Decision Memo North Bridgers Forest Health Project U.S. Forest Service Bozeman Ranger District Custer Gallatin, MT

Douglas Fir trees showing signs of western spruce budworm defoliation and mortality from Douglas Fir Beetle within the Project Area. North Bridger Forest Health Project

Table of Contents Background and Purpose & Need ...... 3 Conditions Observed in the Project Area...... 5 Vegetation Conditions ...... 5 Douglas-fir bark beetle (Dendroctonus pseudotsugae) ...... 5 Western spruce budworm (Choristoneura freeman) ...... 6 Mountain pine beetle (Dendroctonus ponderosae) and lodgepole pine dwarf mistletoe (Arceuthobium americanum) ...... 6 Root rots: Tomentosus (Onnia tomentosa) and schweinitzii (Phaeolus schweinitzii) ...... 6 Aspen Health ...... 7 Wildland Urban Interface ...... 7 Purpose and Need for Action ...... 8 Decision ...... 8 Project Activities ...... 8 Decision Rationale ...... 11 Considerations Based on Collaborative Input, Interdisciplinary Project Development and/or Scoping ...... 11 Extraordinary Circumstances ...... 16 Canada Lynx ...... 17 North American Wolverine ...... 17 Peregrine Falcon ...... 18 Black-Backed Woodpecker ...... 18 Flammulated Owl...... 18 Gray Wolf ...... 19 Yellowstone Cutthroat Trout ...... 19 Western Boreal Toad ...... 20 Northern Leopard Frog ...... 20 Whitebark Pine...... 20 Other Plant Species ...... 20 Other Wildlife and Aquatic Species Considerations ...... 21 Collaboration, Scoping and Public Involvement ...... 23 Collaboration see Smith Creek ...... 23 Scoping & Public Involvement ...... 25 Applicable Categorical Exclusion...... 25 Background ...... 25 Insect & Disease Infestation Categorical Exclusion ...... 26 Findings Related To Other Laws and Regulations ...... 27 National Forest Management Act ...... 27 Endangered Species Act ...... 31 Migratory Bird Treaty Act and Executive Order 13186 ...... 32 Bald and Golden Eagle Protection Act ...... 33 State Water Quality Standards and Clean Water Act ...... 33 Clean Air Act (CAA) ...... 34 Healthy Forest Restoration Act (HFRA) ...... 34 National Historic Preservation Act (NHPA) ...... 34

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Environmental Justice Executive Order...... 35 Administrative Review Opportunities ...... 35 Implementation Date ...... 36 References Cited ...... 37 Appendix A - Design Features, Mitigation and Monitoring ...... A-1 Appendix B - Vegetation Management Treatment Descriptions and Summary ...... B-1

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BACKGROUND AND PURPOSE & NEED The North Bridger Forest Health Project is located approximately 13 miles northeast of Bozeman, MT in the Bridger Mountains (see Figure 1: Project Vicinity Map). The project area is approximately 10,200 acres in size. Activities are proposed on approximately 2,300 acres. The project area lies entirely within Gallatin County in Montana. Specifically, the project lies within the following township and range sections: T2N R6E Sections 22, 23, 24, 26, 27, 35, 36; T2N R7E Sections 30-32; T1N R6E Sections 11, 12, 13, 24; T1N R7E Sections 5, 7, 8, 9, 14, 16, 18, 20-23 . While there are non-Forest Service lands within the vicinity and surrounded by the project area, activities proposed for this project will only occur on National Forest System (NFS) lands.

Figure 1. Vicinity Map of the Project Area.

The North Bridger Forest Health project area was designated as part of an insect and disease treatment program in accordance with Title VI, Section 602, of the Healthy Forest Restoration Act (HFRA), as amended by Section 8204 of the Agriculture Act (Farm Bill) of 2014. For additional information on how the 2014 Farm Bill amended HFRA and areas designated, see the

— Decision Memo — Page 3 North Bridger Forest Health Project project webpage at https://www.fs.usda.gov/project/?project=48493. To be designated, areas must be:  Experiencing declining forest health, based on annual forest health surveys conducted by the Secretary; or  At risk of experiencing substantially increased tree mortality over the next 15 years due to insect or disease infestation based on the most recent National Insect and Disease Risk Map published by the Forest Service; or  In an area in which the risk of hazard trees poses an imminent risk to public infrastructure, health or safety. The project area is located within the wildland urban interface (WUI) as defined in the Gallatin County Community Wildfire Protection Plan (GC CWPP-2006). The majority of proposed treatments are bordered by a private land boundary within ½ - 1 miles.

The treatment units are within Management Areas (MA) 1, 7, 8, 9, 11, 12, 16 and 99 which were assigned in the Gallatin Forest Plan (as amended 2015). Direction in those MA’s and the Forest- wide direction applies to National Forest Service (NFS) lands where activities are proposed in the project area, • MA1 - Developed Recreation Sites such as campgrounds. Maintain these sites for the safety and enjoyment of users. Permit vegetative management to provide diverse vegetative patterns and remove hazard trees. • MA7 - Riparian Areas. Manage the riparian resource to protect the soil, water, vegetation, fish and wildlife dependent upon it. • MA8 - Provide for productive timber stands and optimize timber growing potential. • MA9 - Suitable timber lands which have dispersed recreation value and are visually sensitive. • MA11- Forested big game habitat in productive forest lands that are available for timber harvest provided that big game habitat objectives are met. • MA12 - Maintain and improve the vegetative condition to provide habitat for a diversity of wildlife species and dispersed recreation opportunities. Unsuitable for timber production but harvest is programmed as needed to meet multiple resource objectives other than for timber production. • MA16 - Maintain or improve vegetative conditions and forage production for livestock use. Classified as unsuitable for timber production but harvest is programmed as needed to meet multiple resource objectives other than for timber production. • MA99 - MA 99 are lands that have been acquired since the Forest Plan was published. The treatment units in MA 99 were evaluated with adjacent management areas. Proposed actions in MA99 comply with Forest wide standards and are consistent with the adjacent MA (8 and 9) direction. (Lewellen_Memo_ 2018).

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CONDITIONS OBSERVED IN THE PROJECT AREA

VEGETATION CONDITIONS During the summers of 2016 and 2017, a silviculturist surveyed stands in the project area to assess the severity and types of insects and diseases impacting the stands, as well as assessing hazardous fuel conditions. A silviculture crew conducted exams to evaluate old growth conditions and general stand condition. Additionally, in June 2016 a forest pathologist and forest entomologist from the Missoula Field Office of the U.S. Forest Service Northern Region Forest Health Protection Group visited the project area to observe and document forest health conditions (Egan and Lockman 2016). Areas were reviewed for past insect and disease activity, as well as for 10 year projections based on current conditions and anticipated climate trends. The following conclusions were made based on the observations.

Douglas-fir bark beetle (Dendroctonus pseudotsugae)

Past Douglas-fir bark beetle (DFB) activity has caused mortality in the project area as shown in Figure 2. National Forest Insect and Disease Risk Assessment data show that as much as 90% of the Douglas-fir in the project area is at a size and density that is moderately to highly susceptible to DFB attack (Egan and Lockman, 2016). There is also the potential for a severe and widespread DFB outbreak. Vegetation within the project area is susceptible to further insect activity based on conditions observed.

Figure 2. These photos were taken near Battle Ridge. The forest stands show signs of mortality and defoliation from Douglas Fir Beetle and Western Spruce budworm.

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Western spruce budworm (Choristoneura freeman)

This area has experienced persistent insect activity including a western spruce budworm (WSB) outbreak that caused defoliation, crown dieback, and small tree mortality. Forest health aerial survey data shows that WSB has been chronic in the project area since 2003, defoliating Douglas-fir, Engelmann spruce, and subalpine fir (Egan and Lockman, 2016). Forested stands with these species remain susceptible to continued WSB attack and defoliation, especially in dense stands with multiple canopy layers. WSB can cause crown dieback, reduce growth rates and tree vigor, and increase physiological stress, which in large Douglas-fir can increase susceptibility to DFB. WSB can and has caused mortality in understory canopy layers as indicated in Figure 3. Figure 3. Forest stands in the project area exhibiting western spruce budworm defoliation.

Mountain pine beetle (Dendroctonus ponderosae) and lodgepole pine dwarf mistletoe (Arceuthobium americanum)

Lodgepole pine in the project area experienced a mountain pine beetle (MPB) outbreak between 2007-2010, with most stands having some level of past mortality. Still, severe mortality is possible within limited individual stands, with many stands rating at moderate to high susceptibility of MPB attack. Although it is somewhat unlikely for a widespread MPB outbreak to occur due to the relative lack of lodgepole pine in the project area, lodgepole pine stands present could experience over 90% mortality if an outbreak happened (Egan and Lockman, 2016). Lodgepole pine dwarf mistletoe (DMT) is present in much of the project area. This parasitic plant causes physiological stress, growth loss, general decline, and potential mortality in host trees with severe DMT infections. Additionally, DMT infection spreads to young lodgepole pine and prevents or delays these small trees from replacing the existing larger pine.

Root rots: Tomentosus (Onnia tomentosa) and schweinitzii (Phaeolus schweinitzii)

Root rot has been documented in several Douglas-fir and mixed conifer stands within the project area, although root rot can also affect other conifers. Both diseases are not aggressive tree killers; rather, they are generally slow acting and result in gradual weakening and progressive physiological stress in host trees. They can also increase the host trees’ susceptibility to windthrow. These agents are diseases of the site and there is no practical way to eliminate them from an infected site.

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Figure 4. A) Defoliation from western spruce budworm; B) Dwarf mistletoe in lodgepole pine stand; C) Tomentosus root rot similar to the project area.

In closing, vegetation within the project area and the surrounding landscape is susceptible to ongoing insect and disease activity based on observed conditions now and into the near future.

Aspen Health

Aspen exists throughout the project area in scattered, small clones. A majority of the aspen stands that were surveyed show a lack of sprouting, a general decline in the health of the stand, and moderate to extensive colonization by conifers. Aspen thrive only if they are able to obtain the proper combination of sunlight, soil warmth, and adequate soil moisture. Conifer removal through mechanized harvest can create the proper growth environments to improve aspen health and promote aspen sprouting and clone expansion (Sheppard, 2001; Jones et al., 2005).

Wildland Urban Interface

Hazardous forest fuels were also considered because the area is in a wildland urban interface (WUI). Firefighter and public safety is the number one concern related to wildland fires, then protection of property. Wildland fire suppression in WUI can be uniquely hazardous. Hazards may include structures (homes, outbuildings), access (or lack thereof), power lines and propane tanks to name a few. Even though many of the adjacent private land owners have thinned their forest vegetation, there is a possibility of a fire start spreading from private property onto the Forest or vice versa. During field reviews, the fuels management specialist observed that the insects and diseases noted above are killing and/or weakening trees in many forest stands in the project area. This causes elevated levels of surface fuels on the forest floor and creates small openings in the upper forest canopy where understory trees can grow and develop into “ladder fuels”. The high surface fuels, along with the ladder fuels, can and have created conditions where surface fires can spread into the upper crowns and spread from crown to crown, resulting in ‘crown fires’. Surface fires that transition to crown fires are usually wind driven. These fires are the most

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difficult to attack and most dangerous to suppress. High rates of spread and spotting ahead of the main fire are common. Firefighting tactics are often not effective in those conditions.

PURPOSE AND NEED FOR ACTION Based on observed existing conditions, as well as other supporting information such as annual insect and disease aerial detection surveys, national insect and disease risk maps, community wildfire protection plan, the Gallatin Forest Plan and input from local community members there is a need to: . Respond to the designation under the 2014 Farm Bill of the North Bridger landscape as an area susceptible to insect or disease threats . Reduce the susceptibility of vegetation to subsequent insect and disease activity . Minimize tree mortality that would contribute to surface fuel loading . Reduce hazardous wildland fuel load levels in the treated areas in order to reduce the potential for high intensity wildland fire. . Supply forest products to support local economies and industries.

The purpose of action, developed in coordination with the North Bridger Forest Health Collaborative Group, is to: . Reduce the risk or extent of, or increase resilience to, insect or disease infestations in the project area by improving resiliency of stand structure, function and composition; . Promote aspen regeneration by reducing conifer encroachment; . Provide a benefit to firefighter and public safety and reduce the risk to property/values near treated areas in the wildland urban interface; . Provide forest products to support the local economy.

DECISION

Project Activities

I have decided to implement vegetation and fuels management activities displayed in Table 1, secondary fuels treatments and road related measures described in this section; as well as, the Design Features, Mitigation Measures and Monitoring Requirements described in Appendix A. Approximately 2,300 acres are proposed for vegetation treatment. Vegetation management activities include intermediate treatments and regeneration harvests. Intermediate treatments leave a stocked stand post-treatment, while regeneration harvests replace the stand or parts of the stand with young trees. See Appendix B: Vegetation Management Treatment Descriptions and Summary for more detailed treatment descriptions. Regeneration harvest areas will be restocked

— Decision Memo — Page 8 North Bridger Forest Health Project with trees within five years of harvest, either by natural regeneration or planting of seedlings. Young stands of small trees comprise 519 acres of precommercial thinning treatment and the remaining 1,777 acres of treatment are in stands of sawtimber size, which have commercial value. Treatments and unit locations have been designed to minimize the potential for blowdown, but in all treatment units containing Douglas-fir, an additional entry may be required to remove blowdown material to limit increases in Douglas-fir bark beetle populations. Salvage (removal of dead trees) may be conducted in any sawtimber treatment unit. Trees smaller than sawtimber size may be cut or removed in sawtimber units, either in conjunction with the timber sale or as a follow-up activity. Vegetation management activities include proposed stand improvement treatments as identified in Figure 5. Treatment Units and Transportation Proposal Map, Table 1. Acres of Treatment by Silvicultural System and Appendix B, Table B-1. Proposed Treatment, Acres and Logging System.

Table 1. Acres of Treatment by Silvicultural System* Treatment type Acres Even-aged (clearcut, patch cut, overstory 667* removal) Uneven-aged (group selection) 87* Intermediate (thinning, aspen, sanitation) 1,023 Intermediate (precommercial thinning) 519 Total 2,296 * A portion of these acres are thinning acres. For example, if a proposed treatment Is “Patch cut/Thin,” then thinning will occur in the portions of units not patch cut. Effects of the proposed action will mostly be in the form of altered stand structure, whether that is reducing existing densities or changing the size class and age of a stand. Literature supports the effectiveness of silvicultural control of bark beetles (Fettig et al., 2007; Gibson, 2004). Much of the research points to two silvicultural strategies which have shown promise, one at the landscape level and one at the stand level. At the landscape level, heterogeneity is thought to be more resistant and resilient to insect damage. Silvicultural treatments designed to create age, size, and species mosaics can increase landscape heterogeneity. At the stand level, evidence suggests that thinning can be an effective deterrent to insect infestation and associated losses. In general, reducing tree densities allows residual trees to allocate more resources toward growth thus making them more resistant to insects and disease (Fettig et al., 2007; Fettig et al., 2014; Kegley, 2011; Pederson et al., 2011). Also, Negron et al. (1999) found that stand basal area was the most significant indicator of mortality during a DFB outbreak. Promoting other species besides Douglas-fir where present and healthy will decrease the percentage of Douglas-fir within a stand and will further help reduce hazardous factors (Kegley, 2011). Thinning reduces inter- tree competition and stress on remaining trees and can increase their resistance to bark beetles (Fettig et al., 2007). In aspen stands, the growth environment will be improved by removing competing conifer vegetation and allowing sunlight to reach new aspen growth, resulting in healthier stands, improved soil moisture conditions and more resilient forests. Whole-tree yarding will be used in the majority of sawtimber treatment units. This method gets most of the activity related fuels out of the woods to a landing which will be burned. Other

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Figure 5. Treatment Units and Transportation Proposal Map

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follow-up fuels activities may be required. These activities could include: slashing, broadcast burning in regeneration harvest units or units with heavy natural fuel loading, lop and scatter, crushing or yarding of dead and down material, and/or hand- or machine-piling and burning. Treatments in young stands may have fuels masticated or hand-piled and burned Road management activities are needed to implement the project (e.g. maintenance, reconditioning, reconstruction and temporary road construction). Approximately 9.5 miles of temporary road will be needed to access the proposed units. Estimated locations are identified on Figure 5. Treatment Units and Transportation System Map. Temporary roads must be decommissioned within three years of the project being completed. Decommissioning includes recontouring, ripping, obliteration when appropriate, blocking access points and revegetation. Appendix A includes design features related to temporary road construction and rehabilitation. No permanent roads will be constructed.

DECISION RATIONALE

Considerations Based on Collaborative Input, Interdisciplinary Project Development and/or Scoping

The North Bridger Forest Health Project is an area identified in the Gallatin [Forest] Farm Bill Sec. 602 Areas Preliminary Assessment (USDA 2014) as having an opportunity and need for some level of management to meet desired vegetation conditions. With the opportunity provided in the Farm Bill Authority to utilize a recently established category of actions, the Forest started working with the Custer Gallatin Working Group (CGWG) in early 2016 in hopes of moving forward with the project at that time. Staff transitions slowed progress and collaboration was limited to regular updates on preliminary project development with the CGWG until Spring 2017. At that time, I proceeded to notify the public and other potential interested stakeholders to begin a collaborative process for project development. Local landowners, livestock permittees, local fire officials, conservation organizations, Montana Fish, Wildlife and Parks biologists, a Gallatin County Commissioner, and a timber company representative chose to collaborate, supported by the Custer Gallatin Working Group.

