environmental assessment checklistdnrc.mt.gov/.../2020/...fma_red-owl-timber-salvage.pdfis proposing...

Red Owl Timber Salvage Montana Department of Natural Resources and Conservation

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Environmental Assessment Checklist

Project Name: Red Owl Timber Salvage Proposed Implementation Date: June 2020 Proponent: Kalispell Unit, Northwest Land Office, Montana DNRC County: Lake

Type and Purpose of Action

Description of Proposed Action: The Kalispell Unit of the Montana Department of Natural Resources and Conservation (DNRC) is proposing the Red Owl Timber Salvage. The project is located 8 air miles southeast of Bigfork, MT (refer to Attachments vicinity map A-1 and project map A-2) and includes the following sections:

Beneficiary Legal

Description

Total Acres

Treated Acres

Common Schools Public Buildings MSU 2nd Grant S. 12, T26N, R19W 242 214 MSU Morrill S. 13, T26N, R19W 40 40 Eastern College-MSU/Western College-U of M Montana Tech S. 7, T26N, R18W 311 311 University of Montana School for the Deaf and Blind S. 24, T26N, R19W 80 53 Pine Hills School Veterans Home Public Land Trust Acquired Land

Objectives of the project include:

• To generate revenue for the Trust beneficiaries by salvaging blown down and wind damaged timber before it loses economic value as directed in MCA 77-5-207.

• Salvage blown down trees to reduce fuel loadings to mitigate the potential for high intensity fires next to private property.


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Proposed activities include:

Action Quantity Proposed Harvest Activities # Acres Clearcut Seed Tree Shelterwood Commercial Thinning Salvage 618 Total Treatment Acres 618 Proposed Forest Improvement Treatment # Acres Pre-commercial Thinning Planting Proposed Road Activities # Miles New permanent road construction New temporary road construction Road maintenance 4.5 Road reconstruction Road abandoned Road reclaimed Other Activities Pile burning 618 Spot weed spraying 3

Duration of Activities: Approximately 4 months

Implementation Period: June 2020 The lands involved in this proposed project are held in trust by the State of Montana. (Enabling Act of February 22, 1889; 1972 Montana Constitution, Article X, Section 11). The Board of Land Commissioners and the DNRC are required by law to administer these trust lands to produce the largest measure of reasonable and legitimate return over the long run for the beneficiary institutions (Section 77-1-202, MCA). The DNRC would manage lands involved in this project in accordance with: The State Forest Land Management Plan (DNRC 1996), Administrative Rules for Forest Management (ARM 36.11.401 through 471), The Montana DNRC Forested State Trust Lands Habitat Conservation Plan (HCP)

(DNRC 2010) and all other applicable state and federal laws.

Project Development

SCOPING:

• DATE: April 23rd, 2020 through March 15th, 2020


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• PUBLIC SCOPED: o The scoping notice was posted on the DNRC Website: http://dnrc.mt.gov/public-

interest/public-notices o Adjacent Landowners, Statewide Scoping List

• AGENCIES SCOPED: o USFS, USFWS, Montana DNRC, Tribal Agencies statewide.

• COMMENTS RECEIVED: o How many: 13 total comments; 9 e-mails, 4 phone calls. o Concerns: noxious weeds, maintenance of roads used for log hauling, loss of big

game thermal cover, disturbance of cultural resources. See attached comments document for comments and responses. Results (how were concerns addressed): DNRC plans to complete

herbicide treatments of noxious weeds on the state parcels to control existing weed infestations. All equipment would be washed and inspected prior to start of work. All new roads would be reseeded to site adapted grass to reduce the threat of noxious weed spread. A pre- and post-sale road grading will be done on haul roads. Approximately 10 loads of gravel will be hauled to strategic locations on Red Owl road. This project is a blow down salvage and will have no effects to deer thermal cover. Currently, the DNRC has no record of cultural resources in the area of potential effect, and other THPOs have not identified tribal cultural resources there. If an unanticipated cultural resource is discovered, all project related activities will cease until the resource can be adequately evaluated. The DNRC will keep interested parties apprised of any unanticipated discoveries.

o The DNRC received multiple comments that addressed both the Red Owl Salvage as well as the Schmidt Creek Timber Salvage. Both Environmental Assessments were scoped under one scoping notice. Comments received that were outside the scope of the Red Owl Salvage will be addressed in the Schmidt Creek Environmental Assessment. See Attachment B for full list of comments and responses.

o DNRC specialists were consulted, including: Marc Vessar, DNRC hydrologist; Chris Forristal, DNRC wildlife biologist, Patrick Rennie, DNRC archeologist.

Internal and external issues and concerns were incorporated into project planning and design and will be implemented in associated contracts. OTHER GOVERNMENTAL AGENCIES WITH JURISDICTION, LIST OF PERMITS NEEDED: (Conservation Easements, Army Corps of Engineers, road use permits, etc.)

