Environmental Assessment Forest-Wide Hazardous Tree Removal and Fuels Reduction

Environmental Assessment United States Department of Agriculture Forest-wide Hazardous Tree Removal Forest and Fuels Reduction – Healthy Service Forests Restoration Act Project August 2010 Helena National Forest

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Table of Contents

1.0 Purpose and Need for Action ...... 1 1.1 Summary 1 1.2 Introduction 2 1.3 Purpose and Need 10 1.4 Proposed Action 12 1.5 Location 14 1.6 Scope of the Decision 14 1.7 BScoping & Public Involvement 14 1.8 Issues 16 2.0 Alternatives ...... 21 2.1 How Alternatives Were Developed 21 2.2 Description of Alternatives Analyzed in Detail 21 2.3 1Alternatives Eliminated From Detailed Study 22 2.4 Comparison of the Alternatives 23 3.0 Affected Environment & Environmental Consequences ...... 25 3.1 Effects to Heritage Resources 26 3.2 Effects to Unauthorized Off-Road Travel 28 3.3 Effects to Soil Productivity 29 3.4 Effects to Hydrologic Resources 31 3.5 Effects to Fisheries 40 3.6 Effects to Recreation 52 3.7 Effects to Scenic Values 63 3.8 Effects to Snags 68 3.9 Effects to Wildlife 74 3.10 Effects to Sensitive Plants 159 3.11 Effects to Weeds 166 3.12 Effects to Availability of Firewood 173 3.13 Effects to Socio-economics 174 3.14 Effects to Fuels 176 4.0 Consultation and Coordination ...... 187 4.1 ID Team Members 187 4.2 Federal, State, and Local Agencies 187 4.3 Tribes 188

Appendix A Scoping Comments Appendix B Roads, Campsites, and Administrative Sites to be Treated Appendix C Design Criteria, Mitigation Measures, and Best Management Practices Appendix D Wildlife Analysis Approach Appendix E Summary of Effects to TES and MIS Species Appendix F Cumulative Effects

1.0 PURPOSE AND NEED FOR ACTION 1.1 Summary The Helena National Forest is proposing to fell and remove hazardous trees that are within approximately 125 feet (1 ½ tree lengths) of the edge of National Forest System Roads (NFSRs) open to public travel on the Lincoln Ranger District; and to fell and remove hazardous trees that are within approximately 100 feet (1 ½ tree lengths) of the edge of NFSRs open to public travel on the Helena and Townsend Ranger Districts. The proposal also includes felling and removing hazardous trees in and adjacent to Forest Service campgrounds, recreation areas, administrative sites, and trailheads. These distances should meet the goal of reducing public hazard; however some variation is anticipated during implementation. Please see page 12 for further detail on what this variation is. Healthy live trees, clumps of regeneration, and dead and dying Douglas fir and ponderosa pine trees leaning (greater than 30 degrees) away from roads/trails, would be retained unless the trees pose a safety hazard in the tree removal process. The analysis area includes National Forest System lands on the Helena, Townsend, and Lincoln Ranger Districts in Montana.

An Environmental Assessment (EA) is not a decision document. It is a document disclosing the environmental effects of implementing a proposed action and alternatives to that action. This EA describes and compares the environmental effects of implementing a proposed action and a no action alternative. The EA was prepared in accordance with the National Environmental Policy Act (NEPA) and other relevant federal and state laws and regulations, including the Healthy Forests Restoration Act (HFRA). The HFRA was signed by President Bush in 2003 and contains a variety of provisions to complete an environmental analysis and treatment of lands that are at risk of wildland fire, have experienced wind-throw or blow-down, or are impacted by insect and disease epidemics. On October 6, 2008, the Forest Supervisor of the Helena National Forests determined that the Forest-wide Hazardous Tree Removal and Fuel Reduction Project is an “authorized project” under the HFRA because of an ongoing mountain pine beetle (MPB) epidemic.

Projects authorized under the HFRA are subject to a “Pre-decisional Administrative Review Process” (36 CFR 218). The objection-filing period, which is specific to the 218 process, begins the day after a legal notice announcing the availability of the EA is published in the Helena Independent Record. The objection filing period for this project ended on April 27, 2010. Three objections were filed.

A Decision Notice and Finding of No Significant Impact (DN/FONSI) for this project will be issued by the Forest Supervisor of the Helena National Forest. The DN/FONSI will specify which alternative is selected for implementation and the rationale for the decision.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 1 1.2 Introduction On October 6, 2008, Kevin Riordan, Forest Supervisor, of the Helena National Forest, made the following determinations for the Forest-wide Hazardous Tree Removal and Fuels Reduction Project:

1) Ecosystem components associated with Helena National Forest are threatened by the mountain pine beetle (MPB) infestation. Between 2004 and 2007, aerial survey data showed that over 118,300 acres on the Helena National Forest were impacted by MPB. By 2009, acres impacted by the beetles had escalated to almost 600,000 acres on the Helena NF (approx 63% of the Helena NF landbase). This widespread loss of lodgepole pine and ponderosa pine stands has the potential to impact physical and biological resources. 2) Tree mortality from the beetle infestation poses a significant threat to public safety along travel corridors and in and adjacent to developed recreation sites and administrative sites. Hazard trees increase the potential for: a) persons or property being struck by falling trees; and b) trees falling and blocking roadways, thus preventing both emergency and nonemergency ingress and egress travel.

3) The number of hazard trees has the potential to pose a significant threat for more catastrophic fire events due to increased fuel loads.

Based on these determinations, the Forest Supervisor concluded that the Forest-wide Hazardous Tree Removal and Fuels Reduction Project is an authorized project under Section 102(a)(4) of the HFRA. Accordingly, the environmental analysis for the project was completed under the HFRA, Title I, Section 104.

The Healthy Forest Restoration Act (HFRA) recognizes healthy forests or forest health as an important part of forest management. This project responds directly to forest health objectives as described in the HFRA. Its purpose is to reduce threats to public and firefighter safety by felling and/or removing hazard trees impacted by the mountain pine beetle (MPB) epidemic along roads, trails, and in and adjacent to recreation sites and administrative sites. Additionally it treats the hazardous fuels created by the falling dead trees. The Forest-wide Hazardous Tree Removal and Fuels Reduction Project was determined to meet the definition of a project authorized or covered under HFRA because:

• Section 102(a)(4) of HFRA authorizes expedited vegetation management projects where there is the existence of an insect epidemic. The Responsible Official determined that the dead trees pose a significant threat to the public and that if untreated, the fuel buildup from the falling trees present an increased risk of wildfire starts with an increased resistance to control. • It meets the criteria for the Insect and disease Test in the Decision Diagram 2 of the Guide. • Because the project consists of insect killed trees, it is exempt from the old-growth and large-tree retention requirements of HFRA.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 2 • A collaborative process involving Federal, State, and local governments, tribes, community-based groups, landowners, and other interested persons was included in the process. • The Forest-wide Hazardous Tree Removal and Fuels Reduction Project was selected because of the identified hazards to the public and agency personnel resulting from the MPB epidemic.

Across the Forest, the bark beetle epidemic is now in its fifth or so year in some areas, with the majority of the trees having died over the past two to three years. Once a tree dies from a beetle attack, its roots begin to lose their holding capability and eventually the tree falls to the ground, or breaks off at weakened parts of the tree (e.g., cankers and sap rot). The rate of tree fall is especially exacerbated in older trees which are prone to butt rots. Studies have shown that on a stand basis for lodgepole pine, some of the dead trees begin to fall within a few years of their demise, and within 15 to 18 years nearly all the trees are on the ground, with the majority of the trees falling from years 5 to 9 (Lewis and Hartley, 2006). Once killed by the mountain pine beetle, ponderosa pine deteriorates rapidly and within three to five years, the trees begin to fall (Landram, et al, 2002, Schmid, et al, 2009). As currently evidenced, along our FDSRs’ and across the Forest dead trees have begun to fall.

What is a Hazardous Tree? In response to questions received during the scoping period from the public, this section was created to answer the question, “What is a hazardous tree?” A hazardous tree is defined as any tree that may fail due to a structural defect and, as a result, may cause property damage or personal injury. Tree failure is difficult to predict with certainty due to the complex interaction between a tree and its environment. Every tree would eventually fail; therefore, knowledge of tree species, site characteristics, and local weather conditions and patterns are essential when evaluating tree hazards. A defective tree is hazardous only when its failure could result in damage to something of value. For this project, a hazard tree is a tree with these types of defects that is within approximately 125 feet (1 ½ tree lengths) of an open road, campground or administrative site posing a safety threat. Healthy live trees, clumps of regeneration, and dead and dying Douglas fir and Ponderosa pine trees leaning (greater than 30 degrees) away from roads/trails, would be retained unless the trees pose a safety hazard in the tree removal process. The following table (Table 1.1) identifies tree specific criteria that would be used to identify hazardous trees for this project, in full compliance with the Regional direction. Any one or more of these criteria would qualify a tree as hazardous.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 3 Table 1.1 Hazard Tree Criteria Symptoms, Designation Causal Agent (s) Description & Definition of Hazard Criteria Dead trees; red or no needles. Multiple (insects, Once a tree is dead, it begins to decay. Rates of decay vary Conks may be visible, and disease, fire, other). by species, cause of death, and site (USDA 2000). Pouch bark may or may not be intact. fungus can occur 1-3 years after death and indicate saprot. (USDA 2003) Cankers or galls on the tree Atropellis, stalictiform Cankers on trunk indicate stem decay and lowered structural trunk. & commandra, white integrity. Atropellis canker (lodgepole pine), and white pine pine blister rust, blister rust (whitebark and limber) often girdle and kill trees and western gall rust, create weak points in the stem. Gall rusts and burls create other galls/burls swellings or galls on many conifers; these weaken stems and windbreakage is common. Comandra and stalactiform blister rusts (lodgepole and ponderosa) cause cankers that can girdle stems resulting in top kill or death. (USDA 2003) Fungal fruiting bodies (conks) Stem decay fungi Conks on the trunk indicate stem decay and lowered structural on the trunk. such as Indian Paint integrity. Indian paint fungus (subalpine fir) indicates decay 16’ Fungus, Pini. in either direction from the conk. Pini fungi (all conifers) indicate stem heartrot, extending 2-3’ above and 2-5’ below the conk. (USDA 2003). Thin, rounded crowns, Root disease Root diseases (primarily on older Douglas-fir on the HNF) chlorotic foliage, & fungal (Armillaria, laminated cause decay in the roots which leads to growth loss, fruiting bodies at base/roots. root rot, Schweinitzii) windthrow, and advance of tree death (USDA 2003). Obvious mechanical injury to Abiotic damages Structural injuries can be caused by freeze injury, lightening, the trunk. machinery, fire scars, and lead to stem decay. (Hagle 2003) Crown defects (abundance of Dwarf mistletoe DMT is common in lodgepole pine on the HNF, and can cause brown branches, forked or (DMT), broom rusts witch’s brooms, cankers, and swellings which lead to spiked dead tops). tops, dead branches. Broom rusts (firs and spruce) cause witch’s brooms. Severe DMT and broom rusts can hasten tree mortality and/or heighten tree stress. (USDA 2003). Crown defects (brown Western spruce Several years of heavy defoliation by budworm can cause branches, forked/dead tops, budworm (WSB), branch dieback, top kill, and tree mortality can occur. Douglas- severe defoliation). Dying drought, chemicals, fir, subalpine fir, and Engelmann spruce may be affected. trees with > 1/3 dead limbs, other. Severe foliage loss can result in tree death. (USDA 2003). >40% foliage transparency Dying trees with copious Mountain pine beetle MPB affects all pine species. Pine engraver is common in boring dust in the bark and/or (MPB) or pine lodgepole and ponderosa. Numerous pitch tubes around the at the base (all species), engraver (ips) circumference of a tree indicate death, as feeding of larvae and/or obvious pitch tubes on girdle the cambium (Amman & Logan 1998). Isolated pitch Douglas-fir beetle at least 3 surfaces of the trunk tubes on one face of the tree could indicate a “strip attack” and (DFB) (pines), regardless of crown the tree may be alive. However, pitch tubes may be absent or color. small when a tree undergoes a rapid mass attack; boring dust around the base of the tree is a sure sign that it has been invaded by a sufficient number of beetles to kill it (Amman & Cole 1983). DFB affects Douglas-fir, and does not typically produce pitch tubes; the indicators are limited to boring dust and occasionally pitch streaming. Red turpentine beetle attacks do not constitute a hazard tree (indicated by large, red pitch tubes only on the bottom 6’ of the trunk), as the tree often survives. (Hagle 2003) Trees leaning toward the Multiple (snow Trees leaning severely toward the road particularly on steep road/administrative site and/or damage, soil slopes are likely to be subject to windthrow or structural failure subject to windthrow. slumping or erosion, in the roots or stem. Additionally, scattered LP in an infested root disease, etc.) area that survive the epidemic would be highly subject to windthrow as dead trees are removed due to their shallow root system.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 4 Research shows that dead pine trees begin to fall after three years and that the majority of trees fall within 14 years (Mitchell and Preisler 1998). It is anticipated that many of the dead trees on the Helena National Forest (HNF) would fall across roadways, in administrative sites, across trails, and in developed recreation sites. This situation would create threats to public safety either directly or indirectly (i.e. access into or out of areas may be blocked by fallen trees) and/or would increase the potential for property damage.

Per the “Field Guide for Danger Tree Identification and Response USDA/USDI 2008), the assessment of danger (hazard) trees begins with the potential failure zone (the area that could be reached by any part of a failed tree). When a tree fails, the tree or its parts may strike other trees and cause them to fail as well. The parts may slide or roll. The failed tree may also strike other trees or debris on the ground and fling material a considerable distance (this is especially true in dead timber). When determining the failure zone, ground slope, direction of lean, and height of the tree must all be considered. Per the guide, on level or sloped ground the failure zone is a circle around the tree with a radius of at least 1 ½ times the total tree height. On sloped ground, the failure zone downhill of the tree may have to be extended whatever distance is necessary to protect people.

Recent years have seen a dramatic increase in mountain pine beetle (MPB) activity and conifer tree mortality across Montana. In an attempt to define and track the effects of the infestation, entomologists from the Regional Office have analyzed aerial and ground survey data sets of national forests containing pine at risk for MPB infestations. The analysis included all of the Helena National Forest. Results of the analysis, as documented in the Insect Activity on the Helena NF: Assessment and Recommendations (USDA 2008), confirmed the following: 1) MPB are at epidemic levels in Montana; and 2) Populations are not expected to decline until susceptible host trees are infested or a period of prolonged and severe low temperatures (<-30º F) occurs during late fall-winter-early spring months.

The following maps display hazard tree sites, land ownership, and the roads covered by this analysis (Figure 1.1 and 1.2), as well as the aerial detection survey (ADS) information (Figure 1.3 and 1.4) that covers the insect infestation. The ADS maps show the type of insect infestation and vegetation. These maps can be seen in a larger format on the Helena National Forest website.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 5 Figure 1.1- Helena National Forest Road Side Hazard Project West Half

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 6 Figure 1.2- Helena National Forest Road Side Hazard Project East Half

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 7 Figure 1.3- Road Side Hazard Project 2009 ADS with Watersheds West Half

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 8 Figure 1.4- Road Side Hazard Project 2009 ADS with Watersheds East Half

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 9 1.3 Purpose and Need

The HFRA recognizes healthy forests or forest health as an important part of forest management. This project responds directly to forest health objectives as described in the HFRA. Thus, its purpose is to reduce threats to public safety by felling and/or removing hazard trees impacted by the mountain pine beetle (MPB) epidemic along roads, campgrounds, and administrative sites as well as reducing wildfire risks, protecting watersheds, and addressing the potential threat of wildfires.

These roadside areas are expected to change dramatically if left untreated. The needles of the hazard trees will be very flammable for the next several years; the trees will be falling over and creating a tremendous amount of 1000-hour fuels. These conditions will hamper fire fighter safety and public safety and use of the Forest.

This project is needed to address the following:

Public and Firefighter Safety. The lack of road access, due to trees across roadways, lengthens response time of firefighters and can compromise their safety due to lack of an escape route. In addition, the increase in large dead wood (jackstraw) hampers fire suppression as these areas are difficult to walk through and chainsaws would be needed to remove layers of logs in order to dig fireline. Suppression strategies and tactics would be more successful without the heavy fuel loading and firefighter safety would be greatly improved

As a result, there is a need to ensure public and agency personnel safety by: a) reducing the risk of persons or property being struck by falling trees on approximately 9,416 acres; and b) keeping travel corridors open with adequate clearance for the combination of traditional firefighting equipment (e.g., heavy equipment transport trucks, crew carriers, busses, and fire engines), recreational vehicles, and automobiles on approximately 491 miles of National Forest system roads (NFRS). The combination of such vehicles is typical during an emerging fire emergency when fire resources are arriving and the general public is evacuating. This need moves the Forest in the direction of accomplishing Goals 14 and 15 of the Forest Plan. Goal 14 states “Provide a fire protection and use program which is responsive to land and resource management goals and objectives.” By providing safe travelways firefighters and their equipment can safely maneuver and assist in fire suppression operations. Goal 15 of the Forest Plan instructs, “Develop and implement a road management program with road use and travel restrictions that are responsive to resource protection needs and public concerns.” (Forest Plan page II/2) By clearing roads of hazards, the need for travel restrictions is minimized and it reduces public concerns about travel safety.

This would also meet the direction of Forest Service Handbook (FSH) 7709.59 – Road System Operations and Maintenance Handbook, Chapter 40. The Forest Service works with the Federal Highway Administration (FHA) under the authority of the Highway Safety Act of 1966. (PL 89-564) to make travel on National Forest System (NFS) roads as safe as practicable. According to the handbook, agency policy states that safety is the predominant consideration in road operation and maintenance and takes priority over biological or other

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 10 considerations. In addition, roadways must be managed for safe passage by road users; hazards associated with roadside vegetation need to be managed including identification and mitigation of danger trees. The same policy also states that National Forest System roads must be closed if high priority hazards to users cannot be immediately mitigated.

Fuels. In addition to addressing public and agency personnel safety, and in accordance with the Healthy Forest Restoration Act, the Helena National Forest has a need to reduce wildfire risks, protect watersheds, and address the potential threat of wildfire. Forest Service Manual Chapter 5150 also directs the agency to identify, develop, and maintain fuel structure that contribute to the most cost-efficient fire protection and use program in support of land and resource management direction in the forest plan.

Addressing fuel loading along roadsides would be one way of meeting the previously mentioned manual direction. The increase in the number of hazard trees would increase fuel loading over time as these trees lose needles, small branchwood and they eventually fall over. Heavy fuel loading allows for a longer period of time that the flaming front of a fire occupies one point. This is called residence time. Long residence times promote smoldering of duff and litter, which can subsequently affect soil erosion, native plant recovery, and noxious weed establishment. Smoldering fires also have high smoke emissions. Therefore, by changing fuel models and vegetative characteristics (reducing hazardous fuel loadings), fire behavior can be changed – reducing the risk of high intensity/high severity wildfires.

By treating hazard trees along roadsides, the risks to the public and agency personnel would be reduced. In addition, treating hazard trees would modify fire behavior.

The maintenance required to clear these roads is huge. Based on road clearing records from the Townsend ranger District, it takes 1.3 person days per mile to clear dead trees from a fire. The same work will be needed to clear dead trees from the MPB epidemic. For the roads and mileage proposed this equates to 131 work days for a 5 person crew. Also the time to clear these roads by agency personnel is untenable when contractors could work much safer and quicker using mechanized equipment.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 11 As evidenced by the number of MPB killed trees that have fallen across roads during the spring and summer of 2010, and observed by field personnel, the potential for persons or property to be impacted by falling trees is increasing. There is also an increased risk of dead trees falling and blocking roadways, thus preventing both emergency and nonemergency ingress and egress. The large number of hazard trees across the Helena National Forest also poses a significant threat for more serious fire events with greater potential for large fire growth due to increased fuel loads.

1.4 Proposed Action

The Helena National Forest is proposing to fell and remove hazardous trees that are within approximately 125 feet (1½ tree lengths) of the edge of National Forest System Roads open to public travel on the Lincoln Ranger District; and to fell and remove hazardous trees that are within approximately 100 feet (1½ tree lengths) of the edge of NFSRs open to public travel on the Helena and Townsend Ranger Districts. The proposal also includes felling and removing hazardous trees in and adjacent to Forest Service campgrounds, recreation areas, administrative sites, and trailheads. These distances should meet the goals of the project and some variation is anticipated during implementation. For example in some areas the distance for treatment may be only 50 feet from the edge of a road as that is the extent of mortality. For other areas this distance for 1 ½ tree lengths may not reflect the hazard as this could be an area above the road or campground structure, on a steep slope. In that case according to the Field Guide for danger Tree Identification and Response, (USDA 2008), the distance may be increased. The distance to increase is not given as that is a number that is specific to each specific hazard tree. The need to go beyond a 125 foot distance is expected to be rare, but necessary to meet the purpose and need for this project.

These roads are valuable public roads used by the public to access camping areas, hunting opportunities, pleasure driving, hiking and bicycling trails, fishing opportunities and firewood gathering. Each and every road segment proposed is valued by a broad spectrum of forest users. These roads provide loop opportunities and cross mountain ranges. Each and every road is either open to the public year-round, or during a season in which historical usage has been occurring and is expected to continue.

The project was originally proposed to treat approximately 750 miles of road segments, totaling approximately 13,000 acres. During scoping some groups and individuals felt the width of the proposed treatment was too large. As a result, maximum treatment widths were reduced from approximately 175 feet to 125 feet. Also after on-the-ground review, some areas were found to have a minimal level of mortality and thus a reduced hazard tree component. Therefore these areas were dropped from the proposal. As a result of this groundwork, the proposed treatments were reduced to approximately 491 miles of road segments, encompassing approximately 9,416 acres. Please see Appendix B for more details of the roads, campsites, and administrative sites that are proposed for treatment, and rationale for each roads inclusion for treatment.

Healthy live trees, clumps of regeneration, and dead and dying Douglas-fir and ponderosa pine trees leaning (greater than 30 degrees) away from roads/trails, would be retained unless the trees pose a safety hazard in the tree removal process. Under the proposed action, standing hazard trees would be felled and/or removed up to approximately 125 feet (1 ½ tree lengths) from the edge of or around administrative sites. Areas targeted for tree removal are primarily dead trees

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 12 including beetle infested lodgepole and ponderosa pine stands and completely defoliated Douglas-fir from spruce budworm; however there may be minor amounts of other tree species that are hazardous or become hazardous after treatment and would need to be felled and/or removed. After felling, trees could be left on site, bucked, decked, or removed from the area to reduce fuel hazard. Mature and regenerating healthy, live trees that do not pose a hazard to people or property would be retained after hazard trees are felled and/or removed from the area. After hazard trees are felled and/or removed, the area may resemble a thinning of the forest or a clearcut with scattered regeneration. This would depend upon the number of dead and infested hazardous trees within an area.

The wildlife analysis for this project concluded that the existing condition for Forest Plan Standard 3 is not met within 17 of the 27 Elk Herd Units (EHU) for hiding cover and none of the EHUs meet Forest Plan Standard 3 for thermal cover. The existing condition for Forest Plan Standard 4a is not met within 22 of the 27 EHUs. Implementation of the Decision will not result in any additional EHUs being below these Forest Plan Standards.

Standard 3 is a calculation of hiding cover on elk summer range and thermal cover on elk winter range. There is no opportunity with this decision to increase hiding/thermal cover components. The Project Decision minimally reduces the hiding cover within those EHUs where existing condition is currently below Forest Plan Standard 3; 2 EHUs result in a reduction of 1% of hiding cover and all others are less than 1%. Thermal cover reductions are also minimal; the Proposed Action would treat 170 acres of thermal cover which is less than 1% of existing thermal cover of the affected EHUs All EHUs are currently below Forest Plan Standard 3 for thermal cover.

Along with hiding cover, open road density is an important component of Standard 4a. The scope of the analysis addressed proposed treatment of hazard trees on roads open to the public; recreation sites and administrative sites, which pose a safety concern. No consideration was given to closing roads currently open to the public. The Proposed Action would reduce hiding cover acres within those EHUs where existing conditions is currently below Forest Plan Standard 4(a). However, there is a maximum reduction of 1 percent in hiding cover acres in any given EHU, and this reduction is immediately adjacent to open roads.

Primary slash treatments consist of felling damaged residual trees (poles and saplings) from areas where hazard trees have been felled. Slash piles would be made available to the public for firewood gathering opportunities for at least one year prior to burning.

Commercial salvage could be used as an efficient and effective tool to facilitate the actions that address the needs for ensuring public and agency personnel safety. Merchantable material would be yarded with ground-based tractors. By doing so, this would also meet the need for wood products. This opportunity would represent nearly 35,559 hundred cubic feet (CCF) of wood. products to support local communities and lifestyles. This need would help the Forest move toward accomplishing Forest Plan Goal 11, which states “Provide a sustained timber yield that is responsive to local industry and national needs.” (Forest Plan page II/1).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 13 Table 1.2 Summary of Proposed Action Treatments Action No Action Proposed Action Removal of Hazard trees Acres Considered 0 9,416 Landing areas (these acres overlap treatment acres) 0 235 Slash treatments (these acres overlap treatment acres) 0 975 Total acres with harvest and slash treatments 0 9,416 Salvage of Wood Products Acres 0 9,416 CCF 0 35,559

1.5 Location The Forest-wide Hazardous Tree Removal and Fuels Reduction Project is located on the Helena National Forest. The analysis area includes National Forest System (NFS) lands in the Helena, Townsend, and Lincoln Ranger Districts. The potential project area includes only those acres that could be directly impacted by project implementation. The project area is approximately 491 miles of roads across the Forest, plus 12 administrative sites, and 6 campgrounds. For a specific list of the roads, administrative sites and campgrounds please see Appendix B.

1.6 Scope of the Decision The Forest Supervisor of the Helena National Forest is the Responsible Official for this project. Given the purpose and need for the project, the Forest Supervisor will review the proposed action, the no action alternative, issues identified during scoping, and the environmental consequences associated with implementing each alternative. This information will form the basis for the Forest Supervisor to make the following determinations:

• Whether or not the information contained in this EA is sufficient to make an informed decision. • Whether or not the vegetative treatments should be implemented and, if so, in what manner and in which locations. • Whether or not a site-specific Forest Plan amendment for wildlife standards 3 and 4a is needed.

1.7 Scoping & Public Involvement Concerned agencies, local governments and the public have been in a 5 year dialog about the MPB and have been working together to find information and solutions to addressing the effects of the infestations on public and private lands. This project was created to address the specific concerns with hazardous trees that have been created by this epidemic threatening public and agency personnel health and safety as they use travelways on the Helena NF that are open for use. The collaborative and public involvement process is summarized below. The public scoping content analysis is Appendix A. Collaborative efforts with other agencies, local governments and the public have been ongoing. These efforts address the various insects and disease issues that have arisen on the Helena NF and the surrounding area

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 14 In addition to collaborative efforts, local tribal representatives were notified of our plans to address hazardous trees created by the mountain pine beetle infestation, and encouraged to consult with us in a formal letter dated May 14, 2009. Face-to-face meetings were held with the Blackfeet tribe. Currently, the Confederated Salish and Kootenai Tribes (CKST) have not opted to a face-to-face meeting with staff from the Helena NF to specifically discuss this project, but communication with them is ongoing in regard to the MPB infestation in general. Cultural resource surveys have been initiated and are ongoing during the 2010 field season. Surveys would continue until all areas have been reviewed per design criteria.

Public Scoping On November 18, 2008, the Helena NF mailed a scoping (40 CFR 1501.7) letter describing the proposed action and purpose and need for the project to individuals, organizations, and agencies. A news release describing the proposal was also mailed to local media stations that same day. Both the scoping letter and the news release in the Helena Independent Record indicated that the comment period would end on December 18, 2008. By the close of the comment period on December 18, 2008 the Helena NF had received 15 public comment letters. The comment letters were reviewed by the Responsible Official and the Interdisciplinary Team (IDT). From those letters and other comments received both internally and externally, a list of issues to address during the analysis process was developed. The public comment letters are also formally responded to in Appendix A of this EA. During the scoping period the Helena NF hosted five open house meetings. The open house meetings took place on December 1, 2008 in Helena, MT, December 2, 2008 in Elliston, MT, December 3, 2008 in Marysville, MT, and December 4, 2008 in Lincoln and Townsend, MT.

Forest Plan Amendment Scoping On September 25, 2009, the HNF mailed a scoping letter to solicit input on a site-specific Forest Plan amendment for this project. Analysis for this project indicated the need for a site-specific Forest Plan amendment to the Helena Forest Plan regarding elk summer and winter range and big game security. A legal notice was published in the Helena Independent Record on September 25, 2009. The comment period yielded nine responses. Please see Appendix A for the content analysis of this scoping.

Objection Period The legal notice for the Objection filing period was published on March 27, 2010 in the Helena Independent record. The Objection filing period began on March 28, 2010 and ended on April 27, 2010. Three objections were received on the project. On May 19, 2010 Kevin Riordan, Forest Supervisor, and Dave Carroll met with seven individuals from the three organizations that Objected during the 30-day Objection period. The Forest Supervisor gave an overview of the process and asked the three groups to verbally share their thoughts and clarify their objections. The context was basically, is there an opportunity for all parties to come to an agreement and resolve the objections while still proceeding with the project. After two hours of discussion it was apparent that no agreement would be reached to allow for the three objections to be withdrawn, or the proposal modified in a way that would still meet the purpose and need for action. There were several items the Forest Supervisor agreed to in order to respond to the groups concerns. The project file contains this documentation.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 15 1.8 Issues

The IDT reviewed the scoping letters and public involvement information. Using these comments, “issues” relevant to the proposed action were identified and classified into resource categories. The Forest Service generally defines issues as, “A point of disagreement, debate, or dispute about the proposed action based on effect identified through scoping.” The issues identified were categorized into two types: key issues and analysis issues. Key issues (or ‘significant issues’) are defined as those issues utilized in modifying the proposed action or in the development of an alternative to the proposed action. Analysis issues (or ‘non-significant’ issues) are already decided by law, regulation or Forest Plan direction or policy; addressed through project design; or addressed through comparison of effects of the no action and alternative actions. These are issues that are used to develop alternatives that meet the purpose and need of the proposed action. After an evaluation of their relationship to the proposal, issues (both key and analysis) were identified and defined, then recommended for approval to the Responsible Official. Significant issues and the range of alternatives to analyze in detail were then approved. Public comments related to this project were reviewed by Forest Service resource specialists and the Responsible Official. This review did not identify any key issues that necessitated the development of alternatives to the proposed action. The following is the list of analysis issues as determined from review by the Responsible Official. For each issue, we describe how it relates to the proposed action (cause/effect), how it will be measured (indicators of resource impacts), and how it will be addressed in this assessment. Issues are not a restatement of the project objectives (resource benefits defined by the purpose and need), but express resource tradeoffs that may result from the actions used to attain the project objectives. Nonetheless, how each alternative attains project objectives is measured and compared in this assessment alongside the issues to disclose the full effects of actions.

1.8.1 Protection of Heritage Resources Issue: Whether 9,416 acres of treatment have the potential to adversely affect heritage resources. Adverse effects could include destruction, displacement, disturbance and/or alteration of sites, properties or character. Heritage resources (also referred to as cultural resources or historic properties) include, but are not limited to, archaeological sites, historic structures, historic buildings, sacred sites, traditional cultural properties and cultural landscapes. Measure: The indicator is the number of historic sites directly or indirectly affected. Addressed by: This issue is addressed by the Forest Plan in its requirement of cultural resource inventories of affected areas, and by reviewing past cultural resource inventories to determine if heritage resources have been recorded within or near areas of potential effect. In the Proposed Action, measures were established and required to avoid direct or indirect effects to known or suspected heritage resources. This project meets applicable guidelines to protect heritage resources pursuant to established management direction (as presented in Section 106 of the National Historic Preservation Act of 1966, as amended). Site-specific measures to meet Forest guidelines are found in Appendix C of the EA. Threshold: The requirements from the Forest Plan allow for no direct or indirect effects.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 16 1.8.2 Unauthorized Off-road Travel Issue: Whether removal of hazard trees could potentially increase unauthorized off-road vehicle use to retrieve available firewood. Measure: The amount of proposed treatment acres that occur on slopes less than 10 percent. Addressed by: Calculating acres of treatment along roadsides that are less than10 percent in- slope identified as areas with potential for unauthorized off road use. Threshold: The Helena Forest Plan, local travel management decisions, and the Tri-State OHV Record of Decision (USDA and USDI, 2001), do not allow for any unauthorized cross country or off route travel by motorized vehicles.

1.8.3 Soil Productivity Issue: Whether soil disturbance from mechanical equipment used for hazard tree removal and associated activities may have negative effects on soil physical, chemical and biological properties and could reduce long-term soil productivity. Measure: An estimate of the area with detrimental soil impacts, such as compaction and rutting, was made to quantify soil effects. This estimate was correlated to “detrimental” impact to soil productivity based upon studies and monitoring of similar past activities on similar sites. Addressed by: This issue will be addressed by meeting Regional Soil Quality Standards and Forest Plan requirements to minimize detrimental soil impacts and through a quantitative comparison of soil impacts to accepted thresholds. Threshold: Regional Soil Quality standards (FSM 2500 – Watershed and Air Management, R-1 Supplement No. 2500-99-1) for detrimental soil disturbance (DSD) are used to define detrimental soil impact threshold values. The threshold level is no more than 15% of the affected area can be detrimentally impacted.

1.8.4 Snags Issue: The effect the removal of hazard trees/snags which are an important ecological component of a healthy forest. They can provide habitat such as nesting and foraging, for several wildlife species. Although the MPB has created innumerable snags across the Forest, hazard tree removal will reduce the number of snags available for wildlife habitat in the treated road corridors. Measure: The number and distribution (i.e. snags/acres) of available snags across the Forest. Addressed by: The estimation and comparison of effects and demonstrating compliance with Forest Plan Standards (page II/21). This project assures that Forest Plan standards for snags will be met across the landscapes. Threshold: Retain snags in size classes, numbers and distribution guidelines across the Forest in accordance with Forest Plan standards (page II/21, Forest Plan).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 17 1.8.5 Wildlife Fragmentation/Dispersal/Connectivity Issue: Whether the project will result in fragmentation that can affect animal populations by reducing total available habitat and apportioning remaining habitat into smaller patches. It can also create barriers to dispersal. Measure: The ability of wildlife species to disperse, migrate, or move through the forest landscape. Addressed by: A qualitative assessment of this project relative to this issue was completed. Threshold: There is not a Forest plan standard for this issue Elk Hiding Cover Issue: The effect of the proposed action on hiding cover for elk. Measure: Acres of hiding cover by elk herd unit. Addressed by: Forest Plan big game standards 3 and 4a and the elk hiding cover amendment specific to this Decision. Threshold: Forest Plan standards 3 and 4a and as addressed by the elk hiding cover site specific Forest Plan amendment (Number 24 for the Forest-wide Hazard Tree Removal & Fuels Reduction Project)..

Elk Thermal Cover Issue: Whether the proposed action may result in a loss of thermal cover for elk. Measure: Acres of thermal cover by elk herd unit. Addressed by: Forest Plan big game standard 3. Threshold: Forest Plan standard 3 and as addressed by the elk hiding cover site specific Forest Plan amendment (Number 24 for the Forest-wide Hazard Tree Removal & Fuels Reduction Project)..

Grizzly Bear Issue: Whether the proposed action may impact grizzly bears during project implementation. Measure: Number of miles proposed treatment in the Northern Continental Divide Ecosystem (the mapped grizzly bear distribution zone). Addressed by: The analysis and compliance with guidelines. Threshold: Do not operate outside the road use restrictions in the grizzly bear zone.

Lynx Habitat Issue: Whether he proposed action will result in the loss of lynx habitat. Measure: Acres of treatment in multi-storied and stand initiation lynx habitat. Addressed by: Compliance with Northern Rockies Lynx Management Direction (NRLMD). Threshold: Follow NRLMD guidelines for HU G6 and HU G11.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 18 1.8.6 Non-Native Invasive Species -“Noxious Weeds” Issue: The effect of soil disturbing activity such as tree removal with mechanized equipment has the potential to increase noxious weed populations. Proposed hazard tree removal could disturb surface cover and increase potential for the establishment of weeds. Off-road equipment may also introduce weed seeds from off-site, thus increasing the risk of new infestations within treatment areas and along access roads. Measure: Risk of spread and establishment. Risk is measured by soil surface disturbance that effectively functions as seed bed preparation for noxious weed seeds. Addressed by: If any noxious weed species are located within the disturbed areas, measures to prevent, avoid and control establishment and spread will be implemented. Threshold: The Helena National Forest Plan states, “Implement an integrated weed control program to confine present infestations, and prevent establishing new areas of noxious weeds.” 1.8.7 Availability of Firewood Issue: There is concern about the limiting of available firewood in close proximity to Forest roads that will be accessible to gatherers. Measure: Amount of acres having a reduced amount of firewood available per acre. Forest Plan standards 1, 2, 4 and 6 for firewood will be emphasized in the implementation phase, (Forest Plan page II/24). Addressed by: Availability of firewood on roads not included in this decision as well as directing the public to specific locations (i.e. slash piles created by implementation of this decision). Threshold: No thresholds are established in the Forest Plan, or other direction, for the level of permits that the Forest must supply to maintain community stability. The Forest Plan states: “Provide firewood as an energy source for personal and commercial uses.” This will continue through issuance of personal use firewood permits and providing opportunities to collect firewood. 1.8.8 Socio-economics Issue: Local communities rely upon wood products from the National Forest to provide jobs, contribute to the economy, and sustain rural lifestyles. The level of harvest in this proposal relates directly to jobs and community stability. Local communities anticipate a flow of wood products from the Forest, and this action may affect local budgets, jobs and lifestyles. Measure: The important measure to communities is the amount of potential income generated from the sale of wood products and the representative number of jobs provided by manufacturing wood products. Economic data and harvest volume will be used to estimate timber sale benefits, costs, and jobs attributed to proposed actions. Addressed by: The economic analysis for this project. Threshold: No thresholds are established in the Forest Plan, or other direction, for the level of values and jobs a specific action must supply to maintain community stability. The volume of wood products offered directly relate to potential income and jobs.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 19 1.8.9 Roadless Issue: During the objection process, the issue of removing hazard trees from roads open to the public within Inventoried Roadless Areas (IRAs) was brought forward. Measure: Miles of road within IRAs proposed to be treated. Addressed by: A total of 22.29 miles of such roads were included in the analysis. Threshold: No thresholds are established in the Forest Plan for removal of hazard trees within IRAs.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 20 2.0 ALTERNATIVES This section describes and compares alternatives to the proposed action that are considered in this analysis. It includes a description of each alternative analyzed in detail. Detailed locations are provided in the maps on pages 5 and 6. A comparison of the effects of alternatives in summary form, sharply defines the differences between each, providing a clear basis for choice among options by the decision maker and the reviewer. This comparison is based upon the issues and objectives measures identified in Sections 1.8 and 1.9.

When necessary to reduce unacceptable environmental effects, mitigation measures are identified. Project-specific design features that mitigate effects are identified, as well. Appendix C lists the project design criteria/mitigation for the project.

2.1 How Alternatives Were Developed Two alternatives were analyzed in detail (EA, Section 2.2). The no action alternative is analyzed in detail in order to provide a baseline of the environmental condition if no agency action is undertaken. The proposed action was developed to respond to the purpose and need while meeting agency and Forest Plan requirements. The proposed action went forth to the public in a scoping letter in November 2008. The Forest Service Interdisciplinary Team (IDT) reviewed the comments from the public. To resolve issues and concerns raised by both the public and resource specialists, the IDT incorporated design criteria into the proposed action. It was through this process that the proposed action went from approximately 750 miles of road for treatment (equating to approximately 12,970 acres) to approximately 491 miles of road for treatment (equating to approximately 9,416 acres).

Public and internal issues were reviewed to determine if resource tradeoffs could be reduced through alternative approaches to achieving the purpose and need. Due to Forest Plan management requirements, the proposed action already avoided or minimized impacts to many of the issues (e.g. cultural resources, soil productivity, weeds and community stability). The proposed action removes hazard trees to improve public and agency personnel safety and utilizes commercial harvest to provide wood products.

2.2 Description of Alternatives Analyzed in Detail The description of the two alternatives analyzed in detail is included below. The site-specific maps show the areas where hazard trees would be removed. Those maps apply only to Alternative 2, the proposed action.

2.2.1 Alternative 1 (No Action) As required by Forest Service Manual (FSM) 2332.11 (Public Safety, Hazard Trees), the Forest Service would continue to fell and/or remove hazardous trees in developed recreation sites (e.g., campgrounds, trailheads, picnic grounds, etc.) prior to their being opened to public use. As budgets allow, the Forest Service would also continue to clear trees as they fall across NFSR and trails or the routes would be closed to motorized or other public access for safety reasons, as required by the Highway Safety Act of 1966 and FSM 7733. Alternative 1 does not mean the

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 21 Forest Service gives up the ability to mitigate hazards in developed and administrative sites nor to not clear roads and trails of downed trees. Hazard trees can be felled under No Action. 2.2.2 Alternative 2 (Proposed Action) The following is a summary of the specific actions in Alternative 2. Appendix B lists the roads, campgrounds, and administrative sites considered for treatment. Design criteria/mitigation measures are listed in Appendix C. The project maps display the site-specific locations of these actions.

About 491 miles of road, 6 campgrounds and 12 administrative sites (9,416 acres) would have hazard trees felled and/or removed to improve the safety of firefighters and their equipment during fire suppression efforts and that of the public as they travel Forest roads/trails and recreate at developed and undeveloped campsites and administrative sites. This alternative also includes a site-specific non-significant amendment to exempt the project from Forest Plan big game standards 3 and 4a.

Within the area it is estimated that 975 acres of harvested areas would require slash treatments which may include a combination of mulching, chipping, topping or scattering of tree debris and damaged poles and saplings. In addition, 235 acres of landings would have slash piles burned.

Features Specific to this Action and Required by Direction and Law: The Helena Forest Plan identifies requirements that must be met by all projects implementing actions allowed by it. The IDT identified best management practices (BMP), design criteria and in some cases mitigation to reduce or prevent undesirable effects resulting from management activities. These measures also include Forest Plan standards and guidelines, and other environmental protection required by laws and regulations. Their implementation is an integral part of each applicable activity the requirement applies to (a decision to approve a component activity within an action automatically includes the Forest Plan requirement). For the specific BMP and mitigation measures please see Appendix C of this document.

2.3 Alternatives Eliminated From Detailed Study Federal agencies are required by NEPA to rigorously explore and objectively evaluate a range of reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not considered in detail (40 CFR 1502.14).

There were two alternatives considered but eliminated from detailed study. The first was the initial proposed action that was scoped to the public. The public felt this proposal was too large in scope and would create too wide of an opening along treated roads. In addition, the IDT had some resource concerns thus, the proposed action was reduced from approximately 750 miles of road for treatment (equating to approximately 12,970 acres) to approximately 491 miles of road for treatment (equating to approximately 9,416 acres).

A second alternative that was considered but eliminated from detailed study was one that addressed the road density issue raised from the public. These comments came during the Objection period. Some comments suggested the Responsible Official consider an alternative that would reduce open road densities as a means to increasing elk security. With this proposal

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 22 not being a travel management decision, this proposed alternative is outside the scope of the decision space and analysis. The Purpose and Need is not to lower open road density. This issue is better addressed through ongoing travel management analyses, such as Divide Travel. Please see Appendix A, for further details about the content analysis and response to public comment for this project.

2.4 Comparison of the Alternatives This section compares the effects of the alternatives in a summary form. It first compares how well each alternative meets the purpose and need using the project objectives found in Section 1.9. It then compares how each alternative impacts each of the non-key issues using the measures identified in Section 1.8.

A more detailed comparison for each issue and objective is provided in Section 3. A disclosure of the full analysis, including methods, assumptions and literature is available as separate reports in the project file (PF). Records from this file are available to the public (excepting specific exemptions to protect sensitive or confidential records under the Federal Freedom of Information Act) upon request, and will be posted on a public website during the project objection period (36 CFR 218).

Table 2.1 How Each Alternative Meets the Project Purpose and Need Alt. 1 Alt. 2 Purpose & Need No Action Proposed Action Public and agency personnel safety Acres of hazard trees removed 0 acres 9,416 acres Miles of road kept clear of potential hazard trees 0 miles 491 miles Table 2.2 How Each Alternative Impacts Analysis Issues Issue Alt. 1 Alt. 2 (measurement indicator) No Action Proposed Action Heritage Resources (# of historic sites directly or indirectly affected) 0 0 Potential for Unauthorized Off-road Travel (acres of road <10% slope) 0 acres 1,233 acres Soil Productivity (based on 9,416 ac.) 0 acres 1,129 acres (cumulative acres and % area with detrimental 0% 12% impacts)

Fisheries No Effect May Affect Not Likely to (effects to bull trout) Adversely Affect

No Effect May Affect Not Likely to (effects to bull trout critical habitat) Adversely Affect

No Impact May Impact Individuals, but (effects to western cutthroat trout) will not result in loss of population viability or result

in a trend toward listing under the ESA Recreation (risk of damage to administrative sites) increasing decreasing (trend in accessibility) decreasing stable

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 23 Issue Alt. 1 Alt. 2 (measurement indicator) No Action Proposed Action (trend in visitor safety) decreasing increasing Scenery (meets VQO’s) yes yes Snags (snags/acres) exceeds standards exceeds standards

Wildlife Short-term impacts to Dispersal Minor indirect effects movement patterns 507,193 acres remaining Elk hiding cover 512,635 acres existing post treatment* 19,280 acres remaining post Elk thermal cover 19,450 acres existing treatment* May affect but not likely to Grizzly Bear Minor indirect effects adversely affect Minor indirect effects Lynx Habitat May affect but not likely to adversely affect lynx and/or

its critical habitat

Gray Wolf No effect No effect Sensitive Plants Amerorchis rotundifolia: Aquilegia brevistyla The No Action Alternative, would Botrychium crenulatum May impact individuals but have no new soil Botrychium paradoxum: would not contribute toward disturbing activities Cypripedium passerinum a trend for federal listing or that would disturb loss of viability Goodyera repens sensitive plant Grindelia howellii populations. Juncus hallii Phlox kelseyi var. missoulensis Noxious Weeds Current infestation 1,256 acres 1,256 acres Predicted potential increase (worst case scenario for 10-13 percent per year 1958 acres; with both Alternatives) implementation of mitigation treatments this should be similar to Alternative 1 Availability of Firewood (# of acres with diminished firewood availability) 0 acres 8,205 acres Local Socio-Economics (total amount of potential income - in $000) 0 $8,129 (total jobs represented) 0 213 (salvage volume) 0 35,559 CCF Fuels (fire behavior) highly variable reduced intensity (trend in road accessibility for firefighter) decreasing status quo to increasing (trend in safety conditions for firefighters) decreasing increasing *Please see the wildlife specialist section in Chapter 3

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 24 3.0 AFFECTED ENVIRONMENT & ENVIRONMENTAL CONSEQUENCES For each analysis issue, the existing condition of the affected environment is briefly described. This condition sets the context for predicting the impacts that would occur as a result of implementing the alternatives described in Section 2. For this project, a hazard tree is a tree that is within approximately 125 feet (1½ tree lengths) of an open road or administrative site posing a safety threat.

In order to set the context for cumulative effects, the impacts of past, present, and reasonably foreseeable actions have been assessed relative to each resource affected by the proposed action. Please see Appendix F for cumulative effects. In addition, the project record contains more detailed information as it relates to cumulative effects.

There are 220 miles of FSDRs in Inventoried Roadless Areas open to the public within the project area. Of those miles of road 22.29 miles have hazard trees along them and those miles were included for treatment in the Proposed Action. The variety of purposes served by the existing road system within the IRAs, such as access to trails, trailheads, facilities, campgrounds, private land, well used dispersed sites, etc. were examined. Road segments that were very short and did not appear to serve multiple access reasons are not included in the hazard tree removal project. Therefore I reduced the miles of road treatment in the IRAs from 22.29 miles to 19.54 miles. The miles of roads in IRAs left untreated would be left available for public firewood gathering opportunities.

This section discloses the environmental impacts that would occur by implementing each alternative described in Section 2.2. It presents the scientific and analytical basis for the comparison of alternatives presented in the chart in Section 2.4. The assessment of impacts is based upon the important resource measures and indicators identified in Sections 1.8 and 1.9. In addition, consequences for each resource have been analyzed with the sideboards of the mitigation measures, design criteria, and/or BMPs described in Appendix C. Unless otherwise specified in specialists reports, short-term impacts are those that would occur under five years and long-term impacts are those that would occur beyond five years. Resource impacts are organized by analysis issues and objectives, and occur in the order they are discussed in previous sections.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 25 3.1 Effects to Heritage Resources This analysis focused on cultural resources located within road corridors and administrative sites targeted for hazard tree removal across the Helena National Forest. The analysis area encompasses designated forest road corridors and administrative sites on the Helena, Lincoln, and Townsend Ranger Districts, Helena National Forest. All currently identified cultural resources located within those road corridors and administrative sites were identified by comparing the cultural resource and hazard tree project GIS data layers. All known potentially affected cultural resource sites and proposed areas for treatment were reviewed. It is estimated that about 30-40% of the roads included in the project area are included in areas previously inventoried for other projects. The remainder of the project area is undergoing current field surveys. The direct, indirect and cumulative effects are displayed as the ‘ceiling’ of effects that might occur to heritage sites within the proposed project area. As surveys are completed this information will be updated accordingly and placed in the project record

3.1.1 Affected Environment The HNF is rich in prehistoric and historic cultural resources, as described in HNF cultural resource overviews (see Heritage report) and agency records. The Helena National Forest was the scene of extensive American Indian occupation and use extending back some 10,500 years. Explorers and fur trappers traveled through what would become the state of Montana in the late 1700s and early 1800s. But gold discoveries in the 1860s led to the rapid Euroamerican settlement of this region. Much of the current HNF road system owes its existence to the early mining and settlement history of this region. Upon its formation, the Forest Service simply preempted existing historic travel routes—parts of which had antecedents in American Indian trail networks (often considered “roads” by the Indian themselves because of the extensive traffic, with horses and travois). By this process, homesteads, mines, line camps, stone quarries, logging camps, saw mills, trapper cabins, and other historic features, to which these roads were physically connected, also came into federal ownership at the turn of the 20th Century. Road improvements and new road construction, particularly that spurred by an extensive Forest Service timber harvesting program beginning in the 1940s, followed. But the original location of much of the HNF road system has remained largely unchanged. Therefore, as indicated by this analysis, there is a high correlation between the location of roads and cultural resources.

3.1.2 Alternative 1 (No Action) The No Action Alternative is the current condition. Hazard trees would be removed when circumstances dictated along forest road corridors and in administrative sites. Some road corridors and administrative sites could be closed due to the threat that falling hazard trees pose to the public. Under this alternative, the known cultural resources, or those found through subsequent NHPA Section 106 field survey, would not be affected by a comprehensive and potentially long-term Forest Service hazardous tree removal program along forest roads and in administrative sites. On the other hand, the No Action alternative could eventually result in a sporadic approach to hazard tree removal that could make cultural resource protection difficult.

Cultural resources would be susceptible to the effects of fire-wood collecting, contingent on the degree of control imposed by the Forest Service. For example, designated firewood cutting areas

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 26 could be inventoried for cultural resources. Still, areas posted by law enforcement for no firewood collection would likely be subject to some illegal firewood cutting and gathering.

Hazard trees left standing in proximity to cultural resources could eventually fall over and damage or crush cultural resources. Charter Oak Mine, Cummings Cabin, Kading Cabin, Old Lincoln Cemetery, and Thompson Guard Station are particularly vulnerable to those consequences of dead or dying surrounding timber. Therefore, these sites are at risk of damage from hazard trees.

In the absence of a program of hazard tree removal, archaeological and historical cultural resources could become increasingly threatened by blown-down trees, wildfire, and firewood cutting.

Cumulative Effects The cumulative effects boundary includes the select road corridors and administrative sites across the HNF. Cumulative effects under the No Action alternative are similar to those described for the Proposed Action. The primary difference is that the forest-wide hazard tree removal program would not occur. 3.1.3 Alternative 2 (Proposed Action) The Proposed Action has 108 heritage sites/cultural resources currently identified within or near the roads, recreation, or administrative sites identified for treatment in this project proposal. These cultural resources would be protected through various design features and mitigation measures (see Appendix C and Heritage report).