The collaborative and Forest Service had a mutual goal of addressing the purpose and need for action, notably all aspects of the project intent including support to the local wood products industry. The group had an equal commitment to minimizing disruption of recreation users, especially in light of winter recreation use associated with ski destinations for nordic and alpine skiers. Early on the group advocated for the protection of wildlife habitat and minimizing the spread of invasive weeds.

As the Deciding Official, I instructed my staff and the interdisciplinary (project analysis) team to ensure the project was designed to comply with the current laws, standards and guidance for wildlife species and habitat, invasive weeds, water quality and old growth, while meeting other applicable Gallatin National Forest Plan standards (amended 2015). I also stressed the importance of minimizing impact to recreationalists. I relayed this commitment to the collaborative participants. The collaborative process resulted in refinement of treatment areas

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(IDT_PA Changes since 8/24), additional design features and additional effects analysis and disclosure. This process also provided an opportunity to dialogue with participants on past management effects, desired conditions, forest restoration needs, local economic issues, current forest health and fire threats.

In my decision I focused on forest stand improvements to restore resiliency to insects and disease, address dead and down fuel loads and to reduce the associated potential for higher intensity wildfire, specifically near residences, evacuation routes, and adjacent infrastructure. The project also provides enhancement of aspen clones, protects older large trees into the future through better growing conditions, and thins several previously harvested units to improve growth and resiliency of these younger forest stands. The decision considers economic feasibility and impact to local communities. My decision will effectively meet the purpose and need for action on all acres treated, which is important to the Forest as well as the North Bridger Forest Health Collaborative.

While many issues were raised during collaboration and public involvement, the following issues were the most common and the subject of more interdisciplinary team effort.

Wildlife, and migration corridors: People were concerned with project impacts to wildlife. My decision includes numerous design features to protect wildlife and wildlife habitat. The design features I included in my decision are listed in Appendix A. In response to concerns expressed by the collaborative, the public and agency specialists, impacts from temporary roads will be minimized and key habitat was eliminated from treatment units. There was concern over the potential loss of the Bridger Mountains as a linkage area that allows wildlife movement from the Gallatin Mountain Range to points north. No permanent developments that would create a barrier to species like lynx and grizzly bear are planned under this project. The Lynx Conservation Assessment and Strategy (ILBT 2013) does not identify land management activities such as timber harvest and fuels treatment as a barrier to lynx movement. Human developments in lynx habitat, such as highways, utility corridors, residences, and recreation developments, may impede lynx movements but are not likely to be barriers to movement (ILBT 2013). While research from Squires and others (2010) found that lynx avoided natural openings and clear cuts (crossed at less than their availability based on random locations) in the winter, they found no evidence for avoidance of these areas during the summer. Small openings (up to 40 acres in size) created by proposed treatment activities may be avoided by transient lynx that may move through the area in the winter; however, the size of these affected areas and the availability of mature and mid- aged structural stages would allow for movement of transient lynx during all seasons. Vegetation management activities would not create a barrier to lynx movements in and between LAUs and identified linkage areas between the and the Bangtail Mountains and between the Bridger Range and the . Habitat connectivity consists of an adequate amount of vegetation cover arranged in a way that allows lynx to move across the landscape. Squires and others (2010) concluded that managers should retain a mosaic of habitat with abundant and spatially well-distributed patches of mature, multilayer spruce-fir forests and younger forest stands. Post-treatment lynx habitat in the LAU would consist of a mosaic of treated and untreated stands in a variety of structural stages that will provide habitat for transient lynx in the present day and future.

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Migration would not be impeded for other wildlife species either due to the presence of cover and relatively limited amount of treatment in the larger landscape. The proposed action is in an area that may prove suitable as a movement corridor for grizzly bears between the Northern Continental Divide and Greater Yellowstone Ecosystems sometime in the future (Peck et al. 2017). Grizzly bears are habitat generalists, so land management activities on federal lands were not specifically examined in their analysis. While modeling done by Peck and others (2017) specifically accounted for areas with high road density that may be avoided by grizzly bear, it did not identify specific multi-lane, high-volume highways (e.g., interstate highways I-90 and I- 15) or other infrastructure that would present a potential barrier to movement. Cushman and others (2009) also identified potential barriers to movement. All of these potential barriers were associated with major highways: gaps in federal land ownership with major highway crossings, areas in federal ownership but traversed by major highways, and areas where major highways paralleled corridors. The project would not create any barriers to potential grizzly bear movement. I reviewed the Wildlife Report (2018), Wildlife Worksheet (2018) and Biological Assessment (2018) and determined that the project meets direction and applicable law while effectively minimizing potential adverse impacts. Based on the analysis and design features, I conclude that potential effects are limited in extent and duration and will be insignificant. The collaboration effort and coordination with Montana Fish, Wildlife, and Parks helped eliminate and minimize impacts (IDT Changes since 8/24).

Impacts to recreation uses: The project area is in a highly used recreation area that includes a diversity of recreation uses. Members of the collaborative and others were especially concerned with user conflicts in the winter. I am committed to minimizing the impact to both summer and winter uses. Several roads that are used during the winter for skiing, will not be used for hauling during that season including Forest Service Roads (FSR) #6310, 631B, and #631 (South Brackett Creek Road). No hauling will be allowed on weekends or holidays. Other design criteria are in place to protect roads, trails, trailheads, and campgrounds. Units 61 and 62 were dropped for a variety of reasons, including potential impact to the Bangtail Divide Trail recreation experience. I reviewed the Recreation Worksheet (2018) and considered the genuine concern expressed by some forest users related to recreation uses. The project as designed is consistent with applicable direction. I believe that the recreation user experience will be maintained while balancing the competing demands between the recreation community and other uses. The anticipated direct and indirect effects to recreationalists will be limited to temporary displacement from portions of the area due to design features (appendix A). There will be no change in potential uses or types of opportunities. As a result, potential impacts will be minimal and insignificant.

My decision maintains scenery. Potential negative impacts will be minimized because I incorporated design features (Appendix A) recommended in the Scenery Worksheet 2018. As designed, the project will meet the scenery standards for the project area. Effects will be short term and limited in scope to the immediate treatment units and the project area. I included post treatment monitoring to ensure timely restoration.

Temporary Roads:

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Several comments were received about the potential impact of temporary roads that will be created for implementing the project. Road locations and stream crossings were further scrutinized by the IDT. Early in the planning process some locations were rerouted and some eliminated. Also, project specific design features and best management practices were incorporated in the project design. The intent of this IDT hard look was to minimize the potential for sediment and respond to concerns presented during collaboration and scoping. Three stream crossings were of particular concern during IDT conversations. In June, the hydrologist, fish biologist, engineer and presale forester revisited those stream crossings and eliminated one and agreed on the best placement for the other two so that potential impacts will be minimized or avoided. The decision requires full decommissioning and obliteration of all temporary roads, which includes ripping/tilling and re-contour (if needed) of the temporary road prism, no later than 3 years following completion of project related activities. Weed free seed will also be used to restart vegetation. Temporary roads will be blocked during the project, to prevent new uses from occurring and to limit use to administration purposes. If old existing road prisms are used as a temporary road, then those old existing road prisms will also be decommissioned. The collaborative expressed support for these practices in response to their earlier concerns.

Road management associated with the project is consistent with applicable direction in the Gallatin Forest Plan (amended 2015), Travel Plan (2006) and best management practices associated with road construction and obliteration. I reviewed the Worksheets for Wildlife, Public Transportation, Recreation, Soils, Aquatics, Invasive Weeds, Scenery and Hydrology in order to conclude that potential negative impacts are minimized through design and that there are no unresolved conflicts associated with roads. I acknowledge that some people would prefer that no roads existed but that would not meet the purpose and need of the project. I am very committed to decommissioning temporary roads and having natural ecological functions maintained or restored.

Invasive Weed Management: From the collaborators and public, specific comments were received on the potential this project could have on creating new, or increasing existing, invasive weed infestations. The Custer Gallatin National Forest is dedicated to helping manage, and if possible eliminate, noxious weed infestations. Design criteria is incorporated in my decision to minimize the potential of creating new weed infestations. My staff is already pretreating existing weeds infestations, and we will post treat (as needed) for up to three years after implementation. Additional design criteria includes using weed free seed to revegetate certain disturbed areas and washing/cleaning off- road vehicles. I reviewed the Invasive Weeds Worksheet 2018 and determined that the project, as designed, minimizes potential negative impacts and risk of weed spread. My decision is consistent with all Forest Plan direction. I acknowledge that the spread of invasive weeds is a genuine concern but I believe that the pre-treatment included in this project and the planned best management practices will limit the weed increases from this project. Due to these practices, the direct, indirect and cumulative effects will be minimal. While this project will not address noxious weed infestations throughout the entire Bridger Mountain Range and there are other vectors of opportunity for new weed infestations not related to this project, my goal is to minimize and try to prevent any new increase to noxious weeds throughout the project area. We will continue to work with our partners, members of the North Bridgers Collaborative and others,

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to minimize, with the goal of preventing, invasive weed spread in the Bridger and Bangtail Mountains.

Large Trees: Comments were received asking for the project to minimize the amount of large trees removed from the project area, especially if they pose no disease or insect infestation threats to the tree or stand. The project silviculturist, and/or silviculture crew, surveyed every stand of planned treatment and verified that proposed treatments to large trees are needed due to insect and disease concerns. Specific marking guidelines will assure that treatments maximize the retention of old-growth and large trees, as appropriate for the forest type, to the extent that the trees promote stands that are resilient to insects and disease (Appendix A, Design Feature). Stands that meet old growth criteria (Green et. Al. 2011) were dropped from consideration if it was determined that old growth criteria would not be maintained in the stand after effective treatments. The old growth stands being treated (222 acres) are designed to maintain or increase the large old trees. No old growth stands will be lost and it is expected that reducing competition in the treated stands will result in larger trees for a longer period of time on the landscape, potentially increasing old growth. A regional review of literature suggests that silvicultural treatments in old growth can increase stand resilience while maintaining composition and structure that meets old growth definitions (Bollenbacher and Hahn, 2008). As a result, project effects are expected to be beneficial and within the range of effects that would occur in the event of a natural disturbance that thinned stands.

The other sections of this Decision Memo speak to a number of issues to be considered when categorically excluding a project from an EA or EIS but there are other issues I considered as well, either to ensure consistency with applicable direction or in response to collaboration or public comments.

I reviewed the Fuels Worksheet (2018) and concluded that the project does address the fuels purpose and need. The private inholdings and evacuation routes are of particular concern to me in the project area. The treatments will change fire behavior in normal conditions in those units. Treatments will lower fire line intensity, flame length and rate of spread in the event of a wildland fire start. My intent is not to eliminate fire from the landscape, but to provide for fire fighter and public safety and decrease the wildland fire risk to values, like homes and private property. The project meets the intent of the Federal Wildland Fire Management Policy and is consistent with Forest plan direction. The treatments will assist in cleaning up the insect killed vegetation that could become hazardous fuel build-up. In the event of a fire start in the WUI, in most conditions, the fire event would be less complex, less difficult to suppress and less complicated when cooperating with adjoining agencies. The primary purpose for the project is related to forest health and resiliency, but providing this fuels benefit is also important.

There would be beneficial combined or cumulative effects but, as with the direct and indirect effects from the proposal they would limited in scope to the project vicinity. The effectiveness of treatments like those proposed, is well established in the previously cited publications, for modifying fire behavior in the vicinity of treated areas. This type of treatment, combined with design features to minimize adverse effects, has been shown in repeated analysis on the Forest to not have significant direct, indirect or cumulative effects (Fuels Worksheet 2018).

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I considered the potential effects to Livestock Permittees discussed in the Range Worksheet (2018). In conversations with those stakeholders we agree that early season coordination can eliminate conflicts between logging and grazing operations. Design features in Appendix A minimize potential conflicts with this use. These effects will be minimal to the range resource. The potential disruption will be short term and the forage enhancement may restore a portion of the transitory forage lost over time to increased forest cover in established allotments.

Soil protections are also included in Appendix A - Design Features. I reviewed the Soils Worksheet (2018) and determined that the project, as designed, is consistent with applicable direction and protects soil productivity for the long term. Potential effects will be limited in scope to planned treatment units and projected levels of soil disturbance are within, well- established regional guidelines.

During scoping some commenters wondered about the effects from climate change to the area. Based on the information I reviewed in the Climate Worksheet (2018), direct, indirect effects and potential cumulative effects from the project to climate change would be insignificant due to the limited scale and physical scope of the proposal. Effects from climate change to the project area support the need for increased forest resiliency, like that proposed in this project area. The potential benefits to treated areas are limited in scope to the project area, which is localized, and consistent with forest succession processes.

My decision incorporates monitoring to ensure that the project is implemented as proposed (Appendix A). If monitoring shows that protections or design standards are not meeting intent my staff will evaluate the need for modifications or additional restoration.

Extraordinary Circumstances

My decision is responsive to: • effects findings for pertinent resources from the concerns and issues raised during the required scoping period; • concerns learned from engagement of collaborative participants during working meetings and field trips to the project area; • findings of the interdisciplinary team.

As discussed throughout the previous section, effects will be minor and there is no uncertainty over the significance of effects. Cumulative effects were considered in response to scoping concerns. Based on the agency’s expertise, the responsible official can conclude that if the action fits within an identified category and analysis shows that there are no extraordinary circumstances, then the action would not have significant effects (1909.15_30). I took into account resource conditions identified in agency procedures that should be considered in determining whether extraordinary circumstances might exist. No extraordinary circumstances exist that warrant further analysis and documentation in an Environmental Assessment or Environmental Impact Statement.

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Federally listed threatened or endangered species or designated critical habitat, species proposed for Federal listing or proposed critical habitat, or Forest Service sensitive species

Federally Listed Threatened or Endangered Species Wildlife

Canada Lynx

The North Bridger Project will not have extraordinary circumstances associated with the proposed actions with regard to the Canada lynx. This project will affect a small proportion (1.8%) of the snowshoe hare foraging habitat in the LAU. The project will occur in unoccupied, secondary lynx habitat; if lynx were to pass through the LAU, they will be considered transient individuals. Although the project is situated in unoccupied habitat, the standards in the NRLMD were considered; this project will be consistent with all applicable NRLMD standards. (Biological Assessment 2018 and Wildlife Worksheet 2018). The US Fish and Wildlife Service concurred with the Forest Service finding that the project may affect, but is not likely to adversely affect the lynx (USFWS Concurrence letter 2018). Aquatics and Plants No federally listed aquatic species occur within the project area. (Aquatics Worksheet 2018) No federally listed or proposed plant species are found in the project area (Botany Worksheet 2018). Designated Critical Habitat Wildlife, Aquatic and Plant The project area is entirely outside the critical habitat boundary for Canada Lynx so there will be no effect on critical wildlife habitat (Wildlife Worksheet 2018). No designated critical habitat is found in the project area for threatened or endangered plants, terrestrial or aquatic species. (Aquatic and Botany Worksheets 2018). Species Proposed for Listing Wildlife

North American Wolverine

The North Bridger Project will not have extraordinary circumstances associated with the proposed actions with regard to the North American wolverine. This project will affect a small proportion (essentially 0% of denning and 3% of primary habitat) of wolverine habitat in the analysis area. None of the activities that will affect wolverine denning, primary, or dispersal habitat are considered a threat to the species. Wolverine will be able to adjust their use within their home range to avoid disturbance that is occurring and find forage. In the long term, treatment may enhance foraging habitat for potential prey/carrion. Cumulative effects will be minimal when viewed in the context of the wolverine home range. The project will not jeopardize the continued existence of the distinct population segment of the North American wolverine. (Wildlife Worksheet 2018, Wolverine Programmatic Compliance Worksheet 2018,

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and Wildlife Report 2018). No other terrestrial wildlife species that are proposed for listing are present in the project area.

Aquatics and Plants No fish, amphibian or plant species that are proposed for listing occur in the project area. No proposed critical habitat is present in the project area either (Botany and Aquatics Worksheets). Sensitive Species (Wildlife Worksheet 2018), Aquatic Worksheet 2018, Botany Biological Evaluation)

Wildlife No extraordinary circumstances need to be considered for the following Forest Service Region 1 Sensitive Species: grizzly bear, bighorn sheep, Townsend’s big-eared bat, harlequin duck, trumpeter swan, and bald eagle. These species are either not currently known to occur in or near the project area and/or suitable habitat is not present in the project area or if present in the project area or vicinity, the proposed activities will have no effects on suitable habitat.

