Gilmore Aspen Management Project -...

United States Department of Agriculture Forest Service March 2015

For Information Contact:

Bob Bayer Manchester Ranger District Office

2538 Depot St., Manchester Center, VT 05255 (802) 362-2307 (ext 218)

[email protected]

Responsible Official: Christopher Mattrick

District Ranger Rochester and Middlebury Ranger Districts

Green Mountain National Forest 99 Ranger Rd. Rochester, VT 05767

(802) 767-4261(ex. 513) [email protected]

Gilmore Aspen Management Project Preliminary Environmental Assessment: 30-Day Comment Document Green Mountain National Forest Middlebury Ranger District Towns of Bristol and Lincoln Addison County, Vermont

mailto:[email protected]


This document can be made available in large print. Contact Bob Bayer (802) 362-2307 ext. 114 or [email protected]

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Table of Contents Chapter 1 – Purpose and Need ...................................................................................................................... 1

Introduction .............................................................................................................................................. 1 Background ............................................................................................................................................... 1 Forest Plan Direction ................................................................................................................................ 2 Purpose and Need for Action .................................................................................................................... 2 Public Involvement ................................................................................................................................... 3 Public Issues ............................................................................................................................................. 4 CFR 218 Pre-Decisional Objection Process ............................................................................................. 5 Decision Framework ................................................................................................................................. 5

Chapter 2 – Description of Alternatives ....................................................................................................... 7 No Action ................................................................................................................................................. 7 Proposed Action ....................................................................................................................................... 7 Alternatives Considered but Eliminated from Detailed Study ................................................................. 9

Chapter 3 - Affected Environment and Environmental Effects .................................................................. 10 General Affected Environment for the Project Area .............................................................................. 10 Habitat Diversity, General Vegetation, Wildlife .................................................................................... 14 Visual Quality ......................................................................................................................................... 25 Soils and Wetlands ................................................................................................................................. 29 Threatened, Endangered and Sensitive Species (Wildlife and Plants) ................................................... 33

Chapter 4 - List of Preparers ....................................................................................................................... 38 Chapter 5 - References ................................................................................................................................ 39 Appendices Appendix A – Mitigation Measures............................................................................................. A1 Appendix B – Response To Comments........................................................................................ B1 Figures Figure 1, Project Map................................................................................................................................ B8 Figure 2, Gilmore Project Visual Quality Mitigation................................................................................ 28

Gilmore Aspen Management Project i Preliminary Environmental Assessment: 30-day Comment Document

Chapter 1 – Purpose and Need

Introduction The United States Department of Agriculture (USDA) Forest Service (Forest Service), Green Mountain National Forest (GMNF), is proposing to implement management activities (Proposed Action) on the Middlebury Ranger District within the Towns of Bristol and Lincoln, Addison County (see Project Map, Figure 1). The Gilmore Aspen Management Project (Gilmore Project) includes small scale timber management activities to achieve multiple resource benefits as provided by direction in the 2006 GMNF Land and Resource Management Plan (Forest Plan). The Gilmore Project proposes to increase the acres of the regenerating age class (0-9 years old) of vegetation with a focus on aspen-birch in order to move the forest toward its desired future condition identified in the Forest Plan, as well as improve habitat for wildlife species that prefer these habitats. This project is proposing to clearcut eight (8) small areas each about 4 to 12 acres in size to provide young age classes (0 to 9 years) of aspen. An interdisciplinary team (IDT) of Forest Service resource specialists prepared this preliminary environmental assessment (Preliminary EA) to determine whether implementation of the Gilmore Project may significantly affect the quality of the human environment and thereby require the preparation of an environmental impact statement. By preparing this EA, we are fulfilling federal and agency regulations to comply with the National Environmental Policy Act (NEPA).

Background To implement its Forest Plan, the Forest Service looks for opportunities to work toward meeting Forest-wide Goals and Objectives. Forest Plan, page 10, states under Goal 2, “Increase acres of aspen-birch forest and regenerating forest in order to support species that prefer these habitats.” The long-term forest composition objectives are listed on page 11 of the Forest Plan. The aspen-birch habitat type has been estimated to be currently about 3 percent of the forest. The objective, or desired future condition, is to have an aspen-birch component of between 1 and 5 percent forest-wide. Aspen-birch is one of the habitat types that are uncommon on the forest, and as such, the Forest Plan (p. 11) calls for “adjustments to manage aspen-birch, oak, and permanent upland opening habitats at, or slightly higher than, current levels.” The aspen-birch habitat is an early successional type found throughout New England. As such, frequent disturbance is required to maintain its presence or it will be replaced by late-successional or climax habitat types that contain very little aspen or birch. The Gilmore Mountain area has been identified as having a moderate amount of scattered aspen trees within northern hardwood forests that exhibit intermediate to mature age class distribution. The area lacks any regenerating aspen stands (0 – 9 years old) and there is only a small amount of young aspen from management in the 1980’s. Within the Forest Service land management Compartments 12 and 20, 65 percent of the forested stands are 80 years old and older. Given the age of the mature aspen clones in the project area and relatively frequent high wind and rain

Gilmore Aspen Management Project Page 1 Preliminary Environmental Assessment: 30-day Comment Document

events, these clones are susceptible to wind throw and are dying off. This mortality in the aspen component is leading to a shift away from pioneer communities into common northern hardwoods. Now is an appropriate time to harvest the mature aspen and establish natural regeneration to maintain and enhance the aspen habitat type before it is lost. Thus, this project would begin implementation of a long-term strategy to manage aspen habitat in the area by moving the landscape towards a greater abundance of aspen, distributed across the four distinct age classes identified in the Forest Plan (Table 2.2-2, p. 11).

Forest Plan Direction The Gilmore Project is guided by management direction provided in the Forest Plan. The Forest Plan is a programmatic document that provides the desired balance of multiple uses to meet society’s needs while protecting, restoring, and enhancing our natural resources. This EA is tiered (40 CFR 1508.28) to the Record of Decision and Final Environmental Impact Statement for the Forest Plan. Information and analysis in those programmatic documents that applies to this project-level analysis is incorporated by reference into this EA. The Gilmore Project is located within the Diverse Forest Use management area, MA 3.1. Forest Plan direction for MA 3.1 calls for management activities that provide a mix of habitats for wildlife species with stands that vary in size, shape, height, and tree species. Forest communities such as northern hardwoods, aspen, and oak will be maintained and enhanced where possible. Furthermore, direction for MA 3.1 states that management practices will include both even-aged and uneven-aged silviculture systems. These silvicultural practices will be used to meet timber, wildlife, ecological, visual, and recreation objectives (Forest Plan p. 47). The management emphasis and desired future condition for this MA are provided in the Forest Plan on pages 47-48. The National Forest System (NFS) land lying south and west of Upper Notch Road and Duclos Road lie within the 2006 Abbey Pond Roadless Area (92037) that was evaluated during Forest Plan revision (Forest Plan FEIS, Appendix C pp. C-235 to C-242). Refer to the Gilmore Aspen Management Project Map (Figure 1). This inventoried roadless area was not recommended for wilderness based primarily on having only moderate potential to provide the attributes and values appropriate for wilderness designation. These lands lie within the Diverse Forest Use management area, MA 3.1, and are subject to Forest Plan direction for that MA. Four of the eight units proposed for harvest, units 5, 6, 7, and 8 (about 29 acres) are located in the Abbey Pond Roadless Area.

Purpose and Need for Action The purpose and need for this Proposed Action is to address the possible loss of the aspen-birch habitat in this section of the Middlebury Ranger District, and to work toward the desired future condition as defined in the Forest Plan. Specifically, there is a need to:

• Regenerate areas of mature aspen to provide age class diversity by creating stands of regenerating aspen 0 to 9 years old.


• Begin implementation of the long-term strategy to manage aspen habitat in the area by creating new stands of aspen and moving the landscape towards four distinct age classes: regenerating, young, mature, and old.

• Take advantage of the opportunity to create stands of regenerating aspen from existing mature aspen clones before these clones are lost.

The proposal would implement key Forest-wide management goals and objectives for the Diverse Forest Use MA provided by the Forest Plan:

• Goal 2: “Maintain and restore quality, amount, and distribution of habitats to produce viable and sustainable populations of native and desirable non-native plants and animals.” (Forest Plan, p. 10);

• Goal 2, Objective 4: “Increase acres of aspen-birch forest and regenerating forest in order to support species that prefer these habitats.” (Forest Plan, p. 10);

• Goal 2, Age Class Objectives for Diverse Forest Use: “Apply the following age-class objectives to suitable lands that will be managed using even-aged silvicultural systems to provide a variety of habitat conditions for wildlife and create a balanced distribution of age classes”; for aspen regeneration age class, 0 to 9 years, move toward a desired range of 10 – 20 percent (Table 2.2.2, Forest Plan, p. 11).

Another key component of the purpose and need is the improvement of wildlife habitat. Regenerating stands 0 to 9 years old provide important wildlife habitat for a number of species such as ruffed grouse, woodcock, wild turkeys, deer and bear, bobcat, snowshoe hare, as well as many songbirds such as eastern bluebird, chestnut-sided warbler, common yellowthroat, song sparrow, red-breasted grosbeak, and American goldfinch (Forest Plan Final Environmental Impact Statement (FEIS), p. 3-102).

Public Involvement Formal public involvement for the Gilmore Project was initiated by the distribution of the Scoping Notice package dated February 3, 2014 that was sent to 36 individuals, organizations, towns and agencies. The notice asked that comments be provided by March 10, 2014. The scoping information was made available at this same time on the GMNF website at: http://www.fs.fed.us/nepa/nepa_project_exp.php?project=41839. The project has also been listed in the quarterly GMNF Schedule of Proposed Actions. A total of 7 comment responses were received for the proposal as described in the February 2014 scoping document. The comments from these responses were analyzed and documented in the Gilmore Aspen Management Project Scoping Comments Content Analysis report available in project record. The comments led to the development of the issues described below. Gilmore Aspen Management Project Page 3 Preliminary Environmental Assessment: 30-day Comment Document

http://www.fs.fed.us/nepa/nepa_project_exp.php?project=41839

It is important to note that prior to formal scoping, the Forest Service reached out to various neighbors and organizations. An information package was sent out and a field visit held on December 5, 2013. Four members of the public attended and provided feedback. Additional contact was also made with adjacent landowners who could not attend the field visit. Their comments led to a slight modification of the original Proposed Action to protect a spring and water line that provides drinking water to these nearby residents.

Public Issues An issue is defined as a disagreement or dispute regarding anticipated resource effects resulting from implementing a proposed action. Issues are usually identified based on comments from the public or other agencies. Resource concerns are also identified by the Forest Service IDT and included in the analysis. For purposes of developing this Preliminary EA, public comments have been separated into three issue categories: 1) Issues that remain unresolved at the time of the EA analysis and may be addressed

with the development of an alternative(s) and/or mitigation measure(s) and design criteria. Alternatives, when developed in detail, display a clear difference in environmental effects associated with the unresolved issue. Unresolved issues meet the intent of the Council for Environmental Quality (CEQ) NEPA regulations at 40 CFR 1500.1(b) and 1500.4(g). These issues help focus the environmental effects analysis on the relevant resources of concern in the EA.

2) Issues that are not addressed in the environmental analysis or are only briefly discussed. The CEQ NEPA regulations at 40 CFR 1501.7(a) (3) allow for issues to not be included in the detailed analysis, or to be only briefly discussed if they are: a) outside the scope of the proposed action; b) already decided by law, regulation, Forest Plan, or other higher level decision; c) irrelevant to the decision to be made; or d) conjectural and not supported by scientific or factual evidence.

3) Non-Issues: comments that do not readily lead to an issue because they are not considered a point of disagreement, debate, or dispute over the proposed action based on anticipated environmental effects. These comments generally are those that a) require clarification from the source; b) suggest improvements or corrections to the proposed action; c) ask questions, seek clarification, or request information, d) express general or project specific support; e) are unsubstantiated opinions related to non-specific resource concerns; or, f) suggest opportunities for public collaboration. Three unresolved issues were identified from public comments for the Gilmore Proposed Action and will be discussed in this EA. These issues help focus the discussion of environmental effects in chapter 3.

Issue 1: There is concern that logging activity could contaminate a spring water source, the stream that supplies the water, and damage the water line associated with the spring.


Issue 2: There is concern that logging activity could disturb Jacob’s Ladder (Polemonium van-bruntiae), a Vermont-threatened plant species. Issue 3: There is concern that logging activity, in particular clearcutting, could disrupt the natural beauty of the area, and disturb the adjoining private property.

Other issues and concerns raised by the public that fall into categories 2 and 3 above and either will not be addressed directly, or only briefly addressed in this Preliminary EA are documented in the Gilmore Aspen Management Project Scoping Comments Content Analysis report available in project record. See also Appendix B, Response to Comments.

CFR 218 Pre-Decisional Objection Process Recent rulemaking in 2013 replaced the post-decisional appeals process in place since 2003 (36 CFR 215) with a pre-decisional objection process (36 CFR 218) for EA level NEPA decisions. Rather than being able to file an “appeal” and seek higher-level administrative review of unresolved concerns after a project decision has been made, those who are eligible will now be able to file an “objection” and seek that review before the project decision is signed. The 36 CFR 218 regulations state that in order to be eligible to object under the Objections process, you will need to submit timely “specific written comments” (36 CFR 218.2) during any period “designated for public comment” (36 CFR 218.5(a)). The following public opportunities to submit written comments have been or will be provided for this project: 1) Scoping Period: Comments submitted during the scoping period through March 10, 2014,

initiated by the February 3, 2014 Scoping Notice, helped determine issues specific to the Proposed Action. The analysis has been documented in this Preliminary EA.

2) 30-Day Notice and Comment Period: Comments submitted during the formal 30-day notice

and comment period for this Preliminary EA will be used to identify remaining issues with the proposal or associated environmental analysis so the EA can be finalized and a draft Decision Notice (DN) and Finding of No Significant Impact (FONSI) can be prepared. This 30-day period will be triggered by a legal notice in our newspaper of record, the Rutland Herald.

Decision Framework The District Ranger for the Rochester and Middlebury Ranger Districts is the Responsible Official for decisions regarding the Gilmore Project. The main decision to be made by the Responsible Official is whether to implement management activities as proposed (Proposed Action), select another action alternative (if developed as a result of addressing comments to this Preliminary EA), or select the No Action alternative. For this Preliminary EA, only the Proposed Action and the No Action alternative have been analyzed in detail. Should comments warrant the development of other action alternatives, they would be presented in detail in the Final EA. The Responsible Official will review the anticipated effects of the Proposed Action,


any developed action alternatives, and the No Action alternative as provided in this Preliminary EA and the Final EA prior to making a decision. If comments meeting the requirements for objection standing are received, the Responsible Official will publicly distribute the Final EA and an unsigned draft DN for a 45-day objection period. Anyone who submitted timely specific written comments during the designated opportunities for public comment will be eligible to file objections. The Responsible Official cannot sign the Final DN nor can implementation begin until objections are resolved through collaboration or modification of the decision.


