Environmental Assessment

United States Department of Agriculture Forest Service Elk Smith Project Preliminary Analysis

Rocky Mountain Ranger District Helena-Lewis and Clark National Forest Lewis and Clark County, Montana Responsible Official: Michael Muñoz, District Ranger August 2016

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

U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual’s income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication for program information (e.g. Braille, large print, audiotape, etc.) please contact USDA’s TARGET Center at (202) 720- 2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720- 6382 (TDD). USDA is an equal opportunity provider and employer.

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Table of Contents

Purpose and Need for Action ...... 7 Introduction ...... 7 Purpose Statement ...... 7 Proposed Action and Alternatives ...... 8 Alternative 1 ...... 8 Alternative 2 ...... 8 Forest Vegetation ...... 11 Sensitive Plants ...... 12 Range Report ...... 13 Noxious Weeds ...... 13 Soils ...... 13 Watershed ...... 14 Fisheries ...... 19 Recreation ...... 20 Heritage ...... 20 Wildlife ...... 21 Inventoried Roadless and Visuals Report ...... 24 Roadless ...... 24 Visuals ...... 25 Effects Analysis ...... 27 Fire, Fuels, and Air Quality Report ...... 27 No Action Alternative ...... 37 Proposed Action ...... 43 Conclusion ...... 48 Air Quality ...... 49 Forest Plan Consistency ...... 54 Forest Vegetation Report ...... 56 No Action Alternative ...... 60 Proposed Action ...... 62 Forest Plan Consistency ...... 64 Sensitive Plant Report and Biological Evaluation ...... 65

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No Action Alternative ...... 68 Proposed Action ...... 69 Forest Plan Consistency ...... 70 Range Report ...... 71 No Action Alternative ...... 71 Proposed Action ...... 72 Forest Plan Consistency ...... 72 Noxious Weed Report ...... 72 No Action Alternative ...... 74 Proposed Action ...... 74 Forest Plan Consistency ...... 75 Soils Report ...... 79 No Action Alternative ...... 83 Proposed Action ...... 84 Watershed Report ...... 89 No Action Alternative ...... 91 Proposed Action ...... 92 Cumulative Effects ...... 93 Forest Plan Consistency ...... 95 Fisheries Specialist Report and Biological Evaluation ...... 97 Alternative 1 – No Action ...... 106 Alternative 2 – Proposed Action ...... 107 Conclusions by Alternative ...... 110 Biological Evaluations ...... 111 Westslope Cutthroat Trout ...... 111 Recreation Report ...... 114 No Action Alternative ...... 115 Proposed Action ...... 116 Heritage ...... 117 Alternative 1 ...... 121 Alternative 2 ...... 121 Summary ...... 122

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Wildlife Report and Biological Evaluation ...... 122 Grizzly Bear ...... 126 Canada Lynx ...... 126 Wolverine ...... 127 Black-backed Woodpecker and American Three-toed Woodpecker ...... 127 Bighorn Sheep ...... 127 Gray Wolf ...... 127 Northern bog lemming ...... 128 Elk ...... 128 Mule Deer and White-tailed deer ...... 128 Black Bear, Mountain Goat, Mountain Lion, Dusky Grouse ...... 128 Beaver, Bobcat ...... 128 Golden Eagle, Prairie Falcon ...... 128 Goshawk ...... 128 Migratory Birds ...... 129 Forest Plan Consistency ...... 142 Inventoried Roadless Area and Visuals Report ...... 143 Introduction ...... 143 Alternative 1 – No Action Alternative ...... 148 Alternative 2 – Proposed Action ...... 148 Visuals ...... 152 Introduction ...... 152 Alternative 1: No Action ...... 155 Alternative 2 ...... 156 Environmental Justice ...... 157 Personnel Consulted ...... 158 Federal, State, and Local Agencies Contacted ...... 158 Preparation of this environmental assessment was done by the following: ...... 158 Others Agencies and/or Groups Contacted ...... 158 Tribes Contacted ...... 158 PROJECT MAILINGS ...... 159 Appendix A: Maps ...... 160

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Appendix B: Treatment Units ...... 163 Appendix C: Project Design Features...... 168 Hydrology/Fisheries ...... 168 Heritage ...... 169 Noxious Weeds ...... 169 Range ...... 169 Recreation ...... 170 Soils ...... 170 Vegetation ...... 170 Wildlife ...... 170 Appendix D: Resource Protection Measures ...... 172 Fisheries ...... 172 Heritage ...... 172 Recreation ...... 172 Wildlife ...... 172 Grizzly Bear ...... 172 Big Game: ...... 172 Raptors ...... 173 Appendix E: Past, Present, and Reasonably Foreseeable Activities ...... 174 Appendix F: Monitoring ...... 179 Appendix G: Forest Plan Consistency Table ...... 180 Appendix H: Literature Cited ...... 181

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Purpose and Need for Action Introduction The Elk and Smith Creek drainages on the Rocky Mountain Ranger District are characterized by an overabundance of dense stands of even-aged, young lodgepole pine, largely resulting from the 1988 Canyon . Accumulating surface fuels, continuous crowns, and an abundance of ladder fuels in this type of forest make it more vulnerable to high-intensity, high-severity fires than a more diverse, multi-aged forest. Without management, these stands will become increasingly vulnerable to high-intensity wildfire that resists control and could therefore threaten private property to the east of the Forest boundary, as well as natural and cultural resources throughout the area. This large area of concentrated and continuous fuels, and the risk it represents for a potentially large, uncontrollable fire, limits opportunities to manage wildfire in the Scapegoat Wilderness to the west and south of the project area. Therefore, we propose to treat the following area with a combination of hand slashing and prescribed fire. These treatments would create a multi-aged stand and reduce the continuity and loading of fuel on the landscape. The legal description for proposed activities is: T19N, R9W, Sec 12-15, 21-28, 33-36, T18N, R9W, Sec 1-3, 11-13, T18N, R8W, Sec 1-18, 21-26 Purpose Statement Broadly speaking, the purpose of the Elk Smith Project is to address fuel accumulation and continuity in the project area. More specifically, the purpose of the project is to:

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

In addition to this primary purpose, specific units and treatments within the Elk Smith Project are proposed to address additional needs that have resulted from the accumulation of fuels within the project area. Secondary purposes are to:

• Protect culturally significant sites or areas; • Improve or protect several types of wildlife habitats from the threat of high-intensity wildfire; • Promote aspen regeneration in certain areas; • Protect and enhance existing whitebark pine stands;

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• Prevent increases in susceptibility of forest stands to mountain pine beetle or other infestations; and • Maintain or enhance Western cutthroat trout habitat or opportunities for habitat.

Proposed Action and Alternatives Alternative 1 Under Alternative 1, the no action alternative, existing management activities and natural processes would continue within the project area. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Alternative 1 provides a baseline for comparison of environmental benefits and consequences of Alternative 2 to the existing condition.

Alternative 2 Under Alternative 2, the proposed action alternative, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented. Treatments would occur in 15 units identified within the project area. These units combine to cover an area of 10,331 acres. Over portions of selected units, small conifers would be felled to provide adequate surface fuels to carry prescribed fire, promote aspen regeneration, and maintain natural openings. Prescribed fire would be introduced across all 15 treatment units, though only 30 percent to 50 percent of each unit would be targeted for treatment by fire (burned areas would generally occur in patches of 20 to 100 acres). There are 10,500 acres (1.2 percent) of the 39,242 acre Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area within the Elk Smith Project Boundary. Under the proposed action 10,331 acres are proposed for treatment, all of which would fall within the inventoried roadless area boundary, however, only 30 to 50 percent of the units would be treated. This would account for less than one percent of the inventoried roadless area being treated under the proposed action. Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events. Access for treatments will be accomplished existing routes, no new road construction or reconstruction would be completed. No commercial harvest is being proposed under alternative 2. A map of Elk Smith treatment units is located in appendix A. A detailed table including treatment units, size and proposed treatment methods is located in appendix B. Treatments would be staggered across time and space in order to meet project goals. Implementation would be begin in fall 2017 and would span five to 10 years. All treatments would be dependent on resource protection measures detailed in the following preliminary analysis. In general, units which border private lands would be prioritized for implementation. Proposed activities would incorporate project design features and may incorporate additional resource protection measures. For a detailed list of both, see appendix C and appendix D, respectively.

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Regulatory Framework

Regulatory Framework Common to all Resources The following table gives the Lewis and Clark National Forest Plan Management Areas found within the Elk Smith project area. It also details the acres and associated management goals for each management area within the project area boundary. These are common to all resource areas.

Table 1: Applicable Lewis and Clark National Forest Management Areas Management Area Acres Management Goals Provide sustained high level of forage for livestock and big game Management Area E 2,748 animals. Management Area G 17,018 Maintain and protect Forest resources with minimal investment. Provide winter recreation opportunities supported by public and Management Area H 597 private developments while maintaining other resource values. Protect, maintain, and improve resource quality while providing Management Area O 3,431 timber at a low intensity level to meet local needs. Manage forage for livestock at a moderate intensity level. Manage these areas to protect their wilderness values. Manage Management Area Q 426 with limited investment in range management and trail construction. Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian Management Area R N/A area dependent resources. Timber and range management activities are permitted.

Regulatory Framework by Resource

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

This project also adheres to the requirements of the National Environmental Policy Act (NEPA). The Elk Smith Project Environmental Assessment meets National Environmental Policy Act requirements by comparing the impact of a “No Action Alternative” and an “Action Alternative.” In the case of this report, the impact of these two alternatives on Fire, Fuels, and Air Quality are quantified and compared.

The Clean Air Act of July 1955 also regulates activities outlined in the Action Alternative of this project. This project would adhere to all implementation, reporting, and monitoring requirements

9 Environmental Assessment inherent in following the Clean Air Act. Impacts of the No Action and Action Alternatives are analyzed in the Air Quality sub-section of this report. Guidance to effectively manage and evaluate smoke impacts can be found in Publication Management System 484 – Inter-agency Prescribed Fire Planning and Implementation Procedures Guide, 2014; and in Publication Management System 420- 2 – Smoke Management Guide for Prescribed and Wildland Fire. All prescribed burning proposed in the Action Alternative would be subject to management and approval by the Montana/Idaho Airshed Group.

Both the Rocky Mountain Ranger District National Forest Management Act Analysis and the Elk Smith Project Preliminary Analysis are aligned with Forest Service Manual direction for Fire Management. Manual Direction offers the following vision to managers: “[To] safely and effectively extinguish fire, when needed; use fire where allowable; manage our natural resources; and as a Nation, live with wildland fire Forest Service Manual 5102.” The first priority in all management actions is as follows:

Risk Management and Risk Reduction – Assure management of risk to people, communities and natural and cultural resources is the fundamental principle used to make informed decisions in all fire management programs. Minimize the risk to people, communities and natural and cultural resources by assessing the potential benefits of actions, severity of concerns and probabilities of occurrences to reduce risk. (Forest Service Manual 5102)

The Elk Smith Project Action Alternative is designed to meet this objective by reducing the volume and continuity of fuels in proximity to the National Forest boundary. These activities are intended to reduce risk to human health and safety, as well as to protect communities and resources. In addition, these treatments are intended to increase the efficiency and effectiveness of fire management actions or, in other words, improve their cost-effectiveness.

In accordance with National Policy direction, the Action Alternative for the Elk Smith project was identified and developed utilizing management goals outlined in the Lewis and Clark National Forest Plan (1986). The management goals for all management areas included in the Elk Smith Project Area include the use of prescribed fire.

Table 2: Applicable Lewis & Clark National Forest Management Areas

Acres Management Goals (Prescribed Fire)

Management Area E 2,748

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

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The identification of treatment units, which can be found in Appendix B, in the Elk Smith Project Area also follows direction found in the Tri- Working Group Regional Community Wildfire Protection Plan. This Community Wildfire Protection Plan includes planning direction for Lewis & Clark, Jefferson, and Broadwater Counties. The entire Project Area is within Lewis & Clark County. Specifically, the Community Wildfire Protection Plan identifies Wildland Urban Interface within the Project Area and contains recommendations on fuels treatments that coincide with treatments and units identified in the Elk Smith Action Alternative (Lewis & Clark Community Wildfire Protection Plan, 2015).

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

The following laws, regulations, and policies also apply to proposed activities within the project area.

• 1974 Forest and Rangeland Renewable Resources Planning Act, as amended by the 1976 National Forest Management Act o It is the policy of Congress that all forested lands in the National Forest System be maintained in appropriate forest cover with species of trees, degree of stocking, rate of growth, and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management in accordance with land management plans. A report shall be compiled annually, based on examinations, of all lands in the National Forest System where objectives of land management plans indicate the need to reforest areas that have been cut-over or otherwise denuded or deforested. Treated lands shall be examined after the first and third growing seasons and certified as to stocking rate, growth rate, and other pertinent measures. Lands not certified would be returned to the backlog and scheduled for prompt treatment. o Forest Plans will be developed to identify the suitability of lands for resource management; provide for the diversity of plant and animal communities based on the suitability and capability of land areas to meet multiple-use objectives; and where appropriate, to the degree practicable, preserve the diversity of tree species similar to that existing in the planning area. • Forest Service Manual (FSM 2400 – Chapter 2470 Silvicultural Practices) o 2470.03 - Land managers shall use only those silvicultural practices that are best suited to the land management objectives for the area. Consider all resources, as directed in the appropriate forest plan.

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o 2472.02 - The Forest Service seeks to maintain all forest lands within the National Forest System in appropriate forest cover as directed by the National Environmental Policy Act. o 2472.03 - When harvest or a disturbance event reduces forest cover to an un-stocked or understocked condition, make an initial assessment and diagnosis to identify the acres in need of reforestation treatment or natural recovery in order to meet management objectives. Examine all reforestation areas for certification as meeting specific reforestation standards approved by the Regional Forester for timber production and other resource objectives. Make regeneration examinations, at a minimum, after the first and third growing seasons following treatment.

Sensitive Plants Management standards from the Lewis and Clark Forest Plan that apply to sensitive plants include: • Standard C-2 (1): Comply with the Endangered Species Act, other related laws, executive orders, Forest Service Manual direction, implementing regulations of the National Forest Management Act, legal decisions that have a bearing on the Forest Service Threatened and Endangered species program, consultation with the US Fish and Wildlife Service, recovery plans, and special studies. • Standard C-2 (2): Conduct a biological evaluation of each program or activity which is Forest Service funded, authorized, or carried out on occupied Threatened and Endangered species and sensitive species habitat. This evaluation will determine whether or not informal or formal consultation with the US Fish and Wildlife Service on Threatened and Endangered species is appropriate. • Standard C-2 (3): Identify and evaluate cumulative effects as part of each biological evaluation. This evaluation may result in specific management recommendations in addition to those identified above. • Standard C-2 (13): There are sensitive plants, as listed by the Regional Forester, of limited distribution that occur on the Forest and may require special consideration in land management to maintain diversity within the species gene pool. Assessments of suitable habitats for sensitive plants will be conducted before surface disturbing activities are permitted. The following laws, regulations, and policies also apply to proposed activities within the project area including: • Forest Service Manual 2670.32 (1): Review programs and activities as part of the National Environmental Policy Act of 1969 process through a biological evaluation to determine their potential effect on sensitive species. • Forest Service Manual 2670.32 (2): Avoid or minimize impacts to species whose viability has been identified as a concern. • Forest Service Manual 2670.32 (3): Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole.

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• Forest Service Manual 2672.41: Ensure that Forest Service actions do not contribute to loss of viability of any native or desired non-native plant or contribute to trends toward Federal listing of any species.

Range Report Management of these allotments is in compliance with: • Lewis and Clark Forest’s Land Management Plan Forest Plan Standard D-1 through D-4, (USDA Forest Service 1986a, p. 2-38 to 2-41). • Site specific management direction is provided in the Sun Canyon Range Analysis, June 1997. • Forest Service Manual (FSM) 2200.

Noxious Weeds On National Forest System lands, special management guidelines for the prevention and control of noxious weeds would be applied during development and maintenance activities in accordance with: • Rocky Mountain Ranger District Invasive Plant Management Strategy, • Forest Plan Standard D-2, Noxious Weeds and Other Pests (USDA Forest Service 1986a, p. 2-38 to 2-39). • Forest Service Manual 2900 requires that all forest management activities are designed to minimize or eliminate the possibility of establishment or spread of invasive species on National Forest System lands, or to adjacent areas.

Soils

The following laws, regulations, and policies apply to soil resources affected by proposed activities including:

• The Forest and Rangeland Renewable Resources Planning Act of 1974 (16 U.S.C. 1600-1614) (as amended by National Forest Management Act of 1976 (16 U.S.C. 472a). States that the development and administration of the renewable resources of the National Forest System are to be in full accord with the concepts for multiple use and sustained yield of products and services as set forth in the Multiple-Use Sustained Yield Act of 1960. The Act requires the maintenance of productivity of the land and the protection and, where appropriate, improvement of the quality of the soil and water resources. The Act specifies that substantial and permanent impairment of productivity must be avoided and has far-reaching implications for watershed management in the National Forest System. This Act as amended contains the following sections and provisions pertinent to maintaining a sound soil management program:

a. Section 3 paragraph 6b. This section directs the Secretary of Agriculture to make, and keep current, a comprehensive survey and analysis of conditions of, and requirements for, forest and rangelands of the United States, including a determination of the present and potential productivity of the land.

b. Section 5. This section directs the Secretary of Agriculture to develop and maintain on a continuing basis, a comprehensive and appropriately detailed inventory of all National Forest System lands and renewable resources.

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c. Section 6 paragraph k. This section directs the Secretary of Agriculture to identify lands within the management area which are not suited for timber production.

• Forest Service Manual 2550. Soil Management, Washington Office Amendment 2500-2010- 1. Objectives: To maintain or restore soil quality on National Forest System lands; To manage resource uses and soil resources on National Forest System lands to sustain ecological processes and function so that desired ecosystem services are provided in perpetuity. This directive establishes the management framework for sustaining soil quality and hydrologic function while providing goods and services outlined in forest and grassland land management plans. • Forest Service Manual 2554. R-1 Supplement No. 2500-99-1. Objectives: To meet direction in the National Forest Management Act of 1976 and other legal mandates. To manage National Forest System lands under ecosystem and management principles without permanent impairment of land productivity and to maintain or improve soil quality. This policy defines Regional Soil Quality Standards. • Forest Service Handbook 2509.22. Soil and Water Conservation Handbook. Provides a non- point Source Management Strategy to develop site-specific conservation practices for activities on National Forest System lands to minimize effects on soil and water resources and protect water-related beneficial uses.

Watershed

FEDERAL LAWS AND REGULATIONS

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

Forest and Rangeland Renewable Resource Planning Act of 1974 and National Forest Management Act of 1976 In response to requirements set forth in these two Acts, final rules on National Forest System Land and Resource Management Planning established specific minimum management requirements to be met in accomplishing the goals and objectives for National Forest System lands. These requirements were intended to guide the development, analysis, approval, implementation, monitoring, and evaluation of forest plans. Requirements specific to soils, water and fish habitat are found in 36 Code of Federal Regulation 219.27, volume 47, #190, September 30th, 1982 (Federal Register 1982) as follows:

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(a) Resource protection. “All management prescriptions shall: (1) Conserve soil and water resources and not allow significant or permanent impairment of the productivity of the land; (2) Consistent with the relative resource values involved, minimize serious or long-lasting hazards from flood, wind, wildfire, erosion. (4) Protect streams, streambanks, shorelines, lakes, wetlands, and other bodies of water...; (6) Provide for adequate fish and wildlife habitat to maintain viable populations of existing native vertebrate species....”

(e) Riparian areas. “Special attention shall be given to land and vegetation for approximately 100 feet from the edges of all perennial streams, lakes, and other bodies of water. This area shall correspond to at least the recognizable area dominated by the riparian vegetation. No management practices causing detrimental changes in water temperature or chemical composition, blockages of water courses, or deposits of sediment shall be permitted within these areas that seriously and adversely affect water conditions or fish habitat. Topography, vegetation type, soil, climate conditions, management objectives, and other factors shall be considered in determining what management practices may be performed within these areas or the constraints to be placed upon their performance.”

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

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

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

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

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

STATE OF MONTANA LAWS AND REGULATIONS

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

Montana Code Annotated (MCA) 75-5-703: Development and Implementation of Total Maximum Daily Loads In water bodies for which a Total Maximum Daily Loads has been developed and implemented, Montana law supports a “voluntary program of reasonable land, soil, and water conservation practices for nonpoint source activities for water bodies” in order to achieve compliance with water quality standards (MCA 75-5-703 [8]). In water bodies identified as impaired and in need of Total Maximum Daily Loads development, but for which no Total Maximum Daily Loads has been completed, “new or expanded nonpoint source activities affecting a listed water body may commence and continue if those activities are conducted in accordance with reasonable land, soil, and water conservation practices” (MCA 75-5-703 [10][c]). See Table 1 of the watershed specialist report for a summary of Water Quality Limited Segment in the Little Belt Mountains.

Administrative Rules of Montana (ARM) 17.30.6: Surface Water Quality Standards and Procedures Montana law links water quality to the attainment of “beneficial uses” in a water body. Designated beneficial uses vary by water body classification. The state has classified most of the streams within the project area as B-1 (ARM 17.30.610). Water bodies classified as B-1 must be “maintained

16 Environmental Assessment suitable for drinking, culinary, and food processing purposes, after conventional treatment; bathing, swimming, and recreation; growth and propagation of salmonid fishes and associated aquatic life, waterfowl and furbearers; and agricultural and industrial water supply” (ARM 17.30.623[1]). There are some additional specific standards that apply to B-1 waters” (ARM 17.30.623[2]). Water bodies classified as A-1 have the same beneficial uses as B-1 waters, with some additional specific standards (ARM 17.30.622[3]) similar to those listed for B-1 waters.

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

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

FOREST SERVICE DIRECTION

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

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Lewis and Clark National Forest Plan Management Standards

F-1: (1) Utilize adequate soil and water conservation practices to protect soil productivity and to control nonpoint water pollution from project activities, using as a minimum, practices specified in any State-developed “Best Management Practices.”

F-3: (1) Require application of Best Management Practices to project activities to ensure meeting or exceeding State water quality standards.

(2) Develop additional Best Management Practices during the environmental analysis process and incorporate them into all land use and project plans as a principle mechanism for controlling nonpoint pollution sources and meet soil and water quality or other resource goals.

(3) Meet State water Quality standards as required by the Clean Water Act (33 U.S.C. 1323) and as detailed in the Memorandum of Understanding to implement the 208 Program on National Forests in the State of Montana. Coordinate with the State of Montana concerning stream channels as agreed to in the Memorandum of Understanding with the State of Montana Fish and Game Commission.

(4) Require a watershed analysis of projects involving significant vegetative removal to ensure that the project, considered with other activities, will not increase water yields or sediment beyond acceptable limits. The analysis should identify any opportunities for mitigating adverse effects on water related beneficial uses, including capital investments for fish habitat or watershed improvements.

(5) Conduct an environmental analysis for all management actions planned for floodplains, wetlands, riparian zones, or bodies of water prior to implementation. Adopt the necessary mitigation measure to minimize risk of flood loss, restore and preserve flood plain values, and to protect wetlands.

Management Area R

Riparian areas throughout the forest have been given special consideration. These considerations include: (1) minimizing activities in riparian areas where possible; (2) standards for stream crossings; and (3) measures to avoid stream contamination.

Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian area dependent resources. Timber and range management are permitted.

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Adhere to state water quality standards and maintain current soil productivity. Priority funding will be high structural or land treatments which maintain or rehabilitate watersheds or soil.

Fisheries

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

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

Forest Service Manual sections 2532.02, 2532.03 Refer to the Watershed section above for specific information about this act.

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

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

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

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

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

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

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

Forest Plan Standards C-2: (2) Threatened, Endangered, and Sensitive Species – Conduct a biological evaluation of each program or activity.

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

Recreation

The following laws, regulations, and policies apply to proposed activities within the project area: • Rocky Mountain Ranger District Travel Management Plan – 2007.

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

20 Environmental Assessment addressed, and any necessary mitigation measures are incorporated into project design, the National Environmental Policy Act document, or other appropriate cultural resource agreement. The goal is to avoid, minimize, or mitigate impacts to significant cultural properties. Both National Historic Preservation Act and the Archaeological Resources Protection Act contain provisions for the confidentiality of certain cultural resource information. Site-specific locations and other sensitive site data are not disclosed to the public. Documents containing this information are marked with an asterisk (*) in the bibliography and retained in the cultural resource project file. This information is exempt from public disclosure and not available under the Freedom of Information Act.

Wildlife

National Forest Management Act The Forest Service is charged with maintaining the diversity of all existing native and desired non- native vertebrate species in a planning area under the National Forest Management Act of 1976. The regulations impose a standard by requiring habitat objectives to be established for maintaining viability of Management Indicator Species throughout a planning area.

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

Section 2670 establishes objectives and procedures for managing and protecting threatened, endangered, and sensitive species. In summary, the policy includes: • Review, through the biological evaluation process, actions and programs to determine their potential for effect on threatened and endangered species, species proposed for listing, and sensitive species. • Avoid all adverse impacts on threatened and endangered species and their habitats, except when it is possible to compensate adverse effects totally through alternatives identified in a biological opinion; when an exemption has been granted under the act; or when the biological opinion recognizes an incidental taking. Avoid adverse impacts on species proposed for listing during the conference period and while their federal status is being determined. • Initiate consultation or conference with the Fish and Wildlife Service or National Oceanic and Atmospheric Administration Fisheries when the Forest Service determines that proposed activities may have an effect on threatened or endangered species; are likely to jeopardize the continued existence of a proposed species; or result in the destruction or adverse modification of critical or proposed critical habitat. • Identify and prescribe measures to prevent adverse modification or destruction of critical habitat and other habitats essential for the conservation of endangered,

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threatened, and proposed species. Protect individual organisms or populations from harm or harassment as appropriate. • Avoid or minimize impacts to sensitive species whose viability has been identified as a concern. • Analyze, if impacts cannot be avoided, the significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole.

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

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

Lewis and Clark National Forest Plan The Lewis and Clark National Forest Plan (USDA Forest Service 1986) provides standards and guidelines that set the framework for management of wildlife species. Forestwide standards provide direction for wildlife management and are identified on pages 2-30 to 2-37. Forestwide standards for wildlife applicable to the Elk Smith Project are summarized as follows: • C-1 (5): Require a big-game cover analysis of projects involving significant vegetative removal to ensure that effective hiding cover is maintained. • C-1 (11): Use the Interagency Rocky Mountain Front Wildlife Monitoring/Evaluation Program Management Guidelines in the management of land-use activities. • C-2 (1): Comply with the Endangered Species Act, other related laws, executive orders, Forest Service Manual direction, National Forest Management Act implementing regulations, etc. • C-2 (2): Conduct a biological evaluation of each activity to determine if the activity may affect Threatened and Endangered species. • C-2 (3): Identify and evaluate cumulative effects as part of each biological evaluation. • C-2 (7): In occupied grizzly bear habitat comply with the management direction based on Management situation as described fully in Appendix K of the Forest Plan (USDA Forest Service 1986). • C-4 (1 – 11): The recommended level of hard snags in the Elk Smith project area are 158 snags per 100 acres with a 10 inch diameter-at-breast-height minimum in Douglas- fir/ponderosa pine timber types and 72 snags per 100 acres with a 10 inch diameter-at- breast-height minimum in lodgepole pine timber types. Wildlife trees should be

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adjacent to natural openings and water, clustered in important habitat, and larger diameter trees should be retained where possible. Keep down trees for wildlife feeding sites.

The plan also identifies Management Areas, and provides direction for each. Management Area goals are summarized below along with applicable management direction relative to wildlife.

Table 3: Applicable Lewis & Clark National Forest Management Areas Management Area Acres Management Goals/ Management Direction Provide sustained high level of forage for livestock and big game animals. Maintain important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing Management Area E 2,748 area, migration routes, elk summer range, raptor nesting sites, and significant non-game habitat values. Coordinate prescribed burning and revegetation projects with range management. Jointly financed projects should be considered where feasible. Priority for funding is high. Maintain and protect Forest resources with minimal investment. Maintain important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing Management Area G 17,018 areas, migration routes, elk summer range, raptor nesting sites, and significant non-game habitat values. Improve habitat by prescribed burning and planting desirable forage on disturbed sites. Priority for funding will be low.

Provide winter recreation opportunities supported by public and private developments while maintaining other resource values.

Management Area H 597 Minimize impacts on important identified wildlife habitat. Important identified habitat includes Threatened and Endangered habitat, big- game winter ranges, calving or lambing areas, migration routes, and elk summer ranges. Protect, maintain, and improve resource quality while providing timber at a low-intensity level to meet local needs. Manage forage for livestock at a moderate-intensity level. Management Area O 3,431 Maintain or enhance important identified wildlife habitat, including Threatened and Endangered habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer ranges, raptor nesting sites, and significant non-game habitat. Manage these areas to protect their wilderness values. Manage with limited investment in range management and trail construction.

Management Area Q 426 Maintain or enhance important identified wildlife habitat, including Threatened and/or Endangered habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer-fall range, raptor nesting sites, and significant non-game habitat values.

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Management Area Acres Management Goals/ Management Direction Manage to protect or enhance unique ecosystem values associated with riparian zones. Give preferential consideration to riparian area dependent resources. Timber and range management activities are permitted.

Not Maintain or enhance important identified wildlife and fish habitat. Management Area R applicable Important identified habitat includes Threatened and Endangered species habitat, big-game winter ranges, calving or lambing areas, migration routes, elk summer-fall ranges, raptor nesting sites, spawning areas, and significant non-game habitat values. Uneven-aged harvest systems will provide for stream shading, bank stability protection, and a range of successional stages.

Inventoried Roadless and Visuals Report

Roadless

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

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

Management Area Direction Management Area E: • Recreation – Setting: Recreation setting is mostly roaded natural. Interaction between users may be low to moderate with evidence of other users. • Resource activities will be evident, but will blend with the natural environment. Management Area H: • Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high.

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Management Area O: • Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high. Forest Service Handbook and Manual Direction Forest Service Handbook 1909.12 (72.1) provides definitions for the wilderness attributes of Inventoried Roadless Areas. Forest Service Manual 2300 – Recreation, Wilderness and Related Resource Management, guides management of recreation and wilderness resources on National Forest System lands.

Roadless Analysis Background and Direction Regional Foresters will review the following activities: a. Any necessary timber cutting or removal or any road construction or road reconstruction in emergency situations involving wildfire suppression, search and rescue operations, or other imminent threats to public health and safety in inventoried roadless areas.

b. Timber cutting, sale, or removal in inventoried roadless areas incidental to the implementation of an existing special use authorization. Road construction or road reconstruction is not authorized through this re-delegation without further project specific review.

c. The cutting, sale, or removal of generally small diameter timber when needed for one of the following purposes:

1. To improve threatened, endangered, proposed, or sensitive species habitat;

2. To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period; or,

3. For the administrative and personal use, as provided for in 36 Code of Federal Regulations 223, where personal use includes activities such as Christmas tree and firewood cutting and where administrative use includes providing materials for activities such as construction of trails, footbridges, and fences.

The activities proposed within the Elk Smith project fall within the activities requiring Regional Forester review, as explained in C-2, above. A briefing paper reviewing the proposed project activities was not required by the Regional Forester.

Visuals The Lewis and Clark National Forest Plan provides overall direction for visual quality (scenery) on the forest. Forestwide Management Standard A-8 states that “Landscape management principles will be applied to all activities on the Forest. This will be accomplished by implementing the procedures

25 Environmental Assessment defined in National Forest Landscape Management, Volume 2, Chapter I, of The Visual Management System (Agricultural Handbook No. 462).” (Lewis and Clark Forest Plan, pg. 2-28). The Forest Plan also “states a Visual Quality Objective for each management area. These Visual Quality Objectives provide the guideline for altering the landscape.” (Lewis and Clark Forest Plan, pg. 2-28) Proposed units are located within lands allocated to Management Areas E, G, H, O, Q and R. Guidelines for meeting Visual Quality Objectives are described in Forest Service Handbook 462, National Forest Landscape Management, Volume 2.

Table 4: Applicable Lewis & Clark National Forest Forestwide and Management Area Standards Standard Acres Visual Quality Objective

Not Management Standard A-8 Meets Standard Applicable

Not Meets Standard; occupied grizzly bear habitat Management Standard E-4 Applicable on the Rocky Mountain Division.

Management Area E 2,748 Partial Retention

Management Area G 17,018 Retention or Partial Retention

Management Area H 597 Retention or Partial Retention

Management Area O 3,431 Retention or Partial Retention

Management Area Q 426 Preservation

Not Not Applicable Management Area R Applicable

Manual Direction/Handbook Direction In 1986, when the Lewis and Clark National Forest Plan was adopted, the visual resource was inventoried and analyzed using the original Visual Resource Management System as outlined in Forest Service Handbook 462, National Forest Landscape Management System, Volume 2, Chapter 1. This system, which was released in 1974, established standards of measurement (Visual Quality Objectives) for assessing proposed and existing impacts to the scenic quality. In 1994, after 20 years of experience with the Visual Resource Management System and after additional research in the public and private sectors, the Forest Service revised the Visual Resource Management System and replaced it with the Scenery Management System. This revised system is described in Agricultural Handbook 701, Landscape Aesthetics: A Handbook for Scenery

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Management. Scenery Management System will not be implemented until the Lewis and Clark National Forest Plan is revised. Both the Visual Resource Management System and the Visual Resource Management System will provide guidance for the effects analysis of the scenery (visuals) resource in the Elk Smith Fuels project area.

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

Effects Analysis Fire, Fuels, and Air Quality Report

Technical Terms The following technical terms are used in the body of this report. Definitions of these technical terms are provided, below, for clarity. Broadcast Burning – The intentional burning of debris on a designated unit of land, where the fuel has not been piled or windrowed, by allowing fire to spread freely over entire area. Jackpot Burning – Intentional burning used to reduce fire hazard in areas where heavy fuel concentrations exist but are not continuous enough for a broadcast fire to carry through the fuels, and where piling would be impractical. – The movement of fire through the crowns of trees or shrubs. Active Crown Fire – A crown fire in which the entire fuel complex becomes active crown fire involved, but the crowning phase remains dependent on heat released from the surface fuels for continued spread. Passive Crown Fire – A crown fire in which individual or small groups of trees torch out, but solid flaming in the canopy cannot be maintained except for short periods. Fireline Intensity – The product of the available heat of combustion per unit of ground and the rate of spread of the fire, interpreted as the heat released per unit of time for each unit length of fire edge. The primary unit is British thermal unit per second per foot (Btu/sec/ft.) of fire front. Flame Length – The distance between the flame tip and the midpoint of the flame depth at the base of the flame (generally the ground surface), an indicator of fire intensity.

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Table 5: Elk Smith Proposed Treatment Units

Unit Acres Area Purpose Treatments Anticipated Season

• Slash and burn conifers encroaching on Spring or Fall. natural openings and aspen stands Targeted season for Petty Maintain natural 1 546 • Fell young conifers (less than16 feet) using implementation would Creek openings as fuel breaks power saws over portions of unit be spring. • Broadcast burn utilizing hand ignition • Slash and burn conifers encroaching on Spring or Fall. natural openings and aspen stands. Use Targeted season for Maintain natural prescribed fire in existing aspen clones to implementation would Petty openings as fuel breaks. encourage suckering. be spring. 2 372 Creek Encourage aspen • Fell young conifers (less than 16 feet) using suckering. power saws over portions of unit • Broadcast and jackpot burns utilizing hand ignition • Broadcast burn utilizing helicopter ignition Spring or Fall. Targeted • Burn conifer regeneration and heavy surface season for implementation would Disrupt continuity of fuel loadings (1,000 to 10,000 hour fuels) be fall. fuels throughout unit • Reduction of 30-50 percent in conifer (downed trees and regeneration in patches of approximately 20 continuous conifer to 100 acres Weasel stands); reduce the future 3 1461 • Reduction of heavy surface fuel loadings in Creek risk of high-intensity and patches of approximately 20 to 100 acres high-severity fires in area Target amount burned 500 to 830 acres (treat 30- between wilderness 50percent). Stand replacement patches would boundary and Forest and generally be 100 acres or less. Treatments would private land boundaries occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained.

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Unit Acres Area Purpose Treatments Anticipated Season

• Broadcast burn utilizing helicopter ignition Spring or Fall. • Target conifer regeneration and heavy Targeted season for surface fuel loadings (1,000 to 10,000 hour implementation would Disrupt continuity of fuels) be fall. fuels throughout unit • Reduction of 30 to 50 percent in conifer (downed trees and regeneration in patches of approximately 20 continuous conifer to 100 acres Weasel stands); reduce the future 4 1047 • Reduction of heavy surface fuel loadings in Creek risk of high-intensity and patches of approximately 20 to 100 acres high-severity fires in area • Target amount burned at 300 to 550 acres between wilderness (treat 30 to 50 percent). Stand replacement boundary and Forest and patches would generally be 100 acres or less. private land boundaries Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Broadcast burn utilizing helicopter ignition Spring or Fall. • Target conifer regeneration and heavy Targeted season for Disrupt continuity of surface fuel loadings (1,000 to 10,000 hour implementation would fuels throughout unit fuels) be fall. (downed trees and • continuous conifer Reduction of 30 to 50 percent in conifer Weasel stands); reduce the future regeneration in patches of approximately 20 5 628 Creek risk of high-intensity and to 100 acres high-severity fires in area • Reduction of heavy surface fuel loadings in between wilderness patches of approximately 20 to 100 acres boundary and Forest and • Target amount burned 180 to 320 acres (treat private land boundaries 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely

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Unit Acres Area Purpose Treatments Anticipated Season

stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Broadcast burn utilizing helicopter ignition Spring or Fall. • Target conifer regeneration and heavy Targeted season for Disrupt continuity of surface fuel loadings (1,000 to 10,000 hour implementation would fuels throughout unit fuels) be fall. (downed trees and • Reduction of 30 to 50 percent in conifer continuous conifer regeneration in patches of approximately 20 stands); reduce the future to 100 acres risk of high-intensity and 6 588 Elk Pass • Reduction of heavy surface fuel loadings in high-severity fires in area patches of approximately 20 to 100 acres between wilderness • Target amount burned 170 to 300 acres (treat boundary and Forest and 30 to 50 percent). Stand replacement patches private land boundaries. would generally be 100 acres or less. Encourage aspen Treatments would occur in both densely suckering. stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Slash and burn conifers encroaching on natural Spring or Fall. openings and aspen stands. Use prescribed fire in Targeted season for Maintain natural existing aspen clones to encourage suckering. implementation would openings as fuel breaks. 7 748 Elk Pass • Fell young conifers (less than 16 feet) using be spring. Encourage aspen power saws over portions of unit suckering. • Broadcast and jackpot burns utilizing hand ignition Disrupt continuity of Spring or Fall. 8 584 Elk Pass fuels throughout unit • Broadcast burn utilizing helicopter ignition (downed trees and

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Unit Acres Area Purpose Treatments Anticipated Season

continuous conifer • Target conifer regeneration and heavy Targeted season for stands); reduce the future surface fuel loadings (1,000 to 10,000 hour implementation would risk of high-intensity and fuels) be fall. high-severity fires in area • Reduction of 30 to 50 percent in conifer between wilderness regeneration in patches of approximately 20 boundary and Forest and to 100 acres private land boundaries. • Reduction of heavy surface fuel loadings in Encourage aspen patches of approximately 20 to 100 acres suckering. • Target amount burned 170 to 300 acres (treat 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Slash and burn conifers encroaching on Spring or Fall. natural openings and aspen stands. Use Targeted season for Maintain natural prescribed fire in existing aspen clones to implementation would Horse openings as fuel breaks. encourage suckering. be spring. 9 648 Mountain Encourage aspen • Fell young conifers (less than 16 feet) using suckering. power saws over portions of unit • Broadcast and jackpot burns utilizing hand ignition • Broadcast burn utilizing combination of Spring or Fall. Disrupt continuity of fuel helicopter and hand ignition Cyanide Targeted season for 10 669 that would support west- • Creek Reduction of 30 to 50 percent in conifer implementation would to-east fire spread regeneration in patches of approximately 20 be fall. to 100 acres

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Unit Acres Area Purpose Treatments Anticipated Season

• Reduction of heavy surface fuel loadings in patches of approximately 20 to 100 acre • Target amount burned at 200 to 340 acres (treat 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Target conifers encroaching on natural Spring or Fall. openings and aspen stands Targeted season for Horse Maintain natural • Fell young conifers (less than 16 feet) using implementation would 11 473 Mountain openings as fuel breaks power saws over portions of unit be spring. • Broadcast and jackpot burns utilizing hand ignition • Broadcast burn utilizing combination of Spring and Fall. helicopter and hand ignition Spring is the preferred • Fell young conifers (less than 16 feet) using season for treatment on power saws over select portions of unit (e.g. portions of the unit administrative pasture) bordering private land. • Fall is the preferred Disrupt continuity of fuel Reduction of 30 to 50 percent in conifer Cyanide season for other 12 1500 that would support west- regeneration in patches of approximately 20 Creek portions of the unit. to-east fire spread to 100 acres • Reduction of heavy surface fuel loadings in patches of approximately 20 to 100 acres • Target amount burned 450 to 750 acres (treat 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely

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Unit Acres Area Purpose Treatments Anticipated Season

stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Broadcast burn utilizing combination of Spring and Fall. helicopter and hand ignition Spring is the preferred • Reduction of 30 to 50 percent in conifer season for treatment on regeneration in patches of approximately 20 portions of the unit to 100 acres bordering private land. Disrupt continuity of fuel • Fall is the preferred that would support west- Reduction of heavy surface fuel loadings in Cyanide season for other 13 249 to-east fire spread; patches of approximately 20 to 100 acres Creek portions of the unit. encourage aspen • Target amount burned 75 to 125 acres (treat suckering 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. • Broadcast burn utilizing combination of Spring and Fall. helicopter and hand ignition Spring is the preferred • Reduction of 30 to 50 percent in conifer season for treatment on regeneration in patches of approximately 20 portions of the unit to 100 acres bordering private land. Disrupt continuity of fuel Cyanide Fall is the preferred 14 645 that would support west- • Reduction of heavy surface fuel loadings in Creek season for other to-east fire spread patches of approximately 20 to 100 acres portions of the unit. • Target amount burned 190 to 330 acres (treat 30 to 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely

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Unit Acres Area Purpose Treatments Anticipated Season

stocked areas. Some dense forest areas would be retained. • Broadcast burn utilizing combination of Spring and Fall. helicopter and hand ignition Spring is the preferred • Reduction of 30 to 50 percent in conifer season for treatment on regeneration in patches of approximately 20 portions of the unit to 100 acres bordering private land. • Fall is the preferred Disrupt continuity of fuel Reduction of heavy surface fuel loadings in Cyanide season for other 15 173 that would support west- patches of approximately 20 to 100 acres Creek portions of the unit. to-east fire spread • Target amount burned 50-90 acres (treat 30- 50 percent). Stand replacement patches would generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. Proposed 10,331 Project Acres Total

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The treatments listed above would be staggered across time and space in order to meet project goals. Implementation is expected to begin in fall 2017, would span five to 10 years and is dependent on the use of project design features detailed in the appendices of this preliminary analysis (see appendix C). In general, units which border private lands would be prioritized for implementation first.

