United States Department of COPPER KING FIRE SALVAGE Agriculture Forest Environmental Assessment Service
April 2017 Plains/Thompson Falls Ranger District, Lolo National Forest Sanders County, Montana
Cover Photo: First day of the Copper King Fire as seen from Highway 200. Photo taken July 31, 2016.
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Copper King Fire Salvage Environmental Assessment
Contents
CHAPTER 1: PURPOSE AND NEED FOR ACTION ...... 3 1.1 Introduction ...... 3 1.2 Background ...... 4 1.3 Purpose and Need for Action ...... 6 1.4 Proposed Action ...... 8 1.4.1 Design Criteria ...... 8 1.5 Public Involvement ...... 9 1.6 Issue Resolution ...... 10 CHAPTER 2: ALTERNATIVES ...... 13 2.1 Alternatives Considered in Detail ...... 13 2.1.1 Resource Protection Measures ...... 17 2.1.2 Monitoring ...... 24 2.2 Alternatives Considered but Eliminated from Detailed Study ...... 25 2.3 Comparison of Alternatives ...... 26 2.4 Conflicting Views over Post-fire Salvage ...... 30 CHAPTER 3: ENVIRONMENTAL EFFECTS ...... 37 3.1 Past, Present, and Reasonably Foreseeable Future Actions ...... 37 3.2 Vegetation ...... 40 3.2.1 Resilient Vegetative Conditions ...... 40 3.2.2 Old Growth ...... 44 3.2.3 Forest Carbon Storage and Climate Change ...... 48 3.2.4 Botany ...... 50 3.2.5 Weeds ...... 51 3.3 Soils ...... 56 3.4 Hydrology ...... 64 3.5 Fisheries ...... 76 3.6 Wildlife ...... 86 3.7 Transportation System/Public Safety ...... 131 3.8 Heritage ...... 133 3.9 Recreation ...... 134 3.10 Economics ...... 137 Agencies and Persons Consulted ...... 142
Appendix A - Maps
Appendix B: Detailed Vegetation Treatments
Appendix C: Soils
Appendix D: Response to Literature Provided in Public Comment
i Copper King Fire Salvage Environmental Assessment
ii Copper King Fire Salvage Environmental Assessment
CHAPTER 1: PURPOSE AND NEED FOR ACTION 1.1 Introduction The Lolo National Forest is proposing the Copper King Fire Salvage project (the project) to harvest fire-affected trees, cut hazard trees along roads, and plant tree seedlings within the perimeter of the Copper King Fire, which burned in the summer of 2016. The fire perimeter, of approximately 29,000 acres, is located on the Plains/Thompson Falls Ranger District in Sanders County about 5 miles east of Thompson Falls (see maps in Appendix A).
On July 31, 2016, the Copper King Fire started on National Forest System (NFS) land near the mouth of the Thompson River. Despite initial suppression efforts, a wind event caused the fire to burn across containment lines, affecting nearly 29,000 acres (approximately 19,300 acres of NFS land; 1,400 acres of State Department of Natural Resources and Conservation land; 8,200 acres of Weyerhaeuser land). The fire burned with varying severity, leaving a mosaic of burn patterns on the landscape that range from unburned islands to areas where tree crowns were completely consumed. Of the 19,300 acres of NFS land affected by the fire, approximately 85 percent of the area burned at very high, high, or moderate severity. Virtually all the trees within the very high severity burn areas (7400 acres) are dead.
The majority (92 percent) of the NFS land affected by the fire is allocated to timber production and/or where salvage is permitted by the Lolo Forest Plan1. Salvage of burned timber is therefore appropriate. While the fire was still burning, the Forest Service received numerous comments from the public, local timber industry, and State and local governments to consider salvage of the burned trees to benefit the local economy in an area where unemployment is high and milling infrastructure is nearby2. These requests were considered as well as other comments desiring that the post-fire landscape be left without management. To address the spectrum of public input, the Forest Service developed the project, which includes salvage where economically feasible from accessible lands and retains large blocks of the burned area without management.
The Forest Service has prepared this Environmental Assessment (EA) in accordance with the National Environmental Policy Act (NEPA), the Lolo National Forest Plan, 40 CFR 1508.9, 36 CFR 220.7, and other relevant federal and State laws and regulations. This EA discloses the project’s foreseeable environmental effects for consideration in determining whether or not to prepare an Environmental Impact Statement (EIS) based on the significance of those effects given their context and intensity. The reports cited in this EA and additional project documentation are contained within the project file located at the Plains/Thompson Falls Ranger District office in Plains, Montana and are available upon request.
1 The Forest Plan guides all natural resource management activities and establishes management standards for the Lolo National Forest. It describes resource management practices, levels of resource production and management, and the availability and suitability of lands for resource management. 2 The nearest lumber mill is located at the mouth of the Thompson River, less than a mile from the southwest corner of the Copper King Fire.
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1.2 Background Overview of the Project Area
Intermingled Ownership The northern half of the Copper King project area is intermingled ownership of National Forest, State, and Weyerhaeuser lands. The primary roads within this “checkerboard” area are shared by all three parties through cost share agreements or easements. The Copper King salvage units are generally located within this area where there is a well-established transportation system.
Weyerhaeuser completed most of their salvage operations on approximately 1900 acres by January 2017. Some addition work may be conducted in summer 2017. The State’s salvage operations on approximately 1100 acres are expected to begin in July 2017 (for more detail, refer to Chapter 3, section 3.1 and the Salvage by Ownership map in Appendix A). The cumulative effects of these activities are considered in this Environmental Assessment.
Cabinet-Yaak Grizzly Bear Recovery Zone All the NFS land within the project area is located within Bear Management Unit3 (BMU) 22 in the southeast corner of the Cabinet-Yaak Grizzly Bear Recovery Zone. This BMU is identified as priority 3, the lowest biological rating4. No grizzly bear sightings were reported during the Copper King Fire incident and no sightings have been reported in over a decade. However, the DNA of a male bear was identified in 2011 at a hair snag station in Todd Creek. Although occasional bear use may occur within the project area, it is not considered occupied habitat because no females, particularly females with cubs, have been detected southeast of the Thompson River (project area).
The management of habitat for grizzly bears within the Cabinet-Yaak Grizzly Bear Recovery Zone is governed by the 2011 Forest Plan Amendments for Motorized Access Management within the Selkirk and Cabinet-Yaak Grizzly Bear Recovery Zones. The project is designed to be consistent with the Forest Plan as amended (Appendix Y).
Teepee-Spring Creek Inventoried Roadless Area Approximately 48 percent of the project area is located within the Teepee-Spring Creek Inventoried Roadless Area (IRA) (see maps in Appendix A). Inventoried Roadless Areas were identified in the 1970s Roadless Area Review Evaluations (RARE I and II) as areas to be further studied for possible wilderness status. The Lolo Forest Plan (1986) evaluated these areas for possible wilderness designation and allocated management direction as appropriate. The Teepee-Spring Creek IRA was not identified for possible wilderness designation and was subsequently allocated to other management purposes in the Forest Plan. A portion of the IRA was designated suitable to timber production. After publication of the Forest Plan, the suitable portion of the IRA was developed with roads and timber harvest in the late 1980s and early 1990s.
In 2001, to protect roadless values and characteristics, the Forest Service adopted the Roadless Area Conservation Rule [Roadless Rule], which prohibits road construction, reconstruction, and timber harvest within IRAs with some limited exceptions. The Roadless Rule defines Inventoried Roadless
3 Bear Management Units are areas established for use in grizzly bear analysis. They generally approximate a female home range size and include representations of all available habitat components. 4 BMU priority ratings are based on sightings of family groups, credible grizzly sightings, human caused mortality, adjacency to BMUs having females with young, and within a linkage area or not. Biological ratings for each BMU are derived by the Access Task Group of the Selkirk/Cabinet-Yaak Subcommittee.
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Areas as those areas identified in the set of maps contained in the Roadless Area Conservation Rule Final Environmental Impact Statement or subsequent revisions. IRA boundaries were not modified to exclude developed areas. The Roadless Rule allows for boundary modifications only as needed to correct clerical, typographical, or technical errors.
Because roadless characteristics have been substantially altered within the developed portion of the Teepee-Spring Creek IRA, timber harvest (e.g. salvage) is allowed (36 CFR 294.13 (b)(4)). However, the Forest Service chose not to include any commercial salvage operations within the IRA as part of this project because of the complexity and time needed for the environmental analysis and review by the Washington Office5. Fire salvage is time sensitive due to rapid product deterioration.
Thompson River The Thompson River, a tributary to the Clark Fork River, is located on the western boundary of the fire perimeter. The U.S. Fish and Wildlife Service has designated the river as bull trout6 critical habitat7. The Thompson River serves as foraging, migration, and overwintering habitat that supports bull trout populations in several tributaries located outside the Copper King project area. However, stream sampling, modeling, and natural and man-made barriers suggest that bull trout are likely absent within the project area. The Thompson River also hosts a popular recreational fishery for brown trout, rainbow trout, and cutthroat trout.
The U.S. Plywood Road #9991 [locally known as the ACM road] runs parallel to the Thompson River along the western boundary of the project area and connects Montana State Highways 200 and 2. This unpaved road is open yearlong to public traffic and receives high levels of recreational and commercial use. Because of its proximity to the Thompson River, it is used heavily for fishing and river access. The project would remove hazard trees along the road for public safety.
Road #9991 would be used as a primary haul route to transport logs from the project area to Highway 200. The project is designed to protect the Thompson River. To minimize the potential for sediment delivery to the river from haul, project-specific resource protection measures would be applied before log haul begins. Existing contributing sediment sources on the road would be addressed and dust abatement would be applied. Dust abatement holds the fine-grained material to the road surface, which minimizes the loss of road surface fines as airborne dust and sediment. Resource protection measures are further discussed in Chapter 2.
Project Development
Prior to initiating this project, Forest Service personnel reviewed the Lolo Forest Plan to ensure salvage is appropriate for the area. As stated above, the majority of NFS land affected by the fire is allocated to timber production and/or where salvage is permitted by the Forest Plan. The staff also researched the best available science regarding the effects of and considerations for fire and post-fire
5 To use the “substantially altered” exemption, the Chief’s review and approval is required (Chief’s letter dated May 31, 2012 regarding roadless activities review process). 6 Bull trout is listed as a threatened species under the Endangered Species Act. 7 Critical habitat is defined in the Endangered Species Act as: specific areas within the geographical area occupied by the species on which are found those physical or biological features essential to the conservation of the species and which may require special management consideration or protection; and specific areas outside the geographical area occupied by the species at the time it is listed, upon a determination such areas are essential for the conservation of the species.
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management. Although there are conflicting views about fire salvage (addressed later in Chapter 2, section 2.4), much of the literature suggests that environmental effects depend on several factors, such as the biophysical setting of the forest, pattern of burn severity, operational aspects of tree removal, scale of salvage operations, and other management activities. Recommendations in the literature were considered and incorporated into the project design as appropriate.
The Forest Service also consulted timber industry representatives to determine marketability of fire- killed material. Most contacts indicated an interest in burned forest products and recommended conditions that would improve the potential for selling burned material. Based on industry contact information, anticipated product deterioration, and economic feasibility considerations, field reconnaissance by experienced foresters focused on stands with dead trees greater than 10 inches diameter breast height and containing cut volume greater than five thousand board feet per acre of primarily larch and Douglas-fir. Existing road access and logging systems were also examined. Due to the projected lower economic value of burned trees, expensive logging methods such as helicopter yarding were not included as were areas needing extensive new road construction. These criteria along with resource protections limited the scope of available salvage opportunities.
In addition, hazard trees that have a high likelihood of falling onto existing roads that are open to public and/or administrative motorized use on NFS land were considered for removal. The area within 100 feet of both sides of the road were identified for danger tree mitigation based on average tree height. However, the site-specific determination of whether to remove hazard trees would be based on merchantability, economic feasibility, and resource conditions. Hazard trees not removed and sold for forest products would be felled and left on the ground. 1.3 Purpose and Need for Action The purposes of the Copper King Fire Salvage project are to:
Recover the economic value of forest products in a timely manner to contribute to employment and income in local communities.
Provide a safe transportation system free of hazards associated with fire-affected trees or other hazards in areas of public and administrative use.
Re-establish forested conditions to trend the area toward desired resilient vegetative conditions.
Recover Economic Value to Support Communities One of the goals outlined in the Lolo Forest Plan is to provide a sustained yield of timber and other outputs at a level that will help support the economic structure of local communities and provide for regional and national needs (page II-1). The majority of the fire burned within areas primarily allocated to timber production in the Lolo Forest Plan.
The Copper King Fire Salvage project lies within Sanders County, of which 52 percent of the land base is National Forest System land. Thus, the local community has significant social and economic ties to National Forest System lands. According to the Montana Department of Labor, Sanders County currently has one of the highest unemployment rates in the state (nearly twice the state average). Management decisions made by the Forest Service can have an impact on the economies of smaller, resource-based communities. Economic effects can include changes in local employment and income, and changes in local services and community infrastructure. Forest products made available by
6 Copper King Fire Salvage Environmental Assessment conducting management activities on NFS lands contribute to the local economy and to the sustainability of the forest products industry.
Currently, Montana’s forest products industry is one of the largest components of manufacturing in the state and employs roughly 7,700 workers earning about $335 million in compensation annually, with most of the industry centered in western Montana where the project is located (Morgan et al. 2015). Most Montana mills are operating at less than full capacity and require an adequate supply of timber to remain viable and meet market demand (ibid.).
Harvest of burned material would provide jobs associated with logging and milling and contribute to the supply of timber from National Forest System land, which makes up about 60 percent of the forest land in Montana.
Provide a Safe Transportation System Approximately 119 miles of National Forest System road located within the burned area are at elevated risks to hazards including falling snags and fire-weakened trees. Roughly 60 miles (51 percent) are open to public motorized travel. Due to the intermingled land ownership in the northern portion of the Copper King Fire, the State and Weyerhaeuser have cost share agreements or easements on several Forest roads to access their lands. Since fire containment, personnel working within the fire perimeter observed and cleared fallen trees from the roadway. Over time, additional hazard trees will continue to fall because of increased defect, mortality, weather, and other environmental factors.
Despite its burned condition, public and administrative use of the Copper King area is expected to increase over the next five or more years for mushroom picking, firewood collection, timber salvage, tree planting, BAER work, and other post-fire stabilization and monitoring activities. Hunting (including guiding and outfitting) will likely increase as big game forage re-establishes and flourishes in the nutrient rich post-fire environment.
Although forest employees removed downed trees from roadways during the fall and early winter of 2016, these hazards still had a notable effect to forest access. Without a more substantial effort to address high-risk trees, these hazards will continue to affect safe access for ongoing and future forest management activities including timber harvest, reforestation and stand tending. There is a need to mitigate these hazards to protect the health and safety of the public, and forest managers and contractors conducting land management activities within the area.
Cutting hazard trees along roads would improve the safety of forest users and maintain motorized access.
Re-establish Forested Conditions The Copper King fire resulted in high levels of tree mortality. In areas that burned at high severity, there is little to no seed source remaining for natural tree regeneration. These areas that were forested prior to the fire would likely be dominated by grasses and shrubs for decades.
The National Forest Management Act requires that all forested land in the National Forest System be maintained in appropriate forest cover with species of trees, degree of stocking, rate of growth and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management in accordance with land management plans (i.e. Forest Plans). Consistent with Forest Service policy (Forest Service manual 2472.03), agency personnel conducted an initial assessment and diagnosis to identify areas in need of reforestation treatment or natural recovery in order to meet management objectives outlined in the Forest Plan. Based on the assessment findings and the existing
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allocation of the majority of the area to timber production in the Forest Plan, there is a need for tree planting.
The planting of native tree seedlings would fulfill the Agency’s legal obligations, enhance the overall recovery process, and trend the vegetation component toward desired future conditions outlined in the Forest Plan. 1.4 Proposed Action The proposed action was developed to address the purposes and needs for action as described above. The proposed action, with some modifications, was carried forward as Alternative 2 (modified proposed action), as described in Chapter 2 and analyzed in Chapter 3 of this document.
The proposed action included approximately 1508 acres of salvage and about 200 acres of roadside salvage outside of identified units; danger tree mitigation along roadsides; 2 miles of temporary road construction to access salvage units; and 6000 acres of tree planting. To maintain consistency with the Forest Plan, the proposal also included the closure of 5.5 miles of trail to motorized use to offset the loss of grizzly bear core habitat8 from the temporary road construction.
Design criteria were included in the Proposed Action to minimize and/or avoid potential environmental impacts.
1.4.1 Design Criteria The Copper King Fire Salvage project was designed to avoid or minimize potential environmental harm and comply with all applicable laws, regulation, and direction. Design Features Project-level design features were identified upfront to protect resources in the area. The design features are based on Forest Plan direction, best available science, past experience with fire salvage, and site-specific evaluations. Design features include best management practices (BMPs), which minimize effects on soil and water resources. For harvest and road management activities, BMPs are designed to assure compliance with the Clean Water Act and State of Montana water quality standards. For example: Woody debris would be left within all vegetation treatment areas at levels outlined in the Lolo National Forest Coarse Woody Material Guide and Forest Plan to provide for soil productivity and wildlife habitat.
Within salvage-only units, live trees would be retained. Incidental live trees may be felled if determined to be a safety hazard to workers or if needed to facilitate skid trail, skyline corridor and/or temporary road placement. The location of skid trails, skyline corridors, and temporary roads would require approval by the Forest Service.
Forestry Best Management Practices would be utilized to minimize effects to soil and water.
Standard Riparian Habitat Conservation Area (RHCA) widths would be expanded by an additional 50 feet to provide further protection for streams and other aquatic features in the
8 Grizzly bear core habitat is an area of secure habitat within a bear management unit (BMU) that contains no motorized travel routes or high use non-motorized trails during the non-denning season and is more than 500 meters from a drivable road.
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post-fire area. No salvage harvest would occur within these RHCAs, although hazard trees may be removed along the U.S. Plywood Road #9991 [ACM road].
Wildlife features such as wallows, mineral licks, and seeps would be protected.
The project would be consistent with the Forest Plan as amended by the 2011 Forest Plan Amendments for Motorized Access Management within the Selkirk and Cabinet-Yaak Grizzly Bear Recovery Zones.
Burned Area Emergency Response (BAER) After fire containment, an evaluation of values at risk, considering imminent threats to human life and property, was conducted. This evaluation determined that Burned Area Emergency Response actions were needed to address immediate threats to public safety, values at risk, and resource damage. Approximately $450,000 were appropriated to implement the following actions:
Weed spraying and monitoring (450 acres) Road surface storm proofing and drainage maintenance (40 miles) Culvert and road fill removal on draw and stream crossings (12 locations) Culvert replacement (upsizing) on minor draws (8 locations) Culvert replacement (upsizing) on major draws (6 locations) Culvert replacement (upsizing) on stream crossings (6 locations) Trail storm proofing and drainage maintenance (7 miles) Trail hazard tree removal (8 miles) Heritage site protection (1 location)
A portion of the BAER work was completed in fall 2016 before heavy rain and snow caused operations to cease. The remainder of the BAER treatments will be completed during the summer of 2017. BAER work will provide essential resource protections within the post-fire environment. Cumulative effects of the BAER work are addressed in this environmental assessment. 1.5 Public Involvement
Scoping On October 31, 2016, a scoping letter soliciting comments on the proposed action was mailed to 175 landowners, organizations, other agencies, and individuals who had previously requested notification about the types of activities included in the project. The scoping letter and associated map were also posted on the Lolo National Forest website.
A project announcement and public meeting notice was published in the Clark Fork Valley Press and Sanders County Ledger on November 2nd and 3rd, respectively. The Forest Service held a public meeting on November 9th to share information about the project and encourage public comment. Approximately 13 people attended the meeting.
The Forest Service also sponsored a public field trip to the project area on November 17th. Fourteen people attended, including three state legislators, the Thompson Falls mayor, several timber representatives, and members of the Sanders County collaborative group.
In addition, the Forest Service met with and presented project information to the Sanders County Commissioners and various organizations including the Lolo Restoration Committee, Mineral County Resource Coalition, and Thompson Falls Community Trails Committee.
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In response, 22 individual comment letters and 19 form letters with the same content were received. All but two letters were supportive of the overall proposal; however some expressed concerns regarding specific aspects of the project. Those opposing the project requested the project be dropped or an EIS be prepared due to concerns over potential effects of proposed activities to forest resources (see below). In contrast, several other comments requested more salvage, using all means practical to harvest as much as possible, as fast as possible. Many comments encouraged the Forest Service to request an Emergency Situation Determination (ESD)9 from the Chief of the Forest Service.
In addition, three commenters also provided literature references to be considered. These references are addressed in Appendix D. 1.6 Issue Resolution Public comments were reviewed to identify concerns and issues relative to the Proposed Action. These comments were summarized in the content analysis of public comment, which is located within the Project File. Issues raised by the public were addressed: 1) by developing alternatives to the Proposed Action; 2) in project design; 3) by creating resource protection measures; and 4) through analysis to determine environmental effects. Issues raised during scoping and how they were addressed are briefly summarized below.
Temporary road construction and timber harvest could: o increase sediment delivery to streams and adversely affect fish and water quality o adversely affect soils o damage and slow the re-establishment of trees o exacerbate weed spread o reduce hiding cover for wildlife o reduce snags and downed trees needed by lynx and other forest carnivores for denning o reduce grizzly bear core habitat o reduce attributes of old growth forests o reduce bird and beetle habitats o reduce on-site carbon storage by removing tree boles from the forest as logs Chapter 3 discloses the effects of temporary road construction and timber harvest on these resources. The analysis concluded that the project would not have significant effects. Resource protection measures (Chapter 2, section 2.1.1), best management practices, and project design criteria would minimize adverse effects to the above listed resources. The effects of the Copper King Fire itself is also considered and discussed.
Salvage operations would occur on a relatively small portion (from 8-12 percent) of the National Forest System lands affected by the Copper King Fire, leaving the vast majority of
9 Under 36 CFR 218.21(d), a proposed action is not subject to the pre-decisional objection process if the Chief or Associate Chief of the Forest Service determines that an emergency situation exists with respect to all or part of the proposed action or activity. Use of an ESD would allow implementation to begin as early as June/July 2017.
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the burned area to natural processes. This small scale alone reduces the potential for adverse effects to many of the above listed resources. BAER work that will be completed regardless of this project will reduce the potential sediment delivery from existing roads.
Expected timing of project implementation after next summer could result in increased wood deterioration and reduced value.
The Lolo National Forest has made the Copper King project its highest priority to expedite project completion in response to requests from the public, timber industry, and State and local governments. Additional staffing was obtained and other projects were deferred.
A brief discussion of wood deterioration and resulting value change is discussed in Chapter 2, section 2.3.
Closure of the Bay State Creek trail #1268 to motorized use could reduce recreation opportunities.
Chapter 3, Recreation section 3.9 discusses the effects of the trail closure on public recreation. Currently, the Bay State Creek trail #1268 is closed to motorized use for public safety until hazard trees can be mitigated (Closure order #F17-012-LOLO-D5). Thus in the short-term, the Copper King project would have no effect on recreation access. In the long-term, closure of the Bay State Creek trail to motorized use would reduce 5 miles of motorized trail opportunities, which equates to a 52 percent reduction within the Copper King project area and a 4 percent reduction across the Plains/Thompson Falls Ranger District. Off-road motorcyclists who use or would use this trail would be displaced. However, based on track surveys conducted during the summer and fall of 2015, the trail receives low motorized use. Therefore, the number of recreationists likely affected by the trail closure to motorized use would also be low.
Winter logging requirements could reduce project viability.
The rationale for requiring winter logging in specific units is provided in Chapter 3, Soils section 3.3. Chapter 3, Economics section 3.10 discloses the costs associated with this requirement. To contribute to the body of knowledge about effects of post-fire salvage on soils, monitoring would be required in specific units. These units would be part of an adaptive management study to assess soil disturbance in relation to burn severity and season of harvest.
Ground-disturbing activities associated with salvage activities (e.g. road construction, log skidding/yarding, and log haul on roads) across multiple ownerships could yield sediment to area streams and cumulatively degrade water quality and aquatic habitat.
Chapter 3, Hydrology section 3.4 and Fisheries section 3.5 disclose the cumulative effects of the salvage activities on multiple ownerships within the Copper King Fire perimeter. Resource protection measures (Chapter 2, section 2.1.1), best management practices, project design criteria and ongoing BAER work would minimize the potential for sediment delivery. The highest potential for sediment delivery is from roads used for haul. Cumulatively, sediment delivery from state, private, and Forest Service road-related actions would be low compared to estimated natural background levels post-fire and would not adversely affect stream stability, substrate, or channel structure. Cumulative effects to fish and fish habitat would be low as sediment generated would generally be in small tributaries that are not fish bearing. Haul on Road #9991[ACM road] could deliver small quantities of sediment to the
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Thompson River. The volume of water in the river would dilute the sediment and help to flush it through the system. Minor effects to fish would likely be in the form of temporary avoidance of areas of increased turbidity, immediately downstream from delivery points. However, site- specific resource protection measures would be applied to Road #9991 before haul begins to reduce the sediment potential (see Chapter 2, section 2.1.1).
Salvage operations around the historic Cow Camp Lookout tree, killed by the fire, could damage and/or accelerate the eventual toppling of the tree.
A resource protection measure was developed to buffer the tree and associated historic debris by 100 feet from all activities (see Chapter 2, section 2.1.1 and Chapter 3, Heritage section 3.8). With this required protection, salvage operations would have no adverse effect on this heritage resource. The Montana State Historic Preservation Office has concurred with this finding.
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CHAPTER 2: ALTERNATIVES Section 102(2)(E) of the National Environmental Policy Act (NEPA) requires the Forest Service to study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources. The Forest Service did this with the alternatives described below. 2.1 Alternatives Considered in Detail
Overview of the Alternatives Three alternatives were considered in detail. Maps of the alternatives are located in Appendix A.
Alternative 1: No Action
Alternative 2: Modified Proposed Action
Alternative 3: Alternative with Additional Salvage (derived from public comments)
Details of the Alternatives
Alternative 1 This alternative proposes no actions that are contained in Alternatives 2 and 3. It provides a baseline for comparison of the environmental consequences of Alternatives 2 and 3 to the existing condition and is a management option that could be selected by the Responsible Official. The results of taking no action would be the current condition as it changes over time due to natural forces. Alternative 1 responds to public comments that expressed a desire for no post-fire management actions.
This alternative would continue the standard resource protection and recurrent maintenance activities such as access management and routine scheduled road maintenance that are currently ongoing in the project area. Ecosystem processes such as vegetation succession would continue their current trends.
Alternatives 2 and 3 These alternatives respond to the purpose and need described in Chapter 1 and public comments that requested post-fire actions, particularly salvage, be implemented. Table 2-1 displays the summary of proposed activities within Alternatives 2 and 3. Refer to Appendix A for maps and Appendix B for unit-specific information.
Table 2-1: Summary of Proposed Activities by Alternative Proposed Activities Alternative 2 Alternative 3 Modified Proposed Public-derived Action Alternative with more salvage Vegetation Treatments Salvage (acres) 1242 2055 Mix of salvage and green tree thinning (acres) 100 100 Roadside Hazard Tree Removal1 (mapped) (acres) 158 155 Historic site hazard tree removal2 (Unit 116) (acres) 2 2 TOTAL (acres and percent of NFS land in fire area ) 1502 (8%) 2312 (12%) Road Treatments Temporary Road Construction (miles) 3 7.3 Road Maintenance (miles) 90 105
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Proposed Activities Alternative 2 Alternative 3 Modified Proposed Public-derived Action Alternative with more salvage Other Proposals Tree Planting (acres) 6000 6000 Trail travel management change from open to closed to 5 5 motorized use (Bay State Creek Trail #1268) (miles) 1The table reflects only the mapped concentrations of commercially viable hazard trees. Outside of these areas, incidental hazard trees within 100 feet of National Forest System roads that have a high likelihood of falling on the road would be mitigated as described below. 2Hazard trees would be removed around the historic cabins at the Silver King mine.
Description of the Proposed Activities
Vegetation Treatments
Salvage In identified salvage units, dead and dying trees that meet merchantability specifications10 would be removed. Unmerchantable (rotted, checked, or small diameter) trees would be retained.
Mix of Salvage and Green Tree Thinning In ponderosa pine stands that burned at low to moderate severity, some live trees would be thinned to reduce bark beetle susceptibility of the residual large diameter ponderosa pine trees. Fire-killed trees would be removed as described above under the salvage description.
Roadside Hazard Tree Mitigation Hazard trees within 100 feet of roads would be mitigated. Approximately seven non-contiguous miles of roads are estimated to contain accessible concentrations of merchantable hazard trees (155-158 acres, which are displayed in Table 2-1 and on the maps in Appendix A). Mechanized equipment used to remove the cut trees would remain on the road. Directional felling and a cable yarding systems would be used to bring the trees to the road to be processed and hauled to a milling facility.
Incidental merchantable hazard trees, outside of the concentrated areas along the remainder of the National Forest road system, could also be commercially removed where practicable and agreed to by both the Forest Service and a purchaser. In these areas, hazards are less concentrated due to natural stand conditions, burn severity, or previous removal. Due to the random location of hazard trees, their removal would not result in one long continuous clearing. Rather, hazard trees would be selected for cutting based on their risk of falling (failure potential) and their likelihood of striking the road if they fall. As described above, mechanized equipment used to remove the cut trees would remain on the road. No hazard trees would be removed within riparian habitat conservation areas except along Road #9991 [ACM road], which runs parallel to the Thompson River (see Resource Protection Measures in Chapter 2). Roadside hazard trees located within riparian habitat conservation areas (except those located along Road #9991) would be cut and left on the ground.
Roadside hazard trees that are too small (non-commercial less than 8 inches in diameter) and/or inaccessible due to terrain that makes it infeasible for commercial tree removal, would be felled and left on the ground.
10 For this project, merchantable dead trees are those that are at least 8 inches diameter breast height; have at least an 8 foot piece to a 5.6 inch top diameter; and are at least 33 percent sound.
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A hazard tree is defined as a dead tree within approximately 100 feet of a road that has one or more of the following conditions and any part of the bole of the tree can reach the road as follows:
The tree is leaning more than 10° towards the road.
The roots or part of the bole is comprised in such a way (cat faces on the bole, roots of one side of the tree are burned off, etc.) that the tree would fall towards or onto the road.
Ground conditions would direct the tree towards the road such as steep slopes, unstable ground (scree slopes), etc.
The tree is perpendicular to the ground or has a less than 10° lean, and is exposed to the prevailing wind and the road is on the leeward side of the tree from the prevailing wind in wind prone areas (exposed ridges, saddles, canyons, etc.).
Historic Site Hazard Tree Removal Live and dead trees that are a danger to the historic cabins at the Silver King mine site would be cut and removed.
Road Treatments
Maintenance Road maintenance and application of best management practices (BMPs) would be completed prior to log hauling to ensure safe and efficient haul and protection of water quality in the project area. Maintenance would include activities such as surface blading, minor earth work (e.g. cut and fill reshaping), road surface reshaping, ditch cleaning and reshaping, roadside clearing and/or brushing, seeding disturbed areas, drain dip and cross drain cleaning and construction, culvert cleaning, armoring, and/or replacement, slash filter windrow and sediment trap construction near live water crossings.
Road maintenance activities would complement ongoing BAER work to protect water quality.
Temporary Road Construction In general, temporary roads would be constructed to the lowest standard possible to provide access for timber harvesting equipment and log trucks. Following completion of the project, these roads would be decommissioned. Decommissioning activities would include recontouring the ground to the approximate shape of the surrounding terrain, placing slash and debris on the reclaimed surface, and seeding of native species. Temporary roads with complexity (Alternative 3 only) would be designed by the Forest Service. Complexities include location on steep slopes, length, stream crossings requiring engineering control, and/or complicated topographic features.
Tree Planting Planting of conifer seedlings would be conducted on approximately 6000 acres including areas identified for salvage under both alternatives and other areas where the fire burned at high severity. Depending on site conditions, western white pine, western larch, ponderosa pine, and whitebark pine are the preferred native species that would be planted.
Trail Travel Management Change The Bay State Creek trail #1268 (approximately 5.0 miles) would be closed to motorized use from the junction with Road #9991 [ACM Road] to the junction with Trail #445 to mitigate for the loss of grizzly bear core habitat from proposed temporary road construction (Alternative 2 - 7575ext, 45005Aext, 45005Aext2, 894ext, 18808ext, 875ext, 18832ext, and 18828ext; Alternative 3 - includes
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the temporary roads for Alternative 2 plus 18780ext, 17003ext, 45005ext, and 45008ext.). To comply with the Forest Plan as amended by the 2011 Forest Plan Amendments for Motorized Access Management within the Selkirk and Cabinet-Yaak Grizzly Bear Recovery Zones, potential losses to existing core grizzly bear habitat from forest management activities must be compensated with in-kind replacement concurrently or prior to incurring the loss.
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2.1.1 Resource Protection Measures Resource protection measures are incorporated into the action alternatives to mitigate the potential for proposed activities to cause unintended harm to the environment.
Project-specific resource protection measures (Table 2-2) have been identified for the Copper King Fire Salvage project. In addition, the Lolo National Forest has developed standard operating procedures (SOPs), which include best management practices that have been determined to be effective in minimizing potential environmental effects (see Table 2-3). SOPs area applied to all projects. The following resource protection measures have been incorporated into Alternatives 2 and 3. Thus, the environmental effects displayed in Chapter 3 reflect the implementation of these measures (Tables 2-2 and 2-3).
Table 2-2: Project-specific Resource Protection Measures Resource Description of Project-Specific Resource Protection Measure Units/Location Protection Measure Soils 1 Within listed units, tractor harvest would be restricted to winter operating conditions. Winter operating conditions 1, 3, 5, 7, 9, 25, 26, require frozen ground or depth of snow sufficient to support equipment and protect soil surface. Because depth of 27, 28, 29, 32, 72, snow necessary to protect forest floor varies with snow density, sufficient snow depth would be approved by the 78, 91 timber sale administrator. 2 By purchaser agreement, in lieu of waterbars, slash of mixed sizes (at least 50 percent, less than 6 inches diameter) 4, 12, 13,18, 19, 22, would be placed over skid trails to prevent erosion in units. Slash would cover approximately 65−70% of the trails to 23, 37, 46, 47, 49, a depth of approximately 2−3 inches where available (approximately 10-15 tons/acre). 51, 53, 55, 59, 60, 63, 64, 66, 82, 90, 101-120 3 All existing soil wood (wood in an advanced state of decay) would be left unless it is deemed a hazard to equipment 1, 3, 5, 7, 8, 15, 21, operations. 22, 26, 28, 29, 37, Tops of harvested trees would be left within activity units following the silvicultural prescription in units with low 59, 91 coarse woody debris levels. 4 Units would be planted with trees by hand after harvest and post-harvest activities are complete, following the All Units EXCEPT silvicultural prescription. 4, 59, 61, 62, 66, and 100-109 5 In tractor units, ephemeral draws would be buffered by 50 feet and ground-based equipment would be prohibited Tractor units except at designated crossings. Tree cutting and removal would be allowed within ephemeral draw buffers if they are
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Resource Description of Project-Specific Resource Protection Measure Units/Location Protection Measure dry. In winter log units, buffers would not be required. Wildlife 6 All roads used for log haul or management activities would be returned to their pre-project condition, meaning that Project area roads with berms or entrance obliterations would be returned to that condition upon closure of the timber sale contract. Gated roads would remain gated with same travel management restrictions as before the project. 7 If harvest operations occur prior to July 1st, surveys for nesting woodpeckers would be conducted within affected units. Project area If active nesting were observed in the unit, activities there would be postponed until after July 1st. 8 Temporary road stream crossings (18832ext in Bay State Creek – Alts 2 & 3 and 18780ext in Big Hole Creek – Alt 3 Temporary road only) would be surveyed for Coeur d’Alene salamanders. If present, options to avoid or minimize potential impacts 18832ext (Alt 2 & would be considered. 3), 18780ext (Alt 3 only) 9 The closure of the Bay State Creek trail #1268 to motorized use would occur before construction of temporary roads. Bay State Creek trail #1268 Botany 10 Project botany surveys would occur prior to implementation of timber harvest and temporary road construction. Site- Harvest units and specific sensitive plant protection measures would be developed as needed to maintain the viability of sensitive plant temporary roads species impacted by project activities. where habitat is identified. Aquatics 11 Unless otherwise agreed, log haul would be prohibited on County Road 56 along the Thompson River. County Road 56 12 A slash filter windrow would be installed on all stream crossings on haul routes and where needed when the road is Roads used for haul within 300 feet of streams before blading, haul, and other project activities occur. Slash filter windrows would also be placed on relief culvert outlets that are within 300 feet of a waterway. Road #9991 [ACM road] is an exception based on road surveys and flat topography. Site-specific slash filter windrow locations have been identified on this road. 13 Stream crossings (culverts) selected as needing upgraded for BAER treatments, and on haul routes would be completed prior to log haul, unless otherwise approved by fisheries biologist and Line Officer. 14 As part of log haul, additional erosion controls would be installed on an as needed basis including silt fences, straw bales, or other temporary but effective measures to reduce sediment from reaching streams. 15 Implementation of road BMP treatments would occur between April 1 and October 15 during dry weather periods, unless otherwise approved by project specialist. 16 If new streams or overland flow develop in the post-fire environment, they would be treated as existing streams with the appropriate crossing structure on the road system. 17 Specified road construction would occur between April 1 and October 15 during dry weather periods unless otherwise Short-term specified agreed by a watershed specialist (hydrologist or fisheries biologist) and engineer. road construction
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Resource Description of Project-Specific Resource Protection Measure Units/Location Protection Measure 18 Dust abatement would be applied every year timber haul occurs on Road #9991 [ACM road] adjacent to Thompson Road #9991 [ACM River. road] 19 Road #9991 [ACM The following contributing sediment sources to Thompson River would be addressed on Road #9991 [ACM road] road] prior to log haul:
Location Condition Recommended Action CSS 1 Less than 50-foot Break berms at approximately 50-foot intervals to allow run-off to MP 0.9-1.0 riparian buffer disperse gradually; apply slash filter if point-source sediment inputs exist. CSS 2 Less than 50-foot Break berms at approximately 50-foot intervals to allow run-off to MP 1.7-2.3 riparian buffer disperse gradually. CSS 3 Culvert outlet Apply slash filter to culvert outlet. MP 2.3 CSS 4 Less than 20-foot Construct berm on inside road edge to direct water off outside MP 2.5 buffer; steep bank road edge. CSS 5 Less than 20-foot Break berms at approximately 50-foot intervals to allow run-off to MP 3.1 buffer; steep bank; disperse gradually. road grade directs water into river CSS 6 Road grade directs Modify berms if present to facilitate drainage to the outside. MP 5.2 water away from river CSS 7 Less than 20-foot Construct berm on inside road edge to direct water off outside MP 6.8 buffer; steep bank road edge. CSS 8 Less than 20-foot Add spot gravel to reinforce areas where water puddles. MP 9.5 buffer CSS 9 Culvert outlets Apply slash filters to culvert outlets. MP 12.1-12.2 CSS 10 Less than 20-foot Create berm on inside road edge to divert water of outside road MP 12.2-12.4 buffer; steep bank edge; apply spot gravel to reinforce areas where water puddles. General Action 1: Modify berms where road slopes to outside edge to facilitate directing water and sediment away from Thompson River. General Action 2: Break berms in approximately 50-foot intervals where less than a 50-foot riparian buffer exists between Road #9991 and Thompson River and where water would then be allowed to disperse gradually and prevent washout scenarios that would create point-source sediment inputs.
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Resource Description of Project-Specific Resource Protection Measure Units/Location Protection Measure 20 An additional 50 feet would be added to standard INFISH stream buffers and a map provided to layout crews. The Harvest units boundaries of Riparian Habitat Conservation Areas (RHCAs) would be designated on the ground prior to implementing timber harvest activities. Tree removal and ground-based equipment would be prohibited in all RHCA buffers, except hazard trees would be removed along Road #9991 [ACM road] within the RHCA of the Thompson River. Roadside hazard trees located within RHCAs elsewhere in the project area would be felled and left on the ground.
Channel Type Buffer (feet) Perennial fish bearing stream* 350 Perennial non-fish bearing stream and wetlands greater than 1 acre 200 Seasonally flowing or intermittent streams and wetlands less than 1 acre 150 *Except the Thompson River: RHCAs for the Thompson River would be 300 feet.
Heritage 21 A 100-foot no activity buffer would be established around the historic Cow Camp Lookout tree to protect the feature 3 and the associated historic debris. 22 Historic Forest Service Trail #355 would be buffered from all activities as directed by an archaeologist. However, 3, 7, 9, and designated trail crossings would be identified prior to harvest operations. Slash mats or other ground buffering method temporary roads may be required to protect the existing trail tread at the designated crossings. 45005A-ext and 45005A-ext2 23 The heritage staff would flag no-equipment buffers around historic features at the Silver King Mine. Slash mats may 115, 116 be considered to buffer the ground from heavy equipment near the cabins. 24 Heritage surveys would be conducted prior to implementation of salvage operations and/or hazard tree removal along Salvage units and Road 9991 [ACM road]. As needed, site-specific resource protection measures would be developed to protect hazard tree removal identified heritage features areas accessed from Road 9991 [ACM road] 25 Alternative 3: Heritage surveys would be conducted prior to implementation of salvage activities within at least Units Alt 3: Units 71, 73, 71, 73, 82, 92, 98, and 99. As needed, site-specific resource protection measures would be developed to protect 82, 92, 98, 99 identified heritage resources. Recreation 26 For public safety, segments of Road #9991 [ACM] road would be closed to public travel when felling operations were Road #9991 [ACM] occurring along the road. The segments of road closed would only be where and when there were active felling operations. The remainder of the road would be left open.
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Table 2-3: Standard Operating Procedures Standard Operating Procedures Units/Location Soils During Summer Operating Conditions: 4, 12, 13,18, 19, 22, . Tractor harvest would only occur on dry soils. Soil moisture would be evaluated at the bottom of the root tight layer (2-5 inches 23, 37, 46, 47, 49, below soil surface). Refer to Table B1 in Soil File 4 (Lolo NF Ground-Based Harvest Guidelines) located within the Project File 51, 53, 55, 59, 60, for dry soil, field assessment information. 63, 64, 66, 82, 90, . Existing skid trails and landings would be reused to the extent possible in order to limit new soil disturbance. 101-120 All ground-based harvest would be limited to slopes of 35% or less in accordance with the Lolo National Forest Plan. All tractor units If seasonally moist areas are present at time of harvest, a 50-foot no equipment buffer would be provided around the wet area. All units Existing landings would be re-used to the extent possible All landings Landing rehabilitation (erosion control) would occur on dry soils and would be completed as follows: . Scarification to a depth of 4-6 inches. . Seeding using appropriate Lolo National Forest native grass mix Level of temporary road and excaline trail decommissioning would depend on existing condition of the site prior to road or trail All temporary roads construction and would be decommissioned following site-appropriate combinations of the following: and excaline trails . Top soil and slash would be stored along temporary roads and excaline trails to the greatest extent possible and pulled back over the road surface during decommissioning. . Installed culverts would be removed. . The temporary road and excaline trail surface would have site-preparation to a depth of at least 6 inches. Site preparation may include recontouring, de-compaction, and/or scarification. . Site would be seeded using appropriate Lolo National Forest native grass mix. . Slash of mixed sizes (at least 50% less than 6 inches diameter) would be placed over the site to prevent erosion. Slash would cover approximately 65-70% of the road or trail to a depth of approximately 2-3 inches where available (approximately 10-15 tons/acre). Coarse woody debris would be retained for long-term soil productivity and wildlife habitat. Activity units For salvage harvests (all units except 4, 37, 59, 66): Down woody material over 3 inches diameter by 6 feet long would be retained at the following amounts as measured after post-harvest slash treatments are completed: . A minimum of 4 tons/acre in Fire Groups 2, 4, and 5 . A minimum of 7 tons/acre in Fire Groups 6, 7, 8, 9, 10, and 11 For units with live tree thinning (units 4, 37, 59, 66): Down woody material over 3 inches diameter by 6 feet long would be retained at the following amounts as measured after post-harvest slash treatments are completed: . A minimum of 7 tons/acre in all Fire Groups
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Standard Operating Procedures Units/Location Weeds Weeds along roadways would be treated with herbicide prior to beginning road activities including, but not limited to, temporary road Project Area construction, road reconstruction, and maintenance unless existing road conditions (i.e. vegetation on road, road barriers, etc.) prohibit reasonable access for spraying equipment. Reasonable access would be determined by the District Weed Coordinator. If existing road conditions prohibit access, then treatment would be deferred until the road activities clear the obstruction. The determination of which roads to be treated would be made by the District Weed Coordinator based on weed inventories and treatment schedules. Off-road equipment would be cleaned (power or high pressure cleaning) of mud, dirt, and plant parts before moving into the project area. At the discretion of the Contracting Officer, equipment, vehicles, and trailers of planting contractors would be cleaned of dirt, plant parts, and material prior to initial entry into the project area. Skid trails, skyline corridors, and landings would be approved prior to use. Where possible, skid trails, skyline corridors and landings would be located where there are no obvious standing weed infestations. Where possible during sale preparation activities, identified landing areas would be treated with herbicide as needed. Temporary roads would be treated with herbicide prior to final road obliteration unless waived by agreement. If possible, gravel or other material used for road surfacing would be from a site (pit) that has been previously treated for weeds and is currently weed free. Disturbed sites would be seeded with native seed mixtures or appropriate Lolo National Forest seed mixtures. Straw or other material used for road stabilization and erosion control would be certified weed-free or weed seed-free. Use of herbicides for weed control would follow mitigation measures outlined in the Lolo National Forest’s 2007 Integrated Weed EIS and Record of Decision to protect water resources. These measures include: . All application of herbicides would be performed by, or supervised by, a state licensed applicator following all current legal application procedures administered by the Montana Department of Agriculture. . All herbicides would be handled following Environmental Protection Agency (EPA) label guidelines and other state and federal laws for storage, application, and disposal methods. . Mixing would take place at least 150 feet from open water unless spill containment devices are readily available and an anti-back siphoning device is used when drafting water. . Applicators would review stream and wetland areas to ensure that herbicides would not be applied to open water. . Herbicides would be used to water’s edge only when absolutely needed and provided the product label allows such use. . Herbicide applications near live water or in areas with shallow water tables would follow label directions. . Herbicide applicators would not initiate spraying when heavy rains are forecast that could cause offsite herbicide transport into sensitive resources such as streams. . Herbicide applicators would be familiar with and carry an Herbicide Emergency Spill Plan to reduce the risk and potential severity of an accidental spill. Herbicide applicators would also carry spill containment equipment. . Herbicides would not be applied if snow or ice covers the target vegetation. . Low boom pressure (less than 40 pounds per square inch) would be used to reduce drift. . Drift reduction products would be used as needed near sensitive resources. . Ground-based herbicide application would occur only when wind speed is 10 mph or less.
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Standard Operating Procedures Units/Location . If commercial applicators are used for the application of restricted use pesticides, Forest Service contract administrators would check to make sure their Montana commercial restricted use pesticide license is current. Wildlife Food/wildlife attractant storage special order (F11-005) would be applied to all activities. Project area Travel management restrictions for public motorized use on roads would be maintained during project implementation. Project area If a nesting goshawk is detected, salvage activities would be halted and the wildlife biologist would be consulted to identify protection Project area needs. Aquatics Roads used for haul would have BMPs installed before timber haul. BMPs include road surface and ditch drainage, functioning Roads used for haul ditches, adequate spacing of drain dips or ditch relief culverts, leadouts or drainage structures before stream crossings, road shaping to shed water off the surface and not into streams, and spot graveling of areas where drainage treatments may not be fully effective due to stream proximity. BMPs on haul routes would also be functional at the close of product removal activities. Erosion control measures (e.g. straw bales, wattles, silt fences, hydro mulching, slash, etc.) would be installed where necessary and remain in place during and after ground disturbing activities. Erosion control devices are required on reconstructed roads within 300 feet of streams or drainage crossings and temporary roads. Disturbed areas would also receive appropriate seeding and mulching, and/or slash treatment. Erosion control measures would remain functional until disturbed sites (roads, culverts, landings, etc.) are stabilized; typically for a minimum period of one growing season until vegetative cover stabilizes and reduces runoff potential. If winter hauling is to occur, drain holes would be designated prior to winter haul, and kept open throughout the duration of winter hauling. Drainage would be effective throughout the season and be directed away from all stream (ephemeral, intermittent, perennial) channels. For winter hauling, all culverts would be marked before snow, so they can be located and cleared of debris as needed to keep them functioning. This would aid equipment operators from crushing the inlet and outlet of culverts. Ditches and culverts would be made functional during snow plowing operations. Snow would not be completely removed. In general, a minimum 2 inches of snow would be left on the roadway during plowing operations to protect the surface of the road. Sidecast material during snowplowing would not include dirt and gravel. Instream work would be permitted by Montana Fish, Wildlife and Parks (124 Stream Protection Act permit). Instream work would be limited to July 15 through August 30, unless otherwise stated in the 124 permit. All temporary roads and landings would be rehabilitated and seeded with approved Lolo National Forest seed mix and covered with Temporary roads slash or mulch within one year of Purchaser’s use. Short-term specified roads would be decommissioned following sale and post-sale and landings activities. Forestry Best Management Practices would be utilized to minimize effects to soil and water. All activity areas Heritage If previously unknown heritage resources are encountered during project implementation, activities would be halted and the Zone All activity areas Archeologist would be notified to determine appropriate protection measures. Slash would not be piled on cultural resource features (e.g. can dumps, foundation remains, ditches, root cellar depressions).
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2.1.2 Monitoring There are generally three different types of monitoring:
Implementation monitoring determines whether the project activities were implemented as designed.
Effectiveness monitoring determines if management practices as designed and executed result in the desired resource conditions.
Validation monitoring examines the quality of the data and assumptions used in the analysis process.
Implementation and effectiveness monitoring would be conducted under this project to: (1) determine whether the original objectives of the activities are met; (2) determine the need for additional action; and (3) educate and assist in the design in future projects.
For this project, monitoring would be implemented in accordance with the requirements outlined in the Lolo National Forest Plan. Forest Plan monitoring, done on a sample basis, would also determine the overall effectiveness of the project and effectiveness of the design criteria.
Monitoring of the vegetation treatment activities implemented under contract would occur during and immediately following contract implementation. All preparation and subsequent project- associated operations would be monitored by Forest Service representatives to ensure compliance with specifications.
Vegetation A certified Silviculturist would develop or approve silvicultural prescriptions for each vegetation treatment unit and would assure compliance with these prescriptions during sale preparation, contract administration, and post-harvest activities. The silviculturist would be involved in and/or consulted during treatment area boundary layout, tree designation, and contract preparation.
A qualified Timber Sale Contract Administration team, including a Contracting Officer, Forest Service Representative, Timber Sale Administrator, and/or Harvest Inspector would inspect compliance with provisions of the timber sale contract during implementation of activities.
Weeds Harvest units would be monitored for the presence of weeds in conjunction with future monitoring and/or inventory activities. Follow-up actions would depend on the monitoring findings.
On a representative sample basis, roads sprayed with herbicide would be monitored for treatment effectiveness, the presence of a new noxious weed, or the spread of existing noxious weeds in conjunction with other subsequent activities in the area.
Soils Approximately 10 percent of units would be monitored following implementation. Required monitoring would include units 1, 19, 25, and 49. These units would be part of an adaptive management study to assess soil disturbance in relation to burn severity and season of harvest. There is so much variation in burned forests and logging equipment that it is difficult for small scale research to provide general principles for mitigating ecological damage in the post fire
24 Copper King Fire Salvage Environmental Assessment environment. Some research suggests that managers could benefit from comparing different practices and prescriptions in an operational context instead of relying solely upon scientific research (Duncan 2002). Units 1 and 19 displayed moderate burn severity and units 25 and 49 displayed high burn severity. Units 1 and 25 would be logged under winter conditions while units 19 and 49 would be logged under summer conditions. Units would be monitored immediately after harvest and two years following harvest. All study units are expected to meet soil policy after management activities. If detrimental soil disturbance is greater than 15 percent in any monitored units, a soil rehabilitation plan would be developed to reduce site specific detrimental soil disturbance and reach compliance with Regional soil quality standards.
Heritage Following implementation, an inspection would be conducted of heritage sites located within and adjacent to timber harvest units to assess their condition. 2.2 Alternatives Considered but Eliminated from Detailed Study Federal agencies are required by NEPA to rigorously explore and objectively evaluate all reasonable alternatives and to briefly discuss the reasons for eliminating any alternatives that were not developed in detail (40 CFR 1502.14). Some public comments received in response to the proposed action provided suggestions for alternative methods for achieving the purpose and need. Several alternatives were considered, but dismissed from detailed consideration for the reasons summarized below.
Include salvage within the roaded portion of the Inventoried Roadless Area Approximately 9,150 acres or 47 percent of the National Forest System land within the Copper King fire perimeter is located within the Teepee-Spring Creek Inventoried Roadless Area (IRA). As displayed on the maps in Appendix A, a portion of this IRA contains National Forest System roads.
The 2001 Roadless Area Conservation Rule prohibits timber harvest within IRAs with some exceptions. One of those exceptions is in areas where roadless characteristics have been substantially altered due to the construction of roads and subsequent timber harvest (36 CFR 294.13(b)(4)). To use this exemption, the Chief’s review and approval is required (Chief’s letter dated May 31, 2012 regarding roadless activities review process).
Because the roaded area of the Teepee-Spring Creek IRA fully meets the description of ‘substantially altered’ within the 2001 Roadless Rule, the Forest Service rigorously explored an alternative to include salvage within the IRA. Field reconnaissance was conducted and preliminary salvage opportunities were identified. However, this alternative was not carried forward because of the complexity and time needed for the environmental analysis of activities in IRA and required review by the Washington Office. The timeline for this additional analysis and review process would not meet the need to expedite the project to respond to the rapid product deterioration of burned material.
Reduce road densities to the maximum extent possible One public comment requested an alternative that reduces road densities within the project area to restore terrestrial and aquatic habitat conditions.
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Due to the intermingled ownership in the northern portion of the project area, approximately 57 percent of the road miles have existing cost share agreements or easements. During development of the Copper King project, the existing area transportation plan for the project location was reviewed. This area transportation plan identifies the minimum transportation system in the Copper King project area to meet long-term land management needs on National Forest System lands. This existing plan was validated through review of the entire existing road system using field survey data, aerial photographs, Google Earth ©, and GIS. Based on these reviews, the Forest Service determined that the existing area transportation plan still adequately identifies the minimum road system for the area and that no substantial adjustments are needed. Therefore, the project does not include modifications to the road system.
Ongoing BAER work on the Copper King transportation system has and will continue to address the risk of road drainage failure due to anticipated increased water flow and movement of sediment and debris from the fire (see Section 3.1 for more detail). Copper King Fire Salvage road maintenance would focus on the remaining work required to maintain the roads for project activities and meet best management practices (BMPs). Between BAER work and road maintenance conducted under the Copper King project, approximately 77 and 92 miles (64 and 77 percent), respectively, of the National Forest System roads in the project area would be treated in Alternatives 2 and 3. These treatments would reduce resource effects of the existing road system particularly during the first years following the fire when the landscape is most vulnerable to storm events.
For the above reasons, this alternative was dropped from detailed study.
No salvage The two letters received in opposition to the project requested that no salvage activities be conducted due to the potential adverse effects on the environment.
Dropping all of the salvage activities would not meet the primary purpose of the project. The No Action Alternative (Alternative 1) closely resembles what is being requested because no salvage or associated activities would occur. Alternative 1 is analyzed in this document and therefore another alternative that drops all salvage activities was not developed. 2.3 Comparison of Alternatives In summary, Alternatives 2 and 3 are consistent with the Lolo National Forest Plan, laws, and other regulatory guidance. Both alternatives meet the purpose and need of the project by recovering economic value of forest products, reducing roadside hazards, and reforesting areas affected by the fire. Both alternatives would result in contributions to local economies. Alternative 3 could contribute more jobs and labor income compared to Alternative 2. However, the economic feasibility analysis indicates that Alternative 3 may not sell as currently designed due to high temporary road costs (see Tables 2-4 and 2-5).
Table 2-4: Comparison of Alternatives Alt 2 Alt 3 Yarding Method for Harvest (acres & percent of total harvest acres) Tractor (summer or winter) 364 (24%) 382 (17%) Tractor (winter required) 233 (16%) 269 (12%) Skyline 747 (50%) 1410 (61%) Excaline1 0 (0%) 96 (4%) Roadside Hazard Tree Removal (mapped) 158 (10%) 155 (7%)
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Alt 2 Alt 3 TOTAL 1502 2312 Temporary Road Construction (miles) (see Table 2-5 for more 3 7.3 detail) Construction requiring engineering design due to steep side slopes, 0 3.6 road length, and/or complicated terrain features (miles) Full bench construction2 needed (miles) 0 0.4 Total estimated construction and decommissioning costs $31,000 $256,055 Forest Type - primary species in salvage units (acres and percent) (See Table 2-6 for anticipated wood deterioration by species) Ponderosa pine 45 (3%) 45 (2%) Western larch 296 (20%) 625 (27%) Douglas-fir 603 (40%) 708 (30%) Lodgepole pine 96 (6%) 195 (8%) mix of shade intolerant species (not one species is dominant, but 401 (27%) 659 (29%) the majority of species are shade intolerant) Subalpine fir 10 (1%) 11 (0.5%) Western redcedar 2 (0.1%) 3 (0.1%) mix of shade tolerant species(not one species is dominant, but 19 (1%) 31 (1%) the majority of species are shade tolerant) Estimated Timber Volume (MMBF = million board feet; CCF = 12 MMBF 18 MMBF hundred cubic feet) 24,039 CCF 36,995 CCF Appraised Stumpage Rate $16.33/CCF $1.74/CCF* Total Revenue $854,000 $775,000 Estimated Part and Full Time Jobs Contributed32 (all activities) Direct 140 180 Indirect and Induced 92 130 TOTAL 232 310 Estimated Labor Income Contributed3 (all activities) Direct $6,339,000 $8,346,000 Indirect and Induced $3,288,000 $4,695,000 TOTAL $9,627,000 $13,040,000 1Excaline –a tracked excavator that has been adapted for logging practices to include winches and cables and a longer boom with pulleys that serve as a skyline tower. Excaline machines may be walked (self- propelled by their own power) to remote locations to reduce the need for road construction. Yarding capabilities (length of reach) of an excaline machine are typically less than that of a skyline machine. 2Full bench construction is generally conducted on slopes greater than 65 percent and involves excavating and removing existing soil material from the constructed road prism without embankment (fill) construction. Full bench road segments would not be fully recontoured following project activities because there would be no road fill to pull back onto the prism. 3These may not be new jobs or income, but rather jobs and income supported by this project. *Appraised rate is lower than base rate (of $3.60/CCF) indicating Alternative 3 is not feasible with its current design due to high temporary road costs and may not sell.
