High Country Conservation Advocates Rocky Smith enter for ......2019/05/13 · Ecosystem ouncil...

High Country Conservation Advocates ○ Rocky Smith ○ Center for Biological Diversity ○ San Luis Valley

Ecosystem Council ○ Rocky Mountain Recreation Initiative ○ Great Old Broads for Wilderness ○ Western

Slope Conservation Center

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May 13, 2019 Matthew McCombs Gunnison District Ranger 216 N. Colorado St. Gunnison, CO 81230 Submitted via https://www.fs.usda.gov/project/?project=53662 Re: Taylor Park EA Comments Dear District Ranger McCombs, High Country Conservation Advocates, Rocky Smith, Center for Biological Diversity, Western Slope Conservation Center, San Luis Valley Ecosystem Council, Rocky Mountain Recreation Initiative, and Great Old Broads for Wilderness – Northern San Juan Chapter submit the following comments on the Taylor Park Vegetation Management Project Environmental Assessment (Taylor Park EA). We incorporate by reference scoping comments HCCA et al submitted on May 21, 2018. Thank you for providing the opportunity to comment on this EA. High Country Conservation Advocates (HCCA) is located in Crested Butte and has approximately 1,000 members. HCCA was founded in 1977 to protect the health and natural beauty of the land, rivers, and wildlife in and around Gunnison County now and for future generations. For over 40 years HCCA has engaged on public lands issues, including multiple logging projects. HCCA is a grassroots organization that collaborates with local stakeholders and policymakers, applies sound science, educates, and upholds the environmental laws affecting our community. Rocky Smith is a forest management analyst and consultant with over 35 years’ experience in reviewing projects, plans, policies, and legislation concerning the management of national forests. The Center for Biological Diversity is a 501(c)(3) nonprofit organization with more than one million members and online activists. The Center is based in Tucson, Arizona, and has offices across the country including in Crested Butte and Denver, Colorado. The Center is dedicated to protecting and restoring imperiled species and natural ecosystems. The Center uses science, policy, and law to advocate for the conservation and recovery of species on the brink of extinction and the habitats they need to survive. The Center has advocated and continues to actively advocate for increased protections for species and their habitats across Colorado. The mission of the Western Slope Conservation Center is to build an active and aware community to protect and enhance the lands, air, water and wildlife of the Lower Gunnison Watershed. Our organization began in 1977 when neighbors joined to stop coal mines from dumping waste next to the river. Over the years our mission broadened to include protection of water resources, public lands, and human health. In 2010, we merged with a watershed group that has a history of river restoration, water quality monitoring, and education. Great Old Broads for Wilderness is a national organization, led by women, that engages and inspires the activism of elders to preserve and protect wilderness and wild lands. Broads gives voice to the millions

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of older Americans who want to protect their public lands as Wilderness for this and future generations. We bring experience, commitment, and humor to the movement to protect the last wild places on Earth. The San Luis Valley Ecosystem Council (SLVEC) helps to safeguard over 3.1 million acres of public lands and natural resources in six counties comprising the San Luis Valley, noted for their unchanged landscapes, biological richness, early settlement traditions, and rural lifestyles. This unique region of Colorado contains the mountain watersheds of the Rio Grande, extensive forests and wilderness, rangelands, and scenic panoramas which need SLVEC involvement to guard against inappropriate development and resource management. SLVEC’s mission “to protect and restore the biological diversity, ecosystems, and natural resources . . . by balancing ecological values and human needs” has directed its organizational energies to meet a diverse range of environmental and related threats and challenges within modest budget parameters. The Forest Service’s proposed project is not needed to meet its stated purpose and need. The project’s objectives could be accomplished through a smaller project that prioritizes treatments near human infrastructure and minimizes or avoids new road development across undisturbed ground. As currently proposed, the project would impact numerous resources and values that the public cherishes in and around the project area, as discussed below, and would exacerbate the already serious problems that the Taylor Park area is facing. Specific Treatment Site Recommendations At a bare minimum, HCCA and the undersigned organizations request that the Forest Service remove, or at the very least significantly reduce, several specific treatment areas and proposed roads to protect wildlife, watershed health, recreation, and other resource values. Upper Spring Creek The agency should abandon the mix of treatments proposed northwest of Spring Creek Reservoir. This area could have a full slate of logging methods: Shelterwood Seed Cut, or Group Selection in Spruce, or Clearcut if Mistletoe is Present; Overstory Removal; Dwarf Mistletoe Edge Strip or Clearcut; and Young Stand Pre-Commercial Treatment, Sanitation, or No Immediate Treatment. HCCA is opposed to implementing the project in this specific area for a number of reasons. First, the harvest of mature trees north of Spring Creek Reservoir would largely be a commercial timber harvest focus, as there is no spruce beetle there or indications of declining forest health. Second, we are aware of numerous seeps and springs on the ridge where the operations would be focused. The use of heavy equipment for logging and hauling would damage soils and hydrology. Third, there would be significant timber removal right in the middle of several very popular trails. That area is an island surrounded by trail 422 on the west, trail 648 on the east, the reservoir on the south, and road 759 on the north. Removing the overstory and allowing clearcuts and other logging methods in the middle of this would remove existing barriers between these popular routes, and degrade the area’s scenic integrity. Fourth, we are aware that this landscape currently provides excellent elk hiding cover in a landscape otherwise highly impacted by motorized and nonmotorized recreation. And fifth, it appears that these treatments may take place in an area identified as having a WCATT rank of “functioning at risk.” The EA notes that the




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Rocky Brook-Spring Creek subwatershed includes 33.9 treatment acres; 7 road acres; 424 total affected acres.1 There should be no new roads or cutting in this watershed. South Texas Creek The project should avoid treating areas immediately south of Texas Creek along the proposed road parallel to #755. The 2010 Gunnison Travel Management Plan (TMP) Final Record of Decision Map shows that the road the Forest Service proposes to develop to access treatments in this area was “scheduled to be closed.”2 The TMP addressed road and watershed concerns around Texas Creek, stating for one closed route: “This dead-end road (#755.1H) parallels the Texas Creek road (#755) and in many locations is located within riparian areas or the water influence zone of Texas Creek. There is little need for a parallel route that traverses fragile riparian and wetland habitats and it is my decision to close this road to protect natural resources.”3 The project map available for this proposal shows a very long route that would be developed, stretching from #755.1A on the west and running on the south side of Texas Creek almost to the wilderness boundary on the east, to facilitate clearcuts and associated logging. This was scheduled for closure, yet is still experiencing illicit motorized use. Why resurrect this route near a fragile wetland ecosystem in an area already experiencing significant motorized use problems? Red Mountain Creek Roadless Landscape The agency should remove the network of access roads and treatments that saturate the landscape between Road 742.3D and 742.3H. We are aware that this area currently provides refuge for big game from the hustle and bustle of human activities closer to Taylor Reservoir. New road construction this far into the backcountry would likely spread the footprint of illegal motorized use into an area currently not experiencing that problem to the same degree as other places in Taylor Park.

