chapter 4 consultation, coordination, and...

Griffin Creek Resource Management Project Chapter 4 – Consultation and Coordination

Environmental Assessment 4- 1

Chapter 4

Consultation, Coordination, and Response to Comments

Preparers and Contributors The following Forest Service employees assisted with the development of this environmental assessment:

ID TEAM MEMBER: TITLE: AREA OF CONTRIBUTION: Cory Anderson Pre-Sale Forester Logging Systems Ema Braunberger Resource Information GIS Analysis Hans Castren Forest Technician Recreation Chantelle Delay Botanist Sensitive Plants/Invasive Species Bryan Donner Team Leader Team Coordination/Economics/Scenic Beth Gardner Fisheries Biologist Fisheries Mitch Guenthner Engineer Transportation Systems Amy Jacobs Wildlife Biologist Wildlife Betty Kuropat Silviculturist Vegetation/Silviculture Tim Light Archaeologist Heritage Resources Tami MacKenzie Writer/Editor Writing and Editing Manuel Mendoza Fire Operations Fire and Fuels Derek Milner Soil Scientist Soils Liz Rohde Hydrologist Water Resources Lisa Timchak District Ranger Project Oversight Jamie Tripp Fuels Planner Air Quality

Agencies, Organizations, and People Consulted The Forest Service consulted with the following groups, individuals, Federal, state and local agencies, and tribes during the development of this environmental assessment:

FEDERAL, STATE, AND LOCAL AGENCIES: United States Fish and Wildlife Service Montana Department of Natural Resources and Conservation Montana Department of Fish, Wildlife, and Parks Montana Department of Environmental Quality Flathead County Kootenai National Forest

TRIBES: Confederated Salish-Kootenai Tribes


4-2 Environmental Assessment

BUSINESSES: F.H. Stoltze Land and Lumber Company Plum Creek Timber Company Daily Inter Lake Bear Den Ranch

American Timber Company Hope Ranch Smurfit-Stone Container Corp. Spruce Avenue Limited Partnership LLP Hurst Family Limited Partnership

GROUPS: Alliance for the Wild Rockies Swan View Coalition Montanans for Multiple Use Flathead Economic Policy Center Montana Wood Products Association The Lands Council

WildWest Institute Friends of the Wild Swan Whitefish Lake Institute Flathead Audubon Society American Fisheries Society Trout Unlimited

INDIVIDUALS:

Verna Anfinson Victor and Jeannete Aquino Elizabeth and Heiko Arndt Rep. Bill Beck Ron Buentemeier Darrin and Tami Care Thomas Chichook James and Tina Coulter Ronna Cross Bruce and Terry Elverud Patrick and Marlene Alan and Sallie Gratch Gary and Rita Hall Nell Hankey Joshua Lacitignola Micheal and Lori McDonald Pat McDonnell Michelle McDowell Paul Mico Brent Mitchell

Mary Lou Musser Richard and Carol Nelson Sean Newbury Lynda and Gerry Osborne Sandy Ott Donald Reich McGregor Rhodes Alan and Cherry Rogers Billy Ray Sanders Ronald and Leslie Sears Todd and Barbara Shaver Richard Sherman Gary and Mary Sloan John Smilari Janis Taylor Sen. Bruce Tutvedt Linda Winnie Streich Living Trust Grafe Revocable Living Trust



Response to Comments Public comments express a distinct concept and represent identifiable concerns. Sample statements were selected for each public concern that best represented each distinct concept. In some cases, more than one sample statement was included to better capture the concern. Following the sample statements are a response to each concern from the project’s Interdisciplinary Team memebers. Climate 1. Public Concern: Published scientific reports indicate that climate change will be exacerbated by logging due to the loss of carbon storage. Additionally, published scientific reports indicate that climate change will lead to increased wildfire severity (including drier and warmer conditions that may render obsolete the proposed effects of the Project). The former indicates that the Griffin Creek Resource Management Project may have a significant adverse effect on the environment, and the latter undermines the central underlying purpose of the Project. Therefore, the Forest Service must candidly disclose, consider, and fully discuss the published scientific papers discussing climate change in these two contexts. At least the Forest Service should discuss the following studies: • Depro, Brooks M., Brian C. Murray, Ralph J. Alig, and Alyssa Shanks. 2008. Public land,

timber harvests, and climate mitigation: quantifying carbon sequestration potential on U.S. public timberlands. Forest Ecology and Management 255: 1122-1134.

• Harmon, Mark E. 2001. Carbon sequestration in forests: addressing the scale question. Journal of Forestry 99:4: 24-29.

• Harmon, Mark E, William K. Ferrell, and Jerry F. Franklin. 1990. Effects of carbon storage of conversion of old-growth forest to young forests. Science 247: 4943: 699-702

• Harmon, Mark E, and Barbara Marks. 2002. Effects of silvicultural practices on carbon stores in Douglas-fir – western hemlock forests in the Pacific Northwest, USA: results from a simulation model. Canadian Journal of Forest Research 32: 863-877.

• Homann, Peter S., Mark Harmon, Suzanne Remillard, and Erica A.H. Smithwick. 2005. What the soil reveals: potential total ecosystem C stores of the Pacific Northwest region, USA. Forest Ecology and Management 220: 270-283.

• McKenzie, Donald, Ze’ev Gedalof, David L. Peterson, and Philip Mote. 2004. Climatic change, wildfire, and conservation. Conservation Biology 18:4: 890 -902.

Response: The response to this comment is fully disclosed in Exhibit U-1.

Economics 2. Public Concern: Please evaluate all of the costs and benefits of this project. Please include a detailed list of all the costs to the agency and the public.

Response: All of the costs and benefits of the project are contained in the Economics and Social section of Chapter 3 of the EA. A detailed list of all the costs is found in Exhibit N-8.



3. Public Concern: Inadequate information on economic values and costs. In order for the public to make informed comments on the proposal, some public information should be provided on the costs and values involved in the project (a preliminary cost-benefit analysis).

Response: A cost-benefit analysis related to the value of wood and other products versus the costs of marketing those products is prepared and reported to the Forest Supervisor prior to public scoping of the proposed action. Reporting a preliminary timber sale feasibility analysis at the time the proposed action is developed and publicly scoped will be considered in the future. The Griffin Creek Project considers a wide variety of connected activities that may not all contribute to the costs required to sell wood products. Other sources of funding for accomplishing projects are available other than by the revenues (benefits) generated from the sale of wood products (see the response to #45 below). Cost-benefit analysis is best applied as a comparative tool between alternatives and not as a stand-alone analysis for a single proposal. A complete cost-benefit analysis for all alternatives is located in the Economics and Social section of Chapter 3 of the EA and Exhibit N.

Ecosystem Process and Function 4. Public Concern: Even though ecological restoration is not the project’s priority, the NEPA document must at least identify all the existing ecological liabilities caused by past management actions. This includes poorly located or poorly maintained roads, high-risk fuel situations caused by earlier vegetation manipulation projects, wildlife security problems by open motorized roads and trails plus those that are closed but violated—and include all those impacts in the analyses.

Response: The survey of the project area in preparation of the Griffin Creek Ecosystem Analysis at the Watershed Scale (Exhibit U-1) made a concerted effort and reported on restoration opportunities. The opportunities were identified in the Recommendations section of the EAWS document and include many aspects of the examples given in the comment. The features of the alternatives described in Chapter 2 were developed based on these recommendations. The impacts of the existing conditions are described in the various “No Action alternative” discussions in Chapter 3.

5. Public Concern: We ask, instead, that your proposal utilize ecological sustainability as your guiding principle of management. This means that restoration needs, following decades of extractive management and other human uses that have been very unsustainable, must be identified and prioritized appropriately.

Response: The three action alternatives include a number of restoration activities; such as culvert improvements, application of Best Management Practices on timber haul routes, beaver habitat restoration, bridge relocation, road decommissioning, shrub planting, and reforestation. Most of the vegetation treatments involving timber harvest are designed to shift or maintain species composition and diversity closer to historic means.



6. Public Concern: Noss (2001) addresses basic components of ecosystems: Ecosystems have three basic components: composition, structure, and function. Together, they define biodiversity and ecological integrity and provide the foundation on which standards for a sustainable human relationship with the earth might be crafted….We ask that you consider these key components as you define “desired conditions” or “natural conditions” for the Griffin Creek Project Area. These include amount of interior mature and old-growth forest, amount and size distribution of snags, amounts and distribution of coarse woody debris, and soil conditions and land productivity. In other words, in the case where those components are not within the natural range of conditions, we ask that any project proposal prioritize restoration of those components, and at the very least does not push those conditions further outside the range of natural conditions.

