Elk Smith Project Final Supplemental Environmental Assessment

United States Department of Agriculture Forest Service Elk Smith Project Final Supplemental Environmental Assessment

Rocky Mountain Ranger District Helena-Lewis and Clark National Forest Lewis and Clark County, Montana Responsible Official: Michael Muñoz, District Ranger September 2020

1 For More Information Contact: Michael Muñoz Rocky Mountain Ranger District Helena-Lewis and Clark National Forest PO Box 340 or 1102 Main Avenue NW Choteau, MT 59422 Phone: (406) 466-5341 Fax: (406) 466-3214

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2 Table of Contents

Chapter 1 – Purpose and Need ...... 8 Introduction ...... 8 Background ...... 11 Purpose and Need ...... 12 Regulatory Framework ...... 13 Regulatory Framework Common to All Resources ...... 13 Regulatory Framework by Resource ...... 14 Decision Framework ...... 35 Public Involvement ...... 35 Key Issues ...... 36 Chapter 2 – Alternatives ...... 37 No Action ...... 37 Proposed Action ...... 37 Design Features ...... 38 Resource Protection Measures ...... 42 Monitoring ...... 43 Chapter 3 – Existing Condition and Environmental Consequences ...... 45 Fire, Fuels, and Air Quality ...... 45 Technical Terms ...... 45 Methodology ...... 46 Environmental Consequences ...... 67 Proposed Action ...... 74 Air Quality ...... 80 Vegetation ...... 87 Existing Condition ...... 87 No Action Alternative ...... 91 Proposed Action ...... 92 Sensitive Plants ...... 95 Existing Condition ...... 95 No Action Alternative ...... 99 Proposed Action ...... 100 Range ...... 102

3 Existing Condition ...... 102 No Action Alternative ...... 103 Proposed Action ...... 103 Noxious Weeds/Invasive Plants ...... 104 Existing Condition ...... 104 No Action Alternative ...... 107 Proposed Action ...... 107 Soils ...... 108 Existing Condition ...... 109 No Action Alternative ...... 112 Proposed Action ...... 113 Watershed/Hydrology ...... 117 Existing Condition ...... 118 No Action Alternative ...... 121 Proposed Action ...... 122 Fisheries ...... 126 Existing Condition ...... 126 No Action ...... 137 Proposed Action ...... 138 Recreation ...... 143 Existing Condition ...... 143 No Action Alternative ...... 145 Proposed Action ...... 145 Heritage ...... 146 Existing Condition ...... 147 No Action Alternative ...... 148 Proposed Action ...... 149 Wildlife ...... 151 Existing Condition ...... 151 No Action Alternative ...... 161 Proposed Action ...... 163 Inventoried Roadless ...... 180 Introduction ...... 180

4 Relevant Laws, Regulations, and Policy ...... 182 Methodology ...... 185 Affected Environment ...... 186 Environmental Consequences ...... 188 Compliance with Forest Plan ...... 194 Conclusions ...... 194 Visuals ...... 195 Monitoring ...... 202 Carbon and Greenhouse Gas Emissions ...... 202 Affected Environment ...... 202 Direct, Indirect and Cumulative Effects ...... 203 Personnel Consulted ...... 205 Appendix A: Project Maps ...... 207 Appendix B: Treatment Units ...... 209 Appendix C: Noxious Weed Design Features and Mitigations ...... 217 Appendix D: Past, Present and Reasonably Foreseeable Actions ...... 228 Appendix E: Forest Plan Consistency Table ...... 234 Appendix F: Response to Public Comment ...... 289 Appendix G: Literature Cited ...... 323

Table of Tables Table 1: Applicable Lewis and Clark National Forest Plan Management Areas Goals - All Resources...... 13 Table 2: Applicable Lewis & Clark National Forest Management Areas – Prescribed Fire...... 15 Table 3: Applicable Lewis & Clark National Forest Management Areas – Wildlife...... 31 Table 4: Applicable Lewis & Clark National Forest Management Areas – Inventoried Roadless Areas. .... 33 Table 5: Applicable Lewis & Clark National Forest Management Area – Visuals...... 34 Table 6: Applicable Lewis and Clark National Forest Management Areas...... 52 Table 7: Elk Smith Proposed Treatment Units...... 60 Table 8: Fire Suppression Interpretations from Rothermel (1983)...... 68 Table 9: Fireline Intensity and Flame Length Classes...... 69 Table 10: Existing Condition: Percentage of Unit by Flame Length Class...... 69 Table 11: Existing Condition: Percentage of Unit by Fireline Intensity Class...... 70 Table 12: Existing Condition Crown Fire Activity by Percentage of Unit...... 71 Table 13: Post-Treatment Condition: Percentage of Unit by Flame Length Class...... 76 Table 14: Post-Treatment Condition: Percentage of Unit by Fireline Intensity Class...... 77

5 Table 15: Post-Treatment Crown Fire Activity by Percentage of Unit...... 78 Table 16: Summary of Statutory and Regulatory Consistency – Fuels...... 84 Table 17: Consistency with Purpose and Need...... 85 Table 18: Vegetation Existing Condition in The Project Area and Proposed Treatment Units...... 89 Table 19: Summary of Statutory and Regulatory Consistency – Vegetation...... 94 Table 20: Summary of Statutory and Regulatory Consistency – Sensitive Plants...... 101 Table 21: Noxious Weed Treatment ...... 105 Table 22: Forest Service Risk Assessment Factors...... 106 Table 23: Values, risk rating and action for noxious weed infestations in the project area...... 106 Table 24: Summary of Statutory and Regulatory Consistency – Noxious Weeds...... 108 Table 25: Landform, soils, geology, and sediment delivery by landtype for proposed treatment units. 109 Table 26: Predicted Erosion Rates by Unit...... 114 Table 27: Existing, predicted, and total predicted detrimental soil disturbance by unit...... 115 Table 28: Summary of Statutory and Regulatory Consistency – Soils...... 117 Table 29: Water Erosion Prediction Project Model Estimated Erosion Rates...... 123 Table 30: Summary of Statutory and Regulatory Consistency – Watershed...... 125 Table 31: Historic Properties and Proposed Actions, Based on Alternative...... 150 Table 32: Grizzly Bear Habitat by Subunit...... 152 Table 33: Lynx Analysis Units in the Project Area...... 154 Table 34: Lynx Analysis Unit RM-25 Habitat...... 155 Table 35: Wolverine Habitat...... 156 Table 36: Big game habitat...... 157 Table 37: Effective hiding cover...... 158 Table 38: Goshawk Habitat in the Project Area...... 159 Table 39: Goshawk Habitat in Bailey Basin Territory...... 160 Table 40: Goshawk Habitat in Double Falls Territory...... 160 Table 41: Goshawk Habitat in Ford Creek South Territory...... 160 Table 42: Goshawk Habitat in Bailey Basin Post-fledging Area...... 161 Table 43 Summary of Statutory and Regulatory Consistency – Wildlife...... 179 Table 44 Applicable Lewis and Clark National Forest Plan Management Areas Goals...... 182 Table 45 Applicable Lewis and Clark National Forest Management Areas – Inventoried Roadless Areas...... 183 Table 46: Wilderness Attributes and Roadless Characteristics Crosswalk...... 185 Table 47: Inventoried Roadless Area Acreage...... 187 Table 48: Planned Treatments Within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. 190 Table 49: Applicable Lewis and Clark National Forest Forest-wide Management Area Standards...... 195 Table 50: Elk Smith Proposed Treatments...... 209 Table 51: Past Actions...... 228 Table 52: Reasonably Foreseeable Actions ...... 232

6 Table 53: Forest Plan Consistency...... 234 Table 54: Response to Public Comment...... 289 Table of Figures Figure 1: Elk Smith Project Vicinity Map ...... 11 Figure 2: Photograph at the western boundary of the Project Area, 2013...... 75 Figure 3: South Fork Sun Prescribed Burn Smoke Monitoring, 2003...... 81 Figure 4: PM2.5 24-hour Concentration Chart for Fall Elk-Smith Scenario ...... 83 Figure 5: Landscape View of Project Area ...... 88 Figure 6: Post-1988 Canyon Creek fire stand...... 90 Figure 7: Canada lynx analysis area and the Elk Smith Project...... 154 Figure 8: Elk Smith Project Treatment Unit, WUI and IRA Map 2020 ...... 207 Figure 9: Fire History Map...... 208

Chapter 1 – Purpose and Need The Bear-Marshall-Scapegoat-Swan Introduction Inventoried Roadless Area The Forest Service has prepared this The Bear-Marshall-Scapegoat-Swan Supplemental Environmental Assessment in Inventoried Roadless Area is located in the compliance with the National Environmental Northern Continental Divide Ecosystem. This Policy Act and other relevant Federal and State roadless area surrounds the Bob Marshall laws and regulations. This is a Supplemental Wilderness Complex (Bob Marshall, Scapegoat Environmental Assessment to the November and Great Bear Wildernesses). It also includes 2019 Environmental Assessment and analyzes portions of the Swan Range north of the Bob the potential effects of implementing the Elk Marshall Wilderness Complex. In its entirety, Smith Project, which is within the Elk and Smith the Bear-Marshall-Scapegoat-Swan Creek drainages on the Rocky Mountain Ranger Inventoried Roadless Area is approximately District (Figure 1, Vicinity Map). These drainages 848,097 acres and is managed by three occur within the Bear-Marshall-Scapegoat-Swan National Forests (Flathead, Helena-Lewis and Inventoried Roadless Area where access is Clark and Lolo National Forests). limited to trails that lead into the Scapegoat Wilderness. The 24,220-acre project area is The topography and vegetation in the Bear- characterized by an abundance of dense stands Marshall-Scapegoat-Swan Inventoried of even-aged, young lodgepole pine, largely Roadless Area varies dramatically from the resulting from the 1988 Canyon Creek Fire. The eastern and western sides of the Continental portion of the Bear-Marshall-Scapegoat-Swan Divide. On the east side, the topography was Inventoried Roadless Area that is managed by formed by over thrust faulting and local the Rocky Mountain Ranger District is 39,242 glaciation. Generally, the area is steep and acres. There are two private in-holdings within dissected with numerous valleys. On the west the project area. Activities are proposed only on side, the terrain is steep as a result of the National Forest System lands. uplifting of the Swan Range along the Swan Fault. Glaciers have scoured the sides and Current forest conditions are more vulnerable to high- tops of these mountains. intensity, high-severity fires due to an accumulation of surface fuels, abundant ladder fuels and continuous The east side is composed of Douglas-fir, crowns. Without management, these stands are susceptible lodgepole pine, ponderosa pine, Engelmann to high-intensity wildfire that resists control efforts and spruce, subalpine fir, and white bark pine which threatens natural and cultural resources as well as conifer tree species. private property to the east of the Forest boundary. This project is designed to address these conditions and to create a more diverse, multi-aged forest.

Issues covered in this supplemental analysis • Clarification of the 2001 Roadless Rule Exception that allows the project. The project has applied the following exception under the 2001 Roadless Rule

294(b)2: “The cutting, sale, or removal of timber is incidental to the implementation of a management activity not otherwise prohibited by this subpart;” This exception is appropriate because notwithstanding the prohibition in paragraph (b) of 36 C.F.R. § 294.13, timber may be cut, sold, or removed in inventoried roadless areas if the Responsible Official determines that one of the following circumstances exists. The cutting of small diameter trees will be by hand and only to prepare and implement prescribed fire activities. • Tables displaying treatment acres in the Environmental Assessment and Decision Notice have been adjusted. Clerical errors in acreage for Units #3 and #10 were corrected for the Supplemental Environmental Assessment Treatment Table. • The Supplemental Environmental Assessment has all applicable Wildland Urban Interface acres on a map that also displays the project treatment units, in order to clearly display where designated Wildland Urban Interface is located relative to the treatment acres. • Clarification was added in the introduction, background, as well as the fire-fuels sections of the Supplemental Environmental Assessment as to why the Elk Smith project area was chosen for treatment.

Changes between the Elk Smith Environmental Assessment and the Supplemental Environmental Assessment: All text added to the Supplemental Environmental Assessment is underlined (or bolded text in tables) in this document. In addition to the more notable updates reflected below, the Supplemental Environmental Assessment also was updated with minor edits to correct typos and grammar.  Purpose and Need/Proposed Action • Proposed treatment units and treatment unit boundaries were not changed, with the Exception of Unit 7. Project design, maps, and analysis specified that cutting of small diameter conifers would not occur on 8 acres of Unit #7 which fall outside the currently designated Wildland Urban Interface. • The Secondary Needs section was removed from the Purpose and Need between the Final Environmental Assessment and this Supplemental. While the project may indirectly benefit those needs they are not primary to the purpose and need for the project.  Fire and Fuels Report • In the spring of 2020, the Tri-County Community Wildfire Protection Plan (Tri-County Community Wildfire Protection Plan, 2020) WUI was updated. This new information has been incorporated into the project analysis and maps. The designated WUI within the Elk Smith project area increased by 798 acres as a result of this update. • Changes were made in the Regulatory Framework subsection of the Report. These included a section clarifying how the Elk/Smith areas were identified for the proposed actions. • Under Existing Condition, the Fire History Section was expanded to include additional literature describing fire history and fire regime characteristics of the Northern Continental

Ecosystem, as well as more detail and analysis of fire history occurring on the District and in the Bob Marshall Wilderness Complex. • Under the Proposed Action, detail was added to clarify treatments. This included changing the metric for cutting young conifers from <20’ in height, to <7” in diameter. Additions also specified that cutting of small diameter conifers would not occur on 8 acres of Unit #7 which fall outside the currently designated Wildland Urban Interface. These changes were made both in the text of the section, as well as in an accompanying table. • Additions were also made to the Cumulative Effects Section, under the Proposed Action, to clarify the rationale for cutting small diameter trees in portions of selected units. • The following literature and media was reviewed and addressed: Ayres, 1900; Baker, 2009; Heinselman, 1979; Hollingsworth, 2015; Jain et al., 2012; Landres, 1999; Tri-County Community Protection Plan, 2020 update; Naficy et al., 2015; Naficy, 2015; Naficy, 2019, May 21; Naficy, 2019, July 9; Parks et al., 2016; Sommers and Conard, 2009; Stephens et al., 2012; Teske et al., 2012; Teske, 2012; USDA Forest Service, Decision and Finding of No Significant Impact, 2001; USDA Forest Service, Report of Investigation, 1988; USDA Forest Service, Review Report, 1988; Westerling et al., 2011; Wildland Fire Leadership Council, 2014.  Wildlife • Revised lynx analysis in updated Biological Assessment for ESA section 7 consultation to address changes to the WUI as identified in the 2020 Tri- County CWPP and its application to lynx management direction. • Revised tables and maps • Wolverine

o Completed a Biological assessment for ESA section 7 consultation • Grizzly Bear

o Revised Discussion about 1986 Lewis and Clark National Forest Land and Resource Management Plan Appendix I guidelines.  Roadless • Revised discussion of the 2001 Roadless Rule as it relates to the Elk Smith project.  Scenery • This report was refreshed and clarified to the Purpose and Need.  Forest Vegetation • Corrected discussion of Douglas-fir and subalpine fir as a shade tolerant species. • Updated references. • Changed the metric for cutting young conifers from <20 feet in height to <7 inches diameter at breast height.

• Clarified in which geographic locations stocking surveys would be completed after treatment.

Figure 1: Elk Smith Project Vicinity Map

Background Historically, the local fire regime consisted of frequent low-intensity fires, less frequent moderate- intensity fires, and periodic stand-replacing fires. Fire serves a number of critical landscape functions including: determining vegetation structure and composition, removing diseased, decadent, or insect- infested trees, providing habitat for fire-dependent species such as woodpeckers, regenerating stands of lodgepole, maintaining stands of whitebark pine, clearing trees and shrubs that encroach on grasslands, and regenerating the native grasses and shrubs that provide food for a suite of species including ungulates and bears. In 1988, the Canyon Creek Fire burned across the Elk and Smith Creek areas in a series of fire runs that were noted for their extreme fire behavior, rapid spread, and high intensity. The fire killed over two hundred and fifty head of cattle, burned two hundred miles of fencing, millions of board feet of timber, private and public livestock pasture, two thousand tons of hay, and destroyed numerous cabins and

outbuildings. The fire severely impacted Forest visitors, local farmers and ranchers, and nearby communities. It also resulted in two separate fire shelter deployments. Nine firefighters sustained severe burn injuries in the second of these deployments. Now, thirty-two years later, continuous stands of lodgepole pine regeneration and heavy loadings of large fuels are present. In 2010, the Helena – Lewis and Clark National Forest (Lewis and Clark National Forest at that time) initiated a landscape scale assessment of the Rocky Mountain Ranger District, Southern Analysis Area, which included the Elk Smith Project Area, to assess focused “needs” and identify possible activities for implementing the Lewis and Clark National Forest Plan. The effort identified the Elk and Smith Creek areas as ideal locations to reduce the threat wildland fire poses to human health, safety, property and infrastructure, while promoting ecosystem diversity across the landscape. The entire project area is classified as an inventoried roadless area. The accessible roads lead to homes, campgrounds, and recreation spots. The areas around those dwellings and roads are within the Wildland Urban Interface defined in the 2020 update of the Tri-County Regional Community Wildfire Protection Plan. This plan includes National Forest land immediately adjoining private land, State owned land, and Bureau of Land Management land within the Wildland Urban Interface. The majority of the Project Area on its northern and eastern sides are within the WUI (see Appendix A). Significant archaeological and historic sites are located throughout the Rocky Mountain Ranger District, Southern Analysis Area. They range from prehistoric camps, hunting sites, and rock art to historic recreation residences and Forest Administrative sites. Lastly, the area is prized for its visual quality and the wildlife present. The reef formations that run north-south contrast with the relatively flat open range to the East creating a visually stunning backdrop to the Rocky Mountains. The Rocky Mountain Ranger District, Southern Analysis Area provides habitat for Canada lynx, wolves, grizzly bears, northern goshawks, bighorn sheep, elk, mule and white-tailed deer, cougars, a significant number of passerine and non-passerine birds and other vertebrate species. Purpose and Need The purpose of the Elk Smith Project is to address fuel accumulation and continuity in the project area. More specifically, the purpose of the project is to: • Reduce the future risk of high-intensity, high-severity wildfire within the project area by interrupting the continuity of fuels, specifically continuous stands of lodgepole pine regeneration and heavy loadings of larger fuels; • Reduce the potential for wildfire to spread into the Benchmark corridor (The Benchmark corridor is an area containing a number of recreation residences) to the north and onto private land east of the National Forest boundary; • Create a more diverse landscape that is more resilient to fire by retaining mature areas, disrupting dense areas, and enhancing or re-creating grassland openings; and • Increase flexibility to allow lightning-caused wildfire to play its natural role in adjacent and nearby designated Scapegoat Wilderness.

Regulatory Framework

Regulatory Framework Common to All Resources This project adheres to the requirements of the National Environmental Policy Act of 1969. The Elk Smith Project Environmental Assessment meets National Environmental Policy Act requirements by comparing the impact of a “No Action Alternative” and a “Proposed Action Alternative.” Under the No Action Alternative, standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases on trees would continue their current trends. Safety concerns would escalate as the potential for fire to spread outside of the project area increase. Some incidental tree removal would occur through firewood cutting where permitted. Wildland Fire Use for Resource Benefit would remain a management option for Wilderness lands lying immediately to the west of the Project Area, though its use as a management tool could be undermined by the continued accumulation of fuels in the Project Area. The No Action Alternative provides a baseline for comparison of environmental consequences of the Proposed Action Alternative to the existing condition. It is a management option that could be selected by the Responsible Official. The following table gives the Forest Plan Management Areas (Lewis and Clark NF) found within the Elk Smith project area. It also details the acres and associated management goals for each management area within the project area boundary. Table 1: Applicable Lewis and Clark National Forest Plan Management Areas Goals - All Resources. Management Area Acres Management Goals Provide sustained high level of forage for livestock and big Management Area E 2,748 game animals. Management Area G 17,018 Maintain and protect Forest resources with minimal investment. Provide winter recreation opportunities supported by public and Management Area H 597 private developments while maintaining other resource values. Protect, maintain, and improve resource quality while providing Management Area O 3,431 timber at a low intensity level to meet local needs. Manage forage for livestock at a moderate intensity level. Manage these areas to protect their wilderness values. Manage Management Area Q 426 with limited investment in range management and trail construction. Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration Management Area R N/A to riparian area dependent resources. Timber and range management activities are permitted.

Regulatory Framework by Resource

Fire and Fuels

Federal Laws and Regulations

1974 Forest and Rangeland Renewable Resources Planning Act, as amended by the 1976 National Forest Management Act The Elk Smith Project adheres to a well-defined regulatory framework in terms of Fire, Fuels, and Air Quality. The project evolved directly from the Rocky Mountain Ranger District National Forest Management Act analysis known as the Rocky Mountain South Analysis Area (USDA Forest Service, 2010). Following the direction of the National Forest Management Act, 1976, the Rocky Mountain South Analysis Area identified possible activities for implementing the Lewis and Clark National Forest Plan on an area covering the southern half of the Rocky Mountain Ranger District. The Rocky Mountain South Analysis Area identified the “Elk Creek and Smith Creek areas” as an area of greatest importance to treat fuels in order to reduce “the need to apply all or most of the available resources (i.e. personnel, equipment, and financial resources) to single large-scale fires or high profile fires… that could threaten recreation residences/summer homes, private lands, travel routes, administration sites, and cultural resources… (USDA Forest Service, 2010).”

The Clean Air Act of July 1955 The Clean Air Act also regulates activities outlined in the Alternative section of this project. This project would adhere to all implementation, reporting, and monitoring requirements inherent in following the Clean Air Act. Impacts of the No Action and Action Alternatives are analyzed in the Air Quality subsection of the Fire and Fuels section. Guidance to effectively manage and evaluate smoke impacts can be found in Publication Management System 484 – Interagency Prescribed Fire Planning and Implementation Procedures Guide, 2014; and in Publication Management System 420-2 – Smoke Management Guide for Prescribed and Wildland Fire. All prescribed burning proposed in the Action Alternative would be subject to management and approval by the Montana/Idaho Airshed Group.

Forest Service Direction The Elk Smith Project is aligned with Forest Service Manual direction for Fire Management. Manual Direction offers the following vision to managers: “[To] safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire Forest Service Manual 5102.” The first priority in all management actions is as follows: Risk Management and Risk Reduction – Assure management of risk to people, communities and natural and cultural resources is the fundamental principle used to make informed decisions in all fire management programs. Minimize the risk to people, communities and natural and cultural resources by assessing the potential benefits of actions, severity of concerns and probabilities of occurrences to reduce risk. (Forest Service Manual 5102) The Action Alternative for the Elk Smith Project is designed to meet this objective by reducing the volume and continuity of fuels in proximity to the National Forest boundary. These activities are intended to reduce risk to human health and safety, as well as to protect communities and resources. In

addition, these treatments are intended to increase the efficiency and effectiveness of fire management actions or, in other words, improve their cost-effectiveness.

Lewis and Clark Forest Plan (1986) In accordance with National Policy direction, the Action Alternative for the Elk Smith Project was identified and developed utilizing management goals outlined in the Lewis and Clark National Forest Plan (USDA 1986). The management goals for all management areas included in the Elk Smith Project Area include the use of prescribed fire. Table 2: Applicable Lewis & Clark National Forest Management Areas – Prescribed Fire. Management Area Acres Management Goals (Prescribed Fire) Management Area E 2,748 Management Area G 17,018 (PS12a) Prescribed fire with planned ignitions would be used in this Management Area H 597 management area for the enhancement and maintenance of resources (see Appendix P of the LCNF Forest Plan) for specific Fire Management Management Area O 3,431 Direction). Not Management Area R applicable

The Healthy Forest Restoration Act of 2003 The Healthy Forest Restoration Act of 2003 “incentivized communities to engage in comprehensive forest planning and project prioritization.” It also established statutory minimum requirements for the establishment of Community Wildfire Protection Plans. The Community Wildfire Protection Plan covering Lewis and Clark County is known as the Tri-County Regional Community Wildfire Protection Plan and was developed by the “Tri-County Fire Safe Working Group (TCFSWG), a 501(c)3 organization whose partnerships includes individual citizens, local governments, state and federal agencies, interested contractors, and fire suppression departments from all three counties (CWPP, 2020).” Located entirely within Lewis and Clark County, the Elk Smith Project is covered by the Tri-County Regional Community Wildfire Protection Plan, update of July 2020. Of the 10,329 acres that are included in Elk-Smith Project Units, 8,222 acres are located inside designated Wildland Urban Interface; 2,107 acres are located outside designated Wildland Urban Interface. Treatments identified in the Elk Smith Project meet criteria of the Tri-County Regional Community Wildfire Protection Plan, update of July 2020, for projects intended to further the goals of the National Cohesive Strategy for both lands designated as Wildland Urban Interface, and lands adjoining the designated Wildland Urban Interface.

Federal Land Assistance, Management, and Assistance Act of 2009 The Federal Land, Assistance, Management, and Enhancement Act resulted in a National Cohesive Strategy with the following vision for the coming century: “To safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire.” The Tri-County Community Wildfire Protection Plan includes a Regional Mitigation Plan, with specific strategies to achieve the goals of the National Cohesive Strategy. The individual strategies and how they relate to the Elk Smith Project are included in a table in the Elk Smith Supplement’s supporting documentation, under Fuels.

Vegetation Management areas contained within the proposed project area and associated goals are listed in Table 1. Based on these goals, prescribed fire with planned ignitions may be used, with the exception of Management Area Q, for the enhancement and maintenance of resources. Proposed treatment units are not located within management area Management Area Q. Prescribed fire with unplanned ignitions may be used in management areas E, G, and Q for the enhancement and maintenance of resources, when within pre-established prescribed fire criteria. Forest regeneration within management areas O and R, part of the suitable timber base, would be natural.

Federal Laws and Regulations

1974 Forest and Rangeland Renewable Resources Planning Act, as amended by the 1976 National Forest Management Act It is the policy of Congress that all forested lands in the National Forest System be maintained in appropriate forest cover with species of trees, degree of stocking, rate of growth, and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management in accordance with land management plans. A report shall be compiled annually, based on examinations, of all lands in the National Forest System where objectives of land management plans indicate the need to reforest areas that have been cut-over or otherwise denuded or deforested. Treated lands shall be examined after the first and third growing seasons and certified as to stocking rate, growth rate, and other pertinent measures. Lands not certified would be returned to the backlog and scheduled for prompt treatment. Forest Plans will be developed to identify the suitability of lands for resource management; provide for the diversity of plant and animal communities based on the suitability and capability of land areas to meet multiple-use objectives; and where appropriate, to the degree practicable, preserve the diversity of tree species similar to that existing in the planning area.

Forest Service Direction

Forest Service Manual (FSM 2400 – Chapter 2470 Silvicultural Practices) • 2470.03 - Land managers shall use only those silvicultural practices that are best suited to the land management objectives for the area. Consider all resources, as directed in the appropriate forest plan. • 2472.02 - The Forest Service seeks to maintain all forest lands within the National Forest System in appropriate forest cover as directed by the National Environmental Policy Act. • 2472.03 - When harvest or a disturbance event reduces forest cover to an un-stocked or understocked condition, make an initial assessment and diagnosis to identify the acres in need of reforestation treatment or natural recovery in order to meet management objectives. Examine all reforestation areas for certification as meeting specific reforestation standards approved by the Regional Forester for timber production and other resource objectives. Make regeneration examinations, at a minimum, after the first and third growing seasons following treatment.

Sensitive Plants

Forest Service Direction

Forest Service Manual (FSM 2600 – Chapter 2670 Threatened, Endangered, and Sensitive Plants and Animals) • 2670.32 (1) - Review programs and activities as part of the National Environmental Policy Act of 1969 process through a biological evaluation to determine their potential effect on sensitive species. • 2670.32 (2) - Avoid or minimize impacts to species whose viability has been identified as a concern. • 2670.32 (3) - Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole. • 2672.41 - Ensure that Forest Service actions do not contribute to loss of viability of any native or desired non-native plant or contribute to trends toward Federal listing of any species.

Lewis and Clark Forest Plan

Standard C-2 – Threatened and Endangered Species (1) Comply with the Endangered Species Act, other related laws, executive orders, Forest Service Manual direction, implementing regulations of the National Forest Management Act, legal decisions that have a bearing on the Forest Service Threatened and Endangered species program, consultation with the US Fish and Wildlife Service, recovery plans, and special studies. (2) - Conduct a biological evaluation of each program or activity which is Forest Service funded, authorized, or carried out on occupied Threatened and Endangered species and sensitive species habitat. This evaluation will determine whether or not informal or formal consultation with the US Fish and Wildlife Service on Threatened and Endangered species is appropriate. (3) - Identify and evaluate cumulative effects as part of each biological evaluation. This evaluation may result in specific management recommendations in addition to those identified above. (13) - There are sensitive plants, as listed by the Regional Forester, of limited distribution that occur on the Forest and may require special consideration in land management to maintain diversity within the species gene pool. Assessments of suitable habitats for sensitive plants will be conducted before surface disturbing activities are permitted.

Range

Forest Service Direction

Forest Service Manual 2200 Forest Service Manual 2200 is referenced as it provides the direction for the administration of Allotments and associated Permits.

Consistent with the Elk/Smith project manual direction 2243.34 quoted below specifically calls for the use of tools such as mechanical and prescribed fire to alter vegetation to achieve resource objectives.

2243.34 - Vegetation Management Use cultural, mechanical, biological, chemical, or prescribed fire to eliminate, reduce, perpetuate, or otherwise alter vegetation composition and density. Use methods in the combinations that most effectively achieve objectives of established resource planning processes.

Lewis and Clark Forest Plan

Standard D-1 – Range Improvements 1. Cooperate with permittees in constructing range improvements. Use one of the following approaches to arrange the cooperative work: a. Modify the grazing permit. b. Use collection agreements. c. Use appropriate procurement procedures when the Forest Service pays the permittee to do all the work. 2. Share range improvement cost to increase or maintain the grazing level. The objective will be a 50-50 participation level between the Forest Service and the permittee. Maintenance of these improvements is usually a permittee responsibility. Cost for range improvements to livestock distribution in response to other resource values will be the responsibility of the Forest Service. Maintenance of these improvements is usually a Forest Service responsibility.

3. Use prescribed fire for control of sagebrush and tree encroachment and other vegetative manipulation as needed to meet outputs.

Sun Canyon Range Analysis Site specific management direction for allotments within the project area such as stocking numbers, season of use, grazing system and allowable use standards are provided in the Sun Canyon Range Analysis, June 1997.

Noxious Weeds/Invasive Plants

Federal Laws and Regulations

Federal Noxious Weed Law The federal noxious weed list is determined by rule of the U.S. Department of Agriculture under the definitions and provisions of the Federal Noxious Weed Act of 1974, Title 7, Chapter 61. A federal noxious weed is of foreign origin and is new or not widely prevalent within the United States. Federal noxious weeds are specified as aquatic weeds, parasitic weeds, or terrestrial weeds. For the purpose of weed management on federal lands (Section 2814), a federal agency shall adopt any list classified as noxious by federal or state law.

Executive Order 13112, Invasive Species Each federal agency whose actions may affect the status of invasive species shall, to the extent practicable and permitted by law, identify such actions; subject to the availability of appropriations, and within Administration budgetary limits, use relevant programs and authorities to: (i) prevent the introduction of invasive species; (ii) detect and respond rapidly to and control populations of such species in a cost-effective and environmentally sound manner; (iii) monitor invasive species populations accurately and reliably; (iv) provide for restoration of native species and habitat conditions in ecosystems that have been invaded; (v) conduct research on invasive species and develop technologies to prevent introduction and provide for environmentally sound control of invasive species; and (vi) promote public education on invasive species and the means to address them; and not authorize, fund, or carry out actions that it believes are likely to cause or promote the introduction or spread of invasive species in the United States or elsewhere unless, pursuant to guidelines that it has prescribed, the agency has determined and made public its determination that the benefits of such actions clearly outweigh the potential harm caused by invasive species; and that all feasible and prudent measures to minimize risk of harm will be taken in conjunction with the actions.

State of Montana Laws and Regulations The Montana County Noxious Weed Control Law (MCA 7-2101 through 2153) Established in 1948 to protect Montana from destructive noxious weeds this act, amended in 1991, has established a set of criteria for the control and management of noxious weeds in Montana. Noxious weeds are defined by this act as being any exotic plant species which may render land unfit for agriculture, forestry, livestock, wildlife or other beneficial uses or that may harm native plant communities. Plants can be designated statewide as noxious weeds by rule of the Department of Agriculture or county-wide noxious weeds by district weed boards following public notice of intent and a public hearing. The Montana Noxious Weed Law only pertains to noxious weeds. It cannot be enforced on any weed not designated as a statewide or district “noxious weed”. Local government has the responsibility for implementation and enforcement of weed management in Montana. Each county government is required to appoint a county weed control board, and to develop a long-term noxious weed management plan.

Forest Service Direction

Forest Service Manual (FSM 2900) Forest Service Manual 2900 requires that all forest management activities are designed to minimize or eliminate the possibility of establishment or spread of invasive species on National Forest System lands, or to adjacent areas.

Lewis and Clark Forest Plan

Rocky Mountain Ranger District Invasive Plant Management Strategy, 2015 Invasive Plant Management Strategy is to provide a systematic approach to Districtwide invasive plant management and priority setting to improve coordination and effectiveness of invasive plant management efforts. The Rocky Mountain Ranger District has an urgent need to continue the implementation of an aggressive, effective, and coordinated invasive plants management program. This urgency is in response to the continual increase in invasive plant infestations, a growing national emphasis on invasive plant management. This strategy focuses on the following key approaches to invasive plant management: • Describes a dynamic and adaptive approach to invasive plant management, focusing on the use of best available science. • Emphasizes the importance of effective cooperative relationships to address invasive plants at a landscape scale. • Identifies the value of integrated pest management strategies with a priority focus on education, prevention and early detection and rapid response. • Frames a systematic approach to invasive plant management that guides the prioritization of survey, inventory, treatment and monitoring activities to ensure invasive plant management actions taken are both fiscally responsible and ecologically effective. • Highlights the importance of identifying weed free areas. • Recognizes the importance of identifying causal factors and vectors for invasive plant introduction in order to prevent reinvasion and spread.

Forest Plan Standard D-2, Noxious Weeds and Other Pests (USDA Forest Service 1986a, p. 2-38 to 2-39). 1. Develop a public information and education program to emphasize practices that prevent resource degradation and spread of noxious weeds. 2. Emphasize preventing noxious weeds by reseeding, with desirable plant species, mineral soil exposed by Forest activities. (SA Management Standard F3, Soil and Water Protection.) 3. Evaluate alternatives, as outlined in Forest Service Manual 2155.3, to determine effective environmentally acceptable practices to control noxious weeds and other pests. 4. Identify areas where noxious weed and/or pest control is needed. Special attention should be paid to: streams, bogs, and associated riparian habitat; upland game bird nesting habitat; and any other sensitive non-target animal or habitat which may be adversely affected by spraying. 5. Annually review spray projects, in environmentally sensitive areas, for opportunities to replace spraying with other Integrated Pest Management methods. Cooperate and support basic research for biological control of noxious weeds and other pests. 6. Cooperate closely with other Federal and State agencies, private individuals, contactors, and permittees to control noxious weed and pest infestations.

Soils

Federal Laws and Regulations

The Forest and Rangeland Renewable Resources Planning Act of 1974 (16 U.S.C. 1600-1614) (as amended by National Forest Management Act of 1976 (16 U.S.C. 472a). States that the development and administration of the renewable resources of the National Forest System are to be in full accord with the concepts for multiple use and sustained yield of products and services as set forth in the Multiple-Use Sustained Yield Act of 1960. The Act requires the maintenance of productivity of the land and the protection and, where appropriate, improvement of the quality of the soil and water resources. The Act specifies that substantial and permanent impairment of productivity must be avoided and has far-reaching implications for watershed management in the National Forest System. This Act as amended contains the following sections and provisions pertinent to maintaining a sound soil management program: • Section 3 paragraph 6b. This section directs the Secretary of Agriculture to make, and keep current, a comprehensive survey and analysis of conditions of, and requirements for, forest and rangelands of the United States, including a determination of the present and potential productivity of the land. • Section 5. This section directs the Secretary of Agriculture to develop and maintain on a continuing basis, a comprehensive and appropriately detailed inventory of all National Forest System lands and renewable resources. • Section 6 paragraph k. This section directs the Secretary of Agriculture to identify lands within the management area which are not suited for timber production.

Forest Service Direction Forest Service Manual 2550. Soil Management, Amendment 2500-2010-1. Maintain or restore soil quality on National Forest System lands; to manage resource uses and soil resources on National Forest System lands to sustain ecological processes and function so that desired ecosystem services are provided in perpetuity. This directive establishes the management framework for sustaining soil quality and hydrologic function while providing goods and services outlined in forest and grassland land management plans.

Forest Service Manual 2554. Soil Quality Management R-1 Supplement No. 2500-99-1. Meet direction in the National Forest Management Act of 1976 and other legal mandates. To manage National Forest System lands under ecosystem and management principles without permanent impairment of land productivity and to maintain or improve soil quality. This policy defines Regional Soil Quality Standards.

Forest Service Handbook 2509.22. Soil and Water Conservation Handbook. Provide a non-point source management strategy to develop site-specific conservation practices for activities on National Forest System lands to minimize effects on soil and water resources and protect water-related beneficial uses.

Watershed

Federal Laws and Regulations

Clean Water Act The federal Clean Water Act required each state to develop its own water quality standards, subject to the approval of the Environmental Protection Agency. Section 303(d) of the Clean Water Act required each state to assess all water bodies within its borders in order to identify water quality impairments that exceeded state standards. Under the Clean Water Act, water bodies identified as impaired generally require the development of a “Total Maximum Daily Load” (a water quality restoration plan). The state is required to systematically develop these plans in collaboration with the Environmental Protection Agency. A water body’s status on Montana’s 303(d) list dictates, to a certain extent, the water quality standards under state law. Other aspects of the Clean Water Act (e.g. Section 404) do not apply to this project.

Forest and Rangeland Renewable Resource Planning Act of 1974 and National Forest Management Act of 1976 In response to requirements set forth in these two Acts, final rules on National Forest System Land and Resource Management Planning established specific minimum management requirements to be met in accomplishing the goals and objectives for National Forest System lands. These requirements were intended to guide the development, analysis, approval, implementation, monitoring, and evaluation of forest plans. Requirements specific to soils, water and fish habitat are found in 36 Code of Federal Regulation 219.27, volume 47, #190, September 30th, 1982 (Federal Register 1982) as follows: (a) Resource protection. “All management prescriptions shall: (1) Conserve soil and water resources and not allow significant or permanent impairment of the productivity of the land; (2) Consistent with the relative resource values involved, minimize serious or long-lasting hazards from flood, wind, wildfire, erosion. (4) Protect streams, streambanks, shorelines, lakes, wetlands, and other bodies of water...; (6) Provide for adequate fish and wildlife habitat to maintain viable populations of existing native vertebrate species....” (e) Riparian areas. “Special attention shall be given to land and vegetation for approximately 100-feet from the edges of all perennial streams, lakes, and other bodies of water. This area shall correspond to at least the recognizable area dominated by the riparian vegetation. No management practices causing detrimental changes in water temperature or chemical composition, blockages of water courses, or deposits of sediment shall be permitted within these areas that seriously and adversely affect water conditions or fish habitat. Topography, vegetation type, soil, climate conditions, management objectives, and other factors shall be considered in determining what management practices may be performed within these areas or the constraints to be placed upon their performance.”

(f) Soil and Water Conservation. “Conservation of soil and water resources involves the analysis, protection, enhancement, treatment, and evaluation of soil and water resources and their responses under management and shall be guided by instructions in official technical handbooks. These handbooks must show specific ways to avoid or mitigate damage, and maintain or enhance productivity on specific sites. These handbooks may be regional in scope or, where feasible, specific to physiographic or climatic provinces.” Refer to the section below, best management practices for a discussion of the Forest Service Soil and Water Conservation Practices Handbook.”

Multiple Use Sustained Yield Act of 1960 It is the policy of the Congress that the national forests are established and shall be administered for outdoor recreation, range, timber, watershed, and wildlife and fish purposes (16 USC 2 (I); Sec 528 ). The terms multiple use and sustained yield are defined as: “The management of all the various renewable surface resources of the national forests so that they are utilized in the combination that will best meet the needs of the American people; making the most judicious use of the land for some or all of these resources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; that some land will be used for less than all of the resources; and harmonious and coordinated management of the various resources, each with the other, without impairment of the productivity of the land, with consideration being given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output. The achievement and maintenance in perpetuity of a high-level annual or regular periodic output of the various renewable resources of the national forests without impairment of the productivity of the land.”

Executive Order 11988, Floodplain Management This Executive Order requires that agencies avoid adverse impacts associated with occupancy and modification of floodplains. It generally applies to the 100-year floodplain.

Executive Order 11990, Protection of Wetlands This Executive Order states that agencies shall minimize destruction, loss, or degradation of wetlands and shall preserve and enhance their natural and beneficial values. Agencies are to avoid construction in wetlands unless it is determined that there is no practicable alternative and that all practicable measures are taken to minimize harm to wetlands.

State of Montana Laws and Regulations

Montana Code Annotated (MCA) 75-5-303: Non-Degradation Policy This policy mandates that “existing uses of state waters and the level of water quality necessary to protect those uses must be maintained and protected,” although activities existing as of April 1993 that generate non-point-source pollution are exempted from this policy (MCA 75-5-303[1-2], MCA 75-5- 317[2][a]). This exemption would apply to most Helena-Lewis and Clark National Forest system roads.

Montana Code Annotated (MCA) 75-5-703: Development and Implementation of Total Maximum Daily Loads In water bodies for which a total maximum daily loads has been developed and implemented, Montana law supports a “voluntary program of reasonable land, soil, and water conservation practices for nonpoint source activities for water bodies” in order to achieve compliance with water quality standards (MCA 75-5-703 [8]). In water bodies identified as impaired and in need of total maximum daily loads development, but for which no total maximum daily loads has been completed, “new or expanded nonpoint source activities affecting a listed water body may commence and continue if those activities are conducted in accordance with reasonable land, soil, and water conservation practices” (MCA 75-5- 703 [10][c]). See Table 30 of the watershed report (project file) for a summary of the Water Quality Limited Segment in the Little Belt Mountains.

Administrative Rules of Montana (ARM) 17.30.6: Surface Water Quality Standards and Procedures 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]). 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. The additional standards for A-1 and B-1 waters that are pertinent to this project include “no increases are allowed above naturally occurring concentrations of sediment or suspended sediment (except as permitted in 75-5-318 , MCA), …, which will or are likely to create a nuisance or render the waters harmful, detrimental, or injurious to public health, recreation, safety, welfare, livestock, wild animals, birds, fish, or other wildlife” (ARM 17.30.622[3][f]) for both categories, and “no increase above naturally occurring turbidity or suspended sediment is allowed except as permitted in 75-5-318, MCA” for A-1 waters (ARM 17.30.623[3][d]) and “the maximum allowable increase above naturally occurring turbidity is five nephelometric turbidity units except as permitted in 75-5-318, MCA” for B-1 waters (ARM 17.30.622[3][d]). The term naturally occurring implies “conditions or material present from runoff or percolation over which man has no control or from developed land where all reasonable land, soil and water conservation practices have been applied” (ARM 17.30.602). Reasonable land, soil, and water conservation practices consist of “methods, measures, or practices that protect present and reasonably anticipated beneficial uses” (ARM 17.30.602).

Administrative Rules of Montana (ARM) 17.30.7: Non-degradation of Water Quality Montana water quality law addresses changes in water yield by designating “activities that would increase or decrease the mean monthly flow of a surface water by less than 15 percent or the seven-day 10 year low flow by less than 10 percent as “non-significant” and are not requiring a review under MCA 75-5-303—Non-degradation Policy (ARM 17.30.715).

Forest Service Direction

National Direction On March 20, 1996, the Chief of the Forest Service, Jack Ward Thomas and the Director of the Bureau of Land Management, Mike Dombeck issued a letter to Regional Foresters and State Directors concerning Accelerating Cooperative Riparian Restoration and Management. They stated: “This undertaking is important to us. It represents an opportunity to work together on one of the most significant resources charged to our care, and to involve communities connected by the riparian zone. The USDA Natural Resource Conservation Service will be a principal partner as we begin to implement riparian restoration on a watershed scale in cooperation with all landowners. It is time to fix the creeks! We will work collaboratively to implement this program. This approach requires the integration of ecological, economic, social factors, and participation of affected interests. These are the elements proven effective in successful demonstration areas throughout the West.” (USDA Forest Service, 1996a).

Forest Service Manual 2500. Water Quality Management - Sections 2532.02, 2532.03 Sections 2532.02 and 2532.03 of the Manual describe the objectives and policies relevant to protection and, where needed, improvement, of water quality on National Forest System lands so that designated beneficial uses are protected. Guidelines for data collection activities (inventory and monitoring) are also described.

Lewis and Clark Forest Plan

Forest Plan Standard F-1, Erosion Control • Utilize adequate soil and water conservation practices to protect soil productivity and to control nonpoint water pollution from project activities, using as a minimum, practices specified in any State-developed “Best Management Practices.”

Forest Plan Standard F-3, Soil, Water, and Air Protection 1. Require application of Best Management Practices to project activities to ensure meeting or exceeding State water quality standards. 2. Develop additional best management practices during the environmental analysis process and incorporate them into all land use and project plans as a principle mechanism for controlling nonpoint pollution sources and meet soil and water quality or other resource goals. 3. Meet State Water Quality standards as required by the Clean Water Act (33 U.S.C. 1323) and as detailed in the Memorandum of Understanding to implement the 208 Program on National Forests in the State of Montana. Coordinate with the State of Montana concerning stream channels as agreed to in the Memorandum of Understanding with the State of Montana Fish and Game Commission. 4. Require a watershed analysis of projects involving significant vegetative removal to ensure that the project, considered with other activities, will not increase water yields or sediment beyond acceptable limits. The analysis should identify any opportunities for mitigating adverse effects

on water related beneficial uses, including capital investments for fish habitat or watershed improvements. 5. Conduct an environmental analysis for all management actions planned for floodplains, wetlands, riparian zones, or bodies of water prior to implementation. Adopt the necessary mitigation measure to minimize risk of flood loss, restore and preserve flood plain values, and to protect wetlands.

Management Area R Riparian areas throughout the forest have been given special consideration. These considerations include: (1) minimizing activities in riparian areas where possible; (2) standards for stream crossings; and (3) measures to avoid stream contamination. Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian area dependent resources. Timber and range management are permitted. Adhere to state water quality standards and maintain current soil productivity. Priority funding will be high structural or land treatments which maintain or rehabilitate watersheds or soil.

Fisheries

Federal Laws and Regulations

Endangered Species Act There are no aquatic species listed as “threatened” or “endangered” in the project area.

Clean Water Act (CWA) Refer to the watershed section for specific information about this act.

Multiple Use - Sustained Yield Act (MUSYA), 1960 Refer to the Watershed section for specific information about this act.

Executive Order 11990, Protection of Wetlands Refer to the Watershed section for specific information about this Executive Order.

State of Montana Laws and Regulations

Montana Code Annotated 75-5-303: Non-Degradation Policy Refer to the Watershed section for specific information about this law.

Montana Code Annotated 75-5-703: Development and Implementation of Total Maximum Daily Loads Refer to the Watershed section for specific information about this law. There are no total maximum daily load listed streams present on any of the proposed watersheds.

Montana Code Annotated 77-5-301: Streamside Management Zone Act The Montana Streamside Management Zone law governs what harvest-related activities may occur in riparian and wetland areas adjacent to streams. Retention of trees within Streamside Management Zones is covered by this act.

Administrative Rules of Montana 17.30.6: Surface Water Quality Standards and Procedures Refer to the Watershed section for specific information about this rule.

Administrative Rules of Montana 17.30.7: Non-degradation of Water Quality Refer to the Watershed section for specific information about this rule.

Forest Service Direction

Forest Service Manual 2500. Water Quality Management - Sections 2532.02, 2532.03 Refer to the Watershed section for specific information about these manual sections.

Lewis and Clark Forest Plan

Forest Plan Standard C-2 - Threatened, Endangered, and Sensitive Species 1. Comply with the Endangered Species Act – there are no aquatic Threatened or Endangered species in the project area 2. Conduct a biological evaluation of each program or activity to determine whether the activity may affect Threatened or Endangered species. There are no aquatic Threatened or Endangered species in the project area

Forest Plan Standard C-3 - Fish Habitat 1. Increase the coordination of the fisheries resource with other forest activities and programs…timber management, range management and oil and gas development. 2. Increase coordination with the Montana Department of Fish, Wildlife and Parks to adequately address issues and concerns related the Forest’s overall annual program of work. 4. Emphasize the maintenance or enhancement of habitat supporting populations of Upper Missouri River (blackspotted) cutthroat trout (note: westslope cutthroat trout is currently the proper common name for the blackspotted cutthroat mentioned in the Forest Plan). 5. The management of soil and vegetation in riparian areas is essential to fisheries habitat management. (See Management Standards D3, F3, E-4, G-1, L-4, and P-2).

Recreation

Lewis and Clark Forest Plan

Rocky Mountain Ranger District Travel Management Plan, 2007 Motorized and non-motorized travel on the Rocky Mountain Ranger District has been managed since the 2007 Birch South Travel Management Decision.

Heritage

Federal and State of Montana Laws and Regulations

The National Historic Preservation Act, 1966 (16USC470) The National Historic Preservation Act and its implementing regulations require that federal agencies consider the effects of their undertakings on historic properties. The term ‘historic’ in this context refers to cultural properties that have been determined eligible for inclusion in the National Register of Historic Places. Properties that have not yet been evaluated must be treated as potentially significant until the Agency reaches a determination of ineligibility with the Montana State Historic Preservation Office or the Keeper of the National Register. Historic properties may be the result of aboriginal use (prior to Euro-American influence) or historic period use. They may represent a single event or a complex system. They may be an object, feature, site, or district. They must meet the criteria outlined in 36 Code of Federal Regulations 60.4 to qualify for the National Register. The consideration of effects previewed in National Environmental Policy Act is formalized through the National Historic Preservation Act Section 106 review process. Section 106 review is a ‘cultural-resource-specific’ process that is completed concurrent with the National Environmental Policy Act; it is generally finalized for a selected alternative. National Historic Preservation Act Section 106 review is the subject of both National and Regional Programmatic Agreements, and is included in federal policy, direction and guidance. Federal Agencies carry out their compliance responsibilities with heritage laws and regulations by conducting documentary research, consulting with Indian Tribes, the State Historic Preservation Office, possibly the Advisory Council on Historic Preservation, and others, and often by field-surveying to identify cultural properties. Site-specific effects analysis and the resolution of effects are ensured by following the National Historic Preservation Act regulatory review process specified by 36 Code of Federal Regulations 800. For the Helena-Lewis and Clark National Forest, this process is further guided by the Region 1 Policy for integrating National Environmental Policy Act and National Historic Preservation Act (1991), the Region 1 Programmatic Agreement for Cultural Resources (USDA Forest Service et. al. 2015), and the Lewis and Clark National Forest Site Identification Strategy (1995). Through the Section 106 process, all undertakings are identified and addressed, and any necessary mitigation measures are incorporated into project design, the National Environmental Policy Act document, or other appropriate cultural resource agreement. The goal is to avoid, minimize, or mitigate impacts to significant cultural properties.

Both National Historic Preservation Act and the Archaeological Resources Protection Act contain provisions for the confidentiality of certain cultural resource information. Site-specific locations and other sensitive site data are not disclosed to the public. Documents containing this information are marked with an asterisk (*) in the bibliography and retained in the cultural resource project file. This information is exempt from public disclosure and not available under the Freedom of Information Act.

Wildlife

Federal Laws and Regulations

The Forest and Rangeland Renewable Resources Planning Act of 1974 (16 U.S.C. 1600-1614) (as amended by National Forest Management Act of 1976 (16 U.S.C. 472a). The Forest Service is charged with maintaining the diversity of all existing native and desired non-native vertebrate species in a planning area under the National Forest Management Act of 1976. The regulations impose a standard by requiring habitat objectives to be established for maintaining viability of Management Indicator Species throughout a planning area.

Endangered Species Act of 1973 The Endangered Species Act requires all Federal agencies to review any project authorized, funded, or carried out to determine that the action is not likely to jeopardize the continued existence of any proposed, threatened, or endangered species. This is accomplished via preparation of a biological assessment for those listed or proposed species present in the project area.

Migratory Bird Memorandum of Understanding On December 12, 2008, a memorandum of understanding was signed by the Forest Service and the U.S. Fish and Wildlife Service to promote the conservation of migratory birds (USDA Forest Service and USDI Fish and Wildlife Service 2008), in accordance with Executive Order 13186 (2001). Section D (3) of the Memorandum of Understanding says, “(w)ithin the NEPA process, evaluate the effects of agency action on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors”.

Forest Service Direction

Forest Service Manual 2600 – Wildlife, Fish, and Sensitive Plant Habitat Management, Chapter 2630 – Management of Wildlife and Fish Habitat, The Forest Service Manual provides direction for the management of terrestrial resources. Forest Service Manual 2630 provides overall objectives for maintaining and improving wildlife habitat. The policy relevant to this project states to: • Coordinate with other uses and activities to accomplish habitat management objectives and to reduce detrimental effects on wildlife and fisheries. • Mitigate the negative effects of other resource projects upon wildlife and fish habitat.

Forest Service Manual 2600 – Wildlife, Fish, and Sensitive Plant Habitat Management, Chapter 2670 – Threatened, Endangered, and Sensitive Plants and Animals, Section 2670 establishes objectives and procedures for managing and protecting threatened, endangered, and sensitive species. In summary, the policy includes: • Review, through the biological evaluation process, actions and programs to determine their potential for effect on threatened and endangered species, species proposed for listing, and sensitive species. • Avoid all adverse impacts on threatened and endangered species and their habitats, except when it is possible to compensate adverse effects totally through alternatives identified in a biological opinion; when an exemption has been granted under the act; or when the biological opinion recognizes an incidental taking. Avoid adverse impacts on species proposed for listing during the conference period and while their federal status is being determined. • Initiate consultation or conference with the Fish and Wildlife Service or National Oceanic and Atmospheric Administration Fisheries when the Forest Service determines that proposed activities may have an effect on threatened or endangered species; are likely to jeopardize the continued existence of a proposed species; or result in the destruction or adverse modification of critical or proposed critical habitat. • Identify and prescribe measures to prevent adverse modification or destruction of critical habitat and other habitats essential for the conservation of endangered, threatened, and proposed species. Protect individual organisms or populations from harm or harassment as appropriate. • Avoid or minimize impacts to sensitive species whose viability has been identified as a concern. • Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole.

Lewis and Clark Forest Plan

Forest Plan Management Standard C-1 – Wildlife Coordination and Habitat Management 5. Require a big-game cover analysis of projects involving significant vegetative removal to ensure that effective hiding cover is maintained. 11. Use the Interagency Rocky Mountain Front Wildlife Monitoring/Evaluation Program Management Guidelines in the management of land-use activities.

Forest Plan Management Standard C-2 – Threatened and Endangered Species 1. Comply with the Endangered Species Act, other related laws, executive orders, Forest Service Manual direction, National Forest Management Act implementing regulations, etc. 2. Conduct a biological evaluation of each activity to determine if the activity may affect Threatened and Endangered species. 3. Identify and evaluate cumulative effects as part of each biological evaluation.

7. In occupied grizzly bear habitat comply with the management direction based on Management situation as described fully in Appendix K of the Forest Plan (USDA Forest Service 1986).

Forest Plan Management Standard C-4 – Wildlife Trees 1 – 11.: The recommended level of hard snags in the Elk Smith project area are 158 snags per 100-acres with a 10-inch diameter-at-breast-height minimum in Douglas-fir/ponderosa pine timber types and 72 snags per 100-acres with a 10-inch diameter-at-breast-height minimum in lodgepole pine timber types. Wildlife trees should be adjacent to natural openings and water, clustered in important habitat, and larger diameter trees should be retained where possible. Keep down trees for wildlife feeding sites. The plan also identifies Management Areas, and provides direction for each. Management area goals are summarized below along with applicable management direction relative to wildlife.

Table 3: Applicable Lewis & Clark National Forest Management Areas – Wildlife. Management Area Acres Management Goals/ Management Direction Provide sustained high level of forage for livestock and big game animals. Maintain important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing area, Management Area E 2,748 migration routes, elk summer range, raptor nesting sites, and significant non-game habitat values. Coordinate prescribed burning and revegetation projects with range management. Jointly financed projects should be considered where feasible. Priority for funding is high. Maintain and protect Forest resources with minimal investment. Maintain important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing areas, Management Area G 17,018 migration routes, elk summer range, raptor nesting sites, and significant non-game habitat values. Improve habitat by prescribed burning and planting desirable forage on disturbed sites. Priority for funding will be low. Provide winter recreation opportunities supported by public and private developments while maintaining other resource values. Management Area H 597 Minimize impacts on important identified wildlife habitat. Important identified habitat includes Threatened and Endangered habitat, big- game winter ranges, calving or lambing areas, migration routes, and elk summer ranges. Protect, maintain, and improve resource quality while providing timber at a low-intensity level to meet local needs. Manage forage for livestock at a moderate-intensity level. Management Area O 3,431 Maintain or enhance important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer ranges, raptor nesting sites, and significant non-game habitat. Manage these areas to protect their wilderness values. Manage with limited investment in range management and trail construction. Management Area Q 426 Maintain or enhance important identified wildlife habitat, including Threatened and/or Endangered habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer-fall range, raptor nesting sites, and significant non-game habitat values.

Management Area Acres Management Goals/ Management Direction Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian area dependent resources. Timber and range management activities are permitted. Not Maintain or enhance important identified wildlife and fish habitat. Management Area R applicable Important identified habitat includes Threatened and Endangered species habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer-fall ranges, raptor nesting sites, spawning areas, and significant non-game habitat values. Uneven- aged harvest systems will provide for stream shading, bank stability protection, and a range of successional stages.

Inventoried Roadless

Forest Service Direction

Forest Service Handbook 1909.12– Land Management Planning, Chapter 70– Wilderness Evaluation, (72.1 – Evaluation of Wilderness Characteristics) Provides definitions for the wilderness attributes of inventoried roadless areas to comprehensively evaluate, pursuant to criteria set forth in the Wilderness Act of 1964, the wilderness characteristics of each area identified during the inventory process outlined in section 71.

Forest Service Manual 2300 – Recreation, Wilderness and Related Resource Management Guides management of recreation and wilderness resources on National Forest System lands.

Roadless Rule, 2001 Regional Foresters will review the following activities: a) Any necessary timber cutting or removal or any road construction or road reconstruction in emergency situations involving wildfire suppression, search and rescue operations, or other imminent threats to public health and safety in inventoried roadless areas. b) Timber cutting, sale, or removal in inventoried roadless areas incidental to the implementation of an existing special use authorization. Road construction or road reconstruction is not authorized through this re-delegation without further project specific review. c) The cutting, sale, or removal of generally small diameter timber when needed for one of the following purposes: 1. To improve threatened, endangered, proposed, or sensitive species habitat; 2. To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period; or, 3. For the administrative and personal use, as provided for in 36 Code of Federal Regulations 223, where personal use includes activities such as Christmas tree and

firewood cutting and where administrative use includes providing materials for activities such as construction of trails, footbridges, and fences.

Lewis and Clark Forest Plan

Management Standard D-4: Livestock Grazing Restrictions 4. Adhere to the livestock grazing restrictions for developed recreation areas (Management Area H) and wilderness (Management Area P), as outlined in the management area prescriptions.

Management Area Direction Management Area goals are summarized below along with applicable management direction relative to inventoried roadless areas. Table 4: Applicable Lewis & Clark National Forest Management Areas – Inventoried Roadless Areas. Management Area Acres Management Goals/ Management Direction Recreation – Setting: Recreation setting is mostly roaded natural. Interaction between users may be low to moderate with evidence of Management Area E 2,748 other users. Resource activities will be evident, but will blend with the natural environment. Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to Management Area H 597 moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high. Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to Management Area O 3,431 moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high.

Visuals

Federal Laws and Regulations

Code of Federal Regulations 219.21 – Recreation Resource The visual or scenery resource is regulated by Code of Federal Regulations 219.21 (f), which states, “The visual resource shall be inventoried, and evaluated as an integrated part of evaluating alternatives… [for] both the landscape’s visual attractiveness and the public’s visual expectation. Management prescriptions …shall include visual quality objectives.”

Forest Service Direction In 1986, when the Lewis and Clark National Forest Plan was adopted, the visual resource was inventoried and analyzed using the original Visual Resource Management System as outlined in Forest

Service Handbook 462, National Forest Landscape Management System, Volume 2, Chapter 1. This system, which was released in 1974, established standards of measurement (Visual Quality Objectives) for assessing proposed and existing impacts to the scenic quality. In 1994, after 20 years of experience with the Visual Resource Management System and after additional research in the public and private sectors, the Forest Service revised the Visual Resource Management System and replaced it with the Scenery Management System. This revised system is described in Agricultural Handbook 701, Landscape Aesthetics: A Handbook for Scenery Management. Scenery Management System will not be implemented until the Lewis and Clark National Forest Plan is revised. Both the Visual Resource Management System and the Visual Resource Management System will provide guidance for the effects analysis of the scenery (visuals) resource in the Elk Smith Fuels project area.

Lewis and Clark Forest Plan The Lewis and Clark National Forest Plan provides overall direction for visual quality (scenery) on the forest. Forestwide Management Standard A-8 states that “Landscape management principles will be applied to all activities on the Forest. This will be accomplished by implementing the procedures defined in National Forest Landscape Management, Volume 2, Chapter I, of The Visual Management System (Agricultural Handbook No. 462)” (page 2-28). The Forest Plan also “states a Visual Quality Objective for each management area. These Visual Quality Objectives provide the guideline for altering the landscape” (page 2-28). Proposed units are located within lands allocated to Management Areas E, G, H, O, Q and R. Guidelines for meeting Visual Quality Objectives are described in Forest Service Handbook 462, National Forest Landscape Management, Volume 2. Table 5: Applicable Lewis & Clark National Forest Management Area – Visuals. Management Area Acres Visual Quality Objective Management Area E 2,748 Partial Retention Management Area G 17,018 Retention or Partial Retention Management Area H 597 Retention or Partial Retention Management Area O 3,431 Retention or Partial Retention Management Area Q 426 Preservation Not Management Area R Not Applicable Applicable

Environmental Justice Examination of community composition, as required under Executive Order 12898, found no minority or low income communities or groups to be disproportionately affected under any of the vegetation alternatives.

Decision Framework This assessment discloses the environmental consequences of implementing No Action and the Proposed Action alternatives. The Deciding Official reviews the anticipated consequences of the alternatives to determine whether the action may have a significant effect on the quality of the human environment (FSH 1909.15, Chapter 40, Part 43.1). If the Deciding Official determines that the Selected Alternative may have a significant effect on the quality of the human environment, an environmental impact statement would need to be prepared. If not, then the Deciding Official would evaluate and choose a project alternative based on the following criteria: • The extent that the alternative addresses the purpose and need for action; • Consistency with the goals and finding of Forest policy, including standards, goals, and objectives of the Forest Plan and legal mandates; • How an alternative addresses environmental issues and concerns identified by the public, other resource management agencies, and Forest Service resource specialists; and • Effects of the Proposed Action relative to the No Action alternatives. Details of the Deciding Official’s decision will be disclosed in the Draft Decision Notice and associated Finding of No Significant Impact. These will be distributed to the interested public and made available through the internet on the Helena-Lewis and Clark National Forest’s website: https://www.fs.usda.gov/projects/hlcnf/landmanagement/projects Public Involvement The Council on Environmental Quality defines scoping as “….an early and open process for determining the scope of issues to be addressed and for identifying the significant issues related to a proposed action” (40 CFR 1501.7). Scoping is to begin early and continues until a decision is made.

Elk Smith Project Public Involvement Summary Scoping was initiated on August 14, 2013. Scoping letters were sent to 106 individuals, organizations, agencies, and the connected Tribes. The legal notice was published in the Great Falls Tribune concurrently with the scoping letter. Twelve comment letters were received. Due to changing priorities on the Forest, the Elk Smith Project was put on hold and reinitiated in 2016. Scoping was not reinitiated. However, on April 28, 2016, a notice was published in the Great Falls Tribune inviting members of the public to an open house. On May 6, 2016, the Rocky Mountain Ranger District hosted a public open house to reintroduce and discuss details of the Elk Smith Project. A Preliminary Analysis Environmental Assessment was released for public comment in August of 2016. With this release a legal notice was published in the Great Falls Tribune on August 30, 2016. Nine comment letters were received at that time and those comments were considered in the analysis. However, due to the shifting priorities on the Forest the Elk Smith Project was once again put on hold, until July of 2018, when the Rocky Mountain Ranger District reinitiated the Elk Smith Project.

In April of 2019, the Elk Smith Project Environmental Assessment and draft Decision Notice were released to the public, initiating a 45-day objection period. Two objections were received on the Elk Smith Project. Issues brought forward by the objectors were reviewed by an objection review panel and an objection reviewing officer. Findings were documented in formal letters and sent to the objectors in July of 2019. The Elk Smith project was listed in the Helena-Lewis and Clark NF Schedule of Proposed Actions website and publicly distributed since March 2016 through quarterly reports. Information about the project (e.g., scoping letter, Preliminary Analysis Environmental Assessment, and maps) is posted on the Helena- Lewis and Clark NF Plans and Projects webpage. The Elk Smith Decision Notice was signed in November of 2019. In addition, the Final Environmental Assessment, and the associated Finding of No Significant Impact, were released to the public at the same time. In June of 2020, the original Decision was withdrawn and supplemental analysis was initiated. Key Issues In response to scoping, the Forest received 12 comments from the public. In response to the Preliminary Effects Analysis environmental assessment, nine comments were received. Comments received concerned the effectiveness of prescribed fire; effects of prescribed fire on water yield, specifically, in the downstream irrigation districts; project effects to inventoried roadless areas; control of prescribed fire implementation; control of noxious weeds post burn; effects to soils (including meeting Region One soil quality standards); project effects to management indicator species and their habitats (including effects to goshawk and old growth, and snag-dependent species), and threatened, endangered and sensitive species (including effects to grizzly bear, lynx and their habitats); effects of the project on climate change; and vegetation prescriptions. Responses to specific comments and to the literature provided by the public are contained in appendix F.

Prescribed Burning

Burning prescriptions are Chapter 2 – Alternatives developed based on vegetative conditions, fuels No Action present and objectives. There Under the no action alternative, existing management activities and are several terms used to natural processes would continue within the project area. Standard describe prescribed burning protection and maintenance activities would continue such as fire techniques. The Elk Smith suppression, access management, and road maintenance. Ecosystem Project would mostly consist processes such as impacts from insects and diseases in trees would of broadcast burning and continue their current trends. Safety concerns would escalate. The jackpot burning. These terms No Action Alternative provides a baseline for comparison of are defined below. environmental benefits and consequences of the proposed action to the existing condition. Broadcast burning is the intentional burning of debris on a designated unit of land, Proposed Action where the fuel has not been Under the Proposed Action Alternative, prescribed fire treatments piled or windrowed, by developed to address fuel accumulation and continuity in the project allowing fire to spread freely area would be implemented. Treatments would occur in 15 units over entire area. identified within the project area. These units combine to cover an Jackpot burning is used to area of 10,329 acres. Over portions of selected units, small conifers reduce fire hazard in areas would be felled to provide adequate surface fuels to carry prescribed where heavy fuel fire, promote aspen regeneration, and maintain natural openings. concentrations exist but are Prescribed fire would be introduced across all 15 treatment units. not continuous enough for a However, only 30 percent to 50 percent of the unit would see stand broadcast fire to carry through replacement mortality within the seedling and saplings trees. This the fuels, and where piling stand replacement mortality would generally occur in patches of 20 would be impractical. to 100 acres. The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is approximately 866,330 acres and is managed by three National Forests (Flathead, Helena-Lewis and Clark, and Lolo NFs). The Elk Smith Project boundary is composed of 24,220 acres of the 395,440-acre portion of the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area managed by the Helena-Lewis and Clark National Forest (US Forest Service, 1986). Under the proposed action 10,329 acres are proposed for treatment, all of which would fall within the inventoried roadless area boundary. Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events. Access for treatments would be accomplished utilizing existing routes, no new road construction or reconstruction would be completed. No commercial harvest is being proposed.

A map of Elk Smith treatment units is located in Appendix A. A detailed table including treatment units, size and proposed treatment methods is located in Appendix B. Treatments would be staggered across time and space in order to meet project goals. Implementation would be begin in 2021 and would span five to 10 years. All treatments would be dependent on design features and resource protection measures to minimize impacts. In general, units which border private lands would be prioritized for implementation.

Design Features Project Design Features were developed to avoid or reduce potential adverse environmental impacts, as well as to respond to concerns expressed during the public comment process. These project design features are an integral part of the proposed project and are considered required for implementation.

Vegetation 1. Implementation of hand ignition units would avoid ignition within areas characterized by sparse stocking or poor seedling establishment. 2. Avoid ignition within mature (greater than eight-inches diameter-at-breast-height) conifer stands more than five acres in size.

Range 3. Coordinate all burning or other activities that could affect active grazing allotments with district range specialist and affected grazing permittees.

Noxious Weeds 4. Follow Prevention and Control Measures for noxious weeds as found in Forest Service Manual 2000 Supplement R-1 2000-2001-1, Sec 2081.2. Implement preventative management measures as referenced by Forest Service Manual 2000 including post-disturbance seeding with desirable species (Appendix C of this document). 5. Adhere to mitigation requirements as listed in the Record of Decision for the Lewis & Clark National Forest Noxious Weed Control Record of Decision (1994, page 5 and in Appendix C of this document). 6. Remove all mud, dirt, and plant parts from all equipment before moving into project area. Cleaning must occur off National Forest System lands. This does not apply to service vehicles that will stay on the roadway and travel frequently in and out of the project area. 7. Revegetate all mechanically-disturbed soil, except the travel way on surfaced roads, in a manner that optimizes plant establishment for that specific site unless ongoing disturbance at the site would prevent weed establishment. Forest Service Handbook would be followed for revegetation. 8. All crews would inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment. 9. Establish travel routes for people and equipment to and from project units and treat noxious weeds along these routes before work commences.

Soils 10. Prescribed burning would be conducted when forest floor and soils are moist (20 percent water content or greater) to reduce soil heating and associated nutrient losses. 11. Retain adequate ground cover such that less than 15 percent of the unit contains exposed mineral soil following treatment. 12. Avoid burning on slopes steeper than 50 percent, particularly steep slopes adjacent to drainages. 13. Retain a minimum of 10-tons-per-acre of coarse woody material (greater than four-inch diameter) following treatments. Coarse woody debris requirements do not apply to grasslands or shrub lands since they do not have the natural potential to generate five tons per acre. 14. Though they are rare in the project area, when encountered, direct ignition would not occur on soils with wetland characteristics.

Hydrology/Fisheries All National Forest Service best management practices for prescribed fire in aquatic management zones would be followed, specifically National Best Management Practices for Water Quality Management on National Forest System Lands, FS-990a, April 2012, Volume 1: National Core Best Management Practices Technical Guide, Section Fire-2. Use of Prescribed Fire, pages 54 – 56. Specifically the following: 15. Locate access and staging areas outside of the aquatic management zones and wetlands. 16. Construct fireline to the minimum size and standard necessary to contain the prescribed fire and meet overall project objectives. 17. Locate and construct fireline in a manner that minimizes erosion and runoff from directly entering water bodies by considering site slope and soil conditions, and using and maintaining suitable water and erosion control measures (waterbars). 18. Rehabilitate or otherwise stabilize fireline and staging areas in areas that pose a risk to water quality. 19. Control actions in the aquatic management zones as needed to maintain ecosystem structure, function and processes and onsite and downstream water quality. 20. Keep high-intensity fire out of aquatic management zones to avoid or minimize adverse effects to water quality by observing the following non-ignition buffers on streams and wetlands within the project area: a. 200-foot no-ignition buffers on all streams to preserve riparian vegetation and maintain a vegetated buffer to prevent erosion upslope from entering water bodies. b. If prescribed fire is necessary to meet objectives within the 200-foot non-ignition buffer, specific burn locations would need to be coordinated with the Forest Hydrologist to ensure that additional resource protection measures are in place to protect water quality. c. No-ignition buffers on steep slopes (greater than 50 percent) on slopes above streams that could contribute to sediment delivery in streams. d. When wetlands or springs exist within treatment units, active lighting should only occur outside of the wetland boundary to prevent trampling of wetland soils and fuel spills near surface water. The 50 (less than 35 percent slope) to 100-foot

(greater than 35 percent slope) no-ignition buffer would be implemented to protect surface water within wetlands from sediment delivery. 21. The project should be implemented under adherence to the Montana Stream Management Zone law. 22. Project-area road segments with sediment delivery points immediately into waters should be repaired using appropriate mitigation measures. 23. Hauling and other heavy-equipment traffic should not occur during conditions where the road surface is at or near saturation to prevent forming ruts in roads which should be in best management practices compliant conditions. 24. Removal or damage to non-hazard vegetation should be minimized within stream management zones. 25. Operation of equipment within non- stream management zone wetlands would not occur. 26. During all phases of the project, equipment should not disturb the ground surface in road- drainage run-out areas near streams (i.e. the area where a ditch-relief culvert or road drainage dip diverts water to the forest floor). 27. The Watershed and Fisheries staff should be consulted on any culvert replacements on fish bearing streams to ensure proper aquatic organism passage. 28. Minimize cleaning of vegetated ditches that are still functional and are located near streams. 29. Any skid trails should be reclaimed as part of the implementation of this project. 30. All wetlands, seeps and springs should be identified and marked during project implementation, and should be protected in accordance with Inland Native Fish Strategy or Montana Stream Management Zones law. 31. Areas cleared of vegetation by maintenance or other activities should be seeded with an approved weed-free seed mix. 32. Sediment filtering devices (e.g., filter fence and weed-free straw bales) should be used as needed to limit erosion and delivery of disturbed material into streams or ephemeral drainages. 33. Monitor operations (Watershed/Fisheries staff) to ensure proper application and effectiveness of best management practices. 34. The leave trees in stream management zones should come from the largest trees in the treatment areas which do not threaten a protected target, hazardous trees can be felled towards the stream, when safety allows, and left in stream management zone areas if removal without mechanized entry is not possible. 35. Avoid or minimize the use of glyphosate based herbicides near wet areas to prevent exposure to amphibians. 36. Adhere to the noxious weed mitigation and resource protection measures.

Recreation 37. Implementation would include a public notification plan with consideration given to implementation timing and recreational uses such as hunting season.

38. Implementation would be coordinated with the Forest Public Affairs Officer and Law Enforcement to ensure the public is well informed of the schedule and its potential impacts.

Heritage 39. To meet requirements of the National Historic Preservation Act (Section 106), field surveys would comply with the Prescribed Fire Appendix of the 2015 Heritage Resources Programmatic Agreement. Required consultation with the Montana State Historic Preservation Office has started and they concurred with our plan for project area surveys and site avoidance. 40. If a previously identified historic property is inadvertently affected during project activity, the project work would cease in that location, a site-damage assessment would be prepared, and Montana State Historic Preservation Office and tribes would be informed. The investigation report and damage repair agreement would be finalized prior to finishing that site’s activities. 41. If unidentified archaeology sites or human burials are discovered during implementation, work would cease in that area and the Forest Archaeologist would be notified. Required legal processes would be invoked.

Wildlife

Grizzly Bear 42. To limit disturbance to bears in spring habitat in Management Situation 1 areas: a) Slashing activities in units 1, 2, 7, 9, and 11 would occur after June 30 to minimize disturbance in spring grizzly bear habitat. b) Reconnaissance flight mid-morning to make sure public and livestock were clear of the area. c) Ignition beginning at 1200 hours or later with one or two helicopters; ending approximately at 1700 hours. d) Additional reconnaissance flight over next couple of hours to monitor. e) Possibility of aviation resources used to control fire within unit boundaries for an additional zero to five days. 43. To prevent bears becoming food-conditioned and to minimize the risk of bear-human encounters and maximize both human and bear safety: a. All personnel involved in project implementation would adhere to the Special Food Storage Order LC_10_D1_01 (or any successor orders) at all times.

Northern Goshawk 44. Disturbance to nesting goshawks can be reduced by limiting project slashing activities between April 15 and August 15 within ¼ mile of known active goshawk nests. A map of known goshawk nests would be provided during implementation planning meetings, to fire personnel creating burn plans, and/or to appropriate crew leader(s) prior to implementation in the relevant unit(s).

Amphibians and Aquatic Wildlife 45. To minimize the risk of introducing pathogens or aquatic invasive species: a. Any equipment used for potential fire control or suppression (including but not limited to helicopter buckets, helicopter snorkels, water pumps, hoses, etc.) would

be thoroughly cleaned according to Regional protocol prior to use anywhere on the Rocky Mountain Ranger District. b. Water for potential fire control or suppression would not be transported from one side of the Continental Divide for use on the other side, and where possible would be obtained from within the same drainage or watershed where it is to be used. c. The District Wildlife Biologist, Forest Fish Biologist, or Montana Fish, Wildlife and Parks Area Fisheries Biologist would be consulted regarding use of water dip sites.

Big Game Key Habitats 46. Slashing activities in Units 1 and 2 would occur after June 30 to minimize disturbance in big game calving/lambing/fawning range. 47. Spring burning would occur prior to green up to limit impacts to wildlife, including spring grizzly bear habitat and calving/fawning/lambing ranges. This applies to the targeted spring burning season in Units 1, 2, 7, 9, 11, and 15.

Resource Protection Measures Prior to implementation, each season, those responsible for executing the project would confer with key members of the interdisciplinary team including the wildlife biologist, the botanist, the range and weeds specialist, and the soils specialist, as well as the Montana Fish, Wildlife and Parks biologist to ensure that all relevant resource protection measures would be met. This would involve a detailed review of maps, a unit-by-unit discussion of proposed tactics, and a field review of any units where intention is unclear. Earliest implementation anticipated would be in 2021.

Fisheries Provide cooperative assistance to Montana Fish Wildlife and Parks in their efforts to assure persistence of westslope cutthroat trout in Maudess Creek.

Recreation Recreation facilities damaged by project activities would be repaired and rehabilitated.

Heritage 1. Forest Heritage Resources staff would inform the responsible official and project planners of known vulnerable sites in the general project area. Confidentiality of archaeological and cultural resource information will be maintained. For all projects that involve ground disturbances, known sites would be identified early in the planning stage. The responsible official and project planners would also be informed if sites are identified during project preparation and implementation. 2. Where significant or potentially significant sites are known, during the early planning stage the heritage specialist should try to identify potential undertakings that could benefit site preservation and fit within overall project goals. 3. Undertakings would be planned or modified so they don’t adversely affect significant or unevaluated cultural resources, if possible.

4. Identified significant or unevaluated sites would be avoided by reconfiguring project unit boundaries to exclude the site, or by site-specific pre-treatments (e.g. fuel thinning, blacklining), prior to implementation, to reduce effects. 5. Effects to ‘linear’ historic sites (e.g. trails) would be avoided or minimized by restoring pre- treatment contours or drainage features per Programmatic Protocol.

Wildlife

Grizzly Bear 1. To prevent bears becoming food-conditioned and to minimize the risk of bear-human encounters and maximize both human and bear safety: a. Persons involved in project implementation are encouraged to work in groups of two or more, and to carry bear spray.

Big Game 1. Prescribed fire managers should coordinate with the area Montana Fish Wildlife and Parks biologist when conducting Fall burning operations to minimize disturbance to rutting elk (September rut), as well as rutting sheep and mule deer (November rut).

Raptors 1. To reduce potential impacts to cliff-nesting raptors: a. Helicopter flight paths could be routed to more than one half mile away from active cliff nest sites. A map of active nest sites would be provided during implementation meetings, to fire personnel creating burn plans, and/or to helicopter managers or other appropriate personnel prior for implementation.

Monitoring • Fisheries, hydrology, and range specialists would jointly perform post-implementation monitoring to determine if the limited felling of trees or installation of jackleg structures beneficially dissuade cattle access to streamside bench areas in lower sections of Maudess Creek and Jakie Creek, tributaries of Smith Creek. • Monitor treatment units for First Order and Second Order Fire Effects. This would include the establishment of photo-points in treatment units and controls prior to implementing the Proposed Actions. Photos at established points also would be taken, and interpreted, following prescribed fire implementation. Appropriate photo-points could be revisited following an unforeseen disturbance event in the Project Area. Monitoring of Second Order Fire Effects should be conducted by revisiting, and interpreting, photo-points approximately 15 to 20 years following completion of the project, or at any time the efficacy of treatments comes into question. • The Bailey Basin goshawk territory and any newly discovered territories within ¼ mile of treatment units would be surveyed for occupancy during the nesting season immediately prior

to implementation and for up to five years following treatment or according to Forest Plan monitoring requirements. • Known cliff nest sites within ½ mile of project activities, including helicopter flight paths, would be surveyed for current occupancy during the nesting season immediately prior to implementation activities and, for those sites within treatment units, for up to five years following treatment. • Post implementation monitoring would be conducted by the Range Specialist and Soil Scientist to determine deferment needs. • Project area would be monitored for three consecutive years and would control newly established populations of noxious weeds in accordance with Forest Service Manual 2000 Supplement R1 2000-2001-1, National Best Management Practices Forest Service Manual 2532, and Forest Service Handbook 2509.19. Follow-up treatments for previously treated infestations would be implemented. Monitoring would begin in the spring following treatment. • Monitoring for soil and water resources in compliance with Forest Plan Standards (Management Standards F-1 through F-4). • Roadless Area monitoring would consist of visually surveying units treated with prescribed fire to determine if illegal off-highway vehicle use is taking place in treated areas. If monitoring reveals this is happening, steps would be taken to eliminate the use (i.e. signing, barrier installation, increased law enforcement).

Chapter 3 – Existing Condition and Environmental Consequences Fire, Fuels, and Air Quality

Technical Terms The following technical terms are used in the body of this report. Definitions of these technical terms are provided, below, for clarity. Broadcast Burning—The intentional burning of debris on a designated unit of land, where the fuel has not been piled or windrowed, by allowing fire to spread freely over the entire area. Jackpot Burning—Intentional burning used to reduce fire hazard in areas where heavy fuel concentration exists but are not continuous enough for a broadcast fire to carry through the fuels, and where piling would be impractical. Crown Fire--The movement of fire through the crowns of trees or shrubs. Active Crown Fire--A crown fire in which the entire fuel complex becomes active crown fire involved, but the crowning phase remains dependent on heat released from the surface fuels for continued spread. Passive Crown Fire--A crown fire in which individual or small groups of trees torch out, but solid flaming in the canopy cannot be maintained except for short periods. Fireline Intensity—The product of the available heat of combustion per unit of ground and the rate of spread of the fire, interpreted as the heat released per unit of time for each unit length of fire edge. The primary unit is British thermal unit per second per foot of fire front. Flame Length--The distance between the flame tip and the midpoint of the flame depth at the base of the flame (generally the ground surface), an indicator of fire intensity. First Order Fire Effects--The effects that concern the direct or immediate consequences of fire, such as biomass consumption, crown scorch, bole damage, and smoke production. First order effects form an important basis for predicting secondary effects. Second Order Fire Effects--The secondary effects of fire such as tree regeneration, plant succession, and changes in site-productivity. Although second order fire effects are dependent, in part, on first order fire effects, they also involve interaction with many other non-fire variables. Fire Interval – The time between fires in a defined area, usually at the scale of a point, stand, or relatively small landscape area (Sommers et al., 2009). Fire Rotation – The average number of years required in nature to burn over and reproduce an area equal to the total surface of the area under consideration (Heinselman, 1973).

Fire Regime – A fire regime describes the nature of fires occurring over an extended period of time and is often described in terms of the rotation, frequency, severity, intensity, shape, and size typical of fires in a specific geographic area. As such, fire regimes provide context for the historical fire in that location (adapted from Teske, 2012). Fire Severity-- refers to the effects of a fire on the environment, typically focusing on the loss of vegetation both above ground and below ground but also including soil impacts. Historical Range of Variability – The ecological conditions, and the spatial and temporal variation in these conditions, that are relatively unaffected by people, within a period of time and geographical area (Landres, et al., 1999). Reburn—Indicates when a fire burns onto a previously burned landscape. Usually within a relatively short time of 30-50 years. For the Northern Continental Divide Ecosystem, fires recurring on another fire that burned after 1987 are considered reburns. Multiple overlaps of burning within the perimeter of a fire that burned in an area without recent fire history are sometimes referred to as second-entry, third-entry, and fourth-entry fire. The initial fire may be referred to as first, or initial, entry. Additional terms may refer to this phenomenon, including fire overlap and fire overlay.

