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APPENDIX A: ISSUES RAISED DURING SCOPING

Scoping Comment IDT discussion/response Issue/Theme

Concern over effect/ impacts of a potential increase in use

by commercial, personal, Native American berry picker

impacts – should be analyzed as direct effects because they

are reasonably foreseeable. How will they be monitored

and enforced? What is plan for disposal of waste and

garbage?

Increased use is not a foregone conclusion, but that

potential will be addressed and the resource impacts

will be analyzed in the EA. Monitoring and

responding to changes in human use will likely be

included within project design criteria.

Increased use by

pickers;

Monitoring

Concern about impacts to wildlife – while some would

benefit, others could be negatively impacts; esp. migratory

birds. Migratory bird survey should be done so that site-

specific impacts and design criteria can be assigned, and to

provide baseline for future monitoring. Question about

potential effects to pine marten and other MIS species –

EA should consider pros and cons of project for these

species.

The negative and positive impacts to wildlife and

MIS will be analyzed in the EA. Monitoring

requirements will likely be part of design criteria.

Wildlife effects;

Monitoring

Question about consistency of project with Timber

Production MAC – if the goal is to create/maintain early

seral, isn’t this in direct conflict with producing timber

over long term?

The goal of Timber Production MAC land is to

“Optimize timber production, the utilization of wood

fiber, and other commodities in a manner which

assures the future productivity of the land.” Further,

this MAC is described as, “Portions of the Forest

which are generally suitable for commodity

production. They are primarily timber producing

lands but also include areas with such market values

as minerals, energy, and forage for domestic

livestock grazing. Some lands not suitable for timber

management may be included in these areas.”

Berrypicking is specifically listed as a compatible

and appropriate activity on this MAC.

Treatment/

prescription;

forest plan

consistency

Make a better case for Purpose and Need; cites The IDT discussed fire and land use history at length. Use of fire;

107

Scoping Comment IDT discussion/response Issue/Theme

archaeological and historical sources that Native

Americans burned up and down the Cascade Crest

beginning ~3500 years ago, although population levels and

climate were different. A century of fire suppression has

resulted in forests that do not reflect “historic conditions”;

significant degree of “landscape management” was done

prior to 1900 before Native American numbers dropped.

Reference to historic use of fire by Native Americans in FL

and GA.

The fire history will be described in terms of what we

know and don’t know about the “natural” and human

history and interactions with fire and ecosystems on

the landscape. The reference to FL and GA is not

appropriate to apply to the western side of the

Cascades, which has a natural fire return interval of

hundreds of years. The purpose and need for the

project will focus more on achieving a desired

condition rather than a historic reference point.

Support for

burning; Current

vs. historic

conditions

Concern about economic and wildlife impacts of dwindling

huckleberries as habitat for large ungulates and income for

pickers; decline of this habitat has been to the detriment to

overall forest health and increase of risk of devastating

wildfires. Asserts that because there is a potential for gray

wolf to expand its range to southern Cascades, there is a

clear need for ungulate habitat.

Direct, indirect, and cumulative effects on wildlife,

economics, and other resources will be evaluated for

the proposed action, as well as the consequences of

not taking any action. A reduced number of human

ignitions over the last century is not likely to increase

fire hazard in the ecosystems present in the project

area, which naturally experience long fire return

intervals and high severity fire effects.

Ecosystem and

human effects;

wildlife

Concerned and disappointed that canopy retention may be

as much as 30% in some units; asserts that this conflicts

with re-creating historic conditions.

The treatment prescription proposed is based on the

best available science about huckleberry restoration

in this region. The 15-30% retention range is

intended to provide more open conditions to

stimulate huckleberry production, while also

maintaining some frost protection and structural

diversity. No sources were cited in commenter’s

letter. The team will further investigate alternative

prescriptions to achieve restoration objectives.

Treatment/

prescription

In general supportive of huckleberry production and

recognizes benefits to recreation and wildlife. Cultural

importance of huckleberries as “first foods.”

The historic and current importance of huckleberries

to humans and wildlife will be emphasized and better

developed in the Purpose and Need.

Cultural;

Wildlife

Cites other projects with similar intent; different logging

techniques used; support for including log skidding over

snow as required for the thinning part of this project

Logging over a 3-4 foot snowpack will remain in

proposed action as a desired, but not required method

of implementing the harvest treatments. The IDT

Logging impacts

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Scoping Comment IDT discussion/response Issue/Theme

agreed that the window of opportunity to accomplish

this work would simply be too narrow given the

logistics and access to the area for commercial

equipment. Nevertheless, project design criteria

would be developed to minimize the disturbance of

harvest operations to huckleberries and other

resources.

Concern about current road access and maintenance needs -

how it will impact berry picking areas. Is district planning

to invest in this area? Treatments should be near roads.

Access considerations should include 1) certain roads to be

closed or decommissioned that access picking areas should

be treated in a way that provides safe walking surface; 2)

the needs of the elderly and individuals with limited

mobility; 3) designating certain areas for American Indian

picking only; 4) limit commercial use to only certain areas

The roads to and around the project area currently

meet the standard for their designated Level 2 status.

Roads needed for logging access and hauling may be

rehabilitated where necessary to implement the

project. Two locations near but outside the project

area have been identified for restoration to culverts

and/or erosion damage. In previous discussions with

partner group and tribe leading up to this project and

the Cowlitz Huckleberry Enhancement project, the

Cowlitz Tribe indicated they did not want additional

enhancements to roads or to increase access in order

to maintain the remote and special character of the

area. A decision to restrict commercial picking could

be a later decision at the District Ranger’s discretion,

based on monitoring information and other

considerations. The Cowlitz Tribe expressed that they

did not want to exclude any users from picking in the

area with this project.

Roads/Access;

Management of

human use

How much and where are huckleberries declining

throughout the district? District should not favor single

species management over ecosystem management.

Concern that project is focused on thinning older naturally

regenerated stands over plantations; need to consider

effects to wildlife like spotted owl and migratory birds;

supports a proposed action incorporating snag and down

The current status and decline of huckleberries on the

District is being evaluated as part of this process.

Avoiding single-species management is certainly a

consideration as we further develop the proposed

action. Although huckleberries are the species

identified for enhancement in the purpose and need,

treatments will affect the entire ecosystems of which

Wildlife effects;

Current vs.

historic

conditions

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Scoping Comment IDT discussion/response Issue/Theme

wood, skips and gaps, retain minor species as ways to

mitigate impacts

huckleberry shrubs are part and increase

opportunities to uphold traditional cultural practices.

Treatments emphasize restoration to early seral

stages of development in which huckleberries thrive.

The project area includes stands where the aim is to

maintain current production and stands where the aim

is enhance current production levels. The size and

arrangement of treatment units on the landscape, in

addition to the inclusion of “skips” and other features

to maintain structural complexity, are being

considered for inclusion in the proposed action.

There is only a very limited part of the project where

there are (plantation-type) stands that were not

naturally regenerated following the Greenhorn fire.

There are really no alternative stands that could be

treated which have huckleberry plants.