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary. In this report, the analysis of effects focusses on the Project Area, but a broader area is also included in the analysis of cumulative effects to provide a more useful spatial scale for fire history. In terms of cumulative effects, the analysis includes a larger area defined by two subunits of larger Bear Management Units (BMUs). These subunits are the South Fork Willow subunit of the South Fork Sun Beaver Willow Bear Management Unit, and the Scapegoat subunit of the Dearborn Elk Creek Bear Management Unit. A Cumulative Effects table of Activities Past, Present, and in the Foreseeable future may be found in appendix E.

In terms of temporal scale, the analysis is limited by the historic record. For example, specific fire- perimeter data for wildfires extends back to about 1910. Similarly, logging and thinning activities prior to the 1970s were not well-documented (see Past, Present, and Reasonably Foreseeable Activities, appendix E). However, scientific research extends our understanding of ecological processes shaping the landscape over a much longer period of time. Methodologies for these studies vary. For example, Gruell used photographs taken between 1871 and 1982 to interpret fire and vegetation trends (Gruell, 1983), as well as journals dating back to the 18th Century (Gruell, 1985). Gabriell utilized historic records and Dendrochronology to establish fire history as far back as 1749 for an area immediately to the west of the Project Area (Gabriel, 1976).

In modelling the Existing Condition and the Proposed Action, emphasis was placed on short-term effects. Short-term effects are synonymous with the fire management term “First Order Fire Effects.” The definition of First Order Fire Effects is as follows: The effects that concern the direct or immediate consequences of fire, such as biomass consumption, crown scorch, bole damage, and smoke production. First order effects form an important basis for predicting secondary effects. It follows that, for the purposes of this analysis, long-term effects are synonymous with Second Order Fire Effects, such as tree regeneration, plant succession, and changes in site productivity … these involve interaction with many other non-fire variables (Glossary of Wildland Fire Terminology – National Wildfire Coordinating Group). Because Second Order Fire Effects involve interactions with non-fire variables, they become increasingly difficult to predict with the passage of time. As with past activities, projecting the impact of the No Action Alternative against that of the Proposed Action relied on a body of scientific research, as well as vegetation modelling (See Vegetation Report).

Sources, Methods, and Assumptions The analysis included in this Fire, Fuels, and Air Quality report is based on a review of studies, professional papers, journal articles, and books directly related to the fuels occurring within the Elk Smith Project Area, and the treatments proposed for the Action Alternative in this Environmental Analysis. Precedence was given to articles and studies that considered fire and fuels in close geographic proximity to the Project Area, or in areas displaying similar fuel, fire history, weather, and topography. The Fire and Fuels section of the Rocky Mountain Ranger District National Forest Management Act Analysis, 2010— used in conjunction with the document’s “Literature Cited” section—provided a starting point for this

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literature review. Literature referenced to inform this analysis is included in the Literature Cited section provided at the end of this document, and in “supporting literature” included in the project record.

In addition to literature, fuel modelling and fire history were employed to characterize the existing condition of the Project Area, as well as to evaluate the short and long-term impact to fuels of both the No Action and Action Alternatives. For fuel modelling, LANDFIRE fuel data was used in conjunction with FlamMap. LANDFIRE fuel data describe the composition and characteristics of surface and canopy fuel, and provide a necessary input for running fire behavior models. To accurately portray fuels in the Project Area, LANDFIRE data was modified utilizing regional vegetation data (R1 VMap), and data obtained from the Red Shale Fire of 2013—a fire that burned in the vicinity of the Project Area and in similar fuels (see Hollingsworth, 2015). After modelling fuels, analysts used FlamMap to evaluate potential fire behavior in the Project Area. FlamMap is a fire behavior mapping and analysis program that computes potential fire behavior characteristics, such as flame length, crown fire activity, and fireline intensity. Environmental conditions remain constant in FlamMap; the program uses spatial information on topography and fuels to calculate fire behavior characteristics for a single set of environmental conditions. The program was used to evaluate both the Existing Condition and Proposed Action in terms of fuels and potential fire behavior. Due to the complexity of FlamMap, the author of this report requested technical assistance and expertise from the Rocky Mountain Research Modeling Institute (RMRS FMI). Fire Behavior Specialist LaWen Hollingsworth from the Rocky Mountain Research Station Fire Modeling Institute and Helena-Lewis and Clark Forest Fuels Specialist Jonathan Olsen provided assistance in calibrating LANDFIRE data and in running FlamMap.

In addition to literature and modelling, fire history for the Project Area, and on lands immediately to the east and west, provided important background data for analysis, and assisted in the evaluation of fuel conditions in the Elk and Smith Creek drainages. Fire history for the Bob Marshall Complex as a whole was referenced to enhance understanding of fire regimes and fire-return intervals in the Project Area (Fire History Maps and Data for the Complex are included in Supporting Documentation in the project file).

Existing Condition

Fire History Text Fire history was considered beyond the project boundary. Two Bear Management (BMU) subunits were used to display and analyze fire history: the South Fork Willow subunit of the South Fork Sun Beaver Willow Bear Management Unit, and the Scapegoat subunit of the Dearborn Elk Creek Bear Management Unit. Records of fire perimeters, both from prescribed fire and wildfire, are available from1910 through the present, while “fire start” data are available from 1940 to the present. Since 1940, 113 fire starts have been recorded in the South Fork Willow and Scapegoat subunits. These starts resulted in fires that reached burned-area perimeters ranging from 1/10th of an acre to 17,324 acres (only acres burned within the subunits included). The primary cause of fire ignitions in these subunits was lightning. Of the total 113 starts, 80 were initiated by lightning, with the remaining 33 being human caused (for more detail see Fire Start Data in the Project Record). Fire perimeters in the two subunits are displayed on a map in the appendices (appendix A) Fires play an important role in shaping the landscape of these two subunits, and in shaping landscapes across the west. Research and analysis suggests that this particular landscape experienced fires of moderate severity on a return interval of approximately 35 to 100 years, with most literature indicating this return closer to 35 years than 100 years (Arno, 1980; Gabriel, 1976; Gruell, 1983; Lotan, 1985; RMRD NFMA, 2010). The most important fire shaping vegetation in the Elk-Smith Project Area was the Canyon Creek Fire of 1988. The perimeter of this fire included all the Units identified for the Proposed Action. Only a small

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portion of the Project Area, near its northern border, falls outside this perimeter. The Canyon Creek fire stand-replaced extensive areas of mature conifers in the Project Area, though islands of conifers that were not burned by this fire are interspersed across the landscape. For additional information on the fire history, fire regimes, and condition classes of the southern half of the Rocky Mountain Ranger District, see Rocky Mountain Ranger District NFMA Analysis, 2010.

Environmental Benefits and Consequences

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

No Action Alternative Alternative 1 proposes no actions. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases on trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Wildland Fire Use For Resource Benefit would remain a management option for Wilderness lands lying immediately to the west of the Project Area, though its use as a management tool could be undermined by the continued accumulation of fuels in the Project Area. Alternative 1 provides a baseline for comparison of environmental consequences of the Action Alternative to the existing condition. It is a management option that could be selected by the Responsible Official.

Direct and Indirect Effects As indicated in the above section, Fire History, the Canyon Creek Wildfire of 1988 stands as the most important event influencing the present condition of fuels in the Project Area. This fire “reset” plant communities. Extensive regeneration of lodgepole pine is typical throughout the Project Area and is associated with high volumes of downed woody material and standing snags, also resulting from the 1988 fire. The combination of high volumes of downed woody-debris with the developing crowns of lodgepole pine and other colonizing conifers represents a growing fire hazard. In this case, fire hazard is defined by the rate of spread and intensities that a fire may exhibit, and the potential for a fire to cover extensive acreage. According to researchers, it is typical for fire hazard to grow steadily from a low point immediately following a fire in this fire regime and fuel type. As dead trees fall to the ground, and lodgepole grow within the fire perimeter, fire hazard increases. This hazard peaks around 25 years following a wildfire and remains elevated until moderating approximately 85 years following the fire (Lotan 1985). The direct effect of the No Action Alternative would be to perpetuate this heightened level of fire risk for many decades. In evaluating the Direct and Indirect Effects of the No Action Alternative, fuels in the Project Area were modelled to characterize fire behavior that can be expected given current fuel conditions. Modelling efforts were informed by historic weather and fire observations on the Rocky Mountain Ranger District. Specifically, the Red Shale fire of 2013 burned within the perimeter of the Gates Park fire of 1988, in fuel conditions similar to those found in the Project Area. With weather, fuel and fire behavior observations from this fire, LANDFIRE and VMap data were calibrated to more accurately represent fuel characteristics—such as loading, arrangement, and distribution—across the Project Area landscape (see Fuel/Fire Modelling in the project record). Finally, FLAMMAP (a fire mapping and analysis program) was used to model potential fire behavior in the Project Area. Three outputs were particularly useful in evaluating the present condition of fuels, and in making a comparison to fire behavior in the Project Area

37 Environmental Assessment following implementation of the Proposed Action. These outputs were “Fireline Intensity,” “Flame Length,” and “Crown Fire Activity.” Fireline Intensity and Flame Length are especially useful outputs in analyzing fuel conditions in that they can be tied directly to conditions where fire management activities, such as building handline, conducting burnout operations, and using aviation resources to deliver retardant can be implemented effectively by firefighters. Richard Rothermel, in his seminal publication How to Predict the Spread and Intensity of Forest and Range Fires, defined fire behavior characteristics in relationship to effective fire control, Table 6.

Table 6: Fire Suppression Interpretations from Rothermel (1983)

Flame Length Fireline Intensity Interpretations (Feet) (Btu/sec/ft) Less than 4 Less than 100 Fires can generally be attacked at the head or flanks by persons using handtools. Hand line should hold the fire

4 to 8 100 to 500 Fires are too intense for direct attack on the head by persons using handtools. Hand line cannot be relied on to hold fire. Equipment such as dozers, pumpers, and retardant aircraft can be effective.

8 to 11 500 to 1,000 Fires may present serious control problems— torching out, crowning, and spotting.

Greater than 11 Greater than 1,000 Crowning, spotting, and major fire runs are probable. Control efforts at head of fire are ineffective.

Using Rothermel as a guide, Analysts for this project grouped FLAMMAP outputs for Fireline Intensity (FLI) and Flame Length into the following classes Table 7 and Table 8. Fireline Intensity and Flame Length are correlated--Flame Length is a direct indicator of Fireline Intensity. Values for both Flame Length and Fireline Intensity are displayed in the following graphs for two reasons. First, scientific research commonly evaluates fire behavior and effects in terms of Fireline Intensity. Conversely, Flame Length provides a value that is easier to visualize. For that reason, Flame Length is often used by firefighters, fire managers, the media, and the public to assess and communicate fire behavior (see the definitions of Fireline Intensity and Flame Length offered in the Technical Terms section).

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Table 7: Fireline Intensity (FLI) and Flame Length Classes

Flame Length Flame Length Intensity Flame Length Intensity Intensity Class Range (Btu/sec/ft) Range (Ft) 0 0 0 1 1 to 99 .001 to 3.99 2 100 to 499 4.0 to 7.99 3 500 to 999 8.0 to 10.99 4 1,000 plus 11 plus

For the existing condition, flame lengths and fireline intensity were averaged for proposed treatment units by flame class and fireline intensity class. The percentage of fuels in each class is displayed in Table 8 and Table 9 by unit (for the purpose of comparison with post-treatment conditions). It should be noted that fuels were modelled for the entire Project Area for both the existing condition and the Proposed Action. A map of Project Area results for flame lengths and crown fire potential—Existing Condition and Proposed Action – is located in Appendix A of the fuels specialist report.

Table 8: Existing Condition: Percentage of Unit by Flame Length Class (FLC)

Treatment FLC 0 (no FLC 1 FLC 2 FLC 3 FLC 4 Unit Number fire) (.001 to 3.99) (4.0 to 7.99) (8.0 to 10.99) (11 plus) 1 0% 69.90% 7.55% 1.54% 20.98% 2 0.50% 53.93% 23.48% 11.04% 11.05% 3 2.20% 68.25% 19.68% 5.44% 4.43% 4 3.20% 55.32% 18.76% 6.98% 15.74% 5 0.21% 49.40% 28.96% 8.65% 12.78% 6 0% 52.77% 28.97% 9.69% 8.58% 7 0.15% 42.31% 32.22% 9.20% 16.13% 8 1.24% 67.59% 23.15% 5.23% 2.79% 9 0.07% 78.21% 11.48% 4.19% 6.05% 10 0.47% 56.47% 22.16% 8.98% 11.92% 11 0.33% 81.69% 13.01% 2.76% 2.21% 12 2.03% 40.30% 29.90% 11.96% 15.81% 13 0.01% 30.54% 47.19% 15.60% 6.68% 14 2.75% 56.77% 25.51% 8.01% 6.96% 15 1.91% 65.18% 23.96% 5.94% 3.00%

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Table 9: Existing Condition: Percentage of Unit by Fireline Intensity Class (FLIC)

Treatment FLIC 0 FLIC 1 FLIC 2 FLIC 3 FLIC 4 Unit Number (no fire) (1 to 99) (100 to 499) (500 to 999) (1,000 plus)

1 5.45% 63.79% 10.76% 5.72% 14.27% 2 6.78% 49.80% 36.57% 5.18% 1.67% 3 10.91% 61.31% 24.57% 2.16% 1.04% 4 5.99% 54.21% 26.27% 8.03% 5.51% 5 0.37% 52.48% 37.24% 5.55% 4.36% 6 0.27% 55.16% 38.92% 4.99% 0.66% 7 0.87% 44.31% 42.07% 8.72% 4.02% 8 4.73% 67.26% 26.18% 1.34% 0.49% 9 8.93% 68.81% 17.39% 3.21% 1.67% 10 0.51% 59.76% 30.72% 4.94% 4.06% 11 14.35% 68.04% 16.15% 1.23% 0.24% 12 6.10% 37.85% 44.31% 7.45% 4.30% 13 1.78% 31.39% 64.74% 2.08% 0% 14 8.00% 53.84% 33.24% 3.30% 1.62% 15 5.33% 63.92% 29.01% 1.70% 0.04%

Flame length and fireline intensity results illustrate that approximately 40 percent of the area included in units would exhibit fire behavior resistant to any type of direct attack (Fireline Intensity and Flame Length Classes 2, 3, and 4). In other words, approximately 40 percent of the area included in each unit could be expected to produce flame lengths greater than 4 feet and fireline intensity in excess of 100 British Thermal Units per second per square foot (Btu/sec/ft). It should be remembered that fuels are not neatly grouped across the unit. For a better sense of fuel distribution with its resultant fire characteristics, see the map of Flame Lengths for the Existing Condition (Appendix A). Another output derived from FLAMMAP is crown fire potential. FLAMMAP outputs give insight as to where crown fire activity may occur across the landscape, or area of interest, during the peak of the burn period. In the case of runs modelled for the project, historic weather from active burn periods during the Red Shale fire of 2013 was utilized in developing inputs. For Table 10, crown fire for the existing condition was grouped among four categories. The four categories modelled, and their respective definitions, are as follows: • No Fire: There are insufficient fuels to support fire activity. • Surface Fire: Fire spreads through surface fuel without consuming any overlying canopy fuel. • Passive Crown Fire: A type of crown fire in which the crowns of individual trees or small groups of trees burn, but solid flaming in the canopy cannot be maintained except for short periods.

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• Active Crown Fire: A crown fire in which the entire fuel complex is involved in flame, but the crowning phase remains dependent on heat released from surface fuel for continued spread.

Table 10: Existing Condition Crown Fire Activity by Percentage of Unit

Proposed No Fire Surface Passive Active Treatment Unit Fire Crown Crown Number Fire Fire 1 0% 68.69% 26.63% 4.68%

2 0.50% 18.60% 80.90% 0%

3 2.20% 46.08% 51.56% 0.15% 4 3.20% 44.44% 52.15% 0.21% 5 0.21% 16.21% 83.33% 0.25% 6 0% 29.62% 70.38% 0% 7 0.15% 27.97% 71.88% 0% 8 1.24% 45.49% 53.27% 0% 9 0.07% 70.28% 29.65% 0% 10 0.47% 29.53% 70.00% 0% 11 0.33% 68.90% 30.77% 0% 12 2.03% 28.62% 69.29% 0.07% 13 0.01% 7.96% 92.03% 0% 14 2.75% 37.09% 60.16% 0% 15 1.91% 23.15% 74.94% 0%

As with flame length and fireline intensity, crown fire potential varies across the landscape depending on factors such as slope, fuel distribution, and wind speed. Under the existing condition, areas exhibiting the potential for passive crown fire dominate the landscape. Exceptions are units 1, 9, and 11. These units are characterized by relatively large areas of light fuel (e.g. grasses and forbs rather than heavy blow- down and young lodgepole pine). At a minimum, the No Action Alternative would maintain the flame length, fireline intensity, and crown fire potential listed in tables 3-5, 3-6, and 3-7. It is also likely that the No Action Alternative would result in higher fire occurrence in the Project Area. Recent research on fire occurrence in the Crown of the Continent--the Bob Marshall Wilderness Complex and Glacier National Park—indicates that within a fire perimeter ignitions are reduced for 21 years following a wildfire because “wildland fires create fuel breaks and reduce fuel loads and, if fires recur before fuels can recover, the size and severity of subsequent fires are limited (Parks, 2013).” For the Crown, this reduction in ignitions was greater than half for most of the 21 year period (Parks, 2015). The Elk-Smith Project Area has not seen wildfire for 28 years. Failing to reintroduce fire into the Project Area will keep the potential for new ignitions at an elevated level.

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Another direct effect of taking no action is to increase the potential for severe wildfires in the Project Area or, in other words, fires with the potential to damage ecosystems and property (Fulé 2013). Significant empirical evidence exists indicating the introduction of prescribed fire of even low-intensity can greatly reduce the severity of subsequent wildfire (Arkle, 2012; Peterson, 2007). Moreover, fuels treatments can reduce the amount of smoke produced by subsequent wildfires, by reducing both the amount of fuel burned by a wildfire, and by reducing the residence time and duration of a wildfire (Graham, 2004). By failing to reduce the potential for severe fire in the Project Area, the No Action Alternative would go against fire and fuels management direction aimed at reducing the threat of fire to human life and private property. Forest Service Manual Direction identifies Firefighter safety, public safety, and community protection as the supreme goals of Fire Management. Severe wildfires pose the greatest threat to these goals: “severe wildfires put numerous... values at risk including: critical infrastructure, critical fish and wildlife habitat, firefighter and public health and safety, soil productivity, clean air, and functional fire- adapted ecosystems (Graham, 2004).” Moreover, the No Action Alternative would stand in opposition to The Community Wildfire Protection Plan for Lewis and Clark County. This locally developed plan identifies lands within the Project Area as being part of the Wildland Urban Interface and promotes treatments in this area to reduce the hazard wildfire presents to human life, livestock, and improvements in the Project Area and on lands immediately to the east of the Project Area boundary.

Cumulative Effects Cumulative Effects describes the interaction of the No Action Alternative with other management action in or near the Project Area. It is probable that selecting the No Action Alternative would impact management actions both within the Project Area and in the Scapegoat Wilderness, immediately to the west of the Project Area. First, the No Action Alternative could impact the ability of managers to allow wildland fires to burn in the Scapegoat Wilderness, immediately to the west of the Project Area. Currently, the Lewis and Clark Land Management Plan allows for Wildland Fire Use For Resource Benefit (WFURB) in the Scapegoat Wilderness. Guidance for managing such fires is found in the Bob Marshall Wilderness Complex Wildland Fire Management Guidebook. Due to the close proximity to private lands and improvements, Wildland Fire Use For Resource Benefit is not allowed in the Project Area. The suppression of fires to the west of the Project Area could erode the wilderness character of the Scapegoat Wilderness. The Wilderness Act of 1964 defines Wilderness “as an area where the earth and its community of life are untrammeled by man.” In Wilderness Management: Stewardship and Protection of Resources and Values, Jerry F. Franklin and Gregory H. Aplet interpret Wilderness Character as follows: …the critical determinant of primeval influence is the degree to which ecological processes are free to operate according to historical rhythms. A place is more wild where fires continue to burn, floods erode and create, and migratory animals still roam. Only where ecological processes remain outside of direct human control can the land be called “untrammeled.” (Franklin and Aplet, 2002) Decisions to manage fires for resource benefit—in this case, for the benefit of Wilderness Character--are directly influenced by the risk such fires may pose to human safety and health, as well as private property (Zimmerman 2006; Stephens 2012). The hazard associated with fuels in the Project Area would continue to limit opportunities to manage fire in Wilderness, since these fuels could support the spread of wildfire across the Project Area and toward residences to the north of the Project Area, and/or onto private land to the east of the Project Area. If fuel conditions remain in their current state, managers would be more likely to aggressively suppress wildfires at small acreages on lands to the west of the Project Area than if fuel continuity and loads were reduced in the Project Area. The aggressive suppression of Wilderness fire would erode the untrammeled character of the Scapegoat Wilderness. Moreover, it is well-established

42 Environmental Assessment that wildfires in the Bob Marshall Complex can reduce the size, intensity, occurrence, and severity of subsequent fires (Parks 2013, 2015). Consequently, the suppression of Wilderness fires could result in larger fires, more likely to burn beyond the Wilderness boundary. Besides eroding Wilderness Character, adopting the No Action Alternative would perpetuate conditions that would make it difficult, or impossible, for fire managers to successfully confine, control, or suppress fires within the Project Area when lives, property, or natural resources are at stake. Whether fires originate on adjacent lands and spread into the Project area, or start within the Project Area, they would pose a threat to private lands, buildings, livestock, and residents immediately to the east. If the No Action Alternative is adopted, this threat would increase over the coming decades with the continued accumulation of fuels and growth of existing vegetation (Lotan, 1985).

Proposed Action Under Alternative 2, Action Alternative, prescribed fire and mechanical treatments developed to address fuel accumulation and continuity in the Project Area would be implemented as previously described, resulting in multiple breaks in existing heavy fuels, in a mosaic pattern across the landscape.

Direct and Indirect Effects

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

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Figure 1: Fuels Photo 1 Photograph at the western boundary of the Project Area, 2013. Evident in the background is a dense growth of lodgepole pine regeneration coupled with heavy loadings of downed snags. Before considering the direct and indirect effects of the action alternative, it is important to note that neither the action nor the no action alternative would remove fire from the Project Area. Fire would remain an important part of the ecology both of lands within the Project Area boundary, as well as on adjoining lands. Rather than remove fire from the landscape, the intent of the treatments is to create conditions where fire can occur over large portions of the landscape without the need for suppression (adapted from Reinhardt, 2008). The intensity of wildfire is determined by physical setting, weather, and fuels. Of these three factors, the only one we can modify is fuel (Graham, 2004). The action alternative proposes to modify fuels over a 22,000 acre Project Area by using mechanical treatment and prescribed fire to reduce regenerating conifers and accumulations of downed woody materials. In general, these treatments would create 20 to 100 acre burned patches within units located across the Project Area (total acreage within units is 10,331). Expanses of regenerating lodgepole pine would remain; areas of mature conifer, the survivors of the 1988 fire, would not be targeted for burning or mechanical treatment. The direct impact of these treatments would be to interrupt the continuity of fuels in the Project Area. This reduction of fuel continuity and loading would reduce the severity and intensity of subsequent fires (Arkle, 2012; Parks, 2013, 2015). To quantify the impact of implementing treatments across the Project Area, fuels data were modelled to reflect post-treatment conditions. First, criteria were established to help delineate priority areas within each proposed treatment unit. Treatment goals included focusing treatments within areas that burned in 1988 during the Canyon Creek Fire as much as possible and treating up to 50 percent of the area within each proposed unit. Priority treatment areas and post-treatment fuel values were selected to reflect reductions in surface fuel loadings, increases in canopy base heights, and reductions in canopy bulk densities that would result from the proposed treatments (as if the implementation of all thinning and

44 Environmental Assessment prescribed fire treatments had been accomplished). Once post-treatment fuels had been modelled, FLAMMAP was utilized to model fire-behavior. As in the existing condition, these outputs included Fireline Intensity, Flame Length, and Crown Fire Activity. Results from the FLAMMAP Run are displayed in Table 11, Table 12, and Table 13.

Table 11: Post-Treatment Condition: Percentage of Unit by Flame Length Class (FLC)

Treatment Flame Length Flame Length Flame Length Flame Length Flame Length Unit Number Class 0 Class 1 Class 2 Class 3 Class 4 (no fire) (.001 to 3.99) (4.0 to 7.99) (8.0 to 10.99) (11 plus) 1 0% 94.31% 5.06% 0.10% 0.53% 2 0.50% 77.12% 12.08% 5.15% 5.14% 3 2.20% 86.41% 8.66% 1.68% 1.05% 4 3.20% 77.79% 9.02% 3.20% 6.79% 5 0.21% 69.59% 16.51% 5.47% 8.21% 6 0% 74.54% 15.21% 4.45% 5.80% 7 0.15% 67.40% 21.91% 5.18% 5.36% 8 1.24% 73.97% 16.92% 5.08% 2.79% 9 0.07% 90.11% 5.05% 1.54% 3.24% 10 0.47% 73.97% 12.15% 5.59% 7.82% 11 0.33% 90.10% 7.91% 0.83% 0.82% 12 2.03% 65.60% 12.06% 7.11% 13.19% 13 0.01% 71.48% 23.19% 3.12% 2.20% 14 2.75% 77.39% 10.98% 4.40% 4.48% 15 1.91% 84.45% 8.69% 2.97% 1.97%

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Table 12: Post-Treatment Condition: Percentage of Unit by Fireline Intensity Class (FLIC) Treatment FLIC 0 (no FLIC 1 FLIC 2 FLIC 3 FLIC 4 Unit fire) (1 to 99) (100 to 499) (500 to 999) (1,000 plus) Number 1 19.65% 73.72% 6.17% 0.26% 0.20% 2 8.26% 69.86% 17.96% 3.20% 0.71% 3 13.59% 75.35% 10.36% 0.48% 0.22% 4 6.17% 75.53% 12.64% 3.39% 2.27% 5 4.62% 66.64% 22.08% 3.18% 3.47% 6 3.14% 72.61% 20.03% 3.78% 0.44% 7 1.73% 67.65% 26.96% 2.99% 0.67% 8 5.49% 72.12% 20.56% 1.34% 0.49% 9 10.83% 78.26% 8.13% 1.78% 1.00% 10 1.58% 74.66% 17.55% 3.38% 2.83% 11 12.16% 78.25% 9.16% 0.39% 0.05% 12 5.88% 61.72% 22.06% 6.13% 4.21% 13 2.59% 70.10% 26.49% 0.83% 0% 14 6.40% 74.64% 15.52% 1.93% 1.52% 15 5.46% 81.70% 11.48% 1.32% 0.04%

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Table 13: Post-Treatment Crown Fire Activity by Percentage of Unit Treatment Unit Number No Fire Surface Fire Passive Crown Active Fire Crown Fire

1 0% 93.91% 5.93% 0.16% 2 0.50% 62.22% 37.28% 0% 3 2.20% 78.52% 19.28% 0% 4 3.20% 73.18% 23.62% 0% 5 0.21% 53.78% 45.80% 0.21% 6 0% 65.20% 34.80% 0% 7 0.15% 58.98% 40.87% 0% 8 1.24% 58.41% 40.35% 0% 9 0.07% 83.57% 16.36% 0% 10 0.47% 57.97% 41.56% 0% 11 0.33% 79.51% 20.15% 0% 12 2.03% 59.06% 38.85% 0.07% 13 0.01% 52.52% 47.47% 0% 14 2.75% 66.30% 30.96% 0% 15 1.91% 51.97% 46.12% 0%

Modelling supports the contention that fuel treatments would reduce fireline intensity and flame lengths across the treatment units. With fuel conditions modified in the treatment units, a wider range of fire management tools would be available to manage fire within the Project Area. For example, flame length averaged for all the units was reduced, compared to the pre-treatment condition, from 5.39 feet to 3.27 feet. This suggests that flame lengths exhibited by wildfires in the post-treatment landscape would often fall into the range (less than 4 feet) where ground forces could be safely and effectively deployed to construct and hold handline. This reduction in flame length would also increase opportunities for fire managers to use burn-out as a management tool. Moreover, the size and availability of safety zones and escape routes would be increased, as would the effectiveness of aviation resources. When viewed on a map, post-treatment flame length and crown fire values illustrate how fire behavior, as modelled for flame length and crown fire, would be reduced and provide “breaks” in fuel continuity. These breaks would provide locations where management actions might limit the progress of a wildfire generally moving from west to east, pushed by prevailing winds typical in the Project Area (Appendix A). Reducing fire intensity and severity is perhaps the most essential component in mitigating the risk wildfire poses to firefighters, the public, and resources (Miller, 2014; Fulé, 2013). While wildfire will remain a critical agent of disturbance on the landscape, prescribed fire can aid managers in controlling fire growth and size in specific instances. For example, prescribed fire treatments give managers more opportunity to implement fire control strategies and tactics by providing areas of light fuel that can serve as anchor points for the establishment of fireline. Areas of comparatively light fuels also provide locations from which burnouts may be conducted, or where aerially delivered retardant may be applied effectively, or where crews can establish fireline. Furthermore, these areas of comparatively light fuels, or breaks in

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fuel type and loading, can also be used in conjunction with natural fire barriers and breaks (e.g. rock outcrops) to catch spot fires, establish safety zones, and locate escape routes (Jain, 2012). In addition, when spread across the landscape, fuel treatments can slow, and/or redirect, the spread of fire by forcing a wildfire to flank around these areas of reduced fuels (Graham, 2004). Finally, there is a growing body of evidence showing that the reintroduction of fire to landscapes can, over time, reduce the size of subsequent fires (Parks 2013, 2015; Kennedy, 2009). In all cases, fuels reduction projects give managers more options to safely contain or suppress fires when they pose an unacceptable risk to private property, or human life or health. Managers must remember, however, that every decision to suppress a fire is essentially a trade-off that may reduce the immediate threat of fires to values at-risk, but may undermine forest health and result in increased hazardous fuels (Reinhardt, 2008; van Wagtendonk, 1995). The treatments in this proposal are located in an area where the proximity of values at risk dictates that managers would almost always have to make decisions to reduce the immediate hazard posed by wildfire ignitions. For this reason, fuel treatments are essential to offset the trade-off of forest health and increases in wildland fuels that may occur when wildfires are suppressed to reduce an immediate threat to life, property, or natural resources. From the standpoint of fire and fuels, the durability of the treatments offered in the Action Alternative can only be predicted in general terms. For example, it is impossible to anticipate whether wildfires will ignite and burn within the Project Area, or whether the area will be subject to an extended drought. The occurrence of fires in the Project Area following the completion of the project could extend the effectiveness of treatments. Even discounting the potential for additional disturbance, it is likely the effectiveness of these treatments would persist for at least a couple of decades. Lotan describes the effect of subsequent fire on a regenerating lodgepole stand where “conifers create crown fuels in close proximity to large accumulations of dead woody fuel,” as developing a very “low fire behavior potential (Lotan, 1985).” Recent studies of the impact of wildfires on the severity of subsequent wildfires suggest that an initial wildfire can reduce the size of subsequent fires for 17 years or more, and the severity of subsequent fires by 20 years or more (Parks 2013, 2015). The proposed treatments would occur within a fire perimeter. Following treatment, sources for the recruitment of downed woody material, as well as the potential seed source for lodgepole regeneration will both be limited. Therefore, it is likely these treatments would be far more durable than the typical application of prescribed fire to previously untreated fuels. Due to the many factors contributing to the durability of treatments, the author of this report recommends that treatments are monitored for both First Order and Second Order fire effects. A photo-point record should be established in units, and in controls, prior to implementation of mechanical treatment (felling of young conifers) or prescribed fire treatments. A photographic record, and interpretation, for photo-points should also be completed immediately following the implementation of prescribed fire treatments. These photo-point records should be in addition to the standard narrative evaluations of post-burn conditions that are included in burn plans. Second Order Fire Effects should also be monitored. The timing of this monitoring could depend on the occurrence of unforeseen disturbance events. For example, monitoring could follow the occurrence of a significant wildfire within the Project Area. If all objectives are met in implementing these treatments, managers should consider re-visiting photo-points 15 to 20 years following completion of the Proposed Action, or at any time the efficacy of treatments comes into question.

Conclusion The fuel treatments outlined in the Action Alternative would likely enhance efforts to suppress or control fire in the Project Area. In addition, the treatments could complement ongoing efforts to reduce fuels in the vicinity of recreation residences and lodges along the Benchmark Road by increasing options available to managers to control wildfire in the Project Area. Doing so could prevent such a fire from

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spreading north/northeast towards residences. In addition, the project would dovetail with the establishment of fuel breaks immediately to the north—included in the Benchmark III project. Both Elk- Smith and Benchmark III would provide increased opportunity for managers and firefighters to limit the spread of wildfire across the Forest boundary onto private, state, and Bureau of Land Management lands. The Elk-Smith project would also complement conditions created by past District fuel reduction projects and past wildfires to promote the Rocky Mountain Ranger District’s active Fire Use Management Program. The Rocky Mountain Ranger District has experienced significant wildfire activity over the past 30 years, with numerous wildfires occurring near the Project Area in the last 15 years (Appendix A). These fires have been managed utilizing a number of strategies and tactics. In some cases, the fires have been allowed to burn comparatively unrestricted, with active management limited to some of the following activities: contingency planning and periodic re-evaluation of decisions; monitoring of fire growth and behavior; providing public information; implementing point protection on residences, structures, and administrative sites; implementing trail, road, and area closures when appropriate; initiating evacuations when needed. In some cases, management has included suppression on the entire perimeter of a fire; in other cases, fires have been suppressed only on those portions of the perimeter posing a threat to life, private property, or public values. Over the past 15 years, the perimeters of fires have begun to overlap. One of the first of these overlapping fires occurred in 2001, when the Biggs Flat Fire burned approximately 8,000 acres within the perimeter of the 1988 Gate Park Fire (a Map of Fire History for the Bob Marshall Wilderness Complex is included in project file). Since that time, numerous fires have “bumped” into each other on the District and, indeed, throughout the Bob Marshall Wilderness Complex. According to research, the impact of having an extensive overlay of recent wildfire footprints on the landscape is to reduce the size, occurrence, and severity of subsequent wildfires (Parks 2013, 2015). The Action Alternative is in-step with perpetuating this trend toward smaller, less-severe, wildfires. It promotes conditions where managers can choose, under the right conditions, to permit fires to burn naturally in the Scapegoat Wilderness to the west. In this sense, the project is similar to the South Fork Sun Prescribed Fire Project that was completed to the north and west of the Elk and Smith Creek drainages. The South Fork Sun Project treated approximately 16,000 acres with the objectives of allowing “lightning-caused fires to play a more natural role in this area than has historically occurred…. and to make the wilderness boundary more defensible against the risk of wildfire escaping the wilderness (South Fork Sun Environmental Analysis, 2000).”

Air Quality Smoke produced from fires—both prescribed and wildfire—can reduce visibility and expose humans to harmful pollutants. The primary pollutants produced by fires occurring on wildlands are extremely small airborne particles of solids and liquids. These fine particles are 2.5 micrometers or smaller (referred to as PM2.5), and are small enough that they can be inhaled, get into the lungs, and adversely impact human health (AirNow, 2016). The Environmental Protection Agency, in conjunction with state and local governments, regulates and monitors the public’s exposure to a wide-variety of airborne pollutants, including PM2.5. The effects of the No Action Alternative could potentially result in greater human exposure to particulate matter resulting from smoke. First, the No Action Alternative could result in larger wildfires in the Project Area and in lands immediately to the east of the project, which would produce larger volumes of particulate matter in a given period of time than a smaller wildfire or prescribed fire. Second, fires burning through the Project Area would have access to higher volumes of fuel--with the potential for increased smoke production--than wildfires burning through units pre-treated by prescribed fire. Finally, larger fires tend to burn over a longer period of time than smaller fires or prescribed fires and, consequently, are more likely to produce smoke on days with poor smoke dispersal.

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Managers have few options to control the production or dispersal of smoke from wildfires. Conversely, prescribed fires are scheduled when atmospheric conditions are conducive to smoke dispersal. Montana/Idaho Airshed Group guidelines are followed during all burning operations on National Forests in the respective states. The Airshed Group consults current air quality and smoke dispersion forecasts before authorizing prescribed burns. In addition, the Airshed Group manages the impact of prescribed burning to public health by taking into account the cumulative impact to air quality contributed by all wildfires and prescribed fires burning at a given time. Generally, air quality on the Rocky Mountain Front is Good, as measured by the Air Quality Index. Upward ventilation and winds typically disperse particulates from wildfires and prescribed fires, as well as other pollutants, before they reach dangerous levels in adjacent communities and areas of inhabitation. Monitoring of smoke impacts from recent fires suggests that prescribed burning can be accomplished in the Project Area without exceeding National Ambient Air Quality Standards (NAAQS). Since the amendment of the Clean Air Act in 1990, the Environmental Production Agency has set National Ambient Air Quality Standards for pollutants considered harmful to public health and the environment. Monitoring of smoke impacts from fire on the Rocky Mountain Ranger District focusses on measuring the level of PM2.5 over an averaging time of 24 hours. The current Air Ambient Quality Standard for PM2.5 is 35 micrograms per cubic meter of air (µg/m³), averaged over a 24 hour period. In 2006, this standard was made more restrictive, adjusted from the previous standard of 65µg/m³. Monitoring of smoke impacts from two recent fires (one prescribed and the other a wildfire) on the Rocky Mountain Front illustrate the impact of smoke on nearby receptors. During the fall of 2003, a prescribed burn of over 4,000 acres was conducted immediately to the north and west of the Elk-Smith Project Area. A smoke monitor was placed at the Cobb Ranch approximately two miles northeast of the Project Area.

10/6/2003

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70 24 hr average standard = 65 60 ug/m3

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Figure 2: South Fork Sun Prescribed Burn Smoke Monitoring, 2003 *Note: the PM 2.5, 24-hour average, NAAQS is now at 35 µg/m³. The 24-hour average for the period displayed does not exceed 35 µg/m³.