Response: The range of natural variation was compared with the current landscape components and proposed treatments. The restoration of natural conditions is not the purpose of the proposed action, but evaluating natural conditions provides a context for determining if the proposed action would lead to a sustainable ecosystem. The Forest Plan management area emphases in the project area (see Appendix B) make it incompatible for the Forest Service to manage for natural conditions at the landscape scale, where most of the ecosystem processes operate. However, it is our intention to manage Forest Service lands in a manner that sustains ecosystem processes as much as possible. See the sections in Chapter 3 on Forest Vegetation, Soils, Old Growth Habitat, Snags and Downed Wood Habitat, Neotropical Migratory Birds and Riparian Habitat, and Fire and Fuels for more details on how comparisons with historic conditions and ecological sustainability were considered.

Fire and Fuels 7. Public Concern: Units proposed for burning within project area may have closed forest service access roads (jammers) located within units. These units have the highest potential for noxious weed infestation and exacerbation through fire activities. Please provide an alternative that eliminates units that have noxious weeds present on roads within units from fire management proposals.

Response: All units proposed for ecosystem burning at this time have no existing or historical road systems within the boundaries. While prescribed fire may be used in debris disposal post timber harvest, weed mitigations are in place on all timber contracts on the FNF and disclosed in the Invasive Plant Species section of Chapter 3.

8. Public Concern: Page 2 of the scoping notice says: “Large scale fires occurred about every 25 years between the mid 1600s and 1919.” Fire Ecology in Rocky Mountain Landscapes, by William Baker says the Forest Service is over stating the frequency of wildfire. He contends that there were large fires every few hundred years not the frequent small fires that the scoping notice contends.

Response: The fire history used for this analysis was derived from a current (May, 2010) study conducted by Elaine Kennedy Sutherland (Rocky Mountain Research Station) and her colleagues. This study was done exclusively for the Griffin Creek drainage using three types of samples: increment cores to build tree-ring



chronologies for cross-dating, fire-scar samples to determine calendar year dates of fires, and demographic plots to determine age structures. It must also be noted that fire frequency as used in this analysis is for any fire, small or large, that burned within the Griffin Creek area and not a point on the landscape that burned, then reburned, at a later date.

9. Public Concern: Since one of the project’s goals are to reduce the chances that fire will destroy private structures, and harm people, the current fuel/fire hazard situation on land of all ownerships within the WUI (at least the WUI that’s relevant to this area) must be displayed on a map. More importantly, the fuel/fire hazard situation post-project on land of all ownerships within the WUI must also be displayed on a map. Based on this mapping of current and projected conditions, please accurately disclose the threats to private structures and people under those scenarios, for all alternatives. It must be discernable why some areas are included for treatment and others are not.

Response: The Griffin Creek EA project file contains color maps of fire condition class and historic fire regime for all ownerships. Used together, these maps can show the fuel/fire hazard situation. Also contained in the project file are the rule sets used to determine the condition class departure for various timber stands that may or may not be included for treatment. Even though some areas may score high for fuels reduction, the Forest Service manages for many different resource considerations; including soils, fisheries, water quality, silviculture, timber, and wildlife. Because of the unique considerations involved in managing a number of resources, not all areas within the Griffin Creek project area were available or desirable to treat.

10. Public Concern: The FS must have a detailed long-term program for maintaining the allegedly safer conditions, including how areas will be treated in the future following proposed treatments, or how areas not needing treatment now will be treated as the need arises. The public at large and private landowners must know what the scale of the long-term efforts must be, including the amount of funding necessary, and the likelihood based on realistic funding scenarios for such a program to be adequately and timely funded.

Response: The Griffin Creek EA is only designed to analyze the effects of the proposed actions related to this project. However, the analysis in the section on Fire and Fuels in Chapter 3 discusses the temporal bounds of the project’s proposed treatments. In general, regeneration harvest will provide an adequate area of fuel reduction for approximately 50 years. In units where a non-commercial harvest treatment is proposed, there is a possibility of increased fuel loading for the first two years after treatment if slash is left on site (not piled and burned). In areas adjacent to private property, slash may be piled and burned or removed.

11. Public Concern: Since the scientific literature suggests that your thinning activities will actually increase the rate of fire spread, you need to reconcile such findings with the contradictory assumptions expressed in your scoping letter.

Response: Rate of spread is only one measure of the intensity of a wildland fire; a faster rate of spread does not necessarily result in a greater risk of a high severity crown fire taking place. Even with faster spread rates due to thinning activities, the



benefit of fuel management would be seen in reduced fire damage to the forest with lower mortality in mature trees and less duff consumption. The proposed fuels reduction included in this project consists of a combination of surface fuel reduction and removal of trees. This includes treatment of unacceptable levels of slash that result from fuels reduction in those strategic areas near high values at risk. From a suppression standpoint, grass fires (i.e. treated areas), for example, are easier to control than timber types (i.e. untreated areas) because of lower intensities and reduced spotting.

12. Public Concern: Prescribed fire is a great tool to open up areas dominated by trees in order to increase diversity, or to increase available browse where it is lacking. Neither appear to be the case in the project area.

Response: Prescribed fire use without timber harvest is proposed to reduce high fuel loads and alter the composition and structure of forested stands in areas that are not conducive to mechanical or hand type treatments. Prescribed fire would also reduce areas with high concentrations of ground fuels and low- and mid-level shade tolerant trees that act as ladder fuels, thus lowering intensity and severity of future unplanned wildfires.

13. Public Concern: The discussion in your mailer confirms what is obvious on the map, that without proactive forest health and fuel management, fire has and will continue to manage the vegetation in Griffin Creek. It is disingenuous to proclaim that “Fire suppression since the 1940s has altered the normal disturbance regime and allowed an accumulation of ground and ladder fuels on the landscape.” The lack of forest management that allowed fuel accumulation to reach current conditions is more to blame than fire suppression. If the area has been managed for timber production and multiple uses as prescribed by past and existing plans the fuel accumulation would not have been “allowed”. What is the record of fuel treatments in the Griffin Creek drainage over the past 25 years compared to what was desired to achieve in the previous timber management plan and the current Forest Plan? The monitoring of past fires, timber management and fuel treatments should be disclosed to the public rather than blaming mother nature and fire suppression.

Response: The Flathead Forest Plan was approved in 1986 and is therefore the only forest-level planning document in use for the past 25 years. This plan does not address forest fuels management specifically, but does discuss vegetation and timber treatments that have an effect on the wildland fire and fuel conditions. As Table 3-2 of this EA displays, approximately 13,639 acres of timber treatments have been accomplished in the past three decades. This is 36 percent of the Griffin Creek drainage on NFS lands. The Forest Plan does not have a desired future condition for planning units as small as the Griffin Creek drainage so a comparison of accomplishments versus Forest Plan goals and objectives is not possible. A discussion of the monitoring of past fires, timber management, and fuel treatments is disclosed in the response to Concern #28 below. A comprehensive discussion of



fuel accumulation and the effects of fire suppression can be found in the Fire and Fuels section of Chapter 3.

14. Public Concern: No map of existing fuel hazard classification or stand types depicted in your mailer is provided.

Response: Maps of current vegetation types, fire regime, condition class, and fuel models of pre and post treatment were used in the analysis and to help better strategically locate treatment types. These maps are located in the project file.

15. Public Concern: No strategic fuel breaks are evident or described in this proposed action. A competent fuel break would provide continuity perpendicular to the prevailing wind and provide firefighters a place to control the fire. Scattered treatment units surrounded by high hazard fuel are of little value in stopping a major fire as the fire simply burns around the unit.

Response: While wind is a major factor in where to locate treatment units, the alignment of fuels and topography must be taken into account in fragmenting major pathways for fire to travel. Patterns of disconnected fuel treatment patches that overlap in the heading fire spread direction have been shown to be effective in changing forward fire spread (Finney 2000).

16. Public Concern: The Flathead NF fails to use best available science to evaluate the most serious threat to communities and the environment. Landscape scale continuous fuel treatments should be evaluated on the entire east facing slopes of Squaw Meadows Creek, another on the east slopes of Meadow Creek and another on the entire east hydrologic divide of Griffin Creek.

Response: The FNF strives to use the best available science in our project planning efforts. The comment letter did not suggest or provide any scientific literature that may have been beneficial to the planning team. Please see the responses to #15 and #17 above regarding the use of continuous fuel breaks. Meadow Creek is located in the Logan Creek drainage which is not part of this planning effort. The other suggested areas for fuel treatments we agree are strategically located to reduce the intensity of large-scale wildland fire. Several fuel treatments, both mechanical and prescribed burning, are part of the action alternatives. Treating all fuels across an entire landscape is impractical due to limited funding, inadequate road access, and variable land ownership. Management activities are also not solely fire driven, but on a landscape scale arranged to satisfy other needs such as, but not limited to, timber harvest, water quality, and wildlife issues.