What is the District’s maintenance plan if it intends for

area to have huckleberries into the future? How will it be

monitored? FS should monitor berry production, invasive

weeds, recreation impacts, and impacts to wildlife species;

also monitor difference in response between treatment

types. Concern about mapping overlap with thinning and

underburn in same area.

Long-term maintenance in the form of repeat

prescribed burns or additional timber harvest will

likely not be covered by this EA. The analysis would

become unduly time consuming and difficult given

uncertainty about long-term priorities and available

resources. Future treatments and monitoring

priorities would need to be evaluated on a case-by-

case basis. Underburning is only proposed where

inaccessible to commercial harvest equipment

Future

management/

maintenance;

Monitoring;

clarification about

proposed action

What is meant by huckleberry restoration? Is this a short-

term or long-term goal? Project as described sounds like a

short-term fix. Historic berry fields were developed by

stand-replacing fires or clearcutting and broadcast burning

and persisted for long periods of time, up to 60 years until

overtopping trees suppressed berry plants.

Long-term maintenance in the form of repeat

prescribed burns or additional timber harvest will not

be covered by this EA. The analysis would become

unduly time consuming and difficult given

uncertainty about long-term priorities and available

resources. Future treatments would need to be

Future

management/

maintenance

110

Scoping Comment IDT discussion/response Issue/Theme

evaluated on a case-by-case basis. That being said,

the benefits of thinning and/or prescribed burning

could persist for 20 years or more before the

huckleberries would be suppressed again.

Project is too conservative in reducing overstory which will

limit effectiveness in sustaining berry production

The treatment prescription proposed is based on the

best available science about huckleberry restoration

in this region. Commenter did not cite a source for

this assertion.

Treatment/

prescription

Project needs to provide reasonable access to public;

picking area should be near roads; areas on steep slopes or

greater than 400 yds will not be used by pickers enough to

justify expense

The proposed action would maintain access for the

public to benefit from the increased huckleberry

production. Areas which are less accessible to

humans are proposed for restoration to benefit

wildlife, but the emphasis for this project is to benefit

humans. Funding for implementation of projects is

always uncertain, so various options for

accomplishing restoration outside of easily accessed

areas will be explored.

Roads/Access;

Treatment/

prescription

Stand-replacing fire should be main method of huckleberry

restoration, through clear cutting and broadcast burning;

restoration areas could be in narrow strips along road to

maximize public access

The treatment prescription proposed is based on the

best available science about huckleberry restoration

in this region. Commenter did not cite any references

for this assertion.

Treatment/

prescription

Project should be funded through commercial thinning

using retained receipts (Stewardship process) to complete

restoration project

Funding for implementation of projects is always

uncertain, so various options for accomplishing this

work will be explored.

Implementation

Using heavy-handed management is best way to promote

huckleberry restoration. Overly conservative management

will not result in improvements to huckleberry production.

The treatment prescription proposed is based on the

best available science about huckleberry restoration

in this region. No sources were cited to support this

assertion.

Treatment/

prescription

Huckleberries respond best to massive disturbance both to

establish new plants and stimulate old. Burning to ground

level promotes re-growth of productive plants and major

berry production over long periods of time.

The treatment prescription proposed is based on the

best available science about huckleberry restoration

in this region. No sources were cited by commenter.

Current literature suggests that damage to

Treatment/

prescription

111

Scoping Comment IDT discussion/response Issue/Theme

huckleberry rhizomes, caused by prolonged soil

heating and ground disturbance, is detrimental to

huckleberry restoration. While huckleberries may

return or persist over the 20 years following

treatment if conditions are favorable, site conditions

may also be compromised and more favorable for

other species. Overstory removal with partial plant

pruning is therefore the proposed treatment and

preferred restoration method to limit damage to

rhizomes and ensure sustained huckleberry presence

on the site.

Improvement of huckleberry production and reduction of

canopy cover will benefit many wildlife species with

browse and berries. Treatment methods appear to minimize

disturbance to both wildlife and vegetation communities

The effects of proposed treatments will be analyzed

in the EA.

Treatment/

prescription

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APPENDIX B: PROJECT DESIGN AND MITIGATION MEASURES

Fire/Burning

1. Emissions from any burning will be regulated through compliance with the Washington

Department of Natural Resources Smoke Management Plan, which meets the

requirements of the Washington Clean Air Act (RCW 70.94), Forest Protection Laws

(RCW 76.04), and the United States Clear Air Act (42 USC §7401 et seq.).

2. Activities that include prescribed fire will follow guidelines in the Best Smoke

Management Practices publication issued by the USDA Forest Service and USDA

Natural Resources Conservation Service (O’Neill et al., 2011) to minimize the impacts of

prescribed fire smoke. Guidelines include evaluating smoke dispersion, monitoring the

effects of smoke on air quality, communicating with the public, considering emissions

reduction techniques, and sharing the airshed by coordinating prescribed fire activities

with adjacent landowners.

3. Alternative methods of disposing slash created by project activities will be considered,

including biomass utilization.

4. Desireable burning conditions as well as firing and suppression techniques that may be

used to meet project objectives will be detailed in a prescribed burn plan.

5. All piles to be burned will be covered to minimize fuel moisture content in the piles,

which facilitates quick ignition and a shorter burnout phase.

Heritage

6. Logging activities using mechanized equipment (skidder, tractor, or loader) and use of

the site as a landing will not occur within 100 feet of the archaeological site in Unit 2.

Hand felled trees will be cable yarded which is permitted within the site boundaries

provided a Gifford Pinchot National Forest Heritage Program specialist is on site to

monitor during project implementation.

Silviculture

7. Minimize tree bole scarring by restricting operations during the high sap-flow period of

March 1 through July 31 in Units 1 and 8. Sap-flow operation restrictions may be waived

(in consultation with the District or Forest Silviculturist) if it can be clearly demonstrated

that operations can be conducted without unacceptable damage to leave trees.

8. Protect genetic resource select trees by 1) showing their locations on the sale area map; 2)

ensure they are not used as guy trees or tailholds and protected from skylines; 3)

directionally fall take trees away from them; and 4) protected during post-sale slash

disposal and erosion control work. Unit 5: WWP # 181, DF # 019, MH # 021, MH# 022,

MH # 027, Unit 7: WWP # 145, WWP # 146, DF # 020, WH # 026, MH #014, MH #

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016, MH # 026, Unit # 8: PSF # 621, DF # 021, Unit # 9: PSF # 628, Unit # 10: DF #

055.

Recreation

9. Employ standard contract requirements for signing of harvest areas and haul routes.

10. Minimize or prohibit harvest/haul operations during huckleberry and hunting seasons as

practical. At a minimum, confine activities to weekdays.

11. Protect any improvements in the sale area by contract (PI).

12. Employ standard public safety measures during any prescribed burning.

13. Seek opportunities to educate public through interpretive signs and other measures.

14. Seek opportunities to use potential increased Special Forest Product permit revenues to

fund additional FS presence on site, including Law Enforcement, to address potential

effects of increased use.

Wildlife

15. All harvest activities and prescribed burning will be restricted from March 1 to June 30 to

protect breeding migratory birds and raptors that may be nesting in the treatment units.