For both the road corridors and administrative sites under the Proposed Action, mechanical equipment used for timber felling, bucking, and hauling to landings and decking areas, could cause ground disturbance atop unknown cultural resources in some places. Hand felling and piling would cause less ground disturbance than mechanical equipment. However, a minor amount of soil disturbance would occur in areas where the resultant slash is piled and burned. Trees left standing or down atop a cultural resource would be susceptible to firewood cutting unless otherwise posted and monitored by FS law enforcement. Cultural resources located directly adjacent to roads, which are now obscured or hidden in timber (whatever the stand condition), could become more visible and vulnerable to effects of natural and human agencies once hazard trees are removed, particularly where this work would, by necessity, be extensive (i.e., corridors are created). Specifically: Highly visible cultural resources (i.e., cabin ruins) could invite vandalism and other depreciative behavior (i.e., removal of old wood, digging in bottle dumps, artifact collecting, paint gun sports); Accelerated surface water runoff and erosion could subtly or substantially affect cultural resources, particularly archaeological sites, unless specially addressed through soil or hydrology Best Management Practices; and Felled timber lopped and scattered across a cultural resource could invite firewood collection, unless specific protection measures were implemented (hand stacking and removing the wood).

The mitigation measures and design criteria as described in Appendix C would be implemented to reduce or eliminate the potential adverse effects of hazard tree removal. With mitigation measures and design features in place the Proposed Action there would be no direct or indirect effects and could actually enhance the protection and longevity of cultural resources threatened

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 27 by trees blown by severe wind events, wildfire, and firewood cutting, particularly historic rental cabins and structures in Forest Service administrative sites.

Cumulative Effects The cumulative effects boundary includes the select road corridors and administrative sites across the HNF. Since there are no direct or indirect effects, there are no cumulative effects of the proposed action on heritage resources.

3.1.4 Conclusions Implementation of the proposed action would meet Forest Plan Forest-wide standards as Section 106 compliance has been met, inventory work has been performed and would continue and appropriate tribal consultation has occurred (Forest Plan pages II/15-16).

3.2 Effects to Unauthorized Off-Road Travel Firewood gatherers are generally limited by terrain and do not usually retrieve firewood on any slopes greater than 10 percent. Gathering of firewood with a personal use permit is not allowed in campgrounds or within administrative sites, therefore only those areas where treatment would occur along roads are considered. Due to the unpredictable nature of human behavior a qualitative, not quantitative discussion about the effects of unauthorized off-road travel are found here. Direct, indirect and cumulative effects are considered in a qualitative manner and are reported as such.

3.2.1 Affected Environment The affected areas are the roadsides that are less than 10 % slope where the proposed harvest treatments would occur in this project. Out of the total 9,416 acres proposed for treatment in this project, 1,233 acres could be impacted by unauthorized travel according to the assumption of travel being on 10% or less slope.

3.2.2 Alternative 1 (No Action) This alternative would not include any mechanized hazard tree treatment and therefore the opportunity for unauthorized off-road travel use to retrieve the available firewood would not change.

3.2.3 Alternative 2 (Proposed Action) This alternative treats 9,416 acres of hazard trees along 491 miles of NFSRs within the Helena NF. Of this treatment 1,233 acres would fall on slopes that are less than 10% and could potentially be used for unauthorized access to firewood. Potential for direct and indirect effects from the unauthorized off-road travel that might occur to gather firewood have the highest likelihood on 1,233 acres that are less than 10% slope. The ability to quantitatively measure the intensity of the potential impact that off-road vehicles might have on accessible areas is not feasible, however past Forest experience with managing firewood gathering does give insight into expected effects and how to minimize their impacts.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 28 In order to minimize potential effects to soil and water by the off-road use, the 1,233 acres would have project design features implemented to ensure that treatment areas would have landings available to the public for firewood gathering use per forest plan standards, signs would be posted warning of off-route travel, there would be an increased presence of law enforcement, monitoring would occur in these areas and mitigation activities would be conducted as needed, and landings and skid trails would be rehabilitated after hazard tree removal is complete. In addition, off road travel would continue to be addressed in a Forest – wide communication plan and through law enforcement action. Due to past experience in managing these firewood gathering sites, it is expected that the above mitigation measures would ensure minimal direct and indirect effects.

Cumulative Effects The expected cumulative effects of these actions would not increase the intensity of the already existing unauthorized off-road travel on Forest. Illegal actions would be addressed.

3.2.4 Conclusions Implementation of the proposed action would meet Forest Plan Forest-wide standards for safety, resource protection and facility protection (Forest Plan page II/31). The proposed action would also protect the investment in various facilities associated with the campgrounds and trailheads; provide for public safety and facility protection (Forest Plan pages II/30-31).

3.3 Effects to Soil Productivity More detail of the soil effects analysis can be found in the soils report in the project file. Direct and indirect effects were determined by evaluating the type of treatment proposed. Using the findings from local studies and past monitoring of similar actions, an estimate of the percentage of detrimental impacts was assigned. This was summed by land type to show the direct and indirect effects on a soil type basis. Cumulative effects were determined by combining these effects with past, present and foreseeable effects on the same land type.

3.3.1 Affected Environment Soils in the analysis area have been characterized in the “Soil Survey of Helena National Forest Area, Montana” (USDA Forest Service and Natural Resource Conservation Service 2001). From this soil survey, there are 74 landtypes (i.e. soil mapping units) identified in areas proposed for hazard tree removal actions on approximately 9,416 acres of National Forest System (NFS) lands. A summary of key characteristics for the soils within the areas proposed for hazard tree removal activities, including the number of affected acres, can be found in Table 1 of the soils report.

Thirty-seven of these 74 landtypes contain “sensitive” soils (Table 2 in soils report). These “sensitive” soils occur on about 5,114 acres within proposed hazard tree removal areas. “Sensitive” soils are especially vulnerable to detrimental soil disturbance as a consequence of management activities.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 29 3.3.2 Alternative 1 (No Action) Under Alternative 1, no new management actions are proposed. With no new actions proposed, no new soil effects would occur. However, past and ongoing management activities, such as previous timber harvest, livestock grazing, roads and OHV use, and public firewood gathering would continue to affect soil resources. Similarly no new soil cumulative effects would be predicted, because no new management activities are proposed with Alternative 1. 3.3.3 Alternative 2 (Proposed Action) There would be impacts to soils with operation of ground-based heavy equipment for tree thinning and removal, primarily in areas where logging equipment traffic is concentrated, such as main skid trails and log landings. For logging under “summer conditions”, main skid trails, which are designated or flagged on the ground prior to the start of logging operations, would typically be located in a parallel pattern in a harvest unit, at a spacing of about 100 feet apart (except where converging at the log landings). With an average width of soil disturbance at 10 feet, main skid trails would affect about 9% of the activity area in a tractor harvest unit logged during “summer conditions”. For this Roadside Hazard Tree Removal Project, it is predicted that approximately 847 acres of detrimental soil disturbance would occur on main skid trails as a result of ground-based tree yarding.

Soil would be detrimentally disturbed by compaction, displacement, rutting and erosion in the areas affected by main skid trails in the short-term. Over the long-term, soils affected by detrimental disturbance on main skid trails would recover through natural processes, such as frost heave, bio-perturbation and soil organic material cycling. However, recovery of soils to pre-disturbance conditions would likely take 100 years or longer.

The log landings would generally be located alongside the road that accesses the site and within the harvest unit. Typically, these log landings would be located on gentle terrain, where soil excavation would not be necessary. As a rule of thumb, one log landing would be needed for approximately every 10 acres of land harvested using ground-based log retrieval systems. Each landing would affect approximately ¼ acre. With a size of ¼ acre, one log landing for every 10 harvested acres would affect about 2.5% of the activity area. For this Roadside Hazard Tree Removal Project, it is predicted that approximately 282 acres of detrimental soil disturbance would occur on log landings (Table 3 of soils report).

Slash disposal treatments would be implemented by piling then burning tree limbs and tops on the log landings, following whole tree yarding from the tree removal areas and log processing at the landing. Because slash piling and burning would occur in areas already disturbed by construction and use of the log landing, there would not be any additional area of detrimental soil disturbance as a result of slash disposal.

In total, it is predicted there would be 1,129 acres of detrimental soil disturbance as a result of hazard tree removal activities on 9,416 acres of NFS lands. This would include detrimental soil disturbance associated with main skid trails and log landings. Thus a total of 11% of the activity area would be affected by detrimental soil disturbance, which is in compliance with Region 1 Soil Quality Standards (USDA Forest Service 1999).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 30 Cumulative Effects Refer to Appendix 3 of the soils report for a detailed description of how areas of previous activity were chosen for evaluation of existing soil conditions. Likewise, Table 4 of the soils report displays the results of the characterization of existing soil conditions with predicted disturbance resulting from the implementation of Hazard Tree Removal. Areas that are anticipated to exceed Regional Soil Quality Standards were removed from treatment with mechanical means. Therefore, areas with potential for cumulative effects resulting from the Hazard Tree Removal Project to exceed Soil Quality Standards have been eliminated

Irreversible/Irretrievable Commitments: Soil disturbance which would result from the proposed hazard tree removal activities would represent an irretrievable, but not irreversible commitment of resources. An irretrievable commitment represents a temporary loss of a resource, which can be replaced over time. An irreversible commitment represents a total loss of a resource, which cannot be replaced. Soil disturbance associated with the Hazard Tree Removal Project would be an irretrievable commitment of soil resources, because soil productivity would be recovered over the long-term through natural recovery processes, such as bio-perturbation, decomposition of organic material and nutrient cycling.

3.3.4 Conclusions

Table 3.1 shows how those effects, direct, indirect and cumulative are within the allowable threshold of 15% for the project area.

Table 3.1 Direct, Indirect, and Cumulative Soil Detrimental Impacts by Alternative Soil Resource Impacts Alt. 1, No Action Alt. 2, Proposed Action Affected Area 9,416 9,416 acres Direct & Indirect detrimental impacts 0 acres (0%) 1,129 acres (11%) Past detrimental impacts 0 acres 0 acres Cumulative detrimental impacts 0 acres (0%) 1,129 acres (11%)

By meeting regional SQS guidelines for detrimental soil disturbance, the proposed action is consistent with the Forest Plan.

3.4 Effects to Hydrologic Resources Road sediment modeling (using WEPP: Road software) was done by the forest hydrologist. The accuracy of the model’s predictions is dependent on numerous factors, including the limitations of the model in describing physical conditions of the road and soil, accuracy of field data used as model input, and the limitations of PRISM-modified local climate data. The model output used in this report was annual average sediment delivery from the road buffer. The average is based on 50 years of simulated weather events based on a PRISM-modified climate record for general road locations. Actual annual sediment delivery from a road segment would vary greatly from year to year, depending on such factors as antecedent moisture, snow cover, storm intensity, and storm duration. For additional details on the WEPP: Road model, see Elliot (2000).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 31 3.4.1 Affected Environment The analysis area for direct and indirect effects, and cumulative effects to riparian conditions, is defined by 6th-hydrologic unit code (HUC) watersheds which contain roads proposed for tree- removal. Currently, DEQ-defined beneficial uses are not fully met in 35 of the 73 sixth-HUC watersheds in which tree removal is proposed. Of these 35, 17 are covered by a published TMDL and 18 have no TMDL developed.

Water Quality: Sediment Montana law links water quality to the attainment of “beneficial uses” in a water body. Designated beneficial uses vary by water body classification. The state has classified most of the streams within the project area as B-1 (ARM 17.30.610). Water bodies classified as B-1 must be “maintained suitable for drinking, culinary, and food processing purposes, after conventional treatment; bathing, swimming, and recreation; growth and propagation of salmonid fishes and associated aquatic life, waterfowl and furbearers; and agricultural and industrial water supply” (ARM 17.30.623[1]). There are some additional specific standards that apply to B-1 waters” (ARM 17.30.623[2]). Upper Tenmile Creek and McClellan Creek are classified as A-1 (ARM 17.30.610). Water bodies classified as A-1 have the same beneficial uses as B-1 waters, with some additional specific standards (ARM 17.30.622[3]) similar to those listed for B-1 waters. Please see the Hydrology Specialists Report for more information.

An elevated level of sediment is generally the most common water-quality impairment in forested watersheds with road networks. Common sources include forest roads, stream bank erosion, recent wildfire and prescribed burning, past and present mining activities, and timber harvest activities. Heightened levels of sediment in a stream negatively affect native fish viability and reproductive success, and make the water less suitable for domestic, recreational, agricultural, and industrial uses. Of the beneficial uses designated for A-1 and B-1 streams, increased sediment delivery to streams would most likely affect Aquatic Life and Cold Water Fisheries. Sediment is listed as a probable cause of impairment in streams in 23 of the 35 sixth- HUC watersheds where beneficial uses are not currently fully met. Please see the complete detailed listing in the Hydrology Specialists Report.

Sediment from Roads A 2008 field assessment of several of the roads to be treated under the proposed action identified numerous sediment delivery points. It is likely that many other roads proposed for tree removal or hauling are also sources of sediment to streams. An indication of which roads are most likely to have sediment delivery points was provided by the HNF Roads Analysis Process report (RAP), which designated a watershed road-risk rating for most system roads on the forest based on various parameters (Helena NF, 2004). The intent of the watershed road risk rating was to identify roads that had the potential to serve as sources/vectors of sediment and other pollutants to streams, and roads that, due to their location, are affecting riparian areas, wetlands, or channel and floodplain processes. Road mileage by risk rating is summarized in the Hydrology Specialist Report.

Road segments rated as high-risk are more likely than other roads to serve as sources and vectors of sediment when maintenance has lapsed, due to a higher likelihood of stream crossings or long sections adjacent to a stream channel. However, any road segment that crosses or parallels a

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 32 stream has this potential. Based on the current backlog of deferred road maintenance on the HNF, it is probable that many of the roads paralleling streams or with stream crossings are currently vectors of sediment to stream channels. For example, a 2008 assessment of road sediment sources in the Upper Tenmile 6th-HUC watershed (100301011401) identified 30 points where sediment is episodically delivered from a road to a stream channel during surface runoff events. All of the roads surveyed in this drainage were rated high-risk in the RAP.

The TMDL reports covering watersheds where roadside tree removal is proposed quantify current sediment sources for sediment-impaired streams, and list recommended reductions of sediment delivery from these sources. Existing and target sediment loads from forest roads are listed in Table 3.2. The table displays the estimated current and target sediment load from roads for streams that are covered in a completed TMDL and are adjacent to project roads.

Table 3.2 Estimated Current and Target Sediment Load Forest road sediment TMDL planning Stream name area Current (t/yr) Target (%rdn) Clancy Creek Lake Helena 318 60 Warm Springs Creek (all forks) Lake Helena 237 60 Lump Gulch Lake Helena 576 60 Prickly Pear Creek Lake Helena 4655 60 Tenmile Creek Lake Helena 1558 60 Skelly Gulch Lake Helena 192 60 Blackfoot River (Headwaters to Nevada Upper Blackfoot 1313 30 Creek) Poorman Creek Upper Blackfoot 22 30 Beaver Creek Upper Blackfoot 11 -- Keep Cool Creek Upper Blackfoot 19 -- Lincoln Gulch Upper Blackfoot 11 -- Willow Creek Upper Blackfoot 18 30 Humbug Creek Upper Blackfoot 17 -- Arrastra Creek Upper Blackfoot 19 30 Nevada Creek (Upper) MidBkft-Nevada 3501 26 Washington Creek (Upper) MidBkft-Nevada 371 24 Jefferson Creek (Upper) MidBkft-Nevada 872 34 Buffalo Gulch MidBkft-Nevada 571 32 Ward Creek MidBkft-Nevada 156 31 The TMDL Reports list several other sources of sediment. Refer to the reports for additional information (Endicott & McMahon 1996; MT DEQ, 2004, 2008; US EPA, 2006)

The following table displays the number of road crossings along roads proposed for treatment, the total number of stream crossings, and the number of surveyed sediment delivery points in 15 6th HUC watersheds. Watersheds with streams listed as sediment-impaired on the 2006 Montana DEQ CWA 303(d) list are also noted.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 33 Table 3.3 Road Crossings and Sediment Sources Within- Watershed DEQ Sixth-HUC project- Sixth-HUC watershed name Sediment- watershed no. boundary Sediment Crossings impaired crossings sources 100301010102 Mike Day Creek 3 4 4 100301010103 Faulkner Creek 2 12 12 100301010104 Hay Creek 2 11 11 100301010902 Greyson Creek* 1 1 1 100301011303 Warm Springs Creek 1 4 21 X 100301011307 McClellan Creek 3 3 8 100301011308 Middle Prickly Pear Creek 0 0 0 X 100301011401 Upper Tenmile Creek 13 14 30 X 170102010501 Ontario Creek 13 16 15 170102010502 Little Blackfoot River-Larabee Gulch 5 5 7 X 170102010503 Telegraph Creek 18 23 25 X 170102010505 Upper Dog Creek 10 10 3 X 170102010507 Little Blackfoot River-Hat Creek 2 7 13 X 170102010601 North Trout Creek 7 7 1 170102010603 Little Blackfoot River-Elliston Creek 2 2 10 * this watershed is mislabeled “Boone Run” in the National Hydrography Dataset used in this analysis These data were not recently collected in other project area watersheds. Watersheds with streams listed as sediment-impaired on the 2006 Montana DEQ CWA 303(d) list are also noted.

Sediment from Other Sources Other sources of elevated sediment levels in forest streams include stream bank erosion, past and current mining, livestock grazing, timber harvest, and wildland or prescribed fires. Non-road sediment source information for several of the watersheds covered by the project is detailed in the TMDL documents listed in the Hydrology Specialists Report in the project record.

Water Quality: Non-Sediment Aside from sediment, other water quality impairments in project area streams might include elevated temperature, nutrients, and metals, as well as altered pH. Water-quality-limited segments (WQLS) in watersheds where roadside hazard-tree removal is proposed are listed in Appendix A of the hydrology report in the project record.

Water Yield Water yield response to forest vegetation conditions is highly dynamic and complex. Widespread tree mortality in many of the 6th-HUC watersheds where roadside treatments are proposed would likely result in measurable increases in water yield for at least the next several years. As discussed above, at least 20-30% of a watershed’s canopy must be removed (or die) before a statistically significant increase in stream flow could be observed. Additionally, effects are generally not observed in watershed where annual precipitation does not exceed 18-20 inches. Table 6 of the hydrology report in the project record lists watersheds with at least 20% observed mortality in 2008. Loss of trees by other means (e.g. green-tree timber harvest) is not included here, although such losses would contribute to any yield increase. There would be

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 34 continued tree mortality over time due to ongoing insect infestations (see Silviculture report for additional information), which would continue to affect water yield at the 6th-HUC-watershed scale.

Riparian/Wetland Area Conditions A comprehensive field assessment of riparian and wetland conditions in watersheds where project work is proposed was not done for this report. In 2009, HNF wetland crews identified several isolated (no surface connection to a stream channel throughout the year) wetlands in proposed treatment areas (details of this survey are in the wetlands report). While this survey was not comprehensive, HNF crews will identify and flag all wetlands adjacent to treatment areas prior to commencement of project activities. Field assessment of riparian areas has been done in the context of other management activities on several project watersheds, allowing some general conclusions on riparian conditions to be drawn. Within grazing allotments across the forest, riparian and wetland conditions are more likely to be impaired. Outside of grazing allotments, past and current mining, roads, and informal recreation use also impact riparian conditions at certain locations. Please see Appendix C, Design Criteria, Mitigation, and Best Management Practices.

3.4.2 Alternative 1 (No Action) Under Alternative 1, no new management actions are proposed. If no new actions are undertaken, no new management-related water resource impacts would occur. Past and ongoing management activities, such as road use, OHV use, mining, and livestock grazing would continue to affect water resources. No new additions to watershed-scale cumulative effects would be predicted, because no new management activities are proposed with Alternative 1. However, anticipated road maintenance in some drainages would reduce sediment delivery from roads where work is planned and effectively implemented. This road work would not be as extensive as under Alternative 2. An additional consequence of the no-action alternative would be that hazard trees are removed in a less-structured manner. Potential effects of this could include increased traffic, and increased trailing and other disturbance from firewood gatherers. 3.4.3 Alternative 2 (Proposed Action) Under Alternative 2, the removal and yarding of roadside trees using mechanized equipment would most likely temporarily expose mineral soil to erosion, and may create new (or exacerbate existing) vectors for sediment transport to stream channels. Project activities could expose sediment to overland flow in harvest areas, on skid trails and landings, at ditch crossings, and on haul-route roads.

Proper application of forestry BMPs (Logan, 2001) should minimize erosion from treatment areas (see Soils Report in this document). The application of SMZ and RHCA buffers would most likely prevent transport of eroded sediment from treatment areas or landings directly to streams across untreated forest floor (Ice et al. 2004; Montana DNRC, 2008). Sediment eroded from a treatment unit could, however, reach a stream channel via a road, given hydraulic connectivity and a runoff event of sufficient magnitude to generate flow along the road or in a ditch. The most important step in minimizing this potential impact would be the repair or installation of proper road drainage features on all project roads.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 35 Haul roads are the most likely source of sediment to project area streams, particularly where there are existing sediment delivery points. Increased heavy-truck traffic related to log hauling can increase rutting and displacement of road-bed material, creating conditions conducive to higher sediment delivery rates (Reid & Dunne, 1984). The number of haul trips per road has been estimated for this project, and is presented in the Fisheries report. Sediment delivery from most of these roads could be minimized through application of road maintenance and hauling BMPs. For example, well-designed and maintained road surface drainage, in conjunction with a properly graded road surface, should divert most road-surface runoff to undisturbed forest floor, where conditions allow for sediment deposition and infiltration (Burroughs & King, 1989; Foltz & Burroughs, 1990; Montana DNRC, 2008). At crossings and other areas where proper road drainage cannot prevent overland flow to a stream, gravel surfacing using high-quality aggregate will minimize sediment transport and delivery (Kochenderfer & Helvey, 1987; Burroughs & King, 1989; Sugden & Woods, 2007) Additionally, properly applied log-hauling BMPs should limit any increase in sediment delivery from roads.

Appendix C lists specific design criteria that would reduce sediment delivery to streams. The Fisheries report also lists site-specific measures for numerous road segments. For watersheds not covered in the Fisheries report table, site surveys (currently underway) would be critical in determining needed road improvements. This work would need to be done prior to road improvement work in order to determine site-specific measures. Several road segments were surveyed for sediment delivery points in 2008. These sites were modeled using the Roads module of the WEPP model (Elliot, 2000) in order to estimate potential reductions in sediment delivery resulting from project road improvements. Results indicate that at the sites evaluated, sediment delivery would decrease on an annual average basis by roughly 90% (Table 3.4). Results similar to these could reasonably be expected at other sediment delivery sites on project roads where road maintenance and improvement occurs. The model evaluated existing (native surface) conditions and gravel-surfaced conditions. The model did not account for planned drainage improvements in some locations, which would likely reduce sediment delivery at a similar rate to that of gravel surfacing. These results should be considered a best-case scenario of sediment reduction. Actual reductions in sediment delivery would depend on the effectiveness of road improvement implementation, use patterns, and specific weather events, and would likely be less dramatic. Additionally, while the proposed road BMP work would reduce sediment delivery from project roads during project activities and into the future, blading of native-surface roads temporarily exposes higher levels of sediment to erosion and transport (Sugden & Woods, 2007). Compaction of freshly bladed surfaces prior to rainfall, whether by a roller or by traffic, reduces this temporary road surface susceptibility to erosion.

It is unlikely that the proposed activities would lead to increased streambank erosion, as equipment would not operate in the SMZ or RHCA, and hand crews would not cut trees along stream banks unless they are determined to be hazard trees (e.g. leaning toward a road). Hand crew work within the SMZ is not likely to result in a level of ground disturbance that would lead to any soil erosion or sediment transport. Furthermore, livestock access to streams (within grazing allotments) is unlikely to change, as nearly all trees along stream banks would be left standing.

The proposed activities have the potential to influence stream temperatures by removing streamside trees. Although the shade provided by dead, defoliated trees is substantially less than that

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 36 provided by a living canopy, such trees still provide shade to adjacent streams, albeit a small fraction of that provided by a living tree (Amaranthus et al., 1989). However, understory vegetation (including small trees) is generally unaffected by insect mortality, and any non- hazard-tree vegetation that is providing shade to a stream would not be removed under the proposed action. Furthermore, the total length of any stream around which hazard trees could be removed would be relatively small. The effect of these short segments of canopy reduction would most likely be negligible (e.g. Johnson, 2004).

The proposed work would not significantly impact the hydrologic function of riparian areas in that no mechanical equipment would operate in riparian areas or wetlands, and hand-felling in the SMZ and isolated wetlands would be minimized.

Irreversible/irretrievable Commitments An irretrievable commitment represents a temporary loss of a resource, which can be replaced over time. An irreversible commitment represents a total loss of a resource, which cannot be replaced. Any sediment delivery to streams resulting from implementation of this project would be an irretrievable commitment, in that the stream would recover from the influx of additional sediment over a period of years to decades. However, if all appropriate harvest and road BMPs are carefully and consistently applied, it is unlikely that any irretrievable commitments would result from project implementation (Montana DNRC, 2008).

Cumulative Effects The analysis area for direct and indirect effects, and cumulative effects to riparian conditions, is defined by 6th-HUC watersheds which contain roads proposed for tree-removal. In addition to the impacts of sediment delivery from roads and road impacts on riparian area and stream form and function, several past and present federal and non-federal activities have affected and continue to affect water quality, water yield, and riparian health and vigor in the cumulative effects analysis area. Past timber harvest has likely caused temporary increases in water yield and sediment delivery in the past, though these effects generally attenuate over time. In the past, mining has contributed metals and sediment to stream channels in the watersheds. In some cases, ongoing mining activity continues to be a chronic source of sediment to streams and of riparian degradation. Old mine workings can also pose chronic or episodic water quality problems to forest streams, as in the Tramway Creek (Little Blackfoot) adit-plug failure of November 2008. Past pulses of elevated sediment (e.g. from timber harvest or mining) can remain in stream channels (banks and bed) for many years following deposition. Continued grazing in riparian areas and cattle trailing along streams within grazing allotments would likely continue to contribute elevated sediment levels to streams in the watershed. In the absence of other reductions to sediment delivery in the watershed, streams in several of the watersheds where treatment is planned would continue to receive elevated levels of sediment. WEPP-Road model results of current and projected average annual sediment delivery to stream channels based on surveyed conditions in 2008 and predicted conditions following recently completed or planned road improvements show a reduction of 89 percent.

In the watersheds where roadside tree removal is proposed, water yield most likely has been and would continue to be affected by large-scale tree mortality. As discussed above, large-scale loss of live trees reduces the volume of water removed from a watershed by transpiration. Increases

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 37 in water yield could result in higher peak flows, which have the potential to increase stream bank and bed scour. The proposed action would not contribute to this process as the vast majority of trees to be removed are already dead.

Extensive tree mortality would also affect stream temperature in streams that cross the affected stands. However, understory vegetation, generally unaffected by insect mortality, would continue to provide shade. Furthermore, understory and riparian vegetation exposed to increased levels of sunlight (due to overstory mortality or tree removal) can expand and provide additional shade (Gravelle & Link, 2007). While an increase in incoming short-wave (solar) radiation is generally considered to be the dominant driver of stream temperature increase, numerous factors influence the extent to which a stream exposed to additional direct sunlight would have an increase in water temperature (Johnson, 2004). Thus, the extent of water temperature changes resulting from overstory mortality is difficult to predict. In any case, the likelihood that the proposed action would meaningfully contribute to any stream temperature increase is small, given the relatively short stream segments along which treatment would occur, and given the minimal removal of vegetation in SMZs.

Reasonably foreseeable federal and non-federal activities that could affect water quality, water yield, and riparian health and vigor in the cumulative effects analysis area include future timber harvest, small-scale mining or failure of old mines, continued livestock impacts, roads, and fire. Foreseeable timber harvest activities in the analysis area on the National Forest are not likely to substantially affect water quality or riparian-area viability, assuming compliance with the SMZ law and strict adherence to forestry BMPs (Montana DNRC, 2008). The impacts of roads on water quality, as outlined in the “Affected Environment” section of this report, would be incrementally reduced due to the road maintenance and improvements planned as part of or in conjunction with the proposed action. Other activities that would serve to reduce sediment delivery to streams in project watersheds would likely be implemented periodically in the future within the cumulative effects analysis area. Such activities include watershed improvement projects, culvert upgrades, and effectively implemented allotment management plan (AMP) revisions, among others.

3.4.4 Conclusions Alternative 1 (No Action) Currently, full attainment of all beneficial uses in streams is not being met in several of the 6th- HUC watersheds within which hazard-tree removal is proposed (see Appendix A of hydrology report). In most of these impaired streams, beneficial uses are compromised due at least in part to land use activities off of the Helena National Forest. Under the no-action alternative, full attainment of all beneficial uses would still not be met in these watersheds. Existing activities (e.g. forest roads) on the HNF portions of these watersheds might in some cases not meet the state requirement that “all reasonable land, soil and water conservation practices have been applied” (ARM 17.30.602) to minimize pollution, although effects of forest roads and other management practices in place before April 1993 are exempt from this standard (MCA 75-5- 317).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 38 Alternative 2 (Proposed Action) Proposed activities in this alternative are predicted to reduce net sediment delivery to streams from HNF management activities (e.g. roads, timber harvest). This is based on the assumption that sediment delivery from HNF system roads would be reduced wherever treatment or hauling is planned at sediment-delivery points (due to rigorous use of road BMPs), and that erosion from treatment areas is likely to be minimal with strict adherence to timber harvest BMPs—see the Soils specialist report for additional information on erosion control in harvest units. The assumption that road improvements would reduce sediment delivery is reinforced by before-and- after sediment modeling on some project-area roads (see table below). It is likely that similar results would be attainable at other sediment-delivery sites on other project roads, although roads that are currently in good condition would likely not show sediment delivery reductions similar to the modeled segments. A critical step in treating these sites would be pre-work surveys of roads not surveyed in 2008 that are proposed for tree-removal or hauling, and follow-through with road improvement work prior to tree removal. Surveys were initiated in May 2009 by HNF Engineering staff. Roads should also be brought back up to standard following use, where required.

The most recent Montana DNRC Forestry BMP Audit Report determined that “conclusions drawn from audit results over the past 18 years are very straightforward and consistent; when BMPs are applied correctly, they very effectively protect soil and water resources” (Ziesak, 2008, p 31). Published research has generally confirmed the effectiveness of various BMP practices in reducing erosion and sediment delivery, including gravel surfacing (Swift, 1984; Kochenderfer & Helvey, 1987, Foltz, 1996) and appropriate spacing of drainage features. Although elimination of ruts (blading) reduces sediment transport on roads (Foltz & Burroughs, 1990; Toman & Skaugset, 2007), surface reconditioning can temporarily increase the amount of loose surface sediment which is more easily entrained by overland flow (Ziegler et al., 2001; Sugden & Woods, 2007). Furthermore, reductions in road surface erosion and sediment delivery due to road maintenance last only as long as the road surface and drainage features are maintained.

Rigorous application of existing road maintenance, hauling, and timber harvest BMPs would likely meet the state requirement that “all reasonable land, soil and water conservation practices have been applied” (ARM 17.30.602) to minimize pollution in the watersheds covered by the proposed action. However, monitoring of BMPs during and after project work is critical in determining whether applied measures are effective in minimizing sediment delivery to streams. Where BMPs are shown to be inadequate in protecting water quality, BMPs must be modified or project activities must be discontinued. In compliance with the HNF Forest Plan, a subset of project area roads would be monitored by HNF hydrology staff during operations to evaluate BMP effectiveness. Forest Plan standards related to water quality and riparian conditions would be met under this alternative if, as planned, BMP’s and mitigation measures stipulated in the EA and various specialists reports are properly applied, and work is stopped if designated beneficial uses are threatened by project activities.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 39 3.5 Effects to Fisheries 3.5.1 Affected Environment Fish populations and fish habitat conditions west of the continental divide have been evaluated as part of the Watershed Baseline Condition for the Blackfoot River Section 7 Watershed (USDA 2000a) and the Little Blackfoot River portion of the Upper Clark Fork River Section 7 Watershed (USDA 2000b). With the ongoing updates to that information by 6th code HU and additional field work completed by the Forest Service and other agencies, there is substantial information available.

Detailed watershed baselines for the Upper Missouri River or the Smith River 4th code HUs are in draft stages and have not been completed. However, there is a wealth of information available to be drawn upon. This information is detailed in the fisheries report in the project file.

Key components of the analysis area pertinent to fisheries are the roads and adjacent corridors along the roads where hazard trees are to be removed. Of the roads proposed for treatment under alternative 2, the miles of road posing high, moderate and low risk of sediment delivery to streams (as defined in the watershed portions of the Forest Roads Analysis USDA 2004) are displayed by 6th code hydrologic unit in the hydrology report.

Another component of the analysis area important in relation to risk of sediment delivery to surface waters is how areas adjacent to roads where ground disturbance would occur are located in relation to riparian habitats, ephemeral, intermittent, and perennial stream crossings. Approximately 1,375 acres proposed for treatment are within 150 feet of perennial streams.

Fish Populations Salmonid fishes are the predominant species present on lands in the project area. They include westslope cutthroat trout, bull trout, brown trout, brook trout, rainbow trout, and mountain whitefish. Other fish species present include, but are not limited to various species of suckers, and sculpins. Additional information on bull and westslope cutthroat trout is included in the Threatened, Endangered and Sensitive Fish Species Section. The fisheries report in the project record has more detailed information.

Threatened, Endangered and Sensitive Fishes Bull Trout: The distribution of bull trout is limited to drainages west of the continental divide on the Helena National Forest with the strongest populations being present in the Blackfoot River drainage. Bull trout are present in extremely low numbers within the Little Blackfoot River drainage. The specific streams currently known to support bull trout within the HUCs have been mapped and that information is available in Helena Forest Fishery Files.

Under the Inland Native Fish Strategy or INFISH (USDA 1995) priority drainages for bull trout were established. On the Helena Forest priority drainages include Copper Creek and Landers Fork in the Blackfoot drainage and the Little Blackfoot River drainage upstream of the Dog Creek confluence in the Upper Clark Fork. Besides the priority drainages a secondary tier of bull trout “Special Emphasis Watersheds” were established as an additional means of identifying a refugia network of streams to assist in the protection and recovery of bull trout and identified

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 40 under additional agency commitments in the 1998 Biological Opinion (USDI 1998 page 24). On the Helena Forest special emphasis watersheds include Arrastra Creek, Beaver Creek, Moose Creek, Willow Creek, Poorman Creek, Hogum Creek, Alice Creek, and upper Nevada Creek in the Blackfoot drainage. In the Little Blackfoot drainage Dog Creek was added as a Special Emphasis Watershed.

Critical habitat for bull trout has been designated and includes the non-federal portions of the main stem Blackfoot River, Landers Fork and Copper Creek within the Blackfoot River drainage. In the Little Blackfoot River drainage bull trout critical habitat includes non-federal reaches of the main stem Little Blackfoot River. As agreed to by the Montana Bull Trout Level 1 Team, the condition of critical habitat for bull trout is described using the Section 7 Bull Trout Watershed Baselines and an agreed to “Crosswalk” procedure. The Crosswalk approach is outlined in detail in Appendix B of the fisheries report in the project file. For this project use of the Crosswalk and the existing watershed baseline for the Blackfoot (USDA 2000a) and the Little Blackfoot portion of the Upper Clark Fork (USDA 2000b) and updates to those baselines are the means used to establish the existing condition of bull trout critical habitat.

A Draft Bull Trout Recovery Plan was completed in 2005 (USDI 2005), but has not yet been finalized. Under the Draft Recovery Plan bull trout within various drainages are organized by Core populations and local populations within those core populations. The status of those core and local populations is addressed below to give perspective of how bull trout on the Helena Forest fit within the broader context. The information on the core populations below is based on knowledge from local biologists, the Forest Service, and Montana Fish, Wildlife, and Parks.

Blackfoot Core Bull Trout Population Bull Trout in the Blackfoot River are included as a core population in the Draft Bull Trout Recovery Plan. There are several local populations identified within the Blackfoot Core Bull Trout Population; including the North Fork of the Blackfoot River, Monture Creek, Landers Fork/Copper Creek, Cottonwood Creek, Belmont Creek, and Gold Creeks. The only local population of bull trout in the Blackfoot drainage located within the current project area of the Helena Forest is the Landers /Copper Local population; the other Local Bull Trout Populations are all located downstream of the Helena Forest. More information on the core population continues below. Based on redd counts and limited electrofishing efforts it is likely that there are somewhere between 400 to 500 adult bull trout between the five local populations. Additional adult bull trout are found in numerous other streams throughout the core population area in some of the Special Emphais Watersheds discussed earlier and some in undesignated streams. The overall numbers of bull trout adults included in all of the streams throughout the Blackfoot drainage are probably less than 800 when combined with the adults in the local populations. Recent redd surveys suggest that the four Local Populations below the project area are declining somewhat while the Copper/Landers population is improving. There is good connectivity within the Blackfoot River which allows for several age classes of the bull trout local populations to mingle in the main-stem river. Additionally, adults and sub-adult bull trout from other miscellaneous streams in the Blackfoot drainage likely mix in to some degree as well in the main stem Blackfoot River.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 41 There is likely competition with brown trout and predation by brown trout on bull trout in the main stem Blackfoot River. The competitive edge may be moving in favor of brown trout as temperatures in the main stem Blackfoot have been rising based on information collected by the Montana Department of fish Wildlife and Parks over the last 20 years. Some brook trout are present in some of the local populations so there is some additional threat of decreased bull trout production due to hybridization.

Westslope Cutthroat Trout Westslope cutthroat trout (WCT) are designated a sensitive fish species by the Forest Service and are included as a management indicator species in the Helena Forest Plan. On the Helena National Forest, westslope cutthroat trout are found within this project area in the Blackfoot River, Little Blackfoot River portion of the Upper Clark Fork, Upper Missouri River, and Smith River 4th code hydrologic units. Sixth code HUs supporting WCT including conservation populations of WCT east of the continental divide are identified in Table 2 of the fisheries report located in the project record. Additional information on WCT such as the specific extent of upstream distribution on individual streams within each 6th code hydrologic unit is detailed on 4th code hydrologic unit maps available through the Helena Forest Supervisors Office Fishery Files. WCT distribution is also available through the Montana Department of Fish, Wildlife, and Parks.

WCT Conservation populations are considered to be populations in Montana for which it is important to maintain population viability in order to reduce the risk the species would need to be listed under the Endangered Species Act (ESA). Currently, the potential for loss of viability for a number of WCT conservation populations within the project area is considered high. The conservation populations that may be affected by the project where viability is at risk include: Clancy Creek, Kady Gulch, Magpie Creek, Foolhen Creek, McClellan Creek, Skelly Gulch, Silver Creek, Rooster Bill Creek, Page Gulch, Stemple Creek, Thompson Gulch, Camas Creek, and Spring Gulch. All of the above mentioned populations are located east of the continental divide with the exception of Spring Gulch. Most of these populations are at risk for loss of viability due to a variety of factors including presence of nonnative fishes, limited distribution and isolated nature of the populations, and degraded habitat conditions. More detail regarding risk for these individual WCT populations will be addressed in the Biological Evaluation.

Fish Habitat The impact of sedimentation on fish habitat, specifically spawning and rearing habitat, is a main focus of this analysis. Other aspects of fish habitat for streams within the project area are available in various reports in Helena Forest Fishery Files as well as reports and information from other agencies, but are not discussed in detail in this report as the hazard tree removal project would not affect them measurably if implemented using the proposed design criteria. The existing condition of Critical Habitat for bull trout is addressed as part of the detailed information being available via the Watershed baselines (USDA 2000a and USDA 2000b) and updates to those baselines.

Existing fisheries habitat conditions throughout areas west of the continental divide within the analysis area have been described in the following documents: The Watershed Baseline Condition for the Blackfoot River Section 7 Watershed (USDA 2000a) and the Watershed Baseline Condition of the Little Blackfoot River portion of the Upper Clark Fork Section 7

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 42 Watershed (USDA 2000b) and updates to those baselines. As discussed in the Information Used portion of the fisheries report, the habitat components in the baselines and updates to those baselines are assumed to depict the effects of past and ongoing activities. Information on various aspects of fish habitat for streams throughout the entire project area is available within Helena Forest fishery files as well as reports and files from other agencies. Importantly, as pointed out in the assumptions portion of the fisheries report, the habitat element related to fisheries that can be affected by proposed activities in this hazard tree project is sediment. Consequently, only sediment habitat related information is displayed in detail within this document.

It is commonly accepted among fishery professionals that elevated sediment levels in stream substrates can have negative effects to salmonid fishes (Bjornn and Reiser 1991 pgs 97-103, Furniss et al. 1991pgs 302-303, Suttle et al 2004, Waters 1995 pages 79-109). The percentage emergence of salmonid fishes from redds can be substantially reduced when sediment levels (less than 6.35 mm) exceed 30% (Bjornn and Reiser 1991 graph on page 99). Small increases in sediment levels within spawning gravels can result in substantial reductions in egg survival and fry emergence from stream substrates. Consequently, with the most likely means by which fish can be affected via this proposal being changes in sediment delivery to streams, risk for sediment delivery to streams is used as an overall means to estimate risk for effects to fisheries for this project.

The level of sediment less than ¼ inch in diameter present in stream gravels for sampled streams in each 6th code HU is depicted in Table 3 of the fisheries report. Sediment levels less than 6.4 mm diameter within spawning gravels of numerous streams within many of the various 6th code HUs are already substantially over 30%. Levels of fine sediment in spawning gravels approaching 40% greatly reduce salmonid egg survival and emergence.

The potential for affecting fisheries from project related activities is primarily a function of sediment delivery to streams which in turn can affect conditions in stream substrates that provide spawning and rearing habitat for salmonid fishes (Waters 1995 pages 86-109). Additionally, elevated sediment levels in stream substrates can negatively influence aquatic invertebrate production used as a food source for fish (Waters 1995 pages 76-77 and Suttle 2004). Importantly, with this project having activities focused on the area within 100 feet either side of existing roads, it is important to note that some roads and the associated road drainage features can be primary conduits for the delivery of sediment to surface waters. Furniss, et al. (1991) pgs 297-303 points out forest roads can cause serious degradation of salmonid habitats in a variety of ways. Furniss, et al. (1991) pgs 311-312 also discuss the importance of regular maintenance on existing roads as a key element in keeping sediment delivery low, but they also recognize that the maintenance activities themselves can result in increased sediment delivery. Specifically in regard to bull trout, the Biological Assessment addressing lands in Washington, Oregon, Idaho and Montana (USDA/USDI 1998 pages 38,39, 40, 47, and 49) documents that roads are a key factor on the landscape that have negative impacts to bull trout habitat. Key aspects of roads affecting fish habitat in relation to this proposed project include undersized culverts which can washout during flood events and risk of sediment delivery from the road prism, ditches, fill and cut-slopes. Furniss et al. pgs 297-312 (1991) point out that stream crossings pose the greatest threat to fishery streams when they can be plugged by debris or overtopped by high flows with subsequent severe sedimentation.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 43 The overall effects to fisheries is qualitatively assessed and summarized by 6th code hydrologic unit with the assumption that the project would meet design criteria as well as the assumptions detailed within in this report.

3.5.2 Effects Common to All Alternatives Effects common to both alternatives are related to cumulative effects. Cumulative effects would be similar for both alternatives. There would be continued sediment delivery to streams associated with the existing road system, maintenance of the road system, and use of the road system- although some differences in magnitude of effect between alternatives may come about as a function of road maintenance activities completed and certainly due to the level of use for some roads. Past and foreseeable travel planning decisions have and will be addressing direct and indirect effects of the road system to fish and fish habitat. There would be similar increases in water temperatures for some streams due to increased solar radiation in both alternatives due to tree mortality and associated loss of needles. Fish habitat associated with streambank structure would likely be negatively affected due to increased water yield at some locations in some drainages where high tree mortality has occurred or would occur over in the next several years due to insects. On the other hand the increase in water yield may also flush some sediment from stream spawning gravels in some drainages. There would be continued risk of undersized culvert failures due to washouts in the future. In some streams there is likely to be some new side channel development over time as dead trees fall within the floodplain. The new side channels in streams can result in improved rearing habitat for various life stages of salmonids, but can also result in some sediment movement and deposition. Additionally, the increases in solar radiation due the decrease in shading associated with streamside tree mortality can stimulate shrub production on some stream reaches which can increase the diversity of habitat provided and possibly encourage re-establishment by beaver. There would likely be some losses of trees within streamside areas that help form instream pool habitat and shading due to the difficulty in firewood cutting enforcement over the large landscape. Cumulative effects associated with ongoing domestic livestock grazing would continue on some stream reaches.

Fish Population Viability Because there is risk for some continued negative effects to fisheries from sediment delivery at times for some streams in various 6th code hydrologic units due to a variety of effects, both the no action alternative and the proposed action pose a continuation of the pre-existing threat for adverse effects on bull trout and westslope cutthroat trout in some of the 6th code hydrologic units for reasons outlined earlier in the existing condition and later in the direct, indirect and cumulative effects sections of this report. Viability of some isolated resident westslope cutthroat trout populations within portions of the Little Blackfoot River drainage and in the Upper Missouri drainage are at risk in some streams currently, but that increased risk for loss of viability is currently due to other past and ongoing cumulative effects in combination with the presence of non-native fishes. The same can be said for the bull trout population in the Little Blackfoot River.

With the increased emphasis for control of sediment on important bull and westslope cutthroat trout streams associated with Alternative 2, there should be no change in risk for maintaining viability for any resident WCT or bull trout local population associated with either alternative.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 44 3.5.3 Alternative 1 (No Action) The direct and indirect effects are described in Effects Common to All Alternatives.

Irreversible/Irretrievable Commitments There are no irreversible or irretrievable fishery related commitments associated with either alternative.

Cumulative Effects With the no action alternative fish habitat conditions would continue as portrayed under existing conditions. There would be continued risk for negative effects to fisheries in various drainages associated with sediment delivery to streams due to: already elevated sediment levels in some streams, the existing location and condition of roads, lack of maintenance on many roads, and ongoing commercial, recreational and administrative traffic on various roads.

There would be some road improvements/maintenance planned as part of the regular forest program which would help decrease long term sediment delivery to streams for some roads. However, the amount of road maintenance/improvement is projected to be less than what would occur under Alternative 2; at least in the short term (one to three years).

Several other cumulative effects are the same as for Alternative 2 and are addressed in the Effects Common to all Alternatives section.

3.5.4 Alternative 2 (Proposed Action) With some increased level of road maintenance/improvement planned there is some risk for more short term delivery of sediment to streams due to ground disturbance associated with the maintenance activity itself as pointed out in the programmatic biological assessments completed by the Western Montana Bull Trout level 1 Team (USDA 1999) However, risk for sediment delivery from the elevated levels of use of the road by heavy truck traffic over the following 2-5 years would be less than what it would be without the maintenance. On some of the roads to be used more heavily for log hauling it is difficult to conclude sediment delivery to streams would actually be less than current levels unless spot surfacing at road stream crossing intersections is provided for- see Table 1 in the Design Criteria Section of the Fisheries report in the project file. If spot surfacing of approaches to stream crossings is not accomplished it is critically important that log hauling be limited to periods when the road surface is dry (see specific measures outlined in the various 6th code hydrologic units in Table 1 of the fisheries report). However on other roads risk for negative effects from sediment delivery to streams may be lower in this alternative as compared to Alternative 1 when road blading and cross drain cleaning/improvement alone is all that is needed to reduce sediment delivery from current levels. The miles of roads having high, moderate, or low risk for sediment delivery that would sustain some level of hazard tree removal are displayed by 6th code HUC in Appendix A of the fisheries report. The approximate number of log truck loads generated from the hazard tree removal in the various 6th code HUs is displayed in Table 4 of the fisheries report. The number of log truck loads to pass over the various roads cannot be determined with precision as there are alternative routes that can be used in some cases.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 45 Details regarding the blading, cross drain improvement, and surfacing aspects of road maintenance to be completed on the various roads is included in the engineering portion of the project file. Specific recommendations, additional design features, or limitations on road use important to ensure that risk for sediment delivery is minimized on important fishery drainages for the project is detailed in the Design Criteria, Appendix C of the EA.

Another means by which sediment delivery to streams can occur would be associated with the ground disturbance and activity in the immediate vicinity of the road and its associated drainage ditches. Approximately 312 miles of road segments rated as high risk for sediment delivery would sustain some ground disturbance adjacent to the road. With skid trails likely intersecting existing roads, it would be difficult to avoid some level of sediment delivery to road drainage ditches. A key factor to reduce risk of sediment delivery to streams would be to ensure the existing cross drainage features of road systems are functioning such that sediment is diverted to the forest floor rather than to ephemeral, intermittent, or perennial stream channels. Additional cross drainage features are necessary for some roads in some instances to minimize risk of sediment delivery to important fishery streams. Another means of reducing ground disturbance is by operating equipment over frozen or snow-covered ground. However, winter operations pose additional risk of sediment delivery associated with log hauling and snowplowing of roads as discussed for the Snow Talon Salvage Project on the Helena Forest (Walch 2004 and 2005). Consequently snowplowing and winter use would not occur within some drainages.

The increases in road maintenance proposed as part of Alternative 2 generally entails blading to restore the road prism, cleaning of cross drainage features, brushing and clearing of drainage ditches, and some installation of additional cross drainage features such as rolling dips. To avoid adverse effects to fish habitat associated with increases in sediment delivery at some stream crossings associated with hauling, some gravel surfacing would be necessary on the approaches to some stream crossings on some roads or restrictions on log hauling would need to be implemented, or sometimes both (see Design Criteria). With the improved maintenance, gravel surfacing, restrictions on log hauling, and other design criteria for this project, there may be some reduction in sediment delivery to streams from current levels for at least the short term (1-3 years) for some of the roads. However, that conclusion is difficult to maintain with certainty due to some sediment delivery that can occur solely as a function of the maintenance activities as discussed in the Programmatic Biological Assessment for Road maintenance Activities (USDA 1999).

Along with road generated sediment from vehicle use there is risk for sediment delivery to streams and subsequent effects to fish habitat in some locations due sediment delivery from ground disturbance associated with tree removal in the immediate area around the road such as drainage ditches. As pointed out in the introduction section and other parts of this report there is hazardous tree treatment within a short distance of ephemeral and perennial stream channels. In the assumption section of this report it is stated that BMPS and administration would be 90% successful in preventing sediment delivery, consequently it is likely that there would be some sediment delivery to streams in some locations. There is less likelihood for sediment delivery to ephemeral channels west of the divide as compared to east due to the mandatory buffers required by INFISH (USDA 1995).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 46 Use of forest roads for hauling of hazard trees would result in some continued risk for sediment delivery on some streams and thereby continue to have negative effects on fish and fish habitat on specific streams within some 6th code HUs. Adverse effects to fish resulting from roads and use of roads, including the listed bull trout and sensitive westslope cutthroat trout, are ongoing and have been occurring for decades and are projected to continue in some drainages, during some years, at specific locations. These negative effects may be reduced somewhat temporarily or would remain unchanged from what is currently occurring depending on the effectiveness of road maintenance/improvements completed as part of this project, maintenance of those improvements over time, and implementation of other design criteria. The risk for sediment delivery is summarized by 6th code HUC in Table 4 of the fisheries report in the project file.

An extensive discussion of risk associated with winter use of roads by wheeled vehicles is contained in the fisheries biological assessment (Walch 2004) that was completed for the Helena Forest’s Snow Talon Timber Salvage project and a supplemental memo to that assessment (Walch 2005). Importantly, in relation to this project, monitoring by fisheries personnel on the Snow Talon Salvage Sale suggested that intensive BMP implementation, good sale administration, and favorable weather prevented adverse effects to fish habitat from occurring.

Effects to Trout and Westslope Cutthroat Trout Direct and Indirect Effects to the listed bull trout and the sensitive westslope cutthroat trout vary somewhat by 6th code HU, but are summarized for the entire project area for each alternative in the table below. There would be continuation of existing ongoing negative effects to bull trout Habitat in the Blackfoot River and the Little Blackfoot River portion of the Upper Clark Fork drainage with alternative 2. However, the effects may be somewhat less in some locations than what is occurring currently; especially for streams in the Little Blackfoot drainage where various levels of road improvements not related to this project would occur.

Irreversible/Irretrievable Commitments There are no irreversible or irretrievable fishery related commitments associated with either alternative.