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At no time during the completion of the prescribed burn were the Montana Standards for PM2.5 exceeded (see Figure 2: South Fork Sun Prescribed Burn Smoke Monitoring, 2003). The burn was conducted when the National Ambient Air Quality Standards for PM2.5 were 65µg/m³; however, the 24 average was well below the Figure 2 more stringent current standard of 35µg/m³. A more recent wildfire also offers monitoring data that was utilized to assess the Figure 2 potential impact of the Proposed Action on air quality. During the 2013 fire season, the Rocky Mountain Ranger District managed a wildfire in the Bob Marshall Wilderness Complex named Red Shale. This fire burned entirely within the perimeter of the 1988 Gates Park Fire, in fuels very similar to those in the Elk-Smith Project Area (vegetation similarly determined by a 1988 fire). Discovered on July 18, the Red Shale Fire burned actively through the remainder of July and through the month of August, before fall rains inhibited further growth. The fire grew till its perimeter reached approximately 12,739 acres. To monitor smoke impacts on nearby communities, smoke monitors were placed at Ear Mountain (for the town of Choteau), and at Augusta, Montana. During the period monitored, the Red Shale Fire had numerous active days of burning. Significantly active days of burning resulted in fire growth ranging from several hundred acres to nearly 3,000 acres on July 27 (see Red Shale Fire Progression Map in the project file). Despite this large fire growth, the highest 24-hour average concentration of PM2.5 recorded by the Ear Mountain monitor was 17µg/m³, recorded on July 27. For the Augusta monitor, the highest 24-hour average PM2.5 concentration was 25µg/m³ (see Smoke Monitoring document in the project file). While monitoring of past prescribed and wildfires indicates that the Proposed Action can be implemented without exceeding National Ambient Air Standards, modelling was also completed to evaluate the potential impact of prescribed burning on air quality at potential receptors to the east of the Project Area. Specifically, the Smoke Impact Spreadsheet (SIS) helped evaluate potential impacts. Smoke Impact Spreadsheet is a modeling system for calculating PM2.5 emissions and airborne concentrations downwind of natural or managed wildland fires. As a screening model, Smoke Impact Spreadsheet provides conservative (that is, tending toward higher-than-actual) predictions of the downwind air concentrations at user-selected receptors for comparison with appropriate federal or state air quality standards for particulate matter less than 2.5 microns in diameter (PM2.5). The Action Alternative proposes the use of prescribed fire in both the spring and the fall. For this reason, Smoke Impact Spreadsheet modelled a separate prescribed fire scenario for each of the two seasons. In building the scenario, the author chose to model a prescribed fire of 1,500 acres, carried out over a single operational period. This acreage represents the probable upper-limit for the application of prescribed fire for a given entry (completing the project will occur over several years and require multiple entries). Communities immediately to the east of the project were considered in terms of PM2.5 impacts. These include Augusta, Fairfield and Choteau. Figure 3, below, displays results for a fall scenario and shows PM2.5 (averaged over a 24 hour period) downwind of the project.

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Figure 3: PM2.5 24-hour Concentration Chart for Fall Elk-Smith Scenario Figure 3 indicates that PM2.5 concentrations would be far below the 24 hour standard of 35µg/m³ at downwind receptors such as Augusta (14 miles downwind), Fairfield (33 miles downwind), and Choteau (37 miles downwind). Results for both fall and spring scenarios are included in the project record for this project (See SIS_Results, and SISModel_Notes in the project record). For both scenarios, PM2.5 standards for a 24 hour average were not approached within 0.1 mile of the proposed burn. Under the spring scenario, values for the 24 hour average of PM2.5 ranged from 15.07, at 0.1 mile distance from the burn, to .52392 at 50 miles distance from the burn (the maximum distance that Smoke Impact Spreadsheet models). For the fall scenario, values ranged from 19.635, at 0.1 mile distance, to .41093, at 50 miles. In conclusion, modelling suggest that smoke impacts from the proposed prescribed fire are unlikely to exceed, or approach, PM 2.5 standards in local communities.

Statutory and Regulatory Consistency The follow table summarizes the Proposed Action’s consistency with the relevant laws, regulations, and policies as previously introduced.

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Table 14: Summary of Statutory and Regulatory Consistency

Regulatory Requirement Project Consistency National Forest Management Act, 1976: The Elk-Smith Project evolved from interdisciplinary National Identify issues, concerns, and opportunities; Forest Management Act Analysis that followed the Lewis and and, Conform to the Forest Plan. Clark National Forest Plan: Rocky Mountain Ranger District NFMA Analysis, 2010. National Environmental Policy Act, 1969: This Project includes analysis of a No-Action Alternative and Requires the development and analysis of at an Action Alternative. A statement of purpose was developed least two alternatives, as well as a purpose for the project (see Purpose Statement). and need statement. Healthy Forest Restoration Act, 2003: The Elk-Smith Project Action Alternative would reduce fuels Provides guidance on the development and on lands identified as Wildland Urban Interface in the Tri- use of Community Wildfire Protection County Fire Working Group Regional Community Wildfire Plans, as well as the relationship between Protection Plan. these plans and Federal land management activities. Forest Service Manual Direction: Fire The Action Alternative would reduce fuels at the National management is undertaken to ensure Forest boundary reducing the potential of uncontrolled wildfire firefighter safety, public safety, and to threaten firefighter safety, public safety, as well as public and community protection. private property. Forest Service Manual Direction: Fire See the primary purposes of the project. The Action management is undertaken to ensure the Alternative would be in alignment with Manual Direction. The protection of resources and other values No Action Alternative would maintain continuous fuels, as well from wildfire. as the risk for fires of high-intensity and -severity. These conditions could threaten human health, safety, resources and other values. Forest Service Manual Direction: Fire See Table 15 for Forest Plan Consistency. Prescribed fire is management will utilize prescribed and utilized to reduce fire severity and increase ecosystem wildland fire to meet land and resource resilience to wildfire. The project is also intended to create management goals and objectives. conditions to promote the use of wildfire on lands to the west of the project and, by extension, promote wilderness management goals and objectives.

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Forest Plan Consistency Table 15: Forest Plan Consistency for Fire, Fuels, and Air Management Forest Plan Standard Project Consistency Suppression. The appropriate suppression By reducing fuel loadings, the project would support the efforts of response for Management Areas E, G, and O managers to “control” fire in the Project Area. The Action Alternative ranges from “control” to “confinement” would also enhance opportunities for successful confinement strategies. As an example, natural fuel breaks would be maintained by removing encroaching conifers. Suppression. The appropriate suppression The Action Alternative would support actions to aggressively response for Management Area H is aggressive “control” fire in the project by reducing fuels. Breaks in fuel “control.” continuity, created by the project, would increase the effectiveness of aggressive management actions, providing areas of lighter fuel for direct attack, line location, retardant use, etc. The Proposed Action would also create safer conditions for these actions. For example, escape routes and safety zones would be more accessible following treatments. Prescribed Fire with planned ignitions. The The Action Alternative is a proposal to use prescribed fire to “address Forest Plan directs that in Management Areas E, fuel accumulation and continuity in the Project Area.” The No Action G, H, and O, “Prescribed fire with planned Alternative would not use prescribed fire activities to reduce fuels. ignitions will be used... for the enhancement and maintenance of resources. Prescribed Fire with unplanned ignitions. The Action Alternative proposes to reduce fuels within the Project Within the Project Area, the Forest Plan allows Area. This will increase opportunities to manage unplanned ignitions for prescribed fire with unplanned ignitions in in the portions of the Scapegoat Wilderness that lie due west of the Management Areas E and G, when included in a Project Area (by reducing the risk associated with fire exiting the Fire Management Action Plan. Currently a Fire wilderness boundary and burning through the Project Area toward Management Action Plan does not exist for the adjacent public and private lands). Project Area. Lands immediately to the west of the Project Area are designated wilderness (Management Area P). A Fire Management Action Plan for unplanned ignitions is in effect for these lands. Fire Management Direction: “Prescribe fire to See the project’s purpose statement and the Environmental maintain healthy and dynamically stable Assessments Vegetation Report. To paraphrase the purpose ecosystems that are inherently fire dependent.” statement, “the project aims to create a more diverse landscape that is resilient to fire, and increase flexibility to allow lightning-caused wildfire to play its natural role.” Fire Management Direction: “Consider fire See the project’s purpose statement and the Environmental ecology implications when applying prescribed Assessments Vegetation Report. fire.” Fire Management Direction: “Reduce the cost The Action Alternative is an attempt to integrate prescribed fire of pre-suppression and suppression activities by treatments on non-wilderness lands, with wildland fire use in integrating the total fire management program.” wilderness (i.e. by creating fuels conditions outside wilderness that complement wildfire management in wilderness). In addition,

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Forest Plan Standard Project Consistency prescribed fire treatments in the Action Alternative would create fuel conditions that are safer for firefighters and the public. Fire Management Direction: “Fire should be The No-Action Alternative would maintain hazardous fuel loadings at permitted in wilderness to the maximum the Forest/Private Land interface. Permitting fires to burn in the possible.” Scapegoat Wilderness would pose an increasing threat to public and private lands, to private property, and to human life. With increased risk, it is probable that few fires would be permitted to burn in wilderness lands to the west of the Project Area. Conversely, following the Action Alternative would lower the risk of permitting fire on lands immediately to the west of the Project Area. Fire Management Direction: “Prescribed fire See sections of this report dealing with air quality. All prescribed objectives will be met within the constraints burning proposed in the Action Alternative will be subject to established by Montana State Airshed Group’s management and approval by the Montana/Idaho Airshed Group. Memorandum of Understanding.” Additionally, modelling and monitoring of air quality impacts of smoke emissions suggest that the proposed burns can be completed without exceeding air quality standards. Fire Management Direction: “Gain greater The Elk Smith project has gone through scoping. Additional public public involvement, understanding, and approval involvement will occur in compliance with the Forest Plan, National of our fire management practices.” Environmental Policy Act, and National Forest Management Act.

Consistency with Purpose and Need The purpose of the Elk Smith Project is provided on the second page of this report. The project has four primary purposes that are directly related to fire and fuels. These four purposes are addressed in the following table. In addition, the project has six secondary purposes. These secondary purposes are directly tied to the following resource areas: cultural, wildlife, vegetation, and fisheries. Please refer to the specialist reports for these resource areas for a summary of benefits of secondary purposes. Table 16:Consistency with Purpose and Need

Purpose and Need Summary of Benefits The Action Alternative is consistent with the purpose and need, by Reduce the future risk of high-intensity, high- implementing the activities described in the Elk Smith Treatment severity wildfire within the Project Area by Units. The No Action Alternative is not consistent with the Purpose interrupting the continuity of fuels, specifically and Need as it would maintain continuity and loading of fuels in the continuous stands of lodgepole pine regeneration Project Area and, by extension, maintain the risk of high-severity and heavy loadings of larger fuels. wildfire. The Action Alternative is consistent with this purpose and need. Implementing treatments associated with the Action Alternative will increase opportunities for managers to control or confine fires Reduce the potential for wildfire to spread into resulting from ignitions within the Project Area, or from fires that the Benchmark corridor to the north and onto private land east of the National Forest spread into the Project Area from lands to the west. In addition, treating fuels within the Project Area may increase opportunities to boundary. manage fire for resource benefit within the Scapegoat Wilderness. This, in turn, could reduce fuel continuity and loadings within the wilderness and, over time, reduce the overall size of wilderness fires

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Purpose and Need Summary of Benefits (reducing the potential for large “catastrophic fires” that could spread from the Scapegoat into the Benchmark corridor and onto private land to the east). The No Action Alternative is inconsistent with this Purpose and Need. Taking no action would maintain continuity and loading of fuel in the Project Area. In addition, opportunities to manage fires for resource benefit on lands to the west of the Project Area would be limited. This would likely result in increased continuity and fuel loading in the wilderness, potentially resulting in large landscape fires that could spread through the Project Area into the Benchmark corridor and/or to private land east of the National Forest boundary. The Action Alternative is consistent with this purpose. See table 1 of the fuels specialist report, “Elk Smith Proposed Treatments.” The No Create a more diverse landscape that is more Action Alternative is inconsistent with this purpose. No treatments resilient to fire by retaining mature areas, would reduce fuels in dense areas, and conifers would continue to disrupting dense areas, and enhancing or re- encroach on openings. The landscape would tend toward creating grassland openings. homogeneity. The potential for large, stand-replacing, wildfires would remain consistent, or increase. Exposure of mature conifer to strand-replacing fire would increase. The Action Alternative is consistent with this purpose. This alternative would disrupt fuel continuity and reduce fuel loading in the vicinity of the Benchmark Road, on the north, and at the interface between National Forest Land with lands of other ownership on the Increase flexibility to allow lightning-caused east (including private lands). These treatments could reduce the risk wildfire to play its natural role in adjacent and of managing fire for resource benefit in the Scapegoat Wilderness. nearby lands included in the Scapegoat Without fuel modifications in the Project Area, allowing fires to burn Wilderness. naturally on lands to the west of the Project Area could prove too risky, resulting in the decision to aggressively suppress most starts in this portion of the Scapegoat. In addition, the treatment would complement the South Fork Sun Burn Project in producing conditions where wildland fires in the Wilderness can be successfully managed.

Forest Vegetation Report

Methodology

Spatial & Temporal Scale The geographic analysis and cumulative effects area for this proposal is defined as the project boundary. Temporally speaking, short-term effects are defined as five to 20 years. This time period includes direct, first order fire effects as well as the delayed, indirect effects from burning. Long-term effects are considered at the 100 to 150 year timeframe. This time period represents the average rotation age of lodgepole pine (Barrett 1995; Tackle 1961; USDA Forest Service 1965).

Sources, Methods, and Assumptions Existing forest condition information was derived from Region 1 Existing Vegetation Map Product (R1 VMAP version 14), National Forest Inventory and Analysis (FIA) plot data, forest-level Forest Inventory

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and Analysis intensified grid plot data collected 2012 and 2013, and 2013 field observations. Region 1 Existing Vegetation Map Product is a satellite imagery-based map product produced by the Northern Region Geospatial staff that contains basic vegetation information for every acre on the Helena-Lewis and Clark National Forest. Polygons are based on similar vegetation characteristics. Each polygon contains current lifeform, canopy cover, vegetation type, and size class information. Region 1 Vegetation Map Product dominant vegetation type at 40 percent plurality (basal area or trees per acre) and tree size and canopy categories were utilized to determine pre- and post-treatment unit and project area conditions. Post-treatment conditions also used fire modeling results concerning potential areas within treatment units that would be burned. The National and forest-level Forest Inventory and Analysis data for the project area was combined, post-processed, and placed in a summary database to produce statistically valid project area attributes. Forest-level Forest Inventory and Analysis data stored in the Forest Service Vegetation Database was used in the Forest Vegetation Simulator to project tree growth, size, and density. The Fire and Fuels Extension of Forest Vegetation Simulator was used to project vegetation and fuel load change following prescribed fire. Analysis methodology is documented in the project record. Analysis Measures: • Acres by forest type, size class, and approximate density • Insect susceptibility/hazard rating

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

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Figure 4: Landscape View of Project Area

Vegetation conditions on the remaining 74 percent (17,844 acres) of the project area were created from the 1988 Canyon Creek wildfire. Lodgepole pine, the dominant vegetation type (50 percent of project area, 65 percent of treatment units), has established with densities from 20 to over 27,000 stems per acre (averages around 2,100 stems). Within overly-dense stands, growth stagnation can be expected (USDA Forest Service 1983). Trees generally produce reduced height, diameter, and overall vigor compared to those in stands supporting lower densities (less than 400 tons per acre). At the other end of the spectrum, once forested areas now support very low densities or no trees. Table 2 of the vegetation specialist report depicts stand conditions in the project area and treatment units based on Region 1 Vegetation Map Product attributes, and Appendix A contains an aerial image. About 65 percent of the treatment units is classified in the 0 to 4.9 inch diameter category. A review of imagery (NAIP and Google Earth) in comparison to the Region 1 Vegetation Map Product 0 to 4.9 inch class indicates that 8 percent to 47 percent of the acres (average of 22 percent) in this size class are actually in a non-stocked condition (Appendix C). Non-stocked acres that were once forested (based on existing logs and snags) may have a healthy herbaceous and/or shrub component with minimal to no conifer establishment. Although trees can start producing viable seed in open-faced cones as early as five to 10 years of age, serotinous cones do not generally begin until after age 30 (USDA Forest Service 1965; USDA Forest Service 1983). Seedlings and saplings within the Canyon Creek fire perimeter are less than 28 years old, and cone serotiny is generally less than 30 percent. Quaking aspen is present along drainages and in moist swales throughout the project area with heights up to 20 feet. Small areas of unburned, mature vegetation are scattered throughout. Mature stands are composed of multi-story, mixed conifer in moist areas and nearly pure, even-age lodgepole on cold, dry sites. In many areas, mountain pine beetle has recently killed mature lodgepole. Limber and whitebark pine are under-represented as a dominant vegetation type in the 2014 version of Region 1Vegetation Map Product compared to field observations.

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Table 17: Existing condition in the project area and proposed treatment units based on Region 1 Vegetation Map Product. The top numbers represent the project area and the bottom numbers the treatment units.

Dominance Acres By Size Class Total Acres Type (40% 5.0 to 10 to 15 to N/A 0 to 4.9” & (Percent) Plurality) 9.9” 14.9” 19.9” 5 5 (0.02) Water 1 1 1,803 1,803 (7.4) Grass/Shrub 990 990 (9.6)

Sparse 1,664 1,664 (6.8) Vegetation 200 200 (1.9) 409 409 (1.6) Aspen 190 190 (1.8) 40 2 42 (0.2) Limber Pine 18 18 (0.2) 538 3,251 2,791 406 6,987 (29) Douglas-fir 260 868 749 234 2,111 (20) 10,995 821 39 1 11,856 (49) Lodgepole Pine 6,438 236 25 1 6,701 (65) Engelmann 22 34 30 86 (0.3) Spruce 2 10 4 16 (0.2) Whitebark Pine 6 57 9 71 (0.3) 80 1,090 128 1,298 (5.3) Subalpine Fir 11 75 18 104 (1.0) Totals 3,881 11,659 5,243 3,001 437 (1.8) 24,221 (16) (48) (22) (12) 239 (2) 10,329 1,381 6,727 1,181 802 (8) (13) (65) (11)

Plot data collected in the project area shows the following general habitat types: Douglas-fir/snowberry, Douglas-fir/pinegrass, subalpine fir/grouse whortleberry, subalpine fir/elk sedge, whitebark pine- subalpine fir, lodgepole/twinflower, and lodgepole/pinegrass. With the exception of two habitat types, the project area generally falls within Fire Groups 6 and 7 (Fischer and Clayton 1983). Even though it has been 28 years since the fire, standing snags are abundant with variable density across the project area (Figure 5 – Post-1988 Canyon Creek fire stand containing 134 square feet of basal area per acre in lodgepole pine snags five to 13 inches diameter). Snag diameters are generally less than 13 inches. Downfall has created surface fuel loads between 23 and 88 tons per acre.

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Figure 5 Post-1988 Canyon Creek fire stand

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

Environmental Benefits and Consequences

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

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

Direct and Indirect Effects Plot data collected in the project area in 2012 and 2013 was processed through the Forest Vegetation Simulator to simulate growth over the next 120 years. Simulation results are available in the Project Record. Treatment units support a diversity of lodgepole pine stand densities. In some areas, the 1988 fire removed the seed source and conifer regeneration is extremely low. Exposure of these sites with often

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relatively shallow soil to drought, wind, or high temperatures may also have contributed to poor regeneration success (USDA Forest Service 1983; Lotan et al. 1985). These areas are dependent upon seed dispersal from adjacent cone-bearing trees. An open rather than serotinous cone seed source are required for lodgepole to disperse. Because lodgepole and Douglas-fir seed generally disperses no greater than 200 and 330 feet, respectively, from a seed source (USDA Forest Service 1965), stand regeneration will be gradual over the next 30 to 60 years. These areas may develop a more uneven-age distribution based on the regeneration timeframe (Kashian et al. 2005). In dense, even-age, lodgepole seedling and sapling stands, density-dependent mortality or self-thinning is the most significant process in stand development (Kashian et al. 2005). Dense stands will self-thin at a faster rate than less dense stands as the maximum site capacity is met. Forest Vegetation Simulator simulations indicated a 20 percent to 40 percent density reduction in moderately dense stands and up to 90 percent reduction in excessively dense stands. As trees die, resources would be allocated to residual stems which, in turn, would improve tree health and productivity. Without disturbance or treatment, this process will cause stands to converge in the future at a similar stand structure which would reduce overall landscape heterogeneity (Kashian et al. 2005). Shade intolerant species such as Douglas-fir and subalpine fir may also establish in lodgepole stands as a result of succession (Lotan et al. 1985). Growth and stand development in extremely dense (greater than 10,000 trees per acre), “dog-hair” thickets may stagnate. If not, self-thinning would naturally reduce stand density to a sustainable level. According to the summary database of available Forest Inventory and Analysis and intensified Forest Inventory and Analysis plot data, there is an average of 22 dead trees per acre greater than 10 inches diameter in the project area. Within the next several decades, these trees would fall adding to the existing high surface fuel load. Fire hazard in the project area is currently high, and would remain so for the next decade, as the dense seedling and sapling stands intermix with the high fuel load. As the trees grow in height, canopies lift, and surface fuel decays over the next 60 years, fire hazard would decline (Lotan et al. 1985). Aspen clones currently present in Units 1, 2, 6, 7, 8, 9, 11, 12, and 13 would develop into vigorous, mature clones. Without a disturbance event, such as fire, within the next 30 to 40 years, Douglas-fir and lodgepole establishment and growth in and around the clones would lead to increased competition, decreased aspen vigor and reproduction, and eventual reduction in clone size. Small clones adjacent to conifer are more susceptible to succession than larger, pure aspen clones. Appendix D of the vegetation specialist report shows maps of potential host species basal area loss from mountain pine beetle, Douglas-fir beetle, and western spruce budworm from 2013 through 2027. These maps indicate that short-term mortality can be expected to occur in mature timber in the northern portion of the project area and around Units 9 through12. These areas would continue to be susceptible to insect activity as long as they meet the appropriate stand characteristics (see USDA Forest Service 2011). Little to no insect activity is expected to occur in the seedling and sapling component of the treatment units. Simulated growth based on Forest Vegetation Simulator indicates that near the end of the rotation, most lodgepole pine stands will have a high hazard rating for mountain pine beetle. Sparsely stocked areas would have a low mountain pine beetle susceptibility due to low basal area (20 to 50 square feet per acre) of the trees that are generally greater than 7 inches diameter. Douglas-fir bark beetle hazard would be low to moderate in the Canyon Creek fire footprint since a majority of Douglas-fir diameters would be less than 14 inches. Given the relatively homogeneous forest conditions across the project area, there would be no barriers to bark beetle movement if an outbreak were to occur in the future. Western spruce budworm is currently active in Douglas-fir stands. Defoliation is predicted to occur in Douglas-fir stands, especially those with multiple canopy layers, whenever population outbreaks occur.

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

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

Direct and Indirect Effects A prescribed burn, using parameters similar to those used in the Fire and Fuels analysis, was simulated in Forest Vegetation Simulator with the Fire and Fuels Extension to determine how vegetation and fuel conditions would change compared to the No Action alternative. Because the model does not contain a spatial component, simulation results do not reflect variability in fire movement through and effects to the diverse vegetation (e.g. low-intensity ground fire vs. high-intensity stand-replacement fire). The information provided below is a generalization of fire effects in the treatment units. Simulation attributes and results are provided in the Project Record. Slashing/conifer felling was not modeled due to its site- specific application based on stand structure, species composition, and requirements for fire movement. The existing landscape supports a diversity of stand densities which, in turn, influences tree size and cone abundance. High density stands support smaller diameter trees compared to less dense stands due to competition for resources. The type of cone (open or serotinous) is also variable across the project area. Trees established immediately after the 1988 fire are beginning to produce serotinous cones (less than 30 percent serotiny). According to Turner and others (2007), there is a positive relationship between tree diameter and the frequency and number of cones available per tree. Cone production in high density regeneration stands, therefore, is expected to be lowest due to small stem diameters. Sparsely treed areas would also produce few cones. Regardless of stem diameter or cone production capacity, small, young trees are unable to produce the abundance of cones witnessed in mature lodgepole. Therefore, post- treatment regeneration would be at a rate less than that experienced after the Canyon Creek fire (Lotan et al. 1985). Areas supporting serotinous cones should regenerate within a few year of the burn. Areas with open cones may have a regeneration lag, depending upon fire-created opening size, due to the gradual movement of seed (dispersal distance less than 200 feet) from the adjacent seed source. Application of prescribed fire in locations with poor post-Canyon Creek regeneration establishment would increase the time needed and decrease the likelihood of these areas returning to a forested condition if there is not an immediate seed source. Douglas-fir regeneration, primarily in Units 3, 4, and 6, would rely on wind-dispersed seed (dispersal distance less than 330 feet) to recolonize the burn. Because mature, cone-bearing trees are present at low quantities within or adjacent to treatment units, establishment of Douglas-fir would be slow (Hatch and Lotan 1969; Shearer 1981). Saplings greater than 15 years old that survive the prescribed burn could contribute seed to the recolonization effort. However, if sites are warm and dry and lodgepole is present in the pre-burn stand, lodgepole could begin to dominate the site, especially if future burns continue to remove the Douglas-fir seed source (Crane et al. 1983; Hatch and Lotan 1969; Shearer 1981). According to the Forest Vegetation Simulator simulation, prescribed fire is predicted to kill 20 percent to 60 percent of the trees in treatment units. Tree mortality may be as isolated trees or patches up to 100 acres in size. Within the first decade, a flush of regeneration occurred on the bare mineral soil seedbed which increased stand densities. At the end of the 120-year simulation, tree per acre densities were similar or up to 20 percent less than predicted with the No Action alternative. Basal area reduction as

62 Environmental Assessment generally 10 percent to 20 percent, but may be as high as 50 percent in some areas. With reduced competition, trees were able to produce larger diameters (one to two inches). The overall impact to density, basal area, and tree size in the units would be a combination of the predicted post-burn results and those described for forest development under the No Action alternative. Implementation of stand- replacement fire in patches of 20 to 100 acres over 30 percent to 50 percent of the treatment unit acres would increase the landscape’s overall size- and age-class diversity in the short term. However, as explained in the No Action alternative, landscape heterogeneity would gradually decline over time as stand structure converges to a similar condition. Shade intolerant species such as Douglas-fir and subalpine fir may gradually establish in lodgepole dominated stands due to succession. Based on the simulation, prescribed burning consumed between 25 percent and 60 percent of the existing coarse woody debris, substantially reducing the surface fuel load. In the first decade, fuel load slightly increased as fire-caused tree mortality and snag downfall was added to the forest floor. However, a steady decline in tonnage was predicted such that at the end of the simulation coarse woody debris was either the same or up to 40 percent reduced compared to the no action alternative. The actual placement of fire during implementation, which would target areas of heavy surface fuel accumulation, would determine the changes in coarse woody debris over the treatment area. Implementation of the prescribed burn would assist with surface fuel decay rates which, in turn, would reduce fire hazard in the young forest setting. Felling young conifers in and around aspen stems or clones in Units 1, 2, 7, 9, 11, and 12 would reduce current and future conifer competition and allow the clone to persist in a healthy state longer than untreated clones. Prescribed fire would further reduce competition and stimulate aspen suckering to create an additional age class in the clone. Aspen in Units 6, 8, and 13 would benefit from conifer reduction only if aerially ignited fire moved into or adjacent to the clone. The burn plan should be written such that fire would move through this valuable resource. Based on Forest Vegetation Simulator -simulated growth after the prescribed burn, most lodgepole pine stands near the end of the rotation will have a moderate to high hazard rating for mountain pine beetle. Sparsely stocked areas would have a low mountain pine beetle susceptibility due to low basal area (20 to 50 square feet per acre) of the trees that are generally greater than 7 inches diameter. Douglas-fir within the 1988 Canyon Creek fire footprint would have variable hazard ratings for Douglas-fir beetle, but the general trend is moderate hazard. On productive sites Douglas-fir beetle hazard may start trending toward high. Overall, lower stand densities in Douglas-fir stands would keep the hazard low to moderate. Implementation of the project would not create a barrier to bark beetle movement through the project area should an outbreak occur in the future. Western spruce budworm defoliation, similar to Alternative 1, would continue to be an issue in areas containing multi-storied stands during outbreak years.

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

Statutory and Regulatory Consistency Table 18 summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

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Table 18: Summary of Statutory and Regulatory Consistency

Regulatory Requirement Project Consistency 1974 Forest and Rangeland Renewable Resources Management Area O is within the regulated timber base. Lands Planning Act, as amended by the 1976 National classified as commercial (LSC = 500) within this management Forest Management Act: It is the policy of area would be considered as producing timber suitable for Congress that all forested lands in the National harvest. Suitable timber is available on about 523 acres in Forest System be maintained in appropriate forest treatment units 9, 10, 11, 12, and 13. A majority of suitable land cover with species of trees, degree of stocking, rate in Unit 12 occurs as mature timber that would not be treated with of growth, and conditions of stand designed to the proposed action alternative. Post-treatment stocking surveys secure the maximum benefits of multiple use would be completed on these acres to determine regeneration sustained yield management in accordance with land condition (species composition, density, growth rate, and overall management plans. A report shall be compiled health). Natural regeneration certification would be evaluated annually, based on examinations, of all lands in the based on the silvicultural prescriptions designed to meet National Forest System where objectives of land management objectives. Walk-through surveys would also occur management plans indicate the need to reforest areas on a sample of non-suitable lands to determine natural that have been cut-over or otherwise denuded or regeneration outcome following treatment. Tree species deforested. Treated lands shall be examined after currently present in treatment units should naturally regenerate the first and third growing seasons and certified as to following treatment. Stand densities would be variable and stocking rate, growth rate, and other pertinent generally less than pre-treatment conditions. However, a measures. Lands not certified would be returned to forested condition would still exist following implementation of the backlog and scheduled for prompt treatment. the selected alternative. 1974 Forest and Rangeland Renewable Resources Lands classified as commercial (LSC = 500) within Management Planning Act, as amended by the 1976 National Areas O and R would be part of the Forest’s suitable timber base. Forest Management Act: Forest Plans will be Because classification was incomplete for the project area, a developed to identify the suitability of lands for classification exercise using the best available data was resource management; provide for the diversity of completed in 2014 to facilitate analysis of this project. Although plant and animal communities based on the Management Area O is spatially mapped, there is no spatial layer suitability and capability of land areas to meet available for Management Area R. The land suitability multiple-use objectives; and where appropriate, to classification information is part of the spatial (geographic the degree practicable, preserve the diversity of tree information system) project record. Suitable timber in species similar to that existing in the planning area. Management Area O was calculated to be 900 and 523 acres in the project area and treatment units, respectively. Commercial land is denoted on 6,778 and 2,997 acres across the project area and treatment units. Tree species currently present in the project area should naturally regenerate following treatment.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards and management area direction relevant to forest vegetation is available in the Project Record.

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Sensitive Plant Report and Biological Evaluation

Methodology

Spatial & Temporal Scale The geographic analysis area for direct, indirect, and cumulative effects for this proposal is the project boundary since potential impacts are minimal or beneficial. The temporal length of this analysis is 1 to 10 years because it reflects immediate effect of the prescribed fire on sensitive plants and the time needed for post-fire whitebark germination and seedling survival (Tomback et al. 1993).

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

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

Sparrow’s-Egg Lady’s Slipper Sparrow’s-egg lady’s-slipper is known to occur in the northwest corner of Montana on the Lewis and Clark, Flathead, and Kootenai National Forests (BONAP 2016; MNHP 2016b; Shelly 1988a). Occurrences on the Rocky Mountain Ranger District are located in Blacktail Gulch, Green Timber Basin, Dry Fork Lange Creek, Leavitt Creek, North Fork Birch Creek, Clary Coulee, and Straight Creek with population size between 14 and 100 plants. Sparrow’s-egg lady’s-slipper grows in moist, mossy, seepage areas; riparian zones; and in ecotonal margins of sphagnum bogs, often in full or partial shade of conifers. Although spruce is the preferred habitat, it will grow in association with lodgepole pine (MNHP 2016b; Shelly 1988a). In a monitoring summary written by Dana Fields (1993), it was noted that sparrow’s-egg lady’s-slipper is “[o]ne of the rarest orchids in the Front Range, having a very narrow range of habitat requirements. These requirements include limestone substrate, cool sites at mid-elevations, seeps or springs, a moderate amount of rotting wood on the forest floor, and at least partial shade. Even where these requirements are met the plant is uncommon.” The most important feature at every site appears to be semi-permanent water seepage near the surface. According to the Montana Natural Heritage Program,

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there are 51 occurrences (MNHP 2016b; Shelly 1988a). Round-leaved orchis, small yellow lady’s- slipper, and sparrow’s-egg lady’s-slipper often co-occur. However, sparrow’s egg lady’s-slipper has a narrower range of habitat (USDA Forest Service 2016; Shelly 1988a; Vanderhorst 1996). Threats to the species include impediment or reduction of groundwater flow, noxious weed establishment, grazing, road construction, and timber harvest. The main threat to the species appears to be from potential hydrologic changes at population sites (MNHP 2016b; Vanderhorst 1996). In 2013, approximately 10 sparrow’s-egg lady’s-slipper plants were located along the bank of Cyanide Creek between Units 12 and 14. Cyanide Creek trail 257 crosses the drainage at this location. Plants were growing in the densely stocked willow drainage bottom immediately adjacent to flowing water at about 5,350 feet elevation. The drainage was unburned during the 1988 Canyon Creek fire. Slopes adjacent to the drainage contain seedling and sapling lodgepole pine and a small patch of unburned, mature Douglas-fir. The population is about 55 feet and 100 feet away from the edge of Unit 12 and 14, respectively.

Lackschewitz’ Fleabane Lackschewitz’ fleabane is a Montana endemic known to occur on the Helena - Lewis and Clark, Flathead, and Beaverhead-Deerlodge National Forests (BONAP 2016; MNHP 2016b). Based on the Montana Natural Heritage Program (2016b), Montana currently supports about 37 occurrences with a majority (73 percent) located on the Helena - Lewis and Clark National Forest. Populations are documented at Crown Mountain, Steamboat Lookout, Mount Wright, Headquarters Creek Pass, Sock Lake, Corrugate Ridge, Mount Patrick Gass, Our Lake, Teton Ski Area Peak, Washboard Reef, and Volcano Reef (Heidel 1993; MNHP 2016a). Fleabane grows exclusively in exposed, windy, alpine settings with water-retaining calcareous soil derived from a dolomite substrate (Heidel 1993). According to Heidel (1993), Lackschewitz’ fleabane “grows on midslope settings often between scree and toeslope turf, or on gentle but highly exposed slope crests and ridges.” Fleabane generally grows in association with but not among mats of white dryas, kinnikinnick (Arctostaphylos uva-ursi), and curly sedge (Carex rupestris). On the driest sites (barren slopes) only trace amounts of the species are present. On the wettest sites, fleabane grows in dense sedge sod with high forb diversity (Heidel 1993). Due to the species’ high elevation, alpine habitat requirements, there is a low potential for detrimental impacts from human disturbance or management actions (Heidel 1993; MNHP 2016b; Nature Serve 2016). Non-motorized trails in proximity to known populations have not posed a threat to population stability (Heidel 1993). Lackschewitz’ fleabane is known to occur at 8,400 feet elevation along the Steamboat Lookout Trail near Steamboat Mountain. The population, covering less than eight acres, is on a south-facing scree slope southwest of Unit 8. There are no other known occurrences of fleabane in the project area, and suitable habitat occurs outside of treatment units.

Whitebark Pine Whitebark pine is a long-lived species that is most commonly found as a major seral species on upper alpine sites. The average lifespan is 400 years with the oldest tree recorded near 1,300 years (Keane and Parsons 2010). At the highest forest elevations or alpine sites, whitebark persists as a climax species in a krummholz form (Keane and Parsons 2010, Tomback et al. 2001, Tomback et al. 2011). At its lower elevations, whitebark competes with lodgepole pine. The species generally occurs within a narrow elevation range (Tomback et al. 2011). Whitebark pine starts producing cones at age 30 to 60, but a quality cone crop is dependent upon good canopy volume which occurs between 125 and 250 years of age. Cone crop frequency is about every three to five years (Keane et al. 2012). Clark’s nutcracker, the primary seed dispersal mechanism for whitebark, can transport and cache seeds up to 10 kilometers (Keane and Parsons 2010; Keane et al. 2012). Fire, ranging from small and isolated to large and stand- replacing, is the primary disturbance factor in this forest community that renews the species. Mixed- severity fire, occurring at 60 to 300-year intervals, is the most common whitebark pine fire regime that creates a diverse landscape pattern favorable for whitebark establishment. In the absence of fire,

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whitebark pine is eventually replaced by shade-tolerant species (Keane and Parsons 2010; Keane et al. 2012). Based on information provided to the U.S. Fish and Wildlife Service, the major threats to whitebark pine’s survival across its distribution range are fire suppression, climate change, white pine blister rust, and mountain pine beetle (Federal Register 2011). Whitebark pine is known to occur in the project area from field observations and Region 1 VMAP. The species grows along the Scapegoat Wilderness boundary; in the Whitewater and Petty Creek area southwest of the Petty Ford Creek National Recreation Trail 244; and in Township 18 North, Range 8 West, Sections 2 through 5 around Horse Mountain. Although in many locations whitebark and limber pine habitat is defined by elevation, these five-needle species can share the same habitat on the Rocky Mountain Front. Limber pine is typically found on limestone soils of the entisol soil order, while whitebark typically grows on inceptisol soils (USDA Forest Service 1965). Based on elevation, soils information, and field review, it has been determined that the vast majority of five-needle pine seedlings and saplings growing within treatment units is limber pine. However, without cones, pollen, or an adjacent mature stand, it is very difficult to distinguish between the species. Five-needle pine density is very low with less than 10 trees per acre present in isolated areas.

Round-Leaved Orchis In Montana, round-leaved orchis occurrences have been noted in the Rocky Mountain Front, Bob Marshall Wilderness Complex, Swan Valley, and the northwest corner of the state. On the Rocky Mountain Front, it generally occurs around mossy seeps, sphagnum bogs, ponds, or along streams in wet to moist spruce forests where there is at least partial shade from the overstory (MNHP 2016a; Schassberger 1988; Shelly 1988b). One of the most important features at almost all sites on the Helena - Lewis and Clark appears to be semi-permanent water seepage near the surface which protects the plants roots (Shelly 1988b). Sparrow’s-egg lady’s-slipper may be found in association with round-leaved orchis. Threats to the species include grazing, recreation activities, timber harvesting, road construction, and wildfire. Although information is lacking concerning plant response to activities and disturbances, round-leaved orchis’ specialized habitat requirements indicate that it would not respond favorably to activities that alter the site’s water regime or overstory (Schassberger 1988). Although potentially suitable habitat may occur in the project area, no plants were found during field surveys.

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

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Noxious weed species such as houndstongue (Cynoglossum officinale), leafy spurge (Euphorbia esula), spotted knapweed (Centauria maculosa), Canada thistle (Cirsium arvense), and Dalmatian toadflax (Linaria dalmatica) are documented along Elk Creek in or adjacent to treatment units 7, 9, 11, and 12 (Enterprise Data Warehouse). The Rocky Mountain Ranger District has an active invasive species education, prevention, and control program to reduce the impacts of invasive plant species.

Environmental Benefits and Consequences

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

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

Direct and Indirect Effects Under the No Action Alternative, sensitive plants would continue to grow where they are currently found. The greatest threat to the identified sparrow’s-egg lady’s-slipper population would be a shift in the stream channel that could remove the plant. Although stream channels are dynamic, no change in the system has been predicted at this time. A similar threat would occur for potential yellow lady’s-slipper and round- leaved orchis habitat. These species would generally be protected from wildfire given their wet, riparian habitat preferences. Lackschewitz’s fleabane’s preference for high elevation, exposed, typically talus habitat leaves it generally immune to impacts from natural processes, such as fire. The greatest threat to the population is from foot and equestrian use of the Steamboat Lookout Trail 257. However, population monitoring information (Heidel 1993) indicates that trail use has not previously impacted fleabane populations on the Rocky Mountain Front. Wildfire, mountain pine beetle, and white pine blister rust would continue to threaten whitebark pine in the project area. Although wildfire could directly and indirectly kill trees, it also has the ability to create favorable sites for seed caching if adequate mature, seed-bearing whitebark (20 to 50 trees per acre) are within 10 miles of the fire (Keane et al. 2012). Mountain pine beetle activity has not been a substantial source of pine mortality since 2009 and 2010. However, endemic activity could kill an incidental quantity of mature (greater than 5 inches diameter-at-breast-height) pine each year. White pine blister rust infection would continue to damage and kill whitebark of all sizes. Implementation of the No Action Alternative would have no impact upon sensitive plant species in treatment units. Insects and disease may lead to the decline of whitebark pine, but wildfire and the creation of caching sites could benefit the species if cone-bearing trees are present.