Chapter 2 – Description of Alternatives Alternative development was considered by the Forest Service IDT and the Responsible Official to address the unresolved issues discussed in Chapter 1. It was determined that these issues could be adequately addressed with mitigation measures that are reflected in modifications to the Proposed Action, and thus there have been no other action alternatives developed in detail for this EA. As such, this Preliminary EA will be “focused” (i.e. a focused EA) on analyzing two alternatives in detail and disclosing the effects of the proposed activities for these two alternatives for only those resources that have clearly defined potential effects (please see the discussion at the beginning of Chapter 3). This chapter, therefore, provides the description of the two alternatives that have been carried forward for detailed analysis: 1) No Action, and 2) Proposed Action.

No Action The No Action alternative provides a baseline to compare the environmental effects from the Proposed Action alternative. There would be no implementation of any of the management activities associated with the Proposed Action under this alternative. Current existing management would continue in the project area.

Proposed Action The activities under this alternative are proposed to meet the purpose and need for the Gilmore Project as described above. A minor modification has been made to the original proposal during the pre-NEPA phase to address concerns of adjacent landowners. That modification is reflected in the description below. Mitigation measures developed to address the unresolved issues are included in the analysis presented in Chapter 3 and are listed in Appendix A. These measures would be incorporated into the proposed activities during implementation. Implementation of selected activities is anticipated to begin during the winter of 2015-2016. All activities are designed to be consistent with Forest Plan Forest-wide and Management Area Standards and Guidelines (S&Gs) while moving the existing resource conditions towards the goals, objectives and desired future conditions provided in the Forest Plan. A total of 806 acres within Compartments 12 and 20 were assessed for opportunities to create stands of regenerating aspen to improve age-class distribution. As a result, the project proposes approximately 60 acres of regeneration harvests using conventional clearcutting. To continue developing a diverse age class structure in the project area and provide for effective long-term management, a second and perhaps a third round of similar harvest activities will be proposed in future years in the adjacent stands that have an aspen component. Those proposals, including types of harvest, acreage and specific areas, will be identified and addressed in future NEPA projects.


Table 1 below briefly describes the eight harvest units proposed for treatment. Refer to the Gilmore Aspen Management Project Map (Figure 1) for specific locations of proposed harvests.

Table 1. Gilmore Harvest Units UNIT COMP STAND ACRES ACTIVITY

1 12 11, 12 4.0 clearcut 2 12 11 8.2 clearcut 3 12 8, 10, 15 7.2 clearcut 4 12 35 11.6 clearcut 5 20 4 6.3 clearcut 6 20 46 7.6 clearcut 7 20 110 5.1 clearcut 8 20 46, 110 10.0 clearcut

Activities proposed:

• Establish new regenerating aspen stands on approximately 60 acres using the preferred harvest method of conventional clearcutting leaving 2 to 4 reserve trees per acre. The location of these activities has been designed to allow additional regeneration cuts in the future adjacent to these proposed activities.

• For units 4, 5, 6, 7, and 8, landings would be established as shown on the project map (see Project Map, Figure 1). Old skid roads and landing areas would be utilized as much as possible and rehabilitated at the end of the project. Past forest management activities within Compartments 12 and 20 have established skid trail networks and landings.

• Save and promote the growth (release from competition) of existing apple trees when opportunities arise.

• Use whole tree harvesting to increase the chances that aspen will re-sprout at a high

density.

• Harvest activities would occur primarily when the soil is frozen or there is sufficient snow cover to prevent erosion, compaction, and rutting, or during the driest part of the summer, which is typically during July, August, and September. Summer logging would only be allowed in units 3, 5, and 6 under ideal soil moisture conditions.

• Post-harvest connected actions would include site preparation (if necessary) and stocking surveys.

Whole tree harvesting is a favored method for removing harvested trees from these aspen clearcuts. The optimum aspen regeneration for wildlife habitat yields many hundreds or thousands of tightly spaced stems per acre. Whole tree harvesting may facilitate that level of Gilmore Aspen Management Project Page 8 Preliminary Environmental Assessment: 30-day Comment Document

seedling response. Under a conventional harvest process, tree tops, smaller diameter branches and other non-merchantable material is left on the ground. While this material can have ecological benefits, large jackpots of slash can reduce seedling density, and make it more difficult for seedlings to compete with existing regeneration for the light and growing space required by aspen. Whole tree harvesting has the potential to provide more beneficial light and growing space. Likewise, whole tree harvesting would reduce the need for site preparation (i.e. the removal of remaining small trees and brush to enhance regeneration).

Alternatives Considered but Eliminated from Detailed Study The Forest Service IDT and Responsible Official discussed the project proposal and considered the following alternative actions while developing the Proposed Action in response to public comments received during the scoping process. None of these are included for detailed analysis in this Preliminary EA. 1) A larger unit 1 with skidding and landing using the Baslow Road area

This was considered during development of the original Proposed Action. Unit 1 was proposed at almost twice its current size (8.4 acres versus its current proposed size of 4.0 acres). Skidding and landing would have used Baslow Road. However, this alternative would potentially adversely impact a spring and water line that provides drinking water to a nearby residence. The Proposed Action was therefore modified to avoid the spring area and skid all timber products harvested in units 1 and 2 toward Forest Road 81 (FR81).

2) Other silvicultural methods

Other silvicultural methods that retain more of an overstory such as shelterwood cut or intermediate thinning were considered by the IDT. These methods would inhibit aspen response and favor shade tolerant species. Aspen is very intolerant of shade, (i.e. does not grow well in shaded conditions). Research and past experience in the project area and elsewhere on GMNF shows that clearcutting is the optimal way to regenerate the aspen and birch types. Removal of overstory trees would allow more sunlight to reach the ground and that would improve growing conditions for root and stump sprouts and young seedlings (Casey 2014, Silvicultural Specialist Report).


Chapter 3 - Affected Environment and Environmental Effects This chapter discusses the environmental and social resources and discloses the direct, indirect, and cumulative environmental effects, or impacts, from the No Action and Proposed Action alternatives described in Chapter 2. This chapter begins with a general description of the affected environment for the project area that applies to all or most of the various resources. As necessary, more detail is provided under each resource section. Beyond this introduction, the sections in this chapter are presented by resource area. Each resource section begins with further details on key components of the existing condition (“affected environment”) specific to that resource. This is followed by disclosure of the potential direct, indirect, and cumulative effects for each alternative. For each resource, the relevant unresolved issues (see Chapter 1, Public Issues) are stated. These issues were identified through public scoping and the Forest Service review process, and have been used to guide disclosure of impacts. For some resources, there are no unresolved issues. Discussion of impacts in those situations is framed by the resource concerns identified by the resource specialist. The relevant resources that have clearly defined effects disclosed in detail in this focused Preliminary EA have been summarized from specialist reports located in the project record. They include:

• Habitat Diversity, General Vegetation, and Wildlife • Visual Quality • Soils and Wetlands • Threatened, Endangered and Sensitive Species (Wildlife and Plants)

The effects disclosure for resources that have no or minimal impacts are not included in this focused Preliminary EA, but are provided in specialist reports located in the project record. They include Heritage Resources (Lacy 2014), Hydrology Resources and Aquatic Species (Ketcham 2014), Recreation Resources (Knox 2014), Wilderness (Marks 2013), and Transportation and Roads System (Kamb 2014).

General Affected Environment for the Project Area The Gilmore project area generally encompasses about 806 acres of land from within the 2,205 acres that make up Forest Service Compartments 12 and 20. These two compartments were evaluated in detail for the Gilmore Project because they contain a strong pioneer forest component, pioneer meaning shade intolerant species such as aspen and birch that tend to thrive when forested areas are opened up to sunlight. Forested stands composed of predominantly aspen trees (primarily Populus tremuloides, or quaking aspen) are considered uncommon on the GMNF. Aspen stands have been identified as an important habitat for wildlife and an element of habitat diversity on the GMNF. Aspen trees regenerate well in large openings created by disturbances such as wind or ice storms or


fire, so long as seed and/or aspen trees occur in the general area. Aspen trees and stands of aspen increased in abundance as a result of land clearing and abandonment during the 19th century and first half of the 20th century. Since that time, the abundance and distribution of aspen on the GMNF has been slowly declining as the aspen trees age and decline, and are replaced by beech, birch, maple, and spruce. This decline can also be attributed to a reduction in overall forest management activities, as well as the general resistance of middle-aged forested stands to damage from occasional large natural disturbances. The Gilmore Project harvest units lie within the Diverse Forest Use MA. The general landscape in which the project area sits is a mix of plateaus, low hills and small mountains with a few broader mountain slopes. This landscape supports forests dominated by northern hardwoods, with small patches of aspen, paper birch, mixed wood (northern hardwoods mixed with red spruce), and wetlands. As much as 12 percent of the analysis area is comprised of mostly open wetlands, second in abundance only to northern hardwoods. One of these wetland complexes is the Beaver Meadows and Abbey Pond Ecological Special Area (ESA), which is 330 acres and is approximately 1.2 miles southwest of the closest harvest unit. Softwood stands of spruce and/or fir occupy only about one percent of the area. Aspen trees are generally scattered throughout much of the analysis area among the northern hardwoods. There are no additional natural communities of ecological significance within the analysis area. Stand conditions in the project area run from well stocked pole-sized stands to mature and old mixed wood and northern hardwood stands where mortality to large trees from old age, insects, wind throw and disease is taking its toll on timber resources. Structural diversity across the two compartments is limited by the predominance of mature forest stands, generally between 60 and 120 years old that account for more than three-quarters of all forested stands in the project area. No regenerating stands 0 to 9 years old have been identified in the analysis area. Age class structure objectives in the Forest Plan (Forest Plan, Table 2.2-2, p. 11) applied to this analysis area indicates a need for new regenerating stands and for older stands of all habitat types. Over-mature aspen clones are especially in decline and subject to wind throw and tipping during severe windstorms. Resources Not Discussed in Detail The following resources will not be discussed in detail in this focused Preliminary EA as noted above. The resource specialists found that there would be no or very minimal impacts in each case. However, a brief description of the affected environment for each of these resources follows. Considering Heritage and Cultural Resources, the Gilmore project area is basically a rocky, higher elevation locale that received extensive (although not intensive) agricultural land use during the 19th and 20th centuries. There is relatively little potential for the presence of prehistoric Native American sites in the area, though it may have been used as a travel way roughly paralleling the project area’s Notch Road. Based on examination of the Forest’s Heritage site atlas and in-field reconnaissance by Forest Archaeologists, two historic period archaeological sites have been identified within the project’s Area of Potential Effect (APE),


while associated features (e.g., stone walls and field stone piles) occur intermittently across the landscape. There would be no effect on any Historic Properties because they exist outside the specific activity areas and harvest units proposed for disturbance. Considering Hydrology Resources and Aquatic Species, project units 1 through 7 (see Table 1 above) are in the New Haven River sub-watershed of the New Haven River Watershed. Unit 8 is located the Middlebury River sub-watershed of the Middlebury River Watershed. An unnamed stream channel is paralleled by the Upper Notch Road and is the largest stream in the project area. It most likely holds eastern brook trout. The perennial tributaries to the unnamed brook are also likely to be fish bearing, but their true status is unknown. There may be enough flow at certain times of year (snow melt and spring/summer rain storms) to hold fish for a short amount of time before returning to an intermittent stream status, especially in these relatively small width and depth headwaters tributaries. In the short term, the proposed activities could cause some very minor negative direct effects to aquatic life due to the minor sediment delivery to, or turbidity in, these tributary channels. Following Forest Plan direction, mitigation measures, and the national BMPs would considerably minimize, if not eliminate, these potential effects. In the long term, these potential effects would not have any measureable impact on the sustainability of local aquatic and semi-aquatic populations, or downstream populations or habitat. Considering general recreation within the project area, there are no NFS trails, developed recreation sites, dispersed camping/recreation (known camping) sites, or other recreational infrastructure. The closest recreation resource to the project area is the Beaver Meadow Trail (Forest Trail 270). This trail, a Class 1 (minimally developed) snowmobile trail, has been administratively closed for over five years. An unauthorized trail system that crossed from private property onto NFS land west of Forest Road 81, within Units 1 and 3 has been closed in cooperation with the adjacent landowner. Overland pedestrian travel occurring off NFS trails includes walking, skiing and snowshoeing. This use is not restricted and can occur throughout the project area. FR81 provides access into the National Forest but given limited parking along the road edge and the short road length (dead end), there is little evidence that the road is frequently used for any activity such as cross country skiing, snowshoeing or hiking. Therefore, given the lack of recreation resources within or close to the project area, and limited use, there would be no direct, indirect, or cumulative effects. Considering Wilderness, the closest designated Wilderness area is the Bristol Cliffs Wilderness, approximately 3/4 miles north of the boundary of the northernmost harvest unit (unit 2). No known documented views look out over the project area. The Breadloaf Wilderness is located over four miles to the east of the Gilmore Project Area. Vistas located on Breadloaf Mountain look out to the west toward the Project Area. None of the ground disturbing activities would affect the Wilderness. Concerning visual resources, it is highly doubtful that any of the harvest units would be visible from the Wilderness due to the distance of the project to the Wilderness boundary, the small size of the harvest units, the lack of topography (the harvest units generally lie on level ground), and the intervening forested landscape. Therefore, there would be no direct, indirect, or cumulative effects on wilderness character.