17. Public Concern: The Proposed Action appears inadequate to stop the development and run of another Little Wolf or Brush Creek fire. The Flathead has actually been lucky that a major wind event such as the 1910 or 1988 events have not occurred with the big fires of the last decade. Fuel breaks should be designed to stop a crown fire with 40-50 mile and hour winds.

Response: Fuel breaks are not designed to stop fire but to alter fire behavior to either minimize mortality to live trees, or help ground crews suppress a fire. While fuel breaks are also designed to inhibit both ground to crown fire initiation as well active



crown fire moving into the treated areas under 90 to 97 percentile weather conditions, designing fuel breaks for a very small percentage of weather conditions (i.e. 50-60 mph winds) is impractical and unrealistic due to other management activities that are not solely driven by fire. Fuel breaks also have limited effect on spotting, which usually is a major factor in large fire spread under extreme weather scenarios.

18. Public Concern: Please see Ament (1997) as comments on this proposal, in terms of fire policy and Forest Planning.

Response: This article advocates a change to the prescribed fire and prescribed natural fire polices of government agencies as well as vegetative manipulation as a means of influencing fire behavior. Much of the prescribed fire without timber harvest proposed is to change fire behavior around critical infrastructure sites that could not be otherwise treated by mechanical means (e.g. radio repeater sites). While it is agreed that prescribed fire does have benefit of reducing fire behavior around private structures, the risk has been determined to be high when compared to other treatments. The Griffin Creek action alternatives call for mechanical treatment on Forest Service lands in juxtaposition of private. Residual fuels are then piled and burned in late fall when chance of fire spread is low.

Fisheries 19. Public Concern: We request a careful analysis of the impacts to fisheries and water quality, including considerations of sedimentation, increases in peak flow, channel stability, risk of rain-on-snow events, and increases in stream water temperature.

Response: The fisheries section includes careful consideration of sedimentation, channel shape dimensions (which are a function of stream flows and stream bank stability), and also water temperatures. Past, present and reasonably foreseeable actions that impact these habitat features, as well as the potential impacts from the project, are disclosed.

20. Public Concern: Please disclose in the NEPA document the results of up-to-date monitoring of fish habitat and watershed conditions and how this project will affect the fish in the project area.

Response: The description of the existing condition of fisheries resources includes summary descriptions, charts, graphs and example photographs of fish habitat conditions in the Griffin Creek analysis areas since 1979. This information was then utilized to understand and describe the role of past land management activities. The fisheries section discloses the direct and indirect effects of this project on fish and fish habitat.

21. Public Concern: With respect to the Griffin Creek project area, we hope the Flathead National Forest, through collaboration with FWP and others, will more directly address the conservation of a state species of special concern compared to the improvement of fish passage for an invasive, nonnative species which supports only a “light” fishery.



Response: The Flathead National Forest actively works to restore westslope cutthroat trout where possible and seeks to implement the goals of a statewide Memorandum of Understanding. Recent examples of collaboration to conserve cutthroat trout include Sanko Creek restoration, Upper Good Creek restoration, Sheppard Creek restoration, South Fork Flathead basin restoration, and the Swan Valley Native Fish Committee effort. Within the Griffin Creek project area, the Proposed Action includes measures that should help gradually improve habitat conditions for the cutthroat trout in Upper Griffin Creek. Montana FWP and the Flathead National Forest are developing a strategy for cutthroat trout conservation in the Stillwater River, which may or may not include Upper Griffin Creek. Until the genetic results are known, there are no plans to expand or translocate this population. Consideration was given whether Ingalls or “Yellow” Creek had any future potential for cutthroat trout translocation, but as disclosed in the analysis, this was found infeasible.

22. Public Concern: The MT AFS encourages the Flathead National Forest to collaborate with FWP and other partners to look for opportunities to implement the goals and objectives of the statewide, interagency cutthroat trout memorandum of understanding (MOU; Montana Cutthroat Trout Steering Committee 2007).

Response: See response to #21 above. 23. Public Concern: If opportunities do not occur to enhance the existing westslope cutthroat trout population, we would encourage the U.S. Forest Service to analyze the effects of any proposed actions that may affect the long-term maintenance of the existing westslope cutthroat trout population.

Response: The Fisheries section of Chapter 3 discloses the direct and indirect effects of the proposed action to the cutthroat trout population. A Biological Evaluation was also prepared that found the project “May impact individuals or habitat, but will not likely result in a trend towards federal listing or reduced viability for the population or species.” Although the alternatives are ultimately beneficial, they cannot be determined “beneficial” due to short-term sedimentation impacts and uncertainty if restoration efforts are fast enough and profound enough to improve viability.

Insects and Disease 24. Public Concern: I am in favor of being proactive in the face of the high pine beetle risk (especially in these stands that are mature and ripe for the beetle infestations).

Response: Thank you for your comment. 25. Public Concern: I encourage you to consider regeneration harvests in mixed conifer stands that have a high component of Douglas-Fir as well because of the increase in DF beetle activity after the recent fires.

Response: Between 1660 acres and 3452 acres are proposed for regeneration treatments, depending on the alternative selected. Approximately thirty percent of



those are in mixed conifer stands with a substantial Douglas-fir component. Please see the Forest Vegetation, Environmental Consequences section of Chapter 3 of this EA.

Logging Systems 26. Public Concern: I'm concerned with some units that have a large component of long dead and down LPP (from the last beetle outbreak that were not harvested). It may be too late to go after those now, especially considering our current lack of stable pulp and firewood markets. Flexibility needs to be written into the prescriptions and contracts to allow some room to maneuver.

Response: Unit specific prescriptions will be written to address the desired future condition of the unit. Some units in the proposed action have large amounts of dead and downed LP as a result of the MPB outbreak in the 1980s. MPB is currently active in the Griffin area, so the amount of standing dead lodgepole pine can be expected to increase as a result. However, stands were generally not proposed if they had high densities of standing dead and low densities of live lodgepole pine. Market conditions at the time of project implementation are equated as part of the standard sale or project appraisal process. Flexibility to utilize or treat non-saw material will be considered in the determination of which project contract to use.

27. Public Concern: Sawlog top size should be no less than 4.6" DIB and 5.6" on PP, WWP, and WRC. Vista's should not have had a 4" spec on the LLP, no sawlog processing facility can utilize that.

Response: Sawlog top size will be evaluated at the time of project implementation, but will not be less than 4.6” DIB.

Monitoring 28. Public Concern: For every project proposal, it is important that the results of past monitoring be incorporated into planning. All Interdisciplinary Team Members should be familiar with the results of all past monitoring pertinent to the project area, and any deficiencies of monitoring that have been previously committed to. For that reason, we expect that the following be included in the NEPA documents or project files: • A list of all past projects (completed or ongoing) implemented in the proposed project area

watersheds. • The results of all monitoring done in the project area as committed to in the NEPA

documents of those past projects. • The results of all monitoring done in the proposed project area as a part of the Forest Plan

monitoring and evaluation effort. • A description of any monitoring, specified in those past project NEPA documents or the

Forest Plan for proposed project area, which has yet to be gathered and/or reported.

Response: An effort was made at the beginning of the project to locate planning documents and monitoring reports from past vegetation management projects in the



vicinity of the project area. Prior to the Flathead Forest Plan of 1986, project monitoring plans were uncommon and none were prepared for any projects in this project area. Since implementation of the Forest Plan, three Decision Notices and two Records of Decision with monitoring plans have been authorized and implemented:

› Little Wolf Salvage and Rehabilitation Project (1995) › Spruce Beetle Control Project (1996) › Sheppard Griffin Salvage and Rehabilitation Project (1996) › Tansy Ragwort Control Project (1997) › Sheppard Creek Post-Fire Project (2008)

Exhibit U contains copies of monitoring reports created as a result of monitoring plans outlined in the above listed projects. These reports were made available to the ID Team for use while designing the proposed action and conducting resource analysis of the alternatives. Exhibit U-3 lists the names of the timber sales, the year the sale was completed, and the acres of timber harvest in the project area since implementation of the Forest Plan. Forest Plan monitoring requirements are organized as 63 distinct items. Each item, such as recreation use (Item #1) or cultural resource protection (Item #2), are reported as forest-level statistics. Individual data for these statistics may have been collected from activities in the Griffin Creek project area, but were not reported at the project level. Any monitoring data collected from the project area from individual project monitoring plans and then used in Forest Plan monitoring reports are shown in Exhibit U. All of the monitoring for the above listed projects has been completed with the exception of timber sale related activities in the Sheppard Creek Post-Fire Project area, such as timber harvest monitoring, reforestation monitoring, Best Management Practices monitoring, and post-harvest surveys. A very small portion of the Sheppard Creek project was located in the Griffin Creek drainage. These monitoring activities will be completed as the timber sale harvests are completed.