Soils and Water Quality

16. Avoid equipment operation, soil burning, and vegetation management on unstable soils

mapping (SMU 56) in unit 537148 (Unit 2) to avoid changes in frequency or timing of

mass wasting events.

17. Slash burning of piles greater than 1/8 acre (6000 sq. ft.), will occur only on rocked roads

or landings to reduce impacts from severe soil burning.

18. Ground-based machinery will not operate where soil water content is high enough to

cause detrimental puddling, defined as when the depth of ruts or imprints is six inches or

more (Forest Service Manual, Chapter 2520, R-6 Supplement No. 2500.98-1). The

objective is to limit the degree of detrimental soil rutting and puddling as well as reduce

the potential for sediment delivery to streams.

19. Equipment will operate on a slash mat of limbs and tops when it travels away from

approved skid trails or temporary roads. The slash mat will be as thick and continuous as

practical as a means to reduce soil disturbance. Equipment will make as few trips as

possible. The objective is to limit soil compaction and displacement, to provide water

infiltration and protect the topsoil for vegetative growth.

20. Soils in Units 5 and 6 and shallow, rocky soils will not be decompacted in order to

prevent detrimental soil disturbance. In other areas, decompacting must be done

immediately following logging activities. Any proposed methods for decompacting must

be approved by the sale administrator in consultation with the aquatic specialist or soil

scientist. To prevent re-compacting of the landings, no ground-based equipment will be

operated on decompacted portions of landings after decompacting is completed. Cross-

drains (also called water bars), constructed to drain, will be installed every 150 feet or

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more frequently where slopes exceed 5%, every 100 feet when slopes exceed 15%.

Available logging slash will be placed across the decompacted landing surface.

(Acceptable weed free seed mix; type of weed free mulch; and application rates will be

specified by a qualified specialist). The objective of this measure is to rehabilitate areas

compacted during management activities, accelerate recovery of compacted soils, and

facilitate water infiltration and revegetation on those disturbed areas. Applicable BMP:

T-13. Erosion Prevention and control measures during timber sale operations; T-14 -

Revegetation of area disturbed by harvesting activities; T-16. Erosion control on skid

trails.

21. Locate new landings outside of all no-harvest buffers. Limit landings to the area needed

for safe and efficient yarding and loading operations and have proper drainage. Use

certified weed free straw bale catchments or silt fences to avoid sediment transport to

road ditches or streams. Locate catchments to intercept runoff from the landing prior to

reaching any road ditch or stream.

22. Close and restore landings after harvest and related activities are complete. Place

available logging slash across the soil surface. Closure to vehicles is required to prevent

erosion and sediment delivery, and to allow vegetation to develop. The objective is to

accelerate recovery of compacted soils, and facilitate water infiltration and re-vegetation

on those disturbed areas. These measures will also provide ground cover for exposed

soils in order to reduce the potential for offsite erosion and maintain soil organic matter

to prevent nutrient and carbon cycle deficits.

23. The Forest Service may approve pre-bunching on a unit-by-unit basis on slopes greater

than 35 percent, up to 45 percent slope prior to start of operations. Polepatch units

approved for this type of operation are units 10 and 12, on soil mapping SMU 5150.

Mechanical cutting and harvesting machines will not operate over erosive soils on slopes

greater than 35 percent. Pre-bunching on steep slopes includes ground-based equipment

traveling on slopes greater than 35 percent and away from designated landings,

temporary roads, or skid trails. The mechanical cutting and harvesting machine will:

a. Be limited to slopes less than 45 percent, including short, steep pitches.

b. Avoid traveling across the slope and turning on steep slopes.

c. Operate on a slash mat of limbs and tops deposited directly in front of the

machine, as described previously.

d. Not travel or drive while bearing the weight of trees.

e. Not enter into Riparian Reserves and unstable slopes, unless otherwise specified

in unit specific project design features. Over the snow operations, as described

below, may be allowed.

f. Minimize and restore excavation of road prism for equipment access, upon

verification with a cultural resource specialist, when mechanical cutting and

harvesting activities are complete.

24. Forest Service will approve location of trails used for equipment fueling and servicing on

steep slopes. Locate trails where suitable grade and minimal effects to soils and water

quality exist. Set aside and rehabilitate topsoils post use by moving the soil back to the

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natural contour of the hillslope (re-contour with topsoil on top) and placing slash or

vegetation on exposed mineral soils. The objective is to prevent surface soil erosion

resulting from timber related ground disturbance.

25. Forest Service will perform periodic monitoring of ground-based activity on steep slopes

in order to prevent or rectify resource damage that may occur because of mechanical

cutting and harvesting machines. Resource damage includes forming of ponds, ruts, or

rills; culvert blockages, stream channel instability, and the occurrence of scour or

sediment transport and deposition downstream of cross drains. Project activities will be

curtailed and corrective action taken before allowing the project work to resume, if

resource damage is occurring. Forest Service will document implementation and

effectiveness monitoring of BMPs and make them available to the line officer in order to

determine when adjustments could prevent excessive resource damage. The objective is

to minimize erosion and potential sediment delivery to streams.

26. Over the snow operations: Ground-based equipment can operate on snow which is at

least 2 feet deep, or a combination of 3 to 4 inches of compacted snow and soil frozen to

at least 6 inches in depth. Operations shall not continue where snow does not provide

protection against rutting. For example, if it rains heavily and the soil and snow become

saturated, Forest Service would restrict equipment operations. As an indicator, overnight

temperatures should be less than 25 degrees F; afternoon daytime temperatures should

not exceed 35 degrees F.

27. Harvested trees will be felled away from streams, wetlands or other riparian reserve

features. Exceptions would be trees which are leaning towards the creek, when

conditions would not allow safe felling, or those felled as part of the non-commercial

Riparian Reserve treatment (see PDCs for Fisheries). Any portion of a felled tree that

lands in the no-cut buffer will be left on the ground. The objective of this measure is to

prevent damage to riparian vegetation and soils within Riparian Reserves. Applicable

BMPs: T-6 - Protection of unstable lands; T-13 - Erosion prevention and control

measures during timber sale operations, T-17 - Meadow protection during timber

harvesting.

28. One end log suspension will be required for ground-based and cable yarding systems

except during winching or lateral yarding. No yarding is permitted over perennial and

intermittent stream channels. This will reduce the risk of soil compaction and

displacement from dragging entire logs along the ground. The objective of this measure

is to minimize erosion and potential sedimentation. Applicable BMP: T-13 - Erosion

prevention and control measures during timber sale operations

29. All ground based equipment will be confined to pre-approved skid trails and landings

during yarding and brush disposal operations. Loaders or feller-bunchers may operate off

designated skid trails, but must operate over slash beds that are as thick and continuous as

practicable. Skid trails must be located at least 120 feet from Class 3 and 4 streams, and

wetlands greater than one acre, and 60 feet on wet areas less than one acre. Skid trails

will be spaced a minimum of 150 feet apart for tractors and 400 feet apart for loaders.