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. The analysis area for cumulative effects includes the various 6th code hydrologic units in the Blackfoot, Little Blackfoot River portion of the Upper Clark Fork, Upper Missouri, and Smith River 4th code hydrologic units on HNF lands. Additionally, the cumulative effects analysis includes non-federal reaches of the main stem Blackfoot River from its headwaters downstream to the confluence of Nevada Creek, nonfederal reaches of all the HUCs in the Little Blackfoot drainage downstream to where Spotted Dog Creek enters the Little Blackfoot River, nonfederal reaches of the Upper Missouri 4th code downstream to Holter Dam, and nonfederal reaches of the Smith River downstream from the Birch Creek drainage to and including the French Creek drainage. Appendix C of the fisheries report has more information on cumulative effects.

The cumulative effects of past and ongoing activities to fish habitat for drainages west of the continental divide are reflected in the various 6th code HUC evaluations in the Blackfoot Watershed Baseline (USDA 2000a) and the Little Blackfoot portion of the Upper Clark Fork

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 47 Watershed Baseline (USDA 2000b). Pertinent to this project is the sediment habitat indicator in those baselines as this project has potential to affect sediment delivery to streams in a continuing fashion. This approach meets the guidance outlined in the Council on Environmental Quality Memo of 6//24/2005 (page 1). Consequently sediment is the habitat factor focused on as sediment has a continuing and additive effect in relation to effects to fish. Generally speaking, the sediment portion of fish habitat in many of the 6th code HUCs within the cumulative effects project area is already at a level where fish egg and fry survival is negatively affected.

There are some ongoing federal activities that have continued adverse effects on bull trout. The activities include several grazing allotments in the Little Blackfoot River drainage. Ongoing livestock grazing is also having negative effects on WCT and other fish species in several locations throughout the project area on the Forest. A few examples include, Spring Gulch, Blossburg, Ophir/Hope, Clark Canyon, Drumlummon, Gurnett, Tarhead, Deep Creek, Grassy Mountain, and Avalanche Allotments. Road conditions and maintenance of roads also results in ongoing negative cumulative effects to fish habitat in some locations.

East of the continental divide cumulative effects from past and ongoing activities, pertinent to risk for effect from this hazard tree project, are reflected for various streams in terms of sediment levels present. The sediment level present in the various streams is reflective of all the past and ongoing activities that have occurred in the various drainages. Numerous streams have sediment levels in stream gravels that provide far less than optimum spawning and rearing habitat conditions for salmonid fishes. The activities within the forest are summarized for the cumulative effects project area in Appendix F- Cumulative Effects Summary table.

Some activities have potential to exacerbate spawning gravel sediment levels in streams that already have sediment levels in excess of 35%. For each of the activities a qualitative assessment of effects to fisheries is included. More discussion is included below in regard to overall effect to fish habitat from federal and non-federal activities.

On non-federal lands the types of activities that could result in cumulative effects in the future include, but are not limited to, firewood cutting in streamside zones, new proposals for: salvage timber harvest, green tree timber harvest, log hauling on roads, placer and hard-rock mining, minerals exploration, oil and gas exploration/development, highway construction, highway/road maintenance, highway sanding, snowplowing, construction or maintenance of power transmission and other utility corridors, maintenance of irrigation diversions, vegetative clearing in riparian areas, maintenance of existing communication lines, property subdivison, crop production, herbicide application for weed control, insecticide application to control insects, road and highway maintenance, and fish habitat improvement work.

Although a number of the non-federal activities described above might not be considered reasonably foreseeable in the project area as we do not currently know of specific proposals, it is important to recognize qualitatively that a number of the activities would certainly occur at some point in the not too distant future at some locations within portions of the fisheries cumulative effects analysis area.

It is anticipated that a variety of new activities, of the types discussed above, would occur in the future on federal and non-federal lands with effects on fish ranging from no effect, minor

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 48 negative effects, adverse effects, or beneficial effects depending on the type of activity, magnitude of the activity, where and when the activity is occurring. Many laws and regulations are in place to help reduce the potential for negative effects from activities conducted by all parties and it is likely that many of the activities would result in no effect or only minor negative short-term effects. Additionally, there is voluntary guidance as well best management practices for various activities. However, various activities that may occur in the future on both federal and non-federal lands certainly have potential add to existing past and ongoing effects (ie the current condition described in the watershed baseline for drainages included in the cumulative effects analysis area. This could result in some long-term negative effects or possibly beneficial effects to fish habitat in localized situations depending on the specifics of the project.

Regarding the overall risk for future negative and positive effects that likely would be occurring at some point in the not too distant future from all non-federal lands and federal lands throughout the cumulative effects analysis area, in relation to the discussions above, it is concluded that: there is risk for continued levels of ongoing negative cumulative effects to fisheries in many locations. This conclusion, although somewhat speculative seems justified given that sediment has degraded salmonid spawning gravels to varying degrees in numerous streams in various 6th code hydrologic units and there are a number of ongoing activities on both federal and nonfederal lands that would further degrade fish habitat over time unless very intensive efforts are undertaken to reduce sediment delivery in some locations throughout the cumulative effects analysis area.

An exception to the above conclusion is that there is more probability for net positive cumulative effects in numerous portions of the Blackfoot River portion of the project area due to the well developed watershed group and intense interest in the fishery throughout the Blackfoot River basin. Numerous improvement and mitigation efforts have been completed; many of which are on non-federal lands. Some fishery improvement projects are ongoing, and numerous watershed fishery improvement efforts are planned based on a prioritization completed for the entire Blackfoot Drainage through the partnership efforts of many agencies, organizations, and individuals.

3.5.5 Conclusions Table 3.4 Effects to Bull Trout, Bull Trout Critical Habitat, and WCT Alternative Effects to Bull trout Effects to Bull trout Effects to Westslope Critical Habitat cutthroat trout Alternative 1 No Effect; no additional effect over No effect; no additional No Impact; no additional effect (No Action) current conditions, but continued ongoing effect over current, but over current levels, but negative effect from current baseline continued negative effect continued negative effect in conditions in various 6th code hydrologic from current baseline some locations. units conditions May Affect Not Likely to Adversely Affect May Affect Not Likely to May Impact Individuals, but will th Alternative 2 Bull trout in all 6 code hydrologic units Adversely Affect Bull trout not result in loss of population (Proposed with implementation of road upgrades, Critical Habitat with viability or result in a trend Action) other design mitigation features, and/or implementation of road toward listing under the restrictions on road use. upgrades and other design Endangered Species Act features Note: effects vary by individual 6th code HU as shown earlier. A stand alone biological assessment and biological evaluation for bull trout and westslope cutthroat trout is included in the project file, The BA and Be provide more extensive discussion on rationale pertaining to the call for bull trout and westslope cutthroat trout.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 49 Under Alternative 1, no hazard trees would be removed. Road improvements/maintenance would continue as part of the ongoing forest program, but the magnitude of road maintenance completed would be substantially less as compared to what would likely occur with Alternative 2. Some of the regular program road work/maintenance would occur in areas important to fish and consequently would move the forest forward in meeting forest plan guidance regarding reducing the effects of roads on fish and fish habitat. Firewood cutting enforcement would continue to be challenging in some locations which would likely have continued negative effects on fish in localized situations.

Under Alternative 1, ongoing negative effects to fish would continue due to elevated sediment levels in some streams along with continuation of sediment delivery from roads and other sources related to cumulative effects (elevated sediment levels in stream substrates). Overall effects for bull trout and WCT are summarized below in the table above.

Cumulative effects, both positive and negative, would accrue in some drainages as beetle killed salvage and travel management decisions are implemented. Cumulative negative and positive effects to fisheries from activities not related to sediment or this project would also continue.

Alternative 1 does not fully meet Forest Plan standards as related to fisheries, but actions from ongoing road maintenance activities and upcoming travel planning would continue to move the Forest slowly in the direction of meeting some of the Forest Plan standards related to roads. For more Forest Plan consistency information, please see Appendix D of the Fisheries Report in the project record.

Under Alternative 2, because of where hazard trees are located, numerous roads that are important to fisheries would be used to remove hazard trees. Some road improvements, not related to this project, would occur in various drainages. Although, these improvements would not likely entail upgrades of fish passage culverts or relocation of poorly located roads, the improvements would likely reduce sediment delivery from current levels for some of the roads. However, some of the reduction in sediment may be negated due to the increased use in the road due to log hauling; primarily on roads where it is the road location that makes it very difficult to control sediment delivery. An unknown factor is whether the improvements that are completed would be maintained adequately in the future. Even so it is likely the risk for adverse effects related to sediment delivery to streams occupied by bull and westslope cutthroat trout would be reduced somewhat for some of the roads while the improvements are functional. Maintenance of any road improvements is critical to ensure continued functioning of the upgrades to reduce sediment delivery. Additionally, for roads where little or no maintenance or road upgrades are undertaken, there would be continued negative effects to fish and fish habitat; especially in streams where sediment levels are already somewhat elevated. Enforcement of firewood cutting regulations would continue to be challenging in some locations and the violations that occur would likely have continued negative effects on fish in localized situations. Overall effects for bull trout and WCT are summarized in the table above.

With regard to Forest plan compliance, upgrading road drainage to even a limited degree on many of the roads that are considered to pose high risk to fish, addresses Forest Plan road standards more so than Alternative 1. Consequently Alternative 2 better addresses Forest Plan guidance in regard to minimizing effects of roads on fisheries.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 50 Use of watershed and fisheries information from the 2004 Helena Forest Roads Analysis, in conjunction with the inventory of additional high risk road segments in the Little Blackfoot River drainage, has incrementally moved the Helena Forest in the direction of meeting the intent of INFISH (1995) road standards RF-2 and RF-3 as well as other Forest Plan road standards to the degree the inventories of sediment delivery sites on roads and road upgrades are planned and completed for roads of interest to this particular project. However, other projects currently being planned such as travel planning (cumulative effects) would also be affecting the rate at which Forest Plan requirements are met. Alternative 2 would also move the Forest forward to a limited degree in meeting the intent of the U.S. Fish and Wildlife Service’s 1998 biological opinion on Forest Plans to develop site specific proposals to reduce the impacts from existing road systems causing adverse effects to bull trout, westslope cutthroat trout and other salmonid fishes. There still is potential for negative effects to fisheries to occur with implementation of Alternative 2, but risk for those effects are somewhat less than what would occur with Alternative 1; at least for some of the drainages due to road improvement work planned in conjunction with Alternative 2. With special emphasis to improve road conditions on important bull and westslope cutthroat trout drainages receiving substantial log truck use, risk for negative effects may still be present, but risk for negative effects would be reduced from current levels on some streams for a period of time. With some reductions in sediment delivery expected to occur in some locations one can conclude that risk for negative effects to fisheries as a function of the project in comparison to current conditions are insignificant. For fisheries Forest Plan standard 1, Fish habitat would be maintained by limiting sediment delivery from existing roads and use of the roads. Improvements would be completed on many roads while use of various road segments would be restricted to reduce risk of sediment delivery. For fisheries Forest Plan standard 2, Any work in streams as a function of road upgrades would require coordination with the state to ensure spawning habitats are not adversely affected. This would occur. For Forest Plan fisheries standard 3, Structures such as culverts installed during road improvements would include design features to provide for fish passage if fish use the stream. Westslope cutthroat trout habitat would be maintained by limiting sediment delivery from existing roads and use of the roads.

Forest Plan consistency is addressed in detail in Appendix D of the fisheries report in the project file. Actions taken as part of Alternative 2 to improve road conditions would move the Forest incrementally in the direction of meeting Forest Plan standards. Additionally, ongoing and planned actions regarding travel planning and road uses (addressed as part of cumulative effects) have potential to further move the Forest in the direction of meeting Forest Plan standards for roads in relation to their effect on fish habitat.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 51 3.6 Effects to Recreation 3.6.1 Affected Environment The Helena National Forest manages recreation opportunities that provide valuable physical and mental benefits to residents and visitors. In addition to the enjoyment and satisfaction those recreation activities offer to the individual, they also contribute to the local economy (goods and services).

Currently developed sites are inspected annually by Helena Forest recreation employees to ensure safe conditions. These inspections are routinely conducted each spring before the sites are opened and managed for public use. When hazard trees are identified, they are cut down. Depending upon the site, hazard tree removal might require one day for two individuals or a larger crew for a week or more. In most cases dry hazard trees that are cut down are left in place for firewood. Occasionally the timber may be removed and placed at other administrative sites. In some locations, the increased number of hazard trees in popular recreation areas has grown beyond our Forest capability to remove the trees each spring before the sites are opened for public use. It should be noted that some recreation sites are not gated, thereby limiting opportunities to restrict public access.

The Helena National Forest has issued, on average, 1,500 personal use firewood permits annually. Personal use permits authorize removal of firewood on National Forest lands. House- holds can purchase up to 12 chords annually for a maximum fee of $60.00. While gathering firewood is a necessity for many who heat their homes with wood, this activity is also considered a recreational pursuit. Census data from 2000 indicates approximately 7.5 % of Montana house- holds use wood as a source of heat.

The wide-spread nature of the beetle epidemic has created a large supply of readily available firewood adjacent to roads on the Helena Forest. Specifically, Forest roads close to communities and residential areas are currently experiencing increased activity and available firewood in these areas is quickly diminishing.

Firewood cutting is prohibited in all developed recreation areas within active timber sale units.

This Hazard Tree Removal Project would occur in developed recreation sites, administrative areas and along specific Forest roads on all three Ranger Districts. The amount of hazard trees located within or adjacent to the campgrounds and administrative sites vary. There are existing developed recreation sites with an extremely high degree of dead trees which are not included in this proposal. In January of 2009, dead and dying trees were harvested within the MacDonald Pass Trailhead and Cromwell Dixon Campground. Efforts have been initiated for removal of hazard trees at the Park Lake Campground and Day Use Areas. Identified below are the campgrounds and other administrative sites associated with this proposal.

Helena Ranger District Moose Creek Campground and Ten Mile Picnic Area are within mature lodgepole pine stands and located west of Helena, off the Rimini Road. Although both sites are used at other times of the year, they primarily provide recreation opportunities from Memorial Day through Labor Day. Moose Creek Campground is managed as a fee site.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 52 Kading Campground and the Charter Oak Interpretive Mine are located south of Elliston in an area hit particularly hard by the mountain pine beetle. Charter Oak is managed as an Interpretive Site by the Helena Forest and is only open to the public on days when tours are offered. Kading Campground is managed as a fee site from Memorial Day through September but is available for use yearlong. Many of the lodgepole pine trees within the campground are considered hazardous.

The Kading Administrative Cabin, located across the road from the campground, is managed as a rental facility. Although the cabin is not available in March or April, it is popular the rest of the year. There are a number of hazard trees in the area adjacent to the cabin.

A special use permit is authorized to the Prickly Pear Sportsman for a target range located just east of MacDonald Pass. While the site is not generally open for public use, club members frequent the range throughout the year. There are numerous dead and dying lodgepole pine trees within and immediately adjacent to the target range that may present a hazard to shooters. It should be noted that trees currently serve as a vegetative screen (visual and safety) along the edge of the 100 and 300 yard target ranges.

The Willard Creek Trail provides access to the west side of the Elkhorn Mountains. Forest Road # 4104 which provides motorized access to the trailhead is utilized as a cross-country ski trail during winter. The trailhead itself is primarily used on weekends from Memorial Day through the big game hunting season at the end of November.

Lincoln Ranger District Moose Creek Campground is not managed as a fee site. Although it is not heavily used any time of the year, the primary season of use is during the fall hunting season. The area contains a mix of conifers and cottonwoods.

Cummings Cabin is an administrative facility that is available for public rental from May through February. The cabin is surrounded by a mixed forest, with a predominate species of lodgepole pine.

Other specific sites on the Lincoln District which are included in the Hazard Tree Removal Project include: Pine Grove Camping Area, Alice Creek Trailhead, Indian Meadows Trailhead, Arrastra Creek Trailhead, Dry Creek Trailhead, Flesher Pass Trailhead, Lincoln Cemetery and the Old Lincoln Town-site. These are all popular non-fee recreation or administrative sites which contain hazard trees. Although the severity and number of hazard trees vary by site, they all need to be removed. Currently, hazard trees are cut down in these sites each spring by Forest Service employees.

Townsend Ranger District Skidway Campground, located along the Deep Creek Highway, is a welcome rest stop for travelers. Although the number of overnight visitors is minimal, many people use the facilities for day use. Beginning in 2009 the campground will be managed as a fee site. The campground contains a mix of tree species that need to be removed.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 53 Gipsy Lake Campground is relatively small and overnight use is low. Because the campground is located near Gipsy Lake it is a popular area for families. Beginning in 2009 the campground will be managed as a fee site. The campground is predominately spruce with a minor component of lodgepole pine.

The Thompson Guard Station is an administrative site that is available for public rental from May through February. There are a number of hazard trees adjacent to the cabin area which should be removed.

Other recreation sites on the Townsend Ranger District that are included in the Hazard Tree Removal Project include: Hidden Lakes Trailhead, Edith Lake Trailhead and Stove Camp Trailhead. These sites contain hazard trees that may affect public safety.

Roadside Hazard Trees The project would also facilitate removal of identified hazard trees along the most bug infested and popular open roads on the Helena Forest. Roads have been selected for this proposal based on the amount of traffic and condition of trees. Driving for pleasure and viewing scenery/wildlife are important recreation activities on the Helena National Forest.

In many areas of the Forest, recreation activities occur adjacent to or within 175 feet of designated roads. Forest visitors often camp or park along the roads and expect minimal hazards in those locations. There are many dispersed campsites and parking areas located within the travel corridors. Removal of hazardous trees is necessary to provide for the safety of those who recreate adjacent to Forest roads.

Many of the popular roads that are proposed for hazard tree removal also serve as important snowmobile trails during the winter. The only road on the Townsend Ranger District that might be affected is the Magpie Gulch Road (# 425), approximately 12 miles in length. Both the Helena and Lincoln Districts have a more extensive snowmobile trail system that could be affected. A few of the keys roads which also serve as snowmobile trails include: Little Blackfoot (# 227), Bullion Parks (# 1863), Minnehaha (# 527), Frohner Meadows (# 1878) , Quartz Creek (# 692), Elliston-Spotted Dog (# 314), Dog Creek (# 1855), Ophir-Cave (# 136), Dalton (# 329), Sauerkraut (# 1892), Sucker-Keep Cool (# 1800) , Park Creek (# 607) and Beaver-Dry Creek (# 4106). It is important to note the Lincoln community derives an important economic benefit most winters from the snowmobile trails in the area.

Hazard tree removal is also proposed for the Microwave Road (# 1802) on the Helena Ranger District and Page Gulch Road (# 1827) on the Lincoln Ranger District. The Microwave Road is currently designated and groomed for cross-country skiing. Page Gulch Road, located on Stemple Pass, also serves as an important segment of a designated cross-country ski trail.

Inventoried Roadless Areas Hazard trees proposed for removal are located along approximately 22.29 miles of existing open roads located within 10 Inventoried Roadless Areas (IRA). There are several developed recreation and/or administrative sites located near or adjacent to Inventoried Roadless Areas.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 54 Those potentially affected IRAs include: Nevada Mountain (# 1606) 7.69 miles Anaconda Hill(# 1602) 0.29 miles Bear-Marshall-Scapegoat-Swan (# 1485) 2.86 miles Camas Creek (# 1616) 5.54 miles Grassy Mountain (# 1618) 1.09 miles Ogden Mountain (# 1605) 0.11 miles Crater Mountain (# 1604) 0.64 miles Jericho Mountain (# 1607) 1.79 miles Electric Peak ( # 1609) 1.71 miles Specimen Creek (# 1603) 0.57 miles Total 22.29 miles

A segment of the Little Blackfoot Road (# 227) passes through the Electric Peak Roadless Area (# 1609). The Helena Forest Plan states the Little Blackfoot Road and Kading Campground are excluded from the Inventoried Roadless Area (Appendix C, page 151). However, the Forest Plan did not provide direction regarding a definitive buffer for the road or campground. Approximately 12 miles of roads within the Inventoried Roadless Areas are located on lands managed by the Lincoln Ranger District. Hazard trees could be removed up to 125 feet on either side of those 12 miles of road. If hazard trees were removed along the entire 250 foot wide segment of those 12 miles of road, approximately 364 acres could be impacted. About 10 miles of roads within the Inventoried Roadless Areas are located on lands managed by the Helena or Townsend Ranger Districts. Hazard trees could be removed up to 100 feet on either side of those 10 miles of road. If hazard trees were removed along the entire 200 foot wide segment of those 10 miles of road, approximately 242 acres could be impacted. Thus, a total of 606 acres out of the total of 229,339 acres of Inventoried Roadless Areas could be impacted by this project on Helena National Forest System lands. This is approximately .003 percent of the total Inventoried Roadless Area potentially associated with this project. In addition, there are a number of roads identified under this project which pass through or adjacent to unroaded areas that are contiguous to the Inventoried Roadless Areas. Contiguous unroaded areas are described as those National Forest lands, located adjacent to designated Inventoried Roadless Areas, which have no permanent roads. The size and/or configuration of the contiguous unroaded areas is not a consideration. Although the contiguous unroaded areas are not mapped, hazard trees would be removed along roadsides near the following areas:

• Hedges Mountain (#613) IRA • Hellgate Gulch (#614) IRA • Crater Mountain (#1604) IRA • Grassy Mountain (#618) IRA • Ogden Mountain (#1605) IRA • Bear-Marshall-Scapegoat-Swan • Nevada Mountain (#1606) IRA (#A1485) IRA • Jericho Mountain (#1607) IRA • Lincoln Gulch (#1601) IRA • Lazyman Gulch (#1608) IRA • Specimen Creek (#1603) IRA • Electric Peak (#1609) IRA

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 55 Wild and Scenic River A five mile segment of the Little Blackfoot River lies adjacent to or near a segment of Forest Road # 227, proposed for hazard tree removal. This river segment was previously determined to be eligible for protection under the Wild and Scenic Rivers Act in 1989. The potential classification for this segment of the Little Blackfoot River is “Recreational” and its outstanding value is “Fisheries”. The upper boundary of this river segment is the NW ¼ S28, T8N, R7W (Kading Grade) and the lower boundary of this river segment is S12, T8N, R7W (Ontario Creek).

This portion of the Little Blackfoot River will be studied to determine suitability for inclusion into the Wild and Scenic Rivers system during Forest Plan revision. As an eligible stream segment, the existing Forest Plan specifies that this portion of the Little Blackfoot River will be protected to maintain its outstandingly remarkable resource value and potential for classification until suitability studies can be completed.

3.6.2 Effects Common to All Alternatives Hazard trees within recreation and administrative sites will be removed before the sites are opened for public use. If hazard trees are not removed, recreation and administrative sites would be closed to the public for an unspecified period of time. It is unlikely that either alternative would facilitate the removal of all hazard trees this spring in time to ensure the developed sites were all opened by Memorial Day.

It may be difficult to physically close some campgrounds and other developed sites. There is no easy way to restrict public access and use because not all of the sites are gated. Until all hazard trees within the developed sites are removed, the Forest will have to identify procedures to sign and close those sites and notify the public.

Managers would continue to monitor and evaluate the hazard tree situation along Forest roads. Once that determination is made, Line Officers would determine risks and respond by implementing appropriate management actions to ensure public safety. If roads are deemed unsafe for travel due to the presence of hazard trees, they may be closed until the trees could be cut down.

The public would continue to seek and remove firewood for personal use on the Helena National Forest. Under both alternatives, firewood would remain available along many Forest roads and firewood removal would continue.

The increased removal of dead trees under either alternative would result in impacts to forest resources and visitor use. Regardless of how and when hazard trees are removed that activity may impact use in popular recreation sites. The removal of trees from developed recreation sites could greatly affect the recreation experience for visitors until vegetative screening is re- established.

Developed and administrative sites would be cleared of hazardous trees (caused by bug mortality) under both alternatives. At some sites the number of trees removed may be minimal and not greatly affect the recreational experience. At other sites, the large number of hazard

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 56 trees removed could result in a very different recreation experience. The visual condition of developed sites would change as hazardous trees are removed. Some campsites may loose the limited but remaining overhead canopy. Areas with little or no vegetation may result in warmer campsites and trailheads. It should also be noted the lack of vegetation resulting from hazard tree removal could increase noise within those sites.

Depending upon the number of hazard trees removed, some people may be displaced to other areas for their recreation activities. If a campground has few large green trees remaining after hazard trees are removed, forest visitors may choose to utilize other sites that provide more vegetative cover and screening.

3.6.3 Alternative 1 (No Action) The incremental removal of hazard trees may be more costly in the long-term and result in the closure of more sites for a longer period of time. There is not sufficient recreation staff to remove all hazard trees within the developed sites before the start of the summer season. There would be two notable effects associated with the closure of developed recreation sites.

1) Forest visitors that wish to camp or recreate in a site closed to use could be displaced to another area. The number of recreation/administrative sites closed and the weather would determine the extent of displacement. If there are too many campgrounds closed, the Helena Forest may not be able to meet the demand for overnight camping. Rather than relocate to another site, some visitors may decide not to recreate on the Forest. 2) If the closed campgrounds are also fee sites, there will be a corresponding loss of revenue. While the amount of fees collected vary each year, that loss of funding would impact recreation operations. New fees are currently planned for the Skidway and Gipsy Lake Campgrounds during the 2009 season.

If the No Action Alternative is implemented, hazard trees will be removed from developed and administrative sites by existing Forest Service employees as time and funding allows. Removal of all hazard trees each spring will delay opening some campgrounds and administrative sites. Time spent by Forest Service employees on tree removal would limit other maintenance and/or compliance work that could be accomplished.

Some Forest Service employees may not possess the skills necessary for felling timber within developed sites. As a result, the use of Forest Service crews for tree removal within developed sites increases the likelihood that facilities such as toilets, tables, fences and signs may be damaged.

Forest Service crews would not be able to remove all hazard trees in a timely manner from developed sites. Until the hazard trees are cut down, they would continue to present a hazard. Hazard trees which fall could result in personal injury or damage to vehicles and camping equipment and facilities such as toilets, picnic tables, water systems, signs, bulletin boards, etc..

Hazard trees would remain at the Prickly Pear Sportsmen’s target range. Under the No Action Alternative, responsibility for the removal of hazard trees within the permitted target range would be assumed by the club. The permittee may have limited financial resources for the

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 57 unplanned expense associated with large-scale hazard tree removal. In addition, hazard trees adjacent to the target range would not be removed by the permittee but could still be a hazard to those using the facility.

Firewood gathering would continue as currently exists across the Helena National Forest. The growing number of dead trees adjacent to Forest roads would provide many opportunities for cutting firewood. However, there would be negative impacts associated with the removal of numerous hazard trees by the public along Forest roads including:

• Until all hazard trees are cut down, travel along popular Forest roads may present unreasonable safety risks because the hazard trees could fall on roads or vehicles. • Travel along popular Forest roads may present a greater safety risk if hazard trees are removed by the public rather than contract fallers. Not all publics who cut and haul firewood are concerned about public safety. • Many dispersed campsites and parking areas adjacent to Forest roads contain dead and dying trees which may represent a safety hazard that is not addressed under the No Action alternative. • The desire to cut and remove easily accessible firewood along Forest roads could result in illegal off-route travel. This would occur more frequently under the No Action alternative. • Public cutting of firewood in large quantities along Forest roads could result in a greater accumulation of slash. This would occur more frequently under the No Action alternative. • Dead trees falling on and adjacent to Forest roads would result in additional maintenance needs for those roads.

The only hazard trees removed by the Forest Service from the Inventoried Roadless Areas would occur at Kading Campground and Kading Rental Cabin. It should be noted, Kading Campground was excluded from the Inventoried Roadless Area in the 1986 Forest Plan. As described above, hazard trees within developed sites must be cut down before the sites are open for public use. Hazard trees have routinely been cut down at these two sites for many years with no apparent effect upon Roadlesss characteristics. The existence of two developed sites is inconsistent with a natural appearing landscape associated with an Inventoried Roadless Area.

Hazard trees would not be removed from the five mile segment of the Little Blackfoot River that was determined to be eligible for protection under the Wild and Scenic Rivers Act. As a result, associated resource values would not be adversely impacted or scenic values degraded. However, some hazard trees located adjacent to this five mile river and road segment could fall and injury persons or property.

3.6.4 Alternative 2 (Proposed Action) Recreation and administrative sites would be cleared of hazardous trees in a uniform and timely manner. It is likely hazard trees could be removed much quicker through this large-scale project rather than using existing Forest Service crews. The Helena Forest does not have sufficient recreation staff available to remove all hazard trees within established developed sites this spring before the start of the normal operating season. It should be noted that opening some

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 58 campgrounds this spring could still be delayed even through implementation of the proposed action.

Not only would the hazard trees be removed from the developed and administrative sites but consistent clean-up procedures and mitigation could be ensured. Once the hazard trees are removed, there would be a large amount of slash to remove, chip, pile or disperse. This proposal would greatly facilitate slash treatment or disposal. If agency recreation personnel were not responsible for hazard tree removal, they would be available for many other required tasks within the developed sites (maintenance, improvements, compliance, etc). The level of service provided at developed sites and within the Forest recreation program would not be reduced by time devoted to hazard tree removal.

Contract fallers have more skill and experience at felling trees than most Forest Service employees. As a result, the associated benefits from using contract fallers include: • A greater likelihood that existing facilities within developed sites would not be damaged through tree removal. • Hazard tree removal would occur with less potential for injury to Forest Service employees. • The hazard trees would be removed faster thereby reducing public exposure and risk. • Hazard tree removal would be more cost efficient. • Harvest activities would be scheduled and managed to a much greater extent than through the No Action alternative. • As a result, travel on popular Forest roads included in the roadside hazard tree removal project would become safer.

Log hauling (approximately 4,773 truck loads) associated with commercial harvest of hazard trees would affect recreation opportunities and experiences. If log hauling is conducted during the winter months the truck traffic could prohibit and displace visitors from using the same travel routes. In addition, if log hauling occurred on Forest roads which are also utilized as designated snowmobile trails it would restrict snowmobile travel during periods of hauling.

Truck traffic for log hauling and the associated dust and noise may be an inconvenience and potential safety hazard to Forest visitors. Some recreationists may choose to avoid roads with large numbers of logging trucks. The timing of log hauls will be a critical issue to consider when planning harvest and removal activities.

Log hauling is also a consideration in respect to residential traffic. Many Forest and County roads that would be utilized by logging trucks provide access to local residents. A few of the key roads that could be impacted include: Stemple Pass, Highway 141, Magpie, Little Blackfoot, Rimini, Grassy Mountain, Telegraph, Greenhorn/Skelly and Deep Creek. It will be extremely important to ensure motorists on those routes are knowledgeable about the log truck traffic.

Through this project, hazard trees would also be removed from dispersed recreation sites (campsites & parking areas) along identified road corridor segments. This would provide greater safety to the public using those locations but it would also create a few additional impacts as listed below.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 59 • Removal of vegetative cover may make the dispersed sites less desirable. This could result in displacement to other areas where live trees remain. • Accumulated slash could cover existing dispersed sites making some of them difficult to identify. • Dispersed sites would be temporarily unavailable for recreation use while harvest activities are occurring. • Travel on Forest roads may be temporarily delayed or restricted while harvest activities are occurring. • Timber hauling on some Forest roads would temporarily increase traffic and may affect the recreation experience for some. • Trees that are currently marked with assurance markers on snowmobile trails may be cut down. The loss of assurance markers or other signs may impact existing directional signing that would need to be replaced. • Removal of hazard trees in a few locations may affect snow accumulations on roads which also serve as snowmobile trails. • The removal of hazard trees along Forest roads could facilitate development of new dispersed sites by the public.

The Forest-wide proposal to remove hazard trees along the 491 miles of roads identified in the proposed action would limit available firewood opportunities along these routes. However, given the wide-spread nature of the beetle epidemic, it is unlikely there would be any difficulty in finding available firewood. Where a timber sale contract is used to facilitate removal of trees, remaining slash piles would be made available for firewood. Further, it is likely that there would be areas where a timber appraisal indicates that removal of the material is more costly than the value of the material. In these cases, the Forest Service may facilitate completion of the work by designating public cutting areas, issuing commercial firewood permits or other types of noncommercial service contracts where trees may be felled but not removed. In some instances, Forest Service employees may have to fall hazard trees and those trees could be available to the public through a personal use firewood permit.

Recreation experiences at some developed and dispersed sites would be impacted through the removal of hazard trees. Although the sites would be safer for public use, the loss of vegetative cover may detract from the recreation experience. Existing users may be displaced to areas where trees have not been removed. The extent of public displacement may be dependent upon the number of trees removed. It is also possible the removal of hazard trees and opening campsites to additional sunshine could attract visitors who seek more light or warmth.

The removal of hazard trees along Forest Roads may alter recreation use in dispersed sites. Some existing dispersed sites may disappear or no longer remain popular when trees are removed. It’s also reasonable to assume that new dispersed campsites and parking areas may become established as the existing barrier of trees is removed.

Because firewood would be removed along Forest roads, motorized access to those areas may no longer be physically restricted. Indirectly, the cutting and removal of hazard trees could result in additional motorized impacts and violations adjacent to Forest roads.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 60 Inventoried Roadless Areas If implemented, approximately 22.29 miles of roadside hazard tree removal would occur within Inventoried Roadless Areas (see list above). A portion of the Little Blackfoot Road (# 227) was excluded from the Inventoried Roadless Area in the Helena Forest Plan. However, the Forest Plan did not provide direction regarding a definitive buffer for the road. Removal of hazard trees along Forest roads within IRAs may reduce the natural appearing landscape in some locations, depending upon the extent of tree removal. With the presence of existing roads, the removal of adjacent dead trees would not greatly impact Roadless characteristics. It’s important to note, hazard trees adjacent to Forest roads would probably be cut for firewood by the public unless specifically prohibited.

This hazardous tree removal project meets the intent of the 2001 Roadless Rule because the removal of hazardous trees is needed for maintenance of Forest roads and recreation sites. The cutting, sale, or removal is incidental to the implementation of a management activity not otherwise prohibited (36CFR 294.13(b)(2).Additionally, the proposal does not conflict with Judge Brimmer’s decision because the design of the project (what areas to treat) was based on the risk to people and forest plan direction, not the location of roadless areas.

In 2009, the Secretary of Agriculture, Thomas J. Vilsack reserved final decision authority over certain forest management and road construction projects in Inventoried Roadless Areas. In August of 2009, Secretary Vilsack issued authority to the Forest Service to approve any necessary timber cutting or removal in emergency situations involving imminent threats to public health and safety in Inventoried Roadless Areas. Helena Forest Supervisor Kevin Riordan determined hazardous trees along some roadways and in developed recreation sites is a danger that should be considered an imminent threat. The trees pose a danger to forest recreationists and other forest users, especially if they were to fall on a road or in a campground when people are present.

Roadless landscapes have a number of values or features which sometimes separate them from other forest landscapes. Specifically, Forest Service Handbook 1909.12(72) identifies potential characteristics that can be used to identify a roadless areas capability to be considered for future wilderness. This analysis uses these characteristics as a way of measuring the effects of the project on the roadless lands in the project area.

If implemented, the cutting, sale, or removal of hazard trees along Forest roads within Inventoried Roadless Areas and contiguous unroaded areas may slightly impact wilderness attributes and/or roadless characteristics. The wilderness attributes identified below may be applicable to the 10 Inventoried Roadless Areas and any of the 12 unroaded contiguous areas associated with this project.

Natural – Hazard trees would only be removed along Forest roads or within developed recreation sites. The existence of roads or recreation sites has a far greater impact on the apparent naturalness of the Inventoried Roadless Area than removal of hazard trees. However, the cutting of dead trees would affect the apparent naturalness along approximately 22.29 miles of road within designated IRAs. However, the cutting of dead trees would affect the apparent naturalness along approximately 20.5 miles of road within designated IRAs. The removal of hazardous trees would initially create stumps, slash and areas immediately

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 61 adjacent to the roads and campgrounds that at first appear unnatural. Stumps would be cut to less than 8 inches high to minimize their visual impact. Over time these areas would re- vegetate, as young trees and shrubs fill in the landscape. Undeveloped – The cutting, sale, or removal of hazard trees along Forest roads would only slightly impact the perceived condition of being undeveloped, inaccessible or out of the way. There would be limited to no effect within the interior of the roadless areas as these are further removed from activities. The lands directly adjacent to roads would be perceived as developed; however many of these areas already have the feel of a developed area due to the nearby presence of roads and developed recreation sites. Opportunity for Solitude or Primitive or Unconfined Recreation – Cutting, sale, or removal of hazard trees would allow for greater sight distance from Forest roads. It might also allow traffic noise to carry further than if the dead trees remained standing. Both factors could slightly reduce the subjective value of solitude. However, the dead trees are not anticipated to remain standing forever, as they will fall over time. Therefore this affect would occur with or without implementation of this project. The removal of hazardous trees would not affect primitive or unconfined recreation because these are generally provided further within the roadless areas – not on the outer boundaries next to roads. Roads located within contiguous unroaded areas for this project are located within two Recreation Opportunity Spectrum (ROS) classes: Roaded Modified and Roaded Natural. Timber cutting, sale, or removal activities in those two ROS classes would not impact recreation opportunities within the primitive or semi-primitive ROS classes. Special Features – There are no unique geological, biological, ecological, scenic or cultural features adjacent to roads or developed recreation sites within the Inventoried Roadless Areas or contiguous unroaded areas that would be impacted through the removal of hazard trees. Manageability and Boundaries – The removal of hazard trees along Forest roads would not result in changing any of the roadless boundaries. If mitigation features are implemented, the removal of hazard trees should not result in illegal off-road vehicle travel and thus slightly affect management of some IRAs. Cutting and removing hazard trees along Forest roads and within developed recreation sites would occur within Inventoried Roadless Areas and contiguous unroaded areas. However, the presence of the roads and/or developed recreation sites has a greater impact on wilderness or roadless characteristics than removal of hazard trees within specifically designated areas. The removal of dead trees along roads and developed recreation sites would not impact potential future designations for wilderness or roadless.

Wild and Scenic River The Decision Notice and Finding of No Significant Impact for the Wild and Scenic Rivers Eligibility Study on the Helena National Forest stated the four eligible rivers included would be managed and protected based on their classification and the Management Standards. Forest Plan Amendment #1 provides management direction specific to wild and scenic rivers. One standard states: “timber harvesting will be allowed under standard restrictions to protect the immediate river environment, water quality, scenic, fish and wildlife and other values.” It is also important to note the Forest Plan states roads will be maintained to provide for user safety. Although cutting and removal of hazard trees may impact scenery along the 5 mile river corridor, public

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 62 safety is of primary importance. Approximately ½ mile of private land along this segment of the Little Blackfoot River is private property and trees in that area have already been cut and removed.

Irreversible/Irretrievable Commitments There would be no irreversible or irretrievable commitment to recreation resources or opportunities through the implementation of the Proposed Action.

Cumulative Effects The Cumulative effects analysis area includes the Helena National Forest. Dead and dying trees resulting from bug infestations would result in the removal of hazard trees in developed and administrative sites and along some Forest roads.

The removal of hazard trees within developed and administrative sites is occurring on all National Forests in Region One. Developed sites which undergo large scale hazard tree removal may no longer provide the shade and screening desired by many. As a result, National Forests in western Montana may not be able to provide the desired number of campsites in older mature lodgepole pine stands.

3.6.5 Conclusions The Proposed Action meets Forest Plan Standards for recreation and public safety.

3.7 Effects to Scenic Values

3.7.1 Affected Environment The Helena National Forest Land and Resource Management Plan contains direction for the management of scenic resources in three areas: Forest-wide goals, Management Area (MA) direction, and in Appendix B. The following section identifies Forest Plan direction relevant to the Forest-wide Hazard Tree removal proposed action and project area.

Forest-wide Visual Quality Goal: Goal 9 - Provide forest visitors with visually appealing scenery. Forest-wide Visual Quality Objective: Landscape management would be practiced through out the Forest and would have special emphasis in areas seen from identified visually sensitive roads and trails. Landscape management mitigation principles would be applied to resource activities that may affect the visual setting. Forest-wide Visual Quality Standard: Visual Quality Objectives (VQO) are assigned to each Management Area (MA). These VQOs provide the guidelines for altering the landscape. Portions of each management area may have a more or less restrictive VQO.

Visual Quality Objectives (VQOs) define the degree to which management activities are visible to the average forest visitor. Definitions for each of the VQOs are provided below.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 63 • Retention - Management activities may be present but repeat the form, line, color, texture and pattern of the surrounding natural landscape. Deviations to the landscape are not evident to casual forest visitors. • Partial Retention - Management activities are noticeable but visually subordinate to the surrounding natural landscape. Landscapes appear slightly altered to the average forest visitor. • Modification - Management activities may be dominant but will borrow from naturally occurring landscape elements (line, form, color, and texture). The landscape appears moderately altered to the average forest visitor. • Maximum Modification - Management activities dominate the landscape. To the average forest visitor, the landscape appears heavily altered. The Forest Plan assigns a VQO to each MA. In some cases, additional direction is identified for a specific MA. The following table lists the MAs relevant to this proposal, displays the assigned VQO, and notes any additional MA-specific direction contained in the Plan.

Table 3.5 Forest Plan Management Area Direction for Scenic Resources MA VQO Additional Forest Plan MA direction for scenery management Elkhorn Partial “Short term deviations from the VQO are permitted, if the resulting E– 3 Retention resource management meets the management area’s goals.” Elkhorn E-4 Modification NA Municipal Watershed “The portions of this MA that are located within visually sensitive H-1 & H-2 Modification viewing areas will be managed to meet the more restrictive VQOs noted in Appendix B.” Grazing “The portions of this MA that are located within visually sensitive L-1 Maximum viewing areas will be managed to meet the more restrictive VQOs Modification noted in Appendix B.” Minimal Investment “A less restrictive VQO may be considered on a case-by-case M-1 Retention basis.” Research Natural Areas N-1 Retention NA Recommended Wilderness Preservation NA P-3 Backcountry Dispersed “Short term deviations may occur during construction or Recreation Retention reconstruction of facilities or management activities” R-1 Developed Recreation Partial “Some deviation from PR may be allowed during construction or R-2 Retention reconstruction of needed facilities.” Timber Lands Maximum “The portions of this MA that are located within visually sensitive T-1 Modification viewing areas will be managed to meet the more restrictive VQOs noted in Appendix B.” Timber Lands “The portions of this MA that are located within visually sensitive T-3 Modification viewing areas will be managed to meet the more restrictive VQOs noted in Appendix B.” Timber Lands “The portions of this MA that are located within visually sensitive T-5 Modification viewing areas will be managed to meet the more restrictive VQOs noted in Appendix B.” Wildlife Emphasis “A less restrictive VQO may be considered on a case-by-case basis W-1 & W-2 Partial to meet wildlife objectives.” Retention

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 64 Appendix B (page II-5) of the Forest Plan lists roads, trails, and recreation sites with special VQO designations. Those areas identified in Appendix B are referenced in the Affected Environment section of this analysis.

Proposed treatments are limited to foreground areas of specified developed recreation and administrative sites, and along identified Forest roads. These areas contain high concentrations of recreation use and the scenic resources are critical to delivering quality recreation settings for visitors. Sites and corridors are listed in the following tables under each of the three Ranger Districts: the Helena, Lincoln and Townsend Districts. The identified sites and corridors would serve as the critical viewing locations from which effects would be assessed.

Table 3.6 Helena Ranger District Developed Sites and Roads Developed Site Existing Condition VQO Moose Creek Campground Mature lodgepole pine. Some dead or dying Retention standing trees. Ten Mile Picnic Area Mature lodgepole pine. Some dead or dying Retention standing trees. Kading Campground Epidemic levels of Mountain Pine Beetle Retention Charter Oak Interpretive Epidemic levels of Mountain Pine Beetle Partial Retention The Kading Administrative Cabin Many dead, dying lodgepole pine adjacent to the Partial Retention rental cabin MacDonald Pass Target Range Numerous dead and dying lodgepole pine trees Partial Retention within and immediately adjacent to the target range that provides screening Road Existing Condition VQO Willard Creek Road (# 4104) Varying degree of hazard trees immediately Retention & adjacent to the road Partial Retention Microwave Road (# 1802) Varying degree of hazard trees immediately Retention & adjacent to the road Partial Retention Table 3.7 Lincoln Ranger District Developed Sites and Roads Developed Site Existing Condition VQO Moose Creek Campground Mix of conifers and cottonwoods. Some standing Partial Retention hazard trees. Cummings Cabin Mixed forest, with a predominate species of Partial Retention lodgepole pine. Standing hazard trees. Pine Grove Camping Area Mixed forest, with a predominate species of Partial Retention lodgepole pine. Some standing hazard trees. Alice Creek Trailhead Indian Meadows Trailhead Arrastra Creek Trailhead Mixed forest settings with varying levels of dead Partial Retention and dying trees. Dry Creek Trailhead Flesher Pass Trailhead Lincoln Cemetery Old Lincoln Town-site. Road Existing Condition VQO Page Gulch Road (# 1827) Varying degree of hazard trees immediately Retention & adjacent to the road Partial Retention

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 65 Table 3.8 Townsend Ranger District, Developed Sites and Roads Developed Site Existing Condition VQO Skidway Campground Mix of tree species interspersed with standing dead Retention and dying trees. Gipsy Lake Campground Predominately spruce with a minor component of Partial Retention lodgepole pine. Some standing hazard trees. Thompson Guard Station Hazard trees adjacent to the cabin area Partial Retention Hidden Lakes Trailhead Some standing hazard trees. Partial Retention Edith Lake Trailhead Numerous standing hazard trees. Partial Retention Stove Camp Trailhead Some standing hazard trees. Partial Retention Road Existing Condition VQO Magpie Gulch Road (# 425) Little Blackfoot (# 227) Bullion Parks (# 1863) Minnehaha (# 527) Project corridors traverse a range of elevation and forested habitat types. In general, proposed Retention & Frohner Meadows (# 1878) treatments occur along stretches of these corridors Partial Retention Quartz Creek (# 692), adjacent to stands containing a large component of Elliston-Spotted Dog (# 314) lodgepole pine, Ponderosa Pine, and/or Douglas fir. Dog Creek (# 1855) Varying levels of dead and dying trees are present. Ophir-Cave (# 136) Dalton (# 329), Sauerkraut (# 1892) Sucker-Keep Cool (# 1800) Park Creek (# 607) Beaver-Dry Creek (# 4106)

3.7.2 Effects Common to All Alternatives The visual condition of developed sites would change as hazardous trees either fall or are removed. This loss of mature trees would reduce screening between individual camping units and use areas. In addition, there would be a reduction in overhead canopy. Sites would appear more open and exposed. The reduction in mature trees would increase sun to the under-story, potentially resulting in accelerated growth of seedlings, shrubs and other low growing vegetation.

Along roads, the density of trees would also be reduced. Where infestations are more concentrated, openings may be created. The resulting forest would be more open with a more robust under-story. Views to more distant landscapes would also be likely.

Cumulative Effects Past, present and future management activities within the Helena National Forest were reviewed for cumulative effects to the scenic resources. Natural disturbance regimes would continue to shape vegetation across the Forest. Continued tree mortality resulting from mountain pine beetle infestations would likely require additional vegetation management in an attempt to contain or slow infestation and prevent catastrophic fire.

Long term effects of either alternative are predicted to be consistent with natural occurring vegetation mosaics with more heavily thinned stands adjacent to infrastructure. Proposed treatments would not cause any adverse cumulative effects.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 66 Irreversible/Irretrievable Commitments There are no anticipated irreversible or irretrievable commitments of scenic resources resulting from implementation of either alternative.

3.7.3 Alternative 1 (No Action) The No Action Alternative would have natural disturbance regimes and events such as wildfires, winds, insects and disease continue to shape and change the vegetation of Forest landscapes. Hazard trees within recreation and administrative sites would continue to be cut and removed to meet public safety requirements. New young trees would begin to re-establish and scenic impacts would be lessened. Trees that fall across roads would likely be cut but not removed.

Many hazard trees could remain standing for several years. As trees fall, there would be an increase in woody material on the ground and a reduction in forest canopy. The increased woody debris, along with continued spread of insect infestations, would increase the probability for high intensity fires.

The No Action Alternative would comply with the VQOs of Helena National Forest Land and Resource Management Plan. Long term effects may be less desirable due to increased woody debris, continued spread of beetle infestation, increased occurrence of dead and dying trees, and the potential for high intensity fire events.

3.7.4 Alternative 2 (Proposed Action) The Proposed Action alternative allows the felling and removal of hazard trees along specified roads and within identified recreation and administrative sites. As with the no action alternative, created openings, and a reduction in canopy and screening would result. In addition, cut stumps would be visible. Slash would be removed or used to protect and rehabilitate disturbed areas. These short term impacts would decrease over time as stumps weather and mulch settles and weathers. By implementing mitigation measures outlined in Appendix C, impacts to the scenic resources would be minimized.

Immediately adjacent to roads (up to 125 feet), trees would be thinned and openings may be created. Depending on the location and intensity of treatment, views to more distance landscapes may result. Cut stumps would be visible and slash, where lopped and scattered, would be apparent in the short term. The slash would weather and settle over time. Cut ends of stumps would also weather and turn grey over time. Long term, contrasts created from slash and stumps would diminish and blend into the natural setting. Some felled trees may remain on the ground to protect sensitive plants, soils, or other resources. Standing dead or felled trees may also be left on site to provide wildlife habitat.

Tree removal within stands that serve to screen recreation and administrative sites may result in those sites becoming more visible from travel corridors and other vantage points. Removal of hazard trees would allow remaining young healthy trees to grow faster with less competition for light and moisture. In ten to twenty years, a more diverse mix of species and age classes would be established. VQOs would be met under this alternative.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 67 Dust would result from proposed log hauling. Timing stipulations would be implemented to minimize this short term impact.

Mitigation measures have been developed to ensure impacts to the scenic resources are minimized, regeneration in developed sites is accelerated, and potential vista clearing along road corridors is considered.

Natural disturbances regimes would continue to have a dynamic effect on the landscapes of the Forest. Since management activities are relatively small in relationship to the forest-wide mosaics created naturally, no indirect effects of any significance are anticipated to the visual resources.

At a small scale, indirect impacts could include accelerated growth of under-story vegetation. This can, depending on site-specific conditions, increase the variety of color and texture seen in the landscape and result in positive long term effects to the scenic quality. In addition, more distant vistas from treated corridors and concentrated use areas may be created.

3.7.5 Conclusions Due to the condition of hazard trees proposed for removal, long-term results would be similar, with or without implementation of the proposed action. The effects of proposed treatments would vary in duration and intensity depending upon site-specific conditions. It is anticipated that the short term effects of cut stumps and slash would diminish over time. Long term, accelerated regeneration of the under-story would result, creating species diversity and increased variety in color and texture to the landscapes.

With proposed mitigation measures, the visual effects of proposed activities would meet Forest Plan direction.

3.8 Effects to Snags Direct and indirect effects were determined by the treatment or lack of treatment within each stand. The effects on snags were further affected by the amount of snags left in treated stands. Based on Forest Plan guidelines (page II/21), snags should be managed at 70% of optimum (2/acre) in each 3rd order drainage. See the silviculturist specialist report for further snag analysis details.

The spatial and temporal bounds of this analysis are designed to capture the existing condition and direct, indirect, and cumulative effects to snags. Spatially, the analysis is focused on the treatment units where direct effects can be most clearly demonstrated. Temporally, the existing condition reflects a snapshot of the most recent information available. For cumulative effects, the temporal bound of past activities is limited to the 1950’s due to availability of accurate information.

3.8.1 Affected Environment Snags are important structural and habitat components. Snags are abundant in proposed units based on the purpose and need of the project. Snags are managed at the third-order drainage level, and retention is primarily provided for via unit delineation, inoperable retention areas, un-

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 68 treated areas, and retention of live trees for snag recruitment. Snags are created and affected by a variety of disturbances; at the broad scale, these are most notably fire, insects and disease, and forest management. Snags are abundant on the landscape due to mortality factors. While snags in large size classes are limited, the snags being created by bark beetles are generally in the largest size classes available due to these insects preferring large diameter trees.

The directly affected area includes approximately 9,416 acres of MPB impacted forest stands which would receive immediate treatment. By definition as hazardous road segments, all treatment units contain snags, although the exact amount is variable. Most snags are recently killed mature lodgepole pine, although smaller amounts of other tree species and sizes are also present. Additionally, by definition as hazard trees, most snags would be removed with the proposal within treatment units. Ample snag habitat is provided for outside of the narrow proposed treatment units.