Temporary Road Construction Alternative 2 was designed to minimize the need for and potential resource effects of temporary road construction. Temporary roads in this alternative are relatively short segments, located at ridgetop and upper slope locations with side slopes generally less than 30 percent, and include one minor stream crossing at the upper end of a small tributary to Bay State Creek. Engineering design is not needed on any of the Alternative 2 temporary road segments because of their relatively simple construction based on the factors described.
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In contrast, the publically derived Alternative 3 includes over twice the amount of temporary road construction, with about five segments (3.6 miles) that would require engineering design (see Table 2-5) due to their complexity of location on steeper slopes, length, stream crossings requiring engineering control, and/or complicated topographic features. Full bench construction would be required for approximately 0.4 miles in Alternative 3 due to steep side slopes (greater than 65 percent). Full bench construction involves excavating and removing existing soil material from the constructed road prism without embankment (fill) construction. On these full bench segments, full recontouring would not occur during decommissioning because there would be no road fill to pull back onto the road prism. The cost of temporary road construction in Alternative 3 is estimated to be significantly more (over 8 times) than that estimated for Alternative 2.
In addition, temporary roads in Alternative 3 located on steeper slopes would result in more soil disturbance because a wider area would need to be excavated. Steeper side slopes and more soil disturbance would increase the potential for soil erosion and sediment delivery to streams, particularly in the post-fire environment.
Table 2-5: Cost and Length of Temporary Roads by Alternative Alternative 2 Alternative 3 Cost Cost Miles Road Number Miles (includes construction (includes construction (full bench) and decommissioning) and decommissioning) 894ext 0.18 $1,800 0.18 $1,800 875ext 0.13 $1,300 0.13 $1,300 7575ext 0.42 $4200 0.42 $4,200 48117ext* - - 0.23 (0.10) $25,235 48073ext* 0.28 $2,800 0.45 $22,025 45008-Eext - - 0.26 $2,600 45008-Cext - - 0.20 $2,000 45005-Aext2 0.58 $5,800 0.58 $5,800 45005-Aext 0.36 $3,600 0.36 $3,600 18832ext 0.33 $5,300 0.33 $5,300 18828ext 0.39 $3,900 0.39 $3,900 18809ext* - - 0.69 (0.23) $58,005 18808ext 0.17 $1,700 0.72 $7,200 18780ext* - - 1.61 (0.10) $73,645 17003ext* - - 0.61 $38,145 16044ext 0.13 $1,300 0.13 $1,300 TOTAL 3 $31,700 7.3 (0.43) $256,055 *Roads would require Forest Service engineering design. Factors that necessitate engineering design include location on slopes greater than 30 percent, stream crossings requiring engineering control, and road length more than ½ mile.
Wood Deterioration Wood deterioration affects the quality of the wood products recovered from dead and dying trees. While many factors affect the rate of timber deterioration, tree species is the most important factor and bark thickness is the most important species characteristic (Lowell et al. 2010). The wood of thick-barked species generally dries slower and less extensively in the first year than thin-barked species, resulting in less checking, cracking and breakage. The majority of tree species that were killed in the high to very high severity burn areas of the Copper King Fire were these thicker barked trees.
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As part of the initial project design, identification of salvage opportunities focused on thicker barked species to recover as much economic value as possible while minimizing potential environmental effects. While some areas of thin barked trees are proposed for salvage, the majority of the salvage in both alternatives (~60 percent) is focused on the thicker barked species such as western larch, ponderosa pine and Douglas-fir (Table 2-4).
Table 2-6: Predicted Volume Defect by Species Tree Species Percent Additional References and Assumptions Volume Defect Year 1 Year 2 “About two-thirds of western larch develops cracks in the first year after tree death, although only a small percentage of the volume is affected at this point” (Lowell et al. 2010). It is Western larch 5% 40% assumed that same amount of volume defect would occur in the upper boles, where bark is thinner. Also, it assumed that there would be some checking in the smaller-diameter western larch. It is assumed that all of the checking-related volume loss described in Lowell et al. would occur during the warm/dry Ponderosa pine 16% 33% summer months. In addition to cracking, Lowell et al. reports blue stain impacting 25 to 50 percent of the volume the first year. “Cracks develop in about one-third of trees but are shallow, not affecting much volume” (Lowell et al. 2010). It is assumed that Douglas-fir 5% 20% same amount of volume defect would occur in the upper boles, where bark is thinner. Also, it assumed that there would be some checking in the smaller diameter Douglas-fir. It is assumed that all of the checking related volume loss Grand fir 14% 33% described in Lowell et al. (2010) would occur during the warm/dry summer months. “Cracks are common, likely to affect at least half the trees,” but the volume loss is minimal (Lowell et al. 2010). It is assumed that same amount of volume defect would occur in the upper boles, Lodgepole pine 5% 10% where bark is thinner. Also, it assumed that there would be some checking in the smaller diameter lodgepole pine. In addition to cracking, Lowell et al. reports blue stain impacting one-third to two-thirds of the volume the first year. Cedar shows little deterioration even after 5 years (Minore 1983). Some checking is anticipated on the upper portions of the boles, Western redcedar 5% 10% especially on the warmer aspects/slopes, and would increase as time continue. Mountain These estimates are based on information in Lowell et al. (1992) 15% 33% hemlock and the thin-barked characteristic of this species. It is assumed that all of the checking related volume loss Subalpine fir 40% 60% described in Lowell et al. (2010) would occur during the warm/dry summer months.
Predicted volume defect shown in Table 2-6 is a function of deterioration that occurs (e.g. weather checks, decay, breakage) to decrease the amount of wood product that can be manufactured from a tree. In addition to volume loss, timber can lose value due to the types of products or grade of products that can be manufactured from a log or tree. For example, the blue staining that commonly occurs to the pine species (e.g., lodgepole pine and ponderosa pine) soon after they die causes a significant reduction in value, but not necessarily a reduction in volume (Lowell et al. 2010).
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2.4 Conflicting Views over Post-fire Salvage Public debate over post-fire salvage has been ongoing for many years. Opponents argue that salvage should not be conducted because it causes damage to burned sites and removes dead trees that have important ecological value. The premise of some arguments is that there are no ecological benefits to post-fire salvage (Hutto 2006, Noss et al. 2006). Supporters argue that it is important to recover economic value to support community resiliency. Comments on both sides of the debate have been received on the Copper King project. Opponents of the project cited numerous publications in support of their views. These publications are discussed in detail in Appendix D. The concepts from the literature are generally addressed below.
To begin with, even the term “salvage” is controversial (DellaSalla and Hanson 2015, Lindenmayer and Noss 2006). Objectors to the term find it misleading and inappropriate. They cite to the dictionary definition of “salvage”, which means to recover or save from loss or destruction. They argue that fire is ecologically beneficial and that burned forests have not been destroyed and are not in need of saving. Instead, they suggest using the term, “post-disturbance logging”. For the Copper King project, the term “salvage” simply means the harvest of dead, dying, or deteriorating trees (Forest Service Handbook 2409.26).
Several publications dispute the justification given for other post-fire salvage projects - that is: salvage is needed for forest restoration and/or to reduce fuels for future fires (e.g. Beschta et al. 1995, Karr et al. 2004, DellaSalla et al. 2006, DellaSalla and Hanson 2015). These arguments are not applicable to the Copper King project because the purposes of salvage in this project are to recover some of the economic value to support communities in an economically depressed area and to address roadside hazards (see Chapter 1, section 1.3).
Most of the provided literature discusses general negative ecological consequences that can result from salvage operations, primarily with respect to soils, hydrology, and wildlife habitat. However, several of these publications actually indicate that the effects vary depending on a wide range of factors such biophysical setting of the forest, pattern of burn severity, weather, operational aspects of tree removal, and other management activities (e.g. Peterson et al. 2009, Lindenmayer and Noss 2006, McIver and Starr 2001). Particularly noteworthy is that the bulk of the published literature about the ecological effects of post-fire salvage considers large-scale salvage operations that remove most, if not all, living and dead vegetation across extensive areas. Currently, research is lacking to adequately quantify the spatial scale effects of fire and post-fire salvage operations; and to comprehensively address the range of effects that are produced by all combinations of fire and salvage intensity (Peterson et al. 2009). There is limited research and monitoring data concerning smaller scale salvage projects (like Copper King) that are designed to minimize undesirable ecological effects.
The Copper King project is a relatively small scale project. It would conduct salvage on, at most, 2300 acres or 12 percent of the National Forest System land affected by the fire. Project design, best management practices, and site-specific resource protection measures have been incorporated into the project to minimize the potential for adverse environmental effects (see sections 1.4.1 and 2.1.1). Table 2-7 displays a summary from three publications that provide ecological recommendations for post-fire management and how these recommendations were considered in the design of the Copper King Fire Salvage project.
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Table 2-7: Summary of Ecological Recommendations Provided in the Scientific Literature for Consideration in Post-fire Management Karr et Beschta Lindenmayer How addressed in the Copper King Fire Salvage Project Recommendations al. 2004 et al. 2004 and Noss (2006) Promote natural recovery Under Alternatives 2 and 3, 17,700 acres (92%) and 16,950 acres (88%), respectively, of the National Forest System (NFS) land within the fire perimeter would not be salvaged and would be left to natural recovery processes. Retention of old, large trees and snags Alternatives 2 and 3 would retain all old, large trees and snags on approximately 17,700 acres (92%) and 16,950 acres (88%), respectively, of the NFS land affected by the Copper King Fire. Protect soils against compaction and erosion Resource protection measures would be applied to protect soils (see section 2.1.1). Areas where Regional soil quality standards could not be met were dropped from consideration for salvage. Protect ecologically sensitive areas (e.g. No salvage activities would occur within the Teepee-Spring Creek reserves, roadless areas, steep slopes, fragile Inventoried Roadless Area or on fragile soils. There are no soils) designated reserves within the project area. Within identified salvage units located on slopes greater than 35 percent, fire-killed trees would be removed via a skyline yarding system. Erosion control measures would be applied to skyline corridors as necessary. Rehabilitation of roads and fire lines, avoid Fire lines were rehabilitated during fall 2016 (see Chapter 3, section creation of new roads 3.1). Project-associated road maintenance and resource protection measures, in concert with ongoing BAER work, would minimize soil erosion and sediment delivery from roads. BAER work also addresses undersized culverts. New permanent roads would not be constructed. Only temporary roads would be constructed for the project and would be decommissioned through slope recontouring following completion of salvage operations. Limit reseeding and replanting Tree planting with native species would occur on approximately 6000 acres (32% of the fire area on NFS lands). Seed sources for natural tree regeneration within the fire perimeter are lacking in some areas due to the extent and severity of the fire. There is also a need to plant trees in some areas to meet legal requirements under the National Forest Management Act (see Chapter 1, section 1.3). Avoid new in-stream structures (e.g. sediment Not applicable traps, check dams) Protect and restore watershed before fire Not applicable Continue research, monitoring, and To contribute to the body of knowledge about effects of post-fire
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Karr et Beschta Lindenmayer How addressed in the Copper King Fire Salvage Project Recommendations al. 2004 et al. 2004 and Noss (2006) assessment of the effects of salvage treatments salvage on soils, monitoring would be required in Units 1, 19, 25, and 49. These units would be part of an adaptive management study to assess soil disturbance in relation to burn severity and season of harvest (see section 2.1.2 and Chapter 3, section 3.3). Educate the public on the natural role of Not applicable to the Copper King project. wildfires, allow natural regimes Ban introduction of exotic species Tree planting and any erosion control seeding would be accomplished with native species (see Resource Protection Measures in section 2.1.1). Curtail livestock grazing Seasonal livestock grazing historically permitted mostly on private and State lands and only 2 sections (1280 acres) on National Forest System land within the fire perimeter would be halted in 2017. Grazing in subsequent years would depend on recovery of the burned area. Low-intensity removal or no harvesting in Most of the proposed salvage would occur within areas where the unburned or partially burned patches fire killed all or the majority of the trees. On only about 100 acres (about 0.5 percent of the NFS land affected by the Copper King Fire), green trees would be thinned to improve the resiliency of live survivor, large diameter ponderosa pine to bark beetles. Limit removal of biological legacies from Under Alternatives 2 and 3, 17,700 acres (92%) and 16,950 acres particular areas (e.g. burned old growth (88%), respectively, of the NFS land within the fire perimeter stands) would not be salvaged and would be left to natural processes. Alternatives 2 and 3 include salvage of approximately 271 acres (18 percent) of 1506 acres of pre-fire old growth stands. These stands are now dead and no longer qualify as old growth. The remaining 1235 acres (82%) of pre-fire old growth would remain intact and unaffected by the project (see Chapter 3, section 3.2.2). Ensure maintenance and creation of essential Under Alternatives 2 and 3, 17,700 acres (92%) and 16,950 acres habitat elements for species of concern (88%), respectively, of the NFS land within the fire perimeter would not be salvaged and would be left to natural processes. Habitat for species associated with post-fire environments, snags, and coarse downed woody material would remain abundant (see Chapter 3, section 3.6). Sensitive plant populations would be protected (see Resource Protection Measures in section 2.1.1). The planting of ponderosa pine, western larch, western white pine, and whitebark pine would perpetuate these native species that are of regional concern.
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Karr et Beschta Lindenmayer How addressed in the Copper King Fire Salvage Project Recommendations al. 2004 et al. 2004 and Noss (2006) Protect aquatic ecosystems with adequate No salvage would occur within Riparian Habitat Conservation riparian buffers Areas (RHCAs) except for the removal of hazard trees along the Road #9991 [ACM road]. Standard RHCA widths would be expanded by 50 feet along all waterways (except the Thompson River) to provide further protections to riparian areas. (See Resource Protection Measures in section 2.1.1). Best management practices, erosion control measures, and additional resource protection measures would minimize sediment delivery potential to streams. Road storm-proofing and culvert replacements/removals under BAER would also enhance protection for aquatic systems. Table adapted from Reilly et al. 2015
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Context of Salvage Operations Pertinent to the evaluation of resource effects for the Copper King project, it is important to understand the context of the proposed salvage activities, in terms of scale and setting.
Scale As stated above, the Copper King project is a relatively small scale project, which would conduct salvage on, at most, 2300 acres or 12 percent of the National Forest System land affected by the fire. To put the proposed salvage in an even broader context, Table 2-8 summarizes the acres of wildfire and post-fire salvage at the Region, Forest, and District scale that have occurred over the last decade (2007-2016). The acres of wildfire far surpasses the acres of post-fire salvage. For example, less than two percent of the acres of wildfire that burned on the Lolo National Forest within the last decade was salvaged. This information clearly shows that burned areas and post- fire habitats are abundant and would remain abundant on the Plains/Thompson Falls Ranger District, Lolo National Forest, and in Region 1 even after implementation of the Copper King project.
Of the 61,234 wildfire acres that burned on National Forest System lands within Region 1 in 2016, at most approximately 2,362 acres or 4 percent (Copper King (2312 acres in Alternative 3) and Roaring Lion on the Bitterroot National Forest (45 acres)) would be salvaged.
Table 2-8: Summary of Wildfire and Post-fire Salvage at the Region, Forest, District, and Project scale over the last decade (2007-2016)1 Unit Total National Wildfire on NFS land Post-fire Salvage on NFS land Forest System 2007-2016 2007-2016 land (NFS) Acres and percent of NFS Acres and percent of wildfire acres land2 burned on NFS land Forest Service 25,000,000 2,147,230 (9%) 24,461 (1.1%) Region 1 Lolo National Forest 2,400,000 193,949 (8%) 2720 (2007 Jocko and Chippy fires) (1.4%) Plains/Thompson 490,000 68,680* (14%) 1035 (2007 Chippy Fire) Falls Ranger District Chippy Fire: 47,280 acres 2% of Chippy Fire Copper King Fire ------19,300 Alt 2: 1502 (8%) (2016) Alt 3: 2312 (12%) Data Sources: FACTs data; fire history GIS layers; National Interagency Fire Center (NIFC) *Acres include the 19,300 acres of the 2016 Copper King Fire 1Acres are approximate. 2Includes all NFS lands (e.g. managed, roadless, Wilderness, and special designated areas)
Across the Copper King fire area, a full range of tree species, size classes, and burn severities would be retained on National Forest System land, which would provide for a variety of post-fire habitat conditions (see Tables 2-9 through 2-11). Although salvage is focused in areas of very high vegetation mortality, over 75 percent of the very high burn severity areas would be retained (see Table 2-11). While salvage of merchantable-sized dead trees (larger than 8 inches in diameter) would be conducted, the majority of dead trees of the larger size classes would be retained on the landscape (see Table 2-9).
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Table 2-9: Acres of Salvage in each Tree Size Classification by Alternative Tree National Forest Alternative 2 Alternative 3 Diameter Size System land Acres (percent of tree size Acres (percent of tree size Class (acres) class) class) 5-9.9 inches 4045 248 (6%) 309 (8%) 10-14.9 inches 10,980 947 (9%) 1533 (14%) 15-19.9 inches 3082 305 (10%) 468 (15%) > 20 inches 58 2 (3%) 2 (3%) Data source: R1Vmap
Table 2-10: Acres of Salvage in each Tree Species Classification by Alternative Dominant Tree National Forest System Alternative 2 Alternative 3 Species1 land Acres (percent of Acres (percent of (acres) dominant tree species) dominant tree species) ponderosa pine 1541 45 (3%) 45 (3%) western larch 2119 296 (14%) 625 (29%) Douglas-fir 5201 603 (12%) 708 (14%) lodgepole pine 2504 96 (4%) 195 (8%) mix of shade intolerant 5587 401 (7%) 659 (12%) species2 subalpine fir 1156 10 (1%) 11 (1%)
western redcedar 116 2 (2%) 3 (2%) mix of shade tolerant 771 19 (2%) 31 (4%) species3 Data source: R1Vmap 1A dominant species makes up 60 percent or more of the mapping feature. 2Not one species is dominant but the majority of the species are shade intolerant 3Not one species is dominant but the majority of species are shade tolerant.
Table 2-11: Acres of Salvage in each Burn Severity Classification by Alternative Burn Severity1 National Forest Alternative 2 Alternative 3 System land Acres (percent of burn Acres (percent of burn (acres) severity class) severity class) Low 2890 106 (4%) 130 (4%) Moderate 4623 179 (4%) 254 (5%) High 4238 177 (4%) 268 (6%) Very High 7447 104 (14%) 1659 (22%) Data source: Rapid Assessment of Vegetative Condition after Wildfire (RAVG) satellite mapping (RAVG) 1Based on vegetation basal area loss
Setting In addition to understanding the scale of post-fire management actions, it is important to consider the setting where the actions would take place. For example, in their review of post-fire logging case studies, DellaSalla and others (2015) suggest that although salvage activities on the 2002 Biscuit Fire in western Oregon were proposed on a relatively small percentage of the fire, the salvage was in an area of high ecological importance (previously nominated for national monument status by conservation groups for its biological significance).
The Copper King project area has not been identified as ecologically significant by the Forest Service (Lolo Forest Plan) or by the public during the scoping period or at any other time. As described in Chapter 1 section 1.2, the Copper King salvage units are generally located within an area of intermingled ownership, which is primarily managed for timber production and contains a
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well-established transportation system. Although the area is located within the Cabinet-Yaak Grizzly Bear Recovery Zone, the Copper King fire and proposed salvage is within the farthest southeast corner that is not considered occupied habitat and has the lowest biological rating based, in part, on the lack of grizzly bear sightings. The Copper King project area overlaps a portion of the Teepee-Spring Creek Inventoried Roadless Area, but no salvage activities are proposed there. The Thompson River, which forms the western boundary of the project area, is designated bull trout critical habitat. The potential for the Copper King project to affect this critical habitat is primarily from log hauling on an existing high-traffic road (Road #9991 [ACM road]). Appropriate resource protection measures would be applied on the road prior to haul operations to minimize the potential for sediment delivery to the Thompson River (see section 2.1.1).
Summary The social value of economic benefits versus potential changes in resource conditions has been debated in scientific and policy forums for several decades (Peterson et al. 2009). National Forest System lands are managed for multiple uses and all of these values (social, ecological, and economic) must be considered. The challenge for post-fire management is to determine based on established management objectives, where and when post-fire salvage is appropriate and how to avoid, minimize, or mitigate the potential for undesirable ecological effects associated with proposed post-fire salvage activities.
The Copper King project has been developed as a smaller scale salvage project in an area where the Lolo Forest Plan allows such activities. The project is designed to minimize undesirable ecological effects while realizing social and economic benefits.
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CHAPTER 3: ENVIRONMENTAL EFFECTS This section provides a summary of the environmental effects of the three alternatives (the No Action alternative and two action alternatives). It provides the necessary information to determine whether or not to prepare an environmental impact statement. Further analysis and conclusions about the potential effects are available in the reports for each resource and other supporting documentation cited in those reports. These documents are contained within the project file, which is available at the Plains/Thompson Falls Ranger District office in Plains, Montana. 3.1 Past, Present, and Reasonably Foreseeable Future Actions Consistent with 36 CFR 220.4(f) and Council on Environmental Quality (CEQ) guidance, the past, present, and reasonably foreseeable future actions were considered for analysis of cumulative effects where appropriate for each resource. Past actions considered in the cumulative effects analysis include those that contributed to establishing the baseline conditions of the project area today.
Past Actions
Copper King Fire Suppression Actions and Post-fire Rehabilitation Fire suppression actions included constructing a combination of bulldozer and hand line, as well as using existing roads as fire line. A total of approximately 24 miles of dozer line and 8 miles of hand line were constructed across the multiple land ownerships affected by the fire. In addition, approximately 49 miles of road were used as fire line. In early fall 2016, constructed fire lines (dozer and hand) were rehabilitated by scarifying the soil, scattering brush and timber over disturbed soil, and seeding. Waterbars were installed as needed to provide appropriate drainage and minimize erosion potential.
Timber Harvest Past management actions on National Forest System lands within the project area include timber harvest and related activities. According to Forest Service records, timber harvest has occurred on approximately 3402 acres (17 percent) of the National Forest System land within the project area since the 1940s. Past harvest has ranged from individual tree removals to clearcuts. Regeneration-type harvests account for about 56 percent of the National Forest System land harvested within the project. The remaining 44 percent of the harvest area received intermediate treatments. Prior to the Copper King Fire, all of the regeneration harvested areas were certified as stocked. In many areas, these young forests were densely populated with 25-30 foot tall trees.
Table 3.1-1: Summary of Past Harvest on National Forest System Land by Decade Type of 1940s 1950s 1960s 1970s 1980s 1990s 2000s 2010s TOTAL* Harvest (acres) (acres) (acres) (acres) (acres) (acres) (acres) (acres) (acres) Regeneration 18 0 713 341 260 578 0 0 1910 Intermediate 0 5 218 1172 31 66 0 0 1492 TOTAL 18 5 931 1513 291 644 0 0 3402 *Total figures are likely inflated due to multiple timber harvest entries occurring on the same piece of ground in some areas.
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The most recent timber harvest activity on National Forest System land within the project area is described below:
Sleepy Buckeye (harvest completed in 1995) (located within the Teepee-Spring Creek Inventoried Roadless Area): Mostly regeneration harvest on approximately 644 acres. Associated road construction included the extension of Road 875 (~12 miles) into the IRA in 1989 under the Buckeye Pre-Road Capital Investment Project. Subsequently, the Sleepy Buckeye timber sale constructed approximately 13 miles of road within the IRA (Roads 18828, 18829, 18830, 18832 and the last 2.3 miles of Road 875).
Sleeping Beetle (harvest completed in 1993) (located within the Teepee-Spring Creek IRA): Primarily commercial thinning of lodgepole pine on approximately 81 acres to improve resilience to mountain pine beetle.
Donkey Kong Post & Pole (harvest completed in 1993) (located in NW ¼ Section 20 in Big Hole Creek drainage). 14 acres of post and pole removal – recorded as a regeneration harvest.
Spring Junction (harvest completed in 1991) (located east of Big Hole Peak in the Weeksville drainage): Regeneration harvest on approximately 30 acres.
Todd Creek OSR (harvest completed in 1991) (located in Section 24 in Todd Creek) Removal of seed trees from a previously regenerated unit – approximately 13 acres.
Approximately 9,642 acres within the project area is not National Forest System land. These other lands are primarily owned by the State and Weyerhaeuser. Past timber harvest has occurred on most of this other land within the project area.
Road Development Within the project area there are approximately 119 miles of system roads under Forest Service jurisdiction with about 47 percent of the road miles open year-round to public travel and 4 percent open seasonally. Due to the intermingled land ownership in the northern portion of the Copper King Fire, the State and Weyerhaeuser have easements and cost share agreements on 57 percent of the National Forest system roads to access their lands.
There is an estimated 115 miles of existing road that is not under Forest Service jurisdiction within the project area. These include Weyerhaeuser roads (~101 miles); State roads (~8 miles); and county road (~6 miles).
Mining Limited mining activities occurred within the project area from the late 1880s to the mid-1950s. Most mining activities were associated with the Silver King mine located near the Thompson River. A few adits, tailing piles, and historic buildings remain. Most environmental effects from past mining have likely dissipated.
Livestock Grazing The Thompson River grazing permit is administered by the State for use of State, Weyerhaeuser, and National Forest System lands within the Thompson River and Little Thompson River area. Use of NFS land only occurs on two sections (~1280 acres in Calico Creek). The vast majority of the grazing permit is on State and Weyerhaeuser lands, some of which is located in the Copper King fire perimeter.
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Ongoing and Reasonably Foreseeable Future Actions Ongoing and reasonably foreseeable future actions within the project area include:
Burned Area Emergency Response (BAER) Work After containment of the Copper King Fire, an evaluation of values at risk, considering imminent threats to human life and property, was conducted. This evaluation determined that the following Burned Area Emergency Response actions were needed to address immediate threats to public safety, values at risk, and resource damage:
Weed spraying (authorized under the 2007 Lolo National Forest Integrated Weed Management Record of Decision) and monitoring primarily along roadsides (95 miles or 450 acres) Road surface storm-proofing and drainage maintenance (40 miles) Culvert and road fill removal on draw and stream crossings (12 locations) Culvert replacement (upsizing) on minor draws (8 locations) Culvert replacement (upsizing) on major draws (6 locations) Culvert replacement (upsizing) on stream crossings (6 locations) Trail storm-proofing and drainage maintenance (7 miles) Trail hazard tree removal (8 miles) Heritage site protection (1 location)
The following BAER work was completed in fall 2016 before heavy rain and snow caused operations to cease. The remainder of the BAER treatments will be completed during the summer of 2017.
Work Completed in Fall 2016 Seven culverts were removed to decrease the risk of culvert plugging, overtopping, breaching, and channel scour. These culverts included two in the Buckeye Creek drainage on the Silver King Mine road; two in the Big Hole drainage on Road 18393; and three in the Calico drainage on road 7572.
Additional road fill was excavated where 6 culverts were previously removed in the Big Hole drainage. These included three on Road 18812 and three on Road 18813.
Additional armoring was completed on major culverts on Road #9991 [ACM Road] at the crossing on Bay State Creek and Big Hole Creek.
Storm-proofing and drainage maintenance were conducted on segments of Roads 18809 and 894 in the Big Hole drainage as well as a portion of Road 7572 in the Calico drainage. Work included cleaning of culvert inlets and outlets, drain dip shaping, ditch cleaning, and ditch reconstruction.
Salvage Activities on Other Ownerships Salvage of trees burned by the Copper King Fire is ongoing and/or completed on State (Department of Natural Resources and Conservation (DNRC)) and Weyerhaeuser lands (see Table 3.1-2 and Salvage by Ownership map in Appendix A).
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Table 3.1-2: Salvage Activities on All Ownerships Ownership Acres of Ownership Salvage within Fire Perimeter Acres (% of ownership) Forest Service 19,300 Alt 2: 1502 (8%); Alt 3: 2312 (12%) Weyerhaeuser 8,200 1883 (23%) State (DNRC) 1,400 1,096 (78%) TOTAL 28,900 With Alt 2: 4,481 (16%); With Alt 3: 5,291 (18%)
Montana DNRC Salvage The State will conduct salvage on approximately 1096 acres using both cable and tractor logging methods. Approximately 3 miles of new road construction is planned. The salvage will be contained within 3 separate sales, totaling approximately 5 million board feet. Logging is expected to begin in July 2017.
Weyerhaeuser Salvage Salvage operations on Weyerhaeuser land include approximately 1883 acres, most of which was completed during the fall and winter of 2016/2017. Some additional salvage work could occur during the summer of 2017.
Livestock Grazing Livestock grazing under the Thompson River grazing permit will be halted within the Copper King Fire perimeter during the 2017 season. Approval of grazing in subsequent years will depend on vegetative recovery in the post-fire area.
Firewood Gathering Firewood gathering has occurred and will continue to occur in the future. Due to the amount of dead wood created by the Copper King Fire, firewood collection along open roads is expected to increase over the next several years. Firewood collection occurs within 200 feet of roads and is prohibited in riparian areas.
Mushroom Picking During the late spring and summer of 2017, mushroom picking will occur. No roads will be opened for this activity. 3.2 Vegetation
3.2.1 Resilient Vegetative Conditions
Issue Raised in Public Comment Salvage operations could damage and slow the re-establishment of trees.
Tree species within the project area have adapted to natural disturbances like wildfire. In fact, many conifer trees depend on fire as a disturbance mechanism to survive (Habeck and Mutch 1973). Each tree species has its various characteristics influencing their relative resistance to being killed or injured by fire (for example, bark thickness, root depth, branch configuration, flammability of foliage, and bark resin).
The three species that have the highest degree of resistance to fire (western larch, Douglas-fir, and ponderosa pine) comprised approximately 46 percent of the cover type of the forest stands in the
40 Copper King Fire Salvage Environmental Assessment project area. Another approximately 29 percent of the cover type was comprised of various mixes of shade intolerant species that have various degrees of resistance to fire. The four species that are rated as having a medium degree of resistance (grand fir, western white pine, western redcedar, lodgepole pine and whitebark pine) comprise approximately 19 percent of the cover type, and the species that are rated as low or very low (Engelmann spruce, western hemlock, and subalpine fir) make up approximately 6 percent of the cover type.
The Copper King fire had a very dramatic effect on vegetation in terms of the change to the composition and structure of the forest on a stand and landscape level within the project boundary. In areas of low to moderate vegetation burn severity very little change to composition and structure took place. In these areas, tree composition in the small openings created by the fire may change depending upon the species that are first to regenerate in these areas. If forest openings are too small, shade intolerant species will not regenerate because of the lack of sunlight. The structure may change slightly in areas where the smaller diameter trees were killed by the fire.
The high to very high burn severity areas (that make up 61 percent of National Forest System land affected by the fire) will likely have the most dramatic changes to the composition and structure. Approximately 11,700 acres of National Forest System land that were in various size classes prior to the fire will revert to the seedling stage (see Table 3.2-1 and Figure 3.2-1). In areas where there is adequate seed trees that survived the fire or had a substantial number of lodgepole pine bearing serotinous cones11, regeneration will begin as soon as the first year after the fire. The species composition of these areas will depend on the surviving tree species composition and the success of the regeneration from those trees. In areas of pre-fire existing lodgepole pine or standing dead lodgepole pine, lodgepole pine regeneration is expected to be prolific. The forest structure of large areas in this burn severity will likely have a homogenous size and age class, and depending on regeneration may have a homogenous cover type for years to come. In the areas where no trees survived to produce seed, very little, if any, regeneration will likely take place. Grass and shrubs will most likely be dominant on the landscape.
Table 3.2-1: Burn Severity on National Forest System Land within the Copper King Fire Area and Harvest by Alternative (based on vegetation basal area loss) Burn Severity National Forest System land Alternative 2 Alternative 3 (basal area loss) Acres (percent) Acres (percent) Acres (percent) Low (0%) 2890 (15%) 106 (7%) 130 (6%) Moderate (0-24%) 4623 (24%) 179 (12%) 254 (11%) High (25-74%) 4238 (22%) 177 (12%) 268 (12%) Very High (74-100%) 7447 (39%) 1039 (69%) 1659 (72%) Data source: Rapid Assessment of Vegetative Condition after Wildfire (RAVG) satellite mapping
11 Serotinous cones are covered with a resin that must be melted for the cone to open and release seeds. When a fire moves through the forest, the cones open and the seeds are distributed by wind and gravity.
41 Copper King Fire Salvage Environmental Assessment
Figure 3.2-1: Basal area loss within the Copper King Fire perimeter (RAVG product)
Alternative 1: Direct, Indirect, and Cumulative Effects Approximately 61 percent of the National Forest System land affected by the fire burned at high or very high severity levels where most of the trees in the forest stands are dead or dying. Alternative 1 does not include any tree planting and would rely entirely on natural regeneration to eventually reforest the burned area. In the areas of high to very high burn severity, it would likely take decades to regenerate with conifer trees because there is a lack of surviving seed trees of any species. In addition, there would likely be strong vegetative competition from grasses and shrubs. In these areas, it is unlikely that seral species like ponderosa pine and western larch would return to this landscape within 20 years.
Seral species such as ponderosa pine and western larch are more resistant to future stressors such as insect and disease, fire impacts, and drought. By not planting the desirable seral tree species on any of the burned areas, Alternative 1 would indirectly have long-term negative impacts on future tree composition and in turn, on the resistance and resiliency of forest vegetation to disturbances and stressors (e.g., future fires, insect and diseases, and drought and other climate change impacts).
In the areas of low to moderate burn severity, many of the overstory trees survived to serve as a reliable seed source to naturally restock these sites. While there may be a reliable seed source, some of these openings may not be large enough for shade intolerant species to regenerate. In this case, shade tolerant species would likely regenerate.
This alternative would not likely meet the project purpose to re-establish forested conditions to trend the area toward desired resilient vegetative conditions.
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In Alternative 1, there would also be no silvicultural treatments to improve the resistance of large survivor trees to insects. These stands would remain at a high density, stressed from the fire, and susceptible to bark beetle attacks particularly within the first two years following the fire (Ryan et al. 2012; Lerch et al. 2016).
Forest Plan and Regulatory Consistency Alternative 1 would not meet one of the primary Forest Plan goals for the project area to provide for healthy stands of timber and optimize timber growing potential. In high to very high burn severity areas, it could be many years before natural regeneration takes place because of the lack of surviving trees to serve as seed sources. Meanwhile, these areas would be dominated by grasses and shrubs.
Alternative 1 would not likely fulfill the agency’s legal obligations under the National Forest Management Act, which requires that all forested land in the National Forest System be maintained in appropriate forest cover with species of trees, degree of stocking, rate of growth and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management in accordance with land management plans (i.e. Forest Plans).
Alternatives 2 and 3: Direct and Indirect Effects The salvage operations in Alternatives 2 and 3 would remove dead and dying trees mostly in areas of high to very high burn severity (see Table 3.2-1) and would retain survivor trees. This activity would not change the vegetation composition of the project area.
Alternatives 2 and 3 also include approximately 102 acres of thinning of live trees in low severity burn areas. These treatments would retain the larger trees and remove ladder fuels and reduce the canopy density from around them. The treatments would favor the ponderosa pine and western larch overstory, and remove some of the mid-story and understory Douglas-fir and grand fir trees. This treatment would enhance the resistance and resilience of the retained trees by removing ladder fuels, reducing competition for water and nutrient resources, and changing the microclimates around these trees. This activity would help shift the species composition of these areas from Douglas-fir to ponderosa pine and larch, but would have little effect at the landscape level.
Both Alternatives 2 and 3 would plant 6,000 acres, including about 32 percent of the high to very high severity burn areas. Desired seral species (also, regional species of concern) such as ponderosa pine, western larch, western white pine and whitebark pine would be planted in areas of low to no surviving seed trees, including salvage units. This activity would lead to a greater number of early seral shade intolerant trees in areas that would likely otherwise be grass and shrub-dominated or in areas where the overwhelming tree species to naturally regenerate would be lodgepole pine, Douglas-fir, or shade tolerant species. Alternatives 2 and 3 would meet the project purpose to re-establish forested conditions to trend the area toward desired resilient vegetative conditions.
Some studies indicate that post-fire salvage operations can reduce tree regeneration (Donato et al. 2006; Lindenmayer and Noss 2006). However, other studies have concluded that over the long- term there were no significant differences in vegetation establishment (richness and cover) between areas that were salvaged and areas that were not (Peterson and Dodson 2016; Knapp and Ritchie 2016). Some of the discrepancies between the two findings may be attributed to the amount of soil disturbance caused by the salvage operations, methods used for post-harvest site preparation (e.g. application of herbicide to reduce competition from shrubs, prescribed burning);
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and time lag between the fire and salvage activities. For the Copper King project, soil disturbance would be minimized through the use of timber harvest best management practices, use of skyline yarding systems, and winter logging on about 40 percent of the tractor units (see Soil section 3.3). No site preparation is planned in salvage areas after harvest operations. Salvage operations would occur within the first two years following the fire before the natural vegetation is well-established.
Field observations conducted after similar salvage activities in the 2007 Chippy Fire, located about 10 miles to the northwest of Copper King, indicated that there was no discernible difference in the amount and species of tree regeneration in salvage units vs. unsalvaged areas (District Silviculturist Mike Mueller (2017), pers. comm.).
Regardless, tree planting would be conducted within salvaged areas to trend species composition toward resilient conditions.
Cumulative Effects The influence that past harvest had on the existing tree composition and structure of stands within the project area is reflected in the existing condition. The Copper King Fire has greatly influenced the existing and future forest composition and structure in the project area. Planting desired shade intolerant native species in areas with little or no seed source would benefit the tree composition on up to 6,000 acres (31 percent) of National Forest System lands.
It is unknown if salvage operations on Weyerhaeuser land and State land would include the removal of live survivor trees. If so, this could influence the forest composition and structure on affected areas. If live tree removal occurs along ownership boundaries, it could reduce a source of wind-blown seed onto National Forest System land to a small degree. Regardless, planting would occur where identified as needed on National Forest System land.
Forest Plan Consistency This activity would trend forest composition toward the desired conditions and objectives outlined in the Forest Plan.
3.2.2 Old Growth
Issue Raised in Public Comment Salvage operations could reduce attributes of old growth forests.
The Lolo Forest Plan defines old growth as “individual trees or stands of trees that in general are past their maximum rate in terms of the physiological processes expressed as height, diameter and volume growth” (pages VII-24 to VII-25). The Lolo National Forest Plan Final Environmental Impact Statement (page II-61) (1986) states, “As a strategy for meeting old growth needs, the Forest was segregated into 71 drainages. A minimum of eight percent old growth was allocated to most of these drainages where wilderness was not available.” The eight percent was based on an interpretation of literature available at the time which considered the minimum habitat needed for various old growth associated wildlife species.
In 1994, the Lolo National Forest recognized a need to adjust the strategy for managing old growth (In-service memo 2070, Daniels 4/29/94). The resultant memo adopted the Region 1 old growth definitions (see below) and provided direction for consistent implementation of an old
44 Copper King Fire Salvage Environmental Assessment growth strategy within the Lolo Forest Plan. The strategy states that in order to conserve biological diversity, including old growth associated species, the Forest will:
Retain 8 percent of the Forest land in old growth reserves
Manage landscapes using ecological principles
Prescribe treatments that consider the range of natural variation, age class distribution and natural processes
The Northern Region (Region 1) of the Forest Service has defined old growth in Green et al. (1992, errata corrected 2011). Old growth definitions are stratified by habitat type groups that reflect similarity of disturbance response, potential productivity, stocking density, down wood accumulation, fire frequency, and tree species. The adopted old growth definitions are specific to forest type (the dominant tree species) and habitat type group, and are defined by a minimum number of live trees greater than a specific size and age, in stands with a minimum density. For example, the most common old growth types on the Lolo National Forest require at least 8-10 live trees per acre that are 170-180 years in age and 21 inches in diameter, and have a minimum stand density of 60-80 feet2 of basal area.
Green et al. identify the following attributes that distinguish old growth from young growth:
Large live trees for species and site
Wide variation in live tree sizes and spacing
Accumulations of large-size dead standing and fallen trees that are high relative to earlier stages
Decadence in the form of broken or deformed tops or bole and root decay
Multiple canopy layers
Canopy gaps and understory patchiness
Before the Copper King fire, the project area contained about 1,356 acres of stands on National Forest System land that met or would have met within about two decades the Green et al. (1992, errata corrected 2011) old growth definitions. The majority (over 72 percent) of this old growth burned at high or very high severity during the fire (see Table 3.2-2) and therefore no longer meets old growth definitions because there are not enough live trees of sufficient size and age. In very high severity burn areas, nearly all the trees are dead. Out of the 6 attributes listed above, the only one that remains in these areas is a high accumulation of large-size dead standing trees. Fallen trees that existed before the fire were consumed.
Table 3.2-2: Pre-Fire Old Growth Stands (defined by Green et al. 1992, errata corrected 2011) and Acres Treated by Alternative Fire Severity Pre-fire Old Growth Alternative 2 Alternative 3 (acres and percent ) (acres) (acres) Low 216 (16%) 27 27 Moderate 156 (11.5%) 0 0 High 171 (12.5%) 0 0 Very High 813 (60%) 244 292 Total 1,356 271 (20%) 319 (24%)
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Using the Lolo Forest Plan’s broader old growth definition (old forest stands represented by large size and over 160 years old (Applegate and Slaughter, 2003)), the project area contained less than approximately 3140 acres (16 percent of the project area) of old growth stands before the fire.
Table 3.2-3: Pre-Fire Tree Size and Age Classes, and Harvest by Alternative Tree Diameter Size Class National Forest Alternative 2 Alternative 3 (age class)1 System land Acres (percent of Acres (percent of (acres) tree size class acres) tree size class acres) 5-9.9 inches (15-50 years old) 4045 248 (6%) 309 (8%) 10-14.9 inches (50-120 years old) 10,980 917 (8%) 1495 (14%) 15-19.9 inches (120-180 years old) 3082 305 (10%) 468 (15%) > 20 inches (180-220+ years old) 58 2 (3%) 2 (3%) 1Ages are estimates based on local knowledge of the area. Data source for tree size class: R1 Vmap
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on pre-fire old growth stands because no salvage or other vegetation treatments would occur. However, bark beetles can cause mortality in trees that are damaged, but not immediately killed by fire (McCullough et al. 1998; McHugh et al. 2003; Parker et al. 2006; Perrakis and Agee 2006). Davis et al. (2012) found that bark beetle response to fire-injured trees within the fire boundary pulsed and receded within 2 years post-burn. Therefore, it is uncertain whether old growth stands that are alive today after the Copper King Fire would continue to survive.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 include salvage of merchantable dead trees from approximately 244 and 292 acres, respectively, of pre-fire old growth stands (as defined in Green et al. 1992, errata corrected 2011) that burned at very high severity. This represents 18 and 22 percent, respectively, of the pre-fire old growth stands on National Forest System land within the project area. Based on field assessments, these stands proposed for salvage no longer meet the definition of old growth due to the high tree mortality. Survivor trees would be retained. Therefore, salvage of dead trees would not reduce the amount of existing (post-fire old growth that still meets the Green et al. criteria) within the project area.
Although large dead standing trees would be removed and the amount of future downed trees would be reduced within approximately 18-22 percent of the pre-fire old growth, these attributes would be retained in the remaining 88-92 percent (approximately 1000 acres) of the pre-fire old growth within the project area and on the 17,000 or more acres that would remain unaffected by project activities. The other attributes of large live trees, variation in live tree sizes and spacing, decadence, multiple canopy layers, and canopy gaps and understory patchiness would not be affected because these were removed by the fire.
Alternatives 2 and 3 would also conduct thinning in two stands (27 acres) of surviving ponderosa pine old growth (as defined in Green et al.), which represent approximately two percent of the total pre-fire old growth in the project area. These stands burned at low severity and are located along the fire perimeter. Field assessments conducted by the Regional entomologist identified these stands as high risk to bark beetle attack particularly in the first year after the fire (Forest Health Protection Trip Report 2016; Davis et al. 2012).
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Within the two stands where thinning is prescribed, smaller live grand fir and Douglas-fir trees would be removed from around the large old growth ponderosa pine trees to improve their resistance to beetles. Studies have found that large diameter old growth ponderosa pine trees have increased their growth and vigor following vegetation removal around them (Kolb et al. 2007; Fajardo et al. 2007). After implementation, these stands would continue to meet old growth definitions in Green et al. 1992 (errata corrected 2011). Around the existing live old growth trees, the lower to mid canopy layer would be reduced due to the removal of some of the smaller trees. So although a few old growth attributes would be modified, the thinning of 27 acres would continue to maintain these stands as old growth. Thinning would help to retain the attribute of large live trees over the long term.
Alternatives 2 and 3 would not affect 80 and 76 percent, respectively, of the pre-fire old growth (defined in Green et al.) within the Copper King project area. These stands would be left to natural processes.
Using the Lolo Forest Plan’s broader old growth definition, Alternatives 2 and 3 would salvage merchantable dead trees from less than 13 and 18 percent, respectively, of pre-fire old growth stands (old forest stands represented by large size and over 160 years old (Applegate and Slaughter, 2003)) (see Table 3.2-3). Because these stands no longer meet the definition of old growth due to mortality, Alternatives 2 and 3 would not reduce the amount of old growth.
Cumulative Effects Alternatives 2 and 3 would have no cumulative effect on old growth because salvage operations would only remove dead trees from stands that no longer meet old growth definitions as outlined in Green et al. 1992 (errata corrected 2011) and the Forest Plan. The improvement cutting within 27 acres of survivor old growth stands would reduce the risk of future mortality to bark beetles.
Forest Plan Consistency A forest-wide old growth analysis using 1995-1996 Forest Inventory and Analysis (FIA) data (Czaplewski, 2004) shows that the Lolo National Forest continues to meet the old growth strategy of the Forest Plan. The estimated percentage of old growth (using the more restrictive definition provided by Green et al. (1992, errata corrected 2011) on all forested lands on the Lolo National Forest is 9.0 percent (Bush et al. 2007, updated 2012), above the 8 percent strategy (Lolo Forest Plan EIS, page II-61).
Using the Lolo Forest Plan definition of old growth (Forest Plan, pages VII-24 and 25), the FIA inventory data indicates that at least 14.4 percent of the Lolo National Forest forestlands are old growth, i.e., old forest stands as represented by large size and over 160 years old (Applegate and Slaughter, 2003). At least 20 percent of Lolo National Forest forestlands are old forest stands over 140 years old.
The Lolo National Forest is currently meeting the Forest Plan strategy for old growth at the forest-wide scale, and appears to have an abundance of old growth sufficient to continue to meet the strategy in the event of disturbance such as fire (like Copper King) or pathogens. Alternatives 2 and 3 would not affect the Forest’s ability to meet its old growth strategy, and would improve the resistance of 27 acres of surviving old growth to bark beetles.
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3.2.3 Forest Carbon Storage and Climate Change
Issue Raised in Public Comments Salvage operations could reduce on-site carbon storage by removing tree boles from the forest as logs.
There are no applicable legal or regulatory requirements or established thresholds concerning management of forest carbon or greenhouse gas emissions. In most cases, the National Forest is the most appropriate scale for analyzing greenhouse gas emissions, biogenic carbon, and their effects. Analysis at the smaller scale can result in inaccurate results because the carbon balance of an individual stand fluctuates cyclically over time between carbon emitter and carbon sink, depending on when natural or human disturbances occur to affect its development.
Forests cycle carbon. They are in continual flux, emitting carbon into the atmosphere, removing carbon from the atmosphere, and storing carbon as biomass (sequestration). Over the long-term, through one or more cycles of disturbance and regrowth (assuming the forest regenerates after the disturbance), net carbon storage is often zero because re-growth of trees recovers the carbon lost in the disturbance and decomposition of vegetation killed by the disturbance (McKinley et al. 2011; Ryan et al. 2010; Kashian et al. 2006).
Prior to the Copper King Fire, forests within the project area were composed of mixed conifers at a variety of composition, densities, and structures dominated by mid to late seral age classes. At this stage of their development, these stands were estimated to be net carbon sinks. That is, they were likely sequestering carbon faster than they are releasing it to the atmosphere. As a result of the Copper King Fire, the strength of that net carbon sink has likely been severely weakened due to the burn severity which caused variable levels of vegetation mortality, especially in the trees. Carbon removal has slowed as a result of this mortality. Therefore, in the short term, forested stands burned in the fire are storing carbon in the dead trees and downed logs. As dead trees decompose, carbon would be released to the atmosphere. Over time, affected forests would shift back into a carbon sink assuming most pre-fire vegetation returns and reforestation occurs.
Alternative 1: Direct and Indirect Effects There would be no direct human-induced emissions of carbon into the atmosphere under Alternative 1. Generally due to fire mortality, the project area is and would continue to function as a carbon source in the short term, with dead trees releasing carbon into the atmosphere as they decompose. This state would continue for up to a decade or more until the rate of forest regrowth, assuming trees regenerate, meets and exceeds the rate of decomposition of the killed trees. As stands continue to develop, the strength of the carbon sink would increase (typically peaking at an intermediate age and then gradually declining, but remaining positive) (Pregitzer and Euskirchen 2004). Carbon stocks would continue to accumulate, although at a declining rate, until again impacted by subsequent disturbance.
For at least the short term, on-site carbon stocks would remain higher under Alternative 1 than under Alternatives 2 and 3. Nevertheless, caution is advised against interpreting carbon inventory maintenance or gains from deferred or foregone timber harvest in any specific forest or stand as affecting atmospheric concentrations of greenhouse gases. This only holds true if harvest does not occur elsewhere in the world to supply the same world demand for timber (Gan and McCarl 2007; Murray 2008; Wear and Murray 2004). The result can be a net carbon impact if the timber is replaced in the marketplace with higher carbon source products such as steel or concrete or is
48 Copper King Fire Salvage Environmental Assessment harvested in a manner that does not result in prompt reforestation (McKinley, et al. 2011; Ryan, et al. 2010; Harmon 2009).
Alternatives 2 and 3: Direct and Indirect Effects While the acres of proposed salvage differ between the action alternatives, the differences are negligible in terms of potential effects to carbon sequestration and storage. Therefore, their effects are discussed together.
Alternatives 2 and 3 include harvesting trees that are dead and dying, removing roadside hazard trees, and thinning live trees on approximately 102 acres. Alternatives 2 and 3 would harvest trees on approximately 1502 and 2312 acres, respectively, which represent a miniscule area in the context of regional carbon stores. In the short term, these alternatives would remove some carbon currently stored in dead and live biomass through the cutting of mostly dead trees. A portion of the carbon removed would remain stored for a period of time in wood products (US EPA 2013; Depro, et al. 2008). Additionally, motorized equipment used during any of the proposed activities would emit greenhouse gasses.
For at least the short term, on-site carbon stocks would be lower under the action alternatives than under Alternative 1; however, removal of these trees would reduce the carbon emitted through decomposition of this material. Therefore where treatment occurs, recovery from a source to a sink may be marginally faster with the action alternatives. However, the area of salvage is miniscule relative to the areas impacted by the 2016 wildfires, and immeasurable relative from a landscape or regional carbon perspective.
Removal of dead wood would reduce on-site carbon stores. The portion removed as wood products may partially delay carbon release relative to on-site decay rates. The portion burned would hasten release of that carbon to the atmosphere compared to on-site decay rates. These stands would continue to emit more carbon than they absorb and would remain net carbon sources until trees that sequester additional carbon are well established. The proposed reforestation would hasten the development of these forest stands into a carbon sink function. As stands continue to develop, the strength of the carbon sink would increase then gradually decline, but remain positive (Pregitzer and Euskirchen 2004). Carbon stocks would continue to accumulate, although at a declining rate, until impacted by future disturbances.
Cumulative Effects Alternatives 1, 2, and 3 would not have a discernable impact on atmospheric concentrations of greenhouse gases or global warming, considering the limited changes in both rate and timing of carbon flux predicted within these few affected forest acres and the global scale of the atmospheric greenhouse gas pool and the multitude of natural events and human activities globally contributing to that pool.
Although not a statutorily defined purpose of National Forest System management, forests do provide a valuable ecosystem service by removing carbon from the atmosphere and storing it in biomass (Galik and Jackson 2009). U.S. forests are a strong net carbon sink, absorbing more carbon than they emit (Houghton 2003; US EPA 2013; Heath et al. 2011). For the period 2000 to 2008, U.S. forests sequestered (removed from the atmosphere, net) approximately 481.1 teragrams of carbon dioxide per year, with harvested wood products sequestering an additional 101 teragrams per year. National Forests accounted for approximately 30 percent of that net annual sequestration. National Forests contribute approximately 3 Tg carbon dioxide to the total
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stored in harvested wood products compared to about 92 Tg from harvest on private lands (Heath et al. 2011).
The total carbon stored on the Lolo National Forest is approximately 135 Tg, or about thirty-one hundredths of one percent (0.0030) of approximately 44,931 Tg of carbon stored in forests of the coterminous U.S. (Heath et al. 2011). The Copper King Fire Salvage project would affect only a tiny percentage of the forest carbon stock of the Lolo National Forest, and an infinitesimal amount of the total forest carbon stock of the United States.
Within the U.S., land use conversions from forest to other uses (primarily for land development or agriculture) are identified as the primary human activities exerting negative pressure on the carbon sink that currently exists in this country’s forests (McKinley et al. 2011; Ryan et al. 2010; Conant et al. 2007). The affected forest lands in this project would remain forests, not converted to other land uses, and long-term forest services and benefits would be maintained.
3.2.4 Botany This section is focused on sensitive plants because these are species for which population viability is a concern, as evidenced by significant current or predicted downward trends in 1) population numbers or density and/or 2) habitat capability that would reduce a species’ existing distribution” (FSM 2670.5). Threatened and endangered species listed under the Endangered Species Act were also considered, but no habitat for them (pre or post-fire) occurs within the project area.
High severity burning in the Copper King Fire likely removed for the long-term potential habitat for and perhaps even populations of some sensitive plant species that are not adapted to severe disturbance and/or open canopy. For example, clustered lady’s slipper is a forest understory- dwelling plant and the loss of forest canopy due to the fire removed suitable habitat. This species also grows in the upper 1-3 inches of litter/duff layer covering the soil. In high severity burn areas, the duff was consumed and any clustered lady’s slipper populations in those areas likely no longer exist. For other sensitive plant species that are adapted to disturbance, open canopies, and have deep rooting structures, habitat and the plants themselves likely survived.
Effects Common to All Alternatives All alternatives would have no direct, indirect, or cumulative effects on any federally listed Endangered or Threatened plants because no habitat for them occurs in or near the project area.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on sensitive plant species or their habitat, because no activities would occur. As previously described, the fire likely impacted sensitive species and habitat depending on burn severity.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Because the Copper King Fire burned late into the fall and removed and/or scorched most of the ground vegetation, botanical surveys would be conducted when vegetation sprouts in late spring. A pre-screening process was conducted to identify areas of potential habitat for sensitive species. Known locations of sensitive plants in the project area and vicinity were reviewed. This information was compared with aerial photographs and professional botanical knowledge of pre- burn habitats in the project area to identify potential habitat for threatened, endangered, and sensitive species. Portions of the project area were surveyed in the past for previous projects, but
50 Copper King Fire Salvage Environmental Assessment none directly overlap with proposed salvage units. Field surveys would be conducted once post- burn vegetation sprouts in May-June 2017 before salvage operations would begin. Surveys would focus on proposed salvage units and temporary road locations that overlap sensitive plant habitat (28 units totaling approximately 500 acres). Based on information gathered from the pre- screen review and professional botanical knowledge of the area, the likelihood of finding sensitive plant populations is low. However, if sensitive plant species are identified, site-specific resource protection measures would be developed as needed to maintain the viability of species (see Resource Protection Measures in Chapter 2).
Although 17 sensitive plant species have potential habitat within the project area, seven species (tapertip onion, diamond clarkia, sand springbeauty, clustered lady’s slipper, Britton’s cliff moss, hill monkeyflower, and whitebark pine) could potentially be affected by project activities based on where operations would occur.
Riparian areas would be buffered from salvage operations; therefore Alternatives 2 and 3 would unlikely have any effects to species that inhabit these areas.
The planting of rust-resistant whitebark pine seedlings in favorable burned habitat would benefit the species by promoting blister rust resistance in the project area and, in 30-50 years, potentially yielding more seed-producing whitebark pine trees.
Cumulative Effects Past timber harvest and road construction within the project area may have affected sensitive plants species that were present. Effects could have been positive or negative depending on the species growing habits. Post-fire salvage operations on State and Weyerhaeuser lands may have negative or neutral effects on individual sensitive plants that may inhabit those areas. Again, effects would depend on the species growing habitats.
Based on preliminary review, Alternatives 2 and 3 may impact individuals or habitat for seven sensitive plant species (tapertip onion, diamond clarkia, sand springbeauty, clustered lady’s slipper, Britton’s cliff moss, hill monkeyflower, and whitebark pine). However, these alternatives would not likely contribute to a trend toward federal listing or loss of viability for the species. To ensure individual plants and local populations are protected, surveys would be conducted prior to operations and appropriate protection measures would be applied as needed. The project would have no impact on any other sensitive species because potential habitat would not be affected by project activities.
Forest Plan Consistency Alternatives 2 and 3 would be consistent with the Lolo Forest Plan because, as described above, sensitive plant species would be protected to maintain population viability (Forest Plan standard 27, page II-14).
3.2.5 Weeds
Issue Raised in Public Comment Salvage operations and associated temporary road construction could exacerbate weed spread.
The Copper King Fire had a dramatic effect on the vegetation. Approximately, 49 percent of the National Forest System land within the fire perimeter sustained a high to very high canopy cover
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loss. Another 6 percent of the fire sustained moderate canopy cover loss, while 45 percent had no to very little canopy cover loss (see Table 3.2-4 and Figure 3.2-2).
The limitation of using canopy cover loss is that this method does not differentiate areas of thin barked trees from thick barked trees. This is especially true in areas of no to low canopy cover loss. In these areas, the thin barked trees are likely to be dead from root collar scorch of the surface fire. The canopies of these thin barked trees were likely green when the imagery was taken and will show up on the imagery as such. But in reality, these trees are dead and the needles in the canopies will not turn brown and fall off until this summer 2017. Therefore, the percentage of no to low canopy cover loss is likely an overestimation. At this time, a prediction of the amount of overestimation cannot be calculated with any accuracy. Thus, the percentages used will be those indicated from the imagery taken in the fall of 2016.
In the areas of high to very high canopy cover loss, most, if not all, of the vegetation canopy which includes shrubs and trees was consumed in the fire. This loss of canopy cover has increased the amount of sunlight and water reaching the ground. The organic duff and litter layer was also consumed exposing the mineral soil beneath, which has created a receptive bed for plant seeds, including weeds.