When possible, skid trails will be reestablished at previous skid trail locations rather than

constructing new ones. Landings, skid trails, and corridors will be approved by the sale

administrator prior to timber felling. The objective of this measure is to minimize the

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extent and the degree of soil damage, displacement, and disturbance, and to allow

sediment filtration. Applicable BMP: T-11. Tractor Skid Trail Location and Design.

30. All road drainage structures (e.g. culverts) to be installed will be designed to

accommodate bankfull flow flood events if left in place into the wet season (October 1-

June 30), consistent with Gifford Pinchot Land Resource Management Plan Standards

and Guidelines (USDA 1995) and Memorandum of Understanding between Washington

Department of Fish and Wildlife and USDA-Forest Service Region 6 (WDFW, USDA

2005). Temporary drainage structures will be designed to meet the base flow condition

(approximately 36 inches) if utilized only during the dry season (June 15 - Sept 30) and

removed prior to the fall wet season. If new structures are to weather through fall and

winter, they must comply with standards and guidelines as if a permanent structure. The

objective of this measure is to ensure channel transport function and channel longitudinal

connectivity. Applicable BMP: T-13. Erosion prevention and control measures during

timber sale operations. These are standard guidelines and this project is not anticipated to

install any new culverts.

31. A spill plan will be developed and pre-approved prior to implementation. The plan will

include appropriate operational measures for handling hazardous materials. A Hazardous

Material kit will be on site, and would contain materials to control/contain a spill of fuel,

oils, and/or hydraulic fluid. Fueling equipment will be located outside of riparian

reserves. All service work on heavy machinery and refueling will be done on an

established system road at a site approved by the Forest Service. The objective of this

measure is to reduce the potential for damage to the stream and flood plain as a result of a

hazardous material spill. Applicable BMPs: T-4 - Use of sale area maps for designating

water quality protection needs; T-7 - Streamside management unit designation; T-17.

Meadow protection during timber harvesting; T-22 - Modification of the Timber Sale

Contract (TSC); R-12 - Control of construction in streamside management units.

32. Areas of detrimental gouging or soil displacement resulting from suspended logging

systems will be treated to prevent rill and gully erosion and possible sediment delivery to

stream courses. Erosion control treatment may include but not limited to repositioning

displaced soil to re-contour disturbed sites, creating small ditches or diversions to redirect

surface water movement, scattering slash material to create flow disruption and surface

soil stability. Erosion control measures implemented by the purchaser will be complete

prior to the onset of wet season (October 1 – June 14) and approved by the Timber Sale

Administer in consultation with an aquatic resource specialist prior to the close of the

timber sale. The objective of this measure is to prevent surface soil erosion resulting

from timber related ground disturbance. Applicable BMPs: T-6 - Protection of unstable

lands; T-13. Erosion Prevention and Control Measures During Timber Sale Operations.

33. All yarding and haul activities in units 1 through 6 will be restricted to a Normal

Operating Season (NOS), defined as July 15 to September 30. The objective of this

measure is limit ground disturbing activities to the dry season thereby minimizing soil

displacement, compaction, surface erosion and sediment delivery.

34. All yarding and haul activities in units 7 through 12, which have high water tables and

wetlands, will be restricted to a Normal Operating Season (NOS), defined as Aug 1 to

September 30. The objective of this measure is limit ground disturbing activities to the

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dry season thereby minimizing soil displacement, compaction, surface erosion and

sediment delivery.

35. Exceptions to NOS timing restriction may be made during periods of anomalous weather

conditions. Extraordinary wet weather during NOS may limit yarding and haul

operations. Or, during extended periods of dry weather or sufficient snowpack outside

the NOS, yarding and haul operations may proceed only with the written approval of the

project contract sale administrator in consultation with an aquatic resource specialist and

providing there is daily monitoring to evaluate if exceptional wet weather logging

operations are meeting project design criteria for wet weather (PDC #18) or for over-the-

snow operations (#26). Applicable BMPs: T-4. Use of Sale Area Maps for Designating

Water Quality Protection Needs; T-6. Protection of Unstable Lands; T-7. Streamside

Management Unit Designation; T-13. Erosion Prevention and Control Measures During

Timber Sale Operations; T-17. Meadow Protection during Timber Harvesting; T-22.

Modification of the Timber Sale Contract (TSC); R-12. Control of Construction in

Streamside Management Units.

36. Slash burning shall not take place inside Riparian Reserves.

Documentation of BMPs:

37. BMPs will be documented wherever necessary to assess conditions of haul routes,

landings and skid trails.

Corrective Action:

38. Project activities will be curtailed and corrective action taken when ponding, rutting,

rilling, culvert blockages, stream channel instability, and the occurrence of scour or

sediment transport and deposition downstream of cross drains are encountered on

adjacent system roads, temporary roads, skid trails, landings, stream crossings, riparian

reserves or within harvest units where ground disturbance has occurred.

Fisheries

Forest Management Operations

39. Openings or gaps created by the project in Riparian Reserves may not exceed 0.1 acre in

size or 3 percent of Riparian Reserve area within each treatment unit. Retain 1 or 2 trees

per gap created in Riparan Reserves to maintain future stream shading and microclimate.

40. The trees felled within the no-harvest riparian buffer will remain in place (see Riparian

Reserve PDCs below). Trees felled outside the riparian reserves may be relocated to

restore aquatic habitat by returning woody debris to the aquatic ecosystem.

41. Apply silvicultural practices in riparian reserves to control stocking, acquire vegetation

characteristics needed to attain desired aquatic ecological characteristics including:

streamside shading, bank stability and LW recruitment. Stocking levels should remain

above a relative density of 30% and canopy closure of 40%.

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Riparian Reserve Summary

42. The full Riparian Reserve (RR) width is defined for the Polepatch as 150 feet (one site-

potential tree height) distance in either direction from Class III and IV streams or

wetlands larger than 1 acre. There are no Class I or II streams in the project area. Ground-

based equipment will not be permitted in the RR.

43. The no-cut buffer is defined as the inner 20 feet of the RR. No trees will be felled in this

area.

44. The outer riparian buffer may be treated with a similar commercial harvest as the

upland portion of the treatment unit, and is designated at 120 feet from Class III streams

and 90 feet from Class IV streams.

45. The no-harvest buffer is between the no-cut buffer and outer riparian buffer, and is

proposed for non-commercial treatment for down wood and tree release as described in

below section. This zone is between 20 and 120 feet from Class III streams, between 20

and 90 feet from Class IV streams, and between 20 and 60 feet for wetlands larger than 1

acre.

Riparian Reserve – Down wood and tree release

46. An experienced silviculturist, botanist, ecologist, or associated technician, and wildlife

biologist shall be involved in designing vegetation treatments.

47. No roads or landings will be constructed or reconstructed.

48. The treatment area is located outside of the bankful channel and includes a twenty foot

no-cut buffer which will leave the trees immediately adjacent to the aquatic feature

(wetland, stream) unaffected.

49. Thin conifers to accelerate attainment of late-seral conditions within riparian areas in

competitive exclusion developmental stages within plantations (i.e. where even-aged

stands are growing because of previous silvicultural prescriptions),

50. Thin dense understories resulting in even age plantation management to select for and

promote survival of late-seral trees.