Table 3.9 HNF Bark Beetle Infestation Estimates Year MPB DFB acres acres The snag resource is being dramatically increased by the MPB 2002 4,100 1,200 outbreak. The Regional Aerial Detection Surveys (ADS) are 2003 12,800 1,800 summarized here for bark beetles (MPB, and DFB) because 2004 19,400* 10,800* these are the “tree-killers.” ADS clearly show dramatically 2005 24,800 5,600 increasing MPB mortality, which is creating snags in 2006 34,300 5,300 ponderosa, whitebark, limber, and lodgepole pine, generally in 2007 118,300* 420* the largest size classes available because those are the most 2008 350,770* 5088* susceptible trees. 2009 585,557 107 *portions of Forest not flown

3.8.2 Effects Common to All Alternatives With all Alternatives, mortality trends would continue at the landscape scale creating snags. Public firewood cutting could reduce the snag resource adjacent to roads. Ultimately this removal may not be substantially different than the removal of snags through the proposed action, or snag attrition through fall rates, although the timing of the removal would differ. In the short term snags would be abundant, while in the long term there may be few snags in some areas as forests regenerate and old snags fall. The snag resource is being impacted and increased by the MPB at a landscape scale regardless of alternative. In particular, snags in the lodgepole pine dominance group in the 10” and greater size classes would be increased. The spatial distribution of snags would be appropriately clumpy in the untreated forest matrix. In the long term, there would be a large reduction in snags as areas killed by MPB regenerate and the snags fall.

3.8.3 Alternative 1 (No Action) With No Action, no snags would be cut or removed from treatment units. Ultimately the effects for the No Action alternative are the same as Effects Common to All. With No Action, the loss of dead trees near roads would occur on a longer time span, according to predicted snag fall rates

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 69 (starting at 3 years after death, 90% of snags down within 14 years) combined with an unknown rate of public firewood gathering.

Irreversible/Irretrievable Commitments The snag resource will be abundant in the short term, and in the future may be limited as snags fall and the majority of the forest matrix is in a regenerating phase (consistent with natural snag “pulses” described for lodgepole pine forests by Bollenbacher and others, 2008).

3.8.4 Alternative 2 (Proposed Action)

With the Proposed Action, most snags would be removed within units. The snag resource outside of units will continue to be recruited by insect and other mortality agents; see the analysis for Effects Common to All Alternatives.

Little to no snag retention is desired inside treatment units; removal of hazardous dead trees is the purpose and need for the project. Dead trees that do not pose a hazard (i.e, leaning away from the road) would not be designated for removal; however, the Occupational Safety and Heath Administration requires logging contractors to fall any tree they identify as a safety hazard (OSHA Instruction CPL 2-1.19) so some of these trees may still be cut even if not designated for removal. Snag habitat is managed on the greater landscape through the retention of un-treated areas and retention of live trees for recruitment. Non-hazardous trees will be retained. Within units, there are inclusions of in-operable areas and buffers where snags would be retained. These areas will be identified at the time of layout and implementation. With intermediate harvest, a viable stand of live residual trees is retained after removal of hazardous trees. These live trees provide for snag recruitment. With regeneration harvest, most of the existing overstory is removed. It would not be site-specifically known the proportions of these treatment types until completion of layout; analyses assume the most impactive (regeneration treatments) would occur everywhere, and the actual effects will be less. No prescribed fire is planned aside from slash disposal, and so snag recruitment from fire is not anticipated.

Landscape levels of snags are likely to expand due to the MPB outbreak. Snag creation in untreated areas is expected to continue. Substantial portions of all drainages remain untreated with the Proposed Action. Additionally, the trees to be cut are the same trees available for firewood cutting under the No Action Alternative, and therefore resulting snag conditions are expected to be similar.

For more details about the snag analysis, please see the Forested Vegetation Specialists report.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 70 Table 3.10 Expected Snag Conditions Following the Proposed Action Trees Per Acre Proposed % Drainage Assessment of Remaining Snags 06-09 Treat Ac Untreated Snags Drainage Acres Beetle Kill (ADS) 0202 7,541 6.57 127 98.31% 0203 4,849 26.21 105 97.83% 0204A 6,834 50.02 195 97.15% 0209 4,020 8.09 244 93.94% 0212-1 13,971 28.99 786 94.38% 0212-2 1,741 36.83 2 99.92% 0212-3 3,159 60.17 14 99.56% Proposed treatments cover 0213 5,137 69.34 294 94.28% extremely small portions of these 0214 4,681 32.42 68 98.55% watersheds and snags from 0216 3,510 12.66 30 99.16% beetle mortality alone exceed FP 0310A 3,940 122.73 46 98.84% standard. Removal of some of the snag resource through narrow 0401-1 1,810 4.79 10 99.43% roadside treatments will not 0401-2 4,801 7.19 27 99.43% substantially reduce the snag 0402 9,650 13.06 315 96.74% resource across the watersheds. 0405 7,588 12.36 284 96.26% The same level of snag loss could 0705 4,876 101.15 232 95.25% be expected through the No Action alternative via firewood 0706 5,117 53.99 567 88.92% cutting. Additional snags from 0708A 5,001 22.95 18 99.64% older mortality agents are likely to 0710A 4,931 40.60 1 99.99% be present on these landscapes. 0710C 1,891 88.67 32 98.33% Adequate snags are expected to remain on the landscape in 0814 9,782 170.92 102 98.95% untreated areas. 0822 9,992 202.71 72 99.28% 0901 3,719 46.63 31 99.18% In a few watersheds, snags from 0904 12,674 9.22 10 99.92% recent beetle mortality alone do 1001-1 16,101 206.56 416 97.42% not meet or exceed the standard according to the available ADS 1001-2 3,367 413.44 97 97.13% data. In reality, there are likely 1001A 4,018 595.60 88 97.82% more snags present from older 1105-1 7,256 42.92 328 95.49% mortality causes or in areas not 1105-2 6,775 127.18 204 96.99% flown in 2006 and 2007. Most of these watersheds show snags 1106B 3,136 254.01 8 99.75% present on FIA grid intensification 1107 7,988 253.35 382 95.22% plots. Removal of snags through 1108-1 12,826 116.84 258 97.99% narrow roadside treatments will 1108-2 18,055 119.93 144 99.20% not substantially reduce the snag resource across these 1109 3,798 438.36 48 98.75% watersheds. The same level of 1110A 3,772 133.13 75 98.01% loss could be expected through 1111B 4,366 393.91 129 97.04% the No Action alternative via 1206-1 10,451 19.01 156 98.51% firewood cutting. Adequate snags are expected to remain on the 1303 2,368 61.78 57 97.58% landscape in untreated areas. 1306 6,475 49.92 168 97.41% 1309-1 2,602 9.23 1 99.97% 1309-2 4,960 13.72 211 95.75% 1309-4 2,342 0.71 20 99.14% 1309-5 5,666 5.32 183 96.76% 1310 3,212 2.63 63 98.04% 1312 1,359 1.52 24 98.27%

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 71 Trees Per Acre Proposed % Drainage Assessment of Remaining Snags 06-09 Treat Ac Untreated Snags Drainage Acres Beetle Kill (ADS) 1402-1 2,137 6.06 2 99.93% 1402-2 18,833 0.99 309 98.36% 1404 5,903 0.04 10 99.84% 1505-3 3,454 0.99 26 99.24% 1704F 3,280 12.34 147 95.51%

Irreversible/Irretrievable Commitments There are no irreversible or irretrievable commitments relative to the Proposed Action. The snag resource and dead-tree component would be largely removed within units. Treatment units (road segments and administrative sites) represent a very small percentage of the landscape and would not affect the larger forest matrix. Snags are continually recruited from live trees due to a variety of mortality factors. The removal of hazard trees represents a short term irreversible loss in snags but that loss is not irretrievable. The healthy live tree component of these areas would go unaffected.

Cumulative Effects Past harvest would have reduced the snag resource in some areas, and promoted live residual trees for snag recruitment in others. Fuels activity acres include prescribed burning, which would have created snags in some areas. Past wildfires across the Forest would have added further to the diversity of the landscape, with resulting conditions varying with fire severity and intensity. This activity would have created snags in affected areas.

Please see the cumulative effects appendix for a detailed listing of all past, ongoing, and reasonably foreseeable activities considered for this project. The impacts would be somewhat less than shown, as the final treatment acres is reduced from the 12,970 originally analyzed.

3.8.5 Conclusions The Forest Plan calls for snag management by the third order drainage, an optimum of 2/acre, primarily in MAs other than timber. Large snags >20" dbh are rare because live trees in that size class are also rare. The removal of snags in narrow roadside units would result in the same loss as would occur with No Action over time. For all watersheds, proposed treatments represent extremely small percentages of the total area. The snag resource is abundant due to insects and fire. Snag habitat and linkages are provided through non-treated areas. The area initially analyzed included 12,970 acres of proposed treatments; the lower amount of 9,416 acres is also consistent because fewer snags would be cut and a smaller percentage third order drainages would be treated. Proposed treatments are consistent with the Forest Plan, as shown in the following table.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 72 Table 3.11 Snag Forest Plan Consistency Forest Plan Standard (USDA 1986) Forest –Wide Hazardous Tree & Fuels Reduction Project Consistency Rationale See previous table. There are 50 3rd-order drainages associated with the project. Based on the quantity and locations of recently killed trees per ADS 2006 - 2009, all but 5 exceed this standard from beetle activity alone. The 5 drainages with < 2 beetle-killed trees/acre are: 1309-4; 1312; 1402-2; 1404; and 1505-3. In all of these but 1312 and 1505-3, snag estimates from grid plots exceed the standard. In 1505-3, the available data indicates about 1 snag/acre. However, only 26 acres are 1) The Forest Plan (1986) specifies that proposed for treatment, leaving > 99% of the drainage untreated. In snags should be managed at 70% of 1312, there are 1.52 snags/acre according to available data, and over optimum (2 snags/acre) within each third 98% of the remains untreated. The removal of snags will be miniscule in order drainage. this context. There are likely additional snags from other sources/timing of mortality. This assumption is supported by 2009 aerial photography (see project file, new information added after Objection period). Retention of non-hazardous snags (leaning away from the road) will be emphasized in prescriptions in these areas. In all areas, the percentage of drainages treated is extremely small and removal of snags in those units would not likely affect the snag average for the drainage. 2) Snag management guidelines need SMZs and BMPs are utilized in project design. As the Plan predicts, the not be applied within ¼ mile of riparian snag resource will not be materially affected in riparian areas. areas, because riparian standards should provide for adequate snags. 3) Larch, ponderosa pine, Douglas-fir, There is little to no larch present in proposed units. Spruce is rare and spruce, and subalpine fir, in that priority, mostly limited to riparian areas. Live spruce, ponderosa pine and are the preferred species for snags and Douglas-fir are favored residual tree species. Subalpine fir is present replacement trees (live trees left to and non-hazard trees of this species would be left as well. replace existing snags). The bulk of proposed treatments are in timber-emphasis management 4) Management areas other than T-1 will areas. It is appropriate to focus snag management on untreated areas, be the primary source for snags; in other management areas. Most affected drainages will remain over 90% untreated. 5) …however, if adequate snags This standard does not apply because adequate snags are found in cannot be found outside of T-1 then untreated areas (points 1 and 4). However its goals are considered the following numbers and sizes of snags where possible. The goal of 20 snags per 10 acres averages to 2/acre in should be retained in cutting units if the unit, plus 1/acre replacement trees. If the 2/acre snags are not available. available, then any combination of 3/acre is acceptable by the diameter In units with snags, keep a minimum of classes listed. While retention is not guaranteed due to OSHA, general 20 snags and 10 replacement trees per goals are prescribed: 10 acres, if available. If 20 snags are not - No lodgepole pine snag retention is desired. available, then any combination totaling - Snags > 20” leaning away from the road would be retained unless they 30 should be left by the following dbh pose a safety or feasibility concern. classes: - In most units, there would be reserve trees/patches and inoperable - 13 snags and 6 replacement trees 7-11” areas. The snag resource is naturally clumpy. - 5 snags and 3 replacement trees 12-19” - In intermediate harvest units, there would be trees in various size - 2 snags and 1 replacement tree 20+” classes for snag recruitment. 6) In units – except those of pure These snag retention guidelines need not be followed because adequate lodgepole - without snags keep a snags are found in untreated areas, (points 1 and 4). See the minimum of 30 wind firm trees per 10 description of tree retention for point 5. The Project is further consistent acres, if available, by the following dbh with the Forest Plan in that the units that will have very few residual trees classes: (regeneration harvest) are dominated by lodgepole pine, which are not o 21 trees from 7-11” considered windfirm or suitable for live tree snag recruitment. o 7 trees from 12-19” o 2 trees from 20+”

In addition to the Forest Plan, the project is consistent with considerations found in Estimates of Snag Densities for Eastside Forests in the Northern Region (Bollenbacher et al 2008). Snags should occur in a clumpy manner, and snag conditions/distribution are dynamic depending on

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 73 site, tree species, and seral stage. The distribution of snag size classes is consistent with the Forest Plan goals, and the natural snag levels found in roadless and wilderness areas shown by Bollenbacher and others (2008). The snag resource is experiencing a short term pulse due to the MPB epidemic; at this time lodgepole pine and some ponderosa pine snags are abundant and over time this will lessen as snags fall. Retention of live trees for recruitment is critical to provide for future snags that can provide habitat during the mid-seral stage in these forests when snags will be rare. Leaving live trees in intermediate harvest units will meet this goal. Increasing the vigor of treated areas helps ensure that trees are available for snag recruitment in the future after the current snag pulse is over and the snags existing today have fallen.

The general considerations from Northern Region Snag Management Protocol (USDA 2000) are also met. The protocol recommends that objectives for snag retention be assessed at the watershed scale; this assessment was done at the project area and third order drainage scale using ADS and FIA data. The protocol further recommends that snag prescriptions be applied at the stand scale; the prescription considerations listed in the table meet this intent. In order to avoid undue snag impacts timber harvest due to OSHA safety regulations, the protocol recommends specifying reserve areas in and around harvest units. The design of treated versus untreated areas meets this consideration.

3.9 Effects to Wildlife The analysis that follows confines itself to aspects of the environment that are of particular significance to wildlife. It by no means provides an exhaustive review of all the available habitat components. The tallies of wildlife species associated with different habitats come from personal observations in the project area, observations reported by other biologists and personnel, and studies summarized in the References section.

3.9.1 Assumptions, Information Used, and Methodologies/Scientific Accuracy The Assumptions, Information Used, and Methodologies/Scientific Accuracy (40 CFR 1502.15) Section pertains only to those habitats and species that are analyzed in the Wildlife Specialist Report. Appendix A of the Wildlife Specialists Report summarizes those habitats and species that are carried forward in this analysis and the rationale for those for which there will be no further discussion.

Much of the information presented in this analysis comes directly from field examination of the Forest wide Hazard Tree Removal and Fuels Reduction Project Area. Where direct observation of local habitat components or wildlife species was not possible, inferences were made from scientific literature, data from surrounding areas, and discussions with other biologists. The basic approach has been to begin with site-specific field data and then to use information from other sources, scientific research, and ecological theory to fill in data gaps and to provide a broader context for interpreting local wildlife patterns.

The analysis that follows confines itself to aspects of the environment that are of particular significance to wildlife. It by no means provides an exhaustive review of all the available habitat components. The tallies of wildlife species associated with different habitats come from personal observations in the project area, observations reported by other biologists and personnel, and studies summarized in the References section.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 74 The analyses of the habitats and species described in this report are characterized by different data sets: R1-VMAP (Version 2006), Forest Inventory and Analysis (FIA) base data, and FIA grid intensification data (which include base data). R1-VMAP (described in more detail in the Forested Vegetation Background Report) represents a broad scale, coarse filter type depiction as it relies on satellite imagery and describes three main vegetation components – canopy cover, tree dominance type, and stand size – among other parameters. R1 VMAP spatially represents habitats at the landscape level and within the Project Area. It also provides a context against which to identify treatment effects on a given habitat. The FIA base and intensified data are point data and generally include additional vegetation parameters not comprised in R1-VMAP. For example, snag and down wood habitat data are collected as part of point data but cannot be derived from R1-VMAP. The point data also provide an opportunity to refine and verify broad scale spatial data – i.e. R1-VMAP - and also provide baseline against which future management actions may be measured.

Information and assumptions common to all wildlife habitats and species are: • All calculations are based on proposed treatments on 9,416 acres. Originally, approximately 12,970 acres were proposed for treatments. However, additional analysis resulted in reduced treatment acres to accommodate resource needs. • All wildlife habitat calculations in this Report are based on the 2006 R1-VMAP imagery and may not reflect current levels of tree mortality that are the result of increased insect activity. See the Forested Vegetation Background report for more information. • The scale at which cumulative effects is measured varies among habitats and species. The respective scales are described in the Cumulative Effects section. • Past and ongoing land-use activities have various impacts on wildlife and/or their habitats. Some past activities never had or no longer have present effects to which the Proposed Action would add additional impacts. The impacts of some ongoing activities are reflected in the environmental baselines or never had an impact initially. • All species referenced occur or have potential habitat or potential to occur in the project area

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 75 Table 3.12 Assumptions, Information Used, and Methodologies Used to Determine Effects to Wildlife WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY Snags FIA data reports were used to summarize snags/acre by Forest Plan size Analyses are based on site specific classes using HNF Summary Database at the Forest, landscape, and third-order information and scientific literature. drainage scales. Methodologies and assumptions associated with these data See also the Forested Vegetation are described in the following documents: R1 Vegetation Council Classification Background Report for scientific accuracy Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – and methodologies associated with Field Procedures (USDA 2007a), R1 Multi-level Vegetation Classification, landscape level FIA data and FIA grid Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, intensification plots. Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods- proc/. See also the Forested Vegetation Background Report for additional information and assumptions. Connectivity The Region 1 Connectivity Protocol (USDA 1997) was used to set the context Analyses are based on site specific Dispersal, and identify those categories included in this analysis – i.e. dispersal, information and scientific literature. Migration, and migration, and travel corridors. Travel Corridors Fragmentation Fragmentation effects are based on the extent to which the proposed Analyses are based on site specific treatments expand the zone of fragmentation already created by the existing information and scientific literature. roads. Effects are described. Elk Elk herd units were developed in conjunction with Montana Fish, Wildlife, and Methodologies used to determine direct Parks (FWP) in the Big Belts. Where data were lacking for herd units, and indirect effects to elk are described boundaries were based on a mile and a half extension off-Forest. below. Summer range is assumed to be the entire elk herd unit except for the Effects to summer range are based on Greenhorn Elk Herd Unit for which a unique summer range has been identified hiding cover analyses derived from R1- during discussions between Helena National Forest staff and Montana VMAP, the Criteria for Wildlife Models Department of Fish, Wildlife, and Parks staff during development of the Army Helena National Forest Version June National Guard Biathlon proposal. 2009 (USDA 2009a), field validation, and cover board data collection. Winter range is based on range maps described in the Oil and Gas Leasing Environmental Impact Statement Helena National Forest and Elkhorn Mountains Effects to winter range are based on portion of the Deerlodge National Forest (USDA and USDI 1995) and Montana thermal cover analyses derived from R1- Fish, Wildlife, and Parks Elk Range Maps. VMAP and the Criteria for Wildlife Models Helena National Forest Version June Hiding cover and thermal cover data are derived from R1-VMAP (with the 2009 (USDA 2009a). Winter range maps exception of hiding cover in Sheep Creek and Prickly Pear Elk Herd Units and are in the project file; see metadata for the Spotted Dog Elk Herd Unit) based in part on the following documents: R1 process description. Vegetation Council Classification Algorithms (updated USDA 2006) and the R1 Hiding cover and open road densities

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 76 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System are analyzed relative to Forest Plan (USDA 2007b). Hiding cover and thermal cover calculations are based on the Standards and includes all roads open model runs Version December 2009. Hiding and thermal cover models are between 10/15 and 12/1. Roads are described in the Criteria for Wildlife Models Helena National Forest Version June weighted according to their expected use: 2009 (USDA 2009a). any road considered public is weighted by a factor of 1 (i.e. 1 mile =1 mile) whereas Hiding cover for Sheep Creek and Prickly Pear Elk Herd Units is based on cover any road considered private is weighted board data collected in those areas. Hiding cover for Spotted Dog is based on by a factor of 0.25 (i.e. 1 mile = 0.25 field investigation and analyses described in the project file. miles). This is based on research that Hiding cover based on R1-VMAP is compared against the MFWP indicates roads with less use have definition/thresholds in the Forest Plan. Hiding cover based on cover board and reduced impacts to elk (Perry and other field data is based on the Forest Plan definition/thresholds. Overly1976, Lyon 1979). Witmer and Road density information is derived from our INFRA database and Montana’s deCalesta 1985, Rowland et al. 2000). Roads database. Private roads are assumed to have less impact on elk than Private roads are assumed to receive less public roads. Rowland et al. (2000) examined the relationship of open, closed, use than public roads as they generally and administrative roads on elk habitat use. Administrative roads (restricted are only available for use the private vehicle use, not open to the public) are similar to private roads as far as vehicle landowner. use. Rowland et al. (2000) found that open roads have the greatest impact on Hiding cover for the Sheep Creek and elk habitat use. Based on this and other research (Perry and Overly1976, Lyon Prickly Pear Elk Herd Units was assessed 1979, Witmer and deCalesta 1985) this analysis assigns a weight of 0.25 to using 102 cover board survey points private roads. within 7 polygons. V-Map data were compared to determine which V-Map Elk survey data were provided by MFWP area biologists for Hunting Districts variables (size, crown closure, or cover (HD) 215, 281, 293, 335, 339, 343, 380, 391, 392, and 446. HD 390 is located type) explained the presence of hiding on the Forest however there aren’t any treatments proposed in that HD. cover or non-hiding cover. Those variables were extrapolated across each elk herd unit to identify hiding cover from non-sampled stands. Analyses are based on site specific information and scientific literature. Grizzly Bear The Blackfoot Landscape (Lincoln Ranger District) north of Montana Highway Roads proposed for treatments and for 200 is part of the Northern Continental Divide (NCDE) Grizzly Bear Ecosystem haul routes were calculated by grizzly Recovery Zone. The U.S. Fish and Wildlife Service has mapped the portion of bear subunits and within the grizzly bear the Blackfoot Landscape south of the Recovery Zone, as well as the Divide distribution zone. landscape (Helena Ranger District) southward to Mullan Pass, as mapped grizzly bear Distribution zone—a region of non-core habitat that, nonetheless, is

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 77 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY consistently (though sparsely) occupied by grizzlies. Grizzly bears are listed by the U.S. Fish and Wildlife Service as threatened in these areas. Grizzlies are reported in the Divide landscape south of Mullan Pass each year, but their numbers are very low and their status uncertain. Neither the Elkhorn nor Big Belt Ranges lie within a mapped grizzly bear distribution zone, and both landscapes are considered unoccupied—although transient grizzlies are reported on rare occasions in the Big Belts. The grizzly bears are present in the NCDE Recovery Zone and in the mapped grizzly bear distribution zone “where one would reasonably expect to find grizzly bear use occurring during any/most years, as of 2002” on the Helena Ranger District north of Mullan Pass and on the Lincoln Ranger District. Grizzly bear subunits were used as the basis for analyzing effects to bears within the NCDE (USDI 1993). The distribution zone is used as the basis for effects analysis outside of the NCDE and north of Mullan Pass. Canada Lynx The Helena National Forest Plan was amended March 2007 by the Northern Analyses are based on site specific Rockies Lynx Management Direction (NRLMD) (USDA 2007c). The NRLMD information and scientific literature. applies only to lynx habitat identified as occupied. The Big Belts and the Habitat maps are in the project file; see Elkhorns are considered unoccupied; therefore, the NRLMD does not apply to metadata for process description. those areas. Furthermore, lynx are not listed on the Helena National Forest Species List, prepared by the U.S. Fish and Wildlife Service, for the Big Belts and Elkhorns. The Divide portion of the Helena Ranger District and all of the Lincoln Ranger District are considered occupied and therefore subject to the NRLMD. However, in order to meet the NRLMD intent “Those …isolated portions of National Forests (…Helena), that presently are unoccupied by Canada lynx should consider the management direction that is now incorporated into their Forest Plans when developing projects, but are not required to follow the management direction until such time as they are occupied by Canada lynx” (p. 29), effects to lynx habitat in the Big Belts and Elkhorns will be disclosed as part of this analysis but will not be included in any consultation with U.S. Fish and Wildlife Service. Habitat estimates and maps are derived from R1-VMAP and Pfister et al. (1977). Methodologies and assumptions associated with these data are described in the following documents in addition to Pfister et al. (1977): R1 Vegetation Council Classification Algorithms (updated USDA 2006) and the R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 78 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY (USDA 2007b). Lynx habitat was originally mapped for the Helena National Forest circa 2000. Since that time, new data have become available from which an updated map has been generated. Potential habitat – i.e. coarse filter – continues to be mapped based on habitat types described by Pfister et al. (1977). Stand structure, once based on the Timber Stand Record Management System, is now described according to R1-VMAP attributes. Amounts of habitat have generally remained consistent between the two efforts. Discrepancies in acre figures are mainly associated with an increased accuracy in detecting vegetation life forms. Some stands that were originally classified as forested are actually grass or shrub life forms according to R1-VMAP which represents the most up to date information available. Lynx habitat calculations are based on the model runs December 2009. Lynx analysis unit boundaries have also shifted slightly since originally crafted in 2000. Changes are due to re-aligned unit boundaries along existing features such as ridge tops or other topographic features. The U.S. Fish and Wildlife Service (FWS) designated critical habitat for Canada lynx in the Federal Register on February 25, 2009 to take effect on March 27 2009. The critical habitat boundary is used to determine impacts to primary constituent elements. Fisher Data for fisher are derived from field surveys. Fisher surveys are based on the U.S. Habitat for fishers is based on information provided in Habitat Estimates For Rocky Mountain Fisher Survey Protocol Maintaining Viable Populations of the Northern Goshawk, Black-backed (Schwartz et al. 2006). Woodpecker, Flammulated Owl, Pileated Woodpecker, American Marten, and Analyses are based on site-specific Fisher (Samson 2006b). Habitat models used in Samson (2006b) are described information and scientific literature. in the Criteria for Wildlife Models Helena National Forest (USDA 2009a). Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, and the F12 Intensified Grid Summary Database. Methodologies and assumptions associated with these data are described in the following documents: Region One Vegetation Council Classification Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Snag and down log data are also used. See above for snag and down log

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 79 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY methods and assumptions. Black-backed Data used to analyze effects to habitat are based on the Black-backed Black-backed woodpecker surveys are Woodpecker Woodpecker Northern Region Overview - Key Findings and Project based on A Field Protocol to Monitor Considerations (USDA 2007e) and field surveys. Cavity Nesting Birds (Dudley and Saab Habitat for black-backed woodpeckers is based on information provided in A 2003) and Northern Region Landbird Conservation Assessment of the Northern Goshawk, Black-backed Woodpecker, Monitoring Program Field Methods (Avian Flammulated Owl, and Pileated Woodpecker in the Northern Region, USDA Science Center 2006). Forest Service (Samson 2006a) and Habitat Estimates For Maintaining Viable Effects to Snags and Down Logs are also Populations of the Northern Goshawk, Black-backed Woodpecker, Flammulated applicable to this analysis. The Owl, Pileated Woodpecker, American Marten, and Fisher (Samson 2006b). methodology to determine effects to Habitat models used in Samson (2006b) are described in the Criteria for Wildlife snags are described above under Snags Models Helena National Forest (USDA 2009a). and Down logs. Analyses are based on site-specific information and scientific literature. Flammulated Data used to analyze effects to habitat are based on field surveys. Flammulated owl surveys are based on Owl Habitat for flammulated owls is based on information provided in A Conservation the Northern Region Landbird Monitoring Assessment of the Northern Goshawk, Black-backed Woodpecker, Flammulated Program Flammulated Owl Protocol Owl, and Pileated Woodpecker in the Northern Region, USDA Forest Service (Avian Science Center 2005). (Samson 2006a) and Habitat Estimates For Maintaining Viable Populations of Effects to Snags and Down Logs are also the Northern Goshawk, Black-backed Woodpecker, Flammulated Owl, Pileated applicable to this analysis. The Woodpecker, American Marten, and Fisher (Samson 2006b). Habitat models methodology to determine effects to used in Samson (2006b) are described in the Criteria for Wildlife Models Helena snags are described above under Snags National Forest (USDA 2009a). and Down logs. Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, Analyses are based on site specific and the F12 Intensified Grid Summary Database. Methodologies and information and scientific literature. assumptions associated with these data are described in the following documents: Region One Vegetation Council Classification Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Snag and down log data are also used. See above for snag and down log methods and assumptions. Northern Data used to analyze effects to habitat are based on field observations and Goshawks surveys are based on the

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 80 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY Goshawk surveys. Northern Goshawk Inventory and Habitat for northern goshawks is based on information provided in A Monitoring Technical Guide (Woodbridge Conservation Assessment of the Northern Goshawk, Black-backed Woodpecker, and Hargis 2006). Flammulated Owl, and Pileated Woodpecker in the Northern Region, USDA Forest Service (Samson 2006a) and Habitat Estimates For Maintaining Viable Populations of the Northern Goshawk, Black-backed Woodpecker, Flammulated Owl, Pileated Woodpecker, American Marten, and Fisher (Samson 2006b). Habitat models used in Samson (2006b) are described in the Criteria for Wildlife Models Helena National Forest (USDA 2009a). Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, and the F12 Intensified Grid Summary Database. Methodologies and assumptions associated with these data are described in the following documents: Region One Vegetation Council Classification Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Home range analyses are based on Northern Goshawk Northern Region Overview: Key Findings and Project Considerations (USDA 2009c) and Reynolds et al. (1992). Pileated Data used to analyze effects to habitat are based on field observations and Pileated woodpecker surveys are based Woodpecker surveys. on the Northern Region Landbird Habitat for pileated woodpeckers is based on information provided in A Monitoring Program Field Methods (Avian Conservation Assessment of the Northern Goshawk, Black-backed Woodpecker, Science Center 2007). Flammulated Owl, and Pileated Woodpecker in the Northern Region, USDA Effects to Snags and Down Logs are also Forest Service (Samson 2006a) and Habitat Estimates For Maintaining Viable applicable to this analysis. The Populations of the Northern Goshawk, Black-backed Woodpecker, Flammulated methodology to determine effects to Owl, Pileated Woodpecker, American Marten, and Fisher (Samson 2006b). snags are described above under Snags Habitat models used in Samson (2006b) are described in the Criteria for Wildlife and Down logs. Models Helena National Forest (USDA 2009a). Analyses are based on site specific Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, information and scientific literature. and the F12 Intensified Grid Summary Database. Methodologies and assumptions associated with these data are described in the following documents: Region One Vegetation Council Classification Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 81 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Snag and down log data are also used. See above for snag and down log methods and assumptions. Hairy Data used to analyze effects to habitat are based on field observations and Hairy woodpecker surveys are based on Woodpecker surveys. the Northern Region Landbird Monitoring Hairy Woodpecker habitat models are derived from the R1 Draft Model Set All Program Field Methods (Avian Science Species (USDA 1998) and described in Criteria for Wildlife Models Helena Center 2007). National Forest (USDA 2009a). Effects to Snags and Down Logs are also Habitat estimates are based only on the R1-VMAP model runs December 2009 applicable to this analysis. The (based on 2006 imagery). Methodologies and assumptions associated with methodology to determine effects to these data are described in the following documents: Region One Vegetation snags are described above under Snags Council Classification Algorithms (USDA 2006), and R1 Multi-level Vegetation and Down logs. Classification, Mapping, Inventory, and Analysis System (USDA 2007b). Analyses are based on site specific Snag and down log data are also used. See above for snag and down log information and scientific literature. methods and assumptions.

American Data used to analyze effects to habitat are based on field observations and Effects to Snags and Down Logs are also Marten surveys. applicable to this analysis. The Habitat for American martens is based on information provided in Habitat methodology to determine effects to Estimates For Maintaining Viable Populations of the Northern Goshawk, Black- snags are described above under Snags backed Woodpecker, Flammulated Owl, Pileated Woodpecker, American and Down logs. Marten, and Fisher (Samson 2006b). Habitat models used in Samson (2006b) are described in the Criteria for Wildlife Models Helena National Forest (USDA Analyses are based on site specific 2009a). information and scientific literature. Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, and the F12 Intensified Grid Summary Database. Methodologies and assumptions associated with these data are described in the following documents: Region One Vegetation Council Classification Algorithms (updated USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Snag and down log data are also used. See above for snag and down log

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 82 WILDLIFE ASSUMPTIONS AND INFORMATION USED METHODOLOGIES AND SCIENTIFIC PARAMETER ACCURACY methods and assumptions. Viability Viability analyses are based on the Northern Region Viability Protocol (Samson Acre estimates for existing habitat for 1996) and the Draft White Paper on Managing for Viable Populations (USDA northern goshawks, black-backed 2001). Samson (2006a and 2006b) in A Conservation Assessment of the woodpeckers, flammulated owls, fisher, Northern Goshawk, Black-backed Woodpecker, Flammulated Owl, and Pileated marten, and pileated woodpeckers are Woodpecker in the Northern Region and USDA Forest Service Habitat Estimates derived by multiplying the percent habitat For Maintaining Viable Populations of the Northern Goshawk, Black-backed estimates by total forested acres on the Woodpecker, Flammulated Owl, Pileated Woodpecker, American Marten, and Helena National Forest (978,799 acres). Fisher summarizes the status of viability northern goshawks, black-backed Forest-wide acres are adjusted to reflect woodpeckers, flammulated owls, pileated woodpeckers, American martens, and impacts associated with hazard tree fishers: removal and then compared to thresholds Habitat models are derived from A Conservation Assessment of the Northern recommended by Samson (2006b). Goshawk, Black-backed Woodpecker, Flammulated Owl, and Pileated Viability analyses for hairy woodpeckers Woodpecker in the Northern Region, USDA Forest Service (Samson 2006a), are based on availability of snag habitat. Habitat Estimates For Maintaining Viable Populations of the Northern Goshawk, Hairy woodpeckers utilize similar habitats Black-backed Woodpecker, Flammulated Owl, Pileated Woodpecker, American as black-backed woodpeckers and Marten, and Fisher (Samson 2006b), and Criteria for Wildlife Models Helena additional habitats. National Forest (USDA 2009a). See those documents for methods and Viability analyses for elk include an assumptions. examination of the abundance and Habitat estimates and maps are derived from R1VMAP, R1 Summary Database, distribution of elk habitat. Elk viability is and the F12 Intensified Grid Summary Database. Methodologies and largely determined through hunting assumptions associated with these data are described in the following quotas which is outside the scope of this documents: Region One Vegetation Council Classification Algorithms (updated project. USDA 2006), R1 Grid Intensification using CSE Protocols – Field Procedures Habitat maps are in the project file; see (USDA 2007a), R1 Multi-level Vegetation Classification, Mapping, Inventory, and metadata for process description. Analysis System (USDA 2007b), and FIA Field Guides, Methods, and Procedures at http://fia.fs.fed.us/library/field-guides-methods-proc/. Wildlife habitat calculations are based on the R1-VMAP model runs Version December 2009 (based on 2006 imagery).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 83 Design Criteria/Mitigation Measures Goshawk – No nests have been identified in the project treatment areas. However, should a nest be discovered prior to or during project activities, ground disturbing activities would be restricted inside the post fledgling area (approximately 420 acres surrounding the nest) from 15 April through 15 August to protect the goshawk pair and young from disturbance during the breeding season until fledglings are capable of sustained flight. For new active goshawk nests, a no treatment buffer of a minimum of 30 - 40 acres would be maintained around nest trees to maintain existing conditions in the nest stand (Reynolds et al 1992, Clough 2000).

An active nest was located on the Lincoln Ranger District about 60 meters from Forest Service Road 1163. The nest was located on 7/7/2009 and had three young in the nest at that time. The nest was subsequently re-visited on 7/26/2009 and had apparently succumbed to a wind storm. Given the site fidelity that goshawks exhibit, it’s highly likely that these goshawks would nest in the vicinity in out years. Mitigation measures that are in place should minimize impacts of the Project. This includes surveying the general vicinity for goshawks prior to project implementation.

Grizzly Bears – Treatments and hauling on roads in the Northern Continental Divide Ecosystem will occur during the open road period of use. Treatments and hauling on roads in the mapped Grizzly Bear Distribution Zone will occur during the open road period of use except for the Stemple Pass Ski Trail that is closed year round. Treatment and hauling will occur within administrative levels on the ski trail or during the denning season if possible.

General Raptor Nests - No activity buffers of approximately 30 acres will be established for any raptor nests identified during treatments.

Elk – All hazard tree removal is designed to take place on roads that are currently open at some time during the year (except for the Stemple Pass Ski Trail). Treatment and hauling will not occur during the big game hunting season road closures.

3.9.2 Affected Environment

Introduction & Analysis Areas This assessment takes into account those wildlife habitats and species that are likely to be measurably affected by the proposed action. It also emphasizes issues that have drawn public comment. The discussion includes habitats beyond the immediate vicinity of the treatment areas as needed to accurately portray the character of the local wildlife resource.

Appendix A in the Forest wide Hazard Tree Removal and Fuels Reduction Project Wildlife Specialist Report summarizes the analysis approach taken for each parameter and/or species. Not all species are analyzed in detail in the following report. Appendix A provides the rationale for species carried forward.

All of the habitat data and potential effects are based on vegetation data described in the Forested Vegetation Background Report.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 84 The Forest wide Hazard Tree Removal and Fuels Reduction Project Area was used as the basic analysis area. However, because the project area consists of several isolated treatment areas forest-wide and because some wildlife species move well beyond the boundaries of these areas (e.g. elk, lynx), different analysis areas are necessary to accurately describe impacts to those species and habitats included in the analysis.

The wolf has recently been relisted as endangered west of I -15 and experimental to the east. Therefore it has been re-analyzed as a listed species in Appendices A and B.

3.9.1 Regulatory Framework

Viability is addressed at the Planning Area level, which in this case is the Helena National Forest (929,860 acres) Species with high mobility and/or widespread habitat are also analyzed at the Helena National Forest scale. These include: fisher, flammulated owl, black-backed woodpeckers, northern goshawks, pileated and hairy woodpeckers, and American marten. The Landscape - The Helena National Forest is divided into 4 landscapes. These areas are described in the Elkhorns, Big Belts, Blackfoot, and Divide Integrated Resource Analyses. The Big Belts Integrated Resource Analysis area (or “landscape”) covers approximately 308,467 acres of National Forest lands on the Townsend and Helena Ranger Districts. The Elkhorns landscape covers roughly 129,550 acres, also on the Townsend and Helena Ranger Districts. The Divide landscape covers 202,462 acres, entirely on the Helena Ranger District, and the Blackfoot landscape covers 332,478 acres, entirely on the Lincoln Ranger District.

The Elk Herd Unit - This project area includes 7 elk herd units in the Divide landscape, 4 herd units in the Elkhorns landscape, 10 herd units in the Big Belts landscape, and 8 herd units in the Blackfoot landscape. (See Figure 1 Elk Herd Units Helena National Forest). Boundaries are based on seasonal elk movement and use patterns as determined by Montana Fish, Wildlife and Parks personnel and Helena National Forest Wildlife Staff. They include all land, public and private, within National Forest administrative boundaries plus an extension of at least 1.5 miles onto non-Forest land beyond the boundaries. They cover the area likely to be occupied by elk tied to National Forest lands yearlong (including winter). Elk herd units are used to determine impacts to summer and winter ranges. In particular, they are used to calculate compliance with Helena Forest Plan (HFP) big game standards #2 and #3 relating to cover analyses on seasonal elk ranges (HFP, p. II/17).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 85

Figure 3.1 Elk Herd Units Helena National Forest

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 86 The Lynx Analysis Unit - This is the area used to determine effects to mapped lynx habitat in the project area and equates to an approximate female home range (See Figure 3.2 Lynx Analysis Units and Lynx Critical Habitat Helena National Forest). Lynx Critical Habitat - This is the area used to determine impacts to lynx critical habitat and encompasses approximately 429,275 acres (See Figure 3.2).

Figure 3.2 Lynx Analysis Units and Critical Habitat Helena National Forest

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 87 Northern Continental Divide Ecosystem (NCDE) Recovery Zone Grizzly Bear Subunits - These are the areas within the NCDE Recovery Zone within which effects to grizzly bears are analyzed (See Figure 3 Northern Continental Divide Ecosystem Grizzly Bear Subunits and Mapped Grizzly Bear Distribution Zone Helena National Forest).

Mapped Grizzly Bear Distribution Zone - This is the area outside of the NCDE that extends from the NCDE to Mullan Pass on the Helena Ranger District within which effects to grizzly bears are analyzed (See Figure 3.3).

Figure 3.3 Grizzly Bear NCDE Subunits and Mapped Grizzly Bear Distribution Zone

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 88 3.9.2 Wildlife Issues Primary wildlife issues for the Forest-wide Hazard Tree Removal and Fuels Reduction Project are: • The impacts to snag habitat associated with the removal of hazard trees • The extent to which the removal of hazard trees exacerbates existing fragmentation associated with roads and compromises dispersal, migration, and travel corridors • The effects of hazard tree removal on elk hiding and thermal cover • The effects of hazard tree removal on grizzly bears • The effect of hazard tree removal on lynx habitat • The effect of hazard tree removal on other TES and MIS species

Issue: Snags Snags and their management have become a major conservation issue in managed forests. While it’s been long recognized that snags provide essential wildlife habitat, research increasingly underscores the need to understand snags as part of a larger interacting ecosystem (Bull et al. 1997, Duncan 1999, Rose et al. 2001).

Snags are an important habitat element for several wildlife species (Bull et al. 1997, Rose et al. 2001). We generally think of snags as providing nesting and foraging habitat (Thomas 1979); however, snags meet a variety of behavioral and physiological needs for a variety of species. These include but aren’t limited to singing, viewing, perching, estivating, communicating, escaping, hibernating, resting, and observing (Davis 1983).

Current Condition Snag conditions across the Forest are assessed using a variety of data, including aerial detection flights and FIA plots. Snag data summarized in Wilson (2001) indicated that the Forest has approximately 4.5 snags/acre. Since that time, the Forest has installed grid-intensification plots that provide additional data. The following table summarizes the status of snags both at the Forest and landscape scales. Plots where fire or harvest occurred have been excluded from the analysis; therefore, the estimates are most likely conservative. These data are derived from the Helena National Forest Summary Database.

Table 3.13 Snag Size Class Averages (TPA) Forest-wide and by Landscape1 Size Class Forest-Wide Big Belts Blackfoot Divide Elkhorns Landscape Landscape Landscape Landscape 20”+ dbh 1.2 1.4 1.5 0 2 12-20” 6.5 4.6 10.6 3 5.4 7-12” dbh 26.1 19.8 38.3 17.3 21.2 1Confidence intervals are in the project file.

The analyses in the table Snag Size Class Forest-wide and by Landscape indicates that few large snags (>20”) occur both Forest-wide, and within in the respective landscapes. An analysis of live trees per acre at the 20+ dbh level is summarized in the table Live Trees by Size Class Forest-wide and by Landscape and indicates that it’s possible to achieve some of the target goals.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 89 Table 3.14 Live Trees (TPA) by Size Class Forest-wide and by Landscape1 Size Class Forest-Wide Big Belts Blackfoot Divide Elkhorns Landscape Landscape Landscape Landscape 20”+ dbh 2.9 2.9 2.2 4.5 1.7 1Confidence intervals are in the project file.

Estimates of Snag Densities for Eastside Forests in the Northern Region In 2000, the Northern Region Snag Management Protocol provided optional snag retention standards which were based on using FIA data from western Montana forests. However, the Protocol specifically recognized that FIA data from northern Idaho and eastern Montana were not used in the Protocol, as it was not available at the time. FIA data are now available and the data for the eastside Forests in this paper provide the most current snag data available.

The 2000 Protocol specifically provided that when local data are available or are considered better than the sources used in the Protocol, Forests have the option to use those data sets. The Estimates of Snag Densities for Eastside Forests in the Northern Region (USDA 2008) provides a replacement for the Northern Region Snag Protocol for eastside Montana forests in Region 1.

The table Mean Snag Densities Per Acre by Diameter Class, Inside and Outside of Wilderness/Roadless Areas for the Helena National Forest is excerpted from the Estimates of Snag Densities for Eastside Forests USDA 2008) and provides snag estimates on the Forest based on FIA data. The differences between this table and Snag Size Class Averages (TPA) Forest-wide and by Landscape are due to (1) the previous table is categorized according to Forest Plan snag groupings, and (2) that table is based on both FIA and intensified grid data.

Table 3.15 Mean Snag Densities per Acre by Diameter Classes, Inside and Outside of Wilderness/Roadless Areas for the Helena National Forest Area Snags per Acre Snags per Acre Snags per Acre 10”+ 15”+ 20”+ In Wilderness/ Roadless 10.1 0.9 0.2 Outside Wilderness/ 5.0 1.2 0.4 Roadless As shown by in the table, the larger the snag, the less common it is. This is largely due to less trees living to an older age; as trees age, they grow slower, never reaching very-large diameters, and the inability of systems to contain large old trees and snags due to various types of disturbance agents which kill and remove them over time.

The Forested Vegetation Background Report provides an in-depth analysis of existing snags Forest-wide. Snag availability is characterized by the recent Estimates of Snag Densities for Eastside Forests in the Northern Region (USDA 2008), by 3rd order drainages, and as a result of recent fires and mountain pine beetle outbreaks. These analyses indicate that snags are abundant and well –distributed Forest-wide.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 90 Issue: Connectivity – Dispersal, Migration, and Travel Corridors Connectivity as coined in 1984 by G. Merriam (cited in USDA 1997) refers both to the abundance and spatial patterning of habitat and to the ability of animals to move from patch to patch of similar habitat. Corridors are a means by which connectivity is provided and are defined as strips or stepping stones of ‘hospitable territory traversing inhospitable territory providing access from one area to another” (Dendy 1987 as cited in USDA 1997). The effectiveness of a corridor depends upon the species in question, the type of movement, and the type of corridor. Animals need connectivity to forage within its home range, for dispersal to new home ranges, and for migration between locations.

The Big Belts and the Continental Divide complex on the HNF, along with surrounding areas, historically acted as corridors for many different species migrating along the Rocky Mountain Front (ex. bison, grizzlies, lynx, and wolves) (Craighead 2002). Prior to development by Europeans, areas surrounding these ranges provided more of a linkage than the mountains themselves. As indicated in the journals of Lewis and Clark and documented archeologically, large herds of bison moved through the Smith River and Missouri River valleys. Large predators that preyed upon the ungulates also moved through the valleys. Today, options for movement in the valleys have been eliminated through human development, which has placed an emphasis on the mountain ranges (primarily, undeveloped National Forest lands) to provide connectivity.

Both the Big Belts and the Continental Divide have some limitations in their ability to provide connectivity. These ranges are inherently fragmented landscapes of alternating grasslands and forest with riparian areas serving as primary movement corridors. Roads and early mining in riparian areas have disrupted these corridors. Furthermore, the northern portion of the Big Belt range lacks abundant water sources which may render that area less attractive as a corridor. However, both ranges still provide linkage for a variety of species including some of the continental migrant birds and potentially for wolves and grizzly bears as they expand their range (Craighead 2002).

Regional connectivity through the Blackfoot landscape is less well defined, with its northern portion serving as a source area for migrants and its southern linkage areas much wider and less linear than the Big Belts and Divide landscapes. Elsewhere on the Forest, the Elkhorn Mountains are essentially an island range, surrounded by settled valleys and open country, and thus have limited value as a viable linkage zone.

Connectivity as a concept is being increasingly explored in conservation. While there is no empirical evidence to support the concept of corridors (Rosenberg et. al. 1997) many conceptual models have been built to project connectivity across landscapes (Walker and Craighead 1997, Noss 1991 as cited in Noss et al. 1996).

Walker and Craighead (1997) modeled the potential for current use of the Big Belts as a corridor between the Greater Yellowstone and Northern Continental Divide Ecosystems. They concluded that the Big Belts, in conjunction with other ranges offered the best chance for successful transit between these ecosystems. The Continental Divide was seen as a less viable connection across the Helena Forest because of relatively high open road densities. In addition, the Forest Service Northern Region Overview (USDA 1999) Terrestrial Subgroup has recommended that ten linkage zones in the Northern Rocky Mountains be established to facilitate movement to ensure

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 91 populations are well distributed across the area. The Upper Missouri River valley and the Big Belt Mountains were identified as one such linkage zone.

The Northern Region Connectivity Protocol (USDA 1997) provides a framework within which to describe corridors and subsequent project effects. Of the five types of corridors outlined in the protocol, one has been dismissed from this analysis. Biogeographic corridors exist at a continental spatial scale and are appropriate during discussions of evolution and species distribution. This scale is not appropriate for this analysis. Invasive corridors may be applicable to this project. This type of corridor allows exotic or alien species to extend their ranges in non- historical distributions and usually to the detriment of resident species. A faunal example of this may include the raccoon; a floral example may include noxious weeds. The effect of noxious weed spread by roads and travel systems will be analyzed under the noxious weed specialist report.

The season migration or cyclic corridor facilitates ecological survival across local and elevational spatial scales. This type of movement is seasonal in nature and is of importance for several wildlife species in the Big Belts (e.g. big game, wolverine, and other carnivores). However, the effectiveness of the corridor as a season migration corridor is questionable since the corridor is identified at elevations that may not be conducive to fall/winter migration.

The other two corridor types that apply to this analysis include the dispersal and emigration and travel corridors. The dispersal and emigration corridor type promotes dispersal into unoccupied habitats. Dispersal behavior is most common when population density is too high within an area to support the population. This results in the natural colonization of suitable but unoccupied habitat. This type of corridor can only include habitats consistently capable of supporting and/or contributing to a stable population. This assumption emphasizes the importance of linkages between suitable habitats that would sustain dispersing individuals from a population between areas of colonization.

The amount of existing development in the form of highways, subdivisions, towns, and natural barriers makes the effectiveness of dispersal and emigration corridors questionable. Local transportation systems on the National Forest do play a role in the ability of wildlife species to utilize these potential corridors. As further development on adjacent private lands continues at this dispersal and emigration scale, barriers will continue to expand and become more rigid for those species that avoid human presence at some time of the year. The Big Belt Mountain range does provide linkages between ecosystems and meta-populations as well as serve as local refugia at the landscape-wide and local scale.

The travel corridor provides individuals within a home range the daily life history requirements for reproduction and growth. Travel corridors are loosely defined in the Regional Protocol as travel within a home range required to meet annual life history requirements. These corridor types may also include local refugia for smaller species or species with smaller home range size.

The efficacy of corridors remains largely untested although research does support the need for dispersal and migration habitat for various species. Region One developed the aforementioned Connectivity Protocol as a way of ensuring consistent application region-wide.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 92 Current Conditions Local barriers to movement exist within the project area as a result of open roads and changes in vegetation composition and structure. Depending on the wildlife species, time of year, habitat, climatic conditions, and/or levels of human disturbance, these barriers may or may not deter the project area from serving as a travel, dispersal and emigration, or seasonal migration or cyclic corridor.

Issue: Fragmentation Fragmentation is generally considered a change in landscape structure that leads to smaller patch sizes, less interior habitat, and greater distances between patches which in turn can lead to subpopulation isolation (Reed et al. 1996, Tinker et al. 1998, Temple and Wilcox 2000). It is generally attributed to human activity rather than to natural disturbances.

Fragmentation has two components: reduction of total available habitat and apportionment of remaining habitat into smaller, more isolated patches (Pages 237-264 in Meffe and Carroll 1994). Fragmentation can affect animal populations by decreasing species diversity and densities due to creation of smaller patches of habitat. Fragmentation is not simply the creation of habitat islands. There are many degrees and scales of fragmentation. It is a process with unpredictable thresholds, not simply an either / or condition.

Fragmentation has often been addressed by various researchers as it relates to neotropical migrant birds and loss of forest interior habitat (Faaborg et al 1993 and other authors cited in the paper, Dobkin 1994). Forest fragmentation can affect forest interior birds by direct habitat loss, increase of edge habitat and edge effects, and isolation of forest fragments (Faaborg et al 1993, Dobkin 1994).

Current Conditions The Project Area is characterized by forested stands in places interrupted by sagebrush or grasslands. Aspen stands occur sporadically throughout the project area also. These conditions contribute to the natural fragmentation of the landscape. Past harvest activity and roads in the project area has additionally fragmented the landscape. Some wildlife species thrive in fragmented landscapes – natural or human-caused - while others are strongly associated with large blocks of contiguous habitat, regardless of the lifeform (e.g. tree, shrub, grassland).