• United States Fish & Wildlife Service- DNRC is managing the habitats of threatened and endangered species on this project by implementing the Montana DNRC Forested Trust Lands HCP and the associated Incidental Take Permit that was issued by the United States Fish & Wildlife Service (USFWS) in February of 2012 under Section 10 of the Endangered Species Act. The HCP identifies specific conservation strategies for managing the habitats of grizzly bear, Canada lynx, and three fish species: bull trout, westslope cutthroat trout, and Columbia redband trout. This project complies with the HCP. The HCP can be found at http://dnrc.mt.gov/divisions/trust/forest-management/hcp.

http://dnrc.mt.gov/public-interest/public-notices

http://dnrc.mt.gov/public-interest/public-notices

http://dnrc.mt.gov/divisions/trust/forest-management/hcp

http://dnrc.mt.gov/divisions/trust/forest-management/hcp


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• Montana Department of Environmental Quality (DEQ)- DNRC is classified as a major open burner by DEQ and is issued a permit from DEQ to conduct burning activities on state lands managed by DNRC. As a major open-burning permit holder, DNRC agrees to comply with the limitations and conditions of the permit.

• Montana/Idaho Airshed Group- The DNRC is a member of the Montana/Idaho Airshed

Group which was formed to minimize or prevent smoke impacts while using fire to accomplish land management objectives and/or fuel hazard reduction (Montana/Idaho Airshed Group 2006). The Group determines the delineation of airsheds and impact zones throughout Idaho and Montana. Airsheds describe those geographical areas that have similar atmospheric conditions, while impact zones describe any area in Montana or Idaho that the Group deems smoke sensitive and/or having an existing air quality problem (Montana/Idaho Airshed Group 2006). As a member of the Airshed Group, DNRC agrees to burn only on days approved for good smoke dispersion as determined by the Smoke Management Unit.

ALTERNATIVES CONSIDERED: No-Action Alternative: Timber salvage operations would not occur, and no revenue would be generated for School Trust beneficiaries. Blown down and wind damaged trees would lose economic value. Forest fuels would not be managed to lessen the potential for crown fires near private property. Action Alternative: Approximately 500 thousand board feet of blown down and wind damaged timber would be salvaged from 618 acres and would generate income for the Trust beneficiaries. Fuel loadings would be reduced next to private property.

Impacts on the Physical Environment

Evaluation of the impacts on the No-Action and Action Alternatives including direct, secondary, and cumulative impacts on the Physical Environment. VEGETATION: Vegetation Existing Conditions: No rare or endangered plants are present within the project area. No old growth is present within the project area. A large timber sale harvested much of the project area in 2001 and 2002. Approximately 3.5 MMBF (million board feet) of timber was harvested. This harvest implemented shelterwood harvests and removed mostly Douglas-fir. Ponderosa pine was planted in the spring of 2004. Understory tree stocking is moderate in most of the harvested stands. A March 2020 wind event blew down or damaged scattered overstory leave trees in the old harvest units. Stringers and patches of leave trees were also blown down in un-harvested sections of the project area. The estimated salvage volume is 500 MBF across 618 acres. This amounts to approximately 800 board feet per acre being salvaged. This salvage will only remove blown down and wind


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damaged trees. A small amount of non-wind damaged trees may need to be cut to safely access pockets and stringers of salvage Due to the low volume being salvaged, there will be no impacts or changes to current stocking levels, age class distribution, or cover types. Forested stands within the project area will retain current Stand Level Inventory (SLI) calls.

Vegetation Impact Can

Impact Be Mitigated?

Comment Number Direct Secondary Cumulative

No Low Mod High No Low Mod High No Low Mod High No-Action

Noxious Weeds X X X yes Rare Plants X X X n/a Vegetative community X X X n/a Old Growth X X X n/a

Action Noxious Weeds X X X yes 1 Rare Plants X X X n/a Vegetative community X X X yes 1, 2 Old Growth X X X n/a

Comments: 1. Timber harvest and associated road work may lead to an increase in the occurrence of noxious weeds. Vegetation Mitigations: DNRC plans to complete herbicide treatments of noxious weeds on the state parcels to control existing weed infestations. All equipment would be washed and inspected prior to start of work. All new roads would be reseeded to site adapted grass to reduce the threat of noxious weed spread. Project areas would be monitored for noxious weeds after harvest operations are complete and herbicide treatments may be applied if needed. Comments: 2. Blown down and wind damaged trees could increase populations of Douglas-fir bark beetle. Vegetation Mitigations: Salvage of blown down and wind damaged trees prior to the spring of 2021 would remove population build-ups in tree boles prior to emergence of bark beetles in April or May of 2021.