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project area. In this report, the analysis of effects focuses on the Project Area, but a broader area is also included in the analysis of cumulative effects and provides a more useful spatial scale for fire history. In terms of cumulative effects, the fire- fuels analysis includes a larger area defined by two subunits of larger Bear Management Units. These subunits are the South Fork Willow subunit of the South Fork Sun Beaver Willow Bear Management Unit and the Scapegoat subunit of the Dearborn Elk Creek Bear Management Unit. A cumulative effects table of past, present, and reasonably foreseeable activities may be found in the Supplemental Environmental Assessment, Appendix D. In terms of temporal scale, the analysis is limited by the historic record. For example, specific fire- perimeter data for wildfires extends back to about 1910. Similarly, logging and thinning activities prior to the 1970s were not well-documented (Supplemental Environmental Assessment, Appendix D). However, scientific research extends our understanding of ecological processes shaping the landscape over a much longer period. Methodologies for these studies vary. For example, Gruell used photographs taken between 1871 and 1982 to interpret fire and vegetation trends, as well as journals dating back to the 18th Century (Gruell, 1983; 1985). Gabriel utilized historic records and dendrochronology to establish fire history as far back as 1749 for an area immediately to the west of the Project Area (Gabriel, 1976). Teske worked with remotely sensed data products derived from Landsat sensors to study large wildfire interactions in the recent past, while Naficy used dendroecological data and photogrammetric mapping to understand the dynamics of mixed fire regimes over a long period: from the year 1600 to present (Teske, 2012; Naficy, 2016).

Understanding fire regime characteristics for the project area required context and consideration of fire interactions on a larger landscape. At 24,220 acres, the entire Elk Smith Project Area is smaller than numerous large fires that have occurred on the Rocky Mountain Ranger District in recent years. The area covered by the project only represents about 12% of the entire area within the perimeter of the 1988 Canyon Creek fire. Studies and surveys have often considered fire regime characteristics and attributes at different scales. For example, Ayres surveyed the Lewis and Clark Forest Reserve in 1899 (Ayres, 1900). This landscape covers most of what is currently understood as the Northern Continental Divide Ecosystem, covering an area of approximately 5.5 million acres, and represents a portion of the larger Crown of the Continent Ecosystem. Parks et al. study of wildfire limits on subsequent fire was executed at the scale of the Crown of the Continent Ecosystem (2016). In contrast, some studies have been focused on smaller landscapes within the Northern Continental Divide Ecosystem and Crown of the Continent Ecosystem. For example, Gabriel’s work was defined by the Danaher Basin watershed boundaries, an area covering over 80,000 acres. In this report, we have also considered fire history at the scale of the Rocky Mountain Ranger District and at the scale of the Bob Marshall Wilderness Complex: Scapegoat, Bob Marshall, and Great Bear Wilderness Areas. The Rocky Mountain South National Forest Management Act Analysis, 2010, considered fire history and regimes for the southern half of the Rocky Mountain Ranger District. Modelling of the existing condition, and of the effects of proposed actions, was completed at the spatial scale of the Elk Smith Project Area. Fire history was also considered specifically for the Project Area, utilizing a somewhat larger landscape to include fire history on the adjacent landscape. Two Bear Management Unit subunits were used to display and analyze this fire history: The South Fork Willow subunit of the South Fork Sun Beaver Willow Bear Management Unit, and the Scapegoat subunit of the Dearborn Elk Creek Bear Management Unit. Records of fire perimeters, both from prescribed fire and wildfire, are available from 1910 through the present, while “fire start” data are available from 1940 to the present. Since 1940, 113 fire starts have been recorded in the South Fork Willow and Scapegoat subunits. These starts resulted in fires that reached burned-area perimeters ranging from 1/10th of an acre to 17,324 acres (only acres burned within the subunits included). The primary cause of fire ignitions in these subunits was lightning. Of the total 113 starts, 80 were initiated by lightning, with the remaining 33 being human caused (for more detail see Project Record, Fire Start Data). Fire perimeters in the two subunits are displayed on a map in the Project Record (see Supporting Documentation, Maps). In modelling the Existing Condition and the Proposed Action, emphasis was placed on short-term effects. Short-term effects are synonymous with the fire management term “First Order Fire Effects.” It follows that, for the purposes of this analysis, long-term effects are synonymous with Second Order Fire Effects (National Wildfire Coordinating Group, 2008). Because Second Order Fire Effects involve interactions with non-fire variables, they become increasingly difficult to predict with the passage of time. As with past activities, projecting the impact of the No Action Alternative against that of the Proposed Action relied on a body of scientific research, as well as vegetation modelling (see Environmental Assessment, Forest Vegetation Report).

Carbon and Greenhouse Gas Emissions Section Disclaimer: The Carbon data and trends are based on fire years 1990 to 2011. While there have been additional fires within the spatial area since 2011, the general trend remains the same. Note: Rounding Differences. Due to rounding differences in treatment acres, there may be differences of 2 to 3 acres between the Supplemental EA/Draft Decision Notice and the Resource Reports.

Sources, Methods, and Assumptions The analysis included in this Fire, Fuels, and Air Quality report is based on a review of studies, professional papers, journal articles, webinars, and books. The Fire and Fuels section of the Rocky Mountain Ranger District National Forest Management Act Analysis, 2010—used in conjunction with the documents in the “Literature Cited” section—provided a starting point for this literature review. Literature referenced to inform this analysis is included in the Literature Cited section provided at the end of this report, and in Supporting Documents included in the project record. In writing the Fire, Fuels, and Air Quality report, the greatest weight, in terms of accuracy and reliability was given to studies that included, or were in proximity, to the Elk Smith Project Area. In the cases where these studies were completed as part of a dissertation (when available), they were augmented by related peer-reviewed journal articles. These highly relevant studies include Ayres, 1901; Gabriel, 1976; Gruell, 1983; Lotan, 1985; Teske, 2012; Naficy, 2016, and Parks, 2016. In terms of fire regimes, specific geographic areas display variation within their defined boundaries. This variation is amplified when characterizing spatially separate geographic areas that reflect differences of the respective landscapes in terms of variation in vegetation, climate, elevation, topography, ignition sources, landscape use, patterns of wildfire ignition, and aspect to name a few. For this reason, studies that consider distant geographic areas, or characterize fire regimes broadly (e.g. for the entire Western United States), become increasingly difficult to assess in terms of relevance, accuracy, and reliability. The variation is such that even spatially close landscapes can exhibit unique fire regime characteristics. For example, Teske underscores variation in fire regimes in different geographies, highlighting differences in fire regimes identified for the Greater Bob Marshall Wilderness Area in Montana, the Selway-Bitteroot Wilderness in Idaho and Montana, and the Frank Church River of No Return Wilderness in Idaho, while Parks et al. emphasizes specific differences in fire effects between the Crown of the Continent Ecosystem and the Gila and Aldo Leopold Wilderness Areas (Parks et al, 2015; Teske et al., 2012). In some cases, relevance may be established if similarities between the study area and the project landscape can be established or, in the case of works covering extensive geographies, careful consideration is given to unique characteristics of individual ecosystems within the broad area of consideration. Finally, syntheses and works covering broad subject matters and geographic area can be useful in understanding general concepts and topics. In addition to literature, fuel modelling was employed to characterize the existing condition of the Project Area, as well as to evaluate the short and long-term impact to fuels of both the No Action and Action Alternatives. For fuel modelling, LANDFIRE fuel data was used in conjunction with FlamMap. LANDFIRE fuel data describe the composition and characteristics of surface and canopy fuel and provide a necessary input for running fire behavior models. To accurately portray fuels in the Project Area, LANDFIRE data was modified utilizing regional vegetation data (Region 1 Vegetation Map), and data

obtained from the Red Shale Fire of 2013—a fire that burned in the vicinity of the Project Area and in similar fuels (see Hollingsworth, 2015). After carefully modelling fuels, analysts used FlamMap to evaluate potential fire behavior in the Project Area. FlamMap is a fire behavior mapping and analysis program that computes potential fire behavior characteristics, such as flame length, crown fire activity, and fireline intensity. Environmental conditions remain constant in FlamMap; the program uses spatial information on topography and fuels to calculate fire behavior characteristics for a single set of environmental conditions. The program was used to evaluate both the Existing Condition and Proposed Action in terms of fuels and potential fire behavior. Due to the complexity of FlamMap, the author of this report requested technical assistance and expertise from the Rocky Mountain Research Station Fire Modeling Institute. Fire Behavior Specialist LaWen Hollingsworth from the Rocky Mountain Research Station Fire Modeling Institute and Helena- Lewis and Clark Forest Fuels Specialist Jonathan Olsen provided valuable assistance in calibrating LANDFIRE data and in running FlamMap.

Purpose Statement Broadly speaking, the purpose of the Elk Smith Project is to address fuel accumulation and continuity in the Project Area. More specifically, the purpose of the project is to: • Reduce the future risk of high-intensity, high-severity wildfire within the Project Area by interrupting the continuity of fuels, specifically continuous stands of lodgepole pine regeneration and heavy loadings of larger fuels; • Reduce the potential for wildfire to spread into the Benchmark corridor to the north and onto private land east of the National Forest boundary; • Create a more diverse landscape that is more resilient to fire by retaining mature areas, disrupting dense areas, and enhancing or re-creating grassland openings; and • Increase flexibility to allow lightning-caused wildfire to play its natural role in adjacent and nearby designated Scapegoat Wilderness.

Regulatory Framework The Elk Smith Project adheres to a well-defined regulatory framework in terms of Fire, Fuels, and Air Quality. The Elk Smith Creek Area was identified for management action by the Rocky Mountain Ranger District National Forest Management Act Analysis (USDA, Forest Service, 2010). Under the direction of the National Forest Management Act, 1976, the purpose of the National Forest Management Act Analysis was to go through a Plan-to-Project Analysis of this portion of the District “to assess focused ‘needs’ and identify possible activities for implementing the Lewis and Clark National Forest Plan on an identified area known as the Rocky Mountain South Analysis Area (USDA, Forest Service, 2010).” As noted in the Introduction to the Analysis, “Unlike the National Environmental Policy Act, a [National Forest Management Act] analysis has no specific procedural requirements and therefore is an open- ended process used to arrive at and later propose potential future projects or activities.” The Analysis was conducted by an Interdisciplinary Team and considered a wide range of topics and resources on the southern half of the Ranger District including landscape ecology, fire and fuels, threatened and

endangered species, management indicator species, special habitats, archaeology, and cultural resources. Near the conclusion of the analysis, the Interdisciplinary Team worked with Rocky Mountain Ranger District resource managers to develop management goals “that would reflect the needs of the analysis area and drive development of future potential proposed actions.” This effort resulted in two goals to focus future management actions. 1. Reduce the need to apply all or most of the available resources (i.e. personnel, equipment, and financial resources) to single large-scale fires or high profile fires throughout the [Rocky Mountain South Analysis Area] that could threaten recreation residences/summer homes, private lands, travel routes, administration sites, and cultural resources, without losing the ecological benefit of the fire. 2. Promote and improve ecological health and ecosystem stability and resiliency throughout the Rocky Mountain South Analysis Area After considering the results of the analysis, the Interdisciplinary Team provided a list of areas, including the Elk Smith area, as having the greatest need in terms of these two goals. The basis for identification of the Elk Smith area is indicated in the Rocky Mountain South National Forest Management Analysis report under the Fire and Fuels Section (pages 45-55). The subsection Analysis Recommendations for Future Proposed Action shows that the Elk Smith area was selected by the Interdisciplinary Team based on the risk fire in the area posed to both private and public infrastructure, private property (including homes), as well as roads that might be utilized during a fire for access and egress of Forest visitors, homeowners, ranchers, and fire personnel during a wildland fire event (pages 53-54). The subsection notes that in a majority of the Analysis Area, “[surface] and ladder fuels continue to develop and dead fuels continue to accumulate when there is no disturbance to reduce the amount of fuel in these stands furthering the difficulties with fire suppression and continuing to place firefighter and public safety at risk.” Another indication of the rationale for selecting the Elk Smith area is found in the subsection’s final paragraph: “Finally, areas that have burned within the last 25 years are excellent locations to take advantage of lower fuel loadings and other favorable fuel conditions to apply prescribed fire that will enhance the stand characteristics and provide areas that can act as buffers or barriers to fire spread.” In identifying the Elk Smith area, the Rocky Mountain South National Forest Management Act Interdisciplinary Team also responded to the Ranger District’s goal to “[p]romote and improve ecological health and ecosystem stability and resiliency throughout the [Rocky Mountain South Analysis Area].” For example, the National Forest Management Act analysis pointed out that not only are recently burned areas advantageous locations for prescribed fire that will modify subsequent fire behavior, but that these treatments would also enhance stand characteristics. Prescribed fire, according to the Analysis, “is a readily available management tool to achieve desired future conditions related to diversity, heterogeneity, and intactness.” In assessing a Desired Future Condition in terms of landscape ecology, the Interdisciplinary Team further emphasized utilizing prescribed fire to promote heterogeneity: “[P]romoting ecosystem resiliency in terms of fire may mean carrying out low to moderate intensity prescribed burns, which may reduce structural homogeneity of forest stands (including species composition, age class, density), restore grass and shrub lands, improve forage for livestock, and enhance habitat for wildlife (including grazers and fire-dependent species).” Following detailed analysis,

the Elk Smith area stood out to the Interdisciplinary Team as an ideal place to meet the twin goals of managing fire risk and promoting ecosystem heterogeneity and resilience. This project also adheres to the requirements of the National Environmental Policy Act. The Elk Smith Project Environmental Assessment meets National Environmental Policy Act requirements by comparing the impact of a “No Action Alternative” and an “Action Alternative.” In the case of this report, the impact of these two alternatives on Fire, Fuels, and Air Quality are quantified and compared. The Clean Air Act of July 1955 also regulates activities outlined in the Action Alternative of this project. This project will adhere to all implementation, reporting, and monitoring requirements inherent in following the Clean Air Act. Impacts of the No Action and Action Alternatives are analyzed in the Air Quality sub-section of this report. Guidance to effectively manage and evaluate smoke impacts can be found in PMS 484--Interagency Prescribed Fire Planning and Implementation Procedures Guide, 2014 and in PMS 420-2--Smoke Management Guide for Prescribed and Wildland Fire. All prescribed burning proposed in the Action Alternative would be subject to management and approval by the Montana/Idaho Airshed Group. Both the Rocky Mountain Ranger District National Forest Management Act Analysis and the Elk Smith Project Environmental Assessment are aligned with Forest Service Manual direction for Fire Management. Manual Direction offers the following vision to managers: “[To] safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire” (Forest Service Manual 5102). The first priority in all management actions is as follows: “Risk Management and Risk Reduction – Assure management of risk to people, communities and natural and cultural resources is the fundamental principle used to make informed decisions in all fire management programs. Minimize the risk to people, communities and natural and cultural resources by assessing the potential benefits of actions, severity of concerns and probabilities of occurrences to reduce risk.” (Forest Service Manual 5102) The Elk Smith Project Action Alternative is designed to meet this objective by reducing the volume and continuity of fuels in proximity to the National Forest boundary. These activities are intended to reduce risk to human health and safety, as well as to protect communities and resources. In addition, these treatments are intended to increase the efficiency and effectiveness of fire management actions or, in other words, improve their cost-effectiveness. In accordance with National Policy direction, the Action Alternative for the Elk Smith project was identified and developed utilizing management goals outlined in the Lewis and Clark National Forest Plan (1986). The management goals for all management areas included in the Elk Smith Project Area include the use of prescribed fire.

Table 6: Applicable Lewis and Clark National Forest Management Areas. Management Area Acres Management Goals (Prescribed Fire) Management Area E 2,748

Management Area G 17,018 (PS12a) Prescribed fire with planned ignitions will be used in this Management Area H 597 management area for the enhancement and maintenance of Management Area O 3,431 resources (see Appendix P of the LCNF Forest Plan) for specific Fire Management Direction). Not Management Area R applicable

The Healthy Forest Restoration Act of 2003 “incentivized communities to engage in comprehensive forest planning and project prioritization.” It also established statutory minimum requirements for the establishment of Community Wildfire Protection Plans. The Community Wildfire Protection Plan covering Lewis and Clark County is known as the Tri-County Regional Community Wildfire Protection Plan and was developed by the “Tri-County Fire Safe Working Group, a 501(c)3 organization whose partnerships includes individual citizens, local governments, state and federal agencies, interested contractors, and fire suppression departments from all three counties (Tri-County Community Wildfire Protection Plan, 2020).” A Community Wildfire Protection Plan was first adopted by Broadwater, Jefferson, and Lewis and Clark Counties in 2005. Since that time, the Tri-County Fire Safe Working Group has completed two updates of the Community Wildfire Protection Plan. The first update was released in 2015. The current update of the Tri-County Regional Wildfire Protection Plan was signed and released in July of 2020. According to the plan, the Tri-County Fire Safe Working Group should review and update the Community Wildfire Protection Plan every five years. Located entirely within Lewis and Clark County, the Elk Smith Project is covered by the Tri-County Regional Community Wildfire Protection Plan update of July 2020 (The Tri-County CWPP 2020 is found in the Project Record). Besides being guided by the Healthy Forest Restoration Act, development of the Tri-County Community Wildfire Protection Plan also followed direction provided by the Federal Land Assistance, Management, and Enhancement Act of 2009. The Act resulted in a national Cohesive Strategy with the following vision for the coming century: “To safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire.” (Wildland Fire Leadership Council, 2014).” In addition, the Cohesive Strategy identified three goals to fulfill that vision: “1) Restore and maintain landscapes, 2) Create fire-adapted communities, and 3) Implement safe, effective, efficient risk-based wildfire management decisions.” The Tri-County Community Wildfire Protection Plan includes a Regional Mitigation Plan (pages 36-37), with specific strategies to achieve the goals of the national Cohesive Strategy. The first strategy in the Regional Mitigation Plan is to “[s]upport and implement both condition specific and geographically specific fuel mitigation projects in the region to protect values at risk, create fire-adapted communities, restore and maintain landscapes, and reduce extreme fire behavior.” The plan includes six specific strategies in terms of fuels mitigation projects. The individual strategies and how they relate to the Elk Smith Project are included in a table in the Elk Smith Supplement’s supporting documentation, under Fuels.

Among the functions of the Tri-County Community Wildfire Protection Plan in meeting the Cohesive Strategy is designation of Wildland Urban Interface in Lewis and Clark, Jefferson, and Broadwater Counties. In terms of the Elk Smith Project Area, Wildland Urban Interface is defined by “A. An area extending at least 1 ½ (one and one-half) miles from any structure that is capable of human occupation; B. An area extending at least ¾ (three-quarters) of a mile on either side of the centerline of any ingress/egress (evacuation), route identified in jurisdictional Population Protection Plans.” In addition, “Boundary [Wildland Urban Interface] of National Forest land lying within 1 ½ miles of this eastern boundary [eastern boundary of Rocky Mountain Ranger District in Lewis and Clark County] has been identified to better protect human safety, privately owned livestock, forage, improvements and buildings directly affected by the condition of fuels within this 1 ½ mile boundary.” See Tri-County Regional Community Wildfire Protection Plan, 2020 update, for the full definition of local Wildland Urban Interface (pages 24-25) or Refer to Appendix A, Figure 8). The current Community Wildfire Protection Plan designation of Wildland Urban Interface includes a majority of the Elk Smith Project Area (see Supplement Wildland Urban Interface map). Of the 10,329 acres that are included in Project Units, 8,222 acres are located inside designated Wildland Urban Interface; 2,107 acres are located outside designated Wildland Urban Interface. The portions of the Project Unit falling outside Wildland Urban Interface are on the western side of the Project Area, between the designated Wildland Urban Interface and the north/south ridgeline of Steamboat Mountain which is also the eastern boundary of the Scapegoat Wilderness. Treatments on the Non-WUI portions of the Project are limited to prescribed fire treatment only; cutting of small diameter conifer will not occur outside of the designated Wildland Urban Interface. Units were identified prior to the current Wildland Urban Interface designation (Tri-County Community Wildfire Protection Plan, 2020 update) and were based on the continuity of fuels occurring on ridges that are oriented west to east from Steamboat Mountain, and run directly into the currently designated Wildland Urban Interface. It is important to note that the Tri-County Community Wildfire Protection Plan, 2020, supports mitigation projects, including the use of prescribed fire, both inside and outside of designated Wildland Urban Interface. Recognizing that fuels adjacent to the designated Wildland Urban Interface are likely to impact the Wildland Urban Interface itself, the Plan supports mitigation projects “across jurisdictional boundaries in areas that border the [Wildland Urban Interface] established by this [Community Wildfire Protection Plan] to reduce the risk of wildfire spreading into the [Wildland Urban Interface] and threatening values at risk.” Moreover, the Tri-County Wildfire Protection Plan recognizes the growing risk of fuels conditions resulting in recent wildfires across the Tri-Counties (e.g. the 1988 Canyon Creek fire): “It should be noted that generally, 30 years after a wildfire has occurred, an area may be ready to burn again. Ongoing maintenance of mitigation projects is critical to preserve life safety (page 43).” Finally, the Tri-County Wildfire Protection Plan recognizes the crucial role Wildland Fire for Resource Benefit can play in meeting the national Cohesive Strategy and recommends that “[w]here appropriate, and as fuel and weather conditions allow, land management agencies should manage natural wildfires for resource objectives (page 37).” The goal coincides with the Elk Smith Project’s Purpose to “Increase flexibility to allow lightning–caused wildfire to play its natural role in adjacent and nearby designated Scapegoat Wilderness.”

Existing Condition

Fire History The Elk and Smith Creek drainages are located on the Rocky Mountain Ranger District. The legal description for proposed activities is: Township 08 North, Range 01 West, Sections 4, 7-9, 16-21; Township 08 North, Range 02 West Sections 1, 2, 11-13; and Township 09 North, Range 02 West, Sections 25, 35, 36. Fire History on the Rocky Mountain Ranger District and in the greater Northern Continental Divide Ecosystem is essential to understanding the purpose and need of the Elk Smith Project. Excepting a tier at the Project Area’s northern border, and rocky features at Steamboat Mountain’s southern reaches, the entire Elk Smith Project Area is within the boundary of the much larger Canyon Creek Wildfire of 1988. Fire history for the Project Area and surrounding Forest lands is consistent with that of the Rocky Mountain Ranger District and the larger Northern Continental Divide Ecosystem in that lightning has ignited most fires in the area and is the primary cause of burned area. Unlike designated Wilderness Areas in the Complex, and additional approved areas, Wildland Fire Use for Resource Benefit is not authorized in the Project Area. Fire in, or approaching the area, is subject to fire suppression due to its proximity of homes, roads, trailheads, dispersed campsites, private lands, and infrastructure. Nevertheless, wildfire played a dramatic role in the ecology and fuels of the Elk and Smith Creek drainages when the 1988 Canyon Creek Fire spread from west to east across the current Project Area. The fire severely impacted ranches and communities to the east, burning “40,000 acres of private, State and Bureau of Land Management lands; approximately 200 miles of fence; 2000 tons of hay; 250+ head of cattle; several million board feet of timber; several ranch out buildings; 5 cabins and 1 garage” (USDA Forest Service, Report of Investigation, 1988). The fire also resulted in two separate fire shelter deployments that included burn injuries, but no fatalities, and multiple evacuations of residents (USDA Forest Service, Review Report, 1988). Though the fire remains the largest fire to have occurred in the Northern Continental Divide Ecosystem within the memory of any living person, its place in history is perhaps best understood in the context of fire history over the larger landscapes included on the Rocky Mountain Ranger District, the Northern Continental Divide Ecosystem, and the greater Crown of the Continent Ecosystem. Over the past 40 years, the Rocky Mountain Ranger District has experienced frequent wildfires on a landscape scale. Of the 780,000 acres of National Forest system land on the District, 299,000 acres (38%) have been included within the perimeter of a wildfire occurring from 1981 to the present. This contrasts sharply with wildfires occurring on the District between 1940 and 1981. The area burned over these four decades totaled only 9,887 acres. The decades of the 1950s and 1970s accounted for less than 200 acres of burned area each. Lightning has been the ignition source for almost all large fires (>1,000 acres) on the District, accounting for 98% of all acres burned from 1981 to present (see Supplement Supporting Documentation, Fuels). Fire perimeters from both large and small fires have overlapped over the past 40 years, in some instances up to four times. In addition, some fires have burned extensive acreage within, or predominately within, the perimeters of recent fires. For the period of 1981-present, over 40,000 acres on the Rocky Mountain Ranger District have burned more than one time. This pattern is consistent with fires throughout the Bob Marshall Wilderness Complex: Scapegoat, Bob Marshall, and Great Bear

Wilderness Areas. In the same period, this more expansive landscape of 1,544,478 acres has seen wildfire on over 500,000 acres, with over 110,000 of those acres having burned two or more times in the same period. The extent of reburn is also demonstrated when focusing on large wildfires that burned on the Rocky Mountain Ranger District during the 1988 fire season. The largest of these fires was the Canyon Creek fire that burned 192,519 acres of National Forest, of which 22,146 acres have reburned since 1988. Significant fires reburning portions of the Canyon Creek fire include Burned Point, 1999; Cabin Creek, 2001; Conger Creek, 2007; Bald Bear, 2011; Elbow Pass Complex, 2012; Falls Point, 2012; Rice Ridge, 2017; Alice Creek, 2017. The 54,576-acre Gates Park fire on the Rocky Mountain Ranger District has also experienced reburn since 1988; 17,914 acres have reburned at least once (see Supplement Supporting Documentation, Fuels, and Supplement Fire History Map). While natural ignitions account for most of the burned acres in the Northern Continental Divide Ecosystem and on the Rocky Mountain Ranger District, the South Fork Sun Prescribed Burn Project on the Rocky Mountain Ranger District burned over a relatively broad area and has since displayed patterns of reburn by naturally ignited fire. As with the Elk Smith Project, the South Fork Sun River Prescribed Burn Project was planned to reduce the potential of wildfires burning in the wilderness escaping and threatening structures, trailheads, routes of access and egress, livestock, private property, and human life. Another goal of the project was to create conditions where wildfire would be allowed to burn in designated Wilderness without presenting an unacceptable risk to human life and property beyond Wilderness boundaries, specifically to people and structures along the Benchmark Road (USDA Forest Service, 2001). Prescribed fire treatments for the South Fork Sun Project were completed in the fall of 2003, 2009, and 2011. In total, the treatments introduced fire onto 13,254 acres to the northwest of the Elk Smith Project Area. Even before completion, natural wildfires had started to overlay the treated area. In 2007, the Ahorn fire reburned 1,874 acres at the northern end of the South Fork Sun Project Area (prescribed burn of 2003). In 2011, the Upper Ayres fire encroached on the Project Area, accounting for 22 acres on the Project Area’s western edge. And in 2012, the Elbow Pass Complex reburned 1,392 acres on the southern end of the South Fork Sun Project Area (See Supplement Supporting Documentation, Fuels, and Supplement Fire History Map). The pace of fire occurrence, the size of fires, the severity of fires, and the area of reburn covered by recent wildfires in the Northern Continental Divide Ecosystem have been the subject of a number of studies (Teske, 2012; Parks et al., 2016; Naficy, 2016). These studies have increased our knowledge of the complex role of fire in the Northern Continental Divide Ecosystem and furthered our understanding of answers to several key fire management questions: Are recent fires and reburns natural for this area (or in the Historic Range of Variability)? What role do recent fires and reburns play in shaping ecology and fire behavior in this landscape? Does recent fire history indicate we will see larger, more severe, fires in the coming decades? Fire Regime describes the nature of fire over time for a particular area and can vary depending on topography, vegetation, climate, elevation, and aspect. For example, a grassland at low elevation may experience wildfire on a very short interval between fires (e.g. 5-15 years between fires), while a forest on a north aspect at high elevation may see fire on a much longer interval (e.g. 150-300 years). While displaying markedly different fire regime characteristics, these landscapes may be spatially very close— that is, the distance from a valley bottom to a mountain top may be only a couple of miles. Researchers

have taken a variety of approaches and distinct methodologies to define and explain the complex interactions of fire on larger landscapes that may include substantial variation in vegetation, climate, elevation, topography, and aspect. One of the earliest portrayals of fire interactions, characteristics, and effects in the Northern Rockies was published by H.B. Ayres, following his 1899 survey of the Lewis and Clark Forest Reserve. Ayres’ survey provided a snapshot of vegetation types covering the Reserve at the turn of the century and included detailed descriptions, often accompanied by photographs, of landscapes and the impact of fire on those landscapes. It is evident from Ayres’ report that fire played a significant and complex role over the entire Reserve. For example, he noted that roughly one-third of the forests and grasslands surveyed had recently experienced fire. In addition, Ayres described the effects of fires among different conifer stands including fires of low intensity and high frequency in ponderosa pine stands, as well as the mosaic pattern created by fires of low, moderate, and higher intensity in denser stands of lodgepole pine and Douglas-fir. A careful observer, he detailed variation in fire effects at different elevations, ranging from valley bottoms to the surrounding peaks. And he noted the evidence of fires repeatedly burning across the Forest Reserve. Across the Lewis and Clark Forest Reserve, Ayres documented approximately 768,000 acres of burn resulting from the fire season of 1889. He further stated that about 40 years prior to 1889, similarly large expanses had burned: “Most of the burns of that time have reburned since” (Ayres, 1900). Ayres noted the widespread impact of reburning throughout the report of his survey. In describing the surface fuels in burned areas on the east side of the Continental Divide, he made the following observation: “Although a large proportion of the trees are dead, the fires that killed them have as a rule been so recent that the deadwood has not fallen, while most of the debris from the older fires has been consumed by the later fires” (Ayres, 1900). Herman Gabriel III studied the fire history and ecology of the Danaher Creek drainage in the Bob Marshall Wilderness three-quarters of a century after Ayres completed his survey. Gabriel’s study encompassed an area of over 80,000 acres, lying approximately 10 miles west of the Elk Smith Project Area. By studying the evidence of past fires (through dendrochronology and vegetation characteristics), Gabriel found extremely complex fire effects on the landscape: “[F]ire frequency and intensity seem to have varied so much within this 33,000 [hectare] mountain drainage that area wide generalizations may obscure the lessons written on the landscape” (Gabriel, 1976). Still, he described the area as having two distinct fire cycles occurring and overlapping in the Danaher Basin. The first was a long fire cycle of high intensity fire, and the second was a short cycle of light fire. Gabriel put the Danaher Basin’s Fire Rotation at 150-200 years, which equated to large fires in the Basin at every 12 to 15 years with a fire interval of 15 to 45 years for light fires in any given stand. Gabriel noted the potential for reburn following high intensity fires and concluded: “[H]igh intensity fires, and the accumulation of fuels which precedes them, are normal events in the functioning of the Danaher ecosystem.” Both long and short fire cycles were important to the ecology of the Danaher Basin. For example, “The prairie grasslands in the Basin and the Danaher Meadows, the ponderosa pine savannas, and the open Douglas-fir/pinegrass communities were all maintained by frequent light fires.” Aspen stands were also maintained by these light fires, while high intensity fires played a different role of recycling climax communities: “[High intensity fires], where lodgepole appears to be the climax species, have recycled the lodgepole pine. In effect, such fires created a mosaic of different aged stands within the community, but not a mosaic of different species (153).”

The complexity of fire interactions in the Northern Continental Divide Ecosystem have continued to challenge researchers since Ayres’ early survey and Gabriel’s study of the Danaher. Conducting recent research in the ecosystem, Cameron Naficy has come to understand the area’s fire ecology in terms of Mixed Severity Fire Regimes. Due to its fire history, the vegetation contains “patches created by a mixture of surface fires, and active and passive crown fires that create a fine-scale mosaic of low, moderate, and high severity fire effects” (Naficy et al., 2015). Both Gabriel and Naficy recognized the historical role of large high severity fires in the landscape, with Naficy observing that “high severity was historically common in these [Mixed Severity Fire Regimes], affecting most forest patches at some point in the last 100 to 300 years.” However, both authors recognized that fire interactions in their study areas were more complex than could be fully explained by high severity fire. Gabriel characterized the Danaher Basin as experiencing a short fire cycle of low intensity at lower elevations, and a long fire cycle of high intensity at mid and higher elevations, with some overlap of the two. Naficy’s description of Mixed Severity Fire Regimes adds another dimension to understand fire interactions in the Northern Continental Divide Ecosystem: “[M]ost patches (>75 percent of all patches) experienced a high severity fire followed by one or more low to moderate severity fires that created multi-cohort stand structure.” This mix of fire effects from low, mid, and high severity fire have fundamentally influenced the vegetation in the Northern Continental Divide Ecosystem, leading to the “predominance of young, multi-cohort forest patches.” Looking at two study areas in the Greater Yellowstone Ecosystem and five areas in the Northern Continental Divide Ecosystem, Naficy found median fire intervals of between 30 and 100 years (Naficy, 2016). Recent studies have demonstrated that fires in areas that have not recently seen fire, and reburns, play important roles in the function of the Northern Continental Divide Ecosystem (Gabriel, 1976; Teske, 2012; Naficy, 2016; Parks et al., 2016). All four of these studies find that fire, whether initial or reburn, leads to greater heterogeneity on the landscape: “[W]ildfires maintain ecological resilience by restructuring the landscape through space and time. Assuming they have ecological context, post-fire patches—whether burned once or more than once—add diversity to the landscape, provide additional mechanisms for successional pathways to exist, and promote tree recruitment and establishment” (Teske, 2012). Both types of fire—initial entry and reburn—fundamentally impact the characteristics of fires that follow. Studying the 1988 Canyon Creek and Gates Park wildfires, along with subsequent fire, Teske observed, “[P]revious fires affect the behavior and effects of subsequent fires, including spread, severity, size, timing, and location.” (Teske, 2012). Parks et al. found that wildland fire reduced the severity, size, and occurrence of subsequent fire (2016). The severity of fires is reduced with a reburn. For example, if a fire burns across a landscape that has not seen recent fire, it may burn at high severity. If such a fire reburns, fire severity will likely be reduced to moderate or low. This effect degrades over time, as do other fire effects: “The longer the time between fires, the greater potential for a larger area to burn and perhaps at a higher severity (Teske, 2012).” Considering climate change, scientists have increasingly been interested in determining if fire history in the recent past represents “unnatural” fire occurrence, severity, and size. Modelling of climate change and recent fire history for the Greater Yellowstone Ecosystem indicated that climate change coupled with increased fire occurrence, severity, and size could alter fire regimes and irreversibly change the

vegetation characterizing the ecosystem in a comparatively short period of time (Westerling et al., 2011). Determining whether recent fires in the Northern Continental Divide Ecosystem are within the Historic Range of Variability has been an important consideration for Teske, Naficy, and Parks et al. Teske understands the increased fire occurrence and area covered by fires that has occurred in the past 25 years to be part of a natural process. Interludes of comparatively infrequent fires are punctuated by episodes with multiple large wildfires. Teske’s research indicates that fires occurring in the recent past are not unprecedented: “[T]he area burned within each of the study areas since 1984 yields [Natural Fire Rotations] consistent with results derived from long-term fire atlases and tree-ring research studies for these areas. That is, these results imply that the last 25 years have not been atypical for what is considered ‘natural’ in terms of frequency or area burned for these wilderness areas.” (Teske, 2012). All three researchers are aware that climate change has the potential to lead to “tipping points” that could result in fire regime and vegetation change. Teske acknowledges this potential; however, she concludes that “[O]ur research shows that the total area burned, regardless of individual fire sizes, is within historical ranges published by others. Dillon et al. (2011) also showed no evidence of an increase in annual area burned for the northern Rockies” (Teske et al., 2012). Parks et al. and Naficy see continued fire on the landscape as necessary to maintain ecosystem resilience and both emphasize the importance of negative “feedback loops” that perform a regulatory function: “Self-regulation theory suggests that several aspects of wildland fire are moderated by site- and-landscape-level vegetation changes caused by previous fire, thereby creating a dynamic where one fire exerts a negative feedback regulatory control on subsequent fire” (Parks et al., 2016). Naficy emphasizes that these feedback loops were not incorporated in the modelling conducted by Westerling (Naficy, 2019, July 9). While noting that positive feedbacks, potentially leading to ecosystem change, are possible, Parks et al. considers the disruption of negative feedback loops as potentially more threatening to ecosystem health: “When these feedback mechanisms are interrupted by human activities such as fire suppression, the result is larger and more severe fire in future years (Calkin et al. 2014). . . . [F]eedbacks are necessary components of self-regulating landscapes and for creating and maintaining resilience to future wildland fire events.” (2016). As part of the larger landscape included in the Northern Continental Divide Ecosystem, the Elk Smith Project Area is one of the places where disruption in feedback mechanisms is most likely to be interrupted by fire suppression. The Project Area is not in an area of reburn, though suppression actions have been taken on naturally ignited fires to the south, west, and north of the Project Area in recent years. Continued use of suppression actions in the Project Area, and on surrounding lands, will continue to take place to manage the immediate and direct threat fire in the Project Area would pose to human health, safety, and property. Besides reducing heterogeneity on the landscape, fire suppression will maintain an increased wildfire risk to people and property.

Fuels The Existing Condition of fuels in the Elk Smith Project Area is described and modelled under Environmental Benefits and Consequences. Specifically, see the No Action Alternative.

Proposed Action and Alternatives

Alternative 1 Under Alternative 1, the No Action Alternative, existing management activities and natural processes would continue within the Project Area. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would continue due to elevated fire risk. Alternative 1 provides a baseline for comparison of environmental benefits and consequences of Alternative 2 to the existing condition.

Alternative 2 Under Alternative 2, the Action Alternative, fuel accumulations would be addressed utilizing prescribed fire treatments. The treatments would be timed and implemented to replicate the patchy pattern of a natural reburn on the landscape. Burning would also be conducted to replicate the low and moderate severity fire effects of a reburn. Weather parameters documented during the 12,380-acre Red Shale fire—a reburn located almost entirely within the perimeter of the 1988 Gates Park fire on the Rocky Mountain Ranger District--will aid in achieving these desired effects. The intent is to replicate a reburn pattern in an area where natural fires will be suppressed to protect human life and property and also to allow natural processes, such as wildfire, to occur on Wilderness lands to the west of the Project Area. It is believed such a prescribed fire will reduce the potential occurrence, intensity, severity, and size of subsequent wildfire in the Project Area, significantly reducing the threat to people and property, while enhancing ecosystem resilience and heterogeneity. Proposed treatments consist of hand-slashing small conifers—conifers less than 7” diameter at breast height on select portions of units 1,2,7,9, and 11 -- and prescribed burning on all project units (broadcast1 and jackpot2). Slashing of young conifers is intended solely to meet resource objectives and is discussed in more detail under the Cumulative Effects of the Proposed Action. All areas treated by slashing would be subsequently targeted for prescribed fire application. Broadcast burning would result in burned patches of approximately 20-100 acres. Jackpot burning would be conducted concurrently and would involve smaller pockets of concentrated fuel. The intent of these smaller patches would be to replicate the spotting of natural reburn to isolated pockets of receptive fuel. In combination, broadcast and jackpot burning would cover 30-50% of the total area identified in each unit. These proposed activities would reduce fuel loadings, increasing the potential to effectively manage future wildfire within the Project Area and on lands immediately to the west. Activities to implement Alternative 2 would occur on 15 units identified within the Elk Smith Project Area. These units are identified on a map, provided in Appendix A of this Environmental Assessment.

1 Broadcast burning – intentional burning of debris on a designated unit of land, where the fuel has not been piled or windrowed, by allowing fire to spread freely over entire area. 2 Jackpot burning – used to reduce fire hazard in areas where heavy fuel concentrations exist but are not continuous enough for a broadcast fire to carry through the fuels, and where piling would be impractical.

Details concerning the treatments that would be applied to individual units, the purpose of treating specific units, and the anticipated season of treatment are provided in Table 7. Table 7: Elk Smith Proposed Treatment Units. Anticipated Unit Acres Area Purpose Treatments Season

• Slash and burn conifers Spring or Fall. encroaching on natural Targeted openings and aspen stands. season for • Treatments would cover implementation approximately 30-50% of the would be Maintain natural unit. spring. 1 546 Petty Creek openings as fuel • breaks. Fell young conifers (<7” diameter at breast height) using power saws over portions of unit. • Broadcast burn utilizing hand ignition.

• Slash and burn conifers Spring or Fall. encroaching on natural Targeted openings and aspen stands. season for Use prescribed fire in existing implementation aspen clones to encourage would be suckering. spring. Maintain natural openings as fuel • Fell young conifers (<7” 2 372 Petty Creek breaks. diameter at breast height) Encourage aspen using power saws over suckering. portions of unit • Broadcast and jackpot burns utilizing hand ignition. • Combined treatments would cover approximately 30-50% of unit area.

Disrupt • Broadcast burn utilizing Spring or Fall. continuity of helicopter ignition. Targeted Weasel fuels throughout 3 1461 • Burn conifer regeneration and season for Creek unit (downed heavy surface fuel loadings implementation trees and (1,000-10,000 hour fuels). would be fall. continuous

Anticipated Unit Acres Area Purpose Treatments Season conifer stands); • Reduction of 30-50% in conifer reduce the future regeneration in patches of risk of high approximately 20-100 acres. intensity and • Reduction of heavy surface high severity fires fuel loadings in patches of in area between approximately 20-100 acres. wilderness • boundary and Target amount burned 438- Forest and 731 acres (treat 30-50%). private land Stand replacement patches boundaries. will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring or Fall. helicopter ignition. Targeted Disrupt • Target conifer regeneration season for continuity of and heavy surface fuel implementation fuels throughout loadings (1,000-10,000-hour would be fall. unit (downed fuels). trees and • continuous Reduction of 30-50% in conifer conifer stands); regeneration in patches of reduce the future approximately 20-100 acres. Weasel 4 1047 risk of high • Reduction of heavy surface Creek intensity and fuel loadings in patches of high severity fires approximately 20-100 acres. in area between • Target amount burned 314- wilderness 524 acres (treat 30-50%). boundary and Stand replacement patches Forest and will generally be 100 acres or private land less. Treatments would occur boundaries. in both densely stocked areas and also in some more sparsely stocked areas. Some

Anticipated Unit Acres Area Purpose Treatments Season dense forest areas would be retained.

• Broadcast burn utilizing Spring or Fall. helicopter ignition. Targeted • Target conifer regeneration season for Disrupt and heavy surface fuel implementation continuity of loadings (1,000-10,000-hour would be fall. fuels throughout fuels). unit (downed • Reduction of 30-50% in conifer trees and regeneration in patches of continuous approximately 20-100 acres. conifer stands); reduce the future • Reduction of heavy surface Weasel 5 628 risk of high fuel loadings in patches of Creek intensity and approximately 20-100 acres. high severity fires • Target amount burned 188- in area between 314 acres (treat 30-50%). wilderness Stand replacement patches boundary and will generally be 100 acres or Forest and less. Treatments would occur private land in both densely stocked areas boundaries. and also in some more sparsely stocked areas. Some dense forest areas would be retained.

Disrupt • Broadcast burn utilizing Spring or Fall. continuity of helicopter ignition. Targeted fuels throughout • Target conifer regeneration season for unit (downed and heavy surface fuel implementation trees and loadings (1,000-10,000-hour would be fall. continuous fuels). 6 588 Elk Pass conifer stands); • Reduction of 30-50% in conifer reduce the future regeneration in patches of risk of high approximately 20-100 acres. intensity and high severity fires • Reduction of heavy surface in area between fuel loadings in patches of wilderness approximately 20-100 acres.

Anticipated Unit Acres Area Purpose Treatments Season boundary and • Target amount burned 176- Forest and 294 acres (treat 30-50%). private land Stand replacement patches boundaries. will generally be 100 acres or Encourage aspen less. Treatments would occur suckering. in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Reduction of 30-50% in conifer Spring or Fall. regeneration in patches of Targeted approximately 20-100 acres. season for • Slash and burn conifers implementation encroaching on natural openings would be and aspen stands. Use prescribed spring. fire in existing aspen clones to Maintain natural encourage suckering. openings as fuel • Fell young conifers (<7” diameter 7 748 Elk Pass breaks. at breast height) using power Encourage aspen saws over portions of unit. suckering. • Felling of young conifers will be excluded from 8 acres on unit #7’s western boundary that is located outside designated Wildland Urban Interface. • Broadcast and jackpot burns utilizing hand ignition.

Disrupt • Broadcast burn utilizing helicopter Spring or Fall. continuity of ignition. Targeted fuels throughout • Target conifer regeneration and season for unit (downed heavy surface fuel loadings (1,000- implementation 8 584 Elk Pass trees and 10,000-hour fuels). would be fall. continuous • conifer stands); Reduction of 30-50% in conifer reduce the future regeneration in patches of risk of high approximately 20-100 acres.

Anticipated Unit Acres Area Purpose Treatments Season intensity and • Reduction of heavy surface fuel high severity fires loadings in patches of in area between approximately 20-100 acres. wilderness • Target amount burned 175-292 boundary and acres (treat 30-50%). Stand Forest and replacement patches will generally private land be 100 acres or less. boundaries. • Encourage aspen Treatments would occur in both suckering. densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring or Fall. combination of helicopter and Targeted hand ignition. season for • Reduction of 30-50% in conifer implementation regeneration in patches of would be approximately 20-100 acres. spring. • Maintain natural Reduction of heavy surface openings as fuel fuel loadings in patches of Horse 9 648 breaks. approximately 20-100 acre. Mountain Encourage aspen • Target amount burned 201-335 suckering. acres (treat 30-50%). Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Reduction of 30-50% in conifer Spring or Fall. Disrupt regeneration in patches of Targeted continuity of fuel Cyanide approximately 20-100 acres. season for 10 669 that would Creek • Target conifers encroaching on implementation support west-to- would be fall. east fire spread. natural openings and aspen stands.

Anticipated Unit Acres Area Purpose Treatments Season • Fell young conifers (<7”diameter at breast height) using power saws over portions of unit. • Broadcast and jackpot burns utilizing hand ignition.

• Broadcast burn utilizing Spring or Fall. combination of helicopter and Targeted hand ignition. season for • Reduction of 30-50% in conifer implementation regeneration in patches of would be approximately 20-100 acres. spring. • Reduction of heavy surface fuel Maintain natural loadings in patches of Horse 11 473 openings as fuel approximately 20-100 acres. Mountain breaks. • Target amount burned 450-750 acres (treat 30-50%). Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

Spring and Fall. Spring is the preferred season for Disrupt treatment on continuity of fuel portions of the Cyanide 12 1500 that would unit bordering Creek support west-to- private land. east fire spread. Fall is the preferred season for other portions of the unit.

Anticipated Unit Acres Area Purpose Treatments Season

• Broadcast burn utilizing Spring and Fall. combination of helicopter and Spring is the hand ignition. preferred • Reduction of 30-50% in conifer season for regeneration in patches of treatment on approximately 20-100 acres. portions of the Disrupt unit bordering • continuity of fuel Reduction of heavy surface fuel private land. that would loadings in patches of Fall is the Cyanide 13 249 support west-to- approximately 20-100 acres. preferred Creek east fire spread; • Target amount burned 75-125 season for encourage aspen acres (treat 30-50%). Stand other portions suckering replacement patches will generally of the unit. be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring and Fall. combination of helicopter and Spring is the hand ignition. preferred • Reduction of 30-50% in conifer season for regeneration in patches of treatment on approximately 20-100 acres. portions of the unit bordering • Disrupt Reduction of heavy surface fuel private land. continuity of fuel loadings in patches of Fall is the Cyanide 14 645 that would approximately 20-100 acres. preferred Creek support west-to- • Target amount burned 194-323 season for east fire spread. acres (treat 30-50%). Stand other portions replacement patches will generally of the unit. be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

Anticipated Unit Acres Area Purpose Treatments Season

• Broadcast burn utilizing Spring and Fall. combination of helicopter and Spring is the hand ignition. preferred • Reduction of 30-50% in conifer season for regeneration in patches of treatment on approximately 20-100 acres. portions of the unit bordering Disrupt • Reduction of heavy surface fuel private land. continuity of fuel Cyanide loadings in patches of Fall is the 15 173 that would Creek approximately 20-100 acres. preferred support west-to- • Target amount burned 52-87 acres season for east fire spread. (treat 30-50%). Stand replacement other portions patches will generally be 100 acres of the unit. or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. *Total acreage = 10,329 (Note: Due to rounding differences in treatment acres there may be differences of 2 to 3 acres between the Supplemental EA and Draft Decision Notice and the Resource Reports.)

The treatments listed above would be staggered across time and space in order to meet project goals. Implementation is expected to begin in Fall 2021 and is dependent on the use of resource protection measures detailed in the Appendices of the Environmental Assessment (see Appendix B). In general, units which border private lands would be prioritized for implementation first.

Environmental Consequences

Past, Present, and Reasonably Foreseeable Future activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available in Appendix D of the Supplemental Environmental Assessment. Activities which may have a cumulative effect are described below.

No Action Alternative Alternative 1 proposes no actions. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts to conifers from insect and disease infestation would continue their current trends. Fire suppression efforts would continue in the Project Area and on the surrounding landscape, reducing the potential for reburn in the Project Area and contribute to a sustained trend toward homogeneity in the Project Area’s vegetation. Some incidental tree removal would occur through firewood cutting. The use of Wildland

Fire Use For Resource Benefit would remain a management option for Wilderness lands lying immediately to the west of the Project Area, though its use as a management tool could be undermined by the continuity and heavy loading of fuels in the Project Area. Alternative 1 provides a baseline for comparison of environmental consequences of the Action Alternative to the existing condition. It is a management option that could be selected by the Responsible Official.

Direct and Indirect Effects The Canyon Creek Wildfire of 1988 stands as the most important event influencing the present condition of fuels in the Project Area. This fire “reset” plant communities. Extensive regeneration of lodgepole pine is typical throughout the Project Area and is associated with high volumes of downed woody material and standing snags, also resulting from the 1988 fire. The combination of high volumes of downed woody-debris with the developing crowns of lodgepole pine and other colonizing conifers represents a fire hazard. In this case, fire hazard is defined by the rate of spread and intensities that a fire may exhibit, and the potential for a fire to cover extensive acreage. According to researchers, it is typical for fire hazard to grow steadily from a low point immediately following a fire in this fire regime and fuel type. As dead trees fall to the ground, and lodgepole pine grow within the fire perimeter, fire hazard increases. This hazard peaks around 25 years following a wildfire and remains elevated until moderating approximately 85 years following the fire (Lotan et al., 1985). The direct effect of the No Action Alternative would be to perpetuate this heightened level of fire risk for many decades.

Fireline Intensity and Flame Length are especially useful outputs in analyzing fuel conditions in that they can be tied directly to conditions where fire management activities, such as building handline, conducting burnout operations, and using aviation resources to deliver retardant can be implemented effectively by firefighters. Richard Rothermel, in his seminal publication How to Predict the Spread and Intensity of Forest and Range Fires, defined fire behavior characteristics in relationship to effective fire control, Table 8.

Table 8: Fire Suppression Interpretations from Rothermel (1983). Flame Length Fireline Intensity Interpretations Feet British Thermal Unit/foot/square <4 <100 Fires can generally be attacked at the head or flanks by persons using handtools. Hand line should hold the fire. 4-8 100-500 Fires are too intense for direct attack on the head by persons using handtools. Hand line cannot be relied on to hold fire.

Flame Length Fireline Intensity Interpretations Equipment such as dozers, pumpers, and retardant aircraft can be effective. Fires may present serious control 8-11 500-1,000 problems—torching out, crowning, and spotting. >11 >1,000 Crowning, spotting, and major fire runs are probable. Control efforts at head of fire are ineffective.

Using Rothermel as a guide, Analysts for this project grouped FlamMap outputs for Fireline Intensity and Flame Length into the following classes, Table 9.

Table 9: Fireline Intensity and Flame Length Classes. Fireline Fireline Intensity Range (British Intensity/Flame Length Flame Length Range (feet) Thermal Unit/foot/square) Class 0 0 0 1 1-99 .001-3.99 2 100-499 4.0-7.99 3 500-999 8.0-10.99 4 1,000+ 11+

For the existing condition, flame lengths and fireline intensity were averaged for proposed treatment units by flame class and fireline intensity class. The percentage of fuels in each class is displayed in Table 10 and Table 11 by unit (for the purpose of comparison with post-treatment conditions). It should be noted that fuels were modelled for the entire Project Area for both the existing condition and the Proposed Action. Project Area results for flame lengths and crown fire potential—Existing Condition and Proposed Action--are also displayed on maps in the Project Record (See Supporting Documentation, Maps).

Table 10: Existing Condition: Percentage of Unit by Flame Length Class. Flame Length Flame Length Flame Length Flame Length Treatment Flame Length Class 1 Class 2 Class 3 Class 4 Unit Number Class 0 (no fire) (.001-3.99) (4.0-7.99) (8.0-10.99) (11+) 1 0% 69.90% 7.55% 1.54% 20.98% 2 0.50% 53.93% 23.48% 11.04% 11.05%

Flame Length Flame Length Flame Length Flame Length Treatment Flame Length Class 1 Class 2 Class 3 Class 4 Unit Number Class 0 (no fire) (.001-3.99) (4.0-7.99) (8.0-10.99) (11+) 3 2.20% 68.25% 19.68% 5.44% 4.43% 4 3.20% 55.32% 18.76% 6.98% 15.74% 5 0.21% 49.40% 28.96% 8.65% 12.78% 6 0% 52.77% 28.97% 9.69% 8.58% 7 0.15% 42.31% 32.22% 9.20% 16.13% 8 1.24% 67.59% 23.15% 5.23% 2.79% 9 0.07% 78.21% 11.48% 4.19% 6.05% 10 0.47% 56.47% 22.16% 8.98% 11.92% 11 0.33% 81.69% 13.01% 2.76% 2.21% 12 2.03% 40.30% 29.90% 11.96% 15.81% 13 0.01% 30.54% 47.19% 15.60% 6.68% 14 2.75% 56.77% 25.51% 8.01% 6.96% 15 1.91% 65.18% 23.96% 5.94% 3.00%

Table 11: Existing Condition: Percentage of Unit by Fireline Intensity Class. Treatment Fireline Fireline Fireline Fireline Fireline Intensity Unit Intensity Class 1 Intensity Class 2 Intensity Class 3 Intensity Class 4 Class 0 (no fire) Number (1-99) (100-499) (500-999) (1000+) 1 5.45% 63.79% 10.76% 5.72% 14.27% 2 6.78% 49.80% 36.57% 5.18% 1.67% 3 10.91% 61.31% 24.57% 2.16% 1.04% 4 5.99% 54.21% 26.27% 8.03% 5.51% 5 0.37% 52.48% 37.24% 5.55% 4.36% 6 0.27% 55.16% 38.92% 4.99% 0.66% 7 0.87% 44.31% 42.07% 8.72% 4.02% 8 4.73% 67.26% 26.18% 1.34% 0.49% 9 8.93% 68.81% 17.39% 3.21% 1.67% 10 0.51% 59.76% 30.72% 4.94% 4.06% 11 14.35% 68.04% 16.15% 1.23% 0.24% 12 6.10% 37.85% 44.31% 7.45% 4.30% 13 1.78% 31.39% 64.74% 2.08% 0%

Treatment Fireline Fireline Fireline Fireline Fireline Intensity Unit Intensity Class 1 Intensity Class 2 Intensity Class 3 Intensity Class 4 Class 0 (no fire) Number (1-99) (100-499) (500-999) (1000+) 14 8.00% 53.84% 33.24% 3.30% 1.62% 15 5.33% 63.92% 29.01% 1.70% 0.04% Flame length and fireline intensity results illustrate that approximately 40% of the area included in units would exhibit fire behavior resistant to any type of direct attack. It should be remembered that fuels are not neatly grouped across the unit. For a better sense of fuel distribution with its resultant fire characteristics, see the map of Flame Lengths for the Existing Condition (Supporting Documentation, Maps). Another output derived from FlamMap is crown fire potential. FlamMap outputs give insight as to where crown fire activity may occur across the landscape or area of interest during the peak of the burn period. In the case of runs modelled for the project, historic weather from active burn periods during the Red Shale fire of 2013 was utilized in developing inputs. For Table 12, crown fire for the existing condition was grouped among four categories. The four categories modelled, and their respective definitions, are as follows: • No Fire: There are insufficient fuels to support fire activity. • Surface Fire: Fire spreads through surface fuel without consuming any overlying canopy fuel. • Passive Crown Fire: A type of crown fire in which the crowns of individual trees or small groups of trees burn, but solid flaming in the canopy cannot be maintained except for short periods. • Active Crown Fire: A crown fire in which the entire fuel complex is involved in flame, but the crowning phase remains dependent on heat released from surface fuel for continued spread.

Table 12: Existing Condition Crown Fire Activity by Percentage of Unit. Proposed Treatment Unit Passive Crown Active Crown No Fire Surface Fire Number Fire Fire 1 0% 68.69% 26.63% 4.68%

2 0.50% 18.60% 80.90% 0%

3 2.20% 46.08% 51.56% 0.15% 4 3.20% 44.44% 52.15% 0.21% 5 0.21% 16.21% 83.33% 0.25% 6 0% 29.62% 70.38% 0% 7 0.15% 27.97% 71.88% 0% 8 1.24% 45.49% 53.27% 0% 9 0.07% 70.28% 29.65% 0% 10 0.47% 29.53% 70.00% 0%

Proposed Treatment Unit Passive Crown Active Crown No Fire Surface Fire Number Fire Fire 11 0.33% 68.90% 30.77% 0% 12 2.03% 28.62% 69.29% 0.07% 13 0.01% 7.96% 92.03% 0% 14 2.75% 37.09% 60.16% 0% 15 1.91% 23.15% 74.94% 0%

As with flame length and fireline intensity, crown fire potential varies across the landscape depending on factors such as slope, fuel distribution, and wind speed. Under the existing condition, areas exhibiting the potential for passive crown fire dominate the landscape. Exceptions are units 1, 9, and 11. These units are characterized by relatively large areas of light fuel (e.g. grasses and forbs rather than heavy blow-down and young lodgepole pine). At a minimum, the No Action Alternative would maintain the flame length, fireline intensity, and crown fire potential listed in Table 10, Table 11, and Table 12. It is also likely that the No Action Alternative would result in higher fire occurrence in the Project Area. Recent research on fire occurrence in the Crown of the Continent - the Bob Marshall Wilderness Complex and Glacier National Park—indicates that within a fire imprint, ignitions are reduced for 21 years following a wildfire. For the Crown, this reduction in ignitions was greater than half for most of the 21-year period (Parks et al., 2015). Failing to reintroduce fire into the Project Area will keep the potential for new ignitions at an elevated level. Another direct effect of taking no action is to increase the potential for severe wildfires in the Project Area or, in other words, fires with the potential to damage ecosystems and property. Significant empirical evidence exists indicating the introduction of prescribed fire of even low intensity can greatly reduce the severity of subsequent wildfire (Arkle et al., 2012; Peterson et al., 2007). Moreover, fuels treatments can reduce the amount of smoke produced by subsequent wildfires, by reducing both the amount of fuel burned by a wildfire, and by reducing the residence time and duration of a wildfire (Graham et al., 2004). By failing to reduce the potential for severe fire in the Project Area, the No Action Alternative would go against fire and fuels management direction aimed at reducing the threat of fire to human life and private property. Forest Service Manual Direction identifies Firefighter safety, public safety, and community protection as the supreme goals of Fire Management. Severe wildfires pose the greatest threat to these goals: “severe wildfires put numerous . . . values at risk including: critical infrastructure, critical fish and wildlife habitat, firefighter and public health and safety, soil productivity, clean air, and functional fire-adapted ecosystems (Graham et al., 2004).” Moreover, the No Action Alternative would is not consistent with the goals of The Tri-County Community Wildland Fire Protection Plan. This locally developed plan identifies lands within the Project Area as being part of the Wildland Urban Interface and promotes treatments in this area to reduce the hazard wildfire presents to human life, livestock, and improvements in the Project Area and on lands immediately to the east of the Project Area boundary.

Cumulative Effects Cumulative Effects describes the interaction of the No Action Alternative with other management action in or near the Project Area. It is probable that selecting the No Action Alternative would impact management actions both within the Project Area and in the Scapegoat Wilderness, immediately to the west of the Project Area. First, the No Action Alternative could impact the ability of managers to allow wildland fires to burn in the Scapegoat Wilderness, immediately to the west of the Project Area. Currently, the Lewis and Clark Land Management Plan allows for Wildland Fire Use For Resource Benefit in the Scapegoat Wilderness. Guidance for managing such fires is found in the Bob Marshall Wilderness Complex Wildland Fire Management Guidebook. Due to the close proximity to private lands and improvements, Wildland Fire Use For Resource Benefit is not allowed in the Project Area. The suppression of fires to the west of the Project Area could erode the wilderness character of the Scapegoat Wilderness. The Wilderness Act of 1964, defines Wilderness “as an area where the earth and its community of life are untrammeled by man.” In Wilderness Management: Stewardship and Protection of Resources and Values, John Hendee and Chad Dawson interpret Wilderness Character as follows: [T]he critical determinant of primeval influence is the degree to which ecological processes are free to operate according to historical rhythms. A place is more wild where fires continue to burn, floods erode and create, and migratory animals still roam. Only where ecological processes remain outside of direct human control can the land be called “untrammeled.” Hendee and Dawson, 2002 Decisions to manage fires for resource benefit—in this case, for the benefit of Wilderness Character--are closely allied with the risk such fires may pose to human safety and health, as well as private property (Zimmerman, 2006; Stephens et al., 2012). The hazard associated with fuels in the Project Area will continue to limit opportunities to manage fire in Wilderness, since these fuels could support the spread of wildfire across the Project Area and toward residences to the north of the Project Area, and/or onto private land to the east of the Project Area. If fuel conditions remain at their current state, managers will be more likely to aggressively suppress wildfires at small acreages on lands to the west of the Project Area than if fuel continuity and loads were reduced in the Project Area. The aggressive suppression of Wilderness fire would erode the untrammeled character of the Scapegoat Wilderness. Moreover, it is well-established that wildfires in the Bob Marshall Complex can reduce the size, intensity, occurrence, and severity of subsequent fires (Parks et al., 2013; 2015; 2016). Consequently, the suppression of Wilderness fires could result in larger fires, more likely to burn beyond the Wilderness boundary. Besides eroding Wilderness Character, adopting the No Action Alternative will perpetuate conditions that will make it difficult, or impossible, for fire managers to successfully confine, control, or suppress fires within the Project Area when lives, property, or natural resources are at stake. Whether fires originate on adjacent lands and spread into the Project area, or start within the Project Area, they will pose a threat to private lands, buildings, livestock, and residents immediately to the east. If the No Action Alternative is adopted, this threat will remain elevated over the coming decades (Lotan et al., 1985).

Proposed Action Under Alternative 2, Action Alternative, prescribed fire and mechanical treatments developed to address fuel accumulation and continuity in the Project Area would be implemented as previously described, resulting in multiple breaks in existing heavy fuels, in a mosaic pattern across the landscape. Prescribed fire treatments are typically conducted under a range of weather parameters—often referred to as a “prescription window.” The prescription window is developed with the intent of achieving desired fire effects, while avoiding fire behavior that would resist control. Balancing these two goals can be difficult. On the Rocky Mountain Ranger District, high winds, low relative humidity, high temperatures, and low fuel moistures can all present challenges to fire control, whether prescribed or wildfire. Prescriptions are written with a high end and a low end. The high end is usually defined by the highest windspeed, highest temperature, lowest relative humidity, and lowest fuel moistures under which modelling suggests a burn can be controlled while meeting resource objectives. The low end is defined by the lowest windspeeds, lowest temperature, highest relative humidity, and highest fuel moistures under which a burn can be conducted and still meet resource objectives. Burning at the high end of a burn prescription can lead to control issues, while burning at the low end of the prescription can result in inadequate fire spread, intensity, and fire effects (Baker, 2009). If a prescription is written too narrowly, a suitable window to burn may never present itself. Even under the best of conditions, windows for prescribed burning are rare on the Rocky Mountain Front and often last for only a day or two. Depending on the burn project, weather and fuel conditions may be monitored for several years before a potential burn window is forecast. The Elk Smith project identifies several units where the cutting of small diameter conifers (<7” diameter at breast height) will occur prior to the application of prescribed fire: Units 1, 2, 7, 9, and 11. This cutting is intended to provide wider burn windows and ensure burn objectives are met in areas unlikely to burn on the lower end of a burn prescription. One objective is to ensure that adequate conifer mortality occurs in, and around, aspen stands. Cutting could also occur in areas where a combination of light surface fuels and moderate slopes would be unlikely to carry fire at the low end of a prescription. This cutting will be selective and will only be done in units where it is required to achieve desired conifer mortality over 30-50% of each unit. That is, cutting of small diameter conifers would be limited to no more than 50% of any of the identified units. In addition, stands that were not burned during the 1988 Canyon Creek fire will not be identified for either the cutting of small diameter conifers or the application of prescribed fire. Research suggests these stands tend to persist with naturally occurring reburn and may play an important role in the ecosystem in terms of providing a seed source for regenerating stands (Teske, 2012). Only one unit, Unit 1, is not fully within the perimeter of the 1988 Canyon Creek wildfire. Approximately one half of the unit extends beyond the 1988 fire perimeter. Treatments in this unit would retain mature conifer stands, while removing <7” diameter at breast height conifers from natural openings and at the edges of aspen clones. Unit 7 includes a small portion—8 acres—that extends beyond the boundary of the Wildland Urban Interface as designated by the Tri-County Community Wildfire Protection Plan, 2020 update. The cutting of small diameter conifers will not occur on this 8-acre portion of Unit 7.

Units 3, 4, 5, 6, 10, 12, 13, 14, and 15 do not include the pretreatment, or slashing, of small diameter conifers. Desired objectives can be met through prescribed fire alone in these units due to advantages in slope and fuel arrangement. Some handline construction may be needed on the periphery of all units to contain fire spread. This construction should be limited because existing Forest trails, natural breaks in fuel continuity, and natural barriers will be used to contain prescribed fire. Additional techniques to limit the impact of handline would include substituting wet-line and black-line for constructed line in areas of comparatively light fuel. If available, fireline explosives may be used as a less-impactful method of fireline construction than handline (Baker, 2009).

Direct and Indirect Effects As noted earlier, most of the Project Area is within the perimeter of the Canyon Creek fire of 1988. Since this fire burned, snags created by the fire have continued to fall, resulting in heavy accumulations of surface fuels. Conifers, especially lodgepole pine, have recolonized the site and created large expanses of continuous, heavy canopy fuels occurring in close association with dead, down woody fuels. The Proposed Action would disrupt the continuity of fuels in the Project Area through the introduction of prescribed fire. These treatments would remove encroaching conifers from natural openings, encourage the propagation of fire-resistant aspen, and create openings of 20 to 100 acres across wide expanses of heavy blowdown and lodgepole regeneration.

Figure 2: Photograph at the western boundary of the Project Area, 2013. Evident in the background is a dense growth of lodgepole pine regeneration coupled with heavy loadings of downed snags.

Before considering the direct and indirect effects of the Action alternative, it is important to note that neither the action nor the No Action alternative would remove fire from the Project Area. Fire would

remain an important part of the ecology both of lands within the Project Area boundary, as well as on adjoining lands. Rather than remove fire from the landscape, the treatment is intended to create conditions where fire can occur over large portions of the landscape without the need for aggressive fire suppression (adapted from Reinhardt, 2008). The intensity of wildfire is determined by physical setting, weather, and fuels. Of these three factors, the only one we can modify is fuel (Graham et al., 2004). The Action alternative proposes to modify fuels over a 22,000-acre Project Area by using chainsaws and prescribed fire to reduce regenerating conifers and accumulations of downed woody materials. Expanses of regenerating lodgepole pine would remain; areas of mature conifer, the survivors of the 1988 fire, would not be targeted for burning or mechanical treatment. The direct impact of these treatments would be to interrupt the continuity of fuels in the Project Area. This reduction of fuel continuity and loading would reduce the severity and intensity of subsequent fires (Arkle et al., 2012; Parks et al., 2013; 2015, 2016).

Following the implementation of treatments, it is likely that fire suppression actions would still take place in the Project Area. However, the strategies used to control wildfire in the Project Area would likely change. Aggressive full-suppression strategies limiting fire growth to the smallest possible acreage would likely trend toward less-aggressive confine or contain strategies. With more breaks in fuel continuity and loading, fire managers would be more likely to use natural barriers and areas of light fuel loading to strategically stop, or check, the spread of fire. This trend could increase the role of wildfire as an agent of disturbance in the Project Area, while reducing exposure of fire personnel to hazardous fire conditions, reducing fire management costs, increasing the effectiveness of fire management actions, and reducing the direct impacts of suppression. This trend would be amplified on Wilderness lands to the west, where Wildland Fire For Resource Benefit would likely see expanded use. To quantify the impact of implementing treatments across the Project Area, fuels data were modelled to reflect post-treatment conditions. First, criteria were established to help delineate priority areas within each proposed treatment unit. Treatment goals included focusing treatments within areas that burned in 1988 during the Canyon Creek Fire as much as possible and treating up to 50 percent of the area within each proposed unit. Priority treatment areas and post-treatment fuel values were selected to reflect reductions in surface fuel loadings, increases in canopy base heights, and reductions in canopy bulk densities that would result from the proposed treatments (as if the implementation of all thinning and prescribed fire treatments had been accomplished). Once post-treatment fuels had been modelled, FlamMap was utilized to model fire-behavior. As in the existing condition, these outputs included Fireline Intensity, Flame Length, and Crown Fire Activity. Results from the FlamMap Run are displayed in Table 13, Table 14, and Table 15.

Table 13: Post-Treatment Condition: Percentage of Unit by Flame Length Class. Flame Flame Flame Flame Flame Treatment Length Class Length Class Length Class Length Class Length Class Unit Number 1 2 3 4 0 (no fire) (.001-3.99) (4.0-7.99) (8.0-10.99) (11+) 1 0% 94.31% 5.06% 0.10% 0.53% 2 0.50% 77.12% 12.08% 5.15% 5.14%

Flame Flame Flame Flame Flame Treatment Length Class Length Class Length Class Length Class Length Class Unit Number 1 2 3 4 0 (no fire) (.001-3.99) (4.0-7.99) (8.0-10.99) (11+) 3 2.20% 86.41% 8.66% 1.68% 1.05% 4 3.20% 77.79% 9.02% 3.20% 6.79% 5 0.21% 69.59% 16.51% 5.47% 8.21% 6 0% 74.54% 15.21% 4.45% 5.80% 7 0.15% 67.40% 21.91% 5.18% 5.36% 8 1.24% 73.97% 16.92% 5.08% 2.79% 9 0.07% 90.11% 5.05% 1.54% 3.24% 10 0.47% 73.97% 12.15% 5.59% 7.82% 11 0.33% 90.10% 7.91% 0.83% 0.82% 12 2.03% 65.60% 12.06% 7.11% 13.19% 13 0.01% 71.48% 23.19% 3.12% 2.20% 14 2.75% 77.39% 10.98% 4.40% 4.48% 15 1.91% 84.45% 8.69% 2.97% 1.97%

Table 14: Post-Treatment Condition: Percentage of Unit by Fireline Intensity Class. Fireline Treatment Fireline Fireline Fireline Fireline Intensity Intensity Class Unit Intensity Class Intensity Class Intensity Class Class 4 3 Number 0 (no fire) 1 (1-99) 2 (100-499) (1000+) (500-999) 1 19.65% 73.72% 6.17% 0.26% 0.20% 2 8.26% 69.86% 17.96% 3.20% 0.71% 3 13.59% 75.35% 10.36% 0.48% 0.22% 4 6.17% 75.53% 12.64% 3.39% 2.27% 5 4.62% 66.64% 22.08% 3.18% 3.47% 6 3.14% 72.61% 20.03% 3.78% 0.44% 7 1.73% 67.65% 26.96% 2.99% 0.67% 8 5.49% 72.12% 20.56% 1.34% 0.49% 9 10.83% 78.26% 8.13% 1.78% 1.00% 10 1.58% 74.66% 17.55% 3.38% 2.83% 11 12.16% 78.25% 9.16% 0.39% 0.05% 12 5.88% 61.72% 22.06% 6.13% 4.21%

Fireline Treatment Fireline Fireline Fireline Fireline Intensity Intensity Class Unit Intensity Class Intensity Class Intensity Class Class 4 3 Number 0 (no fire) 1 (1-99) 2 (100-499) (1000+) (500-999) 13 2.59% 70.10% 26.49% 0.83% 0% 14 6.40% 74.64% 15.52% 1.93% 1.52% 15 5.46% 81.70% 11.48% 1.32% 0.04%

Table 15: Post-Treatment Crown Fire Activity by Percentage of Unit. Treatment Unit No Fire Surface Fire Passive Crown Active Crown Fire Number Fire 1 0% 93.91% 5.93% 0.16% 2 0.50% 62.22% 37.28% 0% 3 2.20% 78.52% 19.28% 0% 4 3.20% 73.18% 23.62% 0% 5 0.21% 53.78% 45.80% 0.21% 6 0% 65.20% 34.80% 0% 7 0.15% 58.98% 40.87% 0% 8 1.24% 58.41% 40.35% 0% 9 0.07% 83.57% 16.36% 0% 10 0.47% 57.97% 41.56% 0% 11 0.33% 79.51% 20.15% 0% 12 2.03% 59.06% 38.85% 0.07% 13 0.01% 52.52% 47.47% 0% 14 2.75% 66.30% 30.96% 0% 15 1.91% 51.97% 46.12% 0% Modelling supports the contention that fuel treatments would reduce the risk of subsequent wildfires by reducing fireline intensity. In addition, flame length values suggest that a wider range of fire management tools would be available to manage fire within the Project Area. For example, flame length averaged for all the units was reduced, compared to the pre-treatment condition, from 5.39 feet to 3.27 feet. This suggests that flame lengths exhibited by wildfires in the post-treatment landscape would often fall into the range (less than 4 feet) where ground forces could be deployed safely and effectively to construct and hold handline. This reduction in flame length would also increase opportunities for fire managers to use burn-out as a management tool. Moreover, the size and availability of safety zones and escape routes would be increased, as would the effectiveness of aviation resources. When viewed on a map, post-treatment flame length and crown fire values illustrate how fire behavior, as modelled for flame length and crown fire, would be reduced and provide significant “breaks” in fuel continuity. These breaks would provide locations where management actions might limit the progress of a wildfire generally moving from west to east, pushed by prevailing winds typical in the Project Area (See Project Record, Post Treatment Maps).

While most researchers acknowledge that prescribed fire treatments can dramatically reduce the severity and intensity of subsequent wildfire, there is some disagreement concerning its impact on the overall size and the rate-of-spread exhibited by subsequent fires. For example, Reinhardt, 2008, questions the validity of using fuel treatments “to reduce fire occurrence, fire size, or amount of burned area…” With some reservation, we agree with the arguments included in this journal article, Objectives and considerations for wildland fuel treatment in forested ecosystems of the interior western United States (Reinhardt, 2008). For example, it is understood that we cannot eliminate fire from the landscape. While conceding that fuel treatments will not reduce burned area over time, we do believe they can aid managers in controlling fire growth and size in specific instances. For example, prescribed fire treatments give managers more opportunity to implement fire control strategies and tactics by providing areas of light fuel that can serve as anchor points for the establishment of fireline. Areas of comparatively light fuels also provide locations from which burnouts may be conducted, or where aerially delivered retardant may be applied effectively, or where crews can establish fireline safely. Furthermore, these areas of comparatively light fuels, or breaks in fuel type and loading, can also be used in conjunction with natural fire barriers and breaks (e.g. rock outcrops) to catch spot fires, establish safety zones, and locate escape routes (Jain, 2012). In addition, when spread across the landscape, fuel treatments can slow, and/or redirect, the spread of fire by forcing a wildfire to flank around these areas of reduced fuels (Graham et al., 2004; Teske, 2012). Finally, there is a growing body of evidence showing that the reintroduction of fire to landscapes can, over time, reduce the size of subsequent fires (Parks et al., 2013; 2015; 2016; Kennedy and Fontaine, 2009). In all cases, fuels reduction projects give managers more options to safely contain or suppress fires when they pose an unacceptable risk to private property, or human life or health. Managers must remember, however, that every decision to suppress a fire is essentially a trade-off that may reduce the immediate threat of fires to values at risk but may undermine forest health and result in increased hazardous fuels (van Wagtendonk, 1995). The treatments in this proposal are located in an area where the proximity of values at risk dictates that managers will almost always have to make decisions to reduce the immediate hazard posed by wildfire ignitions. For this reason, fuel treatments that replicate the natural occurrence of natural reburning are essential to offset the trade-off of forest health and increases in wildland fuels that may occur when wildfires are suppressed to reduce an immediate threat to life, property, or natural resources. From the standpoint of fire and fuels, the durability of the treatments offered in the Action Alternative can only be predicted in general terms. For example, it is impossible to anticipate whether wildfires will ignite and burn within the Project Area, or whether the area will be subject to an extended drought. The occurrence of wildfires in the Project Area following the completion of the project could extend the effectiveness of treatments. Even discounting the potential for additional disturbance, it is likely the effectiveness of these treatments will persist for at least a couple of decades. Lotan et al. describe the effect of subsequent fire on a regenerating lodgepole stand where “conifers create crown fuels in close proximity to large accumulations of dead woody fuel,” as developing a very “low fire behavior potential (1985).” Recent studies of the impact of wildfires on the severity of subsequent wildfires suggest that an initial wildfire can reduce the size of subsequent fires for seventeen years or more, and the severity of subsequent fires by 20 years or more (Parks et al., 2013; 2015; 2016). The proposed treatments will occur within a fire perimeter. Following treatment, sources for the recruitment of downed woody

material, as well as the potential seed source for lodgepole regeneration will both be limited. Therefore, it is likely these treatments will be far more durable than the typical application of prescribed fire to previously untreated fuels. Due to the many factors contributing to the durability of treatments, it is recommended that treatments are monitored for both First Order and Second Order fire effects. A photo-point record should be established in units, and in controls, prior to implementation of mechanical treatment (felling of young conifers <7” diameter at breast height) or prescribed fire treatments. A photographic record, and interpretation, for photo-points should also be completed immediately following the implementation of prescribed fire treatments. These photo-point records should be in addition to the standard narrative evaluations of post-burn conditions that are included in burn plans. Second Order Fire Effects should also be monitored. The timing of this monitoring could depend on the occurrence of unforeseen disturbance events. For example, monitoring could follow the occurrence of a significant wildfire within the Project Area. If all objectives are met in implementing these treatments, managers should consider re-visiting photo-points 15 to 20 years following completion of the Proposed Action, or at any time the efficacy of treatments comes into question.

Air Quality Smoke produced from fires—both prescribed and wildfire—can reduce visibility and expose humans to harmful pollutants. The primary pollutants produced by fires occurring on wildlands are extremely small airborne particles of solids and liquids. These fine particles are 2.5 micrometers or smaller (referred to as PM2.5) and are small enough that they can be inhaled, get into the lungs, and adversely impact human health (AirNow, 2016). The Environmental Protection Agency, in conjunction with state and local governments, regulates and monitors the public’s exposure to a wide variety of airborne pollutants, including PM2.5. The effects of the No Action Alternative could potentially result in greater human exposure to particulate matter resulting from smoke. First, the No Action Alternative could result in larger wildfires in the Project Area and in lands immediately to the east of the project, which would produce larger volumes of particulate matter in a given period of time than a smaller wildfire or prescribed fire. Second, fires burning through the Project Area would have access to higher volumes of fuel--with the potential for increased smoke production--than wildfires burning through units pre-treated by prescribed fire. Finally, larger fires tend to burn over a longer period of time than smaller fires or prescribed fires and, consequently, are more likely to produce smoke on days with poor smoke dispersal. Managers have few options to control the production or dispersal of smoke from wildfires. Conversely, prescribed fires are scheduled when atmospheric conditions are conducive to smoke dispersal. Montana/Idaho Airshed Group guidelines are followed during all burning operations on National Forests in the respective states. The Airshed Group consults current air quality and smoke dispersion forecasts before authorizing prescribed burns. In addition, the Airshed Group manages the impact of prescribed burning to public health by taking into account the cumulative impact to air quality contributed by all wildfires and prescribed fires burning at a given time. Generally, air quality on the Rocky Mountain Front is “Good” as measured by the Air Quality Index. Upward ventilation and winds typically disperse particulates from wildfires and prescribed fires, as well

as other pollutants, before they reach dangerous levels in adjacent communities and areas of inhabitation. Monitoring of smoke impacts from recent fires suggests that prescribed burning can be accomplished in the Project Area without exceeding National Ambient Air Quality Standards. Since the amendment of the Clean Air Act in 1990, the Environmental Protection Agency has set National Ambient Air Quality Standards for pollutants considered harmful to public health and the environment. Monitoring of smoke impacts from fire on the Rocky Mountain Ranger District focuses on measuring the level of PM2.5 over an averaging time of 24 hours. The current Ambient Air Quality Standard for PM2.5 is 35 micrograms per cubic meter of air (µg/m³), averaged over a 24-hour period. In 2006, this standard was made more restrictive, adjusted from the previous standard of 65µg/m³. Monitoring of smoke impacts from two recent fires (one prescribed and the other a wildfire) on the Rocky Mountain Front illustrate the impact of smoke on nearby receptors. During the fall of 2003, a prescribed burn of over 4,000 acres was conducted immediately to the north and west of the Elk-Smith Project Area. A smoke monitor was placed at the Cobb Ranch approximately 2 miles northeast of the Project Area.

10/6/2003

70 24 hr average standard = 65 60 ug/m3

5-min average 40 1 hr average 24 hr average

0 0:00 0:45 1:30 2:15 3:00 3:45 4:30 5:15 6:00 6:45 7:30 8:15 9:00 9:45 10:30 11:15 12:00 12:45 13:30 14:15 15:00 15:45 16:30 17:15 18:00 18:45 19:30 20:15 21:00 21:45 22:30 23:15

Figure 3: South Fork Sun Prescribed Burn Smoke Monitoring, 2003.

*Note: the PM 2.5, 24-hour average, National Ambient Air Quality Standards is now at 35 µg/m³. The 24-hour average for the period displayed does not exceed 35 µg/m³. At no time during the completion of the prescribed burn were the Montana Standards for PM2.5 exceeded (see Figure 3). The burn was conducted when the National Ambient Air Quality Standards for PM2.5 were 65µg/m³; however, the 24 average was well below the more stringent current standard of 35µg/m³.

A more recent wildfire also offers monitoring data that was utilized to assess the potential impact of the Proposed Action on air quality. During the 2013 fire season, the Rocky Mountain Ranger District managed a wildfire in the Bob Marshall Wilderness Complex named Red Shale. This fire burned entirely within the perimeter of the 1988 Gates Park Fire, in fuels very similar to those in the Elk-Smith Project Area (vegetation similarly determined by a 1988 fire). Discovered on July 18, the Red Shale Fire burned actively through the remainder of July and through the month of August, before fall rains inhibited further growth. The fire grew to approximately 12,739 acres. To monitor smoke impacts on nearby communities, smoke monitors were placed at Ear Mountain (for the town of Choteau), and at Augusta, Montana. During the period monitored, the Red Shale Fire had numerous active days of burning. Significantly active days of burning resulted in fire growth ranging from several hundred acres to nearly 3,000 acres on July 27 (see Red Shale Fire Progression Map in the project file). Despite this large fire growth, the highest 24-hour average concentration of PM2.5 recorded by the Ear Mountain monitor was 17µg/m³, recorded on July 27. For the Augusta monitor, the highest 24-hour average PM2.5 concentration was 25µg/m³ (see Smoke Monitoring document in the project file). While monitoring of past prescribed and wildfires indicates that the Proposed Action can be implemented without exceeding National Ambient Air Standards, modelling was also completed to evaluate the potential impact of prescribed burning on air quality at potential receptors to the east of the Project Area. Specifically, the Smoke Impact Spreadsheet helped evaluate potential impacts. Smoke Impact Spreadsheet is a modeling system for calculating PM2.5 emissions and airborne concentrations downwind of natural or managed wildland fires. As a screening model, Smoke Impact Spreadsheet provides conservative (that is, tending toward higher-than-actual) predictions of the downwind air concentrations at user-selected receptors for comparison with appropriate federal or state air quality standards for particulate matter less than 2.5 microns in diameter (PM2.5). The Action Alternative proposes the use of prescribed fire in both the spring and the fall. For this reason, Smoke Impact Spreadsheet modelled a separate prescribed fire scenario for each of the two seasons. In building the scenario, prescribed fire of 1,500 acres, carried out over a single operational period was modelled. This acreage represents the probable upper-limit for the application of prescribed fire for a given entry (completing the project would occur over several years and require multiple entries). Communities immediately to the east of the project were considered in terms of PM2.5 impacts. These include Augusta, Fairfield and Choteau. Figure 4, below, displays results for a fall scenario and shows PM2.5 (averaged over a 24 hour period) downwind of the project.