Peregrine Falcon

The North Bridger Project will not have extraordinary circumstances associated with the proposed actions with regard to the peregrine falcon. This project will affect a small proportion (1.5%) of the estimated home range for the potential eyrie and are not expected to disturb breeding peregrine. Treatment activities are expected to have a positive impact on foraging habitat because they will open forested canopies and create open habitat preferred by peregrine for foraging. Cumulative effects will be minimal, as only a small proportion of the estimated home range will be affected and activities will improve foraging habitat structure. The project may impact individuals or habitat, but would not contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH).

Black-Backed Woodpecker

The North Bridger Project will not have extraordinary circumstances associated with the proposed actions with regard to the black-backed woodpecker. This project will affect a small proportion of habitat that is experiencing endemic or greater insect and disease mortality. The risk if these agents causing significant mortality in affected stands will be reduced. However, a large proportion of the Bridger and Bangtail Ranges, and the Forest as a whole, are also at risk of insect, disease, and fire-caused mortality that may attract black-backed woodpecker. As no other activities are proposed for treatment units that will affect their suitability for blacked-backed woodpeckers, there will be no cumulative impacts on this species. The project may impact individuals or habitat, but would not contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH).

Flammulated Owl

The North Bridger Project will not have extraordinary circumstances associated with the

— Decision Memo — Page 18 North Bridger Forest Health Project proposed actions with regard to the flammulated owl. This species is not currently known to be present in the Project Area. This project will affect approximately 25% of the marginally suitable habitat that is present in the project area. The majority of treatment activities in potential owl habitat may improve habitat quality in the long term by altering stand composition and structure and encouraging understory regeneration preferred by this species for foraging. As no other activities are proposed in the Project Area that will affect potential flammulated owl habitat, there will be no cumulative impacts on this species. The project may impact individuals or habitat, but would not contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH).

Gray Wolf

The North Bridger Project will not have extraordinary circumstances associated with the proposed actions with regard to the gray wolf. Disturbance effects associated with the project will be short term and temporary; wolves will adjust their use of the landscape to avoid areas where disturbance is occurring. The project will also cause impacts to prey distribution by affecting security areas, habitat effectiveness, and cover in the project area. Impacts to security and habitat effectiveness will be minor and temporary; pre-treatment levels of these resource measures/indicators will be restored once temporary project roads are decommissioned and activities cease on restricted Forest roads. Impacts to cover will persist for a number of years; however, cover is not limited in the Project area or the analysis area, and will continue to meet Forest Plan standards. Sufficient cover will be available to support potential prey. Cumulative impacts on the gray wolf and its prey are expected to be minor. The project may impact individuals or habitat, but would not contribute to a trend toward federal listing or cause a loss of viability to the population or species (MIIH). Aquatic Species Westslope cutthroat trout, Yellowstone cutthroat trout, western toad, northern leopard frog, and western pearlshell mussel are all classified as a sensitive species within the Northern Region of the U.S. Forest Service. The project area falls outside the native range of westslope cutthroat trout and western pearlshell mussels so there will be no effect and no extraordinary circumstances associated with them. The project will not have extraordinary circumstances associated with the following aquatic species for the reasons discussed below.

Yellowstone Cutthroat Trout

Yellowstone cutthroat trout currently occupy all project area streams. Based on the analysis of proposed project activities and model estimates, it is possible the proposed action will have a small, isolate impact on individual fish and aquatic habitat. Modeled sediment yield estimates are below Forest Travel Plan standards and sediment that does enter stream channels will be minor in amount and duration (both spatially and temporally), mostly occurring at stream crossings on haul routes. The project as designed supports the protection of water quality, and habitat for fish, riparian dependent species and other aquatic organisms. Given the design features, mitigation, and BMP improvements to haul routes prior to vegetation treatment activities, the project may impact individuals or habitat, but will not likely result in a trend

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Western Boreal Toad

Records by the Montana Natural Heritage Program and observations by U.S. Forest Service personnel indicate western toads are present throughout the project area. Project design criteria will protect western toad breeding and rearing areas by applying buffers to standing and flowing waters. Wetlands, ponds, and springs adjacent to or within treatment units will be avoided. Similarly, required design features along perennial, intermittent and ephemeral streams will protect riparian habitat and function. Slash piles will not be created (or burned) within the functional riparian zone, greatly reducing the likelihood of creating hibernacula adjacent to areas most heavily occupied by western toads. A low level of vehicle-related mortality of western toads is expected where toad distribution overlaps with roads. However, it is not expected that vehicle-related mortality will have an impact that will result in a population level downward trend. The project may impact individuals or habitat, but will not likely result in a trend toward federal listing or result in reduced viability for the population or species.

Northern Leopard Frog

Northern Leopard Frogs are found approximately 2-3 miles east of the project area at similar elevation and habitat. There is a high likelihood that northern leopard frogs occupy the lower elevations of the project area. Project design criteria that provide protection for western toad should provide equal protection for northern leopard frog. Standing and flowing water buffers should be adequate to protect those areas used for breeding, rearing, feeding, and hibernating by northern leopard frogs. The project may impact individuals or habitat, but will not likely result in a trend toward federal listing or result in reduced viability for the population or species. Plants Will not have extraordinary circumstances associated with the proposed actions.

Whitebark Pine

Whitebark pine (Pinus albicaulis) is present incidentally in units at higher elevations in the vicinity of Fairy Lake. Habitat conducive to the establishment of stands with a major whitebark pine component does not exist within treatment units. The proposed action may impact individual whitebark pine plants but is not likely to result in a trend toward federal listing or loss of viability. White bark pine (WBP) is a species proposed for listing under the Federal Endangered Species Act.

Other Plant Species

The sensitive plant species short-styled columbine (Aquilegia brevistyla), Northern rattlesnake plantain (Goodyera repens), and small yellow lady's-slipper (Cypripedium parviflorum) were considered to have suitable habitat in the project area. Areas of potential habitat were surveyed and no sensitive plant populations were found. Therefore the proposed action will have no

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Habitat for the remaining 18 sensitive plant species listed for the Gallatin portion of the Custer Gallatin National forest did not exist in the treatment units. Therefore the proposed action will have no impact on these species.

See the Botany Worksheet 2018 for more information related to Sensitive Plants.

Other Wildlife and Aquatic Species Considerations

Presence and potential habitat for Management Indicator Species (MIS) is known to occur in the project area. MIS species for the Custer Gallatin National Forest, as identified in the Gallatin Forest Plan, include grizzly bear, bald eagle, elk, goshawk, marten, and wild trout. Grizzly bear, bald eagle, Yellowstone and West slope cutthroat trout were discussed in the sensitive species section. Elk, goshawk, pine marten and trout occur in the project area at varying levels. Implementation of the proposed activities may have minor impact on habitat for these species and may impact these species at the local level but will not impact forest-wide populations. Additional discussion on MIS, as well as Migratory Birds can be found in the Wildlife Report 2018 and Aquatics Worksheet (2018).

Flood plains, wetlands, or municipal watersheds

Will not have extraordinary circumstances associated with the proposed actions. • There are no municipal watersheds in the project area. • The required no-treatment buffers will be more than adequate to protect floodplains within the project area. • Wetland areas will be protected by required design features that forbid vehicle and logging machinery operation and deposition of any materials in wetland areas. See the Hydrology Worksheet 2018 for more information.

Congressionally designated areas such as wilderness, wilderness study areas, or national recreation areas

There will be no extraordinary circumstances related to these resources because they are neither present in the project area, nor in the larger Bridger or Bangtail Mountain area. (Roadless Worksheet2018).

Inventoried roadless areas or potential wilderness areas

There will be no extraordinary circumstances associated with the proposed actions. No direct effects will occur within the IRA. The proposal meets the requirements of the Roadless Area

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Conservation Rule by not constructing or reconstructing roads or harvesting timber in the North Bridgers Inventoried Roadless Area (IRA). Indirect effects will be limited to the period of operation for the project. Noise from harvest activities or road maintenance work may reduce the opportunities for solitude in the Bridger IRA. This loss of solitude will be of short duration and will not persist into the future thus not compromising the future suitability for wilderness designation. Units 1, 25 and 26 are near but not in the IRA. (Roadless Worksheet 2018)

There will be no effect to potential wilderness areas because no unroaded (potential wilderness) areas exist in the project areas due to the density of roads and infrastructure. (Roadless Worksheet 2018 and Map -Designated Areas, Recommended Wilderness and Special Emphasis Area Map for the Bridger Mountain Range).

Research Natural Areas

There are no Research Natural Areas present in the project area or treatment units therefore there will be no effect and no extraordinary circumstances (Gallatin Forest Plan Amended 2015).

Archaeological sites, or historic properties or areas

• American Indians and Alaska Native religious or cultural sites; Extraordinary Circumstances Determination: Will not have extraordinary circumstances associated with the proposed actions. (Heritage Worksheet 2018).

Explain Determination: Previous work with the Confederated Salish and Kootenai has determined a historical and cultural interest in the Bridger Mountains. In this particular instance, the Salish (historically known as the ‘Flathead’) have stories associated with Flathead Pass and the corridor which was an oft-used route to the Yellowstone River areas for buffalo hunting AND some of the rock art sites on the west slopes of the Bridger Mountains. These areas will not be affected by this project.

• Archaeological sites, or historic properties or areas.

Extraordinary Circumstances Determination: Will not have extraordinary circumstances associated with the proposed actions. (Heritage Worksheet 2018).

Explain Determination: The USFS worked cooperatively with Montana State University in archaeological investigations on the Bridger Mountains over a 4-year period. Several publications resulted. The distribution of archaeological sites was found to be distinctively arranged by the geography and geology. What this means is the travel routes, the selected alpine meadows, the lithic sources and plant communities are distinctively available to people in terms of

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what the geology offered. Evidence of prehistoric (and historic) use was remarkably well associated with these parameters once they were recognized. As such, the way sites are distributed on the Bridgers landscape places them in entirely different regions of the Bridgers than the where this proposal is located. Archeological surveys for this specific North Bridgers project area further confirmed this model, as no new sites were located during the typical “Site Investigation Strategy” (R1:PMOA; SIS).

There are two prehistoric sites and one historic site in locations that could have been selected for “landings”. These site locations will be mapped as avoidance areas in design and implementation phases. They will be flagged on the ground for avoidance prior to and will be monitored during project implementation (Heritage Worksheet 2018). There will be no effect to these properties or sites because the known sites have been avoided through project design (Heritage Worksheet Allen 2018). Surveys were completed to inform the design features. The Montana State Historic Preservation Office concurred with the “no effect” determination on April 12, 2018 (SHPO Concurrence Letter2018)

COLLABORATION, SCOPING AND PUBLIC INVOLVEMENT

Collaboration

The collaborative process for the North Bridger Forest Health Project started with early discussions in 2016 and 2017 between the Custer Gallatin National Forest and the Custer Gallatin Working Group (CGWG). The CGWG represents numerous diverse entities and proved to be a great place to begin a collaborative outreach. In the summer of 2017, a sub-group of CGWG members along with other land owners, interest group representatives, and interested public (see COL North Bridger Collaborative Mailing List) joined in an effort to form the North Bridger Forest Health Collaborative Group.

All initial contacts were made either by phone and/or email in the early stages. The District Ranger also contacted Montana Fish, Wildlife and Parks and Montana Department of Natural Resources. The project area is surrounded by large land holdings and those property owners were contacted. In an effort to reach other individuals with an interest in participating in the collaborative project planning process, an invitation/announcement was released to the Custer Gallatin Forest Wide Media Public Distribution list which goes to the news outlets within the expanse of the Custer Gallatin National Forest and other information outlets (187 names). The announcement /invitation was also posted on the Forest webpage and Facebook page as well as the CGWG webpage and Facebook page. Once the North Bridgers group formed, the Collaborative invited members from their respective network to participate. The collaborative outreach documents are compiled into one document in the project record and on the project webpage called the Collaborative Outreach Packet. Planning and development of the proposal was done through a transparent, non-exclusive collaborative process that included multiple interested persons representing diverse interests. An open house was held (August 30th, 2017) in Bozeman, Montana to begin discussions of the

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project. Notice of the open house was conducted through widely distributed direct mailings to known interested individuals, community groups, local fire districts, County Commissions, Tribal Governments, other agencies, sportsman, conservation and environmental groups, local landowners, special-use permit holders and various businesses. Additionally a news release was published to the media distribution list inviting participation along with posting on the Custer Gallatin National Forest website and Facebook pages. Attendance and participation at this open house included local land/homeowners, private business owners, recreation interest groups, timber industry professionals, local government interests and State wildlife agency biologists.

Participants were informed from the beginning that as the Line Officer, I was not looking for consensus, but their role was to provide input, and considerations from all perspectives through open dialog. As the responsible official, I consider collaboration an important and valuable contribution but the decision is the sole purview of the responsible official. Our objective was to provide a set of meetings and process to foster an understanding of purpose and need and to educate individuals on the NEPA process and resource constraints. With this sharing of ideas, options for project development were identified that complied with the authority under Section 603 of HFRA (16U.S.C.6591b). Participants were informed of potential resource constraints or sideboards that may be warranted to meet other required laws, policy, and the Gallatin National Forest Plan, as well as opportunities to assist during implementation and monitoring. This group of participants attended a field trip, utilized information on the existing conditions and reviewed the ability to achieve Forest Plan goals. Identified opportunity areas within the Designated Area were provided by the Forest Service Interdisciplinary Team to the participants. Through this collaborative process participants assisted resource specialists in the identification of issues, refinement of management options and areas, as well as input on the development of treatment types to meet objectives. Continued interaction with participants was open and ongoing via email correspondence, face to face meetings, field visits to the project area and by telephone with Forest Service Staff.

Specifically, a field trip to the project area was conducted following the open house on August 30th, 2017. The trip allowed participants in the collaborative process to view past treatments, as well as look at untreated areas that were being considered for treatment. There was a comment period during collaboration (ended 9/8/17) after the initial meeting and field trip. The initial proposal was modified to incorporate feedback, then a follow up meeting was held where the Forest Service presented changes to the proposal based on feedback from collaborators and the interdisciplinary team (10/3/2017 Open house material). Understandably, with the various interests represented, not all requested changes could be accommodated.

The responsible official and the agency interdisciplinary team carried out the process in an honest, transparent manner and considered and discussed all information and contributions brought forth from the collaborative process. That collaborative effort was demonstrated as changes and adjustments were made as a result of feedback received during the development of the project’s proposed action.

Additional information on this collaborative process is contained in the project case file. A COL_Planning Summary documents the overall collaboration effort.

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Scoping & Public Involvement

This action was originally listed as a proposal on the Custer Gallatin National Forest Schedule of Proposed Actions in January 2016 under the name Bridger Forest Health Project. In July 2017 the project was re-named due to a staffing transition. The Schedule of Proposed Actions SOPA was updated quarterly during the analysis. The website where the SOPA can be found is https://www.fs.fed.us/sopa/forest-level.php?110111 The public scoping comment period was initiated on 11/27/2017. A scoping letter was sent to 96 individuals, organizations and agencies either via email or postal service. The scoping outreach was posted on the Forest webpage. A new release was sent to the Forest Media mailing list which includes 187 names that are a mix of news outlets, congressional staff and others. The scoping mailing list included our collaborative partners, local and state agency partners like Gallatin County Commissioners and MT Fish Wildlife and Parks, adjacent landowners, and individuals that typically show an interest in these types of project. Some other examples include seven tribal representatives, Montana DNRC, Bridger Rural Fire Department, Representatives of Bridger Bowl and Cross Cut Ranch, Range Allotment permittees and individuals that requested project information. The news release, mailings and mailing lists are in the project file (IDT_Scoping Packet). We received comments from 37 individuals or representatives. Those letters and emails were published on the Project webpage. Some comments were brief, indicating support or opposition, several were essentially form letters. A summary of how the comments were considered is available on the Project webpage (IDT_Scoping Issue Disposition Summary)

APPLICABLE CATEGORICAL EXCLUSION

Background

Section 8204 of the Agriculture Act of 2014 (Public Law 113-79) (also referred to as Farm Bill) amended Title VI of the Healthy Forests Restoration Act of 2003 (HFRA) (16 U.S.C. 6591 et seq.) to add Sections 602 and 603 to address qualifying insect and disease infestations on National Forest System lands. The Secretary of the U.S. Department of Agriculture delegated authority to implement the provisions of the Farm Bill to the Chief of the Forest Service on March 6, 2014. Section 602 provides, in part, the opportunity for Governors to request designation to areas in their State that are experiencing, or at risk of, an insect or disease epidemic. The Forest Service received letters from 35 states requesting designations. These requests were reviewed to ensure they met at least one of the following eligibility criteria outlined in the Farm Bill: experiencing forest health decline based on annual forest health surveys; at risk of experiencing substantially increased tree mortality based on the most recent Forest Health Protection Insect and Disease Risk Map; or contains hazard trees that pose an imminent risk to public infrastructure, health, or safety. Upon reviewing the States’ requests, the Chief designated approximately 45.6 million acres of National Forest System lands across 94 national forests in 35 States. Over 6.6 million acres were

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designated in the Northern Region (1,708,628 million acres in Idaho; 4,955,159 million acres in Montana). These areas are being further evaluated to identify potential projects that reduce the risk or extent of, or increase resilience to, insect and disease infestations. Information on the request and designation process, by state, can be found at http://www.fs.fed.us/farmbill/areadesignations. shtml. Section 603 establishes a categorical exclusion for qualifying insect and disease projects in designated areas on National Forest System lands. An insect and disease project that may be categorically excluded under this authority is a project that is designed to reduce the risk or extent of, or increase the resilience to, insect or disease infestation in the areas (HFRA, Sections 602(d) and 603(a)).

