands as early as originally thought (e.g., not in 15

Appendix 5-65 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

years after logging or fire)” (emphasis added). It is common for stands regenerated by logging to regenerate with density to provide winter snowshoe hare habitat (LCAS 2013, NRLMD FEIS 2007). Stands were reviewed by the wildlife biologist in the field to classify lynx foraging habitats consistent with the best available science (project file exhibit H-25, H-4). Table 3-75 also includes “early stand initiation” which is defined as a regenerating structural stage that is not tall enough to protrude from the snow. These “early stand initiation” acres are not considered lynx winter foraging habitat. The lynx analysis in the supplemental EA discloses the acres of lynx habitat affected as well as structural stage that provide winter snowshoe hare habitat by each alternative for both commercial treatments and for non-commercial treatments such as pre-commercial thinning. Past vegetation management and disturbances such as logging and fire were considered in the baseline habitat condition shown in Table 3-75. No future proposed action exists, beyond the scope of the Glacier Loon project, to pre- commercially thin regenerated stands created from the Glacier Loon project. Regardless of this fact, the analysis in the supplemental EA discloses potential future effects of precommercial thinning (supplemental EA pg.3-256): “if the regenerated stands are pre- commercially thinned in the future, then an increase in winter forage habitat for lynx would not occur, or only occur briefly in summer feeding habitat.”

Comment: There is no analysis in the SEA on lynx as to why larch is being promoted as opposed to lodgepole pine; larch sheds it leaves in the winter, and can never provide winter hare habitat; so why would larch be promoted in general, as well as, critical lynx habitat; the SEA claims that there will be no permanent changes in lynx critical habitat, but the promotion of larch over lodgepole pine is a permanent, serious degradation of lynx critical habitat. (BB- 7)

Response: Discussion of the longevity and function of larch, lodgepole in context to the historical range of variation in the project area along with the Swan Valley is located in the Chapter 3 of the Vegetation Section of the supplemental EA. Lynx have evolved with forest disturbance shaping the habitat. Amendment 21 of the Flathead National Forest Plan directs management to be consistent with natural disturbance regimes including to restore historic proportions of species like western larch in warm-dry PVGs at the stand-level (project file exhibit T-8a Appendix A). The Glacier Loon prescriptions will not replace ecological succession on treated units. Shade tolerant tree species will continue to regenerate through the project area including the project treatment units. Fires, other disturbance and factors like snowfall will continue to shape forest vegetation in the project LAUs. The project activities do not permanently convert Critical Habitat or permanently alter any PCEs associated with Critical Habitat. Critical Habitat will maintain its functionality to provide lynx habitat into the future. Glacier Loon Lynx Critical Habitat Biological Opinion states (pg. 12): “We conclude that the proposed action will not alter the physical and biological features of critical habitat to

Appendix 5-66 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments an extent that appreciably reduces the conservation value of critical habitat for lynx. The proposed action would not directly or indirectly alter critical habitat in Unit 3 to the extent that the conservation role for the species (i.e. to support viable core area lynx populations) would be diminished.”

Comment: There is no analysis of how past logging, which covers 13,691 acres as per the SEA at 3-4, 3-5, which is 55% of the landscape in the Glacier Loon project area outside the wilderness; this may not include another 5154 acres of fuels treatments, which may or may not have overlapped logging units; the SEA notes that hare habitat is sensitive to habitat quality and fragmentation as per the Lewis et al. (2011) published paper. Yet there is no analysis of how much of this forest in the project area is currently suitable for hares. How can the agency do an analysis of cumulative impacts on lynx and lynx critical habitat without analyzing hare habitat? The SEA at 3-251 notes that in Montana, prey provided by hares is generally limited; so what will further reductions do to hare availability for lynx, along with past logging and fuels treatments? (BB-7)

Response: Past logging is summarized for the project in the cumulative effects worksheets H-20 to H-23. These acres and activities are fully summarized for the project and are considered by the project analysis. The baseline condition for lynx habitat is disclosed in the Lynx analysis existing condition (Table 3-75). Winter snowshoe hare habitat is summarized and disclosed for the project LAUs in Table 3-75 and discussed in the analysis. The supplemental EA considers the effects to lynx, lynx habitat, and lynx Critical Habitat due to the project alternatives. Additionally, cumulative effects are discussed in the supplemental EA in both the lynx and lynx Critical Habitat sections. The project analysis concludes that the project LAUs are still capable of supporting lynx (supplemental EA pg. 3-263). The USFWS concluded (Critical Habitat BiOp pg. 12), “Post‐project, project area LAUs are expected to provide conditions that would continue to be conducive to supporting female lynx. Although the proposed action would adversely affect areas of critical habitat, the treatments have small to insignificant and nonpermanent effects on critical habitat. The critical habitat in all LAUs is expected to remain capable of producing adequate densities of snowshoe hares to support continual lynx presence because the project would leave snowshoe hare habitat in adequate amounts to sustain hare populations.”