Considering transportation and road use, it is proposed to skid all logged material from units 1, 2, and 3 to landings to be established at the end of Forest Road 81. The area has been logged previously and remnants of an old skid trail and landing system still exist. Avoiding the use of Baslow Road allows for the protection of a private spring and water line that services a nearby residence. FR81 is a 0.55 mile, dead end, hardened gravel road. It is maintained for the purposes of public and administrative access including access for timber management. There are no plans to widen or improve it, or to change the maintenance level as a part of this project. Any damage to FR81 from the logging operations would be repaired. FR81 is a public road open to those who wish access to NFS lands, and that would not change as a result of this project. In regards to roadless areas, units 5, 6, 7, and 8 lie within the Abbey Pond Roadless Area. As is for the other units proposed for harvesting, these units are subject to Forest Plan standards and guides, and management direction for the Diverse Forest Use MA. NFS lands within the Abbey Pond Roadless Area total 5,453 acres. No timber management activities have occurred within this area in the past 10 years. The units proposed for harvesting total 29 acres, or 0.005 percent of the total acres in the roadless area. This is well within the criteria for defining a roadless area that states that only 20 percent or less of the area may have been harvested in the past 10 years (i.e. no more than 20 percent has been harvested). No road construction is proposed for this project. The proposed activities would not have an adverse effect on the roadless character of the Abbey Pond Roadless Area. The Issue Regarding Natural Beauty, Peace, And Solitude One unresolved issue was identified during project scoping relating to vegetation management, habitat diversity, and aesthetics. There is concern that logging activity, in particular clearcutting, could disrupt the natural beauty, peace, and solitude of the area, and disturb the adjoining private property. The indicator selected to disclose how the proposed activities would impact the project area and thus potentially disrupt the natural beauty, peace, and solitude of the area is the acreage of affected area treated versus acreage of habitat left untreated. The discussion will be framed by the location of the clearcuts as they would lie in relation to nearby residences. The area proposed for treatment is very small (60 acres) compared to the vast larger expanse of the project area of 728 to 806 acres, and the analysis area of 2,173 acres that make up Forest Service Compartments 12 and 20. The sixty acres proposed for treatment is roughly only 7.5 percent of the project area and only about 2.7 percent of the compartment area. Noise would not be expected to travel very far due to intervening topography and vegetation. Any increase in noise and traffic from logging activities would be temporary. These increases would only be in the winter months, and hopefully as planned, for one season. Very few residences are found in the general vicinity of the proposed logging and no cutting would occur immediately adjacent to any residence. The original Proposed Action was modified to protect the water source that serves a nearby residence, and thus has effectively moved logging activities further away from this residence (see Chapter 2 above, the description of the Proposed Action and the section entitled Alternatives Considered but Eliminated from Detailed Study). Truck traffic may occur directly adjacent to unoccupied private land, and on main access roads in the area. Any


damage to private property alongside these roads would be repaired by the purchaser of the timber sale at their expense.

Habitat Diversity, General Vegetation, Wildlife This section discusses the effects pertaining to vegetation and wildlife resources from the perspective of habit diversity. These effects are summarized from the Ecological Diversity Report (Burbank, D. 2014), the Silvicultural Specialist Report (Casey 2014), and the Wildlife Specialist Report (Burbank, M. 2014a), all found in the project record. Affected Environment The analysis area for habitat diversity includes the approximately 2,205 acres of NFS lands within Compartments 12 and 20 in the towns of Bristol and Lincoln, Addison County, Vermont. As described in the General Affected Environment section, this area includes a landscape of hills, plateaus, and small mountains, is dominated by mature northern hardwoods, has abundant open wetlands, and has a particular abundance of aspen trees. Table 2 summarizes the age class structure of aspen stands and the rest of the habitats in the analysis area. Ecological mapping and analysis indicate that sites that will support abundant aspen occupy about 88 percent of the analysis area. Aspen stands currently comprise approximately 91 acres, or four percent of the analysis area, all created by a series of clearcuts in the mid-1980s. By the mid-1990s, these aspen stands had grown out of the regenerating age class and into the young age class. Additional aspen trees and clones are present throughout the analysis area, but they are scattered within the other habitat types and are predominantly mature and old. No regenerating stands 0 to 9 years old have been identified within the area.


Table 2: Comparison of existing and desired age class distribution for aspen, compared to existing conditions across all NFS in the project analysis area.

Habitat Type Age Class (years)

Existing Condition

(all)1

Existing Condition

(suitable EA)2

Forest Plan

Objectives3

Long-term Area

Objectives2,3

yrs class ac % ac % % ac

Aspen 0-9 Regen. 0 0 0 0 10-20 33-50 10-39 Young 91 100 91 100 45-55 101-152 40-59 Mature 0 0 0 0 25-35 68-102 60+ Old 0 0 0 0 3-5 18-26

Totals 91 100 91 100 10-15 220-330

All Forested Types Regen. 0 0 0 0 Young 225 10 170 11 Mature 1,662 75 1,367 89 Old 3 <1 3 <1 Open Upland 48 2 Open Wetland/Water 267 12

Totals 2,205 100 1,540 100 1 Condition across all federal lands within the Gilmore analysis area 3 Applies only to forested federal lands suitable for timber management using even-aged silvicultural systems; total refers to aspen/birch combined.

4 Acre range represents best fit of Forest Plan age class objectives applied to composition objective range for aspen Forest Plan Objectives for aspen/paper birch habitat adapted to this analysis area are to increase its abundance and distribution to around 10 to 15 percent if possible, based on both its abundance now in the area, and its decline within the larger landscape. Monitoring of past clearcut stands on similar sites in and adjacent to the analysis area has shown rapid establishment of hardwood and aspen regeneration (USDA Forest Service FS VEG, FACTS stand data and stocking survey data). Management for aspen through the use of clearcutting produces a robust response and excellent regeneration, providing high quality early successional habitat. The stands identified for aspen clearcut treatments in this project tend to be overstocked, low quality, high risk, or mature. A moderate number of aspen clones occur within them, which can be cut to regenerate the clones and encourage early successional aspen habitat. The mature and low quality condition of these hardwood stands lends itself to regeneration techniques to convert abundant hardwood stands into other more desirable habitat types. These types of harvests then provide wood for a range of purposes including fuel chips for energy. Lastly, a number of wildlife species such as ruffed grouse, woodcock, wild turkeys, deer, moose, bear, bobcat, snowshoe hare, as well as many songbirds such as eastern bluebird, chestnut-sided warbler, common yellowthroat, song sparrow, red-breasted grosbeak, and American goldfinch inhabit the project area. Many of these species depend on a variety of habitats during their life cycle ranging from regenerating stands to mature, older stands. Some depend mostly on early successional habitat that is missing from the project area. State designated deer


wintering areas also exist within these compartments and are associated with wetlands, streams, and softwood stands and plantations. Effects Analysis The No Action Alternative Direct and Indirect Effects As described in Chapter 2, the No Action alternative would not harvest any of the eight proposed harvest units. The current management situation and existing conditions, subject to natural changes, would continue forward. The analysis area for direct and indirect effects includes the approximately 2,200 acres of NFS lands within Compartments 12 and 20. This analysis area will apply to both the No Action and Proposed Action alternatives. General compositional and structural diversity for this area are discussed above in the Affected Environment section and in the General Affected Environment section. The temporal context for this analysis includes both short-term (by 2024) and mid- to long-term (50 to over 100 years from now) scales. The short-term scale reflects the year when the proposed harvests would be expected to be fully implemented and the immediate impacts of management activities would result in noticeable change, i.e. conversion of a hardwood stand to an aspen stand based on stocking surveys. The mid- to long-term scale accounts for management actions or disturbances that may result in changes that take a longer time to be detectable, such as the loss of aspen clones over time. This effects analysis for Habitat Diversity, General Vegetation, and Wildlife will focus on the impacts of the alternatives on aspen and early successional habitat. Creation of this habitat is the principle purpose and need for the project. The change over time in the abundance, distribution, and age class structure of this habitat will focus the effects discussion. The No Action alternative does not meet the purpose and need of the project. This alternative does not create regenerating aspen, does not improve the age class distribution for aspen habitat, does not cut aspen clones before they can no longer sprout and thus perpetuate that habitat, does not move the analysis area toward composition and age class objectives for aspen, and does not improve wildlife habitat by creating early successional habitat. If this alternative is implemented, the distribution, abundance, and overall condition of the aspen-birch component in the project area would continue to decline over time. As most stands with aspen are over 60 years old, most of the aspen trees are also at least that age, and likely older. Over the next few years, the mature aspen trees and clones scattered throughout the analysis area and in the proposed harvest units would continue to age and decline. Most aspen trees do not survive past 100 years, particularly in the East (Perala 1990; Myking et. al. 2011). The ability of these trees to root-sucker depends to a large extent on their level of deterioration; clones that are deteriorating produce few suckers (Perala 1990). While aspen does produce abundant seed, regeneration via seed has low levels of success; highest regeneration success results from root-suckering (Perala 1990). As these trees and clones die off, there will be fewer vigorous old aspen trees left to respond to any disturbance and thus, very limited opportunity for Gilmore Aspen Management Project Page 16 Preliminary Environmental Assessment: 30-day Comment Document

aspen regeneration. Within 40 years, there will be few if any opportunities to enhance this habitat and meet the Forest Plan objectives for aspen-birch habitat in this area. For the existing young stands of aspen in the analysis area, about half will become mature over the next 10 years, and as these young stands transition through the age classes, there will be two age classes of aspen for a short term (see Table 4 ahead). Within 40 years, all the existing aspen stands will transition into the old age class. Within 80 years, these stands will be replaced by shade tolerant species like maple and beech, and the aspen birch habitat type will disappear from the analysis area. With no regenerating aspen stands, and with the eventual loss of existing aspen clones and stands, aspen and early successional habitat will only be created by moderate to large-scale natural disturbances acting on aging forests. Within the next 100 years, the existing even-aged structure of forests within the analysis area will start to break down as more trees age and start to die. From then on, there may be some development of early-successional habitat, some of which would likely include aspen and paper birch, in response to large gaps made by dead and dying trees. Over the long-term, the forest structure would begin to become more uneven-aged overall, and may start to reflect expected age class distributions under natural disturbance regimes with a high proportion in old uneven-aged conditions. Under these conditions, early successional habitat would be expected to make up less than two percent of the analysis area (Lorimer and White 2003), some of which may include aspen and paper birch. Under the No Action alternative, wildlife species that occur in young and mature northern hardwood forest habitats would continue to benefit over the next 100 years, while species that require early-successional habitat would continue to find minimal habitat in the project area until the even-aged hardwood stands start to break up. Species associated with aspen in the analysis area will continue to find young and eventually mature aspen habitat over the next 30 years, but will have to find regenerating aspen habitat elsewhere in the landscape. Species such as ruffed grouse, woodcock, white-tailed deer, black bear, moose, various small mammals, and birds such as cedar waxwing, eastern bluebird, and many species of warblers and fly catchers that benefit from early successional habitat, and particularly the aspen-birch type, would be expected to decline in abundance and distribution within the analysis area. This would contribute to the trend of decreased early-successional habitat and associated wildlife species. Open areas such as maintained wildlife openings would be the only source of early successional habitat over this timeframe. However, there is no guarantee that maintenance of these wildlife openings would continue, and their value as early successional habitat could decline within 20 years of abandonment. Cumulative Effects The cumulative effects analysis area for Habitat Diversity, General Vegetation, and Wildlife is the New Haven River-Baldwin Creek to Mouth watershed, including both National Forest and privately owned lands. This analysis area will apply to both the No Action and the Proposed Action alternatives. The area is comprised of approximately 31,230 acres, of which approximately 7,851 acres are NFS lands. Three-quarters of the land in the analysis area is in private or state ownership. Within the NFS lands, approximately 4,379 acres (56 percent) are Gilmore Aspen Management Project Page 17 Preliminary Environmental Assessment: 30-day Comment Document

managed as Wilderness or Ecological Special Areas; vegetation management for silvicultural and general wildlife habitat purposes are permitted on the remainder of NFS lands in this area. Most of the two compartments (12 and 20) that make up the analysis area for direct and indirect effects fall within this watershed, as do most of the area analyzed for aspen opportunities. All proposed harvest units except Unit 8 fall within this analysis area, and Unit 8 straddles the watershed break. The cumulative effects analysis considers activities approximately 10 years past and 10 years into the future. A ten year time frame was selected because 10 years represents the length of time after a stand is harvested when it is considered to be in the regeneration (0-9 years) stage providing early-successional habitat. This time frame is important also to initiating trends and changes in overall composition and age class distribution. About a third of the analysis area is developed or in active agriculture and most of the remaining two-thirds is in forested habitat (NLCD; Fry et. al. 2011). Based on available data, approximately one percent (228 acres) of the landscape exists in a state that could be interpreted as early-successional habitat (e.g. scrub/shrub), dominated by shrubs and small trees. Aspen and paper birch habitat cannot be determined on non-federal ownership, but on NFS lands within the watershed, this habitat comprises 142 acres (2 percent of NFS lands and less than 1 percent of the watershed). Land use history and its effect on structural diversity in the watershed are likely similar to that described for Compartments 12 and 20 in the effects analysis (above) for the No Action alternative. Consequently, we can assume that structural diversity within the watershed is limited. The age class distribution on NFS lands is similar to that described for the direct and indirect effects analysis area. Currently, there is very little early-successional habitat within the analysis area on NFS and private lands: no regenerating habitat and 52 acres of openings on NFS lands (which are actively maintained as meadow and scrub/shrub), and about 228 acres of scrub/shrub within the entire watershed. No timber sales on federal lands in the analysis area have occurred over the past 10 years, so there has been no management on federal lands that would increase structural or age class diversity. On private and state lands, recent harvesting is limited. A 30-acre regeneration harvest occurred four years ago on private land north of the Forest in Compartment 12, and a 5-acre area of aspen-birch was cleared for a new home and pasture along the Notch Road in Compartment 20. It is unclear if the regeneration harvest was for wildlife or forestry purposes, or for development. No other recent harvests creating early successional habitat are known to exist in the analysis area. There are no known foreseeable future actions associated with federal or non-federal lands within the analysis area that would be relevant to compositional or structural diversity. As noted for the direct and indirect effects analysis, the lack of any action under the No Action alternative, in combination with the lack of known foreseeable future actions and minimal past actions, would not inevitably lead to the loss of all aspen habitat in the watershed. Young aspen habitat is present in the analysis area on federal lands, and these patches will continue to persist certainly for the timeframe of the cumulative effects analysis, as well as for another 40 to Gilmore Aspen Management Project Page 18 Preliminary Environmental Assessment: 30-day Comment Document

80 years. The greatest risk on federal lands and in the larger watershed is the continued maturation of these pioneer forests to the point when these short-lived trees die and are being replaced by later successional forest types such as northern hardwoods. If new aspen stands are not created at this time, then in 80 years this habitat will be lost from the analysis area. In order to understand the degree of cumulative effects risk associated with the No Action alternative, it is important to understand that regenerating aspen trees depends on existing aspen trees that are healthy and capable of sprouting vigorously when cut and exposed to sunlight. Table 3 shows that in the analysis area, about nine percent of NFS lands are young enough, less than 61 years of age, so that aspen trees in these stands will continue to grow and be healthy over the next 10 to 20 years. These trees are the ones most likely to sprout vigorously when cut and managed for aspen regeneration. The remaining 91 percent of NFS lands in the analysis area consists of stands more than 60 years old that may be, or already are, either too old to contain many healthy aspen trees, or are at risk of losing any remaining aspen trees to decline and mortality over the next 40 years.