Insect & Disease Infestation Categorical Exclusion

This categorical exclusion may be used to carry out a collaborative restoration project in an insect and disease treatment area designated by the Chief under section 602. The applicable category of actions is identified in agency procedures Forest Service Handbook 1909.15, Chapter 30, Section 32.3 (Categories Established by Statute), #3. Insect and Disease Infestation. The actions proposed for this project are categorically excluded from documentation in an environmental impact statement (EIS) or an environmental assessment (EA). The Insect and Disease Infestation category is applicable for this project because: 1. The project is in an area designated in accordance with section 602(b) and (c) of the Healthy Forest Restoration Act. The Project Record and project Webpage includes the North Bridgers Forest Health Project Designated Landscape Map and the Montana Designated Landscapes Map which shows that the Project Area is within the designated landscape for Montana. Also available is the Chiefs Designation Letter (USDA 201405).

2. The entire project is in the Wildland Urban Interface as identified in the Gallatin County Community Wildfire Protection Plan (CWPP). The project Vicinity Map on page 2 displays the WUI boundary overlap with the project area. The Fuels Worksheet discusses the Gallatin County Community Wildfire Protection Plan (2006). The CWPP document including a map, is in the Project Record and is available on the Gallatin County Webpage: https://www.readygallatin.com/wpfb-file/gc-cwpp-low-pdf/

3. The project is not located: in congressionally designated Wilderness and Wilderness Study Areas; in areas where the removal of vegetation is restricted or prohibited by statute or by Presidential proclamation; or in areas where the activities described above will be inconsistent with the applicable Land and Resource Management Plan. See the Extraordinary Circumstances portion of this decision memo for more information.

4. The project’s number of acres treated does not exceed 3,000 acres. The total project acres is just under 2,300 acres which is described in the Decision (pp. 3, 9) and Appendix B to the Decision.

5. The project does not include the establishment of permanent roads (p. 9). Additionally:

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a. Temporary roads will be constructed but will be removed no later than three years after the project is completed (p. 10). b. Maintenance or repairs will be conducted on permanent roads that are already established in the project area (p. 10). More detail on road work and temporary roads is on page 9 and in Appendix A under several categories Public Safety and Transportation, Soils and Water.

6. Public notice and scoping was conducted. See discussions on the public involvement process under the Collaboration and Public Involvement section and in the Scoping Packet 2017 in the Project File.

7. The project was developed through a collaborative process that includes multiple interested persons representing diverse interests and is transparent and non-exclusive. See additional discussions on the collaborative process under the Collaboration and Public Involvement section.

8. The best available scientific information was considered to maintain or restore ecological integrity, including maintaining or restoring the structure, function, composition and connectivity. As designed, the project will maintain or restore resiliency in the event of disturbance or change, which I view synonymously with integrity1. The Forest Vegetation Worksheet speaks to science that supports the effectiveness of the proposed treatments toward improving resiliency at the landscape and stand levels. Science presented during scoping was considered either in Worksheets or in the IDT_Scoping Issue Disposition Summary. No science was presented that contradicted the project purpose, need or effectiveness when considered in proper context. Consequently, I conclude that the project considers the best available science as required to maintain ecological integrity including achieving desired structure, function, composition and maintaining connectivity.

9. The project maximizes the retention of old growth and large trees, as appropriate for the forest type, to the extent that the trees promote stands that are resilient to insect and disease. The project as designed retains old growth and large trees consistent with this requirement. Appendix A Design Features and the Forest Vegetation Worksheet 2018 address this requirement.

FINDINGS RELATED TO OTHER LAWS AND REGULATIONS

National Forest Management Act

On April 9, 2012 the Department of Agriculture issued a final planning rule for National Forest

1 Ecosystem integrity. Definition. The ability of an ecosystem to maintain its organization in the face of changing environmental conditions, it is said to have integrity. The integrity of an ecosystem does not only reflect a single characteristic of an ecosystem and therefore encompasses a wide set of criteria.

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System land management planning (2012 Rule) 77 FR 68 [21162-21276]). None of the requirements of the 2012 Rule apply to projects and activities on the Gallatin National Forest, as the Gallatin Forest Plan was developed under a prior planning rule (36 CFR §219.17(c)). Furthermore, the 2012 Rule explains, “[The 2012 Rule] supersedes any prior planning regulation. No obligations remain from any prior planning regulation, except those that are specifically included in a unit’s existing plan. Existing plans will remain in effect until revised” (36 CFR §219.17).

Consistency with the Gallatin Forest Plan as amended The NFMA requires that projects and activities be consistent with the governing Forest Plan (16 USC 1604(i)). The Gallatin Forest Plan (as amended) establishes management direction for the Gallatin portion of the Custer Gallatin National Forest. This management direction is achieved through the establishment of Forest Plan goals and objectives, standards and guidelines, and Management Area (MA) goals and accompanying standards and guidelines. Harvest activities will occur within Forest Plan MAs 1, 7, 8, 9, 11, 12 and 16. This project is consistent with all applicable Forest Plan forest-wide standards (IDT_FP Consistency Summary Table). The resource specialist worksheets that are in the project file (and posted on the project webpage) provide further discussion regarding consistency with applicable direction from the Plan.

Suitability for Timber Production NFMA requires that no timber harvesting shall occur on areas classified as not suited for timber production, except salvage sales, sales necessary to protect other multiple-use values, or activities that meet other objectives on such lands if the forest plan established that such actions are appropriate.

The silvicultural diagnosis process and the Forest Plan were used to determine that all areas associated with this project are suitable for timber harvest using the following criteria:

• Meet the definition of forestland • Technological feasibility exists to protect soil productivity and watershed protection. Forest plan standards, project design criteria, and applicable Best Management practices will be used to protect these resource values. • There is reasonable assurance that lands can be restocked within five years of final harvest. • None of the areas considered for harvest have been withdrawn from timber production

Where timber harvesting is proposed in Management Areas not classified as suitable within the Forest Plan, all treatments are in response to protecting multiple-use values identified in the project purpose and need, such as fuel reduction in the wildland urban interface and are consistent with Forest Plan MA goals such as increasing livestock forage in MA 16 or to maintain sites for the safety and enjoyment of users in MA 1. The MA‘s that are determined to be unsuitable are MA1, MA12 and 16.

Timber Harvest All proposals that involve timber harvest for any purpose must comply with the following four requirements.

— Decision Memo — Page 28 North Bridger Forest Health Project a. Be selected to avoid irreversible damage to soil, slope or watershed conditions. b. Protection is provided for streams, stream banks, shorelines, lakes, wetlands, and other bodies of water from detrimental changes in water temperature, blockages of water courses, and deposits of sediment, where harvests are likely to seriously and adversely affect water conditions or fish habitat.

Project Design Features and Best Management Practices incorporate effective protections for watersheds, fisheries and soils (Water Quality, Aquatic Species and Soils Worksheets 2018). c. Assure that the lands can be adequately restocked within 5 years. Based on past reforestation surveys in similar areas and the regeneration present in the area in areas harvested in the past, there are no indications that with appropriate planning proposed regeneration treatments could not be stocked within 5 years. On this portion of the Custer-Gallatin National Forest, lodgepole pine adequately restocks naturally when not harvested in winter as cones break off of trees during harvest. Lodgepole pine stands prescribed for regeneration harvest will be inspected for stocking at years 1, 3, and 5 following harvest. If unstocked stands still exist at year 3, planting will be considered with species most appropriate to meet stated project goals (DM p. 9 and Appendix A)

Douglas-fir stands will be artificially planted post-harvest due to the low seed viability caused by WSB. These stands will have survival exams at years 1, 3, and 5 following planting. If stocking levels are not acceptable, the area will be replanted. Harsh southerly to westerly slopes were avoided for regeneration units to ensure regeneration success. d. The harvesting system is not chosen because they will give the greatest dollar return. Although timber harvest associated with this project will generate revenue, all treatments have been designed to meet project objectives first, not revenue generation.

Appropriateness of Even-Aged Management and Optimality of Clearcutting When timber is to be harvested using an even-aged management system, a determination that the system is appropriate to meet the objectives and requirements of the Forest Plan must be made and, where clearcutting is to be used, must be determined to be the optimum method. a. For clearcutting, it is determined to be the optimum method, and for other such cuts it is determined to be appropriate, to meet the objectives and requirements of the relevant land management plan [16 USC 1604 Sec.6 (g)(3)(F)(i)]: Even-aged harvests are proposed on 667 acres (some of these acres are thinning acres in units with a “patch cut/thin” prescription). Approximately 380 of these acres are dominated by Douglas-fir; the remainder are dominated by lodgepole pine. Clearcutting was determined to be the optimum regeneration method for meeting management objectives for each of these areas by the project silviculturist. Criteria used to make this determination included: species composition relative to management direction and availability of desired species for seed sources, species susceptibility to observed insect agents, presence of disease infections which

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would be transmitted to the regenerated stand or where non-susceptible species conversion is necessary, and stands subject to wind throw if residual trees were retained. Clearcutting was prescribed for Douglas-fir stands (instead of shelterwood or seed tree harvests) because of the prevalence of root disease and windthrow risk in the project area, and because of the multi-storied structure that would persist with shelterwood or seed tree and the hazard from WSB that would remain if these methods were chosen. b. The interdisciplinary review as determined by the Secretary has been completed and the potential environmental, biological, esthetic, engineering, and economic impacts on each advertised sale area have been assessed, as well as the consistency of the sale with the multiple use of the general area [16 USC 1604 Sec.6 (g)(3)(F)(ii)]: Full interdisciplinary review has been completed for this project. All treatments meet the multiple use goals and objectives in the Gallatin Forest Plan for designated Management Areas (IDT Forest Plan Consistency Summary Table). Worksheets for the disciplines considered are in the Project File. c. Cut blocks, patches or strips are shaped and blended to the extent practicable with the natural terrain [16 USC 1604 Sec.6 (g)(3)(F)(iii)]: Treatment areas are designed to blend as much as possible with the existing terrain. See scenery design features included in the decision (Appendix A). d. Cuts are carried out according to the maximum size limit required for areas to be cut during one harvest operation, provided, that such limits shall not apply to the size of areas harvested as a result of natural catastrophic conditions such as fire, insect and disease attack, or windstorm [FSM Region I supplement 2400-2001-2-2471.1, 16 USC 1604 Sec.6 (g)(3)(F)(iv)]: Regeneration harvest is proposed as described in (a) and all units are less than 40 acres in size (Appendix B Table B-1).

Culmination of Mean Annual Increment

Stands of trees are harvested according to requirements for culmination of mean annual increment of growth (16 USC 1604(m)). This is a concept applied to regeneration harvest. Due to the growth impacts from WSB, stand growth has been affected and growth has likely culminated already. (Forest VegetationWorksheet).

Temporary Road Construction

Construction of temporary roadways in connection with timber contracts, and other permits or leases constructed shall be designed with the goal of reestablishing vegetative cover on the roadway and areas where the vegetative cover has been disturbed by the construction of the road, within ten years after the termination of the contract, permit, or lease either through artificial or natural means. Such action shall be taken unless it is

— Decision Memo — Page 30 North Bridger Forest Health Project

later determined that the road is needed for use as a part of the National Forest Transportation System (16 USC 1608(b)).

Standards of roadway construction: Roads constructed on National Forest System lands shall be designed to standards appropriate for the intended uses, considering safety, cost of transportation, and impacts on land and resources (16 USC 1608(c)). No permanent roads are proposed. Roads constructed for project activity should be designed with minimum engineering standards necessary to accomplish the task safely and with minimal impacts to resources. Temporary project roads will be decommissioned within three years following completion of project-related activities. (p. A-2)

Maintenance of the Diversity of Plant and Animal Communities Forest Plan goals, objectives, standards, and guidelines address maintaining a diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives. This requirement is intended to be met at the forest scale through Forest Plan Implementation. The purpose and need for the project incorporates a number of forest wide goals and standards moving the project area toward the goals. Forest Plan consistency is discussed in all specialist worksheets. In addition to applying this Forest Plan direction, project designs were prescribed by the silviculturist in coordination with the wildlife biologist, fisheries biologist and botanist to address plant and animal community needs (see Forest Vegetation, Wildlife, Botany and Aquatic Species Worksheets 2018). As designed, this project will achieve multiple use objectives based on the suitablilty and capability of the land, which contributes to the needs of a diversity of plant and animal species..

Federal law and direction applicable to sensitive species include the National Forest Management Act (NFMA) and Forest Service Manual 2670. The NFMA directs that guidelines for land management plans provide for diversity of plant and animal communities based on the suitability and capability of the specific land area in order to meet overall multiple-use objectives [16 USC 1604 Sec.6 (g)(3)(B)]. The Gallatin Forest Plan contains standards for sensitive species. The Regional Forester has approved the sensitive species list (those plants and animals for which population viability is a concern) (FSM 2610.5). The analysis and projected effects on all sensitive species listed as occurring or possibly occurring on the Custer Gallatin National Forest is documented in the Biological Evaluations contained in the project file and summarized in the Extraordinary Circumstances section of this document (Wildlife Report 2018, Botany Biological Evaluation 2018 and Aquatic Worksheet 2018). The findings document that the authorized action will have no adverse impacts on some sensitive species but for other species activities May Impact Individuals or Habitat, but will not contribute to a trend toward federal listing. The diversity of plant and animal communities will be maintained, consistent with the NFMA.

Endangered Species Act

The Endangered Species Act of 1973 (as amended) requires Federal agencies to insure that any activities they authorize, fund, or carry out do not jeopardize the continued existence of any species that is Federally listed, or proposed for listing, as Threatened or Endangered (Section 7).

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On August 4, 2017 the U.S. Fish and Wildlife Service issued a list of threatened, endangered, proposed, and candidate species that may be present on the Custer Gallatin National Forest. There are five terrestrial wildlife species on this list, of which two, Canada lynx and the North American wolverine, may be present in the project area. In addition, Canada lynx designated critical habitat is present on the Custer Gallatin, but entirely outside the project area. No federally listed threatened or endangered fish or plant species or critical habitat occur in the project area.

As displayed in the Extraordinary Circumstances section, the Forest Service determined that authorized activities may affect, but is not likely to adversely affect, Canada lynx. Wolverine is a species proposed for listing. It is recognized that project activities may have a negative impact on individual wolverines and/or their habitat, but not to the point where the species’ existence is jeopardized (Wildlife Worksheet 2018). (Biological Assessment 2018). Consistent with the Implementing Regulations for the Endangered Species Act, informal consultation was initiated and U.S. Fish and Wildlife Service concurred with these findings (USFWS 20180209). No conference was required for wolverine; consistency with the Programmatic Biological Assessment for the North American Wolverine (USDA 2014) is documented in the Wolverine Programmatic Screening Compliance Worksheet 2018.

Migratory Bird Treaty Act and Executive Order 13186

The IMBTA implements various treaties and conventions between the , Canada, Japan, Mexico and the former Soviet Union for the protection of migratory birds. A migratory bird is any species or family of birds that live, reproduce or migrate within or across international borders at some point during their annual life cycle. Under the Act, it is unlawful to pursue, hunt, take, or capture a migratory bird except as permitted by regulation (16 U.S.C. 703-704). The regulations at 50 CFR 21.11 prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, or possessing migratory birds, including nests and eggs, except under a valid permit or as permitted in the implementing regulations.

Executive Order (EO) 13186 (66 Fed. Reg. 3853, January 17, 2001) clarified the responsibilities of federal agencies in providing for the conservation of migratory bird species under the IMBTA. This EO requires agencies to ensure that environmental analyses evaluate the effects of federal actions and agency plans on migratory birds, with emphasis on species of concern.

Effects to Neotropical Migratory Birds are analyzed in the Wildlife Report 2018. Consistency with the regulatory framework is described in this document. Please refer to Tables 1 and 2 in the report for compliance with migratory bird-related Forest Plan standards.

This project analyzes the impacts of agency actions on migratory birds, with an emphasis on species of concern and their habitat. The analysis considers the long term benefits and short and long term adverse effects to migratory birds. This project may affect individual migratory birds in treatment units; however, there would be no effects at the population level. For these reasons, the project would be consistent with the International Migratory Bird Treaty Act and Executive

— Decision Memo — Page 32 North Bridger Forest Health Project

Order 13186. Please refer to the Wildlife Report 2018 for a full discussion of the direct, indirect, and cumulative effects on Neotropical migratory birds.

Bald and Golden Eagle Protection Act

The Bald and Golden Eagle Protection Act (BGEPA) (16 U.S.C. 668-668c), enacted in 1940, and amended several times since then, prohibits anyone, without a permit issued by the Secretary of the Interior, from "taking" bald eagles, including their parts, nests, or eggs. The Act provides criminal penalties for persons who "take, possess, sell, purchase, barter, offer to sell, purchase or barter, transport, export or import, at any time or any manner, any bald eagle ... [or any golden eagle], alive or dead, or any part, nest, or egg thereof." The Act defines "take" as "pursue, shoot, shoot at, poison, wound, kill, capture, trap, collect, molest or disturb."