Factors limiting weed spread are shade from tree canopies, higher soil moisture, needle and grass litter that provides a mulch-like covering of the ground, lack of exposed soil, and native plant competition. All of these factors are lacking in the high to very high burn severity areas. Although more water reaches the ground because of the lack of interception from tree branches, these sites dry out faster due to their exposure to more direct sunlight and loss of soil surface organic matter.
Table 3.2-4: Canopy Cover Loss Severity on National Forest System Land within the Copper King Fire Area and Harvest by Alternative Canopy Cover Loss National Forest System land Alternative 2 Alternative 3 Severity Acres (percent) Acres (percent) Acres (percent) None (0%) 4825 (25%) 0 0 Low (0-24%) 3860 (20%) 106 (7%) 129 (6%) Moderate (25-49%) 1158 (6%) 179 (12%) 253 (11%) High (50-74%) 965 (5%) 306(21%) 398 (17%) Very High (75-100%) 8492 (44%) 911 (61%) 1532 (66%) Data source: Rapid Assessment of Vegetative Condition after Wildfire (RAVG) satellite mapping
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Figure 3.2-2: Canopy cover loss within the Copper King Fire perimeter (RAVG product)
After the fire in the fall of 2016, field surveys were conducted to identify the presence of existing weed species within the proposed salvage units and on roads accessing these units. However, weed surveys within the high to very high burn severity areas were inconclusive because of the high degree of plant material consumed by the fire. Some information was gathered from pre- treatment weed inventories along roads within the project area that were sprayed with herbicide in 2014. Because current (post-fire) weed information is limited, it was assumed that the roads within the project area had, to some degree, various weed populations along them. Using the limited data, spotted knapweed, oxeye daisy, St. Johnswort, meadow hawkweed complex, and cheatgrass are the most likely weed species within the project area.
In areas of high to very high burn canopy cover loss, the risk of weed establishment and spread will be high for the first few years after the fire regardless of whether salvage operations occur or not. Weeds already established in these areas, would likely spread. Native grasses, forbs, and shrubs will also respond and spread into areas of exposed mineral soil. Within a few years, native plants will likely be able to out-compete some of the weeds, which will decrease weed spread (Knapp and Ritchie 2016). The weeds that establish within the first few years will likely persist depending on the native plant competition. Over time as the vegetation canopy becomes established and shades the ground, some weeds will die out, but others will continue to survive.
As part of the BAER work, approximately 95 miles of roads (~450 acres) within the fire perimeter will be sprayed with herbicide after vegetation sprouts in 2017 (see Sections 1.4.1 and 3.1). These treatments, authorized under the 2007 Lolo National Forest Integrated Weed Management Record of Decision, will reduce existing weed populations along roadsides and their potential to spread off roads into burned areas.
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Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 includes no ground disturbing activities. The population and the weeds species currently present are expected to increase and spread to susceptible areas within the project area as described above.
Salvage operations on State and Weyerhaeuser land and increased public use in the area over the next several years for mushroom picking, firewood gathering, and hunting could introduce new weeds. Approximately 95 miles of roads in the project area will be treated for weeds as part of the BAER work beginning in 2017. This action will reduce the existing weed populations along these roads. Reducing the weed populations along these roads will lower the risk of weed spread into susceptible habitats along the roads.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 would conduct ground disturbing activities, including timber harvest, temporary road construction, and maintenance activities on existing roads, which could increase the risk of weed establishment and spread. There would be little difference between the alternatives in their effects on weeds. Alternative 2 contains approximately 905 more acres of ground disturbance (harvest and road-related) than Alternative 3, which is about 5 percent more of the National Forest System lands within the project area. However, resource protection measures (see Chapter 2) such as washing off-road equipment to remove weed seeds before moving into the fire area, seeding disturbed areas with native plants, and herbicide treatment along roads before road-related activities begin would reduce weed risk.
Recent studies from around the western United States indicate that post-fire logging treatments produce no significant statistical differences to understory plant diversity and exotic plant [weed] cover when compared to unlogged areas (Knapp and Ritchie 2016; Peterson and Doyle 2016; McGinnis 2010; Keyser 2009). Morgan and others (2015) suggest that fire severity has more influence on weed populations than post-fire mechanical harvest activities.
As displayed in Table 3.2-4, approximately 1217 (82 percent) and 1930 (83 percent) of the timber harvest in Alternatives 2 and 3, respectively, would occur within areas of high to very high canopy cover loss. Within these areas, 60-100 percent of the vegetation canopy is already lost from the fire and up to 100 percent of the organic duff and litter layer has been burned to mineral soil. Factors that limit weed spread including shade from tree canopies, higher soil moisture, needle and grass litter that provides a mulch-like covering of the ground, lack of exposed soil, and native plant competition are already lacking in these areas. Additional soil disturbance from salvage operations with applied mitigation would not substantially exacerbate the existing high weed risk in these areas as supported in the scientific literature discussed above.
Road-related work, including temporary road construction and maintenance, would be a higher risk to promote the establishment and spread of weeds than timber harvest (Birdsall 2012). Resource protection measures would be applied to minimize risk. In addition to the measures listed above, temporary roads would be treated with herbicide prior to obliteration. The list of resource protection measures to reduce weed risk is displayed in Chapter 2.
More detailed information regarding the evaluation of weeds is contained within the Weed report in the Project File.
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Cumulative Effects Past soil disturbing activities over the last sixty years, whether they were natural or man-caused, have helped spread noxious weeds into and throughout the Copper King project area. Weed populations will continue to be influenced by a variety of land-uses across all land ownerships. However, the Copper King Fire has had a greater influence on the future composition of weeds on the landscape than any other past and present action. The fire has increased the susceptibility and risk for establishment and spread of weeds in the fire perimeter by killing the tree and shrub canopy and burning the duff layer, exposing mineral soil. This higher risk is likely to last several years until native grasses, shrubs, and trees regenerate and out-compete invading weeds.
Private and state land located in and along the edges of the project area could be a source for weed seed. Weed treatments on these other lands may or may not occur depending on the landowner. This also could increase the amount of existing weeds and possibly the number of species in the project area.
While it is unknown when the first noxious weeds were established in the project area, a good estimate would be in the 1960s. Before the early1990s, there were few, if any, weed prevention measures in place. The Lolo National Forest adopted preventive measures to avoid weed spread and establishment of new invasive species with the 1991 Noxious Weed Management Amendment to the Lolo Forest Plan. This authorized integrated pest management strategies including the use of certain herbicides. Timber sale contracts were modified to include washing of equipment to remove weed seeds prior to entry onto National Forest land, herbicide spraying of haul routes, and use of weed-free seed grass to re-vegetate disturbed ground. In 2007, the Lolo National Forest adopted an adaptive and integrated weed management strategy to include treatment of new weed species, new weed populations, and use of new control methods.
In 2014, Roads 9991 [ACM road] and 875 (approximately 250 acres), primary haul routes for Alternatives 2 and 3, were sprayed with herbicide to reduce existing weed populations. As stated above approximately 95 miles (450 acres) of road will be treated with herbicide this spring as part of the BAER work, which will reduce the potential of weed spread from roadways. Monitoring across the Lolo National Forest indicates herbicide treatments have been more than 90 percent effective in controlling and reducing weed populations.
Ground-disturbing activities in Alternatives 2 and 3 may contribute to weed spread in the project area. However, recent scientific studies indicate that there is no statistical significance in the difference of understory plant diversity and weed cover between areas that have been salvaged and those that have not (Knapp and Ritchie 2016; Peterson and Doyle 2016; McGinnis 2010; Keyser 2009). Both alternatives require the application of resource protection measures (see Chapter 2) to further minimize the potential for the spread of established weed species and introduction of new ones.
Forest Plan Consistency Alternatives 2 and 3 would be consistent with the Forest Plan because all management activities would incorporate appropriate weed prevention measures. The weed prevention measures outlined in Appendix W of the Plan (amended to the Forest Plan in 1991) are included in the resource protection measures for the Copper King Fire Salvage project (Chapter 2).
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3.3 Soils
Issues Raised in Public Comment Salvage operations and associated temporary road construction could adversely affect soils.
Winter logging requirements are unnecessary to protect soils and could reduce project viability. (The rationale for winter logging is contained within this section. Project viability is addressed in the Economics section 3.10)
Forest Service Soils Manual (FSM 2550; November 2010) and Region 1 Soil Quality Standards provide guidelines and methods to show compliance with the National Forest Management Act (NFMA). The objectives of the Region 1 Soil Quality Standards (R1 SQS) include managing National Forest System lands “without permanent impairment of land productivity and to maintain or improve soil quality”, similar to the NFMA. Region 1 Soil Quality Standards are based on the use of six physical and one biological attribute to assess current soil quality and project effects. These attributes include compaction, rutting, displacement, severely-burned soils, surface erosion, soil mass movement, and organic matter.
The analysis standards address basic elements for the soil resource: (1) soil productivity (including soil loss, porosity; and organic matter), and (2) soil hydrologic function. The soil productivity direction identifies a value of 15 percent detrimental soil disturbance as a guideline for maintenance or loss of soil productivity and to show compliance with the NFMA.
Fire effects overwhelmingly contributed to the existing condition of the soil in the project area. Soil burn severity (not to be confused with vegetative burn severity described in Section 3.2) was mapped following the Copper King fire using Burned Area Reflectance Classification (BARC) and mapping results were field validated (USDA 2016, BAER Report). Soil burn severity describes the fire-caused damage to the soil and is a measure of the effects of fire on soil conditions. Burn severity classes are identified as low, moderate, or high. For the Copper King Fire, BARC mapping showed approximately equal acres of low, moderate, and high burn severity. Approximately 11 percent of acres remained unburned, 29 percent displayed low soil burn severity, 31 percent moderate severity, and 30 percent high severity.
On sites that are considered low burn severity, the duff layer is partially consumed by the fire and very little heating of the soil surface layer has occurred. Low burn severities would not likely affect the soil hydrologic properties or soil stability. Many unburned roots and seeds in the surface soil will aid in vegetating the burned areas. Natural re-vegetation on these sites will occur quickly. Typically, unburned trees and shrubs are present and provide cover that reduces soil erosion.
The moderate burn severity sites have slightly altered surface soil structure, reduced numbers of fine roots and less seed viability in the soil surface. Natural revegetation on these sites can be slower than low burn severity areas. In most places, the duff is reduced to a layer of charred litter. Water repellent (hydrophobic) soil conditions may occur under moderate burn severity sites, but will be discontinuous and short-lived. Sites with moderate burn severity displayed some increased soil erosion during field surveys. These sites are susceptible to physical disturbance caused by equipment due to loss of protective ground cover.
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High burn severity sites have modified surface soil properties. The surface soil structure has broken down, and a short-lived hydrophobic layer may be present. Lack of vegetation canopy, altered soil conditions, and a lack of organic litter or duff increased the risk of rain-impact erosion at the soil surface, reduced infiltration, and increased erosion and runoff. Field surveyed sites with high burn severity displayed extensive rill, sheet, and some gully erosion. Erosion in these areas is expected to increase with spring runoff and high intensity rains. There are few viable roots or seeds in the upper several inches of the soil, and protective ground cover and organic material layers have been removed by the Copper King Fire. Natural re-vegetation on these sites is slow and they are highly susceptible to erosion and physical soil disturbance, making them especially sensitive to tractor harvest (Klock 1975, McIver et al. 2006, Wagenbrenner 2015).
In general, ecosystems found within the project area tend to be fairly resistant to fire effects (Hutto et al. 2016). The redistribution of soil material after fire is a natural geomorphic process and one of the principal drivers of hillslope development in mountainous environments (Wondzell and King 2003). Over time, natural recovery of vegetation and soil processes will occur on these sites. As vegetation re-inhabits sites, it is expected that nutrient cycling will accelerate, litter layers increase, and soil productivity will trend towards pre-fire levels.
The majority of the salvage units are within areas with moderate to high soil burn severity (see Table 3.3-1). Site-specific resource protection measures would be applied to protect soils. For example, tractor units located in high soil burn severity areas would be required to be logged in the winter over frozen ground and/or snow. Coarse woody debris would be retained within salvage units as outlined in the 2006 Lolo National Forest Down Woody Material Guide.
Fire alters many soil properties including consumption of organic matter content and coarse woody debris, which in turn alters nutrient related processes. Organic matter and coarse woody debris are important elements in retaining soil productivity and long-term site health (Maranon- Jimenez and Castro 2013, USDA 2006, Graham et al. 1994). The recovery of organic matter and coarse woody debris following fire is key to restoring ecosystems productivity. Erosion decreases productivity due to a net loss of topsoil. This is especially important in the project area on steep slopes where moderate and high severity fire has consumed the protective forest floor layer leaving the soil vulnerable to erosion (Neary et al. 2005). Keeping debris on site can decrease soil loss by up to 95 percent (McIver and Starr 2000). Generally, increased erosion due to wildfire occurs during the year following the fire, but as vegetation recolonizes sites, erosion stabilizes (Neary et al. 2005).
Table 3.3-1. Soil Burn Severity within Copper King Salvage Units Alternative 2 Alternative 3 Severity Class1 (acres and percent) (acres and percent) Unburned 115 (8%) 138 (6%) Low 224 (15%) 309 (13%) Moderate 341 (23%) 486 (21%) High 822 (54%) 1379 (60%) 1Soil burn severity describes the fire-caused damage to the soil. Data Source: Burned Area Reflectance Classification (BARC) satellite mapping
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects to soil because no activities would occur. The existing conditions resulting from the Copper King fire would persist. Alternative 1 would not alter the current erosion and landslide potential within the fire area. This alternative would retain the existing amount of coarse woody debris, although additional coarse
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woody debris would fall to the ground and come in contact with the soil surface over time. Organic matter would be replaced where high burn severities eliminated the surface litter and duff and would increase water holding capacity on the site over time.
Alternatives 2 and 3: Direct and Indirect Effects Soil disturbance is an unavoidable consequence of forest management activities. Best management practices, standard operating procedures, and project-specific resource protection measures (described in Chapter 2) are included in the action alternatives and would be applied to reduce disturbance and limit the effects of management activities on soil resources; however, it is not possible to completely eliminate disturbance. Resource protection measures that restrict the operating season to winter and maintain coarse woody debris are specifically discussed below.
Alternatives 2 and 3 would meet the Region 1 Soil Quality Standards and Forest Plan standards and therefore would not have a significant impact to soils. The direct and indirect effects for both alternatives would be similar. Because there would be more acres salvaged in Alternative 3, the effects would be greater in areal extent.
Harvest activities may result in soil disturbance but this disturbance is not irreversible, based on local forest soil monitoring studies and peer reviewed research. Soil disturbance that is localized in nature is expected to dissipate within 20-30 years. With rehabilitation, large landings, primary skid trails, and temporary roads are expected to re-establish a functional forest floor and biologic, chemical, and physical soil processes within 40 years.
Winter Harvest Operations The operating season is restricted to winter conditions in tractor units with high burn severity, high existing detrimental soil disturbance, or a combination of both conditions (233 acres in Alternative 2 and 269 acres in Alternative 3). Existing detrimental soil disturbance found during field surveys included bare soil, topsoil displacement, compaction, and sheet, rill, and gully erosion. Units with a winter harvest season mitigation did not meet regional soil policy due to existing soil conditions, or were not expected to meet policy requirements following implementation without the required mitigation.
High severity fire removes protective soil cover including vegetation and organic matter, leaving the soil surface more susceptible to displacement and compaction from ground-based machinery (Dumroese 2006, Klock 1975, McIver et al. 2006), which can ultimately reduce soil productivity (Wagenbrenner et al. 2015). Logging over snow and frozen soil is a highly effective method for reducing physical soil displacement and compaction, and protecting the forest floor (Dumroese 2006, Flatten 2003, McIver et al. 2006). Winter ground-based harvest in high burn severity soils is expected to increase existing detrimental soil disturbance by 4 percent (McIver and Starr 2000, Flathead Monitoring Reports: Soil File 4, Lolo National Forest Monitoring Report). In comparison, summer tractor harvest is expected to increase existing detrimental soil disturbance by 13 percent (Beschta 2004, Rone 2011, Wagenbrenner et al., 2014). The winter harvest mitigation requires frozen ground or snow depth sufficient to protect the forest floor. Depth of snow needed to support ground-based equipment depends on snow density and is determined by the timber sale administrator. Winter harvest operations are required in units 1, 3, 5, 7, 9, 25, 26, 27, 28, 29, 32, 72 (Alt 3), 78 (Alt 3), and 91 (Alt 3).
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On the Lolo National Forest, summer ground-based harvest utilizing cut-to-length (CTL) system12 over a slash mat has been substituted for winter harvest mitigations when winter operating conditions cannot be met in unburned harvest units. Working on a slash mat in these situations is effective for reducing compaction and soil displacement (Han 2009), and resulting soil disturbance is comparable to winter harvest operations (Lolo NF Monitoring Reports 2007- 2015). Documentation regarding the effects of CTL systems on soil disturbance in severely burned soils is extremely limited, but one study completed in the Inland Northwest displayed substantial increases in post-harvest detrimental soil disturbance with the use of log forwarders13 when compared to winter logging (Page-Dumroese et al. 2006a). In addition, a CTL system processes trees at the stump leaving limbs and tree tops on skid trails to provide a layer of slash to cushion equipment operations. However, in high severity burn areas in the Copper King Salvage project, trees do not have branches or leaves that would contribute sufficient slash to support ground-based machinery.
There is so much variation in burned forests and logging equipment that it is difficult for small scale research to provide general principles for mitigating ecological damage in the post-fire environment. Some research suggests that managers could benefit from comparing different practices and prescriptions in an operational context instead of relying solely upon scientific research (Duncan 2002). To contribute to the body of knowledge about effects of post-fire salvage on soils, monitoring is required in Units 1, 19, 25, and 49. These units would be part of an adaptive management study to assess soil disturbance in relation to burn severity and season of harvest. Units 1 and 19 displayed moderate burn severity and units 25 and 49 displayed high burn severity. Units 1 and 25 would be logged under winter conditions while units 19 and 49 would be logged under summer conditions. Units would be monitored immediately after harvest, and two years following harvest. All study units are expected to meet soil policy after management activities. If detrimental soil disturbance is greater than 15 percent in any monitored units, a soil rehabilitation plan would be developed to reduce site-specific detrimental soil disturbance and reach compliance with Regional soil quality standards.
Coarse Woody Debris Retention and Recruitment Organic matter, including the forest floor and coarse woody debris, moderates soil temperatures, improves soil water availability, stores nutrients, and supports microbes and biodiversity that is essential for maintaining ecosystem function (Page-Dumroese et al. 2010). Design features are included in the project to retain all non-merchantable material in units to the extent practical, and to leave tree tops during harvest in units that have a shortage of coarse woody debris (CWD). CWD levels are expected to increase in all units following harvest due to breakage and logging slash, but in the long-term (greater than 10 years) CWD would be lower in these stands than unsalvaged sites (Monsanto et al. 2008). Due to the severity of the fire, existing CWD levels were below levels recommended in the Lolo National Forest Coarse Woody Material Guideline (2006) in units 1, 3, 5, 7, 8, 15, 21, 22, 26, 28, 29, 37, 59, and 91(Alt 3); therefore the tops of cut trees would be left on the ground in these units (see Resource Protection Measures in Chapter 2). In units 4, 6, 13, 14, 17, and 20, CWD levels were low, but within recommended guidelines.
12 Cut-to-length (CTL) is a mechanized harvesting system in which trees are delimbed and cut to length directly at the stump. CTL is typically a two-machine operation with a harvester felling, delimbing, and bucking trees and a forwarder transporting the logs to a landing area close to a road accessible by trucks. 13 A log forwarder is a machine that carries felled logs from the stump to a roadside landing. Unlike a skidder that drags the logs with the leading end suspended, a forwarder carries logs clear of the ground.
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Soil Productivity Soil productivity is defined as the inherent capacity of the soil resource, including the physical, chemical, and biological components, to support resource management objectives. It includes the growth of specific plants, plant communities, or a sequence of plant communities (USDA 2010). All alternatives would maintain soil productivity and comply with Region 1 soil quality standards (USDA Forest Service 1999) because nutrient replenishment, forest floor, and humus stores would remain on the site (Busse et al. 2009). As discussed above, coarse woody debris would be left on-site and sites where organic matter was lost due to high burn severity would be replenished with time.
Alternatives 2 and 3 would not result in changes to soil resiliency or recovery potential. Powers (2002) concludes soil productivity should be preserved if the loss of biomass, organic matter, soil porosity and topsoil is limited. Outside of landings and skid trails, large areas (greater than 100 square feet) with detrimental levels of soil disturbance are not expected to be created because of project design features, site-specific resource protection measures, and standard soil operating procedures. Mitigations including harvest season and CWD retention, as discussed above, would protect crucial soil processes. Reforestation activities would improve and rehabilitate soil condition by allowing for the establishment of new tree seedlings which would increase soil cover, nutrient cycling, and organic matter inputs; ultimately decreasing soil recovery time (Certini et al. 2005).
Harvest activities are designed to avoid detrimental soil impacts on more than 15 percent of the activity area. Although all harvest units would meet Region 1 soil quality standards following implementation, Alternatives 2 and 3 would result in approximately 103 and 140 acres (about 6 percent of the proposed harvest acres and less than 1 percent of the National Forest System land in the Copper King project area), respectively, of detrimental soil disturbance. Detrimental soil disturbance is expected within large log landings, in primary skid trails, at skid trail or skyline corridor convergence, and along temporary roads. However, this soil disturbance is not considered substantial or a permanent impairment. Soil productivity would be maintained since project-related soil disturbance would dissipate with time and detrimental soil disturbance would remain below thresholds where long-term impairment may occur.
Tractor Harvest Units Alternatives 2 and 3 would include approximately 597 and 651 acres, respectively, of tractor harvest units. Of these, 233 acres (39 percent) and 269 acres (41 percent), respectively are restricted to a winter operating season.
Soil disturbance is typically associated with landings and wheel tracks within the main skid trails where soil compaction and displacement can occur. In tractor units, equipment is restricted to slopes less than 35 percent.
Some research suggests that tractor harvest can break up hydrophobic layers, increasing infiltration rates and decreasing erosion. Because very little hydrophobicity was found within the Copper King Fire area (Copper King BAER Report, 2016), erosion rates are not expected to decrease with harvest activities.
Detrimental soil impacts from summer tractor harvest on areas with low to moderate burn severity are estimated at 10 percent of an activity area. Past monitoring on the Lolo and Idaho Panhandle National Forests has shown detrimental soil disturbance levels from tractor harvesting to range from 6-14 percent, including post-harvest fuel treatments (grapple piling, prescribed
60 Copper King Fire Salvage Environmental Assessment fire). Because post-harvest treatments are not proposed in Alternatives 2 and 3, the estimated detrimental soil disturbance would be 10 percent (Rone 2011, Lolo NF Monitoring Report, 2015).
Detrimental soil disturbance from summer tractor harvest on areas with high burn severity are estimated at 13 percent of an activity area (Rone 2011). The higher end of potential detrimental soil impacts are assumed in units where the soil cover and soil resiliency is reduced due to the impacts of the Copper King Fire. Expected impacts on these sites are greater where soil burn severity is high and soil organic matter and vegetation has been removed (Beschta 2004; Wagenbrenner et al. 2015).
Detrimental soil disturbance from winter tractor harvest units are estimated at 4 percent of an activity area. Logging over snow and frozen soil is a highly effective method for reducing physical soil displacement and protecting the forest floor (Flatten 2003, McIver and Starr 2000). Estimated detrimental soil disturbance values for winter season harvest are derived from past monitoring on the Flathead and Lolo National Forests (Flathead Monitoring Reports, Lolo NF Monitoring Report, 2015).
Refer to Appendix C and the Soil report in the Project File for detailed soil effects by treatment unit.
Skyline and Excaline Harvest Units Alternatives 2 and 3, would include approximately 747 and 1410 acres, respectively of skyline harvest units. In addition, Alternative 3 includes 96 acres of excaline harvest.
Minimum soil disturbance would occur with hand-felling and hand-processing of logs on the slope. Soil disturbance occurs when moving trees to and within the corridor. These corridors are narrower than skid trails with an average spacing of about 75 feet. Skyline logging soil disturbance may be greatest at the landing where logs are no longer suspended and corridors converge. Standard operating procedures, which include constructing waterbars in skyline corridors where needed and covering bare soil with slash, would minimize erosion.
Detrimental soil impacts from skyline and excaline harvest are estimated at 4 percent of an activity area. Disturbance from skyline harvest ranges from 0-7 percent with an average of 1-3 percent (Rone 2011, McIver and Starr 2000, Lolo NF Monitoring Report, 2015). The higher end value was chosen to reflect the potential for additional disturbance due to fire effects. Disturbance from the excaline trail in Unit 98 (Alternative 3) is included as an additional temporary road disturbance for unit-specific detrimental soil disturbance calculations. Refer to Appendix C and the Soil report in the Project File for detailed soil effects by treatment unit.
Roadside Hazard Tree Removal For roadside hazard tree removal activities, trees would be cut by hand and winched to the road with a cable. Mechanized equipment would remain on the road.
Estimated detrimental soil impacts from roadside salvage units and hazard tree removal are 7 percent in high burn severity areas and 5 percent in low to moderate burn severity areas. This estimate is likely high, as hazard tree removal would occur along roads approximately 100 feet on either side of the road; mechanized equipment would not leave the road prism; and directional falling would occur wherever possible. Monitoring on the Idaho Panhandle National Forest has shown a range of 3-5 percent disturbance in unburned harvest units (Rone 2011). Again, the estimated 7 percent value reflects the potential for additional soil disturbance due to fire effects.
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Log Landings Landings would be associated with most harvest units. Landings would be located on flat areas away from streams and outside or on the edge of the cutting units. Where existing landings are re-used, additional disturbance from this project would not occur or would be minimal.
Detrimental effects from landing construction could include soil compaction, litter loss, loss of coarse woody debris, increased potential for erosion, nutrient losses, loss of soil hydrologic and biologic function, and possible weed incursions. Unit-specific detrimental soil disturbance from landings is included in the acres of soil disturbance expected from project activities calculated for ground-based units (see Appendix C).
Log landings associated with tractor harvest units are expected to be 0.25 to 0.5 acres in size. Erosion control measures would be used if needed to avoid erosion and sediment transport from landing sites during maintenance and construction. All landings would be rehabilitated and returned to pre-implementation conditions. Rehabilitation measures include scarification and seeding. Placement of woody debris to prevent erosion would be applied as necessary.
Temporary Road Construction and Rehabilitation Temporary road construction causes soil compaction, displacement, and reduced soil hydrologic and biologic function. Increased erosion is expected from temporary road construction, particularly in areas where they would drain onto slopes with high burn severity. Temporary roads are considered 100 percent detrimental and have reduced soil productivity for about 40 years until vegetation, soil organic matter, and the forest floor is restored. Alternatives 2 and 3 include approximately 3 miles (6.7 acres) and 7.3 miles (21.4 acres), respectively, of temporary roads. Temporary road construction is expected to disturb an average area 16 feet in width for slopes less than 50 percent, and an average area 40 feet in width for slopes greater than 50 percent. On steep slopes, erosion and soil disturbance resulting from temporary roads is expected to be higher when compared to more gentle slopes. Approximately 0.3 (1.5 acres) of temporary roads on slopes greater than 50 percent is proposed under Alternative 2 and 2.5 miles (5.2 acres) is proposed under Alternative 3. Temporary roads would be rehabilitated following completion of project activities using an appropriate combination of the following specifications:
Any installed culverts would be removed.
The entire road template would be recontoured to natural ground contour.
Where recontouring is unnecessary, the road surface would be scarified with excavator teeth to a depth equal sufficient to ameliorate the presence of detrimental soil compaction (usually between 2 and 12 inches),
The disturbed area would be seeded with native plant mix.
Woody material would be placed on the template to reduce potential erosion
Recontouring activities would not ameliorate the long-term impacts to soil productivity immediately, but would improve soil conditions compared to those of an existing or abandoned road. The establishment of vegetation and associated additions of organic matter would encourage recovery over time. Recontouring would provide a suitable seed bed for native forest vegetation while increasing soil hydraulic conductivity, organic matter, total carbon, and total nitrogen (Lloyd et al. 2013). These conditions are likely to accelerate the recovery of the soil productivity. Hydrological recovery is expected within the first 10 years with soil infiltration
62 Copper King Fire Salvage Environmental Assessment rates lower than natural forest rates for the first 10 years (Luce 1997). For the long-term, infiltration rates improve over time as freeze/thaw cycles and plant roots improve soil porosity. Soil biological function restores as forest floor and native plant communities re-establish.
Soil Stability Soil erosion potential and sediment delivery potential can increase following wildfire because of the loss of soil cover and increased hydrophobicity (Certini et al. 2005; Beschta et al. 2004). Soils in the Copper King project area displayed shallow, discontinuous hydrophobicity, therefore erosion occurring within units is primarily attributed to loss of soil cover (Copper King BAER Report, 2016).
Harvest activities would not occur on areas with high soil erosion hazard. Tractor units with high soil burn severity have elevated soil erosion potential due to lack of surface vegetation and canopy cover. Tractor harvest units with increased erosion potential due to fire effects would be limited to winter season operations to protect soils from compaction and displacement. All tractor harvest units would be limited to slopes of 35 percent or less because potential for surface erosion increases substantially on steep slopes. Detrimental erosion and sediment delivery is not expected on areas with moderate to low erosion hazard ratings and low to moderate burn severities because soil design features would allow for increases in organic matter cover on the soil surface following treatment. Reforestation activities would occur in most harvest units. Tree planting has been shown to decrease erosion potential following salvage harvesting (Slesak et al. 2015).
Field surveys showed that harvest units would not occur in areas with high mass failure risk. No change in mass failure potential is expected from the action alternatives because no salvage or temporary road construction would occur on soils with high mass failure risk. Soil resource protection measures and reforestation activities would encourage stable slopes and reduce potential for soil stability issues following treatments.
Cumulative Effects For activities to be considered cumulative, their effects need to overlap in both time and space with those of the proposed actions. The appropriate geographic area for soil cumulative effects analysis has been defined as the “land affected by management activity” (USDA Forest Service 1999). This is because soil productivity is a site-specific attribute of the land. The productivity of one area of soil is not dependent on the productivity of another area whether that area is adjacent or not. Similarly, if one acre of land receives soil impacts from management activities and a second management activity that may affect soils is planned for that same site, then soil cumulative effects are possible on that site. Thus, cumulative effects to soil productivity are appropriately evaluated on a site-specific basis. A larger geographic area such as a watershed or project area is not considered an appropriate geographic area for soil cumulative effects analysis. This is because assessment of soil quality within too large an area can mask or “dilute” site- specific effects (Nesser 2001). Thus, cumulative effects to soils are evaluated for site-specific activity areas (i.e. proposed vegetation treatment units), but are not evaluated for the entire watershed or project area.
As discussed above, the post-project detrimental soil conditions for all vegetation treatment units would be below 15 percent within each activity area and meet Region 1 soil quality standards (see Appendix C). This assessment of post-project soil conditions reflects the cumulative effects to soils because it considers existing soil conditions resulting from any previous management or natural activity that affected the soil as well as the direct and indirect effects of this project’s
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activities. There are no reasonably foreseeable future actions that overlap the activity areas; therefore there would be no additional cumulative effects than what is previously described above.
Consistency with the Forest Plan and Other Direction Alternatives 2 and 3 are consistent with the Lolo Forest Plan, National Forest Management Act, and Forest Service directives. The project is consistent with the goals, objectives, and standards for soil resources set forth in the Lolo Forest Plan because project design criteria and Best Management Practices have been included to protect soil resources and limit the disturbance footprint; landscapes with sensitive soils would be protected; and land productivity would be maintained (Forest-wide standard 18, Forest Plan, page II-12). In addition, large wood levels have been considered as found in the Lolo National Forest Down Woody Material Guide (2006) and Graham et al. 1994. The Forest Soil Scientist has been involved in project planning and would be involved with the project through implementation by coordinating with other team members including silviculture and timber specialists to ensure the maintenance and enhancement of soil resources.
Forest Service Manual 2500-99-1 establishes guidelines that limit detrimental soil disturbance to no more than 15 percent of an activity area. All units would meet Region 1 soil quality standards following project implementation; this assessment is based on a consistency review completed for each unit that included harvest methods, landings, unit access, and remediation (see Appendix C). The winter logging requirement prescribed for specific tractor units is necessary to meet the Regional soil quality standards.
The National Forest Management Act (NFMA) requires that all lands be managed to ensure maintenance of long-term soil productivity, hydrologic function, and ecosystem health. All proposed activities are consistent with this direction; proposed activities would not result in irreversible damage to the soil resource as described above. 3.4 Hydrology
Issues Raised in Public Comment Salvage operations and associated temporary road construction could increase sediment delivery to streams and adversely affect fish and water quality.
Ground-disturbing activities associated with salvage operations (e.g. temporary road construction, log skidding/yarding, and log haul on roads) across multiple ownerships could yield sediment to area streams and cumulatively degrade water quality and aquatic habitat.
Approximately 111 miles of streams are located within the Copper King project area, but only about 29 miles (26 percent) are perennial (flow year round). A defining characteristic of the project area streams is that many are perennial in upper watershed areas, but intermittent by the time they reach the Thompson River. This stream channel intermittency is likely due to the underlying geology (Sando and Blasch 2015).
Watersheds used in the analysis are delineated along 7th level Hydrologic Unit Code (HUC) boundaries and include five 7th level HUCs (Table 3.4-1). The 7th level HUCs were drawn from three larger 6th level HUCs which cross the Thompson River.
64 Copper King Fire Salvage Environmental Assessment
Table 3.4-1: Project Area Watersheds by Ownership Seventh HUC Ownership (acres and percent) Total Watershed Forest Service Private State Weyerhaeuser (acres) Bay State Creek 3,088 (89%) 372 (11%) 3,460 Big Hole Creek 4,248 (53%) 373 (5%) 3,416 (43%) 8,037 Buckeye Canyon 5,741 (98%) 94 (2%) 5,835 Calico Creek 1,293 (21%) 1,055 (17%) 3,783 (62%) 6,131 Todd Creek 1,969 (26%) 1,067 (14%) 4,499 (60%) 7,535 TOTAL 16,339 (53%) 94 (<1%) 2,495 (8%) 12,070 (39%) 30,998
Bay State, Big Hole, and Buckeye Creeks are tributary to the Thompson River; and Todd Creek is tributary to Mudd Creek, which flows into the Little Thompson River. Calico Creek goes completely subsurface and does not contribute surface flows to the Thompson River.
Stream surveys and field reviews were completed in the project area during the fall of 2016. The fire burned at high severity in many of the riparian areas, which removed the vegetation and has resulted in a high potential for streambank erosion and instability. In addition, several localized hillslope debris flows were observed during the fall after rain events. Numerous studies have documented increased hillslope and sediment movement after high severity fires (Silins et al. 2009; Slesak et al. 2015; and Wagenbrenner et al. 2015). The Copper King BAER report (2016) estimates soil erosion potential in high severity burn areas as 6.1 tons/acre/year and sediment delivery potential to streams as 5 tons/acre/year based on modeling using Disturbed WEPP. Yields could be much higher if intense rainstorms (e.g. 10-year precipitation events) occur. The probability of erosion occurrence during the first year following the fire is 80 percent and the probability of sediment delivery is 90 percent. Generally, increased erosion due to wildfire occurs during the year following the fire, but as vegetation recolonizes sites, erosion stabilizes (Neary et al. 2005). With approximately 8,125 acres of high burn severity in project area watersheds (Table 3.4-2), the potential sediment delivery resulting from the Copper King Fire, particularly during the first year, is substantial.
Table 3.4-2: Burn Severity by Watershed Burn Severity (acres and percent) Total Watershed Unburned Low Moderate High (acres) Bay State Creek 485 (14%) 613 (18%) 1,112 (32%) 1,250 (36%) 3,460 Big Hole Creek 1,416 (18%) 1,599 (20%) 2,305 (29%) 2,717 (34%) 8,037 Buckeye Canyon 1,463 (25%) 2,090 (36%) 1,477 (25%) 805 (14%) 5,835 Calico Creek 2,474 (40%) 610 (10%) 1,067 (17%) 1,980 (32%) 6,131 Todd Creek 3,735 (50%) 1,025 (14%) 1,401 (19%) 1,373 (18%) 7,535 TOTAL 9,592 (31%) 5,938 (19%) 7,363 (24%) 8,125 (26%) 30,998
All of the streams in the project area have State of Montana B-1 classification standards. These waters are to be maintained suitable for drinking, culinary, and food processing purposes, after conventional treatment; bathing, swimming, and recreation; growth and propagation of salmonid fishes and associated aquatic life; waterfowl and furbearers; and agricultural and industrial water supply.
Section 17.30.623 of the Administrative Rules of Montana lists specific water quality standards that must be maintained for these waters. It is anticipated that project area streams will meet water quality standards in the post-fire environment. However, noteworthy is classification
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standard (2)(d) that states: “the maximum allowable increase above naturally occurring turbidity14 is five nephelometric turbidity units (NTUs)15 except as permitted.” Without measuring NTUs in the stream before the fire and during the next spring runoff, it is impossible to know if this measure would be exceeded. It is likely that in some locations in the project area, turbidity would be five NTUs above pre-fire conditions due to the amount of sediment delivery anticipated from high burn severity areas as discussed above. However, the fire is considered a natural event and the resultant increase in turbidity is also naturally occurring. Therefore, water quality standards would not be exceeded
The Little Thompson River, located just outside the northern boundary of the project area is listed as water quality impaired by the state of Montana. It is identified as not supporting for aquatic life and primary contact recreation due to alteration of streamside vegetation, nitrogen, phosphorus, and sedimentation/siltation. Probable sources of the impairment are listed as grazing, roads, and timber harvest in riparian zones. The 2014 Thompson Project Area Total Maximum Daily Load (TMDL16) is in place for this stream (MT DEQ 2014). No streams located within the project area are listed as water quality impaired by the State.
Alternative 1: Direct, Indirect, and Cumulative Effects
Alternative 1 would maintain existing conditions. Post-fire conditions would continue with widespread accelerated erosion and stream sedimentation, but would diminish over time. Research has shown that by the fourth year following a wildfire, fire-associated erosion is negligible (Elliot and Robichaud 2001).
Large woody debris would gradually begin to accumulate in streams as fire-killed trees eventually fall (Minshall et al. 1998). This has benefits for stream energy dissipation, sediment retention, and fish habitat. The fire will also create a short-term pulse of available nutrients into stream channels (Minshall et al. 1998). This results from nutrient mobilization in upland soils and would peak post fire and decrease to background levels within two years as revegetation occurs and nutrients become locked-up in plant biomass (Choromanska and Deluca 2002).
Ongoing BAER work (see Section 3.1) will improve drainage structures on roads to accommodate anticipated increased water flows in the first few years after the fire. These actions will reduce road-related sediment delivery in the post-fire environment.
Salvage operations would occur on other ownerships, which would likely increase sediment delivery to streams primarily during log haul on roads located within close proximity to streams. Effects would be short-term (lasting the duration of operations) and would not be expected to result in permanent impairment of water quality.
Alternatives 2 and 3: Direct and Indirect Effects
Alternatives 2 and 3 include resource protection measures (see Chapter 2) to minimize short-term
14 Turbidity is a key test of water quality and is caused by particles suspended or dissolved in water that scatter light making the water appear cloudy or murky. Particulate matter can include sediment (especially clay and silt), fine organic and inorganic matter, soluble colored organic compounds, algae, and other microscopic organisms. 15 NTU measures scattered light from the sample at a 90-degree angle from the incident light. 16 A TMDL is a pollutant budget identifying the maximum amount of a particular pollutant that a water body can assimilate without causing applicable water quality standards to be exceeded.
66 Copper King Fire Salvage Environmental Assessment effects of proposed activities to water resources.
Alternatives 2 and 3 would not create permanent or long-term unnatural stress on project area streams. All action alternatives would have no adverse effect to stream temperatures. None of the alternatives would measurably affect water yield. The fine sediment generated from implementing project activities (primarily from road use for haul) would be of relatively short duration occurring over a 2-year period distributed across multiple watersheds, and not continuous in nature. The magnitude of project-related short-term sediment delivery would be low compared to existing conditions in the post-fire environment. The intensity of the sediment effects would also be low based on the widespread nature of the actions in various tributaries and relatively small amounts of sediment delivered where they would occur. Thus, the sediment generated from the implementation of project activities would not adversely affect stream stability, substrates, or channel structure (Megahan and King 2004).
Temperature
Where the Copper King Fire removed the vegetation canopy in riparian areas, stream temperatures will likely be elevated until the shrubs and trees regenerate. Stream temperature is heavily influenced by solar radiation as a primary influence (Johnson 2004; Caissie 2006) and shade from overhead riparian canopy is the most effective variable to reduce radiant heat source (Krauskopf et al. 2010).
Alternatives 2 and 3 would not affect stream temperature. Riparian and streamside areas would be buffered to protect riparian habitat conservation areas (RHCAs)17 and no vegetation removal would occur in these areas except for incidental hazard tree removal where needed along Road #9991 [ACM road] (see Resource Protection Measures in Chapter 2). Road #9991 is located between the Thompson River and the hazard trees. Thus, these hazard trees provide little if any shade to the river as the primary shading is orographic (from the mountainous terrain).
Sediment
Salvage Harvest Alternatives 2 and 3 include approximately 1502 and 2312 acres, respectively, of salvage harvest. Table 3.4-3 displays the acres and percent of salvage by watershed. Most salvage operations would occur within the Bay State and Big Hole watersheds, but less than 15 percent of these watersheds would be affected under any alternative. In the other watersheds, salvage would occur on 6 percent or less of the area.
Table 3.4-3: Salvage by Watershed Logging System (acres) Total Roadside (acres and percent of Salvage Skyline/Excaline Tractor watershed) Watershed Alt 2 Alt 3 Alt 2 Alt 3 Alt 2 Alt 3 Alt 2 Alt 3 Bay State 25 25 235 253 135 135 395 (11%) 413 (12%) Big Hole 43 40 274 788 163 202 480 (6%) 1,030 (13%)
17 Riparian Habitat Conservation Areas (RHCAs) include traditional riparian corridors, wetlands, intermittent streams and other areas that help maintain the integrity of aquatic ecosystems by influencing the delivery of coarse sediment, organic matter, and woody debris to streams; providing root strength for channel stability; shading the stream; and protecting water quality (Naiman et al. 1992).
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Logging System (acres) Total Roadside (acres and percent of Salvage Skyline/Excaline Tractor watershed) Watershed Alt 2 Alt 3 Alt 2 Alt 3 Alt 2 Alt 3 Alt 2 Alt 3 Buckeye 89 89 24 24 86 84 199 (3%) 197 (3%) Calico 80 307 57 74 137 (2%) 381 (6%) Todd 135 135 156 156 291 (4%) 291 (4%) TOTAL 157 154 748 1,507 597 651 1,502 2,312
Studies of sediment production from post-fire salvage have had mixed results in discerning change in sedimentation directly attributed to the logging (Wagenbrenner et al. 2015). In the first one or two years after a high severity fire virtually the entire hillslope can generate large amounts of surface runoff and erosion given sufficient rainfall, and this tends to make the added impact of logging less pronounced in relative terms (ibid.). A study by McIver and McNeil (2006) in Northeast Oregon found widespread increases in soil disturbance from salvage tractor logging but most of the sediment transport was due to the pre-existing road system. McIver and McNeil (2006) attributed low-levels of hillslope sediment transport to: low-to-moderate slopes, erosion- resistant soils, logging on snow and dry ground, two years of recovery between the fire and logging, and the lack of severe rainstorms during the logging period. After an Arizona fire, there was found to be a 150-fold increase in sediment yield from the fire itself, but salvage logging did not have any detectable effect on sediment yields relative to unlogged areas (Stabenow et al. 2006).
On a watershed scale, effects from salvage logging are more difficult to determine. Seven watersheds were studied in the Canadian Rocky Mountains for increases in suspended sediment from burned areas that were salvage logged. Although more suspended sediment was found in the logged drainages, the differences were not statistically significant (Silins et al. 2009).
However, studies have measured increases in plot-scale sediment movement from tractor logging. Wagenbrenner and others (2015) found large increases in sediment production with increased ground disturbances from skidder equipment passes. They found an order of magnitude higher sediment production from skidder plots as opposed to control plots for study sites in northwest Montana. The authors suggest that sediment production after post-fire salvage logging is a function of several interacting factors, but for a given location and rainfall intensity, the key concerns are the amount of soil compaction and loss of surface cover. They recommend: conducting tractor logging over snow or when soils are dry to minimize compaction; reducing runoff and erosion from skid trails; and reducing the delivery of runoff and sediment from skid trails to streams.
Salvage operations in Alternatives 2 and 3 have a potential to increase sediment delivery to streams in the post-fire environment, although the footprint of operations would be relatively small (from 2 to 13 percent of project area watersheds, see Table 3.4-3). The risk would be higher in Alternative 3 because more acres would be salvaged. However, resource protection measures (see Chapter 2) would be applied to incorporate the recommendations from the scientific literature described above and reduce sediment risk from salvage harvest. In Alternatives 2 and 3, tractor logging would be required during the winter over frozen ground and/or snow on approximately 233 and 269 acres (about 40 percent of the tractor units), respectively; and on dry soil during the summer on 364 and 382 acres, respectively. The remainder of the salvage operations would be conducted via skyline yarding in which cut trees would be transported uphill on a suspended cable to the road. Because no mechanized equipment
68 Copper King Fire Salvage Environmental Assessment operates off road in skyline units and the logs are suspended above the ground, soil compaction is generally not a concern. Therefore, these project designs would minimize soil compaction.
In addition, slash would be placed over skid trails to reduce erosion potential. Because the fire reduced the natural vegetative filtering capability of riparian areas, standard RHCA widths would be expanded by an additional 50 feet to allow for more sediment buffering capacity (see Resource Protection Measures in Chapter 2). These expanded buffers would reduce the potential for sediment delivery from salvage harvest units to streams.
Roads Potential sediment delivery from roads used for log haul was evaluated using three methods: road encroachment, stream crossings, and sediment modeling.
Road encroachment or proximity to water bodies is an indicator of a road’s potential to deliver sediment. Roads within 300 feet of a water body are the most probable to deliver sediment (Belt et al. 1992). Monitoring conducted within a research area found that roads within 10 meters (33 feet) of streams delivered 74 percent of the road sediment (Cissel et al. 2013). Roads within 100 and 300 feet of streams were evaluated by the Forest Service (USDA Forest Service 2000) and found to affect sediment delivery, stream dynamics, large woody debris recruitment, and aquatic habitat. Road/stream crossings have a high potential to deliver sediment directly into streams.
Sediment delivery to streams from existing roads and from project-related road activities was modeled using the Roaded WEPP module of the Water Erosion Prediction Project (WEPP). Project road-related activities that have the potential to alter fine sediment (6 millimeter-size fractions or smaller) delivery to streams include temporary road construction, road maintenance, and use for log haul. The tons/year per watershed metric is the primary measurement of road impacts in the project area. All roads within 300 feet of stream channels were modelled for sediment delivery.
Sediment modeling was used as a means to compare alternatives. The WEPP model has a standard error of 50 percent from the mean, which is typical of many sediment models. Sediment delivery estimates use annual precipitation averages, which in any given year and specific location vary because of differences in site conditions and the precipitation regime. Although quantitative values for sediment are generated from the model, results are used for trend and magnitude comparisons and should not be considered absolute values.
Road Maintenance and Use Under Alternatives 2 and 3, maintenance would be conducted on 90 and 105 miles, respectively, of roads prior to their use for haul activities. Activities would include roadside clearing and/or brushing, road surface blading and reshaping, road drainage maintenance and improvement, and dust abatement (Road #9991 [ACM road]). These actions would be conducted in addition to the ongoing BAER work to upsize at-risk culverts and storm-proof roads to accommodate anticipated increased water flow in the post-fire environment.
Maintenance activities would improve and/or maintain the drainage on roads used for haul because improving and maintaining road drainage is an effective way to reduce road-related sediment production from existing roads (Coe 2006, MacDonald and Coe 2007, USEPA 2005, NCASI 2012). Road drainage structures are used to disconnect road segments from the stream channel network (Coe 2006). Drainage structures installed at appropriate intervals remove storm water from the roadbed before the flow gains enough volume and velocity to erode the surface. Appropriately spaced structures also reduce the downslope transport distance of material off the
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road surface (Coe 2006, Luce and Black 1999). The proper placement of structures routes the discharge onto the forest floor so that the water disperses and infiltrates before reaching a stream (Croke and Hairsine 2006, Woods et al. 2006, Sugden and Woods 2007, Packer 1967).
Resource protection measures (see Chapter 2) would also be applied to reduce sediment delivery from roads to streams. Slash filter windrows would be installed at all stream crossings on haul routes and where sediment delivery points are identified along road segments within 300 feet of streams. Slash filter windrows effectively decrease the runoff velocity, trap sediment, and reduce sediment transport distance below the road fill slope. Studies conducted in Idaho showed windrows trapped from 75 to 100 percent of the sediment off the road (Cook and King 1983; Burroughs and King 1985; Seyedbagheri 1996). Erosion control measures such as straw bales, wattles, and silt fences would be installed at relief culvert or drainage dip outlets within 300 feet of streams. A recent research review by Edwards and others (2016) found that silt fences can retain between 16-95 percent of sediment on roads. They also found that other barriers such as straw bales, fiber logs, wattles, and rock check dams can retain between 20 and 95 percent of road sediment (Edwards et al. 2016).
Disturbed areas would also receive appropriate seeding and mulching and/or slash placement. Ground cover such as vegetation, slash, and mulch absorb raindrop impact to reduce soil detachment. These and other erosion control measures are used to slow the flow of water over land to prevent rill and gully erosion and help to filter out soil particles. Broz et al. (2003) report the effectiveness of these erosion control practices as being 50 percent or more. Other studies report higher levels of effectiveness (summarized in USEPA 2005).
Prior to haul, in addition to addressing identified contributing sediment sources, dust abatement would be applied to Road #9991 [ACM road], which is located adjacent to the Thompson River. Sediment production from forest roads occurs during the dry months in the form of dust created primarily from traffic. To prevent loss of road surface fines as airborne dust or sediment, dust abatement is applied to hold the fine material to the road surface. The Lolo National Forest typically uses chloride-based dust control agents (calcium or magnesium chloride), which increase the moisture content of the road surface by attracting moisture from the atmosphere. These dust control materials retard the evaporation of moisture and tighten the compacted soil, which strengthens and hardens the road surface. A hardened road surface reduces the need for routine maintenance such as blading (USDA Forest Service 1999, Han 1992). The dust control effectiveness of these chemical palliatives generally lasts 6-12 months (Han 1992). Sanders et al. (1997) reported that chloride-based dust control agents reduced sediment loss from unpaved roads by 55 to 66 percent.
Increased haul on roads that cross streams and/or are in close proximity to streams would result in short-term sediment delivery into waterways during project implementation. Alternative 3 would yield more sediment than Alternative 2 because more roads (including temporary roads) would be used (see Tables 3.4-4 and 3.4-5), although the difference is not considered substantial. As discussed above, resource protection measures would be applied to reduce stream sedimentation. Sediment delivery would cause temporary localized increases in turbidity immediately downstream from delivery points. However, sediment delivery resulting from road use would be relatively modest compared to the anticipated sediment contributions from fire-related hillslope erosion that is likely to occur during the first few years after the fire, as discussed above. There would be no permanent degradation of water quality from road-related activities or salvage operations.
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Table 3.4-4 displays the haul routes within 300 feet of streams and the number of stream crossing by watershed. Alternative 3 has more haul miles and routes with stream crossings than Alternative 2. The Big Hole watershed, which is the largest, has the most miles of and stream crossings on haul routes. This would indicate that more sediment delivery would likely occur in Big Hole compared to the other watersheds. The WEPP modeling indicated the same results (Table 3.4-5).
Table 3.4-4: Haul Routes by Watershed (includes temporary roads) Haul Road Miles within 300 Number of Road/Stream Haul Route Miles feet of Streams Crossings Watershed Alternative 2 Alternative 3 Alternative 2 Alternative 3 Alternative 2 Alternative 3 Bay State 8.1 8.1 3.2 3.2 6 6 Big Hole 35.0 41.6 11.9 13.7 46 55 Buckeye 8.2 8.2 5.9 5.9 6 6 Calico 13.1 21.2 6.3 7.9 5 14 Todd 20.9 21.5 7.3 7.3 12 12 TOTAL 85.3 100.6 34.7 38.0 75 93
Table 3.4-5: Modeled Sediment Delivery from Haul Routes by Watershed Modeled Road Sediment from Haul (Tons/Year)* Little Thompson Bay State Big Hole Buckeye Calico Todd River1 Current Conditions 2.5 11.5 5.3 12.1 23.0 1.1 Alternative 2 3.4 17.4 8.1 14.6 24.2 2.0 Alternative 3 3.4 18.4 8.1 15.9 24.2 2.0 Post-Implementation 1.2 4.7 2.7 5.5 9.4 1.1 *Includes temporary roads and the application of resource protection measures. To be conservative, the lower end of the range in slash filter windrow effectiveness identified in the scientific literature (discussed above) was used in this analysis. The table reflects a 75 percent reduction of the modeled road sediment at stream crossings due to the required installation of slash filter windrows 1Reflects haul on County road 7512.
The assumptions used in the WEPP model considered the current substantially natural reduced filtering capacity of the watersheds from the loss of vegetation caused by the Copper King Fire. This is why the sediment quantities in Table 3.4-5 are much higher for current conditions compared to post-implementation. Post-implementation is considered to be after widespread vegetative recovery occurs, including in the road ditches and in the stream buffers, which will capture sediment coming off of roadbeds. The post-implementation timeline displayed in the table would likely be four years after the fire or 1-2 years after completion of the project (Elliot and Robichaud 2001).
Modeling estimates that a relatively small amount of sediment would be delivered to the Little Thompson River from hauling activities on County road 7512 (Table 3.4-5). However, it would unlikely be discernable from the effects of all the other traffic the road receives.
Sediment modeling results for Alternatives 2 and 3 are somewhat misleading because they imply that all activities would take place at once. Short-term sediment deliveries would not result in detrimental stream conditions because:
All actions would not simultaneously occur.
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Impacts would not occur within a single year, but would be dispersed over multiple runoff cycles.
Work and total predicted sediment quantities are localized and distributed across multiple watersheds.
The higher risk period for hauling is in the spring during breakup, which occurs at slightly different time periods due to elevation and aspect so only sections of road are at risk from breakup conditions at any one time.
The risk of haul-related sedimentation occurring for more than a few days is very small because operations are suspended when hauling conditions would severely rut road surfaces.
After implementation of the project, resource protection measures that would be implemented for haul activities (primarily installation of additional road drainage) would stay in place. These drainage structures would create shorter flow lengths for water running along roadbeds and therefore less overall sediment generated into streams after project implementation. The strategically placed slash filter windrows would also help decrease the delivery of fine sediment from road surfaces to streams for a few years after the project was completed. Burroughs and King (1985) reported that slash filter windrows were still effective 7 years after installation.
Temporary Road Construction In Alternatives 2 and 3, approximately 3 and 7.3 miles, respectively, of temporary roads would be constructed and used for the project, then obliterated after activities were completed (Table 3.4- 6). Because Alternative 3 contains more miles of temporary roads within 300 feet of streams and more stream crossings, more sediment delivery would be expected compared to Alternative 2, although the magnitude would be relatively small (Table 3.4-7).
Table 3.4-6: Temporary Road Construction by Watershed Miles Temporary Road Number of Temporary Road Miles Temporary Road within 300 feet of Streams Stream Crossings Watershed Alternative 2 Alternative 3 Alternative 2 Alternative 3 Alternative 2 Alternative 3 Bay State 0.72 0.72 0.06 0.06 1 1 Big Hole 0.75 3.78 0.06 0.36 3 Calico 0.98 2.28 0.16 1 Todd 0.51 0.51 TOTAL 2.97 7.29 0.12 0.58 1 4
Table 3.4-7 displays the breakout of modeled sediment delivery from haul on temporary roads. To provide context for the magnitude shown in Table 3.4-7, one ton of sediment (specific weight of 120 lbs/ft3) equates to 1.6 cubic yards (2-3 standard-sized wheel barrow loads). The disturbance from the temporary road construction would likely create an initial small pulse of sediment into the stream systems. This would be a one-time pulse during the construction period that would likely be equal to the tons/year modeled for use displayed in Table 3.4-7. As with other road activities, erosion control measures would be in place to mitigate stream sedimentation. Roads would also be constructed during the dry season to reduce erosion (see Resource Protection Measures in Chapter 2).
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Table 3.4-7: Modeled Sediment Contribution from Temporary Roads Modeled Sediment (Tons/Year)* Watershed Alternative 2 Alternative 3 Bay State 0.13 0.13 Big Hole 0.08 0.61 Calico 0 0.26 TOTAL 0.21 1 * Reflects sediment produced from haul only
Water Yield
Water yield is typically analyzed using the Equivalent Clearcut Area (ECA) model, a common indicator of cumulative watershed effects used to measure the relative loss and recovery of hydrologic function for a forest canopy in areas with snowmelt-dominated runoff (Ager and Clifton 2005). Forest canopy intercepts precipitation and affects snow accumulation and melt, sublimation, evapotranspiration, and temperature moderation (Lewis and Huggard 2010). Any activity or natural event that alters the forest canopy has the potential to affect snow accumulation and ablation and subsequent stream runoff timing and magnitude (Grant et al. 2008). When stream flows are higher than those in which the stream evolved for long durations, stream channels may be altered. This creates the potential for bank scour, erosion, and subsequent increases in bedload deposition.
For the Copper King project, ECA was not used to assess water yield potential and effects because the fire removed the vegetation canopy in large portions of the project area (Table 3.4-2). All project watersheds are above the ECA threshold due to the fire.
Alternatives 2 and 3 would harvest dead trees, which no longer uptake and store water. Most units are located in the moderate to high severity burn areas where the tree canopy was removed by the fire. Although it is unlikely that removal of dead and dying trees would affect runoff, the potential soil compaction from skid trails and temporary road construction would create less soil water holding capacity and could lead to increased overland flow and runoff (Wemple and Jones 2003). However, detrimental soil disturbance, of which compaction is a subset, is predicted to be relatively small compared to the operational footprint of the salvage activities for both Alternatives 2 and 3 due to applied resource protection measures (see Soil section 3.3). In the context of the anticipated widespread increases in runoff from the fire, it is unlikely that the temporary road construction or skidding activities would result in additional measurable increases to water yield (Grant et al. 2008).
Cumulative Effects
The streams and riparian areas within the project area are largely impacted by the Copper King Fire. These streams show signs of streambank instability and will likely experience adjustments in the post-fire runoffs for the next 2-3 years. However, Alternatives 2 and 3 would not affect stream stability and streambank erosion because project activities would not measurably increase water yield and the amount of sediment contributed primarily from road use would be relatively low especially compared to that anticipated from hillslope erosion caused by the fire over the next few years.