Figure 4: PM2.5 24-hour Concentration Chart for Fall Elk-Smith Scenario Figure 4 indicates that PM2.5 concentrations would be far below the 24 hour standard of 35µg/m³ at downwind receptors such as Augusta (14 miles downwind), Fairfield (33 miles downwind), and Choteau (37 miles downwind). Results for both fall and spring scenarios are included in the project record for this project (see Smoke Impact Spreadsheet results, and Smoke Impact Spreadsheet model notes in the project record). For both scenarios, Particulate Matter 2.5 standards for a 24-hour average were not approached within 0.1 mile of the proposed burn. Under the spring scenario, values for the 24-hour average of Particulate Matter 2.5 ranged from 15.07, at 0.1-mile distance from the burn, to .52392 at 50 miles distance from the burn (the maximum distance that Smoke Impact Spreadsheet models). For the fall scenario, values ranged from 19.635, at 0.1-mile distance, to .41093, at 50 miles. In conclusion, modelling suggest that smoke impacts from the proposed prescribed fire are unlikely to exceed, or approach, Particulate Matter 2.5 standards in local communities.

Conclusion The fuel treatments outlined in the Action Alternative would likely enhance efforts to control fire in the Project Area. In addition, the treatments could complement ongoing efforts to reduce fuels in the vicinity of recreation residences and lodges along the Benchmark Road by increasing options available to managers to control wildfire in the Project Area. Doing so could prevent or slow such a fire from spreading north/northeast towards residences. In addition, the project would dovetail with the establishment of fuel breaks immediately to the north—included in the Benchmark III project. Both Elk

Smith and Benchmark III would provide increased opportunity for managers and firefighters to limit the spread of wildfire across the Forest boundary onto private, state, and Bureau of Land Management lands. The Elk Smith Fuel Reduction project would also complement conditions created by past District fuel reduction projects and past wildfires to promote the Rocky Mountain Ranger District’s active Wildland Fire Use Management Program. The Rocky Mountain Ranger District has experienced significant wildfire activity over the past 30 years, with numerous wildfires occurring near the Project Area in the last 20 years (see Supporting Documents, Fire History Maps). These fires have been managed utilizing a number of strategies and tactics. In some cases, the fires have been allowed to burn comparatively unrestricted, with active management limited to some of the following activities: contingency planning and periodic re-evaluation of decisions; providing public information; implementing point protection on residences, structures, and administrative sites; implementing trail, road, and area closures when appropriate; and initiating evacuations when needed. In some cases, management has included suppression on the entire perimeter of a fire; in other cases, fires have been suppressed only on those portions of the perimeter posing a threat to life, private property, or public values. Over the past 20 years, the perimeters of many fires have overlapped. One of the first of these overlapping fires occurred in 2001, when the Biggs Flat Fire burned approximately 8,000 acres within the perimeter of the 1988 Gate Park Fire. Since that time, numerous fires have “bumped” into each other on the District and, indeed, throughout the Bob Marshall Wilderness Complex. According to research, the impact of having an extensive overlay of recent wildfire footprints on the landscape is to reduce the size, occurrence, and severity of subsequent wildfires (Parks et al., 2013; 2015; 2016). The Action Alternative is in-step with perpetuating this trend toward smaller, less-severe, wildfires. It promotes conditions where managers can choose, under the right conditions, to permit fires to burn naturally in the Scapegoat Wilderness to the west. In this sense, the project is similar to the South Fork Sun Prescribed Fire Project that was completed to the north and west of the Elk and Smith Creek drainages. The South Fork Sun Project treated 13,254 acres with the objectives of allowing “lightning caused fires to play a more natural or historical role in the wilderness than what is currently occurring and to make the wilderness boundary more defensible against the risk of a wildland fire escaping the wilderness” (USDA, Forest Service, 2001).

Statutory and Regulatory Consistency Table 16 Summarizes the Proposed Action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 16: Summary of Statutory and Regulatory Consistency – Fuels. Regulatory Requirement Project Consistency National Forest Management Act, 1976: The Elk-Smith Project evolved from interdisciplinary National Identify issues, concerns, and opportunities; Forest Management Act Analysis that followed the Lewis and and, Conform to the Forest Plan. Clark National Forest Plan: Rocky Mountain Ranger District National Forest Management Act Analysis, 2010.

Regulatory Requirement Project Consistency National Environmental Policy Act, 1969: This Project includes analysis of a No-Action Alternative and an Requires the development and analysis of at Action Alternative. A statement of purpose was developed for the least two alternatives, as well as a purpose project (see Purpose Statement). and need statement. The Elk-Smith Project Action Alternative would reduce fuels on lands identified as Wildland Urban Interface in the Tri-County Fire Healthy Forest Restoration Act, 2003: Working Group Regional Community Wildfire Protection Plan. In Provides guidance on the development and addition, the Project aligns with six mitigation strategies for use of Community Wildfire Protection Plans, fuel reduction projects as listed in the Regional Mitigation as well as the relationship between these Strategy (see Tri-County Regional Community Wildfire plans and Federal land management Protection Plan, 2020 update; also, see table in Supplement activities. Supporting Documentation, Fuels: Elk Smith Project Relationship to the Regional Mitigation Plan). The Federal Land, Assistance, See the primary purposes of the project. The Action Management, and Enhancement Act of Alternative addresses all three goals by treating lands 2009 required a national cohesive fire included in designated Wildland Urban Interface and management strategy. The resulting adjoining lands. The purpose is to reduce fire occurrence, strategy had three goals: “1. Restore and size, and severity in the Project Area while enhancing maintain landscapes, 2. Create fire- ecosystem resilience and heterogeneity. The Action adapted communities, 3. Implement safe, Alternative is intended to allow fire managers more flexibility effective, efficient risk-based wildfire in controlling fire when it is a threat to human life and management decisions.” property, while increasing opportunities to use Wildland Fire for Resource Benefit in the Scapegoat Wilderness. Forest Service Manual Direction: Fire See the primary purposes of the project. The Action Alternative management is undertaken to ensure the would align with Manual Direction. The No Action Alternative protection of resources and other values from would maintain continuous fuels, as well as the risk for fires of wildfire. high intensity and severity. These conditions could threaten human health, safety, resources and other values. Forest Service Manual Direction: Fire See Appendix E for Forest Plan Consistency. Prescribed fire is management will utilize prescribed and utilized to reduce fire severity and increase ecosystem resilience wildland fire to meet land and resource to wildfire. The project is also intended to create conditions to management goals and objectives. promote the use of wildfire on lands to the west of the project and, by extension, promote wilderness management goals and objectives.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards and management area direction relevant to fire, fuels and air is available in Appendix E.

Consistency with Purpose and Need The purpose of the Elk Smith Project is provided on the second page of this report. The project has four primary purposes that are directly related to fire and fuels. These four purposes are addressed in the following table.

Table 17: Consistency with Purpose and Need. Purpose and Need Summary of Benefits Reduce the future risk of high-intensity, The Action Alternative is consistent with the purpose and high-severity wildfire within the Project need in implementing the activities described in the Elk Smith Area by interrupting the continuity of fuels, Treatment Units. The No Action Alternative is not consistent specifically continuous stands of lodgepole with the Purpose and Need as it would maintain continuity

Purpose and Need Summary of Benefits pine regeneration and heavy loadings of and loading of fuels in the Project Area and, by extension, larger fuels. maintain the risk of high-severity wildfire. The Action Alternative is consistent with this purpose and need. Implementing treatments associated with the Action Alternative will increase opportunities for managers to control or confine fires resulting from ignitions within the Project Area, or from fires that spread into the Project Area from lands to the west. In addition, treating fuels within the Project Area may increase opportunities to manage fire for resource benefit within the Scapegoat Wilderness. This, in turn, could reduce fuel continuity and loadings within the Reduce the potential for wildfire to spread wilderness and, over time, reduce the overall size of into the Benchmark corridor to the north wilderness fires (reducing the potential for large “catastrophic and onto private land east of the National fires” that could spread from the Scapegoat into the Forest boundary. Benchmark corridor and onto private land to the east). The No Action Alternative is inconsistent with this Purpose and Need. Taking no action would maintain continuity and loading of fuel in the Project Area. In addition, opportunities to manage fires for resource benefit on lands to the west of the Project Area would be limited. This would likely result in increased continuity and fuel loading in the wilderness, potentially resulting in large landscape fires that could spread through the Project Area into the Benchmark corridor and/or to private land east of the National Forest boundary. The Action Alternative is consistent with this purpose. See Table 7, “Elk Smith Proposed Treatment Units.” The No Create a more diverse landscape that is Action Alternative is inconsistent with this purpose. No more resilient to fire by retaining mature treatments would reduce fuels in dense areas, and conifers areas, disrupting dense areas, and would continue to encroach on openings. The landscape enhancing or re-creating grassland would tend toward homogeneity. The potential for large, openings. stand-replacing, wildfires would remain consistent, or increase. Exposure of mature conifer to stand-replacing fire would increase. The Action Alternative is consistent with this purpose. This alternative would disrupt fuel continuity and reduce fuel loading in the vicinity of the Benchmark Road, on the north, and at the interface between National Forest Land with lands Increase flexibility to allow lightning-caused of other ownership on the east (including private lands). wildfire to play its natural role in adjacent These treatments could reduce the risk of managing fire for and nearby designated Scapegoat resource benefit in the Scapegoat Wilderness. Without fuel Wilderness. modifications in the Project Area, allowing fires to burn naturally on lands to the west of the Project Area could prove challenging, resulting in the decision to aggressively suppress most starts in this portion of the Scapegoat. In addition, the treatment would complement the South Fork Sun Burn

Purpose and Need Summary of Benefits Project in producing conditions where wildand fires in the Wilderness can be successfully managed.

Vegetation The Sivilculturist reviewed the project’s proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019), the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 87 to 95) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review the following changes were made: Revise Douglas-fir and subalpine fir to identify these species as shade tolerant rather than intolerant ; Updated references; Changed the metric for cutting young conifers from <20 feet in height to <7 inches diameter at breast height; and Clarified in which geographic locations stocking surveys would be completed after treatment.

Existing Condition The project area, ranging in elevation from 4,800 feet along Ford Creek and Elk Creek to 8,585 feet at Steamboat Mountain, contains a mosaic of vegetation types, sizes, and structures. Scree slopes occur along the wilderness boundary from Crown Mountain southeast to Steamboat Mountain. The northwest one-quarter of the project area consists of contiguous, mature, multi-storied conifer forest. Douglas-fir with diameters generally 10 to 20-inches dominates the lower slopes. Quaking aspen and grass/shrub meadows intermix with Douglas-fir east of Petty Ford Creek trail. Between this location and Crown Mountain, average diameters decrease slightly and stands become mixed with subalpine fir, lodgepole pine, limber pine and whitebark pine. Limber pine is the dominant species on drier, south-facing slopes and limestone parent material at the higher elevations. Whitebark pine is found intermixed with limber pine in this location and in harsh sites adjacent to the wilderness. There are six designated plus-trees, part of the Northern Region’s Genetic Resource Program and the Intermountain Whitebark Pine Restoration Program, along the Crown Mountain trail. Stand densities in the mature timber range from 120 to 270 square feet of basal area per acre.

Figure 5: Landscape View of Project Area

Vegetation conditions on the remaining 74 percent (17,844 acres) of the project area was created from the 1988 Canyon Creek wildfire. Lodgepole pine, the dominant vegetation type (50 percent of project area, 65 percent of treatment units), has established with densities from 20 to over 27,000 stems per acre (averages around 2,100 stems). Within overly-dense stands, growth stagnation can be expected (USDA Forest Service 1983). Trees generally produce reduced height, diameter, and overall vigor compared to those in stands supporting lower densities (less than 400 trees per acre). At the other end of the spectrum, once forested areas now support very low densities or no trees. Table 18 of the vegetation section of this document depicts stand conditions in the project area and treatment units based on Region 1 Vegetation Map Product attributes, and Appendix A of the vegetation specialist report found in the Project Record contains an aerial image. About 65 percent of the treatment units is classified in the 0 to 4.9 inch diameter category. A review of imagery (NAIP and Google Earth) in comparison to the Region 1 Vegetation Map Product 0 to 4.9 inch class indicates that 8 percent to 47 percent of the acres (average of 22 percent) in this size class are actually in a non-stocked condition (Appendix C of the vegetation specialist report, Project Record). Non-stocked acres that were once forested (based on existing logs and snags) may have a healthy herbaceous and/or shrub component with minimal to no conifer establishment. Although trees can start producing viable seed in open-faced cones as early as five to 10 years of age, serotinous cones do not generally begin until after age 30 (USDA Forest Service 1965; USDA Forest Service 1983). Seedlings and saplings within the Canyon Creek fire perimeter are less than 30 years old, and cone serotiny is generally less than 30 percent.

Quaking aspen is present along drainages and in moist swales throughout the project area with heights up to 20 feet. Small areas of unburned, mature vegetation are scattered throughout. Mature stands are composed of multi-story, mixed conifer in moist areas and nearly pure, even-age lodgepole on cold, dry sites. In many areas, mountain pine beetle has recently killed mature lodgepole. Limber and whitebark pine are under-represented as a dominant vegetation type in the 2014 version of Region 1 Vegetation Map Product compared to field observations.

Table 18: Vegetation Existing Condition in The Project Area and Proposed Treatment Units Based On Region 1 Vegetation Map Product, the top numbers represent the project area and the bottom numbers the treatment units. Acres By Size Class Dominance Type Total Acres & 5.0 to 10 to (40% Plurality) N/A 0 to 4.9” 15 to 19.9” (Percent) 9.9” 14.9” 5 0 0 0 0 5 (0.02) Water 1 1 1,803 0 0 0 0 1,803 (7.4) Grass/Shrub 990 990 (9.6) 1,664 0 0 0 0 1,664 (6.8) Sparse Vegetation 200 200 (1.9) 409 0 0 0 0 409 (1.6) Aspen 190 190 (1.8) 0 40 2 0 0 42 (0.2) Limber Pine 18 18 (0.2) 0 538 3,251 2,791 406 6,987 (29) Douglas-fir 260 868 749 234 2,111 (20) 0 10,995 821 39 1 11,856 (49) Lodgepole Pine 6,438 236 25 1 6,701 (65) 0 0 22 34 30 86 (0.3) Engelmann Spruce 2 10 4 16 (0.2) Whitebark Pine 0 6 57 9 0 71 (0.3) 0 80 1,090 128 0 1,298 (5.3) Subalpine Fir 11 75 18 104 (1.0) Totals 3,881 (16) 11,659 (48) 5,243 3,001 (12) 437 (1.8) 24,221 1,381 (13) 6,727 (65) (22) 802 (8) 239 (2) 10,329 1,181 (11)

Plot data collected in the project area shows the following general habitat types: Douglas-fir/snowberry, Douglas-fir/pinegrass, subalpine fir/grouse whortleberry, subalpine fir/elk sedge, whitebark pine- subalpine fir, lodgepole/twinflower, and lodgepole/pinegrass. With the exception of two habitat types, the project area generally falls within Fire Groups 6 and 7 (Fischer and Clayton 1983). Even though it has been 30 years since the fire, standing snags are abundant with variable density across the project area (Figure 6– Post-1988 Canyon Creek fire stand containing 134 square feet of basal area per acre in lodgepole pine snags five to 13-inches diameter). Snag diameters are generally less than 13-inches. Downfall has created surface fuel loads between 23 and 88 tons per acre.

Figure 6: Post-1988 Canyon Creek fire stand. Forest insects have impacted mature conifer across the project area since 2009 according the aerial detection surveys (Appendix B of the vegetation specialist report, Project Record). Mountain pine beetle infestation caused mortality at a rate of 10 to 20 lodgepole per acre over about 4,300 acres between 2009 and 2010. Mortality occurred in the northwest corner of the project area and in mature conifer stringers along Elk Creek, Bailey Basin, Cascade Creek, and Horse Mountain. Only minor quantities of mortality were reported in five-needle pine (limber or whitebark pine). Douglas-fir and western balsam bark beetle mortality were also minor. In 2014 and 2015, Douglas-fir and Engelmann spruce defoliation from western spruce budworm was the most prevalent insect activity in the project area. Again, impacts were noted in areas containing mature trees.

Environmental Consequences

Past, Present, and Reasonably Foreseeable Future Activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available in Appendix D of this document. Past activities that occurred within the project area have created the vegetation conditions discussed in the existing condition section. There are no present or reasonably foreseeable actions that would cumulatively effect forest vegetation. Cumulative effects, therefore, would not be discussed for the forest vegetation resource.

No Action Alternative Under this alternative, no new actions are proposed. Existing management activities and natural processes would continue in the area.

Direct and Indirect Effects Plot data collected in the project area in 2012 and 2013 was processed through the Forest Vegetation Simulator to simulate growth over the next 120 years (see simulation results in the vegetation report, project record). Treatment units support a diversity of lodgepole pine stand densities. In some areas, the 1988 fire removed the seed source and conifer regeneration is extremely low. Exposure of these sites with often relatively shallow soil to drought, wind, or high temperatures may also have contributed to poor regeneration success (USDA Forest Service, 1983; Lotan et al., 1985). These areas are dependent upon seed dispersal from adjacent cone-bearing trees. An open rather than serotinous cone seed source are required for lodgepole to disperse. Because lodgepole and Douglas-fir seed generally disperses no greater than 200 and 330 feet, respectively, from a seed source (USDA FS 1965), stand regeneration would be gradual over the next 30 to 60 years. These areas may develop a more uneven-age distribution based on the regeneration timeframe (Kashian et al. 2005). In dense, even-age, lodgepole seedling and sapling stands, density-dependent mortality or self-thinning is the most significant process in stand development (Kashian et al. 2005). Dense stands would self-thin at a faster rate than less dense stands as the maximum site capacity is met. Forest Vegetation Simulator simulations indicated a 20 percent to 40 percent density reduction in moderately dense stands and up to 90 percent reduction in excessively dense stands. As trees die, resources would be allocated to residual stems which, in turn, would improve tree health and productivity. Without disturbance or treatment, this process would cause stands to converge in the future at a similar stand structure which would reduce overall landscape heterogeneity (Kashian et al. 2005). Shade intolerant species such as Douglas-fir and subalpine fir may also establish in lodgepole stands as a result of succession (Lotan et al. 1985). Growth and stand development in extremely dense (greater than 10,000 trees per acre), “dog-hair” thickets may stagnate. If not, self- thinning would naturally reduce stand density to a sustainable level. According to the summary database of available Forest Inventory and Analysis and intensified Forest Inventory and Analysis plot data, there is an average of 22 dead trees per acre greater than 10-inches diameter in the project area. Within the next several decades, these trees would fall adding to the existing high surface fuel load. Fire hazard in the project area is currently high, and would remain so for the next decade, as the dense seedling and sapling stands intermix with the high fuel load. As the trees grow in height, canopies lift, and surface fuel decays over the next 60 years, fire hazard would decline (Lotan et al. 1985). Aspen clones currently present in Units 1, 2, 6, 7, 8, 9, 11, 12, and 13 would develop into vigorous, mature clones. Without a disturbance event, such as fire, within the next 30 to 40 years, Douglas-fir and lodgepole establishment and growth in and around the clones would lead to increased competition, decreased aspen vigor and reproduction, and eventual reduction in clone size. Small clones adjacent to conifers are more susceptible to succession than larger, pure aspen clones. Appendix D of the vegetation specialist report found in the Project Record shows maps of potential host species basal area loss from mountain pine beetle, Douglas-fir beetle, and western spruce budworm

from 2013 through 2027. These maps indicate that short-term mortality can be expected to occur in mature timber in the northern portion of the project area and around Units 9 through12. These areas would continue to be susceptible to insect activity as long as they meet the appropriate stand characteristics (USDA FS 2011). Little to no insect activity is expected to occur in the seedling and sapling component of the treatment units. Simulated growth based on Forest Vegetation Simulator indicates that near the end of the rotation, most lodgepole pine stands would have a high hazard rating for mountain pine beetle. Sparsely stocked areas would have a low mountain pine beetle susceptibility due to low basal area (20 to 50-square-feet per-acre) of the trees that are generally greater than 7-inches diameter. Douglas-fir bark beetle hazard would be low to moderate in the Canyon Creek fire footprint since a majority of Douglas-fir diameters would be less than 14 inches. Given the relatively homogeneous forest conditions across the project area, there would be no barriers to bark beetle movement if an outbreak were to occur in the future. Western spruce budworm is currently active in Douglas-fir stands. Defoliation is predicted to occur in Douglas-fir stands, especially those with multiple canopy layers, whenever population outbreaks occur.

Cumulative Effects As previously stated, past actions in the analysis area have created the vegetation conditions currently present. The stand-replacement Canyon Creek fire, in 1988, triggered regeneration, which currently is of variable density. There are no present or reasonably foreseeable actions that would cumulatively effect the forest vegetation.

Proposed Action Under Alternative 2, the proposed action, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented as described in Appendix B of this document.

Direct and Indirect Effects A prescribed burn, using parameters similar to those used in the Fire and Fuels analysis, was simulated in Forest Vegetation Simulator with the Fire and Fuels Extension to determine how vegetation and fuel conditions would change compared to the no action alternative. Because the model does not contain a spatial component, simulation results do not reflect variability in fire movement through and effects to the diverse vegetation (e.g. low-intensity ground fire vs. high-intensity stand-replacement fire). The information provided below is a generalization of fire effects in the treatment units. Simulation attributes and results are provided in the project record. Slashing/conifer felling was not modeled due to its site-specific application based on stand structure, species composition, and requirements for fire movement. The existing landscape supports a diversity of stand densities, which, in turn, influences tree size and cone abundance. High-density stands support smaller diameter trees compared to less dense stands due to competition for resources. The type of cone (open or serotinous) is also variable across the project area. Trees established immediately after the 1988 fire are beginning to produce serotinous cones (less than 30 percent serotiny). According to Turner and others (2007), there is a positive relationship between tree diameter and the frequency and number of cones available per tree. Cone production in

high-density regeneration stands, is therefore, expected to be lowest due to small stem diameters. Sparsely treed areas would also produce few cones. Regardless of stem diameter or cone production capacity, small, young trees are unable to produce the abundance of cones witnessed in mature lodgepole. Therefore, post-treatment regeneration would be at a rate less than that experienced after the Canyon Creek fire (Lotan et al. 1985). Areas supporting serotinous cones should regenerate within a few years of the burn. Areas with open cones may have a regeneration lag, depending upon fire-created opening size, due to the gradual movement of seed (dispersal distance less than 200 feet) from the adjacent seed source. Application of prescribed fire in locations with poor post-Canyon Creek regeneration establishment would increase the time needed and decrease the likelihood of these areas returning to a forested condition if there is not an immediate seed source. Douglas-fir regeneration, primarily in Units 3, 4, and 6, would rely on wind-dispersed seed (dispersal distance less than 330 feet) to recolonize the burn. Because mature, cone-bearing trees are present at low quantities within or adjacent to treatment units, establishment of Douglas-fir would be slow (Hatch and Lotan 1969; Shearer 1981). Saplings greater than 15 years old that survive the prescribed burn could contribute seed to the recolonization effort. However, if sites are warm and dry and lodgepole is present in the pre-burn stand, lodgepole could begin to dominate the site, especially if future burns continue to remove the Douglas-fir seed source (Crane et al. 1983; Hatch and Lotan 1969; Shearer 1981). According to the Forest Vegetation Simulator, prescribed fire is predicted to kill 20 percent to 60 percent of the trees in treatment units. Tree mortality may be as isolated trees or patches up to 100 acres in size. Within the first decade, a flush of regeneration occurred on the bare mineral soil seedbed, which increased stand densities. At the end of the 120-year simulation, tree per acre densities were similar or up to 20 percent less than predicted with the No Action alternative. Basal area reduction as generally 10 percent to 20 percent, but may be as high as 50 percent in some areas. With reduced competition, trees were able to produce larger diameters (one to two inches). The overall impact to density, basal area, and tree size in the units would be a combination of the predicted post-burn results and those described for forest development under the No Action alternative. Implementation of stand-replacement fire in patches of 20 to 100 acres over 30 percent to 50 percent of the treatment unit would increase the landscape’s overall size- and age-class diversity in the short term. However, as explained in the No Action alternative, landscape heterogeneity would gradually decline over time as stand structure converges to a similar condition. Shade intolerant species such as Douglas-fir and subalpine fir may gradually establish in lodgepole dominated stands due to succession. Based on the simulation, prescribed burning consumed between 25 percent and 60 percent of the existing coarse woody debris, substantially reducing the surface fuel load. In the first decade, fuel load slightly increased as fire-caused tree mortality and snag downfall was added to the forest floor. However, a steady decline in tonnage was predicted such that at the end of the simulation coarse woody debris was either the same or up to 40 percent reduced compared to the no action alternative. The actual placement of fire during implementation, which would target areas of heavy surface fuel accumulation, would determine the changes in coarse woody debris over the treatment area. Implementation of the prescribed burn would assist with surface fuel decay rates, which, in turn, would reduce fire hazard in the young forest setting.

Felling young conifers in and around aspen stems or clones in Units 1, 2, 7, 9, 11, and 12 would reduce current and future conifer competition and allow the clone to persist in a healthy state longer than untreated clones. Prescribed fire would further reduce competition and stimulate aspen suckering to create an additional age class in the clone. Aspen in Units 6, 8, and 13 would benefit from conifer reduction only if aerially ignited fire moved into or adjacent to the clone. Based on Forest Vegetation Simulator -simulated growth after the prescribed burn, most lodgepole pine stands near the end of the rotation would have a moderate to high hazard rating for mountain pine beetle. Sparsely stocked areas would have a low mountain pine beetle susceptibility due to low basal area (20 to 50 square feet per acre) of the trees that are generally greater than 7 inches diameter. Douglas-fir within the 1988 Canyon Creek fire footprint would have variable hazard ratings for Douglas- fir beetle, but the general trend is moderate hazard. On productive sites Douglas-fir beetle hazard may start trending toward high. Overall, lower stand densities in Douglas-fir stands would keep the hazard low to moderate. Implementation of the project would not create a barrier to bark beetle movement through the project area should an outbreak occur in the future. Western spruce budworm defoliation, similar to Alternative 1, would continue to be an issue in areas containing multi-storied stands during outbreak years.

Cumulative Effects Past actions in the analysis area have created the vegetation conditions currently present. The stand- replacement Canyon Creek fire in 1988 triggered regeneration which currently is of variable density. There are no present or reasonably foreseeable actions that would cumulatively effect the forest vegetation.

Statutory and Regulatory Consistency Table 19: Summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 19: Summary of Statutory and Regulatory Consistency – Vegetation. Regulatory Requirement Project Consistency 1974 Forest and Rangeland Renewable Management Area O is within the regulated timber base. Resources Planning Act, as amended by the Lands classified as commercial (LSC = 500) within this 1976 National Forest Management Act: It is the management area would be considered as producing timber policy of Congress that all forested lands in the suitable for harvest. Suitable timber is available on about 523 National Forest System be maintained in acres in treatment units 9, 10, 11, 12, and 13. A majority of appropriate forest cover with species of trees, suitable land in Unit 12 occurs as mature timber that would degree of stocking, rate of growth, and conditions not be treated with the proposed action alternative. Post- of stand designed to secure the maximum treatment stocking surveys would be completed on these benefits of multiple use sustained yield acres to determine regeneration condition (species management in accordance with land composition, density, growth rate, and overall health). management plans. A report shall be compiled Natural regeneration certification would be evaluated based annually, based on examinations, of all lands in on the silvicultural prescriptions designed to meet the National Forest System where objectives of management objectives. Walk-through surveys would also land management plans indicate the need to occur on a sample of non-suitable lands to determine natural reforest areas that have been cut-over or regeneration outcome following treatment. Tree species otherwise denuded or deforested. Treated lands currently present in treatment units should naturally shall be examined after the first and third growing regenerate following treatment. Stand densities would be seasons and certified as to stocking rate, growth variable and generally less than pre-treatment conditions. rate, and other pertinent measures. Lands not

Regulatory Requirement Project Consistency certified would be returned to the backlog and However, a forested condition would still exist following scheduled for prompt treatment. implementation of the selected alternative. Lands classified as commercial (LSC = 500) within Management Areas O and R would be part of the Forest’s 1974 Forest and Rangeland Renewable suitable timber base. Because classification was incomplete Resources Planning Act, as amended by the for the project area, a classification exercise using the best 1976 National Forest Management Act: Forest available data was completed in 2014 to facilitate analysis of Plans would be developed to identify the this project. Although Management Area O is spatially suitability of lands for resource management; mapped, there is no spatial layer available for Management provide for the diversity of plant and animal Area R. The land suitability classification information is part communities based on the suitability and of the spatial (geographic information system) project record. capability of land areas to meet multiple-use Suitable timber in Management Area O was calculated to be objectives; and where appropriate, to the degree 900 and 523 acres in the project area and treatment units, practicable, preserve the diversity of tree species respectively. Commercial land is denoted on 6,778 and 2,997 similar to that existing in the planning area. acres across the project area and treatment units. Tree species currently present in the project area should naturally regenerate following treatment.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards and management area direction relevant to forest vegetation is available in Appendix E. Sensitive Plants The Sensitive Plants Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019), the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 95 to 102) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to sensitive plant resources. The treatment effects are as originally analyzed and there are no changes to the sensitive plants portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 63 to 69).

Existing Condition Forest Service sensitive species are defined as “[t]hose plant and animal species identified by a regional forester for which population viability is a concern, as evidenced by: a) significant current or predicted downward trends in population numbers or density or b) significant current or predicted downward trends in habitat capability that would reduce a species’ existing distribution” (USDA Forest Service 2005). Regional Foresters are delegated the authority to designate sensitive plant species based on the definition above (USDA FS 2005). There are currently 25 designated sensitive plant species that either occur or are suspected to occur on the Lewis and Clark side of the Helena - Lewis and Clark National Forest. The list of sensitive species, their habitat requirements, and a determination to either include or exclude a plant from analysis is provided in Appendix A of the sensitive plants resource report found in the Project Record. Sparrow’s-egg lady’s-slipper, Lackschewitz’ fleabane, whitebark pine, round-leaved orchis, and small yellow lady’s-slipper are analyzed in this analysis.

Sparrow’s-Egg Lady’s Slipper Sparrow’s-egg lady’s-slipper is known to occur in the northwest corner of Montana on the Lewis and Clark, Flathead, and Kootenai National Forests (BONAP 2016; MNHP 2016b; Shelly 1988a). Occurrences on the Rocky Mountain Ranger District are located in Blacktail Gulch, Green Timber Basin, Dry Fork Lange Creek, Leavitt Creek, North Fork Birch Creek, Clary Coulee, and Straight Creek with population size between 14 and 100 plants. Sparrow’s-egg lady’s-slipper grows in moist, mossy, seepage areas; riparian zones; and in ecotonal margins of sphagnum bogs, often in full or partial shade of conifers. Although spruce is the preferred habitat, it would grow in association with lodgepole pine (MNHP 2016b; Shelly 1988a). In a monitoring summary written by Dana Fields (1993), it was noted that sparrow’s-egg lady’s- slipper is “[o]ne of the rarest orchids in the Front Range, having a very narrow range of habitat requirements. These requirements include limestone substrate, cool sites at mid-elevations, seeps or springs, a moderate amount of rotting wood on the forest floor, and at least partial shade. Even where these requirements are met the plant is uncommon.” The most important feature at every site appears to be semi-permanent water seepage near the surface. According to the Montana Natural Heritage Program, there are 51 occurrences (MNHP 2016b; Shelly 1988a). Round-leaved orchis, small yellow lady’s-slipper, and sparrow’s-egg lady’s-slipper often co-occur. However, sparrow’s egg lady’s-slipper has a narrower range of habitat (USDA Forest Service 2016; Shelly 1988a; Vanderhorst 1996). Threats to the species include impediment or reduction of groundwater flow, noxious weed establishment, grazing, road construction, and timber harvest. The main threat to the species appears to be from potential hydrologic changes at population sites (MNHP 2016b; Vanderhorst 1996). In 2013, approximately 10 sparrow’s-egg lady’s-slipper plants were located along the bank of Cyanide Creek between Units 12 and 14. Cyanide Creek trail 257 crosses the drainage at this location. Plants were growing in the densely stocked willow drainage bottom immediately adjacent to flowing water at about 5,350 feet elevation. The drainage was unburned during the 1988 Canyon Creek fire. Slopes adjacent to the drainage contain seedling and sapling lodgepole pine and a small patch of unburned, mature Douglas-fir. The population is about 55 feet and 100 feet away from the edge of Unit 12 and 14, respectively.

Lackschewitz’ Fleabane Lackschewitz’ fleabane is a Montana endemic known to occur on the Helena - Lewis and Clark, Flathead, and Beaverhead-Deerlodge National Forests (BONAP 2016; MNHP 2016b). Based on the Montana Natural Heritage Program (2016b), Montana currently supports about 37 occurrences with a majority (73 percent) located on the Helena - Lewis and Clark National Forest. Populations are documented at Crown Mountain, Steamboat Lookout, Mount Wright, Headquarters Creek Pass, Sock Lake, Corrugate Ridge, Mount Patrick Gass, Our Lake, Teton Ski Area Peak, Washboard Reef, and Volcano Reef (Heidel 1993; MNHP 2016a). Fleabane grows exclusively in exposed, windy, alpine settings with water-retaining calcareous soil derived from a dolomite substrate (Heidel 1993). According to Heidel (1993), Lackschewitz’ fleabane “grows on midslope settings often between scree and toeslope turf, or on gentle but highly exposed slope crests and ridges.” Fleabane generally grows in association with but not among mats of white dryas, kinnikinnick (Arctostaphylos uva-ursi), and curly sedge (Carex rupestris). On the driest sites (barren slopes) only trace amounts of the species are present. On the wettest sites, fleabane grows in dense sedge sod with high forb diversity (Heidel 1993). Due to the species’ high elevation,

alpine habitat requirements, there is a low potential for detrimental impacts from human disturbance or management actions (Heidel 1993; MNHP 2016b; Nature Serve 2016). Non-motorized trails in proximity to known populations have not posed a threat to population stability (Heidel 1993). Lackschewitz’ fleabane is known to occur at 8,400 feet elevation along the Steamboat Lookout Trail near Steamboat Mountain. The population, covering less than eight acres, is on a south-facing scree slope southwest of Unit 8. There are no other known occurrences of fleabane in the project area, and suitable habitat occurs outside of treatment units.

Whitebark Pine Whitebark pine is a long-lived species that is most commonly found as a major seral species on upper alpine sites. The average lifespan is 400 years with the oldest tree recorded near 1,300 years (Keane and Parsons 2010). At the highest forest elevations or alpine sites, whitebark persists as a climax species in a krummholz form (Keane and Parsons 2010, Tomback et al. 2001, Tomback et al. 2011). At its lower elevations, whitebark competes with lodgepole pine. The species generally occurs within a narrow elevation range (Tomback et al. 2011). Whitebark pine starts producing cones at age 30 to 60, but a quality cone crop is dependent upon good canopy volume, which occurs between 125 and 250 years of age. Cone crop frequency is about every three to five years (Keane et al. 2012). Clark’s nutcracker, the primary seed dispersal mechanism for whitebark, can transport and cache seeds up to 10 kilometers (Keane and Parsons 2010; Keane et al. 2012). Fire, ranging from small and isolated to large and stand- replacing, is the primary disturbance factor in this forest community that renews the species. Mixed- severity fire, occurring at 60 to 300-year intervals, is the most common whitebark pine fire regime that creates a diverse landscape pattern favorable for whitebark establishment. In the absence of fire, whitebark pine is eventually replaced by shade-tolerant species (Keane and Parsons 2010; Keane et al. 2012). Based on information provided to the U.S. Fish and Wildlife Service, the major threats to whitebark pine’s survival across its distribution range are fire suppression, climate change, white pine blister rust, and mountain pine beetle (Federal Register 2011). Whitebark pine is known to occur in the project area from field observations and Region 1 VMAP. The species grows along the Scapegoat Wilderness boundary; in the Whitewater and Petty Creek area southwest of the Petty Ford Creek National Recreation Trail 244; and in Township 18 North, Range 8 West, Sections 2 through 5 around Horse Mountain. Although in many locations whitebark and limber pine habitat is defined by elevation, these five-needle species can share the same habitat on the Rocky Mountain Front. Limber pine is typically found on limestone soils of the entisol soil order, while whitebark typically grows on inceptisol soils (USDA Forest Service 1965). Based on elevation, soils information, and field review, it has been determined that the vast majority of five-needle pine seedlings and saplings growing within treatment units is limber pine. However, without cones, pollen, or an adjacent mature stand, it is very difficult to distinguish between the species. Five-needle pine density is very low with less than 10 trees per acre present in isolated areas.

Round-Leaved Orchis In Montana, round-leaved orchis occurrences have been noted in the Rocky Mountain Front, Bob Marshall Wilderness Complex, Swan Valley, and the northwest corner of the state. On the Rocky Mountain Front, it generally occurs around mossy seeps, sphagnum bogs, ponds, or along streams in

wet to moist spruce forests where there is at least partial shade from the overstory (MNHP 2016a; Schassberger 1988; Shelly 1988b). One of the most important features at almost all sites on the Helena - Lewis and Clark appears to be semi-permanent water seepage near the surface, which protects the plants roots (Shelly 1988b). Sparrow’s-egg lady’s-slipper may be found in association with round-leaved orchis. Threats to the species include grazing, recreation activities, timber harvesting, road construction, and wildfire. Although information is lacking concerning plant response to activities and disturbances, round-leaved orchis’ specialized habitat requirements indicate that it would not respond favorably to activities that alter the site’s water regime or overstory (Schassberger 1988). Although potentially suitable habitat may occur in the project area, no plants were found during field surveys.

Small Yellow Lady’s Slipper Small yellow lady’s-slipper is a widespread, but sparsely occurring variety of Cypripedium. Although the species is found primarily in northwestern Montana, there are occurrences in central and south-central Montana (BONAP 2016; MNHP 2016a). The largest populations on public land are on the Kootenai, Flathead, and especially the Rocky Mountain Front Range on the Helena - Lewis and Clark National Forest (Vanderhorst 1996). The Forest contains 12 yellow lady’s-slipper occurrences in the North Fork Sun River area between Gibson Reservoir and the eastern Forest boundary. Many times small yellow lady’s-slipper grows together with sparrow’s-egg lady’s-slipper and round-leaved orchis (Vanderhorst 1996). The species grows along ecotonal margins of spruce habitat types (damp mossy woods) with wetland features, such as fens, seeps, springs, streamsides from the valley to lower montane zone (MNHP 2016b; Vanderhorst 1996). According to Vanderhorst (1996), “this species has been found to grow in less typical habitats such as aspen stands, Douglas-fir habitat types, brushy river bottoms, willow stringers, and disturbed roadsides with other wet site plants.” Habitat is generally associated with high water table features that provide stable, cool, groundwater discharge to meet the species moisture requirements (Vanderhorst 1996). The greatest threat to population survival appears to be activities, which impede or reduce groundwater flow at population sites (Vanderhorst 1996). Although small yellow lady’s-slipper was not located during field surveys of the project area, there is a potential for suitable habitat to occur at the north end of Unit 12 and near the sparrow’s-egg lady’s-slipper occurrence in Cyanide Creek. Noxious weed species such as houndstongue (Cynoglossum officinale), leafy spurge (Euphorbia esula), spotted knapweed (Centauria maculosa), Canada thistle (Cirsium arvense), and Dalmatian toadflax (Linaria dalmatica) are documented along Elk Creek in or adjacent to treatment units 7, 9, 11, and 12 (Enterprise Data Warehouse). The Rocky Mountain Ranger District has an active invasive species education, prevention, and control program to reduce the impacts of invasive plant species.

Environmental Consequences

Methodology

Spatial & Temporal Scale The geographic analysis area for direct, indirect, and cumulative effects for this proposal is the project boundary since potential impacts are minimal or beneficial. The temporal length of this analysis is 1 to

10 years because it reflects immediate effect of the prescribed fire on sensitive plants and the time needed for post-fire whitebark germination and seedling survival (Tomback et al. 1993).

Sources, Methods, and Assumptions The effects analysis is based on known sensitive plant occurrences, as provided by the Montana Natural Heritage Program (MNHP 2016a; MNHP 2016b) and the Lewis and Clark National Forest plant atlas, and on potential habitat based on current site conditions. A preliminary analysis of the project area to determine potential habitat was conducted using information available from color aerial photography (National Agriculture Imagery Program), topographic and landtype maps, Region 1 Existing Vegetation Map Products (R1VMap – Version 12.1 and 14), Montana Natural Heritage Program field guides and geographic information system (GIS) coverages, the inventory of known plant populations, the draft sensitive plant species viability report for the Lewis and Clark (USDA Forest Service 2016), and various Geographic coverages (including an electronic version of the sensitive plant atlas) and analysis tools. Habitat requirements for each of the sensitive plant species was compared with habitat occurring in the analysis area. A field survey of probable locations was conducted in 2013.

Past, Present, and Reasonably Foreseeable Future Activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available in Appendix D. Past activities that occurred within the project area have created the vegetation conditions discussed in the Existing Condition section. No present or reasonably foreseeable activities would impact sensitive plants.

No Action Alternative Under this alternative, Alternative 1, no new actions are proposed. Existing management activities and natural processes would continue in the area.

Direct and Indirect Effects Under the No Action Alternative, sensitive plants would continue to grow where they are currently found. The greatest threat to the identified sparrow’s-egg lady’s-slipper population would be a shift in the stream channel that could remove the plant. Although stream channels are dynamic, no change in the system is predicted at this time. A similar threat would occur for potential yellow lady’s-slipper and round-leaved orchis habitat. These species would generally be protected from wildfire given their wet, riparian habitat preferences. Lackschewitz’s fleabane’s preference for high elevation, exposed, typically talus habitat leaves it generally immune to impacts from natural processes, such as fire. The greatest threat to the population is from foot and equestrian use of the Steamboat Lookout Trail 257. However, population monitoring information (Heidel 1993) indicates that trail use has not previously impacted fleabane populations on the Rocky Mountain Front. Wildfire, mountain pine beetle, and white pine blister rust would continue to threaten whitebark pine in the project area. Although wildfire could directly and indirectly kill trees, it also has the ability to create favorable sites for seed caching if adequate mature, seed-bearing whitebark (20 to 50 trees per acre) are

within 10 miles of the fire (Keane et al. 2012). Mountain pine beetle activity has not been a substantial source of pine mortality since 2009 and 2010. However, endemic activity could kill an incidental quantity of mature (greater than 5-inches diameter-at-breast-height) pine each year. White pine blister rust infection would continue to damage and kill whitebark of all sizes. Implementation of the No Action Alternative would have no impact upon sensitive plant species in treatment units. Insects and disease may lead to the decline of whitebark pine, but wildfire and the creation of caching sites could benefit the species if cone-bearing trees are present.

Cumulative Effects The No Action Alternative, in conjunction with past, present, and reasonably foreseeable activities, would not produce cumulative effects to sensitive plant species.

Proposed Action Under the proposed action, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented as described in Appendix B.

Direct and Indirect Effects Implementation of the project should have minimal negative effects for sensitive plant species. The project is designed to have a no-ignition buffer within 200 feet of streams to preserve riparian vegetation and maintain a vegetated buffer. In addition, a 50- to 100-foot (slope dependent) buffer around wetlands and springs would provide additional protection of undiscovered sparrow’s-egg and yellow lady’s-slipper and round-leaved orchis populations or potentially suitable habitat. Although fire may back into these buffers, fire intensity and area impacted should be minimal. Neither tree slashing nor prescribed fire would alter hydrologic processes, the greatest threat to these species. The sparrow’s-egg lady’s-slipper population is surrounded by a variety of vegetation conditions. The population itself is growing in relatively dense, shrubby riparian vegetation adjacent to flowing water. To the west (east side of Unit 12), the hillside is generally sparsely stocked with conifer which would not support a high-intensity fire moving into the riparian area. Mature timber and heavy regeneration occur to the south (northwest side of Unit 14) of the population. Treatments are designed to avoid ignition within mature (greater than 8-inches diameter-at-breast-height) conifer stands greater than five acres. Therefore, ignition would not occur in Unit 14 closest to the lady’s-slipper population, and the defined treatment unit boundary should keep fire away from the population. Incidental whitebark seedlings and saplings may be killed during burning, however, impact to the overall whitebark population in the project area would be limited in scope. Implementation of the project should have no impact upon mature, cone-bearing whitebark individuals or stands since these resources are located outside of treatment units. Seedlings and saplings may be removed if they are within target burn areas, which may vary during implementation based on vegetation condition, wind direction, wind speed, moisture, and other variable parameters at the time of the burn. Mixed-severity or stand- replacement prescribed fire would remove competing vegetation (dense lodgepole) and create favorable nutcracker cone caching sites for whitebark seed “[s]ince nutcrackers often prefer open sites with many visual cues for seed caching (Keane et al. 2012).” The availability of cones and subsequent

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regeneration, however, is dependent upon cone productivity in the face of blister rust damage and mortality (need 20 to 50 cone-bearing trees per acre to provide a good seed source) and nutcrackers reclaiming cone caches (Keane and Pearsons 2010; Keane et al. 2012). Although whitebark should germinate within the first one to two years after the fire, germination may be delayed for five to seven years (Tomback et al. 1993). Lodgepole regeneration may directly compete for resources with the more slow-growing whitebark depending upon the post-fire regeneration distribution. Lackschewitz’ fleabane occupies a site at least 1,500 feet upslope from the northern boundary of Unit 8. Due to its high elevation, exposed habitat preference between scree and toeslope turf, there is no potential for application of fire in Unit 8 to move into fleabane’s occupied habitat. Implementation of the project would have no impact upon Lackschewitz’ fleabane. Invasive (noxious) plants are strong competitors with native vegetation and are most likely to establish in disturbed locations. Fire has the potential to create bare soil favorable for rapid noxious weed establishment. Field crews and their associated equipment also have the ability to transport noxious weed seed and plant material into disturbed areas, especially where weed seed sources are readily available. Noxious weed establishment and the associated competition can have a long-term negative effect on sensitive plants and potential sensitive plant habitat. Noxious weeds do not currently threaten sensitive plant populations in the project area. Implementation of project design features, such as inspecting and disposing of all weed seed and plant parts found on crew clothing and equipment and pre-treating weed populations along travel routes used to access treatment units (Appendix C), should substantially reduce or eliminate movement of noxious weeds into sensitive plant habitat.

Cumulative Effects There are no past, present, or reasonably foreseeable actions that in combination with implementation of Alternative 2 would produce cumulative effects to sensitive plant populations or habitat.

Determination of Effects Implementation of the Elk Smith Project as proposed in Alternative 2 would have no impact (NI) upon sensitive plant species listed for the Lewis and Clark side of the Helena – Lewis and Clark National Forest with the exception of whitebark pine. The project may cause incidental loss of whitebark pine seedlings and saplings within prescribed burn areas, but would also create favorable nutcracker cone caching sites beneficial to the species (MIIH – may impact individuals or habitat; BI – beneficial impact).

Statutory and Regulatory Consistency Table 20: Summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 20: Summary of Statutory and Regulatory Consistency – Sensitive Plants. Regulatory Requirement Project Consistency

Forest Service Manual – 2670.32: This section of the document also constitutes as the biological evaluation for sensitive plant species. Although (1) Review programs and activities as part of the implementation of the project may cause incidental loss of National Environmental Policy Act of 1969 whitebark pine seedlings and saplings, there would be an process through a biological evaluation to overall beneficial impact to the species within the project area

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Regulatory Requirement Project Consistency determine their potential effect on sensitive as favorable nutcracker cone caching sites are created. species. Implementation of the project would have no impact upon the (2) Avoid or minimize impacts to species whose other designated sensitive plant species. viability has been identified as a concern. (3) Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole. Although implementation of the project may cause incidental Forest Service Manual 2672.41: Ensure that loss of whitebark pine seedlings and saplings, there would be Forest Service actions do not contribute to loss of an overall beneficial impact to the species within the project viability of any native or desired non-native plant area as favorable nutcracker cone caching sites are created. or contribute to trends toward Federal listing of Implementation of the project would have no impact upon the any species. other designated sensitive plant species.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is summarized in Appendix E. Range The Range Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019) the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 102 to 104) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to range resources. The treatment effects are as originally analyzed and there are no changes to the range portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 70 to 71).

Existing Condition There are four livestock allotments and one administrative horse pasture within the project area. • Elk Creek C&H allotment – 92 yearlings for 62 days between 7/1 and 10/1. • Steamboat C&H allotment – 85 cow/calf pairs for 34-62 days between 7/6 and 9/20 (currently vacant). • Cyanide Creek C&H allotment – 60 cow/calf pairs for 46 days between 7/1 and 9/30. • Smith Creek C&H allotment – 202 cow/calf pairs for 46 days between 7/1 and 9/30. • Elk Creek Administrative pasture. – Variable numbers, variable season. Used as needed, not to exceed 90 head months of use.

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Environmental Consequences

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary. The cumulative effects section extends to include grazing allotments within the project boundary. Temporally speaking, short- term effects are defined as 0 to 10 years. Long-term effects are considered to be greater than 10 years.

Sources, Methods, and Assumptions The methodology used in this analysis includes data from Forest Service files and databases. Geographic information systems were used to understand spatial relationship of grazing allotments to project units. The following assumption were made regarding this analysis: livestock grazing will continue.

Past, Present, and Reasonably Foreseeable Future activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available Appendix D. Activities which may have a cumulative effect are described below. • Wildfire • Personal Use Forest Products (firewood, Christmas trees, etc.) • Noxious Weed Treatment • Road Access and maintenance • Recreational use (fishing, hiking, hunting, dispersed camping, etc.) • Prescribed fire/fuels reduction • Timber harvest on adjacent private lands

No Action Alternative

Direct and Indirect Effects Natural openings and meadows that currently provide forage for wildlife and livestock would continue to see declines in grass and forb production as a result of natural maturation of existing timber and continued encroachment of young conifers. This can result in over utilization of available forage if adjustments are not made when monitoring indicates a need for change. This is a process that takes place over decades.

Proposed Action Under the proposed action alternative, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented as previously described.

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Direct and Indirect Effects The majority of the treatments within the project area are targeting dense stands of lodgepole pine regeneration. These stands do not contribute to the available forage for livestock and due to their locations it is not anticipated that they would be utilized after treatment (units 3-5, 6, 8, 10 and 12-15). Coordination with permittees would be needed although many units would not affect livestock grazing. Units targeted for hand slashing and burning have aspen stands and meadows (with conifer encroachment) targeted for restoration. These treatments would have a positive effect on the available forage in areas accessible to livestock (Units 1, 2, 7, 9 and 11). Coordination with grazing permittees would be necessary to provide for protection of fine fuels to carry fire and to provide rest post burn. This would only be a concern for Units 1 and 2 as 7, 9, 11 are in the vacant Steamboat allotment or the Forest Service administrative pasture. Over time, conifer encroachment within the aspen stands and meadows would return and increased forage, because of the project would decline. No increases in permitted use would be made due to the project.

Cumulative Effects Livestock grazing has occurred in the project area alongside other activities since settlement. Large scale wildfire has the most potential to affect livestock grazing. These effects are generally short-term one to two growing seasons to allow for recovery of forage species.

Forest Plan Consistency Site specific management direction for the allotments within the project area is provided in the Sun Canyon Range Analysis, June 1997. The Sun Canyon Range Analysis was prepared and implemented to meet the Lewis and Clark Forest’s Land Management Plan. Noxious Weeds/Invasive Plants The Noxious Weeds/Invasive Plants Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019) the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 104 to 108) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to noxious weeds/invasive plants resources. The treatment effects are as originally analyzed and there are no changes to the noxious weeds/invasive plants portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 72 to 75).

Existing Condition There is approximately 103 acres of inventoried noxious weeds within the Elk Smith project area. The vast majority of those acres are on the Elk Creek side of the project and within the District’s Administrative horse pasture. Invasive species known to occur within the project include Canada thistle (Cirsium arvense) 0.8 acres, leafy spurge (Euphorbia esula) 32.7 acres, spotted knapweed (Centaurea stoebe ssp. micranthos) 12.4 acres, Sulphur cinquefoil (Potentilla recta) 0.1 acres, oxeye daisy (Leucanthemum vulgare) 2.0 acres, Dalmatian toadflax (Linaria dalmatica) 0.1 acres, and Houndstongue

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(Cynoglossum officinale) 54.8 acres. Inventory acres were pulled from the Forest Service’s Natural Resource Information System database in the spring of 2019.

Treatment of noxious weeds on lands managed by the Helena-Lewis and Clark National Forest is accomplished through the use of integrated weed management. Herbicides, biological and mechanical control methodologies are applied where appropriate. The following is total acres treated within the project area for the last five years. Treatment data was compiled from the Forest Service Activity Tracking System database invasive treatments (July 2016).

Table 21: Noxious Weed Treatment Year Acres Treated

2018 8.4 2017 91.9 2016 90.3 2015 14.6 2014 91.6 2013 94 2012 0 2011 75

Environmental Consequences

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary. The cumulative effects section extends to include National Forest lands within the project boundary. The analysis area was chosen due to the fact that the Forest has no jurisdiction or control over noxious weeds on State or private lands. Temporally speaking, short-term effects are defined as 0 to 10 years; this would cover the period of initial vegetative response triggered by project implementation. Long-term effects are considered to be 10 years and beyond.

Sources, Methods, and Assumptions The methodology used in this analysis includes data from the Natural Resource Information System and Forest Service Activity Tracking System databases. Geographic information systems were used to understand spatial relation of noxious weed inventory to project units. The following assumptions were made regarding analysis: Noxious weed treatment would continue to occur within the project area.

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Forest Service Risk Assessment Factors and Risk Ratings Procedure

Table 22: Forest Service Risk Assessment Factors. Risk Assessment Factors Factor 1: Likelihood of Undesirable Plant Species, Including Noxious Weed Species, Spreading into the Project Area: Undesirable plants, including noxious weed species not located within or NONE (0) immediately adjacent to the project area. Project activity is not likely to result in the establishment of undesirable weed species in the project area. Undesirable plant species present in areas adjacent to but no within the project LOW (1) area. Project activities can be implemented and prevent the spread of undesirable plants into the project area. Undesirable plant species located immediately adjacent to or within the project area. Project activities are likely to result in some areas becoming infested with MODERATE (5) undesirable plant species even when preventative management action is followed. Control measures are essential to prevent the spread of undesirable plants or noxious weeds within the project area. Heavy infestations of undesirable plants are located within or immediately adjacent to the project area. Projects activities, even with preventative management actions, HIGH (10) are likely to result in the establishment and spread of undesirable plant on disturbed site throughout much of the project area. Factor 2: Consequences of Undesirable Plant Establishment in Project Area. LOW to NON-EXISTENT None. No cumulative effects expected. (1) Possible adverse effects on site and possible expansion of infestation within project MODERATE (5) area. Cumulative effects on native plant communities are likely, but limited. Obvious adverse effects within the project area and probable expansion of HIGH (10) undesirable plants, including noxious weed infestations to area outside the project area. Adverse cumulative effects on native plant community are probable.

Risk Rating Identify level of likelihood and consequences of adverse effects and assign values according to the following: None – 0; Low – 1; Moderate – 5; High – 10 Multiply level of likelihood by the consequences. Use the results in this step to determine the risk rating and action as follows in Table 23.

Table 23: Values, risk rating and action for noxious weed infestations in the project area. Value Risk Action Rating 0 None Proceed as planned. Proceed as planned. Initiate control treatments on undesirable plant populations that 1 – 10 Low get established in the area. Develop preventative management measures for the proposed project to reduce the risk of introduction of spread of undesirable plants in the area. Preventative management measures should include modifying the project to include seeding the 25 Moderate area to occupy disturbed sites with desirable species. Monitoring area for at least three consecutive years and provide for control of newly established populations of undesirable plants and follow-up treatment for previously treated infestations.

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Value Risk Action Rating Project must be modified to reduce risk level through preventative management measures, including seeding with desirable species to occupy disturbed sites and controlling existing infestations of undesirable plants prior to project activity. Projects 50 – 100 High must provide at least five consecutive years of monitoring. Projects must also provide for control of newly established populations of undesirable plants and follow- up treatment for previously treated infestations

No Action Alternative

Direct and Indirect Effects Noxious weeds would continue to be treated and spread at the current rate. If no action is taken, the risk of a large fire that burns more acres and at higher severity primarily due to more severe fire effects on soils are likely in the future. Large scale stand replacement fires would produce large areas of soils that experience high burn severity which would be more susceptible to noxious weed expansion/infestation.

Cumulative Effects There would be no cumulative impact under the no action alternative.

Proposed Action

Direct and Indirect Effects Prescribed fire and hand slashing both have the potential to cause expansion of existing noxious weeds infestations and create site conditions favorable to new infestations. However, the project design criteria and resource protection measures prescribed for this project would create conditions that would limit expansion of existing infestations and help prevent new ones. The project is designed to break up continuous fuels to reduce the potential for large-scale stand replacement fire as occurred in 1988. Implementation of prescribed fire treatments to create burned patches of approximately 20-100 acres are designed to break up the continuous fuels which now exist. Treatments are intended to replicate natural reburning and produce low to moderate fire effects. Burning windows are also planned to have fires which burn less intensely. Hand slashing and burning within Units 9 and 11 are largely to treat and enhance aspen stands. This would have a positive effect on aspen as well as non-woody vegetation production within these stands. Increased non-woody vegetative growth within these stands would help to reduce bare ground, which would make the stands more resistant to noxious weed expansion/infestation. Forage production for all large ungulates (wild and domestic) would be a temporary indirect effect of this project. Any increases in forage production would decrease in time as conifer growth and encroachment continues. Using the Northern Region Risk Assessment Rating Procedure, this proposal would have a moderate likelihood of noxious weeds expanding within the project area because of infestations currently within the project area. The project would also receive a rating of moderate for the consequences of noxious weed establishment. When combined, these two risk assessment factors result in the project having an

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overall rating of moderate risk. Based on the overall rating of moderate noxious weed design features (4-9 listed in Chapter 2 and in Appendix C) would be implemented to reduce the risk of introduction of spread of undesirable plants in the area. Preventative management measures should include modifying the project to include seeding the area to occupy disturbed sites with desirable species. Monitoring the area for at least three consecutive years and provide for control of newly established populations of undesirable plants and follow-up treatment for previously treated infestations.

Cumulative Effects Past present and foreseeable activities number 2, 3, 5, 6 and 8 listed in Appendix D all have the same effect as they represent the most common activities to introduce and spread noxious weeds on the landscape. It is foreseeable that all these activities would continue within the project area. The result of implementation of the Elk Smith Project and the resulting improved vegetative conditions as well as reduced chance of large stand replacement fires would reduce the cumulative impact of those activities from the current conditions.

Statutory and Regulatory Consistency

Table 24: Summary of Statutory and Regulatory Consistency – Noxious Weeds. Regulatory Requirement Project Consistency Forest Service Manual (FSM) 2900 requires that all forest management activities are designed to minimize or eliminate the possibility of See Appendix C: Project Design Features establishment or spread of invasive species on National Forest System lands, or to adjacent areas.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in Appendix E.

Summary Both the no action and proposed action alternatives would result in a moderate rating because of the current level of noxious weed infestations within portions of the project area. The project is designed to improve vegetative conditions and reduce the potential for large stand replacement fires. Both of these outcomes would help in making the project area more resistant to expansion and infestation of noxious weeds. Additionally, the project Design Features for this project would be implemented to reduce the chance of expanding current infestations and introduction of new infestations during project implementation. Continued monitoring and application of the Rocky Mountain Ranger District Invasive Plant Management Strategy for all alternatives would be required to suppress and control current infestations and provide for early detection and rapid response to new infestations. Soils The Soils Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019) the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 108 to 117) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the

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treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to soils resources. The treatment effects are as originally analyzed and there are no changes to the soils portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 76 to 84). Existing Condition Soils, Landforms, and Geology Project area geology, landforms, and soils are diverse (Table 25). The majority of the soils in the proposed units have formed from sandstone and shale on steeper slopes. Surface textures are predominately loams.

Table 25: Landform, soils, geology, and sediment delivery by landtype for proposed treatment units. Off Site Sediment Sediment Landtype Units Acres Landform Soils Slope Geology Texture Delivery Pollution Efficiency Hazard - Fires Typic and Glacial drift 10- 13A 12 85.5 Argic Undifferentiated Loam Low Low deposits 25% Cryoborolls 5, 6, 7, Glacial drift Andic 10- Silt 21 8, 10, 940.5 Undifferentiated Low Low deposits Cryochrepts 25% loam 12 2, 3, 4, Steep, drift 10, 11, Andic 25- Sandstone and Silt 21A 1161.6 plastered Low Low 12, 13, Cryochrepts 40% shale loam trough walls 14 2, 3, 4, Typic and 5, 6, 7, Steep valley 25- Sandstone and 71A 2468.7 Andic Loam Low Low 11, 12, sideslopes 60% shale Cryochrepts 13 Argic 1, 3, 4, Low relief Cryoborolls- 10- Sandstone and 161 7, 8, 9, 1893.9 ridges and Loam Low Low Typic 40% shale 11, 12 slopes Cryochrepts 2, 3, 7, Very steep Rockland- 9, 11, 182 445.2 glacial Typic 60% + Limestone Loam Moderate Moderate 12, 13, breaks Cryochrepts 14 3, 4, 5, 6, 7, 8, Very steep Rockland- All non- 183 9, 10, 2898.2 peaks-upper Typic 60% + carbonaceous Loam Low Moderate 12, 14, slopes Cryochrepts rocks 15 7, 9, Well drained Fluvents and 200 103.8 0-10% Undifferentiated Clay Low Low 11, 12 floodplain Borolls 3, 4, 8, Rockland- 202 10, 12, 331.1 Rockland 60% + Limestone Loam Low Low limestone 14, 15 The Soil Resource Inventory for the Lewis and Clark National Forest (Holdorf 1981) was used to determine hazard ratings for the proposed treatment units. Hazard ratings for sediment delivery efficiency and off site sediment pollution due to fires were for landtypes occurring within proposed treatment units that equaled five or more acres. Sediment delivery efficiency ratings are based on the probability of eroded material becoming stream sediment; the ratings are based on slope and drainage density. Offsite sediment pollution hazard ratings due to fire reflect hazard before revegetation. Factors

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included in the rating determination are: a) Time required for re-establishment of protective native vegetation; b) probability of heat induced water repellency in the topsoil; c) probability of accelerated slope mass failures due to the loss of stabilizing effect of plant roots and reduced evapotranspiration rates; and d) probability of accelerated dry soil creep due to removal of the shading effect of the forest canopy. Landtypes 182 and 183 (32 percent of the area proposed for treatment) have moderate ratings due to slopes greater than 60 percent.

Existing Soil Disturbance Units 12 and 13 were each found to have detrimental soil disturbance of four percent due to past harvest activities. Disturbance in both plots was due to compaction and topsoil displacement from previous skid trails. Minor disturbance from cattle grazing was noted, but no detrimental soil disturbance from grazing was detected. In addition to past timber harvest activities and cattle grazing, the majority of the proposed treatment units have been affected by wildfire. Field visits indicate that recovery of the forest floor has occurred since the fire.

Past, Present, and Reasonably Foreseeable Future Activities Used in the Analysis Timber harvest, grazing, prescribed burns, wildfire, and recreational activity have all occurred within the Elk Smith project area with varying levels of soils impacts. With the exception of timber harvest, these activities may be ongoing within the project area. Many of these activities have had only transient impacts that are no longer visible on the landscape (low-intensity fire), or have small impact areas dispersed in isolated pockets across the landscape (grazing, recreational activity). A detailed table of past, present, and reasonably foreseeable activities in the project area can be found in Appendix D. Impacts from these activities are discussed in general terms in the cumulative effects section.

Environmental Consequences

Methodology

Spatial & Temporal Scale The spatial context for the discussion of direct, indirect, and cumulative effects of the proposed action are the proposed treatment units. Effects to soil are generally confined to the site-specific location of activities; for example, a treatment unit. With few exceptions, soil cumulative effects occur only when management activities occur on the same site. Exceptions include large mass failure and debris flows, or large sediment deposits from off-site disturbances that could affect soils in another location. Analyzing effects to soil at a landscape scale (i.e. by watershed) is inappropriate as it does not involve analyzing soil disturbance using a site-specific, activity-area approach as directed under the Northern Region Soil Quality Standards (USDA FS 1999). Additionally, due to the inherent variability of soil properties, it is not feasible to analyze past management effects on the soil at the landscape scale in a meaningful way.

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Temporal boundaries extend until soil impacts from this project are no longer discernable. Soil functions, soil physical properties, and vegetative surface cover would trend toward recovery and meet soil quality standards at the close of the project. Impacts to the soil biological community may be discernible beyond this window, but these changes are not detrimental. Soil biological properties are closely related to plant species composition, and would transition along with vegetation over time.

Sources, Methods, and Assumptions The soils analysis that follows is based on field data, geographical information system data, and modeling. The information was used to analyze effects to the soil resource from the proposed action.

Issue Indicators Issues associated with soil productivity and quality include existing detrimental soil disturbances from past and present activities as well as the potential effects from new disturbances related to proposed activities. Potential soil effects from the proposed burns are reduced surface cover, increased erosion risk, soil heating, and short-term nutrient changes from woody debris loss and ash deposition. As defined by the Region 1 Soil Quality Standards, detrimental soil disturbance includes the effects of compaction, rutting, displacement, severe burning, surface erosion, loss of surface organic matter, and soil mass movement. At least 85 percent of an activity area must have soil in satisfactory condition. An activity area is defined as: “A land area affected by a management activity to which soil quality standards are applied. Activity areas must be feasible to monitor and include harvest units within timber sale areas, prescribed burn areas, grazing areas or pastures within range allotments, riparian areas, recreation areas, and alpine areas” (USDA FS 1999). Detrimental soil conditions pertinent to this project include: • High Burn Severity: Physical and biological changes to soil resulting from high severity burns. This standard is used when evaluating prescribed fire. Guidelines for assessing fire intensity are contained in the Burned-Area Emergency Rehabilitation Handbook Forest Service Handbook 2509.13. • Detrimental Surface Erosion: Rills, gullies, pedestals, and soil deposition are all indicators of detrimental surface erosion. Minimum amounts of ground cover necessary to keep soil loss to within tolerable limits (generally less than one to two tons per acre per year) should be established locally depending on site characteristics. • Soil Mass Movement: Any soil mass movement caused by management activities is detrimental. High soil burn severity is considered detrimental soil disturbance. High burn severity is characterized by deep ash (often gray, white, or reddish in color), extensive charring, dry or brittle roots, loss of forest floor, and altered physical soil structure. Detailed definitions for soil burn severity, low-severity, moderate-severity, and high-severity can be found in Parsons et al. (2010). These terms will be used in the effects analysis. Detrimental compaction and rutting effects are not analyzed because ground based equipment associated with compaction and rutting would not be used in this project.

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Existing Soil Disturbance Existing soil disturbance indicates departure from natural conditions as a result of management activity, and may negatively affect soil productivity when detrimental. Existing detrimental soil disturbance was determined by a Forest Service soil scientist during onsite visits during the summer of 2013. The Soil Disturbance Monitoring Protocol was used to assess existing, management-caused soil disturbance in the proposed burn units (USDA FS 2009). Attributes evaluated include forest floor impacts, surface soil displacement, mixed surface soil/subsoil, rutting, burning (only management prescribed burning is assessed), compaction, and platy or massive structure. Each sample point consisted of a six-inch diameter circular area. Determinations of detrimental soil disturbance were based on the Region 1 Soil Quality Standards. Ten-point transect surveys were conducted within each unit August 2013, yielding percent estimates of detrimental soil disturbance per unit. Units that were known to have past disturbance had intensified 50-point surveys. Survey findings are reported in Table 27 of the soils section of this document.

Predicted Soil Disturbance To predict the amount of Detrimental Soil Disturbance associated with the proposed action, the following assumptions were made: • Projected detrimental soil disturbance due to severely burned soils associated with broadcast and jackpot burning is 6 percent for each proposed treatment unit. While fuel loads and specific treatments vary across the 15 proposed treatment units, it is assumed that implementation would result in mixed-severity fires with the majority being low to low-moderate intensity fires. High soil burn severity would be expected to occur in less than two percent of a low intensity fire and less than 10 percent of a moderate intensity fire (Debano et al. 1998). • Projected detrimental soil disturbance due to surface erosion is negligible within a proposed treatment unit. The Disturbed Water Erosion Prediction Project model (Elliot et al. 2000) was run to generate predicted erosion rates following implementation of the proposed action (see the Watershed report for more details on the Water Erosion Prediction Project modeling located in the project file). The highest predicted erosion rate for a unit was 0.21 tons per acre per year, which is well within the tolerable limit of one to two tons per acre per year (USDA FS 1999). These rates of erosion do not constitute detrimental soil disturbance. • Projected detrimental soil disturbance due to soil mass movement is zero. Based on hazard ratings for landtypes found within proposed treatment units, no mass movement would be expected to occur (Holdorf 1981).

No Action Alternative

Direct and Indirect Effects Natural processes would continue and no direct effects to the soil resource would occur from the no action alternative. No new management activities would occur. Ongoing activities such as firewood retrieval and dispersed camping, which can result in minor localized ground disturbance, and grazing would continue to occur. Noxious weeds would continue to be treated and spread at the current rate.

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Under the No Action alternative, accumulations of woody material would continue to increase beyond natural levels due to altered fire return interval. Uncharacteristic fuel accumulation increases risk of high severity wildfire and associated impacts including loss of ground cover and soil nutrients, erosion, and soil productivity loss.

Cumulative Effects There are no cumulative effects to soils from ongoing activities under existing conditions. Additional cumulative effects from cattle activity are not expected because: 1) no increases in cattle numbers or lengthening of the season of use would occur; 2) trailing through the units would likely use existing cattle/game trails; and 3) allotments would be monitored for compliance with established grazing standards. Cumulative effects due to other ongoing activities, such as recreation and firewood cutting, would be limited to areas where these uses overlap (i.e. grazing or firewood cutting areas are also dispersed camping sites). Effects from firewood cutting and recreational uses are localized in nature and generally minor. Existing detrimental soil disturbance from past harvests would persist (four percent detrimental soil disturbance in Units 12 and 13). Cumulative effects to soils from the no action alternative may exist in the event of a wildfire. Ground cover and nutrient losses coupled with increased erosion may cumulatively result in decreased soil productivity. These losses would be greater than those from a wildfire following post-treatment conditions from the proposed action.

Proposed Action Under the proposed action, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented as previously described.

Direct and Indirect Effects Potential direct environmental effects to the soil resource from the proposed action include severely burned soil and loss of surface layers. In general, burning may be beneficial to soils where burn temperatures are low (through a combination of low fuel loads and moist soils), fire-adapted properties are maintained where they exist, and likelihood of forest floor losses in a severe wildfire are reduced. Burn impacts are more likely to have negative effects on steep slopes and in areas with thick, dry organic horizons. In all cases, these detrimental impacts would be limited in space and intensity through the resource protection measures and would not negatively impact soil productivity in the long term. Potential indirect environmental effects of the proposed action on soil productivity include accelerated erosion as a result of loss of surface cover due to burning, and loss of soil productivity due to noxious weed spread. Resource protection measures described in the Invasive Plants section lead to a low risk of increasing the spread and density of noxious weeds. Work in burned forest soils found that 30 percent cover reduces erosion by half compared to bare soil and 60 percent cover reduced sediment movement to negligible amounts (Robichaud et al. 2000; Orr 1970; Noble 1965). Adequate surface cover and vegetative regrowth would minimize the likelihood of intolerable erosion (one to two tons per acre per year) (USDA FS 1999). Erosion rates after implementation of the proposed action were predicted to be

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0.03 to 0.21 tons per acre per year based on the Disturbed Water Erosion Prediction Project model (see Table 26). Table 26: Predicted Erosion Rates by Unit.

Average Erosion Unit Acres Land Type Slope (%) Potential (tons/Acre)

1 545.7 161 30 0.16 2 371.6 71A 30 - 40 0.09 3 1461 161, 183, 21A, 71A 10 - 45 0.10 4 1047.2 161, 183, 202, 21A, 71A 15 - 30 0.04 5 628.1 183, 71A 25 - 35 0.05 6 587.7 21, 183, 71A 15 - 30 0.14 7 748.2 21, 161, 71A 30 - 40 0.21 8 584.4 21, 161, 183 25 - 30 0.03 9 647.5 161, 183 25 - 30 0.03 10 668.56 183, 21A 25 - 30 0.15 11 472.9 161, 182, 71A 20 - 40 0.05 12 1500.4 182, 183, 71A 20 -30 0.05 13 248.6 21A, 71A 25 - 35 0.05 14 645 183, 71A 20 - 25 0.15 15 172.5 183 20 - 40 0.07

As described above in the methodology section, detrimental soil disturbance associated with the proposed action is expected to be no more than six percent from direct and indirect effects.

Cumulative Effects The cumulative impact of past and proposed treatments under the proposed action would not likely lead to long-term impairment of soil productivity, since the Region 1 Soil Quality Standard would be met. Cumulative detrimental soil disturbance is not expected to exceed 10 percent in any given treatment unit; the majority of units are predicted to have no more than six percent Detrimental Soil Disturbance (Table 27).

Timber Harvest No timber harvest has occurred within the project area since 1990. Prior to 1990, salvage logging occurred in areas associated with the 1988 Canyon Creek fire. Effects from timber harvest primarily include physical impacts such as compaction and rutting, but may also include alterations to plant community composition and nutrient cycling. These physical impacts still persist and overlap with portions of Unit 12 and 13. Disturbance values from past harvests are added with predicted disturbance from project activities to reflect cumulative soil impacts. No treatment area was predicted to exceed 15 percent detrimental soil disturbance.

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Grazing The project area overlaps with portions four livestock allotments and one administrative horse pasture. Soil disturbance associated with cattle can include compaction in areas with heavy use, churning of the soil from hoof action, reduced soil cover in areas that are heavily grazed, increased susceptibility to erosion, and direct erosion where churning occurs along streambanks. While light disturbance associated with cattle use was noted in active pastures throughout the project area, no detrimental soil disturbance from cattle was observed within treatment units. Grazing may have interacting effects with fire as it affects vegetation recovery, plant species composition changes, and susceptibility to erosion. If vegetation is not fully recovered after burning and before grazing is resumed, compaction and erosion would be exacerbated from hoof action on unprotected soil and reduced vegetation cover. In short, without sufficient resting, fire and grazing activities could interact in a way that decreases productivity and alters soil physical properties. This combined effect would be reduced by allowing sufficient plant recovery (both above and below ground) such that the effects of fire and grazing are separated in time and ground cover and root establishment is maintained.

Fires Fire effects on soil are further outlined in the discussion of direct and indirect project effects. Historically, fires occurred with greater frequency within the project area than they do today (see fire and fuels section of this document). Several fire impacts can be beneficial to plants and ecosystems, such as releases of nitrogen and other nutrients, or maintaining specific plant and microbial species compositions. Detrimental soil disturbances from fire most often occur in areas with intense burns and high levels of surface level fuels. However, site visits to the treatment areas did not encounter any locations that had been detrimentally burned, either from natural fire or from prescribed burn activities. Because the soils detrimental impacts of past fire are no longer discernable or are limited and dispersed, they are not likely to overlap in time or space with the impacts from the Elk Smith treatments. Therefore, the cumulative effects from past fires would primarily be non-detrimental soil disturbance related to maintaining fire-adapted plant and microbe communities.

Table 27: Existing, predicted, and total predicted detrimental soil disturbance by unit. Predicted Total Existing Detrimental Predicted Detrimental Soil Detrimental Unit Treatments Soil Disturbance Soil Disturbance (%) from Disturbance (%) Proposed (%) Action Slash and burn conifers encroaching on natural openings and aspen stands 1 Fell young conifers (less than 16 feet) using power 0 6 6 saws over portions of unit Broadcast and jackpot burns utilizing hand ignition Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in 2 existing aspen clones 0 6 6 Broadcast and jackpot burns utilizing hand ignition

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Predicted Total Existing Detrimental Predicted Detrimental Soil Detrimental Unit Treatments Soil Disturbance Soil Disturbance (%) from Disturbance (%) Proposed (%) Action Broadcast burn utilizing helicopter ignition 3 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 500 to 830 acres Broadcast burn utilizing helicopter ignition 4 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 314 to 525 acres Broadcast burn utilizing helicopter ignition 5 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 188 to 315 acres Broadcast burn utilizing helicopter ignition 6 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 175 to 294 acres Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in 7 existing aspen clones 0 6 6 Broadcast and jackpot burns utilizing hand ignition Broadcast burn utilizing helicopter ignition 8 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 175 to 292 acres Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in 9 existing aspen clones 0 6 6 Broadcast and jackpot burns utilizing hand ignition Broadcast burn utilizing combination of helicopter and hand ignition 10 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 202 to 337 acres Slash and burn conifers encroaching on natural 11 openings and aspen stands. 0 6 6 Broadcast and jackpot burns utilizing hand ignition Broadcast burn utilizing combination of helicopter and hand ignition 12 Reduction of 30 to 50 percent in conifer regeneration in 4 6 10 patches of 20 to 100 acres; total target acreage of 450 to 750 acres Broadcast burn utilizing combination of helicopter and hand ignition 13 Reduction of 30 to 50 percent in conifer regeneration in 4 6 10 patches of 20 to 100 acres; total target acreage of 75 to 125 acres Broadcast burn utilizing combination of helicopter and 14 0 6 6 hand ignition

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Predicted Total Existing Detrimental Predicted Detrimental Soil Detrimental Unit Treatments Soil Disturbance Soil Disturbance (%) from Disturbance (%) Proposed (%) Action Reduction of 30 to 50 percent in conifer regeneration in patches of 20 to 100 acres; total target acreage of 194 to 323 acres Broadcast burn utilizing combination of helicopter and hand ignition 15 Reduction of 30 to 50 percent in conifer regeneration in 0 6 6 patches of 20 to 100 acres; total target acreage of 52 to 87 acres

Statutory and Regulatory Consistency Table 28 below summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 28: Summary of Statutory and Regulatory Consistency – Soils. Regulatory Requirement Project Consistency Project is consistent with the Act because Project Design The Multiple-Use, Sustained-Yield Act of 1960 (P.L. 86-517, 74 Features would be implemented to minimize potential adverse Stat. 215; 16 U.S.C. 528-531). impacts to the soil resource. The Forest and Rangeland Renewable Resources Planning Project is consistent with the Act because Project Design Act (RPA) of 1974 (16 U.S.C. 1600-1614) (as amended by Features would be implemented to minimize potential adverse National Forest Management Act (NFMA) of 1976 (16 U.S.C. impacts to the soil resource. 472a). Project is consistent with the Act because Project Design Forest Service Manual 2550 Features would be implemented to minimize potential adverse impacts to the soil resource. Project is consistent with the Forest Service Manual because Forest Service Manual 2554 project would meet Northern Region Soil Quality Standards. Project is consistent with the Forest Service Handbook because Project Design Features would avoid or limit adverse Forest Service Handbook 2509.22 impacts to the soil resource and soil productivity would be maintained.

Watershed/Hydrology The Hydrology Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019) the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 117 to 126) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to Watershed/Hydrology resources. The treatment effects are as originally analyzed and there are no changes to the Watershed/Hydrology portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 85 to 92).

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Existing Condition The project area is a large diverse vegetation treatment project located along the Rocky Mountain Front range southwest of Augusta, Montana. The project area occurs within two 6th-hydrologic unit code (6th-HUC) drainages: Upper Elk Creek, and Upper Smith Creek Tributaries to the Sun River. The north half of the project area is drained by Upper Smith Creek and its tributaries (Moudess, Weasel, Star, Petty, Sixmile, and Jakie Creeks). The southern half of the project area is drained by Upper Elk Creek and its tributaries (East Fork Cyanide, Lead Gulch, Cataract, Sawmill, Horse, Bailey, Cyanide, Bunch Grass and Short Creeks). The geology of the project area is highly complex. The project area is located along the west to east thrust of the Lewis Overthrust. The terrain within the project area consists of rocky and steep hill slopes. Bedrock consists of the Proterozoic and Precambrian quartzite of the Piegan and Flathead Formation; Cretaceous Marias and Kootenai formation siltstone and limestone as well as thick massive sequences of Mississippi age limestone of the Madison formation. The project area was glaciated during the Laurentide glaciation (Pleistocene) leaving behind glacial valleys with deposits of tills and outwash along the sides and base of the valleys. Streams within the project area are steep fast flowing step pool morphology with gravel to boulder bottoms that are mainly bedrock controlled. None of the drainages within the project area are listed by the State of Montana as impaired. The Sun River (Gibson Dam to Muddy Creek), located downstream of the project area, is on the State of Montana 303(d) list for not supporting aquatic life and a total maximum daily loads has been completed for sediment/siltation and temperature. The impairments include sedimentation/siltation from grazing in riparian or shoreline zones and agriculture and temperature related to impacts from hydro-structure flow regulation/modification and channelization. Several wet areas within the proposed activity units were documented, but wetlands have not been delineated. Several units also contain dry swales without defined streambed or banks and do not show recent evidence of water flow. Grazing by cattle have effected stream morphology and function along several reaches within the project area. Existing stream conditions based on 2013-2014 stream surveys are outlined in Table 5-WS of the watershed specialist report (located in the project file).

Elk Creek Elk Creek is beaver dominated along the lower reaches above the forest boundary. The stream is rated as functional along the beaver dominated section to a gravel (Borrow) pit that was constructed in the floodplain of the creek. The pit was constructed following the 1964 flood to repair Forest road. Elk Creek flows intermittently through the borrow pit about two miles upstream from the Forest boundary. The stream reach through the gravel pit is rated as non-functional. The stream is approximately 10 feet lower than its historic natural channel elevation. The borrow pit is roughly 700 feet long and 75 feet wide. Headcutting has occurred downstream of the pit for over 100 feet and upstream for roughly 200 feet. The stream transitions from a Rosgen B/C-type channel above the pit to an E-type throughout the beaver dominated reach below the pit. Elk Creek above the pit is intermittent to perennial up to the basin divide.

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Tributaries to Elk Creek are predominantly Rosgen “A to B” channel types. Mostly boulder and bedrock controlled with step pool morphology. As with the main channel, the streams were rated as functioning at risk in reaches where cattle have easy access to the creeks resulting in unstable banks from trailing within the stream and the lack of adequate vegetation. Where the stream passes through areas that naturally restrict cattle access, the streams were rated functioning.

Smith Creek Smith Creek is a perennial stream that is mainly bedrock controlled. The channel is an A to C channel type. Where cattle have access to the stream, it is rated as functioning at risk mainly for unstable raw banks and suppressed bank vegetation. The tributaries to Smith Creek are dominantly Rosgen “A/B” channel types. Mostly boulder and bedrock controlled, the streams are mostly step pool morphology. As with the main channel, the tributary streams were rated as functioning-at-risk in reaches where cattle have easy access to the creeks resulting in trailing and unstable streambanks due to lack of adequate vegetation. Where the stream passes through areas that naturally restrict cattle access, they were rated functioning.

Wildfire The project area has been affected by past wild and prescribed fire. The latest and largest wildfire was the Canyon Creek fire. Occurring in 1988, the Canyon Creek Fire affected roughly 44 percent of the Elk Creek and 53 percent of the Smith Creek HUC 6 Watersheds. The effects of the Canyon Creek fire to the watershed have mostly recovered over the past 36 years. Post fire erosion, runoff and sediment delivery are now considered to be at levels of low to non-detectable within the fire perimeter.

Environmental Consequences

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary. The cumulative effects section extends to include the 6th-code Hydrologic Unit Code boundaries. The temporal scale of the analysis for direct and indirect effects ranges from one to five years. The potential for short-term increases in erosion and sediment delivery associated with prescribed fire would last as long as soil is disturbed or exposed. Once vegetation and groundcover have stabilized disturbed ground surfaces would not be expected to persist. The potential for sediment delivery is highest in the first year following disturbance and generally recovers to pre-disturbance levels within five years. Therefore, potential effects related to treatment units would be evaluated on a temporal scale of five years.

Sources, Methods, and Assumptions Information used in this analysis includes:

Field data Data collected in the field included terrain, channel, and wetland evaluations used to refine erosion modeling and inform determination of design feature mitigation measures.

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Water Quality Data Water quality monitoring data was not available for the project area. Information in the water quality section of this report is based on the Montana’s 303(d) list.

Geographic Information System Data Geographic information system data was used for spatial analysis including proposed treatment units, existing roads, 6th-code Hydrologic Unit Code watershed boundaries, streams from the national hydrography dataset, Lewis and Clark National Forest landtypes, stream buffers, and various intersections of these layers with the Lewis and Clark National Forest soil resource inventory. This information was used in various analyses.

Holdorf Soil Survey (1981) Soil Resource Inventory for the Lewis and Clark National Forest was used in modeling erosion and sedimentation.