Currently no eagle nests are known to occur in the project area. If an eagle nest is discovered, project design measures will be implemented to eliminate disturbance to nesting eagles, especially during critical time periods (courtship, egg laying, etc.). Incorporation of these measures will make the project consistent with the BGEPA should a nest be discovered. See the Wildlife Worksheet 2018 for more information.

Montana State Water Quality Standards and Clean Water Act

Clean Water Act (CWA) compliance will be achieved through the application of effective Best Management Practices (BMP) (Design Features). All activities will be designed to protect water quality and aquatic resources through the use of BMPs, which are the primary mechanism to enable the achievement of state water quality standards and minimize non-point impacts.(Hydrology and Aquatic Species Worksheets 2018).

There are no 303(d) listed streams or streams for which TMDLs have been developed within the project assessment area. The Decision requires implementation of effective project design criteria and BMPs, in accordance with Montana water quality standards that require the use of effective BMPs to protect beneficial uses. All project operations will be carried out in a manner consistent with the protection of soil, watershed, and fish resources through the application of project design criteria, BMPs, and standard timber sale contract provisions. The decision will comply with TMDL implementation strategies for local TMDL streams. Analysis described above indicates that sediment effects on downstream TMDL streams will likely be negligible and too small to measure. The required surfacing of FS Road #631 and slump repair on FS Road #632 will result in a long term reduction of road-sourced sediment in the project area. This long term benefit will be realized once the temporary increase in sediment yield in the project area has fully recovered, approximately 6 years after project implementation.

Design criteria for this project have adopted guidelines set forth in the Montana SMZ law and has, specific to this project, surpassed those guidelines in terms of protection of streamside areas. The Montana SPA requires the U.S. Forest Service to apply for a permit (SPA 124) when a project may affect the bed or banks of any stream in Montana. Permits will be obtained for all locations where a temporary road crossing is necessary. Proposed temporary road alignments

— Decision Memo — Page 33 North Bridger Forest Health Project indicate that temporary road crossings will be necessary on unnamed tributary channels accessing treatment units 23 and 24. The Montana Department of Environmental Quality – Water Quality Section was consulted and they had no concerns with the project (DEQ Email 3/2018)

Clean Air Act (CAA) The CAA of 1977 (as revised 1991) requires the Environmental Protection Agency (EPA) to identify pollutants that have adverse effects on public health and welfare and to establish air quality standards for each pollutant. Each state is also required to develop an implementation plan to maintain air quality. The CAA (Section 110) requires states to develop State Implementation Plans (SIPS) which identify how the State will attain and maintain national air quality standards. Three elements of the Clean Air Act generally apply to management activities that produce emissions: (1) protection of ambient air quality standards; (2) conformity with state implementation plans; and (3) protection of visibility in Class 1 airsheds. Burning activities will be coordinated through the Montana/Idaho Airshed Group to ensure compliance with the CAA (Appendix A, p. A-2).

Healthy Forest Restoration Act (HFRA) Passed in December 2003, the HFRA provides improved statutory processes for hazardous fuel reduction projects on certain types of at-risk National Forest System and Bureau of Land Management lands and also provides other authorities and direction to help reduce hazardous fuel and restore healthy forest and rangeland conditions on lands of all ownerships. The Agriculture Act of 2014 (or Farm Bill) was signed into law on February 7, 2014. Section 8204 of the Farm Bill amends Title VI of the HFRA by adding section 602 (Designation of Treatment Areas) and section 603 (Administrative Review) to address qualifying insect and disease infestations on National Forest System lands. This project is in an area designated as part of an insect and disease treatment program and meets the limitations and requirements for using the categorical exclusion created under Section 603, Title VI of HFRA. Also see previous discussion under Applicable Categorical Exclusion section.

National Historic Preservation Act (NHPA)

Section 106 of the NHPA directs all Federal agencies to take into account the effects of their undertakings (actions, financial support, and authorizations) on properties included in or eligible for the National Register. Heritage resource surveys have been completed for all units/areas where activities are proposed or where other disturbance may occur. The project is not expected to have any effects on heritage resources because the three known sites will be avoided. The Montana State Historic Preservation Office concurred with these findings in a letter dated 4/12/2018. Recognizing the potential exists for unidentified sites to be encountered or disturbed during project activity, standard provisions for their protection will be included in the contract to implement this project. These provisions will allow the Forest Service to unilaterally modify or cancel a contract to protect heritage resources, regardless of when they are identified. This provision will be used if a site is discovered after project activities have begun. This project is in compliance with the Region 1 programmatic agreement with the State Historic Preservation Office and the Advisory Council on Historic Preservation. (Heritage Worksheet 2/2018 and

— Decision Memo — Page 34 North Bridger Forest Health Project

SHPO Concurrence Letter 2018)

Environmental Justice Executive Order

On February 11, 1994, President Clinton signed Executive Order 12898 requiring each Federal agency to achieve environmental justice as part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies and activities on minority and low-income populations. The transparent, non- exclusive collaborative process used to develop this project, as well as communication with tribes, ensured fair treatment and meaningful involvement of all people regardless of race, color, national origin, or income with respect to the development, implementation, and enforcement of environmental laws, regulations, and policies. No environmental justice issues were identified for this project as it is not expected to lead to disproportionately high and adverse impacts on minority or low-income populations.

ADMINISTRATIVE REVIEW OPPORTUNITIES Decisions that are categorically excluded from documentation in an Environmental Assessment (EA) or Environmental Impact Statement (EIS) are not subject to an administrative review process (pre-decisional objection process) (Agriculture Act of 2014, Subtitle A, Sec. 8006).

— Decision Memo — Page 35 USDA North Bridger Forest Health Project a

IMPLEMENTATION DATE The project is expected to be implemented beginning in late summer of 2018 including contract preparation with contract award planned in 2019. For additional information concerning this decision, contact: Teri Seth NEPA Team Leader Bozeman Ranger District 3710 Fallon St., Suite C Bozeman,tse: .fed. MTc 59718. LJ_

Forest Supervis

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. Persons with disabilities who require alternative means of communication for program information (e.g., Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA's TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English. To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD- 3027, found online at hftp://www.ascr.usda.gov/complaint filing cust.html and at any USDA office or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected] . USDA is an equal opportunity provider, employer and lender.

- Decision Memo - Page 36 North Bridger Forest Health Project

REFERENCES CITED These documents are available on the Project Webpage: https://www.fs.usda.gov/project/?project=48493

Worksheets and Analysis

Aquatics Worksheet. Bruce Roberts, Fisheries Biologist. Aquatic Species Worksheet. 2018. Bozeman, MT.

Biological Assessment. Randy Scarlett, Wildlife Biologist. BA for Canada Lynx and Wolverine. 2018. Bozeman, MT.

Botany Worksheet. Suzanne DiGiacomo, Botanist. 2018. Bozeman, MT.

Botany Biological Evaluation. Suzanne DiGiacomo, Botantist, 2018. Bozeman, MT.

Climate Worksheet. Teri Seth, Biological Scientist. 2018. Bozeman, MT.

Forest Vegetation Worksheet. Johanna Nosal, Silviculturist. 2018. Bozeman, MT.

Fuels Worksheet. Tim Brickell and Fred Jones, Fuels Specialists. 2018. Bozeman, MT.

Heritage Worksheet. Walt Allen and Halycyon LaPoint, Archeologist. 2018. Bozeman, MT.

Hydrology Worksheet. Dale White, Hydrologist. 2018. Bozeman, MT.

Invasive Weeds Worksheet. Karen Kitchen, Rangeland Technician. 2018. Bozeman, MT.

Range Worksheet. Teri Seth, Biological Scientist. 2018. Bozeman, MT.

Recreation Worksheet. Wendi Urie, Recreation Specialist. 2018.

Roadless Worksheet. Wendi Urie, Recreation Specialist. 2018

Sale Feasibility narrative Report. Nate Motzko, Presale Forester. 2017. Bozeman, MT.

SceneryWorksheet_2018. Jane Ruchman, Landscape Architect. 2018. Bozeman, MT.

Soils Worksheet. Tom Keck, Soils Scientist. 2018. Bozeman, MT.

Transportation Worksheet. Grant Morrison, Civil Engineer. 2018. Bozeman, MT.

Wildlife Report. Randy Scarlett, Wildlife Biologist. 2018.

Wildlife Worksheet. Randy Scarlett, Wildlife Biologist. 2018.

Wolverine Programmatic Compliance Worksheet. 2018. Randy Scarlett, Wildlife Biologist. Bozeman, MT.

— Decision Memo — Page 37 North Bridger Forest Health Project

Other References in the Decision Memo

COL_North Bridger Collaborative Mailing List. Collaboration Document. 2017. Bozeman, MT.

COL_MeetingDocuments_8/30/2017. Collaboration Documents. Meeting and Field Trip Materials for August 30 Event. Bozeman, MT.

COL_MeetingDocuments_10/3/2017. OpenHouseMateriaCollaboration Meeting presentation materials prepared by the IDT for October 3rd Event. . Bozeman, MT.

COL_Collaborative Outreach Packet. Compilation of the outreach documents related to the North Bridger Collaborative Outreach. 2017. Bozeman, MT.

COL_PlanningSummary. Summary of the collaboration planning. Compiled by Teri Seth, IDT Leader. Bozeman, MT

DEQ Email 3/2018. Montana Department of Environmental Quality, Water Quality. Email regarding the project. Helena, MT.

Egan, J., Lockman, B. 2016. Evaluation of Insect and Disease Issues for Bridger Forest Health Project Area on the Custer-Gallatin National Forest. FHP Report MFO-TR-16-41. Missoula, MT: U.S. Department of Agriculture, Forest Service, Northern Region, Forest Health Protection.

Fettig, C. J., K. D. Klepzig, R. F. Billings, A.S. Munson, T. E. Nebeker, J.F. Negron, and J.T. Nowak, 2007. The Effectiveness of Vegetation Management Practices for Prevention and Control of Bark Beetle Infestations in coniferous forests of the Western and Southern United States.

Fettig, C. J., Gibson, K. E., Munson, A. S., & Negron, J. F. 2014. Cultural Practices for Prevention and Mitigation of Mountain Pine Beetle Infestations. Forest Science, 13-32.

GC CWPP-2006. Gallatin County Community Wildlfire Protection Plan. https://www.readygallatin.com/wpfb-file/gc-cwpp-low-pdf/

Gallatin National Forest Plan (amended 2015). USDA Forest Service, Gallatin National Forest Plan as amended 2015. Bozeman, MT.

Gibson, K. E. 2004. Mountain Pine Beetle Management. Chapter 4.2. Forest insect and disease management guide for the northern and central . USDA Forest Service, Northern Region, State and Private Forestry. 16 pp.

Green, P., J. Joy, D. Sirucek, W. Hann, A. Zack, and B. Naumann, 2011. Old-Growth Types of the Northern Region. R-1 SES 4/92 (errata corrected 12/11). USDA Forest Service, Northern Region, Missoula, MT.

IDT_FPTable. FP Consistency Summary Table. Compilation Table showing Forest Plan Consistency. Teri Seth. 201805. Bozeman, MT.

IDT PA Changes since 8/24. Memo documenting the changes to the project proposal from collaboration, scoping and IDT input. IDT Compilation. 101710. Bozeman, MT

IDT_Scoping Packet. Scoping Letter, mailing lists and Media Releases. 201711. Bozeman, MT.

— Decision Memo — Page 38 North Bridger Forest Health Project

IDT_Scoping Issue Disposition Summary. Table showing how scoping issues were considered. Compiled Teri Seth. 201804. Bozeman, MT.

Jones, B.E., Rickman, T.H., Vazquez, A., Sado, Y., Tate, K.W., 2005. Removal of encroaching conifers to regenerate degraded aspen stands in the Sierra Nevada. Restor. Ecol. 13, 373–379.

Kegley, S. 2011. Douglas-fir Beetle Management. In F. H. Protection, Forest Insect and Disease Identification and Management. USDA Forest Service.

Lewellen_Memo_2018. Memo to the file regarding MA 99 lands. Corey Lewellen, District Ranger. 2018. Bozeman, MT.

Map - Designated Areas, Recommended Wilderness and Special Emphasis Area Map for the Bridger Mountain Range

Map - Montana Designated Landscapes Map

Map - North Bridgers Forest Health Project Designated Landscape Map

Negron, J.F.; Schaupp Jr.; W.C., Gibson K.; Anhold J.; Hansen D.; Their R.; Mocettini, P. 1999. Estimating extent of mortality associated with the Douglas-fir beetle in the Central and Northern Rockies. Western Journal of Applied Forestry. 14(3): 121-127.

Pederson, L., N. Sturdevant, D. Blackford. 2011. Western spruce budworm management. Chapter 6.1 Forest insect and disease management guide for the northern and central Rocky Mountains. USDA Forest Service, Northern Region, State and Private Forestry. 10 pp.

R1 :PMOA; SIS. Region 1 Programmatic Memorandum of Understanding.

Shepperd, W.D. 2001. Manipulations to regenerate aspen ecosystems. In Sustaining aspen in western landscapes: symposium proceedings. Compiled by W.D. Shepperd, D. Binkley, D.L. Bartos, T.J. Stohlgren, and L.G. Eskew. USDA For. Serv. Proc. RMRS-P-118. pp. 355–366.

Shepperd, W.D., Rogers, P.C., Burton, D. and Bartos, D.L., 2006. Ecology, biodiversity, management, and restoration of aspen in the Sierra Nevada. General Technical Report RMRS-GTR-178. 2011

SHPO Concurrence Letter 2018. Montana State Historic Preservation Office Letter of Concurrence. 201804. Helena, MT.

USDA_201405. Chiefs Designation Letter for landscapes Under Section 602.

USDA 2014. Gallatin [Forest] Farm Bill Sec. 602 Areas Preliminary Assessment

USDA 2006. Gallatin Forest Travel Management Plan

USFWS 20180209. US Fish and Wildlife Service Letter of Concurrence for the North Bridger Forest Health Project.

— Decision Memo — Page 39 North Bridger Forest Health Project

APPENDIX A - DESIGN FEATURES, MITIGATION AND MONITORING

Forest Vegetation

1. Silviculturist will be consulted where treatment deviations are required during contract execution, as a result of changed or unidentified conditions that materially affect the intended treatment as described in the detailed site specific silvicultural prescription. As needed, the silvicultural prescription will be modified and re-approved by a certified silviculturist and the District Ranger. Anticipated Effectiveness: The effectiveness of achieving intended results will be high since a certified silviculturist will determine the best course of action if this situation were to arise and line officer approval will be necessary.

2. Prescribed burning in regeneration units (clearcut, patch cut, and group selection) will be completed within two years of harvest activity completion, unless agreed to by a certified silviculturist. Location and timing of other prescribed burned units will be planned in coordination with a certified silviculturist. This effects units 7, 9, 13, 16, 18, 23, 28, and 51. Anticipated Effectiveness: This requirement will be effective at reducing the chances of established seedling mortality in regeneration units and ensuring that reforestation standards in the NFMA will be met. If surveys show regeneration is minimal after two years and burning is proposed, it will be beneficial to the establishment of regeneration.

3. Mechanical logging activities of clearcut, patch cut, and group selection units will be done at times of the year with no snow cover to facilitate planting or natural regeneration. This effects units 2, 6, 7, 9, 10, 13, 16, 17, 18, 23, 26, 28, 33, 35, 36, 46, 50, 51, 56, and 59. Anticipated Effectiveness: Effectiveness will be moderate, as machinery does not cross over large portions of treatment units and does not always expose bare mineral soil. This feature will make natural regeneration and planting more successful in order to meet reforestation standards from NFMA by improving site preparation in those areas.

4. Design thinning treatments in old growth stands to exceed minimum old growth structure (as defined by Green et al., 2011) post-harvest. Anticipated Effectiveness: Effectiveness will be high, as marking guidelines will dictate that enough large trees be retained in old growth units to keep the stand’s old growth character. Although levels of old growth in the Bridger Bangtail mountains are below Forest Plan standards, this design feature ensures that old growth levels will not be reduced by proposed activities.

5. Maximize the retention of the largest and healthiest trees, as appropriate for the forest type, to the extent the trees promote stands that are resilient to insect and disease. Anticipated Effectiveness: Ensures consistency with the requirements for using the Insect and Disease Infestation category established by Statute.