BAER work was completed in the fall and will resume this summer on roads to address the anticipated increased water flow rates caused by the fire. These actions would reduce potential sediment delivery from roads while the burned area recovers.
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Work includes: Road surface storm proofing and drainage maintenance (40 miles)
Culvert and road fill removal on draw and stream crossings (12 locations)
Culvert replacement (upsizing) on minor draws (8 locations)
Culvert replacement (upsizing) on major draws (6 locations)
Culvert replacement (upsizing) on stream crossings (6 locations)
The six culvert replacements on live streams would occur during July and August in 2017. These actions would result in short-term sediment inputs to affected streams. Monitoring on the Bitterroot National Forest (Jakober 2002) showed that culvert removals generally produced between 2.5 to 5 tons of sediment delivery each. Lolo National Forest monitoring found 1 to 2.5 tons of sediment production for every 500 cubic yards of fill volume (Casselli et al. 1999). Research has shown that this process happens quickly, with 95 percent of the sediment produced occurring within 23 hours (Foltz et al. 2008). The amount of sediment and time it takes to enter the channel can vary depending upon several factors including stream flow, weather (rainy or dry), and mitigation. Foltz et al. (2008) also found that there were no measureable sediment levels at an average of 810 meters (2,656 feet) downstream.
Therefore, it is assumed that the culvert removals would release 2.5 tons of sediment each into their respective streams. It is assumed that the effects of this sedimentation would not be measurable beyond 0.25 mile downstream from the culvert (1,320 feet). These effects would last for approximately 24 hours. These assumptions are consistent with monitoring on the Lolo National Forest and previous sediment analysis from similar projects. Culvert work will occur during low flow at the dry time of year (July-August).
After the initial sediment pulse from crossing removal/replacement, vegetation would reestablish within 1-2 growing seasons and the chronic, yearly sediment source would be eliminated. Also, after some initial stream instability from culvert removal, streams would stabilize after a few bankfull runoff events. Overall, culvert work would have long-term benefits of improved stream stability and reductions in road-related sediment. In addition, the potential that these replaced culverts would fail during future storm events will be significantly reduced.
Salvage Operations on Other Ownerships Weyerhaeuser salvage operations include approximately 1,883 acres. Most activities were completed in the fall and winter of 2016 and the rest will be completed during the summer of 2017. The majority of the acres of Weyerhaeuser salvage are in the Big Hole watershed and the rest are in the Calico watershed. Although the haul routes for the Weyerhaeuser activities were not disclosed, it is estimated from modeling that there was likely 14.6 tons/year of sediment delivered to stream channels in the Big Hole Creek watershed and 9.5 tons/year of sediment into creeks in the Calico Creek watershed over and above the amount shown in Table 3.4-5 for current conditions. Some of the Weyerhaeuser haul occurred in the fall during wet weather and resource protection measures that are included in the Forest Service Copper King project (e.g. slash filter windrows and other erosion control devices) were not applied.
This does not necessarily mean that the sediment modeled for Alternatives 2 and 3 (shown in Table 3.4-5) would be additive to the Weyerhaeuser modeled sediment. Most likely, any sediment that entered stream channels from Weyerhaeuser activities will be flushed through the
74 Copper King Fire Salvage Environmental Assessment system by the spring 2017 runoff. This will be the first snowmelt since the fire and will have increased discharge to flush excess sediment through the system. By the time Forest Service salvage operations were to take place, stream levels would come down and stabilize. While some additional salvage may occur on Weyerhaeuser lands in summer 2017, haul would likely (at least in part) occur on roads to be used by the Forest Service. Increased use on overlapping routes has been already accounted for in the evaluation of sediment delivery from haul routes (Table 3.4-5) and would not be additive. In addition, the Forest Service would have already completed maintenance activities on overlapping routes before haul activities begin. If use of other routes by Weyerhaeuser occurs near streams, additional sediment could be contributed to affected watersheds, but the quantity would likely be low.
The Montana DNRC also plans approximately 1,095 acres of salvage on State land. Of this harvest, 238 acres are in the Big Hole Creek watershed, 550 acres are in the Calico Creek watershed, and 307 acres in the Todd Creek watershed.
The Montana DNRC provided the Forest Service with a map of haul routes that will be used. Many of the routes to be used by the State are the same as those that would be used by the Forest Service and are modeled for sediment delivery in Table 3.4-5. At this time, it is expected that Montana DNRC operations would likely occur concurrently with those of the Forest Service. Therefore salvage operations would overlap in time and some of the haul would overlap in space (location). Maintenance activities and resource protection measures would be applied to roads before haul begins.
In addition to the overlapping use of roads, the Montana DNRC plans to haul on 2.8 miles of additional roads that are within 300 feet of mapped streams. These road miles, as well as the number of crossings and modeled sediment delivery to stream channels from them are displayed in Table 3.4-8 below. Because the Montana DNRC would use many of the same routes as the Forest Service, there would be no additional sediment delivery from those roads beyond what is already displayed in Table 3.4-5 because the model already accounts for an increase in road use. The Montana DNRC’s use of 2.8 miles of additional roads would contribute additional sediment in the Big Hole, Calico, and Todd Creek watersheds, but cumulatively, would likely be negligible considering the size of the watersheds and the application of BMPs before haul.
Table 3.4-8: DNRC Proposed Haul Route by Watershed Cumulative Modeled Existing Modeled Current Conditions Sediment from Forest Service 1 Road Stream Sediment Modeled Sediment and DNRC Haul (tons/year) Watershed Miles Crossings (tons/year) (tons/year) Alternative 2 Alternative 3 Big Hole 1.22 6 1.4 11.5 18.8 19.8 Calico 0.74 2 0.9 12.1 15.5 16.8 Todd 0.83 1 1.1 23 25.3 25.3 1Reflects the addition of modeled sediment quantities from Forest Service haul for the Copper King project shown in Table 3.4-4 to the modeled sediment from DNRC haul routes displayed in this table.
In addition to the haul routes, there is a risk of sediment delivery from the harvest activities on other ownerships, but this has not been measured or verified by relevant research. Both Weyerhaeuser and the Montana DNRC buffer streams from harvest activities through the use of the streamside management zones (SMZs). SMZs are narrower than the riparian habitat conservation areas that would be applied in Alternatives 2 and 3. Therefore the risk of sediment
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delivery from harvest on other ownerships is higher than that for Alternatives 2 and 3, but the effects have not been documented in the scientific literature as described above.
Regulatory and Forest Plan Consistency
Alternatives 2 and 3 are consistent with the Lolo Forest Plan:
Best management practices have been incorporated into all action alternatives and would be applied to assure that water quality is maintained at a level that is adequate for the protection and use of the National Forest and that meets or exceeds Federal and State standards (Forest-wide standard 15, Forest Plan, page II-12)
Project-related increases in water yield would be limited so channel damage would not occur as a result of land management activities (Forest-wide standard 19, Forest Plan, page II-12)
All alternatives were designed to have minimum impacts on the aquatic ecosystem and would not cause permanent or long-term unnatural stress. Channel structure would not be adversely affected. Intragravel sediment accumulations could be affected in low gradient reaches where some of the fine sediment generated from project activities could temporarily deposit in the bottom of pools or behind woody debris downstream of delivery points until flushed out by high spring flows. However, effects would be temporary (i.e. likely less than one year) because of transport dominated stream channel types, the relatively short duration of the activities, and low magnitude and intensity of project-generated sediment. (Forest-wide standard 28, Forest Plan, page II-14)
All action alternatives would be consistent with all other regulatory standards and guidelines.
Thompson River Project Area TMDL (2014) The Little Thompson River is the only TMDL listed stream that would potentially be affected by the project. Actions in the Little Thompson River 6th HUC watershed include only log haul on County road #7512, which is a gravel road open to all traffic. No other activities would occur in the Little Thompson watershed. Although salvage and haul activities would occur in Todd Creek, which is a tributary to Mudd Creek, which is in turn a tributary to the Little Thompson River. As previously described, resource protection measures (Chapter 2) would be applied to Alternatives 2 and 3 to minimize sediment delivery to Todd Creek and any potential short-term effects to the Little Thompson River. 3.5 Fisheries
Issues Raised in Public Comment Salvage operations and associated temporary road construction could increase sediment delivery to streams and adversely affect fish and water quality.
Ground-disturbing activities associated with salvage operations (e.g. temporary road construction, log skidding/yarding, and log haul on roads) across multiple ownerships could yield sediment to area streams and cumulatively degrade water quality and aquatic habitat.
The Copper King Salvage project area contains naturally reproducing native salmonids including westslope cutthroat trout, bull trout, and mountain whitefish. Other natives include species from
76 Copper King Fire Salvage Environmental Assessment the sucker and sculpin families. Nonnative fish within the project area include brook trout, brown trout, and rainbow trout.
Westslope cutthroat trout is a designated Forest Service, Region 1 sensitive species, which indicates viability of the species is a concern. The Lolo Forest Plan (USDA Forest Service 1986) requires the National Forest to manage for sensitive species such that they do not become listed under the Endangered Species Act (ESA). Bull trout were listed as a threatened species under ESA in 1999 and in September 2010 the U.S. Fish and Wildlife Service updated and designated critical habitat for bull trout throughout their U.S. range. The Thompson River is designated bull trout critical habitat, which serves as migration corridor for bull trout that spawn in tributaries outside the Copper King project area.
Fish presence and absence data for many of the project area tributaries is lacking or incomplete. Thompson River and Little Thompson River have the most available data and survey information, while Bay State, Big Hole, Calico and Todd/Mudd Creek have few if any past comprehensive surveys. To help inform the probability of fish within these tributaries, the Climate Shield Cold- Water Habitat for Juvenile Cutthroat Trout, and Bull Trout model (Isaak et al. 2015) was used as the best available science to determine bull trout and westslope cutthroat trout presence, without having stream specific survey information. This model uses stream slope and expected temperatures to estimate the probability of fish presence. The model, combined with knowledge of habitat conditions and barriers in the systems, were used to assess fish presence in area tributaries. Except for the Thompson River, bull trout are likely absent from project area streams and the Little Thompson River. Other native fish, including westslope cutthroat trout, and non- native fish are known to be present in the Thompson, Little Thompson River, Todd Creek and Mudd Creek. Based on modeling results, westslope cutthroat trout are assumed to be present within Calico, Big Hole, and Bay State Creeks.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would maintain the existing condition resulting from the Copper King Fire and the existing road system. Fish habitat in the project area would remain in a state of flux over the next 1-5 years as stream channels adjust from the recent fire effects. Fish populations would be under stress due to increased sedimentation, temperatures, and stream channel changes until the landscape stabilizes and revegetates.
Woody debris recruitment to stream channels would continue to occur from natural causes, such as bank erosion, windthrow, and disease. It is expected that there would be a substantial increase in large woody debris recruitment in the next 1-5 years as fire-killed trees within the riparian areas begin to fall over. Large woody debris is one of the most important influences to overall stream health in the aquatic ecosystem (Riggers et al. 1998). It is extremely important in developing complex and stable stream habitats and habitat for multiple life stages of native salmonids, including over-wintering habitat. It provides direct habitat components such as cover, shade, and low velocity holding water, and also significantly influences the formation and maintenance of pool habitat. Large woody debris is often the dominant pool creator in streams on the Lolo National Forest.
Stream temperatures would increase naturally where the vegetation canopy that once provided adequate stream shading was removed by the Copper King Fire. Once vegetation re-establishes in riparian areas to the point of providing adequate shade to stream channels, temperatures would moderate. Stream temperature is an important indicator of fish habitat condition. Water temperature can impact the growth and survival of cold water species such as trout. In streams
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where the daily maximum temperature is too high during the summer rearing period there may be a limitation in native fish production. Sullivan et al. (1990) reported that elevation and riparian canopy density were the primary factors affecting stream temperature, explaining more than 80 percent of the variability in maximum annual stream temperature. The upper incipient lethal temperature for westslope cutthroat trout is around 19.6ºC, while optimum growth temperature is approximately 13.6ºC (Bear 2005). Because fish are cold-blooded, temperature plays a key role in regulating metabolism. If temperature increases above a suboptimal threshold, the feeding rate declines and is completely inhibited several degrees below the lethal temperature (Sullivan et al. 2000).
Although storm-proofing of 40 miles of road will be conducted under BAER to address anticipated high water flows in the post-fire environment, existing roads within close proximity to streams would continue to be a source of sediment to streams. Within the high severity burn areas where vegetation and soil duff layers have been removed by the fire, it is anticipated that soil erosion rates will be elevated over the next few years, contributing sediment to area streams (see Hydrology section). High levels of fine sediment that settle on the bottom of streams can negatively impact fish spawning success by smothering eggs and reduce the quality and quantity of juvenile rearing habitat available (Weaver and Fraley 1991). High levels of surface fines can also negatively impact aquatic macro invertebrates, resulting in a decreased or less accessible food base for native salmonids.
Salvage operations will occur on other ownerships, which would likely increase sediment delivery to streams primarily during log haul on roads located within close proximity to streams. Effects would be short-term (lasting the duration of operations).
Alternatives 2 and 3: Direct and Indirect Effects Similar to Alternative 1, fish habitat in the project area will remain in a state of flux over the next 1-5 years as stream channels adjust from fire effects. Fish populations will be under stress due to increased sedimentation, temperatures, and stream channel changes until the landscape stabilizes and revegetates. The habitat parameter that has a potential to be affected by project activities is sediment (and habitat elements that are associated with sediment such as substrate embeddedness, pools quality and quantity, etc.), primarily from road-related activities. As discussed in the Hydrology section, stream temperature would not be affected by project activities. Large woody debris recruitment to streams would also not be affected because trees that have the potential to fall into streams would not be removed.
The hydrology analysis determined that Alternatives 2 and 3 would result in short-term, road- related sediment increases during the life of the project, primarily from road use for hauling activities (see Hydrology section). Alternative 3 has a greater risk of sedimentation compared to Alternative 2 because more haul would occur and more temporary roads would be constructed, particularly on steep slopes.
Fine sediments are most likely to be transported to stream channels through road ditch lines or from road surfaces during wet weather periods. Some sediment would enter streams, especially after significant rain storms and during heavy levels of timber haul. This road surface-derived sediment delivery generally occurs where roads are either close to or cross intersecting streams. Fine sediment that may reach the stream network would likely remain in suspension, move rapidly through the system, and be diluted by any measurable stream flows. Increases in fine sediment delivered to streams could temporarily disrupt fish foraging and feeding behavior,
78 Copper King Fire Salvage Environmental Assessment particularly for species that feed by sight. Sediment inputs would be in discrete locations and fish would likely avoid these areas temporarily. Effects would not be lethal.
In Alternatives 2 and 3, road surfaces and drainage would be improved to decrease the erosion potential and intercept road ditch line water that shows signs of turbidity. Roads used for haul would have resource protection measures (best management practices) installed before timber haul use. BMPs include adequate road surface and ditch drainage, functioning ditches, adequate spacing of drain dips or ditch relief culverts, leadouts or drainage structures before stream crossings, road shaping to shed water off the surface and not into streams, installation of slash filter windrows at drainage outlets to limit sediment movement, and graveling of areas where drainage treatments may not be fully effective due to stream proximity (see Chapter 2). Implementation of road BMP treatments would occur between May 15 and October 15, during dry weather periods. Roads identified for these treatments include those that have the most potential to affect fish bearing streams, and where roads encroach within the 300 feet of streams. Within the project area, haul routes identified in Table 3.5-1, would be given special attention to ensure BMP applications are sufficient and effective. It is these roads that are of most concern as they are either close (within approximately 300 feet) to project area streams or they contain many stream crossings.
Table 3.5-1: Roads where BMP applications are focused to protect fisheries Road # Affected Stream 887 Todd Creek 7575 Mudd Creek 875 Multiple tributaries draining to Thompson River 894 Multiple tributaries draining to Thompson River 48073 Tributaries draining to Thompson River 18393 Big Hole Creek 9991 (ACM) Thompson River
Haul on Road #9991, along Thompson River, poses one of the greater risks to bull trout, because of the proximity of the road to designated critical habitat. Resource protection measures such as dust abatement during the summer, and spot treatments to address existing contributing sediment sources would minimize sediment delivery. In context, with existing public traffic on this road and stream channel adjustments to post-fire conditions, sediment generated from haul or potentially from salvage harvest (see Hydrology section) would have little effect to Thompson River fish or fish habitats.
Alternatives 2 and 3 include 3 and 7.3 miles, respectively, of temporary road construction. Following use for this project, temporary roads would be obliterated. Table 3.5-2 summarizes temporary road construction and describes the features that could affect riparian habitat conservation areas and fisheries. The potential negative effects from temporary roads identified in Table 3.5-2 are related to stream or swale crossings and/or road features that could deliver sediment to streams. Swales rarely contain water, but are features on the landscape that could convey water to streamcourses during episodic events of moisture or snowmelt. In the high burn severity environment, swales are expected to more frequently carry water than in a fully vegetated landscape.
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Table 3.5-2: Potential Risks of Temporary Road Construction to Fisheries Number of stream Risk of Length or swale Delivering Road # Alternative (miles) crossings Description Sediment1 Parallels head of a draw, high severity burn area, steep slopes; Calico Creek 7575ext 2 & 3 0.42 1 directly below M 18808ext Swale crossing; head of draw; high 3 0.55 1 severity burn area M No effect; near top of ridge; no swale 18808ext 2 0.17 0 crossings; short extension L 894ext 2 & 3 0.18 0 No effect - no swale crossings L Drainage crossing; high road densities below drainage crossing; high/mod 48073ext 2 & 3 0.28 1 burn severity M Stream crossing; lengthens 48073; 48073ext 3 0.19 1 drains into Big Hole Creek H 16044ext 2 & 3 0.13 0 No effect; top of ridge L Takes off near head of drainage, high 18828ext 2 & 3 0.39 0 severity burn L 875ext 2 & 3 0.13 0 No effect, top of ridge L Crosses drainages, recent signs of downcutting and drainage failures 45005- without temp road; drains both Todd Aext 2 & 3 0.58 2 and Calico Creeks. H 45005- Head of drainages that lead into Calico Aext2 2 & 3 0.36 0 Creek; high burn severity M Stream crossing (or one used to access road); high and mod burn severity; 18832ext 2 & 3 0.33 1 drains into Bay State Creek. H Multiple stream and swale crossings, 18809ext 3 0.69 2 steep; midslope; drains to Big Hole Cr. H Multiple stream crossings, steep midslope; low, moderate, and high burn 18780ext 3 1.6 3 severity; drains into Big Hole Creek. H H - Very Crossing on unstable stream, steep, high 48117ext 3 0.23 1 lower midslope; high burn intensity probability Drainage crossings; steep midslope road, high intensity burn; drains into 17003ext 3 0.61 2 Calico Creek. H 45008- Eext 3 0.26 0 No effect; high burn intensity L 45008- Crosses at top of drainage; high burn Cext 3 0.20 0 intensity; drains into Calico Creek. L 1L=Low; M=Moderate; H=High
With application of BMPs, sediment contribution from the stream crossings on temporary roads would be minimized to a few cubic yards associated with crossing installation. The amount of sediment mobilized during actual project activities would be small and transport would be limited. Duncan et al. (1987) demonstrated that even fine sediments produced from road surfaces settle out rapidly and were stored in small mountain stream channels. Less than 50 percent of sediments traveled further than approximately 310-410 feet.
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Road construction across drainages and in steep slopes in high severity burn areas increases the risk of erosion that generate sediment which could then travel much longer distances. Since these roads are all temporary in nature and would be fully recontoured once harvest operations were complete, they would not be on the landscape for an extended period of time. This reduces the overall long-term risk of erosion and sediment production. Still, storm intensity and weather patterns would greatly influence the chance of temporary road failures.
Sediment generated from use (haul) of these temporary roads would not be significant by the time it reached fish bearing streams, and would have no measurable effect on fish. BMP applications near stream crossings would limit sediment delivery during use of the roads and BMPs would remain in place until the road was obliterated.
Planting tree seedlings on approximately 6000 within the burned area would assist in the natural recovery from the Copper King Fire. Slope and soil stability would improve and sedimentation into streams would decrease as both planting and natural regeneration occurs. There would be no measurable direct effects to fish or fish habitat. Over the long-term (~5+ years), reforestation would provide minor benefits due to increased soil filtering capabilities, and when adjacent to streams, improved canopy cover to reduce solar radiation and stream temperatures.
Cumulative Effects Watersheds in the project area have been impacted from past actions such as timber harvest, fire, road development and use within and near riparian areas, and cattle grazing along the Little Thompson River. Overall, these activities have caused an increase in sedimentation, which has led to a loss of quality habitat and spawning areas for trout. Also, there has been a loss of large woody debris in these streams, which has led to a decline in quality fish habitat. Grazing on private land has also reduced riparian vegetation and bank stability along the Little Thompson River.
Present and future actions include road maintenance, continued grazing on private and State lands, BAER road work, and Montana DNRC and Weyerhaeuser salvage harvest. Compared to past disturbances, watersheds in the project area are not as detrimentally impacted as they were in the 1900s because of a decline in land management activities. For example, most of the timber harvest and associated road construction on National Forest System lands occurred in the 1960s and 1970s. The last timber harvest and associated road construction on National Forest System lands within the project area was completed in 1995, over 20 years ago. There are still some cumulative adverse impacts to streams from past and present activities associated with the road infrastructure (channel instability, increased sediment levels, and reduced quality of aquatic habitat).
One of the primary goals of BAER work is to stabilize the road and trail systems and their drainage structures to prevent damage from soil erosion and storm water run-off. This work will temporarily increase sediment delivery to streams particularly during culvert replacement activities on live streams (see Hydrology section). Ultimately it will reduce the risk of sediment reaching the streams over the longer term and could off-set some of the potential for road-related sediment delivery associated with Alternatives 2 and 3 because road drainage structures will be improved. Cumulatively, BAER work combined with Alternatives 2 and 3 would not have an effect on any other aquatic habitat parameters.
Likely one of the greatest potential disturbances associated with fire suppression efforts conducted during the Copper King Fire was the construction of firelines using heavy equipment.
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Some of these firelines were constructed in RHCAs and had the potential to generate and transport sediment into area streams (USDA 2017). All firelines have been rehabilitated but until the vegetation becomes better established, the potential for more sediment to reach affected streams exist. Overall when considered with Alternatives 2 and 3, changes in sediment levels in streams may temporarily increase but the impacts to aquatic habitat and fish populations would be negligible when considering the magnitude of sediment generated by the Copper King Fire. No other aquatic habitat parameters would be affected by the cumulative effects of fire suppression and the action alternatives.
Within the fire perimeter Weyerhaeuser mostly completed their salvage operations on 1,883 acres during the fall/winter of 2016. Montana DNRC plans to harvest 1,095 acres within the project area as well. For both Weyerhaeuser and DNRC, State of Montana BMPs were and will be employed and no harvest would likely occur within the riparian areas of streams. There would be no cumulative effects on fish habitat related to temperature, large wood, pools, or bank stability.
As described above and in the Hydrology section, road use for haul would generate sediment to area streams. Although some BMPs were applied on some roads used by Weyerhaeuser (although not to the extent included in Alternatives 2 and 3), hauling during wet weather in October and November did yield sediment to small tributaries. Small quantities of sediment would also be generated by both Alternative 2 and 3. As described in the Hydrology section, this does not necessarily mean that the sediment from Alternatives 2 and 3 would be additive to the sediment generated by Weyerhaeuser’s haul activities in the fall. Most likely, any sediment that entered stream channels from Weyerhaeuser activities will be flushed through the system by the spring 2017 runoff. This will be the first snowmelt since the fire and will have increased discharge to flush excess sediment through the system. By the time Forest Service salvage operations were to take place, stream levels would come down and stabilize.
Cumulative levels of sediment from state, private, and Forest Service road-related actions conducted in 2017 would be low compared to estimated natural background levels post-fire (see Hydrology section). Cumulative effects to fish and fish habitat would be low as sediment generated would generally be in small tributaries that are not fish bearing. Minor effects to Thompson River sediment levels and fish (as described above) would be expected due to cumulative haul along Road #9991 [ACM road].
Biological Determination of Effects on Sensitive and Listed Species
Westslope Cutthroat Trout Alternatives 2 and 3 may impact westslope cutthroat trout or habitat, but would not likely contribute to a trend towards Federal listing or loss of viability to the population or species. Project-related short-term sediment increases may have non-lethal effects to individual fish but would not critically impair the westslope cutthroat trout populations within project-area watersheds.
Bull Trout and Critical Habitat Alternatives 2 and 3 may affect and are likely to adversely affect bull trout and bull trout critical habitat in the Thompson River due to the temporary generation of fine sediment from road-related activities: road maintenance, log haul, and temporary road construction. Temporary road construction and use, would increase the drainage network system and road densities for generally less than one year, until temporary roads are obliterated. Road maintenance actions including application of resource protection measures (BMPs) and use of roads for log hauling,
82 Copper King Fire Salvage Environmental Assessment especially within 300 feet of streams, would generate sediment that would be delivered to stream systems. However, quantities would be low in magnitude and short in duration compared to natural increased sediment levels resulting from the Copper King Fire. These effects resulting from Alternatives 2 and 3 would be expected to last one year or less, as spring flows would flush and dilute fine sediments within the Thompson River feeding, migrating, and overwintering habitat.
Bull Trout Critical Habitat The USFWS designated critical habitat for bull trout in the coterminous United States in 2010 (75 FR 63898 October 18, 2010). The Thompson River is designated critical habitat.
The USFWS identified nine primary constituent elements (PCEs) as essential for the conservation of bull trout and may require special management considerations (75 FR 63933 October 18, 2010). The PCEs are discussed below.
1) Springs, seeps, groundwater sources, and subsurface water connectivity to contribute to water connectivity (hyporheic flows18) to contribute to quality and quantity and provide thermal refugia.
Floodplains and riparian areas that provide hydrologic connectivity for springs, seeps, groundwater upwelling, and wetlands and contribute to the maintenance of the water table would be protected through the application of riparian habitat conservation areas. For the Copper King project, standard RHCA widths would be expanded around all riparian features to protect them. No trees would be removed within RHCAs. The exception is Thompson River where hazard tree removal within the RHCA would occur for public safety; however no trees would be removed between the road and the river. As assessed in the Hydrology section, Alternatives 2 and 3 would have no measurable effects to water yield.
There may be a short-term negative impact to PCE #1 (water quality) due to increases in sediment loading from project activities. However, estimated sediment increases would be very small relative to overall sediment loading in the watersheds due to the Copper King Fire. Sediment contributed to streams from project road-related activities would be composed of small-sized material that would stay suspended through much of Thompson River. Once project activities were completed, sediment loading would return to pre-project baseline conditions. The high water volume of Thompson River during the spring would tend to dilute any project-generated sediment that could impact critical habitat; therefore Alternatives 2 and 3 would unlikely have any effect to hyporheic flows.
2) Migratory habitats with minimal physical, biological, or water quality impediments between spawning, rearing, overwintering, and freshwater and marine foraging habitats, including but not limited to permanent, partial, intermittent, or seasonal barriers.
The Thompson River is a feeding, migratory, and overwintering corridor for bull trout. No spawning sites have been identified in the mainstem. There are no barriers within the Thompson River mainstem that block volitional passage of bull trout. Chemical contamination/nutrients are not a concern with this project. Water quality impacts resulting from sediment generated during
18 Hyporheic flow, also called interstitial flow, is the percolating flow of water through the sand, gravel, sediments and other permeable soils under and beside the open streambed. It is the subsurface flow between rheic flow, which is visible free running water such as a stream, river or other moving flow of water; and the water table.
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project activities would be short-term. Within the Thompson River, fine sediment is expected to remain in suspension although some would settle around low velocity areas near channel margins. Water temperatures would be maintained despite some hazard tree removal within the 300-foot RHCA of Thompson River. Minor effects to habitat would not retard movement of bull trout within the Thompson River.
3) An abundant food base, including terrestrial organisms of riparian origin, aquatic macroinvertebrates, and forage fish.
Project-related activities would not likely result in changes to the amount and quality of the food base within the Thompson River. The small, temporary increase in sediment loading from road- related project activities would most likely occur during periods of high runoff that correspond to high stream flows and sediment would be quickly diluted. Thus, impacts to macroinvertebrates, if any, would be discountable. Effects to forage fish would be similar to those described for bull trout above and would not reduce prey species.
4) Complex river, stream, lake, reservoir, and marine shoreline aquatic environments, and processes that establish and maintain these aquatic environments, with features such as large wood, side channels, pools, undercut banks and unembedded substrates, to provide a variety of depths, gradients, velocities, and structure.
The Copper King project would have no impact to PCE #4 because project activities are not expected to generate sediment levels that would affect these habitat features. Any sediment delivery that would occur would be small in nature compared to background levels, and stay suspended through much of Thompson River. No salvage harvest would occur within RHCAs; therefore woody debris recruitment to streams, shade and instream habitats would be maintained. Over time, woody debris would increase as dead trees fall.
5) Water temperatures ranging from 2 to 15°C (36-59°F), with adequate thermal refugia available for temperatures that exceed the upper end of this range. Specific temperatures within this range will depend on bull trout life-history stage and form; geography; elevation; diurnal and seasonal variation; shading, such as that provided by riparian habitat; and local groundwater influence.
Alternatives 2 and 3 would not affect water temperature in the Thompson River or other project area streams. No activities would reduce stream shade within the project area. Applied Riparian Habitat Conservation Areas would adequately protect shade and thermal loading by retaining vegetation along streams. The hazard trees removed along Road 9991 [ACM road] are within a tight cross sectional valley that provides the majority of shading. Although there may be some discreet and short-term increase in solar radiation from tree removal, it would not be enough to increase water temperatures. Therefore, PCE #5 would not be affected.
6) In spawning and rearing areas, substrate of sufficient amount, size, and composition to ensure success of egg and embryo overwinter survival, fry emergence, and young-of-the-year and juvenile survival. A minimal amount of fine sediment, generally ranging in size from silt to coarse sand, embedded in larger substrates, is characteristic of these conditions. The size and amounts of fine sediment suitable to bull trout will likely vary from system to system.
This PCE is only relevant for juvenile survival. Egg, embryo, fry emergence and young-of-the- year age classes are only found in spawning tributaries to Thompson River, outside of the project area boundary. For fluvial and juvenile bull trout, the Thompson River provides a migration path
84 Copper King Fire Salvage Environmental Assessment from the Clark Fork River and overwintering habitat. These life stages are also more resilient to sediment inputs than younger life stages. Within the Thompson River, short-term increases in fine sediment from project activities could temporarily disrupt bull trout foraging and feeding behavior because these fish are sight feeders. Sediment inputs would be in discrete locations and bull trout would likely avoid these areas temporarily.
7) A natural hydrograph, including peak, high, low, and base flows within historic and seasonal ranges or, if flows are controlled, minimal flow departure from a natural hydrograph.
Alternatives 2 and 3 would have no effect on PCE #7. As assessed in the Hydrology section, these alternatives would not measurably affect water yield and thus would not affect peak/base flows. Other factors that could influence the natural stream hydrology such as floodplain connectivity, road density and location, and disturbance history would not be affected.
8) Sufficient water quality and quantity such that normal reproduction, growth, and survival are not inhibited.
Background levels of water quantity and quality could change as a result of the Copper King Fire, but project actions would not affect PCE #8. Alternatives 2 and 3 would not influence bull trout reproduction, growth, or survival from the temporary, minor amount of sediment increase.
9) Sufficiently low levels of occurrence of nonnative predatory (e.g. lake trout, walleye, northern pike, smallmouth bass); interbreeding (e.g. brook trout); or competing (e.g. brown trout) species that, if present, are adequately temporally and spatially isolated from bull trout.
Non-native trout species dominate the Thompson River. As indicated above, the Copper King project would not have any effect on water temperature that could favor “warmer water” non- native species in the Thompson River. Sediment loading described above would be expected to have similar effects on non-native fish, but those effects are small relative to existing conditions. Therefore, project activities would not change the distribution or abundance of fish and would have no effect on PCE #9.
Forest Plan Consistency Alternatives 2 and 3 are consistent with the Lolo Forest Plan.
Best management practices have been incorporated into all action alternatives and would be applied to assure that water quality is maintained at a level that is adequate for the protection and use of the National Forest and that meets or exceeds Federal and State standards. (Forest- wide standard 15, Forest Plan, page II-12)
The project is consistent with Endangered Species Act recovery goals. All action alternatives were designed to be compatible with the habitat needs of bull trout in the Thompson River through resource protection measures, best management practices, and project design. (Forest-wide standard 24, Forest Plan, pages II-13 to 14)
All action alternatives were designed to have minimum impacts on the aquatic ecosystem and would not cause permanent or long-term unnatural stress. (Forest-wide standard 28, Forest Plan, page II-14) o Aquatic insect density or diversity are not expected to change because the relatively small amount of sediment delivered during project implementation would most likely occur during periods of high runoff that correspond to high stream flows, which would quickly
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dilute the sediment. If any impacts to macroinvertebrates were to occur, they would likely be indistinguishable from natural fluctuations in population (McElravy et al. l989; Gravelle et al. 2009).
o Fish populations would not be reduced.
o Intragravel sediment accumulations could be affected in discrete locations within the channel, primarily where there is slow water and/or where some of the fine sediment generated from project activities could temporarily deposit in the bottom of pools or behind woody debris downstream of delivery points until flushed out by high spring flows. However, effects would be temporary and not affect stream stability, substrates, or channel structure due to the stream channel types, the relatively short duration of the activities, and low magnitude and intensity of the project-generated sediment.
o Channel structure would not be adversely affected because there would be no measurable change to water yield. The relatively small quantity of fine sediment generated by road- related activities would not cause aggradation or changes to channel morphology (Megahan and King 2004).
Alternatives 2 and 3 would be consistent with Inland Native Fish Strategy (amended to the Forest Plan in 1995) requirements and direction (see Fisheries report in the Project File for more detailed information). 3.6 Wildlife
Issues Raised in Public Comment Salvage operations and associated temporary road construction could reduce:
hiding cover for wildlife
snags and downed trees needed by lynx and other forest carnivores for denning
grizzly bear core habitat
bird and beetle habitats
The Lolo National Forest provides habitat for many different species of wildlife, several of which occur within the Copper King project area. The presence or absence of these species depends on the amount, distribution, and quality of each animal’s preferred habitat. In addition, some of these species are affected by hunting or trapping, which is regulated by Montana Fish, Wildlife and Parks. This analysis focuses on species listed as federally threatened or endangered on the Lolo National Forest (USDI-FWS 2016) and Forest Service sensitive species (USDA-FS 2013). The table below provides a list of those species, preferred habitat, whether the habitat or species are present in the project area, and whether detailed analysis was conducted for that species. If a species or their habitat does not occur within the project area, no further analysis was conducted.
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Management Indicator Species (MIS)19 including elk, northern goshawk, and pileated woodpecker are also addressed to further assess project compliance with Lolo Forest Plan standards and management area direction (USDA-FS 1986).
The Copper King Fire modified wildlife habitats across the project area but the extent of change depends primarily on the burn severity and the species.
Table 3.6-1: Wildlife Species Considered in the Copper King Analysis Status on Species Present in Habitat Present Species Preferred Habitats Forest Analysis Area in Analysis Area No observations. Yes, habitat is However, hair- present. Project snagging surveys area is within the Alpine/subalpine coniferous forest, conducted in 2011 Cabinet-Yaak Grizzly Bear Threatened lower elevation riparian areas in spring, identified the DNA Grizzly Recovery lack of human disturbance. of one male grizzly Zone bear in the project area. Records of five Yes, USFWS Subalpine fir habitat types (including lynx observations designated cover types with pure or mixed within or near the occupied habitat. subalpine fir, lodgepole pine, Douglas- project area over Most of the habitat fir, grand fir, western larch, and the last 44 years. is currently Canada Lynx Threatened hardwoods) above 4,000 feet in unsuitable due to elevation, vertical structural diversity in the high burn the understory (down logs, severity. Project seedling/saplings, shrubs, forbs) for is outside critical foraging and denning habitat. Riparian willow-cottonwood forests No records of No suitable habitat along low-gradient rivers and streams, species presence in present. Dropped and in open riverine valleys that provide Sanders County from further wide floodplain conditions (greater than review. Yellow-billed 325 feet). The optimal size of habitat Threatened Cuckoo patches are generally greater than 200 acres in extent and have dense canopy closure and high foliage volumes of willows and cottonwoods. (79 FR 48551) There are no Yes suitable High elevations centered near the tree records of habitat present, but line in coniferous forests, rock alpine wolverine within is limited. habitat above tree line, cirque basins, the project area, Wolverine Proposed and avalanche chutes that have food although a carcass sources. Deep, persistent, and reliable was found on spring snow cover (to mid-May) is the Highway 200 just best predictor of wolverine occurrence. outside the project area in 2015.
19 Management Indicator Species are species identified in the Lolo Forest Plan that are used to monitor the effects of planned management activities on viable populations of wildlife or fish including those that are socially or economically important (Lolo Forest Plan, page VII-15).
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Status on Species Present in Habitat Present Species Preferred Habitats Forest Analysis Area in Analysis Area Although a wolf Yes, suitable pack is not known habitat present. to regularly use the Gray Wolf Sensitive Habitat generalists. project area, the species is likely present. No observations The Copper King have been recorded Fire removed most Moist mixed coniferous forested types in the project area. of the suitable (including mature and old-growth habitat. The Fisher Sensitive spruce/fir forests at low- to mid- remaining habitat elevations), riparian/forest ecotones, is unlikely enough secure denning habitat. to support year- round fisher use No species present. No habitat within Northern Bog Wet riparian sedge meadows, bog fens project area. Lemming Sensitive with extensive sphagnum moss mats. Dropped from
further review. Roosts in caves, mines, rocks and In 2006, the species Yes, habitat Townsend’s buildings. Snag roosting habitat also was observed in the present. Big-Eared Sensitive important. Forages over tree canopy, Silver King mine, Bat wet meadows, riparian areas and open located within the
water. project area. Peregrine Species nests in the Yes, suitable Cliff nesting (ledges); riparian foraging Falcon Sensitive cliffs above the habitat is present. (small bird species prey). Clark Fork River. Nesting platforms near a large open Past surveys have No. Dropped water bodies (greater than 80 acres) or not detected eagle from further Bald Eagle Sensitive major river system; available fish and nests along the review. water bird species prey, secure nesting Thompson River. habitat. Burned forests or less typically, Species is Yes, suitable Black-backed Sensitive coniferous forests with high insect associated with habitat is present. Woodpecker infestations (i.e. bark beetles) burned forests. No recorded No habitat in Common Lake habitat. Secure nesting and brood species presence. project area. Sensitive loon rearing areas. Dropped from further review The species has not Yes, but suitable Mature (greater than 9 inches diameter been observed in habitat is limited breast height (dbh)) and old-growth Flammulated the project area but due to the effects ponderosa pine/Douglas-fir with Owl Sensitive has been observed of the Copper abundant moth species prey. Secure across the King Fire nesting habitat (greater than 35% Thompson River in canopy cover). Priscilla Gulch Harlequin No species present Yes, suitable During the breeding season, found near Duck Sensitive habitat is present, large, fast flowing mountain streams. but limited. Coeur A population exists Yes, suitable d'Alene Wet, fractured, moss-covered rock, on the cliff face habitat is present. Sensitive Salamander waterfalls adjacent to Road #9991.
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Status on Species Present in Habitat Present Species Preferred Habitats Forest Analysis Area in Analysis Area No species present No suitable habitat Northern Typically in or adjacent to permanent present. Dropped Leopard Frog Sensitive slow moving or standing water bodies from further with considerable vegetation review Variable including; wetlands, forests, No toads found in Yes, suitable woodlands, sagebrush, meadows and project area habitat present. Boreal Toad Sensitive floodplains. Overwinters in caverns or rodent burrows The Thompson Yes, suitable Falls sheep herd habitat is present. inhabits the project Bighorn area. Use is likely Sensitive Inhabits steep, rocky open slopes Sheep on the slopes and drainages above the Clark Fork and Thompson Rivers West of Continental Divide: Stands with Yes, species Suitable habitat is mean diameter of greater than 10 inches, present present, but the Northern crown closures of at least 40% and amount was Goshawk MIS elevations below 6,200 feet. Foraging reduced by the habitat is variable but typically in Copper King Fire. mature stands with dense canopies fairly open understories Moderately warm, dry Douglas- Yes, species Yes, suitable fir/ponderosa pine; moderately cool, dry present habitat present. Pileated Douglas-fir; moist mid-elevation Woodpecker MIS spruce/grand fir. Large, soft snags
(greater than 21 inches diameter breast height). Habitat generalists, secure habitat Yes, species Yes, suitable Elk MIS during the hunting season, secure winter present habitat present
range.
Snags and Coarse Wood Snags are dead, standing trees that are used by a variety of wildlife species including almost all woodpeckers, many owls, kestrels, songbirds, and mammals such as flying squirrels and marten. Snag densities vary widely across forest types, with (or without) fire, and with past management. Maintaining adequate snag habitat assists in maintaining habitat for several wildlife species such as bluebirds, kestrels, bats, marten, flying squirrels and more (Bull et al. 1997). Post-fire stands of burned trees are important habitat for species using snags including 15 species of birds that were identified more commonly in burned forest than any other cover type (Hutto 1995). This includes the black-backed woodpecker which relies almost exclusively on early post-fire habitats (Hutto 1995). As dead trees fall and become coarse wood on the forest floor, they continue to be used by many wildlife species including pileated woodpeckers, small mammals, marten, weasels, and more (Harmon et al 1986, Carey and Johnson 1995). Samson (2006) concludes that species that use snags and coarse wood (pileated woodpeckers, marten, goshawk (which forage on other birds and small mammals), black-backed woodpecker, flammulated owl and fisher have sufficient habitat on the Lolo National Forest and Northern Region to maintain viable populations.
One of the objectives of the Forest Plan is to provide habitat for viable populations of diverse wildlife species on the Forest (page II-2). Special attention is given to species dependent on
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snags (page II-2). The Lolo Forest Plan defines a snag as “[a] standing dead tree usually greater than 5 feet in height and 6 inches in diameter at breast height” (page VII-38). The Forest Plan identifies the hairy woodpecker and goshawk as representative species of snag users. The Forest Plan does not identify any management indicator species for snag users. However, snag densities, are used as an indicator of population trends for two old growth management indicator species including the northern goshawk and pileated woodpecker. Until monitoring technology becomes available for the goshawk and pileated wood pecker, population trends will be monitored using habitat parameters including old-growth acres and condition, and snag densities (Standard 27, page II-14). In recent years, these species have been monitored more directly and their populations are stable indicating that the habitats they represent are also represented suitably on the landscape (see the discussion on northern goshawk and pileated woodpecker, below).
To achieve Forest Plan objectives, “sufficient snags and dead material are required to be provided to maintain 80 percent of the population of snag-using species normally found in an unmanaged Forest in the portion of the Forest more than 200 feet from all system roads” (Standard 25, page II-14). The Forest Plan provides guidance on how to meet the requirements of Standard 25 when conducting timber management practices. For example, Appendix N of the Forest Plan provides procedures to implement the Forest snag standard (#25) by recommending snag and replacement tree retention, focused on harvest of live (unburned) timber stands of various habitat groups. In 1996/1997, additional guidelines were developed to ensure adequate protection of snags and dead down wood. These guidelines revised the numbers of snags/replacement trees to slightly higher levels and included guidance on implementation in burned forests with proposed salvage harvest. Snags were redefined as greater than 10 inches dbh and greater than 15 feet tall. In 1996, direction provided by then Forest Supervisor Charles Wildes revised the snag retention guidelines in Forest Plan Appendix N. He stated that the guidelines for snag retention would be applied on most forest acres, but that Forest Plan standard 25 provides flexibility to exclude snags in some areas (In service memo dated April 5, 1996).
Furthermore, the 2000 Northern Regional Snag Protocol provides additional guidance on snag and down wood retention with a small amount of guidance relating to application of these principles in burned forests with proposed salvage harvest. Specific to post-fire salvage, the 2000 Northern Regional Snag Protocol states, “In western Montana conifer forests, ponderosa pine, western larch, and Douglas-fir are especially important foraging substrates for birds (Hutto 1995). Bird species differ in the microhabitats they occupy within a burn (Hutto 1995, Saab and Dudley 1998), and salvage methods that ‘homogenize’ the stand structure will not supply the needed range of microsites (Hutto 1995). One possible solution is to take trees from one part of the burn and leave another part untouched (Hutto 1995). This would be the safest method for woodsworkers, as burned forests are notoriously hazardous.”
Snag densities across the Lolo National Forest exceed snag retention guidelines (Table 3.6-2). Before the Copper King Fire, snags present within the West Thompson landscape, where the Copper King project is located, also exceeded snag guidelines (Table 3.6-2).
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Table 3.6-2: Pre-Copper King Fire Snag Densities across the Lolo National Forest and within the West Thompson Landscape (data from Forest Inventory and Analysis Plots) Lolo National Forest West Thompson Landscape Habitat Snags/acre Snags/acre Snags/acre Snags/ Snags/acre Snags/acre Snags/ Group (10- (greater than acre greater greater acre 20”/20+”/ 10”)/ Northern greater than 20” than 10” greater replacement replacement Region snag than 10” than 20” trees) trees) protocol guidelines, Forest Plan Lolo National 2000 Appendix N Forest Dead guidelines and Down 1986 Guidelines 1996/1997 1 ---- 1-2 / 8-12 1-2 >20” 4.2 1.8 ** ** 2 3-4 / 0.1 / 0.3 1-2 / 8-12 4 >20” 6.2 0.9 9.28 0.25 3 ---- 1-12 / 8-12 6-12 with 2- 11.5 1.6 4>20” 36.11 12.04 4 3.5 / 0.1 / 0.3 4-12 / 8-12 6-12 with 11.1 1.0 2>20” 5.79 0.33 5 1 / 0.1 / 0.3 1-12 / --- 12 with 15.4 0.9 4>20” 13.4 ** 6 ------5-10 >10” 20.2 1.9 32.5 2.6 All No guideline No guideline No guideline 11.6±1.2 1.1±0.20 14.99±5.14 1.66±1.19 groups (Mean± standard error) These data are designed for coarse-scale measurement and are not reliable at a finer scale other than the landscape area specified. These data are from before the Copper King Fire. Post-fire snag densities in the West Thompson landscape are currently much higher. **Within habitat groups 1 and 5, plot data in the West Thompson landscape was insufficient and snag estimates could not be made.
Depending on its severity, fire can kill trees, which can dramatically increase the number of snags within the burned area - the higher the burn severity the greater the number of resulting snags. These post-fire stands with high tree mortality provide a habitat that is unique compared to the myriad of unburned habitats on the landscape. Post-fire environments are important habitats for species that use snags, including 15 species of birds that were identified more commonly in burned forests more than any other cover type (Hutto 1995). These species include the black- backed woodpecker which relies almost exclusively on early post-fire habitats (Hutto 1995).
Within the Copper King Fire, high to very high severity burn areas now have entire hillsides comprised of mostly dead trees – this represents approximately 11,685 acres of the Copper King Fire area on National Forest System lands. Within mature stands in these burned areas, this represents about 100-125 snags/acre based on typical pre-fire stand densities and assuming most trees were killed. In comparison, typical live forest stands have snag densities that range from about 4-20 snags/acre (Table 3.6-2). An additional 4623 acres burned at moderate severity and include more snags than unburned, forests but fewer than more severely burned areas. Therefore, snags of all sizes are currently super-abundant (likely over 2 million snags) within the Copper King project area. Currently, the amount of coarse wood on the ground varies depending on what existed before the fire and the severity of the fire. In high to very high severity burn areas, the
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coarse wood was consumed by the fire. Over time, snags will fall and provide high quantities of coarse wood. This coarse wood will continue to provide habitat for a variety of wildlife species that use logs on the ground.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct or indirect effects on snags or down wood because no management activity would occur. Along roads open to public motorized use, snags would likely be cut for firewood by the public. Firewood permits allow cutting within 200 feet of open roads. The remaining snags on National Forest System land within the post-fire landscape would be influenced by the natural processes of decay, wind, insects, and more fire. Salvage operations on State and Weyerhaeuser lands will likely remove most, if not all, snags of a merchantable size on approximately 3000 acres.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 would remove snags from approximately 1502 acres (8 percent) and 2312 acres (12 percent), respectively, of National Forest System land affected by the fire. This would leave approximately 17,798 acres (92 percent) and 16,988 acres (88 percent), respectively, to natural processes and unaffected by project activities. Even within salvaged areas, unmerchantable dead trees (i.e. damaged, defective, and/or too small) would be retained although some may be felled for safety or inadvertently knocked over. Therefore, snags would remain super-abundant on the landscape, providing abundant habitat for snag-associated species. As displayed in Tables 2-9 and 2-10, snags of all tree size classes and species would be retained.
The removal of standing dead trees would reduce habitat quality in the affected areas for wildlife species that use snags for nesting, feeding, cover and roosting. However, salvage would not occur all in one contiguous area, but instead would be scattered in smaller multiple blocks (Alt 2 - 86 units, averaging about 17 acres each, Alt 3 - 107 units, averaging about 22 acres each); therefore snags would be readily available in adjacent unmanaged areas. Since snags would be retained on 17,000 acres or more of the fire area, the effects of removing a relatively small portion of snags would be discountable to wildlife species that use snags. The timing of salvage operations would allow for birds to complete their nesting cycle and the nestlings to fledge (see Resource Protection Measures in Chapter 2). Therefore, direct mortality would be unlikely.
Alternatives 2 and 3 are consistent with recommendations in the scientific literature to retain large areas of snags to provide habitat for species associated with post-fire environments (Russell et al. 2006; Hutto 1995; Cherry 1997, Saab and Dudley 1998). These alternatives would have discountable effects on snag-related species because snags would remain super-abundant on the landscape.
Existing coarse wood would be retained within salvage units. In units that lack existing coarse wood, the tops of cut trees would be retained on site (Resource Protection Measures in Chapter 2). The tops of cut trees as well as the smaller dead trees (less than 8 inches in diameter) that would be left within units would provide for soil productivity and wildlife habitat. Although future coarse woody debris levels would be lower in treated areas compared to untreated areas, at the landscape scale, abundant coarse wood would be available to provide hiding cover, denning, and feeding areas for ground dwelling wildlife.
Cumulative Effects Within the Copper King Fire area, salvage operations on Weyerhaeuser and State lands will remove fire-killed trees on approximately 3000 acres, reducing the number of snags in affected
92 Copper King Fire Salvage Environmental Assessment areas. However, cumulatively, all existing snags would be retained on more than 80 percent of the entire 28,900-acre fire area across all ownerships (see Table 3.1-2), providing abundant habitat for snag-related species. Future coarse wood would also be abundant within untreated areas. Other project-related activities (e.g. planting, road maintenance) would have no cumulative effects on snags.
Over the last decade only about one percent of the over 2 million acres that burned in wildfire across the Northern Region was salvaged. In that same time period, only about 1.4 percent of the nearly 200,000 acres that burned across the Lolo National Forest was salvaged. Therefore, post- fire snag habitat and coarse wood are abundant and widespread at the Forest and Regional scales.
Forest Plan Consistency Alternatives 2 and 3 would be consistent with Forest Plan standard 25. The retention of all snags on 92 and 88 percent, respectively, of the fire area on National Forest System land would provide abundant habitat to contribute to the maintenance of 80 percent of the population of snag-using species normally found in an unmanaged Forest in the portion of the Forest more than 200 feet from all system roads. Samson’s (2006) estimated that post-fire and insect habitats were sufficient across the Lolo National Forest and the Northern Region to provide for population viability of black-backed woodpeckers (the most noteworthy of the post-fire species). The Copper King Fire added to these habitats.
Threatened Species The Endangered Species Act (ESA, PL 93-205, as amended) regulates threatened and endangered species management. Under ESA, the Forest Service shall carry out recovery programs developed by the U.S. Fish and Wildlife Service (USFWS) and must prepare a biological assessment for any action that is likely to affect a listed species or its habitat (16 USC 1536(c)). Forest Plan standard 24 (page II-13) states that all threatened and endangered species will be managed for recovery. Standard 27 (page II-14) states that management practices in essential habitat for threatened and endangered species must be compatible with the species’ needs. Management guidelines for project-level planning for threatened and endangered species are outlined in species-specific recovery plans and/or conservation strategies (i.e. USDI-FWS 1986, 1987, 1993; USDA-FS 2001, 2007).
In accordance with Section 7(c) of ESA, the U.S. Fish and Wildlife Service determined that the following listed threatened wildlife species may be present on the Lolo National Forest: Canada lynx and grizzly bear. There is no designated critical habitat for either species within the project area.
Grizzly Bear The grizzly bear was listed as threatened under the Endangered Species Act in 1975. The Lolo National Forest encompasses portions of three grizzly bear recovery areas, the Northern Continental Divide, Cabinet-Yaak, and Bitterroot. The Copper King project area is located within the southeast corner of the Cabinet-Yaak recovery area, which is approximately 1.7 million acres in size. Specifically, the project area is in Bear Management Unit (BMU20) 22, which is about 163,000 acres in size. In 2011, the Lolo Forest Plan was amended to include management requirements for motorized access within the Cabinet-Yaak recovery area (Forest Plan Appendix
20Bear Management Units are areas established for use in grizzly bear analysis. BMUs generally approximate female home range size and include representations of all available habitat components.
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Y). Controlling and directing motorized access is one of the most important tools in achieving habitat effectiveness and managing grizzly bear recovery (USFWS 1993). The amendment established standards for total motorized route density (TMRD), open motorized route density (OMRD), and core habitat. The amendment also directed that the standards are to be achieved by 2019. Although BMU 22 does not currently meet the standards, the Lolo National Forest is in the process of developing a proposal (separate from the Copper King project) to bring the BMU into compliance by the 2019 deadline.
Because BMU 22 does not currently meet the motorized access standards (see Table 3.6-3), additional requirements apply including:
offsetting any project-level incursion into core habitat21 by creating core habitat elsewhere in the BMU;
offsetting core incursions before they occur;
increasing bear security by increasing core habitat and decreasing levels of open motorized routes and total motorized routes upon project completion if these attributes are affected by a project.
Table 3.6-3: Forest Plan Standards for Motorized Access in BMU 22 Existing Forest Alternative Alternative 2 Alternative 3 Alternatives Condition Plan 1 during project during project 2 and 3 Standard implementation implementation post-project OMRD (% of 36.5 33 36.5 39.2 39.6 35.4 BMU with less than 1 mile/mile2) TMRD (% of BMU 38.2 35 38.2 37.8 37.9 37.7 with less than 2 miles/mile2) Core Habitat 50.7 55 50.7 50.9 50.7 51.1 (% of BMU) OMRD = open motorized route density (open means there is no restriction on motorized use) TMRD = total motorized route density
Forest Plan Appendix Y also limits administrative use of roads closed to the public. If the number of trips exceeds 60 trips per active bear year in the Cabinet-Yaak ecosystem, then that road would be considered “open” for analysis and reporting purposes.
Within the project area, no grizzly bear observations have occurred in the last decade or more and no observations were reported during the Copper King Fire incident. The most reliable record is male grizzly bear DNA captured at a hair snag station in Todd Creek in 2011 (Kendall et al. 2013). No females and particularly females with cubs have been detected southeast of the Thompson River (project area) and thus bears likely only pass through the project area rather than occupy it regularly. In 2016, bear rub trees surveyed in 2011/2012 were revisited and hair collected. DNA results are pending.
21 Grizzly bear core habitat is an area of secure habitat within a bear management unit (BMU) that contains no motorized travel routes or high use non-motorized trails during the non-denning season and is more than 500 meters from a drivable road.
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Grizzly bears are opportunistic omnivores (Schwartz et al. 2003) and feed on an array of animals and plants. Their opportunistic selection of food items has permitted bears to occupy a great variety of vegetation types in North America (Herrero 1972). In Montana, grizzly bears use meadows, seeps, riparian zones, mixed shrub fields, closed timber, open timber, snow chutes, and alpine habitats. Habitat use is highly variable between areas, seasons, local populations, and individuals (Servheen 1983, Craighead and Mitchell 1982, Aune et al. 1984). Many of the habitats within the Copper King project area are similar to those that exist and support grizzly bears within other parts of the Recovery Zone even though the project area burned in 2016. Over the next 2-5 years, forage will become abundant as the vegetation regrows. The Copper King Fire converted large areas from forested (having less understory forage vegetation) to the grass/shrub successional stage which has tremendous potential for increasing bear forage. High- elevation grass and shrub fields near Big Hole Peak provide summer forage and denning habitats while lower-elevation areas along the Thompson and Clark Fork Rivers, and in Weeksville Creek provide spring habitat.
Grizzly bear habitat has been described in terms of the availability of large tracts of relatively undisturbed land that provides security from human-caused mortality and competitive use of habitat by humans (USFWS 1993). Recent work in Alberta, Canada indicates that most bears, across a large population, resided in areas with less than 2.4 miles/mile2 of open road (Boulanger and Stenhouse 2014). On the National Forest System land within the Copper King project area, open road density is currently about 2.0 miles/mile2 (includes roads that are open either yearlong or seasonally to public motorized use). However, in the intermingled ownership portion of the project area, the open road density may be higher due to open roads on private and State lands. In addition, there are approximately 10 miles of trail open to single track motorized (motorcycle use).
Habitats have little motorized vehicle access on the Koo-Koo-Sint Ridge and Clark Fork Face (located in the southern portion of the project area), but gated roads are common throughout most of the project area (except in the southeast corner). Open roads are also common in lower Calico Creek, and Todd Creek (northern portion of the project area) where there is intermingled ownership of Weyerhaeuser, State, and National Forest System land.
For this analysis, the following factors are used to evaluate the project’s potential effects on grizzly bears:
Open road density: Studies indicate that bears change use patterns within their home ranges to avoid highly roaded areas (Mace and Waller 1997; Wakkinen and Kasworm 1997). Open roads increase risk of bear mortality.
Vegetative Cover: Grizzly foraging behavior is typically associated with more open habitats, but bears generally forage in areas with some type of hiding cover nearby (Servheen 1983, Mace et al. 1997, Waller and Mace 1997).
Human developed sites. Human developed sites can affect grizzly bears through food conditioning issues resulting in conflicts and bear use patterns that may avoid higher human use areas
Riparian areas: these areas are important for their use as both travel corridors and high use foraging areas (Servheen 1983).
Disturbance
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Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on grizzly bears because no activities would occur. Alternative 1 would not make progress toward Forest Plan standards for motorized access in BMU 22.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 would not likely adversely affect grizzly bears because:
Although the project area is located within the Cabinet-Yaak Grizzly Bear Recovery Zone, bear use within the project area is considered to be infrequent based on the lack of bear observations within the area.
Security would be maintained and slightly increased.
Vegetative cover would be maintained where it still exists after the fire.