The Water Erosion Prediction Project Modeling predicted erosion resulting from prescribed fire activities. Technical documentation for Water Erosion Prediction Project states that the model values are plus or minus 50 percent of true erosion values, at best (Elliot et al. 2000). Water Erosion Prediction Project is used in this analysis to provide relative erosion values for predicting management activity compliance with Water Quality Act. Detailed information regarding the model inputs and analysis results can be found in the Water Resources project record. The physical basis and performance of the Water Erosion Prediction Project models is discussed in the model documentation (Elliot et al. 2000; Elliott 2004; Robichaud et al. 2007) as well as several peer- reviewed papers (Elliott 2004; Laflen et al. 2004; Larsen and MacDonald 2007). In general, erosion prediction models have difficulty predicting sediment output with precision from a road, hillslope, or watershed at time scales useful to land managers. This is due mainly to a high degree of variability in site characteristics and climate. An average erosion/sediment delivery rate prediction can encompass this variability to some degree, but becomes much more useful when combined with a probability that erosion would occur. The Water Erosion Prediction Project models incorporate climate data tailored to the individual site using Parameter-Elevation Regressions on Independent Slopes Model Data (Daly et al. 2000) and simulate daily events for a number of years specified by the user to determine the probability of sediment leaving the unit. The model incorporates individual precipitation event characteristics and antecedent conditions as well as site characteristics into its prediction of average annual runoff, erosion, and sediment yield values. Changes in water yield are difficult to predict at the landscape scale due to the complexity of water movement in mountainous forested environments. Even with exhaustive site data available only in experimental settings (i.e., transpiration rates, soil moisture and porosity, precipitation, stream flow, groundwater level and flow), water yield estimates are approximate at best. The equivalent clearcut acres method has been in use for several decades in the northern Rockies and provides a reasonable estimation of the impacts of vegetation removal, and was used to estimate the impact on water yield of project activities as well as past and present activities throughout the two 6th-Hydrologic Unit Code

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watersheds in the project area (Troendle and Leaf 1980). The equivalent clearcut acres method predicts water yield increases by assigning coefficients to various types of disturbances. Information used in the analysis includes the timber stand database and various geographic information system layers. Basal area reduction coefficients and mortality factors used in the equivalent clearcut acres analysis were provided by the Helena-Lewis and Clark National Forest silviculturalist. Watershed mean annual precipitation was determined from Parameter-Elevation Regressions on Independent Slopes Model Data (Daly et al. 2000).

No Action Alternative Numerous studies have documented post-wildfire increases in erosion and stream sediment levels (e.g. Wagenbrenner et al. 2006; Spigel & Robichaud 2007; Robichaud et al. 2008; Moody & Martin 2009). While it is difficult to anticipate the exact pattern of burn severity to soils from either a prescribed fire or a wildfire in the project area, some general conclusions can be made from the fire-effects literature as well as monitoring of prescribed fire on the Helena - Lewis and Clark National Forest (for details of Lewis and Clark National Forest monitoring (see the soils specialist report in the project record). Whereas a wildfire typically burns through a landscape when conditions are hot and dry, prescribed fires are usually implemented when soil, duff, and coarse woody debris moisture levels are relatively high (i.e., in the spring and late fall). Burning that occurs during conditions of higher soil moisture generally results in lower impacts to soils (Hartford & Frandsen 1992; Stephan et al. 2012; Stoof et al. 2013). Stephan et al. (2012) found that wildfire-burned drainages exhibited higher severity effects than drainages burned in springtime prescribed fires, and produced substantially greater impacts to water quality. Furthermore, Rhoades et al. (2011) found that post-fire impacts to water quality in and around the Denver municipal watershed were closely correlated to burn severity and extent, the larger the area with high-severity burn effects, the greater the impact to stream water quality during the five-year analysis period following the Hayman Fire in 2002.

Direct and Indirect Effects Natural processes would continue and no direct effects to the watershed resource would occur from the no action alternative. No new management activities would occur. Ongoing activities such as firewood retrieval and dispersed camping, which can result in minor localized ground disturbance, and grazing would continue to occur.

Cumulative Effects Additional cumulative effects from cattle activity are not expected because no increases in cattle numbers or lengthening of the season of use would occur. Cattle trailing through the units would likely continue to use existing cattle/game trails, and the allotments would be monitored for compliance with established grazing standards. Any cumulative effects due to cattle activity would generally be limited to cattle trails and comprise a very small amount of disturbance. Cumulative effects due to other ongoing activities, such as recreation and firewood cutting, would be limited to areas where these uses overlap (i.e., grazing or firewood cutting areas are also dispersed camping sites). Effects from firewood cutting and recreational uses are localized in nature and generally minor.

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Proposed Action

Direct and Indirect Effects Prescribed fire can affect watershed condition by consuming vegetation, dead woody debris, humus and duff, removing protective ground cover, contributing to creation of water-repellant soil conditions, damaging physical and biological soil quality from excessive heat and releasing nutrients and other contaminants to runoff into nearby streams. Also with any vegetation treatments, increase runoff may occur resulting in higher stream flows. The 200-foot buffer of unaltered forest floor on each side of a stream and adjacent wetland is designed to maintain water quality and protect riparian areas and wetlands by reducing or eliminating sediment runoff from reaching stream channels (Ice et al. 2004; Ziesak 2008). Resource protection measures are prescribed to projects to ensure that the disturbance created by prescribed fire does not adversely impact water resources. The most likely consequence of the project to water resources is a potential for increased runoff, erosion and sediment delivery to stream channels in the first one to three years following burning, due to exposure of mineral soil through burning. To estimate the potential for project-related sediment delivery, the Forest Service-Disturbed Water Erosion Prediction Project Model 2.0 (Elliott 2010) was used. A climate dataset was generated to best approximate conditions at the site. Portions of units that were adjacent to streams were modeled to determine the predicted probability of sediment delivery in the first year following treatment, as well as the predicted per-acre sediment yield. Modeling was used to determine optimum “non-ignition buffer” width around streams in order to minimize the probability and volume of sediment delivery. It is estimated that the project would treat approximately 18 percent of the Upper Elk Creek and 19 percent of the Upper Smith Creek watersheds. Studies have shown stream channel condition can change as a result of water yield increases brought on by large areas of tree mortality (fire, insects or disease) or from excessive harvests (MacDonald and Hoffman 1995; Stednick 2006). Research has shown harvest, fire and insect mortality and the resulting reduction in cover on less than 20 percent to 25 percent of a watershed would not result in measurable changes in water yield (Stednick 1996). Potts (1984) found that 35 percent mortality resulted in a 15 percent increase in water yield. The primary influences of water yields is precipitation and research has shown that to achieve a measurable increase of water at least 25 percent of the basal area (cover) would have to be removed (Stednick 1996). Even though fire, insect disease and harvest can result in channel changes because of water yield increases, floods are the major source of channel change and are caused by climate fluctuations (temperature and precipitation) rather than forest management (MacDonald and Hoffman 1995). As all treatment units within the project area would not be treated in a single year, the increase in runoff to streams would be non- detectable. Forest manipulation has shown to change runoff and timing of snowpack regimes. Researchers have shown the creation of small, less than three-acre or five tree height diameter, openings in the forest canopy can change snowpack runoff timing. These opening may be the result of treatments such as timber harvest (Bosch and Hewett 1982; Douglas 1986; Stegmen 1996), or natural opening such as those resulting from bug kills (Boon 2007). It has been shown that snow intercepted within the forest canopy increases surface area and sublimation, decreasing runoff as opposed to snow that has redistributed

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into small forest openings. Snow redistribution into the small canopy openings exhibited higher snow water equivalent as oppose to the surrounding forest canopy. Some studies have witnessed 28 percent more snow in the openings then in the forested areas (Troendle 1983). However, in the studies of snow accumulations within these small openings, no measured gain in the overall runoff was observed from the watershed, likely due to no additional snow within the watershed, only the redistribution of snow within the basin. Boon concluded that within small bug killed stands, increase in snow accumulations, resulted in a lengthened period of snowpack disappearance. Farnes (2005) provided an analysis of timing and quantity of runoff information from fires in the watershed for the Sun River Water Management group. Findings show that the 1988 fires may have resulted in runoff timing of less than a day. Peak flows were found to be four to five days earlier than the 1988 flow; however, the advance may have been the result of warmer climate shifts. The proposed project would treat approximately 2,539 acres or 9.2 percent of the Upper Elk Creek and about 2,192 or 9.5 percent acres in the Upper Smith Creek watershed. It is proposed to introduce fire on roughly 50 percent of the timbered areas. This would equate to 1,270 acres and 1,095-acre openings within the forested area or 4.6 percent and 4.8 percent of the Upper Elk and the Upper Smith watersheds respectively. As only 4.6 and 4.8 percent of the watersheds would be effected by treatments, the proposed action changes to timing or the amount of runoff would be non-detectable. Modeling with Water Erosion Prediction Project used assumptions based on best estimate of the burned area. It is estimated the treatments would consume 20 to 50 percent of the unit, depending on prescription. The model predicted a 3 to 45 percent probability that runoff sufficient to erode and transport sediment to stream channels could occur in the first year following treatment, based on use of a “non-ignition buffer.” The model also predicts the amount of sediment leaving treatment profile and delivered to streams to be small, ranging from 0 to 2.13 tons per acre. Table 29 summarizes those units closest to or encompassing streams and therefore most likely to experience runoff compared with all other units in the project area. Thus, according to the model, there is a low to moderate probability that runoff or sedimentation will enter waterways above detectable levels if the buffer prescriptions are followed. Erosion may occur in the treated areas, however, the probability of runoff reaching streams from treated hillslopes is predicted to be moderate, additional mitigation measures should be used to further reduce the likelihood that any concentrated runoff does not flow through the vegetated buffers. Proper application of soil and water quality practices would prevent sediment runoff into the swales (Ice et al. 2004; Ziesak 2008).

Table 29: Water Erosion Prediction Project Model Estimated Erosion Rates. Average Average Natural Sediment Average Upland Erosion Leaving Probability of Unit Watershed Runoff Erosion Rate Treatment Occurrence (%) (inches) Rate* (tons/acre) profile* (ton/acre) (tons/acre) 1 0-0.004 0.20 19.08 2.13 19-41 2 0.058 0.20 3.86 2.07 16-45 Smith Creek 3 0 0.20 0.14 0.14 8-32 4 0-0.004 0.15 0 0.0 11

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Average Average Natural Sediment Average Upland Erosion Leaving Probability of Unit Watershed Runoff Erosion Rate Treatment Occurrence (%) (inches) Rate* (tons/acre) profile* (ton/acre) (tons/acre) 5 0.004-0.009 0.15 0 0.0 11-20 6 0.004-0.009 0.44 0 0.0 8-13 7 0 0.42 0 0.0 3-13 8** N/A N/A N/A N/A N/A 9** N/A N/A N/A N/A N/A Elk Creek 10 0 0.44 0.01 0.0 10 11 0 0.12 0.01 0.0 6-11 12 0 0.15 0.01 0.0 5-11 13 0 0.15 0.01 0.0 7 14 Smith 0 0.44 0.01 0.0 11 15 Elk Creek 0 0.15 0.02 0.01 16 *All estimates are for five-year return interval **Not analyzed (jackpot burn only) Erosion is a natural process of geologic decomposition that occurs in all watersheds and the rate at which it occurs is a function of soil and stream characteristics, precipitation and flow regimes, and vegetative cover. There are three basic types of erosion; 1) detachment and routing of individual particles from the land surface; 2) mass movement such as landslides and slumps; and 3) detachment and mobilization of stream channel banks or bottom material. All of these processes produce sediment and all stream systems transport sediment. Water Erosion Prediction Project analysis was completed to estimate the current natural and proposed treatment erosion rate for each unit. The potential estimated erosion from the proposed treatments is then compared with that of natural erosion. Sediment that is delivered to streams can degrade water quality. Depending on natural controls, sediment can have a wide range of delivery. Sediment transport through the system is dependent on the stream type. For mountain streams, sediment is very mobile and residence time within the stream system can be relatively short. If the system has a large influx of additional sediment from a large natural event such as a wildfire or due to land management actions i.e. grazing or prescribed fire, the impacts to the system may degrade. For this report the sediment delivery output from the WEPP model is a comparison of natural and proposed treatments. For this analysis, natural sediment delivery within the project area ranged from 0 to 2.17 tons per acre. Comparison of sediment deliveries by treatment unit are shown in Table 29. Several wet areas have been documented within the project area. Properly functioning wetlands are critical in maintaining water quality, groundwater storage, water quantity, habitat and downstream beneficial uses. No active fire ignition would take place within wetlands; however, working in close proximity to and in contact with wetlands increases the potential for introducing sediment, ash, nutrients, chemicals or debris that can affect water quality. Actions to control and contain the prescribed fire, such as fireline construction, can also adversely affect wetlands by creating ground

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disturbance. Wetlands contain sensitive soils and organic soils that can be damaged by foot trampling, or consumption in fire, which can damage the wetland characteristics. Fuel from the propane drip torches could contaminate surface water in the wetland or adjacent springs. As described in the Resource Protection Measures section above, a “non-ignition buffer” (Ice et al. 2004; Ziesak 2008) around the wetland will protect the integrity of the three wetland elements (plants, soils and hydrology) and maintain the ecological function of the wetland.

Cumulative Effects Several past and present federal and non-federal activities have affected and continue to affect water quality, water yield, and riparian function in the cumulative effects analysis area. Past wildfire may have caused temporary increases in water yield and sediment delivery, though these effects generally attenuate over time. Past pulses of elevated sediment (from wildfire) can remain in stream channels (banks and bed) for many years following deposition. Livestock grazing in allotments can impact water quality, water yield and riparian function. Grazing deferment as specified in the Soil Resource Report would reduce the cumulative impact of prescribed fire and livestock impacts to water quality and riparian function. 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 continued livestock impacts in grazing allotments and wildfire. Other activities that will serve to reduce sediment delivery to streams in project watersheds will 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 revisions, among others. Cumulative effects to water quality, water yield, or riparian function from past, present, and reasonably foreseeable activities, in conjunction with proposed treatments in the project area, are not expected to differ from the direct and indirect effects already described. Past and present activities were considered as part of the direct and indirect effects analysis and reasonably foreseeable activities are expected to improve the condition of water resources in the project area.

Statutory and Regulatory Consistency Table 30 below summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 30: Summary of Statutory and Regulatory Consistency – Watershed. Regulatory Requirement Project Consistency 1. Clean Water Act is to restore and maintain the chemical, physical, and biological integrity of the Nation’s waters. Section 303 of the Clean Water Act directs the States to establish water quality Non ignition buffers specified in the Resource Protection standards (subject to Environmental Protection Measures were designed to eliminate the probability of Agency approval) to carry out the purposes of the sediment delivery to state waters. Sediment is a regulated Act. Section 303(d) further directs the States to contaminate in the Clean Water Act. identify waters that do not meet water quality standards and to develop Total Maximum Daily Loads of pollutants. Montana has established

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Regulatory Requirement Project Consistency standards which are applicable to all Forest Service management activities. 2. Clean Water Act section 404 regulates the Non ignition buffers on wetlands are specified in the discharge of dredge or fill materials into waters of Resource Protection Measures and were designed to the United States. Typical Forest Service activities eliminate the probability of discharge of fill into waters of the that could require a 404 permit include activities in United States which includes wetlands. wetlands.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in Appendix E. Fisheries The Fisheries Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019) Watershed Report, the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 126 to 143) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to fisheries resources. The treatment effects are as originally analyzed and there are no changes to the fisheries portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 93 to 109).

Existing Condition The westslope cutthroat trout is the only native trout to the project area. It is also the only sensitive fish species or subspecies found in the project area. This subspecies is also recognized as a “sensitive species” by the Bureau of Land Management and the US Fish and Wildlife Service. The state of Montana recognizes the westslope cutthroat trout as a “species of special concern”. There are two sensitive amphibian species in on the Helena-Lewis and Clark National Forest. These are the northern leopard frog (Rana pipiens) and the western toad (Bufo boreas). This project area is within the occupied range of the western toad. The northern leopard frog has only been found on the Forest in the Highwood Mountain Range. This project area is well outside of either occupied or predicted ranges for this species. The western pearlshell mussel (Margaritifera falcata) is a recently listed sensitive species and “species of special concern”. This mussel has not been found in survey attempts that are closest proximity to the project area (MTFWP, MNHP 2014). The Elk/Smith Project analysis area is also outside the potential or predicted habitat areas mapped by the Montana Natural Heritage Program (Stagliano 2011). Thus, westslope cutthroat trout and the western toad are the two sensitive species with populations or habitat occurring within this project area. Potential effects of project actions to the habitat, populations, and viability of these species are analyzed in this document. The Forest Plan (USDA FS 1986), lists three fish species as Management Indicator Species with instructions to “monitor population levels of all Management Indicator Species on the Forest and determine the relationship to habitat trends.” These three species are listed in the plan under the wildlife category “Commonly Hunted and Fished”. All three fish species are salmonids, which are commonly known as the trout, salmon, char, and whitefish family of fish. The westslope cutthroat trout

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is the only native trout that appears on this Management Indicator Species list. The other two fish Management Indicator Species, eastern brook trout (Salvelinus fontinalis) and rainbow trout (Oncorhynchus mykiss), are introduced species on the Forest and in the State of Montana. Eastern brook trout contain the term, “trout”, in their name. However, as a member of the Salvelinus genus, they are technically a char. Effects to the two non-sensitive Management Indicator Species fishes will also be analyzed in this document. The hydrology and soils specialist’s report will be used as assistance in evaluating potential changes to sediment and water yields (available in the project file). Preparatory field visits were conducted for this project by various members of the interdisciplinary team including fisheries, soils, hydrology, fuels, and range specialists. The fisheries specialist also organized and participated in three different joint survey and genetic sample collection trips with biologists and technicians from Montana Fish Wildlife and Parks during the 2013 field-season. These efforts yielded considerable current information on existing conditions and even led to the discovery of a previously unknown population of westslope cutthroat trout. This population is the only known, genetically pure population of this subspecies within the Sun River drainage. The foreseeable, potential effects to fish populations from actions connected to this project would be changes in these habitat or population related factors; sediment yields, thermal regimes, competitive relationships between native and introduced species, risk of impacts from future wildfires, and availability of prey invertebrates. The foreseeable, potential effects to amphibian species would be changes in these factors; direct or indirect mortality, thermal regimes in breeding ponds and terrestrial habitat areas, ability to migrate overland, sediment inputs into breeding ponds, risk of impacts from future wildfires, and availability of prey species. These potential effects could vary in intensity or not occur at levels that would be measureable or impact individual aquatic organisms or population dynamics. Not all of these potential effects are assumed to be negative to populations of fish and amphibians within the analysis area. In some post-fire situations, westslope cutthroat trout have competed more successfully against brook trout than in pre-fire monitoring time periods (Sestrich et al 2011). Western toads have also demonstrated post-fire population increases (Guscio et al. 2007). Aquatic insects have increased after fire events (Minshall 2003, Minshall et al. 2001). A previously unknown population of westslope cutthroat trout was found in the middle sections of Moudess Creek. Genetic tests confirmed that this population is 100 percent pure. The Moudess Creek population was a significant find that put an emphasis on surveying all other project area tributaries. As this was done, a previously unknown trout population was found in upper Cyanide Creek. This population is predominately rainbow trout in origin as there was little to no visible characteristics of westslope cutthroat trout in the genetic makeup. No other new discoveries were made. Moudess Creek is the only known pure westslope cutthroat trout population in the project area, and in the entire Sun River system. The upper portion of the main-stem of Smith Creek hosts a westslope cutthroat trout population with a 90 percent or higher level of genetic purity. This is the threshold for a population being considered a conservation population under the Upper Missouri River Westslope Cutthroat Trout Status and Recovery Plan (Tews et. al. 2000). The Smith Creek population was genetically sampled in 2013. Laboratory tests have determined it to be a three-way hybrid swarm containing both rainbow trout and Yellowstone cutthroat trout markers.

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Several barriers were found in tributaries of both Elk and Smith Creek. The habitat upstream of these was highly fragmented by smaller cascades and intermittent reaches. No sections were found that appeared to be suitable to replicate other populations. Barriers may also exist on the main-stems of both Elk Creek and Smith Creek. It is more difficult to assess if a cascade is a migration barrier on a large stream because of the much greater potential for passage during high flows. The habitat above the suspected barriers in Elk Creek is highly fragmented by smaller cascades and by intermittent flows. The amount of fragmentation makes it appear unlikely that this currently fishless stream habitat could sustain an introduced population. Fish below the potential barrier on Smith Creek were marked in 2013. Follow-up efforts are being conducted to determine if marked fish migrate above the waterfall. The hybridization existing above the falls could be the result of human stocking efforts or a combination of this activity and fish getting around margin areas during high flows. Moudess Creek flows into Smith Creek less than a quarter of a mile above the waterfall. Thus, the question of whether this is an effective barrier in blocking the upstream migration of exotic fishes is important in formulating a plan to also conserve and expand this population. The western toad is the other sensitive species that either occurs or has a portion of its distribution range within the proposed project area. These were not observed during field visits. There appears to be very limited breeding habitat in the Smith Creek drainage portion of the project area. Incised, box- shaped canyons are prevalent along riparian areas. These tend to run fast in the spring and afford little opportunity for still, ponding areas suitable for western toad breeding. Upland bench areas with ponds, fens and other wetland areas are present, but appear to be a very minor component of this landscape. A shallow pond does exist in the very uppermost part of Smith Creek. In the Elk Creek portion of the project area there is a fairly expansive beaver complex on the main-steam stream, just above the forest boundary. Some of these beaver ponds appear to be suitable for western toad breeding. Several ponds were observed to have a very good distribution of depths and types of littoral or shore-zone areas. Some of the ponds are in main-channel areas that are more likely to scour during the breeding season. Others are on side-channels that would appear to be more conducive to breeding success. An accumulation of fine sediment and rooted aquatic vegetation is further indication that scouring may not be a limiting process in some of these ponds. The forest fisheries biologist did not observe any western toad activity on June 10, 2014 in a limited survey of the beaver complex area. This was not a comprehensive enough effort to rule-out this area as western toad breeding habitat, however. For the purpose of this analysis, western toads would be assumed to be present and reproducing in the project area. The Canyon Creek fire of 1988 burned across much of this analysis area. This is the main effect present on the landscape as most of the project area is roadless and has a limited history of timber harvest activities. Some stream segments lost canopy during this fire event. There is a varying level of recovery of this in the current condition. This is not considered a concern as water temperatures in the project area are heavily influenced by subsurface flows and known to be colder than what is ideal for westslope cutthroat trout persistence. Embryonic emergence is late and slow growth limits the overwintering success of young-of-year fish. An attempt to introduce westslope cutthroat to a segment of Petty Creek, a tributary of Smith Creek, failed for this reason.

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Springtime flows are more than adequate to have transported away the elevated levels of sediment produced during and in the first years after the 1988 fire. Sediment yield recovery curves typically return to near pre-fire levels between four-to-ten years after wildfires of similar intensity, with much of the recovery occurring during the first two years (Moody and Martin 2009; Robichaud and Waldrop 1994; Ice et. al. 2004). Spawning gravels in the project area appear to be loose and not contain fine sediment near levels that have been demonstrated to reduce embryonic survival. Most of the historic harvest/salvage activity is in the Smith Creek basin below the forest boundary. This occurred long enough ago to allow for nearly full recovery in any changes in sediment and water yields. The temporary road network was limited in size with most segments occurring well away from channel or riparian areas. A couple of crossings appear to deliver minor amounts of sediment in comparison to natural yields.

Water Quality: Sediment Increased sediment delivery to streams is the most common water-quality impact in mountainous watersheds containing road networks and managed forestry resources. Heightened levels of fine sediment in a stream negatively affect the populations and reproductive success of fish and aquatic invertebrates such as mussels, amphibians and insects. High sediment production events are especially a concern when a population of a rare or sensitive species is located in an isolated habitat unit. Protecting westslope cutthroat trout from hybridization on the Forest often requires establishing refugia of genetically unique populations of westslope cutthroat trout upstream of constructed fish barriers or protecting those which persist upstream of natural fish barriers such as waterfalls. These isolated populations can no longer migrate to another stream to complete their lifecycle while maintaining genetic purity. This makes these fish more vulnerable to chronically elevated levels of sediment or catastrophic sediment events such as debris flows than those with access to larger stream networks (Sestrich et. al. 2011).

Sediment from Other Sources Other sources of sediment are a few unstable streambanks and some adjacent upland areas with un- vegetated shale outcroppings. Livestock grazing related impacts are present in the project area, but not widespread. Riparian grazing impacts were more evident in 2013 than in 2014 in the Smith Creek drainage portion of the project area. Impacts are light enough that young shrubs and cottonwoods are common on appropriate sites. Terrain limitations and the grazing management regime appear to be limiting impacts to levels which allow for light levels of bank alterations and for all but a trace percentage of bank areas to remain intact. The heavier use areas occur on the lower main-stem of Elk Creek in areas between and away from the beaver ponds and in a few riparian bench areas along Smith Creek tributaries such as Jakie and Moudess Creeks. The livestock use along Smith Creek becomes light and confined mostly to crossings within the Forest boundary. There is evidence of some steep, upland areas not re-vegetating well after the 1988 fire. These areas appear to be contributing mostly pea-gravel or larger material. Slopes are steep and any finer materials that were present and mobile have been recruited and moved through the system.

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Riparian/Wetland Habitat Areas Most stream segments have been visited and assessed within the project areas. A comprehensive mapping of wetland habitats within the analysis sub-watersheds has not been performed, however. There are known wet meadows, fens, vernal pools, and lacustrine wetlands within the area. It is assumed that unknown examples of these aquatic habitat units occur within this project area. Activities in these areas are controlled by state and federal laws and regulations described under the regulatory framework sections of this document. These areas perform vital ecosystem services such as water storage, sediment filtration and carbon sequestration. They are also important habitat areas for amphibians, such as the western toad. The activities proposed in the action alternative, when implemented under these applicable regulations, should not affect the function or integrity of these habitat areas.

Environmental Consequences

Analysis Assumptions and Limitations This analysis of project impacts on fisheries and aquatic wildlife resources assumes that applicable regulations would be effectively followed during implementation. Best management practices for commercial timber harvest and hauling would not be relevant to this project as these types of activities are not being considered. Road related impairments are barely existent in the project area as only the southwest corner of the project area contains roads. Within the project area there is one system road along with a couple of short spurs going into private lands. Elk Creek Road (Forest Road 796) is the system road and it runs for about three miles on Forest Service lands. Comprehensive surveys of native fish population presence and levels of genetic purity have recently been performed in the streams of this project area. As previously mentioned, this work led to the discovery of an unknown, pure population of westslope cutthroat trout. Having reliable knowledge of where native fish are located is not a limitation in this analysis. There is a limitation in that trend data is obviously not available for a newly found population. The very low numbers remaining in this population coupled with the much greater numbers of sympatric brook trout is a reliable indicator that the population has greatly decreased and is in imminently threatened by extirpation without intervention. The rate of this decline is unknown, however. This is also true for the remaining stream segments where conservation level populations of westslope cutthroat trout have disappeared.

Water Quality - Sediment Sediment delivery from prescribed burns is the water-quality impairment that would be most likely to result from proposed project activities. There would be a potential for increasing bare ground by burning vegetation. Bare soil is more erodible than that held better in-place by vegetation. The loss of tree canopy would also potentially increase run-off as a decrease in water uptake and transpiration by trees could occur for the first three or more years after treatments. Increases in run-off would possibly increase erosion rates by increasing the available erosive energy in treated drainages. The forest soil scientist has assessed the soil types within the proposed burn units of the project area. The hydrology specialists used this soil information to model erosion rates in the existing condition and for post-implementation conditions. The Watershed Erosion Prediction Project model was used to

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perform this work. Along with local soil conditions, nearby climate data, burn intensity, and mean slope- lengths within the proposed treatment units were used as input-variables in performing model runs. There are multiple assumptions built into Watershed Erosion Prediction Project, and by necessity, all other sediment modeling methodologies. It is important to assess whether these assumptions have the potential, if violated, to produce a large enough variation between modeled and actual yields to impact the accuracy of conclusions about effects on the survival rate and/or reproductive success of fish or other aquatic wildlife species. Two assumptions in Watershed Erosion Prediction Project modeling would seem to have any potential for missing catastrophic or chronic changes in sediment yield. These correlate to failing to accurately capture high-intensity weather events during the first year after implementation and for soil burn intensity to well exceed predicted values. A localized Prism climate dataset is used in model runs. The pertinent question is whether this dataset contains precipitation and snow-melt events that match or exceed the intensity that would be encountered in the first year after burn implementation. The start- date for the primary climate station used in Watershed Erosion Prediction Project modeling was 1911. Thus, multiple years with high snow-packs and/or high-intensity precipitation events are contained in this data. These years include the catastrophic 1976 flood-event and the heavy winter snow-pack and June rain/snow-fall year of 2011. It does appear to be a valid assumption that precipitation and runoff intensity would fall within or near the range captured in the recorded data-set. The assumption of whether implemented soil burn intensities would be within planned thresholds also appears very likely to be valid. Weather and seasonal constraints for igniting prescribed fires would be well outside of conditions demonstrated to produce high-severity soil and vegetation burns. The forest fisheries biologist visited the Moudess Creek drainage on September 9, 2014 to observe if spatial correlations exist between areas with higher fuel concentrations, areas where buffering strips may be lightly vegetated, and areas where soils may be more easily eroded or slow to re-vegetate. Moudess Creek is the only stream in the project area where the error tolerances in the methodologies used to predicting sediment inputs could potentially affect a conclusion about viability effects on a sensitive aquatic population. The particular potential for error that was of interest in Moudess Creek relates to whether the minimum mapping unit size of soil, slope, and fuel polygons would miss small-scale sites with the potential for high rates of erosion. This scale-related issue would only be a concern in situations, like Moudess, where fish are isolated to an extremely small segment of stream within a small drainage area. In any other situation, the effects of any these inclusions would be mitigated by scale and proportions. There is a segment near the mouth of Moudess Creek that has bare, shale-dominated soils leading almost to the streambank. This area is downstream of the proposed burn unit and the population of pure cutthroat. Also, there are not clusters of trees or other fuel-types that would allow for prescribed fire to be carried to this area. There were not site-specific concern areas found in the catchment of the populated stream reach that necessitated conferring with soil and hydrology specialists for fine-tuning the resolution of data used in model-runs. Conditions in this area appear to indicate that fire would tend to stay further away from the stream than what would be allowed in the proposed action. Terrain and fuel breaks are prominent along these stream segments. More buffering appears to be present in the actual, on-the-ground scenario than what was used in the modeling runs. The westslope cutthroat trout population in Smith Creek is in a much larger drainage basin with a much lower proportion of proposed

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treatment units. Thus, the effects on modeling error of small-scale inclusions that could be more erosive than the mapped parameters would be minimal. The relationship between modeled inputs and actual future yields can also be dependent on factors which are known to act synergistically in increasing sediment yields. Ongoing and future cumulative effects from other sediment producing activities in these drainages would also need to be added in assessing this potential for difference. There are few cumulative effects in this project area. Road densities are low, recent timber harvests are not present, and grazing impacts are low to moderate and not widespread. High risk culverts do not exist within the catchment of either westslope cutthroat trout populations. The likelihood of these activities changing in this project area is very low and mostly within the control of Forest Service management and decision processes. Prescribed fires usually do not create large or persistent changes in sediment yields when soil protection measures and ample riparian buffer strips are present. Watershed Erosion Prediction Project model runs for similar activities within the Forest typically show yield increases of well-less than a total of 0.25 tons per acre of treatment, over a five year period, with a probability of occurrence being well-less than 25 percent. The probability of occurrence is driven by the chance of precipitation events dynamic enough to mobilize and deliver sediment past buffer strips. Fine sediment is relatively heavy with a density exceeding two tons per cubic meter. Thus, 0.25 tons represents about 1/8 cubic meter. This converts in imperial/English units to the volume of a cube that is just over 24 inches per side. Increased sediment delivery and the risk of increased delivery are usually short-term with a return towards baseline conditions starting to occur by the first to second year after implementation (Robichaud et al. 2007; Elliot 2004; Elliot et al. 2000). Thus, for conclusions on effects to be misled by using Watershed Erosion Prediction Project outputs in this project area, violations of assumptions would need to be large enough to represent missing a catastrophic run-off event or some mechanism that would create chronic or prolonged increases in sediment yields. The effects of sediment on fish and other aquatic wildlife are dependent on many more factors than changes in annual yields. Too simplistic of assumptions in effects analyses can lead to under or over emphasizing the impact of changes in sediment regimes on individual organisms and population-level dynamics. The particle size distribution of the sediment (Young et al. 1991) and the timing and duration of entry events are important. Events which greatly increase suspended sediment are more likely to be directly lethal to fish the longer they persist (Newcombe and MacDonald 1991). Using best management practices and adhering to regulatory standards can be expected to prevent both concentrations and durations of suspended sediment that would create fish mortality. Preventing this occurrence has been a primary consideration in the design of these procedures and regulations. Stream reaches vary in the transport power available to move sediment downstream. Higher stream gradients tend to more readily transport sediment. Lower stream gradients tend to store more sediment between floods or flushing flow events. Most stream reaches in this project are transport reaches because of the range of gradients present. Elk Creek near the forest boundary is a storage reach because of the reduction in gradient and beaver activity. Sediment storage occurs temporarily in pools, glides, and other slower areas even in transport reaches (Lisle 1989). This mostly occurs during the “falling limb” of the hydrograph which is when higher flows start to recede (Jackson and Beschta 1982; Lisle 1989). Westslope cutthroat trout begin spawning activities during the time that flow recedes from

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combined snow-melt and spring/early summer rains (Schmetterling 2000). Thus, it is being assumed that increases in stored, fine sediment would have temporal overlap with westslope cutthroat trout spawning and incubation. Fine sediment can reduce trout spawning success by preventing eggs from receiving adequate levels of dissolved oxygen (Bryce et al. 2008; Weaver and Fraley 1993). Fine sediment is considered a concern when smaller than about 6.5 millimeters (Weaver and Fraley 1993). Particle sizes smaller than about 0.85 millimeters have the highest correlation with reducing embryonic survival (Young et al. 1991; Magee et al. 1996; Beschta and Jackson 1979). Generally, complex stream reaches, which feature a multitude of pools, riffles, and runs, better store and buffer the effects of sediment on fish and other aquatic wildlife (Shepard et al. 1998; Baxter and Hauer 2000; Magee et al. 1996; Schmetterling 2000). This complexity allows for a total increase in storage capacity as well as for increased storage capacity in areas not used for spawning. More storage capacity and habitat complexity allows for fine sediment to move through the system without intra- gravel concentrations becoming frequently high. Streams in this project area generally contain a good ratio of pools and a diversity of pool types. The two streams with conservation-level westslope cutthroat trout populations typify this with the addition of “run” and “glide” habitat areas. Overall, the habitat appears to offer a high-level of resiliency to sediment events that are not catastrophic in magnitude or chronic in occurrence. The ability to seasonally store small sediment increases, without suppressing reproductive success, and then transporting these away during higher flows appears to be very high. There is enough transport ability and ample enough storage capacity in the streams of this project area to prevent small, temporary increases in sediment yields from impeding dissolved oxygen flow to eggs in all or most spawning sites. Low levels of cumulative effects from other sediment producing activities contribute to the confidence of making this determination or assumption. Other factors commonly compensate for sediment impacts on hatching or emergence success, such as enhanced alevin or fry survival. In one study embryonic survival was suppressed by fine sediment to the low level of 8.6 percent without recruitment to the population being affected (Magee and others 1996). Most systems have compensatory reproduction at the embryonic stage. This means that more fish survive at the embryonic stage of develop than the habitat can carry at more mature life stages. If survival is high in following age classes, some levels of decreased survival in the embryonic stage can occur without suppressing population numbers. Moudess Creek and Smith Creek are well-below many streams in the ability to compensate for low embryonic survival. These streams are cold, high elevation and relatively low in productivity. A westslope cutthroat trout transplant project failed in Petty Creek within the Smith Creek basin because of a thermal regime that was too cold. The cooler summer waters, earlier winter conditions and lower food supplies create conditions where juvenile fish are likely to be relatively small as they begin their first attempt at over-wintering. Brook trout predation also suppresses the survival of juvenile fish. Thus, this assessment will assume that if moderate or higher increases in sediment levels were to occur and persist for more than two years, a viability risk to the remnant westslope cutthroat trout populations in the project area would exist. The preceding two assumptions are stated using the relative terms “low levels” and “moderate or higher” instead of with a specific quantity or ratio of annual increase. This recognizes a limitation in being able to accurately predict the specific quantity of fine sediment input into a particular stream segment that will measurably lower embryonic survival to levels, which would limit recruitment. Correlations have been made between embryonic survival and the percent of space between spawning

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gravel-sized particles that is occupied by fine sediment-sized particles (Magee et. al. 1996, Weaver and Fraley 1993). However, it is not possible to accurately predict to what extent relatively small, temporary increases in fine sediment yields would raise inter-gravel concentrations of fine-sediment concentrations in a particular stream reach. The movement of sediment through any stream reach is complex with many different variables determining the pattern of transport, settling, storage, scouring, and re-mobilization (Beschta and Platts 1986). Storage of sediment is not homogenous within a stream reach. Dam created pools may contain large concentrations with upwelling zones within riffle areas containing very low amounts. Most studies on the effects of sediment on salmonid fishes have occurred in much larger and more heavily managed drainages. These have been characterized by much higher and more prolonged non- natural inputs. A landmark study in the South Fork Salmon River basin correlated an average inter-gravel concentration of 48 percent fine-sediment with a loss of approximately 20,000 cubic meters of fine- sediments from temporary logging roads a year within a 3,290 square kilometer catchment (Platts et al. 1983). This converts to an average production of approximately 74 tons of temporary road-source sediment produced per acre, per year within that catchment. This is several hundred to more than a thousand times higher than the effects typically modeled or observed on similar prescribed fire projects. Differences in stream discharge, climatic regimes, soil types, and in orders of magnitudes of delivered sediment make it impossible to quantitatively scale-down effects to the level of predicted changes in inter-gravel concentrations of fine sediment. Cross-walking published data representing much higher changes in sediment delivery and population effects may be a limitation, but assuming that these studies observed a much higher effect on salmonid populations appears to be very supportable.

Flow Regimes and Temperature Studies which document the effect of the removal of shade canopy on stream temperatures do not parallel the characteristics of this project as changes in the shading of the stream itself are not being proposed, nor are they expected. Those which demonstrate temperature change from tree removal or mortality have experimental designs with much greater levels of near-stream canopy manipulations. Clear-cutting a living canopy (Hetrick et. al. 1998) or burning riparian canopy with wildfire (Amaranthus et. al. 1989) has been demonstrated to effect stream temperatures. Removing canopy that does not shade streams can temporary increase water yields. Small changes in water yields affect temperatures to a much lesser extent than does removal of direct stream shading (Poole and Berman 2001; Johnson 2004; Rutherford et al. 2004). While increased flows may very slightly alter temperature, they can also expand available summer-time habitat (Hicks et al. 1991). Increased summer habitat has been demonstrated locally to expand westslope cutthroat trout populations, but the number of observations is limited (Moser 2011). The positive effect on population size that was observed is at least as large and likely larger, than expected negative effects of small changes in temperature regimes. Thus, the assumption is being made that temperature changes would not have a negative impact unless modeling of yield increases shows unexpected levels of change. Adding foreseeable thermal effects to predicted local rates of global climate change cannot be expected to form a tipping point for survival at the organism level or viability at the population level. This conclusion is based on climatic predictions made by a multitude of scientists with a weighting towards models which best “back-predict”, which is being able to replicate historical weather observations (Isaak and Riemen

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2012; Isaak et al. 2010; Barsugli 2009). This is a somewhat-rare system in which cutthroat populations are limited by cool summer water temperatures. Predicated temperature increases from climate change are not assumed to be negative for either of the two populations present in the project area. These would actually un-intentionally mitigate any decreases due to temporarily increased summer flows.

Large Woody Debris Recruitment Large woody debris has consistently been shown to increase the carrying capacity of streams for fish, mussel and amphibian populations (Naiman et al. 2002; Rosenfeld and Huato 2003; Adams and Bury 2002). The recruitment zone for large woody debris is generally considered to be within a tree height distance of the floodplain. This allows for enough of a tree to fall into the floodplain that it can be carried in-stream during a flood. Field visits confirm that flood plains are confined by terrain within almost the entirety of the project area. The lowest portions of Elk Creek and Smith Creek are the exceptions. Very seldom, would the 200-foot buffer fail to cover the zone of recruitment. It is thus being assumed that the recruitment of large woody debris would not be increased, decreased, or be modified in timing by actions that would be connected to this project. There is almost no coincidence between proposed units and the areas identified where floodplains become less confined.

Assumptions and Limitations Summary The various assumptions and limitations discussed in this section do not substantively affect the ability to determine whether significant fish and aquatic wildlife issues, as tested for context and intensity under the National Environmental Protection Act, are connected to this project. These limitations primarily affect the ability to quantify effects in specific physical units for specific stream reaches while meeting the standards of research-level experimental designs and accuracy assessments. Less data intensive analysis techniques are available and appropriate for assessing whether the context and intensity of actions connected to this project would approach thresholds which would impact any of the ten National Environmental Policy Act points of significance. These include modeling for the range of conditions observed in the field, using equivalent clearcut area and sediment modeling analyses performed by the hydrology specialist, assessing the scale and spatial distribution of proposed activities, and analyzing the population trends of sensitive species near activity areas.

Information Used

Lewis and Clark National Forest Geographic Information System Datasets used in this analysis include National Hydrologic Dataset (NHD) streams and 6th-Hydrologic Unit Code watershed boundaries, roads, and project treatment polygons. All surveys conducted on the forest for westslope cutthroat trout distribution have been entered into a Geographic Information System dataset. Mussel surveys from the Montana Natural Heritage Program were also used (Stagliano 2011).

Methodology & Scientific Accuracy Quantitative methodology was not used for assessing effects on aquatic species and aquatic habitat conditions in this analysis. Spatial data from the Lewis and Clark National Forest Geographic Information System datasets was used as information in analyses. Cartographic precision and accuracy of this

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information is documented in the Lewis and Clark National Forest Geographic Information System data dictionary and metadata records. Modeling sediment input from existing watershed conditions, and projected yields after implementation was performed by the forest hydrologist. The methodology used was the Watershed Erosion Prediction Project: Disturbance software (Elliot 2004). The forest soil scientist, forest hydrologist and forest fisheries biologist consulted together about input variables and jointly reviewed model results. The accuracy of Watershed Erosion Prediction Project: Disturbance model runs is dependent on several factors. These include a limited set of input variables that describe soil, slope, and vegetation conditions. The ability of modified PRISM climate data to describe local conditions over the modeled time period is also a factor that impacts accuracy. There appears to be less validation efforts published for Watershed Erosion Prediction Project: Disturbance and prescribed fires than for the Watershed Erosion Prediction Project: Road model (Elliot et. al. 1999, Elliot et. al. 2000). The fisheries/aquatic wildlife specialists conferred with two peers about their post-implementation experience using Watershed Erosion Prediction Project: Disturbance on prescribed fire projects (Hendrickson 2014, Van Eimeren 2014). Quantitative monitoring was not performed on the Lolo National Forest following several burns in the Rattlesnake Recreation Area, but the fisheries biologist assigned to these projects relayed that Watershed Erosion Prediction Project model predictions were likely higher than the actual change in yields (Hendrickson 2014). This observation was made with the recognition that actual sediment yields are often not visible. Intact duff layers, lack of fire carrying to riparian buffer zones, and the absence of visible rills or signs of overland, sheet flows informed this professional opinion. Similar, anecdotal-level observations were reported from prescribed fire projects on the Flathead National Forest (Van Eimeren 2014). The 1988 fire has impacted duff layers in the Elk Smith project area so this would be a different condition than in the Lolo National Forest implementation area. However, the occurrence and intensity of fire near the outskirts of the 200-foot buffer area would likely be even less in the Elk Smith project area due to lighter fuel concentrations. The anecdotal-level evidence on the Lolo National Forest combined with the characteristics of this project area indicate that the Watershed Erosion Prediction Project: Disturbance model runs should at least capture real yield quantities if not actually represent worse-case scenarios or even higher quantities. Watershed Erosion Prediction Project: Disturbance runs also produce values for “probability of occurrence”. These indicate what the probability is for delivery of the modeled volumes. Coupled with the characteristically light fuel loading near the outskirt of the riparian buffer areas, the quality of the climate data should produce conservative to accurate probability values.

Analysis Area This section will analyze the potential of the proposed action to affect the habitat parameters of; sediment budgets, water yields, temperature regimes, large woody debris recruitment, food availability, and chemical toxins. These are the habitat quality factors which could be influenced directly or indirectly by actions that would be connected to this project. Westslope cutthroat trout (Oncorhynchus clarki lewisi) are present in two stream segments within the project area. This sub-species is vulnerable to predation from non-native trout and chars and genetic introgression with non-native trout. Thus, this

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section will also analyze if any potential changes to habitat parameters would affect competitive dynamics with other fish species. Cumulative effects from existing and foreseeable impacts and management actions will also be considered for potential additive effects on fish and aquatic wildlife populations. The analysis area for direct, indirect and cumulative effects to aquatic habitat is defined by the sixth order Hydrologic Unit Code (HUC) sub-watersheds which contain treatment areas proposed for prescribed fire, fuel reduction treatments. Within these sub-watersheds, field surveys were performed in 2013 and 2014 to evaluate the presence and status of sensitive and management indicator aquatic species. Potential effects to these species, if the proposed action would be implemented, were also analyzed. Since migration barriers are important in preventing the hybridization of westslope cutthroat trout with non-native species, these were also looked for and evaluated during field efforts. Stream segments above these were evaluated for the ability to sustain westslope cutthroat trout populations. This was done to assess the potential to replicate or even temporarily hold at-risk populations in nearby drainage basins.

No Action

Direct and Indirect Effects Under this alternative, there is no proposed new management action. Without the implementation of new actions, no new management-related impacts to fish, amphibian or other aquatic species and aquatic habitats would occur. Past and ongoing management activities would continue to affect these populations and habitat areas. Stream sediment and thermal regimes would be unaffected in the near- term by implementing this alternative.

Cumulative Effects The only cumulative effect in this alternative is that the risk of larger and higher intensity wildfires would increase more over-time. Watershed Erosion Prediction Project: Disturbance modeling runs for wildfire scenarios produce much higher yields of sediment than do the proposed burns of this project. The risk of sediment yields occurring would be initially lower with no project actions, but continually increase through time as fuel concentrations increase. Predicting the quantity of sediment that would be introduced by a future fire with an increased intensity would be an inexact exercise. Many different variables would determine this and historical precedence across the western United States includes a very wide range (Megahan and King 2004). Isolated westslope cutthroat trout populations in this project area do not have the ability, however, to migrate away from catastrophic-levels of sediment related impacts and maintain genetic integrity. In the Bitterroot National Forest there are several streams where westslope cutthroat trout have persisted under competition from stocked brook trout for many decades. In most of these streams that were being actively monitored, westslope trout populations eventually increased their competitive balance with brook trout after the large wildfires of 2000 (Sestrich et. al. 2011). It cannot be assumed that this relationship would occur in this project area, however. The baseline competitive balance is different with local cutthroat populations being much more likely to be extirpated by brook trout in pre- fire conditions. Run-off and temperature regimes are different and emergence of westslope cutthroat

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trout is also later in this project area. The effects of wildfire on fish populations and competitive balances with non-native species is variable with local considerations and specific effects from fires able to produce different results (Rieman et. al. 2003). Increased large woody debris inputs are believed to be part of the reason for the increase of westslope cutthroat in the streams affected by wildfire in the Bitterroot National Forest. In electrofishing effects in this locality, wood formed pools appear to be more dominated by brook trout. This relationship is also commonly known by many people who locally fish for this species. One study on waters east of the continental divide on the Beaverhead-Deerlodge National Forest indicates that increased woody debris may decrease the size of westslope cutthroat trout populations where eastern brook trout are present (Shepherd 2004). Woody debris has been demonstrated to be important to westslope cutthroat trout (Schmetterling 2000), but increased levels may favor the non-native competitor to an even greater extent in this vicinity. Westslope cutthroat trout tend to be found at the highest densities in deep, slow to moderate velocity runs in electrofishing efforts when both species exists together across most of the Forest. Mid-channel, boulder and bedrock formed pools that tend to have some moderate velocity areas also hold higher proportions of cutthroat trout in this project area with brook trout dominating low velocity pools. This observation has been made while electrofishing nearly 100 percent of the occupied habitat in the project area. The spread of weeds would not increase in the no-action alternative. There would possibly be less need for herbicide application. Protecting aquatic organisms from adverse effects of herbicide application has been provided for application in compliance with label instructions and the current Lewis and Clark National Forest Noxious Weeds Environmental Impact Statement (USDA FS 1994).

Proposed Action

Direct Effects Direct effects to fish are unlikely to occur as heat and/or suspended sediment levels would not be high enough to cause mortality. There are no other connected actions such as entry of ignition accelerants or equipment into streams that would cause chemical or mechanical related fish mortality. Direct effects to amphibians would be at incidental to low levels. Toads would seem most likely to experience heat related mortality. Available information indicates that toads survive low to moderate-intensity fires very well, however (Russell et al. 1999; Guscio et al. 2007; Perry et al. 2012; Hossack et al. 2012). Migrating ahead of the heat and burrowing allows for this survival.

Indirect Effects These are the effects on the habitat quality parameters connected to proposed actions that were mentioned in the Introduction and discussed with some additional detail under the “Analysis Assumptions and Limitations” section. These potential indirect effects are; sediment budgets, water yields, temperature regimes, large woody debris recruitment, food availability, and chemical toxins. The potential effects on large woody debris recruitment were discussed under the “Analysis Assumptions and Limitations” section. Since there is extremely limited spatial coincidence with the zone of recruitment and areas which would be burned, this will not be analyzed further.

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Sediment Yields A review of the Watershed Erosion Prediction Project: Disturbance model outputs performed by the hydrology specialist reveals that expected increases are very low across the analysis area. The probabilities of these increases occurring are low to moderate, and generally below 50 percent. These are found in Table 29 of this document. These values are in tons per acre. Thus, the acres that would be burned need to be used as a multiplier to derive modeled yield increases. The fuels specialists provided information on what proportion of the proposed treatment polygons are expected to carry fire. With the patchiness of fuel concentrations and terrain characteristics, this would generally be considerably less than the overall area of the polygons. After reviewing the total sediment production per drainage modeled to be produced if implementation would occur, it is evident that values are, as expected, very low in comparison to known land management activities and natural events such as wildfires, slumps or cut-bank failures.

Temperature Temperatures in the project area are well below thermal limits observed for distribution and survival of the westslope cutthroat trout (Bear et. al. 2007). The westslope cutthroat trout is the most sensitive fish species in the project area to elevated temperatures. In the stream segments containing conservation populations of westslope cutthroat trout low summer temperatures inhibit recruitment. Changes to stream temperature from wildfire are known to usually be minor (Isaak et. al. 2010). The effects of this project would even be less as ignition and control would be managed to preserve shade canopy.

Weeds and Weed Spraying The extent of this activity is analyzed in the range and weeds section of this document. Any increased weed spraying activities connected to the implementation of this project would be performed using certified herbicides in accordance with all label instructions. Only herbicides specified in the Lewis and Clark National Forest Weed Treatment Environmental Impact Statement (USDA FS 1994) would be used. These measures should prevent nearly all direct or indirect effects to aquatic wildlife species (Tatum 2004). It is possible that some amphibians could move into a treated area soon after application. Western toads can move into a clearing from up to 150 meters away (Deguise and Richardson 2009). This could potentially expose them to recently applied herbicide. Scientific literature reveals concern about the toxicity of the glyphosate group of herbicides on toads and other amphibians. The glyphosate group of herbicides, which includes the brand name “Roundup”, has been found to be toxic to juvenile amphibians at overspray levels (Relyea 2005). Glyphosates are not used on the Forest. These were not included in the approved list in the aforementioned Environmental Impact Statement. These chemicals are also non-selective in killing target plant species. There would be no application of glyphosate connected with this project. Herbicides which may be used include picloram mixed with synergistic herbicides such as triclopyr or 2, 4-D. Picloram is considered slightly toxic to fish, and the risk of exposure under US Forest Service application procedures has been considered to be nearly non-existent (Durkin and Follansbee 2003). This same risk assessment on picloram use states that tests on toxicity levels for amphibians were not available. The forest fisheries biologist searched for more recent literature and found picloram listed as “not acutely toxic” to amphibians with LC50 rates for two species of frogs not found in this project area

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(Kegley et. al. 2007). Synergistic toxicity risk is considered to be a rate of toxicity that is higher than individual chemical components that occurs as a result of combing them together. Synergistic toxicity studies of these forestry herbicide mixes, along with the surfactant ingredients, have consistently determined this effect to range from slightly antagonistic to simply additive (Tatum 2004).

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, loss of large woody debris recruitment or temperature increase to streams resulting from the action alternative would be an irretrievable commitment. The stream would recover from these effects over a time period of years to decades. Adherence to all applicable laws, regulations and best management practices would make it unlikely that any irretrievable commitments would result from project implementation. Refer to the forest hydrologists section of this document for more information on habitat commitments. No irreversible commitments can be linked from implementing this project to fish, amphibian, mussel or other aquatic wildlife species. Mortality of aquatic wildlife attributable to the project would be non-existent to very incidental. Chronic sediment delivery from the road system would be reduced at levels that greatly exceed any foreseeable sediment pulses attributable to the project. Sediment pulses would be well below lethal or life cycle threatening levels.

Cumulative Effects

Biological Impacts from past and present land use activities and current infrastructure features such as the road and trail system are present, but at very low levels in the proposed project area. Fishing pressure is present in the project area. The distribution of this pressure varies slightly. There is some hike-in angling along Smith Creek. Otherwise, pressure is very low to non-existent in the project area. Streams are mostly not accessible by motorized travel and trout exceeding 10 inches in length are rare in most stream segments. Fish populations are robust enough in recruitment to compensate for this level of fishing related mortality. Westslope cutthroat trout are vulnerable to being caught when anglers are present. However, Montana state fishing regulations preclude harvesting westslope cutthroat trout in the project area. The introduction of non-native fish species is the most serious and prevalent impact to the viability of westslope cutthroat trout in the project area. Some management actions can be synergistic to egression by non-native fish by manipulating habitat conditions in ways that give the exotic species a further competitive advantage. Eastern brook trout are more tolerant of elevated sediment levels (Shepard 2004). They can also be more tolerant of increased water temperatures in the higher thermal ranges where both can exist (Shephard and others 1998, Shephard 2004). With project area stream temperatures being so cold, this thermal relationship cannot be assumed to be present. It could possibly even inverse as overwinter survival of juvenile westslope would likely increase more for westslope cutthroat trout. Parallel studies are not available to more reliably support analysis and conclusions. Multiple factors combine to determine which species are benefited by natural and management related

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events. The timing and intensity of an event can be as deterministic in influencing competitive balances as the type of effects created by the event. The forest fisheries biologist observed that brook trout dominate low velocity, wood-dam created pools in Smith Creek during electrofishing efforts in 2013. Westslope cutthroat trout were absent to mostly absent in this type of habitat. Pools and runs formed by bedrock and boulder influenced scour tended to have more velocity. These also contained a much higher proportion of westslope cutthroat trout. The habitat parameter in the project area that appears to most impact the competitive balance between brook trout and westslope cutthroat trout is the occurrence of low velocity pools formed by woody debris jams. Beaver activities were not observed in the stream segments inhabited by westslope cutthroat trout. It can be assumed that pools created by beaver-constructed dams would also favor brook trout as velocity ranges would be similar. Cumulative effects from non-native invasive species other than fishes are relatively minimal within the project area. Whirling disease is present downstream of Forest waters, but tests on and near the forest have been negative for presence. The non-native chytrid fungus (Batrachochytrium dendrobatidis) has been linked to declines in infected populations of amphibians across Montana (Maxwell 2009). There are no known records of observations of non-native aquatic plant invasions on the Forest that impact the abundance of any native aquatic organisms. There are several naturally occurring fish diseases that are or could be present with low levels of infection. Bacterial kidney disease is present in local waters. This disease can infect native and non- native trout (salmonid) species; however, outbreaks of this disease are mainly a concern in hatcheries where fish are in densities well above natural conditions. Fish in the Forest vicinity are routinely tested for six other diseases by the Montana Department of Fish Wildlife and Parks. Tests on and near the Forest have been negative for the presence of these.

Physical Habitat Most of the physical stream habitat in the project area has changed very little from historical conditions. The primary area that has some modifications is the portion of Elk Creek with road adjacency. A few areas of a more limited scale contain a concentration of cattle access and related modifications. These are scattered through portions of Petty Creek, Jakie Creek, Moudess Creek, and the two main-stem streams. One area in Petty Creek appears to contribute enough sediment to be noticeable in downstream segments. The 1988 Canyon Creek Fire led to some debris flows likely followed by several years of increased sediment yields. Several high run-off years, including 2011, have provided the energy necessary to transport away these yields. This expectation is based on processes governed by the laws of physics. Without factors in-place that create chronically elevated yields of fine-sediments or function to entrain or trap sediment within substrates, high flow events will transport away stored sediment as the laws of physics are never broken. Extensive field visits determine that sites with chronically elevated yields are limited in size and number. A few near-stream, shale dominated areas and the aforementioned livestock congregating areas comprise these. Mechanisms that trap sediment within coarser substrates such active glaciers creating rock-flour, some known types of mining activities, and large inputs of road materials with clay, pit-run or unwashed, crushed gravel related binders are not present in the project

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area. The same field visits found that substrates were in an open condition and concentrations of fines were generally low. The hydrology section contains a more detailed description of sediment and water yield cumulative effects.

Conclusions by Alternative

No Action The full attainment of beneficial uses related to fisheries and aquatic wildlife is being met in the streams of all of the sixth order sub-watersheds in which prescribed fire activities are proposed. Under the no- action alternative this would continue to occur. Westslope cutthroat trout would be under a higher risk in future decades of wildfire influenced debris flows containing high concentrations of fine sediment. The increase risk of wildfire could also result in increased recruitment of coarse woody debris. This would appear to benefit eastern brook trout at the expense of westslope cutthroat trout. Other actions connected to the project and cumulative effects would change at levels too small to be likely to affect recruitment or population sizes of fish and aquatic wildlife populations. Grazing related impairments would likely remain at similar levels. There would likely be somewhat less weed spread and spraying in this alternative. This would result in a very small reduction of risk for future impairments to riparian habitat quality and resiliency. There does not appear to be a significant fish and aquatic wildlife issue related to the implementation of this alternative as tested for context and intensity within the 10 National Environmental Policy Act points of significance as defined in the Council on Environmental Quality regulations (40 Code of Federal Regulation, Part 1508.27).

Proposed Action The full attainment of beneficial uses related to fisheries and aquatic wildlife would still be met in the streams of all of the 6th order sub-watersheds in which prescribed fire activities are proposed. This includes recreational uses of these resources as well as those related to species concerns such as viability, diversity, and richness. Slightly increased sediment yields, persisting for five to seven years, is the expected impact that required the most analysis to form a biological conclusion on effects to fish and aquatic species. The outputs of modeling efforts were analyzed within the context of field assessments of existing conditions and relevant scientific information. Streams were analyzed to determine if there were any with dynamics that would cause these low-level, non-persistent yield increases to rise to a level of concern. These were further assessed for population levels, genetic purity, and resiliency to sediment inputs. The determination of this assessment is that actions connected to this alternative would not increase viability threats to sensitive aquatic species or decrease the carrying capacity for other aquatic wildlife species. The attached biological evaluations provide more of this information at species-specific levels. There would potentially be beneficial effects of implementing this alternative to aquatic fish and wildlife species. A reduction in the risk of future catastrophic fire events, including those that would lead to debris flows of materials with high concentrations of fine sediments, would be expected. Increases in

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various trophic levels of the fish and aquatic wildlife food-web would possibly result due to nutrient releases and entry (Spencer et al. 2003; Minshall 2003; Minshall et al. 2001). Definitively concluding that future wildfire events that would be non-beneficial to aquatic wildlife species would be prevented by this alternative is not possible. This is also true for concluding that the beneficial effects of implementing this alternative would occur at levels high enough to be measurable. What is definitive is that fire has historically asserted an active role in shaping the sediment budgets of this landscape, and this will continue regardless of human intervention. Effects from fires of various intensities and spatial patterns on aquatic wildlife populations, and especially fish species, is complex and difficult to predict (Dunham et al. 2003). Thus, effects are not being concluded to be beneficial, but it is recognized that there appears to be characteristics of beneficial effects associated with this alternative. Native aquatic wildlife species are likely to do better in a fire regime that is being brought closer in congruency with the historical parameters of frequency, intensity, and scale. There does not appear to be a significant fish and aquatic wildlife issue related to the implementation of this alternative as tested for context and intensity within the 10 NEPA points of significance as defined in the Council on Environmental Quality regulations (40CFR, Part 1508.27).

Forest Plan Standards Compliance For details on this project’s consistency with the Lewis and Clark National Forest Plan see Appendix E of this document and the Fisheries specialist report in the project record. Recreation The Recreation Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019), the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 143 to 146) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to recreation resources. The treatment effects are as originally analyzed and there are no changes to the recreation portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 110 to 112).

Existing Condition In relation to recreation, the Elk Smith Project area is used by the public for hiking, horseback riding, camping, fishing and hunting. Use levels in this area are light to moderate throughout the snow free season with the fall hunting season (both bow season and general rifle season) likely being the time of year that the area sees the most use. The project area sees a low to moderate level of interest from the pubic for day hiking and overnight hiking (backpacking) and stock parties. Access to trails is from a number of trailheads around the perimeter of the project area. One trailhead is located right on the edge of the project area but is not located within a proposed treatment unit. Some use trails through the project are to access longer trip routes to the west into the Scapegoat Wilderness Area.

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Overnight camping use by the public is low to moderate within the project area. Camping opportunities within and near the project area primarily consist of the use of backcountry dispersed sites with no improvements or road accessible sites with minimal if any improvements. Access to a large majority of these sites is by trail travel. Most dispersed campsites are adjacent to a trail in very close proximity to a stream. Fishing is a popular activity along some streams within the project area with Smith Creek being of the most interest. This activity attracts a moderate level of use from the public during the summer and is surpassed only by hunting in the fall in relation to visitation to this geographic area of the National Forest. Big game hunting for elk and deer in the fall of the year is by far the most popular use of this area. Most hunting use is on a day use basis. A few groups each year do pack in and set up overnight camps. There are no commercial outfitter camps within the project area. There are 15 Forest Service System trails within the project area totaling approximately 34.1 miles. Of the approximate 34.1 total miles of trail within the overall project area, there are approximately 11.8 miles of trail that are within proposed treatment units. There are approximately 28 known locations (dispersed campsites) that show evidence of past recreational use by the public within the project area. There is one developed trailhead within the project area. Of the 29 recreation sites within the project area, there are six dispersed campsites that are within proposed treatment units. Currently off trail travel on foot or horseback within much of the project area is difficult to impossible due to extremely dense regenerating tree saplings and downfall as a result of the 1988 Canyon Creek Fire.

Environmental Consequences

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary. The cumulative effects section extends to include the project area boundary. Temporally speaking, short-term effects are defined as effects that would impact the recreating public only during the time of actual implementation or shortly afterward. Long-term effects are considered to be potential effects to the recreating public that may be present beyond the implementation phase of the Elk Smith Project.

Sources, Methods, and Assumptions The methodology used in this analysis includes data from the Trails INFRA Database and Dispersed Recreation Site INFRA Database. Geographic information systems was used to understand the number and mileage of National Forest System Trails within the project area and the number of trails that are within proposed treatment units. Geographic Information System was also used to analyze and display the number of dispersed recreation sites that exist within the project area as well as within treatment units. Input from recreation resources staff members of the Rocky Mountain Ranger District was used to describe the existing condition related to recreational use of the area by the public as well as what the potential effects might be to public recreation by the implementation of this project. The following assumptions were made regarding this analysis: Overall public recreation use in this area is light to moderate throughout the year. Potential effects to the recreating public within the project area are related to trail use, dispersed site camping and off trail foot and horse travel. Potential impacts would

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tend to be of short duration during the actual time of implementation. Potential effects to the recreating public associated with this project fall into three distinct categories; 1. Potential effects to trail travel. 2. Potential effects to dispersed campsite use and 3. Potential effects to off trail travel and access.

No Action Alternative

Direct and Indirect Effects 1. Potential Effects to Trail Travel: The potential effects to trail travel by taking no action from this proposal would result in a continued trail maintenance need over time as residual standing dead trees from the 1988 Canyon Creek Fire will continue to fall blocking the trail system in some locations. Taking no action would result in no need for any temporary trail closures due to management activities associated with this proposal. 2. Potential Effects to use of Dispersed Recreation Sites / Trailheads: Taking no action could result in a decreased use of the dispersed recreation sites as the extremely dense regenerating tree saplings and downfall as a result of the 1988 Canyon Creek Fire would still be present and block access and or pose safety concerns in some locations. 3. Potential Effects to Off Trail Travel and Access: The no action alternative would not present the opportunity to improve off trail travel conditions because the forest would not be opened up by treatment actions proposed in this project. Potential wildfire intensity would be expected to be higher under the no action alternative, consequently, increasing the potential for the likelihood of more standing dead trees in the area if a wildfire were to occur. Additionally, there would be continued increased difficulty in navigating off trail travel because the extremely dense regenerating tree saplings and downfall that resulted from the 1988 Canyon Creek Fire would not be treated in this area.

Cumulative Effects No cumulative effects to recreation are anticipated in relation to other actions in or near the project area as a result of taking no action.

Direct and Indirect Effects 1. Potential Effects to Trail Travel: The potential effects to trail travel by the implementation of this project are expected be minimal and of a short duration in time. Actual effects to the public from the need to close some trail segments for

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public safety within or adjacent to treatment units would involve not being able to use and traverse these trails during the time of actual implementation and for a very short time following treatment. In addition, there may be a period of time (several years) following implementation that there may be some level of increased downfall across trails within and adjacent to treatment units because individual trees or small groups of trees may near the trails die as a result of prescribed burn treatments. The potential for increased downfall following implementation could be acceptably mitigated by initiating routine monitoring of trail conditions within the project area and responding in a timely manner with an increased trail clearing emphasis on any sections of trail that exhibit elevated levels of downfall. 2. Potential Effects to use of Dispersed Recreation Sites / Trailheads: Some areas containing dispersed recreation sites within the project areas may need to be closed for public safety for a short period of time during actual project implementation and potentially for a short period of time after implementation. Some dispersed recreation sites that are within treatment units may have an elevated level of snag hazard (hazards associated with falling trees in burned areas) after implementation. Any elevated snag hazard in direct proximity to a dispersed recreation sites could be mitigated by having qualified personnel perform a Hazard Tree Evaluation of trees in proximity to sites within treatment units and then having crews fall any tree that poses a significant risk. This may need to be done immediately following implementation and also a second time in the spring of the year following implementation. However, it should be noted that while the agency does routinely take steps to evaluate and mitigate snag hazards within Developed Recreation Sites, it generally does not attempt to mitigate snag hazards in most Dispersed Recreation Site settings. 3. Potential Effects to Off Trail Travel and Access: This project has the potential to significantly improve recreational off trail travel conditions in some locations by removing some of the extremely dense stands of regenerating saplings and also to “clean up” downfall through the use of prescribed burning. In some locations within treatment units off trail travel conditions for the public may be notably improved by the implementation of this project.

Cumulative Effects No cumulative effects to recreation are anticipated in relation to other actions in or near the project area as a result of this proposal. Heritage The Heritage Specialist reviewed the projects proposed action, 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019), the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 146 to 151) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to heritage resources. The treatment effects are as originally analyzed and there are no changes to the heritage portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 113 to 116).

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Existing Condition There are no known cultural properties in the project area that cannot be avoided or have project effects mitigated under provisions in the Programmatic Agreement arranged between Region 1 of the Forest Service, the Montana State Historic Preservation Office, and the Advisory Council on Historic Preservation. Heritage resources or cultural resources are broad and synonymous terms referring to cultural, historic, archaeological, and ethnographic properties and traditional lifeway values representing past, and in some cases, continuing human activities or uses. By their nature, historic resources are nonrenewable, easily damaged, and with few exceptions, irreplaceable.

Environmental Consequences

Area of Analysis For the purposes of this analysis, the project area boundary described in Chapter 2 is used as the general “heritage analysis area.” This area is researched for contextual information and for the existence of, or potential for the occurrence of cultural resources. Within this broad analysis area, a site-specific “area of potential effect”, is intensively analyzed under National Historic Preservation Act Section 106 review. The area of potential effect varies by alternative dependent on the location and nature of proposed treatments and of cultural resources. For this analysis, the area of potential effect includes locations of proposed activities and a buffer zone 100-feet beyond these areas. When a cultural resource site falls within or overlaps the area of potential effect, regulations require that the effects analysis be expanded to include consideration of that entire site (often including a site-specific buffer zone). Heritage resources in the non-Wilderness portion of the Rocky Mountain Division of the Helena- Lewis and Clark National Forest represent a diversity of cultures and landscape use. They represent cultural contexts that include pre-contact subsistence and art, Native American traditional and religious use, early white settlement, trapping, agriculture, logging, transportation, forest administration, recreation, irrigation, and even human burial. Project area sites or features related to these contexts include two pre-contact lithic material scatters (24LC1286 and 24LC2317), a special use permitted guest ranch (24LC2199), roads (including 24LC2008), and a logger’s steam donkey. Recognized historic districts and landscapes that overlap the project area are limited to the Forest Service Historic Trails System. Petty Ford Creek Trail 244 (24LC1288) through the north part of the project area is part of the trail system. The Elk Creek Ranger Station (24LC2198) represented Forest Service Administrative presence in the project area. It is shown on Forest maps from 1912 through 1956. It is not on the 1977 Forest map and no buildings are standing. The Double Falls tract of leased recreation cabins is located near the analysis area. The project area itself has relatively few recorded sites, mainly due to steep terrain and relatively few archeological surveys to date.

Effects Analysis Methods The key indicators for cultural resource analysis are generally: 1) the list of sites, by type, that are eligible for or included in the National Register of Historic Places, or those that have not been evaluated, which overlap with proposed activities; 2) the potential for the occurrence of cultural resources in areas that have not previously been surveyed; and 3) the nature of the proposed treatments. Undertakings

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involving ground disturbance or those that may adversely affect the character of significant cultural resources are primary considerations of the National Environmental Policy Act effects analysis. Sites that have been evaluated and found ‘not eligible’ (insignificant) according to criteria of 36 Code of Federal Regulation 60.4 are reviewed for context, but not otherwise carried forward into the analysis. The Regional Programmatic Agreement and the Forest-specific Site Identification Strategy address details of National Historic Preservation Act Section 106 compliance. They prescribe certain percentages of survey coverage for various types of undertakings, in order to adequately complete Section 106 effects analysis. The amount of survey and research anticipated depends on the undertakings involved. Information from this portion of the analysis assigns the ‘potential for the occurrence of cultural resources’ used in both National Environmental Policy Act and National Historic Preservation Act review. Information from historic maps, the heritage resource database, and from numerous surveys done in the project area identifies specific locations of pre-contact and historic sites relative to proposed impact areas. This information provides historic context and helps identify both specific sites present and the kind of sites, which may exist across the project area. To date, nine heritage survey projects have been done inside the project area, intensively covering 432 acres including the range of topographic settings, which comprise the project area. Survey sampling strategies favor high site probability areas and comply with the Site Inventory Strategy that is part of the Programmatic Agreement. Because of especially poor surface visibility caused by regrowth following the 1988 Canyon Creek Fire, and because most project-area sites were thought to have burned in that fire, the Forest proposed to do most of the required heritage surveying soon after the units are re-burned, to take advantage of improved ground surface visibility. The State Historic Preservation Office concurred with this plan on April 1, 2015. For the known significant or unevaluated sites, avoidance or mitigation of impacts would be arranged ahead of prescribed burning. Surveys done to date have covered 4 percent of the proposed impact area. These would be supplemented with additional surveys, to ultimately cover 30 percent of the prescribed fire treatment acres. Post-prescribed burn surveys are a standard modus operandi for prescribed burn projects. Newly identified sites would be recorded and evaluated for significance.

No Action Alternative

Direct and Indirect Effects Under the No Action Alternative, all effects would be indirect effects. They would include on-going trends of increasing traffic, hunting and recreation activities; grazing pressure; wildfire risk; insect infestation; climate change; and erosion, compaction, and site exposure related to those situations. Of those effects listed, only wildfire risk and insect infestation are addressed by the proposed project. Choosing the No Action Alternative would not cause significant effects to cultural sites.

Cumulative Effects The area of analysis for this No Action Alternative is the project area boundary, the same area considered for the Action Alternative. No cumulative effects to cultural resources were identified for the No Action Alternative.

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Proposed Action

Direct and Indirect Effects This alternative proposes broadcast and jackpot burning, and hand felling, piling, and burning. Specific proposals relative to each cultural resource site are shown in Table 31. The historic routes (‘linear’ sites) are current Forest system routes. They would not be directly affected. If boundaries of the other sites (‘point’ sites) are pretreated with blackline or wetline, or avoided in the case of the one near a unit, they would not be affected either. Both known point sites are on or near unit boundaries. Forest heritage specialists would work with project planners to arrange site avoidance both in project plans and on the ground, to effectively and discreetly avoid sites. ‘Flag and avoid’, blacklining, or wetlining techniques comply with heritage preservation requirements. Because most project-related heritage surveying would occur after units are burned, it is possible currently unrecognized sites would be burned as part of project implementation. Project fire intensities would rarely or never approach what sites were subject to during the intense 1988 Canyon Creek Wildfire. It is likely that any combustibles that were site components burned during that fire and that the prehistoric sites have burned before then, too. Although Unit 1 and part of Unit 2 did not burn in 1988, it can be assumed those areas have also burned in the past. Indirect effects of the project that could affect sites include creation of vegetation breaks and changes in vegetation succession patterns. These changes would be only temporary visual effects, however. More importantly, there are potentially beneficial indirect effects. In the event of wildfires, vegetation breaks created by the burns might serve as firebreaks or to moderate wildfire intensity and reduce the need for dozer lines, retardant drops, or fire camps, which can disturb sites.

Cumulative Effects The area of analysis for the Action Alternative includes the project units and a 100-foot buffer around them. Past, present, and reasonably foreseeable actions in the area, unrelated to project proposals, were considered (Appendix D). Those potentially affecting sites include tree removal and grazing. Proposed actions involve prescribed burning. It is effects to sites can be avoided. Choosing the Action Alternative would not cause cumulative effects to sites. Also, as mentioned above, the prescribed burning treatments could limit future wildfire scale and/or intensity, reducing the need for suppression activities that can damage sites. This would reduce cumulative effects to sites, in the end.

Summary For the proposed action alternative, the site avoidance measures are expected to protect known sites from significant impacts. Some project areas have already been surveyed for cultural resources. Future surveys are planned following implementation to take advantage of improved ground surface visibility. The State Historic Preservation Office has agreed this approach complies with National Historic Preservation Office Section 106 regulations. It also complies with the Forest Plan. If additional sites are identified as part of project surveys, consultation with the State Historic Preservation Office would determine whether they are historically significant.

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Comparison of Alternatives Analysis started by considering all known project area sites for an indication of site types, densities, and potential settings applicable to the proposed range of activities. Recorded pre-contact sites inside the project area are limited to two lithic material scatters (24LC1286 and 24LC2317), both considered to be potentially eligible to the National Register. Recorded historic sites include Petty Ford Creek Trail 244 (24LC1288) and Cyanide Creek Road 257 (24LC2008), unevaluated for significance and so potentially eligible to the National Register; the site of the former Elk Creek Ranger Station (24LC2198), not eligible; and Sky Mountain Guest Ranch (24LC2199), not eligible. The types of actions being considered that could disturb cultural resources include broadcast and jackpot burning and hand treatment involving piling and burning. Lop and scatter hand treatment would not disturb cultural resources. Proposed actions would have design options to allow for site avoidance.

Table 31: Historic Properties and Proposed Actions, Based on Alternative. Preferred Alternative Site & Eligibility. No Action Preferred Alternative Site Avoidance/ Status Alternative Action for Relevant Unit Mitigation Measures Slash and burn conifers encroaching on natural openings and aspen stands 24LC1286, Lithics, Near a unit. Staging & n.a. Fell young conifers (<7” diameter at breast height) using power implementation activities potentially eligible saws over portions of unit must avoid site area. Broadcast burn utilizing hand ignition Slash and burn conifers encroaching on natural openings and aspen stands. Use prescribed fire in existing aspen clones to Inside a unit. Create 24LC2317, Lithics, encourage suckering. blackline or wetline n.a. potentially eligible Fell young conifers (<7” diameter at breast height) using power around site to avoid saws over portions of unit burning across site. Broadcast and jackpot burns utilizing hand ignition Slash and burn conifers encroaching on natural openings and Forms a unit boundary. 24LC1288, Petty aspen stands Implementation activities Ford Cr. Trail 244, n.a. Fell young conifers (<7” diameter at breast height) using power to avoid historic signs potentially eligible saws over portions of unit and blazes Broadcast burn utilizing hand ignition Slash and burn conifers encroaching on natural openings and aspen stands. Use prescribed fire in existing aspen clones to encourage suckering. Fell young conifers (<7” diameter at breast height) using power saws over portions of unit. Broadcast and jackpot burns utilizing hand ignition. Broadcast burn utilizing combination of helicopter and hand ignition 24LC2008, Cyanide No effect to road or its Cr. Rd 257, n.a. Reduction of 30-50 percent in conifer regeneration in patches of features, all modern. potentially eligible approximately 20 to 100 acres Reduction of heavy surface fuel loadings in patches of approximately 20 to 100 acre Target amount burned 202 to 337 acres (treat 30-50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. 24LC2198, Elk Cr. None needed due to site n.a. Proposal irrelevant due to site ineligibility. Ranger Station, no ineligibility.

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Preferred Alternative Site & Eligibility. No Action Preferred Alternative Site Avoidance/ Status Alternative Action for Relevant Unit Mitigation Measures 24LC2199, Sky Mtn. None needed due to site n.a. Proposal irrelevant due to site ineligibility. Ranch, no ineligibility

Wildlife Wildlife Report Update: The “Wildlife Report and Biological Evaluation, Elk Smith Project” was finalized on December 20, 2018. Since that time, the “Record of Decision for the Forest Plan Amendments to Incorporate Habitat Management Direction for the Northern Continental Divide Ecosystem Grizzly Bear Population, Helena-Lewis and Clark National Forest, Kootenai National Forest, Lolo National Forest” [Grizzly Bear Amendment] was released. This decision amended the Lewis and Clark Forest Plan by incorporating habitat-related management direction on National Forest System lands within the Northern Continental Divide Ecosystem primary conservation area, zone 1, and zone 2. The Elk Smith project is located within the primary conservation area. Existing Lewis and Clark Forest Plan standards for grizzly bear habitat were not changed except where they were outdated or conflicted with the amended plan direction. Standards that were changed or removed are noted and consistent with existing standards is provided in Appendix E the updated Forest Plan consistency table and in the project record. The Elk Smith project is consistent with all applicable standards and guidelines in the Grizzly Bear Amendment (more detailed information can be found in the project record). Consultation on grizzly bear was not updated or reinitiated because 1) no new information has been received or generated that reveals affects, which may impact grizzly bear or their habitats in a manner or to an extent not considered in the previous biological assessment; 2) the Proposed project has not been subsequently modified in a manner that causes an effect to grizzly bear, which was not considered in the previous biological assessment. Additional updates to the wildlife analysis include wolverine, Canada lynx, and Canada lynx designated critical habitat. The wolverine analysis area and project effects were updated, to include section 7 consultation with the US Fish and Wildlife Service on project effects to wolverine. The Canada lynx and lynx critical habitat analyses were updated with information from the 2020 Tri-County WUI, effects assumptions to changes in mapped lynx habitat structural stages, as well as submission of an updated section 7 consultation to the US Fish and Wildlife Service based on those changes.

Existing Condition The Elk Smith Project Forest Vegetation Report (in the project record) describes the existing condition of vegetation in the project area. The 1988 Canyon Creek wildfire impacted 74 percent of the project area and resulted in either very dense lodgepole pine forest or areas with very low densities or no trees. There are also many aspen stands scattered throughout the project area (Units 1, 2, 6, 7, 8, 9, 11, 12, and 13). Habitat types identified in the Forest Vegetation Report were used to determine potential

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shrub, forb and grass species present in the project area using the methodology discussed in the Blankenship Vegetation Treatment Project Understory Vegetation Report (USDA FS 2012a).

Grizzly Bear The Revised Biological Assessment For Terrestrial Wildlife Species – Benchmark Hazardous Fuels Reduction Project (USDA Forest Service 2010) and Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities (Evaluation and Compliance Report; USDA Forest Service 2011) provide information on grizzly bear habitat and species status on the Forest. The Elk Smith Project is within the Scapegoat Subunit of the Dearborn Elk Creek Bear Management Unit and the South Fork Willow Subunit of the South Fork Sun Beaver Willow Bear Management Unit (Appendix A of the wildlife specialist report in the project record). Existing acres of habitat in these subunits is displayed in Table 32. Twenty-one percent of the Scapegoat Subunit and 36 percent of the South Fork Willow Subunit are mapped denning habitat. Mapped denning habitat identifies high elevation areas where bears could excavate a den, generally in an open, steep site where snow cover during the winter is high. Mapped spring habitat is 44,051 acres in the Scapegoat Subunit and 42,105 acres in the South Fork Willow Subunit. The majority of Forest Service Lands in the Scapegoat Unit is Management Situation 1 (57,738 acres), with three acres of Management Situation 3 in the subunit. The South Fork Willow subunit includes 89,955 acres of Management Situation 1 lands and 6,592 acres of Management Situation 3 lands. Blanchard (1978) documented that grizzly bears in the Greater Yellowstone ecosystem need open areas for feeding interspersed with nearby areas of cover. Bears in the Northern Continental Divide ecosystem generally prefer to forage in areas with some type of cover nearby and thrive in landscapes with numerous different habitat types (Aune and Kasworm 1989, Mace and others 1997, Waller and Mace 1997). The project area provides little habitat for grizzlies in its current condition as the dense forest does not provide foraging habitat, nor does it provide for travel or access to den sites.

Table 32: Grizzly Bear Habitat by Subunit. South Fork Sun Beaver Dearborn Elk Creek Bear Willow Bear Management Unit – Management Unit – South Scapegoat Subunit Fork Willow Subunit

Total acres of Bear Management Subunit 100,944 120,783 Acres of Subunit within Elk Smith Project 22,451 1,766 Percent of Subunit within Elk Smith Project 22.2 percent 1.5 percent Acres of proposed treatment units in Subunit 10,310 19

Percent of Subunit in proposed treatment units 10.2 percent 0 percent

Acres mapped denning habitat in Subunit 21,250 42,914 Acres mapped denning habitat in project area 5,094 351

Acres mapped denning habitat in proposed treatment units 817 0

Percent mapped denning habitat in proposed treatment units in 3.8 percent 0 percent Subunit

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South Fork Sun Beaver Dearborn Elk Creek Bear Willow Bear Management Unit – Management Unit – South Scapegoat Subunit Fork Willow Subunit

Acres mapped spring habitat in Subunit 44,051 42,105 Acres mapped spring habitat in project area 9,143 1,088

Acres mapped spring habitat in proposed treatment units 4,688 19

Percent mapped spring habitat in proposed treatment units in 10.6 percent 0 percent Subunit

Acres of Management Situation 1 in Subunit 57,738 89,955 Acres of Management Situation 3 in Subunit 3 6,592

Acres of MS-1 in proposed treatment units in Subunit 10,310 16

Percent of MS-1 in proposed treatment units in Subunit 17.9 percent 0 percent

Acres of MS-3 in proposed treatment units in Subunit 0 3

Percent of MS-3 in proposed treatment units in Subunit 0 percent 0 percent

Canada Lynx The Elk Smith Project Area includes portions of five Lynx Analysis Units (Table 33). Most of the project area is within Lynx Analysis Unit RM-25 (Figure 7). Table 34 displays the acres of existing lynx habitat within Lynx Analysis Unit RM-25 by structural stage, as described in the Northern Rockies Lynx Management Direction Record of Decision Attachment 1 (USDA FS 2007a). Lynx habitat was queried in Lynx Analysis Unit RM-25 and the four Lynx Analysis Units surrounding it (RM-22, RM-23, RM-24, and RM-26) using the Canada Lynx Habitat Mapping for Region 1 Eastside Forests (USDA Forest Service Northern Region Geospatial Group 2016), as modified (USDA Forest Service 2016b). The query modifications were made based on field data and knowledge of the project area. The query uses a spatial layer of Potential Natural Vegetation, along with spatial information on timber and fire activity, in combination with the Northern Region Existing Vegetation Mapping Program, to determine primary vegetation (subalpine fir dominated by cover types of spruce/fir, Douglas-fir, and seral lodgepole pine), secondary vegetation (other cool, moist habitat types, e.g. some Douglas-fir), and dry forest habitat types (ponderosa pine, dry Douglas-fir, and dry or climax lodgepole pine) as described in Appendix B of the Northern Rockies Lynx Management Direction Final Environmental Impact Statement (USDA Forest Service 2007b). Dry Douglas-fir and lodgepole were determined using aspects of west, southwest, south and southeast based on knowledge of vegetation in the project area.