SOIL DISTURBANCE AND PRODUCTIVITY: Soil Disturbance and Productivity Existing Conditions: According to the Soil Survey of Lake County Area, Montana (NRCS 1991) accesses via Web Soil Survey (https://websoilsurvey.nrcs.usda.gov/app/HomePage.htm) the soils in these parcels have a ‘K factor’ ranging from low to high. The ‘K factor indicate the susceptibility of soils to sheet or rill

https://websoilsurvey.nrcs.usda.gov/app/HomePage.htm


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erosion. However, the terrain is quite flat in the project area which would substantially limit the risk of off-site erosion from precipitation.

Skid trails in the proposed salvage units are evident from past timber management activities. While no substantial erosion attributable to timber harvest was identified on existing skid trails during field reconnaissance, reduced productivity was apparent in vegetation present.

Soil Disturbance and Productivity

Impact Can Impact Be Mitigated?



Physical Disturbance (Compaction and Displacement)

X X X

Erosion X X X Nutrient Cycling X X X Slope Stability X X X Soil Productivity X X X

Action Physical Disturbance (Compaction and Displacement)

X X X Y S-1

Erosion X X X Y S-2 Nutrient Cycling X X X Y S-3 Slope Stability X X X Soil Productivity X X X Y S-3

Comments: S-1: Physical disturbance from compaction and displacement would be expected on skid

trails and landings. During field reconnaissance, evidence of cumulative impacts from past management was limited to reduce vegetative growth compared to areas outside of skid trails.

S-2: Erosion associated with timber harvest (not including roads) would be expected to have a low risk of occurring because of the nearly flat terrain and the implementation of appropriate Forestry Best Management Practices.

S-3: Coarse and fine woody debris provide a crucial component in forested environments through nutrient cycling, microbial habitat, moisture retention and protection from mineral soil erosion (Harmon et al., 1986). As required in the DNRC Timber Sale Contract, both fine and coarse woody debris would be retained to reduce potential impacts to forest productivity. Although fine woody debris would be left on site for nutrient retention, a reduction in annual fine material contribution would result from this alternative. Units proposed for commercial thin would likely see less reduction than seed tree units.

Soil Mitigations:


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1) Limit equipment operations (harvesting and site preparation) to periods when soils are relatively dry, (less than 20 percent oven-dried weight), frozen, or snow-covered in order to minimize soil compaction and rutting and maintain drainage features. Check soil moisture conditions prior to equipment start-up.

2) On previously harvested areas, the logger and sale administrator would agree to a

skidding plan prior to equipment operations. Skid-trail planning would identify which main trails to use and how many additional trails are needed. Trails that do not comply with BMPs (i.e. trails in draw bottoms) would not be used unless impacts can be adequately mitigated. Regardless of use, these trails may be closed with additional drainage installed, where needed, or grass-seeded to stabilize the site and control erosion.

3) Tractor skidding should be limited to slopes of less than 40 percent unless the

operation can be completed without causing excessive displacement or erosion. Based on site review, short, steep slopes may require a combination of mitigation measures, such as adverse skidding to a ridge or winchline, and skidding from more moderate slopes of less than 40 percent.

4) Keep skid trails to 20 percent or less of the harvest unit acreage by spacing skid trails at least 60 feet apart. The flat terrain in this project area should facilitate event wider spacing. Use existing skid trails to reduce cumulative area impacted. Provide for drainage in skid trails and roads concurrently with operations.

5) Slash disposal: Limit the combination of disturbance and scarification to 30 to 40

percent of the harvest units. Consider disturbance incurred during skidding operations to, at least, partially provide scarification for regeneration.

6) Retain 10 to 15 tons per acre of large woody debris and a feasible majority of all fine litter following harvesting operations. On units where whole tree harvesting is used, implement one of the following mitigations for nutrient cycling: 1) use in-woods processing equipment that leaves slash on site; 2) for whole-tree harvesting, return-skid slash and evenly distribute within the harvest area; or 3) cut tops from every third bundle of logs so that tops are dispersed as skidding progresses.

WATER QUALITY AND QUANTITY: The proposal is limited to harvest windthrown trees and wind-damaged trees that would be prone to dying from insects, disease or stress. The closest stream to a proposed harvest unit is at least 400 feet. Additionally, the terrain is nearly flat which substantially lessens the potential for sediment transport. Water Quality and Quantity Existing Conditions: This project sits entirely within the Bigfork Dam hydrologic unit (6th code) on the Lower Swan River. This is 44,448-acre watershed that includes the Swan River from the outlet of Swan Lake downstream. Johnson Creek is also included in this watershed.


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During field reconnaissance, no surface water was observed. No stream channels or other bodies of water were identified within 400 feet of the project area.