29. Public Concern: Please disclose if the FS has performed all of the monitoring and mitigation required or recommended in any NEPA documents, and the results of the monitoring.

Response: Please see the response to #28 above. Old Growth 30. Public Concern: The FS must disclose its transparent, well thought-out long-term strategy for old-growth associated wildlife species viability in a properly-defined cumulative effects analysis area.



Response: Amendment 21 to the Flathead’s Forest Plan, its EIS, and project file exhibits provide a transparent and well thought-out long-term strategy for the viability of old growth associated species. The consistency of this project to the direction provided by the Forest Plan strategy is provided in Exhibits Q-10 and Rg-1, and in the EA in the Regulatory Framework and Consistency portion of the Chapter 3 section on “Old Growth Habitat.” The rationale for selecting the cumulative effects analysis area for old growth habitat for this project is described in the Analysis Area portion of the Chapter 3 section on “Old Growth Habitat” and in Exhibit Q-8 (Cumulative Effects Considerations for Old Growth). Also see Exhibit Q-4 for Flathead National Forest status and management strategies for old growth associated wildlife.

31. Public Concern: For the Flathead National Forest (FNF), sensitive old-growth dependent species include the northern goshawk and flammulated owl. According to official FS policy, the FNF “must develop conservation strategies for those sensitive species whose continued existence may be negatively affected by the forest plan or a proposed project.”

Response: See Exhibit Rs-20, Conservation Assessment of the Northern Goshawk, Black-backed Woodpecker, Flammulated Owl, and Pileated Woodpecker in the Northern Region, USDA Forest Service. See also Exhibit Rg-1 for the Flathead National Forest evaluation and compliance with NFMA requirements to provide for diversity of animal communities. The northern goshawk is not a sensitive wildlife species on the Flathead National Forest.

32. Public Concern: Please demonstrate that this project will leave enough snags to follow the Forest Plan requirements and the requirements of sensitive old growth species such as flammulated owls and goshawks. Loggers are required to follow OSHA safety standards. Will these standards require snags to be cut down? After snags are cut down for safety for OSHA requirements will there still be enough snags left for old growth sensitive species?

Response: The proposed prescriptions have been used for snag retention in these forest types and have resulted in the meeting or exceeding of snag standards in Flathead National Forest’s Forest Plan Amendment 21. See Exhibit Rd-5 for the snag and downed woody material habitat prescriptions and rationale, as well as “Non-Game Wildlife Habitat” in the Wildlife section of the Features Common to Action Alternatives in Chapter 2 of the EA. See Exhibit Q-10, which includes consistency with Forest Plan Amendment 21 direction. See Rd-3 for the snag and downed woody material habitat and effects analysis. See Rd-10 for post-activity monitoring for downed-wood and snags. For analyses of unharvested and unburned mid- and late-seral/structural forests and old growth habitats, see the sections on “Snags and Downed Wood Habitat” and “Old Growth Habitat” in Chapter 3 of the EA. All snags felled for safety concerns must be left on site.

33. Public Concern: Please disclose how stands to be treated compare to Forest Plan or Regional old-growth criteria. In order to disclose such information, please provide all the details, in plain language, of these areas’ forest characteristics (the various tree components’ species, age and diameter of the various tree components, canopy closure, snag density by size class, amounts of down logs, understory composition, etc.).



Response: As described in the “Old Growth Habitat” section of Chapter 3 of the EA, “Old-Growth Forest Types of the Western Montana Zone” were used as the criteria to identify stands that qualify as old growth habitat (Green, et al. 1992 [updated 2005]; Exhibits Q-1, Q-2, and Q-5). Exhibit Q-2 describes the process used for the Griffin Creek project to identify old growth habitat and stands approaching old growth habitat. Because this screening process incorporated double and triple checking through a variety of information sources, not all stands proposed for treatment needed to be surveyed for old growth habitat on the ground. See exhibit Q-2 for all stands that had new old growth field surveys or a closer look. This includes information about tree species, ages, and diameters, and stand canopy closure, understory composition, and average tree and snag densities. See exhibit P-3 and P-4 for stand examination, treatment diagnosis, and silviculture field visit notes.

34. Public Concern: There are Forest Plan standards for old growth but nothing is said about old growth’s status so the reader cannot know if the Proposed Action should include actions to move toward FP standards or other management actions needed.

Response: The status of old growth habitat in the Griffin Creek drainage is described in narrative, map, and photographs in the Affected Environment part of the "Old Growth Habitat" section in Chapter 3. As described in the Environmental Consequences portion of that section of the EA, Alternatives B and D propose timber harvest in known and suspected old growth habitat. As stated in the EA, “the proposed shelterwood and seed tree harvest would negate most old growth habitat values in these stands,” and the proposed unit numbers are provided. These effects are detailed in Exhibit Q-7. In addition, as stated in the EA and detailed in Exhibit Q-7, understory fuel reduction in 53 acres of existing old growth habitat would not be expected to retain all old growth habitat values in Alternatives B and D. However, reducing this to 14 acres of hand thinning along a narrow edge of the stand and along the wide road-cut through the stand would be expected to retain all old growth habitat values, particularly when one considers that this narrow zone already has edge effects from the clearing on private land and from the road. No other known or suspected old growth habitat would have vegetation management.

Other 35. Public Concern: The Forest Service must complete a full environmental impact statement (EIS) for this Project because the scope of the Project will likely have a significant individual and cumulative impact on the environment.

Response: An EA was determined to be the most appropriate level of analysis for this project. The proposed action was evaluated against the ten steps of significance as outlined in 40 CFR 1508.27 for both context and intensity. None of the ten steps was determined by the Deciding Official to be significant in the Griffin Creek project area and therefore an EIS was not necessary. ID Team members analyzed individual and cumulative resource effects to the extent necessary. A Finding of No Significant Impact (FONSI) will be prepared and presented with the Decision Notice.



36. Public Concern: Please disclose the names of all other past projects (implemented during the life of the Forest Plan) whose analysis area(s) encompass the areas to be “treated” under this proposal.

Response: Please see the response to #28 above. 37. Public Concern: Please utilize the NEPA process to clarify any roadless boundary issues. It is not adequate to merely accept previous, often arbitrary roadless inventories—unroaded areas adjacent to inventoried areas were often left out. Additionally, there is a lot of public support for adding unroaded areas as small as 1,000 acres in size to the roadless inventory.

Response: There are no Inventoried Roadless Areas in or near the Griffin Creek project area. The Griffin Creek landscape does not contain any areas that exhibit unroaded characteristics of greater than 1000 acres in size.

38. Public Concern: The project looks like a good one, thoughtful, well planned, something that is needed.

Response: Thank you for your comment. 39. Public Concern: I also ask that future proposals such as this include a recent satellite image of the area, with the individual prescribed units outlined, so that all readers can better ascertain the potential cumulative effects of the proposed treatments.

Response: A large-format satellite image of the project area with units displayed was available at the open house hosted by the ID Team in April, 2010. Such an image is difficult to interpret when displayed in the 11” by 17” format necessary for our mailings and as such was not included in the mailing for the project scoping. Google Earth™ is a very useful tool available free of charge to computer users with an internet connection. An image with the individual prescribed units outlined is posted on the Flathead National Forest’s project planning web site under the Griffin Creek project: http://www.fs.usda.gov/goto/flathead/projects

40. Public Concern: For many years, Montanans For Multiple Use (MFMU) has advocated for public participation in Forest planning and management in a more informal and personal collaborative format so there is more public ownership and support of a proposed action before the formal NEPA process begins (see attached MFMU 2001 letter to Forest Supervisor). As a minimum, development of proposed actions should be coordinated with local, state, and tribal governments that may be affected as required by the National Forest Management Act (NFMA) before it is announced to the public to begin a formal NEPA process.

Response: The Flathead National Forest complies with all appropriate NFMA and NEPA requirements with respect to its public involvement. The FNF does coordinate our activities with local, state, and tribal governments as well as other federal agencies.

http://www.fs.usda.gov/goto/flathead/projects



41. Public Concern: MFMU is not aware that any comment or suggestion from MFMU or any one else has made any significant difference in Flathead National Forest plans, proposals, or decisions in the last 15 years. We are also unaware of any significant change to any decision as a result of appeals. This record is not one that supports public participation is of any meaningful value on the Flathead National Forest.

Response: Public participation is extremely meaningful on the Flathead National Forest. All comments are considered in the scoping process and in making the final decision on a particular project. We are obviously not able to implement every comment or suggestion we receive as many comments are contradicted by other commenters. The scoping letter submitted by Montanans for Multiple Use on April 15, 2010 contained twelve different comments, as identified by the ID Team. Each of these comments was assigned a category as to how they were used by the ID Team in the formulation of the EA (Exhibit E-11). Some of the comments were outside the scope of the project as they were not connected to the proposed action or needed to be addressed at the Forest Plan level. The majority of the comments, however, were useful to the team as they influenced project design criteria, were addressed by measuring the effects of different alternatives, or were used to develop alternatives to the proposed action. For example: the comment related to the use of temporary versus permanent roads (#56 below) was incorporated into Alternative D.