Table 3: Differences among alternatives in 2024 and 2034 for age classes important to aspen regeneration capacity on forested NFS lands within the cumulative effects analysis area.

Stand Age

Class

Current Acres

No Action Alternative Proposed Action

2024 2034 2024 2034

years ac % ac % ac % ac % ac % ≤60 648 9 622 8 427 6 711 9 516 7

61-100 3,277 44 2,435 33 1,379 18 2,360 32 2,180 29 >100 3,497 47 4,365 59 5,616 76 4,357 59 4,732 64

With no action over the next 10 years, another 12 percent of NFS lands will age from the current situation to over 100 years old (Table 3), and over the subsequent 10 years, about 17 percent of NFS lands will do the same. So in 20 years, on 76 percent of NFS lands, any aspen trees present will have deteriorated beyond recovery. This will reduce the overall abundance of aspen trees on the landscape and will shrink their distribution geographically, and in turn will further limit the ability to regenerate aspen. While over the next 10 years this alternative will not likely have any additional cumulative effects to wildlife species associated with aspen or early successional habitat, the lack of action now will make it more difficult to provide new aspen habitat in the future. This alternative will continue the declining trend in early successional habitat and associated wildlife species within the analysis area. If no actions are taken within the next 20 years, only about a quarter of NFS lands in the analysis area will provide opportunities to create new aspen habitat that could benefit wildlife (i.e. about 24 percent will be less than 100 years old in 2034).


The Proposed Action Direct and Indirect Effects As described above in Chapter 2, the Proposed Action includes about 60 acres of aspen regeneration harvests to create regenerating aspen stands in the 0 to 9 year old age class (see Table 1 and Figure 1). The activities would include some limited apple tree release (where available) and would result in conversion of hardwood stands to aspen/birch habitat. Logging is proposed for the winter months, while all of the trees’ energy reserves are stored in their root systems. This will increase the vigor and abundance of the regenerating sprouts. Clearcutting is proposed, which will remove most of the trees in each unit, and will allow sunlight to reach the new aspen/birch. Because of aspen’s strong affinity to light and the reduced vegetative competition from clearcutting and whole tree harvesting, as well as its strong root-suckering response to cutting, clearcutting is the most effective management approach to creating these stands of aspen (Perala 1990). Whole-tree harvesting will contribute to the success of aspen regeneration in the harvest units because it will reduce the amount of logging slash in the stand, which can shade the small seedlings and occupy space that seedlings need to successfully regenerate. The effects of the Proposed Action on habitat composition would be the creation of an additional 60 acres of aspen habitat, converting existing mature hardwood stands to aspen, and shifting the proportion of aspen/paper birch in the analysis area to eight percent (approximately 174 acres total). This shift would contribute to moving the analysis area toward the Forest Plan’s aspen/paper birch composition objectives of 10 to 15 percent as shown in Table 2 above. The effects of this alternative on structural diversity are small but notable. It would provide 60 acres of regenerating early successional forest habitat, or almost three percent of the analysis area for direct and indirect effects (approximately 2,200 acres of NFS lands within Compartments 12 and 20) as described at the beginning of this section. Given the lack of any regenerating habitat currently in the analysis area, this increase would be meaningful for species dependent on early successional and aspen habitat. Because the regenerating age class only lasts for 10 years, the benefits accrued to species associated with this age class would be short-term. However, these 60 acres of new trees in eight separate patches establishes some additional structural diversity that would persist into the future, until either additional management or natural disturbance creates the next new patches of regenerating habitat. Forest Plan regenerating age class objectives vary by habitat type, and are applied only to lands suitable for management using even-aged silvicultural methods (Forest Plan, Table 2.2-2, p. 11). The age class objectives for the aspen regenerating age class in the Diverse Forest Use MA portions of the analysis area are 10 to 20 percent. All 91 acres of aspen in the project area, currently existing in the young age class of 10 to 39 years of age, are suitable for even-age silviculture, and so can be used with the proposed new aspen acres to project future age class distributions as described in Table 4 below.


Table 4. Comparison of the existing age class distribution of aspen stands with anticipated distributions in the three decades following completion of vegetation treatments.

Age Class (years)

Forest Plan

Objectives Existing

Condition 2024

Condition1 2034

Condition 2044

Condition

years class % acres % acres % acres % acres %

0-9 Regen 10-20 0 0 60 40 0 0 0 0 10-39 Young 45-55 91 100 42 28 60 40 60 40 40-59 Mature 25-35 0 0 49 32 91 60 42 28 60+ Old 3-5 0 0 0 0 0 0 49 32 91 100 151 100 151 100 151 100 1 The estimated 2024 condition is based on the assumption that the proposed harvest units will be harvested by 2017, and the newly established aspen stands will be seven years old by 2024. Based on these assumptions, the regenerating age class for aspen will be in evidence from 2017 through 2026.

As indicated in Table 4, the short-term impact of the Proposed Action alternative is to increase the regenerating age class of aspen to twice the maximum proportion identified in Forest Plan objectives (40 percent). It is challenging to balance age class distribution when starting with just one age class. By creating a substantial amount of new aspen habitat, balancing age class distribution becomes a lower priority than establishing new stands, which can then be manipulated in the future to balance age class distribution. The benefit of this approach is that the Forest Service is more likely to be successful at regenerating aspen because the scattered aspen trees are still vigorous enough to root sucker and establish a dominant cover. As this regenerating habitat only represents three percent of the analysis area, only exists for 10 years, and does not remove old age class habitat of other types, this approach does not negatively affect structural diversity. In addition to the creation of aspen habitat, the proposed clearcuts would also release and revitalize existing groups of wild apple trees and allow for natural regeneration of herbaceous plants. Overall, the health and vigor of new stands would be improved by the removal of declining and diseased timber (especially aspen clones), and an increase in sunlight and growing space for the new seedlings. Over time, this would result in increased growth rates for the young stand and result in vigorous and healthy aspen/birch stands. Ruffed grouse, American woodcock, deer, moose, some small mammals, and many birds that depend on aspen and early successional habitat would benefit from the regenerating aspen habitat. Ruffed grouse, in particular, would benefit from the denser regenerating stands that provide food and cover for young grouse after hatching in the late spring. In the Northeast, declines in forest interior bird species may be related to the loss of early successional habitat. Mature forest interior bird species preferentially use the regeneration cuts or early stages of forest succession during the post-breeding period and fall migration, and experience higher fitness in young forest habitat. However, this increase in regenerating aspen is temporary, and


as such, most or all of these species’ populations may experience small increases in individual numbers or remain at current levels in abundance and distribution within the project area. The increase in early successional habitat from the Proposed Action will last close to 20 years, and species utilizing this habitat would require replacement stands as the existing areas age over time. Long-term benefits would be attained within the analysis area with a series of additional regeneration cuts over future planning cycles. State designated deer wintering areas exist within these compartments and are associated with wetlands, streams, and softwood stands and plantations. Field checks show that deer numbers are low and fluctuate seasonally. This is due in part to poor habitat conditions, namely the lack of early successional habitat that would supply browse in and adjacent to deer wintering areas. The proposed aspen clearcuts would create dense thickets with desirable browse for deer and moose. Softwood stands are mostly mature and over mature with few young regenerating stands that will provide future deer wintering cover. These older softwood stands may provide some snow interception and hiding cover but offer little browse in the understory. Those species that primarily use forested interior habitat in mature age classes may experience a slight reduction in numbers due to a reduction in this habitat. Recent work evaluating temporary and permanent forest openings on the Green Mountain National Forest indicates that forest interior bird species make preferential use of regeneration cuts or early seral stage forests during post-breeding and fall migration. The amount of mature forest habitat within the project area would be slightly lessened but the increase in the amount and distribution of the regenerating habitat would be beneficial and may result in additional breeding success of forest interior bird species. The proposed harvest, a total of approximately 60 acres, is quite small in size and in total area when compared to the amount of older forest habitat available. No meaningful amount of habitat fragmentation would be expected and the disruption to mature forested habitat would be temporary. Therefore, any adverse effects related to mature forested habitat would be minimal and short-term and may be offset by the beneficial effects of the created early successional habitat. Indirect effects would include an increased risk of wind throw of trees in stands along borders of clearcuts. Some residual tree damage would most likely occur during harvesting operations from tree felling and from skidding of trees to landings. There would be limited mortality or damage to some trees as a result of stress, heat, and equipment scraping the boles of trees. This would be reduced by logging in the winter rather than in the summer. Post-harvest activities that would occur include site preparation (if necessary) and stocking surveys. Site Preparation for natural regeneration would include removal of remaining small trees that are at high risk, diseased, damaged or of poor form within one year following the harvest to allow more space and sunlight for the establishment of desired aspen and other timber species. Whole tree harvesting would, however, substantially reduce the need to remove these remaining small trees since many of these would be utilized. Tree stocking surveys, or counting the number of surviving stems, would be conducted following the first and third year of harvest to monitor regeneration success in harvest units and to document progress toward achieving successful regeneration of the harvested stands within five years. Little or no adverse Gilmore Aspen Management Project Page 22 Preliminary Environmental Assessment: 30-day Comment Document

effect would result from these activities. Site preparation would beneficially affect the success of the regeneration. Cumulative Effects The cumulative effects analysis area is described above under the Cumulative Effects discussion for the No Action alternative. Past, present and future activities that affect aspen-birch and early successional habitats, and also wildlife abundance and population, include commercial timber harvest, non-commercial vegetation management, and maintenance of permanent upland openings. These are actions that create or maintain measurable acres of regenerating hardwood forests, aspen and other early successional forests and scrub-shrub habitats. As noted in the discussion for the No Action alternative, there has been no recent timber harvesting on NFS lands in the project area. A 30-acre regeneration harvest occurred four years ago on private land north of the Forest in Compartment 12, and a 5-acre area of aspen-birch was cleared for a new home and pasture along the Notch Road in Compartment 20. The only timber harvesting planned on NFS lands in this area during the next 10 years is this proposed Gilmore aspen project. No known private timber harvests are planned. Beyond 10 years, it is envisioned that more aspen regeneration cuts such as this one would be completed, and thus continue improvements to aspen and early successional habitat, thereby benefiting those wildlife species dependent on those habitats. Any future harvesting would be subject to further analysis. Considering past and foreseeable future activities over the 20-year timeframe, and the proposed activities related to Habitat Diversity, General Vegetation, and Wildlife, the Proposed Action would provide a small increase in early successional habitat and aspen habitat in the analysis area when compared to the No Action alternative. With the low proportion of these habitats across the area, the increase of 60 acres of regenerating aspen habitat would raise the proportion of this habitat by 42 percent within NFS lands to around 202 acres or almost three percent. Within the analysis area as a whole, early successional habitat (i.e. scrub/shrub) would increase by about 26 percent to at least 288 acres, while remaining only one percent of the entire analysis area. So while the increases themselves may appear substantial, the larger impact of these increases is small in terms of watershed-scale compositional or structural diversity. The health, abundance and distribution of wildlife that depend on aspen and early successional habitats would be expected to see a small beneficial cumulative effect within the next 10 years. Over the long term, while this benefit diminishes with time in terms of early successional habitat, it will continue over the length of time these new aspen stands are present in the landscape for species associated with aspen in the other age classes. Those species that depend on interior forest habitat in pole-sized and mature age classes would experience little or no adverse cumulative impacts due to the small scale and size of the proposed harvests, and the lack of relevant past or future activities in the project area. The most important contribution of the Proposed Action to improving early successional and regenerating aspen habitat is the expansion of aspen habitat, which would create new vigorous aspen clones that would persist in the landscape for another 100 years, and which would make Gilmore Aspen Management Project Page 23 Preliminary Environmental Assessment: 30-day Comment Document

use of existing mature clones before they die. Enabling aspen to persist in the landscape, regardless of its abundance, provides for future management options. The creation of an additional 60 acres of aspen via the Proposed Action would help in a small way to mitigate the continuing loss of old aspen trees to decline and death by increasing the number of stands and acres less than 60 years old. This would create a future larger pool of aspen trees and clones able to respond to cutting, and so would extend both the period of time and the acres over which aspen management might be implemented successfully. In conclusion, the impacts of the proposed activities would result in few overall cumulative effects, most of which would be beneficial, and some of which are critically important. Climate Change It is also important to briefly discuss climate change. Research suggests that a warming climate would likely influence ecosystem composition and ecological processes over the long-term (see reviews in Millen 2009, Prout 2009, Colter 2009, Mattrick 2009, and Burbank, D. 2010). Ecosystems are complex, and those complexities are manifest in the various and sometimes contradictory observations and anticipated changes predicted by this research. It is unclear how climate change would ultimately influence individual species-site relationships, or the ability of species to compete for resources or respond to disturbances. Most scientists studying changes in vegetation composition and forest dynamics related to climate change acknowledge these difficulties and our limited knowledge in this area. A review of this research indicates that within the 10-year period of this cumulative impact analysis, climate change is likely to have little if any measureable effect, particularly in relation to aspen habitat. There is no evidence to suggest that aspen is declining in the project area beyond the decline associated with natural aging and forest succession. There is evidence that aspen continues to regenerate successfully in timber sales implemented recently in other parts of the GMNF. Aspen is considered a northern/boreal species, and one may anticipate future shifts in its range resulting from climate change. Research into shifts in elevation zones of forest vegetation in New England suggests that some climate-related changes are occurring now in some areas (Beckage et al. 2007, Hamburg and Cogbill 1988) and not in others (e.g. Solomon and Leak 1994). There is research that suggests other factors such as substrate and land use history interact with climate and make it difficult to attribute ecosystem changes simply to climate (Lee et al. 2005). Research on aspen in the West indicates a complex, unpredictable future for aspen, where increased drought, ozone, and insect outbreaks will vie with carbon dioxide fertilization and warmer soils, resulting in unknown cumulative effects (Morelli and Carr 2011). Conservation of, and management for, ecological diversity is fundamental to building resilience within ecosystems, which in turn will be critical to mitigating potential impacts of climatic change. The Proposed Action identifies specific actions to enhance compositional and structural diversity within the analysis area, consistent with objectives of the GMNF Forest Plan. These actions would increase species and habitat diversity, and improve forest health, all of which would improve the resilience of ecosystems within the analysis area. The No Action alternative will Gilmore Aspen Management Project Page 24 Preliminary Environmental Assessment: 30-day Comment Document

continue the trends associated with conversion of fallow land to forest, farm, or development, and natural forest succession. The eventual loss of aspen due to succession and habitat conversion may reduce the ability of this northern species to adapt to climate change in this landscape, and may accelerate its potential shift out of the Green Mountains north into Canada.