Comment: There is no documentation ever provided in the SEA to demonstrate that stem exclusion habitat, which includes an average of 45% of lynx habitat in the 6 LAUs measured, has no hares, and thus does not have to be managed for hares or lynx; how has this been determined? (BB-7)

Response: Classification of lynx structural stages for both lynx foraging habitats (multistory; stand initiation) and stem exclusion were completed and field verified using the definitions drawn from the best available science (Squires et al. 2010, Squires et al. 2006, NRLMD 2007, LCAS 2000, LCAS 2013). Stem exclusion habitats are characterized by sparse understories and do not provide what science has shown to be

Appendix 5-67 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments snowshoe habitat (project file exhibit H-4).

Comment: The SEA at 3/253-54 claims that new clearcuts are hare summer forage; the citation for this is unclear; the Lynx Amendment classifies these areas as "unsuitable" lynx habitat; why are they classified as unsuitable if there are hares present? (BB-7)

Response: The supplemental EA defines early stand initiation as: “Stand initiation structural stage that currently does not provide winter snowshoe hare habitat. It may provide summer forage. This structural stage has also been referred to as ‘unsuitable’ (NRLMD)” (SEA pg. 3- 253). This definition is consistent with the NRLMD. The NRLMD defines “unsuitable” as: Lynx habitat in an unsuitable condition includes those forests in a stand initiation structural stage that are too short to provide winter snowshoe hare habitat” (NRLMD ROD pg. 9). Given the height of these regenerating stands, the trees are buried by snow during the winter time and the stands do not provide winter snowshoe hare habitat. During summer, when snow is not present, some of these areas may have trees tall and dense enough to provide snowshoe habitat for hares.

Comment: In some landscapes, fire promotes habitat diversity for lynx, and lynx use different areas of the forest after fires, different from areas they used prior to fires; in general, fire will certainly have a much more benign impact on lynx than logging, fuels projects, and roads; this should be clearly noted in the SEA. (BB-7)

Response: The supplemental EA discusses effects to potential for future wildfire and lynx (pg. 3-254). The effects of wildfire to lynx habitat would depend on the size, severity and intensity of wildfire. Stating that fire is more benign to lynx than logging or roads is dependent on the size and scale of each considered. Potential for large, severe and intense wildfire is discussed in the fire/fuels section. Based on the fuels section, the potential for large and severe wildfire could regenerate lynx foraging habitat and other forest structural classes throughout the project LAUs to a far greater degree than the effects of the project. Severe fire could sterilize soils and lengthen the time for forest to regenerate into lynx foraging habitats. Treatments in Glacier Loon decrease the potential for large scale stand- replacing wildlife fire to occur across lynx habitat and the project LAUs.

Comment: Provide a detailed summary of how logging units, combined with fuels treatments, will impact both hare habitat and lynx travel habitat. For example, the SEA at 3-257 claims that some intermediate treatments will still provide lynx travel cover, without providing any actual documentation; if there is not a dense forest canopy, and essentially no understory, how can these units provide lynx travel cover? The SEA is very unclear as to how many acres of intermediate treatments will not have fuels treatments; it appears that most in fact will have these fuels treatments, which is remove all understory cover for both lynx and hares. (BB-7)

Response: Fuel treatments are a combination of the stated prescription and the

Appendix 5-68 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

method of slash treatment. The slash treatments and unit prescriptions are described in the supplemental EA with in Tables 2-5, 2-8 and 2-11. The supplemental EA states (pg. 3-257), “In the Intermediate Harvest Units, there would be trees left in the overstory (approximately 50 to 150 trees per acre); some of these units would likely still provide hiding cover following treatment and could be used by lynx for movement between foraging and denning habitat.” The analysis assumes that sufficient canopy after treatment in some intermediate harvest units for lynx to travel through. This assumption is supported by Squires et al. (2010) and Squires et al. (2013) illustrating that lynx avoid openings, not mature forest for travel. Squires et al. (2010) states, “During winter, lynx strongly avoided clear-cuts and open patches across all spatial scales, whereas in summer there was no evidence of avoidance (pg. 1657). Lynx have also demonstrated the ability to travel long distances through unsuitable habitat (Squires et al. 2013 pg.194).