— Decision Memo — Page A-1 North Bridger Forest Health Project

Fuels

1. Heavy natural fuel concentrations may require hazardous fuel treatments like broadcast burn (BB), jackpot burn (JP), machine pile/burn and creation of fuel breaks. These areas have been field verified. Burn boundaries may extend outside of cutting boundary to support safe and efficient operations. Other options could include piling, trampling and crushing. Units include 6, 7, 9, 10, 16, 18, 23 and 59. Anticipated Effectiveness: The treatments reduce surface and ladder fuel build-up; which reduces fire behavior and the chance of crown fire. 2. Forest Service or purchaser will burn landings, then scarify and seed landings. Anticipated Effectiveness: This will occur after harvest activities are completed. The activity removes through burning, all activity slash that was whole tree yarded and piled at the landing and provides for rehabilitation of the landing pile site after the burn operations are completed. 3. Prescribed burning is conducted based on weather and site specific conditions and will take place under the guidelines set forth in a prescribed fire burn plan developed specifically for this project area. Prescribed burn plans are required to address parameters for weather, air quality and contingency resources and are implemented in full compliance with the Montana Department of Environmental Quality (MTDEQ) air program with coordination through the Montana/Idaho Airshed Group. Anticipated Effectiveness: Coordination with the Airshed Group ensures compliance with Air Quality requirements related to smoke and the Forest Plan.

Heritage

1. Avoid archaeological sites. Anticipated Effectiveness: There are two prehistoric sites and one historic site in locations that could have been selected for “landings”. These site locations will be mapped as avoidance areas in design and implementation phases. They will be flagged on the ground for avoidance prior to, and monitored during, project implementation (see Allen 2018).

Public Safety and Transportation

1. Best Management Practices (BMP’s) will be applied during project implementation and no permanent roads will be established. Anticipated Effectiveness: Very effective. BMP’s are very effective at reducing sediment delivery to streams and reducing the negative impacts of roads.

2. Roads constructed for project activity should be designed with minimum engineering standards necessary to accomplish the task safely and with minimal impacts to resources. Temporary project roads will be decommissioned within three years following completion of project-related activities. Decommissioning may include a wide range of activities (log, debris, and barrier placement, water-barring and hydrological stabilization, full re-

— Decision Memo — Page A-2 North Bridger Forest Health Project

contouring, etc.), at a minimum these temporary routes will not be drivable for either the public or administrative use. No public motorized use of temporary roads constructed for this project will be allowed. Anticipated Effectiveness: Very effective. Decommissioning can be successful, the terrain of this project area is advantageous for successful road closures, including full revegetation and exclusion of future use.

3. Use gates, barricades, or earthen barriers to close roads not open to public motorized use during project implementation. Permanent barricade devices will be considered on an as needed basis when decommissioning temporary roads. Anticipated Effectiveness: High to moderately effective. Gates and barricades can be subject to vandalism, this will require maintenance. Permanent barriers are effective at excluding future use.

4. Implement temporary traffic control measures for public safety in accordance with Forest Service signing policy and the Manual on Uniform Traffic Control Devices. Anticipated Effectiveness: Very effective. Based on past projects, these traffic control measures are effective at protecting the public and preventing/minimizing accidents.

5. Restrict hauling during spring break-up period. Hauling should be done when the roads are relatively dry or when frozen in the winter. This will restrict the working season and may require some flexibility in the schedule of the Purchaser. Anticipated Effectiveness: High to moderately effective. Spring break-up is when the majority of roads are vulnerable to damage and when sediment delivery to streams is of greatest risk. Closure eliminates this potential impact.

6. Perform road improvements on the following roads: • Road #631 – Reshape road prism, approx. 2000 feet of intermittent aggregate base placement. Widening 1 switchback corner. • Road #974 – Reshape road prism, establish drainage, approx. 1 mile of intermittent aggregate base placement. Widening 2 switchback corners. • Road #753D – Widen 1 switchback corner • Road #632 – Reestablish road prism, including establishing required width on corners, establish drainage, mitigate the effects of two slump/soft roadbed areas. Anticipated Effectiveness: These improvements will allow project implementation, as well as improve the long-term durability of the road system.

Range

1. Existing range improvements will be protected and repaired by the contractor if damaged. There is a range fence in Unit 30, a campground fence in Unit 33, and private fences adjacent to Units 16 and 40. Four range tanks are located within the project area, but none are within treatment units. The best way to protect the improvements will be avoidance. Anticipated Effectiveness: This provision in timber sale contracts (Protect

— Decision Memo — Page A-3 North Bridger Forest Health Project

Improvements) has been effective at ensuring protection of, or replacement of, improvements for many years.

2. Natural barriers that limit stock presence in riparian areas will be maintained. Tree removal is the only known natural barriers that might be impacted. It would be difficult to anticipate in advance how tree removal/thinning may change cattle trailing. Routine administration of the allotments and communication with permittees will be the primary monitoring necessary to identify any needs to create additional barriers such as fencing or log placement. Anticipated Effectiveness: The riparian design feature requiring slash placement on temporary roads will be expected to deter cattle movement into riparian areas. Allotment permittees are also required by the terms and conditions of their permit to protect riparian areas. A combined monitoring effort is in the best interest of all groups with an interest in riparian protection. Downed logs/slash and fencing where needed, is a common practice and have been an effective deterrent for cattle over many decades.

3. In the spring when grazing operations are being planned for the year, advance coordination will occur between the Forest Service and grazing and timber operators in regard to timing of operations in order to minimize potential conflicts with cattle in allotments during operations and during rehabilitation. Grazing seasons are generally July 1-October 15. Spring planning occurs in March and April. The intent will be to minimize disruption of grazing operations through coordination. Anticipated Effectiveness: Early coordination provides flexibility in timing of grazing operations to ensure minimal conflicts between grazing and timber operators and to ensure protection of rehabilitation work and new tree growth. Advance coordination has been a common practice and has been effective for decades in balancing these uses in the same area. Range permittees have expressed support for the project and potential improved forage in allotments (Clark memo 12/2017). Based on past experience, these permittees also expressed confidence that they could work around the active logging areas to avoid conflict . 4. Newly seeded areas in cattle allotments will be protected from grazing through slash placement, timing or other means. Anticipated Effectiveness: These types of deterrents have been used routinely in cattle allotments and have shown to be effective at allowing added time for new growth and establishment. This is a common practice.

Recreation

1. Visitors to recreation sites (including the Battle Ridge Campground and dispersed campsites), trails/trailheads and rental cabins (Battle Ridge Cabin) will be notified using a combination of methods such as clear signage, visitor contacts, public notices, social media and press releases that there may be increased noise, traffic, logging trucks, heavy equipment in the area, on forest roads and trails. Any temporary road closures or blockages must be clearly marked and made publicly aware (social media, press releases,

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signs) well ahead of time so visitors have ample time to plan their trips to the forest for recreation purposes Anticipated Effectiveness: Utilizing multiple methods to notify the public of implementation activities will reach more citizens to allow them to adjust where they recreate based on current activities happening in the project area. Past efforts to outreach information to the public via the proposed methods have been effective in decreasing impacts to recreationalists and should work well for this project.

2. Holders of special use permits (such as recreation event organizers and outfitters) will be notified prior to treatment in the vicinity of their authorization. Anticipated Effectiveness: Recreation event planners and permitted outfitter and guides are a small subset of the recreating public with known contact information and the ability to disseminate information further to their clients. The design criteria should effectively mitigate conflicts with these recreational events.

3. No log hauling will be allowed on weekends or holidays to accommodate increased weekend visitor use unless otherwise agreed upon by the District Ranger and the district/zone recreation specialist. Anticipated Effectiveness: Recreational use in the area peaks during weekends thus limiting hauling activities to weekdays only will reduce congestion on roadways and conflicts with recreational users. This design criteria is a common method for reducing congestion and has worked well in the past.

4. No staging or storage, nor the decking or piling of slash will occur at trailheads or on Forest Service trails or roads unless otherwise agreed to by the District Ranger. Anticipated Effectiveness: Trailheads, roads and trails will remain accessible for public use by restricting equipment use, staging or storage, decking or piling from these areas. By separating project activities from recreational infrastructure, conflicts will be reduced. Past projects have included similar design criteria and were effective.

5. All recreation infrastructure such as campground improvements, trailhead improvements, trail signs, trails, etc. will be protected from damage or repaired to their original condition. Anticipated Effectiveness: Protecting recreation infrastructure is a common requirement of vegetation management projects and has resulted in the past in protecting these investments from damage or resulted in the repair of damaged structures.

6. Roads #6310 and 631B through the Crosscut Mountain Sports Center Permit Area and the South Fork of Brackett Creek Road #631 will not be plowed between November 15th and April 15th). Anticipated Effectiveness: Winter restrictions on road plowing in the South Fork of Brackett Creek will eliminate harvest activity conflict with the Nordic ski area operations at Crosscut Mountain Sports Center and allow for continued winter cross-country ski and backcountry ski access in the area. This design criteria was utilized in the South Bridger Forest Health project to mitigate conflicts with operations and

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was effective.

7. In Unit 51 the Crosscut Mountain Sports Center trails will be marked and slash will be minimized on ski trails and on Road #6310. Anticipated Effectiveness: The marking of the winter Nordic ski trails at Crosscut Mountain Sports Center and requirement of minimized slash will protect the trails from impacts from project activities.

8. Slash piles for units 51 and 52 (along Road #6310) will be located such that they do not interfere with Crosscut Mountain Sports Center operations and ski trails. Anticipated Effectiveness: Slash piles may not be burned the same season they are generated and thus need to be located off Nordic ski trails to allow for winter operations at Crosscut Mountain Sports Center. Strategically locating slash piles will be effective in mitigating effects to the Nordic ski areas operations.

9. Temporary roads will not be constructed over top of existing single track National Forest system trails except to cross the trail. Anticipated Effectiveness: Temporary roads will be laid out so that they are not constructed over top existing single track trails. Roads may cross a single track trail but will not change the character of the trails from a narrow single track to a wider road. This design criteria will be effective in mitigating concerns that the desired recreational opportunity with single track trails, which is more primitive and challenging, will not be lost.

10. If there is a need for winter hauling, either North Fork Brackett Creek Road #632 or Fairy Lake Road #74 will be plowed during a given winter season (November 15th – April 15th) leaving the other road snow covered for snowmobile access. 11. Anticipated Effectiveness: The North Fork Brackett Creek Road and the Fairy Lake Road are groomed winter snowmobile routes leading to popular terrain for snowmobilers and backcountry skiers. The two routes are connected by a marked snowmobile trail west of the project area. By plowing only one of these roads during a given winter operating season the other route will provide access to the popular destinations in both areas.

12. No skidding will occur along summer or winter trails except to cross them. Anticipated Effectiveness: Using this design criteria to protect trails is a common requirement of vegetation management projects and has resulted in the past in effectively protecting trails from extensive damage during past projects.

Roadless

1. No roads or skid trails will be constructed within the (Inventoried Roadless Area (IRA). Anticipated Effectiveness: Using this design criteria to protect Inventoried Roadless Areas is a common requirement of vegetation management projects and has in the past resulted in effectively protecting the character of roadless areas during past projects and

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ensures compliance with the roadless rule.

2. No treatment units or areas will be located in the IRA. Anticipated Effectiveness: Using this design criteria to protect Inventoried Roadless Areas is a common requirement of vegetation management projects and has in the past resulted in effectively protecting the character of roadless areas during past projects and ensures compliance with the roadless rule.

3. Cutting unit boundaries adjacent to the IRA will be clearly marked and mapped to avoid the IRA. Anticipated Effectiveness: Using this design criteria to protect Inventoried Roadless Areas is a common requirement of vegetation management projects and has in the past resulted in effectively avoiding unintended activity in the IRA therefore, protecting the character of roadless areas and ensures compliance with the roadless rule.

Scenery

The following design features are required to ensure compliance with the Forest Plan standards for the visual (scenery) resource, within the applicable temporal bounds, which are 5 years after completion of all project-related activity, including burning, regrading, scarifying, seeding and regrowth. Not all of these design features are applicable, feasible or necessary in all proposed units, depending upon the existing local scenic character, visibility of the proposed units from the KOPs, and the assigned FP VQO. Table A-1 Scenery Design Feature Application displays which design features, if any, will be applied for each unit.

1. Shapes, Edges and Interiors of the Units A. Units should be shaped to avoid discernible unnatural-appearing straight lines and sharp corners. B. Where existing forest character and trees allow, trees and tree-clumps that are left within units should avoid on-center, rigid, unnatural-appearing spacing, especially on steeper, visible slopes. C. In the foreground (within ½ mile) of Road #86 and the Fairy Lake Road where it passes through sections 22, 23 and 24, trees with the fullest crowns and large diameter “character” trees should be retained, where consistent with the silvicultural prescription. D. Where possible, abrupt, unnatural-appearing transitions between a cut unit and adjacent dense trees should be avoided. Depending upon the visual character of the trees within and adjacent to the units, this might be accomplished by: locating the unit edges in natural openings; creating a transition zone along the edge that leaves more to transition into adjacent dense forest or cuts more to transition into existing open areas. E. Stumps within 100 ft. of Road #86 within units assigned a FP VQO of “Partial Retention” and 200ft within units assigned a FP VQO of “Retention” should be as low as possible. After logging, highly visible stumps will be treated to reduce discernability. F. After project completion, tree markings should not be discernible within 200 ft by drivers along Road 86 in those units located in areas assigned a FP VQO standard of “Retention”. Implementation of this design feature may involve cut tree marking,

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painting over remaining markings or some other appropriate and practical method.

2. Temporary Roads and Landings G. When possible, landings should be located out of sight from Road #86 in areas that have an assigned a VQO of “Retention” (Units 29-34). Landings that are within the foreground of Road #86 in this area should be restored so that they become indiscernible to drivers along the road within five years after completion of all project-related activities. Landings may be visible in the immediate foreground (up to 300ft) from Road #86 or the Fairy Lake Road in areas assigned a FP standard VQO of “Partial Retention” but should be restored after tree removal work has been completed, so as to not be visually dominant from those roads.

H. The first 300ft of any temporary project road along Road #86 or the Fairy Lake Road in sections 22, 23 or 24, should be curved to avoid straight line views into units or landings. After project work is completed, the first 300ft should be ripped, re-contoured (for units with a VQO of Retention), seeded and slashed. Also refer to the design features listed in the Soils report.

Anticipated Effectiveness of the above-listed design features for the temporary roads and landings: When incorporated into the project work, the Design Features listed above ensure that the proposed units and associated work will not be visually dominant when viewed in the fore/middle/background from the key observation points (KOP) in areas assigned a VQO of Partial Retention and also that the proposed units will meet the requirements for the VQO of Modification when viewed from the KOPs in the middle/background when viewed from the KOPs. Refer to the design features listed in the Soils section for restoration that will also help to meet this standard. These design criteria will ensure that the units visible in the foreground of Road #86 in an area assigned a VQO of Retention will not be discernible to the casual Forest visitor within five years after all project-related work has been completed. This will meet the requirements of the Forest Plan.

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Table A-1. Scenery Design Feature Application Forest Plan Standards Applicable Design Features to meet the Unit Acres for Scenery-VQOs2 Forest Plan standards 3 01 39 PR B, C, D, E, G, H 02 13 PR B, D (where feasible), E, G, H 05 13 PR B, C, D, E, F, G, H 06 21 PR B, C, D (where feasible), E, F, G,H 07 15 PR E, G, H 08 32 PR B, C,E, F 09 34 PR D, G, H 10 76 PR A, B, C, D (where feasible) 11 23 PR A, B, C, D, E, G, H 12 26 PR B 13 17 PR A, C, G, H 14 49 PR A, B, C, D, E, F, G, H 15 17 M -- 16 22 M -- 17 21 M -- 18 14 M -- 21 30 M -- 22 14 M -- 23 40 PR D (on west edge) 24 76 PR -- 25 48 PR -- 26 78 PR D 27 19 PR -- 28 35 M D (where feasible) 29 46 R - the eastern 200 ft C, E, F, G, H along the road PR – remainder of unit

30 19 R A (along north edge), B, C, D, E, F, G, H 31 10 R --

32 45 R A, B, C, D, E, F, G, H

2 Applicable Forest Plan Visual Quality Objectives (VQO): R = Retention, PR = Partial Retention , M =Modification 3 Critical viewsheds for this project are the visible landscapes from Road #86 (Bridger Canyon Road) and from the Fairy Lake Road through sections 22, 23 and 24.

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Forest Plan Standards Applicable Design Features to meet the Unit Acres for Scenery-VQOs2 Forest Plan standards 3

33 26 R B, C, D, E, F, G, H 34 19 R – a 200 ft strip along B, C, D, E, F, G, H the road PR - remainder of the unit 35 28 PR B 36 30 PR -- 37 8 M -- 38 5 M A (along the west edge) 39 12 M D (along the south) 40 8 PR B 41 6 PR A (along western edge); B 42 22 PR B 43 23 PR B 44 17 M -- 45 30 M - 46 29 M A 47 61 PR A, D 48 98 PR A (western, northwest and northern edges), B, D, 50 25 PR D (where feasible) 51 32 PR A (along the north edge), B

52 33 PR A, B 56 133 PR B 58 21 M B 59 64 M B (where possible) 60 75 M B 63 39 PR B 64 17 M B (where possible) 65 25 M 66 10 PR B 67 32 PR B 68 48 M B 69 14 M B 70 28 M B

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Forest Plan Standards Applicable Design Features to meet the Unit Acres for Scenery-VQOs2 Forest Plan standards 3 71 94 M B 72 28 M B 73 102 M B 74 16 PR A, B, C, D, E, F, G, H 75 80 PR D 76 27 PR B 77 17 M A (along southern edge); B 78 23 PR A (where possible) B

Soils

Design features to be applied include the following by category:

Conduct of Logging - Ground-Based Harvesting

1. Ground-based harvest systems will only be used on slopes having sustained grades of 35% or less. Anticipated Effectiveness High. Limits most ground based mechanical equipment from operating up and down steep (>35%) slopes during timber harvesting and skidding operations reducing the likelihood that accelerated rill and/or gully erosion occurs within treatment units.