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

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

Direct and Indirect Effects Implementation of the project should have minimal negative effects for sensitive plant species. The project is designed (Preliminary Analysis, Appendix C Project Design Features) to have a no-ignition buffer within 200 feet of streams to preserve riparian vegetation and maintain a vegetated buffer. In addition, a 50- to 100-foot (slope dependent) buffer around wetlands and springs would provide additional protection of undiscovered sparrow’s-egg and yellow lady’s-slipper and round-leaved orchis populations or potentially suitable habitat. Although fire may back into these buffers, fire intensity and area impacted should be minimal. Neither tree slashing nor prescribed fire would alter hydrologic processes, the greatest threat to these species. The sparrow’s-egg lady’s-slipper population is surrounded by a variety of vegetation conditions. The population itself is growing in relatively dense, shrubby riparian vegetation adjacent to flowing water. To the west (east side of Unit 12), the hillside is generally sparsely stocked with conifer which would not support a high-intensity fire moving into the riparian area. Mature timber and heavy regeneration occur to the south (northwest side of Unit 14) of the population. Treatments are designed to avoid ignition within mature (greater than 8 inches diameter-at-breast-height) conifer stands greater than five acres. Therefore, ignition would not occur in Unit 14 closest to the lady’s-slipper population, and the defined treatment unit boundary should keep fire away from the population. Incidental whitebark seedlings and saplings may be killed during burning, however, impact to the overall whitebark population in the project area would be limited in scope. Implementation of the project should have no impact upon mature, cone-bearing whitebark individuals or stands since these resources are located outside of treatment units. Seedlings and saplings may be removed if they are within target burn areas which may vary during implementation based on vegetation condition, wind direction, wind speed, moisture, and other variable parameters at the time of the burn. Mixed-severity or stand-replacement prescribed fire would remove competing vegetation (dense lodgepole) and create favorable nutcracker cone caching sites for whitebark seed “[s]ince nutcrackers often prefer open sites with many visual cues for seed caching (Keane et al. 2012).” The availability of cones and subsequent regeneration, however, is dependent upon cone productivity in the face of blister rust damage and mortality (need 20 to 50 cone- bearing trees per acre to provide a good seed source) and nutcrackers reclaiming cone caches (Keane and Pearsons 2010; Keane et al. 2012). Although whitebark should germinate within the first one to two years after the fire, germination may be delayed for five to seven years (Tomback et al. 1993). Lodgepole regeneration may directly compete for resources with the more slow-growing whitebark depending upon the post-fire regeneration distribution. Lackschewitz’ fleabane occupies a site at least 1,500 feet upslope from the northern boundary of Unit 8. Due to its high elevation, exposed habitat preference between scree and toeslope turf, there is no potential for application of fire in Unit 8 to move into fleabane’s occupied habitat. Implementation of the project would have no impact upon Lackschewitz’ fleabane. Invasive (noxious) plants are strong competitors with native vegetation and are most likely to establish in disturbed locations. Fire has the potential to create bare soil favorable for rapid noxious weed establishment. Field crews and their associated equipment also have the ability to transport noxious weed seed and plant material into disturbed areas, especially where weed seed sources are readily available. Noxious weed establishment and the associated competition can have a long-term negative effect on sensitive plants and potential sensitive plant habitat. Noxious weeds do not currently threaten sensitive plant populations in the project area. Implementation of project design features, such as inspecting and

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disposing of all weed seed and plant parts found on crew clothing and equipment and pre-treating weed populations along travel routes used to access treatment units (Appendix C), should substantially reduce or eliminate movement of noxious weeds into sensitive plant habitat.

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

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

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

Table 19: Summary of Statutory and Regulatory Consistency Regulatory Requirement Project Consistency Forest Service Manual – 2670.32: (1) Review programs and activities as part of This report constitutes a biological evaluation for sensitive the National Environmental Policy Act of 1969 plant species. Although implementation of the project may process through a biological evaluation to cause incidental loss of whitebark pine seedlings and determine their potential effect on sensitive saplings, there would be an overall beneficial impact to the species. species within the project area as favorable nutcracker (2) Avoid or minimize impacts to species whose cone caching sites are created. Implementation of the viability has been identified as a concern. project would have no impact upon the other designated (3) Analyze, if impacts cannot be avoided, the sensitive plant species. significance of potential adverse effects on the population or its habitat within the area of concern and on the species as a whole. Forest Service Manual FSM 2672.41: Ensure Although implementation of the project may cause that Forest Service actions do not contribute to incidental loss of whitebark pine seedlings and saplings, loss of viability of any native or desired non- there would be an overall beneficial impact to the species native plant or contribute to trends toward within the project area as favorable nutcracker cone Federal listing of any species. caching sites are created. Implementation of the project would have no impact upon the other designated sensitive plant species.

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

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Range Report

Methodology

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

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

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

Environmental Benefits and Consequences

Past, Present, and Reasonably Foreseeable Future activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available Appendix E of the preliminary analysis document. Activities which may have a cumulative effect are described below. 1. Wildfire 2. Personal Use Forest Products (firewood, Christmas trees, etc.) 3. Noxious Weed Treatment 4. Road Access and maintenance 5. Recreational use (fishing, hiking, hunting, dispersed camping, etc.) 6. Prescribed fire/fuels reduction 7. Timber harvest on adjacent private lands

No Action Alternative Alternative 1 proposes no actions that are contained in either action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Alternative 1 provides a baseline for comparison of environmental consequences of Alternatives 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

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

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

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

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

Forest Plan Consistency Site specific management direction for the allotments within the project area is provided in the Sun Canyon Range Analysis, June 1997. The Sun Canyon Range Analysis was prepared and implemented to meet the Lewis and Clark Forest’s Land Management Plan. Noxious Weed Report

Methodology

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

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

Existing Condition There is 102.9 acres of inventoried noxious weeds within the Elk Smith project area. The vast majority of those acres are on the Elk Creek side of the project and within the Districts Administrative horse pasture. These polygons do not represent solid stands of weeds but are areas containing scattered plants. Invasive species known to occur within the project include Canada thistle (Cirsium arvense) 0.8 acres, leafy spurge (Euphorbia esula) 32.7 acres, spotted knapweed (Centaurea stoebe ssp. micranthos) 12.4 acres, Sulphur cinquefoil (Potentilla recta) 0.1 acres, oxeye daisy (Leucanthemum vulgare) 2.0 acres, Dalmation toadflax (Linaria dalmatica) 0.1 acres and Houndstongue also known as gypsy flower (Cynoglossum officinale) 54.8 acres. Inventory acres were pulled from the Natural Resource Information System (NRIS) database in the spring of 2016. Treatment of noxious weeds on lands managed by the Helena-Lewis and Clark National Forest is accomplished through the use of integrated weed management. Herbicides, biological and mechanical control methodologies are applied where appropriate. The following is total acres treated within the project area for the last five years. Treatment data was compiled from the Forest Service Activity Tracking System (FACTS) database invasive treatments (July 2016).

Table 20: Noxious Weed Treatment Year Acres Treated

2015 14.6

2014 91.6

2013 94

2012 0

2011 75

Environmental Benefits and Consequences

Past, Present, and Reasonably Foreseeable Future activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available Appendix E of this preliminary analysis. Activities which may have a cumulative effect are described below. 1. Wildfire 2. Personal Use Forest Products (firewood, Christmas trees, etc.) 3. Livestock Grazing (permitted, administrative and recreational) 4. Noxious Weed Treatment

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5. Road Access and maintenance 6. Recreational use (fishing, hiking, hunting, dispersed camping, etc.) 7. Prescribed fire/fuels reduction 8. Timber harvest on adjacent private lands

No Action Alternative Alternative 1 proposes no actions that are contained in either action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Alternative 1 provides a baseline for comparison of environmental consequences of Alternatives 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

Direct and Indirect Effects Prescribed fire and hand slashing both have the potential to cause expansion of existing noxious weeds infestations and create site conditions favorable to new infestations. However the project design criteria and resource protection measures prescribed for this project would create conditions that would limit expansion of existing infestations and help prevent new ones. If no action is taken the risk of a large fire that burns more acres and at higher severity primarily due to more severe fire effects on soils are likely in the future.

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

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

Direct and Indirect Effects The project is designed to break up continuous fuels to reduce the potential for large scale stand replacement fire as occurred in 1988. Large scale stand replacement fires would produce large areas of soils that experience high burn severity which would be more susceptible to noxious weed expansion/infestation. Implementation of prescribed fires of approximately 10 to 100 acre blocks in the spring or fall are designed to break up the continuous fuels which now exist. Burning windows are also planned to have fires which burn less intensely. Hand slashing and burning within units 9 and 11 are largely to treat and enhance aspen stands. This would have a positive effect on aspen as well as non- woody vegetation production within these stands. Increased non-woody vegetative growth within these stands would help to reduce bare ground which would make the stands more resistant to noxious weed expansion/infestation. Forage production for all large ungulates (wild and domestic) would be a temporary indirect effect of this project. Any increases in forage production would decrease in time as conifer growth and encroachment continues.

Cumulative Effects Past present and foreseeable activities number 2, 3, 5, 6 and 8 listed above all have the same effect they represent the most common activities to introduce and spread noxious weeds on the landscape. It is foreseeable that all these activities will continue within the project area. The result of implementation of

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the Elk Smith Project and the resulting improved vegetative conditions as well as reduced chance of large stand replacement fires will reduce the cumulative impact of those activities from the current conditions.

Statutory and Regulatory Consistency Table 21: Summary of Statutory and Regulatory Consistency

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

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in the project record. Forest Plan standards of specific relevance are described below. Table 22: Forest Plan Consistency for Noxious Weeds Resource

Forest Plan Standards for Noxious Weeds and Project Consistency Other Pests D-2 Noxious Weeds and other Pests (1) Develop a public information and education The Rocky Mountain District is a member of the Rocky program to emphasize practices that prevent resource Mountain Weed Roundtable which has an active public degradation and spread of noxious weeds. education component. The Forest Service supports education efforts by the Montana Weed Control Association. (2) Emphasize preventing noxious weeds by See Appendix C: Project Design Features reseeding, with desirable plant species, mineral soil exposed by Forest activities. (3) Evaluate alternatives… to determine effective Integrated weed management is practiced utilizing the best environmentally acceptable practices to control combination of chemical, biological and mechanical control. noxious weeds and other pests. (4) Identify areas where noxious weed and/or pest See. Rocky Mountain Ranger District control is needed. Special attention should be paid to: Invasive Plant Management Strategy streams, bogs, and associated riparian habitat: upland 11/17/2015 game bird nesting habitat: and any other sensitive non- target animal or habitat which may be adversely affected by spraying. (5) Annually review spray projects, in environmentally Weed treatment personnel evaluate each herbicide application sensitive areas, for opportunities to replace spraying on what is the best treatment method to utilize. Evaluations with other Integrated Pest Management methods. consider things such as pest species and habitat sensitivity as Cooperate and support basic research for biocontrol of well as risk of non-target damage. The District also works noxious weeds and other pests. with Forest Service entomologists on selecting and utilizing

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Forest Plan Standards for Noxious Weeds and Project Consistency Other Pests the best bio-control agents and making sure they are utilized in the appropriate habitat. See also: Rocky Mountain Ranger District Invasive Plant Management Strategy, November 11, 2015 in the project record. (6) Cooperate closely with other Federal and State This is accomplished through participation in the Rocky agencies, private individuals, contractors, and Mountain Front Weed Roundtable. Additionally the District permittees to control noxious weed and pest organizes and participates in numerous spray days annually. infestations.

RATING RISK ASSESSMENT FACTORS AND RISK RATING Using the Northern Region Risk Assessment Rating Procedure, this proposal would have a moderate likelihood of noxious weeds expanding within the project area because of infestations currently within the project area. The project would also receive a rating of moderate for the consequences of noxious weed establishment. When combined, these two risk assessment factors result in the project having an overall rating of moderate risk. Please see the risk assessment tool below for an explanation of ratings.

Risk Assessment Factors Factor 1

Likelihood of Undesirable Plant Species, Including Noxious Weed Species, Spreading into the Project Area:

NONE Undesirable plants, including noxious weed species not located within or immediately adjacent to the project area. Project (0) activity is not likely to result in the establishment of undesirable weed species in the project area.

Undesirable plant species present in areas adjacent to but no LOW within the project area. Project activities can be implemented (1) and prevent the spread of undesirable plants into the project area.

Undesirable plant species located immediately adjacent to or MODERATE within the project area. Project activities are likely to result in some areas becoming infested with undesirable plant species (5) even when preventative management action is followed. Control measures are essential to prevent the spread of undesirable plants or noxious weeds within the project area.

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Heavy infestations of undesirable plants are located within or immediately adjacent to the project area. Projects activities, even with preventative management actions, are likely to result in the establishment and spread of undesirable plant on disturbed HIGH site throughout much of the project area. (10)

Factor 2

Consequences of Undesirable Plant Establishment in Project Area.

LOW to None. No cumulative effects expected.

NON-EXISTENT

(1)

MODERATE Possible adverse effects on site and possible expansion of infestation within project area. Cumulative effects on native (5) plant communities are likely, but limited.

Obvious adverse effects within the project area and probable expansion of undesirable plants, including noxious weed HIGH infestations to area outside the project area. Adverse cumulative (10) effects on native plant community are probable.

Risk Rating

Step 1 Identify level of likelihood and consequences of adverse effects and assign values according to the following:

None – 0

Low – 1

Moderate – 5

High – 10

Multiply level of likelihood times consequences. Step 2

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Step 3 Use the results in Step 2 to determine Risk Rating and Action as follows:

Value Risk Rating Action

0 NONE Proceed as planned.

1-10 LOW Proceed as planned. Initiate control treatments on undesirable plant populations that get established in the area.

Develop preventative management measures for the proposed project to reduce 25 MODERATE the risk of introduction of spread of undesirable plants I the area. Preventative management measures should include modifying the project to include seeding the area to occupy disturbed sites with desirable species. Monitoring area for at least 3 consecutive years and provide for control of newly established populations of undesirable plants and follow-up treatment for previously treated infestations.

Project must be modified to reduce risk level through preventative management measures, including seeding with desirable species to occupy disturbed sites and controlling existing infestations of undesirable plants prior to project activity. Projects must provide at least 5 consecutive

years of monitoring. Projects must also 50- HIGH provide for control of newly established 100 populations of undesirable plants and follow-up treatment for previously treated infestations.

Summary Both the no action and proposed action alternatives would result in a moderate rating because of the current level of noxious weed infestations within portions of the project area. The project is designed to improve vegetative conditions and reduce the potential for large stand replacement fires. Both of these outcomes would help in making the project area more resistant to expansion and infestation of noxious

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weeds. Additionally the Project Design Features for this project would be implemented to reduce the chance of expanding current infestations and introduction of new infestations during project implementation. Continued monitoring and treatment for all alternatives would be required to suppress and control current infestations and provide for early detection and rapid response to new infestations. Soils Report

Methodology

Spatial & Temporal Scale The spatial context for the discussion of direct, indirect, and cumulative effects of the proposed action are the proposed treatment units. Effects to soil are generally confined to the site-specific location of activities; for example, a treatment unit. With few exceptions, soil cumulative effects occur only when management activities occur on the same site. Exceptions include large mass failure and debris flows, or large sediment deposits from off-site disturbances that could affect soils in another location. Analyzing effects to soil at a landscape scale (i.e. by watershed) is inappropriate as it does not involve analyzing soil disturbance using a site-specific, activity-area approach as directed under the Northern Region Soil Quality Standards (USDA Forest Service 1999). Additionally, due to the inherent variability of soil properties, it is not feasible to analyze past management effects on the soil at the landscape scale in a meaningful way. Temporal boundaries extend until soil impacts from this project are no longer discernable. Soil functions, soil physical properties, and vegetative surface cover will trend toward recovery and meet soil quality standards at the close of the project. Impacts to the soil biological community may be discernible beyond this window, but these changes are not detrimental. Soil biological properties are closely related to plant species composition, and would transition along with vegetation over time.

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

Issue Indicators Issues associated with soil productivity and quality include existing detrimental soil disturbances from past and present activities as well as the potential effects from new disturbances related to proposed activities. Potential soil effects from the proposed burns are reduced surface cover, increased erosion risk, soil heating, and short-term nutrient changes from woody debris loss and ash deposition. As defined by the Region 1 Soil Quality Standards, detrimental soil disturbance includes the effects of compaction, rutting, displacement, severe burning, surface erosion, loss of surface organic matter, and soil mass movement. At least 85 percent of an activity area must have soil in satisfactory condition. An activity area is defined as: “A land area affected by a management activity to which soil quality standards are applied. Activity areas must be feasible to monitor and include harvest units within timber sale areas, prescribed burn areas, grazing areas or pastures within range allotments, riparian areas, recreation areas, and alpine areas.” (USDA Forest Service, 1999) Detrimental soil conditions pertinent to this project include: • High Burn Severity: Physical and biological changes to soil resulting from high severity burns. This standard is used when evaluating prescribed fire. Guidelines for assessing fire

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intensity are contained in the Burned-Area Emergency Rehabilitation Handbook FSH 2509.13. • Detrimental Surface Erosion: Rills, gullies, pedestals, and soil deposition are all indicators of detrimental surface erosion. Minimum amounts of ground cover necessary to keep soil loss to within tolerable limits (generally less than one to two tons per acre per year) should be established locally depending on site characteristics. • Soil Mass Movement: Any soil mass movement caused by management activities is detrimental.

High soil burn severity is considered detrimental soil disturbance. High burn severity is characterized by deep ash (often gray, white, or reddish in color), extensive charring, dry or brittle roots, loss of forest floor, and altered physical soil structure. Detailed definitions for soil burn severity, low-severity, moderate-severity, and high-severity can be found in Parsons et al. (2010). These terms will be used in the effects analysis. Detrimental compaction and rutting effects are not analyzed because ground based equipment associated with compaction and rutting will not be used in this project.

Existing Soil Disturbance Existing soil disturbance indicates departure from natural conditions as a result of management activity, and may negatively affect soil productivity when detrimental. Existing detrimental soil disturbance was determined by a Forest Service soil scientist during onsite visits during the summer of 2013. The Soil Disturbance Monitoring Protocol was used to assess existing, management-caused soil disturbance in the proposed burn units (USDA Forest Service, 2009). Attributes evaluated include forest floor impacts, surface soil displacement, mixed surface soil/subsoil, rutting, burning (only management prescribed burning is assessed), compaction, and platy or massive structure. Each sample point consisted of a six-inch diameter circular area. Determinations of detrimental soil disturbance were based on the Region 1 Soil Quality Standards. Ten-point transect surveys were conducted within each unit August 2013, yielding percent estimates of detrimental soil disturbance per unit. Units that were known to have past disturbance had intensified 50-point surveys. Survey findings are reported in Table 4 of the soils specialist report.

Predicted Soil Disturbance To predict the amount of Detrimental Soil Disturbance (DSD) associated with the proposed action, the following assumptions were made: • Projected detrimental soil disturbance due to severely burned soils associated with broadcast and jackpot burning is 6 percent for each proposed treatment unit. While fuel loads and specific treatments vary across the 15 proposed treatment units, it is assumed that implementation would result in mixed-severity fires with the majority being low to low- moderate intensity fires. High soil burn severity would be expected to occur in less than two percent of a low intensity fire and less than 10 percent of a moderate intensity fire (Debano et al. 1998). • Projected detrimental soil disturbance due to surface erosion is negligible within a proposed treatment unit. The Disturbed Water Erosion Prediction Project model (Elliot et al. 2000) was run to generate predicted erosion rates following implementation of the proposed action (see the Watershed report for more details on the Water Erosion Prediction Project modeling). The highest predicted erosion rate for a unit was 0.21 tons per acre per year, which is well within the tolerable limit of one to two tons per acre per year (USDA Forest Service, 1999). These rates of erosion do not constitute detrimental soil disturbance.

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• Projected detrimental soil disturbance due to soil mass movement is zero. Based on hazard ratings for landtypes found within proposed treatment units, no mass movement would be expected to occur (Holdorf, 1981).

Existing Condition

Soils, Landforms, and Geology Project area geology, landforms, and soils are diverse (Table 23). The majority of the soils in the proposed units have formed from sandstone and shale on steeper slopes. Surface textures are predominately loams.

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Table 23: Landform, soils, geology, and sediment delivery by landtype for proposed treatment units Off Site Sediment Sediment Landtype Units Acres Landform Soils Slope Geology Texture Delivery Pollution Efficiency Hazard - Fires 13A 12 85.5 Glacial drift Typic and Argic 10- Undifferentiated Loam Low Low deposits Cryoborolls 25% 21 5, 6, 7, 8, 940.5 Glacial drift Andic Cryochrepts 10- Undifferentiated Silt Low Low 10, 12 deposits 25% loam 21A 2, 3, 4, 1161.6 Steep, drift Andic Cryochrepts 25- Sandstone and Silt Low Low 10, 11, plastered 40% shale loam 12, 13, 14 trough walls 71A 2, 3, 4, 5, 2468.7 Steep valley Typic and Andic 25- Sandstone and Loam Low Low 6, 7, 11, sideslopes Cryochrepts 60% shale 12, 13 161 1, 3, 4, 7, 1893.9 Low relief Argic Cryoborolls- 10- Sandstone and Loam Low Low 8, 9, 11, ridges and Typic Cryochrepts 40% shale 12 slopes 182 2, 3, 7, 9, 445.2 Very steep Rockland-Typic 60% + Limestone Loam Moderate Moderate 11, 12, glacial breaks Cryochrepts 13, 14 183 3, 4, 5, 6, 2898.2 Very steep Rockland-Typic 60% + All non- Loam Low Moderate 7, 8, 9, peaks-upper Cryochrepts carbonaceous 10, 12, slopes rocks 14, 15 200 7, 9, 11, 103.8 Well drained Fluvents and 0-10% Undifferentiated Clay Low Low 12 floodplain Borolls 202 3, 4, 8, 331.1 Rockland- Rockland 60% + Limestone Loam Low Low 10, 12, limestone 14, 15

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The Soil Resource Inventory for the Lewis and Clark National Forest (Holdorf, 1981) was used to determine hazard ratings for the proposed treatment units. Hazard ratings for sediment delivery efficiency and off site sediment pollution due to fires were for landtypes occurring within proposed treatment units that equaled five or more acres. Sediment delivery efficiency ratings are based on the probability of eroded material becoming stream sediment; the ratings are based on slope and drainage density. Offsite sediment pollution hazard ratings due to fire reflect hazard before revegetation. Factors included in the rating determination are: a) Time required for re-establishment of protective native vegetation; b) Probability of heat induced water repellency in the topsoil; c) Probability of accelerated slope mass failures due to the loss of stabilizing effect of plant roots and reduced evapotranspiration rates; and d) Probability of accelerated dry soil creep due to removal of the shading effect of the forest canopy. Landtypes 182 and 183 (32 percent of the area proposed for treatment) have moderate ratings due to slopes greater than 60 percent.

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

Environmental Benefits and Consequences

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

No Action Alternative Alternative 1 proposes no actions that are contained in the action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Alternative 1 provides a baseline for comparison of environmental consequences of Alternative 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

Direct and Indirect Effects Natural processes would continue and no direct effects to the soil resource would occur from the no action alternative. No new management activities would occur. Ongoing activities such as firewood

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retrieval and dispersed camping, which can result in minor localized ground disturbance, and grazing would continue to occur. No additional risk of invasive species establishment and spread within the analysis area is predicted. Under the No Action alternative, accumulations of woody material would continue to increase beyond natural levels due to altered fire return interval. Uncharacteristic fuel accumulation increases risk of high severity wildfire and associated impacts including loss of ground cover and soil nutrients; erosion; and soil productivity loss.

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

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

Direct and Indirect Effects Potential direct environmental effects to the soil resource from the proposed action include severely burned soil and loss of surface layers. In general, burning may be beneficial to soils where burn temperatures are low (through a combination of low fuel loads and moist soils), fire-adapted properties are maintained where they exist, and likelihood of forest floor losses in a severe wildfire are reduced. Burn impacts are more likely to have negative effects on steep slopes and in areas with thick, dry organic horizons. In all cases, these detrimental impacts would be limited in space and intensity through the resource protection measures and would not negatively impact soil productivity in the long term. Potential indirect environmental effects of the proposed action on soil productivity include accelerated erosion as a result of loss of surface cover due to burning, and loss of soil productivity due to noxious weed spread. Resource protection measures described in the Invasive Plants section lead to a low risk of increasing the spread and density of noxious weeds. Work in burned forest soils found that 30 percent cover reduces erosion by half compared to bare soil and 60 percent cover reduced sediment movement to negligible amounts (Robichaud, 2000; Orr, 1970; Noble, 1965). Adequate surface cover (see Resource Protection Measures) and vegetative regrowth would minimize the likelihood of intolerable erosion (one to two tons per acre per year. [USDA Forest Service, 1999]). Erosion rates after implementation of the proposed action were predicted to be 0.03 to 0.21 tons per acre per year based on the Disturbed Water Erosion Prediction Project model (see Table 24)

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Table 24: Predicted Erosion Rates by Unit

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

1 545.7 161 30 0.16 2 371.6 71A 30 - 40 0.09 3 1656.6 161, 183, 21A, 71A 10 - 45 0.10 4 1047.2 161, 183, 202, 21A, 71A 15 - 30 0.04 5 628.1 183, 71A 25 - 35 0.05 6 587.7 21, 183, 71A 15 - 30 0.14 7 748.2 21, 161, 71A 30 - 40 0.21 8 584.4 21, 161, 183 25 - 30 0.03 9 647.5 161, 183 25 - 30 0.03 10 672.9 183, 21A 25 - 30 0.15 11 472.9 161, 182, 71A 20 - 40 0.05 12 1500.4 182, 183, 71A 20 -30 0.05 13 248.6 21A, 71A 25 - 35 0.05 14 645 183, 71A 20 - 25 0.15 15 172.5 183 20 - 40 0.07

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

Cumulative Effects The cumulative impact of past and proposed treatments under the proposed action would not likely lead to long-term impairment of soil productivity, since the Region 1 Soil Quality Standard would be met. Cumulative detrimental soil disturbance is not expected to exceed 10 percent in any given treatment unit; the majority of units are predicted to have no more than six percent Detrimental Soil Disturbance (Table 4 of the soils specialist report).

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

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

Fires Fire effects on soil are further outlined in the discussion of direct and indirect project effects. Historically, fires occurred with greater frequency within the project area than they do today (see fuels report). Several fire impacts can be beneficial to plants and ecosystems, such as releases of nitrogen and other nutrients, or maintaining specific plant and microbial species compositions. Detrimental soil disturbances from fire most often occur in areas with intense burns and high levels of surface level fuels. However, site visits to the treatment areas did not encounter any locations that had been detrimentally burned, either from natural fire or from prescribed burn activities. Because the soils detrimental impacts of past fire are no longer discernable or are limited and dispersed, they are not likely to overlap in time or space with the impacts from the Elk Smith treatments. Therefore, the cumulative effects from past fires would primarily be non- detrimental soil disturbance related to maintaining fire-adapted plant and microbe communities. Table 25: Existing, predicted, and total predicted detrimental soil disturbance by unit

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

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

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Predicted Total Existing Detrimental Predicted Detrimental Soil Detrimental Unit Treatments Soil Disturbance Soil Disturbance (%) from Disturbance (%) Proposed (%) Action • Slash and burn conifers encroaching on natural openings and aspen stands. 11 0 6 6 • Broadcast and jackpot burns utilizing hand ignition • Broadcast burn utilizing combination of helicopter and hand ignition 12 • Reduction of 30 to 50 percent in conifer 4 6 10 regeneration in patches of 20 to 100 acres; total target acreage of 450 to 750 acres • Broadcast burn utilizing combination of helicopter and hand ignition 13 • Reduction of 30 to 50 percent in conifer 4 6 10 regeneration in patches of 20 to 100 acres; total target acreage of 75 to 125 acres • Broadcast burn utilizing combination of helicopter and hand ignition 14 • Reduction of 30 to 50 percent in conifer 0 6 6 regeneration in patches of 20 to 100 acres; total target acreage of 194 to 323 acres • Broadcast burn utilizing combination of helicopter and hand ignition 15 • Reduction of 30 to 50 percent in conifer 0 6 6 regeneration in patches of 20 to 100 acres; total target acreage of 52 to 87 acres

Statutory and Regulatory Consistency Table 26 below summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced.

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Table 26: Summary of Statutory and Regulatory Consistency

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

Watershed Report

Methodology

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

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

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

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

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

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

The Water Erosion Prediction Project (WEPP; Elliot et al. 2000) Modeling predicted erosion resulting from prescribed fire activities. Technical documentation for Water Erosion Prediction Project states that the model values are plus or minus 50 percent of true erosion values, at best (Elliot et al. 2000). Water Erosion Prediction Project is used in this analysis to provide relative erosion values for predicting management activity compliance with Water Quality Act. Detailed information regarding the model inputs and analysis results can be found in the Water Resources project record. The physical basis and performance of the Water Erosion Prediction Project models is discussed in the model documentation (Elliot et al., 2000; Elliott, 2004; Robichaud et al., 2007) as well as several peer- reviewed papers (Elliott, 2004; Laflen et al., 2004; Larsen and MacDonald, 2007). In general, erosion prediction models have difficulty predicting sediment output with precision from a road, hillslope, or watershed at time scales useful to land managers. This is due mainly to a high degree of variability in site characteristics and climate. An average erosion/sediment delivery rate prediction can encompass this variability to some degree, but becomes much more useful when combined with a probability that erosion will occur. The Water Erosion Prediction Project models incorporate climate data tailored to the individual site using Parameter-elevation Regressions on Independent Slopes Model data (Daly et al., 2000) and simulate daily events for a number of years specified by the user to determine the probability of sediment leaving the unit. The model incorporates individual precipitation event characteristics and antecedent conditions as well as site characteristics into its prediction of average annual runoff, erosion, and sediment yield values. Changes in water yield are difficult to predict at the landscape scale due to the complexity of water movement in mountainous forested environments. Even with exhaustive site data available only in experimental settings (i.e., transpiration rates, soil moisture and porosity, precipitation, stream flow, groundwater level and flow), water yield estimates are approximate at best. The equivalent clearcut acres method has been in use for several decades in the northern Rockies and provides a reasonable estimation of the impacts of vegetation removal, and was used to estimate the impact on water yield of project activities as well as past and present activities throughout the two 6th-Hydrologic Unit Code watersheds in the project area (Troendle 1980). The equivalent clearcut acres method predicts water yield increases by assigning coefficients to various types of disturbances. Information used in the analysis includes the timber stand database and various Geographic Information System layers. Basal area reduction coefficients and mortality factors used in the equivalent clearcut acres analysis were provided by the Helena-Lewis and Clark National Forest silviculturalist. Watershed mean annual precipitation was determined from Parameter-elevation Regressions on Independent Slopes Model data (Daly et al. 2000).

Existing Condition The project area is a large diverse vegetation treatment project located along the Rocky Mountain Front range southwest of Augusta, Montana. The project area occurs within two 6th-hydrologic unit code (6th-

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

Environmental Benefits and Consequences

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

No Action Alternative Alternative 1 proposes no actions that are contained in the action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Numerous studies have documented post-wildfire increases in erosion and stream sediment levels (e.g. Wagenbrenner et al., 2006; Spigel & Robichaud, 2007; Robichaud et al., 2008; Moody & Martin, 2009). While it is difficult to anticipate the exact pattern of burn severity to soils from either a prescribed fire or a wildfire in the project area, some general conclusions can be made from the fire-effects literature as well as monitoring of prescribed fire on the Helena - Lewis and Clark National Forest (for details of Lewis and Clark National Forest monitoring, see the Soils Specialist Report in the project record. Whereas a wildfire typically burns through a landscape when conditions are hot and dry, prescribed fires are usually

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implemented when soil, duff, and coarse woody debris moisture levels are relatively high (i.e. in the spring and late fall). Burning that occurs during conditions of higher soil moisture generally results in lower impacts to soils (Hartford & Frandsen, 1992; Stephan et al., 2012; Stoof et al., 2013). Stephan et al. (2012) found that wildfire-burned drainages exhibited higher severity effects than drainages burned in springtime prescribed fires, and produced substantially greater impacts to water quality. Furthermore, Rhoades et al. (2011) found that post-fire impacts to water quality in and around the Denver municipal watershed were closely correlated to burn severity and extent—the larger the area with high-severity burn effects, the greater the impact to stream water quality during the five-year analysis period following the Hayman Fire in 2002. Alternative 1 provides a baseline for comparison of environmental consequences of Alternatives 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

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

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

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

Direct and Indirect Effects Potential direct environmental effects to water resource from the proposed action include sediment delivery and increase flows to waterways. General, burning may be beneficial to water resources where fire-adapted properties are maintained where they exist, and where the likelihood of severe wildfires can be reduced. Burn impacts are more likely to have negative effects on steep slopes. In all cases, these detrimental impacts would be limited in space and intensity through the resource protection measures and would not negatively impact water quality or quantity in the long-term. Potential indirect environmental effects of the proposed action on water quality include accelerated erosion as a result of loss of surface cover due to burning, and the increase in flow and sediment delivery to streams from the increase in soil hydrophobisity. Adequate surface cover (see appendix D - Resource Protection Measures) and vegetative regrowth would minimize the likelihood of intolerable erosion (one to two tons per acre per year. [USDA Forest Service, 1999]). Erosion rates after implementation of the proposed action were predicted to be 0.03 to 0.21 tons per acre per year based on the Disturbed Water Erosion Prediction Project model (see Table 25). See also Soils report for further discussion soils.

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Table 27: Water Erosion Prediction Project Model Estimated Erosion Rates Unit Watershed Natural Average Average Average Sediment Erosion Runoff Upland Leaving Rate (inches) Erosion Treatment (tons/acre) Rate* profile* (ton/acre) (tons/acre) 1 Smith Creek 0-0.004 0.20 19.08 2.13 2 0.058 0.20 3.86 2.07 3 0 0.20 0.14 0.14 4 0-0.004 0.15 0 0.0 5 0.004-0.009 0.15 0 0.0 6 Elk Creek 0.004-0.009 0.44 0 0.0 7 0 0.42 0 0.0 8** 9** 10 0 0.44 0.01 0.0 11 0 0.12 0.01 0.0 12 0 0.15 0.01 0.0 13 0 0.15 0.01 0.0 14 Smith 0 0.44 0.01 0.0 15 Elk Creek 0 0.15 0.02 0.01 *All estimates are for 5 year return interval. **Not analyzed (jackpot burn only)

Cumulative Effects The cumulative impact of past and proposed treatments under the proposed action would not likely lead to long-term impairment of water quality or quantity as Best Management Practices would be performed. Cumulative sediment delivery from treatments units would be expected to be below natural occurring, as Water Erosion Prediction Project Model models have shown.

Timber Harvest No timber harvest has occurred within the project area since 1990. Prior to 1990, salvage logging occurred on private lands in the areas associated with the 1988 Canyon Creek fire. Effects from timber harvest primarily include physical impacts such as compaction and rutting, but may also include alterations to plant community composition and nutrient cycling. These physical impacts still persist and overlap with portions of unit 12 and 13 (see soils report). Disturbance values from past harvests are added with predicted disturbance from project activities to reflect cumulative soil impacts. No treatment area was predicted to exceed sediment delivery to streams or increase flows above naturally occurring levels.

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Grazing The project area overlaps with portions of several grazing allotments. Bank alterations and soil disturbance associated with cattle includes compaction in areas with heavy use, churning of the soil from hoof action, reduced soil cover in areas that are heavily grazed, increased sediment delivery to streams, and direct erosion where churning occurs along streambanks. Areas of the most significant impacts tend to be in or along riparian areas. Grazing may have interacting effects with fire as it affects vegetation recovery, plant species composition changes, and susceptibility to erosion. If vegetation is not fully recovered after burning and before grazing is resumed, compaction and erosion would be exacerbated from hoof action on unprotected soil and reduced vegetation cover. In short, without sufficient resting, fire and grazing activities could interact in a in a way that decreases productivity and alters soil physical properties. This combined effect would be reduced by allowing sufficient plant recovery (both above and below ground) such that the effects of fire and grazing are separated in time and ground cover and root establishment is maintained. Only pack trails are found within the project area. No designated roads are located within the proposed treatment areas.

Fires Fire effects on water quality are further outlined in the discussion of direct and indirect project effects. Historically, fires occurred with greater frequency within the project area than they do today (see fuels report in the project record). Several fire impacts can be beneficial to ecosystems, such as releases of nitrogen and other nutrients. Water quality impacts from fire occur for three to five years following a fire. However, site visits to the treatment areas did not encounter any locations that had been detrimentally burned, either from natural fire or from prescribed burn activities. Because the water quality impacts of past fire are no longer discernable or are limited and dispersed, they are not likely to overlap in time or space with the impacts from the Elk Smith treatments. Therefore, there are no water quality or quantity cumulative effects from past fires in the project area.

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

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Table 28: Summary of Statutory and Regulatory Consistency

Regulatory Requirement Project Consistency 1. Clean Water Act (CWA) is to restore and Non ignition buffers specified in the Resource maintain the chemical, physical, and biological Protection Measures were designed to eliminate the integrity of the Nation’s waters. Section 303 of probability of sediment delivery to state waters. the Clean Water Act directs the States to Sediment is a regulated contaminate in the Clean Water establish water quality standards (subject to Act. Environmental Protection Agency approval) to carry out the purposes of the Act. Section 303(d) further directs the States to identify waters that do not meet water quality standards and to develop Total Maximum Daily Loads of pollutants. Montana has established standards which are applicable to all Forest Service management activities. 2. Clean Water Act section 404 regulates the Non ignition buffers on wetlands are specified in the discharge of dredge or fill materials into waters Resource Protection Measures and were designed to of the United States. Typical Forest Service eliminate the probability of discharge of fill into waters activities that could require a 404 permit include of the United States which includes wetlands. activities in wetlands.

To ensure compliance with local, state, and federal water quality standards, the Lewis and Clark National Forest Plan F-5 requires annual monitoring of “20 percent of all effects of other activities on watershed condition (USDA, 1986, p5-14). If the Elk Smith Project is implemented, areas within the project area would be monitored to determine the effectiveness of treatment-unit Best Management Practices. Monitoring of Best Management Practices, during and after project work, would be critical in determining whether applied measures are effective in minimizing sediment delivery to streams. Monitoring that would likely occur includes review of burn units adjacent to waterbodies to ensure any riparian management zone prescription guidelines were followed, and to identify any erosion and sediment delivery to streams. Where Best Management Practices are shown to be inadequate in protecting water quality, they would be modified or project activities would be discontinued.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in the project record. Forest Plan standards of specific relevance are described below.

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Table 29: Forest Plan Consistency for Soil and Water Resource Forest Plan Standards for Soil and Water Project Consistency

F-1 Erosion Control Project is consistent with Forest Plan Standards as best management practices will be implemented to include erosion control and protect water resources. F-3 (1)(2) Soil, Water and Air Protection Project is consistent with Forest Plan Standards as best management practices will be implemented to include erosion control to protect soil, water and air resources. F-3 (3) Meet State water Quality standards as required Project is consistent with Forest Plan Standards as the by the Clean Water Act (33 U.S.C. 1323), and as Memorandum of Understanding to Implement the 208 Program detailed in the Memorandum of Understanding to on National Forests in the State of Montana will be Implement the 208 Program on National implemented to include erosion control to protect soil, water and air resources. F-3 (4) Require a watershed analysis of projects This report includes analyzes the effects of this project on involving significant vegetative removal to ensure that water or sediment yield to project area streams. the project, considered with other activities, will not increase water yields or sediment beyond acceptable limits. The analysis should identify any opportunities for mitigating adverse effects on water related beneficial uses, including capital investments for fish habitat or watershed improvements. (5) Conduct an environmental analysis for all This report analyzes the effects of this project to riparian, management actions planned for flood plains, floodplain and wetlands. wetlands, riparian zones, or bodies of water prior to implementation. Adopt the necessary mitigation measure to minimize risk of flood loss, restore and preserve flood plain values, and to protect wetlands.

Consistency with Purpose and Need All alternatives would be consistent with the general watershed provisions in the Lewis and Clark National Forest Plan (USDA FS, 1986). Specifically: • The project is consistent with management area standards and guidelines (USDA FS, 1986), • Pertinent soil and water best management practices or resource protection measures listed in the Forest Service National Core Best Management Practices Technical Guide (USDA FS, 2012)) would be implemented (USDA FS, 1986), • Project implementation and post-implementation effects would be monitored to ensure that Best Management Practices are implemented properly and are effective (USDA FS, 1986). • Appendix A of the watershed specialist report summarizes the Forestwide and regional standards that are applicable to water resources, and explains how each standard is being met by the project and by the analyses in this report.