51. Trees felled within the no-harvest riparian buffer will be used to restore aquatic and

terrestrial habitat by returning large and coarse woody debris levels to within the range of

natural variability.

52. Select leave trees to be released with diameter class > 20 inches dbh or largest available

trees.

53. Select drop trees with a diameter class > 14 inches dbh or largest available trees

54. Retain all minor species including: western red cedar (Thuja plicata), Alaskan yellow

cedar (Callitropsis nootkatensis), pacific yew (Taxus brevifolia), big leaf maple (Acer

macrophyllum) red alder (Alnus rubra), spruce (Picea engelmannii), and black

cottonwood (Populus trichocarpa).

55. All felled trees within the no-harvest zone of riparian reserve will be left on site.

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56. Trees to be felled and left on site should be selected in areas inaccessible to roads (> 100

ft) to avoid incidental fire wood harvest where possible.

57. Work in no-harvest zone will be accomplished with hand tools (i.e. chainsaw), no heavy

equipment allowed

58. The project will comply with Normal Operating Season and exceptions defined in

previous measures.

Road Closure and Stabilization – 7700239

59. Develop a vehicle turnaround suitable for passenger cars or trucks at approx. MP 0.45

60. Remove all culverts including ditch relief pipes and live stream pipes. This will total

approximately 189 yds3 of fill material.

61. Create a barrier to future motorized access near MP 0.45.

62. Pull unstable fill slopes where necessary to reduce erosion

63. Contour road surface to shed water (outslope road and install drain dips)

64. Revegetate with native herbaceous and/or woody vegetation, where necessary

65. Implement erosion control (e.g. add revetment, revegetate, straw cover)

66. Retain road in Forest infrastructure maintenance plan (iWEB).

67. Monitor effectiveness

Road Treatment - All

68. Road treatment segments within riparian areas should be contoured to mimic natural

floodplain topography and gradient to the greatest degree possible.

69. During culvert removal on live streams install sediment control barriers (e.g. silt fencing)

between the project and the stream to the extent practical.

70. Dispose of waste material in stable sites out of the flood prone area. Waste material other

than hardened surface material (asphalt, concrete, etc.) may be used to produce a swale

(drain dip) down slope from the stream crossing.

71. Minimize disturbance of existing vegetation in ditches, road surface and at stream

crossings to the greatest extent possible.

72. Conduct activities during dry-field conditions as defined in water quality PDCs (#33, 34,

35).

73. When removing a culvert from a Class III and IV (first or second order, non-fishing

bearing stream), project specialists shall determine if culvert removal should follow the

isolation criteria

74. For culvert removal projects, restore the bankfull channel width plus 50 % (BFW * 1.5)

to allow natural drainage patterns and promote passage of aquatic organisms.

75. Evaluate channel incision risk and construct in-channel grade control structures when

necessary.

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Invasive Plants

76. To prevent the introduction of noxious weeds into the project area, for actions conducted

outside the road prism, all heavy equipment (bulldozers, skidders, graders, backhoes,

dump trucks, etc.) will be cleaned prior to entering National Forest System lands. An

inspection will be required to ensure that equipment is clean before work can begin.

(Standard 2, Pacific Northwest Region Invasive Plant Program Final Environmental

Impact Statement Record of Decision, 2005. This document will be identified below as

“R6 Weed EIS”). In addition, the use of equipment cleaning contract clause WO-C/CT

6.36 is required by Forest Service policy (USDA Forest Service Guide to noxious weed

prevention practices (“Prevention Guide”) p.5). This clause provides:

77. “Purchaser must clean off-road equipment prior to moving between cutting units on this

timber sale that are known to be infested with noxious weeds and other units, if any, that

are free of such weeds. Sale Area Map shows areas, known by Forest Service prior to

timber sale advertisement, that are infested with specific noxious weed species of

concern.”

78. In order to simplify requirements for purchasers, the following mitigation is

recommended:

79. Purchaser must clean off-road equipment prior to moving between cutting units on this

timber sale. This requirement could be waived by the sale administrator, at the request of

the purchaser, with consultation with the district botanist, in specific situations where the

recorded weed lists are the same between two units. There are 10 units with no

recorded weeds. Equipment cleaning will help to avoid introduction of weeds to these

areas with desired vegetation, and help prevent the further spread of weeds already

established in the project area.

80. Use weed-free straw and mulch for all projects, conducted or authorized by the Forest

Service, on National Forest System Lands. If State certified straw and/or mulch is not

available, individual Forests should require sources certified to be weed free using the

North American Weed Fee Forage Program standards or a similar certification process

(Standard 3, R6 Weed EIS).

81. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for invasive

plants before use and transport. Treat or require treatment of infested sources before any

use of pit material. Use only gravel, fill, sand, and rock that is judged to be weed free by

District or Forest weed specialists (Standard 7, R6 Weed EIS).

82. Native plant materials are the first choice in revegetation for restoration and rehabilitation

where timely natural regeneration of the native plant community is not likely to occur.

Non-native, non-invasive plant species may be used in any of the following situations: 1)

when needed in emergency conditions to protect basic resource values (e.g., soil stability,

water quality and to help prevent the establishment of invasive species), 2) as an interim,

non-persistent measure designed to aid in the re-establishment of native plants, 3) if

native plant materials are not available, or 4) in permanently altered plant communities.

Under no circumstances will non-native invasive plant species be used for revegetation.

(Standard 13, R6 Weed EIS).

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83. Landings, and other areas of heavy disturbance would be revegetated if needed (GP

Forest Plan IV-66, Road, Bridge, and Culvert Construction and reconstruction: 3.

Following construction work, erosion control and restoration should be completed during

the same season, or as soon as practicable.). If the landings have a sufficient layer of

bark mulch from harvest activities, to protect the soil and prevent weed growth, in the

judgement of the sale administrator, seeding may not be necessary. If seeding is needed,

it shall be done with a native seed mix and application prescription developed by the

Forest. Guidelines for site preparation would also be followed. The following

prescription is recommended as an example: a locally native seed mix such as 16 lb. blue

wildrye (Elymus glaucus), and 20 lb. California brome (Bromus marginatus), with 4 lb.

slender hairgrass (Deschampsia elongata) applied at a rate of 40 lbs/acre, and enough

weed-free mulch to cover the seed 2-3 inches. Consult North Zone botanist at the time

revegetation is needed for current recommendations, depending on Forest supplies and

site characteristics. Fast-release fertilizers such as urea should be used only when soil is

nutrient deficient, and when plants are actively growing and able to take it up, to avoid

runoff into water bodies. Fast-release nitrogen fertilizer should not be applied with seed

in the fall. When seed is used it should be either certified noxious weed free or from

Forest Service native seed supplies. Purpose of mitigation: to minimize soil erosion and

weed establishment at disturbance sites.

84. Minimize road maintenance clearing zones, as much as safety regulations will allow.

Purpose of mitigation: to maintain shady conditions that help minimize invasive plant

population expansion (Prevention Guide, Goal 5, p.7)

85. During years of project implementation, conduct any road brushing activities during

spring-early summer, before seed heads mature. Purpose of mitigation: to prevent

formation and release of viable seeds that could be dispersed along hauling corridors by

vehicles, and/or when wind-borne seeds could disperse into newly harvested Units.