The 2001 Roadless Rule Inventory found 3,900 roadless areas in the Red Mountain Creek area, part of the area named Elk Mountains – Collegiate. The Red Mountain Creek area is bounded on the north and northeast by the Collegiate Peaks Wilderness Area, on the west and southwest by forest road 742 along the Taylor River and on the east by forest road 742.3D along Pieplant Creek. HCCA and other groups advocated for the roadlessness of this area in 2011.4

Park Cone The agency should remove the network of developed roads and proposed treatments that climb the eastern flank Park Cone. The 2001 Roadless Rule Inventory of the 20,000-acre Crystal Creek area includes the Park Cone area, but Park Cone was not included in the Colorado Roadless Rule inventory. HCCA and other groups advocated for the roadlessness of the area in 2011.5 The Park Cone roadless area is bounded on the north and west by County road 742, on the south by private land along Lottis Creek, and on the east by forest road 752. The 12,100-foot symmetrical Park Cone peak is practically an island surrounded by Taylor Reservoir, Taylor River, Lottis Creek and its unnamed tributaries through Union Park. Although this is a relatively low summit, there is a significant distance between its low and

1 EA Table 9 at p. 40. 2 Available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5182957.pdf. 3 USDA Forest Service, Record of Decision for Gunnison National Forest Travel Management (June 2010), at 37. 4 See Colorado Roadless Area Conservation, National Forest System Lands Proposed Rule and Revised Draft EIS,

Summary of Public Comment, NSG NEPA Services Group (September 2011), at 4-33. Available at

https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5366317.pdf. 5 Id.

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high elevations giving it good prominence within the surrounding area. Potential habitat for lynx is found in this area.

Matchless Mountain The project should remove the to-be-developed roads and planned treatment sites on the northeast side of Matchless Mountain, east of #424 and west of #742. While roads would not penetrate into the Matchless Mountain Colorado Roadless Area, there are numerous places where units and possibly some roads hit the boundary. With logging roads built up to or near the boundary, this would likely facilitate motorized impacts spreading into this landscape. We are specifically concerned with the proposed road that runs east-west from #424 to the private property inholding along #742. This long, parallel line of roads and clearcuts effectively splits in half otherwise intact habitat. Citizens’ Public Lands Proposals Portions of the proposed project overlap with a community public lands legislative effort, the Gunnison Public Lands Initiative (GPLI).6 This appears to include the recommended Matchless Wilderness and Special Management Area (SMA), American Flag SMA, and Union Park SMA. Each of the above areas is included in the GPLI Working Group for Public Lands Revised Proposal, which was released to the public in January of 2019 after almost three years of stakeholder meetings.7 We ask that the Forest Service ensure that the Taylor project is compatible with the GPLI proposal.

The EA Fails to Consider Additional Action Alternatives Submitted by the Public Under the Healthy Forests Restoration Act (HFRA),8 the agency must consider a proposed action and no action alternative, and must consider an additional alternative proposed by commenters during scoping under certain circumstances.

(c) CONSIDERATION OF ALTERNATIVES (1) IN GENERAL Except as provided in subsection (d), in the environmental assessment or environmental impact statement prepared under subsection (b), the Secretary shall study, develop, and describe—

(A) the proposed agency action; (B) the alternative of no action; and (C) an additional action alternative, if the additional alternative—

(i) is proposed during scoping or the collaborative process under subsection (f); and (ii) meets the purpose and need of the project, in accordance with regulations promulgated by the Council on Environmental Quality.9

HCCA et al.’s scoping comments proposed two alternatives that we requested the Forest Service to consider in its EA.10 A review of the EA (pp. 15-21) reveals that the Forest Service did not acknowledge or

6 See https://www.gunnisonpubliclands.org/explore-the-map. 7 Available at

https://static1.squarespace.com/static/53973ed8e4b0ac2dcfe3932c/t/5c365dd9352f53699ea8cdf5/1547066861898/G

PLI+Report+-+19.1.9+-small.pdf. 816 U.S.C. 6514(c). 9 16 U.S.C. 6514(c). 10 At pages 1-5.

https://www.gunnisonpubliclands.org/explore-the-map

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respond to those comments. Much of the proposed project is not in the wildland-urban interface, thus the agency is not exempted from having to consider an additional action alternative. 11 The Forest Service’s failure to explore the alternative or explain why it chose not to do so violates both NEPA and the HFRA.

Recommendation - We request that the agency fulfill its NEPA and HFRA obligations and either “study, develop, and describe”12 the additional action alternatives we proposed, or explain why the EA failed to do so.

This Project Would Cause Adverse Impacts and Provide Little Benefit This project appears to be driven primarily by generating commercial timber and less by a genuine need in the short-term or long-term for ecological health of the forested landscape in and around Taylor Park. The EA states: “The primary purpose of the proposed action is to increase the forest’s ability to respond to multiple and interactive stressors including climate change, drought, insect attack, or disease while promoting safety and reducing fuel loading in the wildland-urban interface and surrounding areas.”13 It is unclear from the EA how this project would accomplish that. Ineffectual resiliency treatments, significant road construction, decreased forest cover, and the cumulative impacts of this project in conjunction with the multiple and diverse stressors that the Taylor Park landscape is experiencing cast doubt on this proposal being able to realize its primary purpose. Long-Term Dwarf Mistletoe Reduction or Eradication is Unlikely The proposal is unlikely to eradicate, or even significantly reduce, naturally-occurring dwarf mistletoe within and around the project area. The “Worrall Report” that was included with the EA notes:

Of the 15,207 acres of proposed treatment in the draft Taylor Park Environmental Assessment, 791 acres are in the spruce-fir forest type (group selection and salvage clearcut). Most of the remaining 14,416 acres are lodgepole pine with dwarf mistletoe. In the fuel breaks (2,818 acres), the primary objective of the treatments is not dwarf mistletoe management, and it is anticipated that dwarf mistletoe will be left in the stands after those treatments. This leaves 11,598 acres where one of the primary goals is dwarf mistletoe reduction or eradication.14

The project is unlikely to accomplish the goal of dwarf mistletoe reduction or eradication across 11,598 acres employing the primary method detailed in the EA, which is: “In areas surrounding young lodgepole pine stands, we would harvest or fell infested edges, generally within 100 to 300 feet of healthy, young trees.”15 Creating “donut” clearcuts around questionably healthy stands, dispersed widely across a landscape that is heavily infected with dwarf mistletoe, is a flawed approach for several reasons.

11 See 16 U.S.C. 6514(d). 12 16 U.S.C. 6514(c). 13 EA at 14. 14 Jim Worrall. Lodgepole Pine Dwarf Mistletoe in Taylor Park, Colorado Report for the Taylor Park Environmental

Assessment, at 4. Available at https://www.fs.usda.gov/nfs/11558/www/nepa/108924_FSPLT3_4631086.pdf. 15 EA at 18.