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Fisheries Specialist Report and Biological Evaluation

Introduction This report analyzes fisheries and aquatic wildlife issues related to a proposed forest-fuels treatment project in the Elk Creek and Smith Creek drainages on the Rocky Mountain Ranger District of the Helena-Lewis and Clark National Forest. These treatments would total to approximately 10,331 acres across 15 burn units. The prescribed fire units would mostly occur within stands of lodgepole pine (Pinus contorta) that regenerated after the 1988 Canyon Creek fire. Some proposed treatments would also address the accumulation of heavy, dead downfall logs within the project area. Proposed units would be limited to upland areas. Project implementation would avoid ignition within 200 feet of riparian and wetland areas. This project would not involve the commercial harvest or mechanical removal of trees in the entirety of the project area, including Streamside Management Zones (SMZ’s). There would not be construction of new permanent or temporary road segments. Two alternatives will be analyzed in this fisheries analysis. Alternative one is the no-action alternative. In this alternative, the decision would be to not implement fuel treatments or any other associated activities. Alternative two is the proposed action alternative in which the all of the 15 burn units would be treated as described in the silviculture and fuels specialists’ reports. This report will analyze the potential of the proposed action to affect the habitat parameters of; sediment budgets, water yields, temperature regimes, large woody debris recruitment, food availability, and chemical toxins. These are the habitat quality factors which could be influenced directly or indirectly by actions that would be connected to this project. Westslope cutthroat trout (Oncorhynchus clarki lewisi) are present in two stream segments within the project area. This sub-species is vulnerable to predation from non-native trout and chars and genetic introgression with non-native trout. Thus, this report will also analyze if any potential changes to habitat parameters would affect competitive dynamics with other fish species. Cumulative effects from existing and foreseeable impacts and management actions will also be considered for potential additive effects on fish and aquatic wildlife populations. The westslope cutthroat trout is the only native trout to the project area. It is also the only sensitive fish species or subspecies found in the project area. This subspecies is also recognized as a “sensitive species” by the Bureau of Land Management and the US Fish and Wildlife Service. The state of Montana recognizes the westslope cutthroat trout as a “species of special concern”. There are two sensitive amphibian species in on the Helena-Lewis and Clark National Forest. These are the northern leopard frog (Rana pipiens) and the western toad (Bufo boreas). This project area is within the occupied range of the western toad. The northern leopard frog has only been found on the Forest in the Highwood Mountain Range. This project area is well outside of either occupied or predicted ranges for this species. The western pearlshell mussel (Margaritifera falcata) is a recently listed sensitive species and “species of special concern”. This mussel has not been found in survey attempts that are closest proximity to the project area (Montana Department of Fish, Wildlife and Parks, Natural Heritage Program 2014). The Elk/Smith Project analysis area is also outside the potential or predicted habitat areas mapped by the Montana Natural Heritage Program (Stagliano 2011). Thus, westslope cutthroat trout and the western toad are the two sensitive species with populations or habitat occurring within this project area. Potential effects of project actions to the habitat, populations, and viability of these species will be analyzed in this report. The Lewis and Clark National Forest Land and Resource Management Plan (Forest Plan), adopted in 1986, lists three fish species as Management Indicator Species (MIS) with instructions to “monitor population levels of all Management Indicator Species on the Forest and determine the relationship to habitat trends.” These three species are listed in the plan under the wildlife category “Commonly Hunted and Fished”. All three fish species are salmonids, which are commonly known as the trout, salmon, char,

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and whitefish family of fish. The westslope cutthroat trout is the only native trout that appears on this Management Indicator Species list. The other two fish Management Indicator Species, eastern brook trout (Salvelinus fontinalis) and rainbow trout (Oncorhynchus mykiss), are introduced species on the Forest and in the State of Montana. Eastern brook trout contain the term, “trout”, in their name. However, as a member of the Salvelinus genus, they are technically a char. Effects to the two non- sensitive Management Indicator Species fishes will also be analyzed in this report. The hydrology and soils specialist’s report will be used as assistance in evaluating potential changes to sediment and water yields. Preparatory field visits were conducted for this project by various members of the interdisciplinary team including fisheries, soils, hydrology, fuels, and range specialists. The fisheries specialist also organized and participated in three different joint survey and genetic sample collection trips with biologists and technicians from Montana Fish Wildlife and Parks during the 2013 field-season. These efforts yielded considerable current information on existing conditions and even led to the discovery of a previously unknown population of westslope cutthroat trout. This population is the only known, genetically pure population of this subspecies within the Sun River drainage. The foreseeable, potential effects to fish populations from actions connected to this project would be changes in these habitat or population related factors; sediment yields, thermal regimes, competitive relationships between native and introduced species, risk of impacts from future wildfires, and availability of prey invertebrates. The foreseeable, potential effects to amphibian species would be changes in these factors; direct or indirect mortality, thermal regimes in breeding ponds and terrestrial habitat areas, ability to migrate overland, sediment inputs into breeding ponds, risk of impacts from future wildfires, and availability of prey species. These potential effects could vary in intensity or not occur at levels that would be measureable or impact individual aquatic organisms or population dynamics. Not all of these potential effects are assumed to be negative to populations of fish and amphibians within the analysis area. In some post-fire situations, westslope cutthroat trout have competed more successfully against brook trout than in pre-fire monitoring time periods (Sestrich and others 2011). Western toads have also demonstrated post-fire population increases (Guscio and others 2007). Aquatic insects have increased after fire events (Minshall 2003, Minshall and others 2001).

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

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

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

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levels of dissolved oxygen (Bryce and others 2008, Weaver and Fraley 1993). Fine sediment is considered a concern when smaller than about 6.5 millimeters (Weaver and Fraley 1993). Particle sizes smaller than about 0.85 millimeters have the highest correlation with reducing embryonic survival (Young and others 1991, Magee and others 1996, Beschta and Jackson 1979). Generally, complex stream reaches, which feature a multitude of pools, riffles, and runs, better store and buffer the effects of sediment on fish and other aquatic wildlife (Shepard and others 1998, Baxter and Hauer 2000, Magee and others 1996, Schmetterling 2000). This complexity allows for a total increase in storage capacity as well as for increased storage capacity in areas not used for spawning. More storage capacity and habitat complexity allows for fine sediment to move through the system without intra-gravel concentrations becoming frequently high. Streams in this project area generally contain a good ratio of pools and a diversity of pool types. The two streams with conservation-level westslope cutthroat trout populations typify this with the addition of “run” and “glide” habitat areas. Overall, the habitat appears to offer a high-level of resiliency to sediment events that are not catastrophic in magnitude or chronic in occurrence. The ability to seasonally store small sediment increases, without suppressing reproductive success, and then transporting these away during higher flows appears to be very high. There is enough transport ability and ample enough storage capacity in the streams of this project area to prevent small, temporary increases in sediment yields from impeding dissolved oxygen flow to eggs in all or most spawning sites. Low levels of cumulative effects from other sediment producing activities contribute to the confidence of making this determination or assumption. Other factors commonly compensate for sediment impacts on hatching or emergence success, such as enhanced alevin or fry survival. In one study embryonic survival was suppressed by fine sediment to the low level of 8.6 percent without recruitment to the population being affected (Magee and others 1996). Most systems have compensatory reproduction at the embryonic stage. This means that more fish survive at the embryonic stage of develop than the habitat can carry at more mature life stages. If survival is high in following age classes, some levels of decreased survival in the embryonic stage can occur without suppressing population numbers. Moudess Creek and Smith Creek are well-below many streams in the ability to compensate for low embryonic survival. These streams are cold, high elevation and relatively low in productivity. A westslope cutthroat trout transplant project failed in Petty Creek within the Smith Creek basin because of a thermal regime that was too cold. The cooler summer waters, earlier winter conditions and lower food supplies create conditions where juvenile fish are likely to be relatively small as they begin their first attempt at over-wintering. Brook trout predation also suppresses the survival of juvenile fish. Thus, this assessment will assume that if moderate or higher increases in sediment levels were to occur and persist for more than two years, a viability risk to the remnant westslope cutthroat trout populations in the project area would exist. The preceding two assumptions are stated using the relative terms “low levels” and “moderate or higher” instead of with a specific quantity or ratio of annual increase. This recognizes a limitation in being able to accurately predict the specific quantity of fine sediment input into a particular stream segment that will measurably lower embryonic survival to levels which would limit recruitment. Correlations have been made between embryonic survival and the percent of space between spawning gravel-sized particles that is occupied by fine sediment-sized particles (Magee and others 1996, Weaver and Fraley 1993). However, it is not possible to accurately predict to what extent relatively small, temporary increases in fine sediment yields will raise inter-gravel concentrations of fine-sediment concentrations in a particular stream reach. The movement of sediment through any stream reach is complex with many different variables determining the pattern of transport, settling, storage, scouring, and re-mobilization (Beschta and Platts 1986). Storage of sediment is not homogenous within a stream reach. Dam created pools may contain large concentrations with upwelling zones within riffle areas containing very low amounts. Most studies on the effects of sediment on salmonid fishes have occurred in much larger and more heavily managed drainages. These have been characterized by much higher and more prolonged non-natural

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inputs. A landmark study in the South Fork Salmon River basin correlated an average inter-gravel concentration of 48 percent fine-sediment with a loss of approximately 20,000 cubic meters of fine- sediments from temporary logging roads a year within a 3,290 square kilometer catchment (Platts and others 1983). This converts to an average production of approximately 74 tons of temporary road-source sediment produced per acre, per year within that catchment. This is several hundred to more than a thousand times higher than the effects typically modeled or observed on similar prescribed fire projects. Differences in stream discharge, climatic regimes, soil types, and in orders of magnitudes of delivered sediment make it impossible to quantitatively scale-down effects to the level of predicted changes in inter- gravel concentrations of fine sediment. Cross-walking published data representing much higher changes in sediment delivery and population effects may be a limitation, but assuming that these studies observed a much higher effect on salmonid populations appears to be very supportable.

Flow Regimes and Temperature Studies which document the effect of the removal of shade canopy on stream temperatures do not parallel the characteristics of this project as changes in the shading of the stream itself are not being proposed, nor are they expected. Those which demonstrate temperature change from tree removal or mortality have experimental designs with much greater levels of near-stream canopy manipulations. Clear-cutting a living canopy (Hetrick and others 1998) or burning riparian canopy with wildfire (Amaranthus and others 1989) has been demonstrated to effect stream temperatures. Removing canopy that does not shade streams can temporary increase water yields. Small changes in water yields affect temperatures to a much lesser extent than does removal of direct stream shading (Poole and Berman 2001, Johnson 2004, Rutherford and others 2004). While increased flows may very slightly alter temperature, they can also expand available summer-time habitat (Hicks and others 1991). Increased summer habitat has been demonstrated locally to expand westslope cutthroat trout populations, but the number of observations is limited (Moser 2011). The positive effect on population size that has actually been observed is at least as large and likely larger, than expected negative effects of small changes in temperature regimes. Thus, the assumption is being made that temperature changes will not have a negative impact unless modeling of yield increases shows unexpected levels of change. Adding foreseeable thermal effects to predicted local rates of global climate change cannot be expected to form a tipping point for survival at the organism level or viability at the population level. This conclusion is based on climatic predictions made by a multitude of scientists with a weighting towards models which best “back-predict”, which is being able to replicate historical weather observations (Isaak and Riemen 2012, Isaak and others 2010, Barsugli 2009). This is a somewhat-rare system in which cutthroat populations are limited by cool summer water temperatures. Predicated temperature increases from climate change are not assumed to be negative for either of the two populations present in the project area. These would actually un-intentionally mitigate any decreases due to temporarily increased summer flows.

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

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

Information Used

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

Methodology & Scientific Accuracy Quantitative methodology was not used for assessing effects on aquatic species and aquatic habitat conditions in this analysis. Spatial data from the Lewis and Clark National Forest Geographic Information System datasets was used as information in analyses. Cartographic precision and accuracy of this information is documented in the Lewis and Clark National Forest Geographic Information System data dictionary and meta-data records. Modeling sediment input from existing watershed conditions, and projected yields after implementation was performed by the forest hydrologist. The methodology used was the Watershed Erosion Prediction Project: Disturbance software (Elliot 2004). The forest soil scientist, forest hydrologist and forest fisheries biologist consulted together about input variables and jointly reviewed model results. The accuracy of Watershed Erosion Prediction Project: Disturbance model runs is dependent on several factors. These include a limited set of input variables that describe soil, slope, and vegetation conditions. The ability of modified PRISM climate data to describe local conditions over the modeled time period is also a factor that impacts accuracy. There appears to be less validation efforts published for Watershed Erosion Prediction Project: Disturbance and prescribed fires than for the Watershed Erosion Prediction Project: Road model (Elliot and others 1999, Elliot and others 2000). The fisheries/aquatic wildlife specialists conferred with two peers about their post-implementation experience using Watershed Erosion Prediction Project: Disturbance on prescribed fire projects (Hendrickson 2014, Van Eimeren 2014). Quantitative monitoring was not performed on the Lolo National Forest following several burns in the Rattlesnake Recreation Area, but the fisheries biologist assigned to these projects relayed that Watershed Erosion Prediction Project model predictions were likely higher than the actual change in yields (Hendrickson 2014). This observation was made with the recognition that actual sediment yields are often not visible. Intact duff layers, lack of fire carrying to riparian buffer zones, and the absence of visible rills or signs of overland, sheet flows informed this professional opinion. Similar, anecdotal-level observations were reported from prescribed fire projects on the Flathead National Forest (Van Eimeren 2014).

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The 1988 fire has impacted duff layers in the Elk Smith project area so this would be a different condition than in the Lolo National Forest implementation area. However, the occurrence and intensity of fire near the outskirts of the 200 foot buffer area would likely be even less in the Elk Smith project area due to lighter fuel concentrations. The anecdotal-level evidence on the Lolo National Forest combined with the characteristics of this project area indicate that the Watershed Erosion Prediction Project: Disturbance model runs should at least capture real yield quantities if not actually represent worse-case scenarios or even higher quantities. Watershed Erosion Prediction Project: Disturbance runs also produce values for “probability of occurrence”. These indicate what the probability is for delivery of the modeled volumes. Coupled with the characteristically light fuel loading near the outskirt of the riparian buffer areas, the quality of the climate data should produce conservative to accurate probability values.

Affected Environment

Analysis Area The analysis area for direct, indirect and cumulative effects to aquatic habitat is defined by the sixth order Hydrologic Unit Code (HUC) sub-watersheds which contain treatment areas proposed for prescribed fire, fuel reduction treatments. Within these sub-watersheds, field surveys were performed in 2013 and 2014 to evaluate the presence and status of sensitive and management indicator aquatic species. Potential effects to these species, if the proposed action would be implemented, were also analyzed. Since migration barriers are important in preventing the hybridization of westslope cutthroat trout with non- native species, these were also looked for and evaluated during field efforts. Stream segments above these were evaluated for the ability to sustain westslope cutthroat trout populations. This was done to assess the potential to replicate or even temporarily hold at-risk populations in nearby drainage basins. A previously unknown population of westslope cutthroat trout was found in the middle sections of Moudess Creek. Genetic tests confirmed that this population is 100 percent pure. The Moudess Creek population was a significant find that put an emphasis on surveying all other project area tributaries. As this was done, a previously unknown trout population was found in upper Cyanide Creek. This population is predominately rainbow trout in origin as there was little to no visible characteristics of westslope cutthroat trout in the genetic makeup. No other new discoveries were made. Moudess Creek is the only known pure westslope cutthroat trout population in the project area, and also in the entire Sun River system. The upper portion of the main-stem of Smith Creek hosts a westslope cutthroat trout population with a 90 percent or higher level of genetic purity. This is the threshold for a population being considered a conservation population under the Upper Missouri River Westslope Cutthroat Trout Status and Recovery Plan (Tews and others 2000). The Smith Creek population was genetically sampled in 2013. Laboratory tests have determined it to be a three-way hybrid swarm containing both rainbow trout and Yellowstone cutthroat trout markers. Several barriers were found in tributaries of both Elk and Smith Creek. The habitat upstream of these was highly fragmented by smaller cascades and intermittent reaches. No sections were found that appeared to be suitable to replicate other populations. Barriers may also exist on the main-stems of both Elk Creek and Smith Creek. It is more difficult to assess if a cascade is a migration barrier on a large stream because of the much greater potential for passage during high flows. The habitat above the suspected barriers in Elk Creek is highly fragmented by smaller cascades and by intermittent flows. The amount of fragmentation makes it appear unlikely that this currently fishless stream habitat could sustain an introduced population. Fish below the potential barrier on Smith Creek were marked in 2013. Follow-up efforts are being conducted to determine if marked fish migrate above the waterfall. The hybridization existing above the falls could be the result of human stocking efforts or a combination of this activity and fish getting around margin areas during high flows. Moudess Creek flows into Smith Creek less than a quarter of a mile above the waterfall. Thus, the question of whether this is an effective barrier in blocking

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the upstream migration of exotic fishes is important in formulating a plan to also conserve and expand this population. The western toad is the other sensitive species that either occurs or has a portion of its distribution range within the proposed project area. These were not observed during field visits. There appears to be very limited breeding habitat in the Smith Creek drainage portion of the project area. Incised, box-shaped canyons are prevalent along riparian areas. These tend to run fast in the spring and afford little opportunity for still, ponding areas suitable for western toad breeding. Upland bench areas with ponds, fens and other wetland areas are present, but appear to be a very minor component of this landscape. A shallow pond does exist in the very uppermost part of Smith Creek. In the Elk Creek portion of the project area there is a fairly expansive beaver complex on the main-steam stream, just above the forest boundary. Some of these beaver ponds appear to be suitable for western toad breeding. Several ponds were observed to have a very good distribution of depths and types of littoral or shore-zone areas. Some of the ponds are in main-channel areas that are more likely to scour during the breeding season. Others are on side-channels that would appear to be more conducive to breeding success. An accumulation of fine sediment and rooted aquatic vegetation is further indication that scouring may not be a limiting process in some of these ponds. The forest fisheries biologist did not observe any western toad activity on June 10, 2014 in a limited survey of the beaver complex area. This was not a comprehensive enough effort to rule-out this area as western toad breeding habitat, however. For the purpose of this analysis, western toads will be assumed to be present and reproducing in the project area. The Canyon Creek fire of 1988 burned across much of this analysis area. This is the main effect present on the landscape as most of the project area is roadless and has a limited history of timber harvest activities. Some stream segments lost canopy during this fire event. There is a varying level of recovery of this in the current condition. This is not considered a concern as water temperatures in the project area are heavily influenced by subsurface flows and known to be colder than what is ideal for westslope cutthroat trout persistence. Embryonic emergence is late and slow growth limits the overwintering success of young-of-year fish. An attempt to introduce westslope cutthroat to a segment of Petty Creek, a tributary of Smith Creek, failed for this reason. Springtime flows are more than adequate to have transported away the elevated levels of sediment produced during and in the first years after the 1988 fire. Sediment yield recovery curves typically return to near pre-fire levels between four-to-ten years after wildfires of similar intensity, with much of the recovery occurring during year first two years (Moody and Martin 2009, Robichaud and Waldrop 1994, Ice and others 2004). Spawning gravels in the project area appear to be loose and not contain fine sediment near levels that have been demonstrated to reduce embryonic survival. Most of the historic harvest/salvage activity is in the Smith Creek basin below the forest boundary. This occurred long enough ago to allow for nearly full recovery in any changes in sediment and water yields. The temporary road network was limited in size with most segments occurring well away from channel or riparian areas. A couple of crossings appear to deliver minor amounts of sediment in comparison to natural yields.

Water Quality: Sediment Increased sediment delivery to streams is the most common water-quality impact in mountainous watersheds containing road networks and managed forestry resources. Heightened levels of fine sediment in a stream negatively affect the populations and reproductive success of fish and aquatic invertebrates such as mussels, amphibians and insects. High sediment production events are especially a concern when a population of a rare or sensitive species is located in an isolated habitat unit. Protecting westslope cutthroat trout from hybridization on the Forest often requires establishing refugia of genetically unique

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populations of westslope cutthroat trout upstream of constructed fish barriers or protecting those which persist upstream of natural fish barriers such as waterfalls. These isolated populations can no longer migrate to another stream to complete their lifecycle while maintaining genetic purity. This makes these fish more vulnerable to chronically elevated levels of sediment or catastrophic sediment events such as debris flows than those with access to larger stream networks. (Sestrich and others 2011).

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

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

Environmental Consequences

Alternative 1 – No Action Under Alternative 1, there is no proposed new management action. Without the implementation of new actions, no new management-related impacts to fish, amphibian or other aquatic species and aquatic habitats would occur. Past and ongoing management activities would continue to affect these populations and habitat areas. Stream sediment and thermal regimes would be unaffected in the near-term by implementing this alternative.

Cumulative Effects The only cumulative effect in this alternative is that the risk of larger and higher intensity wildfires would increase more over-time. Watershed Erosion Prediction Project: Disturbance modeling runs for wildfire scenarios produce much higher yields of sediment than do the proposed burns of this project. The risk of sediment yields occurring would be initially lower with no project actions, but continually increase through time as fuel concentrations increase. Predicting the quantity of sediment that would be introduced by a future fire with an increased intensity would be an inexact exercise. Many different

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variables would determine this and historical precedence across the western United States includes a very wide range (Megahan and King 2004). Isolated westslope cutthroat trout populations in this project area do not have the ability, however, to migrate away from catastrophic-levels of sediment related impacts and maintain genetic integrity. In the Bitterroot National Forest there are several streams where westslope cutthroat trout have persisted under competition from stocked brook trout for many decades. In most of these streams that were being actively monitored, westslope trout populations eventually increased their competitive balance with brook trout after the large wildfires of 2000 (Sestrich and others 2011). It cannot be assumed that this relationship would occur in this project area, however. The baseline competitive balance is different with local cutthroat populations being much more likely to be extirpated by brook trout in pre-fire conditions. Run-off and temperature regimes are different and emergence of westslope cutthroat trout is also later in this project area. The effects of wildfire on fish populations and competitive balances with non-native species is variable with local considerations and specific effects from fires able to produce different results (Rieman and others 2003). Increased large woody debris inputs are believed to be part of the reason for the increase of westslope cutthroat in the streams affected by wildfire in the Bitterroot National Forest. In electrofishing effects in this locality, wood formed pools appear to be more dominated by brook trout. This relationship is also commonly known by many people who locally fish for this species. One study on waters east of the continental divide on the Beaverhead-Deerlodge National Forest indicates that increased woody debris may decrease the size of westslope cutthroat trout populations where eastern brook trout are present (Shepherd, 2004). Woody debris has been demonstrated to be important to westslope cutthroat trout (Schmetterling, 2000), but increased levels may favor the non-native competitor to an even greater extent in this vicinity. Westslope cutthroat trout tend to be found at the highest densities in deep, slow to moderate velocity runs in electrofishing efforts when both species exists together across most of the Forest. Mid-channel, boulder and bedrock formed pools that tend to have some moderate velocity areas also hold higher proportions of cutthroat trout in this project area with brook trout dominating low velocity pools. This observation has been made while electrofishing nearly 100 percent of the occupied habitat in the project area. The spread of weeds would not increase in the no-action alternative. There would possibly be less need for herbicide application. Protecting aquatic organisms from adverse effects of herbicide application has been provided for application in compliance with label instructions and the current Lewis and Clark National Forest Noxious Weeds Environmental Impact Statement (USDA Forest Service 1994), however.

Alternative 2 – Proposed Action

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

Indirect Effects These are the effects on the habitat quality parameters connected to proposed actions that were mentioned in the Introduction and discussed with some additional detail under the “Analysis Assumptions and

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Limitations” section. These potential indirect effects are; sediment budgets, water yields, temperature regimes, large woody debris recruitment, food availability, and chemical toxins. The potential effects on large woody debris recruitment were discussed under the “Analysis Assumptions and Limitations” section of this report. Since there is extremely limited spatial coincidence with the zone of recruitment and areas which would be burned, this will not be analyzed further.

Sediment Yields A review of the Watershed Erosion Prediction Project: Disturbance model outputs performed by the hydrology specialist reveals that expected increases are very low across the analysis area. The probabilities of these increases occurring are low to moderate, and generally below 50 percent. These are found in Table 3 of the hydrology specialist’s report in the project record. These values are in tons per acre. Thus, the acres that would be burned need to be used as a multiplier to derive modeled yield increases. The fuels specialists provided information on what proportion of the proposed treatment polygons are expected to carry fire. With the patchiness of fuel concentrations and terrain characteristics, this would generally be considerably less than the overall area of the polygons. After reviewing the total sediment production per drainage modeled to be produced if implementation would occur, it is evident that values are, as expected, very low in comparison to known land management activities and natural events such as wildfires, slumps or cut-bank failures.

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

Weeds and Weed Spraying The extent of this activity is analyzed in the range/weeds specialist’s report. Any increased weed spraying activities connected to the implementation of this project would be performed using certified herbicides in accordance with all label instructions. Only herbicides specified in the Lewis and Clark National Forest Weed Treatment Environmental Impact Statement (USDA, Forest Service….) would be used. These measures should prevent nearly all direct or indirect effects to aquatic wildlife species (Tatum 2004). It is possible that some amphibians could move into a treated area soon after application. Western toads can move into a clearing from up to 150 meters away (Deguise and Richardson 2009). This could potentially expose them to recently applied herbicide. Scientific literature reveals concern about the toxicity of the glyphosate group of herbicides on toads and other amphibians. The glyphosate group of herbicides, which includes the brand name “Roundup”, has been found to be toxic to juvenile amphibians at overspray levels (Relyea 2005). Glyphosates are not used on the Forest. These were not included in the approved list in the aforementioned Environmental Impact Statement. These chemicals are also non- selective in killing target plant species. There would be no application of glyphosate connected with this project. Herbicides which may be used include picloram mixed with synergistic herbicides such as triclopyr or 2, 4-D. Picloram is considered slightly toxic to fish, and the risk of exposure under US Forest Service application procedures has been considered to be nearly non-existent (Durkin and Follansbee 2003). This same risk assessment on picloram use states that tests on toxicity levels for amphibians were not available. The forest fisheries biologist searched for more recent literature and found picloram listed as “not acutely toxic” to amphibians with LC50 rates for two species of frogs not found in this project area (Kegley and others 2007). Synergistic toxicity risk is considered to be a rate of toxicity that is higher than

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individual chemical components that occurs as a result of combing them together. Synergistic toxicity studies of these forestry herbicide mixes, along with the surfactant ingredients, have consistently determined this effect to range from slightly antagonistic to simply additive (Tatum 2004).

Irreversible/irretrievable Commitments An irretrievable commitment represents a temporary loss of a resource, which can be replaced over time. An irreversible commitment represents a total loss of a resource, which cannot be replaced. Any sediment delivery, loss of large woody debris recruitment or temperature increase to streams resulting from the action alternative would be an irretrievable commitment. The stream would recover from these effects over a time period of years to decades. Adherence to all applicable laws, regulations and best management pratices would make it unlikely that any irretrievable commitments would result from project implementation. Refer to the forest hydrologists report for more information on habitat commitments. No irreversible commitments can be linked from implementing this project to fish, amphibian, mussel or other aquatic wildlife species. Mortality of aquatic wildlife attributable to the project would be non-existent to very incidental. Chronic sediment delivery from the road system would be reduced at levels that greatly exceed any foreseeable sediment pulses attributable to the project. Sediment pulses would be well below lethal or life cycle threatening levels.

Cumulative Effects

Biological Impacts from past and present land use activities and current infrastructure features such as the road and trail system are present, but at very low levels in the proposed project area. Fishing pressure is present in the project area. The distribution of this pressure varies slightly. There is some hike-in angling along Smith Creek. Otherwise, pressure is very low to non-existent in the project area. Streams are mostly not accessible by motorized travel and trout exceeding 10 inches in length are rare in most stream segments. Fish populations are robust enough in recruitment to compensate for this level of fishing related mortality. Westslope cutthroat trout are vulnerable to being caught when anglers are present. However, Montana state fishing regulations preclude harvesting westslope cutthroat trout in the project area. The introduction of non-native fish species is the most serious and prevalent impact to the viability of westslope cutthroat trout in the project area. Some management actions can be synergistic to egression by non-native fish by manipulating habitat conditions in ways that give the exotic species a further competitive advantage. Eastern brook trout are more tolerant of elevated sediment levels (Shepard 2004). They can also be more tolerant of increased water temperatures in the higher thermal ranges where both can exist (Shephard and others 1998, Shephard 2004). With project area stream temperatures being so cold, this thermal relationship cannot be assumed to be present. It could possibly even inverse as overwinter survival of juvenile westslope would likely increase more for westslope cutthroat trout. Parallel studies are not available to more reliably support analysis and conclusions. Multiple factors combine to determine which species are benefited by natural and management related events. The timing and intensity of an event can be as deterministic in influencing competitive balances as the type of effects created by the event. The forest fisheries biologist observed that brook trout dominate low velocity, wood-dam created pools in Smith Creek during electrofishing efforts in 2013. Westslope cutthroat trout were absent to mostly absent in this type of habitat. Pools and runs formed by bedrock and boulder influenced scour tended to have more velocity. These also contained a much higher proportion of westslope cutthroat trout. The habitat parameter in the project area that appears to most impact the competitive balance between brook trout and westslope cutthroat trout is the occurrence of low velocity pools formed by woody debris jams. Beaver activities were not observed in the stream segments inhabited by westslope cutthroat trout. It can be

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assumed that pools created by beaver-constructed dams would also favor brook trout as velocity ranges would be similar. Cumulative effects from non-native invasive species other than fishes are relatively minimal within the project area. Whirling disease is present downstream of Forest waters, but tests on and near the forest have been negative for presence. The non-native chytrid fungus (Batrachochytrium dendrobatidis) has been linked to declines in infected populations of amphibians across Montana (Maxwell 2009). There are no known records of observations of non-native aquatic plant invasions on the Forest that impact the abundance of any native aquatic organisms. There are several naturally occurring fish diseases that are or could be present with low levels of infection. Bacterial kidney disease is present in local waters. This disease can infect native and non- native trout (salmonid) species; however, outbreaks of this disease are mainly a concern in hatcheries where fish are in densities well above natural conditions. Fish in the Forest vicinity are routinely tested for six other diseases by the Montana Department of Fish Wildlife and Parks. Tests on and near the Forest have been negative for the presence of these.

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

Conclusions by Alternative

Alternative 1 – No Action The full attainment of beneficial uses related to fisheries and aquatic wildlife is being met in the streams of all of the sixth order sub-watersheds in which prescribed fire activities are proposed. Under the no- action alternative this would continue to occur. Westslope cutthroat trout would be under a higher risk in future decades of wildfire influenced debris flows containing high concentrations of fine sediment. The increase risk of wildfire could also result in increased recruitment of coarse woody debris. This would appear to benefit eastern brook trout at the expense of westslope cutthroat trout. Other actions connected to the project and cumulative effects would change at levels too small to be likely to affect recruitment or population sizes of fish and aquatic wildlife populations. Grazing related

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impairments would likely remain at similar levels. There would likely be somewhat less weed spread and spraying in this alternative. This would result in a very small reduction of risk for future impairments to riparian habitat quality and resiliency. There does not appear to be a significant fish and aquatic wildlife issue related to the implementation of this alternative as tested for context and intensity within the 10 National Environmental Policy Act points of significance as defined in the Council on Environmental Quality regulations (40 Code of Federal Regulation, Part 1508.27).

Alternative 2 – Proposed Action The full attainment of beneficial uses related to fisheries and aquatic wildlife would still be met in the streams of all of the 6th order sub-watersheds in which prescribed fire activities are proposed. This includes recreational uses of these resources as well as those related to species concerns such as viability, diversity, and richness. Slightly increased sediment yields, persisting for five to seven years, is the expected impact that required the most analysis to form a biological conclusion on effects to fish and aquatic species. The outputs of modeling efforts were analyzed within the context of field assessments of existing conditions and relevant scientific information. Streams were analyzed to determine if there were any with dynamics that would cause these low-level, non-persistent yield increases to rise to a level of concern. These were further assessed for population levels, genetic purity, and resiliency to sediment inputs. The determination of this assessment is that actions connected to this alternative would not increase viability threats to sensitive aquatic species or decrease the carrying capacity for other aquatic wildlife species. The attached biological evaluations provide more of this information at species-specific levels. There would potentially be beneficial effects of implementing this alternative to aquatic fish and wildlife species. A reduction in the risk of future catastrophic fire events, including those that would lead to debris flows of materials with high concentrations of fine sediments, would be expected. Increases in various trophic levels of the fish and aquatic wildlife food-web would possibly result due to nutrient releases and entry (Spencer and others 2003, Minshall 2003, Minshall and others 2001). Definitively concluding that future wildfire events that would be non-beneficial to aquatic wildlife species would be prevent by this alternative is not possible, however. This is also true for concluding that the beneficial effects of implementing this alternative would occur at levels high enough to measureable. What is definitive is that fire has historically asserted an active role in shaping the sediment budgets of this landscape, and this will continue regardless of human intervention. Effects from fires of various intensities and spatial patterns on aquatic wildlife populations, and especially fish species, is complex and difficult to predict (Dunham and others 2003). Thus, effects are not being concluded to be beneficial, but it is recognized that there appears to be characteristics of beneficial effects associated with this alternative. Native aquatic wildlife species are likely to do better in a fire regime that is being brought closer in congruency with the historical parameters of frequency, intensity, and scale. There does not appear to be a significant fish and aquatic wildlife issue related to the implementation of this alternative as tested for context and intensity within the 10 NEPA points of significance as defined in the Council on Environmental Quality regulations (40CFR, Part 1508.27).

Biological Evaluations

Westslope Cutthroat Trout This review serves as the biological evaluation of this project for westslope cutthroat trout.

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(Oncorhynchus clarki lewisi). Westslope cutthroat trout are listed on the USDA Region 1 Sensitive Species List. A biological evaluation is needed to assess effects of this project on the species to meet the requirements of the Forest Service Manual. Westslope cutthroat trout habitat is typically streams with high water quality and few competing fish species. Spawning occurs in late spring/early summer in gravel riffles with low sediment concentrations. Fry emerge in mid-July through mid-August. Table 30 and Table 31 below summarize information on status of the species and projected effects to the species associated with the project. Additional detail is provided throughout the rest of document.

Table 30: Westslope Cutthroat Trout on the Lewis and Clark National Forest; Status and Effects to Species from the Proposed Project

WIFV MIIH Will impact individuals or May impact habitat with a NO Effect individuals or PRESENT (NE) consequence that habitat, but will not the action may IN EFFECT ON likely contribute to SPECIES STATUS PROJECT HABITAT NO contribute to a a trend towards trend towards AREA IMPACT federal listing or (NI) federal listing or loss of viability to cause a loss of the population or viability to the species population or species Westslope Surveys Effects may vary MIIH- Cutthroat performed from none to Treatments are Trout for streams minor depending designed to Oncorhynch within the on specific minimize us clarki project area. conditions in the impacts to lewisi The species stream. No aquatic habitat is known to substantial effects quality. Sensitive be present, at are projected to Environmental (USFS) genetic for any stream effects would be S2 (Natural purity levels habitat areas-see minor in Heritage of 90% and Table 6 and magnitude and

Montana above, in two narrative. wouldn’t persist. streams May impact G4 Natural within the habitat, but Heritage Cumulative would not likely Global Effects contribute to a Analysis trend towards Area federal listing or cause a loss of viability to the population or species. NOTES: NLAA = Not likely to adversely affect MIIH = May impact individuals or habitat, but will not likely contribute to a trend towards federal listing or loss of viability to the population or species LAA = Likely to adversely affect WIFV = Will impact individuals or habitat with a consequence that the action may contribute to a trend towards federal listing or cause a loss of viability to the population or species

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Table 31: Screening Criteria for Reaching a Determination of "No Impact"/ "No Effect" Westslope Cutthroat Criterion Comments Trout 1. Does the activity likely involve the 'direct taking' of westslope cutthroat trout (including the capture, collection, harassment, or No harm to individual fish)? 2. Is the activity likely to involve the introduction of sediment (or Yes, some risk for Refer to analysis section other materials) into a perennial stream? slightly elevated levels of below addressing why sediment delivery from levels are not considered burn polygons to streams significant to westslope in some sixth code cutthroat trout. HUC’s. This condition would be expected to not persist beyond five to seven years. 3. Is the activity likely to significantly change the natural process No, Riparian buffers of Large Woody Debris (LWD) input into a perennial stream? would include the zone of woody debris recruitment. 4. Is the activity likely to measurably increase water temperatures No, shade canopy will be during critical low flow periods, or decrease winter water retained. temperatures? 5. Is the activity likely to disturb stream morphology within areas suitable for westslope cutthroat trout? No 6. Is the activity likely to significantly change riparian vegetation No, some fire could along a perennial stream or riparian area? occasionally enter streamside areas, but this wouldn’t likely be at levels that would “significantly change riparian vegetation along a perennial steam”. 7. Is the activity likely to change water quantity through diversion, withdrawal, or a change in water yield or groundwater? No 8. Does the activity involve amounts of toxic or hazardous materials which could possibly be introduced into a stream- No course? 9. Does the activity involve activity on land-types with the potential for mass movement and does the activity have the No potential to change the natural rate and volume of mass movement? 10. Is there a question or controversy regarding the potential effect of this activity on westslope cutthroat trout or downstream No habitat for the species? 11. Would the decision document required to permit/allow this activity likely require an EIS? N/A All of the responses to the criteria #1 thru #10 above are 'NO'. The determination of effects of this activity is NO IMPACT. See narrative below One or more of the responses to the above criteria (#1 thru #10) are Narrative below suffices 'Yes'. The determination of effects of this activity is MAY N/A for a biological AFFECT. A stand-alone narrative Biological Evaluation may be evaluation documenting needed to assess the extent of impact. more than a no impact call

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Recreation Report

Methodology

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

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

Existing Condition In relation to recreation, the Elk Smith Project area is used by the public for hiking, horseback riding, camping, fishing and hunting. Use levels in this area are light to moderate throughout the snow free season with the fall hunting season (both bow season and general rifle season) likely being the time of year that the area sees the most use. Hiking / Horseback Riding: The project area sees a low to moderate level of interest from the pubic for day hiking and overnight hiking (backpacking) and stock parties. Access to trails is from a number of trailheads around the perimeter of the project area. One trailhead is located right on the edge of the project area but is not located within a proposed treatment unit. Some use trails through the project are to access longer trip routes to the west into the Scapegoat Wilderness Area Camping: Overnight camping use by the public is low to moderate within the project area. Camping opportunities within and near the project area primarily consist of the use of backcountry dispersed sites with no improvements or road accessible sites with minimal if any improvements. Access to a large majority of these sites is by trail travel. Most dispersed campsites are adjacent to a trail in very close proximity to a stream. Fishing: Fishing is a popular activity along some streams within the project area with Smith Creek being of the most interest. This activity attracts a moderate level of use from the public during the summer and is surpassed only by hunting in the fall in relation to visitation to this geographic area of the National Forest.

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Hunting: Big game hunting for elk and deer in the fall of the year is by far the most popular use of this area. Most hunting use is on a day use basis. A few groups each year do pack in and set up overnight camps. There are no commercial outfitter camps within the project area. There are 15 Forest Service System trails within the project area totaling approximately 34.1 miles. Of the approximate 34.1 total miles of trail within the overall project area, there are approximately 11.8 miles of trail that are within proposed treatment units. There are approximately 28 known locations (dispersed campsites) that show evidence of past recreational use by the public within the project area. There is one developed trailhead within the project area. Of the 29 recreation sites within the project area, there are six dispersed campsites that are within proposed treatment units. Currently off trail travel on foot or horseback within much of the project area is difficult to impossible due to extremely dense regenerating tree saplings and downfall as a result of the 1988 Canyon Creek Fire.

Environmental Benefits and Consequences

Past, Present, and Reasonably Foreseeable Future activities used in the Analysis A table of past, present, and reasonably foreseeable future activities in the area of the proposed project is available Appendix E. Activities which may have a cumulative effect are described below. None of the activities listed in Appendix E of this preliminary analysis document are thought to have a significant impact to recreational use of the proposed project area.