Comment: Lynx are reported to tolerate light vehicle use along roads that have good forest cover, with light use being about 8 vehicle trips per day as per Squires et al. 201O; please measure how vehicle use on roads during project activities will displace lynx based on estimated levels of motorized use. (BB-7)

Response: There is no science demonstrating that lynx avoid forest roads or traffic on forest roads (Ruggerio et al. 2000, Squires et al. 2010, Squires et al. 2013). Squires et al. (2010) did not measure a vehicle/day threshold for lynx habitat use around forest roads. It is not known if or at what level of vehicles trips per day lynx would tolerate on forest roads. Instead, Squires et al. (2010) states, “We found no evidence that lynx selected areas away from forest roads or groomed snowmobile trails during winter” (pg. 1654) and for summer, “lynx did not select habitats according to their proximity to dirt-gravel forest roads that were gated or the subset of road open to vehicular traffic” (pg. 1655). Squires et al. (2010) reported, for context, the vehicle traffic on the roads stating (pg. 1657), and “estimated that 8 vehicles/day traveled low volume roads (98% of road length) and approximately 55 vehicles/day travel the remaining (2%) high-volume roads Spur roads that extended off primary timber haul routes were mostly gated and received <20 vehicle trips/year.” The supplemental EA discusses potential impacts to displacement of lynx from high human activity (supplemental EA pg. 3-257), and discusses haul routes, temporary roads, and decommissioning of roads under the “Lynx Habitat Security” subheading for each alternative in Chapter 3 of the supplemental EA. The supplemental EA describes motorized use on roads during project activities with road densities in the Grizzly Bear section of the supplemental EA.

Comment: The SEA at 3-257 claims that stem exclusion habitat is not progressing into hare habitat; no monitoring data is provided to support this claim; how many acres of current stem habitat is not progressing as per natural succession, and how was this measured? (BB-7)

Appendix 5-69 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

Comment: The SEA at 3-257 states that in clearcuts and other regeneration harvest units, hiding cover will be maintained within 600 feet of edges; why aren't intermediate treatments units being managed the same way? Why is hiding cover distance from logging units only considered important for regeneration harvest units? (BB-7)

Response: Regeneration treatments would not provide hiding cover after treatment. The supplemental EA states that the furthest point from cover in the project will be 600 feet. The project considered all units when evaluating distance to cover requirements to meet the forest plan. No point considering all unit prescriptions (regeneration, intermediate, non- commercial) would be further than 600 feet from cover.

Comment: The size of the LAUs evaluated for this project are invalid as per the current best science in Kosterman (2014) and Squires et al. (2013); the average home range size of reproducing female lynx in Montana is roughly 10,000 acres; the size of the LAUs used in the Glacier Loon analysis on average are 1.5-3 times this size; the only valid means of evaluating the project's impact on lynx is to divide the project area outside of wilderness into 2 average lynx home ranges, and measure past and planned effects on dense, young sapling stands that extend above the snow, and dense mature forest habitat, as per Kosterman. (BB-7)

Response: The Lynx Analysis Unit has been determined to be the appropriate scale to evaluate project effects to lynx and approximates the size of a female home range (supplemental EA pg. 3-248). Kosterman (2014) evaluates home ranges (pg. 5): “Because core areas represent the most intensively used portions of a home range (Bingham and Noon 1997, Seaman et al. 1999), we estimated home ranges at two spatial extents to determine whether 50% annual core areas (hereafter core areas) were potentially more predictive of lynx reproductive success than 90% annual home ranges (hereafter home ranges).” Kosterman (2014) does not report calculated home range sizes. Squires et al (2013) used an 80% fixed kernel to estimate home ranges, but did not report home range sizes. It is unclear from where the comment is drawing 10,000 acres. The Wilderness is included within the project LAUs and therefore included in the analysis. Further, it would be arbitrary to remove Wilderness from the analysis based on political distinction alone or the comment preferences, as the area provides suitable habitat for lynx and is a part of the ecological context. The supplemental EA addresses past, present and foreseeable future effects in the lynx analysis in Chapter 3.