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First, this presumes that the young lodgepole pine stands within the perimeter of the clearcuts are free from dwarf mistletoe. This is unlikely. If young stands are surrounded by mistletoe-infected stands, then at least some of the young trees are likely already infected with mistletoe. Depending on how old the younger trees are (i. e., how long they have had to become infected), and how severe the infection in the surrounding overstory is, it may be too late to treat the surrounding stands to promote mistletoe-free younger stands. Stands may have mistletoe even if they do not show it, as the incubation period is 2-12 years, and typically 3-4 years, before shoots emerge.16 Second, the clearcut width proposed is much larger than what is necessary to prevent or greatly reduce new infestation of the young stands, as mistletoe shoots only 50-75 feet, and “most seeds fall within 33 feet of the infected tree.”17 “Although maximum horizontal displacement may reach 16 m [52.5 feet], 10 m [32.8 feet] is a more typical, free-flight distance . . . . Most seeds are displaced horizontally only 2 to 4 m and deposited lower in the crown . . . .”18

Third, this strategy implies that these areas would have to be revisited – and re-logged – continuously into the future to maintain any semblance of mistletoe eradication. Returning periodically to the same overworked forest landscape and reconstructing road networks in perpetuity under the auspices of forest health creates more problems than it solves, as detailed below in our comments. Better would be a forest management approach that prioritizes treatments of mistletoe-infected forests where they are a risk to human infrastructure. Most of the treatments proposed in this project do not do that. The Taylor Project will likely not accomplish the objective to “Protect young, healthy stands of lodgepole pine from infestation by dwarf mistletoe through harvesting infested stands and treatment of adjacent strips and stands.”19 The Forest Service has a long – and for the most part unsuccessful – record of dwarf mistletoe control.20 For just one example, a Forest Service research study involved removal (or pruning) of all visibly infected trees, and one or more follow-up treatments at roughly five-year intervals. (This represents much more intensive management than proposed in the Taylor EA.) “Significantly, in none of the research plots was dwarf mistletoe eliminated. After treatments had reduced the parasite to undetectable levels, populations inevitably began to rise in these experimental areas.”21 In addition, promoting lodgepole health can be a catch-22. Unlike many forest insects and pathogens that are often associated with weak or slow-growing trees, dwarf mistletoes actually do better on vigorous trees.22 Since a primary goal of silviculture is to promote vigorous trees, it can indirectly

16 Hawksworth, F. G, D. Weins, and B. W. Geils, 2002. Arceuthobium in North America. In: Mistletoes of North

American Conifers. USDA Forest Service, General Technical Report RMRS-GTR-98, September 2002, at 31.

Available at https://www.fs.fed.us/rm/pubs/rmrs_gtr098.pdf. 17 EA at 24. 18 Hawksworth, F. G, D. Weins, and B. W. Geils, 2002. Arceuthobium in North America. In: Mistletoes of North

American Conifers. USDA Forest Service, General Technical Report RMRS-GTR-98, September 2002, at 30.

Available at https://www.fs.fed.us/rm/pubs/rmrs_gtr098.pdf. 19 EA at 14. 20 For example, see Conklin, David A. Dwarf Mistletoe Management and Forest Health in the Southwest. USDA

Forest Service Southwestern Region (April 2000). Available at

https://books.google.com/books/about/Dwarf_mistletoe_management_and_forest_he.html?id=IaE2-ZIrPP4C. 21 Id. at 18. 22 Id.

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promote the parasite.23 If a stand were properly treated, dwarf mistletoe would not be a serious problem in subsequent rotations. But for this to be true, the “proper treatment” would essentially have to be a very large clearcut or stand-replacing fire, at least for stands where the disease is a “serious problem” to begin with.24 With partial cutting or donut-hole clearcuts hither and yon across the backcountry of Taylor Park, the disease will almost certainly rebound between each entry and through subsequent treatments.

Recommendation - The persistence and resurgence of dwarf mistletoes in treated areas indicates that infected areas will consistently “underperform” comparable uninfected areas in terms of commercial productivity. For this reason, and because infected stands have been cut at a disproportional rate in recent decades, because there are numerous impacts that would result from this project (discussed below), and because dwarf mistletoe provides some ecological benefits, dwarf mistletoe infected stands should not necessarily receive higher priority for silvicultural treatment than non-infected stands.

Resiliency Treatments are Likely to Be Ineffective One desired long-term condition identified in the EA is the “[c]reation and maintenance of Engelmann spruce dominated stands (and other tree species) with four age classes present in order to increase stand resiliency to bark beetles and other stressors.”25 In its analysis of the related SBEADMR project, the Forest Service stated: “. . . the Forest Service acknowledges that resiliency treatments are unlikely to prevent future spruce beetle epidemics . . . across the entire Forest.26 If resiliency treatments in spruce forests will not prevent future spruce beetle epidemics, then the need to initiate an expensive, multi-year, intrusive and road intensive project is unsupported by the evidence. Recent research highlights the futility of the Forest Service’s proposed attempts at forest resiliency:

Given the influence of tree stress on the development and spread of bark beetle outbreaks it is highly unlikely that forest‐thinning projects would be able to mitigate the risk of future outbreaks. Moreover, thinning projects would not be expected to stop an outbreak once populations are at epidemic levels.27

The Taylor Project treatment “would focus on pockets of dead, diseased, damaged, or declining trees.”28 Standing dead trees have considerable ecological value for wildlife; e. g., they provide nesting and perching habitat for avian species. As is discussed below, lynx continue to use stands with dead spruce. Engelmann spruce snags remain standing for decades.

Recommendation – There is no need to pursue resiliency treatments in Engelmann spruce dominated stands as part of the Taylor Project. Group selection in spruce should be removed from the project.

23 Id. 24 Id. 25 EA at 20. 26 SBEADMR FEIS Appendix H-1 at 9. 27 Jason Sibold, PhD., Testimony before Congress, April 11, 2013, at 4. Attachment 1. 28 EA at 20.




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Fuel Treatments and Salvage Clearcuts Need Site-Specific Analysis The EA proposes 2,820 acres of fuel treatment, yet it lacks any site-specific planning or analysis for this project component. The Forest Service states: “Fuel treatments would include variety of tactics ranging from thinning to clearcutting.”29 Especially given that many of the fuel treatments are close to human infrastructure and communities, it stands that affected members of the public would have a keen desire to know the specifics of these extensive treatments. Research done by the Forest Service clearly shows that the most effective protection for structures is to treat an area of no more than 30 meters around each structure, as well as making the structure itself as least flammable as possible.30

Recommendation - The Forest Service needs to clearly define and substantiate its definition of WUI. While there are various definitions, some of these tend to be overly liberal, allowing for excessive acreage of treatment. The undersigned suggest that a much more limited WUI be used for this project, preferably a 100-foot treatment buffer surrounding structures. We ask that the project clarify its WUI definition to allow for more effective, and less intrusive, forest management. Areas that are much beyond 200-feet from a community or other infrastructure are not part of a WUI, and treatment to protect the infrastructure is not needed there.

The EA also contains a placeholder for potential future salvage clearcuts, stating: “This assessment does not identify specific sites for salvage clearcut. The prescription is intended as contingency in case bark beetle or wildfire mortality occurs. If applied early enough in a proactive fashion, additional mortality losses maybe contained.”31

Recommendation - A blanket exception to site-specific analysis of clearcuts possibly many years in the future should not be part of this decision. Should bark beetle or wildfire mortality occur to a significant extent, the Forest Service cannot rely on this the Taylor Park project (which is ostensibly focused on mistletoe treatment) to grandfather in post-disturbance clearcutting. A new analysis of the then-existing condition would be needed prior to authorization of more than minor salvage cutting.