42. Public Concern: No map or inventory of the existing conditions. When there is no disclosure of where and what extent extreme fire hazard (such as photo 1 in your mailing) exists, it is really not possible for the public to make substantive comments on the competence and reasonableness the proposed treatments.

Response: This type of information was provided on large-format maps at the open house hosted by the ID Team in April, 2010. The level of detail necessary to make informed interpretations would not be possible on the smaller size of maps that can be mailed in large quantities. Maps displaying vegetative and fuel conditions are located in project file exhibits available for review at the Tally Lake Ranger District office in Kalispell.

43. Public Concern: No information is provided regarding Forest Plan Goals, Objectives, and Management Direction for the area.

Response: This information was inadvertently omitted from the public scoping documentation for the Proposed Action presented in March, 2010. Scoping documentation in future projects on the Tally Lake Ranger District will contain Forest Plan goals, objectives, and management area direction. This information for the Griffin Creek project is located in Appendix B.

44. Public Concern: We are encouraged to see a mix of resource activities appearing in the Purpose and Need and not so narrowly focused on timber and fuels management.

Response: Thank you for your comment.



45. Public Concern: Where will money come from to accomplish fish, wildlife, and watershed proposals and when would they be accomplished? The non timber or fire proposals should be as certain of accomplishment and in the same time frame as the timber and fire management portions of the Proposed Action.

Response: Some of the proposed activities, such as culvert upgrades and wildlife habitat improvement, may be accomplished with Congressionally appropriated funds that are dispersed on an annual basis. Other funding mechanisms involve cooperative projects with other government agencies such as the Montana Department of Fish, Wildlife, and Parks or grants from non-profit organizations such as the Rocky Mountain Elk Foundation. Volunteer groups provide valuable labor, particularly with trail maintenance. The certainty of funding for any activity on National Forest System land cannot be assured, however our experience in the past is that well-managed programs will eventually get accomplished. The time frames for accomplishing all of the proposed activities, including vegetation and fuels projects, is the four to six years after the Responsible Official selects an alternative. Some projects not connected to other aspects of the Selected Alternative could be accomplished immediately, such as the opening of the Hand Creek road system to seasonal motorized use. Others may need to wait for accomplishment of another activity, such as the harvest of Unit 73 before the restoration of Trail 211.

46. Public Concern: The upcoming NEPA document must specify and disclose how the project will be consistent with NFMA and its implementing regulations, and must disclose under which set of NFMA and other procedural regulations the project would be analyzed and implemented.

Response: If an action alternative is selected, the Decision Notice and Finding of No Significant Impact will document in the “Findings Required by Law, Regulation, and Agency Policy” section the Griffin Creek Project’s consistency with the National Forest Management Act. Each resource section in Chapter 3 of this EA also discusses regulatory consistency. Please also see the response to #47 below for further information on NFMA consistency.

47. Public Concern: The Forest Service cannot legally implement a project under the 2000 regulations because the Ninth Circuit has held that the agency violated NEPA in promulgating the 2000 regulations and the Forest Service itself determined that the 2000 regulations are unworkable and has formally removed them in their entirety through the federal register. The Forest Service cannot legally implement simply the “transition provision” of the 2000 regulations because Congress directed the agency to have in place a comprehensive set of NFMA regulations that satisfy the explicit statutory requirements, and the Forest Service has never prepared a NEPA analysis, or consulted under Section 7 of the ESA, to assess the long-term implementation of solely the transition provision of the 2000 regulations. The Forest Service’s June 15, 2009 decision to reinstate the 2000 regulations transition provision is illegal at least because the directive was not subject to APA notice and comment rulemaking, and the Forest Service did not comply with NEPA procedures or the ESA consultation requirements prior to issuing this directive.

Response: At present the agency is considering options for its land management planning regulation. In the meantime, we are currently operating under the 2000



Planning rule as amended. These were the last regulations in place before the 2008 rule (1570/1920 WO memo, July 15, 2009). In any event, the Griffin Creek Project is consistent with both the 2000 regulations as clarified by the 2004 interpretive rule as well as the 1982 regulations under which the Forest Plan was developed because it considered the best available science in the development of the EA. The project is also consistent with any applicable provisions of the 1982 regulations because it was determined to be consistent with the Flathead Forest Plan, including the viability provisions of the Forest Plan, which was developed under the 1982 regulations.

48. Public Concern: I wish that we, the public, were given more time to make comments.

Response: We believe we have allowed adequate time for public involvement. The District Ranger and Forest Supervisor would seriously consider providing more time for public comment if such a request was made during the established comment periods. Please refer to the Public Participation section of Chapter 1 for a discussion of public involvement.

Recreation 49. Public Concern: The Proposed Action should include a plan to specifically address this illegal ORV use and the resource damage.

Response: Two Griffin Creek project action alternatives propose the closure and rehabilitation of a user-maintained trail section. Illegal use of Forest roads and trails has been and will continue to be an issue. District recreation staff will be monitoring all recreation use patterns on National Forest System land to determine where the illegal use is occurring and will take appropriate action to limit the resource impacts. Please see the Monitoring section of Chapter 2. National Forest law enforcement efforts will also continue.

50. Public Concern: The Sanders Mtn Trail #172 is a mess given the fire. I strongly agree with the need to re-open it and clear it. It's northward extension up to Brush Divide is in bad need of work and I would like to see a proposal to re-open that historical trail as well.

Response: This non-motorized system trail has received very limited Forest Service maintenance over the past decade due to budget constraints; however, portions of the trail have been kept in a passable condition by users. About half of this trail is located on the western side of the divide between the Kootenai National Forest and the Flathead National Forest. Sections of this trail have been recently relocated using modern mapping techniques. Efforts to restore the trail all the way to the Brush Creek divide will be made given funding availability and/or the willingness of volunteer organizations to contribute.



51. Public Concern: I strongly agree with restoring the McGovern Creek trail. It is actually open but needs trail signage and some clearing. In the area that goes through Plum Cr. Lands, there is a lot of blowdown and forest debris as well as poor signage.

Response: Restoring the McGovern Creek Historical Trail #211 to Forest Service standards for signage, drainage, and clearing is a component of two of the action alternatives. The Forest Service would work cooperatively with the Plum Creek Timber Company if the restoration of this trail is selected for implementation.

52. Public Concern: Where the trail reaches Rd 10306, there is a trail which continues all the way back to Lupine Lake Trail 210, much along old road but some along the best mountain biking trail in the district. I strongly support making this an official trail. It joins Trail #210 just above where 210 crosses Griffin Creek.

Response: This trail is referred to as the Pine Grass Historical Trail #287 and is proposed for restoration in two of the action alternatives (B and D). However, a 0.8 mile section of trail that connects with Road 10306 has been receiving damage to a wetland area. This segment of the trail is proposed to be closed and rehabilitated. Please refer to Chapter 2 for a description of the proposed activities associated with these sections of trails.

53. Public Concern: Additionally, there is an historic trail which remains clearly visible near this junction which travels north to eventually join Griffin Creek at or near the junction with Trail 480. I strongly support re-opening this historical trail, which has been shown on older Forest Service maps.

Response: A review of historical maps from the 1950s, 1960s, and 1970s located in the Flathead National Forest Supervisor’s Office indicated the trail referred to in the comment could be the trail used prior to the construction of the current Griffin Creek Road 538. This trail is no longer on the Forest’s trail system and has not been located by District recreation staff members. At this time, there are no plans to re-open this trail.

54. Public Concern: Trails 800 and the southern portion of Trail 289 are in need of trail work.

Response: Thank you for this information. Maintenance of these trails is dependent on funding availability and/or the willingness of volunteer organizations to contribute.

Access Management 55. Public Concern: Any desire to keep a road in the project area WUI must be in harmony with the alleged priority goals (again, to reduce the chances that fire will destroy private structures and harm people), not driven by timber production goals. The analysis must show how all roads will in fact be in harmony with the priority goals.

Response: The Travel Analysis documentation in Exhibit M is a complete inventory of all existing roads in the Griffin Creek drainage. An interdisciplinary approach was used to assess the use and need for each of these roads. Exhibit M-1 shows the



resource objectives for each road, including the need for fire suppression access in the Wildland Urban Interface.

56. Public Concern: Using mostly temporary roads to manage productive timber lands in Griffin Creek violates the Forest Plan and common sense. What is the reason that roads needed to treat the proposed units must be obliterated at great cost to taxpayers and the environment? This “temporary” short–term management dogma only produces massive costs to the environment and economy.