Water Quality & Quantity




Water Quality X X X H-1 Water Quantity X X X

Action Water Quality X X X H-1 Water Quantity X X X H-2

Comments: H-1: Because no streams are present in the project area and the terrain is nearly flat, no risk of direct adverse impacts from this proposal would be expected from the action alternative. Indirect or secondary impacts would be limited to potential dust transport to surface water. This would have a very low risk of measurable impacts. Due to the blowdown immediately on the banks of streams in the 6th code watershed (specifically, Schmidt Creek), an increase in sediment is likely until the rootwads settle and soil revegetates. This increase in sediment is natural and does not result as a direct, indirect or cumulative impact from human activities.

H-2: With no streams channels in the project area, no surface water conduit connects the area directly to the Swan River. Since most of the trees are currently dead as a result of windthrow and standing trees are prone to dying as a result of insects or disease the risk of a measurable increase in annual water yield as a result of the salvage harvest within the 6th code watershed is very low to non-existent.

Water Quality & Quantity Mitigations: Follow all Forestry BMPs. FISHERIES: Fisheries Existing Conditions: Because no streams were identified within the project area and the closest stream outside of the project area is at least 400 feet away, the risk of potential direct, indirect or cumulative impacts to fisheries populations or habitat is very low and immeasurable. Therefore, no further discussion or analysis for fisheries is warranted for this alternative. WILDLIFE: Wildlife Existing Conditions: The Project Area contains of variety of habitat conditions for native wildlife species, including open-canopy forest with scattered large trees and dense patches of mature forest. The 673-acre Project Area consists of four adjacent DNRC-managed parcels within sections 12, 13 and 24 of T26N, 19W, as well as section 7 of T26N, 18W. All of these parcels are in the wildland-urban interface and bordered by private lands containing low-density housing developments or private industrial timberlands. Lands in sections 7 and 13, as well as 121 acres in the eastern half of section 12 are included in DNRC’s Habitat Conservation


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Plan (hereafter HCP, USFWS and DNRC 2010). Approximately 5.2 miles of open roads are present within the Project Area, of which 1.5 miles are comprised of Montana Highway 83 and an adjacent Department of Transportation (DOT) administrative site. Remaining open roads serve adjacent neighborhoods or as access to powerlines that traverse the parcels. Daily motorized use occurs throughout the Project Area. Because of the proximity of these lands to occupied homes and open roads, non-motorized recreational use of the Project Area is likely moderate. Snags and large downed wood are typically reduced within 300 feet of open roads due to firewood cutting by the public. However, strong wind events in March of 2020 have created large amounts of blown-down, wind-damaged and root-pulled trees throughout the Project Area. Prior to the wind events, the Project Area contained approximately 165 acres of mature forest stands (trees ≥9” dbh with ≥40% canopy closure. The blowdown event created openings less than an acre in size within this habitat. No old-growth forest is present using Green et al. (1992) standards. Another 466 acres consist of stands with mature trees and a more open (<40%) canopy. Most blowdown is scattered widely throughout the Project Area in this more open forest habitat. Approximately 42 acres are comprised of unforested areas such as Montana Highway 83, gravel pit, marshland and the DOT administrative site. As a result of the blowdown event, downed woody debris are abundant throughout the Project Area and are at the high end or exceed the natural range of variation expected for the habitat types present. Overall, habitat conditions within the Project Area are suitable for diverse wildlife species that are generally tolerant of human disturbance. No-Action: None of the proposed activities would occur. In the short-term, no changes to the amounts, quality, or spatial arrangement of forested habitat would occur. In the long-term, habitat suitability for species utilizing large downed wood would increase because blowdown would not be harvested. An increase in wildfire danger, forest insects and disease would also be anticipated due to the current abundance of dead and dying trees. Overall, habitat availability for most species would remain similar to current conditions. Action Alternative (see Wildlife table below):

Wildlife

Impact Can Impact be Mitigated?


No Low Mod High No Low Mod High No Low Mod High Threatened and

Endangered Species

Grizzly bear (Ursus arctos) Habitat: Recovery areas, security from human activity

X X X Y WI-1

Canada lynx (Felix lynx) Habitat: Subalpine fir habitat types, dense sapling, old forest, deep snow zone

X X X Y WI-2

Sensitive Species


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Wildlife



No Low Mod High No Low Mod High No Low Mod High Bald eagle (Haliaeetus leucocephalus) Habitat: Late-successional forest within 1 mile of open water

X X X Y WI-3

Black-backed woodpecker (Picoides arcticus) Habitat: Mature to old burned or beetle-infested forest

X X X N/A WI-4

Coeur d'Alene salamander (Plethodon idahoensis) Habitat: Waterfall spray zones, talus near cascading streams

X X X N/A WI-4

Columbian sharp-tailed grouse (Tympanuchus Phasianellus columbianus) Habitat: Grassland, shrubland, riparian, agriculture

X X X N/A WI-4

Common loon (Gavia immer) Habitat: Cold mountain lakes, nest in emergent vegetation