Issue: Elk Elk serve as a management indicator for hunted species. They are managed to achieve particular population goals. Elk are one of the more manageable species because their habitat requirements are well studied and they respond to habitat and population management (Cooperrider 2002). Elk are very adaptable and occur in a variety of habitats ranging from high mountainous areas to highly managed forests to cold deserts (Skovlin et al. 2002). Elk used to be widespread prior to the settlement of North America. However, due to habitat alterations and extirpation from areas of human settlement elk are now found primarily in coniferous forests (Skovlin et al. 2002).

Management for elk and elk habitat has become increasingly more complex as human activities affect habitat quality and access. Managing for elk requires maintaining quality habitat AND

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 93 meeting public demands – meeting basic elk habitat requirements AND understanding the socioeconomic value of elk. Primary considerations in elk management include (Lonner 1991): • Maintaining habitat security to protect elk during the hunting season • Preserving/recovering desired elk population characteristics as determined by elk managers and distributions relative to land management • Satisfying the growing demand for quality hunting and non-hunting experiences

Methodologies have been developed that measure elk vulnerability – the relationship between elk and land management practices and the demand for elk hunting and non-hunting experiences. These methodologies generally reflect seasonal habitat needs. These different seasonal habitat needs are the focus of the affected environment discussion and include summer range habitat requirements, hiding cover during the hunting season, and winter range habitat requirements.

Elk extensively use the Forest during spring, summer, and fall. During the spring, elk distribution is dependent on the availability of new forage and therefore fluctuates year to year based on snow melt. During the summer, elk use the mountain range widely although as summer continues, higher elevations of cool, moist, areas are frequently used. Elk winter range generally occurs at lower elevations—often on private lands—and on south facing slopes where shallow snow depths allow access to forage throughout the winter.

Current Conditions Elk Summer Range Summer range comprises an entire elk herd unit with the exception of the Greenhorn Herd Unit where summer range has been refined based on efforts between Helena National Forest staff and Montana Fish, Wildlife, and Parks (See Assumptions, Information Used, and Methodologies /Scientific Accuracy Section for more information). Hiding cover is important on summer range as it provides opportunities for birthing areas and escape cover. The table Acres of Forest Plan Hiding Cover on Elk Summer Range by Elk Herd Unit summarizes the amount of Forest Plan hiding cover by summer range per EHU as well as whether the current conditions meet Forest Plan standards for hiding cover1 for those EHUs within the project area. Not all of the EHUs across the Forest are located within the project area.

Data for Forest Plan hiding cover are only available within the cover extent of R1-VMAP which extends approximately one mile beyond the Forest Boundary. In some places, Forest Plan hiding cover may therefore be underestimated. Forest Plan Standard 3 is met on 10 EHUs (out of 27).

1 Subject to hydrologic and other resource constraints, elk summer range will be maintained at 35 percent or greater hiding cover and areas of winter range will be maintained at 25 percent or greater thermal cover in drainages or elk herd units (USDA 1986, p. II/17). Note that since all of the herd units except Prickly Pear and Sheep Creek are based on R1-VMAP, the threshold for this standard is based on the Montana Fish, Wildlife, and Parks levels. In other words, summer range within all herd units except for Prickly Pear and Sheep Creek need to comprise 50% or greater hiding cover. The threshold for Prickly Pear and Sheep Creek remains at 35% since cover board data were collected which align with the Forest Plan definition – i.e. the ability of a stand to hide 90% of an elk at 200 feet.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 94 Table 3-16 Acres of Forest Plan Hiding Cover on Elk Summer Range by Elk Herd Unit (EHU) Elk Herd Unit Total Acres Forest Plan Percent Forest Meets Forest Plan Summer Hiding Cover Plan Hiding Cover Standard #3 Range1 Acres in EHU Summer Range Arrastra 27,738 13,018 0.47 No Atlanta 20,517 12,909 0.63 Yes Battle Mountain 33,967 4,727 0.14 No Beaver Creek-Lincoln 32,406 18,807 0.58 Yes Birch Creek 17,293 12,166 0.70 Yes Black Mountain – 56,339 Brooklyn Bridge 29,815 0.53 Yes Cabin Creek 37,618 16,943 0.45 No Flesher Pass 91,093 38,571 0.42 No Greenhorn 30,330 16,727 0.55 Yes Greyson 33,894 1,721 0.05 No Hedges 52,368 16,795 0.32 No Hellgate 31,999 5,079 0.16 No Jericho 35,345 22,309 0.63 Yes Keep Cool 44,325 17,010 0.38 No Landers Fork 136,515 62,178 0.46 No Little Blackfoot 34,837 25,869 0.74 Yes Little Prickly Pear – 87,022 Ophir 39,865 0.46 No Nevada Creek 38,824 22,959 0.59 Yes North Fork 25,828 3,936 0.15 No Ogden Mountain 56,310 26,419 0.47 No Poorman Creek 67,425 40,980 0.61 Yes Prickly Pear 31,051 3,429 0.11 No Quartz 36,733 16,483 0.45 No Ray Creek 44,885 12,437 0.28 No Sheep Creek 43,848 4,681 0.11 No South Crow 32,586 7,238 0.22 No Spotted Dog 47,477 19,564 0.41 Yes 1Summer Range comprises the entire elk herd unit so acres are the same with the exception of the Greenhorn EHU wherein summer range is a subset of the entire elk herd unit.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 95 Hiding Cover/Open Road Densities Table 3.17 Forest Plan Hiding Cover/Open Road Densities During the hunting season, management of elk includes balancing the need to provide Forest Plan Hiding Cover/Open Road Densities 1 for and protect certain sex and age classes Percent Hiding Cover Maximum Open Road of elk and to provide hunting opportunities. Density 80 2 While these parameters are a management 2.4 mi/mi 70 2 function of Montana Fish, Wildlife, and 1.9 mi/mi 60 2 Parks, the Helena National Forest strives to 1.2 mi/mi 50 2 compliment these objectives through 0.1 mi/mi management of open road densities relative 1 This column corresponds to the Montana Department Fish, to the amount of hiding cover in an elk herd Wildlife, and Parks definition/thresholds in the Forest Plan. See unit. The table Forest Plan Hiding Forest Plan II/18 for the Forest Service definition/thresholds. Cover/Open Road Densities summarizes the Forest Plan standards based on Montana Fish, Wildlife, and Parks definition and thresholds.

The table Elk Herd Unit Data for Hiding Cover and Open Road Density summarizes the amount of Forest Plan hiding cover by elk herd unit (EHU), associated open road densities during hunting season, and whether the current conditions meet Forest Plan standards for hiding cover/open road densities.3 Five of the EHUs meet Forest Plan Standard 4(a).

Table 3.18 Elk Herd Unit Data for Hiding Cover and Open Road Density Elk Herd Unit Total Total Acres Percent Miles Open Open Road Meets Forest Square Forest Plan Forest Road during Density Plan Standard Miles Hiding Plan Hunting During #4a EHU Cover by Hiding Season by Hunting EHU Cover by EHU Season by EHU EHU Arrastra 43 13,018 0.47 76.9 1.77 No Atlanta 32 12,909 0.63 9.7 0.30 Yes Battle Mountain 53 4,727 0.14 49.7 0.94 No Beaver Creek- Lincoln 51 18,807 0.58 75.7 1.49 No Birch Creek 27 12,166 0.70 17.6 0.65 Yes Black Mountain – Brooklyn Bridge 88 29,815 0.53 166.4 1.89 No Cabin Creek 59 16,943 0.45 48.3 0.82 No Flesher Pass 142 38,571 0.42 182.4 1.28 No Greenhorn 88 16,827 0.30 154.6 1.76 No Greyson 53 1,721 0.05 64.4 1.22 No Hedges 82 16,795 0.32 86.6 1.06 No Hellgate 50 5,079 0.16 37.1 0.74 No Jericho 55 22,309 0.63 67.6 1.22 Yes Keep Cool 69 17,010 0.38 62.2 0.90 No

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 96 Elk Herd Unit Total Total Acres Percent Miles Open Open Road Meets Forest Square Forest Plan Forest Road during Density Plan Standard Miles Hiding Plan Hunting During #4a EHU Cover by Hiding Season by Hunting EHU Cover by EHU Season by EHU EHU Landers Fork 213 62,178 0.46 106.4 0.50 No Little Blackfoot 54 25,869 0.74 36.1 0.66 Yes Little Prickly Pear – Ophir 136 39,865 0.46 220.2 1.62 No Nevada Creek 61 22,959 0.59 58.1 0.96 Yes North Fork 40 3,936 0.15 50.0 1.24 No Ogden Mountain 88 26,419 0.47 143.9 1.64 No Poorman Creek 105 40,980 0.61 201.4 1.91 No Prickly Pear 49 3,429 0.11 32.3 0.67 No Quartz 57 16,483 0.45 61.7 1.07 No Ray Creek 70 12,437 0.28 60.5 0.86 No Sheep Creek 69 4,681 0.11 49.7 0.73 No South Crow 51 7,238 0.22 44.6 0.88 No Spotted Dog 74 19,564 0.41 111.8 1.51 No 3 Implement an aggressive road management program to maintain or improve big game security (p. II/17). The existing hiding cover to open road density should be determined over a large geographic area, such as a timber sale analysis area, a third order drainage, or an elk herd unit (p. II/18). See Assumptions, Information Used, and Methodologies/Scientific Accuracy Section for more information. 4 Our open road density calculations are more conservative than the Forest Plan intended since we are weighting local roads by a factor of one rather than by a factor of 0.25 which is the factor upon which the Plan was crafted.

Elk Winter Range Winter range is an important element of elk habitat. Areas with minimal human activities and adequate forage will reduce the energetic costs associated with overwinter survival. Winter range is analyzed at the elk herd unit (EHU) level. The table Acres of Forest Plan Thermal Cover on Elk Winter Range by Elk Herd Unit summarizes the amount of Forest Plan thermal Cover by winter range per EHU as well as whether the current conditions meet Forest Plan standards for thermal cover (See footnote 1). Data for Forest Plan thermal cover are only available within the cover extent of R1-VMAP which extends approximately one mile beyond the Forest Boundary. In some places, Forest Plan thermal cover may therefore be underestimated.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 97 Table 3.19 Acres of Forest Plan Thermal Cover on Elk Winter Range by Elk Herd Unit (EHU) Elk Herd Unit Total Acres Winter Range Forest Plan Percent Forest Meets Forest EHU Acres Thermal Cover Plan Thermal Plan Standard Acres Cover in EHU #3 Winter Range Beaver Creek- 32,406 8,895 379 0.043 No Lincoln Birch Creek 17,293 2,838 322 0.114 No BlackMountain– 56,339 47,980 6,527 0.136 No Brooklyn Bridge Flesher Pass 91,093 23,236 526 0.023 No Greenhorn 56,314 48,676 2,143 0.044 No Greyson 33,894 25,051 97 0.004 No Jericho 35,345 10,148 1,302 0.128 No Keep Cool 44,325 8,924 152 0.017 No Little Prickly Pear 87,022 33,894 2,299 0.068 No – Ophir Nevada Creek 38,824 19,507 1,207 0.062 No Ogden Mountain 56,310 25,363 1,025 0.040 No Poorman Creek 67,425 35,736 2,048 0.057 No Quartz 36,733 19,755 1,423 0.072 No

Very little thermal cover is present in a majority of the EHUs; therefore, no EHUs meet Forest Plan Standard 3 for thermal cover. Regardless, recent research indicates that classic thermal cover (conifer stands more than 40 feet tall with canopy closure of at least 70%) is probably of little or no value to wintering elk (Cook et al. 1998, p. 41-48). This is due to the fact that elk are better able to maintain body condition by taking advantage of solar radiation in open habitats. In addition, recent studies on Montana winter range indicate that, when in forest habitats, elk prefer stands with more open or patchy canopies capable of supporting suitable forested forage (Thompson et al. 2005). Forage in dense thermal cover stands is usually too sparse to sustain elk during severe winter conditions.

Elk Population Information Elk occurred across much of North America prior to European settlement. By the early 1800s, subsistence, market, and hide hunting almost eliminated elk east of the Mississippi River. By 1910, there were fewer than 50,000 elk in North America. As a result of management, elk increased across the west and in Montana. Statewide post-season elk numbers increased from 8,000 in 1922 to 55,000 in 1978 to about 160,000 in 2005 (MFWP 2005, pp. 4-5). These figures illustrate the distribution and expansion of elk in Montana for 1940, 1970 and 1999. Figure 3.3 Elk distribution in the 1940s

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 98 Figure 3.4 Elk distribution in the 1970s Figure 3.5 Elk distribution in 1999

Elk Management Unit Synthesis The project area comprises seven Elk Management Units (EMU) as defined in the state-wide Montana Elk Plan (MFWP 2004). The table Elk Management Units and Associated Hunting Districts summarizes that information. Not all of the Hunting Districts (HD) within each EMU are proposed for hazard tree removal; however, since population objectives may be grouped, all applicable HDs are listed.

The Montana Final Elk Management Plan January 2005 provides detailed information on each EMU relative to goals, objectives, and management challenges. Excerpts are presented in the table Elk Populations and Population Objectives for Elk Management Units within the Project Area. Note that ‘current trend survey’ in this table refers to the year the plan was in preparation.

Table 3.20 Elk Populations and Objectives for Elk Management Units within the Project Area Elk Hunting Elk Populations Population Objectives Management Districts Unit Granite Butte 293, 339, The numbers of elk counted declined slightly Maintain the number of elk 343 in 2003 to 2,036 elk. However, this number observed during post-season remains above the EMU objective of 2,100. Aerial trend surveys within 20% of 2,150 elk (1,720-2,580). Objectives by hunting district are: HD 293 – 750 elk, HD339 – 700 elk, and HD343 – 700 elk1. Deerlodge 215, 335 The numbers of elk observed declined Maintain the number of elk approximately 10% from an average of counted during post-season 1,845 elk during 1993-1996 to an average of aerial trend surveys within 20% 1,663 during 1997-2000, and increased to of 2,100 elk. Objectives by 1,879 in 2003. hunting district are: HD 215 – 1,000 elk and HD 335 – 600 elk.4 Elkhorn 380 The number of elk has been relatively stable Maintain the number of elk since 1992. observed during post-season aerial surveys within 15% of 2,000 elk (1,700-2,300).

4 Granite Butte and Deerlodge are the only EMUs in the Project area that have population objectives by hunting district. All other population objectives are at the EMU level.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 99 Elk Hunting Elk Populations Population Objectives Management Districts Unit West Big Belts 392 The number of elk observed has been Maintain the number of elk relatively stable for the past 10 years. observed during post-season aerial surveys with 20% of 1,100 elk (880-1,320). Bridger 390, 391 In the past 10 years [pre-2005], elk numbers Maintain the number of elk have increased substantially in portions of observed during post-season this EMU. Hunting access restrictions on aerial surveys within 20% of private land have made it difficult for FWP to 3,550 elk (2,840-4,260). manage elk numbers. East Big Belts 446 Observed numbers of elk have increased Maintain the number of elk dramatically since 1972 due in large part to observed during post-season the relative lack of hunting pressure on aerial surveys within 20% of private land compared to public land. 950 elk (760-1,140). Bob Marshall 281 The potential for elk production varies Maintain 500-700 elk observed Wilderness among portions of the EMU. Elk that occupy during post-season aerial Complex the south and east peripheries consistently surveys. Objectives by (BMWC) exhibit higher calf survival than do the elk subunits: 200-300 elk in that occupy the South and Middle Fork of Ovando Mountain area from the Flathead in the interior of the BMWC. fixed-wing aerial surveys; 150- Bulls that reside yearlong within the 200 elk in Marcum-Kershaw Wilderness boundaries exhibit higher area; and 150-200 elk in the survival through hunting season than those Beaver-Keep Cool area. in non-Wilderness areas. Elk populations 2) Maintain less than 200 elk wintering in HD 281 are near modern day observed on private ranches in highs. HD 281 during post-season aerial trend surveys.

Each EMU and Hunting District (HD) has its unique primary challenges that relate to management of elk. Although varied by HD, an overall challenge focuses on elk winter range and the impact elk have on private land during winter. Another challenge concerns access to public lands. Refer to the Montana Elk Plan (2004) for more information.

Aerial Survey Synthesis5 Granitebutte Elk Management Unit/Hunting Districts 293, 339, 343 Approximately 311 elk were observed in HD 293 during aerial surveys in March, 2010; however, only the southern portion of the HD was surveyed. In 2009, 592 elk were observed. Counts in 2009 were up for this portion of the HD over past years.

Fewer elk were observed in HD 339 in 2010 (1004) compared to 2009 (1186), but the population is still over management objectives. In six of the last eight years, the number of elk observed has exceeded the population objective.

Within HD 343, fewer elk were observed in 2010 (443) compared to any year since the mid to late 1990s. While this number is below the population objective that was established for this district, it appeared that elk had moved off winter range by the time this survey was completed. The observation of fewer elk again this year may be due to the late survey date or due to a reduction in the population.

5 All information is excerpted from the respective aerial survey report each MFWP biologist completes annually. These reports are located in the project file.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 100 Deerlodge Elk Management Unit/Hunting Districts 215, 335 Approximately 1,716 elk were observed in HD 215. This is a decrease over the 2009 count of 1,759; however it still remains above objectives.

Within HD 335, fewer elk were observed in 2010. While this number is below the objective, it appeared that elk had moved off winter range by the time this survey was completed. The observation of fewer elk again this year may be due to the late date or due to a reduction in the population.

Elkhorn Elk Management Unit/Hunting District 380 A total of 1,414 elk were observed in HD 380, which is a decrease of 873 elk over last year’s survey. The total count was down considerably but was believed to be a result of a number of contributing factors rather than reflective of a decline in actual numbers. Winter ranges had less snowpack than some years, which allowed elk to be dispersed across the winter range. Other factors may have also contributed to the lower count in 2010 including: continued disturbance caused by antler hunters, winter range closures to motorized vehicles being violated with vehicle tracks observed on this survey going around the Forest Service gate near Glendale Butte with vehicle tracks covering much of the North and South Crow winter ranges. Elk numbers were down some on the east side winter ranges but really declined across most of the west side winter ranges. This may have been a result of wolves working this area. Wolves were evidently observed along the west side of the range this winter. The population objective for this EMU is a range of 1,700-2,300 observed elk. Elk have generally been increasing in this EMU since the late 1980s. Counts in most herd units declined this year but because of poor survey results it is difficult to compare this year’s survey results to previous years.

West Big Belts Elk Management Unit/Hunting District 392 and Bridger Elk Management Unit/Hunting Districts 390, 391 Survey results indicated approximately 1,143 elk in HD 390; down about 984 compared to 2009. HD 392 counts (1,040) were down 369 elk from 2009 and HD 391 numbers (733) were relatively stable compared to 2009 (728). These decreases in HD 390 and 392 may be more from a shift in elk distribution rather than actual declines.

East Big Belts Elk Management Unit/Hunting District 446 A total of 1,629 elk were observed in HD 446 in 2010. This figures represent about a 28% decrease from 2008 when 2,253 elk were counted (surveys were not flow in 2009). However, the 1,629 observed elk is well above the objectives.

Bob Marshall Wilderness Complex A total of 488 elk were observed in HD 281 in 2010 which is below objectives. This represented a decrease of 241 elk from 2008 counts. However, poor flight conditions and timing likely resulted in an undercount of both total elk in 2010.

Elk Population Conclusions Elk numbers fluctuated among HDs in 2010 and according to survey reports may not have been representative of actual elk numbers. The table Elk Observed during Montana Fish, Wildlife,

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 101 and Parks Aerial Surveys by Hunting District from 2005 – 2010 and Figure 3.6 summarize the elk counts by hunting district since 2005 (the year of the Montana Final Elk Management Plan).

Table 3.21 - 2005- 2010 Montana Fish, Wildlife, and Parks Aerial Surveys by Hunting District HD HD HD HD HD HD HD HD HD HD HD 215 281 293 335 339 343 380 390 391 392 446 2005 894 748 184 555 820 * 1745 995 261 1007 1291 2006 953 * 663 771 971 725 2107 1613 488 951 1248 2007 ** * 708 776 892 821 2029 1742 509 1241 1512 2008 1365 726 * 667 822 810 2101 1618 432 974 2253 2009 1759 * 592 450 1186 582 2287 2127 1409 728 * 2010 1716 488 311 388 1004 443 1414 1143 1040 733 1629 Population Objectives 1000 600 750 600 700 700 2000 3500 1000 950 1000 * Data not collected by MFWP **Data not on file at the HNF

No single pattern emerges among HDs and observed elk except perhaps that observed elk numbers fluctuate depending on survey conditions in any given year, among other factors. Hiding cover has been relatively stable for the past decade with the exception of burned areas that have removed thousands of acres of hiding cover from 2000 to 2009. This has mostly occurred in the southern and northern ends of the Big Belts (Maudlow-Toston, Cave Gulch, Bear Gulch, and Meriwether Fires), north of Lincoln (Snow Talon Fire), and west of Helena (MacDonald Pass Fire). These fires correspond to HDs 281, 390, 391, 392, and 343 and with the exception of the Bear Gulch, Meriwether, and MacDonald Pass Fire all occurred prior to 2005. Currently, the mountain pine beetle outbreak on the Forest has killed several hundred thousand forested acres and subsequently canopy cover – and thermal cover - is declining. However many of these trees are still standing and continue to provide hiding cover. This is expected to change over the next several years as dead trees fall. It becomes somewhat difficult to predict a causal relationship between elk numbers and hiding cover since elk numbers have fluctuated over the past few years while hiding cover has remained relatively stable with the exception of burned areas. However, elk populations have been increasing in many areas even in those EHUs where hiding cover standards are not met.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of elk as ‘G5’ and the statewide status as ‘S5’ which are both defined as follows: “common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 102

Figure 3.6 Observed Elk by Hunting District 2005-2010

Issue: Grizzly Bears Grizzly bears occupy the northern portion of the Helena National Forest. They are omnivorous habitat generalists and tend to be found in contiguous, relatively undisturbed mountainous habitat with high topographic and vegetative diversity (USDI 1993, pp. 1-14).

The Northern Continental Divide Ecosystem Recovery Zone (NCDE) includes the Scapegoat Wilderness and adjacent suitable habitat in the northern portion of the Blackfoot Landscape Area (LA) (i.e. north of Highway 200). The Monture-Landers Fork Bear Management Unit (BMU) is the only BMU on the Helena National Forest within the NCDE Recovery Zone (Figure 3.1), and consists of three sub-units (Red Mountain, Arrastra Mountain and Alice Creek).

In recent years, grizzly bears have been expanding their range. Biologists from several agencies have mapped grizzly bear distribution outside of the NCDE Recovery Zone (USDA et al. 2002). Mapped grizzly bear distribution outside of the recovery zone on the Helena NF encompasses the Blackfoot LA and extends south into the Continental Divide LA.

Current Conditions Access Management6 Grizzly bear habitat across the region is best described in terms of the availability of large tracts of relatively undisturbed land that provides some level of security from human depredation and competitive use of habitat by humans (including roading, logging, grazing, and recreation) (USDI 1993, pp. 1-14). To that end, ‘effective’ habitat is often described in terms of core areas – areas free of motorized access during the non-denning period (IGBC 1994) – for each season of use. Open road and total road densities are important measurements in determining core areas and understanding the extent of habitat security for grizzly bears.

Access within the NCDE Recovery Zone is measured according to our Forest Plan standards and the Northern Continental Divide Ecosystem Grizzly Bear Access Management Protocol and

6 Effects to grizzly bears are categorized into three areas: access management, sanitation, and grazing. Access management is assumed to be the only issue of concern for the Roadside Hazard Tree Removal Project.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 103 Flathead National Forest Amendment 19 (USDA 2002). These guidelines incorporate relatively recent science regarding access management and grizzly bears and serve as the benchmark thresholds for access management within the NCDE Recovery Zone. We use this methodology to determine access management effects to grizzly bears within the NCDE Recovery Zone in addition to our Forest Plan Standards. This methodology serves as guidelines and does not replace our Forest Plan Standards.

Research has indicated that grizzly bears underutilize habitat near roads or other human activities (Mace and Waller 1996, McLellan and Shackleton 1989). Managing motorized access can aid in minimizing negative effects on bears from interactions with humans and provide for secure habitat (IGBC 1994). Grizzly bears generally adjust to disturbance associated with roads by avoiding the area that in turn results in a reduction in the amount of habitat available to the bears. Roads also provide increased access into previously remote areas that in turn encourages human settlement, recreational use, and other land uses. These activities can increase the frequency of human-bear confrontations and ultimately reduce habitat availability and grizzly populations.

Seasonal habitat use by grizzly bears is also an important consideration in access management. When bears emerge from the den, they tend to search for food in lower elevations, drainage bottoms, avalanche chutes, and ungulate winter ranges (USDI 1993, pp. 1-14). Throughout the late spring and early summer they move towards higher elevations as food becomes available. Because spring habitat tends to be at lower elevations, increased potential exists for conflict between bears and humans due to greater access into those areas by humans. Roads located in riparian zones, for example, may result in indirect habitat losses through avoidance behavior by bears. Riparian zones are heavily used by grizzlies for feeding and travel corridors (Moss and LeFrance 1987).

Moving Window Analysis The moving windows analysis measures total motorized access route density, open road and open motorized trail route density, and the percentage of a subunit in core areas and is applied only within the NCDE. The guidelines to effectively manage access and core areas for grizzly bears per the NCDE Recovery Zone Protocol (further described in the Flathead National Forest Amendment) are described in the table Route Density and Core Security Areas in the Monture- Landers Fork BMU footnotes.

The table Route Density and Core Security Areas in the Monture-Landers Fork BMU summarizes route density and security areas for the Monture-Landers Fork BMU, Helena National Forest. Under the existing condition, the Alice Creek subunit meets access management standards for open motorized route density and core area. While it exceeds the total motorized route density standard by 0.5%, less than 75% of the landownership in the subunit is managed by the Helena National Forest (this includes recent land acquisitions). Therefore, the access standard is modified and stipulates no net increase in the percent of area with more than 2 miles of open motorized route per square mile resulting from Forest Service (FS) actions. Consequently, the Alice Creek subunit is in compliance with the NCDE Recovery Zone guidelines.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 104 The Helena National Forest manages more than 75% of the land within the Arrastra Mountain and Red Mountain subunits. None of the subunits meet all three moving window criteria; although each subunit does meet at least one criterion.

Table 3.22 Route Density and Core Security Areas in the Monture-Landers Fork BMU 7 Subunit OMRD1 TMRD2 Core3 Alice Creek Subunit (<75% Forest Service management) 9 23 72 (% of area meeting guideline) Arrastra Mountain Subunit 19 20 72 (% of area meeting guideline) Red Mountain Subunit 22 18 64 (% of area meeting guideline) 1Open motorized route density guideline: ≤19% of each subunit with >1.0 mile/mi2; if <75% FS land management, then no net increase in >1.0 mile/mi2 open motorized route density class due to FS actions. 2Total motorized route density guideline: ≤19% of each subunit with > 2.0 mile/mi2; if <75% FS ownership, then no net increase in >2.0 mile/mi2 open route density class due to FS actions. 3Core area (>2,500 contiguous acres, ≥0.3 mi. from motorized route, no roads or trails receive ”high intensity use” (USDA 1990) and no motorized routes open during non-denning period) guideline: ≥68% of the subunit considered core area; if <75% FS ownership, then no net decrease in potential security core areas due to FS actions.

The Forest Plan standard for open-road density within Management Situation (MS) 1 and MS 2 grizzly habitat is 0.55 mile per square mile (Forest Plan page II-19). Existing condition open road density for the Forest within the three subunits is summarized in the table Road Densities per the Forest Plan Standards. Open road densities for the National Forest portions of all three subunits, independently as well as cumulatively, do not exceed Forest Plan standards. All of the Helena National Forest within the NCDE Recovery Zone is classified as MS1 and MS2, as described in Appendix D of the Helena National Forest Plan (pages D1 – D/4). Please refer to Appendix D for MS1 and MS2 definitions and management direction.

Forest Plan Standards The Forest Plan standard for open-road density within Management Situation (MS) 1 and MS 2 grizzly habitat is 0.55 mile per square mile (Forest Plan page II-19). Existing condition open road density for the Forest within the three subunits is summarized in the table Road Densities per the Forest Plan Standards. Open road densities for the National Forest portions of all three subunits, independently as well as cumulatively, are well below Forest Plan standards. All of the Helena National Forest within the NCDE Recovery Zone is classified as MS1 and MS2, as described in Appendix C of the wildlife specialists report and Appendix D of the Helena National Forest Plan (pages D1 – D/4). Please refer to Appendix C of the Wildlife Specialists Report for MS1 and MS2 definitions and management direction.

Table 3.23 Road Densities per the Forest Plan Standards8 Existing Condition Subunit (Standard = 0.55 mi/sq. mi) Red Mountain subunit 0.36 Arrastra Mountain subunit 0.47 Alice Creek subunit 0.14

7 Version January 2010 8 Version January 2010

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 105 Mapped Grizzly Bear Distribution Zone Twelve Forest Plan Management Areas (USDA 1986) are found within the Grizzly Bear Distribution Zone. These 12 management areas have no specific road density standards for the Grizzly Bear Distribution Zone. Rather, the level of road use has been inferred based on the goals and objectives of the management areas. Each management area has been assigned to “road density” categories. The table Acres by Estimated Road Density by Management Area, Helena and Lincoln Ranger District summarizes road density categories by management area.

Table 3.24 Acres by Estimated Road Density9 by Management Area, Helena & Lincoln Ranger District Management Low Road Moderate Road High Road Non-Motorized Area Density Density Density L1 10,979 L2 92 M1 47,235 N1 394 R1 11,748 T1 59,412 T2 6,296 T3 14,817 T4 597 T5 11,613 W1 32,351 W2 5,384 Total Acres (%) 11,748 (6%) 85,364 (42%) 11,071 (6%) 92,735 (46%)

Issue: Lynx Lynx occur in mesic coniferous forests that have cold, snowy winters and provide a prey base of snowshoe hare. In North America, the distribution of lynx is nearly coincident with that of snowshoe hares (Ruediger et al. 2000).

Most lynx occurrences in the western United States are associated with Rocky Mountain Conifer Forest and most are within the 4920-6560 foot elevation zone. Primary vegetation that contributes to lynx habitat is lodgepole pine, subalpine fir, and Engelmann spruce.

Maternal denning sites are found in mature and old-growth coniferous forests with abundant downfall often in spruce/subalpine fir forests (Ruediger et al. 2000). Middle-aged conifer stands (40-120 years old) with open understories and light downfall do not provide good foraging or denning habitat may are often used as travel corridors (Ruggiero et al. 1994). Lynx tend to avoid large open areas and prefer to move between primary habitat sites under cover of mature forest, dense early-seral forest, or tall shrubs. They typically follow ridges, saddles, or riparian zones and when in open country, lynx follow stringers of trees or tall shrubs.

9 Low Road Density: Areas that would be expected to have the lowest road densities on the Forest due to the low- impact type of management (e.g. MA-1 which is nonforest and forested land where timber management and range or wildlife habitat improvements are currently uneconomical or infeasible). Moderate Road Density: Areas that are expected to have more active land management and higher road densities than the Low Road Density category. A wide variety of Management Areas are included in this category (e.g. L1 – land within grazing allotments with a goal of optimizing livestock production). High Road Density: Areas that are expected to have the most active land management and the highest road densities on the Forest (e.g. T1 – timber production emphasis areas).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 106 Snowshoe hares are the primary prey of lynx, comprising 35-97% of the diet. Koehler (1990) reports that snowshoe hare densities are significantly correlated with the densities of trees and shrubs less than 1.0 inch dbh. Therefore, preferred lynx foraging habitat consists of dense conifer seedling and sapling stands that provide snowshoe hare cover and available browse, i.e., lodgepole pine (Koehler 1990). Koehler and Brittell (1990) recommend that seedling/sapling stands within the lodgepole/subalpine fir zone should be well dispersed across lynx habitat. Higher elevation montane habitats with abundant snowshoe hares are optimal habitats.

Current Condition Lynx are not considered present in the Big Belts or Elkhorns. Hair snare surveys in 2002, 2003, and 2004 (2002 only for Elkhorns) did not detect lynx presence nor are they on the U.S. Fish and Wildlife Service species list for those areas. Lynx are considered present on the rest of the Forest and lynx habitat does occur throughout the project area.

The table Lynx Habitat by Lynx Analysis Unit within the Project Area summarizes habitat for Lynx Analysis Units (LAU) according to the definitions in the Northern Rockies Lynx Management Direction (USDA 2007c). All LAUs within which treatment is proposed are included in the table regardless of their occupied status. However, only those that occur within occupied habitat will be analyzed in a biological assessment (i.e. all ‘di’ and ‘bl’ LAUs).

Table 3.25 Lynx Habitat within Lynx Analysis Units (LAU) within the Project Area

Multi- Multi- Stand Stand Total Storied Storied Initiation Initiation Other LAU Habitat Hare NOT Hare Hare NOT Hare Habitat Habitat Habitat Habitat Habitat in LAU bb-03 1,572 830 198 144 9,418 12,162 bb-04 3,103 404 242 128 20,540 24,417 bb-05 1,636 406 301 128 13,670 16,141 di-01 1,133 309 111 55 17,061 18,669 di-02 751 227 44 24 9,572 10,618 di-03 1,951 366 469 90 21,768 24,644 di-04 1,859 431 410 101 17,353 20,154 di-05 1,617 271 44 39 14,661 16,632 di-06 1,177 290 44 11 10,990 12,512 el-01 118 312 1,551 600 9,585 12,166 el-02 10 62 367 880 9,170 10,489 el-03 166 646 495 152 19,303 20,762 bl-04 178 25 146 59 10,534 10,942 bl-05 421 60 177 51 17,315 18,024 bl-07 173 38 64 90 16,926 17,291 bl-08 234 52 63 67 13,329 13,745 bl-09 364 51 147 46 8,044 8,652 bl-10 314 24 464 313 13,822 14,937 bl-11 470 74 557 54 13,284 14,439 bl-12 161 18 447 87 11,195 11,908 bl-13 49 17 424 62 11,488 12,040 bl-14 55 27 490 322 12,171 13,065 bl-15 556 126 24 8 13,644 14,358

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 107 Lynx critical habitat was designated in the Federal Register (Vol. 74, No. 36) on February 25, 2009 and becomes effective March 27, 2009. The designation identifies physical and biological elements of the primary constituent element (PCE) essential to the conservation of lynx. The PCEs for lynx critical habitat are: (a) Presence of snowshoe hares and their preferred habitat conditions, including dense understories of young trees or shrubs tall enough to protrude above the snow; (b) Winter snow conditions that are generally deep and fluffy for extended periods of time; (c) Sites for denning having abundant, coarse woody debris, such as downed trees and root wads; and (d) Matrix habitat (e.g., hardwood forests, dry forest, non-forest, or other habitat types that do not support snowshoe hares) that occurs between patches of boreal forests in close juxtaposition (at the scale of a lynx home range) such that lynx are likely to travel through such habitat while accessing patches of boreal forest within a home range.

Currently the project area is within proposed lynx critical habitat which incorporates all Helena National Forest managed lands north of Highway 12 at approximately 429,275 acres.

Issue: TES and MIS Species Fisher Fishers are small-to-mid-sized carnivores strongly associated with structurally complex forest stands, most often at low and middle elevations rather than in high montane forests (Banci 1994). In the Rocky Mountains, grand fir, Engelmann spruce, and lodgepole pine dominated stands are used by fishers (Jones 1991). Old-growth and mature riparian forests provide particularly good habitat. Fishers make use of hollow logs, standing tree cavities, and dense tree crowns (often, witches brooms) for denning, rearing young, resting, and refuge (Jones 1991). They prey on a variety of small and mid-sized mammals (snowshoe hares, porcupines, squirrels, voles), as well as birds, and carrion (Heinemeyer and Jones 1994). This diverse diet makes them less vulnerable to shifts in prey abundance than lynx and other predators that rely heavily on one or two prey species.

Current Condition The area of consideration for fishers is the forested portions of the Helena National Forest (Forest). Fishers have been recorded on the Forest through survey efforts conducted in 2007, 2008, and 2009 (See data and results in project file). Potential habitat has been estimated in the project area based on methods described in the Assumptions and Methodologies Section. Habitat has been modeled for both summer and winter habitat (See Criteria for Wildlife Models Helena National Forest for definitions). There are an estimated 59,511 acres of fisher summer habitat and 212,008 acres of winter habitat across all four Helena National Forest landscapes.

Primary fisher habitat on the Forest is patchy but widely distributed. It is increasing as forests age. Insect-generated mortality in mature forest is creating more open canopy (unfavorable) but more snags and woody debris (favorable). Primary habitat is interconnected by forested travel habitat. Population is widely distributed but small; precise numbers are unknown. See also the Viability Analysis Section.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 108 Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of fisher as ‘G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range” and the statewide status as ‘S3’ which is defined as “potentially at risk because of limited and/or decline numbers, range, and/or habitat, even though it may be abundant in some areas”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Black-Backed Woodpecker Black-backed woodpeckers are primary cavity nesters that inhabit coniferous forests. They excavate their own cavities in live or dead trees of various species for nesting and play a critical role in excavating cavities that are later used by many other species of birds and mammals (secondary cavity nesters) (Dixon and Saab 2000). Englemann spruce, Douglas-fir, lodgepole pine, ponderosa pine, and western larch are all used as nest trees. Black-backed woodpeckers forage almost exclusively on larvae of bark beetles and wood-boring beetles. Their home range size varies from 178 to 810 acres depending on habitat quality.

Black-backed woodpeckers typically restrict their habitat distribution to early post-fire forests (Hutto 1995). Their abundance appears to be correlated with the number of small snags remaining after a fire rather than the size of the burn. Other research conducted in Montana suggests black-backed woodpeckers may require recent burns for long-term survival (Kotliar et al. 2002). Black-backed woodpeckers may not be as abundant as they once were due to continued fire suppression, frequency of salvage logging, and insect eradication during the last 50 years (Hutto 1995).

Black-backed woodpeckers also occur in unburned landscapes and tend to occupy forest habitats that contain high densities of dead or dying trees with bark beetles and woodborer beetles. However, as mentioned above, research focused in Montana indicates that recent burns are potentially critical to long-term survival (Hutto 1995).

Current Condition In Montana, black-backed woodpeckers are dependent upon moderate to high-severity wildfires that they will utilize for one to six years following the fire. Recent research concludes that while black-backed woodpeckers have tiny territories in recently-burned areas, they are extremely mobile and can colonize wildfires from far away to find new food source.

The area of consideration for black-backed woodpeckers is the Forest; although to date black- backed woodpeckers have only been observed in burned areas of the Forest. The Forest includes several recent fires: Meriwether Fire of 2007, Bear Gulch Fire of 2008, and the MacDonald Pass Fire of 2009. Surveys conducted in those areas indicate that black-backed woodpeckers have colonized those burned landscapes. Surveys elsewhere in forests impacted by the mountain pine beetle did not detect any black-backed woodpeckers. As mortality increases Forest-wide associated with mountain pine beetle activity, black-backed woodpeckers may colonize those areas if and when wood boring beetles are present.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 109 Suitable habitat for black-backed woodpeckers has increased dramatically over the past few years. Primary opportunities have been produced by large fires, but the birds may be attracted also to areas of extensive insect-generated mortality in mature forests. This entire habitat is ephemeral. Potential for suitable habitat over the long term is dependent upon fire and insect outbreaks sufficient to provide a forage base. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of black- backed woodpecker as ‘G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range). Not vulnerable in most of its range” and the statewide status as ‘S3’ which is defined as “potentially at risk because of limited and/or decline numbers, range, and/or habitat, even though it may be abundant in some areas”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Flammulated Owl Flammulated owls are a common raptor of the montane forests of the western United States. They primarily forage on insects, especially moths and beetles (McCallum 1994). They forage by “hawking” which consists of the bird perching on a branch at the lower portion of the forest canopy and waiting for a moth to fly by, or a grasshopper to walk by. Such foraging behavior is presumably facilitated by the open, park-like conditions typical of ponderosa pine forests. Home range size varies from an average of 14.5 ha in Colorado (Linkhart 2001 as cited in Samson 2006a) to 15.9 ha in Oregon (Goggans 1986 as cited in Samson 2006a).

In general, flammulated owls nest in relatively large trees in relatively open areas (Bull et al. 1990, McCallum 1994, Wright et al. 1997). Wright et al (1997) found that flammulated owls, in the northern Rocky Mountains, used large ponderosa pine and Douglas-fir for nesting habitat. McCallum (1994) reports that most published nest records occur in forests where yellow pine (e.g. ponderosa pine) is present, if not dominant. Flammulated owls also nest in large Douglas- fir when ponderosa pines are absent.

Flammulated owl productivity appears to be associated with higher densities of larger diameter trees which suggest that flammulated owls are adapted to forests that were historically maintained by fire (Linkhart 2001 as cited in Samson 2006a). Fire suppression in many western forests, which were historically characterized by open stands of large-diameter trees prior to European settlement, has resulted in higher tree densities especially in the smaller diameter classes. Fire suppression has resulted in conversion of many pine forests to shade-tolerant fir forests and high tree densities in smaller diameter classes.

Flammulated owls may be present in and around the Forest wherever large open-grown conifers (providing foraging and nesting habitat) occur in juxtaposition to denser roosting stands. This habitat is usually localized and patchy, but widely available across the Forest. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 110 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of flammulated owls as ‘G4’ defined as “apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining” and the statewide status as ‘S3B’ which is defined as “potentially at risk because of limited and/or decline numbers, range, and/or habitat, even though it may be abundant in some areas” and “at risk during breeding season, but common in winter”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Current Condition The area of consideration for flammulated owls is the forested portions of the Helena National Forest. Flammulated owls have been detected on the Forest through survey efforts conducted in 2005, 2008, and 2009 (See data and results in project file). Potential habitat has been estimated in the project area based on methods described in the Assumptions and Methodologies Section. There are an estimated 15,808 acres of flammulated owl habitat across all four Helena National Forest landscapes.

While the habitat parameters used to develop the flammulated owl model are based on data collected elsewhere in Montana (Wright 1996) and in Idaho (Groves et al. 1997), the flammulated owls detected on the Forest appear to be selecting similar habitat features as those described in Samson (2006a as derived from Wright 1996 and Groves et al. 1997) i.e. Douglas- fir and ponderosa pine stands.

Forest-wide snag data (See Snag Section) indicate that few large snags or large trees comprise the Forest. Nesting habitat is therefore somewhat limited and as the mountain pine beetle runs its course, the availability of ponderosa pine snags will pulse in the short term, although, many of these snags will be between 7 and 20” size classes, generally not considered nest trees for flammulated owls. Within a few years of mortality, ponderosa pine snags are expected to fall. In light of these conditions, Douglas-fir may provide a more prominent role for flammulated owls than previously anticipated.

Northern Goshawk – Old Growth Dependent Management Indicator (MIS) Group Goshawks are the only large diurnal raptors adapted to interior forest environments in the northern Rockies. Key elements of goshawk habitat are extensive blocks of mature forest with groups of large nesting trees, abundant prey (squirrels, larger songbirds), and mid-level flyways. Goshawks are most commonly associated with mature and old-growth Douglas-fir and ponderosa pine forest, but surveys over the past 15 years on the Helena, Beaverhead-Deerlodge, Lewis and Clark, and Medicine Bow National Forests have found that goshawks will make extensive use of lodgepole pine stands as long as the basic structural attributes that they require are in place and prey is adequate (Lemke 1994; Squires and Ruggiero 1996).

In the more fragmented forest environments east of the Continental Divide where mountains and plains intermingle, goshawks often occupy mosaics of forest and grassland or with a mixture of different forest seral stages. They are capable of foraging through open parks and woodlands and along forest edges, and in certain circumstances do so on a regular basis. Competition from red-tailed hawks and great-horned owls confines goshawks to dense forest, but this apparently applies primarily to nest sites and potential predation on young rather than to foraging by adults.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 111 Goshawks are widespread, and appear well-distributed in forest habitat across the Forest. Suitable habitat is widely distributed. Aging forest processes continue to add to suitable nesting habitat in many areas, although this trend is being balanced by habitat loss to fire and insect- generated mortality. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of goshawks as G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of its range” and the statewide status as ‘S3’ which is defined as “potentially at risk because of limited and/or decline numbers, range, and/or habitat, even though it may be abundant in some areas”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Current Condition The area of consideration for goshawks is the Forest. Goshawk surveys have been ongoing Forest-wide for several years (See data and results in project file). Several nests have been located over time with 7 active nests located in 2010 alone. Goshawks are primarily selecting Douglas-fir trees for nesting which is aligned with the criteria used in the modeled habitat (See Assumptions, Information Used, and Methodologies Section).

Assuming an average home range of 5000 acres per nesting pair, the Forest potentially comprises about 196 home ranges based on total acres on the Helena National Forest (approximately 978, 799 acres). According to the R1 Summary Database, there are approximately 44,633 acres of nesting habitat Forest-wide across all four Helena National Forest landscapes. Assuming approximately 180 acres of nesting habitat per pair (Reynolds et al. 1992), enough nesting habitat exists to support up to 247 pairs of goshawks. Of course, all of the available acres of nesting habitat may not be utilized by goshawks for nesting for several reasons: e.g. juxtaposition of nesting habitat with post fledging habitat; small stand size (Reynolds et al. 1992 recommend at least 30 acre stand size), among others.

Pileated Woodpecker – Old Growth Dependent MIS Group The pileated woodpecker is used as an indicator of mature forests primarily because of their preference for large diameter snags as nest trees that tend to occur more frequently in mature forests (Bull and Holthausen 1993, Bull and Jackson 1995). However, the presence of large trees for nesting appears to be more important than forest age. The pileated woodpecker is able to do well in young and fragmented forests with abundant remnant (older) structure (Mellen et al. 1992).

Many tree species are used by the pileated woodpecker to excavate nest cavities and selection of the tree appears to depend mainly on the availability of suitable trees (Kirk and Naylor 1996). The pileated woodpecker can excavate a cavity in solid wood (Bull 1987) but most often uses trees partially softened by fungal decay. Pileated woodpeckers excavate a new cavity each year and reuse of old cavities is rare (Bull and Jackson 1995).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 112 In the Northern Rockies, pileated woodpeckers tend to use mature cottonwood bottoms, mixed conifer, ponderosa pine, among other habitats (Hutto 1995). Forests with a component of western larch, ponderosa pine, or black cottonwood are also used in the northern Rocky Mountains (McClelland and McClelland 1999). Nest trees in the northern Rockies average about 30” diameter with a minimum of 20” in diameter.

Dead and downed trees and snags are used for nesting and foraging (Bull 1987). The pileated woodpecker is dependent on coarse woody debris for foraging due to the occurrence of carpenter ants associated with the woody debris (Bull 1987, Bull and Jackson 1995). Home range is large (500-1000 acres in the northern Rockies [McClelland 1979]) and comprises a percentage of unlogged areas – i.e. pileated woodpeckers are considered large patch size species.

Current Condition The area of consideration for pileated woodpeckers is the Forest. Surveys have been ongoing Forest-wide for several years as part of the Regional landbird monitoring program, Birds and Burns research, and general and project related surveys (See data and results in project file). Pileated woodpeckers have been detected at several locations across the Forest in habitat consistent with modeling efforts.

The area of consideration for pileated woodpeckers is the Forest. Surveys have been ongoing Forest-wide for several years as part of the Regional landbird monitoring program, Birds and Burns research, and general and project related surveys (See data and results in project file). Pileated woodpeckers have been detected at several locations across the Forest.

The R1 Summary Database provides estimates of 94,845 acres of pileated woodpecker foraging habitat and 35,334 acres of nesting habitat distributed across all four Helena National Forest landscapes. Forest-wide snag data (See Snag Section) indicate that few large snags or large trees comprise the landscape. Nesting habitat is therefore somewhat limited and as the mountain pine beetle runs its course, the availability of ponderosa pine snags will pulse in the short term, although, many of these snags will be between 7 and 20” size classes which generally do not provide nest trees for pileated woodpeckers.

On the Forest, pileated woodpeckers are most abundant in the Blackfoot landscape west of the Continental Divide. Elsewhere on the Forest, the birds are widely distributed but generally uncommon. The Forest east of the Divide is near the edge of the woodpecker’s geographic range. Habitat is widespread and locally abundant across the Forest. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of pileated woodpeckers as G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of its range” and the statewide status as ‘S3’ which is defined as “potentially at risk because of limited and/or decline numbers, range, and/or habitat, even though it may be abundant in some areas”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 113 Hairy Woodpeckers- Snag Dependent MIS Group The hairy woodpecker represents those species dependent on snags. They are year-round resident primary cavity nesters, which subsequently provide nest cavities for a myriad of other small birds and mammals. Hairy woodpeckers reside in many forest communities and utilize a variety of tree sizes. They feed on insects, primarily ants, wood borers, and grubs as well as fruits and berries (Jackson et al. 2002). Hairy woodpeckers forage on a variety of substrates including snags and down logs. They may concentrate in areas of insect outbreaks in response to the increased food source (Sousa 1997).

Current Condition The area of consideration for hairy woodpeckers is the Forest. Surveys have been ongoing Forest-wide for several years as part of the Regional landbird monitoring program, Birds and Burns research, and general and project related surveys (See data and results in project file). Hairy woodpeckers have been detected at several locations across the Forest.

Forest-wide snag data (See Snag Section) indicate an abundance of snags in the 7-12” class (See table Snag Size Class Averages (TPA) Forest-wide and by Landscape). Snags larger than 12” are more limited across the Forest. Because hairy woodpeckers are generalists and will utilize a variety of tree sizes, habitat is abundant and well distributed across the Forest.

Table 3.26 Snag Size Class Averages (TPA) Forest-wide and by Landscape1 Size Class Forest-Wide Big Belts Blackfoot Divide Elkhorns Landscape Landscape Landscape Landscape 20”+ dbh 1.2 1.4 1.5 0 2 12-20” 6.5 4.6 10.6 3 5.4 7-12” dbh 26.1 19.8 38.3 17.3 21.2 1Confidence intervals are in the project file. Hairy woodpeckers are common and well distributed in all forest habitats with insect-supporting trees. Large fires and insect infestations are substantially increasing habitat components for hairy woodpeckers across the Forest. Potential for suitable habitat persistence over the long term is excellent. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of hairy woodpeckers as G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of its range” and the statewide status as ‘S5’ which is defined as “common, widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of its range”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

American Marten – Mature Forest Dependent MIS Group The American marten is an indicator used to monitor the quality of large continuous blocks of mature cover. Martens prefer mature forests, especially during the winter. This may be related to snow depths and increased success of encountering and capturing prey (Thompson and Colgan 1994).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 114 Stumps and down logs provide critical habitat components for foraging and as rest and den sites (Spencer 1987, Coffin 1994). Marten dependence on mature forests in the central Rockies seems to be linked to the availability of coarse woody debris that provides resting sites and thermal cover (Buskirk et al. 1989). Chapin et al. (1997) found that vertical and horizontal structure was more important than age or species composition. Home range size varies from 1.9 km2 for females to 6.0 km2 and 7.3 km2 for resident and temporary males, respectively (Slough 1989).

Current Condition The area of consideration for martens is the Forest. Surveys conducted by Wild Things Unlimited have documented the presence of marten in the Big Belts and along the Continental Divide (See data and results in project file). Surveys conducted as part of a regional effort to determine extent of fishers region wide also documented the presence of marten, primarily west of I-15 (See data and results in project file). The R1 Summary Database provides an estimate of marten habitat of approximately 322,661 acres.

Forest-wide snag data (See Snag Section) indicate that few large snags or large trees comprise the landscape. However, as more trees succumb to mountain pine beetle, snag levels of all sizes will be plentiful across the Forest in the short term. Large snags (>20”) will still be limited despite widespread mortality due to a shortage of large live trees. As trees fall, coarse woody debris will be abundant; however, in many of these places canopy cover will have decreased to the extent that these areas no longer provide marten habitat.

Primary marten habitat is patchy but widely distributed on the Forest. Habitat is increasing in many areas as forests age. Beetle infestations are modifying this habitat—often favorably by increasing large woody debris. Primary habitat sites are interconnected by forested travel habitat. Population is widely distributed; numbers are unknown. See also the Viability Analysis Section.