Food/wildlife attractant storage restrictions apply on all National Forest System lands on the Lolo National Forest.
If a grizzly bear were temporarily displaced during project implementation, there are suitable undisturbed habitats available to move to.
None of the proposed activities would preclude grizzly bear movement or use within the Copper King project area:
o Open road density would remain the same and there would be a reduction of 5 miles of open motorized trail. Therefore, secure (core) habitat would slightly increase after completion of Alternatives 2 and 3.
o Riparian areas would be protected (see Resource Protection Measures in Chapter 2). Open Road Density Although Alternatives 2 and 3 would not affect open road density, 5 miles of trail currently open to motorized use would be closed. This closure would increase habitat security to a small degree.
Vegetative Cover Studies indicate that grizzly bears in Montana do well in areas with a diversity of habitat types, including those with cover and those without (Servheen 1983, Mace et al. 1997, Waller and Mace 1997). Grizzly foraging behavior is typically associated with more open habitats, but bears generally forage in areas with some type of hiding cover nearby, especially during the day (ibid.).
Changes in hiding cover can affect bears if they are at a higher risk of being shot (e.g. along an open road). Within salvage units, there is little, if any, cover due to the burn severity of the Copper King Fire (see Figure 3.6-1). Where live trees would be thinned (approximately 102 acres), cover would be retained. Therefore, Alternatives 2 and 3 would have no measurable effect to vegetative cover and would not preclude the development of cover in the future (Peterson and Dodson 2016; Knapp and Ritchie 2016).
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Figure 3.6-1: Example of vegetative cover loss within high severity burn areas proposed for salvage.
Human Developed Sites There are no developed human sites within the project area. Alternatives 2 and 3 would not increase the potential for human/bear interactions. In 2011, the Lolo National Forest implemented an expanded food/wildlife attractant storage order requiring all users of the National Forest to properly store all attractants in a “bear resistant” manner. This storage is required by the public, Forest Service personnel, and contractors. The food storage order reduces the risk of bear/human conflicts. Thus, no adverse effects associated with attractants would be expected under any alternative.
Riparian Areas Any remaining cover and forage in riparian areas after the Copper King Fire would not be affected by Alternatives 2 and 3 because no salvage activities would occur within Riparian Habitat Conservation Areas (see Resource Protection Measures in Chapter 2).
Disturbance Grizzly bears could be occasionally present within the Copper King project area. The likelihood of directly affecting even one individual grizzly bear is low. Direct effects, if they should occur, would be in the form of disturbance and displacement caused by salvage operations and road work. However, these effects would not disrupt a bear’s normal behavior patterns such as breeding, feeding, or denning. Most project activities would occur between June and October over about a 2-year period. If a bear were present during project activities, it could be temporarily displaced. The effects would be discountable because activities would not occur all at once, but would be separated in time and space such that large portions of the project area would provide suitable areas for displaced individuals. Because grizzly bears are habitat generalists and opportunistic omnivores, a displaced individual could easily find alternate suitable areas to forage within the area.
The temporary increase in traffic associated with project activities (generally from June to October) would not rise to a level that would cause a barrier to animal movement (Mace and Manley 1993). During the winter, when salvage is required for some tractor units, bears are hibernating in dens. No activities would occur near suitable den sites; therefore the potential for disturbance is negligible during this time period.
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Cumulative Effects Because the direct effects described above are limited to the point of being insignificant (i.e. not at a scale where take would occur), cumulative effects would be insignificant.
Public use of the project area would continue and would likely increase over the next few years due to opportunities for post-fire mushroom picking and firewood gathering, and black bear hunting due to increased post-fire visibility. This higher public use would increase the likelihood of bear-human conflicts and potential mortality of any grizzly bears that may be in the area.
BAER road work, such as culvert removal and replacement, and storm-proofing could have a very short-term impact on a grizzly bear, if present, in cases where an impassible or stored road (normally without motorized traffic) was used by heavy equipment to remove or replace an “at- risk” culvert. This type of action, occurring in 15-20 locations, could temporarily disturb a bear moving through the area. Additionally, the 3,000 acres of salvage harvest on Weyerhaeuser and State DNRC lands in the fire area would have similar disturbance effects to those discussed above, but over half of that work was completed in 2016. However, because these activities would be happening so soon after the fire (fall 2016 and spring 2017), little forage is currently available in salvage areas to attract grizzly bears and thus their presence would be highly unlikely.
Forest Plan Consistency Alternatives 2 and 3 are consistent with the Forest Plan. The rationale for the determination of effects demonstrates project consistency with Forest Plan forest-wide standards 24 (page II-13) and 27 (page II-14) that state federally listed species will be managed for recovery, with management practices in essential habitat compatible with the species’ needs.
All action alternatives are also consistent with the Lolo Forest Plan as amended (Appendix Y) by the 2011 Forest Plan Amendments for Motorized Access Management within the Selkirk and Cabinet-Yaak Grizzly Bear Recovery Zones.
Alternatives 2 and 3 would make progress toward the motorized access standards for BMU 22 once the project were completed and offset reductions to core during project implementation (Table 3.6-3). After implementation, Alternatives 2 and 3 would reduce open motorized route density (OMRD) from 36.5 to 35.4 percent within the BMU due to the closure of the Bay State Creek trail to motorized use. All temporary roads and currently gated haul routes were considered open during project implementation because the number of vehicle trips would exceed the 60 trips allowed Forest Plan Amendment Y. Use of gated haul routes and temporary roads would increase OMRD during project implementation even with the closure of the Bay State Creek Trail. Forest Plan Appendix Y allows temporary increases of OMRD during projects as long as post-project conditions move toward the 33 percent standard.
After project completion, Alternatives 2 and 3 would reduce the total motorized route density (TMRD) within the BMU from 38.2 to 37.7 percent (Table 3.6-3) due to the closure of the Bay State Creek trail to motorized use. All temporary roads are included in the total roads calculation during implementation. At the close of project activities, temporary roads would be obliterated. Temporary roads would not cause TMRD within the BMU to increase above the existing condition during project implementation because of the closure of the Bay State Creek trail to motorized use. As required in Lolo Forest Plan Appendix Y, Alternatives 2 and 3 would make progress toward the 35 percent TMRD standard for the BMU after the project were completed (Table 3.6-3).
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After implementation of Alternatives 2 and 3, core habitat (measured at the BMU scale) would increase (improve) from 50.7 percent to 51.1 due to the closure of the Bay State Creek Trail to motorized use. During implementation, the construction of temporary roads (7575ext, 45005Aext, 45005Aext2, 894ext, 18808ext, 875ext, 18832ext, and 18828ext) in Alternative 2 and (7575ext, 45005Aext, 45005Aext2, 894ext, 18808ext, 875ext, 18832ext, 18828ext, 18780ext, 17003ext, 45005ext, and 45008ext in Alternative 3) would reduce existing core habitat. As required by Lolo Forest Plan Appendix Y, the decrease in core habitat would be offset during project implementation by the closure of the Bay State Creek Trail to motorized use, which would create replacement core habitat that would remain in place for at least 10 years. As also required in Lolo Forest Plan Appendix Y, Alternatives 2 and 3 would make progress toward the 55 percent core habitat standard for the BMU after the project were completed (Table 3.6-3).
Canada Lynx The U.S. Fish and Wildlife Service (USFWS) listed Canada lynx as a threatened species in March 2000. USFWS determined that the main threat to lynx was “the lack of guidance for conservation of lynx and snowshoe hare habitat in National Forest Land and Resource Plans and BLM Land Use Plans” (USDI -FWS 2000a). In 2001, the Forest Service signed a Lynx Conservation Agreement with the USFWS indicating that the Lynx Conservation Assessment and Strategy (LCAS) (Ruediger et al. 2000) would be used as the guiding document during project analysis. In March 2007, 18 Forest Plans (including the Lolo National Forest) were amended with the Northern Rockies Lynx Management Direction (NRLMD) Record of Decision (ROD) [USDA-FS 2007]. The NRLMD describes the habitat management considerations needed to ensure lynx recovery.
The USFWS issued a Biological Opinion on the effects of the NRLMD on the Distinct Population Segment (DPS) of Canada lynx in the contiguous United States in accordance with Section 7 of the Endangered Species Act (USDI FWS 2007). In the Biological Opinion, the USFWS concluded that the programmatic and project-level objectives, standards, and guidelines in the Northern Rockies Lynx Management Direction provide comprehensive conservation direction adequate to reduce adverse effects to lynx from Forest management activities and to preclude jeopardy to lynx (USDI FWS 2007).
The NRLMD provides standards and guidelines to apply to lynx habitat. The Lynx Conservation Assessment and Strategy (LCAS; Ruediger et al. 2000 p. 7-2) discusses the use of lynx analysis units (LAUs) to analyze project impacts to Canada lynx. LAUs approximate the area used by an individual lynx and are the units used to analyze the effects of a project (USDA-FS 2007, FEIS Vol. I, p. 370). LAUs are mapped on a broader scale than lynx habitat and thus contain many areas that are not suitable for lynx use. Lynx analysis units contain nearly all the mapped lynx habitat on the Lolo National Forest. An LAU may or may not actually contain a lynx.
The Lolo National Forest is considered occupied lynx habitat; therefore, the standards and guidelines in the NRLMD apply to treatment units located in the affected LAU for this project. The Big Hole LAU overlaps approximately 53 percent of the Copper King project area, in the higher elevation areas. The remaining 47 percent of the project area located outside of the LAU does not contain lynx habitat because it is too low in elevation and/or is comprised of dry forest types that do not provide lynx habitat (Koehler et al. 2008, Maletzke et al. 2008; Squires et al. 2010).
The Copper King project area is outside designated critical habitat (79 FR 54782, September 12, 2014) and is located more than 24 miles from the nearest designated lynx critical habitat.
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Therefore, the project would have no effect on lynx critical habitat and it will not be discussed further.
Until lynx were listed as threatened, Montana FWP managed lynx as a furbearer. No known or reported lynx have been trapped (purposely or inadvertently) in the Big Hole LAU (MTNHP, Tracker, accessed 11/2016). No lynx were detected during carnivore track surveys that were conducted within and around the project area in 2010, 2011, 2014, 2015, and winter 2016/2017. The Montana Natural Heritage Program reports 5 lynx observations in or near the project area within the last 44 years.
Intensive track surveys conducted by the Rocky Mountain Research Station across western Montana, including portions of the Lolo National Forest, have shown that lynx are uncommon to absent in many parts of this region. The Yaak (about 90 miles northwest of the Copper King project area) and the Clearwater Valley near Seeley Lake (about 80 miles southeast of the Copper King project area) are the primary strongholds for lynx in northwest Montana (Squires, Lynx Research Progress Report, 2006). Squires et al. (2013) do not include the Plains/Thompson Falls Ranger District in their map of lynx habitat in the Northern Rockies. On the Plains/Thompson Falls Ranger District, sightings of lynx and/or their tracks are rare and evidence of breeding is unavailable. The Copper King project area contains relatively little preferred habitat as described below due to existing drier forest types, terrain, and climatic conditions.
Habitat Factors Lynx occupy large home ranges, use a variety of habitats, and can make long distance movements. They typically inhabit gentle, rolling topography (Maletzke et al. 2008, Squires et al. 2013). Across its range, dense horizontal cover, persistent snow, and moderate to high snowshoe hare densities (greater than 0.2 hares/acre) are common attributes of lynx habitat. The elevation at which lynx habitat occurs depends on local moisture patterns and temperatures, and varies across the range of the species. Spruce-fir forests are the primary vegetation type that characterizes lynx habitat in the contiguous United States (Koehler 1990a, Apps 2000, McKelvey et al. 2000b, Koehler et al. 2008, Moen et al. 2008, Vashon et al. 2008a, Squires et al. 2010).
In the western United States, most lynx occurrences (83 percent) are associated with Rocky Mountain conifer forest, and most (77 percent) fall within the 4,920–6,560 foot elevation zone (McKelvey et al. 2000b). Engelmann spruce, subalpine fir, and lodgepole pine forest cover types occurring on cold, moist vegetation types provide habitat for lynx (Aubry et al. 2000). Dry forest cover types (e.g., ponderosa pine, dry Douglas-fir) do not provide lynx habitat (Koehler et al. 2008, Maletzke et al. 2008; Squires et al. 2010).
Denning Habitat Denning habitat includes mature and old growth forests with plenty of coarse woody debris. It can also include young regenerating forests with piles of coarse woody debris, or areas where down trees are jack-strawed (USDA-FS 2007; Moen et al. 2008, Squires et al. 2008, Olson et al. 2011). One important aspect of this definition is that denning habitat is not separate from other types of lynx habitat such as foraging habitat but is a structural subset in a wide variety of stand conditions. Within the Copper King project area, denning habitat is abundant and widespread primarily due to the large area of dead and dying lodgepole pine trees that have created “jack- strawed” conditions across much of the mid to high elevations. Coarse woody debris will further increase over time as dead burned trees fall.
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Several studies, (Moen et al. 2008, Olsen et al. 2011, and Squires et al. 2008) across a variety of regions where lynx occur, have not found that denning habitat is a limiting factor because those habitat elements are common in most areas. More specifically, Squires et al. (2008), in a study of lynx denning in western Montana, concluded that den availability was not limited within female home ranges.
Foraging Habitat Lynx foraging habitat is defined as habitat that supports snowshoe hares, the primary prey of lynx (LCAS 2013). Squires et al. (2010) recommends a habitat mosaic of abundant and spatially well- distributed patches of mature, multilayer forests and younger forest stands.
During winter, lynx in Montana select mature, multistoried forests composed of large-diameter trees with high horizontal cover. These forests are predominately Engelmann spruce and subalpine fir in the overstory with some mixed conifers including lodgepole pine, Douglas-fir, and western larch (Squires et al. 2010). According to Oliver and Larson (1996), this stage contains many age classes and vegetation layers. It usually contains large old trees. Decaying fallen trees may be present that leave a discontinuous overstory canopy. A review of Forest Inventory and Analysis (FIA) data for the Lolo National Forest indicates that areas of high structural diversity to support lynx denning and multi-story, old-aged foraging habitat are well- represented across the forest (Bush et al. 2003).
During summer, lynx broaden their habitat use to include early succession – stand initiation forest with high horizontal cover from abundant shrubs, abundant small-diameter trees, and dense spruce-fir saplings (Squires et al. 2010). Field observations indicate that stand initiation forests between roughly 15 and 30 years old have usually developed horizontal cover favorable to snowshoe hares on the Plains/Thompson Falls Ranger District. In addition, stands that are in the early initiation stage, typically aged between 0-14 years old, will become foraging habitat when dense horizontal vegetative cover develops (USDA-FS 2007, LCAS 2013). These stands are only temporarily unsuitable because they will mature into suitable habitat within a few years.
Table 3.6-4: Lynx Habitat Conditions within the Big Hole LAU1 LAU Size Total Lynx Foraging Habitat Other Habitat3 (acres) Habitat within Currently Providing Will Provide Not Providing LAU Yearlong Hare Habitat Yearlong Hare Hare Habitat (Acres of (acres) Habitat in the LAU in future Copper King (Total Lynx Stand Mature Early Stand Stem Project Habitat within Initiation Multi-story Initiation2 Exclusion and Area) Copper King (15-30 years Spruce/Sub (0-14 years old) Intermediate project area) old) -alpine Fir (acres) (acres) (acres) 24,952 8,237 448 (5% of 1969 (24% 3701 (45% of 2120 (26% of lynx habitat of lynx lynx habitat lynx habitat (10,526) (5,655) w/in LAU) habitat w/in w/in LAU) w/in LAU) LAU) 1LAUs were analyzed as a whole rather than at the project scale to display potential effects to lynx at a home range scale without including large areas of non-habitat in the analysis. 2Early stand initiation structural stage where the trees have not grown tall enough to protrude above the snow during winter. This habitat stage is considered temporarily unsuitable for lynx. 3Other habitat includes the stem exclusion and intermediate stages. In the stem exclusion stage, the tree crowns lift and lower branches self-prune, thus growing above the reach of snowshoe hares (LCAS 2013). These stands have very few tall shrubs or saplings in the understory. In this area, once a stand is in the stem exclusion stage, it has a limited potential to develop into mature multi-story habitat unless disturbance
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(e.g. wildfire, prescribed burning, or mechanical treatment) occurs. The intermediate stage is comprised primarily of stands that have matured past the stand initiation stages, are not structurally in the stem exclusion stage but have not yet developed into mature multi-storied stands. Lynx can readily travel through these stands and may occasionally forage in them even though snowshoe hare numbers are rather low.
The Copper King project area contains approximately 5,655 acres of lynx habitat, of which 2,080 acres are currently suitable for lynx use (Table 3.6-4). The remaining 3,575 acres of lynx habitat were converted into the early stand initiation stage by the Copper King Fire and are temporarily unsuitable (~15 years) for lynx use. This is likely too little habitat to support a lynx home range, especially for a reproducing female. Within the Big Hole LAU, even unburned habitat is generally poor for lynx given the climate, forest types, and terrain.
Currently (less than one year post-fire), the habitat is mainly unsuitable for lynx because of the high amounts of unforested areas resulting from the fire. Kosterman (2014) states that lynx home ranges measured in Montana had about 6 percent of this “open” vegetation type. In this LAU, there is now 45 percent open habitat. Also, Kosterman (2014) reports that lynx reproduced most successfully with greater connectivity of mature forest and greater edge density between mature forest and regenerating forest [late stand initiation forest]. A total of 29 percent of these two forest types remain post-fire in an unconnected manner because only patches remain after the fire. Thus only about 29 percent of the LAU is usable lynx habitat, which is quite disconnected. Vanbianchi et al. (2017) confirm older research that found severely burned areas without residual vegetation are of little use to lynx until regrowth is well underway. They do, however indicate that unburned islands, and low/mixed-severity areas can serve as functional lynx habitat immediately after fire. In the case of the Copper King Fire, such a limited amount of suitable habitat remains in the LAU, that year-long persistence of lynx would be highly unlikely. Additionally, the Big Hole LAU is the most disconnected LAU on the west side of the Lolo National Forest (Plains/Thompson Falls and Superior Ranger Districts) because it is surrounded by low-elevation river valleys (Clark Fork, Thompson, and Little Thomson Rivers) and not connected to any other LAU. The high amount of this recently-burned, early stand initiation area will likely preclude lynx use over the next 10-20 years.
In the future (15+ years), the high severity burn areas within lynx habitat have the potential to provide abundant:
foraging habitat when the trees regenerate and grow tall enough to protrude above the snow during winter; and
denning habitat once fire-killed trees fall down, creating piles of coarse woody debris.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, of cumulative effects on lynx or lynx habitat because no activities would occur.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 would not adversely affect lynx because:
The potential for affecting even one individual lynx is low because the species is uncommon in this part of the Lolo National Forest. The lack of enough current habitat to support a lynx home range suggests that lynx would not likely use Big Hole LAU until
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the vegetation sufficiently regenerates in about 15 years, long after the completion of project activities.
Salvage operations would remove dead trees only in unsuitable lynx habitat where the Copper King Fire converted stands to the early stand initiation phase or within areas that are not lynx habitat (lower elevation and/or dry forest types).
Salvage would not affect habitat connectivity because the Copper King Fire already removed the forested cover, which provides for lynx travel. The 102 acres of live tree thinning would not occur within lynx habitat and would maintain cover.
Current and future denning habitat would remain abundant and widespread.
None of the proposed activities would create any large barren areas that Squires et al. (2013) suggest impede lynx movement.
Alternatives 2 and 3 would have no effect on lynx foraging habitat because dead trees would only be removed in unsuitable lynx habitat where the Copper King Fire converted stands to the early stand initiation phase or within areas that are not lynx habitat (lower elevation and/or dry forest types). Disturbance/displacement of individual lynx potentially traveling through the area during project implementation is unlikely because the species is uncommon in this area and suitable habitat is scarce due to the fire. Closure of the Bay State Creek trail to motorized use within the Big Hole LAU would have little effect on lynx because motorized use of the trail is low and this activity is not a factor in defining lynx use (Squires et al. 2010).
After about 15 years, unsuitable habitat would become suitable when trees grow tall enough to protrude above the snow in winter. Salvage units located within these areas would have lower levels of dead standing and dead/down trees than untreated areas. In Alternatives 2 and 3, this would occur on approximately 382 and 693 acres, respectively, which is about 5 and 8 percent, respectively, of the lynx habitat in the LAU. In the future, the trees that would be removed would have served as limited horizontal cover helping support a snowshoe hare population and serve as potential denning structure. However, even with salvage, denning structure would be super-abundant in the future because 2940 acres in Alternative 2 and 2629 acres in Alternative 3 would remain untreated, which means Alternatives 2 and 3 would retain 95 and 92 percent, respectively, of the potential future denning habitat. Therefore, effects to lynx and lynx habitat would be insignificant (would never reach a scale where take would occur).
Cumulative Effects Alternatives 2 and 3 would not individually or cumulatively adversely affect lynx productivity, survival, movement, dispersal, or habitat.
Salvage operations on other ownerships (State and Weyerhaeuser) would not affect Canada lynx because they will occur outside of lynx habitat or within burned, currently unsuitable habitats; therefore these activities would not contribute cumulative effects. If an individual lynx travels through the area during salvage activities, it could be temporarily displaced. The potential for cumulative effects from disturbance is insignificant because lynx presence is unlikely due to the lack of cover and paucity of habitat and/or suitable habitat resulting from the Copper King Fire. There are no other management activities currently occurring or planned to occur within the Big Hole LAU that would affect lynx habitat.
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Forest Plan Consistency Alternatives 2 and 3 are consistent with the applicable standards of the NRLMD, amended to the Lolo Forest Plan in 2007 because they would have no effect on foraging habitat or habitat connectivity (see Wildlife report in the Project File). The rationale for the determination of effects also demonstrates project consistency with Forest Plan forest-wide standards 24 (page II- 13) and 27 (page II-14) that state federally listed species will be managed for recovery, with management practices in essential habitat compatible with the species’ needs.
Wolverine In February 2013, the U.S. Fish and Wildlife Service listed wolverine as a proposed threatened species (Federal Register 78:7864-7890, February 4, 2013). They concluded that while wolverines appear stable to expanding, the primary threats to the contiguous U.S. population are the risk of eventual habitat and range loss due to climate warming, with secondary threats from trapping/wolverine harvest, with potential threats from disturbance associated with human developments [e.g. houses and ski areas] and transportation corridors [e.g. interstate highways and high volume secondary highways], and loss of genetic stochasticity due to isolation between snowy habitats caused by climate change (Federal Register 78:7864-7890, 2013). The USFWS specifically mentions that forestry-related management practices are not likely a factor contributing to the decline (78 FR at 7879). Timber management, winter elk security, thermal cover, or over-the-snow uses managed by the Forest Service were not identified as threats to the U.S. population (78 FR at 7878-79).
On August 13, 2014, after considering the best available science, the USFWS declared that listing the wolverine as a threatened species was not warranted because they determined the effects of climate change are not likely to place the wolverine in danger of extinction now or in the foreseeable future (79 FR 47522). Although the USFWS acknowledged that climate change effects are expected to result in loss of some wolverine habitat, they noted that there is no available data to inform whether or how these projected impacts may affect the viability of wolverine populations. In addition, there is evidence that the population is increasing and that wolverines are expanding both within areas currently occupied as well as suitable habitat not currently occupied (79 FR 47536). Thus, the USFWS withdrew its proposed listing rule.
The U.S. Fish and Wildlife Service’s determination was challenged in Court. In April 2016, the District Court of Montana ruled that the U.S. Fish and Wildlife Service must reconsider protections for wolverines under the Endangered Species Act. Currently, the species is proposed for listing under ESA.
The wolverine is also identified as a sensitive species by the Forest Service in Region 1. Up until November 2012, this species was legally trapped in Montana under the administration of Montana FWP. In November 2012, a court-issued restraining order suspended all wolverine trapping in the state of Montana and the trapping season remains closed.
Surveys for wolverines and other carnivore species have been conducted across the Lolo National Forest in the last several years. There were no detections (confirmed DNA) of wolverines on the Plains/Thompson Falls Ranger District (USDA Forest Service 2012). However, in summer 2015, a young male wolverine was hit by a car on Highway 200 near the mouth of Weeksville Creek, immediately southeast of the project area.
Low detection rates are normal because wolverines naturally occur in low densities with a reported range of one animal per 25 square miles to one animal per 130 square miles (Hornocker
104 Copper King Fire Salvage Environmental Assessment and Hash 1981; Hash 1987; Copeland 1996; Inman et al. 2007a). This may be due to their need for large territories and their tendency to defend those territories from other wolverines (79 FR at 47530).
Habitat Factors Wolverine occurrence has been correlated with remoteness from human development (Banci 1994). However, historical records for western North America reveal little evidence of wolverine presence outside of subalpine habitats (Aubry et al. 2007). The only study to look at wolverine’s spatial relationship with human infrastructure (May et al. 2006) found spatial separation occurring at broad spatial scales but little evidence of avoidance at finer scales (Copeland et al. 2010). The negative association between wolverines and human presence is sometimes interpreted as active avoidance of human disturbance, but it may simply reflect the wolverine’s preference for cold, snowy, and high-elevation habitat that humans avoid (79 FR at 47537). The U.S. Fish and Wildlife Service concluded that because wolverine habitat is generally inhospitable to human use and occupation and most of it is also federally managed, wolverines are somewhat insulated from impacts of human disturbances from industry (e.g., logging), agriculture, infrastructure development, or recreation.
Deep, persistent, and reliable spring snow cover (April 15 to May 14) is the best overall predictor of wolverine occurrence in the contiguous United States (Copeland et al. 2010). Wolverine year- round habitat use takes place almost entirely within the area defined by deep, persistent spring snow (78 FR 7868). This is likely related to the wolverine’s need for deep snow during the denning period (78 FR 7872). No records exist of wolverines denning anywhere but in snow, despite the wide availability of snow-free denning opportunities within the species range (78 FR 7867). The deep, persistent spring snow area in the Copeland et al. (2010) model captures all known wolverine dens in the contiguous United States (78 FR 7868). Additionally, except for denning females (denning habitat is not considered scarce or limiting to wolverine reproduction), wolverines are occasionally observed in areas outside the modeled deep, persistent snow zone, and factors beyond snow cover may play a role in overall wolverine distribution (79 FR 47534). In the contiguous United States, valley bottom habitat appears to be used only for dispersal movements and not for foraging or reproduction (78 FR 7868).
Within the Copper King project area, there are approximately 5,302 acres (18 percent of the project area) mapped where snow persists between April 15 to May 14, which lie along the high- elevation ridges and north aspects. All 5,302 acres are classified as having a less than 50 percent chance of spring snow persisting in that area. Thus even though there is mapped wolverine habitat within the project area, it is relatively poor because the persistence of spring snow is inconsistent between years. The lack of high elevation cirque basins and limited amount of persistent spring snow areas, suggests that wolverines would likely only use the project area for transitory habitat rather than for breeding and year-round use.
Wolverines are opportunistic feeders and consume a variety of foods depending on availability. They primarily scavenge carrion, but also prey on small animals and birds, and eat fruit, berries and insects (78 FR 7867).
Home ranges for wolverines are large and vary greatly in size depending on availability and distribution of food and sex and age of the animal. In central Idaho, average home ranges for resident adult females were 148 square miles (~95,000 acres) and average home ranges for resident adult males were 588 square miles (~376,000 acres) (Copeland 1996). Wolverines in
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Glacier National Park had average adult female home ranges of 55 square miles (~35,000 acres) and adult male home ranges of 193 square miles (~124,000 acres) (Copeland and Yates 2006).
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on wolverine because no activities would occur.
Alternatives 2 and 3: Direct and Indirect Effects Salvage activities in Alternatives 2 and 3 would overlap about 400 acres (7 percent) of the mapped wolverine habitat within the project area. However, wolverines are not thought to be dependent on vegetation or habitat features that may be manipulated by land management activities. They have been documented using both recently logged areas and burned areas (78 FR 7879). Therefore, timber harvest would not adversely modify the habitat or preclude wolverine movement or use of the area.
Because of their naturally low densities, and large home ranges, the potential for affecting even one individual wolverine is low. Direct effects, if they should occur would be in the form of disturbance and displacement caused by salvage operations and increased road use. If a wolverine were present during project implementation, it could be temporarily displaced. However, effects would likely be inconsequential due to the flexibility of habitat use shown by wolverines, the large size of a wolverine’s home range, and there are numerous undisturbed areas within and outside the Copper King project area that this wide-ranging, opportunistic omnivore could use for displacement.
Lastly, Alternatives 2 and 3 would not have a discernable impact on atmospheric concentrations of greenhouse gases or climate change, considering the limited changes in both rate and timing of carbon flux predicted within these relatively few affected forest acres and the global scale of the atmospheric greenhouse gas pool and the multitude of natural events and human activities globally contributing to that pool (see Forest Carbon Storage and Climate Change section 3.2.3).
Cumulative Effects Salvage on other ownerships would unlikely have any effect on wolverines because these lands are located in the drier forest types and lower elevation areas, outside of wolverine habitat. Potential disturbance to an individual traveling through the area would be unlikely and discountable.
Alternatives 2 and 3 would not lead to a loss of species viability or jeopardize the continued existence of the wolverine because:
The potential to affect even one wolverine is low. There are numerous undisturbed areas within and adjacent to the project area that a wolverine could displace to.
Activities would not change the presence, absence, or abundance of snow remaining late into the spring at either the project level or wolverine home range level. None of the alternatives would have a discernable effect on climate change.
Proposed land management activities are actions that do not pose a threat to wolverines at a population level (79 FR 47539). Additionally, these activities, though they may affect individuals are of little consequence due to the species’ large home range size. Any
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effects to individual wolverines caused by this project would not be elevated directly, indirectly, or cumulatively to a level that would represent a loss of viability.
No activities would affect denning habitat.
The project would not increase long-term human use or access to habitat areas of persistent snow.
Salvage activities would not affect wolverine movement or dispersal across the landscape.
Sensitive Species The Forest Service manual and Lolo Forest Plan require the Lolo National Forest to manage for sensitive species. The Forest Service manual defines sensitive species as those plant and animal species identified by a Regional Forester for which population viability is a concern. For species identified as sensitive, the Forest Service shall avoid or minimize impacts to species whose viability has been identified as a concern (FSM 2670.32). Forest Plan standard 27 (at p. II-14) directs the Forest to manage for population viability. All action alternatives are consistent with this direction (see summary for each species below and more detailed information in the Wildlife report in the Project File).
Black-backed Woodpecker Black-backed woodpecker is classified as a “Species of Concern” in Montana, having very limited habitat and/or potentially declining populations in the state; worldwide, it is classified as “common, widespread and abundant” (Montana Natural Heritage Program, Field Guide website, 5/29/13). Samson’s (2006a) assessment in the Forest Service’s Northern Region indicates that habitat is well-distributed and species viability is secure. Counts from the Rocky Mountain Avian data Center from Montana indicate either stable or increasing trends in the last 8 years (2009- 2016) (http://rmbo.org/v3/avian/ExploretheData.aspx, accessed 1/2017).
The apparent disparity between Montana species of concern status and Samson’s (2006a) lack of viability concerns is likely due to a factor identified by Hoyt and Hannon (2002) who studied the species in both burned and unburned habitats. They specify that the species is more burn dependent and its persistence is likely to relate closely to the occurrence of post-fire habitat. Thus at a broad scale, in unburned habitats, black-backed woodpeckers are rare and difficult to find, and may exhibit poor reproduction, but in recent post-fire habitats they are abundant and easy to detect (consider Cilimburg et al. 2006, Hutto 1995).
Hutto (1995) stated that it would be difficult to find a forest-bird species more restricted to a single vegetation cover type in the northern Rockies than the black-backed woodpecker is to early post-fire conditions. Other research (Caton 1996, Hitchcox 1996, Hejl and McFadzen 2000, Powell 2000) also confirmed black-backed woodpeckers utilizing recent burns which were primarily large, stand replacement wildfires. Habitat relationships developed from regional landbird monitoring point count data also show this close association between black-backed woodpeckers and post-fire habitats (http://avianscience.dbs.umt.edu/research_landbird.htm). Black-backed woodpeckers appear capable of migrating long distances to exploit rich foraging resources such as those that occur in recent burns or other large-scale natural disturbances (VanTyne 1926, West and Speirs 1958, Bock and Bock 1974, Yunick 1985).
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Post-fire habitat only provides suitable black-backed woodpecker habitat for a limited time period. Caton (1996) reported that black-backed woodpeckers move into a stand shortly after the trees have burned, and woodpecker numbers usually peak in two or three years. Hutto (1995) reported that black-backed woodpeckers have usually left the stand five to six years after a fire. Harris (1982) indicated that numbers declined after four to five years. Hoyt and Hannon (2002) note that a post-fire area may remain suitable for the black-backed woodpecker up to an interval of eight years post-fire.
Foraging Recently burned (generally 0-5 years) forests tend to provide the primary foraging habitat for black-backed woodpeckers. These recently burned forests contain the highest concentrations of woodborer beetles and larvae (Buprestidae, Cerambycidae, and Siricidae), the primary food source for black-backed woodpeckers. Murphy and Lehnhausen (1998) found black-backed woodpeckers primarily foraging on moderately to heavily burned trees with a range of fire severities that included trees burned only at the base to totally burned trees. Saab and Dudley (1998) found black-backed woodpeckers associated with high intensity, stand replacement fires, and Powell (2000) found that most foraging occurred on totally burned trees.
Nesting The black-backed woodpecker is a primary cavity nester in that they excavate their own cavities, usually in April and May. Black-backed woodpeckers utilize a variety of tree species for nesting. In Oregon, Montana, South Dakota, and Idaho these woodpeckers were found to nest in Douglas- fir, ponderosa pine, lodgepole pine, western larch, and aspen (Bull et al 1986, Caton 1996, Hoffman 1997, Mohren 2002, Taylor and Schachtell 2002). Black-backed woodpeckers primarily nest in dead trees, though nests are also found in live trees within burned and bark beetle infested stands (Dixon and Saab 2000). Saab et al. (2002) found that black-backs nest in medium-sized snags (15.6 + 0.8 inches dbh). Average diameter of nest trees ranged from 9.8 to 15.7 inches dbh in Oregon, Montana, South Dakota, and Idaho (Bull et al 1986, Caton 1996, Hoffman 1997, Mohren 2002, Taylor and Schachtell 2002). Forristal et al. (2005) found that black-backed woodpeckers nested in stands with higher densities of snags compared to random plots. Saab et al. (2004, 2007) found that time since fire had the greatest influence on occupancy of nest cavities for black-backed woodpeckers. Specifically, they report that black-backed woodpeckers nested in areas with significantly higher snag densities (43 + 6/acre in logged forests and 51 + 10/acre in unlogged forests) and larger trees (15.5 inches) than non-nest areas in Idaho post-burn forests (Saab et al. 2002). Nesting numbers peaked 4 years post-fire (Saab et al. 2007). Hutto and Gallo (2006) also found that black-backed woodpecker nests decreased from the third to fifth year after fire.
Threshold Samson (2006b) estimated that the amount of habitat needed for a minimum viable population of black-backed woodpeckers within the Forest Service Northern Region is 29,405 acres (approximately 46 square miles). Over 700,800 acres burned on National Forest System lands in the Northern Region from 2013 through 2016. This acreage is over 23 times more habitat than Samson’s (2006b) estimate for maintaining a viable population. The Lolo National Forest presently has about 50,000 acres of post-fire habitat that burned within the past 4 years. Besides the Copper King salvage proposal of at most 2312 acres, none of this burned area was harvested. This post-fire habitat on the Lolo National Forest alone is twice the amount of habitat that Samson (2006b) estimated is needed to maintain black-backed woodpecker viability across the entire Northern Region.
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Management Recommendations Recommendations in the scientific literature regarding black-backed woodpeckers include:
Powell et al. 2002 recommends retaining stands with high prey densities in post-fire areas.
Hutto (1995), Hitchcox (1996), and Russell et al. (2006) recommend preserving large areas of dense snags in post-fire areas.
Murphy and Lehnhausen (1998), Kotliar et al. (2002), Saab et al. (2004), Hutto (2006), and Hutto and Gallo (2006) recommend retaining unlogged portions of post-fire areas for 0-5 years following fire.
Kotliar et al. (2002) recommend applying different salvage treatments across fire areas including variation in tree distributions, sizes, and species left uncut.
Saab and Dudley (1998) recommend retaining clumps of trees versus uniformly distributed trees in order to promote snag longevity. They also recommend retaining large snags (greater than 20 inches dbh) in order to lengthen the time a post-fire area is suitable for foraging and nesting. Large snags are known to have greater longevity than smaller snags.
Bonnot (2006) recommends delaying harvest in post-fire areas until after the black- backed woodpecker breeding season to minimize disturbance.
Kotliar et al. (2002) and Russell et al. (2006) recommend retaining a diversity of snag species, sizes, and spatial distributions as well as snags in various stages of decay in burned forests.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects to black-backed woodpeckers or their habitat because no post-fire salvage would occur. Firewood cutting of fire-killed trees (potential black-backed woodpecker forage and nesting trees) along open roads within the fire perimeter will likely occur. However, in the context of the 15,743 acres of suitable habitat (moderate to high burn severity) on National Forest System land within the project area, removal of some trees as firewood would be inconsequential.
Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 include approximately 1502 and 2312 acres, respectively, of post-fire salvage, which represents 9 and 14 percent, respectively of the suitable black-backed woodpecker habitat on National Forest System land in the project area. Within salvage units, most potential forage trees would be removed. Although dead trees less than 8 inches in diameter would remain on site, these have little habitat value for the species.
Units are relatively small (Alternative 2 - 86 units, averaging about 17 acres each; Alternative 3 - 107 units, averaging about 22 acres each), although in several cases multiple units are adjacent adding to salvaged patches up to about 100 acres. Even these patches would maintain abundant and nearby post-fire habitat for a bird that can travel long distances. Although individual birds may be disturbed during salvage operations, there would be abundant, nearby habitat to displace to.
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Abundant habitat would be retained in the 14,200 acres (91 percent) and 13,400 acres (86 percent), respectively, of the moderate to high burn severity areas that would be left untreated in Alternatives 2 and 3. This unaffected habitat would provide nearly half of the habitat needed to provide for a viable population across the entire Northern Region (Samson 2006a). Post-fire research (Hutto 1995, Hitchcox 1996, Russell et al. 2006, and Saab and Dudley 1998) recommends preserving large areas of dense snags to provide habitat for post-fire species, like black-backed woodpecker.
As displayed in Table 2-9, Alternatives 2 and 3 would retain approximately 90 and 85 percent, respectively, of the acres of the larger tree diameter classes greater than 15 inches; and about 91 and 86 percent, respectively of the acres of the larger tree diameter classes greater than 10 inches on National Forest System land within the fire area. This would provide abundant nest trees for the species.
Salvage of nest trees within harvest units could destroy black-backed woodpecker eggs or nestlings if tree felling occurs in late spring or early summer before July 1st when young birds fledge and are able to move away from salvage activities. In 2017, salvage operations are unlikely to begin before July 15th. Therefore, there would unlikely be any egg or nestling mortality during the first operating season. In future years, if logging were to begin before July, surveys would be conducted within salvage units to identify nest trees. If nests are located, affected units would not be harvested until after July 1st, when the young birds have fledged (see Resource Protection Measures in Chapter 2). Therefore, salvage operations would not result in the mortality of eggs, nestlings, or adult black-backed woodpeckers.
Cumulative Effects Past timber harvest on approximately 17 percent of the National Forest System lands within the fire perimeter and firewood cutting has resulted in some areas with lower numbers of larger trees before the fire and therefore fewer larger snags post-fire available for the species. However, nearly 16,000 acres was unharvested; therefore the loss of some larger trees before the fire is likely inconsequential to the species.
Salvage operations on State and Weyerhaeuser lands will remove forage and nest trees on approximately 2,978 acres. The forested condition of these lands before the fire is unknown. Cumulatively, Alternatives 2 and 3 combined with salvage on other ownerships would affect only 15 and 18 percent, respectively, of the 29,000-acre Copper King Fire. Even if the unsalvaged areas on private and State lands do not contain suitable habitat, untreated suitable habitat on National Forest System land (13,400 to 14,200 acres, depending on alternative) would provide abundant foraging and nesting habitat, about 46-48 percent of the estimated habitat needed to maintain a viable population across the entire Northern Region (Samson 2006a).
In a broader context, of the 61,234 acres of National Forest System land that burned in wildfire within the Northern Region in 2016, at most approximately 2,362 acres (4 percent) (Copper King and Roaring Lion on the Bitterroot National Forest) would be salvaged. The untreated 2016 fire areas alone would provide twice the estimated habitat needed to maintain a viable population across the entire Northern Region (Samson 2006a). This is indicative of the relatively small amount of post-fire salvage that has occurred within the Northern Region over the last decade (Table 3.6-5), which further emphasizes that post-fire habitat for black-backed woodpeckers is, has been, and will remain abundant. The Region’s prescribed burning program also contributes additional habitat for the species.
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Table 3.6-5: Wildfire and Salvage Activities on National Forest System Land within the Northern Region and the Lolo National Forest over the Last Decade Unit Total National Wildfire on NFS land Post-fire Salvage on NFS land Forest System 2007-2016 2007-2016 land (NFS) Acres and percent of Acres and percent of wildfire acres NFS land burned on NFS land Forest Service 25,000,000 2,147,230 (9%) 24,461 (1.1%) Northern Region Lolo National Forest 2,400,000 193,949 (8%) 2720 (2007 Jocko and Chippy fires) (1.4%)
Alternatives 2 and 3 would not lead to a loss of species viability or contribute to a trend toward Federal listing because:
A comparison of habitat required for a minimum viable population to that available indicates well-distributed habitat far exceeds that needed, given the natural distribution of the species and their habitats as mapped and according to the scientific literature (Samson 2006b). Black-backed woodpecker habitat is abundant and well-distributed across the Region and Lolo National Forest (Samson 2006a, USDA Forest Service 2012).
Salvage activities would be consistent with the recommendations in the scientific literature to retain large areas of dense snags in post-fire areas. These untreated areas would contain a variety of tree species and size classes, including the majority of large snags on National Forest System land within the fire perimeter.
Evidence suggests the black-backed woodpecker is increasing in numbers in the United States (as cited in Dixon and Saab 2000). No demographic information exists to suggest a decline in woodpecker numbers. Bird counts from the Rocky Mountain Avian data Center from Montana indicate either stable or increasing trends in the last 8 years (2009- 2016) (http://rmbo.org/v3/avian/ExploretheData.aspx, accessed 1/2017).
Gray Wolf In May 2011, the U.S. Fish and Wildlife Service removed gray wolves in a portion of the Northern Rocky Mountain Distinct Population Segment (DPS) encompassing Idaho, Montana and parts of Oregon, Washington, and Utah from the Federal List of Endangered and Threatened wildlife species. The U.S. Fish and Wildlife Service and the states will monitor wolf populations in the Northern Rocky Mountains DPS and gather population data for at least five years. Wolves in Montana are now managed under the Montana FWP Gray Wolf Management Plan as a hunted and trapped game species. Since delisting, wolves are analyzed as a sensitive species by the Forest Service in the Northern Region. Population trend numbers reached about 650 wolves in 2011 (Bradley et al. 2013). Prior to delisting, populations were increasing and they appear to have stabilized since 2011 (ibid.).
Currently, there are no wolf packs known to regularly use the Copper King project area (Bradley et al. 2014).
Alternative 1: Direct and Indirect Effects Alternative 1 would have no direct, indirect, or cumulative effects on wolves because no activities would occur.
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Alternatives 2 and 3: Direct and Indirect, and Cumulative Effects If present during project activities, wolves could be temporarily displaced as they would likely avoid areas with active salvage harvest and road work. However, the effects would be discountable because of the wolf’s wide-ranging nature (wolf pack home ranges vary from 50 to 200 square miles), even considering salvage operations on other ownerships and ongoing BAER road work. Activities would not occur all at once, but would be separated in time and space such that large portions of the project area would provide suitable areas for displaced individuals.
Cumulative Effects The Montana Wolf Conservation Management Plan requires the State to regulate wolf harvest to maintain a minimum number of breeding pairs. Thus, it is unlikely that legal hunting would be allowed to lower the wolf population to a point where viability is a concern. Montana FWP also manages deer and elk populations. It is unlikely that the State would manage big game populations to levels so low that wolves would begin switching to alternative prey.
Although project activities could temporarily displace wolves if they are present during implementation, Alternatives 2 and 3 would not adversely affect species viability or contribute to a trend toward Federal listing.
Fisher Fisher is considered a Montana state species of concern, yet they are also classified as a furbearer and thus population numbers are managed by Montana FWP. The species is legally trapped under a limited quota system. Trapping records indicate 2 fishers were trapped in Sanders County (where the Copper King project is located) in 2013 and four were trapped throughout Trapping District 12, which includes Sanders and Lincoln Counties (MTFWP trapping website, accessed 12/8/2016).
Fishers were petitioned for listing as a threatened or endangered species in February 2009. In March 2011, the U.S. Fish and Wildlife Service determined that listing was not warranted (76 FR 38504, June 30, 2011). Based on limited survey information, the current distribution of fishers appears similar to the historic distribution in Idaho and Montana. Precise, current fisher population numbers or trends are unknown. Population numbers were never thought to be historically large because the species is extremely limited in distribution due to its large home range size, particularly in naturally fragmented landscapes. To add to their limited distribution, fishers are highly territorial; therefore overlap among individuals is limited. This also makes the species difficult to survey for and detect. It is known that fisher populations in Montana have resurged from previous lows in concert with human development, timber harvest, and regulation of trapping harvest by Montana FWP.
Research to determine distribution and abundance of fisher using DNA analysis of hair has been ongoing in the Northern Region of the Forest Service since 2007 (Schwartz et al. 2007). Between 2007 and 2017, surveys conducted on the Lolo National Forest detected two fishers about 10 and 15 miles south of the Copper King area. The locations of the detections have been in the expected habitat types and conditions that are also used in habitat modeling for fisher. Because of the patchy distribution of fisher habitat and the difficulty in surveying for the species, lack of detection in these surveys doesn’t necessarily indicate species absence.
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Habitat Factors The home range of fishers varies in size from 6,400 to 20,480 acres (Jones 1991, Heinemeyer 1993, Ruggiero et al. 1994). Foresman (2012) estimated fisher average home range from 4480 to 20,480 acres (average female: 4480 to 7680 acres). Optimum habitat is thought to include mature, moist coniferous forest with a complex understory structure, including a woody debris component (ibid. and Banci 1989; Powell and Zielinski 1994). Samson (2006b) describes fisher habitat as including the following vegetation dominance groups: 1) yew, 2) tolerant mix of grand fir, cedar, and western hemlock, 3) tolerant grand fir/cedar/hemlock, and 4) cedar. Riparian/forest ecotones in low- to mid-elevation areas that do not accumulate large amounts of snow appear important. A review of the above research suggests that the species uses a diversity of tree age and size class distributions at the patch or stand level that provide sufficient (generally greater than 40 percent) overhead cover (either tree or shrub). Based on very limited research of re- introduced populations, fishers in northwestern Montana were most often found in moist grand fir and cedar habitat types (Heinemeyer 1993). Banci (1989) believes the best fisher habitats are multi-aged stands interspersed with small openings and containing riparian habitats. The fisher feeds on snowshoe hares, porcupines, carrion, squirrels, small mammals, and birds (Banci 1989, Powell and Zielinski 1994).
In a study in the Bitterroot Mountains near Lolo Pass, about 70 miles southeast of the Copper King project area, Schwartz and others (2013) found that fishers disproportionately used both stand sites and regional landscapes characterized by large diameter trees and avoided areas with ponderosa pine and lodgepole pine. The average maximum tree diameter in used habitats was 42 inches versus 25 inches in unused habitats. The stands most used by fishers were those mature forests with both large and smaller trees, consistent with evidence that fishers need cover for hunting efficiency or predator escape purposes. They also found that fishers clearly avoided openings such as clearcuts and grassy slopes. They also avoided uniform early seral forests, like lodgepole pine stands. Thus, Schwartz et al. (2013) recommend forest activities that promote the growth of multi-stage stands with ample structure and variation in tree widths and ages to provide the best habitat for fishers.
In the Clearwater Mountains of north-central Idaho, Sauder and Rachlow (2014) found that landscapes with greater than or equal to 50 percent mature forest arranged in contiguous, complex shapes with few isolated patches, and open areas consisting of less than or equal to 5 percent of the area appear to constitute a forest pattern used by fisher.
Seasonal Habitat Considerations Fishers are thought to be limited by high elevation and deep snows although thresholds beyond which the species does not occur have not been precisely calculated. In winter, Heinemeyer (1993) found reintroduced populations of fisher in northwest Montana remained on flat slopes near water at lower elevations. In summer, Jones and Garton (1994) found 90 percent of the observations recorded for 16 radio-collared animals (9 male and 7 female) introduced into north central Idaho, in mature and old-growth forests; whereas in winter young and mature forest were used equally.
Estimates of Fisher Habitat Samson (2006b) used a habitat relationship model to estimate the critical habitat threshold and the amount of habitat available for several species, including fisher, on each forest in Region One. This model used the vegetation inventory information from the Forest Inventory and Analysis (FIA) database as well as remote sensing data. (Samson 2006b). The estimated critical habitat threshold for maintaining a minimum viable population of fisher across all of Region 1 is 100,078
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acres (Samson 2006b). Samson’s (2006b) conservative estimates of fisher habitat on the Lolo National Forest show that fisher habitat is relatively abundant comprising 530,782 acres in winter and 159,136 acres in summer. The most recent habitat model (Olson 2014 VMAP model) identifies 620,540 acres as having a medium and high probability22 of providing fisher habitat on the Lolo National Forest (USDA Forest Service 2014). Therefore, habitat on the Lolo National Forest appears more than sufficient to maintain fisher viability across the entire region.
Using the Olson model, the Copper King project area has about 1,913 acres that has a high probability of providing fisher habitat and an additional 4,328 acres that has a moderate probability of providing fisher habitat. The larger patches of these high and moderate probability areas are in upper Big Hole Creek and Todd Creek while smaller areas exist along the Road #9991 [ACM road], in lower Calico Creek, and in upper Munson Creek.
The Copper King Fire burned at moderate to high severity on approximately 4,333 acres (about 70 percent) of the areas that have a moderate or high probability of providing fisher habitat. These acres are now unsuitable habitat for at least the next 10-20 years due to the loss of vegetation. In addition, approximately 1215 acres of moderate to high probability habitat burned at low severity, which likely lowered the amount of downed coarse wood, reducing the habitat complexity and thus the overall habitat quality. Only about 500 acres of fisher habitat remains unburned; therefore little suitable habitat remains and is not likely enough to support year-round fisher use although some individuals could travel through the area.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on fisher because no activities would occur.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 would have no direct, indirect, or cumulative effects on fishers or their habitat because:
Salvage activities would occur within areas that are unsuitable for fishers because of the loss of canopy cover and live tree density from the fire (see Figure 3.6-1). Timber harvest would not preclude the regeneration of forest vegetation over time (Peterson and Dodson 2016; Knapp and Ritchie 2016).
Fishers would not likely use the burned unsuitable habitat regularly for several years (at least for 10-20 years until shrubs, young trees and fallen logs dominate the stands, but possibly not for up to 60 years after mature forests develop).
Salvage activities would occur on a relatively small portion of the National Forest System land in the project area (8 percent in Alternative 2 and 12 percent in Alternative 3). Coarse woody debris would be abundant in untreated areas once the dead trees fall down.
22 High to medium probability fisher habitat is expected to provide the forest composition, vertical and horizontal structure, ecosystem function, and connectivity that characterizes the mature and older forest habitat that fisher select for. Medium probability fisher habitat has lesser amounts of desired habitat characteristics than high probability habitat. Both high and medium values contribute towards overall fisher habitat if both are within potential dispersal distances that fisher use within a home range or may traverse to find and occupy a new home range or territory (USDA Forest Service 2014).
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Coarse woody debris would be left in salvage units and would provide for future fisher habitat, although the quantity would be less than if left untreated.
The project activities would not improve trapper access or increase vulnerability of fishers. The miles of open road would remain unchanged and the miles of trail open to motorized use would be reduced. Note: Montana FWP fisher quota in 2016/17 was zero fishers.
Peregrine Falcon Peregrine falcons uses cliff faces for nesting. These are usually situated over a large river or water body where falcons prey on ducks and smaller birds. Suitable nesting cliffs are plentiful above Road #9991 [ACM road] in the project area and above the Clark Fork River. Several known nests are adjacent to the project area on the cliffs above the Clark Fork River. Although none are currently known, suitable nest sites within the project area would most likely be along the lower 4 miles of the Road #9991 (but could be up to 9 miles from the mouth of the Thompson River).
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects because no activities would occur.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Several suitable nesting cliffs are available above the harvest units along the lower 9 miles of Thompson River. Habitat use of potential nesting pairs along this area would likely include the suitable cliff nesting site, snags or large trees used as perches, and lastly the river area itself where prey was captured from perches or above.
Alternative 2 and 3 would remove hazard trees along Road #9991 and salvage dead trees more than 300 feet from the Thompson River. Although hazard tree remediation could remove a potential perch tree, effects would be inconsequential because large, live trees along the Thompson River are plentiful. Alternatives 2 and 3 would not cause disturbance to suitable nesting cliff sites because these sites are located hundreds of feet above the harvest units. In addition, harvest would occur within sight of a heavily used open road. Hazard tree removal and salvage along Road #9991 would not affect hunting by falcons along the river any more than the current use by the public on this high traffic road.
Although there is a remote possibility of some salvage-related activity causing one or more falcons to temporarily modify its activity pattern slightly due to the removal of a few potential perch trees, Alternatives 2 and 3 would not affect species viability or lead to a trend toward federal listing. Cumulative effects from other uses of Road #9991 would also be negligible.
Townsend’s Big-Eared Bat Townsend’s big-eared bat is associated with cavernous habitat and rocky outcrops of sedimentary rock such as limestone as well as old-growth forests with large diameter hollow trees for roosting. Maternity colonies occur in warm areas of caves, mines, or occasionally buildings, and hibernacula occur in caves or mines with winter temperatures at 35 to 45ºF and relative humidity greater than 50 percent (Hart et al. 1998). In general, the big-eared bat prefers to roost alone or in small clusters (Foresman 2004). Because these bats hang exposed from cave or mine ceilings, they are very sensitive to disturbance.
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Within the Copper King project area there is one known mine adit (Silver King) which has been closed with a bat-permeable gate. Townsend’s big-eared bats occupy the mine during summer and winter (2005 Lolo National Forest unpublished survey data). Additionally, many rock faces exist in the project area that may have suitable cave-like fissures although no caves are known.
This species feeds on a variety of nocturnal flying insects, specializing primarily on moths, often near foliage, with a few reports of gleaning directly from foliage. Foraging habitats are poorly understood but are known to be variable. Riparian areas and wet meadow habitat appear important for foraging.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects because no activities would occur.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 would unlikely have any direct, indirect, or cumulative effects to this species or its habitat. Although Unit 116 is about 600 feet below the Silver King mine, no activities would occur immediately adjacent to the mine that could affect roosting. Bats could potentially forage within Unit 116 and other harvest units at night when activities would not be occurring. Therefore, Alternatives 2 and 3 would have no impact on this species.
Bighorn Sheep The Thompson Falls bighorn sheep herd uses a portion of the Copper King project area and has had a lower population for the last 3-5 years (Montana FWP 2016). Because no evidence of disease has been observed in this sheep herd, predation may be the factor that has reduced numbers in recent years. There are likely between 50 (current population) and 150 sheep (higher populations in recent years) inhabiting this area.
Bighorn sheep need open habitat where visibility is high to avoid predators and remain more spaced out in their habitat use. Increased spacing between groups of sheep likely reduces disease transmission and predator efficiency. The species also needs cliff habitats for predator escape near the open treeless habitat (Montana FWP 2012). Forested areas are unneeded by bighorn sheep and can actually be a detriment to healthy sheep populations by reducing foraging efficiency and requiring more time watching for predators rather than foraging (Reisenhoover and Bailey 1985, Smith et al. 1999). The Montana FWP (2010) Bighorn Sheep Management Plan identifies conifer encroachment as a habitat limitation on bighorn sheep in this area. Open habitats are available to a large degree in the project area especially after the Copper King Fire. Most sheep use is likely on the slopes and drainages above the Clark Fork and Thomson Rivers. Habitat likely extends from the Clark Fork River, up to about ½ mile over the Koo-Koo-Sint Ridge. On the Thompson River, habitat likely extends from the river up to the Koo-Koo-Sint Ridge and upriver into Bay State and possibly Big Hole Creek.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects because no activities would occur. However, the Copper King Fire converted over 5,000 acres of forested area currently used by the Thompson Falls herd to open habitat, which will benefit the species as described above.
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Alternatives 2 and 3: Direct and Indirect Effects Alternatives 2 and 3 would conduct salvage operations on approximately 757 and 1165 acres, respectively, of the area most likely used by bighorn sheep in the project area. Individual sheep could be temporarily disturbed and displaced by increased project-related vehicle traffic on Road #9991 and harvest activities. However, there would be ample undisturbed areas for sheep to displace to. These local disturbances have not been shown to have adverse effects on individual or population health because the energy expenditure to “escape” the disturbance is very limited. These are also the same sheep observed licking salt from the shoulder of Highway 200 and therefore project-related disturbance would unlikely have adverse impacts.
The removal of dead trees from fire-killed stands would have a slight benefit to sheep foraging efficiency by increasing visibility for sheep and reducing their vulnerability to predation. This would also provide a reduced number of down logs in coming years, allowing sheep to move through burned areas more easily. The thinning of live trees within Unit 59 (16 acres) would increase the forage potential (reduced shading from trees) and increase the visibility that enables sheep to more fully use their habitat. However, in the context of the Thompson Falls sheep herd range, these benefits would likely be unmeasurable.
Cumulative Effects Harvest conducted last fall/winter by Weyerhaeuser in Section 19 along lower Big Hole Creek may have disturbed sheep, but abundant undisturbed habitat provided areas for sheep to displace to. However, this disturbance did not and would not overlap with the timing of Alternatives 2 and 3; therefore are not considered cumulative. No other salvage activities identified on private or State lands would be completed within the area normally used by bighorn sheep. Disturbance effects of Alternatives 2 and 3 would add little to other potential impacts on the Thompson Falls sheep herd (e.g. mortality on Highway 200, predation, other natural mortality sources such as falls). Therefore, cumulatively effects would be negligible.
Flammulated Owl Flammulated owls are small, migratory insectivores that inhabit mountainous forests throughout western North America. McCallum (1994) noted that flammulated owls are “perhaps the most common raptor of the montane forests of the western United States.” The species is ranked by NatureServe as globally secure with a widespread distribution (MNHP 2008). In Montana, the Natural Heritage Program ranks the species as being abundant in some areas, but potentially at risk because of limited breeding habitat or populations (Ibid.).