2. Require a systematic skid trail pattern during logging that maintains an average of at least 75 feet between skid trails in partial harvest units and an average of approximately 100 feet in clearcuts. Skid trails may be closer than this spacing where converging so long as overall spacing averages 75 and 100 feet, respectively. Anticipated Effectiveness = Moderate. Reduces the density of skid trails to a specified amount within treatment units, thereby limiting the total area where soil compaction, rutting, and/or accelerated erosion can potentially occur along skid trails.

3. Lay out skid trails in a manner that minimizes continuous grades steeper than 15% to the extent reasonable based on terrain constraints Anticipated Effectiveness = Low to Moderate (depending on the level of implementation) Reduces the likelihood that concentrated water flow and soil erosion occur along skid trails during heavy rains or rain on snow events.

4. Where reasonable, avoid placing skid trails or temporary roads over strongly convex knobs or along narrow, rocky ridges. These areas, although frequently armored by surface rock, are often the least able to recover from soil disturbance. Anticipated Effectiveness = Moderate to High (depending on the level of implementation.) Reduces soil resource damage to areas of shallow or otherwise fragile

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soils within treatment units.

Soil Moisture Restrictions on Use of Ground Based Harvesting Equipment

5. Ground based skidding and harvesting equipment may be used off skid trails but only to the extent needed to harvest available timber based on the judgement of the timber sale administrator and only when soil conditions in the top six inches of mineral soil are sufficiently dry to not create excessive resource damage. Specific guidelines for identifying when “sufficiently dry” soil conditions exist will be provided by the forest soil scientist who will be available for field assessments of soil conditions if questions arise. Criteria used integrate soil texture and soil moisture effects – see USDA Technical Guide for Estimating Soil Moisture (USDA-NRCS 1998). Repeat passes over the same ground should be minimized. See the Notes to Implementers section for technical details of the approach used. Anticipated Effectiveness High The approach used is very effective at reducing the extent and severity of dispersed, detrimental soil compaction or rutting caused ground- based mechanical equipment use off established skid trails and roads within treatment unit. Approach based on well-established principles of soil physics with regard to soil physical properties, soil moisture levels and soil compaction.

Special Protection Areas – Wetlands

6. Ground based mechanical equipment used for skidding, hauling, or processing timber will not be operated in wetland areas. Anticipated Effectiveness = Moderately high. Eliminates the occurrence of detrimental soil rutting in primary wetland areas while reducing ground disturbance in adjacent transition areas.

Scarification/Shallow Ripping of Disturbed Areas: Landings, Skid Trails, and Temporary Road

7. All landings, skid trails and temporary roads will be scarified/shallow ripped to an approximate average depth of 6 inches below the mineral soil surface. The extent of scarification/shallow ripping required will depend on the specific area to be treated (landing area surrounding the burn pile footprint, skid trails, burn pile footprint or temporary road prism and their respective mitigation objectives (See Notes to Implementers Appendix for specific criteria). This provision may be waived in any portions of an affected area where very rocky soil conditions exist within the top 4 inches of mineral soil. Anticipated Effectiveness = Moderate overall if used separately. This approach can be highly effective at reducing detrimental soil compaction and rutting in landing areas outside the burn pile footprint and along skid trails without any additional mitigation actions. The same approach, however, will be supplemented by re-contouring in the mitigation of temporary roads and modified somewhat to improve mitigation effectiveness in burn pile areas, increasing overall effectiveness to moderately high.

8. Prioritize the siting of landing locations, where reasonable, to low slope forested areas,

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pre-existing road prisms or other prior disturbance areas, and/or areas adjacent to existing Forest Service roads Anticipated Effectiveness = highly effective where applicable. Siting landings on already hardened surfaces or areas of pre-existing DSD eliminates the creation of new detrimental soil disturbance (DSD) where overlap.

Temporary Roads 9. Utilize existing old temporary road or jammer road prisms in lieu of building new temporary roads where feasible. Anticipated Effectiveness: Highly effective where applicable. Utilizing existing temporary road prisms where possible eliminates much of the detrimental soil disturbance associated with new temporary road construction where the old road prism is used.

10. Re-contouring of cut and fill slopes along temporary roads will be conducted at the completion of use. Road segments identified for re-contouring will be based on resource protection needs and road suitability for re-contouring. Modified versions of partial re- contouring will be considered if warranted by special circumstances such as shallow, rocky areas. Anticipated Effectiveness = Moderately High. Very effective when used in conjunction with shallow ripping along the road prism where needed and in accordance with road suitability for re-contouring. See Notes to Implementers section for specific criteria.

Erosion Control Seeding 11. Seed all ground disturbance areas of exposed mineral soil on temporary roads, landings and skid trails with an appropriate native seed mix, provided by or approved by the Custer-Gallatin National Forest, after soil remediation actions have been completed. In all cases, the ground surface should be left rough prior to seeding with sufficient surface mineral soil exposed to ensure a good soil seed contact for seeded species. Broadcast seeding is recommended. Appropriate weed control will be implemented to the extent possible. Anticipated Effectiveness = Moderately High. There is level of interest both within and outside the Forest Service for improving restoration success of the large burn pile footprints associated with whole tree yarding. The goal is convert that interest into positive results. Note: Field tests are planned at several burn pile sites in both the North Bridger and South Bridger project areas to test the efficacy of exposed mineral soil and several other soil amendment treatments to counteract the negative effects of accumulated wood ash on soil physical properties in the underlying mineral soil beneath large burned slash piles. These tests will likely be conducted in conjunction with student research projects at Montana State University.

Course Woody Debris and Soil Productivity – See wildlife section

Anticipated Effectiveness= Moderately high. The retention of 10 to 15 tons per acre in forest stands after harvesting meets the level of CWD recommended for comparable

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forest types in Graham et.al. (1994) to maintain the productivity of conifer stands in this area and represents a reasonable compromise with fuel reduction goals for the North Bridger wildland urban interface area (WUI).

Winter Harvesting

12. Tractor harvesting over snow or frozen ground in the winter will be limited to periods when there is a minimum of 8 inches of settled snow depth covering the ground surface or the underlying ground surface is frozen solid, i.e.: frozen ground. Frozen ground is defined here as having at least the top 3 inches of mineral soil solidly frozen. Winter harvesting must not be conducted or must be halted immediately if ponding or excessive wetness occurs at the soil surface due to partial thawing of an underlying frost layer. Timber harvesting activities conducted under partial thawing conditions would result in excessive soil resource damage. Anticipated Effectiveness = High. Winter logging has a high potential for greatly reducing soil impacts associated with timber harvesting and the use of ground based mechanical equipment to harvest, process and transport forest products, provided appropriate settled snow depth and/or frozen ground criteria, noted above, exist.

13. No landing will be located in Unit 38 nor will the landing for Unit 12 be located outside of an existing treatment unit area unless it is on an already hardened site such on and edge of an existing road prism or other highly disturbed area. Anticipated Effectiveness = High. No detrimental soil disturbance associated with a landing area either within Treatment Unit 38 or attributed to Treatment Unit 38 will be created under this special provision.

Sensitive Plants

1. Management actions where whitebark pine is present as an incidental component should retain healthy trees where possible. The protection of mature and seed-producing trees on the landscape is an objective of the Adaptive Action Plan for Whitebark Pine in the Greater Yellowstone Area (GYCC, 2015) Anticipated Effectiveness: Silvicultural prescriptions and marking guidelines will ensure that healthy whitebark pine are retained as leave trees. Reduction of stand density and removal of competing vegetation through harvest, slashing, and burning will further promote existing whitebark pine and provide sites for future whitebark pine regeneration. Healthy seedling, sapling, and pole size whitebark pine will be protected to the extent possible from damage during harvest and burning operations. Monitoring of the marking and harvest will indicate how well the objective was met.

2. Any changes to the proposed action that may occur during layout will be reviewed by a botany coordinator, and rare plant surveys will be conducted as necessary prior to project implementation in the event of changes. No sensitive plants (other than whitebark pine) were found during surveys in the 2016-2017 field seasons. If there are newly documented occurrences, they will be evaluated, with specific protection measures implemented to

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protect population persistence. Such measures could include the following: • Dropping units from harvest activity; • Modifying unit boundaries to provide adequate buffers around documented occurrences, as determined by a botany coordinator; • Modifying harvest methods, fuels treatment or logging systems to protect rare plants and their habitats; • Implementing, if necessary, Timber Sale Contract provisions B6.24, Protection Measures Needed for Plants, Animals, Cultural Resources, and Cave Resources; C6.24#- Site Specific Special Protection Measures; and B8.33, Contract Suspension and Modification. Anticipated Effectiveness: Implementation of plant- and site-specific mitigation measures will effectively avoid or minimize disturbance to sensitive plant populations. Botany coordinator and timber sale administrator will agree upon acceptable management methods and locations to minimize detrimental impacts.

Water, Fish and Amphibians

1. Standard timber sale protection provisions will be applied to the commercial harvest activities to protect against soil erosion and sedimentation. Standard Best Management Practices for Forestry in Montana (DNRC 2006a) including Montana SMZ compliance rules (DNRC 2006b), as modified specific to this project (below), will be applied during design and implementation of commercial harvest activities. The State of Montana requires that BMP's be applied to all activities to comply with State Water Quality standards. 2. All streams will be buffered per requirements listed in Table A-2 to reduce sediment delivery and will comply with Montana Streamside Management Zone Law and Rules 3. Additional general mitigations: a. All required water quality permits, including 124 permits and Nationwide 404 permit compliance validations for stream crossings, will be acquired by the Custer Gallatin NF prior to any ground disturbance. b. Timber operations will avoid wetland areas. No mechanical entry to wetlands or deposition of materials into wetlands will be permitted. c. Generally, there will be no fuel storage, mixing of fuels, or refueling equipment in riparian areas. If there were no alternatives, refueling in riparian areas may occur, but will require pre-approval by the fisheries biologist or hydrologist, and will have an approved spill containment plan. d. Temporary roads will not enter riparian areas except where necessary to cross streams or wetlands with appropriate stream crossing permits (Gallatin National Forest Travel Plan Standard E-5).

Anticipated Effectiveness: Highly effective. Past and continued monitoring efforts by the Custer Gallatin National Forest and current literature (Sweeny and Newbold 2014) show that the application of vegetative buffers around aquatic dependent ecosystems are effective at maintaining ecological processes for aquatic ecosystems. A formal project implementation review process has been used on the Custer Gallatin NF since 2005 to

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review implementation and effectiveness of project mitigation measures and Best Management Practices (BMP’s) such as those prescribed for the proposed project. In general, rating of the application and effectiveness of BMP’s has shown them to be very effective. The vast majority of BMP’s have been found to meet requirements and provide effective protection of resources. In cases where application objectives or effectiveness goals have not been fully met, improvements to BMP’s have been developed and instituted to improve effectiveness. Implementation Review Reports are available on the Custer Gallatin NF website at: https://www.fs.usda.gov/detail/custergallatin/landmanagement/planning/?cid=stelprdb51 90912

General Unit Design Features All streams will be buffered according to Table A-2: Table A-2. Riparian no treatment buffers and SMZ treatments along Class 1, 2 and 3 streams. SMZ Slope Stream Class < 35% > 35% Class 1 50 feet no treatment 100 feet no treatment Class 2 50 feet no treatment 100 feet no treatment Modified SMZ Modified SMZ direction Class 3 direction with with 15 feet no treatment 15 feet no treatment

(“No treatment buffers” are defined as 50 feet upslope from the ordinary high water mark (OHWM) along Class 1 and 2 streams on slopes less than 35%. For slopes >35%, the no treatment buffer boundaries will be extended to 100 feet. If there any streamside riparian areas containing deciduous shrubs and trees that could benefit from conifer removal, and the project hydrologist and/or fish biologist concur that there are no site specific sediment delivery and/or other related issues, then implementation of the following modified SMZ direction could be extended to include both Class 1 and 2 stream classes. The project hydrologist and fish biologist reviewed streams within Units 10, 23, 24, 26 and 76 during the 2018 field season to determine if there are any riparian enhancement opportunities.

4. For Class 3 streams. treatments can be laid out according to modified SMZ direction previously used: a) No trees will be cut within 15 feet of the Ordinary High Water Mark (OHWM) along any class of stream. b) No treatment buffers may be expanded in areas with wider floodplains and areas that meet the functional definition of riparian (Figure 6). This includes areas within the hydrologic zone of influence of streams characterized by riparian vegetation

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c) Tree retention guidelines along Class 3 streams between 15-50 feet will follow SMZ Rule #5. d) Ground-based equipment will be prohibited from entering SMZs without the appropriate variance from Montana DNRC (SMZ Rule #4). e) The 15 feet no treatment buffers, floodplain & riparian expansions and leave trees will be delineated by a Forest Service fisheries biologist or hydrologist. Streams are defined as, “a natural water-course of perceptible extent that has a generally sandy or rocky bottom or definite banks and that confines and conducts continuously or intermittently flowing water.

Specific Unit Design Features 8. Buffer the steep stream channels, springs and seeps that bisect the center portion of Unit 60 by a minimum of 100 feet, but allow the project hydrologist and/or fish biologist the discretion to widen this buffer if potential sediment delivery issues arise.

Figure 6 . Stream Management Zones 9. To ensure vegetation remains in the unclassified for Class 3 streams. incised draws which bisect Unit 59 some of the leave trees and groups will overlap with the incised draws. Incised draws are steep hillslopes leading to narrow valley bottoms without existing stream channels that could concentrate flowing water following vegetation removal and associated roading.

General Road Design Features

10. Consider alternative private road access opportunities to locate the temporary road in Units 23, 24 to avoid stream crossings. 11. Locate the temporary road accessing Unit 60 above the dry lake bed. This road leaves FS Road # 733 D at or just above the switch back in Unit 66. NOTE: There’s no outlet to this pond which will alleviate downstream sediment issues.

12. Temporary roads in Units 10, 23, 24, and 60 were laid out in conjunction with the Forest Hydrologist and District Fish Biologist to: 1) minimize the number of crossings; 2) locate crossings to avoid streamside cutting and filling and steep approaches; 3) minimize sediment delivery; and, 4) use crossing techniques that avoid fill placement within the Ordinary High Water Mark (OHWM) as defined with State of Montana SMZ rules. These crossings require MFWP 124 permits. Full bench road construction may be required both north and south of the stream crossing for an estimated 300 plus feet. Along these likely north and south stream approaches, to the best possible extent: • Eliminate displacement of excavated materials (side casted boulders and/or top soil) with options such as end hauling and placement of slash filter windrows.

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• Recontour temporary road prism placing adequate slashing with large tree boles to prevent future cattle trailing along this closed road corridor. • Truncate the temporary road in Unit 26 before reaching North Fork Brackett Creek, unnamed tributary and associated meadow complex. It is a desire to protect this meadow complex from all project related activities and avoid increasing future cattle access. • Recontour temporary road(s) in Units 23 and 24 placing adequate slash including large diameter tree boles to prevent future cattle trailing along this closed road corridor.

Anticipated Effectiveness: These design features and mitigation are primarily designed to minimize sediment delivery and maintain other aquatic habitat features such as large woody debris input, stream shade, stream bank stability and stream bank stability and comply with Montana Streamside Management Zone rules.

Weeds

1. Power wash and inspect all off-road vehicles prior to entering Forest Land. This mitigation is required in FSM 2080 - Noxious Weed Management 2081.2 (6.a. (1) (b)). Anticipated Effectiveness: This mitigation measure is common practice on the Forest. A study by Montana State University found that washing equipment removed 66 to 95% of soil, with longer duration washing removing more soil (Taylor et al. 2011). While not 100% effective, this mitigation clearly reduces the spread of noxious weeds.

2. Re-vegetate all disturbed soil (temporary roads, skid trails, landings and burned areas) by planting native grass species (certified noxious weed seed-free). This is a required mitigation measure in FSM 2080-Noxious Weed Management 2081.2(6.a.(2)). Anticipated Effectiveness: Disturbance creates openings for plants to occupy and can be a critical factor in the introduction of non-native plants (Masters and Sheley, 2001). Weeds are often colonizers on bare soil, so restorations that include revegetation of native species provide competition with non-native weeds. When and how reseeding is accomplished has an impact on the effectiveness of this mitigation. Planting native vegetation within the first growing season after burning (Korb et al. 2004) and quickly after temporary road removal projects (Switalski et al. 2004) is suggested to discourage the invasion of non-native species..