Montana employs a standardized ranking system to denote global (range-wide) and state status. Species are assigned numeric ranks ranging from 1 (highest risk, greatest concern) to 5 (demonstrably secure), reflecting the relative degree of risk to the species’ viability, based upon available information. The Montana Natural Heritage database lists the global status of marten as G5’ defined as “common, widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of its range” and the statewide status as ‘S4’ which is defined as “apparently secure, though it may be quite rare in parts of its range, and/or suspected to be declining”. See http://fieldguide.mt.gov/displayClasses.aspx?Kingdom=Animalia

3.9.3 Environmental Consequences

Snags Snags would be managed to meet Forest Plan standards. Specific data as to existing snag densities and numbers of snags likely to be removed by the hazard tree project can be found in the Forested Vegetation background report. • In the short-term, snags would continue to multiply Forest-wide as the ongoing bark beetle epidemic runs its course. Please see the 2009 Aerial Detection Survey map in Chapter One. The consequent increase in habitat opportunities for snag-associated

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 115 wildlife would be substantially greater than what has been the norm on the Forest for the past several decades. • In the long-term, there would be a substantial Forest-wide increase in the volume of large woody debris as snags come down—and a consequent increase in habitat opportunity for wildlife species that make use of large logs and accumulations of woody debris. • Forest-wide, the acreage of forest stands exceeding Forest Plan standards for existing snags (as opposed to “replacement” snags) (HFP, p. II/21) and Eastside Snag Protocol (USDA 2008) recommendations for existing snags would significantly increase. • In the project area: any large snags remaining or developing in the road corridor in the future are likely to be removed—as they are now—by firewood cutters. The width of the functional firewood “corridor” (the distance from the road that firewood gathers are willing to go) would depend on terrain, snag quality, sight distance through the forest, and the relative abundance of dead trees. As a result, snag habitat, though currently abundant along many Forest roads (because firewood cutters are unable to keep up with the new spike in mortality), would once again become sparse at some point in the future. • In the project area: any large snags remaining or developing in the road corridor in the future are likely to be removed—as they are now—by firewood cutters. The width of the functional firewood “corridor” (the distance from the road that firewood gathers are willing to go) will depend on terrain, snag quality, sight distance through the forest, and the relative abundance of dead trees. As a result, snag habitat, though currently abundant along many Forest roads (because firewood cutters are unable to keep up with the new spike in mortality), will once again become sparse at some point in the future. The proposed project will further reduce snags along roadsides.

3.9.4 Alternative 1 (No Action) Direct and Indirect Effects Dead wood habitat is expected to increase under the No Action Alternative. Risks associated with disturbance agents – wildfire, root disease, and insects – would most likely increase as forested stands become denser and more susceptible to these agents. More dead and dying wood would accumulate in the short-term, increasing habitat for cavity depending and dwelling species. However, as previously noted, dead trees along roadsides are susceptible to firewood retrieval. Therefore availability may be limited.

3.9.5 Alternative 2 (Proposed Action) In addition to the Forest-wide effects listed above, the proposed action can be expected to generate the following effects on the snag resource within the project area: • In the short-term, the number of large snags (and potential snags from dying trees) within treated areas and within treated campgrounds and administrative areas would decrease. This would reduce habitat opportunity for snag-using wildlife within treated areas to levels much below those of surrounding beetle-infested forests: snag habitat would drop back to levels more characteristic of pre-epidemic forests.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 116 • Over the long-term, action alternatives would reduce the potential for accumulation of large woody debris on the forest floor within treated stands compared to surrounding areas and would consequently lower habitat opportunity for wildlife species that make use of these habitat components. • While treated stands themselves would retain variable numbers of “replacement” snags, abundant dead trees in surrounding beetle-impacted forests would allow drainages in which treatments sites occur to continue meeting Forest Plan snag standards and Eastside Snag Protocol recommendations.

Direct and Indirect Effects Direct Effects Virtually all large snags and near-term potential snags (dying trees) created by the ongoing beetle epidemic would be removed from project area sites (the treated areas along identified open roads and areas within campgrounds and administrative sites). This resource has been increasing in these areas for 3-5 years and represents a sudden surge in habitat opportunity for snag-associated wildlife (both those species dependent on large dead trees and those that merely take advantage of snags as an alternative habitat component).

If the entire project area were to be treated, the sum of the areas from which the newly created snags would be subtracted would amount to as much as 9,416 acres. However, a proportion of the ground within the “project area” would not be treated because it is occupied by young stands unaffected by the bark beetles, mature trees of species not affected by mountain pine beetles, or non-forest habitat.

Aerial detection flights (ADS 2009, see maps in Chapter One) estimate that roughly 585,557 acres of forest habitat had been attacked by mountain pine beetle. These surveys indicate that snags are being generated in numbers far exceeding anything seen over such a large area in many decades. Removal of hazard trees from road corridors and administrative sites would affect an area representing a maximum of 1% (an estimated 9,416 acres) of the area over which snags are proliferating on the HNF. That is, new snag habitat is being created at a far greater rate than proposed hazard tree removal would reduce it.

Table 3-27 Mean Snag Density per Acre Inside and Outside of Wilderness/Roadless Areas for Snag Analysis Groups: Lodgepole Pine Dominance Group (PICO) and All Other Dominance Groups by Habitat Type Group for the Helena National Forest Area Dominance Habitat Type Snags per Snags per Snags per Group Group Acre 10”+ Acre 15”+ Acre 20”+ In All Other Warm 3.6 0.6 0.1 Wilderness/ Groups Cool 17.3 2.1 0.7 Roadless Cold 21.5 2.2 0.5 PICO All 9.2 0.4 0.0 Outside All Other Warm 2.1 0.7 0.3 Wilderness/ Groups Cool 11.8 3.8 1.5 Roadless Cold - - - PICO All 5.4 0.3 0.0

Examining the lodgepole pine dominance group separately is appropriate for several reasons. Lodgepole pines are uniquely characterized by their growth, form, and lack of wind firmness.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 117 Consequently, lodgepole pines fail to grow as large as other common tree species on eastside Forests, and therefore do not contribute as many large diameter snags.

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for snags is the Helena National Forest. See also the Forested Vegetation Background Report, Cumulative Effects Section for more information on snags and cumulative effects.

Ongoing activities that impact snag habitat include road use and management (and subsequent firewood retrieval), as well as vegetation manipulation projects. Again, current snag levels are high due to mountain pine beetle impacts among others. The Proposed Action would remove these trees where they pose a hazard; however, cumulative impacts associated with ongoing activities are not anticipated given the current snag levels Forest-wide.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities would result in removal of snag habitat (e.g. Cabin Gulch Vegetation Management, Grassy Mountain Fuels Reduction, Warm Springs Habitat Enhancement, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). The Proposed Action is not expected to significantly add to the potential impacts of these reasonably foreseeable impacts so there are no anticipated cumulative impacts.

Irreversible/Irretrievable Commitments Removing existing snags from roadside corridors and local administrative areas would not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development would take several decades. The potential for continued snag creation would remain, thus there are no irreversible or irretrievable commitments of resources.

3.9.6 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites),

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 118 • Treated areas will represent less than 3% of the newly expanded snag resource, • Expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • Treated areas will continue to meet Forest Plan snag standards and Estimates of Snag Densities for Eastside Forests in the Northern Region (USDA 2008) (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • The majority of snags that are being removed are lodgepole pine of which there are few large snags, the proposed treatments, while diminishing habitat opportunities for local individuals, will have no meaningful impact on snag-associated wildlife populations in any of the 4 affected landscapes on the Helena National Forest. Populations of snag- using wildlife species will remain well above what they have been in recent decades, given the abundance of dead tree resources across the Forest landscape. Landscape levels of snags are likely to expand due to the MPB outbreak. Snag creation in untreated areas is expected to continue. Substantial portions of all drainages remain untreated with the proposed action. The table expected snag conditions following the proposed action (excerpted from the forested vegetation background report) summarizes remaining snags post implementation by 3rd order drainage. The acreages listed do not match total proposed acres because there are treatments that do not lie in a third order drainage. The treatment area considered is the original proposal, 12,970 acres; the actual amount treated has been reduced, so the impacts would be less than shown.

Table 3.28 Expected Snag Conditions Following the Proposed Action TPA Snag Estimates from HNF Proposed % Assessment of Snags 06- Summary Database Treat Ac Drainage Remaining Snags Drainage Acres 09 Beetle 7-12” 12- 20”+ Untreated Kill (ADS) dbh 20”dbh dbh 0202 7,541 6.57 16 8 0 127 98.31% Proposed treatments cover 0203 4,849 26.21 48.1 48.1 0 105 97.83% extremely small portions of 0204A 6,834 50.02 36.1 18.1 0 195 97.15% these watersheds and 0209 4,020 8.09 60.2 0 0 244 93.94% snags from beetle mortality 0212-1 13,971 28.99 0 0 0 786 94.38% alone exceed FP standard. 0212-2 1,741 36.83 12 0 0 2 99.92% Removal of some of the 0212-3 3,159 60.17 0 0 0 14 99.56% snag resource through 0213 5,137 69.34 12 0 0 294 94.28% narrow roadside treatments 0214 4,681 32.42 48.1 0 0 68 98.55% will not substantially reduce 0216 3,510 12.66 8 0 8 30 99.16% the snag resource across 0310A 3,940 122.73 0 0 0 46 98.84% the watersheds. The same 0401-1 1,810 4.79 0 0 0 10 99.43% level of snag loss could be 0401-2 4,801 7.19 8 8 0 27 99.43% expected through the No 0402 9,650 13.06 0 3 0 315 96.74% Action alternative via firewood cutting. Additional 0405 7,588 12.36 18.1 0 0 284 96.26% snags from older mortality 0705 4,876 101.15 12 24.1 0 232 95.25% agents are likely to be 0706 5,117 53.99 0 0 0 567 88.92% present on these 0708A 5,001 22.95 12 0 0 18 99.64% landscapes. Adequate 0710A 4,931 40.60 132.4 0 0 1 99.99% snags are expected to 0710C 1,891 88.67 0 0 0 32 98.33% remain on the landscape in 0814 9,782 170.92 24.1 24.1 0 102 98.95% untreated areas. 0822 9,992 202.71 44.9 21.9 1.1 72 99.28% 0901 3,719 46.63 20.8 12 0 31 99.18% In a few watersheds, snags

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 119 TPA Snag Estimates from HNF Proposed % Assessment of Snags 06- Summary Database Treat Ac Drainage Remaining Snags Drainage Acres 09 Beetle 7-12” 12- 20”+ Untreated Kill (ADS) dbh 20”dbh dbh 0904 12,674 9.22 41.5 13.4 0 10 99.92% from recent beetle mortality 1001-1 16,101 206.56 30.1 3 0 416 97.42% alone do not meet or exceed 1001-2 3,367 413.44 0 0 0 97 97.13% the standard according to 1001A 4,018 595.60 24.1 0 0 88 97.82% the available ADS data. In 1105-1 7,256 42.92 16 8 0 328 95.49% reality, there are likely more 1105-2 6,775 127.18 19.3 0 0 204 96.99% snags present from older 1106B 3,136 254.01 0 0 0 8 99.75% mortality causes or in areas 1107 7,988 253.35 0 4.8 0 382 95.22% not flown in 2006 and 2007. 1108-1 12,826 116.84 9 0 0 258 97.99% Most of these watersheds show snags present on FIA 1108-2 18,055 119.93 4.8 0 0 144 99.20% grid intensification plots. 1109 3,798 438.36 48.1 24.1 0 48 98.75% Removal of snags through 1110A 3,772 133.13 0 0 0 75 98.01% narrow roadside treatments 1111B 4,366 393.91 24.1 0 0 129 97.04% will not substantially reduce 1206-1 10,451 19.01 0 0 0 156 98.51% the snag resource across 1303 2,368 61.78 0 0 0 57 97.58% these watersheds. The 1306 6,475 49.92 96.3 0 0 168 97.41% same level of loss could be 1309-1 2,602 9.23 0 0 24.1 1 99.97% expected through the No 1309-2 4,960 13.72 0 0 0 211 95.75% Action alternative via 1309-4 2,342 0.71 24.1 0 0 20 99.14% firewood cutting. Adequate 1309-5 5,666 5.32 0 0 0 183 96.76% snags are expected to 1310 3,212 2.63 3.8 0 2.5 63 98.04% remain on the landscape in 1312 1,359 1.52 0 0 0 24 98.27% untreated areas. 1402-1 2,137 6.06 72 12 0 2 99.93% 1402-2 18,833 0.99 16 6 2 309 98.36% 1404 5,903 0.04 120 36 0 10 99.84% 1505-3 3,454 0.99 0 0 0 26 99.24% 1704F 3,280 12.34 84 0 0 147 95.51%

In addition to the Forest Plan, the project is consistent with considerations found in Estimates of Snag Densities for Eastside Forests in the Northern Region (USDA 2008). Snags should occur in a clumpy manner, and snag conditions/distribution are dynamic depending on site, tree species, and seral stage. The distribution of snag size classes is consistent with the Forest Plan goals, and the natural snag levels found in roadless and wilderness areas shown by USDA (2008). The snag resource is experiencing a short term pulse due to the MPB epidemic; at this time lodgepole pine and some ponderosa pine snags are abundant and over time this will lessen as snags fall. Retention of live trees for recruitment is critical to provide for future snags that can provide habitat during the mid-seral stage in these forests when snags will be rare. Leaving live trees in intermediate harvest units will meet this goal. Increasing the vigor of treated areas helps ensure that trees are available for snag recruitment in the future after the current snag pulse is over and the snags existing today have fallen.

Connectivity – Dispersal, Migration, and Travel Corridors The Helena National Forest provides several linkage zones for a variety of species moving within the Forest and between larger landscapes (Walker and Craighead 1997, Craighead 2002,

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 120 American Wildlands 2008 pp. 57-59, 132-134, 157-160 at http://wildlands.org/programs/corridors/pla/hub). Main threats to connectivity include: private land subdivision, sanitation/human conflict issues, increasing highway traffic, forest/forest roads management, forest highways, and mining (American Wildlands 2008). Today, options for movement in the valleys have been eliminated through human development, which has placed an emphasis on the Forest to provide connectivity.

American Wildlands in an attempt to help focus conservation efforts related to the Big Belt Mountains delineated what they consider to be the vital core wildlife habitat and the best wildlife corridor within the central and northern portion of the range in their Corridors of Life analysis. Their delineation was based upon several factors, including: presence of high quality wildlife habitat, observations of wildlife and wildlife sign, presence of terrain features that may limit wildlife movements (steep rock cliffs that exist in several drainages on the west side of the Big Belt Range and along the banks of the Missouri River), and concentrations of human presence and activity (residential development), recreational activities, and consumptive uses such as mining and grazing). See also American Wildlands website for additional information on that analysis – http://www.mcn.net/~amwild/.

American Wildlands also identified several other areas on the Forest as priority linkages including the continental divide west of Helena. This linkage area provides connectivity for wildlife moving along the continental divide and currently functions as a movement corridor for grizzly bear, wolves, lynx, wolverine, and elk.

Empirical and anecdotal data particularly support the Continental Divide as a linkage zone. Wild Things Unlimited (See data in project file) have documented animals moving north and south of Highway 12 and a lynx and wolf have been killed on Highway 12 in the past since 2001.

3.9.7 Effects Common to All Alternatives Neither the Proposed Action nor the No-Action alternative will increase the frequency of certain components that can make movement through the landscape more difficult for some species. There will be no increase in permanent open roads, long-term human settlement, or other developments.

3.9.8 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to dispersal, migration, and travel corridors under the No Action Alternative. Roads would continue to generate disturbance and provide easy access into the project area. These disturbances would fluctuate in the long-term with forest succession and wildfire. Landscape composition (i.e. interior forests, edges, openings) would continue to provide dispersal, migration, and travel corridors until such time as disturbance changes the nature of these corridors temporally and spatially.

3.9.9 Alternative 2 (Proposed Action) Removal of hazard trees from road corridors, developed recreation sites, and administrative sites will open up patches and swaths of forest habitat, and occasionally disrupt movement patterns across the landscape for certain forest obligates (fishers, lynx, northern flying squirrels, marten,

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 121 red squirrels {a lynx prey item}, red-backed voles). However, the No Action alternative will produce similar vegetation changes as dead trees fall or as they are removed for firewood.

Hazard tree treatments would not preclude travel through these sites, but it would complicate movement to a certain degree. Areas of dense forest would remain interspersed with more open habitats along roads, providing a variety of alternate local travel routes. Tree removal is unlikely to deter straight-line movement by forest birds that quickly wing their way across local bits of less favorable habitat.

While project operations are on-going, species wary of human presence (bears, elk, lynx, mountain lions, wolverines, wolves) will find the hazard tree removal activity a local barrier to movement; and for a time they will need to select alternate travel routes or move through the area when workers are not present (at night, on off-days).

Roads can present barriers, bottlenecks, and otherwise impede movement especially for smaller animals or animals with limited mobility (Mader 1984, Swihart and Slade 1984). The extent to which a road acts as a barrier depends on an animal’s behavior, dispersal ability, and population density. The presence of roads can affect animal movement, behaviorally. Some animals avoid crossing roads and may extend their movements to compensate (Trombulak and Frissell 2000). For some species, the mere presence of a road acts as a barrier; for others, the width of the road and associated clearing may represent the barrier (Oxley, et al. 1974). Also the juxtaposition of preferred habitat to roads determines the extent to which a road acts as a barrier (Lovallo and Anderson 1996). Since the Proposed Action is not a road management proposal, this analysis focuses on the impacts associated with hazard tree removal along roads and not the presence of the road itself except in the context of cumulative impacts.

Direct and Indirect Effects In the short term, project activities will complicate movement through the landscape for some species by causing them to alter travel patterns to avoid human activity. Over the long term, removal of hazard trees will thin out vegetative cover within 100-125 feet of treated road segments and developed recreation and administrative sites. While this loss of cover through removal of hazard trees may cause a number of forest obligates to alter movement patterns, it is highly unlikely to serve as a meaningful barrier to seasonal migration, dispersal, or daily movement for any wildlife species.

Treatments would increase sight distances and allow animals moving through the area to be seen from further away. The open grown forest, created by hazard tree removal, would continue to screen large animals such as elk, deer, moose, and black bears, but only at distances of greater than 200 ft. On the other hand, the forage value of the treated areas would be higher than at present, allowing animals more opportunity to feed as they moved through.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 122 by activity type for analysis simplicity. The cumulative effects analysis area for connectivity is the Helena National Forest.

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted connectivity at the time of the activity and for some time thereafter as wildlife adjusted their movement patterns. These impacts are reflected in the environmental baseline since the baseline reflects current vegetation patterns and road use. Road use that is the result of past and ongoing management decisions will continue to impact wildlife that avoid roads. The Proposed Action may cause short-term, temporary disruptions to animal movement but will not impede animal movement.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities could result in impacts to connectivity if the respective Proposed Action is implemented fully. The table Summary of Reasonably Foreseeable Impacts on Connectivity summarizes the potential impacts to connectivity of foreseeable vegetation management projects. The Forestwide Hazard Tree Removal and Fuels Vegetation Project Proposed Action would impact connectivity through the removal of roadside cover. Therefore, these foreseeable projects could contribute to the cumulative effects of the Proposed Action although at the landscape level; species should be able to adjust movement patterns to take advantage of untreated areas immediately adjacent to those areas from which hazard trees will be removed.

Table 3.29 Summary of Reasonably Foreseeable Impacts on Connectivity Grassy Cabin Gulch Warm Springs Telegraph Elliston Stonewall Mountain Vegetation Habitat Mountain Pine Hazardous Vegetation Fuels Management Enhancement Beetle Fuels Management Reduction Salvage Reduction Connectivity at Connectivity at the Connectivity at Connectivity at Some areas Connectivity at the local level local level may be the local level the local level currently the local level may be affected affected by the 0.7 may be affected may be affected providing may be during project miles of roads that by 15 miles of by the 7 miles of connectivity impacted by implementation could remain on the temporary roads temporary roads will lose some temporary roads associated with landscape post overhead removal of cover treatment as well cover and and temporary as through removal structure roads. of forest cover

Irreversible/Irretrievable Commitments Local reduction of vegetation density generated by hazard tree removal can (and will) be reversed by growth and development of understory conifers released by partial overstory thinning. Removal of overstory vegetation in forest communities inherently adapted to regenerating after such events does not represent an irreversible or irretrievable loss of current or past conditions. The process will take a certain amount of time, but it will go forward.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 123 3.9.10 Conclusions The proposed hazard tree removal project will have no meaningful affect on the ability of wildlife species to disperse, migrate, or otherwise move through the forest landscape. Species that tend to avoid roads may experience fewer impacts than those who use roads as habitat or corridors. For those species, hazard tree removal may render an area unsuitable in the short term until such time as species-specific habitat requirements have been recovered. However, the removal of hazard trees is not expected to impede habitat connectivity as alternate routes to travel exist away from roads and administrative sites proposed for hazard tree removal. The Helena Forest Plan does not address habitat connectivity, thus the proposal affects no Forest Plan standards or guidelines for habitat connectivity.

Fragmentation

3.9.11 Effects Common to All Alternatives Neither the Proposed Action nor the No Action Alternatives fragment the forest continuum in the short-term. Over the long-term, neither alternative addresses the build-up of forest fuels that has been generated by the aging of the forests and, more recently, by the rapid accumulation of dead trees resulting from bark beetle infestations. The eventual insertion of wildfire into this environment would dramatically fragment the mature forest landscape.

3.9.12 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to fragmentation under the No Action Alternative. In the short term, roadside vegetation will continue to provide visual screening in the form of standing trees, live or dead. In the long term (> 10 years or so), as trees fall down or are removed through firewood retrieval, roadside vegetation will be converted to younger stands that will vary in their ability to provide roadside cover.

3.9.13 Alternative 2 (Proposed Action) Direct and Indirect Effects Effects of project alternatives on fragmentation are the same as of effects discussed for connectivity, which are addressed in the previous section. The structural changes anticipated with the Proposed Action are similar to those expected for the No Action Alternative as trees fall to the forest floor or are removed for firewood.

Cumulative Effects

The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C of the Wildlife Specialists Report describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for fragmentation is the Helena National Forest.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 124 Past and Ongoing Activities Past and ongoing activities that have resulted in road construction/use and/or changes to vegetation structure and patch size have fragmented habitats for species that avoid roads or that need large, contiguous blocks of a given habitat. The Proposed Action could cumulatively add to these impacts by reducing roadside screening and through temporary increases in road use.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities (e.g. Cabin Gulch Vegetation Management, Grassy Mountain Fuels Reduction, Warm Springs Habitat Enhancement, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) would fragment wildlife habitat in situations where large, contiguous blocks of a given habitat are converted to different seral stages and/or reduced patch size. The Proposed Action would cumulatively add to these impacts by reducing roadside screening and creating additional edge habitat.

Irreversible/Irretrievable Commitments There are no irreversible or irretrievable commitments with regard to fragmentation.

3.9.14 Conclusions The project creates pockets of variably open habitat amidst a vast array of forested environments. The newly thinned sites are themselves the “fragments”. The surrounding untreated forest, meanwhile, is the dominant feature of the landscape. The Helena Forest Plan does not address fragmentation, and the project is therefore in compliance with the Plan.

Elk

3.9.15 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to elk summer range associated with the No Action Alternative. Several elk herd units currently do not meet Forest Plan Standard 3. Hiding cover would continue to decline as forested stands succumb to mountain pine beetle infestations.

There are no direct effects to hiding cover or open road densities under the No Action Alternative. Several elk herd units currently do not meet Forest Plan Standard 4(a). Over time, as trees die due to mountain pine beetle and fall to the forest floor, the conditions that provided hiding cover would no longer exist in the project area.

There are no direct effects to thermal cover on winter range under the No Action Alternative. As with hiding cover, as trees die, they would no longer provide thermal cover for elk.

3.9.16 Alternative 2 (Proposed Action) Effects of the Proposed Action with regard to elk are essentially the same for all elk herd units within all landscapes. Biologically, the removal of large dead and dying trees from 100-125 foot corridors along numerous stretches of open forest roads would reduce hiding cover that may prove useful to elk in some circumstances. While elk generally avoid open roads, particularly

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 125 those with regular vehicle traffic, dense hiding cover provides a means by which elk can approach roads with some surety under certain circumstances—as when key habitat components are nearby or when elk wish to move up to a road undetected before crossing. It also provides a quick means of escape for elk that happen to encounter humans on a roadway. Removal of cover in the road corridors would diminish the frequency of those site-specific opportunities.

Removal or partial removal of forest cover in centers of human activity, such as campgrounds and administrative sites, would have virtually no effect on how elk operate in the forest.

Because hazard tree removal would occur adjacent to or near open roads, the quality of security areas important to elk during the hunting season would not be diminished. Security areas, by definition, are predominantly forested areas at least ½ mile from open roads.

In the short-term, project activities would displace elk from nearby areas, much as would any logging operation. While elk generally choose not to frequent areas near open roads, project operations (cutting and skidding trees, hauling logs) are likely to redistribute them farther from the roads and administrative areas than usual (Lyon et al. 1985, pp. 37-42). The effect would be short-lived.

Effects with regard to the Helena Forest Plan are summarized in the following section and in the Forest Plan consistency section.

Direct and Indirect Effects Removal of hazard trees within the project area would reduce hiding cover on summer range and thermal cover on winter range (Helena Forest Plan Big Game standard #3). The reduction in hiding cover would also affect the hiding cover/open road density index (Helena Forest Plan Big Game standard #4a). Expected changes are summarized below.

Elk Summer Range The table Acres Remaining Post Treatment of Forest Plan Hiding Cover on Elk Summer Range by Elk Herd Unit summarizes the changes associated with the Roadside Hazard Tree treatments. Approximately 17 EHUs do not meet Forest Plan Standard 3 under the proposed action; however, none of these met Standard 3 under the existing condition. Highlighted rows indicate EHUs that do not meet Forest Plan Standard 3. The Standard requires at least 35% (or 50% depending on how hiding cover is calculated) hiding cover on summer range. The percent of Forest Plan hiding cover pre-treatment is provided for comparative purposes. For all EHUs, there are either no changes in the percent hiding cover post-treatment or changes are within a few percentage points.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 126 Table 3.30 Post Treatment Acres of Forest Plan Hiding Cover on Elk Summer Range Elk Herd Unit Total Forest Plan Forest Forest Percent Meets Percent Acres Hiding Plan Plan Forest Plan Forest Plan Forest Plan Summer Cover Hiding Hiding Hiding Standard #3 Hiding Range Acres Cover Cover Cover Cover Pre- Existing Acres Remaining Remaining Treatment Condition Treated Acres Post (for Post Treatment comparison) Treatment Arrastra 27,738 13,018 119 12,899 0.47 No 0.47 Atlanta 20,517 12,909 133 12,776 0.62 Yes 0.63 Battle 33,967 Mountain 4,727 12 4,715 0.14 No 0.14 Beaver 32,406 Creek-Lincoln 18,807 264 18,543 0.57 Yes 0.58 Birch Creek 17,293 12,166 73 12,093 0.70 Yes 0.70 Black 56,339 Mountain – Brooklyn Bridge 29,815 122 29,639 0.53 Yes 0.53 Cabin Creek 37,618 16,943 174 16,769 0.45 No 0.45 Flesher Pass 91,093 38,571 753 37,818 0.42 No 0.42 Greenhorn 30,330 16,727 148 16,579 0.55 Yes 0.55 Greyson 33,894 1,721 31 1,690 0.05 No 0.05 Hedges 52,368 16,795 12 16,783 0.32 No 0.32 Hellgate 31,999 5,079 18 5,061 0.16 No 0.16 Jericho 35,345 22,309 350 21,959 0.62 Yes 0.63 Keep Cool 44,325 17,010 194 16,816 0.38 No 0.38 Landers Fork 136,515 62,178 38 62,140 0.46 No 0.46 Little 34,837 Blackfoot 25,869 332 25,537 0.73 Yes 0.74 Little Prickly 87,022 Pear – Ophir 39,865 511 39,345 0.45 No 0.46 Nevada 38,824 Creek 22,959 399 22,560 0.58 Yes 0.59 North Fork 25,828 3,936 61 3,875 0.15 No 0.15 Ogden 56,310 Mountain 26,419 473 25,946 0.46 No 0.47 Poorman 67,425 Creek 40,980 691 40,289 0.60 Yes 0.61 Prickly Pear 31,051 3,429 2 3,427 0.11 No 0.11 Quartz 36,733 16,483 274 16,209 0.44 No 0.45 Ray Creek 44,885 12,437 51 12,386 0.28 No 0.28 Sheep Creek 43,848 4,681 7 4,674 0.11 No 0.11 South Crow 32,586 7,238 6 7,232 0.22 No 0.22 Spotted Dog 47,477 19,564 231 19,333 0.41 Yes 0.41

Hiding Cover/Open Road Densities The table Post-Treatment Elk Herd Unit Data for Hiding Cover and Open Road Density summarizes the changes associated with the Roadside Hazard Tree treatments. Approximately 22 EHUs do not meet Forest Plan Standard 4(a) under the proposed action; however, none of these met Standard 4(a) under the existing condition. Highlighted rows indicate EHUs that do not meet Forest Plan Standard 4(a). The open road density is the same for the current and post treatment condition as no new roads are being constructed. There would be some activity on seasonally closed roads during the closure period that may disrupt elk movement. The percent of Forest Plan hiding cover pre-treatment is provided for comparative purposes.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 127 For all EHUs, there is either no change in the percent hiding cover post-treatment or changes are within a few percentage points.

Table 3.31 Post Treatment Elk Herd Unit Data for Hiding Cover and Open Road Density Elk Herd Unit Total %Forest Open Road Forest Plan %Forest Plan Meets Forest Square Plan Density During Hiding Cover Hiding Cover Plan Standard Miles Hiding Hunting Remaining Post Treatment #4a Cover Season Acres Post Existing Treatment Condition Arrastra 43 0.47 1.77 12,899 0.47 No Atlanta 32 0.63 0.30 12,776 0.62 Yes Battle Mountain 53 0.14 0.94 4,715 0.14 No Beaver Creek-Lincoln 51 0.58 1.49 18,543 0.57 No Birch Creek 27 0.70 0.65 12,093 0.70 Yes Black Mountain – Brooklyn Bridge 88 0.53 1.89 29,639 0.53 No Cabin Creek 59 0.45 0.82 16,769 0.45 No Flesher Pass 142 0.42 1.28 37,818 0.42 No Greenhorn 88 0.30 1.76 16,679 0.30 No Greyson 53 0.05 1.22 1,690 0.05 No Hedges 82 0.32 1.06 16,783 0.32 No Hellgate 50 0.16 0.74 5,061 0.16 No Jericho 55 0.63 1.22 21,959 0.62 Yes Keep Cool 69 0.38 0.90 16,816 0.38 No Landers Fork 213 0.46 0.50 62,140 0.46 No Little Blackfoot 54 0.74 0.66 25,537 0.73 Yes Little Prickly Pear – Ophir 136 0.46 1.62 39,345 0.45 No Nevada Creek 61 0.59 0.96 22,560 0.58 Yes North Fork 40 0.15 1.24 3,875 0.15 No Ogden Mountain 88 0.47 1.64 25,946 0.46 No Poorman Creek 105 0.61 1.91 40,289 0.60 No Prickly Pear 49 0.11 0.67 3,427 0.11 No Quartz 57 0.45 1.07 16,209 0.44 No Ray Creek 70 0.28 0.86 12,386 0.28 No Sheep Creek 69 0.11 0.73 4,674 0.11 No South Crow 51 0.22 0.88 7,232 0.22 No Spotted Dog 74 0.41 1.51 19,333 0.41 No

Elk Winter Range The table Acres Remaining Post Treatment of Forest Plan Thermal Cover on Elk Winter Range by Elk Herd Unit summarizes the changes associated with the Roadside Hazard Tree treatments. Thirteen EHUs have proposed treatments in thermal cover on winter range. None of these meet Forest Plan Standard 3 under the proposed action; however, none of these met Standard 3 under the existing condition. Highlighted rows indicate EHUs that do not meet Forest Plan Standard 3. The percent of Forest Plan thermal cover pre-treatment is provided for comparative purposes.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 128 For all EHUs, there are either no changes in the percent thermal cover post-treatment or changes are within a few percentage points.

Table 3.32 Post Treatment Acres of Forest Plan Thermal Cover on Elk Winter Range Elk Herd Total Winter Forest Forest Plan Forest Plan % Forest Meets % Forest Plan Unit Acres Range Plan Thermal Thermal Plan Forest Thermal EHU Acres Thermal Acres Cover Acres Thermal Plan Cover Pre- Cover Treated Remaining Cover Post Standard Treatment (for Acres Post Treatment #3 comparison) Existing Treatment Condition Beaver Creek- Lincoln 32,406 8,895 379 25 354 0.040 No 0.043 Birch Creek 17,293 2,838 322 1 321 0.113 No 0.114 Black Mountain – Brooklyn Bridge 56,339 47,980 6,527 4 6,523 0.136 No 0.136 Flesher Pass 91,093 23,236 526 4 522 0.022 No 0.023 Greenhorn 56,314 48,676 2,143 18 2,125 0.044 No 0.044 Greyson 33,894 25,051 97 1 96 0.004 No 0.004 Jericho 35,345 10,148 1,302 11 1,291 0.127 No 0.128 Keep Cool 44,325 8,924 152 8 144 0.016 No 0.017 Little 87,022 33,894 2,299 Prickly Pear – Ophir 1 2,298 0.068 No 0.068 Nevada 38,824 19,507 1,207 Creek 30 1,177 0.060 No 0.062 Ogden 56,310 25,363 1,025 Mountain 32 993 0.039 No 0.040 Poorman 67,425 35,736 2,048 Creek 18 2,030 0.057 No 0.057 Quartz 36,733 19,755 1,423 17 1,406 0.071 No 0.072

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C of the wildlife specialists report describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for elk comprises the elk herd units affected by the project.

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would cumulatively contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) or road management may have impacted elk hiding or thermal cover at the time of the activity. Some of these impacts may linger yet especially those associated with roads.

Ongoing activities that impact elk habitat include road use and management as well as vegetation manipulation projects including the Clancy Unionville Vegetation Management Project which will result in the removal of elk cover. However, vegetation management activities that occurred

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 129 prior to 2005 are reflected in the environmental baseline. The Proposed Action will remove minor amounts of elk habitat with virtually no measurable impact projected.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities could result in removal of elk habitat if the respective Proposed Action is implemented fully. The table Summary of Reasonably Foreseeable Impacts on Elk Hiding Cover (Acres Impacted) summarizes the potential impacts to elk hiding cover of foreseeable vegetation management projects. The Forestwide Hazard Tree Removal and Fuels Vegetation Project Proposed Action would remove hiding cover in all of these herd units. Therefore, these foreseeable projects could contribute cumulative effects to the Proposed Action.

Table 3.33 Summary of Reasonably Foreseeable Impacts on Elk Hiding Cover (Acres Impacted) Grassy Cabin Gulch Warm Telegraph Elliston Stonewall Mountain Vegetation Springs Mountain Hazardous Vegetation Fuels Management Habitat Pine Beetle Fuels Management Reduction Enhancement Salvage Reduction About 24 acres About 2,622 About 492 acres About 1,540 Elk hiding cover About 4,838 of hiding cover acres of hiding of hiding cover acres of hiding will be treated on acres of hiding would be cover would be would be cover would be about 421 acres cover would be removed in the removed in the removed in the removed in the in the Spotted removed in the Battle Mountain Cabin Creek Sheep Creek Jericho EHU and Dog EHU Beaver Creek - Elk Herd Unit EHU and 123 in EHU 2,858 in the Little Lincoln EHU and (EHU) the North Fork Blackfoot EHU 2,112 acres of EHU hiding cover in the Keep Cool EHU

Irreversible/Irretrievable Commitments The proposed action will produce no new roads. None of the reductions in hiding or thermal cover is irreversible or irretrievable. Vegetation grows back and the corresponding habitats.

3.9.17 Conclusions The number of elk has increased dramatically since the early 20th century. Active management has resulted in robust elk numbers that represent more than a 10-fold increase since the 1920s (Figure 3.7).

More recently, elk populations have fluctuated over the past few years and in 2010 numbers are down in several HDs. This is a reflection of survey conditions more so than actual declines in populations. Several of the challenges faced by elk managers in each respective EMU/HD center on access and elk movement onto private land, as well as factors affecting elk security and winter range. While hiding and thermal cover are certainly important habitat components for elk, it’s difficult to draw a correlation between elk numbers and amount of elk thermal and hiding cover since elk numbers have generally been increasing for the past several decades even in those EHUs that are below Forest Plan Standards. It is unlikely, therefore, that the small amount of elk habitat that will be removed under the Proposed Action would alter elk population numbers.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 130 Overall, the Proposed Action will affect elk to some extent by removing cover along roadsides. Some areas will be more deficient in cover than other areas, depending on the number of hazard trees removed. However, hiding and thermal cover will be lost with no action due to the ongoing mountain pine beetle impacts.

Some of the roads proposed for treatment are closed from October 15 through December 1 for elk security during the hunting season. On these roads, treatment and hauling will not occur during the period of October 15 through December 1. This would minimize impacts to elk.

Grizzly Bears

3.9.18 Effects Common to All Alternatives Both the Proposed Action and the No Action Alternative would retain the current open road density in the NCDE Recovery Zone and the Mapped Grizzly Bear Distribution Zone. In practical terms, this means that grizzly bears residing in and moving through the NCDE Recovery Zone, the Mapped Grizzly Bear Distribution Zone north of Mullan Pass and the undesignated region to the south would have to continue contending with road-associated human activity as it stands. This has proved low enough to allow a small number of grizzlies to travel through the area on a regular basis and to apparently maintain a very low resident population in the southern end of the landscape (in conjunction with areas on the adjacent Beaverhead- Deerlodge NF). However, some roads that are designated closed year round or seasonally are proposed for treatments. This could disrupt grizzly bears in those areas causing them to displace to other, less disturbed areas. Treatments and hauling on roads in the Northern Continental Divide Ecosystem and the mapped Grizzly Bear Distribution Zone will occur during the open road period of use or during December and January while bears are hibernating. Treatment and hauling along the yearlong closed road will occur within administrative levels in order to minimize impacts to grizzly bears.

Implications for grizzlies of retaining current open road densities in the Elkhorns and Big Belts landscapes are limited to how grizzlies may react in the future—should they occupy those areas.

3.9.19 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to grizzly bears associated with the No Action Alternative. Indirect effects include reductions of roadside cover as trees die and fall to the ground. However, since grizzly bears generally avoid roads, the lack of roadside cover should not significantly affect grizzly bears.

3.9.20 Alternative 2 (Proposed Action) In addition to maintaining current open road densities, the Proposed Action would have the following impacts on grizzly bears.

In the short term, the Proposed Action would generate considerable local disturbance within targeted areas along road corridors, recreation sites, and administrative sites while project operations are active. While grizzlies, like elk, generally avoid open roads and other sites

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 131 frequented by humans, the project may temporarily displace bears further from these areas than is the norm at present.

Over the long term, the reduction in hiding and screening cover in treated areas is likely to reinforce the aversion that grizzlies already have for these sites. Diminution of cover at sites already avoided by the bears is unlikely to have any meaningful impact on their behavior patterns or put them more at risk from negative encounters with humans.

Direct and Indirect Effects Direct effects to grizzly bears include removal of roadside cover that may reduce the effectiveness of any given area to provide hiding cover along roads. Approximately 768 and 4,260 acres of roadside vegetation would be removed in the NCDE and the mapped Grizzly Bear Distribution Zone, respectively. The table Acres of Vegetation Treatment in the NCDE and the Mapped Grizzly Bear Distribution Zone summarizes acres treated by subunits within the NCDE and the overall mapped Grizzly Bear Distribution Zone. Acres treated within the NCDE and the Mapped Grizzly Bear Distribution Zone are minimal. Furthermore, since grizzly bears generally avoid roads, the lack of roadside cover should not significantly affect grizzly bears.

Table 3.34 Acres of Vegetation Treated in the NCDE & Mapped Grizzly Bear Distribution Zone Total Acres Acres Treated (% of Total Acres) NCDE Alice Creek Subunit 70,226 61 (<1%) Red Mountain Subunit 76,734 260 (<1%) Arrastra Mountain Subunit 69,316 447 (<1%) Total 216,276 768 (<1%) Mapped Grizzly Bear Distribution Zone Total 206,857 4,260 (2%)

Indirect effects include treatment and hauling on roads potentially resulting in disturbance to grizzly bears. The table Miles of Treatments and Associated Haul Routes by Grizzly Bear Use Area and Road Restriction summarizes the number of miles for which treatment is proposed within the NCDE Recovery Zone and the Mapped Grizzly Bear Distribution Zone as well as the associated haul routes. The road restriction code and description are provided to indicate those roads for which mitigation is in place to minimize effects to grizzly bears.

All treatments and haul routes in the NCDE Recovery Zone would occur on roads that are open year-round with the exception of 4.0 miles of treatment and 4.7 miles of hauling that are proposed on a seasonally closed road within the Red Mountain Subunit (which currently exceeds the Interagency Grizzly Bear Committee (IGBC) recommendations for open and total road densities). However, treatment and hauling would occur during the period of time that the road is open or during December and January while bears are hibernating. Therefore, impacts are expected to be minimal.

Several miles of treatment and hauling in the mapped Grizzly Bear Distribution Zone are proposed along roads that are either open year long or seasonally closed with the exception of 0.9 miles of treatment and hauling that are proposed on a road that is closed year-long. All treatments on roads with seasonal closures would occur while those roads are in their open status

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 132 or during December and January while bears are hibernating. Treatment and hauling along the yearlong closed road would occur within administrative levels in order to minimize impacts to grizzly bears. Some disturbance to grizzly bears that may occur in the vicinity of the closed road is anticipated.

Table 3.35 Miles of Treatment & Associated Haul Route by Grizzly Bear Use Area and Road Restriction Code Grizzly Bear Use Miles of Proposed Road Restriction Miles of Proposed Road Restriction Area Treatment Description Haul Routes Description NCDE Recovery Treatment Data Haul Route Data Zone Subunits Alice Creek 3.9 OPEN-HWY LEGAL 10.7 OPEN-HWY LEGAL Arrastra Mountain 24.2 OPEN-HWY LEGAL 28.3 OPEN-HWY LEGAL Red Mountain 4.0 09-RES 11.4 OPEN-HWY LEGAL 4.7 09-RES 9.8 OPEN-HWY LEGAL Mapped Grizzly Treatment Data Haul Route Data Bear Distribution Zone Blackfoot 4.1 15.5 Landscape 0.9 01-RES 0.9 01-RES 0.5 02-RES 0.5 02-RES 11.6 06-RES 38.1 09-RES 34.6 09-RES 14.5 10-RES 13.9 10-RES 2.9 11-RES 1.5 11-RES 106.8 OPEN-HWY LEGAL 79.4 OPEN-HWY LEGAL 0.6 OPEN-RES Continental Divide 0.4 01-RES 0.2 01-RES Landscape 44.7 OPEN-HWY LEGAL 53.7 OPEN-HWY LEGAL 01-RES: Closed yearlong 02-RES: Closed to highway vehicles 10/15 to 12/1; closed to all others except open to snowmobiles 09-RES: Closed to highway vehicles 10/15 through 6/30 10-RES: Closed to highway vehicles 10/15 through 6/30; all others prohibited year round 11-RES: Closed to highway vehicles 9/1 through 6/30; closed to all other vehicles OPEN-HWY Legal: Open year round

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C of the wildlife specialists report describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for grizzly bears includes the NCDE and the Grizzly Bear Distribution Zone.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 133 to persist within the NCDE. Therefore, the hazard tree removal should not present any cumulative impacts relative to past activities.

Ongoing activities that impact grizzly bears include road use and management as well as vegetation manipulation projects. The Proposed Action will remove dead and dying trees where they pose a hazard; however, cumulative impacts associated with ongoing activities should be minor given the roadside focus of the hazard tree removal. Grizzly bears generally avoid roads so the disturbance and removal of roadside vegetation in addition to other ongoing projects will minimally impact grizzly bears.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in vegetation removal and road management (e.g. Stonewall Vegetation Management Project, Blackfoot Winter Travel Planning, and Divide Travel Planning). The Proposed Action is not expected to significantly add to the potential impacts of these reasonably foreseeable impacts so cumulative impacts will be minimal.

Irreversible/Irretrievable Commitments The proposed action would produce no new roads. None of the reductions in cover along roads or at developed recreation and administrative areas is irreversible or irretrievable.

3.9.21 Conclusions Grizzly bears may experience temporary displacement due to removal of roadside cover as well as through treatment and use of roads that have seasonal closures. Activities along roads during their open season are not expected to displace grizzly bears, although the proposed action would increase the level of activity on those roads proposed for treatment. Generally, grizzlies most likely avoid these areas of open roads. The Proposed Action may affect but is not likely to adversely affect grizzly bears.

Lynx

3.9.22 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to lynx under the no action. Indirect effects include reductions of snowshoe hare habitat as trees die and fall to the ground. However, multi-story snowshoe hare habitat should still exist to the extent that the understory remains during the downfall of dead and dying trees. As some stands fall apart, regeneration would provide stand initiation snowshoe hare habitat.

3.9.23 Alternative 2 (Proposed Action) The proposed action would modify some snowshoe hare habitat in the treated areas adjacent to open roads and to a minor extent in campgrounds and administrative sites. Because snowshoe hares have few qualms about making use of suitable habitat near open roads, if it is available, it is likely that some of these areas identified as hare habitat by the Helena National Forest modeling effort are indeed occupied by hares. While dense vegetation useful to hares (primarily

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 134 young conifers, but also broadleaf shrubs) is not being targeted by hazard tree removal operations, it is certain that some of this component would be incidentally damaged or removed during the process. In some cases, this modification may reduce the effectiveness of vegetation as cover for hares; in other cases it would probably make little difference.

Direct and Indirect Effects The table Acres of Lynx Habitat from which Hazard Trees would be Removed summarizes the effects to potential lynx habitat in both the occupied 10 and unoccupied LAUs. Highlighted rows are those LAUs that occur within designated lynx critical habitat.

Table 3.36 Acres of Lynx Habitat from which Hazard Trees would be Removed Multi- Multi- Stand Stand Total Storied Storied Initiation Initiation Other Habitat LAU Hare NOT Hare Hare NOT Hare Habitat Treated Habitat Habitat Habitat Habitat bb-03 2 3 0 0 33 38 bb-04 20 8 2 2 163 195 bb-05 12 0 3 0 64 79 di-01 5 3 1 0 102 111 di-02 26 18 3 0 234 281 di-03 7 5 0 1 161 174 di-04 46 16 1 0 387 450 di-05 35 5 0 0 288 328 di-06 27 12 0 0 186 225 el-01 0 0 0 0 5 5 el-02 0 0 0 0 8 8 el-03 1 0 0 1 29 31 bl-04 1 0 0 0 5 6 bl-05 3 0 0 0 79 82 bl-07 5 1 0 0 310 316 bl-08 0 0 0 0 163 163 bl-09 99 0 2 1 78 90 bl-10 14 0 4 1 445 464 bl-11 3 0 6 1 297 307 bl-12 0 0 3 0 50 53 bl-13 2 0 1 0 331 334 bl-14 3 2 17 14 577 613 bl-15 5 1 0 0 92 98 Total Habitat 316 74 43 21 4,087 4,451 Treated

Two key components of lynx habitat are the multi-story snowshoe hare habitat and the stand initiation snowshoe hare habitat of which 316 and 43 acres are proposed for treatment, respectively. The affected acres are distributed across several LAUs Forest-wide including occupied and unoccupied habitat. Within occupied habitat only, approximately 281 and 38 acres

10 Occupied LAUs include bl-04 through bl-15 and di-01 through di-06. All el and bb LAUs are in unoccupied habitat.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 135 of multi-story snowshoe hare habitat and stand initiation snowshoe hare habitat are proposed for treatment respectively; clearly the majority of all proposed treatment acres are within occupied habitat. Treatments in the Stand Initiation Hare Habitat Stage should only impact the larger trees in those areas. In other words, the younger trees that comprise the Stand Initiation Stage will remain unaffected except through incidental impacts associated with treatments.

The standards and guidelines applicable to this Project from the Northern Rockies Lynx Management Direction (NRLMD) are summarized in the table NRLMD Standards or Guidelines that may be Applicable to the Forest-wide Hazard Tree Removal and Fuels Reduction Project.

Table 3.37 NRLMD Standards or Guidelines Applicable to the Forest-wide Hazard Tree Removal and Fuels Reduction Project Standard Description Guideline Met? or Guideline HU G6 Methods to avoid or reduce effects to lynx Roads may be upgraded to Best Management should be used in lynx habitat when upgrading Practice (BMP) standards to minimize effects unpaved roads to maintenance levels 4 or 5, if to watershed and soil resources. the result would be increased traffic speeds and volumes, or a foreseeable contribution to increases in human activity or development. HU G11 Designated over-the-snow routes, or Guideline not applicable. designated play areas, should not expand outside baseline areas of consistent snow compaction1, unless designation serves to consolidate use and improve lynx habitat. This is calculated on an LAU basis, or on a combination of immediately adjacent LAUs. This does not apply inside permitted ski area boundaries, to winter logging, to rerouting trails for public safety, to accessing private inholdings, or to access regulated by Guideline HU G12. All S1 New or expanded permanent development Standard is met; removal of hazard trees and vegetation management projects must should not impede the ability of lynx to move maintain habitat connectivity in an LAU and/or through individual LAUs or through the larger linkage area. landscape (i.e. continental divide). Koehler (1990) reported that lynx will travel through silviculturally thinned stands. VEG S1 Unless a broad scale assessment has been Standard is not applicable since no more than completed that substantiates different historic 30 percent of each LAU is currently in a stand levels of stand initiation structural stages limit initiation structural stage that does not yet disturbance in each LAU as follows: if more provide winter snowshoe hare habitat. See than 30 percent of the lynx habitat in an LAU table Lynx Habitat within Lynx Analysis Units is currently in a stand initiation structural stage (LAU) within the Project Area. Furthermore, that does not yet provide winter snowshoe regeneration is not a component of the hare habitat, no additional habitat may be Proposed Action. regenerated by vegetation management projects. VEG S2 Timber management projects shall not Standard is not applicable since regeneration regenerate more than 15 percent of lynx harvest is not a component of the Proposed habitat on NFS lands within an LAU in a ten- Action. Regeneration harvest is defined in the year period. NRLMD as “the cutting of trees and creating an entire new age class; an even-age harvest”. VEG S5 Precommercial thinning projects that reduce Standard is not applicable since snowshoe hare habitat may occur from the precommercial thinning is not a component of stand initiation structural stage until the stands the Proposed Action. Precommercial thinning

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 136 Standard Description Guideline Met? or Guideline no longer provide winter hare habitat only (1) is defined in the NRLMD as “mechanically within 200 feet of administrative sites, removing trees to reduce stocking and dwellings, outbuildings, recreation sites, and concentrate growth on the remaining trees special use permit improvements, including and not resulting in any financial return. infrastructure within permitted ski area boundaries; (2) for research studies, etc.; (3) based on new, peer reviewed information; (4) for aspen; and (5) for whitebark pine. VEG S6 Vegetation management projects that reduce Standard is met as it fits within the exceptions snowshoe hare habitat in multi-story mature or listed for VEG S6. Multi-story habitat will be late-successional forests may occur only (1) impacted within 200 feet of administrative sites within 200 feet of administrative sites, and recreation sites. Along roadsides, dwellings, outbuildings, recreation sites, and salvage of dead and dying trees will occur special use permit improvements, including within multi-story habitat which will in turn be infrastructure within permitted ski area impacted due to location of skid trails. The boundaries.; (2) for research studies, etc.; and NRLMD defines salvage harvest as “a (3) for incidental removal during salvage commercial timber sale of dead, damaged, or harvest (e.g. removal due to location of skid dying trees. It recovers economic value that trails). would otherwise be lost.” VEG S1 Unless a broad scale assessment has been Standard is not applicable since no more than completed that substantiates different historic 30 percent of each LAU is currently in a stand levels of stand initiation structural stages limit initiation structural stage that does not yet disturbance in each LAU as follows: if more provide winter snowshoe hare habitat. See than 30 percent of the lynx habitat in an LAU table Lynx Habitat within Lynx Analysis Units is currently in a stand initiation structural stage (LAU) within the Project Area. Furthermore, that does not yet provide winter snowshoe regeneration is not a component of the hare habitat, no additional habitat may be Proposed Action. regenerated by vegetation management projects. VEG S2 Timber management projects shall not Standard is not applicable since regeneration regenerate more than 15 percent of lynx harvest is not a component of the Proposed habitat on NFS lands within an LAU in a ten- Action. Regeneration harvest is defined in the year period. NRLMD as “the cutting of trees and creating an entire new age class; an even-age harvest”. VEG S5 Precommercial thinning projects that reduce Standard is not applicable since snowshoe hare habitat may occur from the precommercial thinning is not a component of stand initiation structural stage until the stands the Proposed Action. Precommercial thinning no longer provide winter hare habitat only (1) is defined in the NRLMD as “mechanically within 200 feet of administrative sites, removing trees to reduce stocking and dwellings, outbuildings, recreation sites, and concentrate growth on the remaining trees special use permit improvements, including and not resulting in any financial return. infrastructure within permitted ski area boundaries; (2) for research studies, etc.; (3) based on new, peer reviewed information; (4) for aspen; and (5) for whitebark pine. VEG S6 Vegetation management projects that reduce Standard is met as it fits within the exceptions snowshoe hare habitat in multi-story mature or listed for VEG S6. Multi-story habitat will be late-successional forests may occur only (1) impacted within 200 feet of administrative sites within 200 feet of administrative sites, and recreation sites. Along roadsides, dwellings, outbuildings, recreation sites, and salvage of dead and dying trees will occur special use permit improvements, including within multi-story habitat which will in turn be infrastructure within permitted ski area impacted due to location of skid trails. The boundaries.; (2) for research studies, etc.; and NRLMD defines salvage harvest as “a (3) for incidental removal during salvage commercial timber sale of dead, damaged, or harvest (e.g. removal due to location of skid dying trees. It recovers economic value that trails). would otherwise be lost.”