Road Development and Use Associated with this Project is Excessive and Unnecessary Perhaps the most troubling aspect of this proposal is the extensive road system that would be constructed and utilized, particularly the development of up to 109 miles of new temporary roads to access treatment areas.32 This figure does not include the extensive skid trails and landings that would be required (which in the case of SBEADMR, have exceeded initial project estimates thus far). Given that this would occur in Taylor Park, currently the focus of community conversations and concern regarding illegal roads/trails and unsustainable motorized recreation impacts, the Forest Service must consider adjusting this project to significantly reduce the necessity for road and skid trail construction.

29 EA at 20. 30 See: Reducing the Wildland Fire Threat to Homes: Where and How Much?, Jack D. Cohen. In: USDA Forest

Service Gen.Tech.Rep. PSW-GTR-173. 1999. Attachment 2. 31 EA at 21. 32 EA at 37.




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The EA Fails to Consider the Road Network’s Impact on Watersheds Within the project area, two subwatersheds, Rocky Brook-Spring Creek and Taylor Park Reservoir, have a WCATT rank of “functioning at risk.” Within the Rocky Brook-Spring Creek subwatershed, the EA identifies 33.9 treatment acres, seven road acres, and 424 total affected acres. Within the Taylor Reservoir subwatershed, it identifies 91.6 treatment acres, 18.9 road acres, and 387 total affected acres.33 The project’s road network has the potential to further degrade these watersheds. The EA does not contain an analysis of connected disturbed area, thus it is not possible to tell if compliance with this part of the Watershed Conservation Practices Handbook would be achieved.34 The EA also does not state what the background level of soil erosion is, so we have no way to compare that to the amount of sediment likely to be produced under the proposed action. The proposed road system analysis does not include additional disturbance. Ground-based heavy equipment use would require construction and use of temporary roads, skid trails, and landings, which would be more disturbance in addition to the new roads. Nor does the EA disclose and consider the roads within and adjacent to the project area that stem from SBEADMR. The Decision for SBEADMR includes four commercial Primary Treatment Areas (PTAs) within the Taylor Park EA analysis area. These PTAs are “Bear Creek,” “Forest Hill,” “Wheelbarrow Gulch,” and “Matchless Mountain.” What about roads for these treatments? As far as we can tell the EA fails to disclose the potential for road construction in these areas, and they are not noted and are not part of the 109 mile calculation. Such a large road network has the capability of decreasing watershed health by delivering sediment to streams and other water bodies. Where both stream and road densities are high, the incidence of connections between roads and streams can also be expected to be high, resulting in more common and pronounced effects of roads on streams.35 Roads, skid trails, and other disturbed areas can provide the pathway for sediment delivery to waterbodies. Roads are typically the single largest source of elevated erosion in forested watersheds. Landing construction and use involves impacts to soils and vegetation that are as severe and persistent as those from roads, resulting in similar effects on watershed hydrology, erosion and sediment delivery.36 In one study undertaken in Idaho forests, researchers found that the longest travel distance of sediment from forest disturbances originated from a landing.37 Cumulative effects methods indicate that landings contribute to adverse watershed cumulative effects as persistently and significantly as roads.38

33 EA Table 9 at p. 40. 34 See FSH 2509.25, section 11.1. 35 Gucinski, M., J. Furniss, R. Ziemer, and M.H. Brookes. 2000. Forest Roads: A Synthesis of Scientific Information.

Gen. Tech. Rep. PNWGTR-509. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest

Research Station. 103 p. Available at: http://www.fs.fed.us/pnw/pubs/gtr509.pdf. 36 Rhodes, Jonathan J. The Watershed Impacts of Forest Treatments to Reduce Fuels and Modify Forest Behavior.

Pacific Rivers Council (February 2007), at 19. Attachment 3. (Citing Geppert, R.R., Lorenz, C.W., and Larson,

A.G., 1984. Cumulative Effects of Forest Practices on the Environment: A State of the Knowledge. Wash. For.

Practices Board Proj. No. 0130. WA Dept. of Natural Resources, Olympia, WA. See also Ketcheson, G. L. and

Megahan, W. F., 1996. Sediment production and downslope sediment transport from forest roads in granitic

watersheds, USFS INT-RP-486. USFS Intermountain Research Station, Ogden, UT.) 37 Id. at 17 (citing Ketcheson, G. L. and Megahan, W. F., 1996. Sediment production and downslope sediment

transport from forest roads in granitic watersheds, USFS INT-RP-486. USFS Intermountain Research Station,

Ogden, UT.) 38 Id. (citing Menning, K., Erman, D.C., Johnson, K.N., Sessions, J. 1996. Modeling aquatic and riparian systems,

assessing cumulative watershed effects and limiting watershed disturbance. Sierra Nevada Ecosystem Project Final

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Erosion on roads is especially high during the first year after construction.39 However, it remains dramatically elevated as long the roads exist, and even well after abandonment or decommissioning.40 Roads and landings essentially eliminate soil productivity for some time and reduce it for long periods thereafter. This is the case even with “temporary” roads and landings. Due to the persistence of their impacts, “temporary” landings and roads do not have temporary impacts. The negative effects of road and landing construction are large, enduring, and immediate, while recovery is relatively minor and protracted, even with obliteration, all of which belie any application of the term “temporary”. The Forest Service has conceded that the loss of soil productivity on temporary landings and roads is not reversible, because such areas never completely regain their productivity or function naturally even with remediation or abandonment.41

Recommendation - New road construction in Class II watersheds and those on the border between classes I and II should be prohibited outright. Overall, the project should be redesigned to require much less new road construction, even if such roads are deemed “temporary”. Further, any subsequently prepared NEPA document must disclose and analyze the potential cumulative and watershed impacts of road construction.

Road Impacts on Terrestrial Habitat and Wildlife are Unexamined in the EA Roads are one of the most pervasive impacts of human development on natural landscapes. Roads and trails impact wildlife through a number of mechanisms including: direct mortality, changes in movement and habitat use patterns, as well as indirect impacts including alteration of the adjacent habitat and interference with predatory/prey relationships. Some of these impacts result from the road itself, and some result from the uses on and around the roads (access). Ultimately, roads have been found to reduce the abundance and distribution of several forest species.42 The greatest impact or roads, by far, lies in the indirect effects of habitat fragmentation and avoidance by wildlife. Numerous studies document that elk avoid roads and do not use habitat adjacent to roads to its full potential. Hunted game species such as elk become more vulnerable from access allowed by roads and motorized trails resulting in a reduction in effective habitat among other impacts.43 These

Report to Congress, Addendum, pp. 33-52. Wildland Resources Center Report No. 39, University of California,

Davis.) 39 Id. (citing Rhodes, J.J., McCullough, D.A., and Espinosa Jr., F.A., 1994. A Coarse Screening Process for

Evaluation of the Effects of Land Management Activities on Salmon Spawning and Rearing Habitat in ESA

Consultations. CRITFC Tech. Rept. 94-4, Portland, OR.) 40 Id. (citing Potyondy, J.P., Cole, G.F., Megahan, W.F., 1991. A procedure for estimating sediment yields from

forested watersheds. Proceedings: Fifth Federal Interagency Sedimentation Conf., pp. 12-46 to 12-54, Federal

Energy Regulatory Comm., Washington, D.C.) 41 Id. (citing Bitterroot National Forest, 2001. FEIS for the Burned Area Recovery Project. BNF, Hamilton, MT.