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Figure 7: Canada lynx analysis area and the Elk Smith Project.

Table 33: Lynx Analysis Units in the Project Area. Acres in Elk Smith Acres in proposed Lynx Analysis Unit Total Acres Project Area treatment units RM-22 24783.6 0.5 0 RM-23 19475.6 602.8 0 RM-24 23909.0 10.7 0 RM-25 19720.0 19720.0 8897 RM-26 15759.7 12.7 0

Within Lynx Analysis Unit RM-25, fifty-seven percent (11,148 acres) of the lynx analysis unit is lynx habitat (Table 33 and Table 34). Due to the Canyon Creek wildfire, approximately 7,182 acres of the habitat currently provides snowshoe hare habitat in the stand initiation and early stand initiation structural stages. Over half of this hare habitat (5,967 acres) is available in winter (stand initiation structural stage). There is very little mature, multi-story habitat, the preferred lynx foraging habitat in winter, in the lynx analysis unit (1,220 acres, 11 percent). Horizontal cover board surveys were conducted across the project area with results located in the project file.

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Table 34: Lynx Analysis Unit RM-25 Habitat. Lynx habitat RM- Acres early Acres stand Acres Acres stem Acres other 25 stand initiation initiation Multistory exclusion Existing condition 1,215 (11%) 5,967 (54%) 1,220 (11%) 1,328 (12%) 1,418 (13%) Post- 3,322 (29.7%) 4,092 (36.7%) 1,220 (10.9%) 1,241 (11.1%) 1,260 (11.3%) Implementation The Elk Smith Project is along the eastern boundary of Unit 3 (Northern Rockies Unit) (Appendix A of the wildlife specialist report in the project record) of designated critical habitat for Canada lynx (USDI Fish and Wildlife Service 2014a). As such, the project area and surrounding lands to the north, west, and south have been identified as containing the primary constituent element, which is “the physical or biological features essential to the conservation of lynx in areas occupied at the time of listing” (USDI FWS 2014a, page 54811). The primary constituent element for lynx is boreal forest landscapes supporting a mosaic of differing successional forest stages and containing: (a) presence of snowshoe hare and their preferred habitat conditions; (b) winter conditions that provide and maintain deep fluffy snow for extended periods of time; (c) sites for denning that have abundant coarse woody debris; and (d) matrix habitat to connect patches of boreal forest.

Wolverine The analysis area for wolverine will be those 14-digit HUC watersheds that overlap the project area boundary. This equates to an area approximately 36,000 acres in size (57 mi2). The average home range of an adult female wolverine near Glacier National Park has been reported at 55 mi2 (USDI Fish and Wildlife Service 2013). Wolverine habitat across the project area is modeled by Copeland et. al. (2010) and Inman et. al. (2013). The Copeland model (Copeland et. al. 2010) relies on the number of years snow persists until May 15 to indicate areas where wolverine may den. This research was conducted across a large area of the northern hemisphere where wolverine occur, including Scandinavia, Northern Canada, and south into Montana, Idaho, and Wyoming. Copeland and others (ibid) evaluated known wolverine den sites compared against snow persistence modelling to determine areas where wolverine denning habitat is likely to occur, providing graduations of that habitat based on snow persistence in years. Areas with fewer years of snow persistence are generally correlated with a lower probability of denning, with Copeland et al. (ibid) finding that 69% of North American wolverine dens occurred in areas with persistent snow six out of seven study years. Under the Copeland model, there are 370 acres where snow persists in four out of seven years; 2,078 acres where snow persists in three out of seven years; 3,121 acres where snow persists in two out of seven years; and 6,632 acres where snow persists in one out of seven years (Table 35). There are no acres of habitat in the analysis area where snow persists at least six out of seven study years in the Copeland model (ibid). Inman and others (2013) modelled maternal habitat (suitable for use by reproducing females) and primary habitat (areas suitable for survival and use by resident adults), which used radio-telemetry data collected in the Yellowstone Region of the United States and Resource Selection Function modelling. In the Elk Smith analysis area, there are 361 acres of maternal habitat and 6,254 acres of primary habitat.

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Table 35: Wolverine Habitat. Acres (percent) in Post-implementation Model Existing Acres proposed treatment Acres units 6,632 2,684 (40%) 6,632 1 year persistent snow

3,121 1,031 (33%) 3,121 2 years persistent snow Copeland and others 2010 2,078 139 (6%) 2,078 3 years persistent snow

370 0 (0%) 370 4 years persistent snow

361 1 (<1%) 361 Maternal habitat Inman 2013 6,254 642 (10%) 6,254 Primary habitat

31,449 8,840 (28%) 31,449 Dispersal

The results of the two models are similar in the project area.

Black-backed Woodpecker and American Three-toed Woodpecker Black-backed woodpecker prefer densely stocked forests that have recently burned, with population numbers highest from one to six years after the fire (Hutto 2008). The Canyon Creek wildfire created the preferred habitat for black-backed woodpecker, however, the fire occurred over 25 years ago, and the post-burn habitat is now absent. In the absence of burned forest black- backed woodpeckers are thought to disperse and forage on bark beetle outbreaks in old forest stands (Hoyt and Hannon 2002; Saab and Dudley 1998). Between 2009 and 2010, mountain pine beetle activity increased in the northwest corner of the project area, creating foraging habitat for black-backed woodpecker. As described in the Evaluation and Compliance Report (USDA Forest Service 2011), American three-toed woodpecker are found in dense coniferous forests with optimal habitat having 42 to 52 snags per 100 acres measuring 12 to 16 inches diameter-at-breast-height and 20 to 40 feet tall. Per the Forest Vegetation Report, there is an average of 22 dead trees per acre greater than 10-inches in diameter with variable density across the project area. Snags and downed wood within the project area provide foraging habitat for three-toed woodpecker.

Bighorn Sheep Bighorn sheep activity primarily occurs on the Northeast boundary of the project, with some use occurring in the Steamboat Mountain and Elk Creek area (Lonner 2016). There are 1,005 acres of winter range and 191 acres of lambing range mapped along the northeast border of the project area (Table 36 and the Bighorn Sheep Range Map in Appendix B of the wildlife specialist report in the project record).

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Gray Wolf Based on habitat preferences identified in the Evaluation and Compliance Report (USDA Forest Service 2011), there is little preferred habitat in the Elk Smith Project Area. There are no known den or rendezvous sites in the project area, however wolves likely use the area occasionally.

Northern bog lemming The only known bog lemming location on the Forest is along Wood Creek, northeast of the project area. The presence of sphagnum moss seems to be the key indicator of habitat. Although not known to occur in the project area, surveys are not complete.

Elk Elk occur within the project area. There are 1,360 acres of winter range and 9,164 acres of calving range (see Elk Range Map in Appendix B of the wildlife specialist report in the project record) in the Elk Smith Project Area (Table 5 of the wildlife specialist report in the project record). Effective Hiding Cover was calculated for this project as described in Process for Analyzing Big Game Cover (USDA Forest Service 2016a). The Existing Effective Hiding Cover ranges from to 87.2 percent across 18 seventh code watersheds (Table 6 of the wildlife specialist report in the project record).

Mule Deer and White-tailed deer Mule deer habitat within the project area include winter range (2,488 acres) and transitional range (15,371 acres) (Table 7, see Mule Deer Range Map in Appendix B of the wildlife specialist report in the project record). Fawning habitat is not mapped, however fawning occurs in the area. White-tailed deer use occurs on the lower elevations of the project, this species primarily uses lower elevation private lands.

Table 36: Big game habitat. Acres (percent) in Existing Acres in Existing Acres in Species Habitat proposed treatment cumulative effects project area units boundary Winter range 1,360 391 (29 percent) 18,851 Elk Calving range 9,164 3.767 (41 percent) 14,569

Transitional range 15,371 6,717 (44 percent) 19,688 Mule deer Winter range 2,488 390 (16 percent) 23,988 Winter range 1,005 11 (1 percent) 8,262 Bighorn sheep Lambing range 191 0 0

White-tailed deer Winter range 0 0 0

Mountain goat Occupied yearlong 3,228 347 (11 percent) 6,142

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Table 37: Effective hiding cover. Acres Effective Post- implementation Existing Acres (percent) Watershed (HUC7) Total acres Hiding Cover Acres (percent) Effective Effective Hiding Cover removed Hiding Cover 10030104050104 1,064.4 662.5 (62.2 percent) 0 662.5 (62.2 percent) 10030104050105 767.8 669.4 (87.2 percent) 0 669.4 (87.2 percent) 10030104050203 2,992.5 1,714.5 (57.3 percent) 38.1 1,676.4 (56.0 percent) 10030104050204 3,461.2 1,535.4 (44.4 percent) 64.4 1,471.0 (42.5 percent) 10030104050205 2,599.2 1,082.7 (41.7 percent) 263.6 819.1 (31.35 percent) 10030104050206 1,206.4 562.8 (46.7 percent) 187.1 375.7 (31.1 percent) 10030104050207 1,441.3 805.5 (55.9 percent) 197.3 608.2 (42.2 percent) 10030104050208 2,459.4 1,164.8 (47.4 percent) 302.2 862.6 (35.1 percent) 10030104050403 1,786.9 1,200.7 (67.2 percent) 219.9 980.8 (54.9 percent) 10030104050404 4,158.8 1,848.0 (44.4 percent) 388.1 1,459.9 (35.1 percent) 10030104050405 466.5 318.0 (68.2 percent) 20.7 297.3 (63.7 percent) 10030104050406 415.4 211.1 (50.8 percent) 35.2 175.9 (42.3 percent) 10030104050407 1,074.5 645.0 (60.0 percent) 221.7 423.3 (39.4 percent) 10030104050408 484.3 252.5 (52.1 percent) 36.9 215.6 (44.5 percent) 10030104050409 1,074.0 561.8 (52.3 percent) 116.9 444.9 (41.4 percent) 10030104050410 234.4 197.5 (84.2 percent) 56.2 141.3 (60.3 percent) 10030104050411 637.2 330.8 (51.9 percent) 96.9 233.9 (36.7 percent) 10030104050412 1,114.2 644.4 (57.8 percent) 122.3 522.1 (46.9 percent)

Black Bear, Mountain Goat, Mountain Lion, Dusky Grouse These species are part of the “commonly hunted” management indicator species in the Lewis and Clark National Forest Plan (USDA Forest Service 1986). Black bear occur in the project area. Denning habitat may be available in the deadfall associated with the Canyon Creek wildfire. Mountain goats are associated with steep cliffs. There is habitat along the ridge at the southeast project boundary although most of the observed use is in the northeast of the project area (Lonner 2016). The closed conifer, open conifer, aspen plus conifer, and aspen habitats used by the mountain lion (USDA Forest Service 2011) are present in the project area. Dusky grouse winter in conifer stands at high elevations and use forest edges and openings in spring and summer.

Beaver, Bobcat These species are the “commonly trapped” management indicator species in the Lewis and Clark National Forest Plan (USDA Forest Service 1986). Bobcat habitat (dense understory vegetation and rocky areas for denning; USDA Forest Service 2011) is found within the project area. Beaver habitat is located within the riparian areas adjacent to streams, rivers and ponds.

Golden Eagle, Prairie Falcon Golden eagle and prairie falcon are known to occupy the cliffs surrounding the project area. Golden eagle sightings are recorded at Alpine Lake, Ford Creek, Sheep Mountain, and Steamboat Mountain.

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There are prairie falcon sightings at Lone Chief Mountain within the project and at Cyanide Creek and Goss Creek off-Forest. There have been no recent surveys in this area.

Goshawk The status of goshawk on the Forest (through 2010) is described in the Compliance and Evaluation Report (USDA Forest Service 2011). Since 2010, an additional 16 territories were discovered (USDA FS 2015) across the Forest. A thorough discussion of goshawk literature and Forest-wide habitat is found in the Little Belt Hazard Tree Removal Wildlife Report and Biological Evaluation (USDA Forest Service 2014a). As shown in Table 10 of that document, there is adequate habitat on the Forest to maintain a minimum viable population for the entire Northern Rockies Region. For the Elk Smith Project, goshawk habitat was determined using the Northern Region Existing Vegetation Mapping Program. The data and assumptions used are located in the project record. Nesting habitat was determined using the parameters described in the Eastside Goshawk Nest Analysis (USDA Forest Service 2012b) for the Lewis and Clark National Forest. The amount of goshawk habitat in the project area is displayed in Table 38.

Table 38: Goshawk Habitat in the Project Area. Stand Size Class and Acres (percent) in Post-implementation Acres Existing Acres (percent) Canopy Cover proposed treatment units (percent)

Openings 3,396 (14 percent) 1,191 (35 percent) 6,998 (28 percent) Tree - 0.0-inches – 4.9-inches 11,610 (46 percent) 6,743 (58 percent) 8,239 (33 percent) Tree - 5.0-inches – 9.9-inches 5,839 (23 percent) 1,371 (23 percent) 5,609 (22 percent) Tree - 10.0-inches plus 3,764 (15 percent) 1,095 (29 percent) 3,764 (15 percent) 5.0-inches and canopy cover 7,893 (31 percent) 2,149 (27 percent) 7,618 (30 percent) >50 percent Nesting habitat 8,311 (33 percent) 6,200 (75 percent) 8,234 (33 percent) Old growth (potential) 79 (<1 percent) 38 (48 percent) 79 (<1 percent)

There are three goshawk territories wholly or partially within the project area. They are Bailey Basin, Double Falls, and Ford Creek South. The Bailey Basin Territory is entirely within the project area (see Goshawk Map in Appendix B of the wildlife specialist report in the project record) in the Elk Creek drainage. This territory was discovered in 1991, just three years after the Canyon Creek wildfire, and fledged young in 2009, 2010 and 2013. The amount of habitat in the Bailey Basin Territory is displayed in Table 38, while Table 39 displays the habitat in the 477-acre post-fledging area. The Ford Creek South and Double Falls territories are in Ford Creek and Upper Smith Creek drainages respectively, along the northern boundary of the project area. These territories were discovered in 2006. Ford Creek South was occupied in 2007 and 2008, however nesting has not been documented since 2006. Nesting was documented in Double Falls every year from 2006 to 2010. A goshawk was present in the territory in 2014 however, nesting was not observed. Habitat in the Double Falls Territory is displayed in Table 40. Table 41 displays habitat for the Ford Creek South Territory.

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Table 39: Goshawk Habitat in Bailey Basin Territory.

Stand Size Class and Acres (percent) in Post-implementation Acres Existing Acres (percent) Canopy Cover proposed treatment units (percent)

Openings 299 (9 percent) 125 (42 percent) 946 (29 percent) Tree - 0.0-inches – 4.9-inches 1,374 (43 percent) 1,133 (82 percent) 808 (25 percent) Tree - 5.0-inches – 9.9-inches 923 (29 percent) 601 (65 percent) 687 (21 percent) Tree - 10.0-inches plus 528 (16 percent) 262 (50 percent) 528 (16 percent) 5.0-inches and canopy cover 1,234 (38 percent) 813 (66 percent) 1,143 (36 percent) >50 percent Nesting habitat 1,267 (40 percent) 764 (60 percent) 1,227 (38 percent)

Old growth (potential) 19 (<1 percent) 2 (11 percent) 19 (<1 percent)

Table 40: Goshawk Habitat in Double Falls Territory.

Stand Size Class and Acres (percent) in Post-implementation Acres Existing Acres (percent) Canopy Cover proposed treatment units (percent)

Openings 360 (13 percent) 3 (8 percent) 360 (13 percent) Tree - 0.0-inches – 4.9-inches 12 (1 percent) 0 (0 percent) 12 (1 percent) Tree - 5.0-inches – 9.9-inches 1,647 (61 percent) 0 (0 percent) 1,647 (61 percent) Tree - 10.0-inches plus 659 (24 percent) 15 (2 percent) 659 (24 percent) 5.0-inches and canopy 1,963 (73 percent) 9 (0 percent) 1,963 (73 percent) cover >50 percent Nesting habitat 2,061 (76 percent) 15 (1 percent) 2,061 (76 percent)

Old growth (potential) 8 (<1 percent) 0 percent 8 (<1 percent)

Table 41: Goshawk Habitat in Ford Creek South Territory.

Stand Size Class and Acres (percent) in Post-implementation Acres Existing Acres (percent) Canopy Cover proposed treatment units (percent)

Openings 923 (33 percent) 2 (0 percent) 925 (33 percent) Tree - 0.0-inches – 4.9-inches 270 (10 percent) 2 (1 percent) 269 (10 percent) Tree - 5.0-inches – 9.9-inches 403 (14 percent) 3 (1 percent) 402 (14 percent) Tree - 10.0-inches plus 839 (30 percent) 8 (1 percent) 839 (30 percent) 5.0-inches and canopy cover 1,074 (38 percent) 8 (1 percent) 1,074 (38 percent) >50 percent Nesting habitat 1,507 (54 percent) 8 (1 percent) 1,507 (54 percent)

Old growth (potential) 2 (0 percent) 0 percent 2 (0 percent)

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Table 42: Goshawk Habitat in Bailey Basin Post-fledging Area.

Stand Size Class and Acres (percent) in Post-implementation Acres Existing Acres (percent) Canopy Cover proposed treatment units (percent)

Openings 6 (1 percent) 1 (17 percent) 90 (19 percent) Tree - 0.0-inches – 4.9-inches 23 (5 percent) 15 (65 percent) 15 (3 percent) Tree - 5.0-inches – 9.9-inches 226 (48 percent) 153 (68 percent) 149 (31 percent) Tree - 10.0-inches plus 187 (39 percent) 53 (28 percent) 187 (39 percent) 5.0-inches and canopy cover 388 (81 percent) 202 (52 percent) 381 (80 percent) >50 percent Nesting habitat 435 (91 percent) 204 (47 percent) 404 (85 percent)

Old growth (potential) 15 (3 percent) 0 percent 15 (3 percent)

Migratory Birds Requirements and procedures under the Migratory Birds Treaty Act as described in full in the Little Belt Hazard Tree Removal Project Wildlife Report and Biological Evaluation (USDA Forest Service 2014a). In summary, the agency is required to evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors within the National Environmental Policy Act process (Executive Order 13186, 2001; USDA Forest Service and USDI Fish and Wildlife Service 2008). The full report completed for the Elk Smith Project is located in the project file. A summary of that report is included below.

Environmental Consequences

No Action Alternative Alternative 1 proposes no actions. Existing management activities and natural processes would occur. As indicated in the Fire, Fuels, and Air Quality Report, the no action alternative perpetuates the heightened level of fire risk for the next 50 or so years as well as maintains the potential for severe wildfires. The Forest Vegetation Report states that stand regeneration in areas with poor regeneration after the Canyon Creek Fire would be gradual over the next 30 to 60 years. In areas of dense seedling and sapling stands, self-thinning of the stands would occur, and standing snags would fall, adding to the already high fuel load. The aspen clones in the project area would mature, however competition from conifer trees would occur within 30 to 40 years.

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Direct and Indirect Effects

All species Under the no action alternative, there would be no direct effects; habitat for all wildlife species would remain in the current condition in the short-term. There would be no project induced disturbance or changes in forage or prey species. Indirect effects would occur over the long term. As dense stands self-prune, travel within the project area would improve for species such as grizzly bear, wolverine, wolf, elk, deer, black bear, mountain lion, bobcat and goshawk. Den sites within the downed wood would be more accessible for bears, wolverine, wolf and bobcat. Overtime, habitat for snowshoe hare would be reduced as dense lodgepole pine stands self-thin. This results in less prey availability for Canada lynx and bobcat. This reduced hare habitat would continue until the forest naturally regenerates. Although some stands would mature over time, lodgepole stands are not anticipated to create mature, multistory forest preferred by lynx as winter foraging sites (Squires et. al. 2010). Some mature, multistory stands would develop in the stands surrounding the dense lodgepole. This increase in mature, multi-story would be offset by the loss of currently mature trees to beetle activity in the future. As snags begin to fall there would be less foraging habitat for both black-backed woodpecker and three-toed woodpecker. As trees mature, additional goshawk nest stands would become available. As described in the Fire, Fuels and Air Quality Report the no action alternative results in a heightened risk of fire. In the event of a wildfire, habitat for all species requiring forest would be lost. Impacts would be greatest to Canada lynx, elk and deer, mountain lion, and goshawk. The extent of those impacts would depend on the severity and size of the wildfire, which cannot be predicted here. In general, forage and browse would increase for grizzly bear, elk, deer, and bighorn sheep in fire created openings where grasses and shrubs come back after the fire. This increase in available food resources would be offset by a loss of available cover for security and thermal protection. Fire-killed snags would create habitat for black-backed woodpecker, as well as three-toed woodpecker.

Cumulative Effects Under the no action alternative, natural processes would occur, including regeneration of forests, succession of plants species, and wildfire. Activities that are currently present in the project area, as described in Appendix D of the Environmental Analysis, would continue. This includes grazing allotments, the Elk Creek administrative pasture, weed treatments, the Birch Creek South Travel Plan Record of Decision, and the Benchmark III Fuels Reduction Project. The cumulative effects would be as those described in the Benchmark III Fuels Reduction Project Environmental Assessment (USDA Forest Service 2013).

Conclusion The no action alternative may affect, but is not likely to adversely affect, grizzly bear, Canada lynx, and Canada Lynx Designated Critical Habitat. Alternative 1 would not jeopardize the continued existence of wolverine. Changes in habitat over time result in a may impact individuals or habitat, but would not likely contribute to a trend toward federal listing or cause a loss of viability to the population or species for black-backed and American three-toed woodpeckers, and bighorn sheep. There would be no effect

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to gray wolf or Northern bog lemming. Habitat changes over time for elk, deer, black bear, mountain lion, dusky grouse, and bobcat would result in localized habitat changes, but would not alter viability of these species on the planning unit, nor would it result in reduced hunting or trapping opportunities. There would be no changes to mountain goat, beaver, golden eagle, or prairie falcon habitat. Habitat for goshawk would increase in the project area, however no changes in the goshawk population in this area is anticipated due to the current condition of habitat. There would be no changes to mountain goat, golden eagle or prairie falcon habitat.

Proposed Action Under Alternative 2, the proposed action alternative, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented as previously described.

Direct and Indirect Effects The habitat acres treated and post-implementation habitat acres are displayed in Table 32 through Table 38 above. The Forest Vegetation Report identifies habitat types in the project area. The primary understory vegetation associated with those habitat types include snowberry (Symphoricarpus albus), pinegrass (Calamagrostis rubescens), grouse whortleberry (Vaccinium scoparium), twinflower (Linnaea borealis; Howard 1993), and elk sedge (Carex geyeri). Additional species likely to be present are found in Appendix C of the wildlife specialist report in the project record. The Blankenship Understory Vegetation Report (USDA Forest Service 2012a) described the methodology used to determine the species list and described the impacts of fire to those species. Information for the primary understory vegetation is summarized in this report. Overall, the proposed action would increase the vegetative diversity in the area, and correspondingly the habitat diversity in the short-term. The project area would continue to have large patches of dense, young conifers trees as well as unstocked areas. The number of openings within the forested areas would increase, and as trees sprout and grow a younger age class of trees would develop. Some aspen stands would be treated, and aspen health and number would increase. Conifer encroachment in meadow habitats would be removed, thereby maintaining this habitat. In the long-term (100 to 150 years), as the regenerated trees grow and the size classes and structure converge, the habitat diversity would again decrease.

Grizzly Bear The effects of the Elk Smith Project on grizzly bear are very similar to that described for the Benchmark Hazardous Fuels Reduction Project (USDA Forest Service 2010; USDA Forest Service 2013). In general, treatments that maintain natural openings and enhance aspen would remove understory conifers as well as thinning the canopy. The result would likely be more sunlight reaching understory shrubs, forbs and grasses, and a decrease in competition from conifers. In dense areas burning would be used to reduce fuels. We assume that in these units the effects would be to increase the size of openings and stimulate growth of grasses and some forage species. In the Scapegoat Subunit, 2,767 acres are within units designed to maintain openings and enhance aspen while 7,544 acres of dense stands occur in units designed to reduce fuels. Approximately 1,384 acres of opening maintenance and aspen enhancement and 3,722 acres, of fuel reduction in dense stands would occur. In the South Fork Willow Subunit,

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approximately 10 acres of the 19 acres within treatment units would be treated to maintain natural openings and enhance aspen. There are 4,688-acres within treatment units on areas mapped generally as spring grizzly bear habitat in the Scapegoat Subunit, or approximately 11 percent of the spring habitat in the subunit Table 32). In the South Fork Willow Unit there are 19 acres (0 percent) of spring grizzly bear habitat within treatment units. In the Scapegoat Subunit 2,206 acres of spring habitat is within units proposed for opening maintenance and aspen enhancement. All 19 acres of proposed treatment in the South Fork Willow subunit are within this treatment type. Approximately half the acres would actually be treated (1,103 acres in the Scapegoat subunit and 10 acres in the South Fork Willow subunit). By maintaining or enhancing openings that provide foraging opportunities or by increasing productivity of forage species such as grasses and fruiting shrubs, treatments in these units have the potential to be beneficial to grizzly bears (Interagency Grizzly Bear Committee Guidelines 1986, pages 8-11; Zager and others 1983; USDA Forest Service 2012a). The remaining acres proposed for treatment in the Scapegoat Subunit are in units where the treatment would disrupt the fuel continuity by reducing 30 to 50 percent of the conifer regeneration in 20- to 100-acre patches. This treatment would result in approximately 1,241 acres of openings in spring grizzly bear habitat and corresponding loss of available cover. Treatments are expected to have possibly beneficial effects on grizzly bear habitat by creating openings that provide foraging opportunities in the short-term. Adjacent hiding cover will continue to be available, as the openings will be 20 to 100 acres in size (somewhere between 12 and 62 openings created) across the entire 2,482 acres treated. Actual use by grizzly bears will depend on the forage species that develop after the burning and behavior of individual bears that live in the areas. As trees re-establish in the openings and understory grasses and shrubs decline, the value of the area for foraging may decrease. This would happen in the five- to ten-year period following implementation. In the Scapegoat Subunit there are 781 acres (four percent) of mapped potential denning habitat within proposed treatment units. Of that, seven acres are within units proposed for opening maintenance and aspen enhancement. Those treatments would have no impact on available denning habitat, as treatments would not alter the elevation, slope, or snow depth during winter. In units proposed to disrupt the continuity of fuels, there are 774 acres of potential denning habitat. The areas proposed for treatment likely do not currently provide denning habitat, as the dense stands limit access and snow depth. Approximately 387 acres of the potential denning habitat would be treated, creating openings. The area would be more accessible to bears and could provide additional sites for denning while it remains in an open condition (three to five years). There is no denning habitat in the South Fork Willow Subunit proposed for treatment. Under the proposed action, 18 percent (10,310 acres) of Management Situation 1 lands in the Scapegoat Subunit is proposed for treatment. Approximately 2,767 acres are within Units 1, 2, 7, 9, and 11 with treatments designed to maintain natural openings and enhance aspen using slashing and burning on approximately 1,384 acres. The remaining 7,544 acres are in units designed to disrupt fuel continuity and approximately 3,772 acres would actually be treated. Treatments in these units would consist almost entirely of broadcast burning. Spring burning may be necessary in order to achieve treatment objectives, due to the need for very specific vegetation and weather conditions for burning to be successful. Burning may occur in early spring, after snow has

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melted and before significant green-up of vegetation has occurred. Spring is the preferred burn season for Units 1, 2, 7, 9, and 11, as well as the portions of Units 12, 13, 14, and 15 near the private land boundaries. In the South Fork Willow Subunit 16 acres of Management Situation 1 and 3 acres of Management Situation 3 habitat is within units proposed for opening maintenance and aspen enhancement. Spring burning is the preferred season for these treatments. The Lewis and Clark National Forest Land and Resource Management Plan identifies specific wildlife- related guidelines, the Interagency Rocky Mountain Front Wildlife Monitoring/Evaluation Program Management Guidelines, in Appendix I of the plan. Since the time of the 1986 Forest Plan, the Appendix I guidelines have either been modified, superseded, or removed under forest plan amendment number 25, “Record of Decision for the Forest Plan Amendments to Incorporate Habitat Management Direction for the Northern Continental Divide Ecosystem Grizzly Bear Population. (USDA Forest Service 2018) Those guidelines applicable to the Elk Smith project, as specifically retained in the 2018 Grizzly Bear Amendments, are: 1. Avoid human activities in identified grizzly bear habitat constituent elements or portions of constituent elements containing specific habitat values during the following seasonal use periods: a. Spring habitat (concentrated use areas): April 1-June 30. b. Breeding areas: May 1-July 15. (Currently identified breeding areas include upper Muddy Creek, the head of Rinkers Creek, the Ear Mountain area, and the head of the North Fork Dupuyer Creek.) These areas are not within the Elk Smith project area. This portion of the guideline does not apply. c. Alpine feeding sites: July 1-September 15. Alpine feeding sites are not known to occur in the Elk Smith project area. This portion of the guideline does not apply. d. Subalpine fir/whitebark pine habitat types: August 1-November 30. Grizzly subalpine fir/whitebark pine habitat types are not mapped for the project area because 1) subalpine fir/whitebark pine are limited across the project area (see forested veg report); 2) whitebark pine, if it occurs in the project area, is limited and mostly outside of treatment units (forested veg report); 3) Incidental whitebark seedlings and saplings may be killed during burning, however, impact to the overall whitebark population in the project area would be limited in scope and (forested veg report); 4) project activities would also create favorable nutcracker cone caching sites beneficial to the species (forested veg report). Therefore, the project complies with this portion of the guideline. e. Denning habitat: October 15-April 15. See above discussion on denning habitat. 2. Avoid human activities in grizzly bear habitat components that provide important food sources during spring and early summer, April 1-July 15. These habitat components include riparian shrub types, Populus stands, wet meadows, sidehill parks, and avalanche chutes. Maintain an undisturbed zone of at least 1/2 mile between activities and the edge of these habitat components where many important bear foods occur. See discussion below regarding effects to spring and summer habitat.

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The term guideline is expressly defined in the Grizzly Bear Amendment as: “Guidelines. The project or activity i. complies with applicable guidelines as set out in the plan or ii. is designed in a way that is as effective in achieving the purpose of the applicable guidelines (§ 219.7(e)(1)(iv)).” The Interagency Grizzly Bear Committee Guidelines indicate that some silvicultural treatments and managed burning may be used to improve grizzly bear forage species in Management Situation 1 habitat (Interagency Grizzly Bear Committee Guidelines 1986, pages 8-11). The guidelines recommend that such activities occur “at a time or season when the area is of little biological importance to grizzly bears” (Interagency Grizzly Bear Committee Guidelines 1986, page 8), although they note that when that is infeasible, operations should be restricted in time and space to avoid disruptions to bears. Prescribed burning that may occur in Management Situation 1 spring habitat can occur only in areas that have not significantly greened up, in order to carry fire as needed to achieve treatment objectives. It is unlikely that bears would be using these areas, as forage species are unlikely to be available in any quantity. Moist habitats where important spring forbs and sedges are generally found, such as areas within the riparian influence zone would not be targeted for burning and are unlikely to carry fire. All of the spring habitat proposed for treatment in the Scapegoat Subunit is Management Situation 1 land. Sixteen acres of the treatment unit in the South Fork Willow Subunit is spring habitat in Management Situation 1 lands. Burning in these units is likely to increase the size of openings and remove conifer encroachment, as well as remove understory conifers and cause limited mortality of larger overstory trees. Some regeneration of aspen is also expected. Ultimately, these treatments are likely to stimulate growth of some grass and forb species that may be important to bears in spring, through removal of competing conifer overstory and accumulated grassland litter. Burning in some areas may actually accelerate green-up of some grasses or other bear spring forage species. In sum, the potential for temporary disruption of spring foraging habitat is small and may be outweighed by the potential for improvement of spring forage species. Burning that may occur in spring is not expected to affect spring forage to a degree that would disturb bears from the area. Therefore, the Interagency Grizzly Bear Committee Guidelines, as incorporated into the Forest Plan, would be met. The proposed action does not include any road or trail construction or reconstruction, therefore there would be no changes to motorized route density or the amount of area available as Core in the Scapegoat and South Fork Willow Subunits. The guidance in the 1995 Interim Direction for Motorized Access in the Northern Continental Divide Ecosystem (Interagency Grizzly Bear Committee 1995) would continue to be met. All of the proposed treatments would involve personnel on the ground either hand felling and thinning or managing prescribed burning operations. All personnel, including contractors, would be required to adhere to the Food Storage Special Order at all times while on National Forest System lands. Activity associated with treatments would be in addition to normal levels of activity in the area but would be of short duration. Because most of treatment units 1, 2, 7, 9, and 11 are partly or entirely within the generally mapped spring habitat area, any slashing or thinning would occur only after June 30, when it is less likely that

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bears may be using any riparian areas or other spring forage locations that may be in or close to treatment units. This restriction in timing meets the Forest Plan standard requiring use of the Interagency Wildlife Guidelines in project planning and implementation. As discussed above, broadcast or prescribed burning may occur in spring, when conditions are appropriate for achieving treatment objectives. Burning in five treatment units (Units 1, 2, 7, 9, and 11) and portions of three units adjacent to private land (Units 12, 13, and 14) could occur in Management Situation 1 habitat in spring. As discussed above, although the Interagency Grizzly Bear Committee Guidelines recommend avoiding managed burning in Management Situation 1 spring habitat during spring, they recognize that at times this may be unavoidable (Interagency Grizzly Bear Committee Guidelines 1986, page 8). The Guidelines recommend that any activity occurring in these habitats during spring be “restricted in time and space to prevent significant disruptions of normal or expected grizzly activities.” Ten units (7,544 acres) within the proposed action require the use of aerial ignition. Based on past experience (Owen, personal communication 2016), one or two burn windows (one to three consecutive days) occur each spring and one burn window occurs every other year in fall. When a suitable burn window occurs, one to four units would be treated with helicopter operation happening as follows: • Reconnaissance flight mid-morning to make sure public and livestock are clear of the area. • Ignition beginning 1200 hours or later with one or two helicopters; ending approximately 1700 hours. • Additional reconnaissance flight over next couple of hours to monitor. • Possibility of aviation resources used to control fire within unit boundaries for an additional zero to five days. In the units proposed for hand ignition, the nature and size of the proposed burns are such that human activity in the units is likely to be limited to less than 20 people on one day of burning, several of whom are likely to be stationed at an existing developed site such as a trailhead, airstrip, or campground. Burning is generally completed in less than five hours on a single day, with only one unit burned on a given day. One to three people are then likely to carry out follow- up activities such as fire mop-up or monitoring on the subsequent two to three days. Very occasional visits to the general area by one - two people over the next month may occur to monitor the effects of the fire. Therefore, the potential impacts of operations would be restricted in time and space, in accordance with the Interagency Grizzly Bear Committee Guidelines, and potential disturbance of grizzly bears would be minimized. Because of the size of units and the separated nature of project activities relative to the available acreage of spring grizzly bear habitat in the Scapegoat and South Fork Willow Bear Management Unit Subunits and on the Rocky Mountain Ranger District in general, as well as implementation occurring over a 10-year period, project activities are not expected to disturb bears in any measurable fashion. Potential use of helicopters for up to 5 consecutive days exceeds the 3 day limit in the Guide to Effects Analysis of Helicopter Use in Grizzly Bear Habitat (USDA Forest Service and USDI Fish and Wildlife Service 2009). The Guide to Effects Analysis of Helicopter Use in Grizzly Bear Habitat states the available evidence suggests that aircraft flying at relatively low altitudes in occupied habitat can elicit a response by grizzly bears. Effects may range from a simple awareness of the aircraft (i.e., raising the head but otherwise continuing uninhibited) to short-term disturbance or flight response (resulting in physiological changes such as increased stress and energetic demands) to temporary displacement from an area.

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Hence, at most, an individual bear could be temporarily disturbed from an area of project activity, but if such disturbance were to occur it would be of short duration and distance due to the availability of both hiding cover and spring foraging habitat in the immediately adjacent areas. The Elk Smith Project Proposed Action may affect, and is likely to adversely affect, grizzly bear.

Canada lynx Approximately 250 acres of early stand initiation, 1,872 acres of stand initiation, 87 acres of stem exclusion, and 148 acres of other structural stages would be treated across Lynx Analysis Unit RM-25 by implementing the Elk Smith project, totaling 2,357 acres of lynx habitat treated. No multistory structural stage would be treated. Within the Tri-County Wildland Urban Interface, approximately 165 acres of early stand initiation, 1,206 acres of stand initiation, 67 acres of stem exclusion, and 93 acres of other structural stages would be treated by implementing the Elk Smith project. As previously noted, treatments in the Wildland Urban Interface include hand ignition prescribed fire and hand slashing of conifers. Most of the proposed treatment (2,122 acres) occurs in early stand initiation and stand initiation structural stages that provide snowshoe hare habitat. The assumptions made in determining project effects on habitat are described in the spreadsheet of lynx analysis located in the project record. The proposed action results in an increase in early stand initiation habitat to 3,322 acres (29.7 percent of lynx habitat). Early stand initiation habitat can provide snowshoe hare habitat as early as approximately three years after treatment; however, this habitat is only available during the summer as it is not tall enough to protrude above the snow during the winter. Stand initiation structural stage, habitat for snowshoe hare in the summer and winter, is reduced by the project as dense stands of lodgepole pine are targeted for treatment. Despite the reduction, 4,092 acres (37 percent) of lynx habitat in Lynx Analysis Unit RM-25 would continue to provide snowshoe hare habitat during winter in the short term. There are very few acres of mature, multi-story structural stage in the lynx analysis unit due to the Canyon Creek Fire of 1988. The proposed action would not alter this structural stage. There would be a slight decrease (88 acres) in acres of stem exclusion structural stage under the proposed action. The effects to lynx from the proposed action centers around the effects to snowshoe hare and its habitat. There would be a reduction in winter snowshoe hare habitat and a corresponding reduction in the number of hare available in the lynx analysis unit until the early stand initiation habitat grows above the snowline as early as 25 to 35 years. This would result in lynx in the area expending more energy to hunt. There would be no change in preferred winter foraging habitat (mature, multi-storied) for lynx. These changes in structural stage are not anticipated to alter the ability of the Lynx Analysis Unit to support lynx, as there is an abundance of snowshoe hare habitat created by the 1988 fire. Under the proposed action, 25 to 60 percent of the coarse woody debris within treatment units would be consumed. This results in a slight decrease in available denning in the treatment units. This is not expected to impact individual lynx to a great extent, as there is ample coarse woody debris remaining outside the treatment units and over time the standing dead trees in the units would fall, creating more coarse woody debris. The proposed action would result in disturbance to any lynx in the project area during implementation. Although the project area is about the same area as Lynx Analysis Unit RM-25, the treatments would

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occur only on portions of the area at any one time. Lynx in the area of activity would be temporarily displaced to existing habitat within the lynx analysis unit. The Northern Rockies Lynx Management Direction Record of Decision (USDA Forest Service 2007a) amended the Lewis and Clark National Forest Plan with Standards and Guidelines specific to lynx. Consistency with those Standards and Guidelines is shown in Appendix E. Consistency with the most relevant of those Standards (VEG S1 and VEG S6) and Guidelines (Veg G5 and VEG G10) is summarized here: • Standard VEG S1 – Table 34 displays the type and acreage of existing lynx habitat in Lynx Analysis Unit RM-25. The early stand initiation structural stage denotes snowshoe hare habitat that is not yet available in winter. The existing condition is 11 percent of the lynx habitat in early stand initiation. The proposed action would increase the acres of early stand initiation to 3,322 acres, or 29.7 percent of the lynx habitat. Standard VEG S1 is met under the proposed action. • Standard VEG S5 – The Elk Smith project is not proposing the use of precommercial thinning. Slashing of conifers is not prohibited by Standard VEG S5. However, slashing young conifer trees will have a similar effect of temporarily removing snowshoe hare habitat. Due to the similarity of effects, slashing has been restricted to occur only within the wildland urban interface. As described in the assumptions, a maximum of 50 percent of treatment unit acres would be impacted by project implementation . Standard VEG S5 is met. • Standard VEG S6 – There is very little multi-storied mature habitat in the lynx analysis unit. These areas will not be targeted for treatment. The prescribed fire may back through the area, but is expected to burn at very low intensity and not alter the structural stage. Therefore, standard VEG S6 is met under the proposed action. • Guideline VEG G5 – Red squirrel habitat consists of cone producing conifers. According to the Forest Vegetation Report, trees that re-established after the 1988 fire are beginning to produce cones; however, in the high-density stands cone production is expected to be lowest due to the small diameter of the trees. In general, habitat is provided by stands in the multi-storied mature, stem exclusion, and other structural stages. Limited habitat is available in the stand initiation structural stage. The proposed action would thin some areas, allowing smaller trees to grow and produce cone, and would eliminate high-density stands that may be producing some cones (Table 34- Lynx Analysis Unit RM-25 Habitat). The proposed action is consistent with Guideline VEG G5. • Guideline Veg G10 – The Elk Smith proposed action follows standards VEG S1, VEG S5 and S6. Standards VEG S2 is not applicable to the project. The proposed action is consistent with VEG G10. In order to mitigate effects to lynx and its habitat, the Forest proposes the following: 1) In the event lynx denning activities are detected, the Forest will halt operations in units where denning lynx are discovered until such a time a wildlife biologist is able to review the unit and modify the activity, if necessary, to maintain reproductive efforts.

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2) In order to account for adverse effects to snowshoe hare habitat treated inside the Elk Smith project area Wildland Urban Interface, the Forest recommends adding the 165 acres of early stand initiation and 1,206 acres of stand initiation hare habitat (1,371 acres total) towards the Forest’s maximum allowed amount of available habitat that can be treated under the exemption that permits such treatment in the WUI. To date, the Lewis and Clark National Forest has treated 43 acres of the allowable 28,022 acres, with 27,979 acres remaining (US Fish and Wildlife Service 2017). Accounting for the 1,371 acres of hare habitat proposed to be treated under the Elk Smith project would result in a remaining balance of 26,608 acres or 95 percent of the allowable acres for the Lewis and Clark National Forest that have not been used. 3) In order to ensure the effects assumption used in this analysis that implementation of prescribed fire will impact a maximum of 50 percent of treatment units and therefore lynx habitat [as described above and here for the discrete purpose of its contribution towards the Northern Rockies Lynx Management Direction vegetation standard VEG S1 threshold of 30 percent lynx habitat in a structural stage that does not yet provide winter snowshoe hare habitat in Lynx Analysis Unit RM-25)], the Forest will monitor implementation to determine the extent of actual acres of treatment units impacted. Once 50 percent of the proposed treatment unit acres have been implemented, the Forest will: a. review the effects of the treatment to determine the extent of effects (actual amount of treatment that has occurred, by acre). If the average amount of acres treated exceeds the maximum assumed treatment amount of 50 percent, the Forest will adjust implementation procedures for those remaining units or acres in order to not exceed the 50 percent threshold assumption of effects. The proposed action would have some effects to the components of the primary constituent element of Canada lynx designated critical habitat. Only that portion of the project area that falls within lynx analysis units is designated critical habitat (Figure 7). Lynx Analysis Unit RM-25 is the only analysis unit that includes proposed treatments. The effects are discussed by component. • Presence of snowshoe hare and their preferred habitat – within Lynx Analysis Unit RM- 25 there are currently 8,402 acres of snowshoe hare habitat (mature multi-story, stand initiation and early stand initiation structural stages), or 75 percent of the lynx habitat. Very little of the existing habitat is multi-story mature (1,220 acres) due to the 1988 Canyon Creek Fire. Some of the lynx habitat (1,215 acres, or 11 percent) only provides habitat in the summer as it is not yet tall enough to protrude above the snowline in winter. The proposed burning would reduce the amount of snowshoe hare habitat. Due to the protracted implementation schedule (up to 10 years), the reductions would not all take place at the same time. Summer snowshoe hare habitat would re-establish as early as three to five years after burning on many of the treated acres (Elk Smith Project Forest Vegetation Report). Despite these changes, snowshoe hare and their preferred habitat would remain available in the lynx analysis unit. • Winter snow conditions that are generally deep and fluffy for extended periods of time – the proposed action would not result in any changes to the availability of deep, fluffy snow in the project area. There would be no roads or trails constructed for the project, burning activities do

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not occur during winter, and any winter access to the project would be done using trails and routes open to the public. • Denning sites with abundant, coarse, woody debris – there is currently a well-distributed downed wood component in the project area. This is part of the fuel loading issue that the proposed action addresses. The proposed action would result in a 25 to 60 percent decrease in the amount of coarse woody debris within the treatment units (Vegetation section). There would be no reduction in existing coarse woody debris in the untreated areas. Within the proposed units, there are a large number of snags (standing dead tees) that would continue to fall over time and contribute additional coarse woody debris for denning sites. Denning sites would remain abundant and available in the lynx analysis unit under the proposed action. • Matrix habitat between patches of boreal forest that allows lynx to travel between habitat patches – within the analysis area (Lynx Analysis Unit RM-25) there are 8,565 acres of matrix habitat (hardwood forest, dry forest, non-forest, or other habitat types that do not support snowshoe hare). As described in the 2014 lynx critical habitat final rule (FR 79 54827), and again in the Service’s 2017 biological opinion regarding effects to critical habitat from the Northern Rockies Lynx Management Direction (US Fish and Wildlife Service 2017a), vegetation management activities in matrix habitat would not be considered adverse unless those activities would create a barrier or impede lynx movement between patches of foraging habitat and between foraging and denning habitat within a potential home range, or if they would adversely affect adjacent foraging habitat or denning habitat (FR 79 54827). The Service determined that while vegetation management may affect vegetation within matrix habitat, those effects would not likely create a barrier or impede lynx movement between patches of foraging habitat and between foraging and denning habitat. Approximately 1,905 acres (22 percent) of the matrix habitat would be treated. Of the treated acres, 493 acres (<1 percent) occur in units designed to maintain natural openings and improve aspen stands. The remaining 1,412 acres (16 percent) occur in units designed to interrupt the continuity of fuels where burning will result in patchy openings of 20 to 100 acres in size. Lynx may avoid traveling through larger openings; however, because of the patchiness of the proposed burning, the availability of untreated matrix habitat (78 percent), and the availability of untreated lynx habitat within and surrounding treatment units, adequate habitat remains for lynx movement within the Lynx Analysis Unit. There is very little boreal forest habitat directly to the north of the project boundary and prairie to the east of the project area. Matrix habitat would continue to be available for lynx to move between patches of boreal forest to the northwest, south and west. The proposed federal action would not likely create a barrier or impede lynx movement between patches of foraging habitat or between foraging and denning habitat within RM-25 due to the preponderance of untreated matrix habitat in juxtaposition to the untreated denning habitat and untreated foraging habitat that will be present in RM-25 during and after implementation.

The cumulative effects analysis area for Canada lynx designated critical habitat is Lynx Analysis Unit RM-25, which coincides with the area’s portion of critical habitat unit 3, and more specifically those non-Forest lands in RM-25. Presently, there are no known non-Forest Service actions occurring in these areas that would add cumulatively to the Elk Smith project in a way

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that would result in adverse effects. These activities include recreational use of private land, human presence and disturbance, and motorized or mechanized uses. Due to the amount of snowshoe hare habitat treated within Lynx Analysis Unit RM-25, the effects to lynx and the primary constituent element snowshoe hare component in the lynx analysis unit are not considered insignificant or discountable. The Elk Smith Project Proposed Action may affect, and is likely to adversely effect, Canada lynx and Canada Lynx Designated Critical Habitat.

Wolverine According to the Copeland model (Copeland et. al. 2010), from 370 to 6,632 acres of persistent snow cover are within the analysis area Table 35). The proposed action would not alter the snow cover levels. Under the proposed action, 1 acre of maternal habitat and 642 acres of primary habitat (as described by Inman et. al. 2013) are within proposed treatment units. Implementation of the proposed action would not result in a change to the amount of modelled habitat in the analysis area. Project operations could temporarily disturb wolverine if they are present in area, but they would not change the amount of modeled habitat occurring in the project area. Because of the small amount of the project area potentially impacted in relation to an individual wolverines home range (approximately 100,000 acres in Montana; Hornacker and Hash 1981), and the short duration of the impact (from three to seven years), the Elk Smith Proposed Action would not jeopardize the continued existence of wolverine.

Black-backed Woodpecker and American Three-toed Woodpecker Under the proposed action prescribed fire would be used to create opening in dense stands of small trees. Some snags would be created in the burned units, while some snags would be consumed by fire or felled for safety during slashing. Although burning may create black- backed woodpecker habitat, the trees targeted for burning are smaller in diameter than those preferred by this species. Mature timber would not be treated. Black-backed woodpecker would continue to use the project area as they currently do, and the proposed action would have no effect on this species. There is currently an average of 22 snags per acre in the project area, exceeding that needed by three- toed woodpecker by 44 to 52 times. Removal of some snags by the proposed action, and creation of small diameter snags, is not likely to alter three-toed woodpecker’s use of the area or availability of snag habitat; therefore, the proposed action may impact individuals or habitat, but would not likely contribute to a trend toward Federal listing or loss of viability to the population or species.

Bighorn Sheep The proposed action includes 11 acres of bighorn sheep winter range in Unit 1, which is one percent of the winter range within the project area. Approximately half those acres would be treated. (Table 36). Bunchgrasses and shrubs are important food on winter range. Snowberry, pinegrass and elk sedge are identified as food for bighorn sheep (Montana Field Guide 2016, McWilliams 2000; Matthews 2000; Chadwick 2002). Snowberry has a high resistance to fire, with top-killed plants re-sprouting from rhizomes after a burn. The amount and extent of snowberry increases after fire, reaching a maximum within three to five years. Pinegrass is also top-killed by fire and re-sprouts from rhizomes. This species

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increases in response to fire in both frequency and cover. Elk sedge has a high degree of resistance to fire, being one of the first to recolonize burned areas. Fire may improve forage production of elk sedge, a species preferred by bighorn sheep in winter. In all, burning is expected to improve forage conditions on a very minor portion of bighorn sheep winter range. Spring burning would result in improvement the same year while fall burning may not see improved forage conditions until the following year. The Elk Smith Project may impact individuals or habitat, but would not likely contribute to a trend toward Federal listing or loss of viability to the population or species.

Gray Wolf Wolves using the Elk Smith project area would be disturbed during project operations. As there are no known den or rendezvous sites, disturbance would be primarily to hunting individuals. Disturbance would cause individuals to temporarily leave the project area. There would be no changes to available prey from the project. The Elk Smith Project may impact individuals or habitat, but would not likely contribute to a trend toward Federal listing or loss of viability to the population or species.

Northern bog lemming Bog lemming habitat is wet meadows, fens or bog-like environments (Montana Field Guide 2016). Any habitat within the project area would be within management area R (riparian). Project design features include no active lighting in aquatic management zones or wetlands. Although fire could back into riparian areas and wetlands, it is expected that the fire would extinguish due to moisture in the area or intensity would be low. There may be a slight loss of moss species from low intensity fire, as well as grasses and sedges that are part of bog lemming’s diet. The Elk Smith project may impact individuals or habitat, but would not likely contribute to a trend toward Federal listing or loss of viability to the population or species.

Elk The proposed action includes treating 195 acres (14 percent) of elk winter range in the project area and 1,884 acres (21 percent) of elk calving range Table 36). The winter range proposed for treatment is located within Unit 1. Treatments consist of removing encroaching conifers to maintain openings and enhance aspen stands. Broadcast burning is targeted for the spring prior to green up. Some forage may be affected and unavailable the year the unit is burned, however burning would increase forage production (e.g. pinegrass, aspen). Maintenance of openings and enhancement of aspen stands would benefit winter range in the short and mid-term by maintaining availability of forage. Units 1 through 7 include elk calving range. Calving habitat varies, however habitat selection requires abundant succulent and nutritious vegetation (Innes 2011). Units 1, 2, and 7 (927 acres, approximately 464 acres treated) are designed to maintain openings, reduce conifer encroachment, and enhance aspen stands. Treatment in these units would maintain a mix of openings and cover selected for by elk on calving habitat, as well as increase forage quality and nutritive quality (Innes 2011). Units 3, 4, 5, and 6 (2,840 acres) are designed to reduce the continuity of fuels and would remove 30 to 50 percent of the existing dense conifer regeneration as well as the heavy fuel loading. Treatments in these units, on approximately 1,420 acres of calving range, would create forage for elk in the short-term (until trees reestablish) and create 20- to 100-acre openings. Cover would be reduced, although the current density of trees makes it unlikely elk can utilize the existing cover in some areas. Unit 6 also contains aspen,

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which would be enhanced through the proposed treatment. Implementation of the proposed action would occur over approximately 10 years; therefore not all of the calving range would be treated at one time. Effective hiding cover is reduced in 16 of the 18 seventh code watersheds (HUC7) analyzed. The post- implementation effective hiding cover ranges from 31 to 64 percent in the watersheds where hiding cover is reduced (Table 37). These changes would be evident in the short and mid- term. As trees grow and self-prune, as described in the Forest Vegetation report, effective hiding cover would change. In the long-term, hiding cover would return to treated acres as the trees regenerate, and would lessen in areas that self-prune and are impacted by beetles. There would be no roads constructed or reconstructed for the proposed action, therefore elk security values (Hillis et. al. 1991) and habitat effectiveness (Lyon 1983) are unchanged from the existing condition. Elk security is defined by Hillis et. al. (1991) as areas greater than 250 acres in size and greater than 0.5 miles from an open road. More recent literature also uses distance from open motorized routes to determine elk security (Ranglack et. al. 2017). Habitat effectiveness (Lyon 1983) is based entirely on open road density. Because there are no proposed changes to motorized routes, there would be no changes to elk security or habitat effectiveness. Project operations would disturb elk in the project area. Slashing activities in Units 1 and 2 would occur after June 30 to minimize disturbance effects to calving elk. Fall burning on winter range would push elk off the Forest into their primary winter range on private lands. Fall burning during the hunting season would limit access in the area of the burn for approximately one week. Although individual elk and elk habitat would be impacted by the project, treatment would improve several components of habitat in the project area. Viability of elk populations on the planning unit would not be impacted. Depending on burn windows and timing of treatments, disturbance of individual elk may limit hunting opportunities in localized areas in the short-term. There would be no long-term changes in elk population numbers or distribution from the Elk Smith project.

Mule Deer and White-tailed deer The proposed units include 6,717 acres (44 percent) of mule deer transitional range and 390 acres (16 percent) of winter range within the project boundary (Table 36), approximately half of which would be treated. Most of the treated winter range is in Unit 1 (162 acres, or 6 percent of the winter range in the project boundary), and the effects are as described above for elk winter range. Units 11 and 12 include 67 acres of mule deer winter range. These acres are mature timber and openings and would not be targeted for treatment in these units. Fire may burn through the areas at a low-intensity, removing some understory vegetation. This would increase palatability of forage in the area, but otherwise would not impact winter range. Mule deer transitional range includes all proposed units except Unit 13. Unit 11 includes five acres of transitional range in a sliver along the southwest boundary. Of the acres treated, 1,157 acres (eight percent of the total in the project boundary) are within the units that are designed to maintain natural openings and enhance aspen. Treatments would improve transitional habitat by maintaining habitat heterogeneity (i.e. openings, aspen, mature forest) and increasing forage by burning. The remaining acres of transitional habitat (4,404 acres) are within units designed to reduce the continuity of fuels by removing conifer regeneration and heavy fuel loading.

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Approximately 2,200 acres (14 percent of the total in the project boundary) would be treated. Treatments would result in increased heterogeneity of habitat and increased forage availability and palatability (Innes 2013). Aspen stands in Units 6. 8, 12, and 13 would develop into vigorous, mature clones (Forest Vegetation Report). Impacts to effective hiding cover and disturbance are as described for elk. Although individual mule deer and white-tailed deer and their habitat would be impacted by the project, treatment would improve several components of habitat in the project area. Viability of deer populations on the planning unit would not be impacted. Depending on burn windows and timing of treatments, hunting opportunities may be impacted in localized areas in the short-term.

Black Bear, Mountain Goat, Mountain Lion, Dusky Grouse Treatments that are designed to reduce heavy surface fuels (Units 3, 4, 5, 6, 8, 10, 12, 13, 14, and 15; 3,872 acres treated) would remove potential black bear denning habitat (deadfall) in the short term. As snags continue to fall, additional denning habitat, in potentially more accessible habitat, would be available in the mid-term. In the long term, as downed wood deteriorates, less denning habitat would be available to bears in the project area. Those same treatments would impact forage for black bears. Pinegrass and grouse whortleberry (Matthews 2000; Johnson 2001) can be killed by severe fire. Pinegrass would sprout from rhizomes and generally increases in frequency and cover in response to fire (Matthews 2000). Grouse whortleberry would initially decline after a fire but would recover within the short-term. These impacts to black bear habitat may affect individuals, however they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted management indicator species. Mountain goat primarily use rocky cliffs in the project where treatments are limited. There is some potential goat habitat in the helicopter burn units on the southwestern side of the project. In Glacier National Park, mountain goats use pinegrass dominated ledges (Matthews 2000). Fire would impact pinegrass in the project area as described above. The Elk Smith project may impact individuals and their habitat; however, they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted management indicator species. Mountain lion habitat would be impacted by the proposed action. In the short-term, treatments that improve aspen stands would enhance or maintain lion habitat. Burning of dense stands of conifer would not remove lion habitat, as the stands are too dense for lions to travel through and use in the existing condition. In the long-term, as stands mature into open conifer or closed conifer stands lion habitat would be increased. The Elk Smith project may impact individuals and their habitat; however, they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted management indicator species. Dusky grouse eat snowberry and grouse whortleberry berries. Both of these plants are improved in the short-term by burning. Creation of openings and increased forest edges would also improve summer grouse habitat. The Elk Smith project may impact individuals and their habitat; however, they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted management indicator species.

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Beaver, Bobcat Beaver habitat is within the riparian area. Project design features do not allow direct ignition in this habitat. Fire could back through the area, although high soil and fuel moisture would limit fire intensity and extent. The resulting low intensity burn would remove some vegetation from the understory, including willow (Anderson 2006; Uchytil 1989; Uchytil 1992). This would temporarily reduce woody vegetation in isolated areas. Willow species sprout from the root crown following fire, so decreases in available browse would be replaced during the next growing season. These impacts to beaver habitat would not result in a loss of viability in the planning area or any changes to trapping opportunities for this commonly trapped management indicator species. The proposed action would have no effect on rocky areas used by bobcat for denning. The treatments would remove dense understory on up to 3,872 acres (50 percent of units 3, 4, 5, 6, 8, 10, 12, 13, 14, and 15), thereby reducing preferred habitat in the project area. Dense understory would remain where it exists outside the treatment units and in the untreated portions of the treatment units. These impacts to bobcat habitat may affect individuals, however they would not result in a loss of viability in the planning area or any changes to trapping opportunities for this commonly trapped management indicator species.

Golden Eagle, Prairie Falcon The proposed action would have no impact to cliff nesting habitat. Helicopter operations would cause disturbance to cliff nesting raptors if the helicopter approaches too close. This could result in coming off the nest during incubation, which could lead to lower hatching rate or could lead to nest abandonment. The Elk Smith project may affect individuals, however would not result in a loss of viability of golden eagle or prairie falcon in the planning area. If the resource protection measure to route helicopter flights to more than a half mile from cliff nests were implemented, the impacts to individual birds would be lessened, but not eliminated. The determination would not change with inclusion of this resource protection measure.

Goshawk The proposed action would alter goshawk habitat in the project area. Table 38 displays the acres and percent proposed for treatment, by habitat descriptions from Reynolds et. al. (1992), in the project area. The project would increase the acres in openings and decrease the acres in small trees (0 to 4.9-inches diameter-at-breast-height), while also slightly decreasing the acreage of trees in the 5 - 9.9-inches diameter-at-breast-height category, the trees >5.0-inches diameter-at-breast-height and >50 percent canopy cover, and the acres of nesting habitat. Based on percent of each category, only changes in openings and trees 0 to 4.0-inches diameter-at-breast-height are evident (more than 1 percentage point). In the Bailey Basin Territory, 2,155 acres (67 percent) are included in treatments. Seven-hundred thirty acres of that is within units that would maintain natural openings and enhance aspen stands. The remaining 1,425 acres of treatment would disrupt the fuel continuity and loading by treating 30 to 50 percent of the conifer regeneration (primarily stands in the 0 to 4.9 inches diameter at breast height category), as well as improve aspen in Units 6, 8, 12 and 13. In order to show the greatest extent of impact, the analysis assumed 50 percent of the treated acres in the 0 to 4.9 -inches diameter-at-breast-

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height and 5 to 9.9 -inches diameter-at-breast-height size classes would become openings after treatment. Table 39 displays changes by habitat category in this territory. In the Bailey Basin post- fledging area, 153 acres (32 percent) are within treatment units. The majority are within units where the treatment is designed to disrupt the continuity of fuels. Approximately five acres are within units that maintain natural openings and enhance aspen stands. Unit 12 also contains a large aspen stand that would be enhanced. Table 42 displays the changes by habitat category. The greatest changes would be an increase in openings and a decrease in the 5.0 to 9.9 -inches diameter-at-breast-height category, with a slight decrease in the 0 to 4.9 -inches diameter-at-breast-height category. In the Double Falls and Ford Creek South territories, very little treatment is planned. Eighteen acres (0.7 percent) of Double Falls Territory and 14 acres (0.5 percent) of Ford Creek South fall within Unit 1. The slight changes in acres of habitat category do not result in any changes by percentage (Table 40 and Table 41). There are no proposed treatments within the post fledging areas of these territories. Despite all the changes in habitat categories, the proposed action would improve conditions for goshawk. Goshawk hunt in the forest, flying between trees to catch prey. The current very dense stands in the project area do not provide habitat for goshawk because of the lack of flyways. These areas are likely production areas for some prey species; however, the proposed action would increase the heterogeneity of the area thereby providing a more diverse prey base for this generalist species. Although the percentage of habitat in each category for the project area, the territories, and the post- fledging area does not match that recommended by Reynolds et. al. (1992) Table 38), it is similar to that observed on the Lewis and Clark National Forest. Recommendations are to maintain six acres of 40 acres each of nesting habitat in a territory (Brewer et. al. 2009). More than adequate nesting habitat would remain in the project area and territories after implementation. Use of the territories is similar to that observed across the Lewis and Clark National Forest (USDA Forest Service 2015) and is not expected to change due to the proposed action. Project operations could disturb nesting goshawk. Disturbance during incubation (generally mid-April through May) could lead to nest abandonment if it is prolonged. Slashing would occur outside the incubation period primarily due to access to the project area. During the nesting period abandonment is less likely. If the resource protection measure that limits slashing activity within a quarter mile of active nests is implemented, disturbance from slashing would be negligible. Helicopter operations and burning are not expected to disturb goshawk as they would occur outside the nesting and post-fledging periods.

Migratory Birds There would be little to no impacts to habitat of black swift, Calliope hummingbird, willow flycatcher and Cassin’s finch. Aspen habitat for olive-sided flycatcher would be enhanced by the proposed action. There would be no loss of individuals or impacts to populations from the proposed action. See the Elk Smith Migratory Bird Treaty Act Memorandum of Understanding Compliance Report (USDA Forest Service 2016c) in the project record for further information.

Cumulative Effects Cumulative effects are determined from past, present, and reasonably foreseeable actions in and near the project area. Appendix D of this document lists these actions. For the wildlife analysis, past actions

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are considered as part of the existing condition and are not analyzed further here. The Birch Creek South travel plan is also considered in the existing condition. Present projects within the cumulative effects area include Benchmark III Fuels Reduction Project, adjacent to Elk Smith’s northwest boundary. The only foreseeable project with potential cumulative effects is weed treatments that occur primarily along trails and roads. The Smith Creek Piscicide Project will not impact habitat for wildlife considered in the Elk Smith Project. Cumulative effects are analyzed at the scale relevant for each species, as described below. For grizzly bear, the relevant cumulative effects scale is the bear management subunit. The Benchmark III Fuels Reduction Project is within the South Fork Willow Subunit. There are 763 acres of mechanical tree removal and burning occurring within the Subunit. The effects of these treatments will add cumulatively to the effects of treatment on 19 acres under the Elk Smith Project. As described above, the treatments proposed on in the South Fork Willow subunit would maintain openings and enhance aspen, thereby increasing forage production. This adds to the same effect in the Benchmark III Fuels Reduction Project on 592 acres of the subunit. The additional effect is so small however, (0.5 percent of the Subunit total) that it will not result in changes to grizzly use of the area. Sixteen acres of the Elk Smith Project would occur in mapped spring habitat, adding to the 752 acres of treatment under The Benchmark III Fuels Reduction Project. This does not change the effect described in the Benchmark Biological Assessment (USDA Forest Service 2010) that less than 0.5 percent of the total mapped spring habitat on National Forest lands of the Rocky Mountain Ranger District, and approximately 4 percent of the mapped spring habitat in the South Fork Willow Subunit would be affected by the proposed treatments. The cumulative effect is immeasurable. Benchmark III also adds to the disturbance to grizzly bears from project operations. Disturbance during spring is mitigated by not allowing on the ground operations prior to July 1. Weed treatment may result in increased forage production in treatment areas by controlling competition. Treatments generally occur near trails and roads, habitat of low value to grizzly bears. The cumulative effects analysis area for lynx is Lynx Analysis Unit RM-25, and more specifically those non-Forest Service lands in RM-25. RM-25 contains approximately 24 acres of non-Forest Service lands, of which 13 acres are mapped lynx habitat. The quality of habitat within those 13 acres is unknown; however, it occurs along the lower elevations adjacent to the Forest boundary. Presently, there are no known non-Forest Service actions occurring in these areas that would add cumulatively to the Elk Smith project in a way that would result in additional adverse effects. These activities include recreational use of the land, human presence and disturbance, and motorized or mechanized uses. For the remaining species the cumulative effects analysis was conducted at the scale of the sixth code watersheds where the proposed action occurs. This includes Ford Creek (Hydrologic Unit Code 100301040501), Upper Smith Creek (Hydrologic Unit Code 100301040502), Blubber Creek (Hydrologic Unit Code 100301040503), and Upper Elk Creek (Hydrologic Unit Code 100301040504). Within this area, the Benchmark III Fuels Reduction Project treats 398 acres. The Benchmark III Project treats 293 acres of elk winter range, 398 acres of bighorn sheep winter range, and 308 acres of mule deer winter range where forage quality would increase. Taken cumulatively, 4 percent of elk winter range, 3 percent of mule deer winter range, and 5 percent of bighorn sheep winter

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range (Table 36) are impacted. Cumulatively these improvements do not impact populations due to the small overall area. The Double Falls and Ford Creek South goshawk territories are within both the Elk Smith and Benchmark project areas. Elk Smith proposes 18 acres of treatment in Double Falls and 15 acres in Ford Creek South that do not alter the percent of habitat in each size class. Therefore, goshawk habitat is not affected and there are no cumulative effects. The primary effect is disturbance in the territory. The Benchmark project does not allow activities with the post-fledging areas between April 15 and August 15 to minimize disturbance. Therefore, during the nesting season cumulative effects of disturbance are mitigated. There are no cumulative effects to wolverine because there is no habitat (Inman et. al. 2013; Copeland et. al. 2010) in the cumulative effects boundary. The Benchmark III Fuels Reduction Project does not alter snag levels; therefore, there is no cumulative effects to black- backed or American three-toed woodpecker. For the remaining species, Benchmark III would add to the changes in habitat described for Elk Smith. Because of the small total area, impacted cumulative effects would not alter populations in the area. The primary cumulative effect of the Benchmark III Project and weed treatments with the Elk Smith Project is disturbance to wildlife species in the area. The Benchmark III project is currently being implemented and is expected to be completed by 2021. Weed treatments are ongoing. Any disturbed wildlife would move away from the disturbance into available adjacent habitat. There is habitat adjacent to the project areas for all species analyzed.

Statutory and Regulatory Consistency Table 43 below summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

Table 43 Summary of Statutory and Regulatory Consistency – Wildlife. Regulatory Requirement Project Consistency

This document analyzes the effects of the proposed action on National Forest Management Act Management Indicator Species and finds that viability would not be impacted.

This document reviewed the proposed action for effects to Threatened, Endangered, Proposed, and Sensitive species. The proposed action does not result in adverse impacts on Forest Service Manual Threatened, Endangered or Proposed species. Impacts to Sensitive species are minimized and viability will not be impacted.

The project is consistent with the Endangered Species Act. This document is the biological evaluation for Threatened, Endangered Species Act Endangered and Proposed Species. Consultation, as required under the Act and implementing regulations, will be conducted prior to a decision.

This document includes a discussion of migratory birds, as Migratory Bird Memorandum of Understanding required under the Memorandum of Understanding.

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Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in Appendix E (also see Table 15 in the wildlife report). Management area direction for each of the management areas states to ‘maintain’, or ‘minimize impacts’, or ‘maintain and enhance’ important identified wildlife habitat. The effects of the proposed action describe how habitat is maintained or enhanced for Threatened, Endangered and proposed species, sensitive species, and management indicator species. Inventoried Roadless

Introduction This analysis describes the existing condition in portions of the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area that are within the Elk Smith Project area3. This roadless analysis also describes the potential effects to the roadless characteristics and wilderness attributes of the inventoried roadless area from the proposed treatment activities identified in the proposed action. Roadless Expanse was considered in this analysis; however, there is no roadless expanse within the project boundary. The project lies completely within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Small non-inventoried roadless area inclusions were noted, but those inclusions were within a network of roads and high development areas. Those inclusions do not contribute to an unroaded expanse. The Elk and Smith Creek drainages on the Rocky Mountain Ranger District are characterized by an abundance of dense stands of even-aged, young lodgepole pine, largely resulting from the 1988 Canyon Creek Fire. Accumulating ground fuels, continuous crowns, and an abundance of ladder fuels in this type of forest make it more vulnerable to high-intensity, high-severity fires than a more diverse, multi-aged forest. Without management, these stands will become increasingly vulnerable to high intensity wildfire that resists control and could therefore threaten private property to the east of the Forest boundary as well as natural and cultural resources throughout the area. This large area of concentrated and continuous fuels, and the risk it represents for a potentially large, uncontrollable fire, limits opportunities to manage wildfire for its natural role in the designated Wilderness areas west and south of the project area. The purpose of the Elk Smith Project is to address fuel accumulation and continuity in the project area. More specifically, the purpose of the project is to reduce the future risk of high-intensity, high-severity wildfire within the project area by interrupting the continuity of fuels, specifically continuous stands of lodgepole pine regeneration and heavy loadings of larger fuels; to reduce the potential of wildfire spread into the Benchmark corridor to the north and onto private land east of the National Forest boundary; to create a more diverse landscape that is resilient to fire by retaining mature areas, disrupting dense areas, and enhancing or re-creating grassland openings; and to increase flexibility to

3 Inventoried roadless areas are those areas designated as inventoried roadless areas pursuant to 36 CFR 294 Subpart B, §294.11. This includes areas identified in a set of inventoried roadless area maps, contained in Forest Service Roadless Area Conservation, Final Environmental Impact Statement, Volume 2, dated November 2000.

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allow lightning-caused wildfire to play its natural role in adjacent and nearby designated Wilderness. In addition to this primary purpose, specific units and treatments within the Elk Smith Project are proposed to address additional needs that have resulted from the accumulation of fuels within the project area. The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is approximately 866,330 acres and is managed by three National Forests (Flathead, Helena-Lewis and Clark, and Lolo National Forests). The Elk Smith Project boundary is composed of 24,220 acres of the 395,440-acre portion of the Bear- Marshall-Scapegoat-Swan Inventoried Roadless Area managed by the Helena-Lewis and Clark National Forest (US Forest Service, 1986). Under the proposed action, 10,329 acres are proposed for treatment, a majority of which would fall within the inventoried roadless area boundary. Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events. Access for treatments would be accomplished using existing routes, and no new road construction or reconstruction would be completed. No commercial harvest is being proposed. There is no new road construction or reconstruction proposed in the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Equipment and forest crews would be mobilized utilizing existing roads and trails. All small diameter tree cutting would be completed by hand to prepare and implement prescribed fire activities. The Roadless Rule states 36 C.F.R. § 294.13: B) Notwithstanding the prohibition in paragraph (a) of this section, timber may be cut, sold, or removed in inventoried roadless areas if the Responsible Official determines that one of the following circumstances exists. The cutting, sale, or removal of timber in these areas is expected to be infrequent. 2.The cutting, sale, or removal of timber is incidental to the implementation of a management activity not otherwise prohibited by this subpart; The effects to the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area were analyzed using qualitative indicators. The indicators used are the five principal wilderness attributes of potential wilderness areas, as cited in Forest Service Handbook 1909.12. The existing condition of the potential wilderness attributes of inventoried roadless areas is described the Lewis and Clark National Forest Plan Environmental Impact Statement (1986). Specialists then analyzed the effect of the proposed action on each of these attributes. The Forest Service also considers inventoried roadless areas in combination with contiguous roadless lands adjacent to inventoried roadless areas. Both the inventoried roadless areas and roadless areas adjacent to the inventoried roadless areas are referred to as the “roadless expanse”. Potential effects to roadless expanses were considered but no effects were found present because there is no contiguous roadless expanse outside of the inventoried roadless area. The proposed action is consistent with the Roadless Area Conservation Rule which establishes prohibitions on road construction and road reconstruction in inventoried roadless areas on National Forest System lands, with limited exceptions.

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Relevant Laws, Regulations, and Policy

Regulatory Framework

Land and Resource Management Plan Various federal laws, Forest Service Handbook and Manual directives, as well as the Lewis and Clark National Forest Plan and Region 1 direction for conducting roadless expanse resource analyses provide the framework for the Elk Smith Project. The components of this regulatory framework and the direction for management of the roadless resources are outlined below (USDA Forest Service 2017).

Forest Plan The Lewis and Clark National Forest Plan contains both forest-wide and management area-specific direction. Forest Plan direction relevant to the roadless resources within the Elk Smith Project area is listed below. Forest Plan Direction and Regulatory Framework Various Federal laws, Forest Service Handbook and Manual directives, as well as the Forest Plan for the Lewis and Clark National Forest provide the framework for the Elk Smith Fuels Project. The components of this regulatory framework and the direction for management of the roadless resources are outlined below. The Lewis and Clark National Forest Plan contains both forest-wide and management area specific direction. Forest Plan direction relevant to the roadless areas within the Elk Smith project area is listed in Table 44 and Table 45.

Table 44 Applicable Lewis and Clark National Forest Plan Management Areas Goals. Management Area Acres Management Goals Provide sustained high level of forage for livestock and big Management Area E 2,748 game animals. Maintain and protect Forest resources with minimal Management Area G 17,018 investment. Provide winter recreation opportunities supported by public Management Area H 597 and private developments while maintaining other resource values. Protect, maintain, and improve resource quality while providing timber at a low intensity level to meet local Management Area O 3,431 needs. Manage forage for livestock at a moderate intensity level. Manage these areas to protect their wilderness values. Management Area Q 426 Manage with limited investment in range management and trail construction. Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential Management Area R N/A consideration to riparian area dependent resources. Timber and range management activities are permitted.

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Table 45 Applicable Lewis and Clark National Forest Management Areas – Inventoried Roadless Areas. Management Area Acres Management Goals/ Management Direction Recreation – Setting: Recreation setting is mostly roaded natural. Interaction between users may be low to moderate with evidence Management Area E 2,748 of other users. Resource activities will be evident but will blend with the natural environment. Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users Management Area H 597 may be low to moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high. Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users Management Area O 3,431 may be low to moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high.

Forest Service Handbook and Manual Direction Forest Service Handbook 1909.12 – Land Management Planning – Chapter 70 – Wilderness Evaluation provides direction for inventory of all lands that may be suitable for inclusion in the National Wilderness Preservation System. These lands include areas identified in the Forest Service Roadless Area Conservation Final Environmental Impact Statement (Volume 2, November 2000). This Forest Service Handbook also includes direction to comprehensively evaluate, pursuant to criteria set forth in the Wilderness Act of 1964, the wilderness characteristics or attributes of each roadless area identified during the inventory process outlined in section 71. Within this Forest Service Handbook, wilderness attributes include: • Natural • Undeveloped • Outstanding opportunities for solitude or a primitive and unconfined type of recreation • Special Features • Manageability

Roadless Area Conservation Rule The Department of Agriculture, Forest Service adopted the Roadless Area Conservation Rule in 2001 (36 CFR 220 Subpart B) with the purpose “to establish prohibitions on road construction, road reconstruction, and timber harvesting in inventoried roadless areas on National Forest System lands. The intent of this final rule is to provide lasting protection for inventoried roadless areas within the National Forest System in the context of multiple-use management.” Within this rule, the Agency decided to establish a national level rule for the management of roadless areas. Decisions made in the

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1986 Lewis and Clark Forest Plan that allowed certain forms of timber harvesting and/or road construction and/or road reconstruction in inventoried roadless areas must follow the intent of this rule. Within this rule, the cutting, sale, or removal of timber is incidental to the implementation of a management activity not otherwise prohibited by this subpart; described in 36 CFR 294.13(b)(2). Roadless characteristics include: • High quality or undisturbed soil, water, and air; • Sources of public drinking water; • Diversity of plants and animal communities; • Habitat for threatened, endangered, proposed, candidate, and sensitive species, and for those species dependent on large, undisturbed areas of land; • Primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed recreation; • Reference landscapes; • Natural appearing landscapes with high scenic quality; • Traditional cultural properties and sacred sites; • Other locally identified unique characteristics.

Region 1 Direction for Roadless Area Analyses Region 1 provides additional guidance for roadless area analysis and analysis of unroaded lands contiguous to roadless areas (USDA Forest Service 2017). In a Region 1 white paper, Riggers et al. outlines the process of conducting roadless analysis, stating that “projects on lands contiguous to roadless areas must analyze the environmental consequences, including irreversible and irretrievable commitment of resources on roadless area attributes, and the effects for potential designation as wilderness under the Wilderness Act of 1964”. This analysis has considered the effects to the entire roadless expanse – that is both the roadless area and the unroaded lands contiguous to the roadless area. Since the project area and boundary are completely within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area, the roadless expanse was limited to small inclusions with high development.

Purpose and Need for the Project The purpose of the Elk Smith Project is to address fuel accumulation and continuity in the project area. More specifically, the purpose of the project is to: • Reduce the future risk of high-intensity, high-severity wildfire within the project area by interrupting the continuity of fuels, specifically continuous stands of lodgepole pine regeneration and heavy loadings of larger fuels; • Reduce the potential for wildfire to spread into the Benchmark corridor to the north and onto private land east of the National Forest boundary; • Create a more diverse landscape that is more resilient to fire by retaining mature areas, disrupting dense areas, and enhancing or re-creating grassland openings; and • Increase flexibility to allow lightning-caused wildfire to play its natural role in adjacent and nearby designated Scapegoat Wilderness.

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Issues The following issues are relevant to the roadless resources within the analysis area: • Disclose how the project complies with the Roadless Rule; • Impacts of prescribed fire on wilderness attributes and roadless area characteristics.

Other Resource Concerns • Potential wildfire risks to public and firefighter safety; • Limited probability of successfully protecting infrastructure, soil and water resources, and wildlife habitat during a wildfire event.

Methodology Treatment activities are evaluated in relation to their effects on the roadless resource. This analysis discloses potential effects to roadless area characteristics and wilderness attributes from the Elk Smith Project proposed treatment activities in order to determine if, or to what extent, these effects might influence future consideration for wilderness recommendations. As discussed in the Regulatory Framework section, the exception at 36 §294.13(b)(2) of the Roadless Area Conservation Rule applies to this project. This analysis focuses on the potential effects of project activities on roadless characteristics as defined in 36 CFR 294 Subpart B 294.11 – Roadless Area Conservation, Final Rule and wilderness attributes as defined in the 1964 Wilderness Act and Forest Service Handbook 1909.12 (72.1). Table 46 shows the relationship between the wilderness attributes identified in Forest Service Handbook 1909.12 and the roadless area characteristics defined in the 2001 Roadless Area Conservation Rule (36 CFR Subpart B 294.11). The wilderness attributes and associated roadless characteristics are used to compare the effects of the proposed treatment activities on wilderness quality of each roadless expanse in the project area.

Table 46: Wilderness Attributes and Roadless Characteristics Crosswalk. Wilderness Attributes Roadless Characteristic High quality or undisturbed soil, water, and air. Natural: Extent to which the area’s ecological Source of public drinking water. Diversity of plant systems are substantially free from the effects of and animal communities. Habitat for threatened, modern civilization and generally appear to have endangered, proposed, candidate, and for sensitive been affected primarily by forces of nature. species dependent on large, undisturbed areas of land. Natural appearing landscapes with high scenic Undeveloped: Degree to which the area is without quality. Reference landscapes of relatively permanent improvements or human habitation. undisturbed areas. Solitude and Primitive Recreation: Personal Primitive, semi-primitive non-motorized, semi- subjective value defined as the isolation from the primitive motorized recreational opportunity sights, sounds, and presence of others and the spectrum classes of dispersed recreation. developments of man

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Wilderness Attributes Roadless Characteristic Special Features: Unique and/or special geological, Other locally identified unique characteristics, biological, ecological, cultural, or scenic features. traditional cultural properties and sacred sites. Manageability/boundaries: Ability to manage a roadless area to meet the minimum size criteria No criteria (5,000 acres) for wilderness.

Spatial and Temporal Context for Effects Analysis The potential direct and indirect effects to roadless resources were considered within the roadless area. The direct effects would be short-term and temporary, occurring during project implementation. The long-term indirect effects would be related to activities conducted to promote ecosystem maintenance incurring changes in visual qualities and other items within the project area that would influence several of the area’s roadless characteristics. The temporal bounds of the roadless effects analysis are generally dependent on the lasting effects of project activities. Effects can be either short term in nature or long term. Short-term effects are impacts from project activities that are expected to last up to five years. These would include disturbances associated with implementation of the proposed activities as well as impacts that would endure up to five years beyond implementation. Long-term effects are those projected to endure beyond five years.

Affected Environment

Existing Condition The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is located in the Northern Continental Divide Ecosystem. The Helena-Lewis and Clark National Forest, Rocky Mountain District, manages this roadless area, which provides habitat for many wildlife species, including grizzly bear, black bear, cougar, lynx, fisher, marten, elk, whitetail and mule deer, wolf, moose, mountain goat, and bighorn sheep. The higher elevations provide important summer range habitat for big game species. The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is especially important to many members of the public because of its proximity to other wilderness areas and providing the opportunities for expansive hiking, backpacking, hunting, cross-country skiing, and equestrian travel. Livestock grazing and timber harvesting represent other uses (USDA FS, 1986b, FEIS Appendix C). The Bob Marshall, Great Bear, and Scapegoat Wildernesses are accessible from the south by traveling through the Elk Smith project area portion of this roadless area. Table 47 compares the total acres of the Bear-Marshall- Scapegoat-Swan Inventoried Roadless Area to the area’s total acres included in the Elk Smith Project.

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Table 47: Inventoried Roadless Area Acreage. Total Acres in Bear- Acres of Bear- Marshall-Scapegoat- Marshall-Scapegoat- Total Acres of the Bear- Swan Inventoried Swan Inventoried Inventoried Roadless Area Marshall-Scapegoat-Swan Roadless Area Roadless Area within Inventoried Roadless Area managed by the the Elk Smith Project Helena-Lewis and Boundary Clark National Forest Bear-Marshall-Scapegoat- 866,330 395,440 23,664 Swan

Roadless Area Characteristics and Wilderness Attributes: Natural – The extent to which long-term ecological processes are intact and operating. The Forest Plan was silent on long-term ecological processes. However, a significant portion of the Elk Smith Project’s designated Roadless lands are within the Wildland Urban Interface. The entire Project Area is in proximity to private lands and infrastructure. A wildfire within the Project Area will represent an immediate threat to human health and safety, as well as a threat to infrastructure, property and livestock. As a result, natural wildfire ignitions and wildfire moving into the Project Area will likely be suppressed. The continued suppression of fire in the Project Area and in the Scapegoat Wilderness to the west will continue to degrade Roadless Area Characteristics in the Project Area and Wilderness Attributes in the Scapegoat Wilderness to the west. Undeveloped - The degree to which development and uses are apparent to most visitors. Overall, the landscape appears natural and unchanged by development. Outstanding Opportunities for Solitude and Primitive and Unconfined Recreation - Solitude is a personal, subjective value defined as the isolation from sights, sounds, and presence of others and from developments and evidence of humans. Primitive recreation is characterized by meeting nature on its own terms, without comfort and convenience of facilities. The impact of human activity is present on much of the area; however, most impacts blend in with the landscape. Past mining and grazing have created access roads throughout the area. Some roads have naturally revegetated while other Forest Service system roads provide yearlong motorized access into part of the roadless area. The area’s shape and limited roading increase the likelihood for solitude. Outside the portion commonly used by vehicles, one can generally avoid contact with other users. During big game hunting season, it is unlikely that one could avoid close contact with others. Hunting, camping, hiking, and horseback riding offer the best opportunities. The area does offer outstanding opportunities for non-motorized recreation. The majority of recreational use occurs during the fall with big game hunting season. There are occasional hikers throughout the summer months. Special Features and Values - Unique ecological, geographical, scenic, and historical features of an area.