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 137 Critical Habitat Several LAUs are within lynx critical habitat: bl-04 through bl-15 and di-01, di-02, and di-05. The table Effects of the Proposed Action on Primary Constituent Elements summarizes how the proposed action impacts those PCEs. The Proposed Action will not adversely affect lynx critical habitat at the LAU and critical habitat unit levels.

Table 3.38 Effects of the Proposed Action on Primary Constituent Elements Primary Constituent Element Effects of the Proposed Action Presence of snowshoe hares and their preferred Snowshoe hare habitat in lynx critical habitat will be habitat conditions, including dense understories of impacted by the proposed action as follows: young trees or shrubs tall enough to protrude above approximately 201 acres of multi-story snowshoe hare the snow habitat will be affected and 37 acres of stand initiation snowshoe hare habitat. Many of these acres will continue to provide snowshoe hare habitat post- treatment as treatment is designed to remove only hazard trees. Winter snow conditions that are generally deep and Where hazard tree removal is proposed during winter fluffy for extended periods of time on open roads, there should be no need for additional snow plowing. If however, a given road has a winter closure and is utilized in the winter for this project, snowplowing may be necessary which could lead to snow compaction and increased competition from competitors. Sites for denning having abundant, coarse woody Given the abundance of hazard trees within lynx debris, such as downed trees and root wads critical habitat, availability of denning sites should not be compromised by the removal of hazard trees in the project area. Matrix habitat (e.g., hardwood forests, dry forest, non- The Proposed Action treatment sites are scattered forest, or other habitat types that do not support through lynx critical habitat such that travel by lynx snowshoe hares) that occurs between patches of should not be impeded. Approximately 5,580 acres boreal forests in close juxtaposition (at the scale of a are proposed for treatment within the 429,275 acre lynx home range) such that lynx are likely to travel critical habitat boundary. This represents about 1% of through such habitat while accessing patches of boreal the critical habitat. forest within a home range

All primary constituent elements would remain functional under the Proposed Action. Multistory hare habitat impacts range from 1 to 99 acres within 12 different LAUs in critical habitat. Stand initiation impacts range from 1 to 17 acres within 8 different LAUs in critical habitat. These impacts do not significantly reduce the quality or quantity of snowshoe hare habitat at the landscape scale and will not impede the ability of the landscape to produce adequate densities of snowshoe hares to support persistent lynx populations. Neither does the Proposed Action change the vegetation structure to the extent that it would impede lynx movement between patches of foraging and denning habitat since habitat is well distributed beyond the confines of the Proposed Action. Critical habitat will not be appreciably diminished.

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C of the wildlife specialists report describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for lynx comprises the lynx analysis units affected by the project.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 138 Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted lynx habitat at the time of the activity. Some of these impacts remain especially where multi-story snowshoe hare habitat has not yet been re-established.

Ongoing activities that impact lynx habitat include snowmobile activities and vegetation manipulation projects. While all management activities comply with the Northern Rockies Lynx Management Direction, the Proposed Action does remove some lynx foraging habitat and would therefore cumulatively add to the impacts of past and ongoing activities.

Ongoing activities that impact lynx habitat include snowmobile activities, vegetation manipulation projects, and the Continental Divide National Scenic Trail (CDNST) reconstruction which will remove up to ½ acre of multi-story snowshoe hare habitat. While all management activities comply with the Northern Rockies Lynx Management Direction, the Proposed Action does remove some lynx foraging habitat and will therefore cumulatively add to the impacts of past and ongoing activities.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities could result in removal of lynx habitat if the respective Proposed Action is implemented fully. The table Summary of Reasonably Foreseeable Impacts on Multistory and Stand Initiation Hare Habitat (Acres Impacted) summarizes the potential impacts to lynx habitat (multistory and stand initiation hare habitat) of foreseeable vegetation management projects. The Forestwide Hazard Tree Removal and Fuels Vegetation Project Proposed Action would remove lynx habitat in all of these LAUs. Therefore, these foreseeable projects could contribute to the cumulative effects of the Proposed Action.

Table 3.39 Reasonably Foreseeable Impacts on Multistory and Stand Initiation Hare Habitat Telegraph Mountain Pine Beetle Stonewall Vegetation MacDonald Pass Ski Trail Hazard Salvage Management Tree Removal In lynx analysis unit (LAU) di-03, 32 In LAU bl-07, 24 acres of multistory In LAU di-05, approximately 10 to acres of stand initiation hare habitat hare habitat and 10 acres of stand 15 acres of multistory hare habitat will be treated in the wildland interface initiation hare habitat will be treated will be impacted (WUI) , in LAU di-04 about 89 acres in the WUI and in bl-08 60 acres of of stand initiation hare habitat and 43 multistory hare habitat and 10 acres acres of multi-story hare habitat in the of stand initiation hare habitat will WUI will be treated be treated in the WUI

Irreversible/Irretrievable Commitments None of the damage to understory vegetation in the roadside project sites represents an irreversible or irretrievable loss of potential snowshoe hare habitat. Most of the compromised cover would restore itself in short order.

3.9.24 Conclusions Most of the lynx habitat that is impacted is characterized as ‘other lynx habitat’ While some of the understory cover utilized by hares would be incidentally damaged during falling and skidding operations, it would not be targeted for removal, and much of it would remain intact. Roadside

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 139 hazard tree removal, as proposed here, is in fact a classic “salvage” operation. The roadside operation thus complies with the NLRMD. The Proposed Action may affect but is not likely to adversely affect lynx and/or its critical habitat and therefore it is consistent with Forest Plan Standards.

Fisher 3.9.25 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects to either summer or winter fisher habitat associated with Alternative 1. As forested stands associated with fisher habitat move through succession, they will remain susceptible to insects, disease, and fire particularly in pine dominated stands. More dead and dying wood would accumulate in the short term, increasing coarse woody debris for fishers. However, canopy cover will decrease in stands that are killed by mountain pine beetle and other mortality agents reducing the habitat quality and quantity for fishers.

3.9.26 Alternative 2 (Proposed Action) Fishers appear to select structure rather than forest type—vertical and horizontal complexity—CWD, light gaps, and overhead cover. Fishers need structure that leads to high diversity of dense prey populations, structure that leads to high vulnerability of prey, and structure that provides natal and maternal dens and resting sites (Ruggiero et al. 1994). Factors that affect these requirements will displace fisher into forests outside of the treated areas.

Direct and Indirect Effects Direct Effects Direct effects include the removal of approximately 2,048 acres of fisher summer habitat and 2,502 acres of fisher winter habitat. This represents about 3% of summer habitat and 1% of winter habitat. Virtually all large snags and near-term potential snags (dying trees) created by the ongoing beetle epidemic will be removed from project area sites. Removal of hazard trees from road corridors and administrative sites will affect an area representing a maximum of 1% (an estimated 9,416 acres) of the area over which snags are proliferating on the HNF. That is, new snag habitat is being created at a far greater rate than proposed hazard tree removal will reduce it.

Indirect Effects Indirect effects to fisher and their habitat are primarily associated with the ability of fisher to move through treated areas. Cover will decline and forest obligates that regularly move long distances under cover such as fisher are likely to choose alternate routes through dense forest habitat. Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for fisher is the Helena National Forest.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 140 Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted fisher habitat at the time of the activity. Some of these impacts may still be apparent in those areas not yet capable of meeting fisher habitat requirements. The removal of fisher habitat associated with the Proposed Action will not add to the impacts of past activities in a measurable way.

Ongoing activities that impact fisher habitat include the Clancy Unionville Vegetation Management project. That project may impact fisher habitat although since the mountain pine beetle has killed several hundreds of acres of trees not as many ‘green’ acres are being treated as originally proposed. Furthermore, riparian areas will be protected during project implementation. Therefore impacts to fisher and/or their habitat should be minor upon implementation of the Clancy Unionville project.

This Proposed Action will remove dead and dying trees where they pose a hazard which could reduce fisher habitat quality on 1% to 3% of winter and summer fisher habitat, respectively. Therefore, the removal of fisher habitat associated with the Proposed Action will add to the impacts of past activities.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of fisher and snag habitat (e.g. Cabin Gulch Vegetation Management, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). These reasonably foreseeable projects will add to the impacts of the Proposed Action

Irreversible/Irretrievable Commitments Removing fisher habitat through reduction of hazard trees (snags and subsequent coarse, woody debris) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and fisher habitat, will remain.

3.9.27 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • That the treated areas will represent less than 3% of the newly expanded snag resource, • That the expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • That the treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 141 snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Fishers are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.), the proposed treatments, while diminishing travel opportunities for local individuals, will have no meaningful impact on fisher and/or their habitat in any of the 4 affected landscapes on the Helena National Forest. While other projects also remove fisher habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

Black-Backed Woodpecker Black-backed woodpeckers occur throughout the Helena National Forest associated with areas that have burned within the last 10 years. None of the hazard tree removal is associated with any of these burned areas. It’s possible that as hazard trees become attractive to wood boring beetles, the preferred food of black-backed woodpeckers, the removal of these trees could remove some foraging habitat for black-backed woodpeckers.

3.9.28 Alternative 1 (No Action Direct and Indirect Effects There are no direct effects to black-backed woodpeckers associated with the No Action Alternative. Indirect effects include continued widespread mountain pine beetle outbreaks and subsequent tree mortality that could provide new food sources for black-backed woodpeckers.

3.9.29 Alternative 2 (Proposed Action) Direct and Indirect Effects Direct effects include the removal of approximately 9,416 acres of hazard trees that could provide future foraging habitat for black-backed woodpeckers as wood boring beetles inhabit those trees killed by the mountain pine beetle. However, to date, black-backed woodpeckers have not been detected in forested stands that have been killed by insects.

Removal of hazard trees from road corridors and administrative sites will affect an area representing a maximum of 1% (an estimated 9,416 acres) of the area over which snags are proliferating on the HNF. That is, new snag habitat is being created at a far greater rate than proposed hazard tree removal will reduce it.

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for black-backed woodpeckers is the Helena National Forest.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 142 Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute relative to black-backed woodpecker habitat since all evidence to date indicates that black-backed woodpeckers are strongly associated with burned areas. Therefore, the removal of hazard trees associated with the Proposed Action should not add to the impacts of past activities.

Ongoing activities that impact black-backed woodpecker habitat include the Clancy Unionville Vegetation Management project. That project will remove snags that may provide a food source for black-backed woodpeckers should black-backs begin to colonize insect infested forested stands. However, given the abundance of snags across the Forest, the Proposed Action is not expected to add to the potential impacts of these reasonably foreseeable impacts so there are no anticipated cumulative impacts.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of snag habitat (e.g. Cabin Gulch Vegetation Management, Warm Springs Habitat Enhancement Project, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). These reasonably foreseeable projects are not expected to significantly add to the impacts of the Proposed Action since they do not involve the removal of burned forests.

Irreversible/Irretrievable Commitments Removing existing snags from roadside corridors and local administrative areas will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation will remain and therefore foraging opportunities for black-backed woodpeckers.

3.9.30 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • That the treated areas will represent less than 3% of the newly expanded snag resource, • That the expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • That the treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Black-backed woodpeckers are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.)

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 143 The proposed treatments will have no meaningful impact on black-backed woodpeckers and/or their habitat.

Flammulated Owl 3.9.31 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects associated with the No Action Alternative. Flammulated owl habitat would continue to wax and wane as the mountain pine beetle runs its course. Snags along roadsides will most likely succumb to firewood retrieval.

3.9.32 Alternative 2 (Proposed Action) Direct and Indirect Effects The proposed action treats approximately 1,349 acres of potential flammulated owl habitat. Flammulated owls consistently select habitat that combines open forest stands with large trees and snags for nesting and foraging, occasional clusters of thick understory vegetation for roosting and calling, and adjacent grassland openings that provide optimum edge habitat for foraging. The removal of hazard trees will reduce the availability of large trees and snags that flammulated owls use for nesting and foraging. However, removal of hazard trees is restricted to about 1% (about 9,416 acres) of the Forest and new snag habitat is being created at a far greater rate than the proposed hazard tree removal will reduce it. Therefore, impacts to flammulated owl nesting and foraging habitat are expected to be minimal.

Flammulated owls are tolerant to humans in general and nest abandonment is rare if owls are disturbed. However, responses to mechanical disturbances (thinning) that flush roosting adult birds may pose a threat in October when birds are migrating (Hayward and Verner 1994, page 41).

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted flammulated owl habitat at the time of the activity. Some of these impacts may still be apparent in those areas not yet capable of meeting flammulated owl habitat requirements. Therefore, the removal of flammulated owl habitat associated with the Proposed Action will add to the impacts of past activities.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 144 Ongoing activities that impact flammulated owl habitat include the Clancy Unionville Vegetation Management project. That project may impact flammulated owl habitat although since the mountain pine beetle has killed several hundreds of acres of trees not as many ‘green’ acres are being treated as originally proposed. However, some areas that are being treated are in potential flammulated owl habitat and treatments will actually open up the canopy and eventually lead to conditions more favorable to flammulated owls. No cumulative impacts are expected with ongoing activities.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of flammulated owl and snag habitat (e.g. Cabin Gulch Vegetation Management, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). These reasonably foreseeable projects will add to the impacts of the Proposed Action.

Irreversible/Irretrievable Commitments Removing flammulated owl habitat through reduction of hazard trees (snags and subsequent coarse, woody debris) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and flammulated owl habitat, will remain.

3.9.33 Conclusions Given that” • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • That the treated areas will represent less than 3% of the newly expanded snag resource, • That the expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • That the treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Flammulated owls are regarded as apparently secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.), the proposed treatments, while diminishing habitat for local individuals, will have no meaningful impact on flammulated owls and/or their habitat in any of the 4 affected landscapes on the Helena National Forest. While other projects also remove flammulated owl habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 145 Northern Goshawk – Old Growth Dependent Management Indicator (MIS) Group Goshawks hunt for prey in the closed-canopied nesting stands; but they also forage through a variety of other habitat structures, including open-grown stands, old-growth, forest/meadow mosaics, forest edges, and a mix of forest seral stages, as long as prey is abundant. Goshawk home ranges may thus encompass a variety of forest and non-forest habitat configurations

3.9.34 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects associated with the No Action Alternative. Northern goshawk habitat will most likely decline in areas impacted by mountain pine beetle including along roadsides.

3.9.35 Alternative 2 (Proposed Action) Direct and Indirect Effects The proposed action treats approximately 4,615 acres of nesting habitat in the project area, concentrated along roadsides. Goshawks will nest adjacent to roads if habitat conditions are present so the removal of hazard trees could disturb goshawks attempting to nest in the vicinity. The removal of the hazard trees in and of itself shouldn’t impact goshawk nesting habitat. These hazard trees have lost or will lose their canopy cover potentially rendering an area unsuitable as nesting habitat. Goshawks prefer overhead canopy cover for nesting as a means of protection from overhead predators. Foraging habitat may be reduced since the removal of hazard trees – i.e. snags – removes habitat for some goshawk prey species. However, Goshawks should still be able to find preferred prey species in these stands (red squirrels, mid-sized song-birds, ground squirrels, grouse) and will probably still make use of them for foraging (Reynolds et al. 1992, Clough 2000).

Figure 3. 8 Known Goshawk Locations and Territories

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 146 There are at least 27 goshawk nests on the Forest, 14 of which overlap with proposed treatment areas (Figure 3.8). Not all of these nests are currently active; at least 7 are active based on data collected in 2010. Upon project implementation all of these territories will continue to comprise at least 180 acres of nesting habitat per Reynolds et al. (1992) and a diversity of forest and grass stands that provide post-fledgling and foraging habitat sufficient to provide for resident goshawks.

Ongoing activities that impact goshawk habitat include the Clancy Unionville Vegetation Management project. That project may impact goshawk habitat although since the mountain pine beetle has killed several hundreds of acres of trees not as many ‘green’ acres are being treated as originally proposed. However, some areas that are being treated are in goshawk habitat and treatments will open up the canopy in these stands. Cumulative impacts are expected to be minimal with ongoing activities associated with the Hazard Tree Removal and Fuels Reduction Project.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities could result in removal goshawk nesting habitat if the respective Proposed Action is implemented fully. The table Summary of Reasonably Foreseeable Impacts on Goshawk Nesting Habitat (Acres Impacted) summarizes the potential impacts to goshawk nesting habitat of foreseeable vegetation management projects. About 9,000 acres of nesting habitat could be removed in the projects identified in the table. If no considerations are given to maintaining at least 180 acres of nesting habitat per home range, these reasonably foreseeable projects would result in a reduction of nesting habitat and a subsequent reduction in the number of nesting pairs the Forest could support. However, not all of these acres would be removed since at least 180 acres per home range would be retained. So, it’s reasonable to anticipate that there would be no reductions in the amount of nesting pairs the Forest can sustain.

The Forest-wide Hazard Tree Removal and Fuels Vegetation Project Proposed Action would remove nesting habitat in all of these general project areas. Therefore, these foreseeable projects could contribute to the cumulative effects of the Proposed Action.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 147 Table 3.40 Summary of Reasonably Foreseeable Impacts on Goshawk Nesting Habitat (Acres Impacted) Grassy Cabin Gulch Warm Telegraph Elliston Stonewall Mountain Vegetation Springs Mountain Hazardous Vegetation Fuels Management Habitat Pine Beetle Fuels Management Reduction Enhancement Salvage Reduction 453 acres of 2,379 acres of Any goshawk Goshawk Goshawk About 4,884 goshawk goshawk nesting habitat nesting habitat habitat will be acres of nesting habitat nesting habitat that does not would be impacted on goshawk would be would be succumb to the treated; approximately nesting habitat treated treated; mountain pine however, at 410 acres will be treated; harvested and however, at beetle would not least 180 acres however 180 about 958 least 180 acres be treated of nesting acres of nesting underburned; of nesting habitat will habitat per however, at habitat will remain in the home range will least 180 acres remain in the occupied and be retained of nesting both the the six habitat will occupied and unoccupied remain in the unoccupied home ranges both the home ranges occupied and unoccupied home ranges

Irreversible/Irretrievable Commitments Removing goshawk habitat through reduction of hazard trees (snags and subsequent coarse, woody debris that provides foraging and post-fledgling structure and habitat) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and goshawk habitat, will remain.

3.9.36 Conclusions Given that • Adequate nesting habitat will remain to provide at least 180 acres per home range, • Post-fledging habitat will continue to comprise a diversity of structural stages, • Foraging habitat will continue to provide prey opportunities although prey assemblages may shift from those associated with snags to those associated with openings, and • Goshawks are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.), the proposed treatments will have no meaningful impact on northern goshawks and/or their habitat in any of the 4 affected landscapes on the Helena National Forest. While other projects also remove northern goshawk habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

In essence, implementation of the Forest-wide Hazard Tree and Fuels Reduction Project will not reduce the ability of the Forest to provide nesting habitat for each respective home range on the Forest.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 148 Pileated Woodpecker– Old Growth Dependent MIS Group 3.9.37 Alternative 1 (No Action) There are no direct effects associated with the No Action Alternative. Pileated woodpecker habitat will most likely decline in areas impacted by mountain pine beetle associated with firewood retrieval activities. However, sufficient snags will continue to be recruited Forest-wide as the mountain pine beetle epidemic runs its course. Dead wood habitat is expected to increase under the No Action Alternative.

3.9.38 Alternative 2 (Proposed Action) Direct and Indirect Effects The proposed action will treat approximately 3,787 acres of pileated woodpecker habitat in patches that range from less than one acre up to about 90 acres. Bunnell et al. (2002) found that partial harvest – which is, in essence, the hazard tree removal - did not affect the abundance of primary nesters in most cases. In some cases, abundance increased perhaps due to small openings and creation of edges. Therefore, effects to pileated woodpeckers should not be as pronounced in these treatments since they emulate partial harvest. Snag and down wood habitat will continue to be abundant Forest-wide at least in the short term while snags remain standing. Most of the Forest will remain untreated. These areas will continue to provide pileated woodpecker habitat.

Based on McClelland (1977), pileated woodpeckers should continue to persist in the project area at “normal” densities (one pair per 640 acres) since no treatment is larger than 90 acres and most are in patches of 10 acres or less. Furthermore, although large snags are limited Forestwide, the Proposed Action will be concentrated on trees killed by mountain pine beetle (mainly lodgepole pine). The table Mean Snag Density per Acre Inside and Outside of Wilderness/Roadless Areas for Snag Analysis Groups: Lodgepole Pine Dominance Group (PICO) and All Other Dominance Groups by Habitat Type Group for the Helena National Forest in the Snag Section indicates that there are no lodgepole pine 20 inches or greater in diameter. Therefore, although snags are proposed for removal under the Proposed Action, impacts to pileated woodpecker nesting habitat should be minimal.

Cumulative Effects The cumulative effects analysis considers past, present, and reasonably foreseeable actions. Appendix C describes in detail past, reasonably foreseeable, and ongoing activities on lands administered by the Helena National Forest. A brief synopsis is provided here and categorized by activity type for analysis simplicity. The cumulative effects analysis area for pileated woodpeckers is the Helena National Forest.

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted pileated woodpecker habitat at the time of the activity. Some of these impacts may still be apparent in those areas not yet capable of meeting pileated woodpecker habitat requirements. However, this would mainly be in those areas where trees have not reached optimal size for pileated woodpecker nesting

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 149 structure. The removal of pileated woodpecker habitat associated with the Proposed Action will not have a cumulative impact.

Ongoing activities that impact pileated woodpecker habitat include the Clancy Unionville Vegetation Management project. That project may impact woodpecker habitat through the removal of large snags. However, since snags continue to be abundant Forest-wide cumulative impacts are not anticipated with ongoing activities associated with the Hazard Tree Removal and Fuels Reduction Project.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of pileated woodpecker habitat (e.g. Cabin Gulch Vegetation Management, Grassy Mountain, Warm Springs Habitat Enhancement, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). The table Summary of Reasonably Foreseeable Impacts on Pileated Woodpecker Habitat (Acres Impacted) summarizes the potential impacts to pileated woodpecker habitat of foreseeable vegetation management projects. These reasonably foreseeable projects will add to the impacts of the Proposed Action.

Table 3.41 Summary of Reasonably Foreseeable Impacts on Pileated Woodpecker Habitat (Acres Impacted) Grassy Cabin Gulch Warm Telegraph Elliston Stonewall Mountain Vegetation Springs Mountain Hazardous Vegetation Fuels Management Habitat Pine Beetle Fuels Management Reduction Enhancement Salvage Reduction 1,831 acres of 2,698 acres of 614 acres of 1,836 acres of No measurable 2,961 acres of pileated pileated pileated pileated effects to pileated woodpecker woodpecker woodpecker woodpecker pileated woodpecker habitat would habitat would habitat would habitat would woodpecker habitat would treated; treated; treated; treated; habitat treated; however, however, however, however, however, treated acres treated acres treated acres treated acres treated acres will not will not will not will not will not compromise compromise compromise compromise compromise home ranges home ranges home ranges home ranges home ranges

Irreversible/Irretrievable Commitments Removing pileated woodpecker habitat through reduction of hazard trees (snags and subsequent coarse, woody debris that provides foraging and post-fledgling structure and habitat) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and goshawk habitat, will remain.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 150 3.9.39 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • Treated areas will represent less than 3% of the newly expanded snag resource, • Expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • Treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Pileated woodpeckers are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.); the proposed treatments will have no meaningful impact on pileated woodpeckers and/or their habitat in any of the 4 affected landscapes on the Helena National Forest. While other projects also remove pileated woodpecker habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

In essence, implementation of the Forest-wide Hazard Tree and Fuels Reduction Project will not appreciably lower the potential of the Forest to support pileated woodpeckers.

Hairy Woodpeckers- Snag Dependent MIS Group Hairy woodpeckers utilize a variety of habitats and are generally associated with snags and down wood habitat. Snags provide nesting habitat; snags and down wood provide foraging habitat. Hairy woodpeckers forage on a variety of prey items including insects and woodpeckers tend to concentrate in areas of insect outbreaks. Hairy woodpeckers forage on a variety of substrates including snags and down wood.

3.9.40 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects associated with the No Action Alternative. Hairy woodpecker habitat will most likely decline in areas impacted by mountain pine beetle associated with firewood retrieval activities along roadsides. However, sufficient snags will continue to be recruited Forest-wide as the mountain pine beetle epidemic runs its course. Dead wood habitat is expected to increase under the No Action Alternative.

Alternative 2 (Proposed Action) Direct and Indirect Effects The proposed action will treat approximately 3,801 acres of hairy woodpecker habitat. Bunnell et al. (2002) found that partial harvest – which is, in essence, the hazard tree removal - did not affect the abundance of primary nesters in most cases. In some cases, abundance increased perhaps due to small openings and creation of edges. Therefore, effects to hairy woodpeckers

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 151 should not be measurable as these treatments emulate partial harvest. Snag and down wood habitat will continue to be abundant Forest-wide at least in the short term while snags remain standing. Most of the Forest will remain untreated. These areas will continue to provide hairy woodpecker habitat.

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted hairy woodpecker habitat at the time of the activity. Some of these impacts may still be apparent in those areas not yet capable of meeting hairy woodpecker habitat requirements. However, this would mainly be in those areas where trees have not reached optimal size for hairy woodpecker nesting structure. Given the abundance, though, of snag habitat Forest-wide, and the generalist habitat preferences of hairy woodpeckers, the removal of hairy woodpecker habitat associated with the Proposed Action will not add to the impacts of past activities.

Ongoing activities that impact hairy woodpecker habitat include the Clancy Unionville Vegetation Management project. That project may impact woodpecker habitat through the removal of snags. However, since snags continue to be abundant Forest-wide cumulative impacts are not anticipated with ongoing activities associated with the Hazard Tree Removal and Fuels Reduction Project.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of pileated woodpecker habitat (e.g. Cabin Gulch Vegetation Management, Grassy Mountain, Warm Springs Habitat Enhancement, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). These reasonably foreseeable projects are not expected to significantly add to the impacts of the Proposed Action.

Irreversible/Irretrievable Commitments Removing hairy woodpecker habitat through reduction of hazard trees (snags and subsequent coarse, woody debris that provides foraging and post-fledgling structure and habitat) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and goshawk habitat, will remain.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 152 3.9.41 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • Treated areas will represent less than 3% of the newly expanded snag resource, • Expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • Treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Hairy woodpeckers are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.); the proposed treatments will have no meaningful impact on hairy woodpeckers and/or their habitat in any of the 4 affected landscapes on the Helena National Forest. While other projects also remove hairy woodpecker habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

In essence, implementation of the Forest-wide Hazard Tree and Fuels Reduction Project will not appreciably lower the potential of the Forest to support hairy woodpeckers.

American Marten – Mature Forest Dependent MIS Group Studies have indicated that snags and down wood are important habitat components for martens as cover, rest sites, den sites, under snow structures, and hunting (Bull et al 1997).

3.9.42 Alternative 1 (No Action) Direct and Indirect Effects There are no direct effects associated with the No Action Alternative. Marten habitat will most likely decline in areas impacted by mountain pine beetle associated with firewood retrieval activities along roadsides. However, sufficient snags will continue to be recruited Forest-wide as the mountain pine beetle epidemic runs its course. Dead wood habitat is expected to increase under the No Action Alternative.

3.9.43 Alternative 2 (Proposed Action) Direct and Indirect Effects The proposed action would treat approximately 4,286 acres of marten habitat. Virtually all large snags and near-term potential snags (dying trees) created by the ongoing beetle epidemic will be removed from project area sites. However, since most of the hazard trees that will be removed comprise lodgepole pine (due to the mountain pine beetle outbreak), few large trees (20 inches and greater in diameter) will be removed since lodgepole pines of this size are limited Forest- wide. Also, mitigation measures designed to ensure sufficient coarse woody debris is retained on site for the benefit of soil resources will ensure that foraging habitat will remain in treated areas.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 153 Those few large snags remaining or developing in the road corridor in the future are likely to be removed by firewood cutters. Because of the scarcity of snags on either side of the road, firewood cutters are likely to be drawn further into the forest to take visible snags from non- treated stands beyond the corridor as regulations allow. This will result in a somewhat more extensive loss of snag habitat and therefore marten habitat in the expanded cutting corridor along roads and around some campgrounds and administrative sites. However, given the abundance of snag and coarse woody debris Forest-wide, these impacts are expected to be minimal.

Indirect effects to marten are also associated with the ability of marten to move through treated areas. Cover will decline and forest obligates that regularly move long distances under cover such as marten are likely to choose alternate routes through more dense forest habitat.

Past and Ongoing Activities Several past activities never had or no longer have present effects to which the Proposed Action would contribute. Specifically, projects that involved vegetation manipulation (e.g. trail reconstruction, timber harvest, and fuels activities) may have impacted marten habitat at the time of the activity. Some of these impacts may still be apparent in those areas not yet capable of meeting marten habitat requirements – i.e. mature forests. However, this would mainly be in those areas where trees have not reached optimal size for marten nesting and foraging structure. The removal of fisher habitat associated with the Proposed Action will not have a cumulative impact.

Ongoing activities that impact marten habitat include the Clancy Unionville Vegetation Management project. That project may impact marten habitat although since the mountain pine beetle has killed several hundreds of acres of trees not as many ‘green’ acres are being treated as originally proposed. Therefore impacts to marten and/or their habitat should be minor upon implementation of the Clancy Unionville project.

This Proposed Action will remove dead and dying trees where they pose a hazard. Therefore, the removal of marten habitat associated with the Proposed Action will add to the impacts of past activities.

Reasonably Foreseeable Activities Some of the reasonably foreseeable activities will result in removal of marten and snag habitat (e.g. Cabin Gulch Vegetation Management, Telegraph Vegetation Management Project, Stonewall Vegetation Management Project, and Elliston Face Hazardous Fuels Reduction Project) through vegetation manipulation or through firewood retrieval along roads managed through travel planning efforts (e.g. Divide Travel Planning). These reasonably foreseeable projects are not expected to significantly add to the impacts of the Proposed Action.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 154 Irreversible/Irretrievable Commitments Removing marten habitat through reduction of hazard trees (snags and subsequent coarse, woody debris) will not prevent new snags from developing in these areas in the future. In those cases where mature green trees remain, this process may proceed quickly. In areas where residual green trees are young, large snag development will take several decades. But, in any event, the potential for continued snag creation, and marten habitat, will remain.

3.9.44 Conclusions Given that: • Proposed snag reductions will occur within localized areas (linear road corridors and well-defined administrative sites), • Treated areas will represent less than 3% of the newly expanded snag resource, • Expanded snag resource has been available only for 3-5 years (and does not represent typical baseline snag levels on the Forest), • Treated areas will continue to meet Forest Plan snag standards and R1 Eastside Snag Protocol recommendations (by virtue of the sites being managed for replacement snags and the surrounding areas supporting more than enough existing snags for 3rd order drainages to meet Forest Plan standards), and • Martens are regarded as secure according to NatureServe (See http://www.natureserve.org/explorer/servlet/NatureServe.), the proposed treatments, while diminishing travel opportunities for local individuals and some nesting and roosting habitat, will have no meaningful impact on marten and/or their habitat in any of the 4 affected landscapes on the Helena National Forest.

While other projects also remove marten habitat, the cumulative impacts should not threaten species viability as habitat remains abundant and well distributed across the Forest.

Viability Analysis Forest Service Region 1 defines a viable species as “consisting of self-sustaining populations that are well distributed throughout the species range”. Self sustaining populations are “sufficiently large, and have sufficient genetic diversity to display the array of life history strategies and forms that would provide for their persistence and adaptability in the planning area over time.

The following table summarizes the type of data available for each MIS and select sensitive species in the Forest wide Hazard Tree Removal and Fuels Reduction Project Area. Ratings for other sensitive species not included in the following table can be found in the Wildlife Specialists Report Appendix B Summary of Effects to TES and MIS Species.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 155 Table 3.42 Primary Information Sources for Determining Population Viability of MIS & Select Sensitive Species Indicator/ Presence/ Presence/ Intermittent Comprehensive R1 Habitat Sensitive Absence Absence Species Habitat Conservation Surveys Species Surveys Surveys Observations Modeling Assessment by Random Protocol Elk X X Fisher X X American X X Marten Northern X X X X X X Goshawk Pileated X X X X X X Woodpecker Hairy X X X X X Woodpecker Black-backed X X X X X X Woodpecker Flammulated X X X X Owl

Viability ratings for elk are based on relatively complete annual tallies of individuals in the field. Extensive data on suitable habitat is also available for these species, either through Forest-wide habitat modeling or systematic field surveys (or both).

Ratings for goshawk, hairy woodpecker, and grizzly bear are based on wide-ranging, but less complete, population surveys in the field. This information is sufficient to indicate the general magnitude and distribution of populations in the Project Area and throughout the Forest Plan Area (though it is less precise than for the first group of species above). Availability of suitable habitat for these species has been estimated through Forest-wide habitat models, systematic habitat surveys, or both.

Ratings for marten and pileated woodpecker are more problematic. Population information comes primarily through tallies and mapping of fortuitous and, occasionally, targeted field observations. This demonstrates that the species continue to inhabit the Project Area and the Plan Area, and it provides a rough indication of how they are distributed. But it is a crude estimator of viability. On the other hand, Forest-wide habitat models and general field surveys provide a basis for assessing habitat sufficiency.

Based on discussion in the Northern Region Viability Protocol (Samson 1996) and the Draft White Paper on Managing for Viable Populations (USDA 2001), the following qualitative rating system was applied to MIS and select Sensitive Species populations and habitats as a means of getting at population viability.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 156 Table 3.43 Qualitative Rating System for Population Viability Analyses Rating Population Distribution Potential for Population Probably of Population and Condition within Interaction and Persistence over 50-100 Potential Habitat Colonization of Empty years Habitat 5 Population widely distributed, Few limitations on population Very High: Population large, robust and resilient interactions widespread, relatively stable, highly resilient 4 Population well distributed; Some barriers to population High: Population widespread, variable population density interaction and habitat resilient; no insurmountable occupancy decimating factors or habitat problems 3 Population may be widely but Barriers to interaction result in Moderate: Population widely but sporadically distributed; some persistently empty habitat sporadically distributed; key variable density within blocks habitat may be limited or suitable patches vulnerable; decimating factors a potential problem 2 Population segments Population segments often Low: Population small, subject to localized; small but may be isolated; limited routes for stochastic effects; long-term persistent interaction and recolonization of availability of key habitat uncertain empty habitat 1 Population segments Population segments highly Very Low: Populations very small, localized, small, ephemeral isolated; little possibility of habitat limited and unstable; highly interaction or recolonization of vulnerable to stochastic effects empty habitat

These ratings apply to potential habitat for the Helena National Forest as a whole. In some cases, the Forest wide Hazard Tree Removal and Fuels Reduction Project Area contributes to maintaining viability of these populations but is not sufficient in itself to encompass or support a self-contained viable population or subpopulation (as with wolves). Given the lack of quantitative data, it is not possible to define a precise timeframe for probability of persistence. But, in general, it is intended to apply to the long term: the probability that the population will persist for 50-100 years within the Helena Forest Plan Area (USDA 2001, p.8).

Table 3.44 Qualitative Rating System for MIS & Sensitive Species for Population Viability Analyses Estimated Indicator/ Population Population Probability Sensitive Distribution Interaction of Comments Species Rating Rating Population Persistence Elk populations are robust. Habitat is ubiquitous. Barriers to movement are common, but no

Elk significant tracts of elk habitat are isolated. In spite 5 4 5 of local habitat problems, long-term viability of elk populations is not a concern. Primary fisher habitat on the Forest is patchy but widely distributed. It is increasing as forests age. Insect-generated mortality in mature forest is creating more open canopy (unfavorable) but more Fisher 3 4 4 snags and woody debris (favorable). Primary habitat is interconnected by forested travel habitat. Population is widely distributed but small; precise numbers are unknown.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 157 Estimated Indicator/ Population Population Probability Sensitive Distribution Interaction of Comments Species Rating Rating Population Persistence Primary marten habitat is patchy but widely distributed on the Forest. Habitat is increasing in many areas as forests age. Beetle infestations are

American modifying this habitat—often favorably by increasing 3 4 4 Marten large woody debris. Primary habitat sites are

interconnected by forested travel habitat. Population is widely distributed; numbers are unknown. Goshawks are widespread, and appear well- distributed in forest habitat across the Forest. Northern Suitable habitat is widely distributed. Aging forest Goshawk 4 4 4 processes continue to add to suitable nesting habitat in many areas, although this trend is being balanced by habitat loss to fire and insect-generated mortality. On the Forest, pileated woodpeckers are most abundant in the Blackfoot landscape west of the Continental Divide. Elsewhere on the Forest, the Pileated birds are widely distributed but generally 3 3 4 Woodpecker uncommon. The HNF east of the Divide is near the edge of the woodpecker’s geographic range. Habitat is widespread and locally abundant across the Forest. Hairy woodpeckers are common and well distributed in all forest habitats with insect-supporting trees. Large fires and insect infestations are substantially Hairy 5 4 5 increasing habitat components for hairy Woodpecker woodpeckers across the Forest. Potential for suitable habitat persistence over the long term is excellent. Suitable habitat for black-backed woodpeckers has increased dramatically over the past few years. Primary opportunities have been produced by large Black- fires, but the birds may be attracted also to areas of backed 3 4 3 extensive insect-generated mortality in mature Woodpecker forests. This entire habitat is ephemeral. Potential for suitable habitat over the long term is dependent upon fire and insect outbreaks sufficient to provide a forage base. Flammulated owls may be present in and around the Forest wherever large open-grown conifers Flammulated (providing foraging and nesting habitat) occur in 2 3 3 Owl juxtaposition to denser roosting stands. This habitat is usually localized and patchy, but widely available across the Forest.

Samson (2006a and 2006b) summarizes the status of viability northern goshawks, black-backed woodpeckers, flammulated owls, pileated woodpeckers, American martens, and fishers: • The six species considered in this assessment are secure in terms of persistence (http://www.natureserve.org/explorer/serve/NatureServe).

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 158 • Below (and not above) a threshold of 20-30% of habitat amounts, effects of fragmentation (i.e., patch size and isolation) are suggested to have a negative impact on species persistence. • Effects of habitat fragmentation on birds are described to be less in the western United States in comparison to those reported in seminal and numerous studies in the Midwest and east.

Habitat Analysis Conclusions Samson 2006b provides habitat estimates by National Forest necessary to retain viability of selected species within the Northern Region of the Forest Service (See Table 1 Summary of critical habitat thresholds (km2) to maintain minimum viable populations for six species in Northern Region. Total estimated habitat is included by National Forest for each species in Samson 2006b). Samson’s (2006b) estimates for the Helena National Forest are described in the following table along with current habitat estimates and remaining habitat post project implementation. Clearly, habitat continues to remain above critical thresholds for the six species identified in the preceding table. Therefore, viability for these species appears sound and will remain so upon implementation of proposed treatments.

Viability for hairy woodpeckers and elk does not appear to be threatened. Hairy woodpeckers utilize similar habitats as black-backed woodpeckers and additional habitats. The proposal results in treatment of approximately 3,801 acres of hairy woodpecker habitat. Given the widespread availability of forage habitat – i.e. acres infested with mountain pine beetle – and subsequent increases in nesting habitat associated with insect-related tree mortality, abundant habitat exists Forest-wide for hairy woodpeckers. Elk habitat is also abundant and well- distributed across the Forest and elk viability is largely determined through hunting quotas which is outside the scope of this project.

A goshawk nest was recently located on the Lincoln Ranger District about 60 meters from Forest Service Road 1163. The nest was located on 7/7/2009 and had three young in the nest at that time. The nest was subsequently re-visited on 7/26/2009 and had apparently succumbed to a wind storm. Given the site fidelity that goshawks exhibit, it’s highly likely that these goshawks will nest in the vicinity in out years. Mitigation measures that are in place should minimize impacts of the Project. This includes surveying the general vicinity for goshawks prior to project implementation.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 159 Table 3.45 Summary11 of critical habitat thresholds (acres) to maintain minimum viable populations for 6 species in Northern Region on the HNF compared with existing conditions and post-treatment conditions associated with the Forest-wide Hazard Tree Removal and Fuels Reduction Project Species Samson’s Current Habitat Acres of Remaining Are Remaining (2006b) Critical Estimates for Habitat Habitat Habitat Thresholds for the HNF based Treated Estimates Estimates the HNF Grid above the Intensification Critical Data12 Thresholds? Northern Goshawk 315,306 530,020 6,855 523,165 Yes Black-backed 105,514 610,55713 9,415 601,14214 Yes Woodpecker Flammulated Owl 8,006 15,808 1,349 14,459 Yes Pileated Woodpecker 36,324 90,196 3,787 86,409 Yes (nesting and foraging) American Marten 222,148 322,661 4,286 318,375 Yes Fisher Summer 36,324 59,511 2,048 209,960 Yes Winter 162,348 212,008 2,502 209,506 Yes

11 Current habitat estimates are based on the R1 Summary Database (January 2010 Data). 12 Estimates are derived by multiplying the percentage of forested data points identified as a given species habitat by the total forested acres on the Helena National Forest (approximately 929,860 acres according to updated ownership and grid data) except for the black-backed woodpecker. 13 Estimates of black-backed woodpecker habitat are based on the 2009 condition survey reports from aerial insect survey data for mountain pine beetle (USDA 2009b). There are approximately 585,557 acres infested by mountain pine beetle in 2009 on the Helena National Forest. See also the Forested Vegetation Background Report. Estimates also include acres burned by wildfires on the Helena National Forest between 2004 and 2008; this is approximately 25,000 acres. Samson’s (2006b) habitat estimates include both insect and fire-created habitats. 14 Remaining habitat estimates for black-backed woodpeckers are based on the approximately 9,415 acres of proposed treatments.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 160 3.10 .10Effects to Sensitive Plants 3.10.1 Affected Environment The Helena National Forest has known or suspected occurrences of twenty species of sensitive plants. A complete list of the species and a description of habitat associated with those species can be found in Appendix A of the Sensitive Plants Specialists Report. The Northern Region Sensitive Species List, dated 11/04/2004, can be found in the project file. The 2004 Sensitive Species list includes Cirsium longistylum, but this species was removed from the Sensitive Species list per a Regional Forester letter of 11/24/2004. The analysis area for sensitive plants included the buffered Roadside Hazard tree proposed treatment areas and haul routes.

Nine of the twenty sensitive species that are on the Helena National Forest Sensitive Plant list have been found on or very near the Forest. The complete list of species can be found in the Sensitive Plants Specialists Report in the Project File. Of the species that have been found, only those listed as “known” definitely occur within the analysis areas proper. The species listed as “possible” are those species whose habitat is potentially included in the analysis area. The remaining species do not have habitat that would be directly impacted by these activities, due to the type of habitat the plants occur in, or no plants were found during any past or present surveys. A brief description of habitat for each species can be found in Appendix A of the Sensitive Plants Specialists Report in the Project File.

Species Known or Possibly Present One sensitive species, Juncus hallii, is known to occupy habitat within the analysis area (Poole and Heidel 1993; Barton and Crispin, 2002; www.mtnhp.gov;, pers obs, field surveys). In addition, it is possible that habitat for Botrychium crenulatum Botrychium paradoxum, and Phlox kelseyi var. missoulensis, is within the analysis area.

Juncus hallii has fifteen populations Forest-wide. The Montana Heritage database identifies 8 populations on the Helena National Forest (three of the Heritage Program populations were relocated by HNF crews). Seven new populations were found by Helena National Forest survey crews in 2009 while validating a model which predicts sensitive plant habitat (Nock, 2002Bicker, field surveys). Details for field survey protocols and areas that were searched can be found in the project file. Three populations occur in the analysis area.

It is possible that Botrychium crenulatum is present in the wetland areas identified within the analysis area. This species has been found on the Beaverhead-Deerlodge Forest, immediately adjacent to the Helena National Forest. This species has not been found to date in numerous surveys.

Botrychium paradoxum is known from two populations on the Helena National Forest, both in the Divide landscape area. No populations occur in the analysis area.

Phlox kelseyi var. missoulensis has been found in each of the four landscape areas of the Forest. The Montana Heritage database identifies 8 populations on the Helena National Forest. Three new populations were located in 2008 (Olsen, pers obs) and three additional populations were found in 2009 while the Forest was validating a model which predicts sensitive plant habitat

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 161 (Bricker,field surveys; Nock, 2002). Details for field survey protocols and areas that were searched can be found in the project file. No populations occur in the analysis area.

Species Unlikely to be Present All species on the sensitive plant list are searched for during field surveys. Habitats for all species are described in Appendix A of the Sensitive Plants Specialists Report.

The following species have not been found on the Helena Forest to date, but are always searched for in any survey work: Amerorchis rotundifolia, Aquilegia brevistyla, Cypripedium passerinum, Goodyera repens, and Grindelia howellii. Habitat for these species has potential to exist in the analysis area.

The species discussed below that are followed with * have been found on or very near the Helena National Forest. These species all have specialized habitat that does not occur in the analysis area: Astragalus lackschewitzii, Drosera anglica*, Drosera linearis*, Cypripedium parviflorum, Epipactis gigantean, Oxytropis podocarpa, Polygonum douglasii var. austinae, Saxifraga tempestiva, Scirpus subterminalis*, Thalictrum alpinum and Veratrum californicum.

3.10.2 Effects Common to All Alternatives The spread of noxious weeds has a very adverse potential impact on sensitive plant populations Forest-wide. If these species are left unchecked is it likely that noxious weeds would occupy sensitive plant populations, especially those close to motorized routes in drier habitats. Vehicles that travel off of established routes have the potential to harm sensitive plant populations. Herbicide application would have very adverse effects on sensitive plant populations. The Helena National Forest Noxious Weed EIS provides guidance for proper weed treatment (USDA 2006).

The potential exists for wildfire to have a short term detrimental effect on sensitive plant habitats, but no long-term effects in most cases. However in the dry ponderosa pine forest types there has been a dramatic increase of severe wildfires in the ponderosa pine type in recent decades where fuels have built up due to fire suppression (Agee. 2005), In these habitats there is potential for long term damage to sensitive plant habitats (Menges and Dolan, 1998; Pendergrass et al. 1999). Plant response to fire is a result of the interaction between severity of the fire and the individual plant species’ inherent resistance to injury and ability to recover (Brown, et al. 2000). Mortality of herbaceous species is more dependent on the length of time plants are exposed to high heat, determined by the amount of duff and woody fuel consumed by the fire, than flame length and fire line intensity (Armour et al 1984). The effect of wildfire on sensitive plant habitats therefore would depend on the surface fuel conditions. The longer fuels build up on the forest floor, the greater the potential damage to sensitive plant habitats.

Wildland fires also risk enhancing nonnative plant invasions if severe fires damage the native vegetation. Canada thistle, bull thistle, knapweeds, Dalmation toadflax and cheatgrass have been shown to increase following wildfire (Harrod and Reichard, 2002). Noxious weeds are a serious threat to sensitive plant habitats.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 162 3.10.3 Alternative 1 (No Action) No effects would occur to sensitive plants under this alternative except the effects noted under “Effects Common to All Alternatives” section of this document.

Irreversible/Irretrievable Commitments There are no irreversible/irretrievable commitments that would affect sensitive plants under this alternative.

Cumulative Effects The cumulative effects area for sensitive plants is forest-wide. Cumulative effects from the list of projects noted in Appendix F would be minimal. The projects that have occurred since 1993 have all had ground reconnaissance to determine whether sensitive plant populations would be impacted by those actions. Where sensitive plant populations were found, such as the Cave Gulch Fire Salvage project, such populations were buffered from treatment. The treatment in that case was herbicide use. The actions associated with other projects may have impacted individuals or habitat but would not likely contribute to a trend towards Federal listing or cause a loss of viability to the population or species.

The livestock grazing that occurs in the Big Buffalo allotment, Hat Creek allotment and the MacDonald Pass unit of the Tenmile allotment has been ongoing for many decades. The plant populations known from these areas (Phlox kelseyi var. missoulensis, Juncus hallii and Botrychium paradoxum) are still present and have not shown adverse effects from grazing. The plant populations known from these areas are still present and have not shown adverse effects from grazing.

Implementation of the Clancy-Unionville Vegetation Management Project is expected to occur in 2010. This project includes temporary road construction and timber harvest. A sensitive plant population (Botrichium paradoxum) is known from the project area but was not affected by the treatment units.

Surveys are currently occurring or have been completed for future foreseeable actions. If populations have been/are found, they will be protected from ground disturbance or herbicide application. Cumulative effects would likely be minimal.

Future foreseeable actions that would be cumulative with this project include the following:

The Elliston Face Fuels Treatment Project includes approximately 700 acres of fuel reduction using timber harvest and prescribed fire. This project is currently on hold. No sensitive plant populations were found during field surveys of this project area.

The Warm Springs Wildlife Habitat Project would treat approximately 3500 acres with a combination of prescribed fire and mechanical tree removal. In addition, up to 5 miles of temporary road could be constructed. Intensive vegetation data collection in the project area was completed in 2006 with further data collection in 2008. No sensitive plant populations were found during those surveys or previous surveys. If any populations are found at any time they would be protected from ground disturbance or herbicide application.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 163 The Telegraph Vegetation Project would treat approximately 6,300 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 6 miles of new temporary road would be built. There are known populations of Juncus hallii in this project area. Those populations have been identified and will be protected from ground disturbing activities and herbicide application.

The Grassy Mountain Vegetation Project would treat approximately 3,900 acres with a combination of prescribed fire and timber harvest. Up to 0.5 miles of new temporary road would be built. Intensive vegetation data collection in the project area was completed in 2006. No sensitive plant populations were found during those surveys or previous surveys. If any populations are found at any time they will be protected from ground disturbance or herbicide application.

The Stonewall Vegetation Management Project would treat approximately 8,500 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 5 miles of new temporary road would be built. Field surveys of the proposed units and temporary roads were completed in 2009. No sensitive plant populations were found during those surveys or previous surveys. If any populations are found at any time they would be protected from ground disturbance or herbicide application.

The Divide Travel Plan would determine what roads would be open to motorized traffic. There are no direct ground disturbing activities associated with this project. There are known sensitive plant populations within the project area—Botrychium paradoxum, Juncus hallii and Phlox kelseyi var. missoulensis. These populations have been identified in the sensitive plant analysis and would be protected from ground disturbing activities and herbicide application.

The Cabin Gulch Vegetation Management Project would treat approximately 3,400 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 5 miles of new temporary road would be built. No sensitive plant populations were found in field surveys of this project. If any populations are found during implementation they would be protected from ground disturbance or herbicide application.

For more information on cumulative effects, please see the Sensitive Plants Specialists Report. Also, please see Appendix F of this EA.