And Rogue River-Siskiyou National Forest, 2003. Biscuit Fire Recovery Project DEIS, RSNF, Medford, OR.) 42 Fahrig, L., and T. Rytwinski. 2009. Effects of roads on animal abundance: an empirical review and

synthesis. Ecology and Society 14(1): 21. Available at: http://www.ecologyandsociety.org/vol14/iss1/art21/.

Attachment 4. 43 See Rowland, M.M., M.J. Wisdom, B.K. Johnson, and M.A. Penninger. 2005. Effects of roads on elk:

implications for management in forested ecosystems. Pages 42-52. IN: Wisdom, M.J., technical editor, The Starkey

Project: a Synthesis of Long-term Studies of Elk and Mule Deer. Reprinted from the 2004 Transactions of the North

American Wildlife and Natural Resources Conference, Alliance Communications Group, Lawrence, KS. Available

at https://www.fs.usda.gov/treesearch/pubs/24797. Attachment 5. See also Wisdom, M.J. 2007. Shift in Spatial

http://www.ecologyandsociety.org/vol14/iss1/art21/

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studies and many others indicate that the project area’s ability to retain elk habitat would be significantly compromised, yet the EA failed to take the necessary hard look to determine direct, indirect, and cumulative impacts to the local population.

Recommendation – Greatly reduce roads needed for the project. Avoid areas that have the highest quality elk habitat.

The Project Road Density Threshold for Wildlife is Likely Exceeded If the Forest Service is proposing to treat about 15,000 acres and build over 100 miles of temporary roads, that would be a road density of almost five miles per square mile. Granted, there may be road-free lands in between the treatment areas, but that’s still a sobering road density. When skid trails, SBEADMR roads, the current road system, and legal and illegal motorized routes are added, the density is stunning, and the road density in Taylor Park may exceed accepted thresholds for wildlife. The best available science shows that road density is one of the most important metrics of the ecological effects of roads on important watersheds, migratory corridors and other critical wildlife habitat, and other forest resources. It is well documented that beyond specific road density thresholds, certain species will be negatively affected, and some will be extirpated from the affected area. Forman and Hersperger (1996) found that in order to maintain a naturally functioning landscape with sustained populations of large mammals, road density must be below 0.6 km/km² (1.0 mi/mi²).44 There is a direct correlation between road density and various markers for species abundance and viability, and adopting road density thresholds is one of the most effective strategies for achieving an ecologically sustainable road system. Accordingly, Forest Service directives identify road density as one of the “[k]ey ecosystem characteristics [that] provide a mechanism for assessing status of ecosystem conditions regarding ecological integrity.”45 Because the ecological impacts associated with roads and motorized travel are not limited to open system roads, density thresholds for the Taylor Park project (and others) should apply to all motorized forest routes, including closed, non-system, and temporary roads, and motorized trails.

Recommendation – Again, the project needs to be redesigned to require much less road use. The EA should describe motorized route densities across the project area and identify where they exceed accepted scientific thresholds for aquatic and terrestrial integrity.

The EA Fails to Consider the Importance of Connected Habitat for Climate Change Adaptation

Distribution of Elk Away from Trails Used by All-Terrain Vehicles. Report 1, May 2007, USDA Forest Service,

Pacific Northwest Research Station, La Grande, OR. Available at

https://www.fs.fed.us/pnw/pubs/journals/pnw_2018_wisdom001.pdf. 44 Forman, R. T. T., and A.M. Hersperger. 1996. Road ecology and road density in different landscapes, with

international planning and mitigation solutions. Pages 1–22. IN: G. L. Evink, P. Garrett, D. Zeigler, and J. Berry

(eds.), Trends in Addressing Transportation Related Wildlife Mortality. No. FLER- 58-96, Florida Department of

Transportation, Tallahassee, Florida. Available at

file:///C:/Users/Matt/Downloads/Road_Ecology_and_Road_Density_in_Different_Landsca.pdf. Attachment 6. 45 FSH 1909.12, ch. 10, § 12.13.

https://www.fs.fed.us/pnw/pubs/journals/pnw_2018_wisdom001.pdf




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The EA states: “We believe that the proposed action may alleviate some of these potential undesirable long-term effects [of climate change] by enhancing the resiliency of forest stands.”46 At the same time though, climate change generally intensifies the adverse impacts associated with roads. In particular, the warming climate is expected to lead to more extreme weather events, resulting in increased flood severity, more frequent landslides, altered hydrographs, and changes in erosion and sedimentation rates and delivery processes. As a warming climate alters species distribution and forces shifts in wildlife migration, landscape connectivity is increasingly critical to species survival and the ability of ecosystems to adapt. Yet one of the most significant impacts of the transportation system within the forest is to fragment wildlife habitat (terrestrial and aquatic), thereby altering species distribution, interfering with life functions such as feeding, breeding, and nesting, and resulting in loss of biodiversity.

Recommendation – Reduce the road network and extent of treatment locations to conserve connected habitat. Analyze and disclose the direct, indirect and cumulative impacts of climate change, and the interaction of those impacts with road impacts.

What is the Cost of the Road Development, Maintenance, Decommissioning, and Closure? We thank the Forest Service for committing on paper to decommissioning roads that would be developed for this project. The HFRA states that “The Secretary shall decommission any temporary road constructed under a project under this section not later than 3 years after the date on which the project is completed.”47 And the EA states: “The Forest Service or contractor would physically close temporary roads with barriers during periods of inactivity and at final project closeout.”48 But closing with barriers is not the same as obliterating, as the roads still physically exist, and determined motor vehicle users can evade, or even destroy, closures, in effect reopening some roads. During the project, and for years after completion of the project, the temporary roads will continue to have very real impacts on the landscape. For example, temporary roads will continue to allow for harassment of wildlife, littering, fires, invasive plant distribution, and negative impacts to aquatic and riparian habitat, as well as the fish that depend on that habitat. The EA provides no disclosure or analysis of how much it will cost the Forest Service to develop, maintain, decommission, and close the massive road network that would be utilized for this project. Taylor Park is a particularly troublesome landscape to develop an extensive road network and decommission that within a set timeframe. Road maintenance, decommissioning and monitoring require significant amounts of time, expertise, money and manpower. The GMUG manages over 3,600 miles of roads. Yet the GMUG’s average road maintenance budget covers only a fraction of miles of roads that are due for maintenance, and at the same time, the GMUG expects that road maintenance

46 EA at 43. 47 Healthy Forest Restoration Act, 16 USC 6591)(c)(3)(B), as added via section 8204 of the Agricultural Act of

2014. Though EA p. 15 states that “w]e would not develop any new permanent roads for this project”, a design

feature states “Following use for harvest and treatment implementation, both temporary AND designed roads will be

decommissioned…” Measure TSHR-2, EA at 96. If new system roads will not be built for the project, this measure

should be modified to state that existing designed roads may be decommissioned. 48 EA at 37.