Visual Quality The effects disclosed for visual quality are summarized from the Visual Quality Specialist Report (Marks 2015). Affected Environment The general resource condition and affected environment of the project area have been thoroughly described in the General Affected Environment for the Project Area section and in the Habitat Diversity, General Vegetation, and Wildlife section. The GMNF has a documented history of timber harvest in the Gilmore Area since the 1980s. A permanent opening, visible along Notch Road, lies adjacent to units 4, 5, 6 and 7. This opening is maintained by the GMNF which provides some context for the temporary openings that will result from the proposed harvest. Private land parcels, some with homes, are located in the vicinity of and adjacent to the proposed harvests. Recent timber harvest on private land on the east side of FR112 (LaFrance Rd) has opened up viewing opportunities to the east including portions of the project area. The Bristol Cliffs Wilderness is located 3/4 mile north of the project area at its closest point with no known documented views that look toward the project area. The Breadloaf Wilderness is located over 4 miles east of the Gilmore area. Vistas located on Breadloaf Mountain look to the west toward the Champlain Valley which includes the project area. The Forest Plan established visual condition guidelines that lead to Visual Quality Objectives (VQOs) for NFS lands within the GMNF. Visual Quality Objectives help provide a threshold of acceptable impacts that may result from management activities across the landscape. Table 5 below displays the VQO thresholds that are applicable to the Gilmore Project Area. Table 5: Visual Quality Objectives for the Gilmore Project Area

Source: 2006 GMNF Forest Plan On-site views (less than 1/2 mile) from Notch Road and TH30/FR111 (Baslow Rd) have moderate viewer sensitivity and should meet the Partial Retention VQO for temporary alterations such as timber harvest.

Visual Quality Objective Threshold Partial Retention Alterations made by people must

appear subordinate within the surrounding natural appearing landscape.

Modification Alterations may dominate the original surrounding landscape, but constructed facilities must be compatible with the landscape.


On-site views (less than 1/2 mile) from FR81 and FR29B (Duclos Rd) have low viewer sensitivity and should meet the Modification VQO for temporary alterations such as timber harvest. Off-site views (more than 1/2 mile) to the proposed activities should meet the Partial Retention VQO on the upper part of the more noticeable peaks and ridges and the Modification VQO on other locations. Unit 3 can be seen as an offsite view from LaFrance Road. In addition, some of the stands proposed for harvesting fall within the viewshed from other offsite views farther outside of the immediate project area. The current visual conditions from the roads within the project area and offsite views from known vantage points meet the desired VQOs. Effects Analysis There were no unresolved issues directly related to visual quality. One unresolved issue related, in part, to visual quality, is a concern that logging activity, in particular clearcutting, could disrupt the natural beauty of the area, and disturb the adjoining private property. This issue is being addressed above on page 13. Field review and Google Earth computer analysis was used to determine the visual effects. Field visits were made by the GMNF Landscape Architect on September 11, 2013 and November 20, 2013 to the project area. The analysis area for the visual resource includes the project area as well as popular offsite locations with known potential vantage points. These include views from Abbey Pond, Frost Mountain, Bristol Cliffs Wilderness (high point: South Mountain, 2325 feet elevation), and Breadloaf Wilderness at Breadloaf Mountain on the Long Trail. The indicator used to measure effects to visual quality is discussion of the proposed activities and how they do or do not meet VQOs. A threshold of how key views meet the VQOs described above in the Affected Environment section above will be used to disclose the effects of the alternatives. The No Action Alternative Direct and Indirect Effects As described in Chapter 2 for the No Action alternative, there would be no removal (cutting) of the eight proposed harvest units. The current management situation and existing conditions, subject to natural changes, would continue forward. The No Action Alternative would result in no change to offsite or onsite views from the current condition, and thus, no direct or indirect impacts from implementation of this alternative. Mitigation would not be needed. Visual Quality Objectives would be met. Cumulative Effects Since there would be no direct or indirect effects to the landscape from timber harvesting under No Action, there would be no incremental additive activities that would result in cumulative impacts to visual quality. Gilmore Aspen Management Project Page 26 Preliminary Environmental Assessment: 30-day Comment Document

The Proposed Action Direct and Indirect Effects Google Earth computer analysis was used to analyze the project proposal from potential offsite locations greater than 1/2 mile from the proposed timber harvest. The offsite viewing locations include Abbey Pond, Frost Mountain, Bristol Cliffs Wilderness (high point: South Mountain, 2325 feet elevation), Breadloaf Wilderness (Breadloaf Mountain on the Long Trail), home sites along FR112 (LaFrance Road), and homes south of Notch Road in between Duclos Rd and FR112. Much of the Google Earth analysis focused on terrain (as if there were no trees) for visibility to the proposed activities. Although portions of some stands were visible from some of these vantage points in the Google Earth models, due to terrain and remaining vegetation surrounding the stands, the perception of timber harvest is not anticipated to be visually evident on the ground. At most, a slight textural change of the tree canopy might be evident. Visual quality objectives would be met for all known potential offsite views. Onsite views to harvest treatments in units 1, 2, 5 and 6 would not be apparent from the roads in the immediate project area due to terrain, vegetation screening, and distance from the roads, and VQOs would be met without mitigation. Unit 3 is located along FR81. This road has a low visual sensitivity. The guidelines for low visual sensitivity in Table 2.3-3 on page 39 of the Forest Plan indicate that clearcuts may be up to 15 acres in size with irregular shapes. Unit 3 would meet this guideline. The following mitigation measures should be applied to harvest units 4, 7, and 8:

Mitigation 1: Units 4 and 7 lie adjacent to roads with moderate visual sensitivity and would need to follow the Forest-wide visual condition guidelines for moderate visual sensitivity in Table 2.3-3 on page 39 of the Forest Plan. This includes having any roadside openings of no more than 200 feet in length, and providing for a perceived size and shape of clearcut openings of up to 5 acres by using irregular shapes and interspersing islands of leave trees as necessary.

Mitigation 2: Unit 4 is designed to be 11.6 acres in size and rises in elevation from Notch Road. As such, it has the potential to appear as more than 5 acres from that vantage point. To reduce the seen area and to meet the moderate visual sensitivity guidelines in Table 2.3-3 of the Forest Plan (mitigation 1 above), islands of trees should be retained in strategic places as suggested in Figure 2 below.

Mitigation 3: Unit 8 is located along the Duclos Road and directly adjacent to the only year round private residence on that road. The amount of the unit frontage on the roadside should not exceed roughly 200 feet.

The following mitigation should be applied when needed to manage slash from the timber harvest:

Mitigation 4: Gilmore Aspen Management Project Page 27 Preliminary Environmental Assessment: 30-day Comment Document

Where timber harvest takes place adjacent to roads and should whole tree harvesting not be used at that location, pull back remaining slash from the road edge a minimum of 25 feet, then lop and scatter slash to lie within 2 feet of ground so as not to create an unnatural edge for 100 feet from road edge.

With the application of these mitigations, all harvest units would meet VQOs and effects to the visuals resource would be minimal. Figure 2. Gilmore Project Visual Quality Mitigation Retain trees in islands as shown for unit 4.

Gilmore – Unit 4


Cumulative Effects The cumulative effects analysis area includes the project area as well as popular offsite locations with known potential vantage points described above. The cumulative effects analysis considers activities approximately 10 years past and 10 years into the future. No timber sales on federal lands in the analysis area have occurred over the past 10 years. On nearby private and state lands, recent harvesting has been limited. A 30-acre regeneration harvest occurred four years ago on private land north of the Forest in Compartment 12, and a 5-acre area of aspen-birch was cleared for a new home and pasture along the Notch Road. There are no reasonably foreseeable future actions on private lands that are expected to substantially affect the visual resource. Development may continue to open up private lands from forest to more open landscape, creating opportunities to view NFS lands; however, the Forest Service is unaware of any major development in or close to the project area. In conclusion, no cumulative impacts to the visual resource would be expected from implementation of the Proposed Action.

Soils and Wetlands The effects disclosed for soils and wetlands are summarized from the Soils and Wetlands Specialist Report (Quintana-Jones 2014) and the Custom Soil Resource Report for Addison County, Vermont (Web Soil Survey), (USDA - Natural Resources Conservation Service 2014). Additional information has also been incorporated from the Hydrology and Aquatic Species Specialist Report (Ketcham 2014). Affected Environment The general resource condition and affected environment of the project area are thoroughly described in the General Affected Environment for the Project Area section and in the Habitat Diversity, General Vegetation, and Wildlife sections. The area considered in this soils and wetlands analysis includes the lands within approximately 1/4 mile of the eight units proposed for timber harvest. The affected environment includes soils and wetlands that have been relatively undisturbed over the last 20 years. Generally, soils throughout the compartments are productive. The wetter but still productive soils support the softwood stands and stands with aspen clones. Ecological land type analysis indicates there are soil types that are good to moderate for aspen management in the project area. Most of these soils are loamy and underlain by a hardpan (dense layer) beginning at 10 to 25 inches below the soil surface. Peru soils are moderately well drained, Marlow soils are well drained, and Cabot soils are poorly drained. Berkshire is a well-drained, loamy soil lacking a hardpan. All eight harvest units are located on terrain with a low to moderate erosion hazard as determined by soil type and slope (USDA - Natural Resources Conservation Service 2014). Wetlands have hydric soils, with hydrology typified by saturated soil conditions for all or part of the growing season. Wetlands also harbor hydrophytic vegetation. Several small wetland areas and seeps (each less than 1/10 of an acre in size) occur in the project area. They are all State Class III Wetlands and occur in concave landscape positions as small openings in the forest dominated by forbs, ferns and/or sedges. Class I wetlands are identified on the Vermont significant wetlands inventory and are exceptional or irreplaceable in their contribution to Gilmore Aspen Management Project Page 29 Preliminary Environmental Assessment: 30-day Comment Document

Vermont's natural heritage and, therefore, merit the highest level of protection. Class II wetlands are identified on the Vermont significant wetlands inventory maps and merit protection, based on an evaluation of the extent to which the wetland serves functions and values either taken alone or in conjunction with other wetlands. Class I and II wetlands are considered significant according to the Vermont Wetland Rules, but Class III are not and do not need special protection measures. No State Class I or II wetlands occur within the units proposed for harvest, although a few Class II wetlands occur within the analysis area (State of Vermont, Natural Resources Board 2010). Effects Analysis One unresolved issue was identified during project scoping relating to soils and wetlands. There is concern that logging activity could contaminate a spring water source, the stream that supplies the water, and damage the water line associated with the spring. This issue was resolved prior to the initiation of the scoping process and is discussed in the Proposed Action sub-section below. The remaining general soil and wetland resource concerns will focus the discussion of impacts below. The No Action Alternative Direct and Indirect Effects As described in Chapter 2 for the No Action alternative, there would be no removal (cutting) of the eight proposed harvest units. The current management situation and existing conditions, subject to natural changes, would continue forward. Therefore, there would be no soil disturbing activities, and thus no direct or indirect effects. On most sites, soils would become more enriched because all biomass would remain on-site. Soils would not be subject to the risks of erosion and compaction inherent with tree harvesting. Nearby wetlands and streams would not be disturbed. Cumulative Effects Since there would be no direct or indirect effects from timber harvesting and skid trail construction and use under No Action, there would be no incremental additive activities that would result in cumulative impacts to soil and wetland resources. The Proposed Action Direct and Indirect Effects The effects of the proposed harvest on soil, wetlands and water resources would be minor, as long as Forest Plan standards and guidelines (USDA Forest Service 2006a, p. 20-22) and the mitigation measures listed below are implemented. Soils Direct effects to soils resulting from implementation of the Proposed Action would include soil compaction, rutting, erosion, and loss of soil productivity. A temporary reduction of soil nutrient availability may occur as the canopy is removed and the soil is heated by the sun. Soil nutrient loss may occur due to whole tree harvesting (USDA Forest Service 2009). The Forest Plan provides no direction for use of whole-tree harvesting. The GMNF Final Environmental Impact


Statement states: “For all [Forest Plan] alternatives, the type and intensity of harvests on the GMNF would include: minimal use of clearcutting; mostly bole-only logging; relatively long rotations; …Given these conditions the nutrient losses due to harvest (biomass removal) would be minor, as would the effects on soil quality and productivity.” (USDA Forest Service 2006b, page 3-30 to 3-31). Whole-tree harvesting removes more nutrients from the soil system than harvesting where tops and slash are left onsite. Soil nutrient levels and soil/site productivity are maintained over the long term when Best Management Practices (BMPs) (similar to Acceptable Management Practices, or AMPs) are implemented along with harvesting, when long rotations (80-100 years+) are used, and slash is left on-site (USDA Forest Service 2006b; pages 3-30 to 3-31; USDA Forest Service 2012). Based on the best available scientific information, it cannot definitively be predicted if the whole tree harvest clear cuts proposed for the Gilmore project would affect long-term soil productivity. Factors affecting soil productivity are both site-specific (for example, soil mineralogy or soil drainage), and broad (examples are climate change and atmospheric deposition of nitrogen and sulfur). Some nutrient loss would be expected if more biomass is removed from the site. However, based on past observations in stands harvested using a combination of whole tree harvesting and clearcutting, these stands proposed for harvesting would be expected to regenerate vigorously following harvest, indicating minimal impacts to soil productivity (Burt 2014). During the scoping period, public concerns arose regarding a private spring located within Unit 1 and possible effects on water quantity and quality due to harvesting activities. As a result of this concern, the proposed harvest unit (Unit 1) was moved to the east of the original location so that all logging activities would avoid the spring area. The unit was reduced in size and all skidding would be done away from the spring and water line. Concern was also expressed that the stream downhill of Units 3 and 4 might be affected by harvest activities. Forest Plan Standards and Guidelines, AMPs, and BMPs for Water Quality (USDA Forest Service 2012) would minimize any impacts to water supplies in the analysis area. Wetlands No Class I or II wetlands occur within the analysis area, but there are a few small Class III wetlands. Some sediment deposition in small wetlands in or directly adjacent to the project area may occur as a result of timber harvest activities. Monitoring by GMNF personnel has repeatedly demonstrated that the Standards and Guidelines and AMPs successfully implemented in harvest areas are effective in minimizing erosion, compaction, and impacts to wetlands (USDA Forest Service 2009; USDA Forest Service 2006b, pages 3-22 through 3-32). In addition, many harvests have required mitigation measures that further minimized impacts. To a large extent, areas impacted by harvest activities recover over time. Standards and Guidelines, and Mitigation Measures It is important to highlight the following Forest Plan Standards and Guidelines that are most applicable to this project and would be followed: Gilmore Aspen Management Project Page 31 Preliminary Environmental Assessment: 30-day Comment Document

• S-2 requires a buffer strip between management activities and streams and wetlands.