No Action Alternative Alternative 1 proposes no actions that are contained in either action alternative. Standard protection and maintenance activities would continue such as fire suppression, access management, and road / trail maintenance. Ecosystem processes such as impacts from insects and diseases in trees would continue their current trends. Safety concerns would escalate. Some incidental tree removal would occur through firewood cutting. Alternative 1 provides a baseline for comparison of environmental consequences of Alternatives 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

Direct and Indirect Effects Potential effects to the recreating public associated with this project fall into three distinct categories; 1) Potential effects to trail travel. 2) Potential effects to dispersed campsite use and 3) Potential effects to off trail travel and access. 1) Potential effects to Trail Travel: The potential effects to trail travel by taking no action from this proposal would result in a continued trail maintenance need over time as residual standing dead trees from the 1988 Canyon Creek Fire will continue to fall blocking the trail system in some locations. Taking no action would result in no need for any temporary trail closures due to management activities associated with this proposal. 2) Potential Effects to use of Dispersed Recreation Sites / Trailheads: Taking no action could result in a decreased use of the dispersed recreation sites as the extremely dense regenerating tree saplings and downfall as a result of the 1988 Canyon Creek Fire would still be present and block access and or pose safety concerns in some locations. 3) Potential Effects to Off Trail Travel and Access:

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The no action alternative would not present the opportunity to improve off trail travel conditions because the forest would not be opened up by treatment actions proposed in this project. Potential wildfire intensity would be expected to be higher under the no action alternative, consequently, increasing the potential for the likelihood of more standing dead trees in the area if a wildfire were to occur. Additionally, there would be continued increased difficulty in navigating off trail travel because the extremely dense regenerating tree saplings and downfall that resulted from the 1988 Canyon Creek Fire would not be treated in this area.

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

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

Direct and Indirect Effects 1) Potential effects to Trail Travel: The potential effects to trail travel by the implementation of this project are expected be minimal and of a short duration in time. Actual effects to the public from the need to close some trail segments for public safety within or adjacent to treatment units would involve not being able to use and traverse these trails during the time of actual implementation and for a very short time following treatment. In addition, there may be a period of time (several years) following implementation that there may be some level of increased downfall across trails within and adjacent to treatment units because individual trees or small groups of trees may near the trails die as a result of prescribed burn treatments. The potential for increased downfall following implementation could be acceptably mitigated by initiating routine monitoring of trail conditions within the project area and responding in a timely manner with an increased trail clearing emphasis on any sections of trail that exhibit elevated levels of downfall. 2) Potential Effects to use of Dispersed Recreation Sites / Trailheads: Some areas containing dispersed recreation sites within the project areas may need to be closed for public safety for a short period of time during actual project implementation and potentially for a short period of time afterward implementation. Some dispersed recreation sites that are within treatment units may have an elevated level of snag hazard (hazards associated with falling trees in burned areas) after implementation. Any elevated snag hazard in direct proximity to a dispersed recreation sites could be mitigated by having qualified personnel perform a Hazard Tree Evaluation of trees in proximity to sites within treatment units and then having crews fall any tree that poses a significant risk. This may need to be done immediately following implementation and also a second time in the spring of the year following implementation. However, it should be noted that while the agency does routinely take steps to evaluate and mitigate snag hazards within Developed Recreation Sites, it generally does not attempt to mitigate snag hazards in most Dispersed Recreation Site settings. 3) Potential Effects to Off Trail Travel and Access: This project has the potential to significantly improve recreational off trail travel conditions in some locations by removing some of the extremely dense stands of regenerating saplings and also to “clean up” downfall through the use of prescribed burning. In some locations within treatment units off trail travel conditions for the public may be notably improved by the implementation of this project.

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Cumulative Effects No cumulative effects to recreation are anticipated in relation to other actions in or near the project area as a result of this proposal. Heritage

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

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

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

Area of Analysis For the purposes of this analysis, the project area boundary described in Chapter 1 of the preliminary analysis is used as the general “heritage analysis area.” This area is researched for contextual information and for the existence of, or potential for the occurrence of cultural resources. Within this broad analysis area, a site-specific “area of potential effect”, is intensively analyzed under National Historic Preservation Act Section 106 review. The area of potential effect varies by alternative dependent on the location and nature of proposed treatments and of cultural resources. For this prescribed burning analysis, the area of potential effect includes locations of proposed activities and a buffer zone 100 feet beyond these areas. When a cultural resource site falls within or overlaps the area of potential effect, regulations require that the effects analysis be expanded to include consideration of that entire site (often including a site-specific buffer zone). Heritage resources in the non-Wilderness portion of the Rocky Mountain Division of the Helena- Lewis and Clark National Forest represent a diversity of cultures and landscape use. They represent cultural contexts that include prehistoric subsistence and art, Native American traditional and religious use, early white settlement, trapping, agriculture, logging, transportation, forest administration, recreation, irrigation, and even human burial. Project area sites or features related to these contexts include two prehistoric lithic material scatters (24LC1286 and 24LC2317), a special use permitted guest ranch (24LC2199), roads (including 24LC2008), and a logger’s steam donkey. Recognized historic districts and landscapes that overlap the project area are limited to the Forest Service Historic Trails System. Petty Ford Creek Trail 244 (24LC1288) through the north part of the project area is part of the trail system. The Elk Creek Ranger Station (24LC2198) represented Forest Service Administrative presence in the project area. It is shown on Forest maps from 1912 through 1956. It is not on the 1977 Forest map and no buildings are standing. The Double Falls tract of leased recreation cabins is located near the analysis area. The project area itself has relatively few recorded sites, mainly due to steep terrain and relatively few archeological surveys to date.

Effects Analysis Methods The key indicators for cultural resource analysis are generally: 1) the list of sites, by type, that are eligible for or included in the National Register of Historic Places, or those that have not been evaluated, which overlap with proposed activities; 2) the potential for the occurrence of cultural resources in areas that have not previously been surveyed; and 3) the nature of the proposed treatments. Undertakings involving ground disturbance or those that may adversely affect the character of significant cultural resources are primary considerations of the National Environmental Policy Act effects analysis. Sites that have been evaluated and found ‘not eligible’ (insignificant) according to criteria of 36 Code of Federal Regulation 60.4 are reviewed for context, but not otherwise carried forward into the analysis. The Regional Programmatic Agreement and the Forest-specific Site Identification Strategy address details of National Historic Preservation Act/Sec. 106 compliance. They prescribe certain percentages of survey coverage for various types of undertakings, in order to adequately complete Section 106 effects analysis. The amount of survey and research anticipated depends on the undertakings involved. Information from this portion of the analysis assigns the ‘potential for the occurrence of cultural resources’ used in both National Environmental Policy Act and National Historic Preservation Act review.

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Information from historic maps, the heritage resource database, and from numerous surveys done in the project area identifies specific locations of prehistoric and historic sites relative to proposed impact areas. This information provides historic context and helps identify both specific sites present and the kind of sites which may exist across the project area. To date, nine heritage survey projects have been done inside the project area, intensively covering 432 acres including the range of topographic settings which comprise the project area. Survey sampling strategies favor high site probability areas and comply with the Site Inventory Strategy that is part of the Programmatic Agreement. Because of especially poor surface visibility caused by regrowth following the 1988 Canyon Creek Fire, and because most project-area sites were thought to have burned in that fire, the Forest proposed to do most of the required heritage surveying soon after the units are re-burned, to take advantage of improved ground surface visibility. The State Historic Preservation Office concurred with this plan on April 1, 2015. For the known significant or unevaluated sites, avoidance or mitigation of impacts would be arranged ahead of prescribed burning. Surveys done to date have covered 4 percent of the proposed impact area. These would be supplemented with additional surveys, to ultimately cover 30 percent of the prescribed fire treatment acres. Post-prescribed burn surveys are a standard modus operandi for prescribed burn projects. Newly identified sites would be recorded and evaluated for significance.

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

Table 32: Historic Properties and Proposed Actions, Based on Alternative

Site & Eligibility. No Action Preferred Alternative Preferred Alternative Site Status Alternative Action for Relevant Unit Avoidance/ Mitigation Measures 24LC1286, Lithics, n.a. • Slash and burn conifers encroaching Near a unit. Staging & potentially eligible on natural openings and aspen stands implementation activities • Fell young conifers (less than 16 feet) must avoid site area. using power saws over portions of unit • Broadcast burn utilizing hand ignition 24LC2317, Lithics, n.a. • Slash and burn conifers encroaching Inside a unit. Create potentially eligible on natural openings and aspen stands. blackline or wetline around Use prescribed fire in existing aspen site to avoid burning across clones to encourage suckering. site. • Fell young conifers (less than 16 feet) using power saws over portions of unit

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Site & Eligibility. No Action Preferred Alternative Preferred Alternative Site Status Alternative Action for Relevant Unit Avoidance/ Mitigation Measures • Broadcast and jackpot burns utilizing hand ignition 24LC1288, Petty n.a. • Slash and burn conifers encroaching Forms a unit boundary. Ford Cr. Trail 244, on natural openings and aspen stands Implementation activities to potentially eligible • Fell young conifers (less than16 feet) avoid historic signs and using power saws over portions of blazes unit • Broadcast burn utilizing hand ignition 24LC2008, Cyanide n.a. • Slash and burn conifers encroaching No effect to road or its Cr. Rd 257, on natural openings and aspen stands. features, all modern. potentially eligible Use prescribed fire in existing aspen clones to encourage suckering. • Fell young conifers (less than16 feet) using power saws over portions of unit. • Broadcast and jackpot burns utilizing hand ignition. And • Broadcast burn utilizing combination of helicopter and hand ignition • Reduction of 30-50 percent in conifer regeneration in patches of approximately 20 to 100 acres • Reduction of heavy surface fuel loadings in patches of approximately 20 to 100 acre Target amount burned 202 to 337 acres (treat 30-50 percent). Stand replacement patches will generally be 100 acres or less. Treatments would occur in both densely stocked areas and also in some more sparsely stocked areas. Some dense forest areas would be retained. 24LC2198, Elk Cr. n.a. Proposal irrelevant due to site ineligibility. None needed due to site Ranger Station, no ineligibility. 24LC2199, Sky n.a. Proposal irrelevant due to site ineligibility. None needed due to site Mtn. Ranch, no ineligibility

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Alternative 1

Direct and Indirect Effects Under this No Action Alternative, all effects would be indirect effects. They would include on-going trends of increasing traffic, hunting and recreation activities; grazing pressure; wildfire risk; insect infestation; climate change; and erosion, compaction, and site exposure related to those situations. Of those effects listed, only wildfire risk and insect infestation are addressed by the proposed project. Choosing the No Action Alternative would not cause significant effects to cultural sites. See Table 1 of the heritage specialist report above.

Alternative 1 Cumulative Effects The area of analysis for this No Action Alternative is the project area boundary, the same area considered for the Action Alternative. No cumulative effects to cultural resources were identified for the No Action Alternative.

Alternative 2

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

Alternative 2 Cumulative Effects The area of analysis for the Action Alternative includes the project units and a 100 foot buffer around them. Past, present, and reasonably foreseeable actions in the area, unrelated to project proposals, were considered. (See Appendix E). Those potentially affecting sites include tree removal and grazing. Proposed actions involve prescribed burning. It is effects to sites can be avoided. Choosing the Action Alternative would not cause cumulative effects to sites. Also, as mentioned above, the prescribed burning treatments could limit future wildfire scale and/or intensity, reducing the need for suppression activities that can damage sites. This would reduce cumulative effects to sites, in the long run.

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

Methodology

Spatial & Temporal Scale The geographic analysis area for this proposal is defined as the project boundary, as all direct and indirect effects occur within the project area. The cumulative effects analysis area varies for each species analyzed and is specified in the section for that species along with the rationale for the extent chosen. The furthest extent of cumulative effects analysis is the four 6th code watersheds (HUC6) of Ford Creek, Upper Smith Creek, Blubber Creek and Upper Elk Creek. Temporally speaking, short-term effects are defined as those occurring within one to 20 years of project implementation. This time period includes direct, first order fire effects as well as the delayed, indirect effects of burning, and matches the timeframes used in the vegetation report. Long-term effects are considered to be from 100 to 150 years of implementation, as it represents the average rotation age of lodgepole pine, as described in the vegetation report, and is the timeframe over which habitat changes would occur.

Sources, Methods, and Assumptions Background information for all species is found in the document “Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities” (USDA Forest Service 2011). Species ranges were determined from the Montana Field Guide (Montana Field Guide), and personal knowledge. A determination of habitat within the analysis area was made using personal knowledge and field surveys of the proposed treatment areas, aerial photos, and Northern Region Existing Vegetation Mapping Program. Species occurrence was determined from forest records, surveys, and the Natural Heritage Tracker database (Natural Heritage Map Viewer). The geographic information system program ArcMap was used to determine acres of habitat and acres of habitat treated. Data from ArcMap was exported into excel spreadsheets that are found in the project record. Specific models used and assumptions of the analysis are described on the cover page of the spreadsheets.

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Table 33 Indicator Measures for Wildlife Species Species Units of Measure Scientific name (status*) grizzly bear • Acres of habitat (spring and denning) Ursus arctos horribilis • Acres by Management Situation (Threatened, Management Indicator Species) Canada lynx • Acres of habitat by boreal forest and structural stage Lynx canadensis • Acres of snowshoe hare habitat • Critical Habitat Primary Constituent Elements (boreal (Threatened, Critical Habitat, forest landscapes with a) snowshoe hare presence and Management Indicator habitat, b) deep fluffy snow, c) denning sites with Species) coarse woody debris, and d) matrix habitat wolverine • Acres of maternal and primary habitat (Inman 2013) Gulo gulo luscus • Acres identified by Copeland et al (2010) snow persistence model (Proposed , Management Indicator Species) American peregrine falcon Peregrine falcon is not known in or near the project area. They Falco peregrinus anatum are known to occur north of the area near the Forest boundary. There are some cliffs on the edges of the project area, but (Sensitive, Management surveys have not found peregrine falcons. There would be no Indicator Species) effects to peregrines from the proposed action and it will not be considered further. bald eagle There are no known sightings of bald eagle within or near the Haliaeetus leucocephalus Elk Smith Project Area. Habitat (large trees surrounding large water bodies) is not found in the project. There would be no (Sensitive, Management effects to bald eagle from the proposed action and it will not be Indicator Species) considered further. black-backed woodpecker • Acres of habitat Picoides arcticus • Snag numbers (Sensitive) burrowing owl Burrowing owl is not known in the project area. Habitat (open Athene cunicularia grasslands) is found at elevations below the forest boundary. There would be no effects to burrowing owl from the proposed (Sensitive) action and it will not be considered further. flammulated owl Flammulated owl is not known on the Rocky Mountain Ranger Psiloscops flammeolus District. Preferred habitat (mature growth dry ponderosa pine with open canopy) is not found within the project area. There (Sensitive) would be no effects to flammulated owl and it will not be considered further. greater sage-grouse The project falls outside the range of the greater sage-grouse. Centrocercus urophasianus There would be no effects to sage grouse from the proposed action and it will not be considered further.

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Species Units of Measure Scientific name (status*) (Sensitive) harlequin duck Harlequin duck is not known in the project area. The nearest Histrionicus histrionicus occupied habitat is 4.5 miles northeast of the project area in the South Fork Sun River. There would be no effects to harlequin (Sensitive) duck from the proposed action and it will not be considered further. bighorn sheep • Acres winter and lambing habitat Ovis Canadensis (Sensitive, Management Indicator Species) fisher Fisher are not known to occur in the project area. Recent Martes pennanti habitat modelling (Olson and others 2014) indicates there is low probability of habitat for this species on the Rocky (Sensitive) Mountain Ranger District due to deep snow and very cold temperatures. There would be no effects to fisher from the proposed action and it will not be considered further. Gray wolf • General discussion Canis lupus (Sensitive, Management Indicator Species) northern bog lemming • General discussion Synaptomys borealis (Sensitive) Townsend’s big-eared bat Townsend’s big-eared bat is not known to occur in the project Corynorhinus townsendii area. Mines and caves are the primary habitat for roosting, as well as buildings in some locations. The proposed action (Sensitive) would not effects mines, caves or buildings. There would be no effect to Townsend’s big-eared bat and it will not be considered further. greater short-horned lizard Greater short-horned lizard occur up to 4,500 feet in elevation Phrynosoma hernandesi in Montana (Montana Field Guide 2016) below the project area. There would be no effects to greater short-horned lizard (Sensitive) and it will not be considered further. elk • Acres winter and calving habitat • Cervus canadensis Acres effective hiding cover (Management Indicator Species) mule deer Odocoileus • Acres habitat hemionus, white-tailed deer Odocoileus virginianus

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Species Units of Measure Scientific name (status*) (Management Indicator Species) black bear Ursus • General discussion americanus, mountain goat Oreamnos americanus, mountain lion Puma concolor, dusky (blue) grouse Dendragapus obscurus (Management Indicator Species) beaver Castor canadensis, • General discussion bobcat Lynx rufus (Management Indicator Species) golden eagle Aquila • General Discussion chrysaetos, prairie falcon Falco mexicanus (Management Indicator Species) goshawk • Acres habitat in territory, post-fledging area, and nest Accipiter gentilis stand • Acre old growth (Management Indicator Species) American three-toed • Snag numbers woodpecker Picoides dorsalis (Management Indicator Species) migratory birds • General Discussion

Existing Condition The Elk Smith Project Forest Vegetation Report (project file) describes the existing condition of vegetation in the project area. The 1988 Canyon Creek wildfire impacted 74 percent of the project area and resulted in either very dense lodgepole pine forest or areas with very low densities or no trees. There are also many aspen stands scattered throughout the project area (Units 1, 2, 6, 7, 8, 9, 11, 12, and 13). Habitat types identified in the Forest Vegetation Report were used to determine potential shrub, forb and grass species present in the project area using the methodology discussed in the Blankenship Vegetation Treatment Project Understory Vegetation Report (USDA Forest Service 2012a). Further information regarding existing vegetation can be found in the Forest Vegetation Report.

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Grizzly Bear The Revised Biological Assessment For Terrestrial Wildlife Species – Benchmark Hazardous Fuels Reduction Project (USDA Forest Service 2010) and Lewis and Clark National Forest Evaluation and Compliance with National Forest Management Act Requirements to Provide for Viability and Diversity of Animal Communities (Evaluation and Compliance Report; USDA Forest Service 2011) provide information on grizzly bear habitat and species status on the Forest. The Elk Smith Project is within the Scapegoat Subunit of the Dearborn Elk Creek Bear Management Unit (BMU) and the South Fork Willow Subunit of the South Fork Sun Beaver Willow Bear Management Unit. Existing acres of habitat in these subunits is displayed in appendix A Section 2 of the wildlife specialist report in the project record. Twenty-one percent of the Scapegoat Subunit and 36 percent of the South Fork Willow Subunit are mapped denning habitat. Mapped denning habitat identifies high elevation areas where bears could excavate a den, generally in an open, steep site where snow cover during the winter is high. Mapped spring habitat is 44,051 acres in the Scapegoat Subunit and 42,105 acres in the South Fork Willow Subunit. The majority Forest Service Lands in the Scapegoat Unit is Management Situation 1 (57,738 acres), with three acres of Management Situation 3 in the subunit. The South Fork Willow subunit includes 89,955 acres of Management Situation1 lands and 6,592 acres of Management Situation 3 lands. The project area provides little habitat for grizzlies in its current condition as the dense forest does not provide foraging habitat, nor does it provide for travel or access to den sites.

Canada Lynx The Elk Smith Project Area includes portions of five Lynx Analysis Units (Appendix A Section 3a of the wildlife specialist report in the project record). Most of the project area is within Lynx Analysis Unit RM-25. Appendix A Section 3b displays the acres of existing lynx habitat within Lynx Analysis Unit RM- 25 by structural stage, as described in the Northern Rockies Lynx Management Direction Record of Decision Attachment 1 (USDA Forest Service 2007a). Lynx habitat was modeled in Lynx Analysis Unit RM-25 and the four Lynx Analysis Units surrounding it (RM-22, RM23, RM-24, and RM-26) using the Canada Lynx Habitat Mapping for Region 1 Eastside Forests (USDA Forest Service Northern Region Geospatial Group 2016), as modified (USDA Forest Service 2016b). The model modifications were made based on field data and knowledge of the project area. The model uses a spatial layer of Potential Natural Vegetation, along with spatial information on timber and fire activity, in combination with the Northern Region Existing Vegetation Mapping Program, to determine primary vegetation (subalpine fir dominated by cover types of spruce/fir, Douglas-fir, and seral lodgepole pine), secondary vegetation (other cool, moist habitat types, e.g. some Douglas-fir), and dry forest habitat types (ponderosa pine, dry Douglas-fir, and dry or climax lodgepole pine) as described in Appendix B of the Northern Rockies Lynx Management Direction Final Environmental Impact Statement (USDA Forest Service 2007b). Dry Douglas-fir and lodgepole were determined using aspects of west, southwest, south and southeast based on knowledge of vegetation in the project area. Within Lynx Analysis Unit RM-25, 66 percent (13,162 acres) of the Lynx Analysis Unit is lynx habitat (Appendix A Section 3 of the wildlife specialist report in the project record). Due to the Canyon Creek wildfire, approximately 9,050 acres (69 percent) of the habitat provides snowshoe hare habitat in the stand initiation and early stand initiation structural stages. Over half of this hare habitat (7,437 acres, 57 percent) is available in winter. There is very little mature, multi-story habitat in the Lynx Analysis Unit (258 acres, 1 percent). The Elk Smith Project is along the eastern boundary of Unit 3 (Northern Rockies Unit) of designated Critical Habitat for Canada lynx (USDI Fish and Wildlife Service 2014). As such, the project area and surrounding lands to the north, west, and south have been identified as containing the Primary Constituent Elements, which are “the physical or biological features essential to the conservation of lynx in areas occupied at the time of listing” (USDI Fish and Wildlife Service 2014, page 54811). The Primary

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Constituent Element for lynx is boreal forest landscapes supporting a mosaic of differing successional forest stages and containing: (a) presence of snowshoe hare and their preferred habitat conditions; (b) winter conditions that provide and maintain deep fluffy snow for extended periods of time; (c) sites for denning that have abundant coarse woody debris; and (d) matrix habitat to connect patches of boreal forest. Areas designated as critical habitat may “require special management considerations or protection” (USDI Fish and Wildlife Service 2014, page 54804).

Wolverine Wolverine habitat is modeled by Copeland (and others 2010) and Inman (and others 2013). The Copeland model (Copeland and others 2010) relies on the number of years snow persists until March 31 to indicate areas where wolverine will den. Under the Copeland model there are 225 acres where snow persists in four out of seven years; 1,895 acres where snow persists in three out of seven years; 2,761 acres where snow persists in two out of seven years; and 4,731 acres where snow persists in one out of seven years (Appendix A Section 4 of the wildlife specialist report in the project record). Inman modelled maternal habitat (suitable for use by reproducing females) and primary habitat (areas suitable for survival and use by resident adults). In the Elk Smith Project Area there are 180 acres of maternal habitat and 5,030 acres of primary habitat. The results of the two models are similar in the project area.

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

Bighorn Sheep Bighorn sheep activity primarily occurs on the Northeast boundary of the project, with some use occurring in the Steamboat Mountain and Elk Creek area (Lonner 2016). There are 1,005 acres of winter range and 191 acres of lambing range mapped along the northeast border of the project area (Appendix A Section 6, see Bighorn Sheep Range Map in Appendix B, both appendices can be found in the wildlife specialist report located in the project file).

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

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

Elk Elk occur within the project area. There are 1,360 acres of winter range and 9,164 acres of calving range (see Elk Range Map in Appendix B of the wildlife specialist report) in the Elk Smith Project Area (Appendix A Section 6 in the wildlife specialist report). Effective Hiding Cover was calculated for this project as described in Process for Analyzing Big Game Cover (USDA Forest Service 2016a). The Existing Effective Hiding Cover ranges from 41.7 to 87.2 percent across 18 seventh code watersheds (Appendix A Section 5 of the wildlife specialist report).

Mule Deer and White-tailed deer Mule deer habitat within the project area include winter range (2,488 acres) and transitional range (15,371 acres) (Appendix A Section 6, see Mule Deer Range Map in Appendix B in the wildlife specialist report). Fawning habitat is not mapped, however fawning occurs in the area. White-tailed deer use occurs on the lower elevations of the project, this species primarily uses lower elevation private lands.

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

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

Golden Eagle, Prairie Falcon Golden eagle and prairie falcon are known to occupy the cliffs surrounding the project area. Golden eagle sightings are recorded at Alpine Lake, Ford Creek, Sheep Mountain and Steamboat Mountain. There are prairie falcon sightings at Lone Chief Mountain within the project and at Cyanide Creek and Goss Creek off-Forest. There have been no recent surveys in this area.

Goshawk The status of goshawk on the Forest (through 2010) is described in the Compliance and Evaluation Report (USDA Forest Service 2011). Since 2010 an additional 16 territories were discovered (USDA Forest Service 2015) across the Forest. A thorough discussion of goshawk literature and Forestwide habitat is found in the Little Belt Hazard Tree Removal Wildlife Report and Biological Evaluation (USDA Forest Service 2014). As shown in Table 10 of that document, there is adequate habitat on the Forest to

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maintain a minimum viable population for the entire Northern Rockies Region. For the Elk Smith Project, goshawk habitat was determined using the Northern Region Existing Vegetation Mapping Program. The data and assumptions used are found in the UNIONGoshawkAnalysis.xlsx file located in the project record. Nesting habitat was determined using the parameters described in the Eastside Goshawk Nest Analysis (USDA Forest Service 2012b) for the Lewis and Clark National Forest. The amount of goshawk habitat in the project area is displayed in Appendix A Section 7a of the wildlife specialist report. There are three goshawk territories wholly or partially within the project area. They are Bailey Basin, Double Falls, and Ford Creek South. The Bailey Basin Territory is entirely within the project area (see Goshawk Map in Appendix B of the wildlife specialist report) in the Elk Creek drainage. This territory was discovered in 1991, just three years after the Canyon Creek wildfire, and fledged young in 2009, 2010 and 2013. The amount of habitat in the Bailey Basin Territory is displayed in Appendix A Section 7b, while Section 7e displays the habitat in the 477 acre post fledging area (both found in the wildlife specialist report). The Ford Creek South and Double Falls territories are in Ford Creek and Upper Smith Creek drainages respectively, along the northern boundary of the project area. These territories were discovered in 2006. Ford Creek South was occupied in 2007 and 2008, however nesting has not been documented since 2006. Nesting was documented in Double Falls every year from 2006 to 2010. A goshawk was present in the territory in 2014 however nesting was not observed. Habitat in the Double Falls Territory is displayed in Appendix A Section 7c of the wildlife specialist report. Appendix A Section 7d of the wildlife specialist report displays habitat for the Ford Creek South Territory.

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

Environmental Benefits and Consequences

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

No Action Alternative Alternative 1 proposes no actions. Existing management activities and natural processes would occur. As indicated in the Fire, Fuels, and Air Quality Report, the no action alternative perpetuates the heightened level of fire risk for the next 50 or so years as well as maintains the potential for severe wildfires. The Forest Vegetation Report states that stand regeneration in areas with poor regeneration after the Canyon Creek Fire would be gradual over the next 30 to 60 years. In areas of dense seedling and sapling stands, self-thinning of the stands would occur and standing snags would fall, adding to the already high fuel load. The aspen clones in the project area would mature, however competition from conifer trees would occur within 30 to 40 years. Alternative 1 provides a baseline for comparison of environmental consequences of Alternative 2 to the existing condition. It is a management option that could be selected by the Responsible Official.

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Direct and Indirect Effects

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

Cumulative Effects Under the no action alternative, natural processes would occur, including regeneration of forests, succession of plants species, and wildfire. Activities that are currently present in the project area, as described in Appendix E of this Preliminary Analysis, would continue. This includes grazing allotments, the Elk Creek administrative pasture, weed treatment, the Birch Creek South Record of decision, and the Benchmark III Fuels Reduction Project. The cumulative effects would be as those described in the Benchmark III Fuels Reduction Project Environmental Assessment (USDA Forest Service 2013). The no action alternative may affect, but is not likely to adversely affect, grizzly bear, Canada lynx, and Canada Lynx Designated Critical Habitat. There would be no effect to wolverine or its habitat. Changes in habitat over time result in a may impact individuals or habitat, but would not likely contribute to a trend toward federal listing or cause a loss of viability to the population or species for black-backed and American three-toed woodpeckers, and bighorn sheep. There would be no effect to gray wolf or Northern bog lemming would have no effect on gray wolf and northern bog lemming. Habitat changes over time for elk, deer, black bear, mountain lion, dusky grouse, and bobcat would result in localized habitat changes, but would not alter viability of these species on the planning unit, nor would it result in reduced hunting or trapping opportunities. There would be no changes to mountain goat, beaver, golden eagle, or prairie falcon habitat. Habitat for goshawk would increase in the project area, however no changes in the goshawk population in this area is anticipated due to the current condition of habitat it the area. There would be no changes to mountain goat, golden eagle or prairie falcon habitat.

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

Direct and Indirect Effects The habitat acres treated and post-implementation habitat acres are displayed in Appendix A of the wildlife specialist report. The calculations are located in Excel spreadsheets in the project record. The Forest Vegetation Report identifies habitat types in the project area. The primary understory vegetation associated with those habitat types include snowberry (Symphoricarpus albus), pinegrass (Calamagrostis rubescens), grouse whortleberry (Vaccinium scoparium), twinflower (Linnaea borealis; Howard 1993), and elk sedge (Carex geyeri). Additional species likely to be present are found in Appendix C of the wildlife specialist report. The Blankenship Understory Vegetation Report (USDA Forest Service 2012a) described the methodology used to determine the species list, and described the impacts of fire to those species. Information for the primary understory vegetation is summarized in this report.

Grizzly Bear The effects of the Elk Smith Project on grizzly bear are very similar to that described for the Benchmark Hazardous Fuels Reduction Project (USDA Forest Service 2010; USDA Forest Service 2013). In general, treatments that maintain natural openings and enhance aspen would remove understory conifers as well as thinning the canopy. The result would likely be more sunlight reaching understory shrubs, forbs and grasses, and a decrease in competition from conifers. In dense areas burning would be used to reduce fuels. We assume that in these units the effects would be to increase the size of openings, and stimulate growth of grasses and some forage species. In the Scapegoat Subunit, 2,767 acres would be treated to maintain openings and enhance aspen while 7,544 acres of dense stands would be burned to reduce fuels. In the latter treatment, approximately 3,722 acres, or half the total, would be treated. In the South Fork Willow Subunit, 19 acres would be treated to maintain natural openings and enhance aspen. There are 4,688 acres of proposed treatment on areas mapped generally as spring grizzly bear habitat in the Scapegoat Subunit, or approximately 11 percent of the spring habitat in the subunit (Appendix A Section 2 in the wildlife specialist report). In the South Fork Willow Unit there are 19 acres (0 percent) of spring grizzly bear habitat proposed for treatment. In the Scapegoat Subunit 2,206 acres of spring habitat is within units proposed for opening maintenance and aspen enhancement. All 19 acres of proposed treatment in the South Fork Willow subunit are within this treatment type. By maintaining or enhancing openings that provide foraging opportunities or by increasing productivity of forage species such as grasses and fruiting shrubs, treatments in these units have the potential to be beneficial to grizzly bears (Interagency Grizzly Bear Committee Guidelines 1986, pages 8-11; Zager and others 1983; USDA Forest Service 2012a). The remaining acres proposed for treatment in the Scapegoat Subunit are in units where the treatment would disrupt the fuel continuity by reducing 30 to 50 percent of the conifer regeneration in 20 to 100 acre patches. This treatment would result in approximately 1,241 acres of openings in spring grizzly bear habitat. Treatments are expected to have possibly beneficial effects on grizzly bear habitat by creating openings that provide foraging opportunities in the short-term. As trees re-establish in the openings and understory grasses and shrubs decline, the value of the area for foraging may decrease. This would happen in the five to 10 year period following implementation. There are 19 acres of mapped spring grizzly bear habitat proposed for treatment in the South Fork Willow Subunit in Unit 1. The proposed action is to maintain openings and enhance aspen. The same impacts as described above would occur. In the Scapegoat Subunit there are 781 acres (four percent) of mapped potential denning habitat within proposed treatment units. Of that, seven acres are within units proposed for opening maintenance and aspen enhancement. Those treatments would have no impact on available denning habitat, as treatments

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would not alter the elevation, slope, or snow depth during winter. In units proposed to disrupt the continuity of fuels, there are 774 acres of potential denning habitat. The areas proposed for treatment likely do not currently provide denning habitat, as the dense stands limit access and snow depth. Approximately 387 acres of the potential denning habitat would be treated, creating openings. The area would be more accessible to bears, and could provide additional sites for denning while it remains in an open condition (three to five years). There is no denning habitat in the South Fork Willow Subunit proposed for treatment. Under the proposed action, 18 percent (10,310 acres) of Management Situation 1 lands in the Scapegoat Subunit is proposed for treatment. Approximately 2,767 acres are within Units 1, 2, 7, 9, and 11 with treatments designed to maintain natural openings and enhance aspen using slashing and burning. The remaining 7,544 acres proposed for treatment are in units designed to disrupt fuel continuity and approximately 3,772 acres would actually be treated. Treatments in these units would consist almost entirely of broadcast burning. Spring burning may be necessary in order to achieve treatment objectives, due to the need for very specific vegetation and weather conditions for burning to be successful. Burning may occur in early spring, after snow has melted and before significant green-up of vegetation has occurred. Spring is the preferred burn season for Units 1, 2, 7, 9, and 11, as well as the portions of Units 12, 13, 14, and 15 near the private land boundaries. In the South Fork Willow Subunit 16 acres of Management Situation 1 and 3 acres of Management Situation 3 habitat is proposed for opening maintenance and aspen enhancement. Spring burning is the preferred season for these treatments. The Interagency Grizzly Bear Committee Guidelines indicate that some silvicultural treatments and managed burning may be used to improve grizzly bear forage species in Management Situation-1 habitat (Interagency Grizzly Bear Committee Guidelines 1986, pages 8-11). The guidelines recommend that such activities occur “at a time or season when the area is of little biological importance to grizzly bears” (Interagency Grizzly Bear Committee Guidelines 1986, page 8), although they note that when that is infeasible, operations should be restricted in time and space to avoid disruptions to bears. Prescribed burning that may occur in Management Situation-1 spring habitat can occur only in areas that have not significantly greened up, in order to carry fire as needed to achieve treatment objectives. It is unlikely that bears would be using these areas, as forage species are unlikely to be present yet in any quantity. Moist habitats where important spring forbs and sedges are generally found, such as areas within the riparian influence zone are not likely to be targeted for burning and are unlikely to carry fire. All of the spring habitat proposed for treatment in the Scapegoat Subunit is Management Situation-1 land. Sixteen acres of the proposed treatment in the South Fork Willow Subunit is spring habitat in Management Situation 1 lands. Burning in these units is likely to increase the size of openings and remove conifer encroachment, as well as remove understory conifers and cause limited mortality of larger overstory trees. Some regeneration of aspen is also expected. Ultimately, these treatments are likely to stimulate growth of some grass and forb species that may be important to bears in spring, through removal of competing conifer overstory and accumulated grassland litter. Burning in some areas may actually accelerate green-up of some grasses or other bear spring forage species. In sum, the potential for temporary disruption of spring foraging habitat is small, and may be outweighed by the potential for improvement of spring forage species. Burning that may occur in spring is not expected to affect spring forage to a degree that would displace bears from the area. Therefore the Interagency Grizzly Bear Committee Guidelines, as incorporated into the Forest Plan, would be met. The proposed action does not include any road or trail construction or reconstruction, therefore there would be no changes to motorized route density or the amount of area available as Core in the Scapegoat and South Fork Willow Subunits. The 1995 Interim Direction for Motorized Access in the Northern Continental Divide Ecosystem (Interagency Grizzly Bear Committee 1995) would continue to be met.

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All of the proposed treatments would involve personnel on the ground either hand felling and thinning or managing prescribed burning operations. All personnel, including contractors, would be required to adhere to the Food Storage Special Order at all times while on National Forest System lands. Activity associated with treatments would be in addition to normal levels of activity in the area, but would be of short duration. Because most of treatment units 1, 2, 7, 9, 11 and 12 are partly or entirely within the generally mapped spring habitat area, any slashing or thinning would occur only after June 30, when it is less likely that bears may be using any riparian areas or other spring forage locations that may be in or close to treatment units. This restriction in timing meets the Forest Plan standard requiring use of the Interagency Wildlife Guidelines in project planning and implementation. As discussed above, broadcast or prescribed burning may occur in spring, when conditions are appropriate for achieving treatment objectives. Burning in five treatment units (Units 1, 2, 7, 9, and 11) and portions of three units adjacent to private land (Units 12, 13, and 14) could occur in Management Situation-1 habitat in spring. As discussed above, although the Interagency Grizzly Bear Committee Guidelines recommend avoiding managed burning in Management Situation-1 spring habitat during spring, they recognize that at times this may be unavoidable (Interagency Grizzly Bear Committee Guidelines 1986, page 8). The Guidelines recommend that any activity occurring in these habitats during spring be “restricted in time and space to prevent significant disruptions of normal or expected grizzly activities.” Ten units (7,544 acres) within the proposed action require the use of aerial ignition. Based on past experience (Owen, personal communication 2016), one or two burn windows (one to three consecutive days) occur each spring and one burn window occurs every other year in fall. When a suitable burn window occurs, one to four units would be treated with helicopter operation happening as follows: • Reconnaissance flight mid-morning to make sure public and livestock were clear of the area. • Ignition beginning 1,200 hours or later with one or two helicopters; ending approximately 1,700 hours. • Additional reconnaissance flight over next couple of hours to monitor. • Possibility of aviation resources used to control fire within unit boundaries for an additional 0 to 5 days. In the units proposed for hand ignition, the nature and size of the proposed burns are such that human activity in the units is likely to be limited to less than 20 people on one day of burning, several of whom are likely to be stationed at an existing developed site such as a trailhead, airstrip, or campground. Burning is generally completed in less than five hours on a single day, with only one unit burned on a given day. One to three people are then likely to carry out follow-up activities such as fire mop-up or monitoring on the subsequent two to three days. Very occasional visits to the general area by one to two people over the next month may occur to monitor the effects of the fire. Therefore the potential impacts of operations would be restricted in time and space, in accordance with the Interagency Grizzly Bear Committee Guidelines, and potential displacement or disturbance of grizzly bears would be minimized. Because of the size of units and the separated nature of project activities relative to the available acreage of spring grizzly bear habitat in the Scapegoat and South Fork Willow Bear Management Unit Subunits and on the Rocky Mountain Ranger District in general, as well as implementation occurring over a 10 year period, project activities are not expected to displace bears in any measurable fashion. At most, an individual bear could be temporarily displaced from an area of project activity, but if such displacement were to occur it would be of short duration and distance due to the availability of both hiding cover and spring foraging habitat in the immediately adjacent areas.