Response: Alternative D was designed to investigate the use of mostly permanent roads instead of temporary roads. The Proposed Action (Alternative B) proposes 20.5 total miles of temporary road and 2.8 total miles of permanent road. Alternative D proposes 16.6 total miles of temporary road and 1.0 mile of permanent road.

57. Public Concern: It also appears the proposed action maps do not show all the existing roads, as there is roads shown on Plum Creek Sec. 19 T29N, R24W that have no connection to an arterial. How does Plum Creek get to their land?

Response: Roads located on Plum Creek Timber Company lands were inadvertently left off the proposed action maps. These roads are now displayed on the maps in this EA.

58. Public Concern: The area is already well roaded and motorized. No new permanent road construction should be seriously considered.

Response: New permanent road construction is a component of each of the action alternatives. The Travel Analysis process has been utilized for this project and can be found at Exhibit M in the project file. The Travel Analysis identified areas of National Forest System land that could require vehicular access for resource management for the Griffin Creek Project and in the future. Temporary road construction may not be the best choice in all cases when a road in the future may need to be constructed in the same location.

59. Public Concern: How will temporary road construction be rehabilitated?

Response: All temporary roads used for timber harvest would be reclaimed immediately after mechanical or broadcast burning slash reduction activities are complete. Exceptions for Alternative B are Roads K, S, 911B, 9630, and 9641 and for Alternative C are Roads S, 9630, and 9641; which would remain open until planting operations are complete. Reclamation would consist of removal of any culverts, installation of erosion control features, re-contouring the slope for newly constructed temporary roads, and revegetating the disturbed area with native grasses, shrubs, and trees.

60. Public Concern: More road decommissioning should be added to improve long-term water quality.

Response: The Sheppard Griffin Salvage and Rehabilitation Project Decision Notice of 1996 authorized 18.9 miles of road decommissioning in the Griffin Creek drainage.



The roads to decommission were selected after a careful review of the future transportation needs in the area. The remaining open roads were determined to be essential for the resource management of the area. A review of the transportation system (Exhibit M) determined no additional roads could be identified for decommissioning during the Griffin Creek Project.

Soils 61. Public Concern: Please provide estimates of current detrimental disturbance in all previously established activity areas in the watersheds affected by the proposal.

Response: The analysis area forms the boundary for the direct, indirect, and the cumulative effects soil analysis. This area consists of the proposed treatment units and temporary roads for the Griffin Creek Resource Management Project. This analysis area was selected because that is where the effects of implementing the proposed activities would occur. The effects on soils would not extend beyond the harvest, thinning, or prescribed burn units proposed for treatment. Effects to the watershed resource as a whole are discussed in the Water Resources section. Measurements of the current detrimental disturbance for those areas proposed for mechanical treatments in the action alternatives are found in first table of the Soils section of Chapter 3.

62. Public Concern: Please disclose the link between current and cumulative soil disturbance in project area watersheds to the current and cumulative impacts on water quantity and quality.

Response: Selecting geographical boundaries for soil disturbance analysis involves several factors, including the scope of the project considered and the features of the land. Evaluation of cumulative effects to soil productivity does not require an integrated, watershed level assessment since that is not considered an appropriate geographic area. Assessment of soil quality within too large an area can mask or dilute site-specific effects. The analysis area for direct, indirect, and cumulative effects on soil resources encompasses all land within individual treatment areas, landings, and temporary roads. Existing National Forest system roads and trails are considered dedicated lands for other purposes and, as such, soil quality standards do not apply. Current and cumulative soil disturbance in affected activity areas is disclosed in the Soil section of Chapter 3. Project effects to water quantity and quality are discussed in the Water Resources section of Chapter 3.

63. Public Concern: The EIS must cite the results of soil productivity monitoring. The EIS must deal with the very basic question: What are the quantitative effects of management activities on the productivity of the land?

Response: Soil quality monitoring has been conducted on 52 sales on the Flathead National Forest since 1984; 34 of those sales were located on the Tally Lake District. Monitoring results from other districts are used to interpolate results on the Tally



Lake District if they occur on similar landtypes and soils. The information gathered during monitoring is the main basis for determining effects from past activities. Timber harvest soil monitoring reports are located in the Project Record (I-5 through I-15).

64. Public Concern: Please disclose how the proposed “treatments” would be consistent with Graham, et al., 1994 recommendations for fine and coarse woody debris, a necessary consideration for sustaining long-term soil productivity.

Response: Graham et al. 1994 refined the recommendations for coarse woody debris found in Harvey et al. 1981 where the material was related to occurrence of ectomychorrhizal fungi, not to increased soil productivity. Coarse woody debris has no effect on soil nitrogen or other nutrients regardless of decay stage and it can compete with vegetation for limited nutrients through immobilization (Busse 1994, Prescott and Laiho 2002). Specific direction for coarse woody debris is provided by Forest Plan Amendment 21. All alternatives would comply with this standard for downed wood. Coarse woody debris (tons/acre) is specified by potential vegetation group as follows:

Potential Vegetation Group Tons/Acre Range Dry 4-12

Moist 8-21 Cold 7-20

Vegetation 65. Public Concern: What surveys have been conducted to determine presence and abundance of whitebark pine re-generation?

Response: Stand examinations, regeneration exams, and general observations by certified silviculturists have been conducted in the Griffin Creek area since about 1970. No whitebark pine trees have been found in any of these surveys.

66. Public Concern: If whitebark pine seedlings and saplings are present, what measures will be taken to protect them?

Response: Whitebark pine are not present in the project area.

67. Public Concern: Please include an alternative that excludes burning in the presence of whitebark pine regeneration (consider ‘Daylighting’ seedlings and saplings as an alternative restoration method).

Response: Whitebark pine are not present in the project area.



68. Public Concern: Will restoration efforts include planting whitebark pine? Will planted seedling be of rust-resistant stock? Is rust resistant stock available? Would enough seedlings be planted to replace whitebark pine lost to fire activities?

Response: Whitebark pine does not grow naturally in the project area and we have no plans to introduce it.

69. Public Concern: Have white pine blister rust surveys been accomplished? What is the severity of white pine blister rust in proposed action areas?

Response: Surveys have not been conducted to specifically quantify the amount of white pine blister rust in western white pine in the project area. However, blister rust is recorded when found during stand examinations and regeneration surveys. As the number of large western white pine is very small and whitebark pine has not been observed, the number of blister rust recordings is too small to determine a meaningful severity rate.

70. Public Concern: Proposed activities could artificialize the forest ecosystem. Lodgepole pine is particularly subject to blowdown, once thinned. And any forest condition that is maintained through mechanical manipulation is not maintaining ecosystem function. The proposed management activities would not be integrated well with the processes that naturally shaped the ecosystem and resulted in a range of natural structural conditions. Thus, the need for standards guiding both the delineation of zones where artificializing fuel reduction actions may take place, and that also set snag and down woody debris retention amounts.

Response: Lodgepole pine is the dominant forest cover on over 60 percent of the Griffin Creek area (Exhibit P-8 and the Forest Vegetation, Cover Types section of Chapter 3 of this EA). Many lodgepole pine stands in the area were precommercially or commercially thinned in the past. Those stands have remained intact and grown much larger trees than adjacent, unthinned stands. Most of the proposed treatments in lodgepole pine stands are regeneration harvests because those stands are close to 100 years old, are moderately to highly susceptible to mountain pine beetles, would not respond to thinning, and may be prone to blowdown if thinned. Guidance for managing forest vegetation through timber harvest and prescribed burning is provided in the Flathead National Forest Plan, Forest Service Handbooks and Manuals, and other laws and regulations. Direction specific to the Griffin Creek proposals are summarized in the Forest Vegetation, Regulatory Framework section of Chapter 3 of this EA. Standards for snag and down wood retention are summarized in the Snags and Down Wood, Regulatory Framework section of Chapter 3.

71. Public Concern: We both question the volume of clear cutting proposed. Why clear cutting rather than some less intense treatment?....Please explain the circumstances supporting each clear cut determination.

Response: The clearcut regeneration method is used when there are few or no desired trees to leave to meet management objectives. In the Griffin Creek area, the proposed clearcut units are in lodgepole pine stands that are about 100 years old, moderately to highly susceptible to mountain pine beetles, would not respond with positive growth to thinning, and may be prone to blowdown if thinned. Many also



have dwarf mistletoe infections that would be passed to the regenerating lodgepole pine trees. Some lodgepole pine stands are proposed for commercial thinning where the trees are still vigorous and healthy. The site specific prescriptions for the clearcut units would require leaving all or most of the other species in the overstory, especially larch, Douglas-fir, ponderosa pine (if any), and white pine. See the Forest Vegetation section of Chapter 3 and Exhibit P-5 for more detailed information.