3.10.4 Alternative 2 (Proposed Action) Three populations are known to occur in the analysis area as shown in the following table. Two of the populations occur along Road 1859-B1in an area where several other populations have been found.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 164 Table 3.46 Treatment Areas with Known Sensitive Plant Populations Road/Trail Action Species Remarks/Mitigation No. Proposed Present/ Suspected 1878 Haul route and Juncus hallii Known habitat. Establish a clearly marked buffer edge of (known); surrounding individual plant populations. Avoid operation of treatment area wheeled or tracked equipment within buffer zones. Remove trees as necessary to reduce the public safety hazard within plant population buffer zones. Leave only those dead trees within plant population buffer zones that would damage the population by removal. Establish a 100 foot buffer around the population where no herbicide application will occur. 1 population. 1859 B1 Treatment area Juncus hallii Known habitat. Establish a clearly marked buffer Road Area of (known); surrounding individual plant populations. Avoid operation of Concern (see wheeled or tracked equipment within buffer zones. figure xx) Remove trees as necessary to reduce the public safety 0.45 miles. hazard within plant population buffer zones. Leave only those dead trees within plant population buffer zones that would damage the population by removal. Within the 1859-B1 Road Area of Concern: Remove trees using an enforceable commercial contract to control site disturbance caused by noncommercial firewood cutting. Establish a 100 foot buffer around the population where no herbicide application would occur. 2 populations.

Alternative 2, the Proposed Action, has the highest level of soil disturbing activities with the highest level of potential to affect sensitive plant populations.

For the four species that are known or are possibly present, along with the fivespecies that are unlikely to be present but are always surveyed for, it is determined that with the design criteria and proposed mitigation, the decision may impact individuals but would not contribute toward a trend for federal listing or loss of viability.

Irreversible/Irretrievable Commitments There are no irreversible/irretrievable commitments that would affect sensitive plants under this alternative if the mitigation is implemented.

Cumulative Effects The cumulative effects area for sensitive plants is forest-wide. Please see the cumulative effects section under Alternative One for a description of projects. Under Alternative Two, the cumulative effects would likely be minimal.

Surveys are currently occurring or have been completed for future foreseeable actions. If populations have been/are found, they will be protected from ground disturbance or herbicide application.

For more information on cumulative effects, please see the Sensitive Plants Specialists Report. Also, please see Appendix F of this EA.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 165 3.10.5 Conclusions Alternative 1, the No Action alternative, would have no new soil disturbing activities that would disturb sensitive plant populations.

Alternative 2, the Proposed Action, has the highest level of soil disturbing activities with the highest level of potential to affect sensitive plant populations. With the design criteria and proposed mitigation, the decision may impact individuals but would not contribute toward a trend for federal listing or loss of viability. This determination is made for the four species that are known or are possibly present in the analysis area; Juncus hallii, Botrychium crenulatum, Botrychium paradoxum, and Phlox kelseyi var. missoulensis. This same determination is made for the five species that are always searched for, but have not been found on the Helena National Forest; Amerorchis rotundifolia, Aquilegia brevistyla, Cypripedium passerinum, Goodyera repens, and Grindelia howellii.

Both alternatives are consistent with Regional direction, Forest Plan Standards and Guidelines, and the Endangered Species Act.

3.11 Effects to Weeds 3.11.1 Affected Environment The Roadside Hazard Tree treatment areas on National Forest system lands were used as the basic analysis area. The affected environment discussion and the pesticide delivery analysis used NRCS 6th code Hydrologic Unit Codes (HUCs) that had a treatment in them.

Roadsides are an area commonly infested with noxious weeds. Roads have high weed infestations due to several reasons: vehicles carry weed seeds, which are dispersed along travelways; roads are disturbed by maintenance activities on a regular basis, which provides a ready seedbed for weed seeds, both the seeds dispersed by vehicles and those that are carried on the wind or by animals and birds; human use is concentrated along roadsides which increases the exposure of these areas to noxious weed seed dispersal (Lonsdale, 1999; Pauchard et al., 2003).

Various methods of weed control are used on known weed infestations across the Helena National Forest. Although herbicide application has been the primary noxious weed treatment method, numerous biological control insectaries have been established across the Forest.

Herbicide application is the most common form of control used across the Forest. The Forest generally treats approximately 3,900 acres of weeds annually (averaging 2007 through 2009 as typical years).

Additionally, the Helena National Forest utilizes bio-control agents as an integrated effort to manage invasive species. It should be recognized that the bio-control agents can be found other than just within the specified areas. The migration of the bio-control agents is unpredictable as their migration is based on a number of climatic, topographical and environmental influences. It should also be noted that bio-control is a “work in progress” and consideration of areas in and around these sites should be monitored for protection of the bio-agents.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 166 Noxious weeds exist throughout the Forest Service portion of the project area in infestations ranging from areas of 5 to 10 individual weed plants to linear patches along roads and trails to large patches of greater than 20 acres. Infestation level of the patches range from light (1% canopy cover) to high (greater than 50% canopy cover)

The following species of noxious weeds have been identified in the Roadside Hazard Tree Project Area treatments with a breakdown by landscape area:

Table 3.47 Mapped Noxious Weed Infestations Within the proposed Project Area Primary Noxious Weed Species Landscape Infested Acres Musk thistle (Carduus Nutans) Big Belts 7 Musk thistle (Carduus nutans) Total 7 Spotted knapweed (Centaurea maculosa) Big Belts 35 Blackfoot 766 Divide 189 Elkhorns 11 Spotted knapweed (Centaurea maculosa) Total 1001 Canada thistle (Cirsium arvense) Big Belts 42 Blackfoot 7 Divide 155 Elkhorns 2 Canada thistle (Cirsium arvense) Total 205 Leafy spurge (Euphorbia esula) Big Belts 4 Blackfoot 1 Leafy spurge (Euphorbia esula) Total 5 Oxeye daisy (Leucanthemum vulgare) Divide 11 Oxeye daisy (Leucanthemum vulgare) Total 11 Dalmation toadflax (Linaria dalmatica) Big Belts 4. Blackfoot 3 Elkhorns 7 Dalmation toadflax (Linaria dalmatica) Total 14 Sulfur cinquefoil (Potentilla recta) Divide 9 Sulfur cinquefoil (Potentilla repens)Total 9 Common tansy (Tanacetum vulgare) Big Belts 3 Common tansy (Tanacetum vulgare) Total 3 Total acres of mapped infestations 1256

Many infested areas have more than one weed species present; this table shows the predominant species in a given area. Other common noxious weeds associated with the “primary” weeds shown above include houndstongue (Cynoglossum officinale) and butter and eggs (Linaria vulgare). In addition, a given infestation may have more than one of the primary weed species present. For example, spotted knapweed may be the primary mapped species, but Canada thistle is often present as well. Detail on additional species in a given infestation is available in the GIS layer “Weeds”. An additional species of major concern is cheatgrass (Bromus tectorum) which is not mapped but is very common along roadsides and areas of ground disturbance.

Noxious weeds are aggressive plants ecologically (Sheley and Petroff, 1999). Within the Roadside Hazard Tree treatment areas approximately 2,042 acres are currently infested with

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 167 noxious weeds. The majority of these areas were infested from light (less than 5%) to moderate (25% canopy cover of weeds). This represents approximately 9% of the mapped noxious weed infestations on the Forest. The treatment areas are all along roadsides, and, as described above, these areas are susceptible to noxious weed infestation.

There are ten noxious weed species of primary concern in terms of level of infestation in the treatment area: musk thistle (Carduus nutans) spotted knapweed (Centaurea maculosa), Canada thistle (Cirsium arvense), houndstongue (Cynoglossum officinale), leafy spurge (Euphorbia esula), oxeye daisy (Leucanthemum vulgare), Dalmation toadflax (Linaria dalmatica), common toadflax (Linaria vulgare), sulfur cinquefoil (Potentilla recta) and common tansy (Tanacetum vulgare).

3.11.2 Effects Common to All Alternatives Noxious weeds can create monocultures if uncontrolled with herbicides or effective biocontrol. The loss of plant biodiversity, soil productivity and foraging values are great (FEIS, 2004a; FEIS, 2004b; FEIS, 2004c; FEIS, 2009a; FEIS, 2009b; FEIS, 2009c; FEIS, 2009d; FEIS, 2009e). The effects of noxious weed infestations are adverse to native fauna and flora and present the greatest large-scale threat to native ecosystems that exist in the Nation’s wild lands today (Lonsdale, 1999; DiTomaso, 2000; Lodge and Shrader, 2001; Pauchard et al., 2003).

Weed management would continue as in the past. Chemical weed treatments would be used in areas accessible to ground spraying equipment. Bio-control would be used in areas where the biological agents had optimal conditions for survival and expansion. In riparian areas biological control would be emphasized where conditions for insect establishment are met. The roadside infestations are treated on a scheduled basis.

Public access for recreation, firewood collection, and private property access would continue along roadsides across the Forest. Also, Forest users would be free to fully utilize all existing dispersed recreation sites and other open areas, except during spring break-up when the road surfaces are over saturated with moisture. The ground disturbance associated with these activities would likely increase weed infestations where bare soil is exposed.

Weeds would expand into dry Forest areas as conifer species die and sunlight, nutrients and moisture are more available to herbaceous plant species. This is most important in ponderosa pine forests, and lodgepole/Douglas-fir/ponderosa mixed forests. The most susceptible forest habitat types (Pfister et al. 1977) would be dry habitat types that have existing infestations of noxious weeds due to the natural openness of such forest types. These habitat types include Douglas-fir (Pseudostuga menziesii)/pinegrass (Calamagrostis rubescens) Douglas-fir /snowberry(Symphoricarpos albus) and Douglas-fir/bluebunch wheatgrass (Pseudoroegenaria spicata).

Current weed management activities would continue under all alternatives. Chemical weed treatments would be used in areas accessible to ground spraying equipment. Roadside infestations are treated on a scheduled basis. Bio-control would be used in areas where the biological agents had optimal conditions for survival and expansion. In riparian areas, biological control would be emphasized where conditions for insect establishment are met.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 168 New weed infestations would occur under all alternatives, particularly along roadsides and areas of disturbance (Lonsdale 1999). The HNF Noxious Weed EIS (USDA 2006) provides guidance and environmental requirements for weed control activities, which would be applied to this area under any alternative. The forest currently uses herbicides to treat approximately 30% of infestations annually. Roadsides are identified to be treated annually as they are a major vector for weed invasion.

The probability of wildfire across many areas of the Forest area is high due to lodgepole pine mortality from MPB. This mortality has created volatile fire conditions that threaten important ecosystem components in the short term and long term. Given the current conditions within the high mortality areas of the Forest and the dynamics associated with lodgepole mortality, untreated areas can be expected to realize higher intensity fires that consume a considerable portion of duff and litter due to current density, stand structure, red needled litter, and stand composition (Agee and Skinner 2005; Graham et al. 2004).

Native plant diversity would be impacted by infestations of noxious weeds. Noxious weeds dominate plant communities and tend to form monocultures that negatively impact native biological diversity. This weed competition to individual plants and plant communities reduce species diversity and sensitive native plants. Native grasses used for domestic livestock and wild ungulates are particularly susceptible to impacts from weeds (Beck K.G. 2001).

Irreversible/Irretrievable Commitments The effects of noxious weed infestations are adverse to native fauna and flora and present the greatest large-scale threat to native ecosystems that exist in the Nation’s wild lands today (Lonsdale, 1999; DiTomaso, 2000; Mack et al. 2000; Lodge and Shrader, 2001; Pauchard et al., 2003). At high infestation levels these effects are adverse due to the loss of native plant diversity, reduction of wildlife habitat and forage, increase in erosion and depletion of soil moisture and nutrient levels (DiTomaso, 2000). These effects are common to all alternatives due to the effects of noxious weeds whether ground disturbance occurs or not. If noxious weed populations are not controlled, these effects could be irreversible.

3.11.3 Alternative 1 (No Action) Weeds would continue to spread at a rate of about 10-13% year. Treatment of the currently mapped noxious weeds within roadside areas would average about $30.00 per acre. This does not include the cost of monitoring. The Forest Program treats approximately 3155 acres of weeds on an annual basis, under normal funding. Generally a given roadside is treated with Tordon every two to three years rather than annually. Annual treatment costs would likely be one-third of the infestations, or 419 acres for a total of $12,570.00 for Alternative 1.

Cumulative Effects The cumulative effects area for noxious weeds is forest-wide. Noxious weed infestations are introduced and spread through most ground disturbing activities (Young et al. Lonsdale, 1999; 1987; FEIS 2004a; King County, 2007; FEIS 2009a; FEIS 2009b; FEIS 2009d;). Road construction, mining and drilling operations, timber harvest on unfrozen ground and installation of underground facilities such as pipelines are primary activities that have the most potential to spread existing infestations as well as introduce new infestations. Activities such as livestock

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 169 grazing and recreational stock use also have the potential to spread noxious weed seeds, allowing new infestations to be introduced to areas that are away from roads or other disturbance areas. Vehicles that travel the National Forest road and trail system provide a source of weed seed as well as a chronic disturbance along those corridors. Some weeds, such as Dalmation and butter and eggs toadflax, leafy spurge, houndstongue and sulfur cinquefoil spread readily without ground disturbance, and spread very rapidly with disturbance (FEIS 2004b FEIS 2004c; FEIS 2009c; FEIS 2009e). Weed control efforts in the form of herbicide treatment and biological control provide beneficial effects undertaken over time to control existing and new infestations. The existing condition reflects the effect of past disturbances as well as the effect of noxious weed control efforts.

Ongoing projects: Clancy-Unionville Vegetation Management Project: Implementation is expected to occur in 2010. This project includes temporary road construction and timber harvest. Weed treatment is scheduled to occur per the decision for this project.

Future foreseeable actions that could be cumulative with this project include the following:

Elliston Face Fuels Treatment: This project includes approximately 700 acres of fuel reduction using timber harvest and prescribed fire. This project is currently under litigation.

Warm Springs Wildlife Habitat Project: This project could treat approximately 3500 acres with a combination of prescribed fire and mechanical tree removal. In addition, up to 5 miles of temporary road could be constructed. The mitigation of this project includes weed treatment of all infested acres within treatment units prior to implementation. Follow-up treatment is included for years 2 and 3 after implementation. The Forest Program would continue to treat the infestations outside the treatment units. These mitigation measures are intended to minimize new infestations and to contain or reduce existing infestations.

Telegraph Vegetation Project: This project could treat approximately 6,300 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 6 miles of new temporary road would be built. The mitigation of this project includes weed treatment of all infested acres within treatment units prior to implementation. Follow-up treatment is included for years 2 and 3 after implementation. The Forest Program would continue to treat the infestations outside the treatment units. These mitigation measures are intended to minimize new infestations and to contain or reduce existing infestations.

Grassy Mountain Vegetation Project: This project could treat approximately 3900 acres with a combination of prescribed fire and timber harvest. Up to 0.5 miles of new temporary road would be built. The mitigation of this project includes weed treatment of all infested acres within treatment units prior to implementation. Follow-up treatment is included for years 2 and 3 after implementation. The Forest Program would continue to treat the infestations outside the treatment units. These mitigation measures are intended to minimize new infestations and to contain or reduce existing infestations.

Stonewall Vegetation Management Project: This project could treat approximately 8,500 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 5 miles of new temporary road would be built. The mitigation of this project includes weed

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 170 treatment of all infested acres within treatment units prior to implementation. Follow-up treatment is included for years 2 and 3 after implementation. The Forest Program would continue to treat the infestations outside the treatment units. These mitigation measures are intended to minimize new infestations and to contain or reduce existing infestations.

Divide Travel Plan: This decision could be to determine what roads would be open to motorized traffic. There are no direct ground disturbing activities associated with this project. The existing condition creates a situation that increases noxious weed infestation. This project would not change that condition. As with other projects, the Forest Weed program would continue to treat areas of infestation within this area.

Cabin Gulch Vegetation Management Project: This project could treat approximately 3,400 acres with a combination of pre-commercial thinning, timber harvest and prescribed fire. Up to 5 miles of new temporary road would be built. The mitigation of this project includes weed treatment of all infested acres within treatment units prior to implementation. Follow-up treatment is included for years 2 and 3 after implementation. The Forest Program would continue to treat the infestations outside the treatment units. These mitigation measures are intended to minimize new infestations and to contain or reduce existing infestations.

Please refer to the cumulative effects table of the Noxious Weeds Specialists Report in the project file for a specific description of the effect of past, present and foreseeable activities on noxious weed infestations.

3.11.4 Alternative 2 (Proposed Action) Under this alternative, approximately 9,416 acres of hazard tree removal would occur. Hand felling without removal is not included in this analysis due to the low level of ground disturbance. Log landings would occur within units or within the road prism, so no additional acres of disturbance would be associated with landings. No other ground disturbing activities would occur. The total acres of potential ground disturbance in this alternative is 9,416 acres. Of the 9,416 acres of proposed treatment, 1,256 acres are currently infested with noxious weeds.

The proposed action is that ground-based logging systems of tractor logging on 9,416 acres would occur on unfrozen ground. Ground or soil surface disturbance as defined in this report is a measure of surface disturbance that effectively functions as seed bed preparation for noxious weed seeds. If logging occurs on frozen ground or over snow, the amount of disturbance would be reduced.

For the purposes of calculating the potential amount of herbicide applied to the treatment areas, a low risk is equated to soil surface disturbance of approximately 1-5% (midpoint of 3%) of the potential acres affected. Moderate risk is equated to approximately 5-15% soil surface disturbance (midpoint of 10%) of the potential acres affected. High risk is equated to approximately 15% or greater soil surface disturbance of the acres affected. When a high risk is assigned, the type of activity is assessed. Risk levels are associated with infestation following treatment as described in McIver and Starr (2000). Generally, 100% soil surface disturbance is assumed in the case of landings or road recontouring/reconstruction activities.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 171 The following table shows the individual activity proposed in the alternative, the risk of infestation for each activity (based on ground disturbance associated with the activity) and the estimated acres of potential weed infestation. The acres shown in this table do not include the 1256 acres of known infestation.

Table 3.48 Estimated Acres of Weed Infestation due to Proposed Activities Treatment Activity Risk of Potential Acres Estimated Acres of Infestation of Activity* Weed Infestation Tractor harvest, no seasonal restrictions Moderate 9416 ac-1129 ac 0.10 × 8287 = 829 Skid roads and landings 1129 1129 *Total acres of potential weed infestation 1958 acres *This column represents total acres. The listed activities are not expected to cause infestations on all of the acres affected, but all acres affected would be monitored and spot treated with herbicides.

The cost of treatment for this alternative would range from 1,256 acres (all currently infested acres of disturbance) to a maximum of 2,198 acres [infested acres (1,256) plus the predicted infestation due to ground disturbance (942)]. It is recommended that all known infested acres (1,256 acres) should be treated in year one. Treatment costs would be $37,680 in year one. Subsequent years would likely treat approximately one-third of the infested acres, depending on the herbicide that is used. Treatment costs in years two and three would range from $12,570 (419 acres, or 33% of 1,256 acres total) to $40,830 annually [all 1361 acres (419+942)], at $30.00/acre, for a three year period. A range of costs is shown as it is unlikely that all acres would become infested; all acres would be monitored annually however, and spot treated as necessary.

The Helena Forest Noxious Weed Treatment Project identified several sixth code HUCs in which herbicide application would be limited, based on the amount of herbicide applied, the location of the application, the stream flow and HUC area. For more information, please see Appendix B and C of the Noxious Weeds Specialists Report in the project record.

Irreversible/Irretrievable Commitments Please see the previous paragraph under Effects Common to All Alternatives. This alternative has the highest potential for adverse effects, due to the number of acres of disturbance.

Cumulative Effects The cumulative effects area for noxious weeds is Forestwide. Please see the cumulative effects section under Alternative 1 for a description of projects. Under Alternative 2, minor cumulative effects would be expected from this project, assuming design criteria and mitigation for the project would be implemented.

3.11.5 Conclusions This project is consistent with the following Forest Plan management guidelines with the recommended mitigation implemented where appropriate: • Integrated Pest Management, which uses chemical, biological, and mechanical methods, would be the principal control method. Spot herbicide treatment of identified weeds

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 172 would be emphasized. Biological control methods would be considered as they become available. • Funding for weed control on disturbed sites would be provided by the resource which causes the disturbance.

Alternative 1, the No Action alternative, would have no new soil disturbing activities that tend to increase weed invasion. Although the areas proposed for harvest would be treated under the Forest noxious weed program, there is no increased emphasis on the treatment of weeds in this area. Alternative 2, the Proposed Action, has the highest level of soil disturbing activities with the highest level of risk in the short-term for weed invasion. It also has an aggressive plan for returning Roadside Hazard Tree Treatment area to desired conditions and healthy plant communities. Implementing the recommended mitigation and BMPs for weed control would move the area toward meeting Forest Plan Standards for weed control.

Table 3.49 Acres of Weed Infestation and Cost of Treatment Alternative Acres of Weed Infestation Costs of Weed Treatment Recommended for Treatment Alternative 1 There are 1,256 acres of existing No Action weed infestations within treatment 419 ac x $30/ac = $12,570 annually areas. At least 419 of these acres would be treated annually under the normal Forest weed treatment program. Alternative 2 There are 1256 acres of existing YEAR ONE: It is recommended that ALL treatment Proposed weed infestations. areas with known infested acres (1256 acres) be Action Eventually, additional infestations treated. are predicted to occur on up to 1256 ac x $30/ac = $37,680 942 acres over the life of this Subsequent years should re-treat at least one-third of project. the infested acres within treatment units. In addition, Therefore, acres treated would monitoring of other treatment areas would show what range from 419 (1/3 of the current acres became infested following the activity. Those infestation) to a maximum of 1361 acres would be treated in years two and three. (419 + 942). There would be a YEARS TWO AND THREE: Costs would range from range because not ALL acres $12,570 (419 acres, or 33% of the currently infested would be affected by the activities 1256 acres total) to a maximum of $40,830 annually in the very first year. Also, not (infestations on all 1361 acres) ALL disturbed acres may need weed treatment. 419 ac x $30 = $12,570 Up to 1361 ac x $30 = $40,830 3.12 Effects to Availability of Firewood 3.12.1 Affected Environment The Helena National Forest has issued approximately on average, 1,500 personal use firewood permits annually. Personal use permits sold authorize removal of firewood on National Forest lands. The wide-spread nature of the beetle epidemic has created a large supply of readily available firewood adjacent to roads on the Helena Forest. Specifically, Forest roads close to

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 173 communities and residential areas are currently experiencing increased activity and available firewood in these areas is abundant. Firewood cutting is prohibited in all developed recreation areas and within active timber sale units. 3.12.2 Alternative 1 (No Action) Due to no action in this alternative, firewood gathering would continue at its current rate across the Helena National Forest. There would be no direct, indirect or cumulative impacts on the availability of firewood. 3.12.3 Alternative 2 (Proposed Action) This alternative proposed to remove hazardous trees on 9,416 acres along 491 miles of Forest roads across the Helena National Forest. This would reduce the numbers of standing dead trees available as personal use firewood along these routes. There would be approximately 8,205 acres with reduced availability to the public for firewood gathering within the project area. This is the amount of total treatment acres (9,416) minus the number of acres where burning piles and slash treatments are expected to occur (1,210 acres). Per forest plan direction, the slash piles and material from the slash treatments would be available for firewood. It is likely that there would be areas where a timber appraisal indicates that removal of the material is more costly than the value of the material. In these cases, the Forest Service may facilitate the completion of the work by designating public cutting areas, issuing commercial firewood permits or other types of non-commercial service contracts where trees may be felled but not removed. In some instances, Forest Service employees may have to fall hazard trees and these trees would be available for retrieval with a personal use firewood permit.

Cumulative Effects Given the wide-spread nature of the beetle epidemic (i.e. 350,000 acres across the Helena NF), it is unlikely that there would be any difficulty in finding available firewood. It is not expected that these project actions would in any way limit the amount of firewood available to the public in the short or long-term. 3.12.4 Conclusions Forest Plan direction for firewood would be met as landings and areas where hazard trees would be felled would be available for firewood gathering; slash from activities associated with implementation would be available for firewood; and the public would be informed of these opportunities (Forest Plan page II/24).

3.13 Effects to Socio-economics 3.13.1 Affected Environment Financial efficiency is one tool the decision maker uses to make the decision. Many things cannot be easily quantified, such as increases in visitor, worker and firefighter safety, the fire suppression options available to the line officer following treatment, effects on wildlife, and social impacts to local communities.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 174 Analysis of the socio-economic analysis is detailed in the economic specialists report in the project file. Direct and indirect effects were calculated in the Quicksilver program and determined by evaluating the estimated volume harvested, the relationship of volume to jobs, estimated timber receipts and estimated payments to counties.

The analysis area for the environmental assessment includes Anaconda-Deerlodge, Broadwater, Butte-Silver Bow, Jefferson, Lewis and Clark, Meagher, and Powell counties in Montana. Access management activities within the project area have the potential to mainly impact the economic conditions of the communities in these counties.

3.13.2 Alternatives 1 and 2 Social Comparison: A IMPLAN Pro computer model was created for the Helena National Forest and runs an “input-output” analysis. Input-output analysis is a way to examine relationships within an economy both between businesses and between businesses and final consumers and allows for the analysis of potential job and income creation by proposed Forest activities (for details see Social-Economic specialist report in the project file) Table 3.40 shows the potential jobs and income attributed to this project over its lifetime (i.e. 5 years).

Table 3.50 Estimate of Jobs and Income Provided from Hazard Tree Removal Project Alternative Salvage Direct Total Direct Labor Total Labor Volume (CCF) Employment Employment Income ($000) Income ($000) 1 (No Action) 0 0 0 0 0 2 (Proposed Action) 35,559 CCF 133 213 $5,220 $8,129

Economic Comparison: The estimated high bids for the project area indicate that each of them is feasible (highly likely to sell). This is not surprising given the proximity of the sale material to existing roads. The present value of the revenue estimates are based on expected harvests of 50% in 2010 and 50% in 2011. Table 3.7-2 below lists the present net value (PNV) for each alternative.

Table 3.51 Financial Efficiency for the Hazard Tree Removal Project Alternative Cost Benefit PNV 1 (No Action) $0 $0 $0 2 (Proposed Action) $1,379,101 $754,526 -$591,198

3.13.3 Conclusions Table 3.41 indicates that the proposed action is financially inefficient (-$591,198) when all design criteria activities are considered. The No Action Alternative has no costs or revenues associated with it, and in this case has the higher PNV ($0). A reduction of financial PNV in any alternative as compared to the most efficient solution is a component of the economic trade-off, of achieving that alternative. The No Action Alternative would not harvest nor take other restorative actions and, therefore, incur no costs. Many of the values associated with public health and safety and natural resource management are non-market benefits. These benefits should be considered along with the financial efficiency information presented here. These non- market values are discussed in the various resource sections found in this document. The

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 175 proposed action would be economically feasible and thus consistent with the Forest Plan (Forest Plan page II/23).

3.14 Effects to Fuels 3.14.1 Affected Environment The Helena National Forest Fire Management Plan (USDA HNF 2009) outlines appropriate fire management strategies across the HNF based on management area direction in the Helena Forest Plan (1986). The analysis area includes the activity areas along the 491 miles of road segments proposed for treatment. Areas outside of these activity areas have not been analyzed in this report except where otherwise stated. The table below shows the permissible fire management strategies for each management area in the project area. Some management areas can be managed under multiple strategies.

Table 3.52 Fire Management Strategies in the Project Area Fire Management Strategy Management Area Control H1, T4 Control/Contain H2, T1, T2, T3, T5 Control/Contain/Confine L1, L2, M1, N1, P3, R1, W1, W2, EL1, EL2, EL4 Due to current levels of beetle infestation across the forest, conditions would change as more trees succumb to the beetle infestation, needles turn red on affected trees, red needles fall to the ground, and dead trees start to fall over. Road segments proposed for treatment occur in numerous vegetation types with various structures but the common theme is that all proposed road segments have a high incidence of hazard trees. Fuel Models Current conditions are best represented by four fuel models. Fuel models are stratified into four groups: grass, shrub, timber, and slash. Fuel models are determined by the vertical and horizontal structure of the vegetation and reflect the primary carrier of fire through the system (Anderson 1982). Vegetation growth and succession are dynamic processes as can be reflected by changes in fuel models over time. Fuel models can represent different successional stages as a forest regenerates, matures, and then dies over time. Fuel model descriptions were obtained from Scott and Burgan (2005) and Anderson (1982). The following photos and descriptions portray the primary fuel models for the proposed road segments.

Fuel Model 161, Low Load Dry Climate Timber-Grass- Shrub FM 161 has low load of grass and/or shrubs with litter under a timber overstory. The understory can consist of grasses, forbs, or short shrubs or any combination thereof. The overstory is lodgepole pine that may be mixed with Douglas-fir or subalpine fir. Conifer regeneration is lacking. The live herbaceous element is dynamic in fuel model 161, meaning the value transfers from live to dead as influenced by time of year. Rate of spread and flamelengths are low. The moisture of extinction is 20 %.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 176

Fuel Model 165, Very High Load Dry Climate Timber- Shrub – FM 165 has a timber overstory with heavy forest litter and a tall shrub or seedling/sapling understory. This fuel model includes any combination of moist site Douglas-fir, lodgepole pine, whitebark pine, Engelmann spruce, or subalpine fir with an understory of tall shrubs and/or conifer regeneration. Rate of spread and flamelengths are moderate. The moisture of extinction is 25 percent.

Fuel Model 183, Moderate Load Conifer Litter – FM 183 combines moderate load conifer litter and light load of coarse woody debris. This fuel model includes Douglas- fir/lodgepole pine. An understory of litter is the main component that would carry fire. This fuel model has a sparse vegetative understory. Rate of spread is very low and flamelengths are low. The moisture of extinction is 20 percent.

Fuel Model 188, Long-Needle Litter – FM 188 is mostly comprised of a moderate load of long-needle pine (ponderosa pine) litter but may have a small amount of herbaceous fuels. This vegetation type indicates Douglas- fir as the climax tree species on the HNF but ponderosa pine may be maintained as an important seral constituent. Rate of spread is moderate and flamelengths are low. The moisture of extinction is 35 percent.

Fire Behavior Fire behavior includes elements important to describing wildland fire, including: fire intensity, rate of spread, flamelength, and fire type. Fire intensity is a quantitative measure that describes the rate of heat release per unit time per unit length of the linear fire front (Agee 1993, p. 15; Davis and Holbeck 2001). Rate of spread refers to the speed of the moving fire front. As fuel moistures approach the moisture of extinction for that fuel model, fire spread will be affected as these fuels don’t burn as readily (Anderson 1982). Flamelength is an indicator of fire intensity and is generally measured from the flame tip to the ground surface (NWCG 2010). Firefighters are usually effective with flamelengths up to 4 feet. Mechanized equipment can work on fires with flamelengths less than 8 feet while fires with flamelengths greater than 8 feet may only be safely attacked with aerial resources such as helicopters and airtankers. If flamelengths exceed

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 177 11 feet, all resources are fairly ineffective. Surface fires are generally able to be staffed with firefighters.

Three different types of fire include surface fire, torching, and crown fire. Surface fire or a nonlethal fire refers to a low intensity fire confined to surface fuels with minimal overstory mortality, edge, and patch size (Agee 1998; Arno et al. 2000). Mixed severity regimes are essentially a combination of fire intensities occurring at a moderate return interval ranging from low intensity surface fire, group torching, and some amount of stand-replacing fire that create patches of intermediate size and an abundant amount of edge (Agee 1998; Arno et al. 2000). A crown fire or stand-replacing fire is a moderate to high intensity fire with nearly complete overstory mortality creating large patch sizes with an intermediate amount of edge (Agee 1998; Arno et al. 2000).

In addition, several indicators address fire effects. Fire effects include such factors as vegetation mortality, scorch height, canopy consumption, burn mosaic, and fire severity. Burn mosaic refers to the patch dynamics created by the fire which can be influenced by the type of fire (surface, torching, or crowning), fuel loading, vertical and horizontal fuel continuity, weather, and topography in addition to numerous other variables. Fire severity can be judged as the effect of fire on the tree canopy, understory vegetation, soil surface organic debris, and mineral soil and includes three general categories of classification: low or light severity, moderate or mixed severity, and high severity (DeBano et al. 1998). Fire severity usually portrays fire effects to the resource of concern such as to the soil or overstory tree canopy.

Fire Behavior Modeling Of the four fuel models, fuel models 165 and 188 would burn as a crown fire under the conditions modeled. The other two fuel models burn benignly under most circumstances, although fuel model 161 would burn as a crown fire with 50 percent slope on south and west aspects. Table 3.53 Existing Condition Fire Behavior for Proposed Road Segments (20 % slope-20mi/hr 20-ft wind) Fire Behavior Fuel Model Parameter 161 165 183 188 Flamelength (ft) 1 102 <1 55 Fireline Intensity (BTU/ft/s) 10 11,473 3 4,679 Fire Type surface crown surface crown

Fuel models 161 and 183 could be directly suppressed with firefighters as flamelengths are less than 4 feet. Fuel models 165 and 188 are beyond the flamelength threshold which all resources are fairly ineffective. Refer to the project file for complete modeling results.

These areas are accessible by engine due to direct road access. Initial attack fire suppression is generally more successful with quick response time. Based on site visits to numerous areas proposed for hazard tree removal, these trees are already “checking” or forming fissures along the bole of the tree that weaken the tree. These weakened trees may fall at any time, but a wind event could trigger blow-down. Hazard trees can compromise firefighter safety if firefighters are working in these areas. In addition, the presence of the hazard trees along roadsides may

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 178 impede ingress and egress if trees have fallen over the road which would not only affect firefighters but local landowners, recreationists, and other Forest Service personnel.

3.14.2 Effects Common to All Alternatives Both the No Action and Proposed Action alternatives include sections of road that would not be treated. Wildland fire behavior in untreated areas depends on the fuels in addition to topography and weather. Hazard trees would remain along untreated roadsides which could affect road travel and create conditions with heavy 1000-hr fuel loading (dead wood greater than 3 inches in diameter) that impedes fire suppression efforts. The fine dead wood created in an epidemic [mountain pine beetle mortality in lodgepole pine] stand is highly flammable although this phenomenon gradually tapers off by 20 years following an epidemic (Page and Jenkins 2007).

3.14.3 Alternative 1 (No Action) Roadside areas are expected to change dramatically if left untreated. The green needles of dying trees will turn red over the next few seasons and drop to the ground. These dead trees will have mostly fallen within fifteen years (Mitchell and Preisler 1998) which will greatly heighten 1000- hr fuel loading. This increase in large dead wood (often called “jackstraw”) hampers fire suppression as these areas are difficult to walk through and chainsaws are needed to remove layers of logs in order to dig fireline. Fireline production can be very slow which may limit the success of initial attack. In addition, heavy loadings of 1000-hr fuels allows for long residence time should a fire occur. Residence time refers to the total length of time that the flaming front of the fire occupies one point. Long residence time promotes smoldering of duff and litter which creates high smoke emissions and exposes mineral soil. Exposed mineral soil creates a suitable site for noxious weed establishment and potential for erosion. Fire suppression costs can be very high during this extended mop-up phase to extinguish large dead logs. Changes in forest structure will accelerate for ten to twenty years as trees die and eventually fall over. For purposes of fire behavior analysis for this alternative, fifteen years from the present will be examined (year 2025).

One impact under this alternative would be the maintenance required to clear roads as dead trees fall over. For an example of this workload, the Townsend District Fire Crew spends 12-20 person days per year clearing the Magpie Road (FS Road #425) from fire-killed trees that are continuing to fall within the Cave Gulch Fire of 2000 perimeter (Beagley 2009). About 15 miles of this road fall within the old fire within the HNF administrative boundary. Therefore, between 0.8 – 1.3 person days per mile are necessary to keep this road clear. However, the scale of the current mortality is forest-wide and would require an incredible amount of work to maintain the current road system by removing trees that fall across roads. When looking at only the road segments proposed in Alternative 2 and assuming 1.3 person days per mile are required, 655 person days per year (or 131 work days for a 5-person crew) would be needed to clear fallen dead trees from roads. This number is considered conservative as the stocking levels along the Magpie Road in the Big Belts are generally far less than road segments proposed under this project.

This alternative may severely affect ingress and egress for fire fighters. Roads play a critical role in fire suppression as they are used for access and anchor points. An anchor point is an advantageous location from which to start constructing a fireline. The anchor point is usually a

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 179 barrier to fire spread that is used to minimize the chance of being flanked by the fire while line is being constructed. Roads can be used as a firebreak and as a safe location from which to begin fireline construction. In addition, roads can be used to burn out from so as to create a defensible space by consuming flammable fuels. Lack of road access would lengthen response time of ground resources and may compromise firefighter safety due to lack of use as an escape route.

If engines or hand crews cannot access a fire by road, access is limited to hiking or helicopter. Every fire must be sized up to provide for firefighter safety. During this size-up safety concerns must be evaluated, eliminated, or mitigated. After querying the National Interagency Fire Center’s online records, 36 incidents have been reported between 1934 and present involving snags, trees, and tree limbs that have injured or killed firefighters in fire suppression activities (NIFC 2010). This is a conservative value. The risk of fighting fires with large numbers of snags or working in jackstraw conditions where escape routes are compromised would require mitigating the safety concerns or possibly not engaging firefighters.

Fuel Models Without any treatment, most areas are expected to convert to fuel models 10 or 187 over the next fifteen years. These fuel models contain a substantial loading of 1000-hr fuels on the ground. The visual difference between these fuel models lies in the size of the fuels on the ground and whether ladder fuels (such as conifer regeneration) are present. There are also some important fire behavior differences, including higher intensities for fuel model 10 and a greater propensity for torching and crown fire. FM 201 and 202 may be created in some activity areas that have slash remaining from firewood gatherers.

Fuel Model 10, Timber with Litter and Understory – FM 10 includes areas with a heavy load of downed logs as is common following disturbance. Torching, crowning, and spotting are common in this type. Common conifers include moist-site Douglas-fir, lodgepole pine, Engelmann spruce, and subalpine fir. Rate of spread and flamelengths are moderate. The moisture of extinction is 25 percent.

Fuel Model 187, Large Downed Logs – FM 187 includes areas with a heavy load of litter and large- diameter downed logs. This fuel model occurs in stands of higher elevation forests with mortality in the form of large-diameter logs on the ground. Common conifers include subalpine fir, Engelmann spruce, lodgepole pine, and whitebark pine. Rate of spread and flamelengths are low. The moisture of extinction is 25 percent.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 180 Fire Behavior The residence time in these fuel models can be long as these large fuels are slow to extinguish. Long residence times can promote smoldering of all surface material including duff, litter, vegetation, and fine woody debris which can subsequently affect erosion, native plant recovery, and noxious weed establishment. Smoldering fires also have high smoke emissions. Because of the extent of hazard trees, these concerns are valid over the broad landscape.

Fire Behavior Modeling Under this alternative fire behavior would be variable depending on the fuel model. Most areas will be represented by the fire behavior as displayed with fuel models 10 and 187. Table 3.52 represents Alternative 1 based on 20% slope, 20mi/hr 20-ft wind, & Crown Bulk Density of 0.005 lb/ft3

Table 3.54 Alternative 1 Fire Behavior Fire Behavior Fuel Model Parameter 10 187 Flamelength (ft) 7 3 Critical Surface Flamelength (ft) 2 7 Fireline Intensity (BTU/ft/s) 379 45 Fire Type torching surface

Fire behavior under this alternative would be highly variable and would greatly depend on the influence of weather. Under moderate weather conditions, a stand may burn as shown with fuel model 187. However, given the same stand and severe weather conditions fuel model 10 may be more representative. Flamelengths less than 4 feet can generally be directly attacked by firefighters but they are ineffective if flamelengths are greater than 4 feet. Mechanized equipment such as dozers and skidgeons are used for flamelengths less than 8 feet.

3.14.4 Alternative 2 (Proposed Action) The proposed action identifies those road segments that are important travel routes having the largest number of hazard trees. The proposed action would remove hazard trees instead of allowing these trees to fall over time. As a result, this action would have many favorable consequences, including: • Firefighter safety would be improved during fire suppression within the project area by removing hazard trees, • Ingress and egress routes would benefit due to the reduced long-term maintenance by removing all hazard trees along the proposed road segments now instead of having to attempt to maintain these travel routes intensively over the next fifteen years and beyond and, • Fire behavior would be changed with implementation of the proposed action as the fuel models and vegetation characteristics would change within the project area. • Roads could be used as a firebreak and provide a location from which to begin fireline construction

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 181 • Roads could be used to burn out from so as to create a defensible space by consuming flammable fuels The Snow/Talon Fire in 2003 burned over 37,000 acres on the Lincoln Ranger District and prompted a roadside project that removed hazard trees in the Copper Creek area. Very little maintenance has been needed along these road segments within the Snow/Talon Fire area as the hazard trees were removed at one time (Kurtz 2010). The hazard tree removal in the Copper Creek area has helped maintain ingress and egress routes and provided conditions more conducive for successful initial attack and improved firefighter safety along this heavily-used corridor.

Fuel Models Post-treatment fuel models were predicted based on the dominant understory or fuel stratum that would carry fire following hazard tree removal. Post-treatment fuel models depend on post- treatment canopy cover, fuel loadings, and ladder fuels. FM 201 and 202 may be created in some activity areas that have slash remaining from firewood gatherers (these model outputs are available in the project record).

Fuel Model 102, Low load dry climate grass – FM 102 is shown in the foreground of this photo. This fuel model is best represented by short grass (less than 1 foot high) and may include some fine dead fuel. Live herbaceous fuel moisture has a strong effect on fire intensity and rate of spread. Rate of spread is fairly high and flamelengths are moderate. The moisture of extinction is 15 percent.

Fuel Model 122, Moderate Load Dry Climate Grass- Shrub – FM 122 represents a fuelbed with a moderate amount of grass and shrubs that range in height between 1 to 3 feet as shown in the foreground of this photo with the interspersed grass and juniper. Some 1000-hr fuels greater than 3 inches diameter may remain in the activity areas, but the main carrier of fire would be the grass/shrub component. Live herbaceous fuel moisture has a strong effect on fire intensity and rate of spread. Rate of spread is high and flamelengths are moderate. The moisture of extinction is 15 percent.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 182 Fuel Model 161, Low Load Dry Climate Timber- Grass-Shrub – FM 161 has low load of grass and/or shrubs with litter under a timber overstory, which can be open. Along roadsides following implementation this fuel model best represents those areas with a tree overstory and a grass/forb/short shrub understory. Rate of spread and flamelengths are low. The moisture of extinction is 20 percent.

Fire Behavior Thinning along roadsides can reduce fire intensity and improve safety should an extreme event occur (Cohen 2009). In past years, research has been conducted in the western US on how fuels treatments affect wildland fires that subsequently move through the treated areas. The probability that a given acre is burned by a wildland fire is low, and even lower when looking at the probability that a given treated acre be burned by a wildland fire (Rhodes and Baker 2008). However, when looking at how wildland fires burn through treated areas, fuels treatments should be judged successful if desirable changes are made to wildland fire behavior. Instead of focusing on the probability of a treated area experiencing a fire, the probability that a wildland fire is positively affected by a treated area should be judged more important (see Finney 2008 for more information). Treatments have been designed not to stop fire but to alter the fire behavior in treated areas, thereby reducing the future effects of a potential wildfire (Stratton 2004).

Treatments in this alternative serve to open stands and therefore increase midflame windspeed which can intensify surface fire, but the reduced crown fire potential and greater ease of control is often considered an acceptable tradeoff (Finney 2001; Scott and Reinhardt 2001). Given a 20- ft windspeed of 20 mi/hr, thinning a fully sheltered stand (wind reduction factor of 0.2) to partially sheltered (wind reduction factor of 0.3) changes the midflame windspeed from 4 mi/hr to 6 mi/hr. This 2 mi/hr increase would most likely not affect fire behavior substantially. A regeneration harvest (clearcut or seedtree harvest) would have a wind reduction factor of 0.4 which would result in a midflame windspeed of 8 mi/hr (with no risk of crown fire). A thinned stand can also enhance moisture loss in live and dead fuels due to increased insolation and wind (Pollet and Omi 2002).

If windthrow occurs adjacent to the proposed roadside activity areas following implementation this would increase the surface fuel loading of 1000-hr fuels in addition to needles and branchwood. While needles are green, potential fire behavior would generally be low. Once needles turn red and the fuels desiccate, potential fire behavior depends on time of year and weather conditions. Fire behavior may be more active during the summer with high temperature, low relative humidity, low fuel moistures, and wind direction conducive for fire spread than the remainder of the year. After a number of years the needles will start decomposing which generally results in less active fire behavior.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 183 Slash created through activities affects fire behavior depending on the type of fuel that remains. Small branchwood and needles are quite flammable, especially while red needles remain. Large diameter wood, such as limbs and boles, do not affect fire intensity as much as residence time.

Chipping debris has been identified as a potential slash disposal method. Chips may either be left on-site or removed. Cohen (2009) cautions against leaving large amounts of chips as burn duration can be lengthened thereby removing the surface cover; the resultant soil heating might kill roots and seeds. These same effects can transpire if a wildfire occurs during extreme conditions following an extensive fire-free period (Cohen 2009). Glitzenstein et al. (2006) demonstrated variable fire behavior in chipped plots depending on fuel moistures and time of season.

Fire Behavior Modeling Post-treatment fire behavior would be different from Alternative 1, the No Action alternative.

Table 3.55 Alternative 2 Fire Behavior (20 % Slope and 20mi/hr 20-ft Wind)

Fire Behavior Fuel Model Parameter 102 122 161 Flamelength (ft) 7 8 2 Critical Surface Flamelength (ft) - - 6 Fireline Intensity (BTU/ft/s) 423 501 38

Fire Type surface surface surface

Activity areas that are thinned with no risk of crown fire and an understory dominated by grasses and shrubs are best represented by fuel model 122. A typical shrub in this fuel model could be common juniper, mountain big sagebrush, or shrubs typically found under a forest canopy that are cured. Post-implementation activity areas dominated by grasses are represented by fuel model 102. Activity areas that have a timber overstory remaining and an understory composed of shrubs and grasses are best represented by fuel model 161. Flamelengths as modeled in fuel models 102 and 122 are beyond the threshold for direct attack by firefighters. However, fires in these types can generally be effectively engaged by engines or using indirect fireline and burning out to consume the flammable fuels.

Cumulative Effects The cumulative effects analysis includes past, current, and foreseeable future activities as these activities influence the fire/fuels resource. The scale used is the roadside activity areas; a broad scale beyond the activity areas is addressed in a separate document examining the forest-wide cumulative effects for activities on the fire/fuels resource (USDA HNF 2010f). Most activities have little influence on fire/fuels, with the exception of harvest, thinning, prescribed fire, and unplanned ignitions (including wildfires and fires managed for resource benefits, formerly called wildland fire use) that have changed the vegetation. Less than 5 percent of the activity areas proposed along the 491 miles of road segments have been previously treated through harvest, mechanical thinning, activity fuel removal, crushing activity fuels, or prescribed fire.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 184 Table 3.56 Past Activities from 1979 through 2008 within the Project Area Acres of Project Activity Area Treated Mechanical Fuels Activities 133 Activity Fuel Removal or Crushing Activity Fuels 37 Fuels Prescribed Fire 134 Regeneration Harvest 118 Intermediate Harvest 43 Total 465

These activities have promoted vegetation diversity by creating a mosaic of age classes. Prescribed fire is especially effective at reducing surface fuels, raising canopy base height, removing ladder fuels, and conditioning trees and understory vegetation to fire.

Table 3.57 Acres Burned During Large Fires 1988 -2009 within the Proposed Activity Areas Wildfire Acres of Project Area Burned Warm Springs 5 Cave Gulch 301 Maudlow/Toston 125 Moose/Wasson 10 Snow/Talon 15 Total 456

Unplanned ignitions have various effects on vegetation depending on size of the fire, flamelengths, and intensity. In general, these fires remove ladder fuels and consume surface fuels. Removal of ladder fuels raises canopy base height which makes it more difficult for a surface fire to transition to a crown fire. Consumption of surface fuels has many effects depending on the different sizes of dead wood, but the small diameter fuels are more easily consumed which generally reduces fire intensity and flamelengths for a period of time. Mortality in forested stands depends on the amount of scorch to the bole and cambium in addition to the residence time of the fire. Less than 5 percent of the project area has burned by wildfires.

3.14.5 Conclusions Under Alternative 1, without treatment, as hazard trees fall into the roadway these roads may not be able to be maintained due to the sheer magnitude of mortality along the 491 miles of road proposed in the activity areas. Engine and vehicle access could be limited. Heavy loadings of dead wood hamper fireline production and may create dangerous conditions for firefighters in these activity areas.

Under Alternative 2, providing usable and safe travel routes are crucial for firefighter access and ingress/egress for all forest users and landowners. Implementation of the proposed action offers an efficient and effective means of maintaining the current travel system, as witnessed by the hazard tree removal within the Snow/Talon Fire area. Removal of all hazard trees within the activity areas would have a dramatic effect on firefighting access and suppression success. With

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 185 a serviceable road system, firefighters can better access fires. Quicker response times can increase suppression success. Conditions would be safer for firefighters in the treated areas as there would be far fewer hazard trees. Also, suppression strategies and tactics would be more successful without the heavy 1000-hr fuel loading. Successful suppression of fires during initial attack is a performance measure of the National Fire Plan and protecting ingress/egress routes were identified in the Tri-County, Powell County, and Meagher County Community Wildfire Protection Plans. Alternative 2 will implement the Forest Plan and meet the goals of these plans.

The overall Forest Plan direction for public safety and facilities protection would be achieved by Alternative 2. Goal 14 on page II/2 of the forest plan would be met in that the proposed action helps provide a fire protection program that is responsive to the forests land and resource management goals for the affected management areas.

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 186 4.0 CONSULTATION AND COORDINATION The Forest Service consulted the following individuals, Federal, state and local agencies, tribes and non-Forest Service persons during the development of this environmental assessment:

4.1 ID Team Members Name Role Education Years Experience Callery, Dave Hydrology M.S. Water Resources 8 years Carroll, Dave NEPA Coordinator B.S. Forest Management 26 years Cole, Larry Lands B.S. Forest Management 31 years David Payne Rec/visuals/roadless B.S. Resource Management 32 years Diemert, Vel GIS Forest Service training 20 years Harper, Archie Fisheries B.S. Fish & Wildlife Management 20 years Hollingsworth, Fuels M.S. Forestry 10 years LaWen Johnston, DJ Transportation Votech 25 years Kamps, Amber Lead Ranger/Project B.S. Forest Management 20 years proponent/writer editor M.S. Ecosystem Management Lahey, Tim Pre-sale B.S. Forestry 7 years McGuire, Kyle Archeology B.A. Anthropology/Archaeology 12 years Marr, David Soils B.S. Natural Resource Management 6 years Martinez, Robert Air Quality Technical Fire Management - USFS 15 years Milburn, Amanda Silviculture B.S. Resource Conservation 10 years Olsen, Lois Sensitive Plants/Weeds B.S. Range Management 30 years Pengeroth, Denise Wildlife M.S. Wildlife Biology 25 years Schilling, Tracy Range B.S. Range Sciences 9 years Scott, Sharon Co IDT Leader B.S. Forestry 20 years Teig, Lauri Writer/editor B.S. Biology 12 years Walch, Len Fisheries B.S. Biology; B.S. Fishery Science; 30 years M.S. Fishery Management Wyatt, Steve Rec/Minerals/Lands/S.U. B.S. Range Management 30 years

Federal, State, and Local Agencies

Name Group/Agency Title Elkhorn Working Group Murray, Mike Tri-County Fire Working Group County Commissioner

Spengler Paul Tri-County Fire Working Group Disaster and Emergency Services Coordinator McKelvey Pat Tri-County Fire Working Group Fire mitigation & prevention specialist Dutton, Leo Tri-County Fire Working Group L&C County Sheriff

Forest-wide Hazardous Tree Removal and Fuels Reduction Project EA Page 187 Name Group/Agency Title Lythgoe, Tom Tri-County Fire Working Group Jefferson County Commissioner Buckles, Sally Tri-County Fire Working Group Disaster and Emergency Services Coordinator Koenke, Mike Tri-County Fire Working Group Disaster and Emergency Services Broadwater County Coordinator Burton, Tim Tri-County Fire Working Group City of City Manager Helena Larsen, Steve Tri-County Fire Working Group City of Fire Chief Helena Clark, Don Tri-County Fire Working Group Waterworks Director Kroll, Butch Tri-County Fire Working Group State of DNRC Montana DNRC Atkins, Ken Tri-County Fire Working Group Disaster and Emergency Services Coordinator Volunteer Fire Tri-County Fire Working Group Departments Private Contractors Tri-County Fire Working Group Forestry Consultants Tri-County Fire Working Group Drake, Robert Tri-Lakes Fire Council Mack Long Fish Wildlife and Parks Pat Flowers Fish Wildlife and Parks Jenny Sika Fish Wildlife and Parks

4.2 Tribal Coordination Name Tribe Title Clarinda Burke Confederated Salish and Kootenai Tribes Tribal Historic Preservation Officer John Murray Blackfoot Tribe Tribal Historic Preservation Officer

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