In Montana, calling flammulated owls were correlated with the number of ponderosa pine trees greater than 15 inches diameter breast height (dbh); low live basal area, low canopy (less than 40 percent) in ponderosa pine and moderate canopy (less than 70 percent) in sites dominated by Douglas-fir (Wright 1996). They appear to avoid young, dense stands of Douglas-fir, clearcuts, and intensively cutover areas, but they will use thinned or selectively logged stands (McCallum 1994). Owl habitat on the Lolo National Forest is characterized by single-or two-storied ponderosa pine or ponderosa/Douglas-fir forests with 35-85 percent canopy cover and greater than 14 inches basal area weighted dbh (Samson 2006a).
Mean territory size, based on a study of four males, averaged 27.4 to 32.9 acres (Linkhart et al. 1998). Researchers found one to four areas (1.2 ± 1.0 acres in size) near the nest cavity served as important foraging areas (ibid). The flammulated owl subsists on insects, especially moths and beetles, and forages in the tree canopy, between trees, and on the ground. Closed canopy forests shade out grasses and small shrubs needed to support the owl's prey species. Also, the typical
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foraging maneuvers of the owl may be difficult in dense forests. Because of its feeding strategy, the owl needs open forested environments historically maintained by frequent fire (ibid.). These owls occur in association with managed and unmanaged stands throughout their range.
Before the Copper King Fire, the area had a limited amount of habitat because of the terrain and forest types. The severity of the fire rendered a portion of the habitat unsuitable until mature forests develop in about 4-5 decades. Currently, within the project area (post-fire), there are approximately 622 acres of suitable, existing flammulated owl habitat (Lolo National Forest, Unpublished wildlife habitat models, 2011, adjusted for fire severity). The suitable habitat is primarily located in lower to mid elevation areas around the fire perimeter. These are mature forest stands that usually contain larger snags suitable for flammulated owl nesting that did not burn or burned at low severity during the Copper King Fire.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on flammulated owls or their habitat because no activities would occur.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 would include approximately 32 acres of green tree thinning within existing flammulated habitat, which would be beneficial to the species because the habitat would be maintained in a more resilient condition. However, since the treated area is so small relative to the landscape, benefits would likely be negligible. Project activities may temporarily disturb individual birds if they are present during implementation, but due to the size of the treatment area, operations would be of short duration and there is other suitable habitat within and outside the project area that any displaced owl could move to. Planting of ponderosa pine in some areas could enhance the development of suitable habitat in about 50 or more years.
Cumulative effects would be negligible because salvage operations on other ownerships are focused in areas where habitat is likely unsuitable because the fire killed most of the trees.
Alternatives 2 and 3 would not contribute to a trend toward federal listing or a loss of species viability because salvage would not preclude development of stands within appropriate forest types into suitable habitat in the future (Peterson and Dodson 2016; Knapp and Ritchie 2016). The thinning of live trees on approximately 32 acres would be beneficial and disturbance to individual birds, if present, would be discountable.
Harlequin Duck Harlequin ducks use swift, low gradient streams with many loafing sites and overhanging vegetation for nesting. Before and after nesting, these ducks feed on aquatic insects, which are dependent on clean water. Within the project area, the Thompson River appears to have the potential to provide habitat for breeding. Habitat in the water and along the immediate creek side is used throughout the breeding season, after which the birds return to the Pacific Ocean. No harlequin ducks have been observed in the project area.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects because no activities would occur.
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Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Haul traffic on Road #9991 [ACM road] could deliver additional sediment to the Thompson River. However, resource protection measures would be applied to reduce delivery (Chapter 2). As described in the Fisheries section, the small, temporary increase in sediment loading from road-related project activities would most likely occur during periods of high runoff that correspond to high stream flows and sediment would be quickly diluted. Thus, impacts to aquatic insects, if any, would be discountable. Additional haul traffic from salvage operations on other ownerships and the replacement of 2 culverts on Road #9991 under BAER work would also contribute sediment to the Thompson River. However, in the context of the amount of naturally occurring sediment from the fire, cumulative effects would be negligible (see Hydrology and Fisheries sections 3.4 and 3.5).
Coeur d'Alene Salamander Coeur d'Alene salamanders have been found in three primary types of habitat: springs or seeps, waterfall spray zones, and edges of streams. The species uses the wet zone immediately adjacent to the stream, is generally found under moss and between rocks, but does not live in the water. It also does not use upland areas (Werner 2004). The species is found in conjunction with both perennial and intermittent surface water. Thus, it is possible to locate Coeur d'Alene salamanders at a wet site in the spring, yet be unable to find any animals at the same site later in the summer when the site is dry on the surface. Coeur d'Alene salamanders are most difficult to find in streamside habitat, where they are usually observed underneath moist rocks on the banks adjacent to the water (Montana Field Guide).
A known population exists in a cold water spring flowing over a cliff face adjacent to Road #9991 [ACM road] near Unit 119. Other known populations exist across the Thompson River and in several areas around the Plains/Thompson Falls Ranger District. Within the Copper King project area, habitat may also be available along small, steep tributary drainages such as Big Hole and Bay State Creeks.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on Coeur d'Alene salamanders because no activities would occur.
Alternatives 2 and 3: Direct and Indirect Effects Salvage harvest activities would have no effect on this species because Riparian Habitat Conservation Areas would protect suitable habitat from disturbance (see Resource Protection Measures in Chapter 2).
If the species is present, temporary road construction across small tributary streams (18832ext in Alternative 2; and 18832ext and 18780ext in Alternative 3) could have lethal effects to individual salamanders from the rearrangement of soil and rock materials near the stream and heavy equipment use. Therefore, these areas would be surveyed prior to construction activities to determine presence. If the species is present, the road location would be modified if possible. If relocation is not possible, construction activities could result in the mortality of a few individuals. However, Alternatives 2 and 3 would not lead to a loss of species viability or contribute to a trend toward Federal listing because a relatively small portion of potential habitat would be disturbed.
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Cumulative Effects Cumulative effects are likely very limited because relatively little activity would occur within and adjacent to stream channels. These actions would occur in a few discrete locations on the landscape. Past road construction likely disturbed small, localized areas of suitable habitat at stream crossings. The potential effects of this project combined with past actions and salvage operations on other ownerships would not contribute appreciable cumulative effects to this species or habitat and would not affect population viability. State required streamside management zones would be buffered from project activities.
Boreal Toad Boreal toads are found in a wide variety of habitats including wetlands, forests, woodlands, sagebrush, meadows, and floodplains in the mountains and mountain valleys (Reichel and Flath 1995, summarized in Maxell 2000 and Werner et al. 2004). Adult and juvenile toads are freeze- intolerant and overwinter and shelter in underground caverns, or more commonly in rodent burrows. While smaller juveniles are active almost exclusively during the day, adults are usually active at night except during the spring and at higher elevations. Adult boreal toads are largely terrestrial and are known to travel miles from their breeding sites through coniferous forests and subalpine meadows, lakes, ponds, and marshes (Werner et al. 2004).
Boreal toads generally breed in lakes, ponds, and slow streams, laying eggs one to three months after the snow melts (Reichel and Flath 1995, Werner et al., 2004). Timing of breeding is dependent on temperature, snowmelt, and/or the presence of surface water from flooding and takes place from May to July in shallow areas of large and small lakes, beaver ponds, temporary ponds, slow moving streams, and backwater channels of rivers. Adults will move up to four kilometers (about 2.5 miles) away from water after breeding and juveniles will disperse up to four kilometers from their birth place.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on boreal toads because no activities would occur.
Alternatives 2 and 3: Direct and Indirect Effects No salvage would occur within Riparian Habitat Conservation Areas, which would protect streamside habitat (see Resource Protection Measures in Chapter 2). Because toads are known to travel along stream areas - especially downstream (Young and Schmetterling 2009), the stream buffer would preclude any impacts on toads within or adjacent to streams.
Because the boreal toad is an upland species for the summer and early fall (before underground hibernation), its home range and daily use could overlap somewhat with salvage operations. Salvage harvest has the potential to harm individual toads (which are likely widely spaced in their upland habitats). However, potential adverse impact from project activities in non-breeding areas would likely affect only a few individuals, if present, and would not have population-level impacts. Toads are more active at night when project activities would not be occurring, which would further limit potential effects.
Cumulative Effects There are no clear reasons for declines in toad populations. Major factors known or hypothesized to have caused amphibian declines include habitat loss and alteration, pathogens and diseases, introduction of nonnative species, chemical pollutants, global climate change, and increased
120 Copper King Fire Salvage Environmental Assessment ultraviolet radiation (Werner et al. 2004). The past events in the project area that may have altered toad habitat were road construction, livestock grazing on other ownerships, mining, and logging that occurred in or near wet habitats.
Culvert replacements on live streams to be conducted in 2017 as part of BAER work will not measurably affect toads, if present, because activities would occur between July 1 and August 31, when most toads have completed their breeding cycle and returned to the uplands for the year.
Salvage operations on other ownerships could also harm individual toads in upland areas, if present. Like the Forest Service, operations would occur during the day and are limited to about 3000 acres. Large areas would be left undisturbed. Cattle grazing has been curtailed for 2017.
The potential effects of Alternatives 2 and 3 combined with those of past, present, and reasonably foreseeable actions would not contribute appreciable cumulative effects to this species or habitat and would not affect species viability. Therefore, Alternatives 2 and 3 would not contribute to a trend toward Federal listing.
Management Indicator Species Management indicator species, considered widespread and common animals, were designated in Forest Plans to represent species whose population changes are believed to indicate the effects of management activities on representative wildlife habitats (FSM 2621). The Lolo Forest Plan defines Indicator Species as “species identified in a planning process that are used to monitor the effects of planned management activities on viable populations of wildlife and fish including those that are socially or economically important” (Forest Plan, page VII-15). The Lolo Forest Plan identifies northern goshawk (natural old growth forests), pileated woodpecker (mature old growth with limited management), and elk (big game), as “Management Indicator Species” (MIS) (Forest Plan standard 27, at p. II-14 and Forest Plan Final Environmental Impact Statement, pp. III-28 through III-29).
The Lolo Forest Plan standard 27 states that habitat for management indicator species will be monitored. Elk population data, collected by Montana FWP will be compared against habitat data to test elk/habitat relationships. Forest Plan standards 21, 22, and 23 (page II-13) provide for the protection of elk habitat such as wallows and winter range. The Plan further states that as monitoring technology become available for northern goshawk and pileated woodpecker, population trends will be monitored. In the interim, habitat parameters including old growth acres and condition, and snag densities will be monitored as an indicator of population trend. In recent years, both population and habitat have been monitored at a Region-wide scale and a forest scale. This data indicates that population trends for northern goshawk and pileated woodpecker are stable or increasing. Information from these efforts is summarized in the individual species sections below.
Northern Goshawk
Status The northern goshawk is found throughout North America with breeding documented from Alaska to Newfoundland and south through the Rocky Mountains, Sierra Mountains, and into Mexico. In Region 1, the species breeds in mountainous or coniferous regions throughout western and southern Montana as well as north and north central Idaho. Goshawks winter throughout their breeding range with a portion of the population wintering outside breeding areas (Montana Distribution committee 1996; Squires and Reynolds 1997).
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According to NatureServe, the northern goshawk is globally secure – common, widespread and abundant. The species is not considered a “species of greatest conservation need” by either the states of Montana (http://fwp.mt.gov/wildthings/cfwcs/strategy.html) or Idaho (http://fishandgame.idaho.gov/cms/tech /CDC/cwcs_table_of_contents.cfm), and is not contained in either of the states’ Comprehensive Wildlife Conservation Strategies. It is no longer listed as a species of concern in Montana because of recent surveys that found them to be more abundant than previously thought (MNHP 2008).
The most recent petition for listing the goshawk under the Endangered Species Act occurred in 1997. After a formal 12-month review by a scientific committee, the U.S. Fish and Wildlife Service determined that listing under ESA was not warranted. Analysis of data from 17 states comprising 222 million acres indicated “that the goshawk population is well-distributed and stable at the broadest scale (63 FR 35183, June 29, 1998). Based on this information and Region- wide surveys, the goshawk was removed from the sensitive species list in Region One but the species is still considered a Management Indicator Species for natural old growth forests on the Lolo National Forest.
Based on recent broad-scale habitat and inventory and monitoring assessments conducted in Region 1, breeding goshawks and associated habitats appear widely distributed and relatively abundant on National Forest System lands, including the Lolo National Forest (Samson 2006a, errata corrected 2008; 2006b; Canfield 2006, Kowalski 2006). Not a single known nest site is isolated from other known nests by more than the goshawks’ estimated dispersal distance (Samson 2006a). The habitat threshold for maintaining a minimum viable population of goshawks across the entire Region is 30,147 total acres of post-fledging area (PFA) habitat (Samson 2006b). All 12 National Forests in Region One contain estimated habitat amounts that far exceed the Region-wide estimate (Samson 2006b). The Lolo National Forest contains 54,848 acres of PFA habitat, about one and one-half times the amount needed Region-wide to maintain a viable population (ibid., errata corrected 2008).
Furthermore, in a random sample of goshawks nesting in a heavily managed landscape adjacent to the Lolo National Forest, monitoring showed reproductive rates and nest success above or well within the ranges reported in studies done in less-managed landscapes throughout the western United States (Clough 2000). Results suggest goshawks do well even in managed landscapes.
Goshawks have been observed across the Thompson River from the Copper King project area. Based on the suitable habitat present in the project area before the Copper King Fire, it is expected that this species likely used the area.
Biological Information The northern goshawk occurs in a variety of forested areas throughout North America (Squires and Reynolds 1997). Some remain in a breeding area year-round, while others begin migration from breeding grounds in late September and continue through November (ibid.). In winter, limited information indicates goshawks use a greater variety of habitats than in summer (Squires and Kennedy 2006).
Pair formation and nest building begins in early April and egg-laying occurs in April and May. The adult female typically defends the nest while males hunt for food. The young fledge off the nest in mid- to late-July, remain in the home range until September when they disperse, often traveling long distances. Goshawk home ranges consist of at least three levels of habitat during the breeding season: the nest area (1 to 148 acres), post-fledging area (PFA) (about 420 acres),
122 Copper King Fire Salvage Environmental Assessment and some amount of general habitat used for foraging (i.e. Reynolds et al 1992; Kennedy et al. 1994; McGrath et al. 2003; Squires and Kennedy 2006). The diversity of forest vegetative composition, age and structure increases beyond the nest area.
Habitat Factors In its comprehensive status review of the species (see above), the U.S. Fish and Wildlife Service found that while the goshawk typically uses mature forests or larger trees for nesting habitat (the nest area), it is considered a forest habitat generalist, using a variety of types and ages. The USFWS found no evidence in its finding that the goshawk is dependent on large, unbroken tracts of “old growth” or mature forest, 63 FR 35183 (June 29, 1998).
The goshawk’s use of and dependence on mature forest’s has been debated and rebutted in the literature (i.e. Greenwald et al. 2005, Reynolds et al. 2005). “Due to frequent bias in goshawk nest detection methods…goshawk selection of mature forests [for nesting] over other forest stages has been demonstrated in only a few studies” (Squires and Ruggiero 1996 and Clough 2000, both in Squires and Kennedy 2006 at p. 25). Moser (2007) found that 39 percent of PFAs in northern Idaho consisted of forested stands dominated by greater than 12 inch diameter trees and greater than 70 percent canopy cover, whereas in west-Central Montana, Clough (2000) found PFAs consisted of 11.3 percent mature, although 66 percent of Clough’s post-fledging areas (PFAs) were comprised of stands dominated by greater than five inch diameter trees and greater than 50 percent canopy cover.
Goshawks hunt a variety of prey items on the ground, on vegetation, and in the air, including tree squirrels (all forest types and canopy covers), ground squirrels (open grass/shrub, clearcut areas), rabbits, hares (seedling/saplings, meadow/forest and riparian/forest ecotones, old growth), songbirds, woodpeckers, and grouse species that rely on a variety of forested and non-forested habitats (Squires and Reynolds 1997; Squires and Kennedy 2006). Goshawks have also been reported feeding on carrion, including gut piles left by hunters (Squires 1995, Wyoming). In west central Montana, snowshoe hares and red squirrels are used extensively (Clough 2000), and in Idaho, ground squirrels appear important (Patla 1997).
Foraging and Nesting Habitat Reynolds et al. (1992) gives recommendations for the percentage of tree size classes, openings and canopy closure within a goshawk territory. Other more recent and more local research was also used to provide a better estimate of goshawk habitat needs. These studies provide a range of successional stages recommended for goshawk foraging habitat. Due to the severity of the Copper King Fire, the project area no longer falls within the desired ranges recommended for foraging habitat from the literature across the western United States. For example, the shrub/forb/grass class is over twice that recommended in the literature.
Nesting habitat criteria includes a tree canopy cover of 60 percent or greater and tree diameter of 10 inches or greater. Within the moderate to very high severity burn areas within the Copper King project area, goshawk nesting habitat was rendered unsuitable due to the loss of tree canopy by the fire. Nesting habitat is now absent across about 10 square miles in the center of the fire area. Currently, the project area contains about 4,388 acres of suitable nesting habitat which is mainly located around the perimeter where the fire burned at a lower severity. Goshawk pairs could nest along the periphery of the area and forage throughout the fire area.
Brewer et al. (2007) recommend six nest stands of about 40 acres each or 240 acres of nesting habitat per territory. The National Forest System land in the project area is large enough to
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contain about 4 non-overlapping territories. Within the project area, there is over four times the nesting habitat recommended to support 4 goshawk pairs (Table 3.6-6).
Table 3.6-6: Effects to Goshawk Nesting Habitat by Alternative Alternative Available acres of nesting Recommended acres of nesting habitat1 habitat2 1 4,338 960 2 4296 960 3 4276 960 1 Nesting habitat is defined as: forest type equals grand fir, subalpine fir, intolerant mix, larch, western white pine, ponderosa pine, Douglas-fir, aspen, grand fir/cedar/hemlock mix, subalpine fir/spruce/hemlock mix, and birch, canopy cover greater than or equal to 60 percent, and size class greater than or equal to10 inches diameter breast height (Clough 2000, Patla 1997, Hayward and Escano 1986 - summarized in Samson 2006a) 2 Reynolds et al. (1992) recommend 6 patches of 25 acres per home range (150 acres/nesting pair). However, in Region 1, Brewer et al. (2007) recommend 6 patches of at least 40 acres per home range (240 acres per nesting pair), a more conservative approach. In the Copper King project area, 960 acres (240 acres x 4 pairs) would provide sufficient nesting habitat for the 4 potential home ranges of 5000 acres in size that could “fill” the area with goshawks.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on goshawk or its habitat because no activities would occur.
Alternatives 2 and 3: Direct and Indirect Effects Foraging Habitat Alternatives 2 and 3 would have no effect on foraging habitat because the salvage of fire-killed trees and the thinning of live trees on 102 acres would not modify the existing forest successional stages. The live tree thinning would retain the upper tree canopy, and therefore, would not change the distribution of tree size classes in the project area.
Nesting Habitat Vegetation treatments in Alternatives 2 and 3 would overlap approximately 42 and 62 acres, respectively, of suitable nesting habitat in (Units 63, 64, 66, 79 [Alt 3 only], 113, 115, 116, 117, and 118). This represents about 1 percent of the 4338 acres of nesting habitat within the project area. Timber harvest would reduce the existing canopy cover by 30-80 percent. When canopy cover is reduced below 60 percent, stands would no longer serve as suitable nesting habitat until crowns return to pre-treatment levels, more than 10 years out (Reynolds et al. 1992; Squires and Ruggiero 1996; McGrath et al. 2003). Post-treatment, Alternatives 2 and 3 would still retain over four times the amount of recommended nesting habitat (Reynolds et al. 1992), which would support more nests than the territorial nature of the goshawks would tolerate. Thus, effects would be minor given the abundance of nesting habitat within the project area.
Cumulative Effects The Copper King Fire reduced the amount of suitable nesting habitat within the project area. Because salvage operations on State and Weyerhaeuser lands will focus on the removal of fire- killed trees, potential effects to goshawk nesting habitat would be minimal. Although Alternatives 2 and 3 would alter about one percent of the nesting habitat, they would not individually or cumulatively lead to a loss of species viability because foraging habitat would be unaffected and nesting habitat would remain abundant; and goshawk habitat is abundant and
124 Copper King Fire Salvage Environmental Assessment well-distributed across the Forest and Region – more than sufficient to sustain a viable population.
Pileated Woodpecker The pileated woodpecker is considered widespread and common in Montana (MNHP 2009). In 1990, the Northern Region designed a monitoring program to help biologists and managers better understand the habitat relationships and population trends of landbirds breeding in this region. Monitoring data indicate that the pileated woodpecker population is relatively abundant and evenly distributed across the Forest and northwest Montana.
Several observations of pileated woodpecker occurred within the project area before the Copper King Fire. Sign from pileated excavations into larger dead trees is also common throughout the Plains/Thompson Falls Ranger District.
From 1995 to 2004, 762 permanent bird point count sites were placed along 22 transects randomly distributed across the Lolo National Forest. Ninety-one percent (20 of 22) of the transects had at least one pileated woodpecker detection, which indicates the species is common and abundant. Of the 762 point count sites, 132 pileated woodpeckers were detected for an average detection rate of 17 percent. Pileated woodpeckers would not be expected to occur at every point because of the large average size of their home range. These detections include observations across the Plains/Thompson Falls Ranger District.
Samson 2006 estimated the viable population for pileated woodpeckers to be 180 individuals across the entire Region. The location of 132 pileated woodpeckers on a relatively small sample of 22 transects across the Lolo National Forest suggests that the Forest supports its own viable population.
Monitoring on the Lolo National Forest in old growth stands treated to restore dry/forest old growth characteristics indicated that the woodpecker is present in treated (44 percent), untreated (63 percent) as well as in areas that burned in wildfire (33 percent) (USDA-FS 2008). In 2007, a random sample of bird species abundance in old growth on the Lolo National Forest found pileated woodpecker occurrence was common (http://www.birdsource.org/LBMP/).
Habitat Factors Although the pileated woodpecker is most often associated with mature forests (Conner et al. 1976, Conner 1980, Shackelford and Conner 1997), it is able to do well in young and fragmented forests (Mellon et al. 1992), including forested areas with just 10 percent forest cover (Bonar 2001). The nest tree is the most important variable for predicting nesting habitat (Kirk and Naylor 1996, Giese and Cuthbert 2003). In Montana, the species selects western larch for nesting more frequently than other tree species, followed by ponderosa pine, black cottonwood, aspen, western white pine, and Douglas-fir (McClelland and McClelland 1999). Nest tree diameters are generally larger than 15 inches (ibid.), and winter roost trees are generally larger than 10 inches in diameter (Bonar 2001). Pileated woodpeckers are considered non-migratory. Territory size varies from 700 to 1557 acres for breeding pairs (Bull and Holthausen 1993).
Estimates of habitat determined from Forest Inventory and Analysis data clearly indicate that habitat for the species is abundant and well-distributed Region and forest-wide (Samson 2006a). On the Lolo National Forest, conservative estimates showed 99,080 acres of habitat is available for nesting and 157,470 acres for wintering foraging (considered a critical time of the year for the
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woodpecker). Available habitat on the Lolo National Forest alone is twice that needed to maintain a minimum viable population of the species in the entire region (Samson 2006b).
As discussed above, the pileated woodpecker is designated as an indicator of mature old growth forest with limited management in the Lolo Forest Plan (USDA-FS 1986), although it uses a variety of habitats. Because of their broader habitat use patterns and wide distribution throughout the project area, the amount of nesting and foraging habitat available in the project area is used to assess effects to the species. Nesting habitat is the better habitat and can also be used for foraging, whereas habitat mapped as foraging habitat usually is suboptimal for nesting and expected to be mainly used for foraging only (Figure 3.6-2). The amount of old growth forest (defined by Green et al. 1992) is reported because this habitat represents some of the highest quality habitat available, although it is only a small portion of what is suitable for and used by pileated woodpeckers. The numbers and occurrence of pileated woodpeckers suggests that the Lolo National Forest has adequate mature old growth to support the pileated woodpecker and other species that use mature old growth forests.
Figure 3.6-2: Display of the overlap between foraging habitat, nesting habitat, and old growth.
Foraging Habitat Old Growth Nesting Habitat
Old Growth Before the Copper King fire, the project area contained about 1,356 acres of stands on National Forest System land that met or would have soon met (within about two decades) the Green et al. (1992, errata corrected 2011) old growth definitions. The majority (over 72 percent) of this old growth burned at high or very high severity during the fire (see Table 3.2-2) and no longer meet old growth definitions because there are not enough live trees of sufficient size and age. In very high severity burn areas, nearly all the trees are dead.
Only considering old growth greatly underestimates the amount of suitable habitat available for pileated woodpeckers in the project area. Analyzing the broader category of mature forest will give a more realistic estimate of suitable habitat considering information from Mellon et al. (1992) and Bonar (2001).
Nesting and Foraging Habitat Another way to analyze pileated woodpecker habitat is to select forest stands that meet the habitat requirements that were outlined by Samson (2006a) including a wide variety of forest types and tree diameters over 10 inches for foraging habitat and over 15 inches for nesting habitat. Within the project area (post-fire), there are approximately 5101 acres of nesting and foraging habitat and additional 5802 acres of foraging habitat (Table 3.6-7). The available nesting habitat alone could provide habitat for 3 to 7 pairs of pileated woodpeckers.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on pileated woodpeckers or their habitat because no activities would occur.
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Alternatives 2 and 3: Direct and Indirect Effects Suitable habitat is abundant and would remain abundant following implementation of the Copper King project. Effects to pileated woodpeckers would primarily occur in the form of snag losses from post-fire salvage operations. In Alternatives 2 and 3, this would be most pronounced on 277 and 522 acres, respectively, of timber harvest in nesting habitat (Table 3.6-7). This equates to a modest 5 and 10 percent, respectively, of the 5101 acres of suitable nesting habitat, leaving the remaining 90-95 percent unaffected. Alternatives 2 and 3 also include salvage of approximately 244 acres (18 percent) and 292 acres (22 percent), respectively, of the pre-fire old growth within the project area.
Pileated woodpeckers would not likely use these areas for nesting after harvest because dead trees greater than 8 inches in diameter would be removed. However, the vast majority of nesting habitat remaining (90-95 percent) and the super-abundance of snags on the landscape, would provide more available habitat than in most areas of the Lolo National Forest. Longer-term, large snags outside of salvage units would remain on the landscape for many years (20-80) to supply nesting trees for the species now and into the future.
Pileated woodpeckers nesting in trees that would be salvaged in 2017 would complete their nesting cycle before harvest occurred thus avoiding impacts to eggs or nestlings. In 2018, pileated woodpecker nesting activity would be observed during black-backed woodpecker surveys conducted in units prior to harvest. If nesting is observed, harvest would be postponed until after completion of the nesting cycle and nestlings can fly (similar timeframe as black- backed woodpecker).
Salvage harvest in Alternatives 2 and 3 would reduce the quantity of dead trees on approximately 10 and 17 percent, respectively, of suitable foraging habitat (Table 3.6-7). However, small dead trees (less than 8 inches in diameter) would still be available for forage within harvested areas and the quantity of dead and dying trees outside of treated areas would be tremendous - far greater than pre-fire conditions.
Table 3.6-7: Summary of Timber Harvest in Pileated Woodpecker Habitat by Alternative Existing Condition Alternative 2 Alternative 3 (acres and % of (acres and % of total (acres and % of total project area) pileated habitat) pileated habitat) Nesting (and 5,101 (18) 277 (5.4%) 522 (10.2%) foraging) Foraging 5,802 (20) 300 (5.1%) 416 (7.2%) Total 10,903 (38) 577 (10.5%) 938 (17.4%)
Cumulative Effects The diversity of habitats used by this species would enable it to persist through a variety of influences. Pileated woodpecker habitat is abundant and well-distributed across the Region, Forest, and Copper King project area. Salvage operations on other land ownerships may displace individual woodpeckers through the removal of snags. However, considering these other salvage operations, Alternatives 2 and 3 would have no measurable adverse cumulative effects on the species or its habitat at the project area, Forest, or Regional scale due to the extensive amount of available habitat, the relatively small amount being treated, the relatively small scale of effects, and the fact that the species is common and widespread.
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Elk The Forest Service Manual directs the forests to manage for species that are in demand for hunting (FSM 2601.2, 2602, and 2603). The Lolo Forest Plan contains goals, objectives, and standards for big game management that include providing and improving habitat for big game, protecting features such as wallows and mineral licks, managing winter range, providing hunting opportunities and working cooperatively with Montana FWP (USFS 1986). Big game on the Plains/Thompson Falls Ranger District primarily refers to elk, white-tailed deer, and mule deer. There are smaller numbers of moose and bighorn sheep. Managing for the requirements for elk generally fulfills the needs of other big game species. The document “Coordinating Elk and Timber Management” (Lyon et al. 1985), as well as the Montana elk management plan (MTFWP 2004), were considered in assessing the effects of timber harvest on elk habitat.
Montana Department of Fish, Wildlife, and Parks’ goals for the elk population in the Salish Elk Management Unit (of which the Copper King area is a portion) include maintaining elk numbers, a diverse bull age structure, and maximizing hunting opportunities (MTFWP 2004). They are also trying to maintain 80 percent of existing habitat security (MTFWP 2004). This requires secure habitat areas in summer, controlling vulnerability from hunting, and providing winter range sufficient to support elk when little forage is available. Although more recent research is now available, the “Coordinating elk and timber management” document (Lyon et al 1985) is used to help balance needs for elk and management of other resources. Lolo National Forest Plan Management Area 18 and 19 (Elk Winter Range) comprise 5695 acres within the project area. Lolo National Forest Plan goals for these winter range areas are to “optimize forage/winter range”.
The elk population trend in Hunting District 122 (the project area) is not tracked by MTFWP, but adjacent hunting districts were either at or above population objectives for 2015 and 2016 (http://fwp.mt.gov/fishAndWildlife/management/elk/ [accessed 2/2017]). Hunting regulations have been relatively stable in HD122 over the last 10-15 years indicating no major changes in population status as well.
Elk habitat effectiveness and vulnerability are key components to habitat management for elk because throughout the year elk use a large variety of stands, habitats and forest types (Christensen et al. 1993). Habitat effectiveness quantifies how thoroughly elk are able to use a given land area based on how much they are disturbed while in the area – generally in summer. Habitat effectiveness in the Copper King project area is higher toward the southern end where there are fewer open roads and less disturbance. The intermingled ownership lands in Calico and Todd Creeks have more open roads and more activity. However, recent elk research (Ranglack et al. 2015) indicates that nutrition in summer forage assists elk throughout the entire year and is a key habitat component that has not been fully considered in the past. They also indicate that, during summer, the effects of high quality forage availability are more important than the negative influence from open roads (ibid.). The forage availability dropped precipitously immediately post-fire, but will recover to very-high levels in 2017 and later, higher than pre-fire levels because of the upcoming flush of highly nutritious grasses, forbs, and shrubs. Key summer range areas generally include higher-elevation slopes with moisture and high plant growth potential. Thus, post-fire habitat effectiveness (and summer range) will be quite high for many years to come because of the fire, but will be highest where human disturbance is lower.
Vulnerability is the likelihood of hunting-related mortality, which can be affected through cover and access management (Christiansen et al. 1993). Within the Copper King project area, hiding cover is low because of the loss of vegetation in the moderate to high severity burn areas (for
128 Copper King Fire Salvage Environmental Assessment example, see Figure 3.6-1). Over time (10-20 years), vegetative cover will become re- established. Existing road closures prevent excessive hunting mortality by restricting public motorized access to several portions of the project area. Open post-fire forest conditions could lead to an increase in hunting pressure in the area for several years until the vegetation regrows to obstruct sight-lines and fallen trees reduce the ability of hunters to walk through the area.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on elk because no management activities would occur. The post-fire flush of highly nutritious grasses, forbs, and shrubs will provide high quality forage over the next several years.
Alternatives 2 and 3: Direct and Indirect Effects Potential effects to elk would primarily be in the form of disturbance. Salvage operations and related road work could temporarily disturb elk during implementation on a relatively small footprint of the project area (less than 12 percent of National Forest System lands within the project area). However, activities would not occur everywhere all at once and there would be ample areas for elk to displace to and forage. During winter harvest operations, elk would most likely be located in lower elevation areas with less snow and away from harvest units resulting in less potential for disturbance. Temporary displacement would not lead to mortality or long-term consequences.
Post-fire salvage in Alternatives 2 and 3 would cause little, if any, measurable effect to habitat. Harvest would remove dead trees, which are not used by elk. These dead trees provide very little cover; therefore their removal would not measurably increase elk vulnerability. Post-fire vegetative regrowth on tractor skid trail and landings could be temporarily slowed due to soil disturbance from project activities. However, potential detrimental soil disturbance would only occur on approximately 103 acres in Alternative 2 and 140 acres in Alternative 3, which is about 6 percent of the proposed harvest acres and less than 1 percent of the National Forest System land in the Copper King project area (see Soil section 3.3). In addition, studies have found that over the long-term there were no statistical difference in vegetation establishment (richness and cover) between areas that were salvaged and areas that were not (Peterson and Dodson 2016; Knapp and Ritchie 2016). Therefore, effects would be negligible compared to the expected post-fire flush of highly nutritious grasses, forbs, and shrubs across the post-fire landscape.
Cumulative Effects Salvage operations on State and private land and BAER road work that are concurrent with implementation of Alternatives 2 and 3 could provide additional disturbance to elk in the area. However, total activities on all ownerships would occur on less than 20 percent of the project area and would not occur all at once. Therefore, there would be ample areas for elk to forage away from project-related disturbance. Vegetative cover was substantially reduced by the fire and the removal of dead trees would not further measurably affect cover. There would be no change in open public motorized road access, therefore elk security would be maintained. Cumulative effects of Alternatives 2 and 3 would be discountable.
Migratory Birds Numerous avian species, including those listed as Forest Service sensitive or management indicator species are protected under the Migratory Bird Treaty Act. Executive Order 13186 of 2001 outlined the responsibilities of Federal agencies regarding migratory bird conservation. In December 2008, the Forest Service entered into a Memorandum of Understanding (MOU) with
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the U.S. Fish and Wildlife Service on the Migratory Bird Treaty Act to further clarify agency responsibilities. Four key principles embodied in the MOU direct the Forest Service to: 1) focus on bird populations; 2) focus on habitat restoration and enhancement where actions can benefit specific ecosystems and migratory birds dependent on them; 3) recognize that actions taken to benefit some migratory bird populations may adversely affect other migratory bird populations; and, 4) recognize that actions that may provide long-term benefits to migratory birds may have short-term impacts on individual birds. The parties agreed that through the NEPA process, the Forest Service would evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors. The needs of migratory birds are addressed throughout this analysis, including the individual sections on project impacts to black-backed woodpecker, flammulated owl, northern goshawk, and pileated woodpeckers as well as other sections of this EA that address habitat diversity.
Migratory bird species are currently monitored by the Northern Region and through the USGS Breeding and Christmas Bird Surveys (http://www.mbr-pwrc.usgs.gov/bbs/bbs00.html). These larger monitoring efforts can help to detect population trends.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on migratory birds or their habitat because no activities would occur. Over time, as vegetative succession occurs within the fire area, shifts in usage by the different migratory species would occur. In the near-term, the area will likely be used by species that favor open habitats or burned areas (e.g. black-backed woodpeckers, kestrels, and bluebirds). When mature forests develop, other species that favor older, denser forests will tend to occupy the area.
Although salvage operations on State and Weyerhaeuser lands will remove snags on approximately 3000 acres, abundant fire-killed trees would remain available within the fire perimeter for species that use snags. Cumulatively, Alternative 1 would maintain suitable habitat for a variety of migratory bird species.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Because of the myriad of species included in the migratory bird group, any habitat modifications could have effects on some species but not others. Alternatives 2 and 3 would harvest dead trees from 1502 acres (8 percent) and 2312 acres (12 percent), respectively, of the National Forest System land within the project area. Nearly 17,000 acres of unharvested, burned habitats would be retained, which would be more than adequate to maintain habitat for post-fire bird species. The salvage harvest would change the balance of habitats by making salvage units more suitable for some species (e.g. bluebirds and kestrels) and less suitable for others (potentially warblers). Timber harvest activities would create disturbance that could temporarily displace birds to unaffected areas. If timber harvest occurs during spring, it could have negative effects on individual nesting birds because nests, eggs and nestlings would be unable to move away from activities. These impacts are unlikely to have population-level effects because: 1) these species are currently abundant enough that loss of some reproduction in a year is insignificant, 2) treatments in the project area would occur on about 8-12 percent of the total area, and 3) most species reproduce relatively quickly, enabling them to repopulate a small area easily.
“Migratory birds” include such a wide range of species which use nearly every habitat available in the Northern Region. Managing landscapes to maintain a balance of vegetative conditions with reference conditions can balance the needs of many species. At the same time, avoiding adverse effects on Endangered, Threatened, and sensitive species focuses attention on species
130 Copper King Fire Salvage Environmental Assessment where special management may be required. According to Partners in Flight, the Intermountain West area needs restoration work to improve historic structure of ponderosa pine forests, aspen habitats, and riparian habitats to best conserve the suite of birds native to this area (Rich et al. 2004). Salvage activities on all ownerships within the Copper King project area would not preclude the development of these key communities. Salvage harvest on all ownerships would reduce the amount of fire-killed trees on less than 20 percent of the Copper King fire area, retaining nearly 24,000 acres of post-fire habitats unaffected. Therefore, cumulatively, Alternatives 2 and 3 would not affect migratory bird populations because of the relative small scale of the salvage operations, the limited intensity of effects, and the widespread/secure nature of these species (note that sensitive bird species are discussed above). 3.7 Transportation System/Public Safety Within the Copper King project area there are approximately 242 miles of existing road, of which 119 miles (49 percent) are under Forest Service jurisdiction. Due to the intermingled ownership in the northern half of the area, approximately 68 miles (57 percent) of the National Forest System roads have existing cost share agreements or easements.
Of the roads under Forest Service jurisdiction, about 60 miles (51 percent) are open yearlong or seasonally to the public. The most traveled road within the project area is Road #9991 [ACM road] that is located along the Thompson River on the western boundary of the fire perimeter. The road connects Montana State Highways 2 and 200 and receives high recreation and commercial traffic volumes during the spring, summer, and fall. Due to the amount of public use, it is maintained for passenger vehicles.
Although the Copper King area was closed to the public during and immediately after the fire, these restrictions were lifted in the fall in response to public, adjacent landowner, and State and local government requests; recognizing guiding and outfitting, hunting, firewood collecting, timber salvage, and other uses of the area. The closure was lifted only after a concerted effort by the Forest Service to assess roadside hazards and to fell dead and/or fire-weakened trees that posed an immediate threat to public safety. Roadside hazards still exist as danger trees will continue to fall over time because of increased defect, mortality, weathering agents, heavy snow, and other environmental factors. Therefore, this project includes roadside hazard tree abatement.
One public comment recommended that the road system be minimized to reduce resource effects of the transportation infrastructure in the post-fire environment. 36 CFR 212 Subpart A requires each national forest to identify the minimum road system needed for safe and efficient travel and for administration, utilization, and protection of National Forest System lands. The minimum system is the road system determined to be needed to meet resource and other management objectives in the Forest Plan (36 CFR 212.5(b)). The Lolo National Forest has completed its identification of the minimum road system. This forest-wide analysis did not identify any needed changes for the existing road system within the Copper King project area.
During development of the Copper King Fire Salvage project, the existing area transportation plan for the project location was reviewed. The East Bay area transportation plan identifies a minimum transportation system in the Copper King project area to meet long-term land management needs on National Forest System lands. The East Bay area transportation plan mapped the existing and future road system, identified issues, and assessed benefits, problems and risks associated with the road system. To validate the plan, the Forest Service reviewed the entire existing road system in the project area using field survey data, Google Earth©, aerial photographs, and GIS. Based on these reviews, the Forest Service determined that the East Bay
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area transportation plan still adequately identifies the minimum road system at the project scale, and that no substantial adjustments are needed. Therefore, the project does not include modifications to the road system.
Ongoing BAER work on the Copper King transportation system has and will continue to address the risk of road drainage failure due to anticipated increased water flow and movement of sediment and debris from the fire (see Section 3.1 for more detail). Copper King Fire Salvage road maintenance would focus on the remaining work required to maintain the roads for project activities and meet best management practices (BMPs). Between BAER work and road maintenance conducted under the Copper King project, approximately 77 and 92 miles (64 and 77 percent), respectively, of the National Forest System roads in the project area would be treated in Alternatives 2 and 3. These treatments would reduce resource effects of the existing road system particularly during the first years following the fire when the landscape is most vulnerable to storm events.
Alternative 1: Direct, Indirect, and Cumulative Effects In the absence of hazard tree removal along roads in the Copper King area, fire-killed and weakened trees would remain until they fall on their own. Dead trees will likely fall at varying rates depending on several factors including size, species, and weather events. Even though some imminent danger trees could be dealt with, it would be difficult to stay pro-active with this activity as more and more trees become hazards over time. Due to the unpredictable nature of when hazard trees fall, leaving a high number of them along roads would create unsafe road travel conditions for years into the future.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 include approximately 158 and 155 acres, respectively, of concentrated roadside hazard tree removal in addition to salvage units. These mapped areas are what is estimated to be viable for commercial removal as part of the timber sale. Along the rest of the road system, hazard trees would be felled and left on the ground. Removal of these other hazard trees could occur if there is a market for the material and further site-specific resource evaluations identify no concerns. Felling of hazard trees would be prioritized by road based on the degree of public use.
Once fully completed, both action alternatives would effectively reduce roadside hazards along almost all of the National Forest System roads within the project area providing a safer transportation system for both public and administrative use. Along Road #9991 [ACM road] alone, concentrated areas of hazard trees would be removed (along 3 miles) and incidental hazard trees would be also be mitigated (11 miles), substantially increasing the likelihood that recreational and commercial traffic could pass without incident.
Salvage operations by Weyerhaeuser and the State include removal of dead trees on their lands along Roads 875 and 894, which are open to the public. Cumulatively, salvage activities on all lands would improve public safety on the road system over the long term.
Forest Plan Consistency All action alternatives are consistent with the Lolo Forest Plan. A project-specific Travel Analysis was conducted to ensure roads within the project area would be the minimum number and meet the design standards to provide for safety and to meet user and resource needs (Standard 48, page II-17). Roads within the project area would be managed to provide for resource
132 Copper King Fire Salvage Environmental Assessment protection, wildlife needs, commodity removal, and a wide range of recreation opportunities (Standard 52, page II-18). 3.8 Heritage
Issue Raised in Public Comment Salvage operations around the historic Cow Camp Lookout tree, killed by the fire, could damage and/or accelerate the inevitable toppling of the tree.
Heritage surveys were conducted in the fall of 2016 and focused on areas with high probability of containing heritage resources. However, snow fall in November curtailed survey efforts. Most areas unable to be field-reviewed before the snow are primarily high probability areas within the additional units in Alternative 3. 36 CFR 800.4((b)(2) allows a phased process to conduct identification and evaluation efforts where access to properties is restricted. The agency official may also defer final identification and evaluation of historic properties if it is specifically provided for in a programmatic agreement executed pursuant to §800.14(b). A programmatic agreement between the Montana State Historic Preservation Office (SHPO) and the Forest Service has been signed. In addition, the Confederated Salish and Kootenai Tribes has also signed the agreement as a participating party. All necessary field surveys would be conducted prior to implementation and identified heritage resources would be protected as needed.
Consultation with the Montana SHPO and the Confederated Salish and Kootenai Tribes has been ongoing and would continue until project completion.
There are three known heritage sites that are recommended as eligible on the National Register of Historic Places23 within the project area: Silver King mine, Cow Camp lookout tree, and historic Forest Service Trail #355.
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on heritage resources because no activities would occur. Indirectly, the historic features at the Silver King mine site would be at greater risk from hazard trees under this alternative. Harvest units 115 and 116 are designed specifically to address the hazards around the existing structures. During BAER work, hazard trees around one cabin were felled because it was at imminent risk. However, the other cabins are still threatened by fire-weakened trees.
Heritage resources are subject to natural weathering and vegetation encroachment. Tree mortality and deadfall may continue to impact heritage sites in the post-fire environment. The Cow Camp Lookout tree was killed by the wildfire, and may continue to stand for an unknown period of time but will inevitably fall at some point. Some segments of the historic Forest Service Trail #355 still have a visible trail tread. Trees will continue to fall around and over the trail tread, which will eventually obscure the existing trail corridor clearing, making the trail more difficult to identify in the future.
23 The National Register of Historic Places is the official list of the Nation's historic places worthy of preservation.
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Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 would have no direct, indirect, or cumulative adverse effects to the known eligible historic sites identified above because project-specific resource protection measures (see Chapter 2) would be applied to protect them. These sites would be buffered from project activities and monitored by Forest Service heritage personnel. The Montana SHPO has concurred that the project would have no adverse effect to the known eligible historic properties (letter dated March 2, 2017).
Removal of the hazard trees around the historic structures at the Silver King mine in Units 115 and 116 would mitigate the existing threat of fire-weakened trees falling on and destroying the cabins. Project activities would also maintain the defensible space surrounding the structures. During the Copper King Fire, the site was in considerable danger from being completely destroyed due to the amount and close proximity of vegetation to wooden structures. Fire crews protected the site by removing understory vegetation away from the cabins and installing a temporary sprinkler system. Removing additional hazard trees would further protect this historic site and re-establish a more open forest, reminiscent of what the site likely looked like when the mine was operating.
Alternatives 2 and 3 would buffer historic Forest Service Trail #355 within Units 3, 7, and 9 from salvage activities and therefore would have no adverse effects to this historic resource. Although trees within the buffer would eventually fall on and across the trail, retaining a corridor of dead trees within the harvested units would provide visible clues to the trail’s location in the future.
Alternatives 2 and 3 would also buffer the Cow Camp Lookout tree and associated historic debris in Unit 3 from salvage operations and therefore would have no adverse effects to this historic resource. Surrounding dead trees would be retained within 100 feet of the feature.
As stated above, additional heritage surveys would be completed prior to implementation within affected areas and appropriate protections would be applied as needed to identified sites (see Resource Protection Measures in Chapter 2). If any identified sites cannot be adequately protected, project activities that could adversely affect heritage resource would be dropped. Therefore, Alternatives 2 and 3 would have no adverse direct, indirect, or cumulative effects on heritage resources.
Forest Plan Consistency All action alternatives are consistent with the Lolo Forest Plan. Cultural resources were considered during the planning process, field inventories were conducted and will be completed prior to ground disturbing activities, and the Forest has consulted with the State Historic Preservation Office (Forest Plan standard 54, page II-20). In addition, the Forest has discussed this project with the Confederated Salish and Kootenai Tribes (Forest Plan standard 55, page II- 20). 3.9 Recreation
Issue Raised in Public Comment Closure of the Bay State Trail #1268 to motorized use could reduce recreation opportunities.
The project area is primarily used for dispersed recreation activities. There are no developed recreation sites within the Copper King Fire perimeter.
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The project area contains three maintained trails (Koo-Koo-Sint Ridge #445, Bay State Creek #1268, and Todd Springs #345), totaling approximately 13.5 miles. The Todd Springs Trail #345 (3.8 miles) is closed yearlong to motorized use. The other two trails are designed for hiker and stock use with single-track motorized (motorcycle) use allowed.
The Copper King Fire burned at moderate to very high severity around the Koo-Koo-Sint Ridge and the Bay State Creek trails. The following BAER work will be completed on these trails to provide for public safety and to protect the trail infrastructure from erosion:
installation and repair of drainage structures on 3.5 miles of the Bay State Creek trail and 3.6 miles of the Koo-Koo-Sint Ridge trail to manage expected increases in runoff caused by the fire;
reshaping of the trail tread to facilitate drainage on 4.5 miles of the Bay State Creek trail and 2 miles of the Koo-Koo-Sint Ridge trail to limit trail erosion from expected storm flows; and
felling of hazard trees along the trails as needed for public safety.
Currently, the Bay State Creek trail #1268 and the Koo-Koo-Sint Ridge trail #445 are closed to motorized use for public safety (Closure Order F17-012-LOLO-D5).
Motorized Recreation
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct, indirect, or cumulative effects on motorized recreation because no activities would occur. As stated above, the Bay State Creek and Koo-Koo-Sint Ridge trails are currently closed to motorized use until hazards posed by dead and fire-weakened trees are mitigated.
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Under Alternatives 2 and 3, approximately 5 miles of the Bay State Creek trail #1268 would be closed to motorized use. Per the amended Forest Plan, any projects within the Cabinet-Yaak Grizzly Bear Recovery Zone that will cause a reduction in core habitat requires a concurrent in- kind replacement to maintain required standards. Any newly created core must remain in place for at least 10 years. If the trail is reopened to motorized use at some point in the future, replacement core habitat would need to be created somewhere else within the Bear Management Unit (BMU) by closing other open motorized routes unless the core standard for the BMU is higher (better) than the required standard.
As stated above, this trail was designed for hiker and stock use, but single-track motorized (motorcycle) use is currently allowed. Based on track surveys conducted during the summer and fall of 2015, the trail receives low motorized use, likely by local residents and hunters. The trail (tread width of 18-24 inches) is located in mountainous terrain and climbs 4000 feet in elevation in the 5 miles, making it challenging for likely all but experienced off-road motorcyclists.
In the short-term, there would be no direct, indirect, or cumulative effects of this closure because the Bay State Creek and Koo-Koo-Sint Ridge trails are currently closed to motorized use until hazards posed by dead and fire-weakened trees are mitigated.
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In the long-term, the closure of 5 miles of the Bay State Creek trail to motorized use would reduce motorized trail opportunities within the project area by 52 percent for at least 10 years. Motorcyclists who use and would use this trail would be displaced to other trails open to motorized use.
On the Plains/Thompson Falls Ranger District, there are approximately 337 miles of trail, of which about 119 miles or 35 percent are open yearlong or seasonally for single-track motorized use. The closure of the Bay State Creek trail to motorized use would reduce single-track motorized trail opportunities by approximately 4 percent on the District for at least the next 10 years.
General Recreational Use
Alternative 1: Direct, Indirect, and Cumulative Effects Alternative 1 would have no direct effects on general recreation use. However, indirectly, by not implementing the roadside hazard tree removal, motorized recreation access along open roads on National Forest System land within the project area could be temporarily impeded by downed trees blocking the road(s).
Alternatives 2 and 3: Direct, Indirect, and Cumulative Effects Alternatives 2 and 3 would conduct hazard tree removal along roadsides, which would more likely keep open roads passable to the public and administrative use than Alternative 1.
Road #9991 [ACM road] would be temporarily closed during tree felling operations along the road. These would be “rolling” closures, meaning that the closed segment would only be where felling activities were actively occurring. Therefore, the public would have access to most of the road at any given time during daylight hours and full access after operations along the road have ceased for the day. Those wanting to travel along the Thompson River during felling operations could use County Road 56 across the river as an alternate route.
Log haul traffic would occur on roads open to the public within the project area and appropriate signing would be posted to warn travelers of this use. Log haul would be prohibited on County Road 56, offering travelers an alternate route that is free of Copper King project activities along the Thompson River. Road #9991 would be dust-abated to minimize airborne dust and reduce fine sediment delivery into the Thompson River from additional road use resulting from the project (see Hydrology section). In any given year, Road #9991 typically receives heavy commercial and recreation traffic compared to other roads on the District and dust abatement is generally not applied. Dust abatement included in the Copper King project would benefit recreationists who fish along the Thompson River and camp in the two developed campgrounds located across the river, outside the project area. Reducing airborne dust would maintain air quality and visual attractiveness of the river corridor.
There would unlikely be any cumulative effects to general recreation use due to the temporary and intermittent nature of the proposed activities.
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3.10 Economics
Issue Raised in Public Comment Winter logging requirements could reduce project viability. (Rationale for winter logging is provided in Soils section 3.3).
Three measures are appropriate for the economic analysis: project feasibility which addresses only the timber harvest component of this project; financial efficiency, which addresses present net value (PNV) or the net monetary costs and benefits of the project; and economic impacts, which are the effects of this project on local jobs and labor income. The costs associated with required winter logging for identified tractor units (see Resource Protection Measures in Chapter 2) are included in the economic analysis.
Project feasibility is used to determine if the timber harvest portion of a project is feasible, that is, will it sell, given current market conditions. The determination of feasibility relies on a residual value analysis (price of the timber = revenues – costs) that uses local delivered log prices and stump-to-mill costs to determine if a project is feasible. The appraised stumpage rate from this analysis is compared to the base rate (in this case, the base rate is the minimum stumpage rate, which is the lowest rate for which the Forest Service may sell timber). The project is considered feasible if the appraised stumpage rate exceeds the base rate.
Financial efficiency provides information relevant to the future financial position of the government as the project is implemented. Financial efficiency considers anticipated Forest Service costs and revenues. PNV is the difference between the present value of the revenues and present value of the costs. PNV converts costs and revenues over the entire time frame of the project into a single figure for a selected year. A positive PNV means that the project would generate more financial revenues than financial costs. The NEPA planning is a sunk cost at the time of the decision and is not included in the PNV analysis.
Financial efficiency analysis is not intended to be a comprehensive analysis that incorporates monetary expressions of all known market and non-market benefits and costs. Many of the values associated with natural resource management are best handled apart from, but in conjunction with, a more limited financial efficiency framework. These non-market benefits and costs associated with the project are discussed throughout the various resource sections of this EA.
Economic impacts are used to evaluate potential direct, indirect, and cumulative effects on the economy. They are measured by estimating the direct jobs and labor income generated by 1) the processing of the timber volume from the project and 2) Forest Service expenditures for contracted other activities. The direct economic and labor income benefit employees and their families and, therefore, directly affect the local economy. Additional indirect and induced multiplier effects (ripple effects) are generated by the direct activities. Indirect effects are felt by the producers of materials used by the directly affected industries. Induced effects occur when employees of the directly and indirectly affected industries spend the wages they receive. Together the direct and multiplier effects comprise the total economic impacts to the local economy.
Economic impacts are estimated using input-output analysis, which is a means of examining relationships within an economy, both between businesses and between businesses and final consumers. It captures all monetary market transactions for consumption in a given time period.
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The resulting mathematical representation allows one to examine the effect of a change in one or several economic activities on an entire economy, all else constant. The model used for this analysis is the 2014 IMPLAN data in conjunction with response coefficients that relate timber harvest quantity to direct jobs and income (Sorenson et al. 2016). IMPLAN translates changes in final demand for goods and services into resulting changes in economic effects, such as labor income and employment of the affected area’s economy.
Data used to estimate the direct effects from the timber harvesting and processing were provided by the University of Montana’s Bureau of Business and Economic Research (BBER) (Sorenson et al. 2016). This national dataset is broken into multi-state regions and is considered more accurate than that which is available from IMPLAN. The Northern Rockies BBER Region (Montana and Idaho) is used for this analysis. The BBER data represents the results of mill censuses that correlate production, employment, and labor income. The economic impact area for this analysis consists of Sanders and Mineral Counties. Potential limitations of these estimates are the time lag in IMPLAN and the uncertainty of where the timber will ultimately be processed. The analysis assumes the harvested timber volume would be processed in the Sanders and Mineral County impact area. However, if some of the timber were processed outside the region, then a portion of the jobs and income would be lost by this regional economy.
Table 3.10-1 Project Feasibility and Financial Efficiency Summary (2016 dollars)
Category Measure Alt 1 Alternative 2 Alternative 3 Timber Harvest Acres Harvested 0 1502 2312 Information Volume Harvested (CCF) 0 24,039 36,995 Base Rates ($/CCF) $0 $3.60 $3.60 Appraised Stumpage Rate $0 $16.33 $1.74 ($/CCF) Predicted High Bid $0 $35.54 $20.95 ($/CCF) Total Revenue (Thousands $0 $854 $775 of $) Timber Harvest & Required PNV (Thousands of $) $0 $517 $442 Design Criteria Timber Harvest & All PNV (Thousands of $) $0 -$2,743 -$3,088 Other Resource Activities * Volume and acres are estimations CCF= hundred cubic feet
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Table 3.10-2: Total Employment and Labor Income over the Life of the Project* Non-Timber Harvest-related Activities Alt 1 Alternative 2 Alternative 3 Part and Full Time Jobs Contributed Direct 0 65 65 Indirect and Induced 0 22 22 Total 0 88 88 Labor Income Contributed ($) Direct $0 $2,637,000 $2,648,000 Indirect and Induced $0 $686,000 $691,000 Total $0 $3,323,000 $3,338,000 Timber Harvest and Processing Alt 1 Alternative 2 Alternative 3 Part and Full Time Jobs Contributed Direct 0 75 115 Indirect and Induced 0 70 108 Total 0 145 222 Labor Income Contributed ($) Direct $0 $3,702,000 $5,698,000 Indirect and Induced $0 $2,602,000 $4,004,000 Total $0 $6,304,000 $9,702,000 All Activities Alt 1 Alternative 2 Alternative 3 Part and Full Time Jobs Contributed Direct 0 140 180 Indirect and Induced 0 92 130 Total 0 232 310 Labor Income Contributed ($) Direct $0 $6,339,000 $8,346,000 Indirect and Induced $0 $3,288,000 $4,695,000 Total $0 $9,627,000 $13,040,000 * It is important to note that these may not be new jobs or income, but rather jobs and income supported by this project. Part and Full Time Jobs Contributed is the total full and part-time wage, salaried, and self-employed jobs contributed to the economic impact area from the change in final demand associated with this project. Labor Income Contributed includes the wages, salaries and benefits of workers who are paid by employers and income paid to proprietors in the economic impact area from the change in final demand associated with this project. Direct effects represent the impacts for the expenditures and/or production values specified as direct final demand changes. Indirect effects represent the impacts caused by the iteration of industries purchasing from industries resulting from direct final demand changes. Induced effects represent the impacts of all local industries caused by the expenditures of new household income generated by the direct and indirect effects of final demand changes. Total effects are the sum of direct, indirect, and induced effects.
Alternative 1: Direct and Indirect Effects Under Alternative 1, no activities would occur; therefore no financial costs would be incurred from salvage operations and associated activities. However, the NEPA planning costs will have already been incurred, representing a sunk cost with no return on the planning investment. Alternative 1 would yield a present net value of zero (Table 3.10-1). This value also neglects the resulting losses in timber values and non-market benefits. In addition, since the planning costs for this project have already been incurred, there would be no return on the planning investment.