These strips minimize impacts to wetlands and riparian areas. Streams and wetlands were avoided in selecting the unit boundaries, and the small Class III wetlands and ephemeral streams occurring in the project area are not large enough to warrant a protective strip.

• S-3 requires that logging equipment operations only be allowed when soil conditions are such that compaction, rutting, and erosion will be minimal.

• G-6 requires prompt mulching and re-vegetation of critical bare soil areas following implementation of management activities. Examples of critical bare soil areas are stream crossings along roads and places where road drainage features empty into areas close to streams.

• G-10 is designed to limit the activities within 100 feet of all wetlands, including Class III wetlands, to those that protect, manage, or improve wetland riparian area condition. For example, limited harvesting of trees may be allowed within 100 feet of wetlands in order to promote aspen regeneration or specific food sources such as young tree browse. No Class I or II wetlands are within 100 feet of the harvest units. G-10 will be applied for any wetlands found within or close to the harvest units during project implementation.

• G-2 directs the Forest Service to implement AMPs for Maintaining Water Quality on Logging Jobs. Best Management Practices for Water Quality (USDA Forest Service 2012) have also been shown to be effective in minimizing these impacts.

The proposed action states that harvest activities would ideally occur only when the soil is frozen or there is sufficient snow cover, or during the driest part of the summer. Harvesting during the dry summer months of July, August, and September, if implemented, would result in only minor impacts to soil and water resources in units 3, 5, and 6 (Soils and Wetlands Specialist Report; Quintana-Jones 2014). Implementation of appropriate Forest Plan standards and guides, BMPs, and AMPs would minimize or eliminate any adverse impacts. Soil moisture conditions would be determined at implementation to decide if summer logging in those units is appropriate. All other units (1, 2, 4, 7, and 8) would be restricted to harvesting on snow-covered or frozen ground due to soil types and conditions. Harvesting under these winter conditions has been shown to prevent or minimize erosion, rutting, and compaction (USDA Forest Service 2009), and little or adverse impacts would be expected. Cumulative Effects The cumulative effects analysis area for soils and wetlands is the same as the area defined for the direct and indirect effects, including the lands within approximately 1/4 mile of the eight units proposed for timber harvest as described above. The time period considered for effects is 10 years back in the past and 10 years into the future. The primary activities with the potential to have cumulative effects on long-term soil productivity and wetland health within the analysis


area 10 years into the future would include poorly implemented timber harvests (i.e. if AMPs are not implemented); development such as residential and commercial construction and road building; and atmospheric deposition such as the deposition of sulfur and nitrogen that could reduce soil productivity through leaching out soil nutrients. No timber sales have occurred over the past 10 years on federal lands in the analysis area. Likewise, no timber sales are known to be planned in the project area for the next 10 years. Timber harvesting on private land in the past 10 years includes a 30-acre regeneration cut completed four years ago at the end of LaFrance Road just outside of the analysis area, and a 5-acre area of aspen-birch that was cleared for a new home and pasture along the Notch Road. There are no reasonably foreseeable future actions on private lands that are expected to substantially affect soil and wetland resources. Most of the timber harvesting practices currently occurring on private land are thinning and single tree selection, which would generally have less of an impact on soil productivity and wetland health (USDA Forest Service 2014). Private land development could occur in the future; however, the Forest Service is unaware of any major development in or close to the project area. In conclusion, no cumulative impacts to soil and wetland resources would be expected from implementation of the Proposed Action.

Threatened, Endangered and Sensitive Species (Wildlife and Plants) The effects disclosed for threatened, endangered and sensitive (TES) species are summarized from the Biological Evaluations prepared for wildlife and plants (Burbank, M. 2014b, and Deller 2014) and the Wildlife Report (Burbank, M. 2014a). These reports are very detailed; only summary information will be provided here. The Endangered Species Act requires that federal activities do not jeopardize the continued existence of any species federally listed or proposed as threatened or endangered, or result in adverse modification to such species’ designated critical habitat. In accordance with Section 7(c) of this Act, a report of the listed and proposed threatened or endangered species that may be present in the project area was reviewed. Forest Service Manual 2670.22 provides direction to implement management practices to ensure species do not become threatened and to maintain viable species populations distributed throughout their range on NFS lands. This analysis includes potential effects to sensitive species for which the Regional Forester has identified that population viability is a concern. These species are described as Regional Forester’s Sensitive Species (RFSS). Affected Environment The general resource condition and affected environment of the project area have been thoroughly described in the General Affected Environment for the Project Area section and in the Habitat Diversity, General Vegetation, and Wildlife section.


Effects Analysis One unresolved issue was identified during project scoping relating to TES plants and animals. There is concern that logging activity could disturb Jacob’s Ladder (Polemonium van-bruntiae), a Vermont-threatened plant species. The indicator selected to disclose how the proposed activities for each alternative would impact Jacob’s Ladder is the location of the species within the project area and what activities are proposed that could affect the plants. This issue will be addressed by mitigation. The No Action Alternative Direct and Indirect Effects As described in Chapter 2 for the No Action alternative, there would be no removal (cutting) of the eight proposed harvest units. The current management situation and existing conditions, subject to natural changes, would continue forward. Therefore, there would be no direct or indirect effects to either plant or animal TES species. There would be no potential impact to Jacob’s Ladder. Cumulative Effects Since there would be no direct or indirect effects from timber harvesting under No Action, there would be no incremental additive activities that would result in cumulative impacts to plant and animal TES species. The Proposed Action Direct and Indirect Effects Animal Species The biological evaluation (BE) for animal species evaluated the impacts that the proposed Gilmore Aspen Management Project might have on four federally-listed threatened and endangered (T&E) species and their habitats. The Likelihood of Occurrence (LOO) for each of the four federally-listed threatened or endangered species for the GMNF is discussed in detail in the BE and is summarized here.

Common Name Scientific Name ESA Status Status on GMNF

Likelihood of Occurrence in Project Area

Gray wolf Canis lupus Endangered Historic only Low Eastern mountain

lion Puma concolor

couguar Endangered Historic only Low

Canada lynx Lynx canadensis Threatened Historic only Low Indiana bat Myotis sodalis Endangered Current Low

The GMNF in general, and the project area in particular, may include some elements of the kinds of habitats occupied by the gray wolf, eastern mountain lion, and Canada lynx. However, these species are considered extirpated on the GMNF, and none of these three species is likely Gilmore Aspen Management Project Page 34 Preliminary Environmental Assessment: 30-day Comment Document

to occur in the project area in the foreseeable future (Tumosa 2001a,f,I; USDA Forest Service 2006c). As discussed in detail in the BE, the fourth species, the Indiana bat, would not be present within the project area. No hibernacula are located in the immediate area and project area is not within 5 miles of any hibernacula; the nearest hibernaculum is roughly 18 miles south of the project area. To date, this species has been found primarily at low elevations in the Lake Champlain Valley. Temperature may be a limiting factor (Watrous et al. 2006). Most of the GMNF is situated at higher elevations in the Green and Taconic Mountains where temperatures may be too cool for Indiana bats (USDA Forest Service 2006c). Since the Gilmore project area is at or above 1500 feet elevation, all of the area is unlikely to include suitable maternity roosting habitat. There are no other areas specified by the U.S. Fish and Wildlife Service (USFWS) as important bat habitat within the project area. In conclusion, there would be no effect on gray wolf, eastern cougar, Canada lynx, or Indiana bat. The first three are not known to occur presently, nor are likely to occur in the foreseeable future within the project area. No critical habitat for any of these species occurs within the project area. Indiana bats are unlikely to be found within the project area. The BE also discussed in detail the effects that the proposed Gilmore Project might have on 22 Regional Forester Sensitive Species (RFSS), or their habitats. Only summary information will be presented here. The analysis determined that the Proposed Action would have no impact on the following RFSS species, and thus would not threaten their continued viability on the GMNF, nor result in a trend towards Federal listing of these species:

Common loon Bald eagle Peregrine falcon Sedge wren Rusty Blackbird Bicknell’s thrush Wood turtle Boulder beach tiger beetle Brook floater West Virginia white Harpoon clubtail Southern pygmy clubtail Forcipate emerald Gray petaltail

Of these species, only the rusty blackbird, has a moderate likelihood of occurrence in the project area, and as such, may be found there. All others listed above are unlikely to occur in the project area. Some including the bald eagle, peregrine falcon, and Bicknell’s thrush are likely to occur only as occasional and transient individuals. No critical or important habitat for any of these species is located within the Project area. Gilmore Aspen Management Project Page 35 Preliminary Environmental Assessment: 30-day Comment Document

The BE determined that the proposed project activities could adversely impact (i.e. a “may affect” determination) individuals of the following species, but actions are not likely to cause a trend towards federal listing or loss of viability within the planning area for any species:

Eastern small-footed bat Little brown bat Northern long-eared bat Tri-colored bat Jefferson salamander Blue-spotted salamander Four-toed salamander

The eastern small-footed bat and tri-colored bat are unlikely to be found in the project area. The Jefferson salamander, the blue-spotted salamander, the four-toed salamander, and the northern long-eared bat have a moderate likelihood of occurrence in the project area, and as such, may be found there. The little brown bat has a high likelihood of occurrence and therefore, is most likely, or known, to occur in project area. The project area does not include suitable hibernation sites for any of the bat species. The project area has abundant suitable foraging and roosting habitat for the tri-colored bat, the little brown bat, and the northern long-eared bat. It does not have any summer cliff-rock roosting habitat, but has foraging habitat for the eastern small-footed bat. Most, and possibly all, of the proposed timber and habitat management actions would take place during winter, on frozen ground, when the above RFSS are not active on the landscape. Winter logging would substantially reduce the likelihood of adverse impacts to any of the above seven species, and in particular, to the three RFSS bats. Three units (3, 5, and 6) are viable for summer logging during the driest conditions (July, August, September); that decision would be made during implementation after consideration of soil and ground conditions, and the need for any further mitigation (see also the Soils discussion under the Soils and Wetlands resource section above). It is important to note that the USFWS published a Proposed Rule to list the northern long-eared bat (Myotis septentrionalis) as endangered (78 FR 61046). A Final Rule is anticipated in the Spring of 2015. The USFWS also is assessing whether ESA listing is warranted for the little brown bat (Myotis lucifugus). Should the northern long-eared bat or little brown bat be listed as threatened or endangered before the Gilmore Aspen Management Project is completed, the project and this BE must be reviewed, and a Supplemental Information Report (SIR) likely will be warranted. At that time, new or amended mitigations for this project may be required, such as further restrictions on logging when bats are active. Plant Species There are no federally listed threatened or endangered plant species on the GMNF, and thus, there will be no effect. The BE evaluated 88 vascular TES species and 18 non-vascular TES species and determined that the Proposed Action would have no effect on these species when mitigation is applied.


Appalachian Jacob’s ladder (Polemonium vanbruntiae), a RFSS, is known from the edge of units 7 and 8, but would be flagged and avoided. There could potentially be more plants in unit 6 and also in unit 5. Timber harvest and log skidding could adversely affect those plants. In regards to a beneficial effect, cutting to regenerate aspen is not expected to improve habitat for Appalachian Jacob’s ladder. Units 1 through 5 and unit 8, include either sugar maple/beech/yellow birch or old field northern hardwoods, with slightly high site indexes, at moderate elevation, suggesting potential habitat for a few plants on the RFSS list: summer sedge (Carex aestivalis), large yellow lady’s slipper (Cypripedium parviflorum var. pubescens), butternut (Juglans cinerea), and ginseng (Panax quinquefolius). There appears to be little to nothing in the way of rich site indicator species, however, and it is unlikely that these species occur there, with the exception of butternut, which could be there as a relic leftover from previous land use. Meadow horsetail (Equisetum pratense) may occur along streams if the site is seepy, and bog chickweed (Stellaria alsine) may occur in moist, springy places that have nutrient enrichment. The following mitigations would be applied, and thus there would be no effect to these species:

• To protect Appalachian Jacob’s ladder, surveys should occur in suitable sites (that have not already been searched) in late spring or early summer before implementation and if found, the work should be adjusted or areas flagged for avoidance to avoid this species.

• To protect meadow horsetail and bog chickweed, the wettest sites should be searched in late spring to early summer before implementation, and if found, the work should be adjusted to avoid these species.

• To protect butternut, if any butternut trees are found that are not already dead, they should be left standing.

Non-native invasive plants (NNIP) are also a concern on the GMNF. Surveys of the Gilmore project area have indicated that honeysuckle may be found along FR 81 and Duclos Road, and barberry was also found in the project area. Both are species that could spread into aspen regeneration sites. The following mitigation would be applied to minimize the adverse effects of NNIP:

• To prevent these species from responding to increased light and ground disturbance and potentially infesting the aspen regeneration sites, they should be treated prior to project implementation. It is suggested that a more thorough assessment of NNIP be completed and a treatment plan be developed that’s in keeping with the Forest-wide Invasive Plant Control EA.

Two other mitigation measures would also further minimize the adverse effects of NNIP:

• To prevent the introduction of additional NNIP, any equipment used to implement the project should be cleaned prior to accessing the site.


• For all re-vegetation activities, seed mixes should be of native species and mulches should be biologically inert.

Cumulative Effects As described above, the only threatened and endangered species (plant or animal) of concern is the Indiana bat. Since it has been determined that Indiana bats are unlikely to be found within the project area, there would be no impact to that species. The proposed mitigation, in particular, winter only harvests as implemented for units 1, 2, 4, 7, and 8, and flagging and avoidance of areas where Jacob’s ladder could be found would eliminate or minimize potential impacts to RFSS species. Since there would be no direct or indirect effects from timber harvesting and log skidding under the Proposed Action, there would be no incremental additive activities that would result in cumulative impacts to plant and animal threatened and endangered species, and thus, no cumulative impacts.

Chapter 4 - List of Preparers The following Forest Service employees participated in development of the Proposed Action and/or preparation of Gilmore Project EA as members of the Interdisciplinary Team (IDT), or provided technical assistance and/or review of the EA.