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Canada lynx There are 6,293 acres (48 percent) of lynx habitat in Lynx Analysis Unit RM-25 proposed for treatment in the Elk Smith Project (Appendix A Section 3b of the wildlife specialist report). Most of the proposed treatment (5,490 acres) occurs in early stand initiation and stand initiation structural stages that provide snowshoe hare habitat. The assumptions made in determining project effects on habitat are described in the spreadsheet of lynx analysis located in the project record (UNIONLynxAnalysis2016data.xlsx). The proposed action results in an increase in early stand initiation habitat to 3,839 acres (29 percent of lynx habitat). Early stand initiation habitat can provide snowshoe hare habitat beginning approximately three years after treatment, however this habitat is only available during the summer as it is not tall enough to protrude above the snow. Stand initiation structural stage, habitat for snowshoe hare in the summer and winter, is reduced by the project as dense stands of lodgepole pine are targeted for treatment. Despite the reduction, 4,720 acres (36 percent) of lynx habitat in Lynx Analysis Unit RM-25 would continue to provide snowshoe hare habitat in the short-term. There are very few acres of mature, multi-story structural stage in the lynx analysis unit due to the Canyon Creek Fire of 1988. The proposed action would not alter this structural stage. There would be a slight decrease in acres of stem exclusion structural stage under the proposed action, and an increase of 565 acres in other structural stage due to thinning. The effects to lynx from the proposed action centers around the effects to snowshoe hare and its habitat. There would be a reduction in snowshoe hare habitat and a corresponding reduction in the number of hares available in the Lynx Analysis Unit until the early stand initiation habitat grows above the snowline in approximately 25 to 35 years. This would result in lynx in the area expending more energy to hunt. There would be no change in preferred winter foraging habitat (mature, multi-storied) for lynx, either negative or positive. These changes in structural stage are not anticipated to alter the ability of the Lynx Analysis Unit to support lynx, as there is an abundance of snowshoe hare habitat created by the 1988 fire. Under the proposed action, 25 to 60 percent of the coarse woody debris within treatment units would be consumed. This results in a slight decrease in available denning in the treatment units. This is not expected to impact individual lynx to a great extent, as there is ample coarse woody debris remaining outside the treatment units and over time the standing dead trees in the units would fall, creating more coarse woody debris. In addition, in some areas planned for treatment the density of trees is such that it is unlikely lynx are using the area to den. The proposed action would result in disturbance to any lynx in the project area during implementation. Although the project area is about the same area as Lynx Analysis Unit RM-25, the treatments would occur only on portions of the area at any one time. Lynx in the area of activity would be displace to existing habitat within the Lynx Analysis Unit. The Northern Rockies Lynx Management Direction Record of Decision (USDA Forest Service 2007a) amended the Lewis and Clark National Forest Plan with Standards and Guidelines specific to lynx. Consistency with those Standards and Guidelines is shown in Appendix E of the wildlife specialist report. Consistency with the most relevant of those Standards (VEG S1 and VEG S6) and Guidelines (Veg G5 and VEG G10) is summarized here: • Standard VEG S1 – Appendix A Section 3 displays the type and acreage of existing lynx habitat in Lynx Analysis Unit RM-25. The early stand initiation structural stage denotes snowshoe hare habitat that is not yet available in winter. The existing condition is 12 percent of the lynx habitat in early stand initiation. The proposed action would increase the acres of early stand initiation to 3,839 acres, or 29 percent of the lynx habitat. Standard VEG S1 is met under the proposed action. • Standard VEG S6 – There is very little multi-storied mature habitat in the Lynx Analysis Unit (248 acres, Appendix A Section 3 of the wildlife specialist report). Although 74 acres is included

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in proposed units, project design features do not allow active ignition on these acres. The fire may back through the area, but is expected to burn at very low intensity and not alter the structural stage. Therefore Standard VEG S6 is met under the proposed action. • Guideline VEG G5 – Red squirrel habitat consists of cone producing conifers. According to the Forest Vegetation Report, trees that re-established after the 1988 fire are beginning to produce cones; however in the high density stands cone production is expected to be lowest due to the small diameter of the trees. In general, habitat is provided by stands in the multi-storied mature, stem exclusion, and other structural stages. Limited habitat is available in the stand initiation structural stage. The proposed action would thin some areas, allowing smaller trees to grow and produce cone, and would eliminate high density stands that may be producing some cones. In all, over 4,600 acres of lynx habitat is expected to provide red squirrel habitat after the proposed action is implemented (Appendix A Section 3 in the wildlife specialist report). The proposed action is consistent with Guideline VEG G5. • Guideline Veg G10 – The Elk Smith proposed action follows standards VEG S1 and S6. Standards VEG S2 and S5 are not applicable to the project. The proposed action would have some effects to the components of the Primary Constituent Element of Canada lynx Designated Critical Habitat. The effects are discussed by component. • Presence of snowshoe hare and their preferred habitat – Within Lynx Analysis Unit RM-25 there are currently 9,305 acres of snowshoe hare habitat, or 71 percent of lynx habitat in the analysis unit. Very little of the existing habitat is multi-story mature (248 acres) due to the Canyon Creek Fire. Some of the habitat (1,610 acres) only provides habitat in the summer as it is not yet tall enough to protrude above the snowline in winter. The proposed action would reduce the amount of snowshoe hare habitat through burning. Due to the protracted implementation schedule (up to 10 years), the reductions would not all take place at the same time. In addition, snowshoe hare habitat would re-establish within three to five years of burning on many of the treated acres (Forest Vegetation Report). Within five years after the entire project has been implemented there would be 8,817 acres of snowshoe hare habitat, or 67 percent of lynx habitat in the Lynx Analysis Unit. A higher number of acres would provide only summer habitat (3,839 acres). Despite these changes, snowshoe hare and their preferred habitat would remain available in the Lynx Analysis Unit. • Winter snow conditions that are generally deep and fluffy for extended periods of time – The proposed action would not result in any changes to the availability of deep, fluffy snow in the project area. • Denning sites with abundant, coarse, woody debris – There is currently a well distributed downed wood component in the project area. This is part of the fuel loading issue that the proposed action addresses. The proposed action would result in a 25 to 60 percent decrease in the amount of coarse woody debris within the treatment units (Forest Vegetation Report), or over approximately half the Lynx Analysis Unit. There would be no reduction in existing coarse woody debris in the untreated areas. Within the proposed units, the large number of snags (standing dead tees) would continue to fall over time and contribute additional coarse woody debris for denning sites. Denning sites would remain abundant and available in the Lynx Analysis Unit under the proposed action. • Matrix habitat between patches of boreal forest that allows lynx to travel between habitat patches – Within the project area there are 4,780 acres of matrix habitat (non-boreal forest). Some of this would be treated and the structural stage changed, however it would continue to be forested habitat. Openings created would be 20 to 100 acres in size. There is very little boreal forest

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habitat to the north and prairie to the east of the project. Matrix habitat would continue to be available for lynx to move between patches of boreal forest to the northwest, south and west.

Wolverine According to the Copeland model (Copeland and others 2010), from 225 to 4,731 acres of persistent snow cover are within treatment units (Appendix A Section 4 of the wildlife specialist report). The proposed action would not alter the snow cover levels. Under the proposed action, 0.6 acres of maternal habitat and 642 acres of primary habitat (as described by Inman and others 2013) are within proposed treatment units (UNIONWolverineAnalysis.xlsx). The parameters that model habitat include latitude adjusted elevation, terrain ruggedness, April 1 snow depth, road density, interpolated human density, distance to high elevation talus, distance to tree cover, and distance to April first snow. The only parameter altered by the proposed action is distance to tree cover. The proposed action would create openings of 20 to 100 acres in size in dense lodgepole stands. If the openings were perfect circles, they would be from 0.2 miles to 0.45 miles across; a distance that wolverine can easily travel. The openings would be irregularly shaped and would persist for three to five years before regenerating. It would be another two to four years before the trees are tall enough to provide cover for a wolverine (about four to five feet tall). Project operations could displace foraging wolverine if they are present in area. Because of the small amount of habitat potentially impacted in relation to an individual wolverines home range (approximately 100,000 acres in Montana; Hornacker and Hash 1981), and the short duration of the impact (from three to seven years), the Elk Smith Proposed Action would not jeopardize the continued existence of wolverine. See Appendix D of the wildlife specialist report for the Programmatic Biological Assessment and concurrence.

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

Bighorn Sheep The proposed action would treat 1,005 acres (11 percent) of bighorn sheep winter range in the project boundary (Appendix A Section 6 in the wildlife specialist report). Bunchgrasses and shrubs are important food on winter range. Snowberry, pinegrass and elk sedge are identified as food for bighorn sheep (Montana Field Guide 2016, McWilliams 2000; Matthews 2000; Chadwick 2002). Snowberry has a high resistance to fire, with top-killed plants re-sprouting from rhizomes after a burn. The amount and extent of snowberry increases after fire, reaching a maximum within three to five years. Pinegrass is also top- killed by fire and re-sprouts from rhizomes. This species increases in response to fire in both frequency and cover. Elk Sedge has a high degree of resistance to fire, being one of the first to recolonize burned areas. Fire may improve forage production of elk sedge, a species preferred by bighorn sheep in winter. In all, burning is expected to improve forage conditions on bighorn sheep winter range. Spring burning would result in improvement the same year while fall burning may not see improved forage conditions

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until the following year. The Elk Smith Project may impact individuals or habitat, but is would not likely contribute to a trend toward Federal listing or loss of viability to the population or species.

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

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

Elk The proposed action includes treating 391 acres (29 percent) of elk winter range in the project area and 3,767 acres (41 percent) of elk calving range (Appendix A Section 6 of the wildlife specialist report). The winter range proposed for treatment is located within unit 1. Treatments consist of removing encroaching conifers to maintain openings and enhance aspen stands. Broadcast burning is targeted for the spring prior to green up. Some forage may be effected and unavailable the year the unit is burned, however burning would increase forage production (e.g. pinegrass, aspen). Maintenance of openings and enhancement of aspen stands would benefit winter range in the short and mid-term by maintaining availability of forage. Units 1 through 7 include elk calving range. Calving habitat varies, however habitat selection requires abundant succulent and nutritious vegetation (Innes 2011). Units 1, 2, and 7 (927 acres) are designed to maintain openings, reduce conifer encroachment, and enhance aspen stands. Treatment in these units would maintain a mix of openings and cover selected for by elk on calving habitat, as well as increase forage quality and nutritive quality (Innes 2011). Units 3, 4, 5, and 6 (2,840 acres) are designed to reduce the continuity of fuels and would remove 30 to 50 percent of the existing dense conifer regeneration as well as the heavy fuel loading. Treatments in these units, on approximately 1,420 acres of calving range, would create forage for elk in the short-term (until trees reestablish) and create 20 to 100 acre openings. Cover would be reduced, although the current density of trees makes it unlikely elk can utilize the existing cover in some areas. Unit 6 also contains aspen, which would be enhanced through the proposed treatment. Implementation of the proposed action would occur over approximately 10 years, therefore not all of the calving range would be treated at one time. Effective Hiding Cover is reduced in 16 of the 18 seventh code watersheds (HUC7) analyzed. The post- implementation Effective Hiding Cover ranges from 31 to 60 percent in the watersheds where hiding cover is reduced (Appendix A Section 5 of the wildlife specialist report). These changes would be evident in the short and mid-term. As trees grow and self-prune, as described in the Forest Vegetation report, Effective Hiding Cover would change. In the long term, hiding cover would return to treated acres as the trees regenerate, and would lessen in areas that self-prune and are impacted by beetles. There would be no roads constructed or reconstructed for the proposed action, therefore elk security values (Hillis and others 1991) and habitat effectiveness (Lyon 1983) are unchanged from the existing condition.

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Project operations would disturb elk in the project area. Slashing activities in Units 1 and 2 would occur after June 30 to minimize disturbance effects to calving elk. .Fall burning on winter range would push elk off the Forest into their primary winter range on private lands. Fall burning during the hunting season would limit access in the area of the burn for approximately one week. Although individual elk and elk habitat would be impacted by the project, treatment would improve several components of habitat in the project area. Viability of elk populations on the planning unit would not be impacted. Depending on burn windows and timing of treatments, hunting opportunities may be limited in localized areas in the short term.

Mule Deer and White-tailed deer The proposed action includes 6,717 acres (44 percent) of mule deer transitional range and 390 acres (16 percent) of winter range within the project boundary (Appendix A Section 5 of the wildlife specialist report). Most of the treated winter range is in Unit 1 (323 acres) and the effects are as described above for elk winter range. Units 11 and 12 include 67 acres of mule deer winter range. These acres are mature timber and openings and would not be targeted for treatment in these units. Fire may burn through the areas at a low intensity, removing the understory vegetation. This would increase palatability of forage in the area, but otherwise would not impact winter range. Mule deer transitional range includes all proposed units except Unit 13. Unit 11 includes five acres of transitional range in a sliver along the southwest boundary. Of the acres treated, 2,313 acres are within the units that are designed to maintain natural openings and enhance aspen. Treatments would improve transitional habitat by maintaining habitat heterogeneity (i.e. openings, aspen, mature forest) and increasing forage by burning. The remaining acres of transitional habitat (4,404 acres) are within units designed to reduce the continuity of fuels by removing conifer regeneration and heavy fuel loading. Approximately 2,200 acres would be treated. Treatments would result in increased heterogeneity of habitat and increased forage availability and palatability (Innes 2013). Aspen stands in Units 6. 8, 12, and 13 would develop into vigorous, mature clones (Forest Vegetation Report in the project record). Impacts to Effective Hiding Cover and disturbance are as described for elk. Although individual mule deer and white-tailed deer and their habitat would be impacted by the project, treatment would improve several components of habitat in the project area. Viability of deer populations on the planning unit would not be impacted. Depending on burn windows and timing of treatments, hunting opportunities may be impacted in localized areas in the short term.

Black Bear, Mountain Goat, Mountain Lion, Dusky Grouse Treatments that are designed to reduce heavy surface fuels (Units 3, 4, 5, 6, 8, 10, 12, 13, 14, and 15; 3,772 acres) would remove potential black bear denning habitat (deadfall) in the short-term. As snags continue to fall, additional denning habitat, in potentially more accessible habitat, would be available in the mid-term. In the long-term, as downed wood deteriorates, less denning habitat would be available to bears in the project area. Those same treatments would impact forage for black bears. Pinegrass and grouse whortleberry (Matthews 2000; Johnson 2001) can be killed by severe fire. Pinegrass would sprout from rhizomes and generally increases in frequency and cover in response to fire (Matthews 2000). Grouse whortleberry would initially decline after a fire but would recover within the short-term. These impacts to black bear habitat may affect individuals, however they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted Management Indicator Species. Mountain goat primarily use rocky cliffs in the project where treatments are limited. There is some potential goat habitat in the helicopter burn units on the western side of the project. In Glacier National Park mountain goats use pinegrass dominated ledges (Matthews 2000). Fire would impact pinegrass in

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the project area as described above. The Elk Smith Project may impact individuals and their habitat; however they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted Management Indicator Species. Mountain lion habitat would be impacted by the proposed action. In the short-term, treatments that improve aspen stands would enhance or maintain lion habitat. Burning of dense stands of conifer would not remove lion habitat, as the stands were too dense for lions to travel through and use. In the long-term, as stands mature into open conifer or closed conifer stands lion habitat would be increased. The Elk Smith Project may impact individuals and their habitat; however they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted Management Indicator Species. Dusky grouse eat snowberry and grouse whortleberry berries. Both of these plants are improved in the short-term by fire. Creation of openings and increased forest edges would also improve summer grouse habitat. The Elk Smith Project may impact individuals and their habitat; however they would not result in a loss of viability in the planning area or any changes to hunting opportunities for this commonly hunted Management Indicator Species.

Beaver, Bobcat Beaver habitat is within the riparian area. Project Design Features do not allow direct ignition in this habitat. Fire could back through the area, although high soil and fuel moisture would limit fire intensity and extent. The resulting low-intensity burn would remove some vegetation from the understory, including willow (Anderson 2006, Uchytil 1989, Uchytil 1992). This would temporarily reduce woody vegetation in isolated areas. Willow species sprout from the root crown following fire, so decreases in available browse would be replaced during the next growing season. These impacts to beaver habitat would not result in a loss of viability in the planning area or any changes to trapping opportunities for this commonly trapped Management Indicator Species. The proposed action would have no effect on rocky areas used by bobcat for denning. The treatments would remove dense understory on up to 3,772 acres (50 percent of units 3, 4, 5, 6, 8, 10, 12, 13, 14, and 15), thereby reducing preferred habitat in the project area. Dense understory would remain where it exists outside the treatment units and in the untreated portions of the treatments units. These impacts to bobcat habitat may affect individuals, however they would not result in a loss of viability in the planning area or any changes to trapping opportunities for this commonly trapped Management Indicator Species.

Golden Eagle, Prairie Falcon The proposed action would have no impact to cliff nesting habitat. Helicopter operations would cause disturbance to cliff nesting raptors if the helicopter approaches too close. This could result in coming off the nest during incubation which could lead to lower hatching rate, or could lead to nest abandonment. The Elk Smith Project may affect individuals, however would not result in a loss of viability of golden eagle or prairie falcon in the planning area. If the resource protection measure to route helicopter flights to more than ½ mile from cliff nests is implemented, the impacts to individual birds would be lessened, but not eliminated. The determination would not change with inclusion of this resource protection measure.

Goshawk The proposed action would alter goshawk habitat in the project area. Appendix A Section 7a of the wildlife specialist report displays the acres and percent proposed for treatment, by habitat descriptions from Reynolds (and others 1992), in the project area (from UNIONGoshawkAnalysis.xlsx). The project would increase the acres in openings and decrease the acres in small trees (0 to 4.9 inches diameter-at- breast-height), while also slightly decreasing the acreage of trees in the 5 to 9.9” diameter-at-breast-height

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category, the trees greater than 5.0 inches diameter-at-breast-height and greater than 50 percent canopy cover, and the acres of nesting habitat. Based on percent of each category, only changes in openings and trees 0 to 4.0 inches diameter-at-breast-height are evident (more than one percentage point). In the Bailey Basin Territory 2,155 acres (67 percent) are included in treatments. Seven-hundred thirty acres of that is within units that would maintain natural openings and enhance aspen stands. The remaining 1,425 acres of treatment would disrupt the fuel continuity and loading by treating 30 to 50 percent of the conifer regeneration (primarily stands in the 0 to 4.9 inches diameter-at-breast-height category), as well as improve aspen in Units 6, 8, 12 and 13. In order to show the greatest extent of impact, the analysis assumed 50 percent of the treated acres in the 0 to 4.9 inches diameter-at-breast- height and 5 to 9.9 inches diameter-at-breast-height size classes would become openings after treatment. Appendix A Section 7b of the wildlife specialist report displays changes by habitat category in this territory. In the Bailey Basin post-fledging area (PFA) 153 acres (32 percent) are within treatment units. The majority are within units where the treatment is designed to disrupt the continuity of fuels. Approximately five acres are within units that maintain natural openings and enhance aspen stands. Unit 12 also contains a large aspen stand that would be enhanced. Appendix A Section 7e of the wildlife specialist report displays the changes by habitat category. The greatest changes would be an increase in openings and a decrease in the 5.0 to 9.9 inches diameter-at-breast-height category, with a slight decrease in the 0 to 4.9 inches diameter-at-breast-height category. In the Double Falls and Ford Creek South Territories very little treatment is planned. Eighteen acres (0.7 percent) of Double Falls Territory and 14 acres (0.5 percent) of Ford Creek South fall within Unit 1. The slight changes in acres of habitat category do not result in any changes by percentage (Appendix A Sections 7c and 7d of the wildlife specialist report). There are no proposed treatments within the post fledging areas of these territories. Despite all the changes in habitat categories, the proposed action would improve conditions for goshawk. Goshawk hunt in the forest, flying between trees to catch prey. The current very dense stands in the project area do not provide habitat for goshawk because of the lack of flyways. These areas are likely production areas for some prey species; however the proposed action would increase the heterogeneity of the area thereby providing a more diverse prey base for this generalist species. Although the percentage of habitat in each category for the project area, the territories, and the post fledging areas does not match that recommended by Reynolds (and others 1992) (Appendix A Section 7a in the wildlife specialist report), it is similar to that observed on the Helena - Lewis and Clark National Forest. Recommendations are to maintain six areas of 40 acres each of nesting habitat in a territory (Brewer and others 2009). More than adequate nesting habitat would remain in the project area and territories after implementation. Use of the territories is similar to that observed across the Helena - Lewis and Clark National Forest (USDA Forest Service 2015) and is not expected to change due to the proposed action. Project operations could disturb nesting goshawk. Disturbance during incubation (generally mid-April through May) could lead to nest abandonment if it is prolonged. Slashing would occur outside the incubation period primarily due to access to the project area. During the nesting period abandonment is less likely. If the resource protection measure that limits slashing activity within ¼ mile of active nests is implemented, disturbance from slashing would be negligible. Helicopter operations and burning are not expected to disturb goshawk as they would occur outside the nesting and post-fledging periods.

Migratory Birds There would be little to no impacts to habitat of black swift, Calliope hummingbird, willow flycatcher and Cassin’s finch. Aspen habitat for olive-sided flycatcher would be enhanced by the proposed action. There would be no loss of individuals or impacts to populations from the proposed action. See the Elk

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Smith Migratory Bird Treaty Act Memorandum of Understanding Compliance Report (USDA Forest Service 2016c) in the project record for further information.

Cumulative Effects Cumulative effects are determined from past, present, and reasonable foreseeable actions in and near the project area. Appendix E of this Preliminary Analysis lists these actions. For the wildlife analysis, past actions are considered as part of the existing condition and are not analyzed further here. The Birch Creek South travel plan is also considered in the existing condition. Present projects within the cumulative effects area include Benchmark III Fuels Reduction Project, adjacent to Elk Smith’s northwest boundary. The only foreseeable project with potential cumulative effects is weed treatments that occur primarily along trails and roads. The Smith Creek Piscicide Project will not impact habitat for wildlife considered in the Elk Smith Project. Cumulative effects are analyzed at the scale relevant for each species, as described below. For grizzly bear the relevant cumulative effects scale is the Bear Management Subunit. The Benchmark III Fuels Reduction Project is within the South Fork Willow Subunit. There are 763 acres of mechanical tree removal and burning occurring within the Subunit. The effects of these treatments will add cumulatively to the effects of treatment on 19 acres under the Elk Smith Project. As described above, the treatments proposed on in the South Fork Willow subunit would maintain openings and enhance aspen, thereby increasing forage production. This adds to the same effect in the Benchmark III Fuels Reduction Project on 592 acres of the subunit. The additional effect is so small however, (0.5 percent of the Subunit total) that it will not result in changes to grizzly use of the area. Sixteen acres of the Elk Smith Project would occur in mapped spring habitat, adding to the 752 acres of treatment under The Benchmark III Fuels Reduction Project. This does not change the effect described in the Benchmark Biological Assessment (USDA Forest Service 2010) that less than 0.5 percent of the total mapped spring habitat on National Forest lands of the Rocky Mountain Ranger District, and approximately 4 percent of the mapped spring habitat in the South Fork Willow Subunit would be affected by the proposed treatments. The cumulative effect is immeasurable. Benchmark III also adds to the disturbance to grizzly bears from project operations. Disturbance during spring is mitigated by not allowing on the ground operations prior to July 1. Weed treatment may result in increased forage production in treatment areas by controlling competition. Treatments generally occur near trails and roads, habitat of low value to grizzly bears. Lynx cumulative effects are analyzed at the Lynx Analysis Unit scale. The Elk Smith Project occurs in Lynx Analysis Unit RM-25. The Benchmark III Fuels Reduction Project occurs in Lynx Analysis Unit RM-23. There are no cumulative effects. For the remaining species the cumulative effects analysis was conducted at the scale of the sixth code watersheds where the proposed action occurs. This includes Ford Creek (Hydrologic Unit Code 100301040501), Upper Smith Creek (Hydrologic Unit Code 100301040502), Blubber Creek (Hydrologic Unit Code 100301040503), and Upper Elk Creek (Hydrologic Unit Code 100301040504). Within this area, the Benchmark III Fuels Reduction Project treats 398 acres. The Benchmark III Project treats 293 acres of elk winter range, 398 acres of bighorn sheep winter range, and 308 acres of mule deer winter range where forage quality would increase. Taken cumulatively, four percent of elk winter range, three percent of mule deer winter range, and five percent of bighorn sheep winter range (Appendix A Section 6 in the wildlife specialist report) are impacted. Cumulatively these improvements do not impact populations due to the small overall area. The Double Falls and Ford Creek South goshawk territories are within both the Elk Smith and Benchmark project areas. Elk Smith proposes 18 acres of treatment in Double Falls and 15 acres in Ford Creek South that do not alter the percent of habitat in each size class. Therefore, goshawk habitat is not affected and there are no cumulative effects. The primary effect is disturbance in the territory. The

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Benchmark project does not allow activities with the post-fledging areas between April 15 and August 15 to minimize disturbance. Therefore, during the nesting season cumulative effects of disturbance are mitigated. There are no cumulative effects to wolverine because there is no habitat (Inman and others 2013; Copeland and Others 2010) in the cumulative effects boundary. The Benchmark III Fuels Reduction Project does not alter snag levels, therefore there is no cumulative effects to black-backed or American three-toed woodpecker. For the remaining species Benchmark III would add to the changes in habitat described for Elk Smith. Because of the small total area impacted cumulative effects would not alter populations in the area. The primary cumulative effect of the Benchmark III Project and weed treatments with the Elk Smith Project is disturbance to wildlife species in the area. The Benchmark III project is currently being implemented and is expected to be completed by 2021 Weed treatments are ongoing. Any disturbed wildlife would move away from the disturbance into available adjacent habitat. There is habitat adjacent to the project areas for all species analyzed.

Statutory and Regulatory Consistency Table 34 below summarizes the proposed action’s consistency with the relevant laws, regulations, and policies as previously introduced. Table 34: Summary of Statutory and Regulatory Consistency Regulatory Requirement Project Consistency National Forest Management Act This document analyzes the effects of the proposed action on Management Indicator Species and finds that viability would not be impacted. Forest Service Manual This document reviewed the proposed action for effects to Threatened, Endangered, Proposed, and Sensitive species. The proposed action does not result in adverse impacts on Threatened, Endangered or Proposed species. Impacts to Sensitive species are minimized and viability will not be impacted. Endangered Species Act The project is consistent with the Endangered species act. This document is the biological evaluation for Threatened, Endangered and Proposed Species. Consultation, as required under the Act and implementing regulations, will be conducted prior to a decision. Migratory Bird Memorandum of Understanding This document includes a discussion of migratory birds, as required under the Memorandum of Understanding.

Forest Plan Consistency A table indicating this project’s consistency with Forest Plan standards is available in the project record. Forest Plan standards of specific relevance are described below.

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Table 35: Forest Plan Consistency for Wildlife Resource Forest Plan Standards for Wildlife Project Consistency C-1 (5): Require a big-game cover analysis A big game cover analysis was completed. Analysis results are found in Appendix A Section 5 of the wildlife specialist report. The proposed action results in 31.1 to 59.9 percent hiding cover in the affected watersheds. This meets the Forest Plan standard of 30 percent effective hiding cover. C-1 (11): Use the Interagency Rocky Mountain Front The proposed action includes Project Design Features or Wildlife Monitoring/Evaluation Program Management resource protection measures (such as helicopter flight paths Guidelines in the management of land-use activities. staying ½ mile from active cliff nesting raptor nests) that were developed as part of the Monitoring/Evaluation Program. In addition, other restrictions and the travel plan incorporated the recommendations. C-2 (1): Comply with the Endangered Species Act, This is addressed above under Summary of Statutory and other related laws, executive orders, Forest Service Regulatory Consistency. Manual direction, National Forest Management Act implementing regulations, etc. C-2 (2): Conduct a biological evaluation of each This document is the Biological Evaluation. A Biological activity to determine if the activity may affect Assessment will be prepared and submitted to USDA Fish and Threatened and Endangered species. Wildlife Service prior to a decision. C-2 (3): Identify and evaluate cumulative effects as Cumulative effects are identified and evaluated above. part of each biological evaluation. C-2 (7): In occupied grizzly bear habitat comply with As stated in the effects section for grizzly bear, we comply the management direction based on Management with management direction on the Management Situation 1 situation as described fully in Appendix K of the lands in the project. Forest Plan (USDA Forest Service 1986). C-4 (1 – 11): maintain the recommended level of hard Per the Forest Vegetation Report, as described under black- snags in the project area. backed woodpecker and three-toed woodpecker above, the project area averages 22 snags per acre. Although some would be removed with treatments the project area will continue to exceed the 72 to 158 snags per 100 acres required by the plan.

Management Area Direction for each of the Management Areas states to ‘maintain’, or ‘minimize impacts’, or ‘maintain and enhance’ important identified wildlife habitat. The effects of the proposed action describe how habitat is maintained or enhanced for Threatened, Endangered and proposed species, sensitive species, and management indicator species. Inventoried Roadless Area and Visuals Report

Introduction This analysis describes the existing condition in portions of the Bear-Marshall-Scapegoat-Swan (BMSS) Inventoried Roadless Area (IRA) that are within the Elk Smith Fuels Project area. In addition, this roadless analysis describes the potential effects from the proposed activities identified in the alternatives of the Elk Smith Project to the roadless area characteristics and wilderness attributes of the Inventoried Roadless Area, as well as the unroaded lands contiguous to them. The Elk Smith Fuels project does not include any portions of the Sawtooth Inventoried Roadless Area which is adjacent to the Bear-Marshall- Scapegoat-Swan Inventoried Roadless Area. No activities will occur in the Sawtooth Inventoried Roadless Area within the Elk Smith Fuels project.

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Overview of Issues Addressed During the public scoping process, one comment was received regarding inventoried roadless areas. The specific responses to the comment and explanations of how the comments were addressed either in the analysis or through project design features, are included in Appendix A – Public Involvement Summary of the Environmental Analysis (EA). The following issue is relevant to the roadless resources within the analysis area: • Disclose how project complies with the Roadless Rule. (Alliance for the Wild Rockies Comment #36)

Issue Indicators Impacts to the roadless area characteristics as described in 36 Code of Federal Regulation 294.11 – Roadless Area Conservation, Final Rule and wilderness attributes of roadless areas as described in Forest Service Handbook 1909.12 (72.1) – Wilderness Evaluation.

Affected Environment The Elk Smith Fuels Project area is located on National Forest System land west and north of Augusta, Montana in Lewis and Clark County. The landscape is typical of mountainous areas located west of the Continental Divide but the topography varies. Much of the project area is steep and well timbered, but there are also rocky slopes and small grassy parks. Fairview Mountain, with an elevation of 8,246 feet, is the highest point within the area.

Existing Condition The Lewis and Clark National Forest Plan established Forestwide multiple-use goals, objectives, and management area requirements as well as management area prescriptions. Roadless areas are well distributed throughout the Forest and will be managed to provide semi-primitive recreation opportunities (USDA Forest Service 1986a). The analysis of roadless lands, documented in Appendix C of the Final Environmental Impact Statement for the Forest Plan, described each roadless area, the resources and values considered, the range of alternative land uses studied, and the effects of management under each alternative (USDA Forest Service 1986b). As a result of the analysis, some roadless areas were recommended for inclusion in the National Wilderness Preservation System and others were assigned various non-wilderness prescriptions. The Elk Smith Fuels project does not include any portions of the Sawtooth Inventoried Roadless Area which is adjacent to the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. No activities will occur in the Sawtooth inventoried roadless areas within the Elk Smith Fuels project.

Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is located in the Northern Continental Divide Ecosystem. The Helena-Lewis and Clark National Forest, Rocky Mountain District, manages this roadless area, which provides habitat for many wildlife species including, grizzly bear, black bear, cougar, lynx, fisher, marten, elk, whitetail and mule deer, wolf, moose, mountain goat, and bighorn sheep. The higher elevations provide important summer range habitat for big game species. The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area is especially important to many members of the public because of its proximity to other wilderness areas, providing the opportunities for expansive hiking, backpacking, hunting, cross-country skiing and equestrian travel. Livestock grazing and timber harvesting represent other uses (USDA Forest Service 1986b, FEIS Appendix C3 – C5). The Bob Marshal, Great Bear, and Scapegoat Wildernesses from the south can be accessed by traveling through the Elk Smith project area portion of this roadless area.

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Table 36: Inventoried Roadless Area Acreage

Total Acres in IRA Acres of IRA Percent of total IRA Name of Inventoried managed by the within the Elk acres within the Elk Roadless Area Rocky Mountain Smith Project Smith Project District Boundary Boundary Bear-Marshall-Scapegoat- 39,242 10,500 1.2 Swan *Portion of the Bear-Marshall-Scapegoat-Swan inventoried roadless areas managed by the Helena-Lewis and Clark National Forest, Rocky Mountain Ranger District. Total acreage of the Bear-Marshall- Scapegoat-Swan inventoried roadless areas managed by the Flathead, Lolo and Helena-Lewis and Clark National Forests is 866,330 acres (USDA FS 1986, FEIS Appendix C-3).

Desired Condition

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

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

Management Area Direction

Management Area E: • Recreation – Setting: Recreation setting is mostly roaded natural. Interaction between users may be low to moderate with evidence of other users. • Resource activities will be evident, but will blend with the natural environment.

Management Area H: • Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to moderate. The rural setting is a substantially modified environment. Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high.

Management Area O: • Recreation – Setting: The recreation setting is roaded either natural or rural. In roaded natural, resource activities will be evident, but will blend with the natural environment. Interaction between users may be low to moderate. The rural setting is a substantially modified environment.

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Resource modification and use is primarily to enhance recreation and to maintain vegetative cover and soil. Interaction between users is moderate to high.

Forest Service Handbook and Manual Direction • Forest Service Handbook (FSH) 1909.12 (72.1) provides definitions for the wilderness attributes of Inventoried Roadless Areas. • Forest Service Manual (FSM) 2300 – Recreation, Wilderness and Related Resource Management, guides management of recreation and wilderness resources on National Forest System lands.

Roadless Analysis Background and Direction Regional Foresters will review the following activities: d. Any necessary timber cutting or removal or any road construction or road reconstruction in emergency situations involving wildfire suppression, search and rescue operations, or other imminent threats to public health and safety in inventoried roadless areas. e. Timber cutting, sale, or removal in inventoried roadless areas incidental to the implementation of an existing special use authorization. Road construction or road reconstruction is not authorized through this re-delegation without further project specific review. f. The cutting, sale, or removal of generally small diameter timber when needed for one of the following purposes: 1. To improve threatened, endangered, proposed, or sensitive species habitat; 2. To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period; or, 3. For the administrative and personal use, as provided for in 36 Code of Federal Regulation 223, where personal use includes activities such as Christmas tree and firewood cutting and where administrative use includes providing materials for activities such as construction of trails, footbridges, and fences. The activities proposed within the Elk Smith project fall within the activities requiring Regional Forester review, as explained in c. 2, above. A briefing paper reviewing the proposed project activities was not required by the Regional Forester.

Environmental Consequences

Methodology Analysis was accomplished using ArcMap and relevant Geographic Information System (GIS) data layers from the Helena – Lewis and Clark National Forest, Rocky Mountain Ranger District, including trails, roads, recreation sites, inventoried roadless areas, summer and winter Recreation Opportunity Spectrum classes, winter use, and management areas. On-line visitor information provided by the Helena – Lewis and Clark National Forest and other local organizations was used as an overview of the roadless values and wilderness attributes within the analysis area. A review of existing law, regulation and policy relevant to roadless resources within the project area was conducted and relevant section of the Forest Plan and Forest Service Handbooks are referenced.

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Roadless Analysis The purpose of the analysis on the roadless resource is to disclose potential effects to roadless area characteristics and wilderness attributes from the Elk Smith Project proposed activities, and determine if, or to what extent these effects might influence future consideration for wilderness recommendations. This analysis focuses on the potential effects of project activities on roadless characteristics as defined in 36 Code of Federal Regulation 294 .11 – Roadless Area Conservation, Final Rule and wilderness attributes as defined in the Forest Service Handbook (FSH) 1909.12 (72.1).

Spatial and Temporal Context for Effects Analysis The potential direct and indirect effects to roadless resources were considered within the Elk Smith Project Area boundary. The direct effects would be short term and temporary, occurring during project implementation. The long-term indirect effects would be related to ecosystem restoration, changes in visual qualities, and other items within the project area that would influence several of the areas roadless characteristics.

Design Features There are numerous project design features in place to help minimize impacts to roadless resources such as Air Quality, Botany, Soils, Watershed and Fisheries, Visual Resources and Wildlife. A complete list of project design features is included in chapter 2 of the Environmental Analysis. The following project design feature is relevant to minimizing unauthorized motorized use associated with proposed activities within roadless areas:

Recreation • Implementation would include a public notification plan with consideration given to implementation timing and recreational uses such as hunting season. • Implementation would be coordinated with the Forest Public Affairs Officer and Law Enforcement to ensure the public is well informed of the schedule and its potential impacts.

Cumulative Effects Process Cumulative effects to roadless resources were considered within the 39,424 acre Bear-Marshall- Scapegoat-Swan Inventoried Roadless Area that is managed by the Helena-Lewis and Clark National Forest, Rocky Mountain Ranger District. Potential cumulative effects to roadless resources would be related to other activities occurring within the roadless expanse that have the potential to impact roadless area characteristics or wilderness attributes. Cumulative impacts to roadless resources would result if other activities take place during implementation of the Elk Smith Fuels project, or until Fuels growth obscures the visible stumps from the hand slashing of small diameter trees and hand fire lines, approximately three to five years.

Connected Actions, Past, Present, and Foreseeable Activities Relevant to Cumulative Effects Analysis The effects of past actions within the Elk Smith project area are incorporated into the description of the existing conditions. The following present and foreseeable actions are relevant to the cumulative effects analysis for roadless resources within the Elk Smith analysis area: Lewis and Clark National Forest, Rocky Mountain Ranger District:

• Benchmark Fuels Environmental Analysis

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• Rocky Mountain Ranger District Travel Plan Environmental Impact Statement, Badger Two Medicine Area • Rocky Mountain Ranger District Travel Plan Environmental Impact Statement, Birch Creek South Area • Range Allotments in the Inventoried Roadless Area • Weed and invasive species treatments

Issue Indicators The issue indicators for cumulative effects are the same as used for the direct and indirect effects listed previously.

Alternative 1 – No Action Alternative

Direct and Indirect Effects – Roadless Resources If the no action alternative is chosen, the proposed thinning and prescribed burning would not be implemented within the project area. There would be no direct effects from proposed activities to roadless resources. However, there would be a chance of an indirect effect under alternative 1, as the fuel reduction project would not occur, and the risk of severe wildfire would remain. In the long-term, this may result in indirect effects to roadless resources potentially resulting in changes to the recreation setting or scenic quality of the project area. An effect to wilderness attributes from taking no action would be to Naturalness (the extent to which long-term ecological processes are intact and operating). Fire would not be reintroduced into this fire- adapted ecosystem, fire suppression efforts would continue and the risk of large, severe wildfires would remain. This may detract from the characteristic of “naturalness” throughout the area, since conditions would not allow the reestablishment of fire as a natural process on the landscape.

Cumulative Effects There are no known cumulative effects to roadless resources from the no action alternative.

Irreversible and Irretrievable Commitments of Resources In the no action alternative, there would be no irreversible and irretrievable commitments of resources relevant to the roadless resources within the project area.

Alternative 2 – Proposed Action Under Alternative 2, the proposed action alternative, prescribed fire treatments developed to address fuel accumulation and continuity in the project area would be implemented. Treatments therefore consist of hand-slashing small conifers (generally up to 16 feet) and prescribed burning (broadcast and jackpot). Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events. Elk Smith Project units are summarized in Attachment 2: Treatment Units. Treatments would be staggered across time and space in order to meet project goals. Implementation is expected to begin in spring 2017 and is dependent on resource protection measures detailed in the environmental assessment. In general, units which border private lands would be prioritized for implementation. Proposed activities incorporate all resource protection measures.

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The only actions proposed within the Bear-Marshall-Scapegoat-Swan is prescribed fire, jackpot burning, and the associated hand slashing of small diameter trees. Commercial harvest and road construction are not part of the proposed action and therefore would not occur in the roadless area. The Elk Smith Fuels project does not include any portions of the Sawtooth Inventoried Roadless Area which is adjacent to the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area. No activities will occur in the Sawtooth Inventoried Roadless Area within the Elk Smith Fuels project. Therefore, no direct, indirect, or cumulative effects are expected in the Sawtooth Inventoried Roadless Area or within the roadless expanse.

Direct and Indirect Effects – Roadless Resources The activities proposed within the inventoried roadless areas include construction of hand fire lines, hand slashing of small diameter trees and prescribed fire. The map in Appendix A shows the units and treatments proposed within the roadless expanse. No treatments and therefor no effects are consider in the adjacent

Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area and Unroaded Lands Contiguous to the Inventoried Roadless Areas – Effects to Roadless Area Characteristics and Wilderness Attributes This analysis focused on the Wilderness Attributes listed in the Forest Service Handbook (FSH) 1909.12 (72.1) – Wilderness Evaluation. Natural – The extent to which long-term ecological processes are intact and operating. Reintroducing fire into this fire adapted ecosystem would begin reversing the trends caused from past fire suppression and reduce the risk of large, severe wildfires. This would enhance the characteristic of “naturalness” throughout the area, by establishing forest characteristics that would have been more typical of this area if fire had been allowed to play its natural role in landscape processes. Management-ignited prescribed fire, however, is a form of “modern human control or manipulation” and would to some extent affect the “untrammeled” and natural character within the roadless areas. The proposed action would enhance or help to maintain the roadless resources including high quality soil, water and air; diversity of plant and animal communities; and habitat for threatened, endangered, proposed, candidate, and sensitive species, and for those species dependent on large, undisturbed areas of land. See additional discussion of the roadless resources in Attachment 1: Elk Smith Roadless Characteristics Worksheet. Undeveloped – The degree to which development and uses are apparent to most visitors. There would be little evidence that the fires were initiated as a management tool versus natural ignition. The fire hand lines would create a linear disturbance within the roadless area. Stumps from the hand slashing of small diameter trees may remain visible for several seasons following the prescribed fire, which may detract from the undeveloped character for visitors traveling through the roadless area. There are also concerns that the hand lines could encourage unauthorized motorized use. Design features are in place to obliterate fire hand lines adjacent to or that intersect existing roads and trails to reduce the potential for unauthorized motorized use. Blackened trees from the prescribed burning would be noticeable; however, fire is a natural process and should not affect the roadless integrity. The proposed prescribed fire would help ensure the forest maintains a visual appearance characteristic of a wildfire within its natural regime as opposed to an unnaturally intense wildfire, thereby enhancing or helping to maintain the roadless characteristic of natural appearing landscapes with high scenic integrity. The creation of openings in the forest from low- and mixed-severity prescribed fire ranging from 20 to 100 acres in size would create a visually appealing mosaic in the landscape, enhancing the overall

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existing landscape character. See additional discussion of the roadless resources in Attachment 1: Elk Smith Roadless Characteristics Worksheet. Outstanding opportunities for solitude or primitive unconfined recreation – Solitude is a personal, subjective value defined as the isolation from sights, sounds, and presence of others and from developments and evidence of humans. Primitive recreation is characterized by meeting nature on its own terms, without comfort and convenience of facilities. There may be short-term effects to “solitude” within the project area during project implementation due to the presence of Forest personnel managing the prescribed fire and noise associated with the use of chainsaws for the hand slashing of small diameter trees. The proposed activities would not affect opportunities for “primitive and unconfined type of recreation.” See additional discussion of the roadless resources in Attachment 1: Elk Smith Roadless Characteristics Worksheet. Special features and values – Unique ecological, geographical, scenic, and historical features of an area - The proposed action would not affect the special features or values of the Bear-Marshall-Scapegoat- Swan Inventoried Roadless Area because there are no special features within the Elk Smith project area. The proposed action would maintain the productive and primitive Elk hunting opportunities within the Inventoried Roadless Area for approximately15 to 20 years and enhance these opportunities in the long- term. Hand lines within sites could alter historic and prehistoric sites. See additional discussion of the roadless resources in Attachment 1: Elk Smith Roadless Characteristics Worksheet. Manageability – The ability to manage an area for wilderness consideration and maintain wilderness attributes - Overall, the effects to wilderness character within the Inventoried Roadless Areas would be minor and short-term. The proposed action would not affect the suitability of the area for designation as Wilderness pursuant to the Wilderness Act of 1964.