86. Opportunity, depending on available funding (Prevention Guide: goal 2, Practice 2,

Goal 6, Practice 18). Control specified invasive plants at landings, culvert replacement

sites, and along access roads for 1/4 mile preceding areas of ground disturbance (i.e.

staging areas, and harvest units adjacent to roads), to 1/4 mile following area of ground

disturbance, and within timber harvest units, as specified below:

a. During the season the ground disturbing phase of project implementation begins,

but prior to ground disturbance, weeds would be controlled (prevented from

setting seed). Control efforts would occur before invasive species have set seed

for the year (June or July). The Gifford Pinchot National Forest (contact: North

Zone Botanist) would provide a list of weeds to be controlled previous to project

implementation. The project lead would inform the Gifford Pinchot North Zone

botanist when the weed control work would be performed, and when it is

complete.

b. During subsequent seasons of project implementation weed re-occurrences

along access roads would be controlled as specified above.

c. For two field seasons following project completion, weed re-occurrences at

landings, and along access roads, would be controlled as specified above. In

addition, harvest units would be surveyed for invasive plant establishment and/or

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encroachment. If new invasive plant populations are located within harvested

units, invasive plants would be controlled, and population data would be collected

for entry into the Natural Resource Inventory System (NRIS) database, as

specified above.

d. After two years, the North Zone Botanist would re-evaluate the weed control

needs within the project area and determine whether further treatment is needed.

It is likely that, at some sites, weed control beyond two years would be necessary.

e. All invasive plant control actions would be entered into the FACTS database on

an annual basis.

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APPENDIX C: METHODS FOR EVALUATING FUEL LOADINGS AND FIRE BEHAVIOR

The Fuel Characteristic Classification System (FCCS) (Ottmar et al. 2007) was used to model

current fuel and fire behavior characteristics and the effects of the proposed action on those

characteristics. FCCS provides a set of 216 predefined fuelbeds covering a variety of forests and

compiled from published and unpublished literature, fuels photo series, fuels datasets, and expert

opinion (Ottmar et al. 2007). Field data and observations were used along with the Photo series

for quantifying natural forest residues in common vegetation types of the Pacific Northwest

(Maxwell and Ward 1980) to modify FCCS fuelbeds to represent pre- and post- mechanical

treatment and post- prescribed fire stand conditions in the planning area.

FCCS captures the structural complexity of fuelbeds by compiling and analyzing the data from

six fuel strata: canopy, shrub, non-woody, leaf litter, dead and down woody, and ground fuel

(e.g., humus or duff). FCCS converts the quantitative descriptions of fuel characteristics to

estimates of potential surface fire behavior. Surface fire behavior predictions are based on a

modification of the Rothermel (1972) fire spread model, which calculates the potential spread

rate of a fire moving upslope with the wind) through homogeneous surface fuels, under uniform

conditions with respect to fuel loading and arrangement, fuel moisture, wind, and slope. The

spread rate calculations describe fire behavior in the flaming front of the fire, which is influenced

primarily by fine fuels. Sandberg et al. (2007b) reformulated the Rothermel model to allow

input of multiple fuelbed strata into the surface fire behavior model. Potential fire behavior

outputs were generated based on the default fuel moisture scenario D2L2C3 and midflame wind

speed of 4 mph. Based on local knowledge, the D2L2C3 fuel moisture scenario (1 hr=6%, 10

hr=7%, 100 hr=8%, 1000 hr=12%, nonwoody=60%, shrub=90%, crown=90%, duff=60%)

corresponds to dry conditions under which fuels ignite readily and prescribed fire would be

successful at meeting project objectives. Slope was assumed constant at 0%.

FCCS calculates reaction intensity (RI), rate of spread (ROS), and flame length (FL) based on

Sandberg et al.’s (2007b) reformulation of the Rothermel fire spread model. The RI (BTU ft-2

) is

derived from the reactive volume of fuels per unit of ground surface, surface fuel depth, heat of

combustion (Sandberg et al. 2007a). The ROS (ft min-1

) is a function of the RI, propagating

energy flux, and radiant heat sink (Sandberg et al. 2007a). The FL (ft) is derived from the

product of RI, ROS, and flame residence time (Byram, 1959; Albini, 1976; Sandberg et al.,

2007a).

Potential fire behavior and emissions may be misrepresented where fuel cover is not continuous,

because FCCS assumes continuity of the fuelbed components used to calculate fire behavior

characteristics (Riccardi et al., 2007). Site specific field observations are needed periodically

throughout the mechanical treatment phase to verify whether sufficient continuous fuels exist to

propagate fire spread. Fuel conditions are expected to change over time as new vegetation

develops and activity fuels compress and decompose. Further analyses are required to predict

future fire behavior characteristics as fuel loads change over time.

Modeled constant wind speeds and fuel moisture scenarios do not account for differences in

surface wind speeds, fuel moistures, and potential fire behavior related to canopy density. Dense

forest canopies shade fuels more than open canopies, which results in higher relative humidities,

lower temperatures, and higher surface fuel moistures under dense canopies (Andrews, 1986).

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Dense forest canopies may retard surface winds that dry fuels more than open canopies (Agee,

2002), which contributes to higher fuel moistures under dense canopies (Weatherspoon, 1996).

Higher surface fuel moistures under dense canopies may reduce the probability of ignition in

these forest stands (Graham et al., 2004). Additional factors, such as slope (Chandler et al.,

1991), influence potential fire behavior; however, the FCCS default setting assumes no slope

(0%) for surface fire behavior predictions.

Current Conditions

Current conditions are represented by FCCS default fuelbed 238, which is modeled from Pacific

silver fir and mountain hemlock forests occurring on cool, moist sites at high elevations in

montane and subalpine forests along the western slopes of the Cascade crest. These forests often

have dense understories of false azalea, huckleberry, beargrass, and sedge species. Changes to

the default fuelbed were made to reflect specific local conditions based on field data,

observations, and photo series (Maxwell and Ward, 1980). Average tree heights and height to

crown were reduced for all stories. Midstory density was increased to 60 trees per acre and

understory decreased to 200 trees per acre with an average DBH of 3 inches. Changes to species

composition reflect the presence of Douglas-fir, western hemlock, and western white pine in

addition to Pacific silver fir. Woody fuel loading was increased slightly but remains light and

rotten wood and duff loadings were decreased.

Stand characteristics vary throughout the Polepatch planning area. Pockets of dense sapling and

pole-sized trees are contrasted by large meadow openings with stringers of trees. The fuelbed

that represents current conditions, described above, is intended to be a best average

representation of the stands proposed for prescribed burning. General conclusions can be drawn

about other stands in the analysis area by adapting modeled treatment effects.

Post-Harvest Conditions

Expected near-term post-treatment conditions (1-5 years following treatment) are represented by

changes made to the current condition FCCS fuelbed (see above) based on the treatment

prescription. The thinned version of this fuelbed reduces total canopy cover to 15-30% with the

majority of the removal in the mid-story. Shrub cover is expected to increase by 3-5 years after

harvest as more light is able to penetrate the canopy. Increases in fuel loading are attributed to

harvest residue. Forest residue photo series by Maxwell and Ward (1976) and Ottmar et al.