Comment: There currently are no criteria for specific habitats in lynx habitat or lynx

Appendix 5-70 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

critical habitat; the Lynx Amendment has not actual habitat standards, just limitations; how can lynx habitat be managed without any specific habitat standards? (BB-7)

Response: Standards for lynx habitat (e.g. Standard VegS1 pg. 8) are documented in the NRLMD (project file exhibit H-120). “Standard” is defined on pg. 14 of the glossary in the NRLMD. Habitat standards for lynx from the Northern Rockies Lynx Management Direction (“lynx amendment) are identified in the Regulatory Consistency section (supplemental EA pg. 3-265). The NRLMD was adopted to contribute to the recovery and conservation of lynx (NRLMD pg. 1) with approval of the USFWS (H-133). The lynx analysis in the supplemental EA identifies winter lynx foraging habitat as “multistory hare” and “stand initiation hare” habitat (SEA pg. 3-253) which is a valid analysis consistent with the best available science. Definitions for the structural stages is located in the supplemental EA and in project file exhibit H-4.

Comment: The criteria for significant impacts on lynx critical habitat are reducing/removing understory vegetation within the boreal forest on a scale proportional to large landscapes used by lynx; a landscape important to lynx would be the home range area of approximately 10,000 acres; yet there is no analysis in the SEA as to how the 2 home ranges within the non- wilderness areas of the Glacier Loon project would be impacted cumulatively as per habitat requirements as per the current best science; we could not determine what the basis was for the SEA claim that lynx critical habitat will not be significantly impacted (appreciably reduced as per SEA 3-276), including why it is not even currently severely degraded from past activities. (BB-7)

Response: The Lynx Analysis Unit has been determined to be the appropriate scale to evaluate project effects to lynx and approximates the size of a female home range (supplemental EA pg. 3-248). Kosterman (2014) does not report calculated home range sizes. Squires et al (2013) used an 80% fixed kernel to estimate home ranges, but did not report home range sizes. It is unclear from where the comment is drawing 10,000 acres. The Wilderness is included within the project LAUs and therefore included in the analysis. Further, it would be arbitrary to remove Wilderness from the analysis based on political distinction alone or the comment preferences, as the area provides suitable habitat for lynx and is a part of the ecological context.

Comment: The SEA at 3-276 states that 10 trees per acres plus a few snags will retain lynx denning habitat; no citation was provided for this claim. (BB-7)

Response: Lynx are known to use root wads or piles of woody debris for denning habitat in mature stands with horizontal cover (supplemental EA pg. 3-251). The supplemental EA discusses on pg. 3-276 that PCE 1c, or denning conditions, would be reduced by project activities. The supplemental EA does not claim denning habitat will be retained, but states that snag retention will provide denning structures for future denning habitat stating (pg. 3- 276), “as treated stands regenerate, sufficient cover combined with denning structures (fallen snags, root wads) would create denning

Appendix 5-71 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments habitat over time.”

Comment: The agency needs to demonstrate how past and planned logging units have impacted habitat connectivity for lynx corridors, which would have a 60% canopy cover and be connected across a landscape, including connections that are not fragmented by heavy- use roads. (BB-7)

Response: Cumulative effects and direct, indirect effects of the project are analyzed in the supplemental EA chapter 3 lynx section including past and foreseeable logging activities. The lynx analysis in Glacier Loon considers changes to forest structure and creation of openings consistent with the findings of Squires et al. (2013). The analysis in the supplemental EA states: “the mosaic of forest openings and lynx forage through the project LAUs were considered in regard to habitat distribution and lynx travel when designing the proposed project” (supplemental EA pg. 3-250). This consideration was based on the wildlife biologist’s expert opinion, knowledge of the Swan Valley and a review of the best available science regarding lynx movement including Squires et al. (2013) for lynx travel requirements (supplemental EA pg. 3-250). Squires et al. (2013) evaluates lynx travel patterns at large scales, identifies putative travel corridors at the scale of the Northern Rockies, and concludes that preferences for travel may vary by season (winter vs. summer). Squires et al. (2013) illustrates canopy cover is reflective of lynx home range selections, while landscape connectivity is an additional analysis. Using 60% canopy cover as a stand-alone threshold for lynx movement between forest stands is not an appropriate interpretation of this variable. See comment response on pg. 5-48 for additional information. There is no science demonstrating that lynx avoid forest roads or traffic on forest roads (Ruggerio et al. 2000, Squires et al. 2010, Squires et al. 2013). For additional information see comment response on pg. 5-54.