X X X N/A WI-4

Fisher (Martes pennanti) Habitat: Dense mature to old forest less than 6,000 feet in elevation and riparian

X X X Y WI-5

Flammulated owl (Otus flammeolus) Habitat: Late-successional ponderosa pine and Douglas-fir forest

X X X Y WI-6

Gray Wolf X X X Y WI-7


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Wildlife



No Low Mod High No Low Mod High No Low Mod High (Canis lupus) Habitat: Ample big game populations, security from human activities Harlequin duck (Histrionicus histrionicus) Habitat: White-water streams, boulder and cobble substrates

X X X N/A WI-4

Northern bog lemming (Synaptomys borealis) Habitat: Sphagnum meadows, bogs, fens with thick moss mats

X X X N/A WI-4

Peregrine falcon (Falco peregrinus) Habitat: Cliff features near open foraging areas and/or wetlands

X X X N/A WI-4

Pileated woodpecker (Dryocopus pileatus) Habitat: Late-successional ponderosa pine and larch-fir forest

X X X Y WI-8

Townsend's big-eared bat (Plecotus townsendii) Habitat: Caves, caverns, old mines

X X X N/A WI-4

Wolverine (Gulo gulo) Habitat: Alpine tundra and high-elevation boreal forests that maintain deep persistent snow into late spring

X X X N/A WI-9

Big Game Species


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Wildlife



No Low Mod High No Low Mod High No Low Mod High Elk X X X Y WI-10 Whitetail X X X Y WI-10 Mule Deer X X X Y WI-10

Comments: WI-1. Grizzly Bear – The proposed Project Area occurs within a grizzly bear Recovery Area (USFWS 1993, Wittinger 2002). Salvage harvesting of scattered blowdown would occur on 618 acres of this habitat. Duration of proposed activities would be relatively short during the non-denning season (<150 operating days) and would occur after the spring period (April 1 – June 15). Removal of dead blowdown and wind-damaged trees would have minor effects on grizzly bear hiding cover. Several unauthorized motorized trails would be closed through the proposed project and impact to visual screening along open roads would be minimal. No new roads would be built but there would be a short-term increase in motorized use of approximately 4.5 miles of road in the area (2.6 miles open road, 1.9 miles restricted road). Additionally, appreciable use of the Project Area by grizzly bears is unlikely due to several open roads in the parcels, relatively close proximity of Montana Highway 83, and adjacent occupied home sites. Increased disturbance under the Action Alternative would be additive to other motorized disturbance in the vicinity of the Project Area, including a DNRC-proposed forest management project in the adjoining Schmidt Creek parcel (section 18, T26N, R18W). The greatest risks to bears within the CEAA would remain human habitations and associated attractants that bring bears into conflict with people. WI-2. Canada Lynx – Approximately 134 acres of suitable Canada lynx habitat occur within the proposed Project Area. Scattered blowdown harvest would occur across 120 acres of this habitat (89.6% of habitat present). Proposed blowdown harvest would not appreciably alter habitat suitability for use by lynx. Following proposed harvesting, coarse woody debris would remain within levels outlined by Graham et al. (1994) and some large logs (>15 inches in diameter) would be retained within lynx habitat. Canada lynx have been observed within 6 miles of the Project Area in higher elevation (>4,000 ft.) USDA Forest Service land (MNHP 2020). While lynx use of the Project Area is possible, it is unlikely due to lower elevations/snow depths, poor connectivity due to interspersed unsuitable habitat, and surrounding human developments. Increased disturbance under the Action Alternative would be additive to other motorized disturbance in the vicinity of the Project Area, including a DNRC-proposed forest management project in the adjoining Schmidt Creek parcel (section 18, T26N, R18W). WI-3. Bald Eagle – The Project Area falls within the territory of the Loon Lake eagle pair, however, the last known nest site is over 1.3 miles from any proposed harvest. Homes, lakes, highways and other open roads are situated between the nest site area and the DNRC parcels. Appreciable use of the Project Area would not be expected due to the lack of preferred habitat (e.g. lakes, meadows). Additionally, the number of home sites and open roads around the Project Area would suggest that any eagles that may be present are likely habituated to human disturbance. WI-4. This species was evaluated and it was determined that the Project Area lies outside of the normal distribution for the species, and/or suitable habitat was not found to be present.