Alternative 1 would support no direct, indirect, or induced employment, and no labor income contribution to local economies (Table 3.10-2). This alternative has the potential to continue the
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decline of timber-related employment in the rural communities of the economic impact area. Continued decline in timber harvest from National Forest System lands could potentially impact wood product employment and associated indirect and induced employment. A 2009 report by Spelter, McKeever, and Toth states many of the forests in the West are publicly owned, and supply from these lands has decreased. Since January of 2007, twenty six sawmills have experienced permanent closure. Most negatively affected were the states of Montana and California, whose losses in this period (2007-2009) were 26 and 25 percent, respectively (Spelter, McKeever and Toth 2009). In 2010, the only major pulp mill in Montana closed. Permanent closures also continued to impact the state’s log home industry (Morgan et al. 2011). Operations at most other facilities were curtailed in 2009 and 2010. Timber processing capacity dropped from 934 MMBF in 2004 to 606 MMBF in 2009. Capacity utilization, which normally exceeds 70 percent, dropped to 50 percent in 2009 (McIver et al. 2013). A 2015 Forest Products Outlook report stated that log supply affected milling facilities across the state in 2014 and would continue into 2015 (Morgan et al. 2015).
Changes in the economic base and wood products infrastructure for the impact area would also likely continue to be influenced by fluctuations in market prices, international market conditions, changes in technology, and industry restructuring.
Cumulative Effects Alternative 1 would not be without some associated cumulative economic effects. This alternative would have the potential to continue the decline of timber-related employment in the rural communities of the economic impact area. Cumulative loss in timber-related jobs could affect the remaining infrastructure and capacity of local rural communities, and could disrupt the dependent local goods and services industries.
Alternatives 2 and 3: Direct and Indirect Effects Project Feasibility The appraised stumpage rate from the feasibility analysis was compared to base rates. In this case the minimum rate of $3.60 per hundred cubic feet (CCF) was used. The appraised stumpage rate and base (minimum) rates for each alternative are displayed in Table 3.10-1. For Alternative 2, the appraised stumpage rate is greater than the base rate, indicating that Alternative 2 is feasible (likely to sell), even with winter logging requirements for specific tractor units. For Alternative 3, higher costs (associated primarily with temporary road construction) translate to a lower stumpage rate of $1.74/CCF. With a stumpage rate lower than the minimum rate of $3.60, Alternative 3 is not feasible with its current design.
Financial Efficiency The financial efficiency analysis is specific to the timber harvest and other activities associated with the alternatives (as directed in Forest Service Manual 2400-Timber Management and guidance found in Forest Service Handbook 2409.18). Costs for sale preparation, sale administration, regeneration, and restoration activities are included. If exact costs were not known, the maximum of the cost range was used to produce the most conservative PNV result. If actual costs are lower, all else equal, PNV would be higher than the estimates in Table 3.10-1. The expected revenue for each alternative is the corresponding predicted high bid from the sale feasibility analysis. The predicted high bid is used for the expected revenue (rather than the appraised stumpage rate) since the predicted high bid is the best estimate of the high bid resulting from the timber sale auction.
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Because not all costs of the project are related to the timber sale, two PNVs were calculated. One PNV indicates the financial efficiency of each alternative, including all costs and revenues associated with the timber harvest and required design criteria (such as snow plowing associated with winter logging). A second PNV includes all costs for each alternative with the required design criteria and for the timber harvest and all other resource activities (e.g. tree planting and associated exams, hazard tree felling).
Results shown in Table 3.10-1 indicate that Alternatives 2 and 3 are financially efficient (positive PNVs) for the timber harvest with designed criteria, and Alternative 2 has the highest PNV ($517 thousand). When comparing Alternatives 2 and 3, high costs associated with Alternative 3 are affecting the appraised stumpage rates, the predicted high bid, and the PNV. Some of the high costs associated with Alternative 3 include the additional miles of road maintenance, snow plowing, temporary road and obliteration, and the addition of a unit for swing yarding (excaline).
Table 3.10-1 also indicates that all action alternatives are financially inefficient (negative PNV) for timber sale with designed criteria and other resource activities. The primary driver of the negative PNV is the cost of tree planting and required follow-up exams on 6,000 acres (~$3,090,000). Appropriated funding rather than timber sale revenue would be used to finance the planting activities. Alternative 3 has a lower PNV (-$3,088 thousand) than Alternative 2 (-$2,743 thousand) indicating that Alternative 3 is the least financially efficient alternative.
The decision maker takes many factors into account in making the decision. When evaluating trade-offs, the use of efficiency measures is just one factor that is considered.
Economic Impacts Alternatives 2 and 3 would support existing jobs through timber harvest-related and other non- commercial activities. Table 3.10-2 displays the direct, indirect and induced, and total estimates for employment (part and full-time) and labor income that may be attributed to each alternative. Since the expenditures occur over time, the estimated impacts of jobs and labor income would be spread out over the life of the project. It is important to note that these may not be new jobs or income, but rather jobs and income that are supported by this project. It is anticipated that the timber harvest would occur over a two-year period, with the other resource activities spread out over seven years. This means that the impact of timber harvest to jobs and labor income would occur over a shorter time period than those associated with other resource activities. This can be attributed to the short time period in which fire-killed trees are economically viable for sawtimber use due to rapid deterioration. However, implementation could take longer than anticipated due to unforeseen circumstances.
Alternative 3 would generate more jobs and labor income than Alternative 2 for timber harvest. Alternative 2 and 3 would be of equal value for jobs and labor income for the non-timber activities.
Cumulative Effects Management of the Lolo National Forest has an impact on the economies of local counties. However, there are many additional factors that influence and affect the local economies, including changes to industry technologies, management of adjacent National Forests and private lands, economic growth and international trade. These alternatives would provide a variety of opportunities for contracts that may contribute to the local economy and have the potential to attract new business and residents and retain existing businesses and residents.
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Salvage operations are also ongoing on Weyerhaeuser and State lands within the Copper King Fire perimeter. The Forest Service’s salvage project would complement the economic benefits (jobs and labor income) and timber supply contributed from post-fire salvage operations on other ownerships.
In addition, there are other foreseeable future Forest Service projects within Sanders County and counties closest to the project area that are in various stages of planning that potentially may add to the Forest’s annual timber offerings during the time of implementation of the project. These ongoing and foreseeable projects are expected to add cumulatively to the employment and income of the economic impact area within the life of the Copper King project.
Forest Plan Consistency Consistent with the Forest Plan, an economic analysis has been completed that includes the probable marketability (i.e. economic feasibility) of the commercial timber harvest portion of the project (Forest Plan standard 11, page II-11).
Agencies and Persons Consulted The Forest Service consulted the following individuals, Federal, State, tribal, and local agencies during the development of this environmental assessment:
Federal, State, and Local Agencies: Montana Department of Environmental Quality Montana Fish, Wildlife, and Parks Montana Department of Natural Resource and Conservation Montana State Historic Preservation Office Advisory Council on Historic Preservation U.S. Fish and Wildlife Service Sanders County Commissioners City of Thompson Falls State Legislators Bob Brown, Jennifer Fielder, and Denley Loge
Tribes: Confederated Salish and Kootenai Tribes
Other: Sanders County Collaborative Mineral County Resource Coalition Lolo Restoration Committee Weyerhaeuser Bitterroot Valley Log and Timber Big Sky Forest Products F.H. Stoltze Land & Lumber Company Eagle Stud Mill, Inc. Hunt's Timbers Inc. Montana Log Home Supply LLC Pyramid Mountain Lumber, Inc. RY Timber, Inc. Stimson Lumber
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Sun Mountain Lumber Thompson River Lumber Tricon Timber, LLC Willis Enterprises Idaho Forest Group
In addition to consulting with the above parties, the Forest Service also contacted approximately 175 landowners, organizations, other agencies, and individuals who were identified as potentially interested in or affected by the proposal (see Chapter 1, section 1.5). To date, 41 parties have commented on the project. A complete list of public contacts is included in the Project File.
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Appendix A Maps
NOTE: Due to budgetary constraints, maps are of a small scale. These maps along with the entire Environmental Assessment are posted on the Lolo National Forest website (http://www.fs.usda.gov/main/lolo/landmanagement/projects), where viewers can use the “zoom- in” function to see greater detail. Larger scale maps of the alternatives are available at the Plains/Thompson Falls Ranger District office upon request.
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Appendix B Detailed Vegetation Treatments
Table B-1: Vegetation Treatment Areas by Alternative Forest type in Unit Equipment majority Number Acres1 Type2 Treatment of stand Alt 2 Alt 3 1 14 Tractor Salvage PP X X 2 30 Skyline Salvage PP X X 3 74 Tractor Salvage DF X X 4 15 Tractor mix of salvage and green thin DF X X 5 15 Tractor Salvage PP X X 6 29 Skyline Salvage PP X X 7 14 Tractor Salvage DF X X 8 23 Skyline Salvage PP X X 9 13 Tractor Salvage PP X X 10 29 Skyline Salvage DF X X 11 13 Skyline Salvage DF X X 12 22 Tractor Salvage DF X X 13 7 Tractor Salvage DF X X 14 10 Skyline Salvage DF X X 15 28 Skyline Salvage PP X X 17 14 Skyline Salvage GF X X 18 5 Tractor Salvage GF X X 19 14 Tractor Salvage GF X X 20 9 Skyline Salvage GF X X 21 13 Skyline Salvage GF X X 22 3 Tractor Salvage GF X X 23 8 Tractor Salvage MH X X 24 8 Skyline Salvage SAF X X 25 11 Tractor Salvage LP X X 26 11 Tractor Salvage LP X X 27 24 Tractor Salvage DF X X 28 17 Tractor Salvage DF X X 29 17 Tractor Salvage LP X X 30 25 Skyline Salvage DF X X 31 50 Skyline Salvage DF X X 32 22 Tractor Salvage PP X X 33 45 Skyline Salvage DF X X 34 10 Skyline Salvage DF X X
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Forest type in Unit Equipment majority Number Acres1 Type2 Treatment of stand Alt 2 Alt 3 36 47 Skyline Salvage LP X X 37 13 Tractor mix of salvage and green thin DF X X 38 10 Skyline Salvage DF X X 39 17 Skyline Salvage DF X X 40 17 Skyline Salvage DF X X 41 6 Skyline Salvage SAF X X 42 17 Skyline Salvage SAF X X 43 18 Skyline Salvage SAF X X 44 7 Skyline Salvage SAF X X 45 12 Skyline Salvage LP X X 46 15 Tractor Salvage SAF X X 47 6 Tractor Salvage SAF X X 48 7 Skyline Salvage SAF X X 49 94 Tractor Salvage DF X X 50 80 Skyline Salvage SAF X X 51 4 Tractor Salvage SAF X X 52 13 Skyline Salvage SAF X X 53 32 Tractor Salvage SAF X X 54 5 Skyline Salvage SAF X X 55 1 Tractor Salvage SAF X X 56 24 Skyline Salvage DF X X 57 61 Skyline Salvage DF X X 58 24 Skyline Salvage DF X X 59 16 Tractor mix of salvage and green thin PP X X 60 6 Tractor Salvage DF X X 63 24 Tractor Salvage L X X 64 12 Tractor Salvage DF X X 66 57 Tractor mix of salvage and green thin DF X X 68 35 Skyline Salvage DF X X 69 12 Skyline Salvage LP X X 70 9 Skyline Salvage LP X 71 114 Skyline Salvage DF X 72 21 Tractor Salvage DF X 73 23 Skyline Salvage LP X 74 28 Skyline Salvage DF X 75 12 Skyline Salvage DF X 76 29 Skyline Salvage DF X 77 21 Skyline Salvage DF X
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Forest type in Unit Equipment majority Number Acres1 Type2 Treatment of stand Alt 2 Alt 3 78 5 Tractor Salvage DF X 79 43 Skyline Salvage DF X 81 120 Skyline Salvage LP X 82 18 Tractor Salvage LP X 90 9 Tractor Salvage SAF X X 91 10 Tractor Salvage DF X 92 79 Skyline Salvage DF X 93 23 Skyline Salvage DF X 94 6 Skyline Salvage DF X 95 8 Skyline Salvage DF X 96 12 Skyline Salvage DF X 97 27 Skyline Salvage LP X 98 96 Excaline Salvage LP X 99 110 Skyline Salvage DF X 100 1 * roadside hazard tree removal SAF X X 101 1 * roadside hazard tree removal SAF X X 102 1 * roadside hazard tree removal L X X 103 2 * roadside hazard tree removal SAF X X 104 13 * roadside hazard tree removal DF X X 105 3 * roadside hazard tree removal LP X X 106 0.1 * roadside hazard tree removal DF X X 107 1 * roadside hazard tree removal DF X X 108 1 * roadside hazard tree removal DF X X 109 7 * roadside hazard tree removal LP X X 110 13 * roadside hazard tree removal PP X X 111 10 * roadside hazard tree removal DF X X 112 6 * roadside hazard tree removal DF X X 113 39 * roadside hazard tree removal DF X X 114 4 * roadside hazard tree removal C X X 115 3 * roadside hazard tree removal GF X X hazard tree removal around X X 116 1 T historic structures GF 117 10 * roadside hazard tree removal L X X 118 10 * roadside hazard tree removal DF X X 119 9 * roadside hazard tree removal GF X X 120 19 * roadside hazard tree removal DF X X 1Acres are approximate 2Equipment reflects the primary yarding system. Units may contain incidental areas that would require another type of equipment. *Tractor would remain on the road and cut hazard trees would winched to the road with a cable.
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Vegetation Treatment Descriptions:
Salvage Dead and dying trees meeting merchantability specifications would be removed. For this project, merchantable trees are those that are at least 8 inches in diameter at breast height; have at least an 8 foot piece to a 5.6 inch (diameter inside bark) top; and are at least 33 percent sound.
Mix of Salvage and Green Tree Thinning In ponderosa pine stands that burned at lower severity, live trees would be thinned to reduce bark beetle susceptibility of the residual ponderosa pine trees. Fire-killed trees would be removed as described above under the salvage description.
Roadside Hazard Tree Removal Hazard trees within 100 feet of roads would be mitigated. Approximately seven non-contiguous miles of roads are estimated to contain accessible concentrations of merchantable hazard trees (155- 158 acres, which are displayed in Table 2-1 and on the maps in Appendix A). Mechanized equipment used to remove the cut trees would remain on the road. Directional felling and a cable yarding systems would be used to bring the trees to the road to be processed and hauled to a milling facility.
Incidental merchantable hazard trees, outside of the concentrated areas along the remainder of the National Forest road system, could also be commercially removed where practicable and agreed to by both the Forest Service and a purchaser. In these areas, hazards are less concentrated due to natural stand conditions, burn severity, or previous removal. Due to the random location of hazard trees, their removal would not result in one long continuous clearing. Rather, hazard trees would be selected for cutting based on their risk of falling (failure potential) and their likelihood of striking the road if they fall. As described above, mechanized equipment used to remove the cut trees would remain on the road. No hazard trees would be removed within riparian habitat conservation areas except along Road #9991 [ACM road], which runs parallel to the Thompson River (see Resource Protection Measures in Chapter 2). Roadside hazard trees located within riparian habitat conservation areas (except those located along Road #9991) would be cut and left on the ground.
Roadside hazard trees that are too small (non-commercial less than 8 inches in diameter) and/or inaccessible due to terrain that makes it infeasible for commercial tree removal, would be felled and left on the ground.
A hazard tree is defined as a dead tree within approximately 100 feet of a road that has one or more of the following conditions and any part of the bole of the tree can reach the road as follows:
The tree is leaning more than 10° towards the road.
The roots or part of the bole is comprised in such a way (cat faces on the bole, roots of one side of the tree are burned off, etc.) that the tree would fall towards or onto the road.
Ground conditions would direct the tree towards the road such as steep slopes, unstable ground (scree slopes), etc.
The tree is perpendicular to the ground or has a less than 10° lean, and is exposed to the prevailing wind and the road is on the leeward side of the tree from the prevailing wind in wind prone areas (exposed ridges, saddles, canyons, etc.).
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Historic Site Hazard Tree Removal Trees that are a danger to the historic cabins at the Silver King mine site would be cut and removed.
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Appendix C Soils
Tables C-1 through C-5 summarize the estimated detrimental soil disturbance for Alternative 3 associated with harvest activities by unit for skyline, roadside hazard tree removal, summer tractor, winter tractor, and excaline methods. Alternative 3 is represented in detail because it contains the maximum number of units to be harvested. Alternative 2 drops entire units (see Appendix B). Region 1 Soil Quality Standards identifies a threshold of 15 percent detrimental soil disturbance (DSD) as a guideline for maintenance or loss of soil productivity and to show compliance with the National Forest Management Act. Predictions of additional DSD from project activities are estimates based on best available science. For more information, see the Soil report and supporting documentation in the Project File. Skyline Harvest
Table C-1: Skyline Harvest Soil Disturbance Estimate – Alternative 3 Potential DSD (%) Total Cumulative DSD Reduction Current Estimated From Salvage DSD without from Unit DSD Post-Activity (including From Rehabilitation Rehabilitation (%) Short-term harvest Temporary (%) (%) method and Roads DSD (%) mitigations)
2 2% 4% 3% 9% 4% 4% 6 8% 4% 1% 13% 4% 9% 8 2% 4% 2% 8% 5% 3% 10 9% 4% 0% 13% 3% 10% 11 4% 4% 0% 8% 3% 5% 14 9% 4% 0% 13% 3% 10% 15 2% 4% 2% 8% 5% 2% 17 9% 4% 0% 13% 3% 10% 20 9% 4% 0% 13% 3% 10% 21 9% 4% 0% 13% 4% 9% 24 2% 4% 0% 6% 3% 3% 30 4% 4% 2% 10% 4% 6% 31 2% 4% 0% 6% 3% 3% 33 2% 4% 0% 6% 3% 3% 34 2% 4% 0% 6% 3% 3% 36 2% 4% 4% 10% 5% 5% 38 0% 4% 0% 4% 3% 0% 39 2% 4% 0% 6% 3% 3% 40 6% 4% 0% 10% 0% 10% 41 0% 4% 0% 4% 3% 1%
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Potential DSD (%) Total Cumulative DSD Reduction Current Estimated From Salvage DSD without from Unit DSD Post-Activity (including From Rehabilitation Rehabilitation (%) Short-term harvest Temporary (%) (%) method and Roads DSD (%) mitigations)
42 0% 4% 0% 4% 3% 1% 43 0% 4% 0% 4% 3% 1% 44 0% 4% 0% 4% 3% 1% 45 0% 4% 0% 4% 3% 0% 48 0% 4% 0% 4% 3% 1% 50 8% 4% 2% 14% 4% 10% 52 2% 4% 0% 6% 3% 3% 54 8% 4% 0% 12% 3% 9% 56 6% 4% 0% 10% 3% 7% 57 2% 4% 0% 6% 3% 3% 58 2% 4% 1% 7% 4% 4% 68 6% 4% 0% 10% 3% 7% 69 2% 4% 2% 8% 4% 4% 70 2% 4% 0% 6% 3% 3% 71 2% 4% 3% 9% 4% 4% 73 4% 4% 0% 8% 3% 5% 74 2% 4% 0% 6% 3% 3% 75 4% 4% 0% 8% 3% 5% 76 4% 4% 0% 8% 3% 5% 77 2% 4% 0% 6% 3% 3% 79 0% 4% 0% 4% 3% 0% 81 2% 4% 3% 9% 4% 5% 92 2% 4% 3% 9% 4% 5% 93 4% 4% 0% 8% 3% 5% 94 4% 4% 8% 16% 7% 10% 95 4% 4% 0% 8% 3% 5% 96 4% 4% 5% 13% 5% 8% 97 0% 4% 2% 6% 4% 2% 99 2% 4% 2% 8% 3% 5%
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Roadside Hazard Tree Removal
Table C-2: Roadside Hazard Tree Removal Soil Disturbance Estimate – Alternative 3 Potential DSD (%) Total Cumulative DSD Reduction Current From Salvage Estimated DSD without from Unit DSD (including From Post-Activity Rehabilitation Rehabilitation (%) harvest Temporary Short-term (%) (%) method and Roads DSD (%) mitigations)
100 0% 7% 0% 7% 0% 7% 101 0% 7% 0% 7% 0% 7% 102 2% 7% 0% 9% 0% 9% 103 3% 7% 0% 10% 0% 10% 104 2% 7% 0% 9% 0% 9% 105 2% 7% 0% 9% 0% 9% 106 2% 7% 0% 9% 0% 9% 107 2% 7% 0% 9% 0% 9% 108 3% 7% 0% 10% 0% 10% 109 2% 5% 0% 7% 0% 7% 110 0% 5% 0% 5% 0% 5% 111 0% 5% 0% 5% 0% 5% 112 0% 5% 0% 5% 0% 5% 113 0% 5% 0% 5% 0% 5% 114 0% 5% 0% 5% 0% 5% 115 0% 5% 0% 5% 0% 5% 116 0% 5% 0% 5% 0% 5% 117 0% 5% 0% 5% 0% 5% 118 0% 5% 0% 5% 0% 5% 119 0% 5% 0% 5% 0% 5% 120 0% 5% 0% 5% 0% 5%
Summer Tractor Harvest
Table C-3: Summer Tractor Harvest Soil Disturbance Estimate – Alternative 3 Potential DSD (%) Total Cumulative DSD Reduction Current From Estimated Salvage DSD without from Unit DSD From Post-Activity (including Rehabilitation Rehabilitation (%) Temporary Short-term harvest (%) (%) Roads DSD (%) method and mitigations) 4 2% 10% 0% 12% 3% 9% 12 7% 10% 0% 17% 5% 12%
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Potential DSD (%) Total Cumulative DSD Reduction Current From Estimated Salvage DSD without from Unit DSD From Post-Activity (including Rehabilitation Rehabilitation (%) Temporary Short-term harvest (%) (%) Roads DSD (%) method and mitigations) 13 9% 10% 0% 19% 5% 14% 18 3% 10% 0% 13% 6% 7% 19 9% 10% 0% 19% 6% 13% 22 9% 10% 0% 19% 6% 13% 23 2% 10% 0% 12% 5% 7% 37 3% 10% 0% 13% 6% 7% 46 3% 13% 0% 16% 6% 10% 47 3% 13% 0% 16% 5% 11% 49 6% 13% 0% 19% 6% 13% 51 0% 10% 0% 10% 5% 5% 53 6% 13% 0% 19% 6% 13% 55 8% 10% 0% 18% 4% 14% 59 0% 10% 0% 10% 3% 7% 60 0% 10% 0% 10% 6% 4% 63 0% 10% 0% 10% 6% 4% 64 0% 10% 0% 10% 5% 5% 66 0% 10% 0% 10% 6% 4% 82 0% 13% 0% 13% 6% 7% 90 3% 13% 0% 16% 6% 10%
Winter Tractor Harvest
Table C-4: Winter Ground-Based Harvest Soil Disturbance Estimate – Alternative 3 Potential DSD (%) Total Cumulative DSD Reduction Current From Salvage Estimated DSD without from Unit DSD (including From Post-Activity Rehabilitation Rehabilitation (%) harvest Temporary Short-term (%) (%) method and Roads DSD (%) mitigations)
1 9% 4% 0% 13% 4% 9% 3 9% 4% 0% 13% 4% 9% 5 10% 4% 0% 14% 4% 10% 7 7% 4% 0% 11% 4% 7% 9 7% 4% 0% 11% 3% 8% 25 9% 4% 0% 13% 3% 10%
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Potential DSD (%) Total Cumulative DSD Reduction Current From Salvage Estimated DSD without from Unit DSD (including From Post-Activity Rehabilitation Rehabilitation (%) harvest Temporary Short-term (%) (%) method and Roads DSD (%) mitigations)
26 7% 4% 0% 11% 4% 7% 27 9% 4% 0% 13% 3% 10% 28 10% 4% 0% 14% 4% 10% 29 9% 4% 0% 13% 4% 9% 32 7% 4% 0% 11% 3% 8% 72 7% 4% 0% 11% 3% 8% 78 7% 4% 0% 11% 3% 8% 91 9% 4% 0% 17% 4% 13%
Excaline Harvest
Table C-5: Excaline Harvest Soil Disturbance Estimate – Alternative 3 Potential DSD (%) Total Cumulative DSD Reduction Current Estimated From Salvage DSD without from Unit DSD Post-Activity (including From Rehabilitation Rehabilitation (%) Short-term harvest Temporary (%) (%) method and Roads DSD (%) mitigations)
98 2% 4% 1% 7% 3% 4%
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Appendix D
Review of Literature Provided in Public Comment
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Literature Provided by Tricon Timber, LLC The commenter submitted the following literature to support their statement that salvage logging is not detrimental to soils. 1 James, Cajun. 2014. Post-Wildfire Salvage Logging, Soil Erosion, and Sediment Delivery – Ponderosa Fire, Battle Creek Watershed, Northern California Preliminary Results. Sierra Pacific Industries. 23 pp.
Forest Service Response: This reference is a study conducted by Sierra Pacific Industries of post-wildfire soil erosion with and without salvage on the 2012 Ponderosa Fire in northern California. This study was designed and implemented within 40 days of fire containment and before any rainfall event occurred. Therefore the study captured all rainfall and erosion events after both the fire and subsequent salvage logging. Counterintuitively, the field data showed that the least disturbed sites actually produced the highest average hill slope soil erosion while the most disturbed sites produced the lowest average hill slope soil erosion. Specifically, the control sites, which were disturbed only by the fire produced the highest average erosion rates. The first year data demonstrated that the site disturbance eliminated soil hydrophobicity, increased rainfall infiltration, reduced runoff velocity, shortened hill slope length, and thereby substantially reduced overall average soil erosion and sediment delivery.
This was a preliminary study that considered effects from salvage logging on erosion and runoff within 1 year of harvest activities. It did not consider erosion and runoff in subsequent years, or effects to soil disturbance and ground cover. Results in the study area were attributed to the presence of a strong hydrophobic soil layer resulting from fire effects. Hydrophobicity is site specific and generally depends on soil type and extent of soil heating.
This article was not applicable to the Copper King project for the following reasons: Region 1 Soil Policy considers site specific soil disturbance including compaction, rutting, and displacement to assess long-term soil productivity. This study did not consider the effects of soil disturbance on long-term site infiltration rates or productivity. Ground cover is an important measure of soil productivity. Preliminary results from this study displayed a decrease in ground cover in areas that experienced ground disturbance from harvest activities. In the Copper King fire area soils displayed very little hydrophobicity, including high severity burn areas (Copper King BAER Report, 2016). Increased erosion and runoff in the fire area is expected due to lack of surface vegetation but is not attributed to soil hydrophobicity. Site conditions in the study area and the Copper King Salvage Project area are not comparable. Although detailed soil classification was not provided in this study, soils in the Copper King fire are not similar to those in the study area. Rainfall intensity was also much higher in the study area than those experienced under normal conditions in the Copper King area. This study was preliminary (considered only one year of results). 2 Poff, Roger J. 1989. Compatibility of timber salvage operations with watershed values. USDA Forest Service Gen. Tech. Rep PSW-109, pp. 137-140
Forest Service Response: This reference is an article about the timber salvage on the 1987 Indian Fire on the Tahoe National Forest in California. The author suggests that salvage was carried out without compromising watershed values and in some cases actually improved watershed conditions by providing ground cover, removing trees that were a source of erosive water droplets, and by breaking up hydrophobic soil layers. Negative impacts of timber salvage on watersheds were minimized by using an interdisciplinary team that identified issues, concerns and opportunities early, defined specific resource objectives for each resource, and had access to accurate site information, and developed management prescriptions in the context of whole watersheds and fire management areas.
This paper is not applicable to the Copper King project. It is an observational report and does not present methodology or study results. It is unclear how results and conclusions were determined. Description of the prescribed treatments was not detailed enough to compare to proposed treatments in the Copper King area, no methodology was provided, and no data is provided for the results and conclusions presented. 3 Smith et al. 2009. Impacts of Post-fire Salvage Logging and Wildfire Burn Intensity on Soil Productivity and Forest Recovery.
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Forest Service Response: This reference is a study conducted on the 2003 Booth and Bear Butte Fire Complex in central Oregon to examine the effects of salvage logging and burn intensity on soil productivity and forest recovery. The study found that compaction and subsoiling after post-fire salvage logging had little effect on soil bacterial and fungal species richness and function. However, available phosphorus and nitrogen were lower in the compacted and subsoiled units following salvage treatments than in undisturbed treatment areas. Tree seedling growth was monitored for 3 years after planting and found that subsoiling after ground-based harvest positively affected tree seedling survival and growth.
This study is not applicable to the Copper King project. Region 1 soil policy is based on the use of six physical and one biological attribute to assess current soil quality and project effects. These attributes (compaction, rutting, displacement, severely-burned soils, surface erosion, soil mass movement, and organic matter) are used as a proxy to determine: (1) soil productivity, and (2) soil hydrologic function (Page-Dumroese et al, 2009). This study analyzed a variety of chemical, physical, and biological properties to assess soil productivity but only disclosed results from microbial analysis and phosphorus and nitrogen analysis. These indicators alone are not sufficient to assess long term soil productivity, and soil hydrologic function was not considered in this study. The tree seedling growth study showed a benefit to tree growth from subsoiling after salvage logging; subsoiling is not proposed in the Copper King project. Soil burn severity was not considered in the salvage logging section of this study, and it is unknown if harvest activities were conducted on soils with high burn severity. Results from this study are not contradictory to recommendations made in the Copper King Soils report, but this study displayed few effects to the soils resource that would guide management actions. 4 USDA Forest Service. 2002. Postfire Logging: Is It Beneficial to a Forest. Science Findings: Issue 47. Pacific Northwest Research Station. Portland, OR.
Forest Service Response: This reference is an issue of Science Findings published by the USDA Forest Service Pacific Northwest Research Station. It summarizes the debate about post-fire logging. Specifically with respect to soils, the article discusses the findings of a post-fire logging study conducted on the 1996 Summit Fire in eastern Oregon. The logging was done over snow, the skidding equipment traveled on a limited number of main trails, and no new roads were built. The experimental study found that the use of logging machinery disturbed between 8 and 20 percent of the soil area in study units, with displacement and compaction the principal types of disturbance. Sediment transport out of the area was minimal. The study suggests that logging can be done with acceptable effects on soils and minimal sediment transport off-site, provided the right equipment and approach are used.
For the Copper King project, soils would be protected through carefully developed project design, resource protection measures, and best management practices. For example, similar to the study discussed in the article, winter logging would be required on specific tractor units where there are soil concerns. This reference is cited in the Copper King Soils report to support recommended management actions.
Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense
1 Beschta, Robert L., Christopher A. Frissell, Robert Gresswell, Richard Hauer, James R. Karr, G. Wayne Minshall, David A. Perry, and Jonathan J. Rhodes. 1995. Wildfire and Salvage Logging: Recommendations for Ecologically Sound Post-Fire Salvage Management and Other Post-Fire Treatments On Federal Lands in the West. Oregon State University, Corvallis, OR.
Comment Excerpt: Beschta et al. (1995) found: There is no ecological need for immediate intervention on the post-fire landscape. With respect to the need for management treatments after fires, there is generally no need for urgency, nor is there a universal, ecologically-based need to act at all. By acting quickly, we run the risk of creating new problems before we solve the old ones. Ecologically speaking, fires do not require a rapid human response. We should not talk about a "fire crisis" but rather of managing the landscape with the anticipation that fire will eventually occur. Given the high degree of variability and high uncertainty about the impacts of post-fire responses, a conservative approach is warranted, particularly on sites susceptible to on-site erosion. Although our current understanding of the ecological effects of post-fire logging is incomplete, what we do know suggests that such logging can and often has resulted in
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense significant damage to soils, streams and wildlife by: eliminating or significantly reducing large, dead standing trees critical for many wildlife species; damaging the soil through increased soil erosion and compaction; creating warmer, drier microclimate conditions (thereby increasing fire danger); simplifying forest structure; removing important sources of nutrients and organic material (potentially reducing long-term productivity); and, encouraging the spread of noxious weeds into burned areas. In short, post-fire logging reduces important components of the forest ecosystem, and tends to further exacerbate stresses caused by the initial disturbance event.
Beschta et al. (1995) question the ecological justifications of post-fire logging stating that while “there is little reason to believe that post-fire salvage logging has any positive ecological benefits… there is considerable evidence that persistent, significant adverse environmental impacts are likely to result from salvage logging, based on many past cases of salvage projects.” There is also no scientific support that post-fire logging is needed to reduce risk of future fires. Beschta et al. (1995) state they “…are aware of no evidence supporting the contention that leaving large dead wood material significantly increases the probability of reburn.”
Fire is a natural and essential component of forest ecosystems and the presence of fire indicates high degrees of ecosystem function. Beschta et al. (1995) state, “Land managers should be managing for the naturally evolving ecosystems, rather than perpetuating artificial ones we have attempted to create.”
Forest Service Response: This reference is a post-fire management commentary paper written in response to concerns about salvage logging and other management practices to be implemented following the extensive fires in 1994. Beschta et al. 1995 contains general principles and recommendations for post-fire salvage and other treatments on Federal land in the interior Columbia and upper Missouri Basins. The authors ask land managers to consider all post-fire hazards and management alternatives, but their recommendations are often biased toward a “hands-off” approach (Everett 1995 (cited reference #10, below)). Specific to post-fire management, Beschta et al. (1995) recommend: allowing natural recovery and prohibit human intervention unless the natural recovery process is not occurring; protect soils; preserve capabilities of species to naturally regenerate; prohibit salvage logging in sensitive areas (e.g. erosive soils, riparian and roadless areas, fragile soils); limit salvage logging (e.g. limit the amount and size of trees that can be harvested); prohibit new road construction; conduct active reseeding and replanting only under limited conditions; avoid use of structures near stream channels; educate the public; and continue research to address ecological and operational issues.
The Forest Service proposes salvage on at most 2300 acres or 12 percent of the National Forest System land affected by the Copper King Fire. Within salvage units, some fire-killed trees would be left to provide for wildlife habitat and soil productivity. Nearly 17,000 acres of 88 percent of the fire area on National Forest System lands would be left to natural processes. The Copper King Fire Salvage project incorporates carefully developed design criteria, resource protection measures, and best management practices to minimize undesirable ecological effects (see EA, Chapter 2). For example, no salvage would occur within riparian areas and the standard width of riparian habitat conservation areas used to protect riparian areas (stream buffers) would be expanded to provide further protections to aquatic resources.
The purposes of the salvage are to address public safety concerns and support local economies by providing employment opportunities and wood products (see EA, Chapter 1). Proposed salvage is not for the purposes of ecological restoration or to reduce the risk of future fires as referenced in the “comment excerpt” above. The Copper King Fire Salvage project is designed to minimize undesirable ecological effects while realizing other social or economic benefits such as providing employment opportunities and supporting industry infrastructure by contributing to the timber supply of local mills. 2 Beschta, Robert L., Jonathan J. Rhodes, J. Boone Kauffman, Robert E. Gresswell, G. Wayne Minshall, James R. Karr, David A. Perry, F. Richard Hauer and Christopher A. Frissell. 2004. Postfire management on forested public lands of the western United States. Conservation Biology, Vol. 18, No. 4, August 2004, Pages 957-967.
Comment Excerpt: Beschta, et al. (2004) state: “Forest ecosystems in the western United States evolved over many millennia in response to disturbances
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense such as wildfires. …Forest ecosystems area especially vulnerable to postfire management practices because such practices may influence forest dynamics and aquatic systems for decades to centuries.” The plethora of information strongly implicates post-fire logging as ecologically detrimental.
Forest Service Response: This reference is similar to Beschta et al. 1995 (cited reference #1) in that it provides similar recommendations for post-fire management on public lands in the western US from the perspective of ecosystem recovery: promote natural recovery; protect soils; rehabilitate sites disturbed by fire suppression; ban introduction of exotic species; curtail livestock grazing; avoid use of structures near stream channels; limit post-fire logging; and prohibit new road construction
See response to cited reference #1. This reference is further addressed in the EA (Chapter 2, section 2.4).
In their synthesis of scientific findings on the effects of logging following large wildfire in western North America, Peterson et al. 2009 suggest that the effects of post-fire logging depends on the biophysical setting of the forest, the intensity of the fire, intensity of the logging operation, and other management activities. The authors found that a better understanding is needed of scale-related issues to reduce scientific uncertainty of post-fire logging. They highlight that more information is needed on how the proportion of harvest area relative to the total fire area affects the magnitude of change in different resources. For example, the Copper King Fire Salvage project would include salvage on at most 12 percent of the National Forest System land affected by the fire. 3 Bull, E., et al. 2001. Effects of Disturbance on Forest Carnivores of Conservation Concern in Eastern Oregon and Washington. Northwest Science. Vol 75, Special Issue, 2001.
Comment Excerpt: Many adverse consequences to soil, ecological processes, wildlife, and other elements of the natural environment are associated with logging, including thinning. For example: “Salvage or thinning operations that remove dead or decayed trees or coarse woody debris on the ground will reduce the availability of forest structures used by fishers and lynx.”
Forest Service Response: This article provides a brief overview of the habitat needs for Canada lynx, fisher and wolverine. The authors state that large stand- replacement fires (like Copper King) convert mature forests to early successional forests and that the resulting young stands do not provide suitable habitat for fishers, wolverines, or denning lynx. The Copper King project proposes salvage on at most 2300 acres or about 12 percent of the National Forest System land affected by the fire. Nearly 17,000 acres or 88 percent would be left to natural processes and would provide snags and downed coarse wood in the future for these species when forest succession develops into suitable habitat. 4 Campbell, J., D. Donato, D. Azuma, and B. Law. 2007. Pyrogenic carbon emission from a large wildfire in Oregon, United States. Journal of Geophysical Research. Vol. 112, G04014. December 2007.
Comment Excerpt: Post-fire logging and pre-fire thinning reduce on-site carbon storage by removing tree boles from the forest as logs. Research finds that tree boles, even in severely burned forests, account for less than 5% of the carbon released during fire, which consumes primarily needles and surface fuels. Even in high severity fires, only about 25% of above-ground carbon stores are released. For these reasons, research finds that forest thinning in anticipation of fire releases more carbon to the atmosphere than would fire (Meigs et al. 2009, and Campbell et al.2007).
Road construction and logging, even winter logging, would…reduce on-site carbon storage by removing tree boles from the forest as logs. Indeed, research finds that tree boles, even in severely burned forests, account for less than 5% of the carbon released during fire, which consumes primarily needles and surface fuels (Meigs et al. 2009, and Campbell et al. 2007).
Forest Service Response: This article measures the total pyrogenic carbon emissions from the 2002 Biscuit Fire in southwestern Oregon. The authors used federal inventory plots which had been measured on 10-year intervals beginning in 1970 as their pre-burn metrics and selected 54 plots across burn severities to
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense determine total carbon emissions caused by the fire. They concluded that the total pyrogenic emissions from the Biscuit fire were between 3.5 and 4.4 million metric tons of carbon. Put into context, this number is nearly equal to the gross primary production and 18 times the annual net primary production of the Klamath- Siskiyou ecoregion where the fire occurred. Or put in another way, the carbon emissions estimated to have been released by the Biscuit Fire in this study is equal to about a third of the carbon reported to be released annually through fossil fuel burning in Oregon, which is considered to be regionally significant.
While the study notes that nearly 60% of these pyrogenic emissions of the Biscuit Fire came from litter, foliage, and small down wood debris, it makes no conclusions about the effects of post-fire logging or pre-fire thinning. The statement the commenter makes, “research finds that forest thinning in anticipation of fire releases more carbon to the atmosphere than would fire” is the claim of the commenter and is not supported by the research presented in this article.
The Copper King project would harvest fire-killed trees on up to approximately 2300 acres, which would, in the short term, remove and release some carbon currently stored within the dead trees. A portion of the carbon removed would remain stored for a period of time in wood products (US EPA 2013; Depro, et al. 2008). However, none of the alternatives would have a discernable impact on atmospheric concentrations of greenhouse gases or global warming, considering the limited changes in both rate and timing of carbon flux predicted within these relatively few affected forest acres and the global scale of the atmospheric greenhouse gas pool and the multitude of natural events and human activities globally contributing to that pool (see EA Chapter 3, Forest Carbon Storage and Climate Change section for more details). 5 Center for Biological Diversity and John Muir Project, 2014. Nourished By Wildfire: The Ecological Benefits of the Rim Fire and the Threats of Salvage Logging. January 2014.
Comment Excerpt: The Center of Biological Diversity and John Muir Project (2014): Burned forests are not dead zones, but rather teem with life. The reflex reaction to log after forest fires directly contradicts decades of scientific research showing both the immense ecological importance of post-fire landscapes and the significant harm that can occur when such areas are logged. Forest fires like the Rim fire are essential to maintain biological diversity in the Sierra’s ecosystems, and burned and dead trees provide critical habitat to numerous wildlife species. Of course, a legitimate public-safety exception is warranted to protect the public from falling trees in heavily traveled corridors.
This report analyzes the Rim fire in relation to the relevant biological science and recommends: Rather than industrial scale salvage logging, post-fire management should focus on activities that benefit forest health, water quality and the many species that depend upon fire for their very existence.
Forest Service Response: This is a position paper written by a conservation organization in opposition to a proposal to salvage burned timber resulting from the 2013 Rim Fire in the Sierra Nevada Mountains of California. The Rim Fire burned over 257,000 acres and the Forest Service initially proposed salvage on approximately 30,000 acres, which was later dropped to about 15,000 acres in the responsible official’s decision. The authors discuss the ecological importance of burned forests and the potential adverse environmental effects of salvage activities. The authors recommend that post-fire logging be avoided except to address public safety and research funds should be dedicated to learning more about the biological diversity of post-fire areas.
The Forest Service recognizes the ecological value of burned forests. At most, approximately 2300 acres (12 percent) of the National Forest System land affected by the Copper King Fire would be salvaged. Within proposed harvested areas, some dead trees would be retained to provide for wildlife habitat and soil productivity. Nearly 17,000 acres or 88 percent of the burned area would be left to natural processes. The project also incorporates carefully developed design criteria, best management practices, and resource protection measures to minimize undesirable ecological effects from salvage harvest (see EA, Chapter 2).
The Forest Service also recognizes the social value of economic benefits and the importance of supporting local communities. Therefore, the Copper King Fire Salvage project was designed to minimize undesirable ecological effects while realizing other social or economic benefits such as providing employment opportunities and supporting industry infrastructure by contributing to the timber supply of local mills.
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense 6 Cherry, M.B., 1997. The black-backed and three-toed woodpeckers: life history, habitat use, and monitoring plan. Unpublished report. On file with: Lewis & Clark National Forest, P.O. Box 869, Great Falls, Montana, 59403, 406-791-7700. 19 pp.
Comment Excerpt: The black-backed woodpecker is a sensitive species. Cherry (1997) states: The black-backed woodpecker appears to fill a niche that describes everything that foresters and fire fighters have attempted to eradicate. For about the last 50 years, disease and fire have been considered enemies of the “healthy” forest and have been combated relatively successfully. We have recently …realized that disease and fire have their place on the landscape, but the landscape is badly out of balance with the fire suppression and insect and disease reduction activities (i.e. salvage logging) of the last 50 years. Therefore, the black-backed woodpecker is likely not to be abundant as it once was, and continued fire suppression and insect eradication is likely to cause further decline.
Forest Service Response: This 20-year old paper was written to examine the life history of the black-backed and three-toed woodpecker, to gain an understanding of their similarities and differences, the niches they occupy, and use the information to develop a monitoring plan for the black-backed woodpecker in southwestern Montana. It is important to note that this paper was written when large-scale fire was far less common than it is today. Due to the increase in large fires within Region 1 over the last two decades, the species concerns and management recommendations provided in this paper are likely not as pertinent as they once were. Since this paper was published, Region-wide surveys have been conducted for the black-backed woodpecker and a population viability assessment has been completed which determined that habitat for the species is well-distributed across the Region and by Forest and that species viability in the Northern Region is not an issue.
Recommendations in the Cherry paper suggest retaining 30% of the fire area unmanaged for fires greater than 10,000 acres (like Copper King); retaining large portions of the dead trees uncut; and leave as many snags as possible. Nearly 17,000 acres or about 88 percent of the National Forest System land affected by the Copper King fire would be left to natural processes and provide abundant nesting and foraging habitat for black-backed woodpeckers. 7 DellaSala, Dominick A. and Chad T. Hanson, 2015. The Ecological Importance of Mixed-Severity Fires: Nature's Phoenix. Published by Elsevier Inc.
Comment Excerpt: DellaSalla and Hanson (2015) state: Along with the surge in scientific investigation into historical fire regimes over the past 10-15 years has come enhanced understanding of the naturalness and ecological importance of mixed- and high-severity fire in many forest and shrub ecosystems. Contrary to the historical assumption that higher-severity fire is inherently unnatural and ecologically damaging, mounting evidence suggests otherwise. Ecologists now conclude that in vegetation types with mixed- and high severity fire regimes, fire-mediated age class diversity is essential to the full complement of native biodiversity and fosters ecological resilience and integrity in montane forests of North America (Hutto, 1995, 2008; Swanson et al., 2011; Bond et al., 2012; Williams and Baker, 2012a; DellaSala et al., 2014). Ecological resilience is essentially the opposite of “engineering resilience,” which pertains to the suppression of natural disturbance to achieve stasis and control of resources (Thompson et al., 2009). Ecological resilience is the ability to ultimately return to predisturbance vegetation types after a natural disturbance, including higher- severity fire. This sort of dynamic equilibrium, where a varied spectrum of succession stages is present across the larger landscape, tends to maintain the full complement of native biodiversity on the landscape (Thompson et al., 2009).
…As discussed above, in mixed-severity fire regimes, higher-severity fire occurs as patches in a mosaic of fire effects (Williams and Baker, 2012a; Baker, 2014). In conifer forests of North America, higher-severity fire patches create a habitat type, known as complex early seral forest (DellaSala et al., 2014), that supports levels of native biodiversity, species richness, and wildlife abundance that are generally comparable to, or even higher than, those in unburned old forest (Raphael et al., 1987; Hutto, 1995; Schieck and Song, 2006; Haney et al., 2008; Donato et al., 2009; Burnett et al., 2010; Malison and Baxter, 2010; Sestrich et al., 2011; Swanson et al., 2011; DellaSala et al., 2014). Many rare, imperiled, and declining wildlife species depend on this habitat (Hutto, 1995, 2008; Kotliar et al., 2002; Conway and Kirkpatrick, 2007; Hanson and North, 2008; Bond et al., 2009; Buchalski et al., 2013; Hanson, 2013, 2014; Rota, 2013; Siegel et al., 2013; DellaSala et al., 2014; Baker, 2015; see also Chapters 2–6). The scientific literature reveals the naturalness and ecological importance of multiple age classes and successional stages following higher-severity fire, as well as the common and typical occurrence of natural forest regeneration after such fire (Shatford et al., 2007; Donato et al., 2009; Crotteau et al., 2013; Cocking et al., 2014; Odion et al., 2014). These and other studies suggest that mixed-
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense severity fire, including higher-severity fire patches, is part of the intrinsic ecology of these forests and has been shaping fire- dependent biodiversity and diverse landscapes for millennia.
Forest Service Response: This cited reference is a book that discusses the various ecological benefits of mixed and high severity fires. Chapter 11 specifically addresses post-fire management. The authors state that there is no ecological basis for post-fire logging and, suggest that if forests are to be managed for ecological integrity, post-fire logging is not a management practice that should continue.
The authors present case studies where post-fire logging occurred over large landscapes following large fire events and summarize the following effects: degradation of stand structure and function, loss of soil nutrients, chronic sedimentation and erosion, reduction in carbon storage, increased abundance of invasive species, and increased fine fuel loads and potential reburn severity. However, they also state that “response of fire-adapted species and communities to post-fire logging depends on the scale, intensity, degree of biological legacies removed (McIver and Starr, 2000, Lindenmayer and Noss, 2006), disturbance history of the site (Reeves et al., 2006, Hutto, 2006), and species-specific tolerance to logging” (page 315). The authors recommend: 1) post-disturbance landscapes be allowed to regenerate naturally; 2) road building be avoided; 3) post-fire logging in dense, mature, or old forest stands be avoided to maintain complex, early-seral habitat; 4) large dead trees be left on site as biological legacies; 5) interventions only be made in ways that promote natural processes; and 6) fragile areas be avoided by establishing “go” and “no go” zones if post fire logging is to occur.
The Forest Service agrees with the assertion in the citation provided by the commenter (see comment excerpt) that in vegetation types with mixed- and high severity fire regimes, ‘mixed-severity fire, including higher-severity fire patches, is part of the intrinsic ecology of these forests and has been shaping fire-dependent biodiversity and diverse landscapes for millennia.’
In terms of scale, the Forest Service proposes salvage on at most 2300 acres or 12 percent of the National Forest System land affected by the Copper King Fire. Within salvage units, some fire-killed trees would be left to provide for wildlife habitat and soil productivity. Nearly 17,000 acres of 88 percent of the fire area on National Forest System lands would be left to natural processes. The purposes of the salvage are to address public safety concerns and support local economies by providing employment opportunities and wood products (see EA, Chapter 1). Proposed salvage is not for the purpose of forest restoration. In contrast to what the authors describe about the affected areas in their case studies, the Copper King Fire Salvage project is not located within an area of “ecological significance” (see discussion in Chapter 2, section 2.5.). To minimize undesirable ecological effects, the Copper King Fire Salvage project incorporates carefully developed design criteria resource protection measures, and best management practices (see EA, Chapter 2). 8 DellaSala, Dominick, James R. Karr, Tania Schoennagel, Dave Perry, Reed F. Noss, David Lindenmayer, Robert Beschta, Richard L. Hutto, Mark E. Swanson, Jon Evans; 2006. Post-Fire Logging Debate Ignores Many Issues. SCIENCE, Vol. 314, 6 October 2006, pp. 51-52.
Comment Excerpt: DellaSala et al. 2006 state: Recent controversy concerning post-fire logging in Oregon is emblematic of the problems of “salvage logging” globally. Although tree regeneration after disturbances in forested areas is important, a narrow view of this issue ignores important ecological lessons, especially the role of disturbances in diversifying and rejuvenating landscapes. Scientific advances in recent decades demonstrate that disturbances are not catastrophes, trees in these landscapes are not wasted if they are not harvested, and post-fire logging is not forest restoration. (Disturbances) create and sustain the structure and composition of forests; disturbed areas also support species that are rare or absent from closed canopy forests, including many that are restricted to recently burned areas. . . .
When viewed through an ecological lens, a recently disturbed landscape is not just a collection of dead trees, but a unique and biologically rich environment that also contains many of the building blocks for the rich forest that will follow the disturbance. . . .
Ecological damage caused by post-disturbance logging may outweigh short-term economic benefits. If conducted improperly, timber harvest of any kind,
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense damages soils and below-ground processes, spreads invasive species, increases sediment delivery to streams and destroys or degrades key environments for terrestrial and aquatic species. With post-disturbance logging, however, these impacts occur when forest recovery is most vulnerable to the effects of additional especially anthropogenic, disturbances, creating cumulative effects not associated with logging in undisturbed forests. Such effects can extend for a century or more, because of the removal of long-persisting and functioning biological legacies. Moreover, a focus on post disturbance logging will divert the attention of forest managers from conducting legitimate fuels reduction in fire prone areas by, thinning overly stocked trees and undergrowth…
Forest Service Response: The cited reference is an opinion letter-to-the-editor published in Science magazine about 10 years ago.
The Forest Service proposes salvage on at most 2300 acres or 12 percent of the National Forest System land affected by the Copper King Fire. Within salvage units, some fire-killed trees would be left to provide for wildlife habitat and soil productivity. Nearly 17,000 acres of 88 percent of the fire area on National Forest System lands would be left to natural processes. The purposes of the salvage are to address public safety concerns and support local economies by providing employment opportunities and wood products (see EA, Chapter 1). Proposed salvage is not for the purpose of forest restoration.
DellaSalla et al. also state that if post-disturbance logging is conducted for timber production, stringent ecological safeguards must be in place to minimize impacts to terrestrial and aquatic ecosystems. Consistent with this recommendation, the Copper King Fire Salvage project incorporates carefully developed design criteria resource protection measures, and best management practices to minimize undesirable ecological effects (see EA, Chapter 2). For example, the standard width of riparian habitat conservation areas used to protect riparian areas (stream buffers) would be expanded to provide further protections to riparian areas and aquatic habitat. 9 Donato, D.C., Fontaine, J.B., Campbell, J. L., Robinson, W.D., Kauffman, J.B., and Law, B.E., 2006. Post-wildfire logging hinders regeneration and increases fire risk. Science Express. www.scienceexpress.org.
Comment Excerpt: Research suggests that post-fire recovery occurs best in the absence of logging and that logging hinders recovery (Donato et al. 2006).
Forest Service Response: This reference is a brief article about a study of early conifer regeneration and fuel loads after the 2002 Biscuit Fire, with and without post-fire logging. The study suggests that post-fire logging conducted 2+ years after the fire reduced regeneration due to soil disturbance and increased both fine and coarse downed woody fuel loads.
There was some controversy surrounding this study as other forest science researchers and Oregon State University professors questioned the study’s limited data set and design; and suggested that the article lacked adequate context and supporting information to be clearly interpreted by scientists, resource managers, policy-makers and the public (Baird 2006; Newton et al. 2006).
Newton et al. point out that in the case of the Biscuit Fire (Donato’s study area), logging was postponed for 2 years allowing more seeds to geminate and increasing seedling exposure to injury during logging. If the Copper King project schedule is maintained, salvage operations would begin within a year of the fire. In addition, approximately 350 acres (about 50 percent of the tractor units) would be logged over snow or frozen ground, which would reduce disturbance to the soil and any naturally regenerating vegetation. Regardless, Copper King salvage units would be planted with native tree seedlings.
Interesting to note, more recent research (e.g. Peterson and Dodson 2016; Knapp and Ritchie 2016) indicates that vegetative recovery increases in richness and cover over time regardless of salvage treatments. The authors suggest that disturbance associated with high-severity wildfire may present a bigger threat to vegetative recovery than the disturbance associated with salvage logging.
By design, the Copper King project would leave the tops of cut trees and other woody material on the ground within salvage units for soil protection and wildlife
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense habitat where existing downed wood is deficient. As pointed out in Newton et al.’s critique of the cited reference, Donato et al.’s observations of increased logging slash after logging may have been intended, similar to the Copper King project design. 10 Everett, Richard. 1995, August 16. Review of Beschta Document, Memorandum. USDA, Forest Service.
Comment Excerpt: In a response to Beschta et al. (1995) commissioned by R-6 Regional Forester John Lowe, Everett (1995) conceded that there was “little to no evidence” that post-fire salvage removal of trees limits the intensity of future fires.” He also found no support for frequent claims by salvage proposals that post-fire logging results in no more environmental damage than green harvest.
Forest Service Response: The reference is a letter written by Richard Everett of the USDA Forest Service Forestry Sciences Lab in Wenatchee, WA to the R6 Regional Forester providing his review the recommendations outlined in Beschta et al. 1995 (cited reference #1, above). Mr. Everett summarized that “limiting post-fire management action to only intensive management or only to custodial management [hands off] is inappropriate; every situation is different and should be handled on a case-by-case basis”.
In this 21-year old letter, Mr. Everett did acknowledge that at the time, “a precise evaluation of the effects of salvage logging and total tree retention on reburn fire intensity has not been accomplished.” But he further acknowledged that it is taking more time for burned snags to fall and burned forests to again increase in tree cover and fuel continuity. “Because of the time tables involved, the field testing of the intense reburn concept started in the recent past and will continue into the future.” He went on to say, “What is in the literature is that when dead and live tree biomass increase so does flame length, and fireline intensity (Rothermal 1983). Temperature and duration of heat increase with added forest fuels (Ottmar and Vihnanek 1990). Massive fires with extremely violent behavior occur when excessive fuels are ignited (Project Flambeau Countryman 1969).”
Regardless, the purpose of the salvage in the Copper King project is not to reduce future fire intensity (see EA, Chapter 1).
Mr. Everett’s letter does not include any mention of salvage proposals claiming post-fire logging results in no more environmental damage than green harvest. 11 Franklin, Jerry F., 2015. Comments on the Draft Environmental Impact Statement for the Westside Fire Recovery Project, Klamath National Forest. Jerry F. Franklin, Professor of Ecosystem Analysis, School of Environmental and Forest Science, College of the Environment, University of Washington.
Comment Excerpt: Old-growth forests feature valuable habitat characteristics because of the diversity found only in old growth. Even after a disturbance such as severe fire, these stands retain important habitat characteristics found nowhere else.
In 2015, Dr. Jerry Franklin wrote a letter to the Forest Service concerning a post-fire project proposed for Late Successional Reserves (LSRs) in a national forest covered under the Northwest Forest Plan (NWFP). Dr. Franklin was a principle scientist that assisted the Forest Service in creation of the NWFP as a member of the Forest Ecosystem Management Assessment Team (1993). His letter stated, “Given the important and well defined ecological role assigned the LSRs in the ...(NWFP) I have paid special attention to the scientific rationale offered for the extensive salvage logging that is proposed in LSRs.” His specific comments (Franklin, 2015) include: Salvage logging of large snags and down boles does not contribute to recovery of late successional forest habitat; in fact, the only activity more antithetical to the recovery processes would be removal of surviving green trees from burned sites. Large snags and logs of decay resistant species, such as Douglas-fir and cedars, are particularly critical as early and late successional wildlife habitat as well as for sustaining key ecological processes associated with nutrient, hydrologic, and energy cycles.
Stand-replacement fires provide large pulses of coarse woody debris (CWD) including snags and logs, which lifeboat dependent species and processes until the regenerating forest begins to produce large and decay-resistant dead wood structures, which is typically not for a century or more. Since this pulse provides all of the large CWD that is going to be available to the ecosystem for at least the next 100 to 150 years, it is not appropriate to use the levels of CWD found in
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense mature and old stands of a particular Plant Association Group (PAG) as a guide to levels of CWD that should be retained after salvage. Effectively none of the large snags and logs of decay-resistant species can be viewed as being in excess of what is needed to assist in natural recovery to late successional forest conditions and, hence, appropriate for salvage on land allocations where ecological objectives are primary, such as LSRs. Retention of large snags and logs are specifically relevant to Northern Spotted Owl (NSO) since these structures provide the habitat that sustain most of the owl's forest-based prey species.
Large snags and logs are the most important surviving structural elements or biological legacies of a forest disturbance (Franklin et al. 2002), excepting only surviving large live trees. Importance, in this case, refers to the roles of these structures in: 1) Providing essential habitat for an immense array of species; 2) Maintaining important ecosystem functions; and 3) Structurally enriching the young forest stands, making it possible for mid- and late-successional species to re-colonize the stand much earlier in its chronological development than would otherwise be the case (Franklin et al. 1987).
(Large snags and down wood) ...structures provide habitat for early as well as late successional species and sustain many important ecosystem processes (e.g., Harmon et al. 1986). ... (L)arge Douglas-fir logs continue to fulfill important ecological functions, such as habitat for small mammals and salamanders, for 200 to 250 years after their death. Cedar snags can persist for at least as long as 1½ centuries and as logs for over twice that long.