Comment: The SEA at 3-280 states that hare densities will remain "sufficient" within remaining habitat until regenerated stands grow back to hare habitat in about 20 years; however, the amount of suitable hare habitat within a given landscape is never defined, so it is unclear what constitute "sufficient" hare habitat. How was this determined? (BB- 7)

Response: This conclusion was drawn by the wildlife biologist based on review of the best available science, field work in the project area, impacts of the Glacier Loon project on lynx foraging habitats and project design discussed in the supplemental EA analysis and the Biological Analysis. The project would reduce winter lynx foraging habitat by approximately 380 acres or less than 1% of the winter lynx foraging acres in the project LAUs. The USFWS concurred with the determinations and concluded (Critical Habitat BiOp pg. 12), “Post‐ project, project area LAUs are expected to provide conditions that would continue to be conducive to supporting female lynx. Although the proposed action would adversely affect areas of critical habitat, the treatments have small to insignificant and nonpermanent effects on critical habitat. The critical habitat in all LAUs is expected

Appendix 5-72 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments to remain capable of producing adequate densities of snowshoe hares to support continual lynx presence because the project would leave snowshoe hare habitat in adequate amounts to sustain hare populations.”

Comment: The agency concludes at 3-280 that lynx critical habitat will remain available on a landscape scale to meet lynx needs; however, the specific habitat features lynx need are never identified; what are these in the project area outside wilderness, and what is the basis for determining that suitable lynx breeding habitat will remain, if it even exists at present? (BB-7)

Response: The USFWS concluded (Critical Habitat BiOp pg. 12), “Post‐project, project area LAUs are expected to provide conditions that would continue to be conducive to supporting female lynx. Although the proposed action would adversely affect areas of critical habitat, the treatments have small to insignificant and nonpermanent effects on critical habitat. The critical habitat in all LAUs is expected to remain capable of producing adequate densities of snowshoe hares to support continual lynx presence because the project would leave snowshoe hare habitat in adequate amounts to sustain hare populations.”

Appendix 5-73 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: FISHER

Specific habitat features are summarized in terms of PCEs in the Critical Habitat analysis and discussed in the supplemental EA. Please refer to comments above regarding scale to assess the impacts of lynx and inclusion of the Wilderness area in the analysis.

Comment: The Flathead National Forest will not maintain a viable population of fisher because there is no evidence of fisher present in the landscape, and no positive effort is being made to protect and maintain sufficient habitat for fisher, within the project area or forest-wide… and where carnivore monitoring was conducted the Flathead has not detected one fisher on the whole Forest. (BB-5) (BB-6)

Response: Under the Selected Alternative, 320 acres of fisher habitat would be treated adjacent to existing wetlands (supplemental EA, page 3-283). No treatment is proposed in old growth habitat. No harvest would occur in Riparian Conservation areas (Decision Notice– Appendix 2). Downed logs and cover will be retained in these areas. Prescription for treatments would provide for snag and down woody debris (supplemental EA, page 3-284). Under Cumulative Effects, the supplemental EA states “there would continue to be adequate old growth, riparian habitat, and mid to late-seral forest matrix habitat to maintain connectivity and functional home ranges” (supplemental EA, page 3-286). The document “Flathead National Forest Evaluation and Compliance with NFMA Requirements to Provide for Diversity of Animal Communities” was also incorporated into the analysis; it describes how fisher habitat is thought to occur at historically normal levels at both the Flathead National Forest and Region One scales (project file exhibit H-18, page 43). Samson (2006) also described how potential fisher habitat is plentiful throughout Region 1. The supplemental EA discusses Fisher habitat within the project area as well as throughout the Swan Valley in reference to habitat requirements for fisher (supplemental EA pg. 3-303). Fisher naturally exist at low densities and are difficult to detect (supplemental EA pg. 3-302). Monitoring has not detected fisher in the Swan Valley or on the Flathead National Forest. However, Marten, a species with similar habitat requirements have been detected throughout the Swan Valley (project file exhibit H-24). Monitoring, habitat management direction and the Glacier Loon project analysis support the determination made in the supplemental EA (page 3-283) and that there appears to be “little risk of population loss across the Forest and the Region” (supplemental EA, page 3-286, Project File Exhibit H-18).