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WI-5. Fisher – Approximately 22 acres of potential fisher habitat would be subject to salvage harvesting activities (68.3% of fisher habitat available in the Project Area). Snags and coarse woody debris would be maintained to meet ARMs 36.11.411 through 36.11.414. Crown closure of live trees would not be appreciably affected, as only dead and dying trees would be removed. Habitat suitability of these 22 acres for fishers would be reduced to a minor degree. However, appreciable use of the area by fishers is not likely given the lack of suitable habitat and connectivity within the Project Area. No new roads would be constructed that could fragment habitat or increase access for trapping. To reduce potential adverse effects on fishers, at least 2 large snags and 2 large snag recruitment trees per acre (>21 inches dbh) would be retained (ARM 36.11.411). These snags are important habitat features that provide resting and denning sites for fishers. Riparian fisher habitat is not present in the Project Area. Overall connectivity would not change within the Project Area. Considering the low availability of suitable habitat in the surrounding area, lack of fisher observations within the last 30 years (MNHP 2020), and prevalence of dry ponderosa pine forest types, which are avoided by fishers (Olson et al. 2014), the likelihood of fishers using the surrounding area is low.

WI-6. Flammulated Owls – The proposed salvage harvest would occur over 496 acres (100.0% of habitat in the Project Area) of preferred flammulated owl cover types. Harvest of blowdown and wind-damaged trees would not substantially change forest structure preferred by flammulated owls. Records of flammulated owls within 5 miles of the Project Area are lacking (MNHP 2020). Should flammulated owls be present in the area, they could be temporarily displaced by harvesting activities. Existing standing snags would be minimally impacted; snags and snag recruits would be maintained according to ARM 36.11.411. To retain potential nesting trees for flammulated owls at least 2 large snags and 2 large snag recruitment trees per acre (>21 inches dbh) would be retained (ARM 36.11.411), with an emphasis on retaining larger ponderosa pine snags. Substantial changes in potential use of the larger surrounding area by flammulated owls would not be expected.

WI-7. Gray Wolf – Wolves may use habitat near the Project Area. Disturbance associated with timber sales at den and rendezvous locations can adversely affect wolves; however, timing restrictions would apply if den or rendezvous sites are documented (ARM 33.11.430(1)(a)(b)).

WI-8. Pileated Woodpecker – The proposed salvage harvest would occur across 121 acres of suitable pileated woodpecker habitat (91.9% of habitat available in the Project Area). Recent blowdown trees have increased foraging opportunities for pileated woodpeckers. Harvesting would only remove blowdown and wind-damaged trees; existing standing snags would be minimally impacted. To reduce potential adverse effects on pileated woodpeckers, at least 2 large snags and 2 large snag recruitment trees per acre (>21 inches dbh) would be retained and any snags cut for safety reasons would be left in the harvest unit (ARM 36.11.411). Broken-topped ponderosa pine >400 feet from open roads would also be retained. Downed wood present prior to the blowdown events would remain within units, as well as non-merchantable broken logs. Although pileated woodpeckers are generally tolerant of disturbance, harvesting could temporarily displace individual woodpeckers in the immediate vicinity of the harvest units during activities. Measurable changes in potential use of the larger surrounding area by pileated woodpeckers would not be expected.

WI-9. Wolverine – No potentially suitable wolverine habitat exists within the proposed Project Area. The Project Area does not maintain deep snow into late spring and does not contain high-elevation alpine habitat. While a wolverine could pass through the Project Area during its extensive movements, appreciable use of the area is not expected. Given the large home range area (average 150+ sq. miles) wolverines occupy, and long distances wolverines typically


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cover during their movements, the proposed activities would not be expected to measurably affect use of the area by wolverines.

WI-10. Big Game – Year-round use of the Project Area by big game is likely. The Project Area contains winter range habitat for elk, moose, mule deer, and white-tailed deer (DFWP 2008). The proposed salvage harvesting would not appreciably affect snow intercept or thermal cover because dead and dying trees do not substantially contribute to this habitat attribute. Hiding cover would be minimally affected with the removal of scattered blowdown trees. No new open roads would be built and visual screening along existing roads would be maintained where it is available. Motorized access to restricted roads within the Project Area would remain restricted during and after harvesting. Potential disturbance of big game associated with harvest activities would be localized and occur for a relatively short time but could be additive to other sources of disturbance in the surrounding area, including a DNRC-proposed forest management project on the adjoining Schmidt Creek parcel (section 18, T26N, R18W).

Wildlife Mitigations: If a threatened or endangered species is encountered, consult a DNRC biologist

immediately. Similarly, if undocumented nesting raptors or wolf dens are encountered within ½ mile of the Project Area, contact a DNRC biologist.

Contractors will adhere to food storage and sanitation requirements as described in the timber sale contract. Ensure that all attractants such as food, garbage, and petroleum products are stored in a bear-resistant manner.

Prohibit contractors and purchasers conducting contract operations from carrying firearms while on duty as per ARM 36.11.444(2).

Prohibit all motorized activities more than 100 feet from open roads from April 1 – June 15 per GB-RZ2 (USFWS and DNRC 2010).

Limit harvesting activities more than 100 feet from open roads in individual HCP parcels to 150 operating days or less during the grizzly bear non-denning season (June 16 – November 15).