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budgets will decline.49 Although the GMUG has not disclosed what the current total is for deferred maintenance, its Travel Analysis Report (TAR) proposed that in 2015 the Forest Service would only be able to maintain approximately 18 percent of total road miles.50 The TAR discussed that the Forest Service was seeking to decrease maintenance funds, and also discussed how the Forest Service was seeking to decrease maintenance costs. The Forest Service’s assessment of maintenance costs for ML 2 roads is $135,000 annually and these roads at most receive maintenance every five to eight years.51 Over a decade ago the 2005 GMUG Road Analysis Report found that the road system was not sustainable.52 This report documented that as of July 2005, the total deferred maintenance backlog just on ML 3-5 roads was over $2 million.53 The report also documented that while total deferred maintenance needs on the GMUG continued to grow annually, the budget continued to shrink. This reduction in maintenance and funding reveals a systemic pattern of road neglect, while the Taylor project (and SBEADMR) proposes significant road construction and use by heavy logging trucks, adding to the need for maintenance in an already overburdened system.

Recommendation – Road construction should be kept to the absolute minimum necessary to

accomplish project goals, i. e., much, much less than the 109 miles proposed. HCCA asks that

this be a top priority of the project. We are committed to help the agency with designing a

project to require fewer miles of new roads, and with decommissioning of these routes through

public stewardship collaboration if the Forest Service is interested in such an opportunity.

Recommendation - Please ensure that all temporary roads developed are fully decommissioned and obliterated within three years of the completion of the project. If money is not expected to be available to decommission roads, do not build them in the first place. The portions of the project using roads, e. g., for hauling logs, that would need future maintenance but for which money will likely not be available should not be approved.

The Project is Inconsistent with the Gunnison Travel Management Plan The identified proposed road network in the project proposal map is at odds with the Gunnison TMP and the extensive public process that shaped that document. If roads were scheduled for closure in the TMP, then they should not be utilized for this project. In addition, if the agency could not accomplish decommissioning of these routes in the almost 10 years since the finalization of the TMP, how is it expected to accomplish the Taylor project’s lofty decommissioning goals? The Gunnison Ranger District stated in its 2012 TMP implementation memo that “as a general policy, any user-created (non-system) routes that exist on the ground not shown or listed in this 2010 decision

49 Grand Mesa, Uncompahgre and Gunnison National Forests, Final Travel Analysis Report, Executive Summary

(June 1, 2015), at 6. Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3841509.pdf. 50 50 U.S. Forest Service, Grand Mesa, Uncompahgre and Gunnison National Forests, Final Travel Analysis Report

(June 1, 2015), at D-1. Available at http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3841524.pdf. 51 Id. 52 U.S. Dept. of Agriculture, Grand Mesa, Uncompahgre and Gunnison National Forests, Road Analysis Report

(2005), at 2-15-17 and 3-25. 53 Id. at 2-15-16.

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3841509.pdf

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3841524.pdf




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are also to be decommissioned.”54 Resurrecting routes that are not identified in the TMP, or were scheduled for closure in the TMP, flies in the face of that document’s reasoning and analysis.

“One of the major objectives for completing travel analysis and developing the Preferred Alternative was to better define a manageable and sustainable transportation system on NFS lands. This Preferred Alternative considers the existing and expected funding, grants, and other volunteer contributions related to road and trail maintenance in its assessment of scope and sustainability of the transportation system. The travel analysis done by the Forest Service interdisciplinary team also used defined criteria to develop a sustainable and desirable transportation network. Recreational objectives as well as safety, route integrity, and sustainability were also considered in the development of the Preferred Alternative. The Preferred Alternative defines a transportation system of open roads and trails, administrative roads, and non-motorized trails that meet the management objectives for transportation, access, public safety, and recreational opportunity. The Preferred Alternative also defines what would be a minimum transportation system. I find that the Preferred Alternative and this decision best balance the needs associated with multiple-use management, and which is physically sustainable.”

Recommendation – Modify the project to eliminate use of roads slated for decommissioning/closure in the TMP.

Public Use of the Project Road Network is Possible, Adding to a Growing Problem in Taylor Park We also are concerned that implementation of the Taylor Project will embolden the public to use unauthorized routes in this area. Use of unauthorized routes is already a significant problem on the GMUG, and particularly in Taylor Park. Legitimatizing the use of unauthorized routes to facilitate implementation of the Taylor project will only embolden a minority of the public to use these routes, further complicating and stressing the maintenance and decommissioning processes.

Recommendation – Any new road development in Taylor Park needs to be coupled with increased enforcement.

What is the Estimated Truck Traffic and Impacts? The EA provides no estimate of the number of haul trucks that would be required for this project, the impacts of likely substantial heavy truck traffic, and the relationship between that use and current uses in the Taylor Park area (and beyond). Hauling down Taylor Canyon could delay or interfere with recreational traffic, and decrease the overall safety of traffic on this road.

Recommendation – Provide an estimate of the number of truck trips by time of day and season, and propose and adopt mitigation measures to limit traffic impacts.

Cutting Would be Allowed Too Close to Water Bodies

54 USDA, Decision Memo, 2012 Travel Management Implementation, U.S. Forest Service, Gunnison Ranger

District, Gunnison & Saguache Counties, Colorado.




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We are troubled by the project design feature that would in some cases allow treatment and vehicle use as close as 25 feet from water bodies.55 Cutting and heavy equipment use this close to intermittent streams, reservoirs, and ponds could adversely affect water quality.

Recommendation – We request a minimum 100 foot buffer around all water bodies, where no use of heavy equipment would be allowed. Trees that are true safety hazards within the buffers could be felled by hand crews, then winched out of the area.

The Project Would Adversely Affect Big Game, Lynx, and Other Wildlife Proposed treatment areas and the road infrastructure needed to access those areas overlap with important wildlife habitat. Elk, mule deer, bighorn sheep, moose, Canada lynx, and other iconic western Colorado animals stand to be significantly impacted by this project. The EA Fails to Consider Impacts to Big Game Habitat Colorado Parks and Wildlife’s online big game mapping tool56 indicates that the project overlaps with the following big game habitats:

Bighorn sheep Winter Concentration Areas and Summer Range57 (the EA states “No suitable high mountain habitat is present in the treatment areas”58);

Elk Migration Patterns, Summer Concentration Area, and Summer Range59

Moose Concentration Area, Summer Range, and Winter60 (there is no analysis of impacts to moose in the EA);

Mule Deer Migration Patterns and Summer Range.61 The Forest Service must thoroughly consider the project’s impact on these species, their habitat, and the recreation and economics (especially for big game hunting) associated with them. Removing trees, even dead ones, will generally reduce hiding cover for deer and elk. Sizable blocks of undisturbed, moderately dense trees form very important security cover for these species. Logging would fragment these blocks, reducing or eliminating the hiding cover and security for deer and elk. Constructing roads would allow deeper penetration of motor vehicles into deer and elk habitat, increasing the disturbance to the animals. While roads used for the project may be closed to the public, closures are often removed or circumvented by hunters and recreationists and others determined to drive further into an area. Thus the presence of new roads could lead to increased hunting pressure and decreased habitat effectiveness, possibly driving deer and elk out of the area, at least during project implementation. The Forest Plan requires that a minimum habitat effectiveness of 40 percent be maintained in “units dominated by forested ecosystems”.62

55Design feature WQSP-2i, EA at 99. 56 Available at https://ndismaps.nrel.colostate.edu/index.html?app=HuntingAtlas. 57 See Attachments 7 and 8. 58 At 120. 59 See Attachment 9. 60 See Attachments 10 and 11. 61 See Attachment 12. 62 Plan at III-29.

https://ndismaps.nrel.colostate.edu/index.html?app=HuntingAtlas




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Recommendation – Given the importance of deer and elk, the agency should show how the design and implementation of the project would ensure that this standard will be met. It must do the same for the standard on Plan pp. III-28 and III-29 requiring retention of 60 percent hiding cover along arterial and collector roads and around 60 percent of the perimeter of all natural and created openings.