Name Title Area of Responsibility Christopher Mattrick District Ranger Responsible Official Bob Bayer NEPA Coordinator Interdisciplinary team (IDT) leader Holly Knox Rec Program

Manager Recreation

Mike Burbank Wildlife Biologist Wildlife and threatened, endangered and sensitive animal species

Diane Burbank Forest Ecologist Ecological resources, Habitat diversity Donna Marks Landscape Architect Visual quality Thomas Tenyah GIS Coordinator GIS Nancy Ketcham Fisheries Biologist Fisheries, aquatics Dave Lacy (retired) and Tim Watkins

Forest Archeologist Heritage and cultural resources

Mary Beth Deller Botanist Threatened, endangered and sensitive species, and non-native invasive plants

John Kamb Civil Engineer Transportation (roads) Jeff Tilley Forester Timber management Chris Casey (retired) Silviculturalist Silviculture, timber Angie Quintana-Jones Soil Scientist Soils and Wetlands


Chapter 5 - References The following scientific references were important in developing the Gilmore Aspen Management Project Proposed Action and completing the analysis documented in this EA. This list below is presented by resource area. It includes all references from Specialist reports with the following exceptions: the Plants Biological Evaluation has over 90 references (see Project Record); the Wildlife/Animal Biological Evaluation has about 75 references (see Project Record). Only those references from the Biological Evaluations that were directly cited in this EA are listed below. General References USDA Forest Service. 2006a. Green Mountain National Forest Lands and Resource Management Plan. 164 pp. USDA Forest Service. 2006b. Green Mountain National Forest Final Environmental Impact Statement. USDA Forest Service. 2006c. Final Environmental Impact Statement. Appendix E – Biological Evaluation of the Green Mountain National Forest Land and Resource Management Plan Revision on federal endangered, threatened, and proposed species and Regional Forester sensitive species. Habitat Diversity Beckage, B. B. Osborne, D.G. Gavin, C. Pucko, T. Siccama, and T. Perkins. 2008. A rapid upward shift of a forest ecotone during 40 years of warming in the Green Mountains of Vermont. Proceedings of the National Academy of Sciences 105(11): 4197-4202. Burbank, D. 2014. Gilmore Mountain Aspen Project, Ecological Diversity Report. (Specialist Report). 14 pp. Burbank, D.H. 2010. Climate change and potential impacts to vegetation and forested ecosystems on the Green Mountain National Forest. USDA Forest Service, Green Mountain National Forest, Middlebury, VT. Burbank, M. 2014a. Gilmore Mountain Aspen Project Wildlife Habitat Report. (Specialist Report). 5 pp. Burbank, M. 2014b. Gilmore Mountain Aspen Management Project Biological Evaluation (Wildlife). 27 pp. Carey, A.B. and R.O. Curtis. 1996. Conservation of biodiversity: a useful paradigm for forest ecosystem management. Wildlife Society Bulletin 24:610-620.


Casey, C. 2014. Gilmore Mt Aspen Project – Silvicultural Specialist Report. (Specialist Report). 13 pp. Cogbill, C.V., J. Burk, and G. Motzkin. 2002. The forests of presettlement New England, USA: spatial and compositional patterns based on town proprietor surveys. Journal of Biogeography 29: 1279-1304. Colter, A. 2009. Soils and climate change. USDA Forest Service, White Mountain National Forest, Campton, NH. 9 pp. Fry, J., G. Xian, S. Jin, J. Dewitz, C. Homer, L. Yang, C. Barnes, N. Herold, and J. Wickham. 2011. Completion of the 2006 National Land Cover Database for the Conterminous United States, PE&RS, Vol. 77(9):858-864. Available at http://www.mrlc.gov/nlcd2006.php Hamburg, S.P. and C.V. Cogbill. 1988. Historical decline of red spruce populations and climatic warming. Nature 331: 428-431. Leak, W.B. 1976. Relation of tolerant species to habitat in the White Mountains of New Hampshire. USDA Forest Service Research Paper NE-351, Northern Research Station, Radnor, PA. Lee, T.D., J.P. Barrett, and B. Hartman. 2005. Elevation, substrate, and the potential for climate-induced tree migration in the White Mountains, New Hampshire, USA. Forest Ecology and Management 212: 75-91. Lorimer, C.G. and A.S. White. 2003. Scale and frequency of natural disturbances in the Northeastern US: implications for early successional forest habitats and regional age distributions. Forest Ecology and Management 185:41-64. Mattrick, C. 2009. Climate change and botanical resources on the White Mountain National Forest. USDA Forest Service, White Mountain National Forest, Campton, NH. 10 pp. Millen, W. 2009. Estimating climate change effects on New England Forests – literature review and summary. White Mountain National Forest, Campton, NH. 2 pp. Morelli, T.L. and S. Carr. 2011. A review of the potential effects of climate change on quaking aspen (Populus tremuloides) in the Western United States and a new tool for surveying sudden aspen decline. Gen. Tech. Rep. PSW-GTR-235. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station. 31 p Myking, T., F. Bøhler, G. Austrheim, and E.J. Solberg. 2011. Life history strategies of aspen (Populous tremula L.) and browsing effects: a literature review. Online at: Forestry, doi:10.1093/forestry/cpq044


http://www.mrlc.gov/downloadfile2.php?file=September2011PERS.pdf

http://www.mrlc.gov/downloadfile2.php?file=September2011PERS.pdf

http://www.mrlc.gov/nlcd2006.php

http://forestry.oxfordjournals.org/content/early/2011/01/09/forestry.cpq044.full.pdf+html

http://forestry.oxfordjournals.org/content/early/2011/01/09/forestry.cpq044.full.pdf+html

Perala, D.A. Quaking Aspen. In: Burns, R.M., and B.H. Honkala, tech. coords. 1990. Silvics of North America: 2. Hardwoods. Ag. Hdbk. 654. USDA Forest Service, Washington, DC. 877 p. Prout, L. 2009. Climate change and wildlife – summary of available literature. White Mountain National Forest, Campton, NH. 11 pp. Solomon, D.S. and W.B. Leak. 1 994. Migration of tree species in New England based on elevational and regional analyses. USDA Forest Service Research Paper NE-688. Northern Research Station, Radnor, PA. Soils and Wetlands Resources Burt, N. 2013. Soil, Water Wetlands Specialists Report. (Specialist Report). 3 pp. Quintana-Jones, A. 2014. Gilmore Mountain Aspen Project Soil and Wetland Resource Report. (Specialist Report). 6 pp. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed [01/27/2014]. State of Vermont, Agency of Natural Resources - Department of Forests, Parks and Recreation. 1987. Acceptable management practices for maintaining water quality on logging jobs in Vermont. Waterbury, VT. 50 pp. Available: http://www.vtfpr.org/watershed/documents/Amp2006.pdf State of Vermont, Natural Resources Board. August 2010. “Vermont Wetland Rules, Vt. Code R. 12 004 056”. Available: http://www.nrb.statevt.us/wrp/rules.htm. University of Vermont, LAND Stewardship Program. July, 2010. “Soil Disturbance Monitoring in the Green Mountain National Forest”. Unpublished report available in the GMNF Supervisor’s Office, 231 N. Main Street, Rutland, VT 05701. 23 pp. USDA - Natural Resources Conservation Service. 2014. Custom Soil Resource Report for Addison County, Vermont. 32 pp. USDA – Natural Resource Conservation Service. 2014. “Gilmore Mountain Aspen Project Erosion Hazards”. July 2014. 6 pp. USDA Forest Service. 2012. National Best Management Practices for Water Quality, Management on National Forest System Lands, Volume 1: National Core BMP Technical Guide. United States Department of Agriculture Forest Service FS-990a, April 2012. USDA Forest Service. 2009. “Soil, Water and Riparian Monitoring in Harvest Areas, Monitoring Results from 2005-2008, Green Mountain National Forest”. Unpublished Report. Gilmore Aspen Management Project Page 41 Preliminary Environmental Assessment: 30-day Comment Document

http://websoilsurvey.nrcs.usda.gov/

http://www.vtfpr.org/watershed/documents/Amp2006.pdf

http://www.nrb.statevt.us/wrp/rules.htm

USDA Forest Service. 2014. Personal Communication. Phone conversation between Chris Casey (Forest Service Silviculturalist) and Chris Olson, Addison County Forester. Hydrology Resources and Aquatic Species Ketcham, A. 2014. Gilmore Aspen Restoration Project Hydrology and Aquatic Species and Habitat Report. (Specialist Report). 8 pp. AFS, 1999. Influences of Forest and Rangelands Management on Salmonid Fishes and Their Habitats, Special Publication Number 19. W. R. Meehan, editor. American Fisheries Society, 5410 Grosvenor Lane, Bethesda, MD 20814. NCASI, 2012. Assessing the Effectiveness of Contemporary Forestry Best Management Practices (BMPs): Focus on Roads. Special Report No. 12-01. National Council for Air and Stream Improvement, Inc. (NCASI), Research Triangle Park, NC 27709-3318. Recreation Resources Knox, H. 2014. Gilmore Mountain Aspen Management Project Recreation Resources Report. (Specialist Report). 3 pp. USDA Forest Service. 2013. INFRA Trails Database. Heritage Resources Lacy, D. 2014. Gilmore Mountain Aspen Project Heritage/Cultural Resources Report. (Specialist Report). 2 pp. Casjens, L. 1978. A Cultural Resource Overview of the Green Mountain National Forest. Peabody Museum of Archaeology and Ethnology. Report on file at the Forest Supervisor’s office. Haviland, W.A., and M.W. Power. 1994. The Original Vermonters: Native Inhabitants, Past and Present. University Press of New England. Lacy, D.M. 1999. Myth Busting and Prehistoric Land Use in the Green Mountains of Vermont. In The Archaeological Northeast, edited by M.A. Levine, K.E. Sassaman and M.S. Nassaney. Bergin and Garvey, Westport, CT. pp 115-124. Transportation and Roads System Kamb, J. 2014. Response to Comments on Road Issues. (Specialist Report). 1 p. Wilderness Marks, D. 2013. Email Communication to R. Bayer. Dec12, 2013. (Specialist Report). 1 p. Visual Resources Marks, D. 2015. Gilmore Project Visual Quality Report. (Specialist Report). 5 pp.


USDA, Forest Service. 1974. National Forest Landscape Management Volume 2. Agriculture Handbook 462. Washington, D.C.: US Department of Agriculture. 47 pp. Botany Deller, M.B. 2014. Prefield Research Summary & Short Biological Evaluation Form Threatened, Endangered & Sensitive Species (Biological Evaluation). 17pp. Wildlife DeGraaf R.M and Yamasaki M. 2000. New England Wildlife Habitat, Natural History and Distribution. University Press of New England. 496pp. Dessecker D.R., Norman G.W. and Williamson S.J. editors. 2006. Ruffed Grouse Conservation Plan. Association of Fish and Wildlife Agencies. 94pp. Ehrich, P.R., Dobkin D.S. and Wheye, D. (1988), The Birder’s Handbook A Field Guide to the Natural History of North American Birds. Simon and Schuster, Fireside, New York. 785. Smetzer, J. R., King, D. I. and Schlossberg, S. (2014), Management regime influences shrubland birds and habitat conditions in the Northern Appalachians, USA. The Journal of Wildlife Management, 78: 314–324. doi: 10.1002/jwmg.658 Threatened, Endangered, and Sensitive Species Kurta A. and Kennedy J. 2002. The Indiana Bat: Biology and Management of an Endangered Species. Bat Conservation International. 253pp. Tumosa, J. 2001a. Species Data Collection Form for Canis lupis. Revised by M.A. Stevens, 2002. Unpublished, Green Mountain National Forest, Rutland, VT. Tumosa, J. 2001f. Species Data Collection Form for Lynx canadensis. Revised by D. Batchelder, 2002. Unpublished, Green Mountain National Forest, Rutland, VT. Tumosa, J. 2001i. Species Data Collection Form for Puma concolor couguar. Revised by M.A. Stevens, 2002. Unpublished, Green Mountain National Forest, Rutland, VT. Watrous, K.S., T.M. Donovan, R.M. Mickey, S.R. Darling, A.C. Hicks, S.L. von Oettingen. 2006. Predicting Minimum Habitat Characteristics for the Indiana bat in the Champlain Valley. Journal of Wildlife Management 70: 1228-1237.


Appendix A – Mitigation Measures The Green Mountain National Forest Land and Resource Management Plan (Forest Plan) established Forest-wide and Management Area Standards and Guidelines (S&Gs) to mitigate potential adverse effects of management activities (Forest Plan, Chapter 2, Section 2.3; and Chapter 3). The Gilmore Project has been designed to be consistent with all Forest Plan S&Gs. Although S&Gs are usually implemented without any need for explanation in site-specific NEPA documents, there are occasions when their emphasis specific to a project is needed to facilitate compliance with the Forest Plan. Mitigation measures have also been developed specifically for the Gilmore Project to address resource concerns beyond those addressed by Forest Plan S&Gs. Listed below are relevant emphasized S&Gs and mitigation measures for the Proposed Action alternative by resource area. Visual 1. Units 4 and 7 lie adjacent to roads with moderate visual sensitivity and would need to follow

the Forest-wide visual condition guidelines for moderate visual sensitivity in Table 2.3-3 on page 39 of the Forest Plan. This includes having any roadside openings of no more than 200 feet in length, and providing for a perceived size and shape of clearcut openings of up to 5 acres by using irregular shapes and interspersing islands of leave trees as necessary.

2. Unit 4 is designed to be 11.6 acres in size and rises in elevation from Notch Road. As such, it has the potential to appear as more than 5 acres from that vantage point. To reduce the seen area and to meet the moderate visual sensitivity guidelines in Table 2.3-3 of the Forest Plan (mitigation 1 above), islands of trees should be retained in strategic places as suggested in Figure 2 below.

3. Unit 8 is located along the Duclos Road and directly adjacent to the only year round private residence on that road. The amount of the unit frontage on the roadside should not exceed roughly 200 feet.

4. Where timber harvest takes place adjacent to roads and should whole tree harvesting not be used at that location, pull back remaining slash from the road edge a minimum of 25 feet, then lop and scatter slash to lie within 2 feet of ground so as not to create an unnatural edge for 100 feet from road edge.

Soil, Water, Wetlands and Fisheries The following Forest Plan Standards and Guidelines are most applicable to this project and should be followed: 1. Apply S-2 requiring a buffer strip between management activities and streams and wetlands.

The small Class III wetlands and ephemeral streams occurring in the project area are not large enough to warrant a protective strip.

Gilmore Aspen Management Project Page A1 Preliminary Environmental Assessment: 30-day Comment Document

2. Apply S-3 requiring that logging equipment operations only be allowed when soil conditions

are such that compaction, rutting, and erosion will be minimal.

3. Consider applying guideline G-6 requiring prompt mulching and re-vegetation of critical bare soil areas following implementation of management activities.

4. Consider applying guideline G-10 to limit the activities within 100 feet of all wetlands, including Class III wetlands, to those that protect, manage, or improve wetland riparian area condition. No Class I or II wetlands are within 100 feet of the harvest units.

5. Consider applying guideline G-2 that directs the Forest Service to implement AMPs for Maintaining Water Quality on Logging Jobs. Best Management Practices for Water Quality have also been shown to be effective in minimizing these impacts.