Irreversible and Irretrievable Commitments of Resources In alternative 2, proposed action, there would be no irreversible and irretrievable commitments of resources relevant to the roadless resources within the project area.

Cumulative Effects Cumulative effects (Past, Present, and Reasonably Foreseeable Actions) to roadless resources were considered within the 39,242 acre Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area that is managed by the Helena-Lewis and Clark National Forest, Rocky Mountain District, and the unroaded lands contiguous to the Inventoried Roadless Areas. Potential cumulative effects to roadless resources are related to other activities occurring within the roadless expanse that have the potential to impact roadless area characteristics or wilderness attributes. Cumulative impacts to roadless resources would result if other activities take place during implementation of the Elk Smith Fuels project, or until vegetation growth obscures the visible stumps from the hand slashing of small diameter trees and hand fire lines, approximately three to five years. The effects of past actions within the Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area are incorporated into the description of the existing conditions for the Bear-Marshall-Scapegoat-Swan. The present and reasonably foreseeable future actions within the cumulative effects analysis area were reviewed for potential cumulative effects when the direct or indirect effects of the alternatives are added to them. The projects occurring within the spatial and temporal boundaries described previously for roadless resources cumulative effects analysis are considered here. Past harvest and fuel activities (1980’s to present) and wildfires (early 1800’s to present) have produced the environmental conditions now present in the Inventoried Roadless Area. The past activities include

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prescribed burning, wildfire, man-caused fire, fuels treatment, thinning, range improvements, timber harvest, reforestation needs and activities, and wildlife activities. Recreational activities such as hunting, camping, hiking, and snowmobiling and cross-country skiing in the winter would continue within the analysis area. Other ongoing and reasonably foreseeable activities that would be occurring within the analysis area include hazard tree removal, weed treatments, trail maintenance, commercial guided recreation, and ongoing use of grazing allotments. All of these activities, when added to the activities proposed in the Elk Smith Fuels Project have the potential to cumulatively affect the roadless values and wilderness attributes within the analysis area. The primary effects would be due to the increased presence of people and associated noise that would directly affect solitude and opportunities for primitive and unconfined recreation. The long-term impacts of other ongoing and reasonably foreseeable activities, such as noxious weed treatment and hazard tree removal, when added to the activities proposed in the Elk Smith Fuels Project, have the potential to cumulatively impact the natural and undeveloped characteristics by causing changes to the scenic qualities within the project area and creating a setting where “resource modifications and utilization practices are evident, but harmonize with the natural environment” as indicated in a Roaded Natural Recreation Opporutnity Spectrum setting. Most of these effects would be beneficial because they would increase the resiliency of forest conditions and reduce the risk of potential negative impacts from severe wildfire, therefore, maintaining the roadless and wilderness qualities that are currently valued by the public. Following are specific projects occurring within the Elk Smith project area with potential to cumulatively impact the roadless resources.

Summary of Effects of Both Alternatives Alternative 1, no action would have no direct or cumulative effects to roadless resources. The purpose and need for the Elk Smith Fuels Project would not be addressed. Potential long-term indirect effects to roadless resources would be due to the ongoing risk of severe wildfire that could lead to changes in the recreation settings, visual qualities and naturalness within the roadless expanse. In Alternative 2, prescribed fire and fuels reduction is proposed within the Inventoried Roadless Areas to promote ecological restoration of a mix of vegetation composition and structure across the landscape. Prescribed fire is proposed on about 10,331 acres (about 26.5 percent) within the Bear-Marshall- Scapegoat-Swan Inventoried Roadless Area. However, only portions of most treatment units will actually be treated. The proposed action, would have short-term direct impacts to roadless resources during project implementation such as increased presence of people and noise within the project area. Project design features are in place to limit potential effects. The proposed treatments would address the purpose and need for the Elk Smith Fuels Project, resulting in a more diverse, resilient and sustainable forest ecosystem with a reduction in risk of negative impacts from severe wildfire. The long-term indirect effects from alternative 2 to roadless resources would be generally beneficial and help to maintain the existing recreation settings and scenic qualities within the project area. Impacts would be stable or improving for a majority of roadless area characteristics and wilderness attributes with short-term impacts to the undeveloped character from the hand slashing of small diameter trees and construction of hand fire lines, short-term impacts to solitude during project implementation, and potential adverse effects to cultural resources. Cumulative effects to roadless resources would generally be short-term and related to an increased presence of people the associated noise that may affect solitude.

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Visuals

Introduction The visual quality (scenery) of the Elk Smith Fuels project area may be affected by actions proposed by this project. These effects vary in duration and intensity and are visible from a few identified viewpoints along the Elk Creek Road (Forest Road #196) up to the Elk Creek Trailhead within the project area and the private inholdings. The visual effects of these proposed activities will meet Forest Plan standards and Visual Quality Objectives (VQO) with the implementation of the identified design criteria.

Regulatory Requirements

Forest Plan Direction (goals, objectives, standards) The Lewis and Clark National Forest Plan provides overall direction for visual quality (scenery) on the forest. Forestwide Management Standard A-8 states that “Landscape management principles will be applied to all activities on the Forest. This will be accomplished by implementing the procedures defined in National Forest Landscape Management, Volume 2, Chapter I, of The Visual Management System (Agricultural Handbook No. 462).” (Lewis and Clark Forest Plan, pg. 2-28). The Forest Plan also “states a Visual Quality Objective (VQO) for each management area. These Visual Quality Objectives provide the guideline for altering the landscape.” (Lewis and Clark Forest Plan, pg. 2- 28) Proposed units are located within lands allocated to Management Areas E, G, H, O, Q and R. Guidelines for meeting Visual Quality Objectives are described in Forest Service Handbook 462, National Forest Landscape Management, Volume 2 and Table 37.

Table 37: Applicable Lewis & Clark National Forest Forestwide and Management Area Standards Standard Acres Visual Quality Objective Management Standard A-8 Not Applicable Meets Standard Meets Standard; occupied grizzly bear Management Standard E-4 Not Applicable habitat on the Rocky Mountain Division. Management Area E 2,748 Partial Retention Management Area G 17,018 Retention or Partial Retention Management Area H 597 Retention or Partial Retention Management Area O 3,431 Retention or Partial Retention Management Area Q 426 Preservation Management Area R Not Applicable Not Applicable

Manual Direction/Handbook Direction In 1986, when the Lewis and Clark National Forest Plan was adopted, the visual resource was inventoried and analyzed using the original Visual Resource Management System (VMS) as outlined in Forest Service Handbook 462, National Forest Landscape Management System, Volume 2, Chapter 1. This system, which was released in 1974, established standards of measurement (Visual Quality Objectives) for assessing proposed and existing impacts to the scenic quality.

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In 1994, after 20 years of experience with the Visual Resource Management System and after additional research in the public and private sectors, the Forest Service revised the Visual Resource Management System and replaced it with the Scenery Management System (SMS). This revised system is described in Agricultural Handbook 701, Landscape Aesthetics: A Handbook for Scenery Management. Scenery Management System will not be implemented until the Lewis and Clark National Forest Plan is revised. Both the Scenery Management System and the Visual Resource Management System will provide guidance for the effects analysis of the scenery (visuals) resource in the Elk Smith Fuels project area.

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

Analysis Methods Proposed activities in the Elk Smith Fuels project area may impact visual/scenic quality by introducing colors, lines, textures, and patterns that contrast with the existing landscape character of the project area. The measurement indicator for these effects is the visible effect of proposed activities as seen from the viewpoints identified as important in this analysis. This analysis includes both direct and indirect visual effects and will be analyzed to determine whether or not these effects meet the Visual Quality Objectives (VQOs) identified in the Lewis and Clark Forest Plan. Two visual landscape management systems were used to evaluate this project area. The Visual Resource Management System (National Forest Landscape Management System, Volume 2, Chapter 1, Handbook 462) and the Scenery Management System (Landscape Aesthetics, a Handbook for Scenery Management, Handbook 701). These two systems were used in combination with field study of the area. Through field visits, important viewpoints were identified, scenic integrity levels were determined and Forest Plan visual inventory data was verified. The Visual Quality Objectives for the Elk Smith Fuels project were reviewed prior to this analysis and found to be appropriate based on the current management direction for this area. No changes or refinements of the Visual Quality Objectives were found to be necessary for this area at this time. Desired conditions for the Elk Smith Fuels project were taken from the Lewis and Clark Forest Plan and from observations made in the field. These desired conditions were compared with the existing conditions of the area and the results of implementation of the alternatives.

Analysis area boundary The Elk Smith Fuels project area boundary will be used to conduct the visual (scenery) resource analysis for this project.

Existing Condition

Scenic Integrity of the Elk Creek Drainage Scenic integrity is defined in USDA Handbook 701 as: …a measure of the degree to which a landscape is visually perceived to be "complete." The highest scenic integrity ratings are given to those landscapes which have little or no deviation from the character valued by constituents for its aesthetic appeal. Scenic

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integrity is used to describe an existing situation, standard for management, or desired future conditions. Using definitions contained in this handbook, the landscapes of the Elk Creek drainage "appear to be slightly altered". These deviations are typically visually subordinate to the surrounding landscape and have a scenic integrity level that is defined as "moderate". Mine tailing ponds and other mining activity do not occur on National Forest lands, but impacts, including some tailings, do affect public lands. Past timber harvesting in the drainage is not typically visually evident from the main Elk Creek Road (Forest Road #196), except for middle ground views up near the private inholdings. Power lines are evident along parts of Forest Road #120, as is fencing and pastureland in private lands. Generally, the landscape appears visually to be very intact. There is, however, concern about pine-dominated landscapes (lodgepole pine) with stands that are becoming increasingly at risk to insect infestation and disease because of past drought conditions. Some of these stands are showing a moderate to high amount of mortality due to increasing insect infestation and portions of these stands are visible from the Elk Creek corridor. Fire suppression in the past 80 to 100 years has had an impact on the scenic integrity of the vegetative condition in the Elk Smith Fuels project area. In the drier habitat types, naturally occurring fires would have periodically burned through these stands and across the open parks in the area creating an “open grown” forest condition and keeping encroaching trees out of the parks. Far fewer understory trees would have existed. Currently, these forests have developed dense patches of younger-aged trees that dominate these sites. In the wetter habitats, under prime conditions, fire would have created more stand replacing patterns, where all or most of the trees would have been killed. A problem associated with lack of wildfire, due to past fire suppression, is the decline of quaking aspen, a species that thrives from frequent fire entry. This species occurs throughout the drainage, but is being overtaken by conifers and being shaded out in many areas. Fire has the tendency to kill competing conifers or invigorate aspen clones by killing older trees and encouraging the establishment of young trees. Aspen, like lodgepole pine, rely naturally upon wildfire to create suitable sunny habitats where they can vigorously compete with other more shade-tolerant species.

Landscape Visibility Landscape visibility addresses the relative importance and sensitivity of what is seen and perceived in the landscape. The Elk Smith Fuels project area can be viewed from a few locations along the main road and trails in the area. Views from the Elk Creek Road (Forest Road #196), dispersed recreation sites and hiking trails along this route are considered to be the most important.

Internal Issues Studied in Detail What are the effects of the proposed Elk Smith Fuels on visual/scenic quality? Proposed activities in the Elk Smith Fuels project area may impact visual/scenic quality by introducing colors, lines, textures, and patterns that contrast with the existing landscape character of the project area. The measurement indicator for these effects is the visible effect of proposed activities as seen from viewpoints identified as important in this analysis and as measured against the Visual Quality Objectives (VOQ) established for this area by the Lewis and Clark Forest Plan.

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Environmental Effects Analysis

Effects Common to Both Alternatives At present, insect infestations are causing some mortality in the pine and Douglas-fir tree communities in the Elk Smith Fuels project area. Specifically, mountain pine beetle is infesting and killing the lodgepole pine trees and Douglas-fir beetle is creating mortality in the Douglas-fir trees. This mortality is obvious to those who live in the private inholdings and for those people traveling Elk Fork Road. The infested trees are most noticed as red-needled trees or standing dead trees. These trees are noticed in small groups or clumps or scattered individuals of red or dead trees in an otherwise green forest canopy. Mortality as a result of these insects will continue to be visually evident in the Elk Smith Fuels project area regardless of the alternative chosen. It is anticipated that many of the dead trees within close proximity to the Elk Creek Road (Forest Road #196) will be cut down by local people for firewood. The effects of firewood cutters can vary. In general, firewood cutters take those trees that are already dead and the patterns of removal from firewood gathering tend to echo what is happening naturally across the landscape. Often landscapes that have had a moderate degree of firewood taken out, especially next to busy roads, can appear quite messy, with slash piles and tree tops left randomly scattered across the forest floor. These visual effects diminish over time, but can initially create a noticeable visual change to the scenic quality of an area if there is a large patch of dead being removed. Fire suppression in the past 80 to 100 years has had an impact on the scenic integrity of the vegetative condition in the Elk Smith Fuels project area. In the drier habitat types, naturally occurring fires would have periodically burned through these stands and across the open parks in the area creating an “open grown” forest condition and keeping encroaching trees out of the parks. Far fewer understory trees would have existed. Currently, these forests have developed dense patches of younger-aged trees that dominate these sites. In the wetter habitats, under prime conditions, fire would have created more stand replacing patterns, where all or most of the trees would have been killed. Concerns about wildfire in this project area are amplified by the increasingly large numbers of dead or down trees considered to be “fuel” for fires, by the proximity of private inholdings. In general, wildfire, whether it be a ground fire that burns underneath the canopy of trees or a “stand replacing” fire that kills large patches of trees, tends to create natural patterns that are inherent on these landscapes. The Visual Quality Objective’s established for the project area by the forest plan, will be met by any future wild fires in the project area.

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

Direct and Indirect Effects Tree mortality as a result of infestations of mountain pine beetle and Douglas-fir beetle, is creating a pattern of red-needled trees across many of the forested landscapes in the Elk Smith Fuels project area. The no action alternative proposes to do nothing with these trees, leaving them in place on the landscape to create natural patterns of dead within the live forest canopy.

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As mentioned above in the effects common to both alternatives, there would be some visual impacts created by firewood gathering activities along the Elk Creek Road (Forest Road #196).The Visual Quality Objective’s established for this area by the Forest Plan would be met, even with the anticipated tree removal by firewood cutters. Wildfires, both under burns and stand replacing, may create additional changes to the visual/scenic quality of the project area over time. The Alternative 1 would not initiate prescribed fire to reduce fuels in these areas.

Alternative 2 Alternative 2 is the proposed action alternative. Alternative 2 concentrates on the reduction of fuels in stands located adjacent to or nearby private properties and areas of high dispersed camping use within the project area. In addition to fuels reduction, these units would also protect mature forests, and increase the overall health and vigor of younger forests. Slashing of small diameter trees combined with prescribed burning would also be initiated to further reduce the fuels across the landscape. Alternative 2 would initiate changes to the visual or scenic quality of the area and these effects would meet the Forest Plan standards and Visual Quality Objectives established for the project area. There are design criteria that are required to reduce the visual effects of the proposed actions, particularly of those units visible from Elk Creek Road (Forest Road #196).

Effects of Fuels Treatments In the Elk Smith Fuels project, slashing is recommended as a pre-treatment for some of the prescribed burning units. Slashing is the cutting down of smaller trees (less than 6 inches diameter-at-breast-height) and the laying of them on the forest floor beneath stands of larger trees. This process creates a more open appearing stand with opportunities to view greater distances across the otherwise forested landscape. It not only removes dense understory trees but also provides a fuel bed for fire to carry beneath the crowns of the existing overstory trees. Initially, these effects are quite noticeable but would quickly begin to blend with the surrounding vegetation.

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

Cumulative Effects Cumulative effects in the Elk Smith Fuels project area include past, present, and foreseeable future timber harvesting, prescribed burning, road reconstruction, recreational use, range developments, private land development, special use permits, and weed spraying. The following past, present and foreseeable actions were considered in the cumulative effects analysis. Lewis and Clark National Forest, Rocky Mountain Ranger District: • Benchmark Fuels Environmental Assessment • Rocky Mountain Ranger District Travel Plan Environmental Impact Statement, Badger Two Medicine Area • Rocky Mountain Ranger District Travel Plan Environmental Impact Statement, Birch Creek South Area

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• Range Allotment Management • Weed and Invasive Species Management

Cumulative Effects of Alternative 1: The above actions will have many and varied effects to the visual quality of the Elk Smith Fuels project area. The most obvious of these would be those effects created by the firewood gathering adjacent to the private inholdings. These activities combined with the natural process of insect, disease, and wildfire would have some effects to the scenery of the project area but these would be short-term (three to five years). Even with these activities taking place Forest Plan standards (Visual Quality Objectives) would be met.

Cumulative Effects of Alternative 2: The cumulative effects analysis boundary for the visual resource is the same as the Elk Smith Fuels project area boundary. As described above, there are few past, present, and foreseeable actions that will, would, or have taken place in the Elk Smith project area that would leave visual effects. The most obvious of these would be those effects created by the fuels reduction work and firewood gathering. These activities would have some effects to the scenery of the project area. For three to five years, while the bulk of the activities are being accomplished, including vegetative treatment proposed by the Elk Smith Project, the area would appear very busy. However, the long-term Forest Plan standards would be met.

Monitoring Roadless Area monitoring would consist of visually surveying units treated with prescribed fire to determine if illegal off-highway vehicle use is taking place in treated areas. If monitoring reveals this is happening, steps would be taken to eliminate the use (i.e. signing, barrier installation, increased law enforcement). Environmental Justice Examination of community composition, as required under Executive Order 12898, found no minority or low income communities or groups to be disproportionately affected under any of the vegetation alternatives. This was not raised as an issue during public scoping.

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Personnel Consulted Federal, State, and Local Agencies Contacted

Preparation of this environmental assessment was done by the following: Wayne Green Forest Hydrological Technician Mark Bodily Forest Archaeologist Jason Oltrogge Range and Noxious Weeds Specialist Megan McGinnis Soil Scientist David Shanley-Dillman Roadless and Visuals Kraig Lang Recreation Specialist Laura Conway Forest Wildlife Biologist Kelly Keim Archaeologist Michael Muňoz Rocky Mountain District Ranger Tanya Murphy Silviculturist/Sensitive Plant Coordinator Russell Owen Fuels Specialist Kendall Cikanek Forest Fisheries Biologist Dave Yarger GIS Specialist Jennifer Woods NEPA Coordinator Michael Ferrell Writer/Editor Erin Fryer Interdisciplinary Team Leader

Others Agencies and/or Groups Contacted Montana Fish Wildlife and Parks USDA—Natural Resources Conservation Service Montana State Historic Preservation Office U.S. Fish and Wildlife Service Lewis and Clark County Commissioners Montana Department of Natural Resources Montana Department of Environmental Quality Teton County Commissioners Northern Region NEPA Coordinator Tribes Contacted Little Shell Tribe Blackfeet Tribe

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Confederated Salish/Kootenai

PROJECT MAILINGS Scoping letters, information and correspondence over the course of this project was mailed to recreation residence permit-holders, lodge and resort owners, interested individuals, organizations, groups and cooperators. Tribal Governments and applicable regulatory agencies were also contacted.

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Appendix A: Maps

Figure 6: Elk Smith Project Vicinity Map

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Figure 7: Elk Smith Project Alternative Map 2016

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Figure 8 Elk Smith Project Inventoried Roadless Map 2016

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Appendix B: Treatment Units Proposed actions under the Elk Smith Project were developed to address fuel accumulation and continuity in the project area. Treatments therefore consist of hand-slashing small conifers (generally up to 16 feet) and prescribed burning (broadcast and jackpot). Proposed treatments would reduce fuel loadings and provide for favorable conditions to protect resources from future fire events.

Unit-specific treatments align with existing conditions on the ground to meet project goals. Prescriptions do not apply to the entire unit, but to those areas which meet our purpose and need, and which are further detailed by treatment descriptions in Table 38 below.

Treatments would be staggered across time and space in order to meet project goals. Implementation is expected to begin in fall 2017, continue for five to 10 years and is dependent on resource protection measures discussed in this preliminary analysis and detailed in appendix C which follows. In general, units which border private lands would be prioritized for implementation.

Table 38: Elk Smith Proposed Treatments Anticipated Unit Acres Area Purpose Treatments Season • Slash and burn conifers encroaching on natural openings and aspen stands. Maintain natural openings Spring or fall, 1 546 Petty Creek • Fell young conifers (less than 16 feet) using power saws over as fuel breaks spring target portions of unit. • Broadcast and jackpot burns utilizing hand ignition. • Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in existing aspen clones to Maintain natural openings encourage suckering. Spring or fall, 2 372 Petty Creek as fuel breaks; encourage • Fell young conifers (less than 16 feet) using power saws over spring target aspen suckering portions of unit. • Broadcast and jackpot burns utilizing hand ignition. Disrupt continuity of fuels • Broadcast burn utilizing helicopter ignition. throughout unit (downed • Burn conifer regeneration and heavy surface fuel loadings (1,000 to trees and continuous 10,000 hour fuels). Spring or fall; 3 1657 Weasel Creek conifer stands); reduce the • Reduction of 30-50 percent in conifer regeneration in patches of 20 fall target future risk of high intensity to 100 acres; total target acreage of 500 to 830 acres. and high severity fires in • Reduction of heavy surface fuel loadings in patches of 20 to 100 area between wilderness acres

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Anticipated Unit Acres Area Purpose Treatments Season boundary and Forest and • Stand replacement patches not to exceed 100 acres; treatments private land boundaries would occur in densely stocked areas and also in some more sparsely stocked areas, some dense forest areas would be retained. • Broadcast burn utilizing helicopter ignition Disrupt continuity of fuels throughout unit (downed • Target conifer regeneration and heavy surface fuel loadings (1,000- trees and continuous 10,000 hour fuels) conifer stands); reduce the • Reduction of 30-50 percent in conifer regeneration in patches of 20-100 Spring or fall; 4 1047 Weasel Creek future risk of high intensity acres; total target acreage of 314-525 acres spring target and high severity fires in • Reduction of heavy surface fuel loadings in patches of 20-100 acres area between wilderness boundary and Forest and • Stand replacement patches not to exceed 100 acres; treatments would private land boundaries occur in densely stocked areas and also in some more sparsely stocked areas, some dense forest areas would be retained • Broadcast burn utilizing helicopter ignition Disrupt continuity of fuels throughout unit (downed • Target conifer regeneration and heavy surface fuel loadings (1,000- trees and continuous 10,000 hour fuels) conifer stands); reduce the • Reduction of 30-50 percent in conifer regeneration in patches of 20-100 Spring or fall; 5 628 Weasel Creek future risk of high intensity acres; total target acreage of 188-315 acres fall target and high severity fires in • Reduction of heavy surface fuel loadings in patches of 20-100 acres area between wilderness boundary and Forest and • Stand replacement patches not to exceed 100 acres; treatments would private land boundaries occur in densely stocked areas and also in some more sparsely stocked areas, some dense forest areas would be retained.

Disrupt continuity of fuels • Broadcast burn utilizing helicopter ignition. throughout unit (downed • Target conifer regeneration and heavy surface fuel loadings (1,000- trees and continuous 10,000 hour fuels). conifer stands); reduce the • Reduction of 30-50 percent in conifer regeneration in patches of 20-100 future risk of high intensity Spring or fall, 6 588 Elk Pass acres; total target acreage of 175-294 acres. and high severity fires in fall target area between wilderness • Reduction of heavy surface fuel loadings in patches of 20-100 acres. boundary and Forest and • Stand replacement patches not to exceed 100 acres; treatments would private land boundaries; occur in densely stocked areas and also in some more sparsely stocked encourage aspen suckering areas, some dense forest areas would be retained.

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Anticipated Unit Acres Area Purpose Treatments Season • Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in existing aspen clones to Maintain natural openings encourage suckering. Spring or fall, 7 748 Elk Pass as fuel breaks; encourage • Fell young conifers (less than 16 feet) using power saws over spring target aspen suckering. portions of unit • Broadcast and jackpot burns utilizing hand ignition Disrupt continuity of fuels • Broadcast burn utilizing helicopter ignition. throughout unit (downed • Target conifer regeneration and heavy surface fuel loadings (1,000 trees and continuous to 10,000 hour fuels). conifer stands); reduce • Reduction of 30 to 50 percent in conifer regeneration in patches of future risk of high intensity 20- to 100 acres; total target acreage of 175 to 292 acres. Spring or fall, 8 584 Elk Pass and high severity fires in • Reduction of heavy surface fuel loadings in patches of 20 to 100 fall target area between wilderness acres. boundary and Forest and • Stand replacement patches not to exceed 100 acres; treatments private land boundaries; would occur in densely stocked areas and also in some more encourage aspen suckering sparsely stocked areas, some dense forest areas would be retained. • Slash and burn conifers encroaching on natural openings and aspen stands; use prescribed fire in existing aspen clones to Maintain natural openings Horse encourage suckering. Spring or fall, 9 648 as fuel breaks; encourage Mountain • Fell young conifers (less than 16 feet) using power saws over spring target aspen suckering portions of unit. • Broadcast and jackpot burns utilizing hand ignition. • Broadcast burn utilizing combination of helicopter and hand ignition. • Reduction of 30 to 50 percent in conifer regeneration in patches of Disrupt continuity of fuel 20 to 100 acres; total target acreage of 202 to 337 acres. Cyanide Spring or fall, 10 673 that would support west-to- • Reduction of heavy surface fuel loadings in patches of 20 to 100 Creek fall target east fire spread acre. • Stand replacement patches not to exceed 100 acres; treatments would occur in densely stocked areas and also in some more sparsely stocked areas, some dense forest areas would be retained. Horse Maintain natural openings Spring or fall, 11 473 • Slash and burn conifers encroaching on natural openings and Mountain as fuel breaks aspen stands. spring target

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Anticipated Unit Acres Area Purpose Treatments Season • Fell young conifers (less than 16 feet) using power saws over portions of unit. • Broadcast and jackpot burns utilizing hand ignition. • Broadcast burn utilizing combination of helicopter and hand ignition. Spring and fall, • Reduction of 30 to 50 percent in conifer regeneration in patches of spring target for Disrupt continuity of fuel 20 to 100 acres; total target acreage of 450 to 750 acres. portions Cyanide 12 1500 that would support west-to- • Reduction of heavy surface fuel loadings in patches of 20 to 100 bordering private Creek east fire spread acres. land and fall • Stand replacement patches not to exceed 100 acres; treatments target for other would occur in densely stocked areas and also in some more portions sparsely stocked areas, some dense forest areas would be retained. • Broadcast burn utilizing combination of helicopter and hand ignition. Spring and fall, • Reduction of 30 to 50 percent in conifer regeneration in patches of spring target for Disrupt continuity of fuel 20 to 100 acres; total target acreage of 75 to 125 acres. portions Cyanide that would support west-to- 13 249 • Reduction of heavy surface fuel loadings in patches of 20 to 100 bordering private Creek east fire spread; encourage land and fall aspen suckering acres. • Stand replacement patches not to exceed 100 acres; treatments target for other would occur in densely stocked areas and also in some more portions sparsely stocked areas, some dense forest areas would be retained. • Broadcast burn utilizing combination of helicopter and hand ignition. Spring and fall, • Reduction of 30 to 50 percent in conifer regeneration in patches of spring target for Disrupt continuity of fuel 20 to 100 acres; total target acreage of 194-323 acres. portions Cyanide 14 645 that would support west-to- • Reduction of heavy surface fuel loadings in patches of 20 to 100 bordering private Creek east fire spread acres. land and fall • Stand replacement patches not to exceed 100 acres; treatments target for other would occur in densely stocked areas and also in some more portions sparsely stocked areas, some dense forest areas would be retained. • Disrupt continuity of fuel Broadcast burn utilizing combination of helicopter and hand Spring and fall, Cyanide 15 173 that would support west-to- ignition spring target for Creek east fire spread • Reduction of 30 to 50 percent in conifer regeneration in patches of portions 20 to 100 acres; total target acreage of 52 to 87 acres bordering private

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Anticipated Unit Acres Area Purpose Treatments Season • Reduction of heavy surface fuel loadings in patches of 20 to 100 land and fall acres target for other • Stand replacement patches not to exceed 100 acres; treatments portions would occur in densely stocked areas and also in some more sparsely stocked areas, some dense forest areas would be retained.

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

Prior to implementation, each season, those responsible for executing the project will confer with key members of the interdisciplinary team including the wildlife biologist, the plants biologist, the range and weeds specialist, and the soils specialist, as well as the Montana Fish, Wildlife and Parks biologist to ensure that all relevant resource protection measures will be met. This will involve a detailed review of maps, a unit-by-unit discussion of proposed tactics, and a field review of any units where intention is unclear. Earliest implementation anticipated would be spring, 2015.

Hydrology/Fisheries All National Forest Service best management practices for prescribed fire in aquatic management zones (AMZ) would be followed, specifically National Best Management Practices for Water Quality Management on National Forest System Lands, FS-990a, April 2012, Volume 1: National Core Best Management Practices Technical Guide, Section Fire-2. Use of Prescribed Fire, pages 54 – 56. Specifically the following:

. Locate access and staging areas outside of the aquatic management zones and wetlands. . Construct fireline to the minimum size and standard necessary to contain the prescribed fire and meet overall project objectives. . Locate and construct fireline in a manner that minimizes erosion and runoff from directly entering water bodies by considering site slope and soil conditions, and using and maintaining suitable water and erosion control measures (waterbars). . Rehabilitate or otherwise stabilize fireline and staging areas in areas that pose a risk to water quality. . Control actions in the aquatic management zones as needed to maintain ecosystem structure, function and processes and onsite and downstream water quality. . Keep high-intensity fire out of aquatic management zones to avoid or minimize adverse effects to water quality by observing the following non-ignition buffers on streams and wetlands within the project area:

o 200 foot no-ignition buffers on all streams to preserve riparian vegetation and maintain a vegetated buffer to prevent erosion upslope from entering water bodies. o If prescribed fire is necessary to meet objectives within the 200 foot non-ignition buffer, specific burn locations would need to be coordinated with the Forest Hydrologist to ensure that additional resource protection measures are in place to protect water quality. o No-ignition buffers on steep slopes (greater than 50 percent) on slopes above streams that could contribute to sediment delivery in streams. o When wetlands or springs exist within treatment units, active lighting should only occur outside of the wetland boundary to prevent trampling of wetland soils and fuel spills near

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surface water. The 50 (less than 35 percent slope) to 100 foot (greater than 35 percent slope) no-ignition buffer would be implemented to protect surface water within wetlands from sediment delivery. Heritage • To meet requirements of the National Historic Preservation Act (Section 106), field surveys will comply with the Prescribed Fire Appendix of the 2015 Heritage Resources Programmatic Agreement (P.A.). Required consultation with the Montana State Historic Preservation Office (SHPO) has started and they concurred with our plan for project area surveys and site avoidance. • If a previously identified historic property is inadvertently affected during project activity, the project work would cease in that location, a site-damage assessment would be prepared, and Montana State Historic Preservation Office and tribes would be informed. The investigation report and damage repair agreement would be finalized prior to finishing that site’s activities. • If unidentified archaeology sites or human burials are discovered during implementation, work would cease in that area and the Forest Archaeologist would be notified. Required legal processes would be invoked. Noxious Weeds • Follow Prevention and Control Measures for noxious weeds as found in Forest Service Manual 2000 Supplement R-1 2000-2001-1, Sec 2081.2. Implement preventative management measures as referenced by Forest Service Manual 2000 including post-disturbance seeding with desirable species. • Adhere to mitigation requirements as listed in the Record of Decision for the Lewis & Clark National Forest Noxious Weed Control Record of Decision (1994, page 5). • Remove all mud, dirt, and plant parts from all equipment before moving into project area. Cleaning must occur off National Forest System lands. This does not apply to service vehicles that will stay on the roadway and travel frequently in and out of the project area. • Revegetate all mechanically-disturbed soil, except the travel way on surfaced roads, in a manner that optimizes plant establishment for that specific site unless ongoing disturbance at the site would prevent weed establishment. Forest Service Handbook would be followed for revegetation. • All crews would inspect, remove, and properly dispose of weed seed and plant parts found on their clothing and equipment. • Establish travel routes for people and equipment to and from project units and treat noxious weeds along these routes before work commences.

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

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Recreation • Implementation would include a public notification plan with consideration given to implementation timing and recreational uses such as hunting season. • Implementation would be coordinated with the Forest Public Affairs Officer and Law Enforcement to ensure the public is well informed of the schedule and its potential impacts.

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

Vegetation • Implementation of hand ignition units would avoid ignition within areas characterized by sparse stocking or poor seedling establishment. • Avoid ignition within mature (greater than 8 inches diameter-at-breast-height) conifer stands more than five acres in size.

Wildlife

Grizzly Bear To limit disturbance to bears in spring habitat in Management Situation 1 areas: • Slashing activities in units 1, 2, 7, 9, 11 and 12 would occur after June 30 to minimize disturbance in big game calving/lambing/fawning range.

To prevent bears becoming food-conditioned and to minimize the risk of bear-human encounters and maximize both human and bear safety: • All personnel involved in project implementation would adhere to the Special Food Storage Order LC_10_D1_01 (or any successor orders) at all times.

Northern Goshawk Disturbance to nesting goshawks can be reduced by limiting project slashing activities between April 15 and August 15 within ¼ mile of known active goshawk nests. A map of known goshawk nests will be

170 Environmental Assessment provided during implementation planning meetings, to fire personnel creating burn plans, and/or to appropriate crew leader(s) prior to implementation in the relevant unit(s).

Amphibians and Aquatic Wildlife To minimize the risk of introducing pathogens or invasive aquatic species: • Any equipment used for potential fire control or suppression (including but not limited to helicopter buckets, helicopter snorkels, water pumps, hoses, etc.) will be thoroughly cleaned according to Regional protocol prior to use anywhere on the Rocky Mountain Ranger District. • Water for potential fire control or suppression will not be transported from one side of the Continental Divide for use on the other side, and where possible will be obtained from within the same drainage or watershed where it is to be used. • The District Wildlife Biologist, Forest Fish Biologist, or Montana Fish, Wildlife and Parks Area Fisheries Biologist will be consulted regarding use of water dip sites.

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

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Appendix D: Resource Protection Measures Fisheries • Provide cooperative assistance to Montana Fish Wildlife and Parks (MTFWP’s) in their efforts to assure persistence of westslope cutthroat trout in Maudess Creek with Montana’s Environmental Policy Act upcoming decision regarding brook trout suppression in Maudess Creek.

Heritage • In a confidential report, the Forest Heritage Resources staff will inform the responsible official and project planners of known vulnerable sites in the general project area. For all projects that involve ground disturbances, known sites will be identified early in the planning stage. The responsible official and project planners will also be informed if sites are identified during project preparation and implementation. • Where significant or potentially significant sites are known, during the early planning stage the heritage specialist should try to identify potential undertakings that could benefit site preservation and fit within overall project goals. • Undertakings will be planned or modified so they don’t adversely affect significant or unevaluated cultural resources, if possible. • Identified significant or unevaluated sites will be avoided by reconfiguring project unit boundaries to exclude the site, or by site-specific pre-treatments (e.g. fuel thinning, blacklining), prior to implementation, to reduce effects. • Effects to ‘linear’ historic sites (e.g. trails) would be avoided or minimized by restoring pre- treatment contours or drainage features per Programmatic Protocol.

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

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

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

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Raptors To reduce potential impacts to cliff-nesting raptors: • Helicopter flight paths could be routed to more than ½ mile away from active cliff nest sites. A map of active nest sites would be provided during implementation meetings, to fire personnel creating burn plans, and/or to helicopter managers or other appropriate personnel prior for implementation.

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

Table 39 Past Actions Activity 1800- 1940- 1950- 1960- 1970- 1980- 1990- 2000- 2010- Total 1939 1949 1959 1969 1979 1989 1999 2009 2019

Fire / Fuels

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

Wildfire for 241 520 761 Resource Benefit

Wildlife Habitat 80 534 614 Burn

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

Broadcast Burn 698 1,090 1,788

Jackpot Burn 20 20

Fuelbreak 2,104 2,104

Piling of Fuels 147 96 332 575

Trampling Fuels 22 20 42

Pile Burn 176 164 10 585 935

Fuels Monitoring – 9 plots Pre-treatment

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

Harvest

Hazardous Fuels 14 205 219 Thin

Pre-commercial Thin 42 28 70

Commercial Thin 1 77 78

Salvage Cut 18 18

Single Tree Selection 13 13

Clearcut (Stand or 24 36 60 Patch)

Reforestation

Certification of 1,015 24 1,039 Natural Regen

Certification of 7 1 8 Planted

Stocking Surveys

(no certification 282 282 recorded)

Insect / Invasives

Verbenone & MCH 30 195 225 Installation

Carbaryl Application 70 70

Infested Tree 10 10 Removal

Pesticide Application 92 92

BioControl 20 20

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

Mechanical/Physical 30 30 Removal

Legislative Direction (Rocky Mountain Heritage Act 2014)

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

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

Designated Wilderness Addition - Silver King/Falls

Creek (Scapegoat Bear Management Unit Subunit)

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

Deep Creek-Elk Creek Conservation Management Area 22,395 (Scapegoat Bear Management Unit Subunit)

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

Table 40: Reasonably Foreseeable Actions Activity Number Acres

Broadcast Burning* 379

Burn Plans* 9 each (may be combined)

Burning of Piled Material* 173.7

Certification of Natural 36 Regeneration without Site Prep*

Fireline Construction* 2.5 miles

Initiate Natural Regeneration* 19

Invasives—Pesticide Application* 187.2

Jackpot Burning—Scattered 203 concentrations*

Post Treatment Exam Fuels 713 Management*

Pre-commercial Thin* 18

Rearrangement of Fuels* 111

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

Scarify and Seed Landings* 4

Site Preparation for Seeding— 2 Manual*

Soil Productivity Monitoring* 131

Stocking Survey* 108

Thinning for Hazardous Fuels 15 Reduction*

Yarding—Removal of Fuels by 113 Carrying or Dragging*

Post-Fuels Treatment Monitoring* 9 plots with periodic monitoring

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

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

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Appendix F: Monitoring • Fisheries, hydrology, and range specialists will jointly perform post-implementation monitoring to determine if the limited felling of trees or installation of jackleg structures beneficially dissuade cattle access to streamside bench areas in lower sections of Maudess Creek and Jakie Creek, tributaries of Smith Creek. • Monitor treatment units for First Order and Second Order Fire Effects. This would include the establishment of photo-points in treatment units and controls prior to implementing the Proposed Actions. Photos at established points also would be taken, and interpreted, following prescribed fire implementation. Appropriate photo-points could be revisited following an unforeseen disturbance event in the Project Area. Monitoring of Second Order Fire Effects should be conducted by revisiting, and interpreting, photo-points approximately 15 to 20 years following completion of the project, or at any time the efficacy of treatments comes into question. • The Bailey Basin goshawk territory and any newly discovered territories within ¼ mile of treatment units would be surveyed for occupancy during the nesting season immediately prior to implementation and for up to five years following treatment or according to Forest Plan monitoring requirements. • Known cliff nest sites within ½ mile of project activities, including helicopter flight paths, will be surveyed for current occupancy during the nesting season immediately prior to implementation activities and, for those sites within treatment units, for up to five years following treatment. • Post implementation monitoring would be conducted by the Range Specialist and Soil Scientist to determine deferment needs. • Project area would be monitored for three consecutive years and would control newly established populations of noxious weeds in accordance with FSM 2000 Supplement R1 2000-2001-1, National best management practices Forest Service Manual 2532, and Forest Service Handbook 2509.19. Follow-up treatments for previously treated infestations would be implemented. Monitoring would begin in the spring following treatment. • Monitoring for soil and water resources in compliance with Forest Plan Standards (Management Standards F-1 through F-4).

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Appendix G: Forest Plan Consistency Table

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