The Project Would Impact Lynx Habitat It is notable that the project area is very close to an area of high lynx concentration.63 The Research Report stated that “[a] lynx-established core use area has developed in the Taylor Park and Collegiate Peak area . . . .” It is likely that the easternmost and northeasternmost proposed treatment units are very close to this core area. Lynx may disperse through the project area, even if it does not have the highest quality habitat. Indeed, resident lynx, including two den sites, exist in two of the five lynx analysis units in the project area.64 Dwarf mistletoe produces witches brooms, which are said to form fire ladders, i. e., allowing surface fires to climb into the crowns of trees.65 If so, these brooms may also increase horizontal cover and provide habitat for snowshoe hare, lynx’ favorite prey. The proposed treatment would degrade and eliminate lynx habitat. Dwarf mistletoe strip cuts and clearcuts, overstory removal, and group selection in spruce would convert the treated areas into unsuitable habitat. Shelterwood seed cuts would at least reduce the quality of, if not destroy, lynx habitat by reducing density of trees and the dense horizontal cover desired by snowshoe hare, and by removing down dead wood and standing dead (which is future down dead wood that could form future denning habitat). Logging is likely to damage and kill understory trees via felling of larger trees, and skidding them to landings. Spruce-fir forests are typically multi-aged, i. e., they have younger trees beneath an older overstory, a structure that forms good lynx habitat. Recent research on the adjacent Rio Grande National Forest indicates that lynx still use habitat where the spruce overstory has been killed by bark beetles.66 Spruce trees killed by bark beetles often remain standing for decades. When they do fall down, they form denning habitat. Any understory in these stands remains after beetle-kill, providing the dense horizontal cover needed by snowshoe hare and

63 See figure 4 in: General Location of Lynx (Lynx Canadensis) Reintroduced into Southwestern Colorado February

4, 1999 to February 1, 2005. Tanya Shenk, Colorado Division of Wildlife (now the Division of Parks and Wildlife),

April, 2005. See also Figure 3 in: Areas Of High Habitat Use From 1999‐2010 For Radio‐Collared Canada

Lynx Reintroduced To Colorado, David M. Theobald and Tanya M. Shenk, Colorado Division of Wildlife, March,

2011. And finally, see p. 28 of Wildlife Research Report, Post-Release Monitoring of Lynx Reintroduced to

Colorado, July 1, 2006 – June 30, 2007, T. M. Shenk, Colorado Division of Wildlife. 64 Biological Assessment (BA) at 14. 65 EA at 6, BA at 10. 66 Squires, John R., Joseph Holbrook, Lucretia Olson, Jake Ivan, Rick Lawrence, and Randy Ghormley, 2017.

Response of Canada Lynx and Snowshoe Hares to Spruce-Beetle Tree Mortality and Wildfire in Spruce-fir Forests

of Southern Colorado. Progress Report, 2016. Attachment 13.




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lynx. Another recent study showed that hares and lynx avoided stands that had been salvaged logged after bark beetle attack.67 Also:

Precommercial thinning has been shown to reduce hare numbers by as much as 2- and 3-fold … due to reduced densities of sapling and shrub stems and decreased availability of browse.68

The large mileage of roads needed for the project, including existing roads reopened, would, at least in the short-term, fragment habitat for lynx. As discussed above, these roads may not be successfully closed or decommissioned after project completion, meaning they will get used by motor vehicles, extending the duration of habitat fragmentation. Though lynx are believed to not avoid use of habitat along roads with low usage, they do appear to avoid use of denning habitat in these areas.69 Also roads facilitate human access, especially during hunting season, which could result in higher lynx mortality. Overall, the proposed treatment and the roads needed for it will reduce habitat connectivity in the project area. The BA at 25 concludes that the proposed project is not likely to adversely affect lynx. Part of the justification for this conclusion is that only 131 acres of suitable habitat would be converted to the stand initiation structural stage (SISS). Based on the proposed treatment, this cannot be correct. It could only be true if almost all of the existing lodgepole pine stands are considered unsuitable habitat or non-habitat, as a considerable amount of lodgepole pine-dominated stands would be clearcut or strip cut. But mature lodgepole pine is lynx habitat, as it can be used for travel, migration, dispersal, etc. to areas of higher quality habitat. But even if the existing lodgepole stands are unsuitable, 741 acres of spruce would be cut with group selection, moving those treated acres into the SISS phase.

Recommendation – Delete the units dominated by spruce-fir. They have the best lynx habitat in the project area, and there is no reason to cut them, except for hazard trees near infrastructure. Reduce the size and number of the dwarf mistletoe strip cuts and clearcuts. As discussed above, they are much larger than needed to address mistletoe, and cutting them would increase the fragmentation of habitat. Correctly calculate the amount of suitable habitat that would be converted to SISS, and adjust the finding of “not likely to adversely affect” if necessary.

The Project Would Likely Negatively Impact Hunting in Taylor Park The Taylor Project stands to compromise hunters pursuing elk, mule deer, and other species in and around Taylor Park. Despite this, this is nothing in the EA disclosing or analyzing the impacts that 15,000

67 Thomas, Julie P., Mary L. Reid, Robert M.R. Barkley, and Thomas S. Jung, 2019. Salvage Logging After An

Insect Outbreak Reduces Occupancy By Snowshoe Hares (Lepus Americanus) And Their Primary Predators. Global

Ecology and Conservation 17 (2019). Attachment 14. 68 Interagency Lynx Biology Team. 2013. Canada Lynx Conservation Assessment and Strategy. 3rd edition. USDA

Forest Service, USDI Fish and Wildlife Service, USDI Bureau of Land Management, and USDI National Park

Service. Forest Service Publication R1-13-19, Missoula, MT. 128 pp. 69 BA at 24.




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acres of logging, 109 miles of road development, and the expected use would have on this critical economic and cultural institution.

Recommendation – Do not implement the project during big game hunting season. In the alternative, undertake a staggered approach of treatments that concentrate in one area at a time, rather than here and there across the landscape, so as not to disturb the entire landscape during hunting season.