The massive input of large dead wood is characteristic and critical to stand development processes and the ultimate provision of habitat for late-successional species following stand replacement fires (Maser et al., 1988; Franklin et al. 2002). As noted, these wood structures may persist and play functional roles for several centuries, particularly in the case of decay resistant species. Large pines may also persist as snags for several decades and additional periods as logs on the forest floor. In fact, the entire recovering forest ecosystem will depend upon this pulse of CWD until it reaches a point in its development where the new stand begins to generate snags and logs of comparable size and heartwood content— generally between 100 and 200 years (Maser et al., 1988; Franklin et al. 2002).
Consequently, basing snag and CWD retention following salvage on levels of these structures found in existing mature and old forests is not appropriate; all of this initial pulse of wood is needed to reach those levels one to two centuries from now! Indeed, the use of mature forests as a standard for CWD is particularly inappropriate since this is the period when CWD levels are at their lowest level during the entire natural developmental sequence from stand-replacement fire to old growth.
Forest Service Response: In the letter, Dr. Franklin states that his comments are focused primarily on activities proposed for Late Successional Reserves (LSRs), a land use allocation that he helped create. His primary concerns were that a large portion of the Westside Fire Recovery project on the Klamath National Forest was proposed within LSRs and that, in part, the logging was justified on the basis that it is needed to assist in rapid re-establishment of late-successional forest conditions and Northern Spotted Owl habitat. Dr. Franklin’s disagrees with the stated purpose and says, “salvage logging of large snags and down boles does not contribute to the recovery of late-successional forest habitat.”
The Copper King project is not located within designated Late Successional Reserves (LSRs), is not located within Northern Spotted Owl habitat, and is not proposed for the purpose of reestablishing late-successional forest conditions (see EA, Chapter 1). This reference is not relevant to the Copper King project. 12 Frissell, C.A. and D. Bayles, 1996. Ecosystem Management and the Conservation of Aquatic Biodiversity and Ecological Integrity. Water Resources Bulletin, Vol. 32, No. 2, pp. 229-240. April, 1996.
Comment Excerpt: . . . Post-fire activities such as (salvage logging) that increase the probability of chronic sediment inputs to aquatic systems pose far greater threats to both salmonid and amphibian populations and aquatic ecosystem integrity than do fires and other natural events that may be associated with undesired forest stand condition (Frissell and Bayles 1996).
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense
Forest Service Response: This reference is a philosophical article about what is ecologically effective ecosystem management, particularly with respect to aquatic systems. The authors recommend that managers and scientists “identify catchments and aquatic networks where ecological integrity has been least damaged by prior management and develop means to ensure their protection as reservoirs for natural biodiversity, keystones for regional restoration management models, monitoring benchmarks, and resource for ecological research”.
This article is not specific to wildfire or post-fire management and, in itself, is not relevant to the Copper King project. The reference to salvage logging in the article was in an example the authors used to show that disturbance events that shape terrestrial systems and management responses to them may be problematic to aquatic systems and vice versa. Specifically, the authors state, “Indeed, perceived management problems in terrestrial systems, such as the depletion of older, larger trees, and proliferation of dense younger stands in some western forests that has recently been labeled a ‘forest health crisis’, do not necessarily correspond to the major threats to aquatic systems. Indeed, in the forest health example, many of the proposed cures (e.g., salvage logging and massive thinning programs, continuing existing livestock grazing policies) pose far greater threats to fish populations and aquatic ecosystem integrity than do fires and other natural events that might (or might not) be associated with the ‘undesired’ changes in forest structure.”
For the Copper King project, carefully developed design criteria, best management, practices, and resource protection measures would be used to minimize effects to aquatic systems (see EA, Chapter 2). For example, standard riparian habitat conservation area (stream buffer) widths would be expanded to provide further protections to riparian areas and aquatic habitat. 13 Hitchcox, Susan M., 1996. Abundance and nesting success of cavity-nesting birds in unlogged and salvage-logged burned forest in northwestern Montana. Master’s thesis, Biological Sciences, University of Montana, Missoula, MT.
Comment Excerpt: In four recent independent studies conducted in the intermountain West, post-fire logging caused significant changes in abundance and nest density of cavity-nesting birds, although the effect differed somewhat by location (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998). Most cavity-nesters showed consistent patterns of decrease after logging, including the mountain bluebird and the black-backed, hairy, and three-toed woodpeckers; abundance of the Lewis’ wood-pecker increased after logging.
Several authors point out that on a landscape scale, wildfire creates patches of highly attractive habitat for a distinct array of species (Hutto 1995). To maintain healthy metapopulations of these species over the landscape, post-fire patches should be managed with great care (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998).
Forest Service Response: This reference is a graduate thesis, in which the author measured bird communities and nest site characteristics in salvaged stands and nearby unharvested stands. The study indicated that unharvested stands had generally higher values for bird use and more habitat available.
Although snag habitat would be reduced on the up to 2300 acres proposed for salvage, nearly 17,000 acres or about 88 percent of the National Forest System land affected by the Copper King fire would be left to natural processes and provide abundant habitat for cavity-nesting birds. 14 Hutto, R. L. 1995. Composition of bird communities following stand-replacement fires in the Northern Rocky Mountain (U.S.A.) conifer forests. Conservation Biology 9:1041-1058.
Comment Excerpt: Hutto (1995) states: “Fire (and its aftermath) should be seen for what it is: a natural process that creates and maintains much of the variety and biological diversity of the Northern Rockies.” Hutto further notes (1995):
Fire is such an important creator of the ecological variety in Rocky Mountain landscapes that the conservation of biological diversity [required by NFMA] is likely
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense to be accomplished only through the conservation of fire as a process…Efforts to meet legal mandates to maintain biodiversity should, therefore, be directed toward maintaining processes like fire, which create the variety of vegetative cover types upon which the great variety of wildlife species depend.
Unfortunately, we are not currently managing the land to maintain the kind of early successional seral stages that follow stand-replacement fires and, hence, many fire-dependent plant and animal species. . . . Most of the forested landscape in the northern Rockies evolved under a regime of high-intensity, large fires every 50-100 years, not under a regime of low-intensity, frequent understory burns.
Indeed, stand-replacing crown fires are part of the fire regime that creates the biodiversity which the agency is required by law to insure. Put bluntly, there is a kind of ignorance, bordering on mass hysteria, that needs to be addressed in today’s political climate, which sees all wildland fire as bad and all burned forests as wasted resources, a view which is every bit as dangerous (and actually quite consistent with) the now acknowledged agency ignorance that favored suppression of wildfires at all costs for many decades.”
Forest Service Response: This article is a detailed study of bird communities within burned forests. The author found that 15 bird species are generally more abundant in early post-fire communities than in any other major cover type occurring in the northern Rockies. The author provides several broad recommendations about fire policy, prescribed and wildfire, salvage harvest, and green harvest. It is important to note that this article is nearly 20 years old and was written when large-scale fires were far less common than they are today and the proportion of post-fire logging on National Forest System lands compared to acres burned was higher.
With regard to post-fire timber harvest, the author recommends that on public lands, managers should leave an adequate amount of standing dead trees after a fire. He further suggests that “it may be best to take trees from one part of the burn and leave another part of the burned untouched”.
This is precisely what is being proposed in the Copper King project. At most 2300 acres or about 12 percent of the National Forest System land affected by the fire is proposed for salvage. Nearly 17,000 acres or about 88 percent of the National Forest System land affected by the Copper King fire would be left to natural processes and provide abundant habitat for bird species that use with post-fire environments. 15 Jones, A.J., and Gordon E. Grant. 1996. Peak flow responses to clear-cutting and roads in small and large basins, western Cascades, Oregon. Water Resources Research, Vol. 32, No. 4, pages 95-974, April 1996.
Comment Excerpt: Jones and Grant (1996) describe the relationship of roads and clearcutting: The addition of roads to clear-cutting in small basins produced a quite different hydrologic response than clear-cutting alone, leading to significant increases in all sizes of peak discharges in all seasons, and especially prolonged increases in peak discharges of winter events. These results support the hypothesis that roads interact positively with clear-cutting to modify water flow paths and speed the delivery of water to channels during storm events, producing much greater changes in peak discharges than either clear cutting or roads alone. Roads alone appear to advance the time of peak discharges and increase them slightly. Road surfaces, cutbanks, and ditches, and culverts all can convert subsurface flow paths to surface flow paths (Harret al., 1975; King and Tennyson, 1984; Wemple, 1994; Wright et al., 1990). Reid (1991) and Reid and Dunne (1984) estimated discharges from culvert outfalls in western Washington and associated them with runoff from road surfaces.
Forest Service Response: This reference is a study of long-term changes in streamflows associated with clearcutting and road construction in Cascades Range of western Oregon. The study found that at a landscape scale, forest harvesting produced a detectable change in peak discharges in basins ranging up to 150,000 acres. The increases were attributable to changes in flow routing (due to roads) rather than mere changes in water storage due to vegetation removal. It is important to note that the annual precipitation in the study area is about 100 inches and falls mostly as rain. This is over twice the annual precipitation at the highest elevation within the Copper King project area, were it falls mostly as snow.
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense This reference does not include any discussion about fire or post-fire management. The commenter did not indicate how he perceives it is relevant to the Copper King project.
Within many portions of the Copper King fire area, tree mortality is high, which has affected peak flows in the area. The salvage of fire-killed trees on a relatively small portion of the fire area would not further affect peak flows because dead trees no longer take up and store water and the removal of dead trees would not further reduce the tree canopy. Following completion of the project, the temporary roads constructed to access some of the salvage units would be rehabilitated through recontouring the prism as much as possible back to the natural hillslope. 16 Karr, J.R., Rhodes, J.J., Minshall, G.W., Hauer, F.R., Beschta, R.L. Frissell, C.A. Perry, D.A., 2004. Postfire salvage logging's effects on aquatic ecosystems in the American West. BioScience, 54: 1029-1033.
Comment Excerpt: Karr et al. (2004) in an evaluation of the effects of post-fire salvage logging on aquatic ecosystems provides the following background: Throughout the American West, a century of road building, logging, grazing, and other human activities has degraded stream environments, causing significant losses of aquatic biodiversity and severe contractions in the range and abundance of sensitive aquatic species, including native salmonid fishes (Reiman et al. 2003). Compounding these problems, federal land management has worsened ecological degradation, rather than conserving or restoring forest ecosystems (Leopold 1937, Langston 1995, Hirt 1996). Land managers’ focus on commodity extraction sharpened by recent changes in forest policy, regulations, and laws that encourage salvage logging after fires- perpetuates this trend and its harmful impacts.
Karr et al. (2004) also state, “Although often done in the name of post-fire restoration, salvage logging typically delays or prevents natural recovery in several important ways (Beschta et al. 1995, 2004, Lindenmayer et al. 2004).”
Forest Service Response: This article is very similar to the Beschta et al. 2004 (cited reference #2 above), article published three months earlier in Conservation Biology. All the authors of this article are authors of Beschta et al. 2004. The recommendations in this article are very similar as well: allow natural recovery to occur on its own, or intervene only in ways that promote natural recovery; retain old and large trees; protect soils; protect ecologically sensitive areas (e.g. riparian and roadless areas, regions with steep slopes and watersheds with sensitive or imperiled aquatic species); avoid creating new roads and landings; limit reseeding and replanting; do not place structures in streams; protect and restore watersheds before fires occur; continue research, monitoring, and assessment; and educate the public. The authors note that the impacts of fire and of salvage logging vary in severity from site to site depending on a site’s natural conditions and on its history of human use.
The purpose of the salvage logging in the Copper King project is not for post-fire restoration (see EA, Chapter 1). Please see responses to cited references #1 and #2. This reference is further address in the EA (Chapter 2, section 2.4). 17 Lindenmayer, D.B., D. R. Foster, J. F. Franklin, M. L. Hunter, R. F. Noss, F. A. Schmiegelow, D. Perry. 2004. Salvage Harvesting Policies After Natural Disturbance. SCIENCE VOL 303 27 February 2004 www.sciencemag.org
Comment Excerpt: Considering that these forests have evolved with fire and thus regenerate successfully following fire, “salvage” logging can only disrupt the natural process of regeneration. The scientific understanding of post-fire forest regeneration and potential for major impacts of salvage actions on sensitive post- fire ecosystems suggests that a carefully contemplated rather than a hasty response is essential for seeing that the highest priority—restoration—will be accomplished. Lindenmayer, et al. (2004) note a whole host of ecosystem damaging aspects of post-fire logging:
Natural disturbances and the biological legacies produced by them are often poorly understood by policy-makers and natural-resource managers. …(N)atural disturbances are key ecosystem processes rather than ecological disasters that require human repair. …Major disturbances also can aid ecosystem restoration by recreating some of the structural complexity and landscape heterogeneity lost through previous intense management of natural resources. … Salvage
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense harvesting activities undermine many of the ecosystem benefits of major disturbances. …
(S)alvage harvesting removes critical habitat for species, such as cavity-nesting mammals, woodpeckers, invertebrates like highly specialized beetle taxa that depend on burned wood, and bryoflora closely associated with recently charred logs. …(S)alvage logging can impair ecosystem recovery. …(S)ome taxa may be maladapted to the interactive effects of two disturbance events in rapid succession.
Forest Service Response: This commentary article was published in the policy forum section of Science magazine in 2004. The authors reference “large-scale disturbances” (e.g. wildfires that burned from 990,000 to 25,000,000 acres in different parts of the world), “extensive salvage harvesting” (e.g. the largest timber salvage operation in U.S. history, salvaging more than 1.5 billion board feet of lumber salvage in New England after the 1938 hurricane), and “removal of large quantities of biological legacies” (emphasis added) as a need to formulate salvage harvesting policies before major disturbances occur.
The Copper King Fire and proposed salvage project is on a far lesser scale than the disturbance events and salvage harvest discussed in the article. At most, approximately 2300 acres (12 percent) of the National Forest System land affected by the Copper King Fire would be salvaged. Within those harvested areas, some dead trees would be retained to provide for wildlife habitat and soil productivity. Nearly 17,000 acres or 88 percent of the burned area would be left to natural processes. The project also incorporates carefully developed design criteria, best management practices, and resource protection measures to minimize undesirable ecological effects from salvage harvest (see EA Chapter 2). 18 Marañón-Jiménez, Sara; Jorge Castro, Emilia Fernández-Ondoño and Regino Zamora; 2013. Charred wood remaining after a wildfire as a reservoir of macro- and micronutrients in a Mediterranean pine forest. International Journal of Wildland Fire. http://dx.doi.org/10.1071/WF12030.
Comment Excerpt: Also, Marañón-Jiménez et al., 2013 state that “(p)ost-fire woody debris constitutes …a valuable natural element as a potential source of nutrients, which would be lost from ecosystems in cases where it is removed.”
Forest Service Response: This reference is a study conducted in Spain to measure the nutrients retained in coarse woody debris following wildfire. The results show that the remains of partially charred wood biomass act as an important nutrient reservoir, which provide a source of nutrients in the long term and help to mitigate the nutrient losses associated with wildfire and post-fire management. The authors suggest, “the suitability of the remaining woody debris after fires for the nutrient capital of the ecosystem should be considered for post-fire management of burnt areas”.
In the Copper King project, salvage would occur on at most 2300 acres or about 12 percent of the National Forest System lands affected by the fire. Within salvage units, coarse woody debris would be retained to meet Forest and Regional guidelines (see EA, Chapter 2). Nearly 17,000 acres or 88% of the National Forest System land affected by the fire would be left to natural processes. 19 Meigs, W., D. Donato, J. Campbell, J. Martin, and B. Law. 2009. Forest fire impacts on carbon uptake, storage, and emission: The role of burn severity in the Eastern Cascades, Oregon. Ecosystems. DOI 10.1007/s10021-009-9285-x. October 2009.
Comment Excerpt: Post-fire logging and pre-fire thinning reduce on-site carbon storage by removing tree boles from the forest as logs. Research finds that tree boles, even in severely burned forests, account for less than 5% of the carbon released during fire, which consumes primarily needles and surface fuels. Even in high severity fires, only about 25% of above-ground carbon stores are released. For these reasons, research finds that forest thinning in anticipation of fire releases more carbon to the atmosphere than would fire (Meigs et al 2009, and Campbell et al 2007).
Road construction and logging, even winter logging, would…reduce on-site carbon storage by removing tree boles from the forest as logs. Indeed, research finds that tree boles, even in severely burned forests, account for less than 5% of the carbon released during fire, which consumes primarily needles and surface fuels (Meigs et al 2009, and Campbell et al 2007).
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense
Forest Service Response: This article investigates and compares carbon (C) fluxes between ponderosa pine and mixed-conifer forests types within low, moderate, and high severity burns. In total, 64 plots were measured in the Metolius River watershed in Oregon between burned and unburned stands, stratified by forest type and burn severity. Both above and below ground C pools were quantified using a variety of measurements, transects, and regression models. Upon statistical analysis of measurements taken between forest types and burn severity the authors conclude that: 1) Stand-scale C combustion ranged from 13-35% and varied with burn severity, with the largest proportion of C being produced in the combustion of surface and ground fuels. The total landscape-scale C emissions were equivalent to 2.5% of anthropogenic CO2 emissions from fossil fuels during the course of the study; 2) Both live overstory tree mass and seedling density were found to decrease with increased burn severity. Live shrub and herbaceous mass was conversely found to increase with increased severity; and 3) Net Primary Productivity (NPP) was only 40% lower in high vs. low severity burns despite high declines in live aboveground C pools. The authors conclude that this indicates a rapid response of early successional vegetation offsets declines in NPP and Net Ecosystem Production (NEP), therefore buffering impacts fire would otherwise have on landscape-level C storage.
While the study notes that the combustion of tree boles account for a relatively small amount of the C released from fires, it makes no conclusions about the effects of post-fire logging or pre-fire thinning. The statement the commenter makes, “research finds that forest thinning in anticipation of fire releases more carbon to the atmosphere than would fire” is the claim of the commenter and is not supported by the research presented in this article.
The Copper King project would harvest fire-killed trees on up to approximately 2300 acres, which would, in the short term, remove and release some carbon currently stored within the dead trees. A portion of the carbon removed would remain stored for a period of time in wood products (US EPA 2013; Depro, et al. 2008). However, none of the alternatives would have a discernable impact on atmospheric concentrations of greenhouse gases or global warming, considering the limited changes in both rate and timing of carbon flux predicted within these relatively few affected forest acres and the global scale of the atmospheric greenhouse gas pool and the multitude of natural events and human activities globally contributing to that pool (see EA Chapter 3, Forest Carbon Storage and Climate Change section for more details). 20 Noss, R. F. and D. B. Lindenmayer (2006). "The ecological effects of salvage logging after natural disturbance - Introduction." Conservation Biology 20(4): 946-948.
Comment Excerpt: Noss and Lindenmayer (2006) state, . . . available evidence points to often severe and long-lasting negative effects of post-disturbance logging on a wide variety of ecosystems and their biota. To log what is often the most biologically diverse and threatened forest condition in the landscape is fundamentally irrational.
Forest Service Response: This citation is an introduction written for a special section in Conservation Biology on the effects of salvage logging in response to proposed Congressional legislation, which could have expanded salvage logging on public lands. It introduces 5 papers on the subject, which the authors say provide a strong argument for increased research and monitoring on the effects of natural disturbances and post disturbance logging in forests. They point to the following papers as evidence of severe and long-lasting negative effects of post-disturbance logging on a wide variety of ecosystems and their biota.
Foster and Orwig: their case study is the 1938 hurricane in the northeastern U.S. and the subsequent salvage logging operation, which was largest in U.S. history.
The scale of salvage proposed in Copper King is far less than that which occurred following the 1938 hurricane. At most, salvage would occur on 2300 acres or 12 percent of the National Forest System land affected by fire. Carefully developed design criteria, best management practices, and resource protection measures would be applied. This case study is not relevant to the project.
Schmiegelow et al.: The authors state that the boreal forest of Canada, the largest and most intact forest on Earth, is still shaped largely by natural disturbance. However, they indicate that these forests are at risk of vastly increased post-fire salvage logging. Although standards exist for structural
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense retention (i.e. leaving live and dead trees and other plant material on site) during timber harvesting, the conventional standards are limited to those implemented at the stand level and disregard the legitimate biological need to maintain post fire forests on a landscape.
As stated above for Foster and Orwig, the scale of the Copper King project is relatively small compared to the size of the area that burned. Nearly 17,000 acres or 88 percent of the National Forest System land affected by the fire would not be salvaged and would be left to natural processes.
Hutto: The author suggests that snag retention guidelines developed for green tree forests are not properly applied to burned forests because the birds and other species closely associated with severely burned forest require vastly higher densities of snags than do most species found in unburned forests.
In the Copper King project, all snags would be left on nearly 17,000 acres or 88 percent of the National Forest System land affected by the fire, which would provide abundant habitat for species closely associated with burned forests.
Reeves et al.: These authors focus on the effects of post-fire logging in riparian areas of the western U.S.
The Copper King Salvage project does not include salvage within riparian areas. In fact, standard riparian habitat conservation area (RHCA) (stream buffer) widths would be expanded to provide further protections to riparian areas and aquatic habitats. This study is not relevant to the project.
Lindenmayer and Ough: their case study is the montane eucalypt forests of southeastern Australia where intensive and extensive salvage logging after wildfire has been the normal course of action since the 1930s. They note the loss of large trees with hollows, which has significant implications for a variety of marsupials.
As stated above for Foster and Orwig, the scale of the Copper King project is relatively small compared to the size of the area that burned. Nearly 17,000 acres or 88 percent of the National Forest System land affected by the fire would not be salvaged and would be left to natural processes. This case study is not relevant to the project. 21 Noss, Reed F., Jerry F. Franklin, William L. Baker, Tania Schoennagel, and Peter B. Moyle. 2006. Managing fire-prone forests in the western United States. Front Ecol Environ 2006; 4(9): 481–487.
Comment Excerpt: Noss et al. (2006) also shows the problem with post-fire logging.
Forest Service Response: In this article, the authors review the ecological science to recommend fire and fuel management policies for forests before, during, and after wildfires. Noss and others summarize the historic fire regimes of western forests and the ecological effects that have occurred due to fire suppression. They also provide a decision making framework for when ecological restoration through human intervention may be warranted. Specifically with regard to post-fire logging, the authors state that this activity “does not contribute to ecological recovery; rather it negatively affects recovery processes with intensity of impacts depending upon the nature of the logging activity.” They also say, “post-fire logging in naturally disturbed forest landscapes generally has no direct ecological benefits and many potential negative impacts” citing to Beschta et al. 2004; Donato et al. 2006; and Lindenmayer and Noss 2006. The article identifies the following concerns: Trees that survive fire for even a short time are critical as seed sources and as habitat that sustains biodiversity both above and below ground.
Except in specific instances, the Copper King project would only remove dead trees. The Copper King fire resulted in high levels of tree mortality. In areas that burned at high severity, there is little to no seed source remaining for natural tree regeneration. The planting of native tree seedlings is proposed.
Dead wood, including large snags and logs, rivals live trees in ecological importance.
All snags would be left on nearly 17,000 acres (88 percent) of the National Forest System land affected by the Copper King fire. Within proposed salvage
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense units, some fire-killed trees would also be retained.
In forests subject to severe fire and post-fire logging, streams and other aquatic ecosystems will take longer to return to historical conditions.
In the Copper King project, no salvage harvest would take place within riparian habitat conservation areas (RHCAs). At most salvage would occur on 2300 acres or about 12 percent of the National Forest System land affected by the fire.
Following severe fire, the biggest impacts on aquatic ecosystems are often excessive sedimentation caused by runoff from roads.
Burned Area Emergency Response (BAER) work completed following the fire included storm-proofing of roads (ensuring proper drainage), culvert armoring, and culvert removals. Additional work will be completed in 2017, including upsizing numerous culverts. Prior to log haul for the Copper King project, erosion control measures, including slash filter windrows would be applied along roads in appropriate locations to minimize sediment transport.
Post-fire seeding with non-native plants is often ineffective at reducing soil erosion and generally damages ecological values.
No post-fire seeding with non-native plants is planned. The proposed tree planting within the burned area would only be with native species. 22 Reid, Leslie M. and Thomas Dunne 1984. Sediment Production from Forest Road Surfaces. Water Resource Research, Vol. 20, No. 11, Pp. 1753-1761, November 1984.
Comment Excerpt: Increased heavy-truck traffic related to log hauling can increase rutting and displacement of road-bed material, creating conditions conducive to higher sediment delivery rates (Reid and Dunne, 1984).
Forest Service Response: This reference is a study conducted in western Washington on the sediment delivery from roads. The authors found that the erosion rate from gravel roads increased with an increase in traffic intensity.
It is important to note that this study was conducted on the west slope of the Olympic Mountains in Washington, where the annual rainfall in the study area was about 154 inches. In contrast, the annual precipitation rates within the Copper King project area range from approximately 20 inches at lower elevations to over 50 inches at the highest elevations of which a large proportion falls as snow. Sediment delivery from roads is primarily dependent upon precipitation as a transport mechanism. In many years runoff could equate to very little sediment delivery, or the reverse could be true if an abnormally wet year is experienced. Although the magnitude of sediment delivery reported in the article may not apply to the Copper King project, the study’s finding that sediment delivery from roads increases with increased traffic generally does apply.
Therefore for the Copper King project, best management practices would be applied along haul routes to ensure proper road drainage and slash filter windrows and other sediment control devices would be used to minimize sediment movement off of the road prisms (see EA, Chapter 2). In addition, Burned Area Emergency Response (BAER) work completed following the fire included storm-proofing of roads (ensuring proper drainage), culvert armoring, and culvert removals. Additional work will be completed in 2017, including upsizing numerous culverts. 23 Riggers, Brian; Rob Brassfield; Jim Brammer; John Carlson; Jo Christensen; Steve Phillips; Len Walch; Kate Walker; 2001. Reducing Fire Risks to Save Fish – A Question of Identifying Risk. A Position Paper by the Western Montana Level I Bull Trout Team, 2001.
Comment Excerpt: Riggers, et al. (200l): . . . emphasize the importance of wildfire, including large-scale, intense wildfire, in creating and maintaining stream systems and stream habitat. In western Montana, the two primary natural disturbance mechanisms responsible for initiating stream dynamics that ultimately increase habitat complexity and diversity are fires and floods. In the short-term, fires trigger other processes, such as erosion and woody debris recruitment, which are critical in the formation of young, biologically rich stream systems. Over longer time periods, fires recycle nutrients, regulate forest development and
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense biomass, and maintain biological pathways (Keane, et al. 1999). The effect of fire on these processes is ultimately transferred to stream channels. Fires, and the ecological processes associated with them, are thus an integral part of maintaining our native fish populations.
. . . Post-fire activities such as (salvage logging) that increase the probability of chronic sediment inputs to aquatic systems pose far greater threats to both salmonid and amphibian populations and aquatic ecosystem integrity than do fires and other natural events that may be associated with undesired forest stand condition (Frissell and Bayles 1996).
Forest Service Response: This reference is an unsanctioned position paper written by a group of federal biologists who were then members of the Western Montana Level 1 Bull Trout Team. This paper was written in response to the development of the regional Cohesive Strategy to implement the National Fire Plan. The paper briefly identifies the aquatic benefits of wildfire, the potential negative effects of fire suppression actions on aquatic systems, and the existing reduced quality of aquatic habitat conditions that have resulted in native fish populations being less fit and less resilient to watershed disturbances. In terms of wildfire, the authors say that the real risk to fisheries is not the fire itself, but the existing condition of the watersheds, fish communities, and stream networks. Therefore, they believe that protection of aquatic systems is not a justification for fuels reduction treatments. Instead, they say that fish populations will respond better to projects directed at reducing the immediate risks (barriers, roads, exotic species, and suppression) than to projects aimed at reducing fire intensity or scale.
The authors state, “We believe, in most cases, proposed projects that involve large-scale thinning, construction of large fuel breaks, or salvage logging as tools to reduce fuel loadings with the intent of reducing negative effects to watersheds and the aquatic ecosystem are largely unsubstantiated.” However, they do acknowledge that there are undoubtedly exceptions to their position.
This article is not relevant to the Copper King project because the project’s purpose is not to reduce fuels (see EA, Chapter 1). 24 Saab, Victoria A. and Jonathan G. Dudley, 1998. Responses of Cavity-Nesting Birds to Stand-Replacement Fire and Salvage Logging in Pine/Douglas-Fir Forests of Southwestern Idaho. United States Department of Agriculture Forest Service Rocky Mountain Research Station Research Paper RMRS-Rp-11, September, 1998.
Comment Excerpt: In four recent independent studies conducted in the intermountain West, post-fire logging caused significant changes in abundance and nest density of cavity-nesting birds, although the effect differed somewhat by location (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998). Most cavity-nesters showed consistent patterns of decrease after logging, including the mountain bluebird and the black-backed, hairy, and three-toed woodpeckers; abundance of the Lewis’ wood-pecker increased after logging.
Several authors point out that on a landscape scale, wildfire creates patches of highly attractive habitat for a distinct array of species (Hutto 1995). To maintain healthy metapopulations of these species over the landscape, post-fire patches should be managed with great care (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998).
Forest Service Response: The article studies the responses of cavity-nesting birds to stand-replacement fire and salvage logging. The authors’ preliminary findings suggest that nesting densities continued to increase up to four years after fire. Among treatments (salvage and unlogged), overall densities were similar although species composition differed. For example Lewis’ woodpecker was the most abundant and successful species in the salvaged units, whereas black- backed woodpeckers favored unlogged stands. The authors suggest that retaining clumps of trees rather than uniformly distributed trees would benefit the entire cavity-nesting community.
At most 2300 acres or about 12 percent of the National Forest System land affected by the Copper King fire is proposed for salvage. Nearly 17,000 acres or about 88 percent of the National Forest System land affected by the fire would be left to natural processes and would provide abundant habitat for cavity-nesting bird
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense species that use with post-fire environments. 25 Thompson, I., Mackey, B., McNulty, S., Mosseler, A. (2009). Forest Resilience, Biodiversity, and Climate Change. A Synthesis of the Biodiversity/Resilience/Stability Relationship in Forest Ecosystems. Secretariat of the Convention on Biological Diversity, Montreal. Technical Series no. 43, 67 pages.
Comment Excerpt: DellaSalla and Hanson (2015) state: Along with the surge in scientific investigation into historical fire regimes over the past 10-15 years has come enhanced understanding of the naturalness and ecological importance of mixed- and high-severity fire in many forest and shrub ecosystems. Contrary to the historical assumption that higher-severity fire is inherently unnatural and ecologically damaging, mounting evidence suggests otherwise. Ecologists now conclude that in vegetation types with mixed- and high severity fire regimes, fire-mediated age class diversity is essential to the full complement of native biodiversity and fosters ecological resilience and integrity in montane forests of North America (Hutto, 1995, 2008; Swanson et al., 2011; Bond et al., 2012; Williams and Baker, 2012a; DellaSala et al., 2014). Ecological resilience is essentially the opposite of “engineering resilience,” which pertains to the suppression of natural disturbance to achieve stasis and control of resources (Thompson et al., 2009). Ecological resilience is the ability to ultimately return to predisturbance vegetation types after a natural disturbance, including higher- severity fire. This sort of dynamic equilibrium, where a varied spectrum of succession stages is present across the larger landscape, tends to maintain the full complement of native biodiversity on the landscape (Thompson et al., 2009).
…As discussed above, in mixed-severity fire regimes, higher-severity fire occurs as patches in a mosaic of fire effects (Williams and Baker, 2012a; Baker, 2014). In conifer forests of North America, higher-severity fire patches create a habitat type, known as complex early seral forest (DellaSala et al., 2014), that supports levels of native biodiversity, species richness, and wildlife abundance that are generally comparable to, or even higher than, those in unburned old forest (Raphael et al., 1987; Hutto, 1995; Schieck and Song, 2006; Haney et al., 2008; Donato et al., 2009; Burnett et al., 2010; Malison and Baxter, 2010; Sestrich et al., 2011; Swanson et al., 2011; DellaSala et al., 2014). Many rare, imperiled, and declining wildlife species depend on this habitat (Hutto, 1995, 2008; Kotliar et al., 2002; Conway and Kirkpatrick, 2007; Hanson and North, 2008; Bond et al., 2009; Buchalski et al., 2013; Hanson, 2013, 2014; Rota, 2013; Siegel et al., 2013; DellaSala et al., 2014; Baker, 2015; see also Chapters 2–6). The scientific literature reveals the naturalness and ecological importance of multiple age classes and successional stages following higher-severity fire, as well as the common and typical occurrence of natural forest regeneration after such fire (Shatford et al., 2007; Donato et al., 2009; Crotteau et al., 2013; Cocking et al., 2014; Odion et al., 2014). These and other studies suggest that mixed- severity fire, including higher-severity fire patches, is part of the intrinsic ecology of these forests and has been shaping fire- dependent biodiversity and diverse landscapes for millennia.
Forest Service Response: This paper reviews the concepts of ecosystem resilience, resistance, and stability in forests and their relationship to biodiversity, with particular reference to climate change. It was written in direct response to a request by the ninth meeting of the Conference of the Parties to the Convention on Biological Diversity to explore the links between biodiversity, forest ecosystem resilience, and climate change. There is nothing specific in this publication to fire salvage and the commenter did not indicate how he perceives it is relevant to the Copper King project. 26 Trombulak SC and Frissell CA., 2000. Review of Ecological Effects of Roads on Terrestrial and Aquatic Communities. Conservation Biology 14: 18-30.
Comment Excerpt: Roads often have devastating impacts on water quality and fish habitat by increasing landslides, erosion, and siltation of streams. Roads also fragment forests and degrade or eliminate habitat for species that depend on remote landscapes, such as bears, wolves, and other large, wide-ranging predators (Trombulak and Frissell 2000).
Forest Service Response: This commentary article reviews the ecological effects of roads. The authors say that roads of all kinds affect terrestrial and aquatic ecosystems in seven general ways: (1) increased mortality from road construction, (2) increased mortality from collision with vehicles, (3) modification of animal behavior, (4) alteration of the physical environment, (5) alteration of the chemical environment, (6) spread of exotic species, and (7) increased alteration and use of habitats by humans. They state that their review demonstrates the importance to conservation of avoiding construction of new roads in roadless or sparsely roaded
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense areas and of removal or restoration of existing roads to benefit both terrestrial and aquatic animals and plants.
In the Copper King project, no permanent roads would be constructed. However, Alternatives 2 and 3 would include construction of 3 and 7.3 miles, respectively, of temporary road, which would be decommissioned following use for the project. Decommissioning treatments would include recontouring the road prism as much as possible to the natural hillslope and seeding and applying slash to the disturbed area. During their “life”, temporary roads would be closed to public motorized use. Due to their temporary nature and closure to public use, potential disturbance effects to wide-ranging predators (as described in the comment excerpt above) would be short-term – limited to the length of the project (approximately 2 years). In addition, temporary roads would be generally located in mid to upper slope locations with few stream crossings to reduce the potential for sediment delivery. 27 USDA Forest Service, 2000a. Environmental Effects of Postfire Logging: Literature Review and Annotated Bibliography. Gen. Tech. Rep. PNW-GTR-486. Wenatchee, WA: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station.
Comment Excerpt: USDA Forest Service (2000a) also finds that the removal of dead trees associated with post-fire logging has the potential for significantly changing wildlife habitat both structurally, through removing existing and future snags and large woody material, and functionally, by means such as reducing populations of insect prey. The majority of studies reviewed by USDA Forest Service (2000a) observed substantial adverse habitat impacts associated with post-fire logging. They note that habitat modification associated with salvage logging may particularly impact cavity nesting birds, and that aspects of a post-fire forest provide desirable habitat resources:
In four recent independent studies conducted in the intermountain West, post-fire logging caused significant changes in abundance and nest density of cavity- nesting birds, although the effect differed somewhat by location (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998). Most cavity- nesters showed consistent patterns of decrease after logging, including the mountain bluebird and the black-backed, hairy, and three-toed woodpeckers; abundance of the Lewis’ wood-pecker increased after logging.
Several authors point out that on a landscape scale, wildfire creates patches of highly attractive habitat for a distinct array of species (Hutto 1995). To maintain healthy metapopulations of these species over the landscape, post-fire patches should be managed with great care (Caton 1996, Hejl and McFadzen 1998, Hitchcox 1996, Saab and Dudley 1998).
Additionally USDA Forest Service (2000a) states, “no studies have specifically looked at how post-fire logging alters the size distribution of fuel and the concomitant changes in future fire risk.”
Ground based winter logging may not be effective mitigation for soil impacts and may impede recovery of the burned area. (USDA Forest Service, 2000a.)
USDA Forest Service (2000a) cite several studies that find that “post-fire logging associated with road building, conducted with ground-based log retrieval systems, or undertaken in stands having steep slopes and sensitive soils likely will have the greatest potential for exacerbating the erosion problems typically observed in burned watersheds.”
Forest Service Response: This publication is a review of the scientific literature on post-fire logging published prior to 2000, with a focus on environmental effects of logging and removal of large woody structure. The authors found that information on the environmental effects of post-fire logging was “scanty at best” - they found only 14 studies that isolated the actual effect of post-fire logging compared to unlogged controls. Results of this review are summarized in 16 major conclusions. The authors acknowledge that harvest practices and prescriptions have changed substantially over time and therefore they show the dates of actual the logging activity. They also note that the effects of post-fire logging is dependent on site characteristics, logging methods, and intensity of the fire.
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense Specific to the comment excerpts provided: The Copper King project proposes to remove fire-killed trees from at most 2300 acres or 12 percent of the National Forest System land affected by the fire. Nearly 17,000 acres or 88 percent would be left to natural processes and would provide ample habitat for species associated with post-fire environments.
Fuels reduction is not the purpose of the Copper King project (see EA, Chapter 1).
Klock et al. (1975) summarized in the cited reference found that winter logging substantially reduced soil disturbance from ground-based. They also found that tractor-on-snow and helicopter logging preserved the most vegetation cover. Sexton (1994) summarized in the cited reference found that salvage lowered forb & shrub biomass and species richness in the first 2 years. However, recent research (e.g. Peterson and Dodson 2016; Knapp and Ritchie 2016) indicates that understory vegetation increases in richness and cover over time regardless of salvage treatments. The authors suggest that disturbance associated with high- severity wildfire may present a bigger threat to vegetative recovery than the disturbance associated with salvage logging.
Carefully developed design criteria, best management practices, and resource protection measures would be applied to the Copper King project to minimize the potential for soil erosion (see EA, Chapter 2). 28 Wisdom, Michael J.; Richard S. Holthausen; Barbara C. Wales; Christina D. Hargis; Victoria A. Saab; Danny C. Lee; Wendel J. Hann; Terrell D. Rich; Mary M. Rowland; Wally J. Murphy; and Michelle R. Eames. Source Habitats for Terrestrial Vertebrates of Focus in the Interior Columbia Basin: Broad-Scale Trends and Management Implications. http://www.fs.fed.us/pnw/pubs/gtr485.
Comment Excerpt: Please include an alternative that reduces road densities to the maximum extent possible. Wisdom et al. (2000) state: Efforts to restore habitats without simultaneous efforts to reduce road density and control human disturbances will curtail the effectiveness of habitat restoration, or even contribute to its failure; this is because of the large number of species that are simultaneously affected by decline in habitat as well as by road- associated factors.
Forest Service Response: This is a broad-scale (100 million acres) assessment of habitat change for terrestrial species since pre-settlement times, including an assessment of road-effects on a variety of species. The authors indicate that old forests, native grass and shrub lands have declined over time. They also say that many of the species assessed (especially terrestrial carnivores) were negatively affected by some aspect of roads on the landscape. The authors suggest that a reduction in road densities would benefit several carnivore species. The authors also state that their conclusions need to be validated by agency and other scientists also examining their results on a finer scale.
The Copper King project is not a restoration project and is focused on the purpose and need described in the EA in Chapter 1. The Copper King project would not affect road densities. Following completion of the project, temporary roads constructed to access salvage units would be rehabilitated through recontouring the prism as much as possible to the natural hillslope. This reference has little, if any, relevance to the Copper King project. 29 Scientists Post-fire Letter, 2013. Open Letter to Members of Congress from 250 Scientists Concerned about Post-fire Logging. October 30, 2013.
Comment Excerpt: Numerous studies document the cumulative impacts of post-fire logging on natural ecosystems, which led numerous scientists concerned about post-fire logging to transcript their concerns to Congress. In their open letter to members of Congress (Scientists Post-fire latter , 2013), the scientists state: (N)umerous scientific studies tell us that even in patches where forest fires burned most intensely the resulting post-fire community is one of the most ecologically important and biodiverse habitat types in western conifer forests. …Post-fire conditions serve as a refuge for rare and imperiled wildlife that depend upon the unique habitat features created by intense fire. … Moreover, it is the least protected of all forest habitat types and is often as rare, or rarer, than old- growth forest, due to damaging forest practices encouraged by post-fire logging practices.
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense Numerous studies document the cumulative impacts of post-fire logging on natural ecosystems, including the elimination of bird species that are most dependent on such conditions, compaction of soils, elimination of biological legacies (snags and down logs) that are essential in supporting new forest growth, spread of invasive species, accumulation of logging slash that can add to future fire risks, increased mortality of conifer seedlings and other important re- establishing vegetation (from logs dragged uphill in logging operations), and increased chronic sedimentation in streams due to the extensive road network and runoff from logging operations. We urge you to consider what the science is telling us: that post-fire habitats created by fire, including patches of severe fire, are ecological treasures rather than ecological catastrophes, and that post-fire logging does far more harm than good to the nation’s public lands.
Moreover, it is the least protected of all forest habitat types and is often as rare, or rarer, than old-growth forest, due to damaging forest practices encouraged by post-fire logging practices.
Forest Service Response: This reference is a 1½ page petition letter to Congress in opposition to H.R. 1526 (Healthy Forests for Healthy Communities Act) and HR 3188 (Rim Fire Emergency Salvage Act). H.R. 1526, among other things, would have made salvage of dead, damaged, or down timber resulting from wildfire occurring in 2013 not subject to judicial review or to any restraining order or injunction issued by a U.S. court. HR 3188 would have required the Rim Fire salvage timber sales to proceed to completion and would have made such sales not subject to administrative or judicial review in any U.S. court. Both bills were proposed in Congress, but neither was signed into law. Contrary to the authors’ claims, the proposed legislation would not have “suspended federal environmental protections”. Projects would still have been subject to public involvement, NEPA review, and all other legal requirements. The proposed legislation would only have exempted qualified salvage projects from administrative review and litigation.
In support of their concerns about these two pieces of proposed legislation, the authors highlight the ecological importance of post-fire habitat and describe a worst- case scenario of the effects of salvage harvest as cited above in the comment excerpt.
The Copper King Fire Salvage project would conduct salvage harvest on at most 2300 acres or 12 percent of the National Forest System land affected by the fire. Nearly 17,000 acres or 88 percent of the burned area would be left to natural processes. The project also incorporates carefully developed design criteria, best management practices, and resource protection measures to minimize undesirable ecological effects of salvage harvest (see EA, Chapter 2). For example, winter logging would be required for specific tractor units to protect soils; and standard riparian habitat conservation area widths (i.e. stream buffers) would be expanded by an additional 50 feet to reduce the potential for sediment to reach streams from salvage units; and roads used for log haul would be maintained to provide for proper drainage to minimize erosion and sediment delivery potential. No new permanent road would be constructed. Temporary roads used to access salvage units would be rehabilitated following use for the project.
Over the last decade, only about one percent of the over 2 million acres affected by wildfire across the Forest Service, Northern Region was salvaged. In that same time period, only about 1.4 percent of the nearly 200,000 acres affected by wildfire across the Lolo National Forest were salvaged. Therefore, post-fire habitat is likely not as “rare” as the authors suggest. 30 Scientists Post-fire Letter, 2015. Open Letter to U.S. Senators and President Obama from 264 Scientists Concerned about Post-fire Logging and Clearcutting on National Forests. September 2015.
Comment Excerpt: A similar letter [see 2015 letter above] was sent to U.S. Senators and President Obama by 264 scientists in September 2015 (Scientists Post-fire Letter, 2013).
Forest Service Response: This reference is a 2-page petition letter to Congress in opposition to H.R. 2647 (Emergency Wildfire and Forest Management Act of 2016) and S. 1691 (National Forest Ecosystem Improvement Act). H.R. 2647 and S. 1691, among other things, would have established a categorical exclusion to allow up to 3000 acres of salvage as part of the restoration of National Forest System lands following a catastrophic event. Projects would be required to be
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Literature Cited by Jeff Juel, Alliance for the Wild Rockies & WildLands Defense collaboratively developed. Both bills were proposed in Congress, but neither was signed into law. Contrary to the authors’ claims, the proposed legislation would not have “suspended federal environmental protections”. Although a categorical exclusion would have reduced the amount of NEPA documentation, all qualified projects would still have been subject to public involvement, NEPA review, and all other legal requirements.
This 2015 petition letter is very similar to the 2013 letter described above. See Forest Service response to “Scientists Post-fire Letter, 2013”, cited reference #29. 31 Nez Perce/Clearwater National Forests. January 2016. Johnson Bar Fire Salvage Final EIS.
Comment Excerpt: The Johnson Bar Fire Salvage Final EIS (Nez Perce/Clearwater National Forests, 2016) states: Haul roads can be a source of sediment to project area streams, particularly where there are existing sediment delivery points (roadside ditches leading to stream channels). Increased heavy-truck traffic related to log hauling can increase rutting and displacement of road-bed material, creating conditions conducive to higher sediment delivery rates (Reid and Dunne, 1984).
Forest Service Response: Response is specific to the comment excerpt. For the Copper King project, best management practices would be applied along haul routes to ensure proper road drainage and slash filter windrows and other sediment control devices would be used to minimize sediment movement off of the road prisms (see EA, Chapter 2). In addition, Burned Area Emergency Response (BAER) work completed following the fire included storm-proofing of roads (ensuring proper drainage), culvert armoring, and culvert removals. Additional BAER work will be completed in 2017, including upsizing numerous culverts.
Literature Provided by Dick Artley The commenter cites the following in support of his statement “Dead and dying trees are important to the survival of many natural resources in the forest and should not be removed to provide opportunities for corporate profit or to produce private industrial tree-farm conditions”.
Forest Service Response: The Forest Service understands the importance of dead trees, for example to provide habitat for some wildlife species and recycle nutrients to the soil. The Lolo Forest Plan requires that in the portion of the Forest more than 200 feet from all system roads, sufficient snags and dead material will be provided to maintain 80 percent of the population of snag-using species normally found in unmanaged Forest (II-14). Forest Plan Appendix N identifies procedures to implement the forest snag standard across the landscape.
The Copper King Fire proposes salvage of fire-killed trees on at most about 2300 acres or 12 percent of the National Forest System land within the fire perimeter. This means that all the snags would be retained on nearly 17,000 acres or 88 percent of the area burned on National Forest System land. Within salvage units, smaller dead trees (less than 8 inches in diameter) and existing coarse woody debris would be retained. Where existing coarse woody debris is lacking, the tops of cut trees would be retained on site. 1 Bartels, Ronald, John D. Dell, Richard L. Knight Ph.D. and Gail Schaefer “Dead and Down Woody Material” Animal Inn
“Intensified forest management, responding to the ever-increasing demand for forest products, will have a strong influence on the amount and distribution of woody material that remains as wildlife habitat through present and future stand rotations. Leaving the perpetuation of large down material to chance will
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probably result in its disappearance from the managed forests of the future, along with the loss of dependent plant and wildlife species.”
Forest Service Response: This article is taken from the Forest Service Region 6 website and is part of the Animal Inn program that focuses on the value of dead, dying, and hollow trees for wildlife. Although this article specifically talks to forest conditions on the west side of the Cascade Mountains in Washington, the concepts presented are relevant to forests elsewhere. See above response. 2 Byron, Eve “Wuerthner to speak on forest ecology and value of dead trees” Published in the Helena Independent Record, November 17, 2009
“Wuerthner has long argued that dead trees are critical to a healthy forest ecosystem and don’t necessarily need to be removed from a forest to lessen the danger of catastrophic wildfires.”
“Wuerthner said logging as a preventive measure might slow down the infestation, but research shows that anywhere from 50 to 80 percent of the trees need to be removed if conditions are ripe for a major attack.
“ “So you have to ask yourself, what’s the point? That is the Vietnam approach to forestry — kill all the trees so you can ‘save’ them,” Wuerthner wrote, adding that logging isn’t benign and is expensive. “So you further have to ask whether the costs in terms of ecosystem impacts (the spread of weeds on logging roads for instance) are worth the presumed benefits.”
Forest Service Response: This article (commentary) discusses that all dead trees do not need to be cut to keep a forest healthy or increase the chance of wildfire. A key aspect of this article is dealing with beetle infestations and reducing the risk to beetles. The Copper King Fire Salvage project would remove fire-killed trees on at most about 2300 acres or 12 percent of the area burned on National Forest System lands within the fire perimeter. The objectives of the tree removal are to recover economic value of forest products and provide a safe transportation system free of hazards associated with fire-affected trees; not to promote forest health or lessen wildfire risks. This article is not relevant to the Copper King Fire Salvage project. 3 “Dead Trees are Good Homes” Parks Canada, 2009
“When many of us think of a healthy forest, we think of tall, green trees. It’s hard to imagine how a tree killed by mountain pine beetle could be good for a forest. However, to be truly healthy and support all the wildlife that depends on it, there must be a variety of young, old and dead trees in a forest ecosystem. At “endemic” or normal levels, mountain pine beetles help maintain this diversity by colonizing and killing old or damaged trees, therefore kick-starting the invaluable process of decomposition. Decomposing wood returns nutrients to the system while providing shelter and food for many plants and animals. Standing dead trees host a diversity of organisms that would not be present without them.”
Forest Service Response: This is an article on the Parks Canada website on mountain pine beetle and the role it plays in forest diversity. This article is not relevant to the Copper King Fire Salvage project other than the general statements about the benefits of dead trees and decomposing wood. See above response to commenter’s statement, “Dead and dying trees are important…” 4 Kreil, Randy “Bare Trees” North Dakota Outdoors, March 1994
“Things are not always what they seem. At first glance a dead or dying tree seems like a tragic loss of a valuable resource. But on further inspection it becomes clear that a dead tree is simply a part of nature. And as a part of nature it serves an important purpose that isn't always obvious to us.
Dead trees and dead parts of trees are critically important to birds and mammals for nesting, rearing of young, feeding and as shelter. With a little forethought and tolerance we can maintain our organized, structured lifestyle and at the same time provide wildlife the habitat it needs to survive. In the long run, we'll be the better for it.”
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Forest Service Response: This educational article from North Dakota’s nongame program discusses the benefits of dead trees in the landscape – both urban and rural. See above response to commenter’s statement, “Dead and dying trees are important…” 5 Miller, Edward W. “Savage or Salvage Logging?” The Coastal Post - September, 1998
“The forest floor is a living, breathing factory of life and death. The out-reaching roots of a great tree search out from that chemical stew we call soil not only moisture but those elements it needs while its solar panels, or leaves, exchange carbon dioxide and oxygen.
Years later, when this aged giant completes its cycle and falls, crashing to earth, those very organisms and creatures which sustained it in life will gradually disassemble its biomass, returning to the soil those molecules which the next generation of seedlings, already sprouting, require for sustenance.”
“Forest biologists such as Herbert Kronzucker, Ph.D., point out that dead and dying trees sustain the coming generations, are not a hazard, and are essential to the health of the forest.” Alaskan fire management official John LeClair has noted that dead trees left standing, rather than increasing the hazard of fires, burned more slowly, retarding the conflagration in contrast to the "explosive inferno" when a live tree full of inflammable resins caught fire.”
Forest Service Response: This is opinion commentary in opposition to salvage logging of non-native species in Marin County CA, which is irrelevant to the Copper King Fire Salvage project in Montana. The commentary then goes to the quotes shown – dead trees provide many things to continue life. See above response to commenter’s statement, “Dead and dying trees are important…” 6 Maser, Chris Ralph G. Anderson, Kermit Cromack, Jr. Ph.D. Jerry T. Williams and Robert E. Martin, Ph.D. “Dead and Down Woody Material” From Wildlife Habitats in Managed Forests the Blue Mountains of Oregon and Washington
“Dead and down woody materials have long been viewed by foresters as unsalvaged mortality, the utilization of which is an important objective of good timber management. This material is also viewed as a fire hazard, and steps are frequently taken to reduce the amount of flashy fuels from timber harvest areas. Woody materials are also recognized as home for small vertebrate animals that are considered "pests" which impede reforestation.
These are all valid considerations, but dead and down woody material in various stages of decay serves many important functions, one of which is habitat for wildlife. Instead of viewing logs left in a forest as unsalvaged mortality or a fire hazard, this chapter examines their role as wildlife habitat. Elton (1966, p. 279) put it this way:
When one walks through the rather dull and tidy woodlands--say in the managed portions of the New Forest in Hampshire [England]-that result from modern forestry practices, it is difficult to believe that dying and dead wood provides one of the two or three greatest resources for animal species in a natural forest, and that if fallen timber and slightly decayed trees are removed the whole system is gravely impoverished of perhaps more than a fifth of its fauna.”
Forest Service Response: See above response to commenter’s statement, “Dead and dying trees are important…” 7 Naylor, Brian, Ph.D. “Cavity Trees – Nature’s Refuge” The Ontario Woodlot Association Newsletter, Winter / Spring 2006, Vol. 42
“Cavity trees are dead or dying trees that contain one or more holes or cavities that could be used by wildlife for a variety of purposes — nesting and raising young, denning, roosting, resting, feeding, caching food, escaping predators and hibernating.”
“The majority of wildlife species that use cavities cannot excavate their own holes and rely on those created by primary cavity users or on holes that form naturally. This group is called secondary cavity users. The kestrel, some owls such as the saw-whet and barred owls, ducks such as the common goldeneye and wood duck, and songbirds like the eastern bluebird, great-crested flycatcher and white-breasted nuthatch are all secondary cavity users. Many mammals are in this category too. These include deer mice, red squirrels, grey squirrels, flying squirrels, weasels, martens, fishers, raccoons, porcupines and black
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bears.”
Forest Service Response: See above response to commenter’s statement, “Dead and dying trees are important…” 8 “Removal of dead wood and dead trees was listed as a key threatening process” Schedule 3 of the Threatened Species Conservation Act 1995 [12 December 2003].
“Dead wood and dead trees provide essential habitat for a wide variety of native animals and are important to the functioning of many ecosystems. The removal of dead wood can have a range of environmental consequences, including the loss of habitat (as they often contain hollows used for shelter by animals), disruption of ecosystem process and soil erosion.”
“Removal of dead old trees (either standing or on the ground) results in the loss of important habitat such as hollows and decaying wood (Gibbons & Lindenmayer 2002) for a wide variety of vertebrates, invertebrates and microbial species and may adversely affect the following threatened species: Broad- headed Snake, Orange-bellied Parrot, Regent Parrot (eastern subspecies), Five-clawed Worm-skink, Nurus atlas, Nurus brevis, Meridolum corneovirens, Pale- headed Snake, Stephens' Banded Snake, Rosenberg's Goanna, Pink Cockatoo, Red-tailed Black-cockatoo, Glossy Black-cockatoo, Turquoise Parrot, Scarlet- chested Parrot, Barking Owl, Superb Parrot, Masked Owl, Hoary Wattled Bat, Spotted-tailed Quoll, Eastern False Pipistrelle, Eastern Freetail-bat, Squirrel Glider, Brush-tailed Phascogale, Glandular Frog, Red-crowned Toadlet, Brown Treecreeper (eastern subspecies).”
Forest Service Response: See above response to commenter’s statement, “Dead and dying trees are important…” 9 Santiago, Melissa J. and Amanda D. Rodewald, Ph.D. “Dead Trees as Resources for Forest Wildlife” Ohio State University Extension Fact Sheet
“Birds are the most obvious benefactors of dead trees. They use snags, limbs, and logs for perching, foraging, and nesting. In some forests, 30 to 45 percent of the bird species are cavity nesters. In North America alone, 55 avian species nest in cavities. Cavity-nesting birds are classified as primary excavators (who can excavate hard wood), weak excavators (who can excavate soft, dead wood), or secondary cavity-users (who can utilize existing cavities). In Ohio, eastern bluebirds, American kestrels, and wood ducks are examples of species that rely on cavities in dead wood for successful reproduction. Other birds, such as ruffed grouse, will use logs for drumming and courtship displays.
However, birds are not the only creatures that benefit from dead wood. Mammals, amphibians, reptiles, and invertebrates seek refuge in natural cavities and dens. For example, salamanders rely on the security and dampness of soil found beneath a rotting log. Small mammals find cover and relief from the hot midday sun in dead limbs and downed wood, while spiders, beetles, worms, and microbes move and feed within the decaying matter. Additionally, fungi and mushrooms flourish on and around logs, breaking down the organic matter to release important nutrients back into the forest ecosystem.
Logs provide other important ecological functions as well. Decaying logs retain moisture and nutrients that aid in new plant growth. Young trees may sprout from a single downed limb known as a nurse log. The soft wood tissue of a nurse log offers an ideal substrate for many young trees during their initial growth and development. Logs also store energy and fix nitrogen. Furthermore, dead wood serves as a ground cover, lessening soil erosion and preventing animals such as deer from over-browsing plant seedlings.”
Forest Service Response: This paper focuses on the benefits of snags and down woody material. See above response to commenter’s statement, “Dead and dying trees are important…” 10 Schneider, Gary, “Dead Trees (they’re still full of life)” The Macphail Woods Ecological Forestry Project, December 2008
“Wildlife trees (dead or dying trees used for nesting, feeding, denning and roosting) go through several stages that can start with ants tunneling into the rotting centre to flycatchers perching on the bare branches. For cavity-nesting birds they are critical habitat. Some species excavate cavities for their nests, while
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others take over and enlarge existing holes. Many of these birds in turn help the forest, eating insects which can damage trees.”
Forest Service Response: This paper focuses on the benefits of snags and down woody debris. See above response to commenter’s statement, “Dead and dying trees are important…” 11 Science Findings, issue twenty, November 1999 Pacific Northwest Research Station USDA Forest Service
“Twenty years after publication of a report on wildlife habitat in managed east-side forests, Pacific Northwest Research Station scientists Evelyn Bull, Catherine Parks, and Torolf Torgersen, are updating that report and discovering that the current direction for providing wildlife habitat on public forest lands does not reflect findings from research since 1979. More snags and dead wood structures are required for foraging, denning, nesting, and roosting than previously thought. In this issue of Science Findings, Bull, Parks, and Torgersen, share their latest findings, which include the fact that snags and logs are colonized by organisms representing a broader array of plants, invertebrates, and vertebrates than was previously recognized.”
Forest Service Response: This article points out that over time, more is discovered about the value of snags and down woody debris over the landscape for a wide variety of animals, birds, fungi and insects. See above response to commenter’s statement, “Dead and dying trees are important…”
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