Comment: The lack of species detections for fisher undermines the assumption that by taking care of habitat, the Flathead NF can ensure species viability. [However, in this case the project is reducing the attributes that fisher require]. The Forest Plan requires

Appendix 5-74 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

that the Forest Service ensures the existence of viable populations of species, not the theoretical possibility that the species should be present. Moreover, without any indication that there are viable populations of MIS in the Project area before the Project, it is unclear how the Forest Service could conclude that viable populations of MIS will be maintained after conclusion of the Project, in violation of the NFMA. (BB-5)

Response: Based on the effects of the Glacier Loon project to fisher and fisher habitat, the analysis concluded that the Glacier Loon project would not threaten fisher viability on the Flathead Forest (pg. 3-310). Please see project file exhibit H-18 for how Flathead National Forest direction ensures fisher viability. In the Species Status Assessment for Northern Rockies Fisher (https://www.fws.gov/mountain- prairie/es/species/mammals/fisher/20170727%20Final%20NRM%20Fisher%20SSA.pdf ), the USFWS concludes that potential stressors such as forestry have varying but low effects to the Northern Rocky Mountain Fisher and their habitat patches (pg. 4). The assessment states (pg. 60), “the effects of present and future forest management may be influenced by factors such including location, scale and juxtaposition of treatments to previous disturbances…” The analysis in the supplemental EA considers the local level effects to habitat and based upon these effects concludes that the project would not impact viability for fisher and would not result in a trend toward listing (supplemental EA pg. 5-51).

Comment: The Forest Plan requires monitoring the distribution of fishers and the change in population status, ensuring projects do not contribute to the loss of viability of fisher, avoiding adverse impacts to fisher or their habitats whenever possible and preparing a fisher management plan or conservation strategy to prevent the loss of population viability. The Flathead has not completed a conservation strategy for fisher. This project does not avoid adverse impacts to fisher and their habitats but instead increases them. (BB-5)

Response: Amendment 21 monitoring plan elements direct the monitoring for “forest carnivore distribution,” not in the change of population status (project file exhibit T-8a pg. 5). The Flathead National Forest has fulfilled this monitoring requirement (project file exhibit H- 24). The Forest Service is currently conducting research on fisher within the Region. A conservation strategy will be developed at the regional level based on this research upon its completion. The fisher Conservation Strategy for Washington was reviewed for the project design and effects analysis (supplemental EA pg. 3-303). Under the Selected Alternative, 320 acres of fisher habitat would be treated adjacent to existing wetlands (supplemental EA, page 3-283). No treatment is proposed in old growth habitat. No harvest would occur in Riparian Conservation areas (Decision Notice – Appendix 2). Downed logs and cover will be retained in these areas. Prescription for treatments would provide for snag and down woody debris (supplemental EA, page 3- 284). Under Cumulative Effects, the supplemental EA states “there would continue to be

Appendix 5-75 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments adequate old growth, riparian habitat, and mid to late-seral forest matrix habitat to maintain connectivity and functional home ranges” (supplemental EA, page 3-286). The supplemental EA analysis for fisher conclude there would not be adverse impacts to fisher (supplemental EA pg. 3-310).

Appendix 5-76 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: WOLVERINE

Comment: The Flathead should proceed with caution regarding impacts to wolverine. New scientific studies are emerging about landscape effects from logging and other human activities so assumptions about habitat usage, prey availability and motorized use might change. (Carroll et al. 2001; Rowland et al. 2003; May et al. 2006; Krebs et al. 2007; North America; Krebs et al. 2004; Persson et al. 2009; May et al. 2008; Copeland et al. 2007; Carroll et al. 2001; Rowland et al. 2003; Landa et al. 1998; et al. 2009; Copeland et al. 2010. (BB-5)

Response: The Wolverine analysis in the supplemental EA discusses effects to wolverine from vegetation management and other human activities associated with the Glacier Loon project (supplemental EA pg.3-281). The analysis considers habitat usage by wolverine, prey availability and effect of motorize use consistent with the findings of the attached science (Project File section AA). It should be noted that not all the above cited science speaks directly to effects of human activity on wolverine habitat, mortality, motorized use or prey availability. Further, the citations do not all clearly show negative wolverine response to forest roads or vegetation management in wolverine habitat.