72. Public Concern: We see no shortage of recent clearcuts in this area, and cannot fathom why anything close to the proposed 3,500 acres of new “regeneration” logging is moving this area to a “desired condition.”

Response: The desired condition includes a landscape mosaic of various forest stand sizes, ages, and species; fuel levels and distributions that allow for safe and effective fire suppression; functional wildlife habitat and security for the many species that use the area; high water quality; stream and wetland function for aquatic species and wetland ecology; and opportunities for camping, trail use, and other recreational activities. For the Griffin Creek project, the “desired condition” is not the same as the “historical condition.” However, estimating and comparing the historical condition with the current and proposed future conditions provides perspective to see if ecosystem processes can continue to function. As stated in the Forest Vegetation section of Chapter 3 of this EA, “Under natural disturbance regimes (mainly large-scale fire), at any point in time the amount of area in a seedling or sapling stage of forest development could range from about 5 to 70 percent. The historic mean is about 20 percent. Currently, the seedling and sapling classes cover about 54 percent of the Griffin Creek area. This is near the high end of the historical range of variation because of recent large wildfires, bark beetle mortality, and subsequent timber harvest that occurred over the last four decades.” After implementation of the project, about 60 percent of area would be in the seedling/sapling size class, still within the historical range of variation. See Chapter 1 for more detail on the desired condition and purpose and need for the project. See the Forest Vegetation section of Chapter 3 and Exhibit P-11 for more information on the historic range of variation.

Water 73. Public Concern: We request the FS design a restoration/access management plan for project area streams that will achieve recovery goals.

Response: Access needs were thoroughly assessed in the Travel Analysis document (Exhibit M-1) for the long term and short term. Resource enhancement projects are included in the action alternatives to help move the streams toward an improved condition.

74. Public Concern: Please disclose the locations of seeps, springs, bogs and other sensitive wet areas, and the effects on these areas of the project activities.

Response: The number of seeps and springs vary from time of year and from one year to the next so it is not possible to capture that information in a meaningful way. Bogs



and other wet areas are not definitely mapped at this planning level, but will be avoided as the projects included in the Griffin Creek Proposals are implemented on the ground.

75. Public Concern: Where livestock are permitted to graze, we ask that you assess the present condition and continue to monitor the impacts of grazing activities upon vegetation diversity, soil compaction, stream bank stability and subsequent sedimentation.

Response: This process was thoroughly addressed in the Lemonade Springs/Island Meadows Range Allotments EA and Decision Notice of 2010 (Exhibit U-6). The findings in these documents are incorporated in the Water Resources analysis found in Chapter 3.

76. Public Concern: It is extremely important the FS disclose the environmental baseline for watersheds. Generally, this means their condition before development or resource exploitation was initiated. When such information is provided, comparison with the current conditions (after impacts of development) will aid in the assessment of cumulative effects of all alternatives.

Response: Information for past and predicted water yield is included in the Water Resource analysis.

77. Public Concern: Please disclose if there are any WQLS streams or TMDL streams in the project area.

Response: There are no WQLS streams or TMLD streams in the project area.

78. Public Concern: How much water yield recovery has occurred in the recent wildfires and how much will the proposed action harvests contribute to water yields and effects on streams? If the proposed timber harvests would increase water yields to the detriment of streams, then the extent of harvest should be scaled back to allow streams to function with acceptable water yield increases.

Response: The water yield and associated “Equivalent Clearcut Area” discussed in the Water Resource section includes the effects of all known wildfires. A great deal of effort was used to “re-grow” stands that have been burned in fires, with a reasonable estimate of the severity or percent of the stands that we burned.

79. Public Concern: Another concern we have includes the construction of several new roads in the Griffin Creek Project Area. In several cases, temporary roads constructed over historic roads either intersect with (e.g., Sec. 34 T29N R25W; Sec 31 T29N R25W) or run adjacent to (e.g., Sec 02 T28N R25W; Sec 20 T29N R25W; Sec 27 T29N R25W) the headwaters of Griffin Creek and other tributaries.

Response: Many of the roads that were “reclaimed” by removal of culverts and construction of drain dips were affecting hill slope hydrology due to undersized culverts and a lack of sufficient ditch relief culverts. When the Travel Analysis (Exhibit M-1) was complete it became apparent that many roads would be needed for ongoing and future management activities. New roads will meet the newest standards to minimize impacts to water resources with stream crossing size, increased ditch



drainage, and location considering filtration between the road and streams. In Alternative D, permanent roads are recommended instead of temporary roads to address concern about sequential installation then removal of culverts and the associated sediment that is inevitable with these activities.

80. Public Concern: Additionally, we would encourage the U.S. Forest Service to perform an adequate level of analysis of the foreseeable impacts to stream habitats and fishes and provide an account of planned mitigation measures.

Response: An analysis of the potential impacts to stream habitats and fish populations is found in the Fisheries, Water Resources, and Neotropical Migratory Birds and Riparian Habitat sections of Chapter 3. The design criteria for mitigating potential impacts can be found in the Features Common to all Action Alternatives section of Chapter 2.

Noxious Weeds 81. Public Concern: Please address the ecological, social and aesthetic impact of current noxious weed infestations within the project area. Include an analysis of the impact of the actions proposed by this project on the long and short term spread of current and new noxious weed infestations. What treatment methods will be used to address growing noxious weed problems? What noxious weeds are currently and historically found within the project area? Please include a map of current noxious weed infestations which includes knapweed, Saint Johnswort, cheat grass, bull thistle, Canada thistle, hawkweed, hound’s-tongue, oxeye daisy and all other Category 1, Category 2 and Category 3 weeds classified as noxious in the MONTANA COUNTY NOXIOUS WEED LIST.

Response: The Invasive Plant Species section in Chapter 3 addresses these concerns. Exhibit T-2 includes a map of current noxious weed infestations.

82. Public Concern: Are yellow and orange hawkweeds present within the project area?

Response: Yes. These hawkweeds account for the largest area of infestation of any invasive plant in the project area, with much more orange hawkweed present than yellow hawkweed.

83. Public Concern: Please address the cumulative, direct and indirect effects of the proposed project on weed introduction, spread and persistence that includes how weed infestations have been and will be influenced by the following management actions: road construction including new permanent and temporary roads, and skid trails proposed within this project; opening and decommissioning of roads represented on forest service maps; ground disturbance and traffic on forest service template roads, mining access routes, and private roads; removal of trees through commercial and pre-commercial logging and understory thinning; and prescribed burns.

Response: The Invasive Plant Species section in Chapter 3 addresses these concerns, with the exception of mining access routes (which are not a component of the action alternatives).



84. Public Concern: What open, gated, and decommissioned Forest Service roads within the project area proposed as haul routes have existent noxious weed populations and what methods will be used to assure that noxious weeds are not spread into the proposed action units?

Response: The Invasive Plant Species section in Chapter 3 addresses these concerns.

85. Public Concern: What commitment to a long-term, consistent strategy of application is being proposed for each weed infested area within the proposed action area? What long term monitoring of weed populations is proposed?

Response: The Forest weed program operates under the Flathead National Forest Noxious and Invasive Weed Control Decision Notice (2001). Management strategies are outlined in this document. The Forest weed program consists of prevention and control. Monitoring occurs on treated infestations to determine efficacy of the control measures.

86. Public Concern: What native plant restoration activities will be implemented in areas disturbed by the actions proposed in this project?

Response: There are proposals by the district fisheries biologist and the district wildlife biologist to plant shrubs in previously impacted areas. This includes native shrub species sourced from the Forest, which would be planted into wildlife openings and riparian areas. Please also see the response to Public Concern #87 below.

87. Public Concern: Will disturbed areas including road corridors, skid trails, and burn units be planted or reseeded with native plant species?

Response: Areas disturbed by machinery will be revegetated with an approved native grass mix. One of the main results of prescribed burning is a flush of native plant growth. Studies and observations have shown that revegetating burned areas is not necessary (Stella, K., C. Sieg and P. Fule. 2010); that there is minimal effectiveness of native and non-native seeding following three high-severity wildland fires (International Journal of Wildland Fire, Vol. 19, pp. 746–758).

88. Public Concern: Which units within the project area currently have no noxious weed populations within their boundaries?

Response: A map of infestations is included in the project record. Although surveys may not have found an infestation in a particular unit, that does not mean there are no weeds in that unit. Surveys are intuitive and focus primarily on rare plant habitat.

89. Public Concern: What minimum standards are in the Flathead National Forest Plan to address noxious weed infestations?

Response: The Forest Plan does not define any standards for noxious weeds. The Flathead Noxious and Invasive Weed Control Decision Notice (2001) defines weed program management on the Forest.