(1990) were used to estimate fuel loadings. Post-treatment fuels remaining on site will vary, but

fuel accumulations are expected to compress and decompose quickly, aided by moist conditions

and heavy winter snowpacks. Treatment specifications will minimize fuel accumulations along

any major travel routes.

Prescribed Fire Pre-treatment Conditions

Studies by Minore et al. (1979) on the Gifford Pinchot and Mt. Hood National Forests found that

huckleberry fields were unreceptive to burning by drip torch without cured slash added to the

site. Preliminary evidence from a 2011 prescribed burn corroborates Minore et. al’s findings.

The 2011 prescribed burn took place in the Sawtooth Berry Fields on the Gifford Pinchot

National Forest. Fire effects monitoring noted the mosaic burn pattern of the 70 acre unit.

Consumption occurred where red slash was present on the site, but fire did not travel into

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adjacent huckleberry and beargrass plants. Therefore, prescribed fire site preparation for

Polepatch will specify at least 8 tons/acre of downed fuels less than 3 inches in diameter be on

site in areas that will be burned. Desired fuel loadings will be achieved by cutting understory

trees, limbing overstory trees, and allowing slash to cure on site. Changes to the current

conditions fuelbed include a reduction in understory canopy cover and an increase in dead, down

woody fuels. Some overstory and midstory trees may be harvested and removed from the site

where access allows.

Post-Prescribed Fire Conditions

Expected post-prescribed fire conditions are represented by changes made to the fuelbed created

for prescribed fire pre-treatment conditions (see above). The fire-treated version of this fuelbed

reduces total canopy cover to 28% as indicated by the results of FOFEM analyses (see below for

information on FOFEM analyses). Shrub and herb covers are expected to decrease by 25-100%,

with the greatest consumption where slash is present. Fuel loading is expected to decrease in all

size classes with 75-100% consumption of fuels under 3 inches diameter. Post-treatment fuels

remaining on site will vary depending on fuel continuity and environmental conditions at the

time of burning, but residual fuel accumulations are expected to compress and decompose

quickly, aided by heavy winter snowpacks and generally moist conditions.

Fire Effects

FOFEM (First Order Fire Effects Model) version 6.0 (Keane et al., 2012) is a computer program

for predicting tree mortality, fuel consumption, smoke production, and soil heating caused by

prescribed fire or wildfire. First order fire effects are the immediate consequences of fire and

form an important basis for the prediction of secondary effects such as tree regeneration, plant

succession, and changes in site productivity. FOFEM is intended to directly assess fire impacts

and severity and to plan prescribed fires that accomplish resource needs.

Analyses in this report highlight the effects of fire on tree mortality. Tree mortality outputs in

FOFEM include tree mortality by species and size class, and pre- and post-fire canopy cover.

Predicted changes in canopy cover and percent mortality from prescribed burning in Polepatch

are found in Table 27. Species present, except Douglas-fir, are relatively fire intolerant;

therefore, even low flame lengths and scorch heights result in a moderate to high amount of

mortality, particularly in small diameter trees.

FOFEM is a point model which means that it predicts fuel consumption and smoke emissions for

a point on the landscape/stand (about 1-5 m2). The extrapolation of that point measurement

upwards in scale is at the discretion of the user. Fuel and moisture conditions across a stand and

landscape are notoriously variable, so one point estimate for large areas can introduce bias into

the predictions.

Fuel Consumption and Emissions

Fuel consumption and emissions were calculated using Consume 3.0 (Ottmar et al., 2005) and

results will be incorporated into an approved burn plan before any slash treatment occurs.

Consume imports data from the FCCS fuelbeds created and outputs fuel consumption, pollutant

emissions, and heat release. Consume makes calculations based on fuel loadings, fuel moisture

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and other environmental factors. Consume includes separate equations to calculate consumption

of activity, natural, and piled fuels. Emissions outputs from a fire that burns through each of the

treatment condition scenarios are found in Table 27. Emissions associated with the burning of

“Rx pre-treat” are those expected from prescribed burning operations in the proposed action.

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APPENDIX D: COMMENTS ON DRAFT EA AND IDT RESPONSES

# Comment Received IDT Response/Clarification

GPTF-1 EA cites the 1918 Cispus Burn incorrectly; should be

the 1918 Greenhorn Fire

The 1918 Greenhorn Fire was a reburn on the 1902 Cispus Fire.

GPTF-2 We are still unclear at the historic and current

conditions of huckleberries throughout the district.

The EA stated that “Prior to the 1918 Cispus Burn*,

the area was a large assemblage of late successional

forest with some mid-successional and early seral

stage extents (EA p. 22).” The background section of

the EA mentions “evidence regarding Native

American burning as a traditional cultural practice,

specifically with regards to the creation and

maintenance of huckleberry fields (EA p. 2).”

Natural fire return intervals indicate that landscape conditions prior

to the 1902 Cispus Fire and the subsequent 1918 Greenhorn Fire,

which reburned a large portion of the Cispus Fire, were likely

characterized by large assemblages of late successional forest with

some mid-successional and early successional extents.

Descriptions of landscape vegetation characteristics are necessarily

vague because natural fire return intervals of the vegetation types

present on this landscape range from 250-500+ years. Local

historic references of fire frequency and extent are limited beyond

the past 100-150 years, which limits the ability to draw concrete

and/or quantitative conclusions about historic conditions at any

specific point in space or time.

Native American burning as a traditional cultural practice likely

contributed to the amount and distribution of different successional

stages across the landscape. Native American burning is

considered when calculating natural fire return intervals; other

human-caused fires are not considered.

Conditions described do not negate one another; rather, the

occurrence of Native American burning helps explain the amount

and extent of successional stage distributions.

GPTF-3 Both of these historic conditions seem to be at odds.

If the goal is to focus on desired future conditions

rather than detail the historic conditions the EA

should explain the current population of huckleberry

fields on the district and how much and where they

should be distributed. Without this information it

Changing climatic and social conditions dictate the need to focus

on desired future conditions. However, determination of desired

future conditions without analysis of historic and present conditions

would be remiss. Average historic conditions currently provide the

best representation of sustainable natural systems.

Specific stands for treatment in the Polepatch Huckleberry

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# Comment Received IDT Response/Clarification

appears the Forest Service is favoring huckleberry

enhancement in large concentrated areas without a

comprehensive/landscape vision. This is especially

concerning because the entire project is within older

naturally regenerated stands that contain a fair

amount of diversity, which are lacking on the Forest.

Restoration were identified by the Forest Service, but the general

location for Polepatch was identified by the Cowlitz Tribe as an

area historically important to huckleberry picking tribes. Cowlitz

Tribe and Pinchot Partners advocated huckleberry enhancement in

the area in a letter dated July 17, 2009 (EA, p. 2).

The Polepatch project area is relatively small, and few other

projects that focus specifically on huckleberry restoration have

been done on the Gifford Pinchot National Forest outside of the

designated Sawtooth Berry Fields. We agree that the development

of a comprehensive management plan as regards huckleberries

should be considered if future projects of this nature are considered,

particularly as treated areas increase in size either individually or

collectively.