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There are no special features and values in the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Manageability - The ability to manage an area for wilderness consideration and maintain wilderness attributes. Manageability could be feasible with some altering of the boundary. Private property could become an added complexity to managing the inventoried roadless area with the current boundary and existing roads.

Environmental Consequences

Alternative 1 – No Action The existing condition would remain. No treatment action would be implemented on the Elk Smith landscape. Only ongoing uses, permitted activities, and natural processes would continue. This is the baseline condition and will be used for comparison of effects.

Direct and Indirect Effects If the no action alternative is chosen, none of the proposed vegetation treatments would be implemented within the inventoried roadless area. There would be no direct effects from proposed activities to roadless resources. If no action is taken, the threat of high intensity wildfire and the associated hazards to the public, fire suppression resources, valued structures and community infrastructure such as power corridors will increase. In the long term, this may result in indirect effects to roadless resources, potentially impacting natural conditions such as high-quality soil, water, air, sources of public drinking water, and opportunities for primitive recreation. Natural - the extent to which long-term ecological processes are intact and operating: Treatments would not be implemented to maintain the characteristics of ecosystem composition and structure. Suppression actions would continue to take place in the Project Area and in the Scapegoat Wilderness Area to the west, reducing or eliminating the natural role of fire. The landscape would trend from heterogeneity toward homogeneity. Natural qualities in the roadless area would degrade. Undeveloped - the degree to which the impacts documented in natural integrity are apparent to most visitors: Since no treatment would occur, there would be no impact to this attribute. Outstanding Opportunities for Solitude or Primitive and Unconfined Recreation - Solitude is a personal, subjective value defined as the isolation from sights, sounds, and presence of others and from developments and evidence of humans. Primitive recreation is characterized by meeting nature on its own terms, without comfort and convenience of facilities: No treatment activities would be implemented, so there would be no direct impacts to solitude or primitive and unconfined recreation. Indirect impacts to opportunities for primitive recreation could result from dense forest conditions, fuel loading, and an increase in fallen dead trees that make travel

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through the area difficult. These conditions could enhance opportunities for solitude for those visitors who are willing and able to negotiate the increasingly inaccessible areas. The future threat of high intensity wildfire could impact opportunities for primitive recreation by changing the natural setting or scenic quality of the area. In the case of a large wildfire, sight distance and vegetative screening could be changed for decades, impacting opportunities for solitude as sights and sounds of visitors in the area as well as activities on adjacent lands would more easily be seen and heard. Special Features - Unique ecological, geographical, scenic, and historical features of an area: Since no treatment would occur, there would be no impact to special features. Manageability - The ability to manage an area for wilderness consideration and maintain wilderness attributes: Choosing the no action alternative would not change the manageability of the inventoried roadless area.

Alternative 2 – Proposed Action In accordance with 36 CFR 294.13 (b) (2); proposed treatments within the Bear-Marshall-Scapegoat- Swan Inventoried Roadless Area the cutting, sale, or removal of timber is incidental to the implementation of a management activity not otherwise prohibited; Prescribed fire treatments in Douglas-fir and lodgepole pine stands would restore ecosystem composition and structure by reducing existing fuel loading, stimulating vegetation that is adapted to periodic burning, and creating patches of natural regeneration. Treatments would re-establish fire to mimic natural disturbance on the landscape and maintain/enhance ecological communities that have been in decline. Small diameter timber would be cut (hand cutting with chainsaws) to maintain or improve the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area characteristics (CFR 294.13(b)(2)). No commercial timber harvest is proposed in the inventoried roadless area. No road construction or reconstruction is proposed in the Bear- Marshall-Scapegoat-Swan Inventoried Roadless Area. The treatment units are designed to create a mosaic of vegetation and fuel structure that will be more resilient to future disturbances from fire and potential effects from changes in climate conditions. The treatments within the project boundary were designed to buffer surrounding wildland urban interface and to maintain ecosystem function within the roadless area. The units within the roadless expanse would reflect a disturbance function of a resilient landscape. Proposed treatments within the project boundary would include prescribed fire activities and the rearrangement of fuels by hand. Also, aerial ignition, by heli-torch or plastic sphere dispenser, is proposed to mitigate personnel safety concerns related to snags and hand igniters. Refer to the forest vegetation report in the project record. In Table 48, the total acres within the inventoried roadless areas and roadless expanses are used to place into context the vegetation conditions and magnitude of proposed treatments.

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Table 48: Planned Treatments Within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Inventoried Roadless Primary Treatment Primary Treatment Activity Acres Area (acres) Type Bear-Marshall- Prescribed Burning Broadcast Burn utilizing helicopter 3,235 Scapegoat-Swan (10,329 acres) and /or hand ignition Inventoried Roadless Broadcast Burn utilizing helicopter 4,308 Area. for ignition (866,330 acres) Slash small diameter conifers 2,786 broadcast burn utilizing hand ignition Untreated No Treatments 13,892 For a complete discussion of the expected impacts of the proposed action on potential wilderness values in the analysis area, see the roadless report’s Wilderness Qualities or Attributes Worksheet, located in the project record. This worksheet contains analyses from resource specialists concerning the impact of proposed action on potential wilderness values including botanical, wildlife, soils, or hydrological resources. The summaries below are drawn from the specialist analyses in the worksheet. Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area Natural – The extent to which long-term ecological processes are intact and operating. Prescribed fire treatments would include Douglas-fir and lodgepole pine stands and would restore ecosystem composition and structure by reducing existing fuel loading and creating patches of natural regeneration. Reintroducing fire into this fire adapted ecosystem would ameliorate the impacts of fire suppression in the Project Area. Fire suppression activities in the Project Area would likely have fewer impacts in the project area, since managers would have more opportunity to utilize breaks in fuel continuity to slow, or stop, the spread of wildfire as it burned in, or toward, the Wildland Urban Interface. In addition, Wildland Fire Use For Resource Benefit would likely see increased use in the Scapegoat Wilderness. This would enhance the characteristic of “naturalness” throughout the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area by establishing forest characteristics that would have been more typical of this area if fire had been allowed to play its natural role on the landscape, and it would reduce the impacts of aggressive fire suppression. Management-ignited prescribed fire and the rearrangement of fuels is a form of modern human control or manipulation and would to some extent affect the “untrammeled” and natural character within the roadless areas (Yung, n.d.). Using low- and mixed-severity burning would mimic a wildfire within its natural regime, as opposed to a high-intensity wildfire, thereby enhancing or helping to maintain the roadless characteristic of natural appearing landscapes. In contrast, the untreated areas could appear unnatural to visitors when compared with the treated areas. The proposed action would enhance or help to maintain the roadless resources including high quality soil, water, and air; diversity of plant and animal communities; and habitat for threatened, endangered,

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proposed, candidate, and sensitive species, and for those species dependent on large, undisturbed areas of land. Undeveloped – The degree to which development and uses are apparent to most visitors There would be little evidence that the prescribed burns were initiated as a management tool versus natural ignition. The use of fire lines could create a linear disturbance within the Bear-Marshall- Scapegoat-Swan Inventoried Roadless Area; however, the use of fire line will be kept to a minimum as it is anticipated that natural breaks in fuel continuity, natural barriers to fire spread, and existing trails can be used in many cases to contain prescribed fire spread. Other methods such as black and wet lining will further reduce the need for the construction of fire lines utilizing hand tools. Blackened trees from the prescribed burning would be noticeable; however, fire is a natural process and should not affect the roadless integrity. The proposed prescribed fire would help ensure the forest maintains a visual appearance characteristic of a wildfire within its natural regime, including a mosaic of low, moderate, and high fire severity effects on the landscape. The result will contribute to the roadless characteristic of natural appearing landscapes with high scenic integrity. Stumps from the hand cutting of small diameter trees and prescribed fire treatments may remain visible for several seasons following restoration, which may detract from the undeveloped character for visitors traveling through the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Other short-term indirect impacts on the undeveloped characteristics include smells of smoke, which could persist for a few days after ignition. However, it is not expected for smoke emissions to exceed the State of Montana air quality standards and there would be less smoke than what is predicted under the no action alternative. Dust from machinery could also be present while operations occur. These effects would not cause lasting impacts on the undeveloped characteristics. Outstanding opportunities for solitude or primitive unconfined recreation – Solitude is a personal, subjective value defined as the isolation from sights, sounds, and presence of others and from developments and evidence of humans. Primitive recreation is characterized by meeting nature on its own terms, without comfort and convenience of facilities. There may be short-term effects to solitude within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area during project implementation due to the presence of Forest personnel managing the prescribed fire and noise associated with the use of chainsaws to cut small diameter trees. Solitude could temporarily be reduced during project implementation due to the sounds of equipment and helicopters during aerial ignition. However, this disturbance would likely occur for only a few days each year until the activity is complete. Timing would depend on weather, smoke dispersion conditions, and funding. Solitude would have short-term direct impacts during burning activities. Sights and sounds of machinery and crews would be obvious and apparent to visitors just inside the roadless expanse while treatments were ongoing. Solitude could be affected in the long term in the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area where the tree density and spacing allows for greater sight distance. In general, recreation patterns are not expected to deviate from the existing condition.

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Indirect effects to opportunities for primitive and unconfined recreation could result from changes to the appearance of the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area following broadcast and jackpot burning. These treatments are proposed in a portion of the larger Bear-Marshall-Scapegoat- Swan Inventoried Roadless Area. The remainder of the inventoried roadless area would offer the same opportunities as under existing conditions. The proposed vegetation management treatments would result in improvements in forest health and sustainability that are large and widespread. In the event of a wildfire or insect infestation, the reduction of fuel would likely reduce subsequent fire size, occurrence, and severity; insect infestation among conifers could potentially be reduced. In addition, the treatments would increase aspen vigor and reproduction across the landscape, maintaining an important ecosystem component in the Elk Smith Project Area. This would indirectly benefit primitive and unconfined recreation in the long term by retaining opportunities for activities currently enjoyed by the public. Effects to primitive and unconfined recreation would be minor and limited to those time periods when activities were taking place. People could be displaced from areas while project implementation was occurring. An indirect effect of proposed prescribed fire activities could be displacement of visitors to untreated areas for recreation, mostly because of visuals. Downfall from burned trees could dissuade some visitors.

Special Features There are no special features and values in the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area.

Manageability Overall, the effects to wilderness character within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area would be minor and short term. The proposed action would not affect the existing manageability of the roadless and unroaded lands in the analysis area. There are no new roads proposed in the roadless area that would complicate potential wilderness boundary management.

Alternative 2 Cumulative Effects

Cumulative Effects Process Cumulative effects to roadless resources were considered within the roadless area. Potential cumulative effects to roadless resources would be related to other reasonably foreseeable, ongoing and past project activities occurring within the roadless expanse that have the potential to impact roadless area characteristics or wilderness attributes.

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis Cumulative effects to roadless resources were considered within the Elk Smith Project’s 24,220 acres. The effects of past actions within the roadless expanses are incorporated into the description of the existing conditions and summarized. Cumulative impacts to roadless resources would result if other activities take place during implementation of the Elk Smith Project, or until vegetation growth obscures

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the visible stumps from the hand cutting of small diameter trees and hand fire lines, approximately three to five years. Short-term effects could potentially diminish outstanding opportunities for solitude or primitive unconfined recreation for some visitors within the roadless expanse areas. Sounds from fire personnel and mechanical equipment do have the short-term potential to displace visitors during fuels treatment activities as well as impact one’s solitude experience. The increased noise from prescribed fire activities has the potential to negatively impact one’s solitude and primitiveness experience. The activities proposed in the Elk Smith Project have the potential to cumulatively impact the natural and undeveloped characteristics by causing changes to the scenic qualities within the project area and creating a setting where resource modifications and utilization practices are evident. Evidence of human activity would likely be noticeable to users of the area after treatments. This would have the short-term effect to impact undeveloped and scenic qualities. These impacts should be considered in context of the impacts of fire suppression activities occurring if treatments are not implemented. Without treatment, wildfires in the Project Area are likely to be more common and larger. Fire suppression activities to protect human safety and property are likely to require more resources, over a longer duration, and are less likely to be effective. Impacts on the landscape are likely to cover a broader landscape and include more extensive areas of fireline construction and retardant application. In addition, trail and area closures are likely to be maintained over a longer period, impacting the public’s ability to enjoy these roadless landscapes and impacting local economies. The impacts of smoke produced by larger wildfires are also likely to impact Forest visitors and local communities over a longer period than typically occurs with the application of prescribed fire. The long-term cumulative effects proposed hand cutting activities and fuels treatments within the roadless area will make travel into and out of the area more accessible and easier for visitors; therefore, it is possible assume there will be an increase in the human presence and visitation within the area. Increased access and visitation have the potential to reduce one’s sense of solitude and primitiveness. In addition, prescribed fire treatments may cause an increase in noxious weed infestations. While mitigation measures are included, those mitigation measures include pre- and post-treatment of the units. One’s sense of solitude and primitiveness would be impacted in the short-term if one is in the area at the time implementation actions are occurring. Reintroducing fire into this fire-adapted ecosystem would reduce the risk of large, severe wildfires. This would cumulatively enhance the characteristic of “naturalness” throughout the roadless expanse areas. Other present and reasonably foreseeable future activities include continued ongoing maintenance on open forest roads, including maintaining road and surface drainage to address current resource issues such as erosion, clearing roadside vegetation, and repairing and maintaining culverts. These activities would have a largely neutral effect on potential wilderness attributes in the analysis area as they would perpetuate the existing human-modified landscape condition. Recreational activities such as big game hunting, horseback riding, snowmobiling, cross country skiing, and camping would continue. Motorized use of trails and snowmobiling in the winter would continue. Other ongoing and reasonably foreseeable activities that would occur within the roadless expanses include trail maintenance, noxious weed treatment, commercial guided recreation, and ongoing use of grazing allotments and roads. These activities, when added to the activities proposed in the Elk Smith,

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have the potential to cumulatively effect the roadless values and wilderness attributes within the analysis area. The primary effects would be due to the increased presence of people, vehicles, and associated noise that would directly affect solitude and opportunities for primitive and unconfined recreation in all roadless expanses. Cumulative effects are expected to be primarily short-term and temporary.

Compliance with Forest Plan The proposed alternatives are consistent with the Lewis and Clark National Forest Plan, as documented in the Forest Plan consistency table located in (page 183, Appendix E of the 2019 Environmental Assessment located in the project record). Consistent with 36 CFR 294.13 (b)(2), the cutting of generally small diameter timber is incidental to the implementation of the proposed prescribed fire management activities that are not otherwise prohibited by the Roadless Rule.

Conclusions Under the no action alternative, potential impacts to natural and recreation values would result from not addressing wildfire suppression. Wildfire suppression is a management option that will see continued use in the Project Area in the future, due to the immediate threat wildfire poses to human health and safety, as well as to property, infrastructure, and livelihoods. Paradoxically, continued suppression of wildfire events will undermine the ability of managers to effectively, and safely, suppress wildfire in the future. It will also lead to increased homogeneity on the landscape as aspen stands and conifer stands develop without fire. The Project Area is part of a fire-adapted ecosystem that requires disturbance events such as wildfire for its maintenance. Mimicking wildfire using prescribed fire is likely to reduce the occurrence, size, and severity of wildfires starting in the Project Area, or wildfire moving into the Project Area. The no action alternative will perpetuate conditions that will potentially support larger, more severe fires that pose a greater threat to human health, safety, property and livelihoods. The proposed action would have short-term direct impacts to roadless resources during project implementation such as increased presence of people and noise within the project area. These disruptions will likely compare well to the longer disruptions and impacts that may be anticipated from suppression activities associated with larger, more severe fires that could result from the no-action alternative. The proposed treatments would address the purpose and need for the Elk Smith Project, resulting in long term resiliency for the roadless area with reduced risk of wildfire to people, livestock, infrastructure and property. The long-term indirect effects from the proposed action to roadless resources would be generally beneficial and help maintain the existing recreation settings and scenic qualities within the project area. Impacts would be stable or improving for a majority of roadless area characteristics and wilderness attributes. There would be short-term impacts to the undeveloped character from the hand cutting of small diameter trees and construction of prescribed fire control lines in addition to short-term impacts to solitude during project implementation. These impacts would be offset by the expansion of Wildland Fire Use for Resource Benefit in the Scapegoat Wilderness, increased heterogeneity in the Project Area, and a reduction in wildfire threat to people.

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Cumulative effects to roadless resources for the proposed action would generally be short term and related to an increased presence of people, vehicles, and the associated noise that may affect solitude. Proposed treatments that would generally reduce density would be consistent with the natural range of variation description for the Elk Smith Project and increase the resiliency of forests to forest insects and pathogens. The project would be consistent with Roadless Area Conservation Rule and be within the exceptions identified in 36 294.13(b)(2) because the proposed treatments would include the cutting, sale, or removal of timber incidental to the implementation of a management activity not otherwise prohibited. Treatments in the roadless area are within the range of variation that would be expected to occur under natural disturbance regimes of the current and anticipated future climate. Visuals Introduction The visual quality (scenery) of the Elk Smith Fuels project area may be affected by actions proposed by this project. These effects vary in duration and intensity and are visible from a few identified viewpoints along the Elk Creek Road (Forest Road #196) up to the Elk Creek Trailhead within the project area and the private inholdings. The visual effects of these proposed activities will meet Forest Plan standards and Visual Quality Objectives with the implementation of the identified design criteria. Regulatory Requirements Forest Plan Direction (goals, objectives, standards) The Lewis and Clark National Forest Plan provides overall direction for visual quality (scenery) on the forest. Forest-wide Management Standard A-8 states that “[l]andscape management principles will be applied to all activities on the Forest. This will be accomplished by implementing the procedures defined in National Forest Landscape Management, Volume 2, Chapter I, of The Visual Management System (Agricultural Handbook No. 462)” (Lewis and Clark Forest Plan, pg. 2-28). The Forest Plan also “states a Visual Quality Objective for each management area. These Visual Quality Objectives provide the guideline for altering the landscape” (Lewis and Clark Forest Plan, pg. 2-28). Proposed units are located within lands allocated to Management Areas E, G, H, O, Q and R. Guidelines for meeting Visual Quality Objectives are described in Forest Service Handbook 462, National Forest Landscape Management, Volume 2 and Table 49.

Table 49: Applicable Lewis and Clark National Forest Forest-wide Management Area Standards. Standard Acres Visual Quality Objective Management Standard A-8 Not Applicable Meets Standard Management Standard E-4 Not Applicable Meets Standard; occupied grizzly bear habitat on the Rocky Mountain Division. Management Area E 2,748 Partial Retention Management Area G 17,018 Retention or Partial Retention Management Area H 597 Retention or Partial Retention

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Standard Acres Visual Quality Objective Management Area O 3,431 Retention or Partial Retention Management Area Q 426 Preservation Management Area R Not Applicable Not Applicable Manual Direction/Handbook Direction In 1986, when the Lewis and Clark National Forest Plan was adopted, the visual resource was inventoried and analyzed using the original Visual Resource Management System as outlined in Forest Service Handbook 462, National Forest Landscape Management System, Volume 2, Chapter 1. This system, which was released in 1974, established standards of measurement (Visual Quality Objectives) for assessing proposed and existing impacts to the scenic quality. In 1994, after 20 years of experience with the Visual Management System and after additional research in the public and private sectors, the Forest Service revised the Visual Management System and replaced it with the Scenery Management System. This revised system is described in Agricultural Handbook 701, Landscape Aesthetics: A Handbook for Scenery Management. The Scenery Management System will not be implemented until the Lewis and Clark National Forest Plan is revised. Both systems will provide guidance for the effects analysis of the scenery (visuals) resource in the Elk Smith Fuels project area. Other Regulatory Requirements The visual or scenery resource is regulated by CFR 219.21 (f), which states, “The visual resource shall be inventoried, and evaluated as an integrated part of evaluating alternatives… [for] both the landscape’s visual attractiveness and the public’s visual expectation. Management prescriptions shall include visual quality objectives.” Analysis Methods Proposed activities in the Elk Smith Fuels project area may impact visual/scenic quality by introducing colors, lines, textures, and patterns that contrast with the existing landscape character of the project area. The measurement indicator for these effects is the visible effect of proposed activities as seen from the viewpoints identified as important in this analysis. This analysis includes both direct and indirect visual effects and will be analyzed to determine whether or not these effects meet the Visual Quality Objectives identified in the Lewis and Clark Forest Plan. The two visual landscape management systems used to evaluate this project area were the Visual Resource Management System (National Forest Landscape Management System, Volume 2, Chapter 1, Handbook 462) and the Scenery Management System (Landscape Aesthetics, a Handbook for Scenery Management, Handbook 701). These two systems were used in combination with field study of the area. Through field visits, important viewpoints were identified, scenic integrity levels were determined, and Forest Plan visual inventory data was verified. The Visual Quality Objectives for the Elk Smith Fuels project were reviewed prior to this analysis and found to be appropriate based on the current management direction for this area. No changes or refinements of the Visual Quality Objectives were found to be necessary for this area at this time.

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Desired conditions for the Elk Smith Fuels project were taken from the Lewis and Clark Forest Plan and from observations made in the field. These desired conditions were compared with the existing conditions of the area and the results of implementation of the alternatives. Analysis area boundary The Elk Smith Fuels project area boundary will be used to conduct the visual (scenery) resource analysis for this project.

Existing Condition Scenic Integrity of the Elk Creek Drainage Scenic integrity is defined in United States Department of Agriculture Handbook 701 as: “…a measure of the degree to which a landscape is visually perceived to be "complete." The highest scenic integrity ratings are given to those landscapes which have little or no deviation from the character valued by constituents for its aesthetic appeal. Scenic integrity is used to describe an existing situation, standard for management, or desired future conditions. Using definitions contained in this handbook, the landscapes of the Elk Creek drainage "appear to be slightly altered." These deviations are typically visually subordinate to the surrounding landscape and have a scenic integrity level that is defined as "moderate." Mine tailing ponds and other mining activity do not occur on National Forest lands, but impacts, including some tailings, do affect public lands. Past timber harvesting in the drainage is not typically visually evident from the main Elk Creek Road (Forest Road #196), except for middle ground views up near the private inholdings. Power lines are evident along parts of Forest Road #120, as is fencing and pastureland in private lands. Generally, the landscape appears visually to be very intact. There is, however, concern about pine-dominated landscapes (lodgepole pine) with stands that are becoming increasingly at risk to insect infestation and disease because of past drought conditions. Some of these stands are showing a moderate to high amount of mortality due to increasing insect infestation and portions of these stands are visible from the Elk Creek corridor. The existing landscape is largely the result of the Canyon Creek fire of 1988. This expansive fire was a natural event, though efforts were made to suppress its spread across the Project Area and onto private lands to the east of the Project Area. The Project Area is now characterized by extensive stands of dense, even-aged, lodgepole pine. These often occur growing through a matrix of downed snags that have fallen since 1988. Snags from the Canyon Creek fire persist on the landscape but continue to fall, adding to the depth of downed fuels in the area. Young aspen stands also occur across the landscape, in some cases independent of the lodgepole stands. Many of the aspen stands are embedded deeply within lodgepole pine regeneration, while other clones have significant conifer regeneration on their edges and within their perimeters. Patches of mature conifers that were not burned during the 1988 fire are also evident on the landscape. Grass and shrub meadows interrupt expanses of downed snags and regenerating lodgepole pine. The northern tier of the Elk Smith Project Area is predominately mature Douglas-fir forest that largely escaped the direct impacts of the 1988 fire, though spotting from the fire did occur in this locale—the edge of the 1988 fire appears broken and non-linear here. The

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Project Area elevation ranges from 4,800 feet to 8,585 feet, with vegetation reflecting changes in elevation, from lodgepole pine and Douglas-fir forest at lower elevation to whitebark pine, subalpine fir, and limber pine in the higher subalpine forest. Landscape Visibility Landscape visibility addresses the relative importance and sensitivity of what is seen and perceived in the landscape. The Elk Smith Fuels project area can be viewed from a few locations along the main road and trails in the area. Views from the Elk Creek Road (Forest Road #196), dispersed recreation sites and hiking trails along this route are considered to be the most important. Internal Issues Studied in Detail Proposed activities in the Elk Smith Fuels project area may impact visual/scenic quality by introducing colors, lines, textures, and patterns that contrast with the existing landscape character of the project area. The measurement indicator for these effects is the visible effect of proposed activities as seen from viewpoints identified as important in this analysis and as measured against the Visual Quality Objectives established for this area by the Lewis and Clark Forest Plan.

Environmental Effects Analysis Effects Common to Both Alternatives At present, insect infestations are causing some mortality in the pine and Douglas-fir tree communities in the Elk Smith Fuels project area. Specifically, mountain pine beetle is infesting and killing the lodgepole pine trees and Douglas-fir beetle is creating mortality in the Douglas-fir trees. This mortality is obvious to those who live in the private inholdings and for those people traveling Elk Creek Road. The infested trees are most noticed as red-needled trees or standing dead trees. These trees are noticed in small groups or clumps or scattered individuals of red or dead trees in an otherwise green forest canopy. Mortality as a result of these insects will continue to be visually evident in the Elk Smith Fuels project area regardless of the alternative chosen. It is anticipated that many of the dead trees within close proximity to the Elk Creek Road (Forest Road #196) will be cut down by local people for firewood. The effects of firewood cutters can vary. In general, firewood cutters take those trees that are already dead and the patterns of removal from firewood gathering tend to echo what is happening naturally across the landscape. Often landscapes that have had a moderate degree of firewood taken out, especially next to busy roads, can appear quite messy, with slash piles and tree tops left randomly scattered across the forest floor. These visual effects diminish over time but can initially create a noticeable visual change to the scenic quality of an area if there is a large patch of dead being removed. Concerns about wildfire in this project area are amplified by the increasingly large numbers of dead or down trees considered to be “fuel” for fires, by the proximity of private inholdings. In general, wildfire, whether it be a ground fire that burns underneath the canopy of trees or a “stand replacing” fire that kills large patches of trees, tends to create natural patterns that are inherent on these landscapes. The Visual Quality Objectives established for the project area by the forest plan will be met by any future wildfires in the project area.

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Alternative 1: No Action

Summary Alternative 1 is the No Action Alternative. Any changes to the scenic quality of the project area would be the result of insect infestation, disease, or wildfire. Dead trees would be noticed from Elk Creek Road and from dispersed campsites within the Elk Smith Fuels project area boundary. While the scenic quality is expected to change in this alternative, these changes will not be a result of a planned timber harvest and the Forest Plan Visual Quality Objectives would be met.

Direct and Indirect Effects Tree mortality as a result of infestations of mountain pine beetle and Douglas-fir beetle is creating a pattern of red-needled trees across many of the forested landscapes in the Elk Smith Fuels project area. The No Action Alternative proposes to do nothing with these trees, leaving them in place on the landscape to create natural patterns of dead within the live forest canopy. As mentioned above in the effects common to both alternatives, there would be some visual impacts created by firewood gathering activities along the Elk Creek Road (Forest Road #196). The Visual Quality Objectives established for this area by the Forest Plan would be met, even with the anticipated tree removal by firewood cutters. Wildfires, both under burns and stand replacing, may create additional changes to the visual/scenic quality of the project area over time. Alternative 1 would not initiate prescribed fire to reduce fuels in these areas. Fire suppression would continue in the Project Area and on nearby lands. As a natural landscape disturbance, fire would be limited, or eliminated, on the landscape. The structure of existing stands of conifers would converge, contributing to homogeneity across the landscape. Snags in the area would continue to fall, contributing to increased surface fuel loads. Fire danger would increase. Wildfires that resisted suppression efforts would be of increased severity, intensity, and size. In the absence of a disturbance event, such as wildfire or prescribed fire treatment, the health and vigor of aspen stands across the project area is likely to decrease. Conifers will continue to encroach on aspen, reducing the size of aspen clones. The impact on smaller aspen stands may be particularly noticeable. Overall, this important, and iconic, feature of the landscape will be negatively impacted by the lack of disturbance.

Alternative 2: Summary Alternative 2 is the proposed action alternative. Alternative 2 concentrates on the reduction of fuels in stands located adjacent to or nearby private properties and areas of high dispersed camping use within the project area. In addition to fuels reduction, these units would also protect mature forests and increase the overall health and vigor of younger forests. Cutting of small diameter trees combined with prescribed burning would also be initiated to further reduce the fuels across the landscape. Alternative 2 would initiate changes to the visual or scenic quality of the area and these effects would meet the Forest Plan standards and Visual Quality Objectives established for the project area. There are

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design criteria that are required to reduce the visual effects of the proposed actions, particularly of those units visible from Elk Creek Road (Forest Road #196). Effects of Fuels Treatments In the Elk Smith Fuels project, cutting is recommended as a pre-treatment for some of the prescribed burning units (less than 7” diameter at breast height) and leaving them in place. Young conifers would be removed at the margins of aspen stands and on some natural openings. These downed conifers would be visible as they cured and their needles changed color; however, they would become less visible as subsequent prescribed fire application reduced their profile on the landscape. Additionally, aspen suckering initiated by prescribed fire would further reduce this visual impact. Effects of Prescribed Burning Additionally, prescribed fire has many effects for two types of fire use. These treatments are broadcast burning and jackpot burning. Broadcast Burn: A broadcast burn is a prescribed burn where fire is applied to most, if not all, of an area within well-defined boundaries to reduce fuel hazard, as a resource management treatment, or both. It is most often used in regeneration harvests where all or most of the trees have already been removed. This burning prescription would be noticed as blackened ground surfaces, blackened stumps, standing and downed dead trees and logs, and small clumps of standing red-needled trees. Jackpot Burning: Several units in the Elk Smith Fuels project include jackpot burning. Jackpot burning is used to reduce fire hazard in areas where heavy fuel concentrations exist but are not continuous enough for a broadcast fire to carry through the fuels. In the Elk Smith Project, broadcast and jackpot burning will be combined on several units. In some portions of the landscape, isolated concentrations of fuels may be present that will be ignited over the landscape. These patches will likely be smaller than the more continuous fuels treated with broadcast burning. The overall effect on the landscape will be variation in the patch size of area burned. Isolated burned patches will be interspersed across the landscape with larger patches (generally 20 to 100 acres). The resulting pattern on the landscape should be patchy, emulating the pattern of reburn by wildfire, where pockets of burn are created by the main fire spotting over less receptive fuel beds. The combined area of patches resulting from both jackpot and broadcast burning will cover 30 percent to 50 percent of Project Area Units.

Direct and Indirect Effects Most of the treatment units would not be visible from Elk Creek Road (Forest Road #196). Portions of a few units may be visible from the private inholdings. These units lie within Management Area H which has a Retention/Partial Retention Visual Quality Objective assigned to it by the Forest Plan. All units would meet the Forest Plan Visual Quality Objective of Partial Retention about three to five years after implementation.

Cumulative Effects Cumulative effects in the Elk Smith Fuels project area include past, present, and foreseeable future timber harvesting, prescribed burning, road reconstruction, recreational use, range developments,

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private land development, special use permits, and weed spraying. The following past, present, and foreseeable actions were considered in the cumulative effects analysis. Lewis and Clark National Forest, Rocky Mountain Ranger District: • Benchmark III Fuels EA • Rocky Mountain Ranger District Travel Plan EIS, Birch Creek South Area • Range Allotment Management • Weed and Invasive Species Management • Fire Management Cumulative Effects of Alternative 1: The above actions will have many and varied effects to the visual quality of the Elk Smith Fuels project area. The most obvious of these would be those effects created by the firewood gathering adjacent to the private inholdings. These activities combined with the natural process of insect, disease, and wildfire would have some effects to the scenery of the project area, but these would be short term (three to five years). Even with these activities taking place, Forest Plan standards (Visual Quality Objectives) would be met. The impacts of fire suppression are considered, below, for both alternatives. Cumulative Effects of Alternative 2: The cumulative effects analysis boundary for the visual resource is the same as the Elk Smith Fuels project area boundary. As described above, there are few past, present, and foreseeable actions that will, would, or have taken place in the Elk Smith project area that would leave visual effects. The most obvious of these would be those effects created by the fuels reduction work and firewood gathering. These activities would have some effects to the scenery of the project area. For three to five years, while the bulk of the activities are being accomplished, including vegetative treatment proposed by the Elk Smith Project, the area would appear very busy. However, the long-term Forest Plan standards would be met. Fire suppression is an important fire management strategy in the Elk Smith Project area, and it will likely see continued use to reduce the immediate threat a wildfire in the area poses to human health, safety, and property. However, fire suppression can impact natural processes in fire adapted ecosystems. The consequence of interrupting these processes include increased risk of larger, more severe, fires. If successful, fire suppression can also lead to more homogenous landscapes compared to landscapes that see natural fire occurrence and reoccurrence. Due to the area’s location within--and in immediate proximity to—the Wildland Urban Interface, wildfires are unlikely to play their natural ecological role in the area, unless they overcome all management efforts to suppress their spread. The proposed action seeks to replicate the effects of a reburn, or second entry fire, on the landscape. The results are intended to create a mosaic of fire patches on the landscape, increasing heterogeneity and resilience in the ecosystem. Visually, these effects will include more variation in conifer stands across the Project Area. Variation would primarily be in age class and density. In addition, aspen clones would be a more prominent component of the landscape, with the area occupied by clones expanded from post-fire suckering.

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Monitoring Roadless Area monitoring would consist of visually surveying units treated with prescribed fire to determine if illegal off-highway vehicle use is taking place in treated areas. If monitoring reveals this is happening, steps would be taken to eliminate the use (i.e. signing, barrier installation, increased law enforcement). Carbon and Greenhouse Gas Emissions The Carbon and Greenhouse portions of this EA Supplemental and the projects proposed action were reviewed in the 2019 Final Environmental Assessment for the Elk Smith Project, the 2015 (updated 2019), the Fuels, Wildlife, and Roadless Supplemental Reports, the Supplemental Environmental Assessment (USDA Forest Service 2020, pages 202 to 205) for the Elk Smith Project Supplemental Environmental Assessment. Based on this review there are no changes to the treatment types, amount of acres treated, and effects on the ground, therefore, no changes for assessed impacts to carbon and greenhouse gas emissions. The treatment effects are as originally analyzed and there are no changes to the carbon and greenhouse gas emissions portion of the 2019 Final Environmental Assessment (USDA Forest Service 2019, pages 153 to 157).

Introduction Forests play an important role in the global carbon cycle by taking up and storing carbon in plants and soil. Forestry has gained attention in recent decades because of its potential to influence the exchange of carbon with the atmosphere, either by increasing storage or releasing carbon emissions. Forests have a carbon “boom and bust” cycle. They take up and store atmospheric carbon as they grow through photosynthesis and release carbon through mortality due to aging or disturbances. Following mortality events, forests regrow and the cycle continues. Forests can store carbon in soils and plant material as well as in harvested wood products outside of the forest ecosystem. A complete and quantitative assessment of forest carbon stocks and the factors that influence carbon trends (management activities, disturbances, and environmental factors) for the Helena – Lewis and Clark National Forest is available in the project record (USDA Forest Service 2015b).

Direct and Indirect Effects Analysis Boundaries The effects analysis area for carbon includes forested lands within the Helena – Lewis and Clark National Forest because this is where slashing and prescribed burning treatments are proposed and where carbon stocks may be affected. The effects analysis for greenhouse gas emissions is the global atmosphere given the mix of atmospheric gases can have no bounds. The timeframe for the analysis is 10 years because all project activities should be completed by then.

Affected Environment The carbon legacy of the Helena – Lewis and Clark National Forest is tied to the history of Euro-American settlement, land management, and disturbances. In the 1880s, large areas of land were cleared for agriculture, settlements, and railroad expansion. By the 1890s, the region’s forest products industry started growing. Timber harvest, at a small scale in the late 1800s, continued to expand and intensify

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through the early 1900s (Baker et al. 1993) with large-scale logging in the 1940s. The carbon legacy is also tied to the region’s history of fire, fire management, and severe bark beetle outbreaks causing widespread tree mortality, reduced carbon uptake, and increased emissions from the decay of dead trees (Kurz et al. 2008). Historical disturbance dynamics, forest regrowth and recovery, and forest aging have been most responsible in driving carbon accumulation trends since the 1940s. Large scale fires, mountain pine beetle and Douglas-fir beetle outbreaks, and recurrent western spruce budworm defoliation are most recent disturbance events shaping the Forest’s carbon trends. Forests in the Helena – Lewis and Clark National Forest are maintaining a carbon source and forest carbon stocks have decreased by about 13.8 and 2.44 percent, respectively, on the Helena and Lewis & Clark portions of the combined National Forest between 1990 and 2013. Negative effects on carbon stocks may in part be due to recent insect-caused tree mortality and large wildfires in 2003, 2007, and 2011 (USDA Forest Service 2015b; USDA Forest Service, 2017). As young stands established from these disturbances, reach middle-age in the coming decades, the rate of carbon accumulation will likely increase so the Forest has the potential to again become a carbon sink (USDA Forest Service, 2017). Over half of the stands in the Helena – Lewis and Clark National Forest are middle-aged and older (greater than 80 years) and there has been a sharp decline in new stand establishment in recent decades (Birdsey et al., in press). If the Forest continues on this aging trajectory, more stands will reach a slower growth stage in coming years, potentially causing the rate of carbon accumulation to decline. According to satellite imagery, fire has been the dominant disturbance type on the Helena – Lewis and Clark National Forest from 1990 to 2011, affecting approximately 0.21 percent of the forested area annually (Birdsey et al., in press). During this period, about 4.6 percent of the forested area experienced some level of fires including prescribed fires and wildfires. However, some prescribed fires that burned only along the forest floor may have gone undetected because they did not cause a change in canopy cover. Carbon losses from the forest ecosystem associated with fires have been relatively small compared to the total amount of carbon stored in the forest, with losses from 1990 to 2011 equivalent to about 2 percent of non-soil carbon stocks.

Direct, Indirect and Cumulative Effects The proposed Elk Smith project includes slashing and prescribed burning treatments that would be conducted on approximately 10,330 acres of the Helena – Lewis and Clark National Forest. This scope and degree of change would be minor, affecting a maximum of 0.97 percent of the 1,068,998 acres of forested land in the Helena – Lewis and Clark (2,846,606 total acres). In addition, the effect of the proposed action focuses on the aboveground carbon pool that is stored in live woody vegetation, which comprise about 29 to 32 percent of the total ecosystem carbon stocks of the Helena – Lewis and Clark (USDA Forest Service 2015b). The effect of the proposed prescribed fire focuses on the down dead and standing dead pools, which together comprise about 10 to 12 percent of the Forestwide ecosystem carbon stocks. However, about 28 percent or more of the ecosystem carbon is in mineral soils, a very stable and long-lived carbon pool (McKinley et al., 2011; USDA Forest Service 2015a; Domke et al. 2017).

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Climate change is a global phenomenon, because major Greenhouse Gases4 mix well throughout the planet’s lower atmosphere (IPCC 2013). Considering emissions of greenhouse gases in 2010 were 5 estimated at 13,336 ± 1,227 teragrams carbon globally (IPCC 2014) and 1,881 teragrams carbon nationally (US EPA, 2015), the Elk Smith project makes an extremely small direct contribution to overall emissions. Because local greenhouse gases emissions mix readily into the global pool of greenhouse gases, it is difficult and highly uncertain to ascertain the indirect effects of emissions from single or multiple projects of this size on global climate. Any initial carbon emissions during the implementation of the proposed project would have a temporary influence on atmospheric carbon concentrations, because carbon will be removed from the atmosphere as forests regrow, minimizing or mitigating any potential cumulative effects. From 2000 to 2009, forestry and other land uses contributed 12 percent of the human-caused global 6 Carbon Monoxide 2 emissions (IPCC 2014). The forestry sector’s contribution to greenhouse gases emissions has declined over the last decade (IPCC 2014; Smith et al. 2014; FAOSTAT 2013). The largest source of greenhouse gases emissions in the forestry sector globally is deforestation (e.g., conversion of forest land to agricultural or developed landscapes) (Pan et al., 2011; Houghton et al., 2012; IPCC 2014). However, forest land in the United States has had a net increase since the year 2000, and this trend is expected to continue for at least another decade (Wear et al., 2013; USDA Forest Service 2016). The proposed activities in the Elk Smith project will not result in the loss of forest land from the Helena – Lewis and Clark National Forest. In fact, forest stands are being retained and prescribed burned to mimic natural fire effects to maintain a vigorous condition that supports enhanced tree growth and productivity, reduces the risk of insect and disease, and supports sustainable ecosystems thus contributing to long-term carbon uptake and storage. Some assessments suggest that the effects of climate change in some United States forests may cause shifts in forest composition and productivity or prevent forests from fully recovering after severe disturbance (Anderson-Teixeira et al., 2013), thus impeding their ability to take up and store carbon7 and retain other ecosystem functions and services. Climate change is likely already increasing the frequency and extent of droughts, fires, and insect outbreaks, which can influence forest carbon cycling (Kurz et al., 2009; Allen et al., 2010; Joyce et al., 2014). In fact, reducing stand density, one of the goals of this proposed action, is consistent with adaptation practices to increase resilience of forests to climate-related environmental changes (Joyce et al., 2014). This proposed action is consistent with options proposed by the Intergovernmental Panel on Climate Change for minimizing the impacts of

4 Major greenhouse gases released as a result of human activity include carbon dioxide (CO2), methane, nitrous oxide, hydrofluorocarbons, and perfluorocarbons. 5 This report uses carbon mass, not carbon dioxide (CO2) mass, because carbon is a standard unit and can easily be converted to any other unit. To convert carbon mass to CO2 mass, multiply by 3.67 to account for the mass of the oxygen (O2).

6 Fluxes from forestry and other land use (FOLU) activities are dominated by CO2 emissions. Non-CO2 greenhouse gas emissions from FOLU are small and mostly due to peat degradation releasing methane and were not included in this estimate. 7 The term “carbon” is used in this context to refer to carbon dioxide.

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climate change on forests, thus meeting objectives for both adapting to climate change and mitigating greenhouse gases emissions (McKinley et al., 2011). The relatively small quantity of carbon released to the atmosphere and the short-term nature of the effect of the proposed action on the forest ecosystem are justified, given the overall change in condition increases the resistance to wildfire, drought, insects and disease, or a combination of disturbance types that can reduce carbon storage and alter ecosystem functions (Millar et al., 2007; D’Amato et al., 2011). Many forest species of the Northern Region are well adapted to fire and in some cases may depend on it for survival and regeneration. Historical fire suppression has allowed some fire-dependent forests to become unnaturally dense and surface fuels to build up in some areas of the region (e.g., Agee 1998; Agee and Skinner 2005). Furthermore, climate change has caused warming temperatures and increasing intensity and frequency of droughts, which has led to increased wildfire activity in many forest types (Westerling et al., 2006). In the absence of prescribed fire to reduce stand density and fuel loads, the fire-adapted forest where the proposed treatments would take place may be more at risk to a high-severity wildfire, resulting in decreased ecosystem services and potentially increased carbon emissions. Prescribed fires generally target surface and ladder fuels and are typically less severe than wildfires (Agee and Skinner 2005), because they are conducted only when weather conditions are optimal and fuel moisture is high enough to keep combustion and spread within predetermined limits. Thus, prescribed fires result in minimal overstory tree mortality and typically combust less than 50 percent of the available fuel (Hurteau and North 2009), producing lower greenhouse gases emissions than might be emitted if the same area were to burn in a high-severity wildfire (Wiedinmyer and Hurteau 2010). Also, a large portion of the emissions associated with prescribed fires is from duff, litter, and dead wood which comprise carbon pools that would otherwise decay quickly over time, releasing carbon to the atmosphere. Hazardous fuels reduction and restoration treatments can help reduce the incidence, severity, and areal extent of wildfires in forests where fire exclusion has resulted in high fuel loadings and tree densities (Agee and Skinner 2005; Stephens et al., 2013). High-severity fires, especially when they occur repeatedly, can affect human health and safety, infrastructure, and ecosystem services, and can cause delayed regeneration or even a transition of forests to non-forest ecosystems in some areas (e.g., Haffey et al., 2018). By reducing the threat of wildfire, the proposed action would create conditions more advantageous for supporting forest health in a changing climate and reducing greenhouse gases emissions over the long term.

Personnel Consulted Preparation of this environmental assessment was done by the following: Michael Muňoz Rocky Mountain District Ranger Russell Owen Fuels Specialist Tanya Murphy Silviculturist/ Sensitive Plant Coordinator Wayne Green Forest Hydrological Technician Mark Bodily Forest Archaeologist Jason Oltrogge Range/Noxious Weed Specialist Allison Torres Soil Scientist

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Rory Gluckert Roadless and Visuals Kraig Lang Recreation Specialist Dave Kemp Forest Wildlife Biologist Kelly Keim Archaeologist Eric Archer Forest Fisheries Biologist Elaina Graham GIS Specialist Jennifer Woods NEPA Coordinator Kelsey Fallis Writer/Editor Fred Godfrey/Erin Fryer Interdisciplinary Team Leader

Federal, State, Tribes, and Local Agencies Contacted Montana Fish Wildlife and Parks Montana Department of Environmental Quality USDA—Natural Resources Conservation Service Lewis and Clark County Commissioners Montana State Historic Preservation Office Northern Region NEPA Coordinator U.S. Fish and Wildlife Service Little Shell Tribe Local Water District Representatives Blackfeet Tribe Lewis and Clark County Commissioners Confederated Salish/Kootenai Montana Department of Natural Resources

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Appendix A: Project Maps

Figure 8: Elk Smith Project Treatment Unit, WUI and IRA Map 2020

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Figure 9: Fire History Map.

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Appendix B: Treatment Units Proposed actions under the Elk Smith Project were developed to address fuel accumulation and continuity in the project area. Treatments therefore consist of hand-slashing small conifers (<7” diameter at breast height) and prescribed burning (broadcast and jackpot). Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events. Unit-specific treatments align with existing conditions on the ground to meet project goals. Prescriptions do not apply to the entire unit, but to those areas which meet our purpose and need, and which are further detailed by treatment descriptions in Table 50 below. Treatments would be staggered across time and space in order to meet project goals. Implementation is expected to begin in fall 2017, continue for five to 10 years and is dependent on resource protection measures discussed in Chapter 2. In general, units which border private lands would be prioritized for implementation.

Table 50: Elk Smith Proposed Treatments. Anticipated Unit Acres Area Purpose Treatments Season

• Slash and burn conifers Spring or Fall. encroaching on natural Targeted openings and aspen stands. season for Maintain natural Use prescribed fire in existing implementation openings as fuel aspen clones to encourage would be 2 372 Petty Creek breaks. suckering. spring. Encourage aspen • suckering. Fell young conifers (<7” diameter at breast height) using power saws over portions of unit

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Anticipated Unit Acres Area Purpose Treatments Season • Broadcast and jackpot burns utilizing hand ignition. • Combined treatments would cover approximately 30-50% of unit area.

• Broadcast burn utilizing helicopter ignition. • Disrupt Burn conifer regeneration and continuity of heavy surface fuel loadings fuels throughout (1,000-10,000 hour fuels). unit (downed • Reduction of 30-50% in conifer trees and regeneration in patches of continuous approximately 20-100 acres. conifer stands); • Reduction of heavy surface Spring or Fall. reduce the future Targeted Weasel fuel loadings in patches of 3 1461 risk of high season for Creek approximately 20-100 acres. intensity and implementation • high severity fires Target amount burned 438- would be fall. in area between 731 acres (treat 30-50%). wilderness Stand replacement patches boundary and will generally be 100 acres or Forest and less. Treatments would occur private land in both densely stocked areas boundaries. and also in some more sparsely stocked areas. Some dense forest areas would be retained.

Disrupt Spring or Fall. • Broadcast burn utilizing continuity of Targeted helicopter ignition. fuels throughout season for unit (downed • Target conifer regeneration implementation and heavy surface fuel Weasel trees and would be fall. 4 1047 loadings (1,000-10,000-hour Creek continuous conifer stands); fuels). reduce the future • Reduction of 30-50% in conifer risk of high regeneration in patches of intensity and approximately 20-100 acres. high severity fires

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Anticipated Unit Acres Area Purpose Treatments Season in area between • Reduction of heavy surface wilderness fuel loadings in patches of boundary and approximately 20-100 acres. Forest and • Target amount burned 314- private land 524 acres (treat 30-50%). boundaries. Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring or Fall. 6 588 Elk Pass Disrupt continuity of helicopter ignition. Targeted

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Anticipated Unit Acres Area Purpose Treatments Season fuels throughout • Target conifer regeneration season for unit (downed and heavy surface fuel implementation trees and loadings (1,000-10,000-hour would be fall. continuous fuels). conifer stands); • Reduction of 30-50% in conifer reduce the future regeneration in patches of risk of high approximately 20-100 acres. intensity and • high severity fires Reduction of heavy surface in area between fuel loadings in patches of wilderness approximately 20-100 acres. boundary and • Target amount burned 176- Forest and 294 acres (treat 30-50%). private land Stand replacement patches boundaries. will generally be 100 acres or Encourage aspen less. Treatments would occur suckering. in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Reduction of 30-50% in conifer Spring or Fall. regeneration in patches of Targeted approximately 20-100 acres. season for • Slash and burn conifers implementation encroaching on natural openings would be and aspen stands. Use prescribed spring. Maintain natural fire in existing aspen clones to openings as fuel encourage suckering. 7 748 Elk Pass breaks. • Encourage aspen Fell young conifers (<7” diameter suckering. at breast height) using power saws over portions of unit. • Felling of young conifers will be excluded from 8 acres on unit #7’s western boundary that is located outside designated Wildland Urban Interface.

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Anticipated Unit Acres Area Purpose Treatments Season • Broadcast and jackpot burns utilizing hand ignition.

• Broadcast burn utilizing helicopter Spring or Fall. Disrupt ignition. Targeted continuity of • Target conifer regeneration and season for fuels throughout heavy surface fuel loadings (1,000- implementation unit (downed 10,000-hour fuels). would be fall. trees and • Reduction of 30-50% in conifer continuous regeneration in patches of conifer stands); approximately 20-100 acres. reduce the future • risk of high Reduction of heavy surface fuel 8 584 Elk Pass intensity and loadings in patches of high severity fires approximately 20-100 acres. in area between • Target amount burned 175-292 wilderness acres (treat 30-50%). Stand boundary and replacement patches will generally Forest and be 100 acres or less. private land • Treatments would occur in both boundaries. densely stocked areas and also in Encourage aspen some more sparsely stocked suckering. areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring or Fall. combination of helicopter and Targeted hand ignition. season for • Reduction of 30-50% in conifer implementation regeneration in patches of would be Maintain natural approximately 20-100 acres. spring. openings as fuel Horse 9 648 breaks. • Reduction of heavy surface Mountain Encourage aspen fuel loadings in patches of suckering. approximately 20-100 acre. • Target amount burned 201-335 acres (treat 30-50%). Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely

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Anticipated Unit Acres Area Purpose Treatments Season stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Reduction of 30-50% in conifer Spring or Fall. regeneration in patches of Targeted approximately 20-100 acres. season for implementation Disrupt • Target conifers encroaching on would be fall. continuity of fuel natural openings and aspen Cyanide 10 669 that would stands. Creek support west-to- • Fell young conifers (<7”diameter east fire spread. at breast height) using power saws over portions of unit. • Broadcast and jackpot burns utilizing hand ignition.

• Broadcast burn utilizing Spring or Fall. combination of helicopter and Targeted hand ignition. season for • Reduction of 30-50% in conifer implementation regeneration in patches of would be approximately 20-100 acres. spring. • Reduction of heavy surface fuel Maintain natural loadings in patches of Horse 11 473 openings as fuel approximately 20-100 acres. Mountain breaks. • Target amount burned 450-750 acres (treat 30-50%). Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

Cyanide Disrupt Spring and Fall. 12 1500 Creek continuity of fuel Spring is the that would preferred

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Anticipated Unit Acres Area Purpose Treatments Season support west-to- season for east fire spread. treatment on portions of the unit bordering private land. Fall is the preferred season for other portions of the unit.

• Broadcast burn utilizing Spring and Fall. combination of helicopter and Spring is the Disrupt hand ignition. preferred continuity of fuel • Reduction of 30-50% in conifer season for Cyanide 14 645 that would regeneration in patches of treatment on Creek support west-to- approximately 20-100 acres. portions of the unit bordering east fire spread. • Reduction of heavy surface fuel private land. loadings in patches of Fall is the approximately 20-100 acres. preferred

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Anticipated Unit Acres Area Purpose Treatments Season • Target amount burned 194-323 season for acres (treat 30-50%). Stand other portions replacement patches will generally of the unit. be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

• Broadcast burn utilizing Spring and Fall. combination of helicopter and Spring is the hand ignition. preferred • Reduction of 30-50% in conifer season for regeneration in patches of treatment on approximately 20-100 acres. portions of the unit bordering Disrupt • Reduction of heavy surface fuel private land. continuity of fuel Cyanide loadings in patches of Fall is the 15 173 that would Creek approximately 20-100 acres. preferred support west-to- • Target amount burned 52-87 acres season for east fire spread. (treat 30-50%). Stand replacement other portions patches will generally be 100 acres of the unit. or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

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Appendix C: Noxious Weed Design Features and Mitigations Northern Region – Forest Service Manual Policy The following policy (FSM 2080, Supplement No.:-1 2000-2001-1, Sec 2081.2-Prevention and Control Measures) outlines Best Management Practices to be used as protection measures to various authorized activities on National Forest System lands in the Northern Region. 2081.2 - Prevention and Control Measures. 1. Roads. a. Required Objectives and Associated Practices. (1) Incorporate weed prevention into road layout, design, and alternative evaluation. Environmental analysis for road construction and reconstruction will include weed risk assessment. (2) Remove the seed source that could be picked up by passing vehicles and limit seed transport in new and reconstruction areas. (a) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area. (b) Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders as determined by the Forest Weed Specialist. Reference Contract Provision C/CT 6.626. (3) Re-establish vegetation on bare ground due to construction and reconstruction activity to minimize weed spread. (a) Revegetate all disturbed soil, except the travel way on surfaced roads, in a manner that optimizes plant establishment for that specific site, unless ongoing disturbance at the site will prevent weed establishment. Use native material where appropriate and available. Use a seed mix that includes fast, early season species to provide quick, dense revegetation. To avoid weed contaminated seed, each lot must be tested by a certified seed laboratory against the all State noxious weed lists and documentation of the seed inspection test provided. (b) Use local seeding guidelines for detailed procedures and appropriate mixes. Use native material where appropriate and available. Revegetation may include planting, seeding, fertilization, and weed-free mulching as indicated by local prescriptions. (c) Monitor and evaluate success of revegetation in relation to project plan. Repeat as indicated by local prescriptions. (4) Minimize the movement of existing and new weed species caused by moving infested gravel and fill material. The borrow pit will not be used if new invaders, defined by the Forest Weed Specialist, are found on site.

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(5) Minimize sources of weed seed in areas not yet revegetated. If straw is used for road stabilization and erosion control, it must be certified weed-free or weed-seed free. (6) Minimize roadside sources of weed seed that could be transported to other areas during maintenance. (a) Look for priority weed species during road maintenance and report back to District Weed Specialist. (b) Do not blade roads or pull ditches where new invaders are found. (c) Maintain desirable roadside vegetation. If desirable vegetation is removed during blading or other ground disturbing activities, area must be revegetated according to section (3) (a), (b), (c) above. (d) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) (e) Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders, as determined by the Forest Weed Specialist. Reference Contract Provision C/CT 6.626. (f) Straw used for road stabilization and erosion control will be certified weed-free or weed- seed-free. (7) Reduce weed establishment in road obliteration/reclamation projects. Revegetate according to section (3) (a), (b), (c) above. b. Recommended Objectives and Associated Practices. (1) Retain shade to suppress weeds. Consider minimizing the removal of trees and other roadside vegetation during construction, reconstruction, and maintenance, particularly on southerly aspects. (2) Consider re-establishing vegetation on bare ground due to construction and reconstruction activity to minimize weed spread. Road maintenance programs should include scheduled fertilization to maintain vigor of competitive vegetation (3-year period suggested). (3) Minimize the movement of existing and new weed species caused by moving infested gravel and fill material. All gravel and borrow sources should be inspected and approved before use and transport. The source will not be used if the weeds present at the pit are not found at the site of intended use. If weeds are present, they must be treated before transport and use. (4) Minimize roadside sources of weed seed that could be transported to other areas. Weed infestations should be inventoried and scheduled for treatment. (5) Ensure that weed prevention and related resource protection are considered in travel management. Consider weed risk and spread factors in travel plan (road closure) decisions. (6) Reduce weed establishment in road obliteration/reclamation projects. Consider treating weeds in road obliteration and reclamation projects before roads are made undriveable. Monitor and retreat as indicated by local analysis and prescription.

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(7) Evaluate and prioritize noxious weeds along existing Forest Service access roads leading to project area and treat as indicated by local analysis and prescriptions, before construction equipment moves into project area. New road construction must be revegetated as described in Weed Prevention measure, see Roads Required Objectives and Associated Practices section (3) (a), (b), (c) above. 2. Recreation, Wilderness, Roadless Areas. a. Required Objectives and Associated Practices. (1) Minimize transport and establishment of weeds on National Forest Service lands. (a) Include environmental analysis for recreation and trail projects in weed risk assessment. (b) Post and enforce statewide weed-free feed orders. (c) Seed only when necessary at backcountry sites to minimize introduction of nonnative species and weeds. Reseed according to Roads (3) (a), (b), (c) above. (2) Reduce weed establishment and spread from activities covered by Recreation Special Use Permits. (a) Include Clause R1-D4, (or subsequent approved direction), in all new and reissued recreation special use permits, authorizations, or other grants involving ground-disturbing activities. Include this provision in existing ground-disturbing authorizations, which are being amended for other reasons. (b) Revegetate bare soil resulting from special use activity according to Roads (3) (a), (b), (c) above. (3) Prevent weed establishment resulting from land and float trail use, construction, reconstruction and maintenance activities. (a) Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders (as determined by the Forest Weed Specialist). b. Recommended Objectives and Associated Practices. (1) Minimize transport and establishment of weeds on National Forest System (NFS) lands. (a) Encourage backcountry pack and saddle stock users to feed only weed-free feed for several days prior to traveling off roads in the Forest. Before entering NFS land, animals should be brushed to remove any weed seed. (b) Stock should be tied and/or held in the backcountry in such a way as to minimize soil disturbance and avoid loss of native/desirable vegetation. (c) Maintain trailheads, boat launches, outfitter and public camps, airstrips, roads leading to trailheads, and other areas of concentrated public use in a weed-free condition. (d) Motorized and/or mechanized (such as mountain bikes) trail users should inspect and clean their vehicles prior to using NFS lands. (2) Consider reducing weed establishment and spread from activities covered by recreation, special use permits. Consider including Clause R1-D4, (or subsequent approved direction), by amending existing ground-disturbing authorizations as indicated by local prescriptions.

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(3) Prevent weed establishment resulting from land and float trail use, construction, reconstruction, and maintenance activities. (a) All trail crews should inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment. (b) Inspect and approve all gravel and borrow sources before use and transport. The source will not be used if the weeds present at the pit are not found at the site of intended use. If weeds are present, they must be treated before transport and use. 3. Cultural Resources. Required Objectives and Associated Practices. Reduce weed establishment and spread at archeological excavations. Revegetate bare soil resulting from cultural resource excavation activity according to the Roads (3) (a), (b), and (c) in section above. 4. Wildlife, Fisheries, and Botany. Required Objectives and Associated Practices. Incorporate weed prevention into wildlife, fisheries, and botany project design. a. Include weed risk assessment in environmental analysis for wildlife, fish and botany projects with ground disturbing actions. b. Revegetate bare soil resulting from wildlife and fish project activity according to the Roads (3) (a), (b), (c) section above. c. Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) d. Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders (as determined by the Forest Weed Specialist). 5. Range. a. Required Objectives and Associated Practices. (1) Ensure weed prevention and control are considered in management of all grazing allotments. (a) Include weed risk assessment in environmental analysis for rangeland projects. (b) When other plans do not already address noxious weeds, include practices and control measures in Annual Operating Plans. (2) Minimize ground disturbance and bare soil. (a) Revegetate, where applicable, bare soil from grazing activities according to the Roads (3) (a), (b), (c) section above. (b) Check areas of concentrated livestock use for weed establishment and treat new infestations. (3) Minimize transport of weed seed into and within allotments.

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(a) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) (b) Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders (as determined by the Forest Weed Specialist). (c) Straw used for road stabilization and erosion control will be certified weed-free or weed- seed-free. b. Recommended Objectives and Associated Practices. (1) Transport of weed seed into and within allotments should be minimized. (a) Avoid driving vehicles through off-road weed infestations. (b) Feed certified weed-free feed to livestock for several days prior to moving them onto the allotment to reduce the introduction of new invaders and spread of existing weed species. Consider using transitional pastures when moving animals from weed infested areas to the National Forest. (Transitional pastures are designated fenced areas that can be logistically and economically maintained.) (c) Consider excluding livestock from sites with new invaders or treat new invaders in these areas before entry by livestock. (2) Maintain healthy desirable vegetation that is resistant to noxious weed establishment. (a) Consider managing forage utilization to maintain the vigor of desirable plant species as described in the Allotment Management Plan. (b) Minimize or exclude grazing on restoration areas until vegetation is well established. 6. Timber. a. Required Objectives and Associated Practices. (1) Ensure that weed prevention is considered in all pre-harvest timber projects. (a) Include weed risk assessment in environmental analysis for timber harvest projects. (b) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) Reference Contract Provision C/CT6.26 (c) Clean all equipment prior to leaving the project site, if operating in areas infested with new invaders (as designated by the Forest Weed Specialist). Reference Contract Provision C/CT6.261 (2) Minimize the creation of sites suitable for weed establishment. Revegetate bare soil as described in the Roads (3) (a), (b), and (c) in sections above. b. Recommended Objectives and Associated Practices. (1) Ensure that weed prevention is considered in all timber projects. (a) Consider treating weeds on roads used by timber sale purchasers. Reference Contract Provision C/CT6.26.

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(b) Treat weeds on landings, skid trails and heli bases that are weed infested before logging activities, where practical. (2) Minimize the creation of sites suitable for weed establishment. Soil disturbance should be minimized to meet harvest project objectives. (3) Consider monitoring for weeds after sale activity and treat weeds as indicated by local prescriptions. (a) Consider trust, stewardship, or other funds to treat soil disturbance or weeds as needed after timber harvest and regeneration activities. (b) Consider monitoring and treating weed infestations at landings and on skid trails after harvest. 7. Minerals. a. Required Objectives and Associated Practices. (1) Minimize weed establishment in mining, oil and gas operations, and reclamation. (a) Include weed risk assessment in environmental analysis for minerals and oil and gas projects. (b) Include weed prevention measures in operation and/or reclamation plans. (c) Retain bonds until reclamation requirements are completed. (d) Revegetate bare soil as described in the Roads (3) (a), (b), (c) section above. (2) Remove seed source and limit seed transport into new or existing mining and oil and gas operations. Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) (3) Minimize weed spread caused by moving infested gravel and fill material. (a) The borrow pit will not be used if new invaders (as defined by the Forest Weed Specialist) are found on the site. (b) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) (c) Do not establish new gravel and fill material sources in areas where new invaders are present on National Forest Service lands. Where widespread weeds occur at new pit sites strip at least the top 8" and stockpile contaminated material. Treat weeds at new pits where widespread weeds are present. b. Recommended Objectives and Associated Practices. (1) Consider removing seed source and limiting seed transport into new or existing mining and oil and gas operations. Where applicable, treat weeds on project access routes. Reference Contract Provision C/CT6.27. (2) Minimize weed spread caused by moving infested gravel and fill material.

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(a) Inspect and approve all gravel and borrow sources before use and transport. The source should not be used if the weeds present at the pit are not found at the site of intended use. If weeds are present, they should be treated before transport and use. (b) Consider maintaining stockpiled material in a weed-free condition. (c) Check the area where pit material is used to ensure that no weed seeds are transported to the use site. 8. Soil and Water. a. Required Objectives and Associated Practices. (1) It is required that integrated weed prevention and management be used in all soil, watershed, and stream restoration projects. (a) Include weed risk assessment in environmental analysis for soil, watershed, and stream restoration projects with ground disturbing actions. (b) Revegetate bare soil resulting from excavation activity according to the Roads (3) (a), (b), (c) section above. (c) Remove all mud, dirt, and plant parts from all off road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) (d) Clean all equipment prior to leaving the project site, if operation in areas infested with new invaders (as designated by the Forest Weed Specialist). (e) Straw used for road stabilization and erosion control will be certified weed-free or weed-seed-free. b. Recommended Objectives and Associated Practices. Integrate weed prevention and management in all soil, watershed, and stream restoration projects by considering treating weeds in road obliteration and reclamation projects before roads are made undriveable. Monitor and retreat as indicated by local prescriptions. 9. Lands and Special Uses. a. Required Objectives and Associated Practices. (1) Incorporate weed prevention provisions in all special use permits, road use permits, and easements. (a) Include weed risk assessment in environmental analysis for land projects with ground disturbing actions. (b) Revegetate bare soil as described in the Roads (3) (a), (b), (c) section above, as a condition of the authorization. (c) Include approved special use provision R1-D4, see FSH 2709.11, chapter 50, (or subsequent approved direction) in all new and reissued special use permits, authorizations, or other grants involving ground disturbing activities. Include this provision in existing ground disturbing authorizations, which are being amended for other reasons. (d) Include noxious weed prevention and control measures as indicated by local prescriptions in new or reissued road permits or easements granted pursuant to FLPMA (P.L.

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94579 0/2/76), FRTA (P.L. 88657 0/3/64) or subsequent authorities. This includes FLPMA Private and Forest Road Permits and Easements; FRTA Private and Forest Road Easements; Cost Share Easements; and Road Use (commercial haul) Permits (7730). (While the approved terms and conditions of certain permits or easements may not provide for modification, the necessary weed prevention and control provisions may be included in written plans, specifications, stipulations and /or operation and maintenance plans attached to and made a part of the authorization.) (e) Clean all equipment prior to leaving the project site, if operating in areas infested with New Invaders (as designated by the Forest Weed Specialist). (2) Minimize weed spread caused by moving infested gravel and fill material. (a) Do not establish new gravel and fill material sources on National Forest Service lands in areas where new invaders are present. Where widespread weeds occur at new pit sites strip at least the top 8" and stockpile contaminated material. Treat weeds at new pits where widespread weeds are present. (b) Remove all mud, dirt, and plant parts from all off-road equipment before moving into project area. Cleaning must occur off National Forest lands. (This does not apply to service vehicles that will stay on the roadway, traveling frequently in and out of the project area.) b. Recommended Objectives and Associated Practices. (1) Incorporate weed prevention provisions in all special use permits, road use permits and easements. (a) Consider including special use provision R1-D4 by amending existing ground disturbing authorizations as indicated by local prescriptions. (b) Consider including noxious weed prevention and control provisions by amending existing ground disturbing authorizations when determined to be necessary by the authorized officer. (While the approved terms and conditions of certain permits or easements may not provide for modification, the necessary weed prevention and control provisions may be included in written plans, specifications, stipulations and/or operation and maintenance plans attached to and made a part of the authorization.) (2) Minimize weed spread caused by moving infested gravel and fill material. All gravel and borrow sources should be inspected and approved before use and transport. The source should not be used if the weeds present at the pit are not found at the site of intended use. If weeds are present, they should be treated before transport and use. 10. Fire. a. Required Objectives and Associated Practices. (1) Increase weed awareness among all fire personnel. Include weed risk factors and weed prevention considerations in the Resource Advisor duties on all Incident Management Teams and Fire Rehabilitation Teams during pre-fire, pre-incident training. (2) Mitigate and reduce weed spread during wild fire activities (a) Initiate establishment of a network of helibases, camps and staging areas that will be maintained in a noxious weed-free condition.

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(b) Minimize weed spread in camps by incorporating weed prevention and containment practices such as mowing, flagging or fencing weed patches, designating weed-free travel routes and washing equipment. (c) Inspect all fire going vehicles regularly to assure that undercarriages and grill works are kept weed seed free. All vehicles sent off Forest for fire assistance will be cleaned before they leave or return to their home. (3) Minimize weed spread during smoke jumper operations. (a) Inspect, remove, and properly dispose of weed seed and plant parts found on clothing and equipment. (b) Coordinate with Weed Specialist(s) to locate and/or treat practice jump areas. (4) Mitigate and reduce weed spread in Air Operations. (a) Initiate establishment of a network of helibases that will be maintained in a noxious weed-free condition. (b) Minimize weed spread at helibases by incorporating weed prevention and containment practices such as mowing, flagging or fencing weed patches, designating weed-free travel routes. (c) Provide weed prevention briefings for helibase staff. (d) Inspect, and if necessary clean, contract fuel and support vehicles before and after each incident when travelling off road or through weed infestations. (e) Inspect and remove weed seed and plant parts from all cargo nets. (5) Mitigate and reduce weed spread from Logistics Operations activities. (a) Look for weed-free camps, staging, drop points and parking areas. (b) Regularly inspect and clean fire vehicles as necessary to assure that undercarriages and grill works are kept weed seed free. (6) Integrate weed prevention and management in all prescribed burning. Mitigate and reduce weed spread during prescribed fire activities. (a) Include weed risk assessment in environmental analysis for prescribed fire projects. (b) Coordinate with local Noxious Weed Management Specialist to utilize helibases that are maintained in a weed-free condition, whenever possible. (c) All crews should inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment. (d) Add weed awareness and prevention education to Fire Effects and Prescribed Fire training. (7) Encourage desirable vegetation during rehabilitation activities. (a) Revegetate only erosion susceptible and high risk areas (as defined in Regional Risk Assessment Factors and Rating protocol) as described in the Roads (3) (a), (b), (c) section above.

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(b) Straw used for road stabilization and erosion control will be certified weed-free or weed-seed-free. b. Recommended Objectives and Associated Practices. (1) Mitigate and reduce weed spread during fire activities. (a) Initiate establishment of a network of helibases, camps, and staging areas on private land that will be maintained in a noxious weed-free condition. (b) Consider checking and treating weeds that establish at cleaning sites after fire incidents, during rehabilitation. (c) Emphasize Minimum Impact Suppression Tactics (M.I.S.T.) to reduce soil and vegetation disturbance. (2) Minimize weed spread during smokejumper operations. Travel through weed infested areas should be avoided or minimized. (3) Mitigate and reduced weed spread from Logistics Operations activities. Traffic should be routed through camps to avoid weed infested areas. (4) Integrate weed prevention and management in all prescribed burning. Mitigate and reduce weed spread during prescribed fire activities. (a) Consider treating high risk areas (as defined in Regional Risk Assessment Factors and Rating protocol) with weed infestations (such as roads, disturbed ground) before burning and check and retreat after burning if necessary. (b) Consider avoiding ignition and burning in high risk areas (as defined in Regional Risk Assessment Factors and Rating protocol) that cannot be treated before or after prescribed fire. (5) Encourage desirable vegetation during rehabilitation activities. (a) Check and treat weeds at cleaning sites and all disturbed staging areas. (b) Treat weeds within the burned area as part of rehabilitation plan to reduce weed spread. (c) Check weed spread resulting from fire and fire suppression activities. (d) Consider applying for restoration funding for treatment of weed infestations within the fire area. 11. Administration. a. Required Objectives and Associated Practices. (1) Ensure all Forest Service employees are aware of and knowledgeable about noxious weeds. (a) Train Line Officers in noxious weed management principles and practices. (b) Each unit will have access to Weed Specialist at the Ranger District or Supervisor's Office.

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(2) Ensure all Forest workers are reducing the chance of spreading noxious weeds. All Forest workers will inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment including Forest Service vehicles. b. Recommended Objectives and Associated Practices. Consider a reward program for weed awareness, reporting, and beating new invaders. Lewis & Clark National Forest Noxious Weed Control Record of Decision, 1994 No chemical treatment with Picloram or Clopyralid (or similar chemical agent in areas where ground water is within 20 feet of the soil surface on coarse textured soils, or 3 feet for medium textured soils, or 2 feet for fine textured soils. No chemical treatment within 100 feet of any known sensitive plant, fish, or animal populations. Areas that are 100 to 500 feet from these populations will be hand treated with Clopyralid (or similar chemicals) No chemical treatment of weeds will be permitted within 10 feet of surface water. Chemical applications within 10 to 100 feet of surface water will be limited to specified quantities depending on the size of the adjacent stream and the site characteristics. The maximum application amount is designed to insure that even under the worst case runoff conditions the worst case possible herbicide concentrations in surface water remain below levels that are injurious to aquatic organisms. All herbicide application workers must be advised explicitly of the hazards of these chemicals and instructed in the proper herbicide application techniques, so as to reduce dose levels below worst-case values assumed in the risk analysis. Appropriate personal protective equipment will be considered in developing project safety and health analysis for Forest Service applicators (See Health and Safety Code Chapter 9-10, FSH 6709.11) Pesticides must be applied under the supervision of a certified pesticide applicator under the laws of the State of Montana. Pesticides must be applied consistent with the instructions on the label. The use of herbicides to control weeds in campgrounds will be restricted to 2,4-D. Public notification and signing will precede the application of herbicide, and the treated area will be closed to public use for one day following treatment. Areas adjacent to water wells, and other selected areas within the campgrounds will be manually treated by hand-grubbing. The location of the inventoried noxious weed infestations scheduled for manual treatment will be compared with the Forest cultural resource site atlas in consultation with the Forest Archaeologist prior to treatment. If it is determined that there is a probability of cultural resource disturbance, then an onsite cultural inventory will be conducted prior to treatment. If cultural resources are found during manual treatment, work will be stopped until the Forest Archaeologist can conduct a cultural resource evaluation. There will be no chemical treatment within 100 feet of any summer home, administrative site, or other human dwelling that is to be occupied within 24 hours of spraying.

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Appendix D: Past, Present and Reasonably Foreseeable Actions

Past Actions Past activities were generated based on actions reported in the Forest Service Activity Tracking System and the fire history layer for the largest cumulative effects analysis area in the project area. Tables are based on actions in the South Fork Willow subunit of the South Fork Sun Beaver Willow Bear Management Unit, and Scapegoat subunit of the Dearborn Elk Creek Bear Management Unit. Several activities in a management sequence have been accomplished on the same acres.

Table 51: Past Actions. Activity 1800- 1940- 1950- 1960- 1970- 1980- 1990- 2000- 2010- Total 1939 1949 1959 1969 1979 1989 1999 2009 2019

Fire / Fuels

Wildfire 8,052 2,519 0 280 0 65,268 27 6,079 18,432 100,657

Wildfire for Resource Benefit 0 0 0 0 0 241 0 0 520 761

Wildlife Habitat Burn 0 0 0 0 0 0 0 80 534 614

Underburn 0 0 0 0 0 0 1,160 5,363 11,148 17,671

Broadcast Burn 0 0 0 0 0 698 0 0 1,090 1,788

Jackpot Burn 0 0 0 0 0 20 0 0 0 20

Fuelbreak 0 0 0 0 0 0 2,104 0 0 2,104

Piling of Fuels 0 0 0 0 0 147 96 0 332 575

Trampling Fuels 0 0 0 0 0 22 20 0 0 42

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Activity 1800- 1940- 1950- 1960- 1970- 1980- 1990- 2000- 2010- Total 1939 1949 1959 1969 1979 1989 1999 2009 2019

Pile Burn 0 0 0 0 0 176 164 10 585 935

Fuels Monitoring – Pre- 0 0 0 0 0 0 0 9 plots 9-plots treatment

Harvest

Hazardous Fuels Thin 0 0 0 0 0 0 0 14 205 219

Pre-commercial Thin 0 0 0 0 0 42 28 0 0 70

Commercial Thin 0 0 0 0 0 1 0 0 77 78

Salvage Cut 0 0 0 0 0 18 0 0 0 18

Single Tree Selection 0 0 0 0 0 13 0 0 0 13

Clearcut (Stand or Patch) 0 0 0 0 0 0 24 0 36 60

Reforestation

Certification of Natural Regen 0 0 0 0 0 0 1,015 24 0 1,039

Certification of Planted 0 0 0 0 0 0 0 1 0 8

Stocking Surveys (no 0 0 0 0 0 0 282 0 0 282 certification recorded)

Insect / Invasives

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Activity 1800- 1940- 1950- 1960- 1970- 1980- 1990- 2000- 2010- Total 1939 1949 1959 1969 1979 1989 1999 2009 2019

Verbenone & MCH Installation 0 0 0 0 0 0 0 30 195 225

Carbaryl Application 0 0 0 0 0 0 0 0 70 70

Infested Tree Removal 0 0 0 0 0 0 0 10 0 10

Pesticide Application 0 0 0 0 0 0 0 92 0 92

BioControl 0 0 0 0 0 0 0 20 0 20

Mechanical/Physical Removal 0 0 0 0 0 0 0 30 0 30

Legislative Direction (Rocky Mountain Heritage Act 2014)

Passage Of Rocky Mountain Front Heritage Act—Wilderness 0 0 0 0 0 0 0 0 67,000 67,000 Additions

Designated Wilderness Addition - Patricks Basin (South 0 0 0 0 0 0 0 0 4,797 4,797 Fork Willow Bear Management Unit Subunit)

Designated Wilderness Addition - Silver King/Falls 0 0 0 0 0 0 0 0 0 0 Creek (Scapegoat Bear Management Unit Subunit)

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Activity 1800- 1940- 1950- 1960- 1970- 1980- 1990- 2000- 2010- Total 1939 1949 1959 1969 1979 1989 1999 2009 2019

Deep Creek-Elk Creek Conservation Management 0 0 0 0 0 0 0 0 0 41,969 Area (South Fork Willow Bear Management Unit Subunit) Deep Creek-Elk Creek Conservation Management 0 0 0 0 0 0 0 0 0 22,395 Area (Scapegoat Bear Management Unit Subunit)

Present Actions • Helena-Lewis and Clark National Forest, Forest Plan Revision. • Birch Creek South Record of Decision: Designates roads, trails, and airfields to be managed as system routes under the Forest Transportation System. The October 2007 decision covered 262,108 acres. • Whitebark pine plus-trees: The Forest has identified and protected six whitebark pine trees with some level of resistance to white pine blister rust along the Crown Mountain trail. Cones, pollen, and scion have been and will be collected from one or all of these trees. Verbenone pouches (mountain pine beetle anti-aggregation pheromone) have annually been installed on the trees since 2006 and will continue in the near future. Note: There are no present activities for Fuels or Aviation.

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Reasonably Foreseeable Actions

Table 52: Reasonably Foreseeable Actions Activity Number Acres

Broadcast Burning* 379

Burn Plans* 9 each (may be combined)

Burning of Piled Material* 173.7

Certification of Natural Regeneration without 36 Site Prep*

Fireline Construction* 2.5 miles

Initiate Natural Regeneration* 19

Invasives—Pesticide Application* 187.2

Jackpot Burning—Scattered concentrations* 203

Post Treatment Exam Fuels Management* 713

Pre-commercial Thin* 18

Rearrangement of Fuels* 111

Re-vegetation monitoring for 277 germination/survival of seeds and/or plants*

Scarify and Seed Landings* 4

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Activity Number Acres

Site Preparation for Seeding—Manual* 2

Soil Productivity Monitoring* 131

Stocking Survey* 108

Thinning for Hazardous Fuels Reduction* 15

Yarding—Removal of Fuels by Carrying or 113 Dragging*

Post-Fuels Treatment Monitoring* 9 plots with periodic monitoring

Preparation of Fire Management Action Plan for 4,797 Patricks Basin Addition to the Bob Marshall Wilderness—South Fork Willow Bear Management Unit Subunit

Preparation of Fire Management Action Plan 5,241 Silver King/Falls Creek Addition to the Scapegoat Wilderness—Scapegoat Bear Management Unit Subunit. *Activities included in Benchmark III Fuels Reduction Project Decision Notice, 2013 **Rocky Mountain Front Heritage Act, 2014

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Appendix E: Forest Plan Consistency Table

Forest Plan Consistency

Table 53: Forest Plan Consistency. *Note: The following table does not contain a full list of the Lewis and Clark National Forest Plan Standards and Guideline, rather it shows only those with a Direct, Indirect or Cumulative effect due to project actions. For a complete Forest Plan Consistency table see the project record. **Grizzly Bear Amendment Notes: The Grizzly Bear Amendment replaced and/or removed some of the existing standards. That has been noted where applicable. The Grizzly Bear Amendment standards and guidelines are applicable to zones established as part of this Amendment (Primary Conservation Area and Zones 1, 2, and 3). Only NCDE-STD-WL-01, NCDE-STD-WL-02, NCDE-GDL-WL-01, NCDE-GDL-WL-02, and NCDE-STD-SFP-01 pertain to Zone 2 or 3 or both. See the map here in tab "Management Area Maps"

Lewis and Clark National Forest

Forest Plan Standard Compliance with Management Direction

Management Standard A-6 Special Interest Areas These areas have been considered as part of the Heritage Inventory and manage, but do not publicly identify special interest areas which need protection. Specialist report and proposed action will not have an effect, These areas include areas with rare or unusual vegetation and other special sites. therefore we are in compliance with the Forest Plan standard. Management Standard A-7 Cultural Resource Management Pre-implementation survey completed in compliance with (1) Identification of Cultural Resources -- A cultural survey, will be conducted to identify and Forest Plan, applicable Programmatic Agreement, and record cultural properties within the area of environmental impact. Sites, building, districts and National Historic Preservation Act Section 106. Post-

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objects which may qualify for the National Register of Historic Places will be nominated in prescribed burn surveys will be needed to comply with the accordance with established procedures. Programmatic Agreement. National Register evaluations unformalized at this stage. (2) Protection of Cultural Resources - (a) Evaluate, according to criteria which determine eligibility for the National Register of Historic Appropriate pre-implementation site evaluations and Places, and in consultation with the SHPO, any identified archaeological or historical site, building, consultation have been done. structure, or district. (b) Consult with the SHPO and together determine the project’s effect on significant cultural Impacts to known, potentially significant sites will be avoided. properties. If no effect is identified, the Forest proceeds with the project. If an effect is identified, The SHPO concurred with our plans. the Forest and the SHPO determine whether the effect will be adverse or not. No further site visits are needed in order to arrange (c) A schedule will be developed for visiting known sites to determine what protection, if any, is avoidance. Post- implementation inventories and monitoring necessary. are planned. (3) Management of Cultural Resources-Cultural resources are not renewable. Therefore, the Forest will make every effort to design projects without adversely affecting cultural resources. Statement applies to this project. Normally, slight project modification will avoid any potentially adverse effects. Management Standard A-8 Visual Resource Management (1) Landscape management principles will be applied to all activities on the Forest (FSM 2380). This standard will be met by following the Visual National Forest Landscape Management, Volume 2, Chapter I, The Visual Management System. Management System (FSM 2380) (2) A VQO is stated for each management area. If the VQO conflicts with the management prescription, the prescription will prevail, unless the area is within the seen areas of the roads or This standard will be met by applying this standard to the trails identified on Forest Plan maps. In these seen areas visual resource management principles treatment prescriptions. will be emphasized and visual impacts mitigated to meet the VQO. (3) The Forest adjacent to or as seen from all or segments of the following roads and trails, as This standard will be met by applying this standard to the shown on Forest Plan maps, will be managed for its visual resource. Only roads and trails that may treatment prescriptions. be affected by development are identified.

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Wildlife and Fish Management Standard C-1 Wildlife Coordination and Habitat Management Meetings with Montana Fish, Wildlife and Parks biologist Brent Lonner have occurred several times regarding the Elk Smith Project. Conversations with MFWP biologists have occurred informally throughout this process. MFWP has been (1) Strengthen wildlife habitat coordination with all Forest uses by improving cooperation with the a regular participant in the Sun River Working Group, whose MDFW&P. Identity wildlife habitat values early in the planning of other resource projects. Protect members have been updated frequently regarding project those values through involvement of appropriate MDFW&P personnel during all stages of project planning. planning and implementation. Refer to project file section B: items identifying public and agency coordination, project file C2:scoping mailing list; project file section D: correspondence and public interaction; section E: notification of EArelease and revised mailing lists. (2) Utilize the general concepts presented in Agriculture Handbook No. 533, Wildlife Habitats in Wildlife habitat parameters are described for each species Managed forests. This handbook provides management strategies for various wildlife habitat analyzed and are found in the individual species analyses. situations. The handbook's specific habitat parameters may have to be adjusted for the Lewis and Specific wildlife species, habitat, and management Clark National Forest. When more site specific management recommendations are available information reflecting the best available and most current through the Forest Service or MDFW&P those recommendations will be followed. science is referenced throughout the wildlife analysis. (3) An annual meeting will be held at the Forest Supervisor and Regional Supervisor level to discuss programs affecting wildlife resources and habitats, as specified in the MOU dated The annual meeting is not applicable to the project level. September 1978. In addition, annual meetings should be held at the District level with appropriate Communications regarding this project were conducted. MDW&P personnel to discuss specific projects and issues of mutual interest or concern. A big game cover analysis was completed. Analysis results are (5) Require a big-game cover analysis of projects involving significant vegetative removal to ensure found in Appendix A Section 5. The proposed action results in that effective hiding cover is maintained. The cover analysis should be done on a drainage or elk 31.1 to 59.9 percent hiding cover in the affected watersheds. herd unit basis. Drainages or elk herd units containing identified summer/ fall range will be This meets the Forest Plan standard of 30 percent effective maintained at 30% or greater for effective hiding cover. hiding cover.