90. Public Concern: Please include an alternative in the DEIS that includes land management standards that will prevent new weed infestations by addressing the causes of weed infestation. The failure to include preventive standards violates NFMA because the Forest Service is not ensuring the protection of soils and native plant communities.

Response: Proactive prevention of weed infestations is included in all alternatives, including the No Action Alternative. These preventative measures would be incorporated into project implementation contracts if an action alternative is selected. The measures are presented in the Features Common to all Action Alternatives section of Chapter 2 and the Invasive Plant Species section in Chapter 3 discusses these measures.

91. Public Concern: Please disclose how the productivity of the land been affected in the project area and forestwide due to noxious weed infestations, and how that situation is expected to change in the coming years and decades.

Response: The Invasive Plant Species section in Chapter 3 addresses this concern. 92. Public Concern: Please disclose the results monitoring of weed treatments on the FNF that have been projected to significantly reduce noxious weed populations over time, or prevent spread. This is an ongoing issue of land productivity.

Response: Monitoring results of treated areas are entered into the FACTS database, and reports are periodically produced from the database to determine program efficacy. In general, monitoring has determined that biological control of tansy ragwort has drastically reduced existing infestations, as well as prevented a landscape scale infestation. Repeated roadside spraying has reduced many infestations along main roads, although with frequent public traffic, these areas will continue to need treatment. Many trails on the Forest that have been treated repeatedly have fewer infestations than when treatments first began.

Sensitive Species 93. Public Concern: What threatened, endangered, rare and sensitive plant species and habitat are located within the proposed project area?

Response: The Threatened and Sensitive Plant Species section of Chapter 3 and the Biological Evaluation and Analysis report in Exhibit T identify these plant species.

94. Public Concern: What standards will be used to protect threatened, rare, sensitive and culturally important plant species and their habitats from the management actions proposed in this project?

Response: The Threatened and Sensitive Plant Species section of Chapter 3, and the Biological Evaluation and Analysis report in Exhibit T, and the measures presented in the Features Common to all Action Alternatives section of Chapter 2 describe how these plant species will be conserved.



95. Public Concern: Describe the potential direct and indirect effect of the proposed management actions on rare plants and their habitat. Will prescribed burning occur in the spring and early summer; please give justifications for this decision using current scientific studies as reference.

Response: There are no known rare plant occurrences in the project area at the time of this analysis; however, if any are found, prescribed burning in those habitats will be re-addressed.

Wildlife 96. Public Concern: For the proposal to be consistent with the Forest Plan, enough habitat for viable populations of old-growth dependent wildlife species is needed over the landscape. Considering potential difficulties of using population viability analysis at the project analysis area level (Ruggiero, et. al., 1994), the cumulative effects of carrying out multiple projects simultaneously across the FNF makes it imperative that population viability be assessed at least at the forest wide scale (Marcot and Murphy, 1992). Also, temporal considerations of the impacts on wildlife population viability from implementing something with such long duration as a Forest Plan must be considered (id.) but this has never been done by the FNF. It is also of paramount importance to monitor population during the implementation of the Forest Plan in order to validate assumptions used about long-term species persistence i.e., population viability (Marcot and Murphy, 1992; Lacy and Clark, 1993).

Response: Please read the above response to Public Concern #30 on old growth habitat. See also Exhibit Rg-1 for an up-to-date Flathead National Forest evaluation and compliance with NFMA requirements to provide for diversity of animal communities. For Observations and Monitoring of Old Growth Associated Species, see Exhibit Q-6.

97. Public Concern: Specifically how will the Griffin Creek Resource Management Project affect Flammulated owls, cavity-nesters usually associated with mature stands of ponderosa pine and Douglas-fir?

Response: The potential effects of this project on flammulated owls are discussed in the Flammulated Owl portion of the “Sensitive Wildlife Species” section of Chapter 3 of the EA. These effects are detailed in Exhibit Rs-2. See also the EA sections in Chapter 3 on “Snags and Downed Wood Habitat” and “Old Growth Habitat” and the project file exhibits cited therein.

98. Public Concern: What surveys has the FNF specifically designed to detect flammulated owls? Absent an appropriate landscape management strategy for insuring their viability, based upon the best available science, it is arbitrary and capricious to dismiss potential impacts on the ground where the FS has failed to conduct the kind of comprehensive surveys that would reveal their presence.

Response: Flammulated owl survey and monitoring information in and near the Flathead National Forest is provided in Exhibit Rs-2. See also the narrative under “Population Status” for the Flammulated Owl part of the “Sensitive Wildlife Species” section of Chapter 3 of the EA, which includes a discussion about the difficulty of



detecting this species. See also Exhibit Rg-1 for the Flathead National Forest evaluation and compliance with NFMA requirements to provide for diversity of animal communities.

99. Public Concern: The FS should firmly establish that the species that exist, or historically are believed to have been present in the analysis area are still part of viable populations. Analysis must identify viable populations of MIS, TES, at-risk, focal, and demand species of which the individuals in the analysis area are members in order to sustain viable populations.

Response: The Forest Service will comply with all applicable regulation regarding viable populations. Wildlife survey, monitoring, and population information in and near the Griffin project area is provided in Exhibits Q-6, Rb-2, Rd-11, Rn-1, Rs-2, and Rt-7. These include all Management Indicator Species and TES species. See also the narrative under “Population Status” for each wildlife species or habitat in the Wildlife part of Chapter 3 of the EA. See also Exhibit Rg-1 for the Flathead National Forest evaluation and compliance with NFMA requirements to provide for diversity of animal communities.

100. Public Concern: Please examine how this project could affect grizzly bears, lynx and other species listed under the Endangered Species Act and if it will adversely modify critical habitat or proposed critical habitat. Please examine how this project will affect all MIS and sensitive species.

Response: An exhaustive analysis was performed for grizzly bears and for the Canada lynx and its designated Critical Habitat. See the “Threatened and Endangered Wildlife” section of Chapter 3 of the EA and Exhibits Rt-2 through Rt-15. There are no other threatened or endangered wildlife species whose ranges that could be affected by this project (Exhibit Rt-1). A similar level of analysis was also done for all MIS and sensitive species that could be impacted by this project. See the “Introduction” to the Wildlife section of Chapter 3 of the EA, and Chapter3 sections on “Old Growth Habitat,” “Snags and Downed Wood Habitat,” “Commonly Hunted Big Game,” “Neotropical Migratory Birds and Riparian Habitat,” and “Sensitive Wildlife Species.” See also Exhibit File sections Q, Rb, Rd, Rg, Rn, Rr, Rs, and Rt.

101. Public Concern: Completion of this proposal as presented would limit future options by further increasing the large amount of seral and early successional habitat currently found within the project area and on adjacent lands. The connectivity for many wildlife species to use habitat on a local (e.g. pine marten) and broader (e.g. fisher, wolverine, grizzly bears) scale will be further compromised.

Response: Effects on wildlife from changes in forested connectivity and from increases in early seral/structural-stage area are displayed in Chapter 3 of the EA in the sections on “Old Growth Habitat,” ”Snags and Downed Wood Habitat,” “Commonly Hunted Big Game,”” Neotropical Migratory Birds and Riparian Habitat,” “Sensitive Wildlife Species,” and “Threatened and Endangered Wildlife.” This includes big game, grizzly bears, wolverine, fisher, and other old growth associated and riparian wildlife species. See also Exhibits Q-12 (high-contrast edge along old growth habitat), Rb-3 (availability of cover and forage for big game), Rd-3 (snag and downed woody material habitat and effects analysis), Rg-7 (connectivity



within and beyond the Griffin Creek Analysis Area), Rr-3 (effects on riparian habitats including forested connectivity), Rs-8 (effects on fisher), Rt-4 (Threatened and Endangered Wildlife Species Biological Assessment), Rt-8 (lynx habitat existing conditions), and Rt-15 (lynx habitat effects analysis).

102. Public Concern: Maps indicate that very large openings will be created by individual cutting units and combinations of cutting units. How do these comply with Regional and Forest Plan standards especially in light of huge openings created by recent wildfires? How do the proposed openings lay in relation to previous timber management and are some of previous cutting units still without hiding cover?

Response: The Flathead NF does not have standards for large openings specific to wildlife outside of the grizzly bear recovery area. Region 1 provides direction that the size of openings created by even-aged silviculture will normally be 40 acres or less, with several exceptions. For situations that exceed the size limitation, Regional Forester approval is required (Forest Service Manual 2471.1.). The Griffin Creek project proposes 17 to 27 new openings that range from 46 to 1400 acres, depending on the alternative. Exhibits P-15 (analysis of openings greater than 40 acres), Rb-3 (availability of cover and forage for big game), and Rt-15 (lynx habitat effects analysis) clearly display the juxtaposition of proposed new openings with each other and with existing openings that have not yet regained hiding cover.



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