Effectively close all restricted roads in the Project Area via a combination of gates, berms, rocks, and stumps.

Retain visual screening along roads to the greatest extent practicable. Protect brush and undamaged trees of all sizes as much as possible. Retain patches of advanced regeneration of shade-tolerant trees as per LY-HB4 (USFWS

and DNRC 2010) in all harvest units. Retain at least 2 snags and 2 snag recruits per acre >21 inches dbh or the next largest

available size class, particularly favoring ponderosa pine, western larch and Douglas-fir for retention. If snags are cut for safety concerns, they must be left in the harvest unit.

Emphasize retention of 15-inch diameter downed logs, aiming for at least one 20-foot-long section per acre in areas away from open roads and private property boundaries.

Literature: DFWP. 2008. Maps of moose, elk, mule deer, and white-tailed deer distribution in Montana. In

Individual GIS data layers. Available online at: http://fwp.mt.gov/gisData/imageFiles/distributionElk.jpg http://fwp.mt.gov/gisData/imageFiles/distributionMoose.jpg http://fwp.mt.gov/gisData/imageFiles/distributionMuleDeer.jpg http://fwp.mt.gov/gisData/imageFiles/distributionWhiteTailedDeer.jpg

Green, P., J. Joy, D. Sirucek, W. Hann, A. Zack, and B. Naumann. 1992. Old Growth Forest Types of the Northern Region. R-1 SES. USDA Forest Service, Northern Region, Missoula MT 60pp.

http://fwp.mt.gov/gisData/imageFiles/distributionWhiteTailedDeer.jpg


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MNHP. 2020. Natural Heritage Map Viewer. Montana Natural Heritage Program. Retrieved on May 3, 2020, from http://mtnhp.org/MapViewer.

Olson, L. E., J. D. Sauder, N. M. Albrecht, R. S. Vinkey, S. A. Cushman, and M. K. Schwartz. 2014. Modeling the effects of dispersal and patch size on predicted fisher (Pekania [Martes] pennanti) distribution in the U.S. Rocky Mountains. Biological Conservation 169:89-98.

USFWS. 1993. Grizzly bear recovery plan. Missoula, Montana. 181 pp. USFWS and DNRC. 2010. Montana Department of Natural Resources and Conservation

Forested Trust Lands Habitat Conservation Plan, Final Environmental Impact Statement, Volumes I and II., U.S. Department of Interior, Fish and Wildlife Service, Region 6, Denver, Colorado and Montana Department of Natural Resources and Conservation, Missoula, MT.

Wittinger, W.T. 2002. Grizzly bear distribution outside of recovery zones. Unpublished memorandum on file at U.S. Forest Service, Region 1, Missoula, Montana

AIR QUALITY:

Air Quality Impact Can

Impact Be Mitigated?



Smoke X X X n/a Dust X X X n/a

Action Smoke X X X Yes 1 Dust X X X Yes 1

Comments: 1. Smoke will be created from pile burning and dust may be created from log hauling operations. Air Quality Mitigations: Burning would occur on days approved by the Montana/Idaho Airshed group and DEQ. Conduct test burn to verify good dispersal. DNRC may implement measures to mitigate dust created from hauling operations. These mitigations include but are not limited to the following: slow driving speeds, restricted haul period, application of dust abatement on road surfaces. ARCHAEOLOGICAL SITES / AESTHETICS / DEMANDS ON ENVIRONMENTAL RESOURCES: A Class I (literature review) level review was conducted by the DNRC staff archaeologist for the area of potential effect (APE). This entailed inspection of project maps, DNRC's sites/site leads database, land use records, General Land Office Survey Plats, and control cards. The Class I search revealed that no cultural or paleontological resources have been identified in the APE. Because little ground disturbance is expected with the proposed project, because the project area has been extensively logged in the past, and because the local geology is not likely to produce caves, rock shelters, or sources of tool stone, no additional archaeological investigative work will be conducted. However, if previously unknown cultural or paleontological

http://mtnhp.org/MapViewer


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materials are identified during project related activities, all work will cease until a professional assessment of such resources can be made.

Will Alternative result in potential

impacts to:




Historical or Archaeological Sites X X X n/a

Aesthetics X X X n/a Demands on Environmental Resources of Land, Water, or Energy

X X X n/a

Action Historical or Archaeological Sites X X X yes 1

Aesthetics X X X yes 1 Demands on Environmental Resources of Land, Water, or Energy

X X X n/a

Comments: Timber harvest activity and associated road work could disturb archaeological resources. Mitigations: All THPO offices throughout the state have been notified of this project. Currently, the DNRC has no record of cultural resources in the area of potential effect, and other THPOs have not identified tribal cultural resources there. No state-owned Heritage Property will be affected by the proposed timber harvest. If an unanticipated cultural resource is discovered, all project related activities will cease until the resource can be adequately evaluated.