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The proposed action includes Project Design Features or (11) Data gathered through The interagency Wildlife Monitoring/ Evaluation Program is the basis resource protection measures (such as helicopter flight paths for grizzly bear, elk, mountain goat, mule deer, bighorn sheep, and raptors management staying ½ mile from active cliff nesting raptor nests) that were guidelines. These guidelines will be used in the management of land-use activities occurring within developed as part of the Monitoring/Evaluation Program. In habitat of these species on the Rocky Mountain Front. addition, other restrictions and the travel plan incorporated the recommendations. Management Standard C-2 Threatened and Endangered Species There are no listed threatened or endangered species on the Helena - Lewis and Clark National Forest. Three plants listed on the US Fish and Wildlife Service Endangered Species List as Threatened and occurring in Montana are water howellia (Howellia aquatilis), Spalding’s catchfly (Silene spaldingii), and Ute ladies’-tresses (Spiranthes diluvialis) (USDI Fish and Wildlife Service 2016a; USDI Fish and Wildlife Service 2016b). (1) Comply with the Endangered species Act, other related laws, executive orders, Forest Service Species occurrences and suitable habitat are only known on Manual direction, implementing regulations of the National Forest Management Act, legal Forests west of the Continental Divide for water howellia and decisions that have a bearing on the Forest Service T7E species program, consultation with the US Spalding’s catchfly and in the Missouri, Jefferson, Fish and Wildlife Service, recovery plans, and special studies. Cooperate with future interagency Beaverhead, Ruby, and Madison River drainages for Ute recovery efforts. ladies’-tresses. No analysis was conducted for the threatened species. Wildlife: The project is consistent with the Endangered Species Act. This document is the biological evaluation for Threatened, Endangered and Proposed Species. Consultation, as required under the Act and implementing regulations, will be conducted prior to a decision. Fisheries: There are no threatened or endangered aquatic (2) Conduct a biological evaluation of each program or activity which is Forest Service funded, species in the project area. There were biological evaluations authorized, or carried out on occupied T&E species and sensitive species habitat. This evaluation performed for the sensitive fish and amphibian species with occurrences or potential habitats within the project area.

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will determine whether or not informal or formal consultation with the US Fish and Wildlife Veg: This analysis constitutes the biological evaluation for Service on T&E species is appropriate. proposed activities within the project area. Wildlife: The wildlife report is the Biological Evaluation. A Biological Assessment will be prepared and submitted to USDA Fish and Wildlife Service prior to a decision. Plants:: This analysis constitutes the biological evaluation for proposed activities within the project area. Direct, indirect, (3)Identify and evaluate cumulative effects as part of each biological evaluation. This evaluation and cumulative effects of the proposed activities on sensitive may result in specific management recommendations in addition to those identified above. plants are discussed in this analysis. Wildlfie: Cumulative effects are identified and evaluated in the wildlife report and biological evaluation. Entire District, including project area stratified into MS-1 and MS-3 habitat; human activity managed according to IGBC Guidelines for strata. Approximately 18 percent of MS-1 habitat is to be treated with prescribed fire that may enhance (5) Participate in the interagency Wildlife Monitoring/Evaluation Program for the Rocky Mountain some forage species. If burning in MS-1 spring habitat occurs, Front. The members chartered this program in 1980 to promote better coordination of wildlife it will be limited in space, time, and duration. All project studies along the Front. Data gathered through this program is the basis of the grizzly bear activities, except possibly some prescribed burning, to occur management guidelines. The Interagency Grizzly Bear Guidelines will be used to coordinate between July 1 and March 31 to minimize disturbance of multiple-use activities with the biological requirements of endangered and threatened species. grizzly bears in spring habitat, per recommendations in the Wildlife Guidelines, Grizzly Bear Guidelines and elsewhere. See grizzly bear analysis in EA. Removed (7) The occupied grizzly bear habitat (all of the Rocky Mountain Division) has been stratified As stated in the effects section for grizzly bear, we comply according to “The guidelines For Management Involving Grizzly Bears in the Greater Yellowstone with management direction on the Management Situation 1 Ecosystem” (USFS, 1979). Forest management on occupied grizzly bear habitat will comply with lands in the project. this management direction. Replaced with NCDE-STD-WL-01: Appendix K deleted

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All personnel, including contractors, associated with this (8) Manage problem grizzly bears in accordance with the “Guidelines for Determining Grizzly Bear project are required to adhere to the Food Storage Special Nuisance Status for Controlling Nuisance Grizzly Bears in the Northern Continental Divide and Order LC-10-D1-10 to prevent or minimize bear-human Cabinet-Yaak Grizzly Bear Ecosystems.” conflicts. Wolves were removed from protection under the Endangered Species Act by Congressional action in May 2011. Consultation on impacts of the project to wolves occurred (9)Manage gray wolf primarily by maintaining a suitable prey base and important habitat prior to that, with the US Fish and Wildlife Service concurring components such as rendezvous sites. Management for big game species will follow the on a determination that the project "May affect, is not likely management guidelines established by the interagency Wildlife Monitoring/Evaluation Program. to adversely affect" gray wolves. See the analysis in the EA and BA addendum for specific information regarding maintenance of prey populations and habitat. See wolf analysis in EA. Ongoing communication exists with (10) Compile all reports of wolf sightings, sign, or other activity in order to maintain knowledge of MFWP, which manages and monitors wolf population since present distribution and population levels. When available, define management situation final de-listing in May 2011, regarding wolf numbers, location, stratification based on current habitat suitability, population, and distribution trends. den sites, and wolf management activities. (12) Maintain bald eagle and Peregrine falcon essential habitat (currently unoccupied). Suitable habitat exists outside identified essential habitat. If active nest sites or other important habitat The project does not alter bald eagle or peregrine falcon components are discovered, a management standard for such area will be developed based on habitat as shown in the analysis. information available in the literature or from knowledgeable persons. This report analyzes potential effects of proposed activities on designated sensitive plant species. Whitebark pine seedlings and saplings may be removed during project (13) There are sensitive plants, as listed by the Regional Forester, of limited distribution that occur implementation, but the loss would not result in a trend on the Forest and may require special consideration in land management to maintain diversity toward federal listing or reduced population viability. Stand- within the species gene pool. Assessments of suitable habitats for sensitive plants will be replacement prescribed fire would create competition- free, conducted before surface disturbing activities are permitted. favorable nutcracker cone caching sites which is beneficial for whitebark. The project would have no impact upon the remaining 24 designated sensitive plant species for the Lewis

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and Clark side of the Helena – Lewis and Clark National Forest. Management Standard C-3 Fish Habitat The forest soil scientist was consulted on soil modeling parameters for WEPP:Road model runs. The forest hydrologist was consulted with on numerous effects analysis, (1) Increase the coordination of the fisheries resource with other forest activities and programs BMP and mitigation questions. The range program manager including timber harvest, range management, and oil and gas exploration or development. was consulted on weeds and herbicide use. These specialists and line officers were also briefed on fisheries and aquatic wildlife needs and concerns. Fishery, mussel and amphibian biologists from the Montana Department of Fish, Wildlife and Parks Fisheries were (2) Increase coordination with the Montana Department of Fish, Wildlife, and Parks to adequately consulted with about species status in the project area, address issues and concerns related to the Forest’s overall annual program of work. project effects and desired mitigation. Population survey efforts were jointly conducted with biologists from Montana Department of Fish, Wildlife, and Parks. The project would utilize Water Quality BMPs For Montana (4) Emphasize the maintenance or enhancement of habitat supporting populations of Upper Forests and the Montana Streamside Management Zone Laws Missouri River (blackspotted) cutthroat trout. and Rules. Management Standard C-4 Wildlife Trees Wildlife trees include snags (standing dead trees) and down trees. Snags may be 'hard' or 'Soft.' Hard snags are sound wood that may or may not have commercial value. If an axe sinks into the wood with difficulty, the snag is hard. Soft snags are in advances stages of decay and usually have no commercial value. (1) Following are the recommended sizes and numbers of hard snags by timber type. The (1-11) Per the Forest Vegetation Report, as described under management level percentage relates to the optimum number of hard snags for the various black- backed woodpecker and three-toed woodpecker

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timber types, based on cavity nesting species present, territory sizes, and other habitat above, the project area averages 22 snags per acre. Although parameters. The primary excavator (woodpecker) species most representative of the type is also some would be removed with treatments the project area listed. will continue to exceed the 72 to 158 snags per 100 acres required by the plan. Douglas fir ponderosa pine - 70% Management Level Hairy woodpecker 10 inch dbh minimum 158 snags11 00 acres Riparian/Aspen -- 100% Management Level Downy woodpecker 6 inch dbh minimum This project includes Douglas-fir, riparian/aspen and 3CO snagsll00 acres lodgepole pine. Current values are 2200 snags per acres. Lodgepole Pine -- 40% Management Level Reductions due to burning will occur, however snags standards would continue to be met. Northern three-toed woodpecker 10 inch dbh minimum Subalpine Fir whitebark Pine -60% Mgmt Level Mixed Conifer -- 63% Management Level Black backed three-toed woodpecker 10 inch dbh minimum 135 snag/l 00 acres The project would not directly remove snags through cutting. (2) Keep all soft snags, which are not a safety or fire hazard. All soft snags that are not a safety hazard or consumed by burning will be maintained. (3) Locate wildlife trees adjacent to natural openings, near water, in valley bottoms, or in aspen The project will not directly remove snags through cutting groves, if possible. It is in these areas that wildlife threes are utilized most often. and wildlife trees will not be identified.

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The project will not directly remove snags through cutting (4) Cluster wildlife trees in important habitat, rather than spacing them uniformly in an area. and wildlife trees will not be identified. (5) Retain larger diameter wildlife trees wherever possible, because they provide for more species The project will not directly remove snags through cutting than do smaller trees, and wildlife trees will not be identified. (6) Concentrate wildlife trees in areas away from roads. To limit firewood cutting, develop and The project will not directly remove snags through cutting implement educational programs to inform the public about the importance of snags to wildlife. and wildlife trees will not be identified. Use area closures, road closures, or sign essential snags and ‘Wildlife Trees’ where necessary. (9) Snags could be provided where there are too few, by killing diseased, mistletoe infested, and There is no lack of snags in the project area (See Forest cull trees. Vegetation Report). Protection of large snags within burn units will be considered (10) Where feasible, consider protecting snags when using prescribed fire by clearing brush or during implementation. Wildelife: Protecting snags in the applying retardant. proposed units is not feasible or necessary. It is recommended that burning occur under conditions that allow large down wood (greater than 8 inches in diameter) to be retained or implement measures that would protect (11) Keep down trees for wildlife feeding sites. To reduce fire hazard, keep logs instead of designated logs during burning. Wildlife: There is an excess of windrows, slash piles, and root wads. It is preferable to have two logs with bark per acres and downed wood providing fuel in the project area. The project some deteriorated logs. is designed to remove some downed wood. However, snags from the 1988 Canyon Creek fire would continue to fall and add to downed wood. Management Standard C-5 Management Indicator Species Monitoring of management indicator species (MIS) as per the monitoring plan is summarized in the “Lewis and Clark Monitor population levels of all Management Indicator Species on the Forest and determine the National Forest Evaluation and Compliance with National relationship to habitat trends. Population levels will be monitored and evaluated as described in Forest Management Act Requirements to Provide for Viability the monitoring plan. and Diversity of Animal Communities” (USDA Forest Service 2011). Refer to the analysis and to analysis of selected species

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in the Benchmark III Fuels Reduction Environmental Assessment. Analyses for these species determined that population viability for all MIS will be maintained during and after implementation of the Elk Smith Project. Wildlife Category Indicator Species Endangered and Threatened : gray wolf, bald eagle, peregrine falcon, grizzly bear. elk, mule deer, whitetail deer, black bear, bighorn sheep, Commonly Hunted and Fished : mountain goat, mountain lion, blue grouse, cutthroat trout, brook trout, rainbow trout. Commonly Trapped: beaver, bobcat Special Interest: wolverine, lynx, golden eagle, prairie falcon. Special Habitat Needs: Old Growth Forest: Goshawk Tree Cavity-Conifer: Northern 3-toed woodpecker Range Management Standard D-1 Range Improvements Any reconstruction of existing range improvement(s) (1) Cooperate with permittees in constructing range improvements. Use one of the following removed or damaged due to prescribed burning operations approaches to arrange the cooperative work. would occur under the appropriate agreement. Any reconstruction of existing range improvement(s) (a) Modify the grazing permit. removed or damaged due to prescribed burning operations would occur under the appropriate agreement. Any reconstruction of existing range improvement(s) (b) Use collection agreements. removed or damaged due to prescribed burning operations would occur under the appropriate agreement.

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Any reconstruction of existing range improvement(s) (c) Use appropriate procurement procedures when the Forest Service pays the permittee to do all removed or damaged due to prescribed burning operations the work. would occur under the appropriate agreement. (2) Share range improvement cost .to increase or maintain the grazing level. The objective will be a 50-50 share between the FS and the permittee. Maintenance of these improvements is usually a Any reconstruction of existing range improvement(s) permittee responsibility. Cost for range improvements to livestock distribution in response to removed or damaged due to prescribed burning operations other resource values is the responsibility of the FS. Maintenance of these improvements is would occur under the appropriate agreement. usually a FS responsibility. The proposed action under the Elk Smith Fuels Reduction Environmental Assessment does not include range forage (3) Use prescribed fire for control of sagebrush and tree encroachment and other vegetative improvement treatments. However, an indirect benefit of the manipulation as needed to meet outputs. fuels reduction treatments may be a reduction of tree and sagebrush encroachment. Management Standard D-2 Noxious Weeds and Other Pests The Rocky Mountain District is a member of the Rocky (1) Develop a public information and education program to emphasize practices that prevent Mountain Weed Roundtable which has an active public resource degradation and spread of noxious weeds. education component. The Forest Service supports education efforts by the Montana Weed Control Association. (2) Emphasize preventing noxious weeds by reseeding, with desirable plant species, mineral soil See Project Design Features exposed by Forest activities. (3) Evaluate alternatives, as outlined in FSM 2155.3, to determine effective environmentally Integrated weed management is practiced utilizing the best acceptable practices to control noxious weeds and other pests. combination of chemical, biological and mechanical control. (4) Identify areas where noxious weed and/or pest control is needed. Special attention should be See. Rocky Mountain Ranger District Invasive Plant paid to: streams, bogs, and associated riparian habitat; upland game bird nesting habitat; and any Management Strategy 11/17/2015 other sensitive non-target animal or habitat which may be adversely affected by spraying.

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(5) Weed treatment personnel evaluate each herbicide application on what is the best treatment method to utilize. Evaluations consider things such as pest species and habitat sensitivity as well as risk of non- target damage. The District (5) Annually review spray projects, in environmentally sensitive areas for opportunities to replace also works with Forest Service entomologists on selecting and spraying with other IPM methods. Cooperate and support basic research for biological control of utilizing the best bio-control agents and making sure they are noxious weeds and other pests. utilized in the appropriate habitat. (6) This is accomplished through participation in the Rocky Mountain Front Weed Roundtable. Additionally the District organizes and participates in numerous spray days annually. Management Standard D-3 Riparian Area, Soil, and Water Protection in Range Management Best management practices are considered in allotment (2) Best management practices will be used to minimize livestock damage to soils, streamsides, management plans. Grazing adjustments are not applicable and other fragile areas. to the Elk Smith Fuels Reduction Project. (5) Adjust allotment management plans to consider landtype limitations as given in the Lewis and Allotment management plans will not be adjusted under this Clark National Forest Soi1 Resource Inventory (Holdorf,1981). project. Timber Management Standard E-1 Timber Management Coordination and Information (1) Develop and implement ongoing public information and education programs to foster an This is an on-going Forest-wide effort. Timber harvest and informed public. Provide public information, when requested or needed, to explain harvesting, other timber uses are not proposed in the Elk Smith Project. timber use, reforestation, or other timber management activities. (2) Increase public information and education regarding general rules and regulations on firewood This information is included in all Forest Service issued cutting, including explanations of the reasons for these regulations and the importance of snags firewood permits. Firewood cutting is not proposed in the Elk and other habitat components to wildlife species. Smith Project. Management Standard E-2

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Firewood Administration and Utilization Firewood cutting would continue on the Rocky Mountain (1) Issue permits for personal use firewood cutting, as directed by National policy. Standard rates, Ranger District under personal use permits following set annually by the Regional Office, will apply to all firewood cutting. Northern Region direction. Standard does not apply. Firewood removal is not proposed (4) When roads approach diverse complexes of T&E habitat components, they should not be in the Elk Smith Project. Firewood cutting activities on the opened to firewood cutting during any season. For roads which enter areas of low vertical relief Rocky Mountain Ranger District would occur under the and limited component diversity, access for firewood cutting is compatible with grizzly bear use as District's current program. long as the access is prohibited during important use seasons. Firewood cutting should be limited In the NCDE primary conservation area, this is modified by to 2 to 3 years after timber harvest. Then the road should be permanently closed to the public. NCDE-GDL-VEG-01 through 05 as well as by NCDE-STD-AR-02 and 04. Management Standard E-3 Reforestation Stocky surveys would occur in stands (~523 acres in Management Area O with a commercial land suitability (2) The first-year stand examination will certify that the ground conditions necessary for natural classification) within the suitable timber base the first, third, regeneration are present and that adequate restocking should occur. and fifth year following treatment. Walk-through surveys would occur on a sample of non-suitable lands to determine natural regeneration outcome following treatment. (3) Intermediate stand examinations will be scheduled at the appropriate intervals for the Regeneration condition would be evaluated based on the individual sites to monitor seedling establishment. If the regeneration process is not working and silvicultural prescription designed to meet management will not occur under existing site conditions, evaluate the stand to determine if additional objectives. treatment is needed to bring the regeneration to a satisfactory level. Natural regeneration certification of suitable timber land would be based on the silvicultural prescriptions designed to (4) The 5th-year stand examination will: meet mangement objectives. Certification may occur based on third year survey results.

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(a) Certify the stand regeneration is completed by meeting the following criteria: *The required natural regeneration has survived at least three full growing seasons, is in a healthy condition, and is at least 6 inches A192 -Planted stock has survived two growing seasons and is in a healthy condition (healthy leaders and buds). Natural regeneration certification of suitable timber land would be based on the silvicultural prescriptions designed to -At least 90% of the reforestable land area in the stand meets the prescribed stocking meet mangement objectives. Certification may occur based level. on third year survey results. -The District Silviculturist has determined the stand is satisfactorily stocked. (b) Identify those stands not meeting all certified standards, but progressing satisfactorily toward certification. c) Schedule for retreatment those stands not progressing to certification.

Management Standard E-4 Timber Harvest (1) Require silvicultural examinations and prescriptions before any silvicultural treatment. Silvicultural prescriptions would be written and approved Exceptions include cutting of trees that block vision along roads, cutting hazard trees, clearing prior to implementation of the Elk Smith Decision. Treatment right-of-way, clearing for mineral development, minor and incidental amounts of wood products, specifications would follow the selected alternative as and cutting personal firewood. described in the Decision Notice. Soil and Water Management Standard F-1 Erosion Control Fisheries: Appendix to Hydrology report lists appropriate soil and water BMPs that were analyzed and would be applied for (1) Utilize adequate soil and water conservation practices to protect soil productivity and to this project. Noxious weed BMPs (FSM 2000 Supplement R-1 control nonpoint water pollution from project activities, using as a minimum, practices specified in 2000-2001-1) and herbicide control incorporated into affects any State developed ‘BMPs’ analysis as well. Watershed: Project is consistent with Forest Plan Standards as best management practices will be implemented to include erosion control and protect water

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resources. Soils: Design features such as burning in cool, moist conditions; avoiding active ignition on slopes over 50%; limiting the amount of exposed mineral soil; and deferring grazing will be adequate to protect soil productivity and control erosion and sediment delivery. (2) Develop and update watershed management and erosion control handbooks and Existing handbooks and supplements were referenced for this supplements. project. The watershed scale is inappropriate for assessing soil-related (3) Watershed improvement projects will be identified, prioritized, and developed on a watershed impacts; the soils impacts are limited to the treatment unit basis. area. Management Standard F-2 Data Collection Soil data included: Soil survey data needed to assess soil parent material, erosion hazard, and other important qualities. FACTs past activity data was used to assess where (1) Collect soil and water data needed to validate assumptions important in both long-range and areas of historical soil disturbance could be anticipated. A project planning. Include a statement of why the data is needed, and what type of data is needed, field visit was conducted to assess current condition and as part f a data collection plan. estimate coarse woody debris. Grazing allotment data was also used to anticipate areas which may experience interacting effects with burn. Burn impacts were extrapolated from other studies, fuel (2) Decide how to get the needed data. Consider extrapolating from other studies, working with modeling, NAIP imagery, and past prescribed burns. Existing existing projects of other agencies, and the capabilities of the Forest Service. soil disturbance was evaluated with the Soil Disturbance Monitoring Protocol. There will a need to assess impacts with monitoring using the Soil Disturbance Monitoring Protocol the season following (3) Determine the data needed to predict and monitor soil and water impacts from the following burn treatments; this monitoring will collect information on activities. soil burn severity as percentage of the burn area to better assess prescribed burn impacts in the future.

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There will a need to assess impacts with monitoring using the Soil Disturbance Monitoring Protocol the season following burn treatments; this monitoring will collect information on (d) Grazing. soil soil compaction, erosion, and productivity impacts related to grazing as percentage of the burn area to better assess grazing impacts and their potential interaction with fire (4) Display the results of the data and analysis in appropriate reports. Use this information to This information will be compiled in the annual soil Forest improve predictions of watershed impacts and to validate monitoring requirements. Plan Monitoring report. Management Standard F-3 Soil, Water and Air Protection Fisheries: Appendix to Hydrology report lists appropriate soil and water BMPs to be applied for this project and BMPs are incorporated into affects analysis. Noxious weed BMPs as (1) Require application of BMPs to project activities to ensure meeting or exceeding State water found in FSM 2000, Sup. R-1 2000-2001-1 also analyzed and quality standards. would be applied. Watershed: Project is consistent with Forest Plan Standards as best management practices will be implemented to include erosion control and protect water resources. Fisheries: Appendix to Hydrology report lists appropriate soil and water BMPs to be applied for this project and BMPs are incorporated into affects analysis. Noxious weed BMPs as (2) Develop additional BMPs during the environmental analysis process and incorporate them found in FSM 2000, Sup. R-1 2000-2001-1 also analyzed and into all land use and project plans as a principal mechanism for controlling nonpoint pollution would be applied. sources and meeting soil and water quality or other resource goals. Watershed: Project is consistent with Forest Plan Standards as best management practices will be implemented to include erosion control and protect water resources. (3) Meet State water quality standards as required by the Clean Water Act, and as detailed in the Fisheries: Analysis of the proposed project has indicated MOU to Implement the 208 Program on National Forests in the State of Montana. Coordinate with there is a low probability of detectable increases to runoff

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the State of Montana concerning stream channels as agreed to in the MOU with Montana Fish and and sediment delivery to water ways. Coordination with Game Commission. Montana Fish, Wildlife, and Parks has been ongoing since project inception. This would continue. Watershed: Project is consistent with Forest Plan Standards as the Memorandum of Understanding to Implement the 208 Program on National Forests in the State of Montana will be implemented to include erosion control to protect soil, water and air resources. (4) Require a watershed analysis of projects involving significant vegetative removal to ensure that Fisheries: Analysis of the proposed project has indicated the project, considered with other activities, will not increase water yields or sediment beyond there is a low probability of detectable increases to runoff acceptable limits. The analysis should identify any opportunities for mitigating adverse effects on and sediment delivery to water ways. Watershed: This report water related beneficial uses, including capital investments for fish habitat or watershed includes analysis of the affects of this project on water or improvement. sediment yield to project area streams. Fisheries: Analysis of the proposed project has indicated (5) Conduct an environmental analysis for all management actions planned for floodplains, there is a low probability of detectable increases to runoff wetlands, riparian areas, or bodies of water prior to implementation. Adopt the necessary and sediment delivery to water ways. Mitigation measures mitigation measure to minimize risk of flood loss, to restore and preserve floodplain values, and to have been proposed and would further reduce impacts from protect wetlands. the proposed action. Watershed: This report analyzes the affects of this project to riparian, floodplain and wetlands. Best management practices specific to the proposed action (10) I n accordance with NFMA, RPA, and Multiple Use-Sustained Yield Act, all management are incorporated into Resource Protection Measures. Analysis activities will be planned to sustain site productivity. During project analysis, ground disturbing shows that Northern Region Soil Quality Standards would be activities will be reviewed and needed mitigating actions prescribed. met (11) Require prompt revegetation of disturbed areas, especially cut and fill slopes, to control surface erosion. To stabilize disturbed areas, seed with grasses, forbs, and deep-rooted native Ground cover will be retained and burn severity will be shrubs, where natural establishment of native cover is not expected within two years. Ideally the limited to less than 15% detrimental disturbance; this should seedbed should be firm with a roughened surface. The slope must be stable, usually less than 2:l. eliminate the need for revegetation, decompaction, or other Steeper slopes can be benched or terraced. Compacted soils should be ripped from eight to actions to reduce erosion or restore soil productivity. twelve inches.

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(12) Select seeding mixtures based on site conditions, soil protection, ease of establishment and Post-burn revegetation should not be needed; native species seed availability. Fertilizer is usually necessary. Native species should be used when available. and mulching will be applied only as appropriate to site Mulching will be used only on very critical areas where wind is not a problem or the mulching can conditions and will follow Forest Service handbook direction. be protected. Soils Resource Protection Measures include vegetative and (13) Achieve a 70 % vegetative or litter cover level on cut and fill slopes and other soil disturbance litter cover; exposed mineral soil would be kept to less than areas within 2 growing seasons or a natural level of vegetative and litter cover when it is less than 15% of a treatment unit. Vegetative cover will be monitored 70%. following activities as a part of assessing soil disturbance and deferred grazing needs. Fire, Fuels, and Air Quality: "All prescribed burning proposed in the Action Alternative will be subject to management and (14) Comply with Federal and State standards and the Montana Airshed Group's MOU on any approval by the Montana/Idaho Airshed Group. Additionally, management activity that may effect air quality. modelling and monitoring or air quality of impacts of smoke emissions suggest that the proposed burns can be completed without exceeding air quality standards." Fire, Fuels and Air Quality: "All prescribed burning proposed in the Action Alternative will be subject to management and (15) Protect air quality by cooperating with Montana Air Quality Bureau in the Prevention of approval by the Montana/Idaho Airshed Group. Additionally, Significant Deterioration program and State Implementation Plan. modelling and monitoring or air quality of impacts of smoke emissions suggest that the proposed burns can be completed without exceeding air quality standards." Social Management Standard H-I Native American Claims (2) Any decision respecting 1895 Agreement lands will be made only after informing the Blackfeet Tribe. Notice of proposed actions respecting these lands will be sent to the Chairman of the Tribal consultation has been done. Blackfeet Tribe in sufficient time to enable the Blackfeet Tribe to properly consult with the Forest Service.

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Management Standard H-2 Native American Rights For this Elk Smith Project, the Forest heritage staff considered American Indian traditional use, belief systems, religious practices and life-way values as directed by the (1) Protect and preserve for Native Americans their inherent right of freedom of belief, Archaeological Resources Protection Act of 1979 (ARPA), the expression, and exercise their traditional religions. National Historic Preservation Act (NHPA), the Native American Graves Protection and Repatriation Act (NAGPRA), the American Indian Religious Freedom Act (AIRFA) and the Religious Freedom Restoration Act (RFRA). (2) Assess impacts of Forest Service activities on Native American spiritual sites and objects. No sites or objects of this type are known in the project area. (5) Consult with the Blackfeet Tribe regarding the establishment of proper procedures to This topic is covered in regularly scheduled Government-to- implement the American Indian Religious Freedom Act. The Forest Service will negotiate an Government meetings with Blackfeet Tribal representatives. agreement with the Blackfeet Tribe on this issue. Management Standard J-3 Land Uses Project development has included NFMA analysis, scoping, and an open house, held in Augusta, Montana (spring 2016). (1) Enhance resource management by working with other agencies and landowners to develop Besides input received through scoping, the project has been and achieve common resource objectives. guided by planning documents produced by other agencies and cooperators, as well as consultation with other agencies. Facilities Management Standard L-1 Signing Establish and maintain signs according to Regional signing standards, with the following priority: Areas will be appropriately signed during operational periods (1) Safety, Warning, and Regulatory Signs of the Elk Smith Project in order to alert the public.

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Areas will be appropriately signed during operational periods (2) Guide and Directional Signs of the Elk Smith Project in order to alert the public. Areas will be appropriately signed during operational periods (3) Informational Signs of the Elk Smith Project in order to alert the public. The following standards apply to occupied grizzly bear habitat on the Rocky Mountain Division: Not Applicable to this project (34) Limit new road construction to an absolute minimum to provide isolation and disturbance This has been removed and replaced with NCDE-STD-AR-01 free areas for grizzlies. Where new road construction is required: through 04 and NCDE-GDL-AR-01 and 02 (which all apply to the PCA). Protection Management Standard P-1 Protection A majority of trees (lodgepole and Douglas-fir seedlings and saplings) within treatment units are too small to be (2) During ongoing infestations, control insects and disease through silvicultural and biological susceptible to major insects. Prescribed fire, a silvicultural practices. Chemical controls will be limited to high value areas or used on a broader scale only practice, is designed to alter stand density which would when all other measures have failed and other resource values can be protected. Emphasize improve overall tree vigor. However, over time forest cooperative control measures between Federal, State, and private landowners. conditions would become increasingly susceptible to mountain pine beetle. Chemical controls for insects are not feasible or desired for the Elk Smith Project. The Action Alternative for the Elk Smith Project proposes to use prescribed fire to achieve a number of land management goals. These goals are included in the Purpose Statement and (3) Use prescribed fire as appropriate to achieve land management goals, including improvement include, "[creating] a more diverse landscape that is more or maintenance of vegetation diversity Management area direction indicates the appropriate use resilient to fire…" Prescribed fire treatments would occur of prescribed fire. Management Areas E, G, H, and O. The Forest Management Plan authorizes the use of prescribed fire with planned ignitions in all four of these Management Areas.

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Management Standard P-2 Debris Control (4) Leave approximately 10 tons of fuel per acre, where available. This should be material over Implementation of the selected alternative would retain at four inches in diameter, which is randomly scattered over the area. Material should touch the least 10 tons per acre of coarse woody debris. ground for faster decomposition. Fisheries : There would be no foreseeable need connected with this project to install drainage structures to control (8) Put slash piles in landings, along skid trails, and on the edge of logging roads, when possible. erosion. Timber: Standard does not apply. Timber harvest These locations facilitate firewood gathering. with subsequent slash treatment is not proposed in the Elk Smith Project.

Management Area E (124,570 acres; 6 8 %). Nearly all of this management area occurs on big-game winter range and contains both grass and forested lands. The land is generally near the Forest boundaries. Goal: Provide sustained high level of forage for livestock and big game animals.

Forest Plan Standard Compliance with Management Direction Wildlife Operation, Protection, and Maintenance (CW2b) Maintain important identified wildlife habitat, including T&E Habitat would be enhanced for grizzly bear in the short-term and lynx in the mid-term. Forage habitat, big-game winter ranges, calving or lambing areas, availability for big game would be enhanced and winter and calving/range habitats are migration routes, elk summer range, raptor nesting sites, and maintained. significant non-game habitat values. Nonstructural Improvements (DR3a) Use prescribed fire to control tree/shrub encroachment and The Elk Smith Project Action Alternative proposes to use prescribed fire to reduce the future risk to maintain or enhance forage production on range. of high-intensity, high-severity wildfire in the project area. This primary purpose includes Mechanical or chemical methods are also acceptable. "enhancing or re- creating grassland openings." Forage production may be enhanced by the use of

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Cooperate closely with other Federal and State agencies, prescribed fire, but is not among the primary purposes of the project. The Rocky Mountain Ranger individuals, contractors, and permittees to control noxious District currently cooperates with other Federal and State agencies, individuals, contractors and weed and pest infestations. permittees to control noxious weed and pest infestations in the project area through the Rocky Mountain Front Weed Roundtable (see Noxious Weed Report). Soil and Water Protection (FW2b) Adhere to State water quality standards and maintain current soil productivity. Priority for funding will be moderate for Best management practices specific to the proposed action are incorporated into Resource structural or land treatments which maintain or rehabilitate Protection Measures. Analysis shows that Northern Region Soil Quality Standards would be met watersheds or soils. Protection Suppression (PD8b) The appropriate suppression response ranges from "control" By reducing fuel loadings, the project would support the efforts of managers to “control” fire in to "confinement" in this management area depending upon the Project Area. The Action Alternative would also enhance opportunities for successful location, expected fire behavior, and other decision logic confinement strategies. As an example, natural fuel breaks would be maintained by removing criteria related to values at risk. The decision criteria will be encroaching conifers. stated in a Fire Management Action Plan. Prescribed Fire (PS12a) The Action Alternative is a proposal to use prescribed fire to “address fuel accumulation and Prescribed fire with planned ignitions will be used in this MA continuity in the Project Area.” The No Action Alternative would not use prescribed fire activities for the enhancement and maintenance of resources. to reduce fuels. Prescribed Fire (PS 12b) Prescribed fire with unplanned ignitions may be used in this The Action Alternative proposes to reduce fuels within the Project Area. This will increase MA for the enhancement and .maintenance of resources, opportunities to manage unplanned ignitions in the portions of the Scapegoat Wilderness that lie when within pre-established prescribed fire criteria. due west of the Project Area (by reducing the risk associated with fire exiting the wilderness These criteria will be detailed in a Fire Management Action boundary and burning through the Project Area toward adjacent public and private lands). Plan. Currently a Fire Management Action Plan does not exist for the Project Area.

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Management Area G (259,178 acres; 14.1 percent).contains large areas of undeveloped land. Motorized access is very limited. The land is forested but contain much rock, some grassy inclusions. and is generally steep and broken. Much of the area is non-commercial forest or is not economical for timber harvest. The exception to this description is the Two-Medicine drainage, a broad U-shaped valley on the Rocky Mountain Division. Goal: Maintain and protect Forest resources with minimal investments.

Forest Plan Standard Compliance with Management Direction

Wildlife Operation, Protection, and Protection, and Maintenance (CW2b) Maintain or enhance important identified wildlife habitat, including Habitat would be enhanced for grizzly bear in the short-term and lynx in the mid-term. T&E habitat, big-game winter ranges, calving or lambing areas, Forage availability for big game would be enhanced and winter and calving/range habitats migration routes, elk summer concentration areas, raptor nesting are maintained. sites, and significant nongame habitat values

Nonstructural Improvements (DR3a)

The Elk Smith Project Action Alternative proposes to use prescribed fire to reduce the future risk of high- intensity, high-severity wildfire in the project area. This primary purpose Use prescribed fire to control tree/shrub encroachment and to includes "enhancing or re-creating grassland openings." Forage production may be maintain or enhance forage production on range. Mechanical or enhanced by the use of prescribed fire, but is not among the primary purposes of the chemical methods are also acceptable. Cooperate closely with project. The Rocky Mountain Ranger District currently cooperates with other Federal and other Federal and State agencies, individuals, contractors, and State agencies, individuals, contractors and permittees to control noxious weed and pest permittees to control noxious weed and pest infestations. infestations in the project area through the Rocky Mountain Front Weed Roundtable (see Noxious Weed Report).

Soil and Water Protection (FW2c)

Adhere to State water quality standards and maintain current soil Best management practices specific to the proposed action are incorporated into Resource productivity. Priority for funding Protection Measures.

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will be moderate for structural or land treatments which maintain Analysis shows that Northern Region Soil Quality Standards would be met. or rehabilitate watersheds or

Protection Suppression (PD8b)

The appropriate suppression response ranges from "control" to" By reducing fuel loadings, the project would support the efforts of managers to "control" fire confinement" in this MA depending upon location, expected fire in the Project Area. The Action Alternative would also enhance opportunities for successful behavior, and other decision logic criteria related to values at risk. confinement strategies. As an example, natural fuel breaks would be maintained by The decision criteria will be stated in a Fire Management Action removing encroaching conifers. Plan. Prescribed Fire (PS 12a)

Prescribed fire with planned ignitions will be used in this The Action Alternative is a proposal to use prescribed fire to “address fuel accumulation and management area for the enhancement and maintenance of continuity in the Project Area.” The No Action Alternative would not use prescribed fire resources. activities to reduce fuels.

Prescribed Fire (PS 12b) The Action Alternative proposes to reduce fuels within the Project Area. This will increase Prescribed fire with unplanned ignitions may be used in this opportunities to manage unplanned ignitions in the portions of the Scapegoat Wilderness management area for the enhancement and .maintenance of that lie due west of the Project Area (by reducing the risk associated with fire exiting the resources, when within pre-established prescribed fire criteria. wilderness boundary and burning through the Project Area toward adjacent public and These criteria will be detailed in a Fire Management Action Plan. private lands). Currently a Fire Management Action Plan does not exist for the Project Area.

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Management Area H (29,146 acres; 1.6 %) MA- H includes developed recreation sites such as campgrounds, ski areas, recreation residences, and the land adjacent to all of these sites. Some livestock grazing occurs within and adjacent to the area. Goal: Provide winter recreation opportunities supported by public and private developments while maintaining other resource values. Forest Plan Standard Compliance with Management Direction Visual Quality Objectives The VQO will usually be retention or partial retention. Although the landscape is changed by resource activities, the natural appearance of the landscape This standard will be met by applying this standard to the treatment prescriptions. remains dominant. The modification VQO is acceptable when activity is not visible from an arterial road. If the VQO is not met and the visual impacts can be classified as This standard will be met by applying this standard to the treatment prescriptions. EVC 4 or greater, the site should be rehabilitated within 2 years to restore the landscape to at least an EVC Class 3. Wildlife Operation, Protection, and Protection, and Maintenance (CW2c) Minimize impacts on important identified wildlife Habitat. Important Habitat would be enhanced for grizzly bear in the short-term and lynx in the mid- identified habitat includes T&E habitat, big-game winter ranges, calving or term. Forage availability for big game would be enhanced and winter and lambing areas, migration routes, and elk summer ranges. calving/range habitats are maintained. Range Nonstructural Improvements (DR3a) The Elk Smith Project Action Alternative proposes to use prescribed fire to reduce Use prescribed fire to control tree/shrub encroachment and to maintain or the future risk of high-intensity, high-severity wildfire in the project area. This enhance forage production on range. Mechanical or chemical methods are primary purpose includes "enhancing or re-creating grassland openings." Forage also acceptable. Cooperate closely with other Federal and State agencies, production may be enhanced by the use of prescribed fire, but is not among the individuals, contractors, and permittees to control noxious weed and pest primary purposes of the project. The Rocky Mountain Ranger District currently infestations. cooperates with other Federal and State agencies, individuals, contractors and

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permittees to control noxious weed and pest infestations in the project area through the Rocky Mountain Front Weed Roundtable (see Noxious Weed Report). Protection Suppression (PD8a) The Action Alternative would support actions to aggressively “control” fire in the project by reducing fuels. Breaks in fuel continuity, created by the project, would Aggressive ‘control’ will normally be the appropriate fire suppression increase the effectiveness of aggressive management actions, providing areas of response in this management area. lighter fuel for direct attack, line location, retardant use, etc. The Proposed Action would also create safer conditions for these actions. For example, escape routes and safety zones would be more accessible following treatments. Prescribed Fire (PS 12a) The Action Alternative is a proposal to use prescribed fire to “address fuel Prescribed fire with planned ignitions will be used in this management area accumulation and continuity in the Project Area.” The No Action Alternative for the enhancement and maintenance of resources. would not use prescribed fire activities to reduce fuels.

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Management Area O (22,702 acres: 1.2%). MA- O is on The Rocky Mountain Division and the majority is commercial forest land, in the general forest. Some of the land produces forage suitable for grazing. The area is on all slopes, is primarily summer range for big-game animals, and has inclusions of noncommercial forest land, grass, rock, and scree. Most of the management area is associated with existing roads for wilderness classification. Goal: Protect, maintain, and improve resource quality while providing timber at a low intensity level to meet local needs. Manage forage for livestock at a moderate intensity level. Forest Plan Standard Compliance with Management Direction Visual Quality Objectives VQO will be retention or partial retention. Retention may be appropriate if the area is within the seen area of a sensitivity level1 road, trail, or use area. If the VQO is not achieved and the visual This standard will be met by applying this standard to the treatment prescriptions. impacts can be classed as EVC 5 or greater, the site should be rehabilitated within 2 years to restore the landscape to at least an EVC Class 4. Wildlife Operation, Protection, and Protection, and Maintenance (CW2a) Maintain or enhance important identified wildlife habitat, including Habitat would be enhanced for grizzly bear in the short-term and lynx in the mid- term. T&E habitat, big- game winter ranges, calving or lambing areas, Forage availability for big game would be enhanced and winter and calving/range habitats migration routes, elk summer range, raptor nesting sites, and are maintained. significant nongame habitat. Nonstructural Improvements (DR3a) The Elk Smith Project Action Alternative proposes to use prescribed fire to reduce the Use prescribed fire to control tree/shrub encroachment and to future risk of high-intensity, high-severity wildfire in the project area. This primary purpose maintain or enhance forage production on range. Mechanical or includes "enhancing or re-creating grassland openings." Forage production may be chemical methods are also acceptable. Cooperate closely with other enhanced by the use of prescribed fire, but is not among the primary purposes of the Federal and State agencies, private individuals, contractors, and project. The Rocky Mountain Ranger District currently cooperates with other Federal and permittees to control noxious weed and pest infestations. State agencies, individuals, contractors and permittees to control noxious weed and pest

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infestations in the project area through the Rocky Mountain Front Weed Roundtable (see Noxious Weed Report). Reforestation Natural conifer and/or aspen regeneration will occur following implementation of the Forest regeneration will be natural. selected alternative. However, prescribed burning is not planned within this Management Area. Soil and Water Protection (FW2b) Soil: Best management practices specific to the proposed action are incorporated into Adhere to State water quality standards and maintain current soil Resource Protection Measures. Analysis shows that Northern Region Soil Quality Standards productivity. Priority for funding will be high for structural or land would be met. Hydrology: Yes, state water quality standards will be meet and current soil treatments which maintain or rehabilitate watersheds or soils. productivity will be maintained. This is articulated in the soil and watershed specialist report for with the prescription and implementation of BMPs/Design criteria. Protection Suppression (PD8b) The appropriate suppression response range from “control” to By reducing fuel loadings, the project would support the efforts of managers to "control" “confinement” in this MA depending upon location, expected fire fire in the Project Area. The Action Alternative would also enhance opportunities for behavior, and other decision-logic criteria related to values at risk. successful confinement strategies. As an example, natural fuel breaks would be maintained These decision criteria will be stated in a Fire Management Action by removing encroaching conifers. Plan. Prescribed Fire (PS12a) Prescribed fire with planned ignitions may be used in this MA if fire is The Action Alternative is a proposal to use prescribed fire to “address fuel accumulation commensurate with the goals and objectives of the RNA as provided and continuity in the Project Area.” The No Action Alternative would not use prescribed for in the Establishment Record. fire activities to reduce fuels. Fuels (PS11)

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Activity fuels created through the Action Alternative would be limited to the falling of Fuels reduction methods for activity created fuels include burning, young conifers (<16ft.) using power saws over portions of some units. These fuels would removing residue, or rearranging, such as dozer trampling, Disposal be managed for fuels reduction and to meet visual quality standards by the application of activities will meet visual quality objectives. prescribed fire subsequent to the felling treatment. The use of Dozers, or other heavy equipment, for disposal activities is not proposed by the Action Alternative.

Management Area Q (51,834 acres: 2.8%).MA-Q includes the East Slope Recommended Wilderness. This MA is on the Rocky Mountain Division and is contiguous with the Bob Marshall and Scapegoat Wildernesses. Goal: Manage these areas to protect their wilderness values. Manage with limited investment in range management and trail construction. This recommendation is a preliminary administrative recommendation that will receive further review and possible modification by the Chief of the Forest Service, the Secretary of Agriculture, and the President of the United States. Final decisions on wilderness designation have been reserved by the Congress to itself. If designated wilderness by Congress, it will be managed as MA-P, the Bob Marshall- Scapegoat Wilderness. Forest Plan Standard Compliance with Management Direction Visual Quality Objectives The VQO is preservation. The objective allows for ecological changes only. This standard will be met by applying this standard to the treatment Management activities, except for very low visual impact recreation activities are prescriptions. prohibited. Wilderness Management (BM2) This standard will be met by applying this standard to the treatment Manage areas to protect their wilderness values. prescriptions. Wildlife Operation, Protection, and Protection, and Maintenance (CW2a) Maintain or enhance important identified wildlife habitat, including T&E habitat, big- Habitat would be enhanced for grizzly bear in the short-term and lynx in game winter ranges, calving or lambing areas, migration routes, elk summer-fall the mid-term. Forage availability for big game would be enhanced and range, raptor nesting sites, and significant nongame habitat values. winter and calving/range habitats are maintained.

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Soil and Water Protection (FW2b) Soil: Best management practices specific to the proposed action are Adhere to State water quality standards and maintain current soil productivity. incorporated into Resource Protection Measures. Analysis shows that Northern Region Soil Quality Standards would be met. Protection Suppression (PD8b) By reducing fuel loadings, the project would support the efforts of The appropriate suppression response range from “control” to “confinement” in this managers to "control" fire in the Project Area. The Action Alternative MA depending upon location, expected fire behavior, and other decision-logic criteria would also enhance opportunities for successful confinement strategies. related to values at risk. These decision criteria will be stated in a Fire Management As an example, natural fuel breaks would be maintained by removing Action Plan. encroaching conifers. Prescribed Fire (PS12a) The Action Alternative proposes to reduce fuels within the Project Area. This will increase opportunities to manage unplanned ignitions in the Prescribed fire with unplanned ignitions may be used in this MA for the enhancement portions of the Scapegoat Wilderness that lie due west of the Project and maintenance of resources, when within pre-established prescribed fire criteria. Area (by reducing the risk associated with fire exiting the wilderness These criteria will be detailed in a Fire Management Action Plan. boundary and burning through the Project Area toward adjacent public and private lands). Currently a Fire Management Action Plan does not exist for the Project Area.

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Management Area R (33,321 acres: 1.8%). (Suitable timber acres 1,412). MA-R consists of riparian areas through the Forest. They are made up of the lakes, streams, and land where vegetation is influenced by surface and subsurface water. Many important resources, such as fish, some wildlife, and certain vegetation communities, are totally dependent on this area for their existence. Streams usually flow year round in riparian areas, although the main characteristic of these management areas is riparian vegetation, not necessarily stream flow. Management area boundaries of riparian areas are determined by onsite characteristics of soil and vegetation. NOTE: Riparian areas throughout the Forest have been given special consideration. These considerations include: (1) minimizing activity in riparian areas where possible; (2) standards for stream crossings; and (3) measures to avoid stream contamination. Goal: Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian area dependent resources. Timber and range management activities are permitted. Forest Plan Standard Compliance with Management Direction Setting and Visual Quality Objectives This standard will be met by applying this standard to the The Riparian Management Area will be managed to meet adjacent recreation settings and VQOs. treatment prescriptions. Wildlife Operation, Protection, and Protection, and Maintenance (CW2d) Maintain or enhance important identified wildlife and fish habitat. Important identified habitat Habitat would be enhanced for grizzly bear in the short-term includes T&E species habitat big-game winter ranges, calving or lambing areas, migration routes, and lynx in the mid-term. Forage availability for big game elk summer-fall ranges, raptor nesting sites, spawning areas, and significant nongame habitat would be enhanced and winter and calving/range habitats are values. Uneven-aged harvest systems will provide for stream shading, bank stability protection, maintained. and a range of successional stages. Soil and Water Protection (FW2a) Adhere to State water quality standards and maintain current soil productivity. Priority for Soil: Best management practices specific to the proposed funding will be high for structural or land treatments which maintain or rehabilitate watersheds action are incorporated into Resource Protection Measures. or soil. Refer to Management Guidelines D-3, E-4, F-3, 3-3, L-4, and P-2 for specific direction for Analysis shows that Northern Region Soil Quality Standards activities in riparian zones. would be met. Protection

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Suppression (PD8b) By reducing fuel loadings, the project would support the efforts The appropriate suppression response range from “control” to “confinement” in this MA of managers to “control” fire in the Project Area. The Action depending upon location, expected fire behavior, and other decision-logic criteria related to Alternative would also enhance opportunities for successful values at risk. These decision criteria will be stated in a Fire Management Action Plan. confinement strategies. As an example, natural fuel breaks would be maintained by removing encroaching conifers. Prescribed Fire (PS11) Activity fuels created through the Action Alternative would be limited to the falling of young conifers (<16ft.) using power saws over portions of some units. These fuels would be managed for fuels reduction and to meet visual quality Fuel reduction methods for activity created fuels include burning, removing residue, or standards by the application of prescribed fire subsequent to rearranging, such as dozer trampling. Disposal activities will meet riparian area objectives. the felling treatment. The use of Dozers, or other heavy equipment, for disposal activities is not proposed by the Action Alternative. Activity fuels will not be created in Management Area R. Prescribed fire will not be ignited in Management Area R. Prescribed Fire (PS12a) The Action Alternative proposes to reduce fuels within the Project Area. This will increase opportunities to manage unplanned ignitions in the portions of the Scapegoat Wilderness that lie due west of the Project Area (by reducing Prescribed fire with unplanned ignitions may be used in this MA for the enhancement and the risk associated with fire exiting the wilderness boundary maintenance of resources. and burning through the Project Area toward adjacent public and private lands). Currently a Fire Management Action Plan does not exist for the Project Area.

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Wildlife (WL)

Standards

NCDE-STD-WL-01. Grizzly bear habitat on NFS lands in the NCDE shall be The project is consistent with this standard. The Elk Smith project occur delineated and managed as primary conservation area, zone 1, zone 2, or occurs with the primary conservation area (PCA). (USDA 2018*, p. 1-28, zone 3 (see figure 1-4 or subsequent USFWS updates if applicable). Figure 1-4).

NCDE-STD-WL-02. Within the NCDE primary conservation area, zone 1, and The project is consistent with this standard. Food storage orders are in place zone 2, food/wildlife attractant storage special order(s) shall apply to NFS in the project area and will be adhered to by all personnel (see the Wildlife lands. Report and Biological Evaluation at p. 23 and Biological Assessment, p. 27).

NCDE-STD-WL-03. In each bear management subunit within the NCDE primary The project is consistent with this standard. There are two bear management conservation area, temporary changes in the open motorized route density, subunits within which the project occurs: the Scapegoat and South Fork total motorized route density, and secure core shall be calculated for roads Willow subunits. There is no new road construction or reconstruction used for projects (as defined by “project (in grizzly bear habitat in the NCDE)”) proposed in the Elk Smith project. Roads to be used for project during the non-denning season (see glossary). Calculations will include implementation are open. Therefore there are no changes to motorized estimated changes for each year of the anticipated duration of the project and route density in these subunits. See the Wildlife Report and Biological will be incorporated into the 10-year running average required by standard Evaluation at p. 23 and Biological Assessment, p. 27. NCDE-STD-AR-03.

Guidelines [The project or activity complies with applicable guidelines as set out in the plan or is designed in a way that is as effective in achieving the purpose of the applicable guidelines (See Appendix 1, pp. 1-1 to 1-2 Grizzly Bear ROD)]

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NCDE-GDL-WL-01. Within the NCDE primary conservation area, zone 1, and The project is consistent with this guideline. Food storage orders are in place zone 2, contractors, permittees, lessees, operators, and their employees in the project area and will be adhered to by all personnel (see the Wildlife should be informed of food/wildlife attractant storage special order(s) and Report and Biological Evaluation at p. 23 and Biological Assessment, p. 27). procedures for safely working and recreating in grizzly bear country, prior to turnout of livestock or beginning work and annually thereafter, in order to reduce the risk of grizzly bear-human conflicts.

NCDE-GDL-WL-02. Within the NCDE primary conservation area, zone 1, and This guideline is not applicable since any camping on the National Forest by zone 2, if a contractor, permittee, lessee, operator or their employees elect to contractors would occur in developed recreation sites. camp on NFS lands other than in a developed recreation site, the site should be evaluated and written authorization (i.e., a campsite agreement that includes the food/wildlife attractant storage special order) should be provided before the campsite is established. The purpose is to reduce the risk of grizzly bear-human conflicts.

NCDE-GDL-WL-03. Within the NCDE primary conservation area and zone 1, The project is consistent with this guideline since no planting will occur under clover should not be used in seed mixes on NFS lands. Native seed mixes or the Elk Smith project.C475 those that are less palatable to grizzly bears should be used so that seeded areas do not become an attractant.

Access and Recreation (AR)

Standards

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NCDE-STD-AR-01. Within the NCDE primary conservation area, motorized use of roads with public restrictions shall be permitted for administrative use (see glossary) as long as doing so does not exceed either six trips (three round trips) per week or one 30-day unlimited use period during the non-denning season (see glossary). The exception to this standard is: • emergency situations as defined by 36 Code of Federal Regulations This standard is not applicable since only open roads (i.e. no public (CFR) 218.21. restrictions) will be used for project implementation. Note: Administrative use is not included in baseline calculations and is not included in calculations of net increases or decreases. If the level of administrative use exceeds this standard, the use is counted as a project (see “project (in grizzly bear habitat in the NCDE)” in the glossary in the Grizzly Bear ROD).

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NCDE-STD-AR-02. In each bear management subunit within the NCDE primary conservation area, there shall be no net decrease to the baseline (see glossary) for secure core and no net increase to the baseline for open motorized route density or total motorized route density on NFS lands during the non-denning season (see glossary). The following conditions are not considered a net increase/decrease from the baseline: • administrative use (see glossary); • temporary use of a motorized route for a project (see “project (in grizzly bear habitat in the NCDE)” in the glossary) that meets the conditions stipulated in NCDE-STD-AR-03; • mining activities (as authorized under the Mining Law of 1872) and This standard is not applicable. There is no new road construction or oil and gas activities (as authorized under the Federal Onshore Oil and reconstruction proposed in the Elk Smith project. Roads to be used for Gas Leasing Reform Act of 1987) conducted in accordance with valid project implementation are open. Therefore there are no changes to existing rights and applicable standards and guidelines listed under motorized route density in the PCA. See the Wildlife Report and Biological NCDE-MIN; Evaluation at p. 23 and Biological Assessment, p. 27. • updated or improved data on a motorized route without an actual change on the ground; • changes in technology or projections that result in changed open motorized route density, total motorized route density, or secure core values without actual change on the ground (e.g., a switch from the North American Datum of 1927 to the North American Datum of 1983 geodetic reference system); • a road closure location is moved a short distance to a better location (e.g., to the nearest intersection or turnout) to allow a turn-around providing for public safety, to reduce vandalism, or to improve enforcement of the road closure;

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) • the agency exchanges, acquires, buys, or sells lands with motorized routes; • a change in a motorized route necessary to comply with Federal laws; • a change in a motorized route necessary to address grizzly bear- human conflicts, human safety concerns, or resource damage/concerns (e.g., a road paralleling a stream may be decommissioned and replaced by a new upslope road to reduce water quality impacts); • a change made by an adjacent landowner that decreases the percentage of secure core or increases open motorized route density or total motorized route density values on an adjacent national forest; • use of a motorized route for emergency situations as defined by 36 CFR 218.21; and • temporary roads (see glossary).

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NCDE-STD-AR-03. In each bear management subunit within the NCDE primary conservation area, temporary changes in open motorized route density, total motorized route density, and secure core shall be allowed for projects (as defined by “project (in grizzly bear habitat in the NCDE)” in the glossary). The 10-year running average for open motorized route density, total motorized route density, and secure core shall not exceed the following limits during the non-denning season (see glossary): • 5 percent temporary increase in open motorized route density in each bear management subunit (i.e., open motorized route density This standard is not applicable. There is no change to secure core, ORD, or baseline plus 5 percent); TRD associated with the Elk Smith project. There is no new road construction • 3 percent temporary increase in total motorized route density in or reconstruction proposed in the Elk Smith project. Roads to be used for each bear management subunit (i.e., total motorized route density project implementation are open. See the Wildlife Report and Biological baseline plus 3 percent); and Evaluation at p. 23 and Biological Assessment, p. 27. • 2 percent temporary decrease in secure core in each bear management subunit (i.e., secure core baseline minus 2 percent). Exceptions to this standard include: • temporary changes for emergency situations as defined by 36 CFR 218.21 and • temporary changes for actions where valid existing rights preclude or constrain agency discretion (e.g., certain contracts, permits, leases).

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NCDE-STD-AR-04. Within the NCDE primary conservation area, a restricted road may be temporarily opened for public motorized use to allow authorized uses (such as firewood gathering), provided the period of use does not exceed The project is consistent with this standard. No restricted roads would be 30 consecutive days during one non-denning season and occurs outside of opened for the public under the Elk Smith project. spring and fall bear hunting seasons. However, temporary public use of a restricted road shall not be authorized in secure core (see glossary).

NCDE-STD-AR-05. Within the NCDE primary conservation area, the number and capacity of developed recreation sites on NFS lands that are designed and managed for overnight use by the public during the non-denning season (e.g., campgrounds, cabin rentals, huts, guest lodges, recreation residences) shall be limited to one increase above the baseline (see glossary) in the number or capacity per decade per bear management unit. The following conditions are not considered an increase from the baseline: • the agency obtains better information or updated information in its database(s); • the agency acquires land that contains developed recreation sites; This standard is not applicable since the project does not propose any developed recreational opportunities. • the agency increases the number or capacity of a developed recreation site in order to comply with Federal laws; • the agency maintains or modifies an existing overnight developed or dispersed recreation site in such a way that does not increase the number or capacity of the site (e.g., installing a pit toilet to avoid damage to water resources or installing a bear-resistant food storage structure to reduce grizzly bear-human conflicts); • the agency modifies an existing developed recreation site to enhance human safety (e.g., enlarging a road pullout to allow trailers to safely turn around);

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) • the agency operates a developed recreation site to allow overnight use only during the denning season (see glossary); and • the agency makes a corresponding reduction in the number or capacity of overnight developed recreation sites in the same bear management unit through any of the following means: (1) equal reduction in capacity at another site; (2) closure of a developed site(s); or (3) consolidation and/or elimination of dispersed camping, when and where it can be enforced effectively and it is reasonably assured that new dispersed sites will not develop nearby. If these measures are used to offset an increase in number or capacity, they must be in place before the initiation of the increase. If the agency reduces the number or capacity of developed sites below baseline levels, these reductions may be used at a future date to mitigate equivalent impacts of an increase, expansion, or change of use in developed sites within that bear management unit. Note: This standard does not apply to dispersed recreation sites or to developed recreation sites managed for day use only (e.g., outfitter camps, roadside trail crossings, or interpretive pullouts; trailheads, picnic areas, or boat launches that are closed at night; ski areas that do not have overnight lodging).

NCDE-STD-AR-06. Within the NCDE primary conservation area, new or reauthorized recreation permits shall include a clause providing for This standard is not applicable since the project does not include modification, cancellation, suspension, or temporary cessation of activities if authorization or re-authorization of recreation permits. needed to resolve a grizzly bear-human conflict situation.

NCDE-STD-AR-07. Within the NCDE primary conservation area, new or reauthorized permits for ski areas on NFS lands that operate during the non- This standard is not applicable since the project does not include denning season shall include requirements to limit the risk of grizzly bear- authorization or re-authorization for permits for ski areas. human conflicts (e.g., to store garbage in a bear-resistant manner).

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NCDE-STD-AR-08. Within modeled grizzly bear denning habitat in the NCDE primary conservation area, there shall be no net increase in the percentage of This standard is not applicable since the project does not include designation area or miles of routes designated for motorized over-snow vehicle use on of over-the-snow vehicle use. NFS lands during the den emergence time period (see glossary).

NCDE-GDL-AR-01. In each bear management subunit within the NCDE primary conservation area, each project (as defined by “project (in grizzly bear habitat in the NCDE)” in the glossary) should be designed so that on-the-ground implementation does not exceed 5 years to reduce the potential duration of grizzly bear disturbance or displacement due to project-related activities. Exceptions may be made where necessary, for example to accommodate: • actions where existing rights preclude or constrain agency discretion The project could take up to ten years to implement with lopping and (e.g., certain contracts, permits, leases); scattering occurring most likely within the first 5 years. Because of the small size of the treatment units, the application of prescribed fire could extend • prescribed burning (including slash disposal), best management beyond the five year period. However, this is within the exceptions provided practices to protect water quality, or required reforestation activities; so the project is consistent with this standard. or • emergency situations as defined by 36 CFR 218.21. If an extension to the five-year time limitation is required (e.g., to meet contractual obligations or to complete on-the-ground treatments), the reasons should be documented in writing prior to authorization of the extension.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-GDL-AR-02. Within the NCDE primary conservation area, secure core, open motorized route density, and total motorized route density should be restored to pre-project levels (as defined by “project (in grizzly bear habitat in the NCDE)” in the glossary) within 1 year after completion of the project to reduce the potential duration of grizzly bear disturbance due to project- related activities. Exceptions may be made where necessary, for example to accommodate: This standard is not applicable. There are no changes to secure core, ORD, or • actions where existing rights preclude or constrain agency discretion TRD associated with the Elk Smith Project since there are no temporary roads (e.g., certain contracts, permits, leases); or reconstruction and only roads already opened would be used for project implementation. See the Wildlife Report and Biological Evaluation at p. 23 • prescribed burning (including slash disposal), best management and Biological Assessment, p. 27. practices to protect water quality, or required reforestation activities; or • emergency situations as defined by 36 CFR 218.21. If an extension to the 1-year time limitation is made (e.g., to meet contractual obligations or to complete on-the-ground treatments), the reasons should be documented in writing prior to authorization of the extension.

NCDE-GDL-AR-03. Within the NCDE primary conservation area, if the number or capacity of day-use or overnight developed recreation sites is increased, the project should include one or more measures to reduce the risk of grizzly- bear human conflicts in that bear management unit. The measure(s) should be Not applicable to the project. in place prior to completion of the project or be included as one of the design criteria. Measures can include but are not limited to: offering additional public information and education; providing backcountry food-hanging poles or bear-resistant food or garbage storage devices; project design criteria that

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) would limit capacity increases to those needed for public health and safety; and increasing law enforcement and patrols.

Terrestrial Ecosystems Vegetation (VEG)

NCDE-GDL-VEG-01. Within the NCDE primary conservation area, measures to reduce the risk of disturbance to the grizzly bear population should be incorporated into vegetation and fuels project design criteria, which vary on a The project is consistent with this guideline. Design Features are included in site-specific basis (e.g., some activities should be restricted in spring habitat the project to minimize disturbance to grizzly bears as follows: To limit during the spring; areas with low levels of human activity should be provided disturbance to bears in spring habitat in Management Situation 1 areas: adjacent to areas with high levels of disturbance). Note: Management slashing activities in units 1, 2, 7, 9, 11 and 12 would occur after June 30 to activities such as pre-commercial thinning, burning, weed spraying, and minimize disturbance; and spring burning would occur prior to green up to implementation of road best management practices may need to be limit impacts to wildlife, including spring grizzly bear habitat and completed during the spring in order to meet resource objectives (especially if calving/fawning/lambing ranges (see Biological Assessment at pages 31-32) . needed to prevent resource damage), in which case other measures should be used to reduce the risk of disturbance (e.g., limiting the duration of the activity or limiting the use of closed roads).

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-GDL-VEG-02. Within the NCDE primary conservation area, vegetation management activities should be designed to avoid detrimental effects on the Although the Elk Smith project is not specifically designed to benefit wildlife, grizzly bear population and to include one or more measures to protect, some of the treatment units may result in improved spring grizzly bear forage maintain, increase, and/or improve grizzly habitat quantity or quality (e.g., by opening the canopy, reducing conifer competition, and using prescribed promoting growth of berry-producing shrubs, forbs, or grasses known to be fire that would improve spring forage species (see Biological Assessment at bear foods) in areas where it would not increase the risk of grizzly bear-human pp. 27, 30). Therefore, the project is consistent with this guideline. conflicts.

The project is consistent with this guideline. C540Design Features are in place that will provide measures to retain cover including but not limited to the NCDE-GDL-VEG-03. Within the NCDE primary conservation area, measures to following (see the Environmental Assessment): a 200 foot no-ignition buffer retain cover (where present) along a portion of grass/forb/shrub openings, is in place on all streams to preserve riparian vegetation; when wetlands or riparian wildlife habitat, or wetlands should be incorporated in project design springs exist within treatment units, active lighting would only occur outside criteria (this varies on a site-specific basis). of the wetland boundary; and, all wetlands, seeps and springs would be identified and marked during project implementation, and would be protected in accordance with INFISH or Montana SMZ law.

NCDE-GDL-VEG-04. Within the NCDE primary conservation area, vegetation management projects (including timber sales and other non-commercial This guideline is met. Standard operating procedures on the District include vegetation management contracts) should include a provision for investigation of any grizzly bear-human conflict and taking the necessary modification, cancellation, suspension, or temporary cessation of activities, if actions. needed, to resolve a grizzly bear-human conflict situation.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

The Elk Smith project is not designed to enhance grizzly habitat but rather to (see the Environmental Assessment): • Reduce the future risk of high-intensity, high-severity wildfire within the NCDE-GDL-VEG-05. To reduce the risk of grizzly-bear human conflicts within project area by interrupting the continuity of fuels, specifically continuous the NCDE primary conservation area, vegetation management activities stands of lodgepole pine regeneration and heavy loadings of larger fuels; designed to enhance grizzly habitat (e.g., to increase huckleberry production) • Reduce the potential for wildfire to spread into the Benchmark corridor to should not occur in or next to campgrounds, administrative facilities, or other the north and onto private land east of the National Forest boundary; developed recreation sites that operate during the non-denning season. • Create a more diverse landscape that is more resilient to fire by retaining mature areas, disrupting dense areas, and enhancing or re-creating grassland openings; and • Increase flexibility to allow lightning-caused wildfire to play its natural role in adjacent and nearby designated Scapegoat Wilderness.

Grazing (GRZ)

Standards

NCDE-STD-GRZ-01. Within the NCDE primary conservation area and zone 1, new or reauthorized livestock grazing permits and annual operating plans shall incorporate requirements to reduce the risk of grizzly bear-human conflicts Not applicable since authorization or re-authorization of grazing permits is (e.g., a food/wildlife attractant storage special order). New or reauthorized not a component of the Elk Smith project. permits shall include a clause providing for modification, cancellation, suspension, or temporary cessation of activities, if needed, to resolve a grizzly bear-human conflict situation.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-STD-GRZ-02. Within the NCDE primary conservation area, a sheep grazing permit in non-use status shall not be allowed to increase allowable Not applicable; no sheep allotments in the project area and not a component animal unit months beyond what was previously permitted prior to being in of the Elk Smith project. non-use when it is returned to use. Note: The Lewis and Clark National Forest does not have any sheep allotments.

NCDE-STD-GRZ-03. Within the NCDE primary conservation area and zone 1, permits for livestock grazing shall include a provision that requires the Not applicable since authorization or re-authorization of grazing permits is reporting of livestock carcasses within 24 hours of discovery, which shall be not a component of the Elk Smith project. followed by proper disposal of the carcass. Boneyards shall not be established on NFS lands.

NCDE-STD-GRZ-04. Within the NCDE primary conservation area and zone 1, there shall be no net increase in the number of active sheep allotments or in permitted sheep animal unit months above the baseline (see glossary) on NFS Not applicable; no sheep allotments in the project area and not a component lands. Allowable animal unit months shall not be increased for inactive of the Elk Smith project. allotments. Note: Existing allotments may be combined or divided as long as doing so does not result in grazing allotments in currently unallotted lands or an increase in animal unit months.

NCDE-STD-GRZ-05. Within the NCDE primary conservation area, there shall be no net increase in the number of active cattle grazing allotments above the Not applicable since the Elk Smith project does not propose grazing allotment baseline (see glossary) on NFS lands. Note: Existing allotments may be management. combined or divided as long as doing so does not result in grazing allotments in currently unallotted lands.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-STD-GRZ-06. Within the NCDE primary conservation area and zone 1, temporary permits for grazing by small livestock for purposes such as Not applicable since the Elk Smith project does not propose utilizing small controlling invasive exotic weeds, reducing fire risk, or trailing of small livestock for controlling weeds, reducing fire risks, etc. livestock across NFS lands shall not result in an increase in bear-small livestock conflicts.

NCDE-GDL-GRZ-01. On NFS lands within the NCDE primary conservation area, the number of open or active sheep grazing allotments should be reduced if Not applicable; no sheep allotments in the project area and not a component an opportunity exists with a willing permittee, to reduce the risk of conflicts of the Elk Smith project. with grizzly bears.

NCDE-GDL-GRZ-02. Within the NCDE primary conservation area, an allotment management plan and plan of operation should specify any needed measures Not applicable since the Elk Smith project does not propose grazing allotment to protect key grizzly bear food production areas (e.g., wet meadows, stream management. bottoms, aspen groves, and other riparian wildlife habitats) from conflicting and competing use by livestock (this varies on a site-specific basis).

Special Forest Products (SFP)

Standards

NCDE-STD-SFP-01. Special-use permits for apiaries (beehives) located on NFS lands shall incorporate measures including electric fencing to reduce the risk Not applicable since the Elk Smith project does not propose issuing a special of grizzly bear-human conflicts, as specified in the food/wildlife attractant use permit for apiaries. storage special order.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

Renewable/Non-Renewable Energy and Mineral Resources (MIN)

Standards

NCDE-STD-MIN-01. Within the NCDE primary conservation area, mining activities (as authorized under the Mining Law of 1872) and oil and gas activities (as authorized under the Federal Onshore Oil and Gas Leasing Reform Act of 1987) occurring on NFS lands, where feasible shall avoid, Not applicable since mineral use/authorization/re-authorization is not a minimize, and/or mitigate environmental impacts to grizzly bears or their component of the Elk Smith project. habitat, subject to valid existing rights. Stipulations or mitigation measures already included in existing leases, permits, or plans of operation on NFS lands shall not be changed, nor will additional stipulations or mitigation measures be added, without the lease, permit, or plan of operation holder’s agreement.

NCDE-STD-MIN-02. Within the NCDE primary conservation area, new or Not applicable since mineral use/authorization/re-authorization is not a reauthorized permits, leases, and/or plans of operation shall include a component of the Elk Smith project. provision for modification or temporary cessation of activities if needed to resolve a grizzly bear-human conflict situation.

NCDE-STD-MIN-03. Within the NCDE primary conservation area, new plans of operation, permits, and/or leases for mineral activities shall include measures to reasonably mitigate potential impacts of mineral development for the Not applicable since mineral use/authorization/re-authorization is not a following: component of the Elk Smith project. • land surface and vegetation disturbance; • water table alterations that affect bear foods on the surface; and

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) • construction, operation, and reclamation of mine-related facilities such as impoundments, rights of way, motorized routes, pipelines, canals, transmission lines, or other structures.

NCDE-STD-MIN-04. Within the NCDE primary conservation area, in addition to measures included in the food/wildlife attractant special order(s), new plans of operation, permits, and/or leases for mineral activities shall include the following measures regarding grizzly bear attractants: • bear-resistant food storage and garbage containers shall be used at development sites and at any campgrounds or dispersed sites where exploration or production-related human occupancy is anticipated; • garbage shall be removed in a timely manner; Not applicable since mineral use/authorization/re-authorization is not a component of the Elk Smith project. • road kills shall be removed daily during active operating periods to a designated location determined in close coordination with Montana Fish, Wildlife and Parks; • feeding of wildlife shall not be allowed; and • locations of work camps shall be approved in advance of operations. Food storage requirements shall be strictly adhered to in any work camps.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-STD-MIN-05. Within the NCDE primary conservation area, if minerals activities have the potential to adversely affect grizzly bears or their habitat as determined by a site-specific analysis, new plans of operation, permits, and/or leases for mineral activities shall include the following mitigation measures, stipulations, or surface use criteria regarding grizzly bear habitat: • ground-disturbing activities in identified grizzly bear spring habitat (as identified in a site-specific biological evaluation or other environmental document) shall be avoided between April 1 and June 30. If timing restrictions are not practicable, other measures shall be taken to reasonably mitigate negative impacts of mineral activity to grizzly bears;

• seismic activity in identified grizzly bear denning habitat (as Not applicable since mineral use/authorization/re-authorization is not a identified in a site-specific biological evaluation or other component of the Elk Smith project. environmental document) shall be avoided during the denning season (see glossary). If timing restrictions are not practicable, other measures shall be taken to reasonably mitigate negative impacts to the grizzly bear; • cumulative impacts of multiple concurrent seismic and/or drilling operations shall be limited by timing restrictions. If timing restrictions are not practicable, reasonable and appropriate measures shall be taken to mitigate negative impacts to the grizzly bear; • reasonable and appropriate measures regarding the maintenance, rehabilitation, restoration, or mitigation of functioning aquatic systems and riparian habitat conservation areas shall identify how reclamation will occur, plant species to be used in reclamation, a

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) timeframe of when reclamation will be completed, and monitoring criteria; and • reclamation and revegetation of motorized routes, drilling pads, and other areas disturbed by mineral activities shall be completed as soon as practicable by the operator.

NCDE-STD-MIN-06. Within the NCDE primary conservation area, if mineral activities have the potential to adversely affect grizzly bears or their habitat as determined by a site-specific analysis, new plans of operation, permits, and/or leases shall include the following mitigation measures regarding motorized access: • public motorized use that is not associated with minerals activities shall be prohibited on motorized routes constructed for exploration and/or development; Not applicable since mineral use/authorization/re-authorization is not a • a traffic management plan shall be developed as part of the component of the Elk Smith project. proposed activity to identify when and how motorized routes will be used, maintained, and monitored (if required) and how motorized route standards and guidelines will be implemented after activities have ended; • helicopter use associated with seismic activity, exploration, drilling, or development must follow an approved plan or permit; and • speed limits shall be adopted on motorized routes if needed to prevent or reduce collisions with grizzly bears.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-STD-MIN-07. Within the NCDE primary conservation area, minerals contractors and lessees shall require employees to attend training related to Not applicable since mineral use/authorization/re-authorization is not a safely living near and working in grizzly bear habitat prior to starting work and component of the Elk Smith project. on an annual basis thereafter.

NCDE-STD-MIN-08. Within the NCDE primary conservation area, new leases Not applicable since mineral use/authorization/re-authorization is not a for leasable minerals shall include a no surface occupancy stipulation (see component of the Elk Smith project. glossary).

NCDE-GDL-MIN-01. Within the NCDE primary conservation area, in addition to forestwide guidelines, the following guidelines apply to new leasable minerals activities, including leases, surface use plans for proposed wells or operations, and permits to conduct seismic exploration or drilling. To reduce potential grizzly bear disturbance or displacement, helicopter use plans should: • avoid establishing recurring helicopter use (see glossary), especially in spring Not applicable since mineral use/authorization/re-authorization is not a habitats or other known important grizzly bear habitats or use areas; and component of the Elk Smith project. • avoid establishing landing zones, especially in spring habitats or other known important grizzly bear habitats or use areas. If a landing zone is deemed necessary for safe implementation of the seismic or surface use plan or permit to drill, the landing zone should be constructed only in an area that has had site-specific analysis and approval.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD)

NCDE-GDL-MIN-02. Within the NCDE primary conservation area, leasable energy activities should use the best available noise-reduction technology on Not applicable since mineral use/authorization/re-authorization is not a equipment and motorized vehicles to reduce potential disturbance or component of the Elk Smith project. displacement of grizzly bears, whenever possible.

NCDE-GDL-MIN-03. Within the NCDE primary conservation area, along motorized routes, seismic corridors, and pipelines constructed for leasable Not applicable since mineral use/authorization/re-authorization is not a energy activities, wildlife cover should be maintained at regular intervals component of the Elk Smith project. where present (this varies on a site-specific basis) in order to provide habitat connectivity for grizzly bears.

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NCDE-GDL-MIN-04. Within the NCDE primary conservation area, for locatable and non-energy leasable minerals activities with the potential to adversely affect the grizzly bear or its habitat (this varies on a site-specific basis), the following tiered measures should be considered to mitigate impacts to grizzly bear habitat. Beginning at step 1, any subsequent steps would be implemented only if the prior steps are not possible or achievable. • Step 1: The operator should reclaim the affected area back to suitable bear habitat that has similar or improved characteristics and qualities compared to the original habitat (such as the same native vegetation). Not applicable since mineral use/authorization/re-authorization is not a • Step 2: If step 1 is not attainable, operators should either acquire a component of the Elk Smith project. perpetual conservation easement (or easements) or purchase comparable or better replacement grizzly bear habitat within the primary conservation area. Acquisition of habitat within connectivity corridors could also be considered for mitigation, when appropriate. Habitat acquired for mitigation may require a purchase rate of > 1:1 on an acreage basis, depending on the quality of habitat degraded and habitat available for acquisition. • Step 3: If steps 1 and 2 are not achievable, the next option is to offset negative effects to bears and grizzly bear habitat with other appropriate types of actions.

NCDE-GDL-MIN-05. Within the NCDE primary conservation area, carrying bear Not applicable since mineral use/authorization/re-authorization is not a deterrent spray should be recommended to mineral permittees, lessees and component of the Elk Smith project. operators to reduce the risk of grizzly bear-human conflicts.

NCDE-GDL-MIN-06. Within the NCDE primary conservation area, available Not applicable since the project does not include any gravel pit use or resources at existing gravel pits should be used before constructing new pits construction.

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Grizzly Bear Amendment Lewis and Clark National Forest Plan Amendment (note that all references are to the Grizzly Bear Amendment ROD) to reduce the risk of grizzly bear disturbance or displacement associated with blasting of rock or crushing of gravel.

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Appendix F: Response to Public Comment

Table 54: Response to Public Comment. Commenter: Larry Brandvold

Comment 1: I oppose prescribed burn in Elk Creek Smith Creek areas. I favor option 1. The area is very slowly recovering and needs time to heal from the 1988 burns that burned so hot the soil was sterilized. Much of the area is simply grass, with no forest re-growth. To burn it again??? Forest Service Response: The purpose of the project may be found in the Purpose and Need for Action section of the Preliminary Analysis. The Proposed Action does not include actions that would target areas that only consist of grass for the introduction of prescribed fire (See Proposed Action and Alternatives and the description of treatments in Appendix B). After very intense burns, soil productivity and biological communities may be reduced as deep as six-inches; however, communities remain largely unchanged beneath the soil surface, and even in very hot burns, some organisms remain, and help aid recovery. Therefore, soils are not truly sterilized. Furthermore, soils may quickly recolonize when high-severity patch sizes are small. Because soils have had approximately 30 years to recover from the Canyon Creek fire, these soils are not sterile. Small patch sizes targeted by project burn activities are likely to have short recovery times and not adversely affect productivity. The soil specialist report was updated to reflect this information in greater detail in the Issues Indicator section.

Comment 2: If hand cutting of trees is required to carry fire, it looks like the goal is to eliminate all timber from the Nation Forest Land. If the lodgepole pine saplings won’t carry fire, then they are naturally fire resistant and provide a break in fuels in the existing condition. No need to re-burn. Forest Service Response: Hand cutting of trees will only occur in six of the proposed units--1, 2, 7, 9, 11, 12. In these select units, conifers will be cut in portions of the units and target young trees that are "encroaching on natural openings and aspen stands." See EA, Table 7: Elk Smith Proposed Treatment Units. These treatments are intended to promote the health and extent of fire-resistant aspen stands, as well as the effectiveness of natural openings as fuel breaks. Under extreme fire conditions, these conifers could burn. Prescribed fire will not be introduced during extreme fire conditions. Cutting these conifers and letting them cure will allow managers to introduce prescribed fire under conditions that are safe for prescribed fire personnel and conducive to effective fire control, while still meeting the objectives of removing conifers that are encroaching on aspen stands and natural openings.

Comment 3: Noxious weeds are a problem following any fires and the forest service has not really stepped up to the plate to control weeds in the past. I question that the funding will follow after the burn to at least make an attempt to keep them somewhat controlled. Funding is always an excuse for not performing and has been used forever for not getting the job done, but look at the fleet around the offices. They cost money!

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Forest Service Response: We share your concern for noxious weeds, however Forest Service funding is outside the scope of this analysis. Please, see the summary under the Noxious Weed Report, on bottom of page 78 and top of page 79, of the Elk Smith Preliminary Analysis. Additionally, specific Project Design Features to reduce the potential for noxious weed introduction and spread are included in Appendix C, on page 169, of the Elk Smith Preliminary Analysis.

Comment 4: Elk don’t appear to use the area and burning more won’t help. Big game animals need cover to use an area like Smith/Elk Cr. Big game animals need a timber canopy for protection just like we need a house or tent! Presently, the fish and game is trying to get elk to utilize the south side of the District instead of utilizing the adjacent private land. Also local ranchers have had 5 grizzlies on their cattle on Elk Creek. The grizzlies are pushed down the drainages by lack of food. And continuous fire does not help with game cover. But, the forests that are heavily infested with lodgepole pine in time do succeed to Doug fir and better big game habitat. It seems that re-burning will just start the vicious cycle over again and loose what cover we are developing. Forest Service Response: A hiding cover analysis was conducted for the project. The Wildlife Report notes that hiding cover would be reduced in 16 of the 18 seventh code watersheds analyzed (page 21). Post-implementation hiding cover would range from 31 to 60 percent, and Forest Plan Standard C-1 (5) is met. Comments from Brent Lonner, FWP biologist, indicated a desire to leave some younger trees for security recruitment (Lonner 2016) and to create a heterogenous landscape.

Comment 5: The goal of self limiting fire is not realistic. Areas on the North Fork Sun have burned three times and the let-burn fires still seem to make it to the easternmost boundaries of the wilderness because grass carries fire very well. Forest Service Response: The term "self-limiting fire" was not used in the Fire, Fuels, and Air Quality Report. However, the report did consider recent scientific literature that analyzed the behavior and effects of fires occurring in recent burn perimeters, as opposed to those that occur on landscapes with little, or no, recent history of fire. One author cited in the Fire, Fuels, and Air Quality Report, page 41, concluded that "wildland fires create fuel breaks and reduce fuel loads and, if fires recur before fuels can recover, the size and severity of subsequent fires are limited." We do not refute this conclusion. We are aware of two Wildland Fires managed for Resource Benefit on the North Fork of the Sun River that have made it to the easternmost boundary of the wilderness: Gates Park, 1988, and Fool Creek, 2007 (both spread beyond the wilderness boundary by long-range spotting originating from in mature conifer stands with no recent fire history). A third Wildland Fire managed for Resource Benefit--Moose Ridge, 2015--spotted into the upper reaches of the South Fork of Deep Creek, which had recently been designated as Wilderness. We agree that grass can carry fire very well given specific environmental conditions, but would add that fire carrying in grass displays far different characteristics than fire burning in other fuel types. For example, it does not exhibit the flame lengths, fireline intensity, or long-range spotting associated with crown fire carrying through conifer stands.

Comment 6: Why do the specialist reports all assume that there is going to be a severe and intense burn under Alternative 1?

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Forest Service Response: Comparisons of the Action and No Action Alternatives were not based on the assumption of a severe and intense burn. See "Sources, Methods, and Assumptions" for the areas of specialty represented in the Elk Smith Project Preliminary Analysis.

Comment 7: The forest service can pursue fire suppression, selective logging, and grazing to reduce the risk of wildfire. Forest Service Response: Grazing can be used as an effective tool to reduce fine fuels which can help limit fire growth/spread in open meadows and timber stands. However, the purpose of this project is to reduce the risk of large wind driven fire in the canopy of dog haired lodgepole regeneration. The Elk Smith Project treatment units are located within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. Tree cutting within inventoried roadless areas is limited to those that are “generally small diameter” (Preliminary Analysis, Roadless Analysis Background and Direction, page 25) for the purpose of reducing “the risk of uncharacteristic wildfire effects.” Mature conifer constitute less than 36 percent of project area and 21 percent of the treatment units (Forest Vegetation Report, Table 2, page 6). The project is designed to retain mature conifer (Preliminary Analysis Appendix C: Project Design Features, Vegetation, page 170). Treatment units are composed predominantly of small diameter (less than 5 inches diameter) conifer which are not merchantable for harvest. The purpose of the project is to address fuel accumulation and continuity created by the 1988 Canyon Creek Fire. In order to mechanically address these issues within treatment units following the Inventoried Roadless Area direction, intermediate thinning of small diameter trees with slash left on site would have to be the treatment. This treatment would add to the current fuel load which would be counterproductive to the project’s purpose. As a result, widespread thinning is not proposed in the Elk Smith Project.