Threatened, Endangered, and Sensitive Species 1. To protect Appalachian Jacob’s ladder, surveys should occur in suitable sites (that have not

already been searched) in late spring or early summer before implementation, and if found, the work should be adjusted to avoid this species.

2. To protect meadow horsetail and bog chickweed, the wettest sites should be searched in late spring to early summer before implementation, and if found, the work should be adjusted to avoid these species.

3. To protect butternut, if any butternut trees are found that are not already dead, they should be left standing.

NOTE: New mitigation measures may be required if the northern long-eared bat (Myotis septentrionalis) is federally-listed as threatened or endangered before the Gilmore Project is completed. Development of specific mitigation measures will be dependent on the final listing determination and/or monitoring that may occur at the project site. Non-Native Invasive Plants (NNIP) 1. To prevent the introduction of additional NNIP, any equipment used to implement the project

should be cleaned prior to accessing the site.

2. To prevent honeysuckle and barberry from responding to increased light and ground disturbance and potentially infesting the aspen regeneration sites, they should be treated prior to project implementation. A more thorough assessment of NNIP should be completed in early spring to late summer before implementation, and a treatment plan be developed that is in keeping with the Forest-wide Invasive Plant Control EA.

3. For all re-vegetation activities, seed mixes should be of native species and mulches should be biologically inert.

Gilmore Aspen Management Project Page A2 Preliminary Environmental Assessment: 30-day Comment Document

Appendix B – Response To Comments This appendix summarizes the public comments received in response to the Gilmore Aspen Management Project scoping process, and provides the Forest Service response to those comments. Responses were received during a comment period that was initiated on February 3, 2014 and ended on March 10, 2014. Scoping comments and the full content analysis are located in the project planning record. The following individuals and organizations provided comments: Commenter Number Name 001 E. Hanson 002 J. Quaglino 003 W. King 004 R. Quaglino 005 J. Buck, ANR 006 A. Weik, RGS 007 C. Kimball

Public comments helped develop the issues that were used to guide the analysis. An issue is defined as a disagreement or dispute regarding anticipated resource effects resulting from implementing the proposed action. Comments for this analysis were separated into three categories: 1) unresolved issues at time of analysis that were addressed; 2) other issues that are responded to below; and 3) non-issues. The table below lists the substantive comments taken from the comment letters. It is organized by the three issue categories defined above, and then further broken out by the resource category that seemed to best describe the comment. Each comment is identified by commenter number (001 – 007) and the sequentially numbered comment in their comment letter. Ex. Comment 001-1 represents commenter 001 (E. Hanson), his/her comment number 1. Category 1: UNRESOLVED ISSUES The following 3 unresolved issues were developed from the comments below. They represent unresolved conflicts associated with the proposed action and are addressed with the development of an alternative(s) and/or mitigation measure(s). Natural Resources Management Issue 1 PC 30100 Water/Watershed Mgmt

There is concern that logging activity could contaminate a spring water source, the stream that supplies the water, and damage the water line associated with the spring.

Gilmore Aspen Management Project Page B1 Preliminary Environmental Assessment: 30-day Comment Document

Comment 001-1 NOTE: Buried water line from spring in U.S. Tract 512 goes to his property. I am concerned that logging activities [in Unit 1] will damage the water line. RESPONSE: The original proposal was modified to address this concern. Unit 1 was decreased in size and located away from the water source and line. Also, log skidding and a log landing area were originally proposed for Baslow Road, in the vicinity of the water source. Modifications were made to avoid the spring area and skid all timber products harvested in units 1 and 2 toward Forest Road 81 (FR 81). Please see the discussion in Chapter 2 of the EA under the section entitled Alternatives Considered but Eliminated from Detailed Study.

Comment 001-2 I am concerned that logging activities will contaminate his water source (spring). RESPONSE: See the response to comment 001-1.

Comment 004-3 One of my concerns would be any runoff [from use of road] and consequent damage to the area. RESPONSE: Any damage by the purchaser or logger to either FR 81 or the private property abutting FR81 would be repaired at their expense. There are no plans to improve the road beyond what is needed for this project. All sections of the road would be maintained at the level needed for the project and consistent with the existing maintenance level. Please see the discussion on page 13 of the EA, above, in the paragraph that begins with “Considering transportation and road use...”,

Comment 004-5 Will the clearcutting of Units 3 and 4, which are uphill from a stream that runs through my property, be the cause of any runoff or compromise said stream in any way? Will the FS take any measures to protect the water from contamination? This stream is the source of fresh water for the house directly across the Upper Notch Road from my property. RESPONSE: From the map (Figure 1), units 3 and 4 lie in different areas. However, both seem to lie near streams. Best management practices and Forest Plan standards and guidelines would provide protection to these stream courses. Also, winter only logging should offer up additional protection against runoff and erosion. Please see also the response to comment 001-1 in regards to protecting the water source near unit 1. The effects of project activities on streams are disclosed in Chapter 3 of the EA in the section entitled Soil and Water.

Natural Resources Management Issue 2 PC 31100 T, E & S

There is concern that logging activity could disturb Jacob’s Ladder (Polemonium van-bruntiae), a Vermont-threatened plant species.

Comment 003-1 Aspen Cut Unit #8 contains a population of Vermont-threatened Appalachian Jacob's ladder Polemonium van-bruntiae. The Vermont Fish and Wildlife Biodiversity Program refers to it as EO #04, subpopulation 1. The Jacob's ladder plants occur in the cattail wetland ca. 25 west of Duclos Road and between 100 and 150 yards south of the Notch Road. A small group of plants occurs in the south-central portion of the wetland and a somewhat larger group is found in the


middle of the cattail growth at the southern end of the wetland and south as far as the run-off from the wetland keeps the soil fully saturated, a span of perhaps 50 yards. RESPONSE: Flagging and avoidance would be used to protect areas where Jacob’s ladder could be growing. Please see the effects discussion in EA Chapter 3 for the Proposed Action under the section entitled Threatened, Endangered and Sensitive Species (Wildlife and Plants), particularly around pages 36-37. See also the mitigations displayed in Appendix A, those listed under Threatened, Endangered, and Sensitive Species.

Comment 003-2 I have no concerns about the intended clearcut to promote aspen regeneration as long as the treatment area, skid road and log landing remain 50 yards south or west of the Jacob's Ladder site, and as long as the aspen regeneration site does not extend far enough west to be a threat to Jacob's ladder site E.O. #4, subpopulation 4, which lies in relatively open saturated land about 250 yards west of the wetland occupied by subpopulation 1..... As longs as skid roads do not cross areas with fully saturated soils the likelihood of damaging Jacob's ladder plants is slight. RESPONSE: See the response to comment 003-1 above.

Natural Resources Management Issue 3 PC 32000 Timber Resource Mgmt

There is concern that logging activity, in particular clearcutting, could disrupt the natural beauty, peace, and solitude of the area, and disturb the adjoining private property.

Comment 002-2 Concerned that his rear property lines (and the adjacent piece owned by his cousin) are not compromised [by harvest activities]. RESPONSE: Logging would only occur on Forest Service lands. Any damage by the purchaser or logger to adjoining private property would be repaired at their expense. Forest Plan standards and guidelines, and the mitigation of winter only harvesting would minimize or eliminate adverse impacts from timber operations. Please see the discussion of potential effects for the various resources in Chapter 3 of the EA, above.

Comment 002-3 Asked that some kind of buffer is left between FS clearcut and his property. RESPONSE: No buffer is planned between harvesting on Forest Service lands and the adjoining private property. Visual concerns are addressed in the EA Chapter 3 section on Visual Quality. Further disclosure in regards to this issue may be found in the Chapter 3 section entitled Habitat Diversity, General Vegetation, and Wildlife.

Comment 002-5 Asked that, as for unit 3, minimum site change will occur back there so as to not encourage more curiosity seekers. RESPONSE: Unit 3 would be harvested in accordance with generally accepted procedures. FR 81, including the end of the road where it is anticipated that a log landing would be placed, would be restored to an environmentally sound condition (i.e. any erosion concerns would be addressed). FR 81 would remain open to public use after the close of


the timber sale. See also the response to comment 002-1 below. Comment 004-4 [Unit 4] I fear the clearcutting of this area will allow easy access to this

area and subsequently to my "Private Lands". Will there be any buffer zone between our properties? Will this line be obviously and clearly marked to inform the boundary is the end of government land? RESPONSE: No buffer is planned between harvesting on Forest Service lands and the adjoining private property as stated for comment 002-3 above. Any damage by the purchaser or logger to either FR 81 or any adjoining private property would be repaired at their expense. There are no plans to improve the road beyond what is needed for this project. See also the responses to comment 002-1 below. In regards to boundary lines, they will be clearly marked and identified to the logger.

Comment 004-8 … my reason for owning property on the Upper Notch Road is for it's natural beauty, peace, and solitude the land provides me and my family. Hopefully, the FS projects in our area will not disrupt this. RESPONSE: The harvest of 60 acres spread over the area as shown in Figure 1 is a relatively small timber sale. All reasonable accommodations would be made to minimize impacts. Only one residence is in the general vicinity of the proposed logging and no cutting would occur immediate adjacent to this residence. The original Proposed Action was modified to move activities away from this residence. Further disclosure in regards to this issue may be found in the Chapter 3 section of the EA entitled Habitat Diversity, General Vegetation, and Wildlife.

Category 2: OTHER ISSUES The following comments and concerns were either not addressed in the environmental analysis or were only briefly discussed. These comments did not necessitate mitigation or alternative development. They are addressed as noted.

PC 40000 Roads Mgmt

There is concern that the use of FR81 will attract more visitors to the area, thus creating disturbance and possible damage to adjoining private property.

Comment 002-1 My main concern is that Forest Road 81 will not be widened or made to appear more accessible from the Notch Road … so that he won't have to be putting up with the inevitable surge [public] of those who have to see what is going on. RESPONSE: This concern is already decided by law, regulation, Forest Plan, or other higher level decision. There are no plans to widen or improve Forest Road 81 or maintain it to a different maintenance level as a part of this project. The road would only be maintained to safely manage National Forest lands and best management practices would be used to minimize any potential environmental effects. FR 81 is a public road open to those that wish access to National Forest lands, and that will not change as a result of this project.


Comment 002-4 Asked that FS utilize Baslow Road to cut Units 1 and 2 and not connect to FR 81 if at all possible. Any connections between Units 1 and 2 would be disastrous to us. RESPONSE: Baslow Road would not be used to skid or haul logs in order to address concerns for a nearby water source and line. See response to comment 001-1 above. Wood products from units 1 and 2 would be skidded toward the end of FR 81. FR 81 would be used for the main access.

Comment 002-6 Stated: I would be upset with myself if I didn't request that the road [FR 81] be closed. RESPONSE: This concern is outside the scope of the analysis.

Comment 004-2 I, along with my brother, are concerned about any present or future improvements to or along FR 81, especially along the section of the Right of Way. I request that the landscape and roadbed be kept, so that at the least, no visible improvements will show at the entrance or the area of my property. RESPONSE: There are no plans to improve the road beyond what is needed for this project. All sections of the road would be maintained at the level needed for the project and consistent with the existing maintenance level. Please see the discussion in the EA on page 13 in the paragraph that begins with “Considering transportation and road use...”. Appropriate action will be taken to follow protocols for the use of this road during project implementation.

Comment 004-6 Will there be any residual damage to FR 81 and my property caused by any equipment and the log trucks that will be used to access Unit 3. How would this be resolved? RESPONSE: Any damage by the purchaser or logger to either FR 81 or to any abutting private property would be repaired at their expense. There are no plans to improve the road beyond what is needed for this project. See also the responses to comment 002-1 above.

Comment 004-7 Hopefully.... FR 81 only be minimally used to access Unit 3 and not connected to the Baslow Road access for Units 1 and 2. We [he and his brother] would find this unacceptable with the obvious resulting disruption of the natural beauty, along with the great disruption that such a road development could bring to increase our concerns. RESPONSE: FR 81 would be the main access to the harvesting operations; Baslow Road would not be used (see response to comments 002-4 and 001-1). See also the response to comment 004-8 above. All sections of the road would be maintained at the level needed for the project and consistent with the existing maintenance level. At the close of the timber sale, the road would remain open to public access. There is no expectation that any large scale increase in use of this short dead end road would result from the harvest operations.

PC 60000 Public Land Ownership/ Boundaries

There is concern that current activities do not align with previously granted Right of Way across private property.

Comment 004-1 …sold part of our original lands in the area to the U.S. Forest Service (as opposed to a private owner) so that the Upper Notch area be kept as natural and pristine as possible. These were the wishes of our father.


We also granted, only by the urging of our father, a Right of Way (across what is now my property) to the FS on the guarantee and pretexts that the area would not be developed but only for a trail to access Gilmore Pond. As we both have seen-this, in reality, has not been the case. RESPONSE: This concern is outside the scope of the analysis and has already been decided by a previous decision.

NON-ISSUES (3A – 3F) The following comments do not readily lead to an issue because they are not considered a point of disagreement, debate, or dispute over the proposed action based on anticipated environmental effects. They are addressed as noted.

PC 31200 Fish & Wildlife Mgmt

Support for the use of even-age treatments, especially clearcutting, to regenerate early-successional forest communities that will help prevent declines of early-successional forest communities and constituent wildlife species.

Comment 006-1 The Ruffed Grouse Society strongly supports the use of even-age treatments, especially clearcutting, to regenerate early-successional forest communities. These habitat management treatments are essential if ongoing declines of early-successional forest communities and constituent wildlife species are to be arrested. RESPONSE: This comment expresses general or project specific support.

Comment 006-2 … many wildlife species dependent on young forest habitats are experiencing population declines as a direct result of the ongoing maturation of our eastern deciduous forests. .... As those forests have matured, habitat needed by early successional wildlife has decreased to the point where populations of some of these once-abundant species now may be imperiled. RESPONSE: This comment expresses general or project specific support.

PC 32000 Timber Resource Mgmt

Support for aspen management proposal in regards to forest management goals.

Comment 005-1 I have reviewed your aspen management proposal and do not see any conflicts with your forest management goals. RESPONSE: This comment expresses general or project specific support.

Comment 006-3 The Ruffed Grouse Society strongly supports the Gilmore Aspen Management Project Proposal. RESPONSE: This comment expresses general or project specific support.

PC 81000 General Requests

General requests for information, questions, etc.


Comment 007-1 Questions on Baslow easement: Does easement include garden plot? Would we consider leasing garden plot or renewing permit? RESPONSE: This comment asks questions, seek clarification, or request information. It is best addressed by a separate conversation with the Responsible Official.


FIGURE 1. Gilmore Aspen Management Project Map


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