The Project Would Adversely Affect Species Needing Continuously Forested Habitat and Other Species The proposed treatment would remove or thin forest canopy throughout the project area. This would degrade, or in some cases, eliminate habitat for species that include, but are not limited to: marten, goshawk, boreal owl, and olive-sided flycatcher. Goshawk are especially intolerant of humans near the nest during the nesting season, so there must be a considerable no-disturbance buffer around them during the nesting season. Boreal toads could be crushed or their winter hibernation areas destroyed by the use of heavy equipment.

Recommendation – Before any treatment occurs, thoroughly survey the proposed treatment units and access routes for these species. Modify or delete units to retain nesting and foraging habitat. For boreal toads, stay out of areas with off-channel water bodies, which are or could be toad habitat. Overall, reduce the size of clearcut openings and acreage cut to limit the adverse impacts to wildlife.

Slash Disposal is Excessive The slash piles to be burned as part of this project are excessively high: under the Design Features proposed for the project, piles to be burned would have to be at least 12 feet high, and could be up to 50 feet by 50 feet in ground coverage.70 There is also no restriction on the size of material to be piled. Thus, burning piles would result in long-lasting fires that would likely cause soil sterilization and loss of nutrients. This would compromise regeneration and invite weed establishment and propagation.

Recommendation – Consider other slash disposal methods. Where piling and burning is used, reduce the size of the piles size of material in them. Some slash must be retained to protect and renew soils. If slash is piled, it should be limited to hand piles composed of material three inches or less in diameter and no more than about four feet high. Burning should not occur in areas with weeds, like cheatgrass (Bromus tectorum), that proliferate and dominate after fires. Design Feature IW-1 (EA at 84) should be mandatory. If slash is chipped, depth should be limited to about two inches and cover not more than about 15 percent of a unit. Chips would prevent vegetation from sprouting, and could consume a considerable amount of soil nitrogen during decomposition.

Protect Scenic Quality The EA fails to examine the scenic impacts of the project. At the public meeting in 2018 in Tincup, this

was one of the concerns expressed by nearby property owners. The presence of stumps, landings, skid

roads, slash piles, and other artifacts of logging operations are not a welcome sight for most residents of

and visitors to scenic areas such as Taylor Park. Proposed treatment would reduce the visual quality of

70 Design feature SP-4, EA at 94.




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treated areas. Clearcut and strip-cut logging and associated activities would move the visual condition to

modification, maximum modification, or possibly even unacceptable modification. This might not

comply with the visual quality objectives established by the Forest Plan.

Recommendation - Site-specific analysis should identify the highest quality scenic views in the area and design any treatment to maintain them to the maximum extent possible, consistent with safety. Other areas where natural scenery is very important to users should also be identified and protected. The analysis must show how the visual quality objectives for the project area will be met.

The EA Fails to Take a Hard Look at Cumulative Impacts from Other Projects on the GMUG While each resource write-up in the EA has a cumulative impacts section, they are rather general,

especially the one for wildlife. Recreational impacts are likely to interact cumulatively in and around the

Taylor Park area with this project, yet the EA provides little analysis of this important issue in the context

of affected resource values. Nor does the EA adequately address the cumulative impacts of this project

in conjunction with SBEADMR.

Recommendation - The EA must fully disclose cumulative impacts of the proposed project and other projects, such as SBEADMR. Cumulative impacts analysis must include detailed information and a clear analysis of effects on resources, not just a description of actions.

The Adaptive Management Scheme Must Include Triggers for Initiating Changes in Management One way to provide assurances to the public that ecosystems and resources would be sufficiently protected from harm is through the use of clear and specific triggers in the project’s proposed adaptive management. Triggers are thresholds indicating a possible need for change in management, or at least evaluation of existing management. In the report Decision Making Triggers in Adaptive Management the authors state that triggers are, “. . . predetermined decision points that are built into the decisionmaking framework at the outset (i.e., if this, then what).”71 The report identifies various cases where triggers and adaptive management have been used in timber sales and in other federal plans and projects. One of the primary lessons described is: “If they (the agency) acknowledge uncertainty, they must show that they have a clear monitoring and mitigation strategy that is within their power to implement if unexpected or unacceptable effects are detected.”72 The Report concludes with five recommendations for the effective use of triggers. First, more effort should be made to ensure that adaptive management includes a clear feedback loop and is conducted in a way that allows for learning. Second, monitoring programs and triggered mitigation measures should be enforceable and include pre-specified timelines. Third, agencies must demonstrate that they will not violate substantive legal requirements in order to survive judicial review. Fourth, the responsibilities for designing, conducting, interpreting, and funding monitoring should be made explicit and up front. And

71 Martin Nie and Courtney Schultz, Report to USDA Pacific Northwest Research Station, NEPA for the 21st

Centry, Decision Making Triggers in Adaptive Management (2011). Attachment 15. 72 Id. at 458.




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finally, decisions about trigger points and trigger mechanisms should be clearly explained and be made transparently.73

Recommendation – Triggers that are tied to enforceable actions in the anticipated Adaptive Management Group (AMG) process are crucial to provide the assurances the public and stakeholders require that unforeseen adverse impacts from implementation can be corrected. These triggers and suggested adaptive management actions should be developed by a team composed of Forest Service IDT members and the various stakeholders who have participated substantively thus far in the formation of the AMG, and then circulated to the public for comment before inclusion in the Final EA.

Conclusion The following statement in the EA sums up the agency’s approach: “In total, this legacy of forestry actions has not only contributed to disease control efforts but also contributed to age-class diversity which increases forest resiliency to landscape level stressors, supplied fuel reduction in the wildland-urban interface and generally supported ecosystem health.”74 We agree that a legacy of actions has contributed to various efforts, but not to actual disease control. Taylor Park is host to mistletoe, a natural tree parasite, which will likely persist long into the future. Extensive management of the area’s vegetation by the Forest Service has done little to control its pervasiveness on the landscape. The proposed project would not change this, but it would continue to negatively affect the ecosystem health of Taylor Park. HCCA and the undersigned request that you considerably reduce the size of this project, at a minimum in the areas identified at the beginning of our comments, and address the issues and questions we have raised. Thank you for your consideration.

Matt Reed Public Lands Director High Country Conservation Advocates PO Box 1066 Crested Butte, CO 81224 303.505.9917 [email protected] /for/ Rocky Smith, Forest Management Analyst Edward B. (Ted) Zukoski 1030 Pearl St. #9 Senior Attorney Denver, CO 80203 Center for Biological Diversity (303) 839-5900 1536 Wynkoop St., Suite 421 [email protected] Denver, CO 80202

73 Id. at 518-521. 74 EA at 7.

mailto:[email protected]





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(303) 641-3149 [email protected] Christine Canaly Robyn Cascade Director Leader, Northern San Juan Chapter San Luis Valley Ecosystem Council Great Old Broads for Wilderness P.O. Box 223 C/o PO Box 2924 Alamosa, CO 81101 Durango, CO 81302 (719) 589-1518 (970) 385-9577 [email protected] [email protected] Rosalind McClellan Patrick Dooling Project Coordinator Executive Director Rocky Mountain Recreation and Wildlife Initiative Western Slope Conservation Center 1567 Twin Sisters Rd. PO Box 1612 Nederland, CO 80466 Paonia, CO 81428 (720) 635-7799 (970) 527-5307 [email protected] [email protected]






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