Comment 8: Also, as recommended in the prescribed burn alternative – burn should only be in early spring or late fall, when conditions are right. This also should be the only time for allowing fires for “resource benefit” to burn. They would then be having the best benefit with low intensity, low severity and low risk of spread, which is what a resource benefit fire is supposed to be. Otherwise, active suppression when the fire is small is the best option because the resource benefit fire isn’t within prescription anyway. Forest Service Response: Wildland Fire Use for Resource Benefit (WFURB) is not currently authorized within the Elk Smith Project Area. Wildland Fire Use for Resource Benefit is authorized on lands to the west of the Project Area, in the Scapegoat Wilderness. Decisions to manage wildfires are guided by the Wildland Fire Decision Support System (WFDSS). This is a Risk Informed Decision Process that includes consideration of such factors as the time-of-year of a fire start, proximity to values at risk, Forest Plan direction, potential duration of the fire, and resource availability, among other factors. For more information on WFDSS, visit http://wfdss,usgs.gov/wfdss/WFDSS_Home.shtml

Comment 9: This project analysis is written with a flawed comparison between alternative 1 no action, which is assumed to lead to catastrophe and alternative 2, the proposed action, where man manages the correct way. It really reads like specialists were told what their conclusions should be before they wrote their reports and that no independent thought was allowed. Alternative 1 could be changed to better management, trying some common sense solutions.

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Forest Service Response: Under 36 CFR 220.7(b)(2)(i) and EA shall briefly describe the proposed action and alternatives that meet the need for action. The Elk Smith Preliminary Analysis is the agencies proposal for meeting the purpose and need of the project. In order to establish the need for action and establish a baseline the agency chose to use a no action alternative per 36 CFR 220.7(b)(2)(ii) an EA may document consideration of a no-action alternative through the effects analysis by contrasting the impacts of the proposed action and any alternatives with the current condition and expected future condition if the proposed action were not implemented. Additional alternatives can be developed from public comment.

Commenter: Linda Brandvold

Comment 1: Unfortunately here on the Rocky Mountain front the Chinook southwesterly winds blow fires across recent burns, no matter what the fuel, grass, regeneration, old growth, the fire carries. I believe the wind is the overriding factor. Examples of this on the district are the Elk Hill fire burned through the Hazard lake fire at 2 shacks , the Sheep mountain fire through the Ahorn fire on the south side of Gibson headwaters, the Moose ridge fire thru the Hazard lake fire along Cabin creek and in the Sun River Game preserve where previous fires the Gates Park, Biggs Flat and Redshale had burned. Forest Service Response: Wind is certainly an important factor in the spread of wildfire on the Rocky Mountain Front. However, it is not a factor we can control: "The intensity of wildfire is determined by physical setting, weather, and fuels. Of these three factors, the only one we can modify is fuel (Graham, 2004)." The impact of fuels treatments as they pertain to fire behavior and control are analyzed in the Fire, Fuels, and Air Quality Report (see the Direct and Indirect Effects of the No Action Alternative and the Proposed Action). The benefit of areas of lighter fuel loading is not to eliminate fire from the landscape, but to provide places where fire growth can be limited when it presents an unacceptable risk to safety, private property, or resources. Crews were able to stop the northward progression of the Elk Hill fire by selecting areas of relatively light fuels in the Hazard Lake fire perimeter, constructing fireline, and utilizing bucket drops. Southward progression of the fire was also stopped in the vicinity of Whiskey Creek, in light fuels, utilizing similar tactics. Eastward expansion of the Sheep Mountain fire was successfully controlled in light fuels in the Arsenic drainage, while the fire was unable to sustain eastward growth in the light and discontinuous fuels in the vicinity of Windfall Creek (within the Ahorn fire perimeter). The most active suppression actions on the Moose Ridge Fire were taken at the head of the South Fork of Deep Creek and were successful largely because of the light fuels in the area. We do not dispute that wind, coupled with other environmental factors, can produce fire behavior and growth-even in comparatively light fuels-that is difficult to control. For example, efforts were made to stop the Sheep Mountain fire's eastward expansion using retardant on openings to the west of Sun Butte. Winds in excess of thirty miles an hour grounded aircraft and produced long-range spotting that rendered control efforts ineffective.

Comment 2: As far as “reducing continuous stands of lodgepole pine regeneration”: the units of regeneration in the project area already have spruce-fir in them and are regenerating naturally as a successional forest. Forest Service Response: Page 58 of the Preliminary Analysis indicates that lodgepole pine is the dominant vegetation type established following the Canyon Creek wildfire. Table 2 on page 6 of the vegetation specialist report displays the acres of dominant vegetation by size class within the treatment units based

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on the Region 1 Vegetation Map Products. In the 0 to 4.9 inch diameter class, that which would have regenerated following the last wildfire, lodgepole pine constitutes 96 and 94 percent of the dominant vegetation in the treatment units and project area, respectively. Field review in 2013 (project record) validates the information provided in Region 1 Vegetation Map Products for the treatment unit.

Comment 3: As far as “creating a diverse landscape”: I believe much of the project area has progressed enough in 30 years to have a diverse mosaic landscape. Unit 10 and the west side of unit 12 shows a diversity in tree ages, particularly as older trees protect timbered gullies and the nose of the units. (Refer to Powerpoint Elk Smith unit 10 and 12 photos.) I would eliminate these as re-burning would create more of a monoculture. Forest Service Response: The proposed treatments (pages 8, 28 through 34, and 43 of the Preliminary Analysis) would create openings of 20 to 100 acres across wide-expanses of heavy blowdown and lodgepole pine regeneration, promote regeneration and expansion of quaking aspen where it is present, and remove conifer from natural meadows. Prescribed burning would be targeted in only 30 to 50 percent of the treatment unit leaving 50 to 70 percent in the current condition. In addition, fire ignition would avoid mature (greater than 8 inch diameter) conifer stands greater than five acres in size to maintain structural diversity (Preliminary Analysis Appendix C: Project Design Features, page 170). Hand ignition would also avoid areas with sparse stocking or poor seedling establishment (Preliminary Analysis Appendix C: Project Design Features, page 170).

Comment 4: Unit 9 also has timber fingers in it. Mature trees should not be burning and should be excluded from units. Fingers typically follow the draws. To preserve water quality, draws should not be burned. The benefit of habitat and diversity provided by mature timbered-fingers outweighs the benefits of burning them up as they would have little effect in a catastrophic burn across the landscape, except providing a cooler climate and a wetter zone Forest Service Response: See response to above comment 3. The Hydrology/Fisheries section of Appendix C: Project Design Features on pages 168 and 169 of the Preliminary Analysis lists management actions and restrictions that must be followed within the aquatic management zone along streams and wetlands to avoid or minimize adverse effects to water quality and riparian vegetation.

Comment 5: The North fork of the Sun River at Biggs creek where 1988, 2001, and 2015 fires have carried through the grass, but the drainage holds mature timber intact. The wind blows right over the draw; the trees, moisture and topography protect it. For this reason I recommend eliminating unit 7. It is the headwaters of both Elk creek and Smith Creek. It shows some diversity of landscape and wet areas. (Refer to Powerpoint photo Elk Smith Unit 7- West end.) Forest Service Response: See response to above comments 3 and 4. Page 30 and 165 of the Preliminary Analysis describe the treatment purpose and specifics for Unit 7. The intent of treatment is to maintain natural openings and encourage quaking aspen regeneration and expansion. Based on the Preliminary Analysis’s Project Design Features (page 170), mature timber covering areas larger than five acres would not be targeted for burning.

Comment 6: The basin in Unit 4 (refer to Powerpoint Elk Smith Unit 4 photo 1) has a diversity of trees and age classes, is north-facing and has a moist climate with numerous draws. This more mature and diverse basin should be retained.

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Forest Service Response: Preliminary Analysis, pages 29 and 164, indicates that the purpose of treatment in Unit 4 is to disrupt fuel continuity. The treatment is designed to treat 30 to 50 percent of the conifer regeneration in patches of 20 to100 acres. Heavy surface fuel loads would also be reduced in the 20 to 100 acre patches. The overall focus of treatment in this unit is conifer regeneration and heavy surface fuel loads. Mature timber covering areas larger than 5 acres would not be targeted for burning (Preliminary Analysis, Project Design Features, page 170).

Comment 7: In Unit 3 where the Welcome Cr trail No 214 leaves Jakie Cr and climbs the hill into the Moudess creek basin the trees and age classes are also diverse. I thought that the head of Moudess creek east of Welcome pass was one of the most beautiful basins I’d seen on the front when I rode it in 2004 and 2014. It shouldn’t be further burned in consideration of visual landscape. Forest Service Response: The Roadless/Visuals report considers the effects of the proposed action on sensitive viewing areas and measures whether or not the proposed action meets the visual quality objectives within the project area boundary. Please see this report for further details.

Comment 8: Unit 2, 8 and show a monoculture and are good candidates to burn. Although, again, I recommend protecting riparian areas. This would provide diverse, moist habitat as well as a windbreak. Forest Service Response: See response to above comments 3 and 4. Page 30 and 165 of the Preliminary Analysis describe the treatment purpose and specifics for Unit 7. The intent of treatment is to maintain natural openings and encourage quaking aspen regeneration and expansion. Based on the Preliminary Analysis’s Project Design Features (page 170), mature timber covering areas larger than five acres would not be targeted for burning.

Comment 9: We know all too well how quickly fire spreads across grass in the wind. The thought that “re-creating grass openings makes landscape more resilient to fire” is flawed. The example of the 1988 Gates Park fire, 2002 Biggs Flats fire, the Hazard Lake fire 2005 and the 2015 Moose Ridge fires burning repeatedly through the same Sulfur Hill and Horse Hill grassy knobs and then burning on eastward with the wind, demonstrates that making grass openings doesn’t stop fire. Also the grass openings after the Moose ridge and Elk hill Fire are very dry and cured out and do not look at all resilient. Some springs have dried up after the Moose ridge fire along sulfur creek as well as the creek itself. Forest Service Response: The project is not designed to eliminate the possibility of a fire, it is to create breaks in the continuous stands of doghaired lodgepole regeneration. The native grasses have adapted with fire and the grass openings do provide an opportunity to fight the fire. Please see the Fuels report for a detailed analysis.

Comment 10: Recent studies from the University of British Columbia Department of Ecology and Forestry have found that the older trees have a beneficial effect on the younger trees surrounding them. (The CBC 1 radio broadcast 09/28/2016). This effect comes through the fungus that desires carbon and lives on the interconnected rhizomes that are shared between the trees. The “Elder “trees “encourage” the healthiest, most carbon fixing surrounding young trees to grow better by sending them carbon and other nutrients such as phosphorus and nitrogen. It is therefore extremely important to forest health to

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retain the older trees as well as groups of healthy trees. The research was done on a mix of Douglas-fir and lodgepole pine groups. The old school of thinking of opening up the landscape to encourage sunlight and tree growth is not necessarily the way to encourage healthy forests. I would highly recommend retaining the oldest trees and tree clusters in the project area. According to this research they will grow healthier and protect themselves more than we can ever know or do by man-made vegetative manipulation. Forest Service Response: The project is designed to maintain mature conifer across the treatment units to provide for structural diversity (Preliminary Analysis Appendix C: Project Design Features, Vegetation, page 170). In addition, only 30 to 50 percent of the treatment unit is targeted for prescribed burning which would retain healthy, intact groups of small diameter conifer over the remaining acres (Preliminary Analysis, proposed treatment specifics, pages 8, 28 through 34, and 43).

Comment 11: I would like to request that a carbon study be done on this project by an independent specialist. Trees sequester carbon but presently the Lewis and Clark and Helena are net carbon producers (Forest Plan Revision Existing Condition). Go figure for the Forest Service. Anyway, in light of climate change and the Global and Presidential Initiative to reduce carbon, our forests should be net carbon sinks if we are doing a good job of managing our forests. Forest Service Response: The importance of carbon storage capacity of the world’s forests is tied to their role globally in removing atmospheric carbon that is contributing to ongoing global warming. Meaningful and relevant conclusions on the effects of a relatively minor land management action, such as the Elk Smith Project on global greenhouse gas emissions or global climate change is neither possible nor warranted. Forests are in a continual flux, both emitting carbon into the atmosphere and removing it through photosynthesis. The proposed activities may alter the rates and timing of that flux within the individually-affected forest stands. However, these changes would be localized, miniscule in relation to the role the world’s forests play in climate change, and indistinguishable from the effects of not taking action in the Elk Smith Project area. Therefore, this issue was not addressed further. For additional information, refer to the Forest Carbon Cycling and Storage Report (Doc. CC-01). The potential impacts of climate change on forest ecosystems in the western United States include increases in the frequency and severity of large wildfires and potential rapid growth in forest insect populations and associated tree mortality (Joyce et al. 2008). The Elk Smith Project is designed to address these risks by reducing the potential for large, high-severity wildfires; providing for public and firefighter safety should a wildfire occur in the project area; and decreasing the probability of fires spreading onto private land. Preliminary Analysis, pages 35 through 37 and 174, indicates that the fire analysis area has had a long history of wildfire. Fire size, severity, and frequency influence the quantity of carbon that is naturally released into the atmosphere. The regenerating forests that result, as well as residual mature trees, act as carbon sinks. Based on analysis (Preliminary Analysis, pages 41 and 42), the chance of new ignitions in the project area are at an elevated rate if no action is implemented. No action would lead to increased fire severity over the action alternative. With no action, subsequent wildfire would have increased smoke, live and dead fuel (trees, snags, logs, litter, duff, etc.) consumption, and soil heating. While implementation of the Elk Smith Project would emit carbon, it would lead to reduced carbon emission during a subsequent wildfire compared to the quantity that would be emitted under a higher severity fire following no treatment. In addition, a lower severity fire may retain more live trees (carbon sinks) than a high severity, stand replacement fire. Joyce, L.A. et al. 2008. National Forests. In: Preliminary Review of Adaptation Options for Climate-sensitive Ecosystems and Resources. A Report by the U.S.

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Climate Change Science Program and the Subcommittee on Global Change Research. Washington, D.C., USA. Final Report, Synthesis and Assessment Product 4.4.Silviculture

Comment 12: As far as project impact on others, please notify Augusta seniors as well as outfitter and guides of your proposed action and give them opportunity to comment. Requested is a meeting at the senior citizens center in Augusta. They did not know about the deadline but were extremely interested in prescribed burns in their locality. Posters announcing meetings at the local establishments would be a good idea as many Augusta citizens don’t get the Helena, Great Falls, Fairfield or Choteau papers. Forest Service Response: Public Open House was conducted at the Senior/Youth Center in Augusta on May 6th, 2016. In addition, information was posted in the Newspaper of Record as well as local newspapers, on our Forest projects webpage and at the local ranger district office.

Comment 13: I’m pleased you will be following the Rocky Mountain Ranger District Invasive Plant Management strategy. I have observed that repeated burning encourages more weed infestation. The new burn along Moose Furman trail doesn’t seem to have noxious weeds. Whereas, the repeated burns along the North Fork of the Sun River have bad infestations of Spotted Knapweed as well as Canadian thistle forests. They are not even close to being contained. Please fund for continual week control in your units as part of the project. Units 9 and 11 have mapped concentrations of Noxious weeds. Forest Service Response: We share your concern for noxious weeds. The District is committed to monitoring as described in Appendix F page 179 in order to detect and treat new infestations within the project area. Specific Project Design Features to reduce the potential for noxious weed introduction and spread are included in Appendix C, on page 169, of the Elk Smith Preliminary Analysis. Also, see Appendix F page 179 of the Elk Smith Preliminary Analysis for the monitoring plan.

Commenter: Mike Gilkerson

Comment 1: Controlled burns are the best way to safe guard the forests. Small burns remove the understory and clean the ground. The older Forests were more open and could control fires better, than what has happened over the last 100 years. We have let the forests stagnate tool long and now all we have is large fires. Forest Service Response: Wildland Fire Use for Resource Benefit is another management option available on lands to the west of the Project Area, in the Scapegoat Wilderness. The Project Area, itself, is located immediately adjacent to private lands, private property, and private infrastructure. There are few natural barriers to impede fire moving across the Project Area and threatening values to the east of the National Forest boundary. Prescribed fire holds the potential to reduce the risk subsequent fires pose to firefighter and public safety, as well as private property. Other benefits of the Action Alternative are discussed in the Direct and Indirect Effects and the Cumulative Effects sections of the various Specialist's reports for the Elk Smith Preliminary Analysis.

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Comment 2: Good idea, I hope you can do the controlled burns and reduce the fire potential in the area. Forest Service Response: Thank you for your comment on the Elk Smith Project.

Commenter: Ray Mills

Comment 1: I would like to see activity to reduce deadfall especially with past fires ('88). Forest Service Response: The Action Alternative would reduce deadfall within the perimeter of the Canyon Creek Fire ('88). These actions are identified in Table 5 of the Preliminary Analysis. Unit boundaries are displayed in Figure 7, Appendix A, of the Preliminary Analysis.

Comment 2: I wants to make sure not Rx all at once. Pleased to see we have units identified. Forest Service Response: We do not anticipate implementing the prescribed fire in a single entry. A recent project of comparable acreage--the South Fork Sun Burn--was implemented in three phases. Each phase was completed in a separate year and required multiple days to complete. Phases were completed in 2003, 2009, and 2011. Due to proximity of the Elk Smith Units to private land, implementation will require more phases, or entries, than the South Fork Sun Burn. The Air Quality section of the Fire, Fuels, and Air Report utilized a prescribed fire of 1,500 acres, carried out over a single operational period, for modelling purposes. This input was selected because the author felt it represented "the probable upper-limit for the application of prescribed fire for a given entry."

Comment 3: Overall I'm supportive of the project proposal. Forest Service Response: Thank you for your comment on the Elk Smith Project.

Commenter: Jerry Loomis

Comment 1: The work and science that went into this is phenomenal if not overwhelming. Humans have played God or over 100 years in suppressing wildfires, and in more recent times nearly stopped responsible logging. Now it seems we must play God again and repair the end result of our non- harvesting, fire suppression efforts. Obviously doing nothing is not a good a viable plan for the multitude of reasons and documentation presented. I came away from my reading with a much better understanding of the project and really learned a lot of good information I did not know. Forest Service Response: Thank you for your comment on the Elk Smith Project.

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Comment 2: Are you as well as FWP, US Wildlife service aware of a nesting pair of goshawks on Petty Creek, approximately 0.4 mile downstream of the FS trail 244 crossing the creek? This spot has been in use the past two years and when I pass through it they let me know I am not welcome. Giving them room, excluding that area would be wise. Forest Service Response: This comment refers to the Bailey Basin goshawk territory. Impacts to this pairs habitat was analyzed in the wildlife report (page 13, pages 24-25, pages 34-36). There is a proposed resource protection measure that, if implemented as part of the decision, would reduce disturbance to this pair during nesting.

Comment 3: Disruption of recreational activities would be to expected but I have some concern about conducting any burns during the fall bow hunting season as well as the firearm season. Besides an area outfitter, numerous local hunters (including me) enjoy hunting the whole area. If possible wouldn’t spring, adjusting to weather conditions be more desirable? Forest Service Response: Units identified in the project cover a wide range of elevations, aspects, and fuel characteristics. In general, implementation during spring is more likely to be successful on units at lower elevations, while higher elevations may not meet prescription parameters except during the fall. Overall, prescribed burning on the Rocky Mountain Front is difficult, with acceptable burn windows appearing relatively infrequently. It is not uncommon on the Rocky Mountain Front for prescribed fire managers to wait several years to arrive at the right fuel conditions, combined with an advantageous weather forecast, to safely introduce fire into a single unit. Large landscape-level prescribed burn projects such as Elk-Smith and the South Fork of the Sun can take a decade or more to fully implement. It is likely that adding additional restrictions on burn prescriptions--such as restricting burning to spring to protect hunting opportunity in the fall--would lengthen the time required to implement this project to several decades, or longer. It is our belief that the long-term benefits of this project to public safety, firefighter safety, private property protection, and ecosystem function outweigh the short-term impacts implementation will pose to recreation. We also believe that this project may provide benefits to recreation activities such as hunting and would note that a local outfitter who utilizes the area for hunting has been supportive of the project since its inception.

Comment 4: In units 1 & 2 the project would burn or cut down about 918 combined acres. This sounds like a big chunk of real estate if it all is in one big block (page 161) in the two units (Unit 1 with 546 and Unit 2 with 272 acres). The maps (page 162) presented show a very big area indicating a very small portion of the forest to be treated. My question is besides these do you have other macro maps that would give one a better idea of exactly what parts of each unit would be “treated”? The plan is sound but my concern is in the details and implementation. Please advise if I overlooked more detailed maps. Forest Service Response: The table provided with the Fire, Fuels, and Air Report--Table 7: Elk Smith Proposed Treatment Units--did not specify the percentage of conifers targeted, or the size of patches that would be targeted for prescribed fire. This was an unintended omission. As with other units in the project, treatments in units 1 and 2 will target 30-50% reduction in younger conifers, in patches of 20 to 100 acres. We do have the data to produce a map showing a potential treatment pattern. Such a map was not produced for the Preliminary Analysis because it could be misleading. The map would

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represent a specific pattern of treatment, based on a specific set of environmental variables. It would not be possible to replicate these exact conditions when implementing the project. Perhaps the best way to get a sense of how treatments will look on the landscape is to view past wildfires and prescribed fires that have burned in similar fuels. The project record contains such photo-documentation, and they are available upon request.

Comment 5: What actions will be in place to ensure that any controlled fire treatment does not get out of control? Will there be immediate air support available for fire suppression? If a fire does outrun its desired boundary and takes off wildly, will motorized equipment (cats, ATV’s or other vehicles) be allowed in to attack? Please advise. Forest Service Response: As with all management ignited fires, Prescribed Fire burn plans will be developed for the units in this project. These plans will specify the resources needed to implement and contain the prescribed fire, and identify contingency resources to be utilized if the fires exceed pre-defined Management Action Points. The resources identified will be matched to the complexity of the burn project. For example, aircraft may not be required for a simple blacklining operation. On the other hand, the general ignition of most of these units will require the use of aircraft, both for ignition operations and for use in holding operations. We anticipate that the availability of aviation resources will be essential for the implementation of most of the units identified in this project. ATVs may be utilized in implementing some of the units located near main access roads. Equipment such as fire engines and water tenders may be identified as contingency resources for implementing prescribed fire on some, or all, of the units. For example, engines could be staged along access roads, or at the Forest boundary, when implementing a burn. The use of heavy equipment, such as dozers, would likely be restricted to the vicinity of the National Forest boundary or the vicinity of specific values at risk--such as inholdings or structures.

Comment 6: I was impressed with the depth of considerations given to our native plants, wildlife and visual aspects. I am an area cabin in-holder at Double Falls and have lived through over 45 years of fire seasons. While the Canyon creek fire was the most terrifying, it’s some of the smaller fires that take hold and spread rapidly that I worry most about. Because of my family and my vested interest we support Alternative 2: Do something. Forest Service Response: Thank you for your comment on the Elk Smith Project.

Commenter: Fort Shaw Irrigation District

Comment 1: The Fort Shaw Irrigation District (FSID) adamantly opposes the Forest Service's Elk Smith Project at this time until several items of interest that affect the wellbeing of the FSID water users can be resolved. Although FSID does support some prescribed burns to reduce the chances of catastrophic fires, the Elk Smith project does not take into consideration the major economic benefit agriculture has to the entire Sun River Watershed. Forest Service Response: The Rocky Mountain Ranger District recognizes water is vital to irrigation for agriculture purposes. However, the watershed report discussion of water yield (pg 19) acknowledges that an increase in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not

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discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable. The level of prescribed fire according to watershed analysis indicates available flows should not substantially change.

Comment 2: As part of consultation with other government agencies in the Sun River Watershed, the Forest Service never consulted with the FSID or any other agriculture group on how a project of this magnitude would impact water supply for FSID and its water users over the long-term. In the F.S. planning document it even describes how they met with a hunting group to get their concurrence which FSID does no understand why F.S. did not do the same for another government agency like FSID. Forest Service Response: A public meeting was held in Augusta on May 6, 2016 which all interested parties could attend. And the Rocky Mountain Ranger District personnel were indeed invited by a local area conservation group called, the Sun River Wildlife Team, to present the same information provided during the initial public meeting regarding the Elk/Smith proposal. The Rocky Mountain Ranger District can make similar presentations to other groups when feasible. The presentations did not seek to acquire concurrence from any conservation groups or other entities, as that is not required in accordance with National Environmental Policy Act.

Comment 3: In the Soil and Water section, FSID could not find anywhere there was a review of possible long-term impacts to water supply for agriculture use which is a key economic benefit to this region. Forest Service Response: The Watershed Report discussion of water yield (pg 19) acknowledges that an increased in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable.

Comment 4: In the Land Uses management section, again it does not address the possible long-term impacts to water supply for agriculture use which is a key economic benefit to this region. Forest Service Response: The level of prescribed fire according to the watershed analysis indicates available flow will not substantially change. The is emphasized quite well as a result of the more than likely 10 year time period to fully implement the prescribed fire activities according to prescriptions. As

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previously indicated, changes in flow should not be measureable and therefore impact economics of water availability. See watershed report page 19 in the project record.

Comment 5: Will this project over the long-term actually reduce the long-term risks of catastrophic fires in this region? With this mind-set, then there will need to be the same type of projects throughout the nation on a reoccurring basis. How will this impact the quantity and timing of the annual snowmelt that FSID so depends upon for survival. This type of large scale burning when the trees have not become mature yet does not make sense since some old growth trees is essential to a healthy watershed Forest Service Response: The Watershed Report discussion of water yield (pg 19) acknowledges that an increased in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable.

Comment 6: As FSID reviews the entire document, there is no mention of agriculture benefits or impacts which is just as important as wildlife, fisheries, aesthetics, plant diversity, or any other benefit mentioned in the plan. Forest Service Response: The Elk Smith project was looked at from a number of resource areas, the range resource section does discuss the direct, indirect and cumulative impacts of the proposed treatment units on permitted livestock. The level of prescribed fire planned for ignition according to the watershed analysis indicates available flows should not substantially change, and hence not impede other agriculture land uses outside of the National Forest Service lands.

Commenter: Greensfield Irrigation District

Comment 1: Erosion, and subsequently water quality, are issues which are directly related to deforestation and loss of ground cover. The Elk-Smith Project Preliminary Analysis document fails to adequately assess the long-term environmental impact that these burns will have regarding progressive soil erosion and sedimentation; and the promotion thereof. Forest Service Response: The Soil Specialist Report acknowledges that increased erosion is a risk of project activities due to diminished ground cover and physical changes in soil structure. Long- and short-term erosion increases are predicted using Water Erosion Prediction Project modeling (see pg 6 of specialist report, data contained in the watershed folder in the project record), and the model predicted that a 10-year storm event would generate a maximum increase of 0.21 tons of sediment per acre within the first 5 years of project implementation. Because tolerable soil loss is generally recognized to

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be 1-2 tons of sediment per acre annually, these results indicate that there is a very low risk that project activities would result in detrimental erosion increases. Furthermore, by staggering burns over time and limiting the extent of high severity burns, ground cover is expected to recover fully and leave only a small portion of the watershed susceptible to erosion at any point in time.

Comment 2: In theory , water supply or overall basin runoff yields will be impaired as a result of a loss of the forest canopy. Tree stands, regardless of maturity, shelter snow packs from the devastating effect of sublimation. Warm, dry winds can decimate and diminish the snow water content of snow packs thereby decreasing the quantity of water or basin yield. Irrigation districts such as GID rely exclusively on the amount of water emanating from the mountains to satisfy our water rights. The Elk-Smith Project Preliminary Analysis document fails to adequately assess or quantify the long-term environmental and economic impacts that the proposed burns will have on the loss of water availability and basin yield due to increased sublimation. Forest Service Response: The Watershed Report discussion of water yield (pg 19) acknowledges that an increased in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable.

Comment 3: The timing of water runoff from the watershed impacts the ability of irrigation districts to store and utilize water in accordance with their water rights. Premature or accelerated runoff results in a significant loss of water with respect to irrigation as reservoirs quickly fill and spill before the irrigation season peaks. The practice of deforestation and loss of forest canopy results in premature and accelerated runoff events as the exposed snow pack is subjected to increased radiant and convective heating which promotes warming and "ripening" of the snow pack thus promoting and accelerating runoff. The result is a net loss of water that we have historically used under our water right. The Elk-Smith Project Preliminary Analysis document fails to adequately predict and quantify the long-term environmental and economic impacts that the proposed burns will have by causing premature and accelerated runoff patterns. Forest Service Response: The Watershed Report discussion of water yield (pg 19) acknowledges that an increased in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable.

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Comment 4: Upon our review the analysis document , there is no reference or consideration of agriculture benefits or impacts. Protection of the water rights and the water users are just as important as wildlife, fisheries, aesthetics, plant diversity, or any other benefit mentioned in the analysis. Greenfields Irrigation District and the US Bureau of Reclamation are the largest water right holders in the Sun River Basin. The long-term success of irrigation agriculture in the Basin is dependent upon the quantity and quality of this water which in turn is directly related to and a function of the management of the watershed. The economic impact of irrigated agriculture in the region is significant. Yet neither GID, the Reclamation nor other irrigation district were identified as being listed as groups that were consulted or contacted in preparation of the Elk-Smith Project Preliminary Analysis document. However, it is my understanding that FS staffers met with a hunting group to get their concurrence and that two Indian tribes , without an actual physical presence in the Sun River Basin, were contacted for input. Really? Forest Service Response: The Watershed Report discussion of water yield (pg 19) acknowledges that an increased in water yield could occur after prescribed fires due to diminished ground cover. Research has shown that at least 25 percent of a watershed would have to be treated to show any measurable increase in runoff. The timing of runoff was not discussed. However, approximately 23 to 24 percent of the Elk Smith and the Upper Smith Creek drainages are proposed to be treated. The project would occur over a 10 year period, therefore 2 to 5 percent of the watersheds would be treated in any given year. Therefore, the watershed analysis has shown that there is a low probability there will be a measurable change in water yield and difficult to determine. Therefore, the change in timing of the runoff as a result of the project would also be indeterminable. Native American Tribes with traditional interest in the area were consulted as required by law as part of Section 106 of the National Historic Preservation Act (codified in 36CFR800) and per the Forest Service Manual 1560 on a government-to-government level. Forest Service Manual 1563.01c contains an inclusive list of all the laws and Executive Orders that require consultation with Native American Tribes.

Commenter: Benjamin Pierce

Comment 1: We will want assurances and conditions in place to make absolutely sure that none of the fires ignited by the USFS burn out onto any of our private lands. Much of our current ownership burned in 1988 and it is still trying to heal back up and much timber value was lost on our private lands. We need to make sure this does not happen again from fires lit by the USFS. Forest Service Response: We acknowledge your concern for private lands and the risk associated with prescribed burning. The Elk Smith Project was proposed because we believe that introducing prescribed fire in the near future represents less risk to private property and firefighter safety than attempting to suppress a large wildfire in the Elk and Smith Creek drainages under current and projected fuel conditions. In the event wildfire does occur in the area following the completion of the project, we believe efforts to protect private property to the east and north of the Project Area will have a higher probability of success. Prescribed fire plans are required for all management ignited fires. These plans specify the weather and fuel conditions under which burning can occur, along with resources needed to implement and control the burn, as well as specifying contingency resources. Careful planning can

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reduce, but not eliminate risk. We hope that communication of our intentions to burn, the conditions under which we are burning, and the resources we will use to burn will help assure adjacent landowners that the risk of using prescribed fire has been reduced to an acceptable level.

Comment 2: I believe it is your intent not to cut or burn any mature stands of timber that survived the last fire and we would not want to see any visual impacts or thinning/burning on the little remaining mature stands in the area especially in Areas 1, 2, and 3 along Petty and Smith drainages. Forest Service Response: The Roadless/Visuals report considers the effects of the proposed action on sensitive viewing areas and measures whether or not the proposed action meets the visual quality objectives within the project area boundary. Please see this report for further details.

Comment 3: It is important to us that no new weeds are added to the ecosystem as a result of this process as we currently invest heavily in weed reduction on our lands downwind and to the east of USFS lands. Forest Service Response: We share your concern for noxious weeds and thank you for the efforts that you take on your private lands. Please, see the summary under the Noxious Weed Report, on bottom of page 78 and top of page 79, of the Elk Smith Preliminary Analysis. Additionally, specific Project Design Features to reduce the potential for noxious weed introduction and spread are included in Appendix C, on page 169, of the Elk Smith Preliminary Analysis.

Comment 4: It will be important to respect current ROW agreements across our lands if they are utilized for this project and we appreciate your current efforts to improve signage along trails on our private grounds. Forest Service Response: The Forest Service will respect legal requirements of ROW and will make any request for anticipated variances to landowners and not proceed outside of ROW requirements unless documented approval is provided by affected landowners.

Comment 5: It is important to us that the treated areas continue to look “natural” after the treatments. Forest Service Response: The Roadless/Visuals report considers the effects of the proposed action on sensitive viewing areas and measures whether or not the proposed action meets the visual quality objectives within the project area boundary. In addition, page 9 of the Specialist report speaks directly to the effects the proposed action on the Natural Character of the Inventoried Roadless Area. Please see this report for further details.

Commenter: Native Ecosystem Council and Alliance for the Wild Rockies

Comment 1: This is a massive impact on wildlife habitat within an IRA (BMSS). The project area is 24, 1 l 4 acres (Draft EA at 58). The proposal includes 15 burn units for a total of 10,331 acres within this IRA, with 43% of wildlife habitat in the project area being burned. The draft EA does not address why this proposal does not violate the Road less Area Conservation Rule (RACR). There are two serious problems with compliance with this Rule, the first being

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management to reduce natural fires in IRAs, and the second the planned destruction of habitat for 2 threatened species within the IRA. There is no allowance, as far as we are aware, of a management emphasis i n IRA to prevent fires with fuels reduction projects. The draft analysis does not define why the proposed burning areas contain "unnatural concentrations" of fuels. Dense stands of young lodgepole pine are a natural response to fire, and is why this species is clearly adapted to fire. What are the criteria the agency used to identify that the dense young lodgepole pine stands resulting from the 1988 fire are unnatural and require management intervention? Since one of the prime ecological values for IRAs is protection of agency management actions, the Forest Service has fallen far short of demonstrating that the proposed burning is needed to restore unnatural conditions. We believe this project is a clear violation of the RACR, and should not go forward. Forest Service Response: The Roadless/Visuals report considers the effects of the proposed action on the Wilderness Attributes and Roadless Characteristics within the Inventoried Roadless Areas the overlap the project area boundary. Please see this report for further details. In addition, both the Fuels and Silvicultural specialist reports discuss the existing condition of the timber stands within the project area. The purpose and need of the project discusses why there is a need for action within the Elk Smith project area.

Comment 2: The effect of the proposed burning in this IRA on hiding cover were not actually disclosed in the EA. The reduction of hiding cover in this IRA is clearly not beneficial to any wildlife, including mule deer, elk, grizzly bears and lynx. The agency needs to clearly define the current and proposed levels of hiding cover, including as measured by patch size. If patches of hiding cover are going to be burned out, the remaining "fragments" have to be a minimum size as per the current best science (at least 600 feet wide) to still provide cover. There are several telling photos in the preliminary analysis that indicate that hiding cover in this landscape is VERY sparse. For example, the cover photo showing a small portion of the entire landscape does not contain any hiding cover. Figure 5 in the EA at 85 shows that about the only hiding cover in this landscape is the dense, young lodgepole stands that have regenerated from the 1988 fire, or are about 28 years old. Forest Service Response: Page 5 of the wildlife report (page 22 of Preliminary Analysis) lists the Forest-wide standards for wildlife that includes C-1 (5) to require a big-game cover analysis of projects involving significant vegetation removal to ensure that effective hiding cover is maintained." That analysis was conducted per Forest process (USDA Forest Service 2016a). The existing effective hiding cover is described on page 12 of the wildlife report (page 128 of the Preliminary Analysis) under elk. The effects to hiding cover are described on pages 21-22 (pages 137-138 of Preliminary Analysis).

Comment 3: The effect of the proposed burning in this IRA on hiding cover were not actually disclosed in the EA. The reduction of hiding cover in this IRA is clearly not beneficial to any wildlife, including mule deer, elk, grizzly bears and lynx. The agency needs to clearly define the current and proposed levels of hiding cover, including as measured by patch size. If patches of hiding cover are going to be burned out, the remaining "fragments" have to be a minimum size as per the current best science (at least 600 feet wide) to still provide cover. There are several telling photos in the draft analysis that indicate that hiding cover in this landscape is VERY sparse. For example, the cover photo showing a small portion of the entire landscape does not contain any hiding cover. Figure 5 in the EA at 85 shows that about the only hiding cover in this landscape is the dense, young lodgepole stands that have regenerated from the

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1988 fire, or are about 28 years old. Yet these are being targeted for burning. In addition, photo 5 in the EA at 60 shows that a burned stand comprised of many snags does not actually provide any hiding cover due to a lack of any regeneration in the understory. Overall, the project area seems pretty devoid of hiding cover. Yet the proposed burning of dense young lodgepole stands that currently provide hiding cover is 7,437 acres (draft EA at 126, for stand initiation habitat for lynx), or on 3 l% of the 21, 1 14 acre project area. The project proposal includes burning 3,877 acres of these dense sapling stands (draft EA at 134). This would bring identified hiding cover in this project area down to 3,560 acres, or 15% of the project area. Thus the project would remove about half of the known, existing hiding cover, even though it is already severely reduced from the 1988 fire. The rationale for this ongoing removal of wildlife hiding cover is never justified in the analysis. Why is something like 15% hiding cover better for wildlife than somewhere around 30% cover? Why is there too much cover for elk, mule deer, grizzly bears and lynx, so that cover removal will benefit these species? Forest Service Response: A hiding cover analysis was conducted for the project. The Wildlife Report notes that hiding cover would be reduced in 16 of the 18 seventh code watersheds analyzed (page 21 of the wildlife report, page 137 of the Preliminary Analysis). Post-implementation hiding cover would range from 31 to 60 percent, and Forest Plan Standard C-1 (5) is met. A total of 2,818 acres of effective hiding cover will be removed by the project (pages 33-34). A loss of cover for all wildlife species was noted at page 14. Effects of reduced cover to species is discussed on pages 21-22 (Preliminary Analysis Page 137- 138), and page 24 (Preliminary Analysis page 140).

Comment 4: The analysis did not define why project impacts to lynx would be beneficial, as well as necessary for ecosystem management of this IRA. There will be a significant increase in unsuitable lynx habitat with this project. The NRLMD ROD defines "unsuitable habitat" for lynx as the early stand initiation stage when trees are too short to extend above the snow in the winter (ROD at 9, ROD glossary at 12). This project will increase unsuitable lynx habitat from the existing level of 1613 acres, or 6% of the project area, to 3839 acres, or 16% of the project area. Why is a doubling of lynx unsuitable habitat in critical habitat considered an insignificant impact? Forest Service Response: The analysis did not claim the project would be beneficial to lynx. Impacts to lynx habitat were analyzed on pages 10-11 (Pages 126-127 of Preliminary Analysis), pages 18-19 (pages 134-135 of Preliminary analysis) and page 33. The proposed action would increase early stand initiation and other lynx habitat, and decrease stand initiation and stem exclusion. The amount of mature, multi-story habitat would not be altered. The primary constituent elements of lynx critical habitat are boreal forest landscapes with a) snowshoe hare presence and habitat, b) deep fluffy snow, c) denning sites with coarse woody debris, and d) matrix habitat. The effects of the project on the primary constituent elements of critical habitat are described on pages 19- 20 of the wildlife report (page 134-135 pf Preliminary Analysis).

Comment 5: Also, the analysis did not explain why the reduction of suitable lynx habitat in the stand initiation stage would be beneficial to lynx. Simply saying it will meet the NRLMD direction does not imply a benefit for actions within this IRA. There are currently 7,437 acres of stand initiation habitat, or suitable lynx summer habitat, in the project area (analysis at 126). There will be 3877 acres of this habitat removed with burning. Thus the suitable stand

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initiation habitat will be reduced from 31% of the project area down to 15%, or by about half. The analysis does not explain by I 5% stand initiation habitat i s more beneficial to lynx than 31% stand initiation habitat, including within critical habitat. Forest Service Response: Page 18 of the wildlife report (page 134 of the Preliminary Analysis) describes the changes in lynx habitat. The proposed action would result in 36% of the lynx habitat in the stand initiation structural stage that provides both summer and winter snowshoe hare habitat, and no change in the limited amount of mature, multistoried habitat currently available.

Comment 6: The analysis also claims that the NRLMD standards for VEG S2 and S5 do not apply to the project. VEG S2 defines impacts by "timber management (NRLM D ROD Attachment at 3). VEG S5 restricts pre-commercial thinning to protect suitable lynx habitat. Id. Although the NRLMD has never been programmatically assessed for impacts in lynx critical habitat, it clearly also is inapplicable to the proposed project because it arbitrarily exempts prescribed burning project from any protection and management of lynx habitat. It is illogical to define conservation measures for lynx only by timber harvest, and not burning activities, which have the same impact to remove suitable lynx habitat. The NRLMD ROD at 41 states that the greatest threats to lynx persistence and reproduction are from changes in vegetation structures that provide snowshoe hare habitat during summer and winter. To then limit such impacts to only those triggered by timber harvest is illogical. Forest Service Response: Per the Northern Rockies Lynx Management Direction "Standard Veg S2 applies to all timber management projects…" (USDA Forest Service 2007) and the glossary states "timber management consists of growing, tending, commercially harvesting, and regenerating crops of trees" The Elk Smith project is not a timber management project. The purpose and need is to address fuel accumulation as described on page 7 of the Preliminary Analysis. Standard Veg S5 "applies to all pre-commercial thinning projects..." defined as mechanically removing trees to reduce stocking and concentrate growth on the remaining trees...” Although the standards do not apply, the effects of these actions (pre-commercial thinning and prescribed burning) on lynx habitat are analyzed (Wildlife report pages 18-19, Preliminary Analysis pages 134-135).

Comment 7: The VEG2 standard in the NRLMD will be violated with this project, which is a Forest Plan as well as an ESA violation. The VEG2 standard requires that no more than 15% unsuitable lynx habitat be created within a 10 year period. The project area contains 13, 1 62 acres of lynx habitat (analysis at 126, 134). The unsuitable acres of this lynx habitat are currently 1613 acres, or 12%. The project would increase these unsuitable acres with the burning of 3877 acres of suitable lynx habitat i n young regenerating lodgepole pine stands, to 5490 acres. These would constitute 42% unsuitable lynx critical habitat, or an increase of 30% over a 10-year period. This is double the allowance of the NRLMD. Thus as per the habitat conservation measures in the NRLMD, this project would have a significant adverse impact on lynx, even if it were not critical habitat. Forest Service Response: The primary constituent elements of lynx critical habitat are boreal forest landscapes with a) snowshoe hare presence and habitat, b) deep fluffy snow, c) denning sites with coarse woody debris, and d) matrix habitat. The effects of the project on the primary constituent elements of critical habitat are described on pages 19-20 of the wildlife report (pages 135-136 of the Preliminary Analysis). The proposed action would not result in changes to deep fluffy snow. There will be a reduction in snowshoe hare habitat, from 71 percent of the lynx habitat to 67 percent five years post-

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implementation (wildlife report page 19, Preliminary Analysis page 135). More of the hare habitat would be available only during the summer, with 39 percent of the lynx habitat remaining as hare habitat available in both summer and winter (page 33 of wildlife report). Although some coarse woody debris would be removed, denning habitat would remain well distributed. Matrix habitat would remain available for movement. See wildlife report pages 18-20 (Preliminary Analysis pages 134-136). Consultation with USDI Fish and Wildlife Service will be completed prior to a decision on this project.

Comment 8: The proposed temporary removal of lynx suitable habitat on 29% of the lynx habitat in the project area (3,877 acres) for 20-30 years is a violation of the ESA because this habitat has been identified as critical habitat. The level of suitable lynx habitat on lynx habitat in the Project Area will be reduced by halt from 31% to 15%. . Also, the increase in unsuitable lynx critical habitat from 7% to 16% of lynx habitat in the project area, will double the amount in the project area, which is also a significant change is habitat availability for lynx. This project clearly violates the ESA for both lynx habitat and critical habitat. Forest Service Response: The primary constituent elements of lynx critical habitat are boreal forest landscapes with a) snowshoe hare presence and habitat, b) deep fluffy snow, c) denning sites with coarse woody debris, and d) matrix habitat. The effects of the project on the primary constituent elements of critical habitat are described on pages 19-20 of the wildlife report (pages 135-136 of the Preliminary Analysis). The proposed action would not result in changes to deep fluffy snow. There will be a reduction in snowshoe hare habitat, from 71 percent of the lynx habitat to 67 percent five years post- implementation (wildlife report page 19, Preliminary Analysis page 135). More of the hare habitat would be available only during the summer, with 39 percent of the lynx habitat remaining as hare habitat available in both summer and winter (page 33 of wildlife report). Although some coarse woody debris would be removed, denning habitat would remain well distributed. Matrix habitat would remain available for movement. See wildlife report pages 18-20 (Preliminary Analysis pages 134-136). Consultation with USDI Fish and Wildlife Service will be completed prior to a decision on this project.

Comment 9: The analysis does not define the adherence to the 19119/68 direction for grizzly bears, especially the 68% core habitat in this MS 1 landscape. For 10 years, this core habitat will be disturbed, not only with slashing of smaller trees and cutting of trees up to 16 inches dbh, but with creation of firelines and helicopter ignition. There is not analysis in the EA about why this does not violate the requirements for grizzly bear core habitat, or as a result, how much core habitat will be reduced over the 10 year life of this project. Why isn't this information provided? Disturbances appear to be significant, not only because they will occur in spring bear habitat, but because human activities will be considerable. The analysis indicates that 7544 acres will require aerial ignition with helicopters. No data is provided to indicate this will not displace grizzly bears from spring bear habitat. Control of the fire will require up to 5 days, with 20 people per day for various activities for each unit; op up will require 2-3 days with 1- 3 people. There are 1 5 units, so each unit will trigger extensive human activities. The time required for hand slashing is not identified, as is cutting trees under 16 inches dbh. The slashing will occur one year, while burning will occur during a different year, so there will be multiple disturbances per unit over several years. This clearly will not maintain core habitat, since there will be displacement of grizzly bears in each unit for several years. With all the units located adjacent to one another, the disturbance impacts of one unit will most likely affect adjacent un its, to that the cumulative disturbance per unit may be quite a few years. In addition, these disturbances will be staggered over time, given that burn windows each spring are only 102 periods in the spring. Staggered disturbances will make it even more difficult for

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grizzly bears to track where these are occurring in core habitat. These burning disturbances are never evaluated in the analysis as to how much grizzly bear core habitat will be removed for I0 years. Forest Service Response: Page 17 of the wildlife report, first paragraph, states that there would be no change to Core because there is no proposed change to motorized route access. The duration of potential disturbance and effects to bears is described on pages 17-18 of the wildlife report.

Comment 10: There is no actual measurement of hiding cover in the project area, or how it will be affected by the cover removal project. The agency needs to define why a significant reduction in hiding cover for grizzly bears is a benefit as per the current best science. Forest Service Response: The effective hiding cover in the project area is described on page 12 of the wildlife report, with effects analyzed on pages 21-22. Additional information of the importance of hiding cover to grizzly bear in this landscape, and effects to that cover, were added to the wildlife report.

Comment 11: The project will "maintain" 2767 acres of openings, supposedly as a benefit to grizzly bears. There was no analysis as to why existing levels of hiding cover are adequate so that development of more cover is not important for grizzly bears. Forest Service Response: See above on hiding cover for grizzlies

Comment 12: The analysis frequently 'suggests' that burning will increase forage for grizzly bears, but if this is actually the case, then why isn't the existing forage in the 1988 burn area considered adequate and super abundant? It is not clear how the agency determined that more grizzly bear forage is needed at the expense of hiding cover. At a minimum, the agency needs to identify the grizzly bear plant species that occur in the existing burned openings to show that forage values increase for bears after burning. What species are these? Citing vegetation changes from other geographic areas does not demonstrate why burning is a benefit to grizzly bear forage in the project area. It has been 28 years since the fire, plenty of time for some monitoring of grizzly bear foods and habitat use of this landscape. Forest Service Response: Page 10 of the wildlife report states, "The project area provides little habitat for grizzlies in its current condition as the dense forest does not provide foraging habitat, nor does it provide for travel or access to den sites." Pages 15 to 16 of the wildlife report describes the effects to the forage availability.

Comment 13: The spring burning is clearly an adverse impact on the grizzly bear, and the analysis indicates that spring burning is the preferred treatment period for half of the units (1 , 2, 7, 9, 1 1, 12, 13, 14) units for 5181 acres. There is a planned spring burning on 4,688 acres, all of which is in MS 1 grizzly bear habitat. This is clearly a violation of MS 1 direction, as the burning is not needed for grizzly bears, and thus should not take priori ty over bears. Forest Service Response: Page 16 of the wildlife report discusses burning in MS-1 spring habitat.

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Comment 14: This is clearly a fuels reduction project, where wildlife habitat that is fuels is slated for removal. As is noted in the analysis at 37 and 43, there is extensive regeneration of lodgepole pi ne throughout the project area, as well as high volumes of downed logs and standing snags. The fire hazard is noted to have peaked at this time, or about 25 years after the 1988 fire. The analysis are 42 claims that fuels reduction is necessary because fire in this IRA is a threat to human life and property. The analysis at 47 states that this project is needed to create safety zones and escape routes (maybe for wildlife???); fuel breaks will be creates in areas where management actions might limit the progress of wildfire west to east due to winds; with fuels reduction activities, the agency will be able to implement more fire control strategies, such as anchor point for fire lines, and conducting burnouts. The analysis at 48 notes that with fuels reduction activities, the agency will be able to catch spot fires to slow the fire spread; they will be able to manage fires when they pose an unacceptable risk to private property and human life. The conclusion for these fuels treatment action is that they will enhance agency efforts to suppress and control fire. In spite of all these justifications for fuels management in this IRA, grizzly bear MS I habitat, and critical lynx habitat, the analysis never defines why fire control is necessary. Making fire control easier is the clear objective, yet the need for fire control in the first place remains unknown. Clearly there is not human safety factor in this IRA. And protection of adjacent private structures does not require massive fuels reductions in the IRA. Forest Service Response: The Fire, Fuels, and Air Report indicates that fire hazard peaks around 25 years following a fire. This increased hazard persists "until moderating approximately 85 years following the fire (Lotan 1985)." The need for fire control in the Project Area is based on its immediate proximity to private lands, property, and infrastructure. For this reason, Wildland Fire Use for Resource Benefit not authorized in the Project Area. In addition, the majority of the Project Area is identified as Wildland Urban Interface in the Tri-County Regional Community Wildfire Protection Plan. Fires igniting in those portions of the Project Area that are outside of designated Wildland Urban Interface will have a high potential to spread into the Wildland Urban Interface. With the close proximity of private property, dwellings, and infrastructure, any wildfire igniting in the Project Area is likely to be considered "unwanted" and elicit a full suppression response. The treatments proposed will enhance the safety and increase the likelihood for success of fire personnel who are engaged in fire suppression in the Project Area.

Comment 15: The analysis notes at 48 that these fuels reduction treatments will destroy and remove any conifer seed sources, since trees will be burned and killed. It is not clear why this should be a purpose for action. Does this mean that the agency is planning on converting these forested lands to grasslands? This is a huge impact of the proposed burning that is never addressed in the analysis. How will these burned areas regenerate in the future if there are no seed sources? Why would a Jong-term removal of forest stands be a benefit to wildlife in this IRA? The agency needs to provide a thorough analysis of how this burning will affect recruitment of new trees in burned areas. Forest Service Response: The purpose and need for the project is described in the Introduction and Purpose Statement section of the Preliminary Analysis (page 7). The main purpose is to address fuel accumulation and continuity in the project area following the 1988 Canyon Creek Fire. Preliminary Analysis page 10 further discusses the intent of the Elk Smith Project to address fuel load in an efficient and effective manner while reducing risk to human health and safety. The unit specific treatment purpose and actions are described on pages 8, 28 through 34, and 43 of the Preliminary Analysis. The Elk Smith project does not plan to convert forest land to grassland. Approximately 30 to 50 percent of treatment units may have stand-replacement burns between 20

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and 100 acres in size. Mature conifer and expanses of regeneration would remain untouched on 50 to 70 percent of the unit (Preliminary Analysis, page 44). The prescribed burn would reduce accumulated coarse woody debris following the 1988 Canyon Creek fire and dense stands of lodgepole pine regeneration. Regeneration in newly burned areas would occur within a few years if serotinous cones are present or gradually over time if relying on non-serotinous cones in adjacent stands. Preliminary Analysis, pages 60 through 63, describes predicted stand development over time. Based on the National Forest Management Act’s direction to maintain forest land in appropriate forest cover, post-treatment stocking surveys will be completed to monitor reforestation progress (Preliminary Analysis, page 64).

Comment 16: The analysis notes repeatedly that the burning will reduce downed logs which provide habitat for countless wildlife species. The analysis at 63 notes that treatments will consume 25-60% of the downed logs. Why is this considered a benefit in an IRA for wildlife? Forest Service Response: The reduction of downed logs was never stated to be a benefit. The effects of the loss of 25-60 percent of downed wood within treatment units is described on page 19 for lynx and page 22 for black bear.

Comment 17: The analysis at 48 notes that the effectiveness of this fuels reduction will be about 2 decades. Does this mean that at that time, the objective wilI again be to remove these new young trees because they are fuels? This seems to indicate that the agency considers these trees as nothing more than fuels that need to be continually removed. This is a direct contradiction of the purpose of the project that claims that these burns will allow future natural fires to be allowed in this landscape. Forest Service Response: The Fire, Fuels, and Air Report does not predict what actions might, or might not, be required to manage fuels within the project area in twenty years’ time. The report does discuss the significant limitations to predicting future disturbance events, with their impacts to fuel conditions, over time. The report also proposes that fuel conditions be monitored over time, and after disturbance events (Page 48).

Comment 18: We would like the agency to provide more information on the other prescribed burning programs that have occurred in the landscape, as the 16,000 acre South Fork Sun prescribed fire north and west of the Elk Smith Creek project. Please map all past treatments in the Unit 3 lynx critical habitat, and the bear subunits that include the Elk Smith Creek project area. Al so, please define what the habitat loss has been for lynx in these other burns, especially on impacts to hares. Also, what has been the impact on grizzly bear core habitat in the affected subunits? The cumulative impacts of past and planned burning on both lynx and grizzly bears was clearly ignored by the Elk Smith analysis, and needs to be corrected. Forest Service Response: Cumulative impacts for lynx were analyzed at the scale of Lynx Analysis Unit RM-25, as all treatments occur within this Lynx Analysis Unit (Wildlife report page 25). Additional information on prescribed burning in Unit 3 of lynx Designated Critical Habitat and the Scapegoat and South Fork Willow subunits was added to the wildlife report cumulative effects section.

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Comment 19: The analysis did acknowledge that the Benchmark project includes over 700 acres of additional spring burning in grizzly bear habitat. Yet there is no actual measure of how this burning, along with burning in the Elk Smith project, will impact spring bear use. Forest Service Response: The cumulative effects are discussed on page 25 of the wildlife report (page 141 of the Preliminary Analysis). The cumulative effects of the Benchmark III Fuels Reduction Project are discussed on this page.

Comment 20: The analysis at 58 notes that there are many areas in the 1988 burn that remain unstocked. Given this, why are stocked areas being burned to eliminate trees? Why instead isn't there a program to replant unstocked areas? In addition, since many acres are planned to burn early stand initiation acres, to kill any existing trees, why is this increase in unstacked lands considered necessary in this IRA? This program seems like a tree destruction project because trees only qualify as fuels, not wildlife habitat!. Forest Service Response: Page 58 of Preliminary Analysis states that due to various environmental factors 22 percent of the 0 to 4.9 inch diameter class within treatment units is currently in a non-stocked condition. These acres represent 14 percent of the total treatment unit acres and 6 percent of the project area and contribute to landscape diversity. Non-stocked or poorly stocked stands are part of the complex, post-disturbance, structural variability and may be the result of low cone serotiny and/or local fire severity (Turner et al. 2016). These areas have a healthy herbaceous and/or shrub component with minimal to no conifer establish at this time. The Direct and Indirect Effects sections for both the No Action and the Proposed Action alternatives (Preliminary Analysis pages 60 through 62) discuss the projected development of non-stocked to fully stocked stands through time. Gradual tree recruitment from non- serotinous cones is expected to occur in the currently understocked stands (Turner et al. 2016). In order to meet National Forest Management Act requirements of maintaining appropriate forest cover, stocking surveys would be completed following project implementation (Preliminary Analysis page 64). If post-treatment stand conditions are not meeting the silvicultural prescription stocking standard, additional treatments may be prescribed. The purpose of the project is to “address fuel accumulation and continuity in the project area” (Preliminary Analysis, page 7) which is present outside the non- stocked areas. The proposed treatments (pages 8, 28 through 34, and 43 of the Preliminary Analysis) would create openings of 20 to 100 acres across wide- expanses of heavy blowdown and lodgepole pine regeneration, promote regeneration and expansion of quaking aspen where it is present, and remove conifer from natural meadows. Prescribed burning would be targeted in only 30 to 50 percent of the treatment unit to reduce fuel accumulation and reduce stand density leaving 50 to 70 percent in the current condition. In addition, fire ignition would avoid mature (greater than 8 inch diameter) conifer stands greater than five acres in size to maintain structural diversity (Preliminary Analysis Appendix C: Project Design Features, page 170). Hand ignition would also avoid areas with sparse stocking or poor seedling establishment (Preliminary Analysis Appendix C: Project Design Features, page 170). Implementation of the proposed project would meet the objectives described in the Purpose Statement (Preliminary Analysis, page 7). Turner, M.G.; Whitby, T.G.; Tinker, D.B.; and Romme, W.H. 2016. Twenty-four years after the Yellowstone Fires: Are post-fire lodgepole pine stands converging in structure and function? Ecology 97(5):1260-1273.

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Comment 21: It is not clear exactly how many trees of whitebark pine and limber pine are planned for destruction. The analysis suggests these trees are incidental to the project, but no actual analysis of provided. Both tree species are extremely valuable to wild life, and destruction of these in never recommended, let alone in an IRA where many such trees have already been burned up in the 1988 fire. Forest Service Response: The document at 126 states "The project area provides little habitat for grizzlies in its current condition as the dense forest does not provide foraging habitat, nor does it provide for travel or access to den sites." On page 122, under sources, methods and assumptions, it states a "determination of habitat within the analysis area was made using personal knowledge and field surveys of the proposed treatment areas..."

Comment 22: The analysis at 126 claims that this project area, although it is identified as MS 1 habitat, has no actual value to grizzly bears for travel, foraging or denning habitat. The data to indicate there is no grizzly bear use of this project area, however, was never provided. How has it been determined that this area does not receive any grizzly bear use? Forest Service Response: The document at 126 states "The project area provides little habitat for grizzlies in its current condition as the dense forest does not provide foraging habitat, nor does it provide for travel or access to den sites." On page 122, under sources, methods and assumptions, it states a "determination of habitat within the analysis area was made using personal knowledge and field surveys of the proposed treatment areas..."

Comment 23: The project area include 1360 acres of elk winter range, and 9164 acre of elk calving habitat. It is not clear why burning of 7,437 acres of hiding cover will benefit elk winter range of calving habitat. There is no actual analysis of management criteria for either habitat, or why burning is part of this management strategy. What are the goals for these habitats, what are the current conditions, and why is treatment needed to meet objectives? What science indicates burning of these areas will benefit elk? The project will burn 391 acres of elk winter range (Unit 1), and 927 acres of elk calving habitat (units 1-7). Why does cover removal in these areas benefit elk? Forest Service Response: Pages 21-22 of the wildlife report describe the effects of the proposed action on elk habitat.

Comment 24: There is also a cumulative effect of treating elk winter range due to the Benchmark project, where 293 acres of winter range will be burned. The overall management goals for this burning of elk winter range were not identified in the analysis, except for a brief notation that pine grass will increase with burning. The science that supports this beneficial claim was not cited. Forest Service Response: Page 26 of the wildlife report (page 144 of the Preliminary Analysis) describes the cumulative impact. The overall goal of the project is to reduce fuels within the project area, as described in detail in the purpose and need section of the preliminary analysis (Page 7 of the Preliminary Analysis). The overall goal is not to create elk habitat. As noted, the analysis shows what the effect to elk would be both within the project area and cumulatively.

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Comment 25: The project area also include 2488 acres of mu le deer winter range. There will be 390 acres of this winter range treated (removed with burning, in unit 1, plus 67 acres in units 1 1-12. The science and monitoring that indicates this will benefit mule deer was never provided. Nor was any information provided on what the specific habitat goals are for mule deer on this winter range, and why burning will help achieve these objectives. Forest Service Response: Page 22 of the wildlife report describes the impacts to mule deer winter range.

Comment 26: Isn't it a coincidence that a project with the goal of reducing fuels will also benefit both elk and deer winter range??? Given this is in an IRA, the agency needs to provide the science that demonstrates that management actions in this IRA are necessary for mule deer, a forest MIS, as well as MIS elk. Forest Service Response: See pages 144 and 145 for information on the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area and its associated management area designations including emphasis on wildlife species and habitats.

Comment 27: The analysis falsely claims at 137 that elk security will not change with the project. It is impossible that the removal of 3887 acres of high quality hiding cover will not impact elk security as per the Hillis Paradigm. A correct analysis of security, which includes blocks of contiguous hiding cover at least 250 acres in size, needs to be provided. Elk security will clearly be reduced, both currently and in the future, with this project, so this adverse impact needs to be fully disclosed to the public, as well as information as to why this benefits wildlife habitat in the IRA. Forest Service Response: Elk security is defined by Hillis (and others 1991) as areas greater than 250 acres in size and greater than 0.5 miles from an open road. More recent literature also uses distance from open motorized routes to determine elk security (Ranglack et. al. unpublished). Habitat effectiveness (Lyon 1983) is based entirely on open road density. Because there are no proposed changes to motorized routes, there would be no changes to elk security or habitat effectiveness, the proposed action would increase the heterogeneity of the area thereby providing a more diverse prey base for this generalist species. This clarification will be included in the wildlife report and Environmental Assessment.

Comment 28: Elk security is defined by Hillis (and others 1991) as areas greater than 250 acres in size and greater than 0.5 miles from an open road. More recent literature also uses distance from open motorized routes to determine elk security (Ranglack and others, unpublished). Habitat effectiveness (Lyon 1983) is based entirely on open road density. Because there are no proposed changes to motorized routes, there would be no changes to elk security or habitat effectiveness, the proposed action would increase the heterogeneity of the area thereby providing a more diverse prey base for this generalist species. This clarification will be included in the wildlife report and EA. Forest Service Response: The analysis at page 130 of the EA is referring to the no action alternative effects to wildlife. It states the "no action alternative may affect, but is not likely to adversely affect, grizzly bear, Canada lynx, and Canada Lynx Designated Critical Habitat. There would be no effect to wolverine

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or its habitat. “The preliminary analysis did not include a determination call for grizzly bear, lynx, lynx critical habitat or wolverine. The determination for the decision will be made when the Biological Assessment is completed and consultation requested.

Comment 29: Please summarize the acres of stand initiation habitat that have been or will be pre-commercially thinned or prescribed burned in the LAU that is most affected by this project, as well as adjacent LAUs, so that the agency's management of key lynx foraging habitat that is also critical habitat can be identified as per cumulative impacts. Forest Service Response: The spreadsheet UNIONlynxAnalysis2016data.xlsx summarizes Lynx Analysis Unit acres by structural stage for RM-25 and the adjacent Lynx Analysis Units. All proposed actions are within RM-25, and this is the extent of the cumulative effects analysis. The existing condition includes past activities, and there are no other present or reasonable foreseeable activities in RM-25 (see wildlife report page 25)

Literature Cited from the Public During the Objection Comment Period

Objector: Native Ecosystems Council

Literature Citation #1: Berg, N. E. Gese, J. Squires, and L. Aubry. 2012. Influence Of Forest Structure On The Abundance Of Snowshoe Hares In Western Wyoming. Journal of Wildlife Management 76:1480-1488. This study is not cited in the BA however other more recent studies cited in the BA represent similar findings. The applicability of this study to the Elk Smith project is limited due to the largely homogeneous habitat conditions of the projects area, over 50% stand initiation lynx habitat within the project area due to 1988 fire, as compared to the multiple habitat types included in the Wyoming study area. The study did find the greatest hare abundance in late seral multi-story stands and dense 30-70 year old regenerating lodgepole pine stands which is consistent with the habitat descriptions and the effects analysis relative to snowshoe hare habitat as described in the project BA.

Literature Citation #2: Brittell, J., R. Poelker, S. Sweeney, and G. Koehler. 1989. Native cats of Washington. Wash. Dept. of Wildlife, Olympia. 169 pp. In Lynx (Felis lynx) biology and management: a literature review and annotated bibliography. USDA Forest Service, Northern Region. 1992. Literature was cited but not provided by the objector for our review.

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Literature Citation #3: Cheng, E., K. Hodges, and L. Mills. 2015. Impacts of fire on snowshoe hares in Glacier National Park, Montana, USA. Fire Ecology Volume 11, Issue 2, 2015. Literature was cited but not provided by the objector for our review.

Literature Citation #4: Burt, W. 1964. A Field Guide To The Mammals. Houghton Mifflin company Boston. This brief (< 1 page), very general, 55 year old field guide description of lynx does not represent the best available scientific information on lynx and has very little relevance to the project.

Literature Citation #5: Gehman, S. 2010. Wildlife of the Gallatin Mountains, southcentral Montana. Wild Things Unlimited, Bozeman, MT. This is not really applicable since it’s well outside of the project area.

Literature Citation #6: Griffin, P. 2004. Landscape Ecology Of Snowshoe Hares In Montana. Ph.D. Thesis, University of Montana, Missoula. The Elk Smith Wildlife Report states that background information for all species is found in the “Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities” (USDA Forest Service 2011) which is in the project record. This citation is in that document therefore it’s incorporated by reference to Elk Smith.

Literature Citation #7: Griffin, P. and L. Mills. 2007. Precommercial Thinning Reduces Snowshoe Hare Abundance In The Short Term. Journal of Wildlife Management 71 :559- 564. This literature is not specifically referenced in the Biological Assessment and although the proposed action does not include pre-commercial thinning, the BA does acknowledge that the proposed slashing and prescribed burning would have effects upon snowshoe hare and lynx foraging similar to the findings of the study.

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Literature Citation #8 Holbrook, J., J. Squires, L. Olson, N. DeCesare, and R. Lawrence. 2017a. Understanding And Predicting Habitat For Wildlife Conservation: The Case Of Canada Lynx At The Range Periphery. Ecosphere 8:e01939. Paper was used and cited in the Biological Assessment

Literature Citation #9 Holbrook, J., J. Squires, B. Bollenbacher, R. Graham, L. Olson, G. Hanvey, S. Jackson, and R. Lawrence. 2018. Spatio-temperal responses of Canada lynx (Lynx canadensis) to silvicultural treatments in the Northern Rockies, U.S. Forest Ecology and Management 422:114-124. Paper was used and cited in the Biological Assessment

Literature Citation #10 Holbrook, J., J. Squires, L. Olson, R. Lawrence, and S. Savage. 2017b. Multi-scale Habitat Relationships Of Snowshoe Hares (Lepus americanus) In The Mixed Conifer Landscape Of The Northern Rockies, USA: Cross-Scale Effects Of Horizontal Cover With Implications For Forest Management. Ecology and Evolution 7:125-144. Paper was used and cited in the Biological Assessment

Literature Citation #11 Kosterman, M. 2014. Correlates of Canada lynx reproductive success in Northwestern Montana. MS Thesis, University of Montana, Missoula. Paper was used and cited in the Biological Assessment

Literature Citation #12 Kosterman, M., J. Squires, J. Holbrook, D. Pletcher, and M. Hebblewhite. 2018. Forest Structure Provides The Income For Reproductive Success In A Southern Population Of Canada lynx. Ecological Applications 28:1032-1043. Paper was used and cited in the Biological Assessment

Literature Citation #13

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Lewis, C., K. Hodges, G. Koehler, and L. Mills. 2011. Influence of stand and landscape features on snowshoe hare abundance in fragmented forests. Journal of Mammalogy 92:561-567. This study is not cited in the BA but has limited applicability to the Elk Smith project due to the largely homogeneous habitat conditions, over 50% stand initiation lynx habitat within project area due to 1988 fire. The project design promotes the retention of the remaining pockets of multi-story habitats while focuses treatments in stand initiation habitats to promote habitat diversity across the project area.

Literature Citation #14 McDaniel, G., K. McKelvey, and L. Ruggiero. 2004. Micro-Scale Habitat Use Of Snowshoe Hares In Eastern Idaho, Including A Comparison Between Telemetry And Pellet Counts. USDA Forest Service, Rocky Mountain Research Station, Missoula, MT. This study found seasonal variations between summer and winter hare habitat use based on pellet counts and telemetry locations suggesting that the juxtaposition of habitats may be important. As described in the BA, the existing condition of the project area is largely a homogeneous stand initiation structural stage with only scattered pockets of mature habitat resulting from the 1988 fire. Although the paper is not cited in the BA the project design would improve habitat diversity and distribution providing better seasonal habitat variation for hares over time as described in the paper.

Literature Citation #15 McKelvey, K. and G. McDaniel. 2001. An analysis of snowshoe hare (Lepus americanus) numbers in Island Park based on pellet sampling and capture/recapture trapping. USDA Forest Service, Rocky Mountain Research Station, Missoula, MT. This paper evolved from the same study as citation #14 with greater focus on hare use of young regenerating lodgepole stands and the impacts upon hare use associated with thinning. This paper is not cited in the BA and has limited applicability to the Elk Smith project due to the largely even aged lodgepole pine regeneration resulting from the 1988 fire. The study found the greatest hare use in unthinned lodgepole stands 15-25 years of age and based on overall findings the authors predicted these stands would be unproductive hare habitat in another 10-15 years. Based on the findings of this study, the 30 year old lodgepole regeneration in the project area is near the end of providing productive snowshoe hare habitat and the proposed project treatments would promote development of young regenerating stands of hare habitat. The effects analysis of the BA does reflect that hare habitat would decline in the short term due to slashing and burning treatments.

Literature Citation #16 Squires, J., L. Ruggiero, J. Kolbe, and N. Decesare. 2006. Lynx Ecology In The Intermountain West: Research Program Summary Summer, 2006. USDA Forest Service Rocky Mountain Research Station, Missoula, MT.

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The literature provided includes one page on mortality factors to lynx which has limited application to the Elk Smith project. The paper identifies mortality causes of collared lynx as trapping and shooting, predation, starvation, and unknown causes. The objector does not correlate how project activities may directly contribute to lynx mortality therefore the relevance of the paper to the project is uncertain.

Literature Citation #17 Squires, J., and L. Ruggiero. 2007. Winter prey selection of Canada lynx in Northwestern Montana. Journal of Wildlife Management 71: 310-315. The Elk Smith Wildlife Report states that background information for all species is found in the “Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities” (USDA Forest Service 2011) which is in the project record. This citation is in that document therefore it’s incorporated by reference to Elk Smith.

Literature Citation #18 Squires, J. 2007. April 5, 2007 response to information request by Sara Johnson in regards to comments on the LCAS for lynx management; included Dr. Squire's comments to Jim Claar on September 27, 2002 in regards to a review of the Lynx Conservation Assessment and Strategy. The Northern Rockies Lynx Management Direction (NRLMD) amended Forest Plans in 2007, replacing the LCAS as current lynx management direction. The BA addresses consistency with the NRLMD (USDA 2007) and comments on the LCAS are not relevant to the Elk Smith project.

Literature Citation #19 Squires, J. 2009. Letter to Carly Walker, Rural Landscape Scientist, Missoula County Rural Initiative, Missoula County, MT. Letter has limited applicability to the Elk Smith project. The questions (by C. Lewis) and responses (by J. Squires) in the letter are specific to lynx populations and habitat conditions in the Seeley Lake area which provide very different habitat conditions than the Elk Smith project area. Squires does state that the level of forest thinning and fragmentation in the Seeley area in the past five years (prior to 2009) is of concern and that the lynx population in that area may be declining. Along the eastern front where the Elk Smith project occurs however, lynx habitat is much lower quality, very little development is occurring, and forest management activities are minimal therefore the content of the letter has very limited correlation with this project.

Literature Citation #20 Squires, J. 2015. Personal communication to participants of a BLM field trip to the Garnet Mountains on June 9, 2015. Literature was not provided by the objector for review.

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Literature Citation #21 USDA. 2011. Flathead National Forest Hungry Horse-Glacier View Ranger Districts Consultation Records: wildlife council meeting notes December 8 - 9/2010, Holiday Inn Parkside, Missoula. 1/31/2011. The notes provide a brief summary of the findings of lynx research conducted west of the continental divide by John Squires of the Rocky Mountain Research Station but do not provide any new information that would change the effects analysis of the Elk Smith BA.

Literature Citation #22 Vanbianchi, C., M. Murphy, and K. Hodges. 2016. Canada lynx use of burned areas: conservation implications of changing fire regimes. Ecology and Evolution 2017:1-13; DOI: 10.1002/ece3.2824. Literature was not provided by the objector for review.

Literature Citation #23 USDA. 1994. The Scientific Basis For Conserving Forest Carnivores, American Marten, Fish, Lynx And Wolverine. Chapter 5. USDA Forest Service Rocky Mountain Forest and Range Experiment Station. General Technical Report RM-254. Literature was not provided by the objector for review.

Literature Citation #24 Gehnman, S., K. Baughan, and B. Robinson. 2014. Snow-Tracking Surveys On The Helena National Forest December 2012-March 2013. Wild Things Unlimited. This is not really applicable since this is a report on surveys conducted well outside of the Elk Smith project area.

Objector: Alliance for the Wild Rockies

Literature Cited #1: Baker, William, 2009; Fire Ecology in Rocky Mountain Landscapes. Island Press, Washington, D.C. USA. Comments provided by objector emphasized portions of Barker’s book that discussed low frequency and high severity fires occurring in subalpine forests. This fire regime, or rotation, does not accurately reflect conditions on the Rocky Mountain Ranger District. For example, the objector underscored that “Dr.

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Baker estimates the high severity fire rotation to be 135-280 years for lodgepole forests.” The Elk Smith Environmental Assessment gave precedence “to articles and studies that considered fire and fuels in close geographic proximity to the Project Area, or in areas displaying similar fuel, fire history, weather and topography (EA, page 39).” The Elk Smith Environmental Assessment also benefitted from the Rocky Mountain Ranger District National Forest Management Act Analysis, 2010. This Analysis included a fine-grained consideration of the Fire History, Historic Fire Regimes, and Fire Regime Condition Class that covers the entire Elk Smith Project Area and was also grounded in sources relevant to the Southern Half of the Rocky Mountain Ranger District (RMRD NFMA Analysis, pages 45-53). The studies consulted in the EA, were consistent in characterizing the area as burning much more frequently and exhibiting a far wider range of variation than the high severity, long-rotation described by Baker (see EA, page 38): “Research and analysis suggests that this particular landscape experienced fires of moderate severity on a return interval of approximately 35 to 100 years, with most literature indicating this return closer to 35 years than 100 years (Arno, 1980; Gabriel, 1976; Gruell, 1983; Lotan, 1985; RMRD NFMA, 2010).” The Rocky Mountain Ranger District National Forest Management Act Analysis, 2010, only assigns 8% of the Rocky Mountain Ranger District South as being characterized as Fire Regime V (200+-year frequency and high severity). The majority of the southern portion of the District is included in Fire Regime III (35 to 100+ year frequency and mixed – severity). In short, the relevance of Dr. Baker’s work on high severity/low frequency fire rotations to the Elk Smith Project Area are limited compared to studies and research that consider the unique characteristics of vegetation, fire history, and fire ecology of the project area and its immediate environments.

Literature Cited #2: Schoennagel, T., Veblen, T., Romme, W., 2004. The Interaction of Fire, Fuels, and Climate across Rocky Mountain Forests. BioScience Volume 54, Issue 7, pages 661-676 Literature not provided by objector. Found at https://academic.oup.com/bioscience/article/54/7/661/223530 Objector directed the Forest Service to this paper which focused on subalpine forests characterized by fires of high severity and long fire interval. Schoennagel’s journal article includes case-studies of the Yellowstone fires of 1988, and the 2002 Rodeo-Chediski and Hayman Fires. These fires are geographically distant from the Elk Smith Project Area. The Elk Smith Environmental Assessment gave precedence “to articles and studies that considered fire and fuels in close geographic proximity to the Project Area, or in areas displaying similar fuel, fire history, weather and topography (EA, page 39).” The high-severity fires and long fire-return intervals of the areas that inform Schoennagel’s conclusions are in sharp contrast with the fire regimes and fire severity typical on the Rocky Mountain Ranger District and across the Bob Marshall Wilderness Complex (see EA, page 38): “Research and analysis suggests that this particular landscape experienced fires of moderate severity on a return interval of approximately 35 to 100 years, with most literature indicating this return closer to 35 years than 100 years (Arno, 1980; Gabriel, 1976; Gruell, 1983; Lotan, 1985; RMRD NFMA, 2010).” In her analysis, Schoennagel acknowledges the variability in fire regimes across the Rocky Mountain landscape as transitions occur in such features as vegetation, aspect, and elevation. She cautions that her conclusions are based on generalization: “In this summary, we assume a one-to-one correspondence between forest types and fire

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regimes; however, as we emphasize throughout this text, this is a considerable oversimplification.” The geographic separation of Schoennagel’s work from the Elk Smith Project Area, combined with the article’s emphasis on high-severity fire regimes, limited the relevance of this study to the Elk Smith Project.

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Appendix G: Literature Cited 16 U.S.C. 36 §§1600 et seq. 1988. “National Forest Management Act of 1976,” as amended.

Agee, J. K. and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest Ecology and Management 211: 83–96.

Agee, J.K. 1998. The landscape ecology of Western forest fire regimes. Northwest Science. 72(Spec. issue): 24–34.

Agricultural Handbook 701, Landscape Aesthetics: A Handbook for Scenery Management.

AirNow, 2016. Particle Pollution (PM). [Online] March 2016. www.airnow.gov/index.cfm?action=aqibasics.particle

Allen, C.D., A.K. Macalady, H. Chenchouni, D. Bachelet, N. McDowell, M. Vennetier, and N. Cobb. 2010. A global overview of drought and heat-induced tree mortality reveals emerging climate change risks for forests. Forest Ecology and Management 259: 660–684.

Anderson, Michelle. 2006. Salix exigua. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: USDA Forest Service Fire Effects Information System [2016, July 6].

Anderson-Teixeira, K.J., A.D. Miller, J.E. Mohan, T.W. Hudiburg, B.D. Duval, and E.H. DeLucia. 2013. Altered dynamics of forest recovery under a changing climate. Global Change Biology 19: 2001– 2021.

Arkle, Robert S.; Pilliod, David S.; Welty, Justin L. 2012. Pattern and Process of Prescribed Fire Influence Effectiveness at Reducing Wildfire Severity in Dry Coniferous Forests. Forest Ecology and Management 276, 2012, 11 p.

Aune, K., & Kasworm, W. F. 1989. East Front grizzly bear study; final report. Montana Department Fish, Wildlife and Parks. Helena, Montana.

Ayres, H.B. Lewis and Clark Forest Reserve, Montana. 21st Annual Report, Part V, U.S. Department of Interior, Geological Survey, 1900, 27-80.

Baker, William L. Fire Ecology in Rocky Mountain Landscapes. Island Press, Washington, Covelo and London, 2009, 605 pp.

Barrett, S.W. 1995. Regional silviculture of the United States. John Wiley & Sons. 643 p.

Baxter, C.V. and F.R. Hauer. 2000. Geomorphology, hyporheic exchange, and selection of spawning habitat by bull trout (Salvelinus confluentus). Can. J. Fish. Aquat. Sci 57: 1470-1481.

Beschta, R.L. and W.S. Platts. 1986. Morphological features of small streams: Significance and Function. Water Resources Bulletin, American Water Resources Association. Vol. 22, No. 3, p. 369-379.

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Beshta, R.L. and W.L. Jackson. 1979. The intrusion of fine sediments into a stable gravel bed. J. Fish. Res. Board Can. 36: 204-210.

Bighorn Sheep — Ovis canadensis. Montana Field Guide. Montana Natural Heritage Program and Montana Fish, Wildlife and Parks. Retrieved on July 5, 2016, from Montana Field Guide - Bighorn Sheep

Birdsey, R, Dugan, A, Healey, S, Dante-Wood, K, Zhang, F, Chen, J, Hernandez, A, Raymond, C, McCarter, J. In press. Assessment of the influence of disturbance, management activities, and environmental factors on carbon stocks of United States National Forests. Fort Collins, Colorado: Gen. Tech. Report RM-xxx.

BONAP. 2016. The biota of North America program: North America vascular flora. Available from: http://www.bonap.org.

Boon, Sarah. 2007. Snow accumulations and ablation in beetle-killed pine stands in Northern Interior British Columbia. BC Journal of Ecosystems and Management 8(3):1-13. http://www.forrex.org/publications/jem/ISS42/vol8_no3_art1.pdf

Bosch, J.M. and Hewlett, J.D. 1982. A review of catchment experiments to determine the effects of vegetation changes on water yield and evapotranspiration. Journal of Hydrology, 55(1982) 3-23. Elsevier Scientific Publishing Company, Amsterdam Netherlands.

Brewer, L.T., R. Bush, J.E. Canfield, and A.R. Dohmen. 2009. Northern Goshawk Northern Region Overview, Key Findings and Project Considerations. USDA Forest Service, Northern Region, Missoula, MT, USA. December.

Chadwick, Amy C. 2002. Carex geyeri. In: Fire Effects Information System, [Online]. U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station, Fire Sciences Laboratory (Producer). Available: USDA Forest Service Fire Effects Information System [2016, July 6].

Copeland, J.P., K.S. McKelvey, K.B. Aubry, A. Landa, J. Persson, R.M. Inman, J. Krebs, E. Lofroth, H. Golden, J.R. Squires, A. Magoun, M.K. Schwartz, J. Wilmot, C.L. Copeland, R.E. Yates, I. Kojola, and R. May. 2010. The bioclimatic envelope of the wolverine (Gulo gulo): do climatic constraints limit its geographic distribution? Canadian Journal of Zoology 88: 233-246.

Crane, M.F.; Habeck, J.R.; Fischer, W.C. 1983. Early postfire revegetation in a western Montana Douglas-fir forest. Research Paper INT-319. Ogden, UT: U.S. Department of Agriculture, Forest Service, Intermountain Forest and Range Experiment Station. 29 p.

D’Amato, A.W., J.B. Bradford, S. Fraver, and B.J. Palik. 2011. Forest management for mitigation and adaptation to climate change: Insights from long-term silviculture experiments. Forest Ecology and Management 262: 803–816.

Daly, C., G.H. Taylor, W.P. Gibson, T.W. Parzybok, G.L. Johnson, and P.A. Pasteris. 2000. High-quality spatial climate data sets for the United States and beyond. American Society of Agricultural Engineers 43, no. 6 1957–62.

DeBano, Leonard F., Daniel G. Neary, and Peter F. Folliott. 1998. Fire’s Effects on Ecosystems. John Wiley & Sons, New York.

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Domke, G.M., C.H. Perry, B.F. Walters, L.E. Nave, C.W. Woodall, and C.W. Swanston. 2017. Toward inventory-based estimates of soil organic carbon in forests of the United States. Ecological Applications 27: 1223-1235.

Dunham, J.G., M.K. Young, R.E. Gresswell, B.E. Rieman. 2003. Effects of fire on fish populations: landscape perspectives on persistence of native fishes and nonnative fish invasions. Forest Elcology and Management 178 (2003) 183-196. doi:10.1016/S0378-1127(03)00061-6

Elliot, W.J., D.E. Hall, and D.L. Scheele. 2000. Disturbed WEPP: WEPP interface for disturbed forest and range runoff, erosion, and sediment delivery. Technical Documentation. USDA Forest Service, Rocky Mountain Research Station and San Dimas Technology and Development Center. Draft, February 2000.

Executive Order 13186 of January 10, 2001. Responsibilities of Federal Agencies to Protect Migratory Birds. Federal Register Volume 66, Number 11, page 3853 to 3856.

FAOSTAT. 2013. FAOSTAT database. Food and Agriculture Organization of the United Nations, available at http://faostat.fao.org/.

Farnes, Phillip. 2005. Sun River Water Management Analysis Part 2. Snowcap Hydrology, P.O. Prepared for the Sun River Watershed Group, Box 169, Bozeman Monatan 59771-0691.

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