Comment: It is clear that this project will continue the past trends of a loss of natural, undeveloped habitat key to wolverine habitat use; this impact was ignored in the SEA; for example, there remains a relatively intact block of undeveloped habitat, generally west and south of Lindbergh Lake, that is good quality wolverine habitat; indeed, the SEA notes that wolverine have been known to use this landscape; this block of habitat includes sections 9/ 10, 14, 21, 22, 27, 28 and 34; there will be many new harvest units put in this undeveloped habitat, as well as new roads (e.g., units 66-92); the project will clearly reduce wolverine habitat. (BB-7)

Response: The project does not propose to “develop” any habitat in the Glacier Loon project area. No additional permanent human infrastructure will be built in the project area. Temporary roads built in the Glacier Loon project will be rehabilitated after use. Based on a review of the best available science, the USFWS has stated that wolverines are not thought to be dependent on specific vegetation or habitat features that may be manipulated by land management activities (USDI 2013a; supplemental EA pg. 3-284). Effects to wolverine, wolverine prey and wolverine habitat in the block of land identified in the comment are disclosed and discussed as part of the impacts of the Glacier Loon alternatives in the wolverine section of the supplemental EA.

Comment: The SEA falsely claims that wolverine prey species will not be impacted by the project; however, almost every treated acre, from logging to fuels treatments, will severely reduce snowshoe hares; it is not clear why snowshoe hares are not a prey species for wolverine. (BB-7)

Response: Impacts to wolverine prey species are described in the supplemental EA on pg. 3-285. Part of this analysis discusses response by ungulates which states that here

Appendix 5-77 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments will be no expected change in the overall ungulate population numbers. Snowshoe hare habitat and project effects to snowshoe hare are evaluated as part of the lynx section in the supplemental EA. The conclusions of this analysis for snowshoe hare, are relevant to wolverine as a potential prey species. However, no science exists that states that snowshoe hare are an obligate prey of wolverine, as they are to lynx. In other words, wolverine diets are not specific to just snowshoe hare.

Appendix 5-78 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

WILDLIFE: UNGULATES

Comment: The EA does not disclose the existing thermal cover.…..The Forest Service used the entire Glacier Loon Project area as the analysis area for elk, despite the requirement from the best available science to use an elk herd home range as the level of analysis for elk. An average elk herd home range in Montana is 18,200 acres for an entire year, and about 4,225 acres during the rut…..The Environmental Assessment does not reference the best available science on elk security, Hillis et al (1991), nor does it actually apply the definition of elk security area (250 acre continuous blocks at least 0.5 miles from a road) and provide a map of elk security before, during, and after the Project. It does not demonstrate that 30% of each elk herd home range will be retained in security blocks as defined by Hillis et al (1991)…..The Environmental Assessment does not address or apply the best available science on elk habitat effectiveness: Christensen et al (1993)….. The Forest Plan requires that the Forest Service maintain open road density at less than 1.0 mile/square mile or less in moist sites in elk summer habitat. The Environmental Assessment did not address this requirement or demonstrate compliance with it. (BB-5)

Response: The supplemental EA identifies that thermal cover on MA9 lands exceeds 50% as directed by the Forest Plan (supplemental EA pg. 3-356). The project would not affect existing thermal cover on white-tailed deer winter range (MA 9). The supplemental EA has been updated on page 3-364 to discuss further about elk moist sites. Elk moist sites are associated with elk summer range and include subalpine fire climax series, and are found in headwaters of drainages bordering streams, marshy meadows or occupy moist swales or benches. Moist areas in the project area are located in the headwaters of Glacier Creek, Crazy Horse Creek and Herrick Run – these are found in the Mission Mountain Wilderness where there are no roads. No treatments are proposed in wilderness. A project file exhibit in section AA displays a map of these moist areas and the road density associated with these moist sites. The project is consistent with Forest Plan direction for open road density at elk moist sites. The Flathead National Forest Plan does not contain any standards, guidelines, or objectives for calculations of habitat effectiveness for elk or for a proportion of an elk herd unit to be composed of elk security as defined by Hillis et al. (1991). Habitat effectiveness is a measure of usable habitat for elk outside of hunting season and is described by miles of open road per square mile (Christensen et al. 1993; Lyon 1983). As stated in the supplemental EA analysis, currently on approximately 22 percent of the project area exceeds 1 mi/mi2 of open road density as calculated by the Flathead Forest’s Amendment 19 road density analysis (supplemental EA pg. 3-245). Hillis et al. (1991) described elk security as vulnerability during hunting season based on motorized hunter access. Public motorized access will not increase as a result of Glacier Loon and elk security would remain intact. The supplemental EA discusses elk security on pg. 3-257 and references Hillis et al. (1991) on pg. 3-362. Elk are known to use different seasonal habitats in the entire project area including