GPTF-4 We reviewed the cumulative effects section of the

EA, specifically Table 36 that outlines timber harvest

and road work in the Lower Cispus watershed.

Timber harvest and road reconstruction (system &

temp) are the majority of work currently taking place

in the watershed. For a Tier 2 Key watershed, we

would expect there to be more of a focus on aquatic

restoration.

We agree there are watershed restoration opportunities in the

Lower Cispus and the Forest will continue to pursue these projects

as funding becomes available. We are currently soliciting grant

sources and are considering shifting emphasis of Forest

appropriated funds as other priority watersheds are closed out.

GPTF-5 We recognize there are 130 culvert replacements, but

36 of those are on private land, and we question

whether 69 culverts were actually replaced in the

Lower Cispus using Legacy Roads or if this is an

error.

The reported number culvert work is consistent with our records.

The account does include all federal and private land in the analysis

area. And as per CEQ regulations, the cumulative effects

assessment includes past, present and reasonably foreseeable future

projects. Projects with completed NEPA and signed decisions were

included in this analysis.

The majority of the Lower Cispus subwatershed culvert work was

completed in FY 08 on FR 2800 from MP 1.4-11.8 and involved

upgrades of relief pipes from 18 inch CMP to 24 in CMP. The

contracted work was completed by King Construction, Inc with

Agreement No. AG-05K3-S-08-0008 and Task Order 1 – 2008.

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# Comment Received IDT Response/Clarification

GPTF-6 The total of the road construction and reconstruction,

minus private land, is 27.3 miles, which is closing in

on the 39 miles of decommissioned or stabilized

roads. We recognize that the summary of cumulative

effects provided in table 37 reflect private land

management impacts, but the Forest Service could be

doing more to restore this Tier 2 Key watershed.

The cumulative effects assessment includes private lands. This

project will construct no new roads and proposes to close and

stabilize approximately 0.6 miles of road and complies with plan

direction to have no net gain in road miles. Reconstruction of

existing roads does not contribute to the Forest gross road miles

and should not be confused with new construction.

We concur that the Forest Service has ample restoration

opportunities in the Lower Cispus subwatershed. See response to

comment GPTF-4 above.

GPAG-

1

We think additional commercial thinning and stand

replacing cuts could be accomplished to offset the

cost of the Huckleberry restoration activities. We

think broadcast burning should be conducted over the

entire Huckleberry treatment area as well as

broadcast under burning of thinned areas. The

restoration project could be done in two phases. It

could be phased in over three years, with half the

area treated the first year and the remaining half

completed three years later. This would phase the

restoration project to allow a consistent availability

of huckleberries to the public during the restoration

project.

The team sought a balance of treatments for project feasibility. Pre-

treating stands to create a fuelbed is costly as is the actual burning

itself. Also, burning would not be guaranteed due to optimal burn

conditions being very limited by weather, topography and airshed

restrictions (many factors beyond our control). Note, too, that

huckleberry response time from burning can be twice as long (10-

15 years) as mechanical treatment response.

The desire to avoid creating new permanent or temporary roads for

this project in this planning area limited the extent to which stands

could be treated (with fire or mechanical/thinning) from a practical

standpoint.

The treatment units will undoubtedly occur in phases with more

than one sale being offered in different years and commercial/non-

commercial units being treated/burned in different stages as time

and funding allows.

AFRC-

1

Supportive of Alternative 2. Mention that “the

selection of appropriate harvest systems can have a

significant positive impact on the financial status of

the project. Current mechanical harvesting

equipment, in use throughout the timber industry, has

The interdisciplinary team endeavors to be as flexible as possible in

project planning to allow for innovation in technology that may

occur between when a decision is made and when the project is

implemented. At the same time the team must have enough

information and make some assumptions as to the nature of

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# Comment Received IDT Response/Clarification

a very light footprint on the ground and thus

minimizes detrimental soil effects.”

implementation in order to evaluate effects of the proposed

activties. We appreciate the info about the latest industry

technology!

AFRC-

2

We encourage the expansion of the Normal

Operating Season (NOS) identified in Appendix B of

the draft EA document, Items 28 and 29. Seasonal,

recreation, and wildlife restrictions often make

timber sales extremely difficult to complete within

the contract timelines. Fire season restrictions on top

of other operating restrictions can often limit work to

4-5 hours per day. All of these restrictions have a

cost to the purchaser and result in a lower bid for the

stumpage. Expansion of the NOS may also allow the

operator to operate under the guidelines identified in

Appendix B Item 20 – “Over the Snow operation.”

Assuming the project area is accessible during winter

months, without significant snow plowing expense,

winter operation can be very beneficial to

prospective bidders. Generally, it is at this time of

year when it is important to maintain economic

activity by providing work for logging crews and a

source of wood for mills to process.

Exceptions to NOS timing restriction may be made during periods

of anomalous weather conditions (see PDC #35). Extraordinary

wet weather during NOS may limit yarding and haul operations.

Or, during extended periods of dry weather outside the NOS,

yarding and haul operations may proceed only with the written

approval of the project contract sale administrator in consultation

with an aquatic resource specialist and providing there is daily

monitoring to evaluate if exceptional wet weather logging

operations are meeting project wet weather design criteria.

AFRC-

3

Pleased to see this project will work to improve the

road infrastructure of the forest as needed for timber

haul. The road system on the Gifford Pinchot

National Forest is a significant asset to the forest and

its’ stakeholders, which allows for both recreation

and timber haul. Access is important to many user

groups on the forest and a sound stable road system

will help to make forest management activities

economically viable now and in the future.

Forest transportation system maintenance and public access will

continue to be considerations for project planning. A forest-wide,

collaborative and interdisciplinary travel analysis is currently in

progress to inform future planning efforts and management

decisions.

K-1 What would be nice to see would be fairly good-size The treatment prescription proposed is based on the best available

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# Comment Received IDT Response/Clarification

areas cleared. Five or ten-acre clearings (or larger)

seems reasonable. Postage-stamp sized clearings are

not going to accomplish the target goals of

improving berry habitat and foraging habitat for large

ungulates.

science about huckleberry restoration in this region. The 15-30%

retention range is intended to provide more open conditions to

stimulate huckleberry production, while also maintaining some

frost protection and structural diversity. See Proposed Action (pp. )

which outlines in detail the size of treatments, and the discussion of

anticipated effects on huckleberries, wildlife, and other resources

(Chapter 3).

K-2 I suggest planning team members consult with local

Native American Tribes to see if they might have

suggestions for areas which would be most

suitable…. And with local residents of Randle,

Packwood, and the rest of the Big Bottom area to

learn which areas historically were good picking

areas but are no longer due to forest encroachment.

See EA, Purpose and Need (p. ) and Background (p. ). Tribes were

consulted prior to and during planning of this project. Desireable

areas were identified by the Cowlitz Tribe and a variety of

stakeholders, and the suitable and feasible areas to focus treatment

were refined through field review by the interdisciplinary team.