3. Avoid existing ‘new invader’ weeds by leaving a buffer of trees around the perimeter of these existing infestations, as designated by the Forest Weed Specialist).” Avoiding existing weed patches is a recommended practice for noxious weed management. Anticipated Effectiveness: Flagging ‘new invader’ infestations and providing a foot buffer so the infestation remains undisturbed during the project should minimize the chance of spreading the new invader to other areas. Currently only one unit is known to contain a new invader species. Unit 25 has an infestation of yellow toadflax which is considered a new invader in this area of the Forest, as it is one of only a few known infestations of yellow toadflax in the Bridger Mountains. Unit 56 has an infestation of St. Johnswort in close proximity (within 100 feet of the unit boundary). Other new invaders may be identified prior to or during implementation of this project.

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4. Pre-treat weeds along haul roads at least one year prior to starting soil disturbance and do follow-up treatments along haul roads and temporary roads for the first 3 post project years. Pre and post treatment of roads are recommended in FSM2080 - Noxious Weed Management 2081.2 (6. b. (1) (a) and 1. b. (4)). Anticipated Effectiveness: Roads are vectors for spreading weeds, so pre-treatment will help reduce seed sources prior to project initiation. Most noxious weed seeds can remain viable in the soil for decades, therefore, although pre- and post- treatment of roads is likely to reduce weed infestations in the short-term, continued monitoring and treatment of roadways is part of the invasive weed strategy for the forest (GNF Weed EIS, 2005). Even with continued treatment, eradication of weeds along roads is unlikely. The timber contract will include the provision to pre and post treat haul roads and post treat temporary roads. Most haul roads were treated in 2017 and are under contract to be treated again in 2018. Treatment of roads during years 2 and 3 post project will be completed by Forest Service contractor or Forest Service crew.

5. Annually survey and treat all weeds, both new and existing, for three years following final reclamation of treatment units. This mitigation measure is recommended by the USFS Northern Region Risk Assessment Rating protocol for high risk projects. Additionally, monitoring and treating weeds after timber harvest is recommended in FSM2080 - Noxious Weed Management 2081.2 (6. b. (3) (a) and (b)). Anticipated Effectiveness: Follow up surveys and weed treatments will help control weed patches. It is reasonable to assume that additional funding or capacity will be available to implement this mitigation for example, KV funds, cooperative funding or inclusion as contract requirements.

6. Any gravel and borrow sources needed for construction or enhancement of existing roads will be inspected for noxious weeds and approved before use and transport. This mitigation is recommended in FSM2080 - Noxious Weed Management 2081.2 (1. b. (3)). Gravel source, whether existing or new, need to be reviewed to determine if previous cultural resource inventories have been conducted (and sites absent or present) or if additional cultural resource inventories are needed Anticipated Effectiveness: This practice is reasonably effective at limiting the spread of weeds. The District Weed Specialist will be available to inspect sources of material located on FS lands, and the Gallatin County Weed Supervisor inspects gravel pits throughout the county and keeps a list of clean sources.

Wildlife

1. Bird Protections • Protect raptor nests discovered during recon, layout, and marking. At a minimum, the nest tree will be retained; further protection, if needed, will be prescribed by the Wildlife Biologist. • If an active goshawk nest is found in the project area, no treatment will be allowed within the nest stand, which will be a minimum of 40 acres surrounding an occupied goshawk

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nest. • No mechanical thinning or other ground-disturbing activities will be allowed between April 15 and August 15 within the post fledging area (PFA, approximately 420 acres) surrounding an active goshawk nest. • If a bald eagle nest is discovered in the project area, the recommendations provided in the Montana Bald Eagle Management Guidelines (Montana Bald Eagle Working Group 2010) will be used to protect the site and reduce or eliminate potential disturbance.

2. Special habitat features avoidance: • Wallows, springs, and moist meadows will be avoided when encountered in treatment units to protect these key habitat features. Avoidance areas will be determined through collaboration between wildlife, fisheries, hydrology, and other resource areas. • Other special and unique wildlife habitats such as licks, talus, cliffs, and caves will be avoided if encountered in or near proposed treatment units. Appropriate protection measures will be determined by the District Wildlife Biologist. No talus, cliffs or caves features have been identified at this time.

3. Management Area 11 standards: • In MA11, design even-aged openings so that no point is greater than 600 feet from cover. This will be applicable to Unit 59 and the southern-most portion of Unit 56, which are the only regeneration harvest units in MA11 in the Project Area. Untreated patches of effective cover (a range of sizes is preferable) will be retained to meet this standard. • In MA11, restrict timber sale activities to no longer than five consecutive years. The following units are in MA11 or a portion of the unit is in MA11: 56 (portion), 58, 59, 60. • In MA 11, maintain a minimum of two years inactivity following 1-3 years of consecutive sale activity, or a minimum of five years inactivity following 4-5 years of consecutive sale activity.

4. Snags and Dead and Down Woody Material Standards and design criteria • Retain an average of 30 snags (> 18 ft. in height and > 10 inch DBH) per 10 acres within harvest units. Retain the largest snags available and those with complex structures (existing cavities, hollows, large complex limbs, multiple tops, etc.). If there are not sufficient dead trees meeting these size criteria, the largest available dead trees should be retained. • Retain snags as singles and clumps in treatment units; design proposed treatment (through layout and marking) to minimize impacts to large, complex legacy snags, where feasible. • Retain a minimum of 15 tons per acre of three-inch diameter or larger debris (if available) after machine site preparation and/or hazard reduction within harvest units. While a mix of size classes, lengths, and decay classes will be provided, there will be a preference for the largest and longest (> 10 inches in diameter and > 20 feet long being the most desirable) pieces available to provide for structural complexity and the needs of wildlife species through time. No removal of downed wood will occur where the 15 ton minimum cannot be met. • Retain downed wood as singles and in piles/ clumps within treatment units, particularly where piling of debris occurs, to provide for heterogeneity.

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• In timber sale contracts where machine piling is specified, windrowing of dead and downed woody debris will be prohibited. • Retain an average of 30 live snag replacement trees (> 10 inch DBH, where available) per 10 acres within harvest units.

5. Forest Food Storage Order All attractants (food, garbage, etc.) will be stored in compliance with the Custer Gallatin National Forest food storage order. Contractors will be informed of possible risks associated with working in bear habitat, and will be required to comply with the Custer Gallatin National

6. Unit 56 Mitigation In order to provide for a diversity of habitat in Unit 56 (Management Area MA12), the treatment prescription (Regeneration harvest – Patch Cut/Thin/Plant) will be adjusted in the following manner: 1. Rather than patches (created openings) accounting for 60%-80% of the unit acres, limit patches to 25% of the unit acres; 2. As the majority of Unit 56 currently provides denser stand conditions than much of the surrounding area, retain at least 25% of unit acres, generally in the densest portions of the stand, in an untreated condition. Locate these untreated areas or “skips” in a manner such that they are consistent with the purpose and need of the project (e.g. not situated along the Forest boundary where insect and disease agents or firebrands are more likely to affect adjacent private lands) and where temporary roads and skid trails will not affect their integrity, where feasible; 3. The minimum size of untreated patches or “skips” should be 10 acres; 4. Commercially thin the remaining 50% of the unit acres in a manner consistent with the purpose and need of the project.

NORTH BRIDGERS – MONITORING Timber Sale Administration Forest Service Sale Administrator will oversee the logging contract. Objective: Ensure contract compliance and that intent of contract provisions are met. Provisions are the mechanism to incorporate many (but not all) of the protections identified in the design features.

Silviculture Monitoring to ensure that timber marking complies with marking guidelines identified in the silviculture prescription process. Objective: Ensure consistency with silviculture objectives.

Aspen stands will be assessed post treatment to determine whether sprouting is adequate and/or if there is a need for further actions such as burning or browse deterrents such as slash placement or fencing. Objective: To monitor success and the need for further action to improve sprouting success.

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Reforestation surveys will be scheduled in conifer regeneration units. Typically this is done prior to reforestation activities and first, third and fifth year after harvest. Objective: This monitoring ensures that NFMA and Forest Service reforestation policy will be met.

Service Contract Administration In the event a service contract is awarded to thin the precommercial size tree units, a Forest Service Administrator will oversee the contract implementation. Objective: Ensure contract compliance and that intent of contract provisions are met. Provisions are the mechanism to incorporate many (but not all) of the protections identified in the design features.

Fuels Monitoring Units include 6, 7, 9, 10, 16, 18, 23 and 59 will be monitored after logging to assess heavy natural fuel concentrations to determine the need for additional hazardous fuel treatments like broadcast burn (BB), jackpot burn (JP), machine pile/burn and creation of fuel breaks. Objective: To ensure that fuel loading is acceptable in these areas post logging to reduce the risk of undesirable fire behavior.

Range Allotment Monitoring Routine administration of the allotment and communication with permittees will be the primary monitoring necessary to identify any needs to create additional barriers such as fencing or log placement in order to protect riparian areas. Objective: The Water, Fish and Amphibians design feature requiring slash placement on temporary roads is expected to deter cattle movement into riparian areas. Allotment permittees are also required by the terms and conditions of their permit to protect riparian areas. A combined monitoring/administration effort is in the best interest of all groups with an interest in riparian protection.

Scenery monitoring Review effectiveness of scenery design features in particular in units 29-34 to ensure timely restoration to meet the retention visual quality objective. Objective: To evaluate effectiveness of design and ensure timely restoration n visually sensitive corridors.

Soil - Detrimental Soil Disturbance Monitoring Soil monitoring will be conducted in year 2 and year 5 after all vegetation treatment activities and associated mitigations have been completed. Treatment units targeted for post-activity soil monitoring will be those having the greatest likelihood of exceeding the 15% standard based on the initial soils analysis or post-project reconnaissance sampling. Objective: To ensure compliance with the Forest Service Region One 15 maximum detrimental soil disturbance (DSD) standard and assess the effectiveness of the Soils Design Features.

Weed Monitoring

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Annually survey newly disturbed areas and previous weed infestation near units three years following final reclamation of treatment units. This monitoring is recommended by the USFS Northern Region Risk Assessment Rating protocol. Additionally, monitoring and treating weeds after timber harvest is recommended in FSM2080 - Noxious Weed Management 2081.2 (6. b. (3) (a) and (b)). Objective: To inform proactive weed containment post project and to evaluate effectiveness of weed best management practices.

Wildlife Continue looking for raptor nest as the project progresses. Objective: If nests are located, protections will be incorporated.

Implementation Monitoring A formal project implementation review process has been used on the Custer Gallatin NF since 2005 to review implementation and effectiveness of project mitigation measures and Best Management Practices (BMP’s) such as those prescribed for the proposed project. Objective: To evaluate whether the purpose and need for action is met, whether BMPs are met and the intent of other design features was achieved. Project Monitoring Reports for other projects is available on the Forest Webpage.

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APPENDIX B: VEGETATION MANAGEMENT TREATMENT DESCRIPTIONS AND SUMMARY Vegetation Management Treatment Description, Summary and Map

Descriptions of Proposed Vegetation Treatments Proposed silvicultural treatments are dependent on numerous factors, including the current and desired forest vegetation conditions at the stand and landscape scales, biophysical setting, management direction and emphasis for the area, and project purpose and need for action. Silvicultural treatments proposed trend the forest vegetation toward conditions that are more resistant and resilient to disturbances and stressors. Descriptions of the proposed vegetation treatments are defined below and a list of the treatments by unit is provided in Table B-1. Proposed Treatments, Acres and Logging System below. There are multiple kinds of treatments proposed in the North Bridger Forest Health project area. Below are descriptions of the specific types of treatments that fall under the Intermediate harvest category. The other major category is regeneration harvest.

Intermediate treatments leave a stocked stand4 post-treatment, while regeneration harvests leave an un- stocked stand. The National Forest Management Act requires regeneration harvest areas to be stocked within five years post-treatment. Intermediate Treatments - Intermediate treatments leave a stocked stand when completed. Thinning Reducing stand densities to 60-100 ft2/acre of basal area. Tree distribution will range from clumped to widely-spaced. Thinning in old growth stands will retain minimum old growth criteria as defined by Green et al., 2011. Precommercial thinning will thin small trees to a 12-22 foot spacing.

Aspen Release Removal of conifers within 50-150’ of healthy aspen clones. Fencing of clones may be required if browsing pressure is deemed to be too high based on post treatment monitoring.

Sanitation Removal of individual trees infected by insect or disease where they occur in a unit to reduce actual or anticipated spread of insects or disease. The specific insect- or disease-affected trees being removed varies by unit, but is usually lodgepole pine with dwarf mistletoe or conifers with genetic spruce budworm susceptibility.

4Stand. A contiguous group of trees sufficiently uniform in age class distribution, composition, and structure, and growing on a site of sufficiently uniform quality, to be a distinguishable unit, such as mixed, pure, even-aged, and uneven-aged stands. A stand is the fundamental unit of silviculture reporting and record-keeping.

Stocking — A description of the number of trees, basal area, or volume per acre in a forest stand compared with a desired level for balanced health and growth.

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Salvage Removal of a portion of the dead trees within a stand. Forest Plan standards of snag retention will be met.

Regeneration Harvests - Regeneration treatments seek to create a new age class, either as the only age class in a stand or as part of an uneven-aged stand. The National Forest Management Act requires stands to be restocked within five years post-treatment. Restocking will occur by natural regeneration or by planting. If planting is used, Douglas-fir will be the primary species planted.

Clearcut Removal of almost all trees within a stand. Snags and snag recruitment trees, as directed by the Forest Plan, will be maintained.

Patch Cuts A form of clearcutting that will have almost total tree removal over 60-80% of unit acres. Patches will range in size from 5-25 acres. Snags and snag recruitment trees, as directed by the Forest Plan, will be maintained within patches.

Overstory Removal A form of clearcutting where advance reproduction (small trees existing in the unit) acts as the desired new generation of trees. Most overstory trees will be removed (snags and snag recruitment trees, as directed by the Forest Plan, will be maintained). The new stand will already be stocked with the existing advance reproduction. Stocking surveys will be conducted post-harvest to ensure that natural regeneration or planting is not necessary.

Group Selection Removal of all trees in 2-5 acre groups, which in total comprise 30% of the stand. The result is the first step (or a continuation) to creating three age groups in a stand or a unevenage stand.

Table B-1. Proposed Treatments, Acres and Logging System

Logging System or Unit Acres Proposed Treatment Prescription Method 01 39 Thin Tractor 02 13 Group selection/Natural regeneration Tractor 05 13 Thin Tractor 06 21 Group selection/Thin/Natural regeneration Tractor 07 15 Clearcut/Natural regeneration Tractor 08 32 Aspen/Thin Tractor 09 34 Aspen/Clearcut/Natural regeneration Tractor 10 76 Patch cut/Natural regeneration Tractor 11 23 Aspen/Thin Tractor

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12 26 Thin Tractor 13 17 Aspen/Clearcut/Plant Tractor 14 49 Aspen/Thin Tractor 15 17 Aspen/Thin Tractor 16 22 Clearcut/Natural regeneration Tractor/Skyline 17 21 Clearcut/Overstory removal/Natural regeneration Tractor 18 14 Clearcut/Natural regeneration Tractor 21 30 Thin/Sanitation Tractor 22 14 Thin Tractor 23 40 Clearcut/Plant Tractor 24 76 Thin Tractor 25 48 Thin Tractor 26 78 Patch cut/Thin/Plant Tractor 27 19 Thin Tractor 28 35 Clearcut/Plant Tractor 29 46 Thin Tractor 30 19 Thin Tractor Swing 31 10 Thin Skyline 32 45 Thin Tractor 33 26 Patch cut/Thin/Plant Tractor 34 19 Thin Tractor 35 28 Patch cut/Thin/Natural regeneration Tractor 36 30 Aspen/Clearcut/Natural regeneration Tractor 37 8 Thin/Sanitation Tractor 38 5 Aspen/Thin/Sanitation Tractor 39 12 Thin/Sanitation Tractor 40 8 Thin/Sanitation Tractor 41 6 Aspen/Thin/Sanitation Tractor 42 22 Aspen/Thin/Sanitation Tractor 43 23 Thin Tractor 44 17 Thin Tractor

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45 30 Thin/Sanitation Tractor 46 29 Group selection Tractor 47 61 Thin Tractor Swing 48 98 Thin Tractor 50 25 Group selection/Thin Tractor 51 32 Patch cut/Thin/Plant Tractor 52 33 Thin Tractor 56 133 Patch cut/Thin/Plant Tractor Swing 58 21 Thin Tractor/Skyline 59 64 Patch cut/Natural regeneration Tractor/Skyline 60 75 Thin Tractor/Skyline 63 39 Thin Tractor 64 17 Overstory Removal/Clearcut/Plant Tractor 65 25 Thin Tractor 66 10 Precommercial Thin Hand/Machine 67 32 Precommercial Thin Hand/Machine 68 48 Precommercial Thin Hand/Machine 69 14 Precommercial Thin Hand/Machine 70 28 Precommercial Thin Hand/Machine 71 94 Precommercial Thin Hand/Machine 72 28 Precommercial Thin Hand/Machine 73 102 Precommercial Thin Hand/Machine 74 16 Aspen Hand 75 80 Precommercial Thin Hand/Machine 76 27 Precommercial Thin Hand 77 17 Precommercial Thin Hand 78 23 Precommercial Thin Hand/Machine Total Acres: 2,296

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