Appendix 5-79 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

areas in the Wilderness. The project area was used as the scale of analysis for several reasons. In the Mission Mountains, elk occupy low to mid elevations during winter and early spring partly due to the deep snow depths at higher elevations. Elk move higher in the upper parts of drainages through the summer into the late fall. The project area represents a cross section of elevations that elk and other ungulates would use seasonally (summer vs. winter) that can appropriately give context to the effects of the project activities across seasonal ranges. Second, the analysis also needs to recognize the project in a broader context of herd units, in this case considering the scale of effects at the project area likely provides better context especially considering elk movement and distribution of elk habitat through the project area. Christiansen et al. (1993) acknowledges that project-level effects may necessitate analysis over landscape units from 30,000 to 150,000 acres. The Glacier Loon project area is 37,320 acres and is an appropriate scale to measure the effects of the project to big game species (supplemental EA 3-351). No map is included illustrating security for big game. Access management for grizzly bear, grizzly bear security core, visual screening and retention of hiding cover would all benefit big game security. For more information please see the supplemental EA under MIS: Big Game (page 3-351).

Comment: Even though the SEA concluded there will be no significant impacts on big game from the project, there was no actual analysis provided; for example, the habitat effectiveness level during logging and post-logging activities, such as fuels treatments, was never measured; as well, the level of security as defined by the Hillis Paradigm (cited in the SEA at 3-362), was not defined either for current or post-project levels; and one of the biggest issues for big game at present, or displacement to private lands during the hunting season, is not even mentioned in the SEA; this displacement is strongly affected by a lack of security on public lands; some areas proposed for treatment are suitable as big game security as per the Hillis Paradigm, but will be removed with project activities; as well, the impact of past logging on big game security appears to be severe; the agency has completely failed to address this significant issue. (BB-7)

Response: The Flathead National Forest Plan does not contain any standards, guidelines, or objectives for calculations of habitat effectiveness for elk or for elk security as defined by Hillis et al. (1991). Hiding cover, elk security, and displacement are discussed in the Big Game section of the supplemental EA for elk and other big game species. Hillis et al. (1991) described elk security as vulnerability during hunting season based on motorized hunter access. Public motorized access will not increase as a result of Glacier Loon and elk security would remain intact. Hillis et al. (1991) is not only and best available science regarding elk security. Proffitt et al. (2012) has found that elk security may be higher on private lands when compared to public. Elk habitat selection is also influenced by nutrition and not just motorized routes. Ranglack et al. (2017) found that while motorized routes and security areas (as per Hillis et al. 1991) influenced resource selection of elk during hunting season, the magnitude of that effect

Appendix 5-80 Glacier Loon Fuels Reduction and Forest Health Project: Final Decision Notice and FONSI Appendix 5- Response to Comments

was small relative to nutrition.

Comment: Disclose the amount of big game (moose and elk) hiding cover, winter range, and security currently available in the area; disclose the amount of big game (moose and elk) hiding cover, winter range, and security during Project implementation; disclose the amount of big game (moose and elk) hiding cover, winter range, and security after implementation; disclose the method used to determine big game hiding cover, winter range, and security, and its rate of error as determined by field review. (BB-6)

Response: The wildlife analysis for big game species (supplemental EA, pages 3-333 thru 3-345) provides a description of existing conditions, and an analysis of effects to hiding and thermal cover, security, as well as discussion of habitat characteristics, habitat availability and existing conditions in the project area, and population health at several levels, including project level, throughout the Swan Valley and at the regional level. The project does not occur on Management Area 13 designated lands (elk winter range) and thermal cover for elk will not be affected. No activities will decrease existing white-tailed deer thermal cover on Management Area 9 lands (MA9).

Appendix 5-81