OTHER ENVIRONMENTAL DOCUMENTS PERTINENT TO THE AREA: List other studies, plans or projects on this tract. Determine cumulative impacts likely to occur as a result of current private, state or federal actions in the analysis area, and from future proposed state actions in the analysis area that are under MEPA review (scoped) or permitting review by any state agency.

• n/a

Impacts on the Human Population

Evaluation of the impacts on the proposed action including direct, secondary, and cumulative impacts on the Human Population.


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impacts to:




Health and Human Safety X X X n/a Industrial, Commercial and Agricultural Activities and Production

X X X n/a

Quantity and Distribution of Employment

X X X n/a

Local Tax Base and Tax Revenues X X X n/a Demand for Government Services X X X n/a Access To and Quality of Recreational and Wilderness Activities

X X X n/a

Density and Distribution of population and housing

X X X n/a

Social Structures and Mores X X X n/a Cultural Uniqueness and Diversity X X X n/a

Action Health and Human Safety Industrial, Commercial and Agricultural Activities and Production

X X X n/a

Quantity and Distribution of Employment

X X X n/a

Local Tax Base and Tax Revenues X X X n/a Demand for Government Services X X X n/a Access To and Quality of Recreational and Wilderness Activities

X X X n/a

Density and Distribution of population and housing

X X X n/a

Social Structures and Mores X X X n/a


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impacts to:



No Low Mod High No Low Mod High No Low Mod High Cultural Uniqueness and Diversity X X X n/a

Comments: The proposed action will have no direct, indirect, or cumulative impacts. Mitigations: n/a Locally Adopted Environmental Plans and Goals: List State, County, City, USFS, BLM, Tribal, and other zoning or management plans, and identify how they would affect this project.

• n/a

Other Appropriate Social and Economic Circumstances: Costs, revenues and estimates of return are estimates intended for relative comparison of alternatives. They are not intended to be used as absolute estimates of return. The estimated stumpage is based on comparable sales analysis. This method compares recent sales to find a market value for stumpage. These sales have similar species, quality, average diameter, product mix, terrain, date of sale, distance from mills, road building and logging systems, terms of sale, or anything that could affect a buyer’s willingness to pay. No Action: The No Action alternative would not generate any return to the trust at this time. Action: The timber harvest would generate additional revenue for the MSU 2nd Grant, MSU Morrill, Montana Tech, and the School for the Deaf and Blind Trusts. The estimated return to the trusts for the proposed harvest is $75,000.00 based on an estimated harvest of 500,000 board feet 3,000 tons) and an overall stumpage value of $25.00 per ton. Costs, revenues, and estimates of return are estimates intended for relative comparison of alternatives, they are not intended to be used as absolute estimates of return. References DNRC 1996. State forest land management plan: final environmental impact statement (and

appendixes). Montana Department of Natural Resources and Conservation, Forest Management Bureau, Missoula, Montana.

DNRC. 2010. Montana Department of Natural Resources and Conservation Forested State

Trust Lands Habitat Conservation Plan: Final EIS, Volume II, Forest Management Bureau, Missoula, Montana.

Does the proposed action involve potential risks or adverse effects that are uncertain but extremely harmful if they were to occur? No Does the proposed action have impacts that are individually minor, but cumulatively significant or potentially significant? No


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Environmental Assessment Checklist Prepared By:

Name: Pete Seigmund Title: Forest Management Supervisor, Kalispell Unit Date: 05/2020

Finding

Alternative Selected Action Alternative Significance of Potential Impacts I find that the impacts of the proposed action alternative as described in this Environmental Assessment are not significant. This Environmental Analysis has been completed for the Red Owl Timber Salvage. After a thorough review of the EA, project file, response and discussions with Department and other specialists, Department policies, standards and guidelines, and the State Land Management Rules, and HCP rules I have taken the decision to choose the action alternative. I believe that this EA has described a good approximation what this project would accomplish by salvaging blown down and wind damaged timber before it loses its economic value, and to reduce fuel loadings to mitigate the potential for high intensity fires next to private property. This project will reduce the susceptibility of residual trees to epidemic insect infestations and outbreaks, and improve the availability of necessary nutrients, water, and sunlight that may be limited in this stand. Need for Further Environmental Analysis

EIS More Detailed EA X No Further Analysis

Environmental Assessment Checklist Approved By:

Name: David M. Poukish Title: Kalispell Unit Manager, DNRC Date: 5/27/2020 Signature: /s/ David M. Poukish


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Attachment A- Maps


12

A-1: Timber Sale Vicinity Map

[PROJECT NAME] VICINITY MAP

Name: Red Owl Timber Salvage Legal: S. 7, T26N, W18W S. 12, 13 & 24, T26N, R19W


13


14

Attachment B:

Scoping Comments and Responses


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Friends of the Wild Swan

PO Box 103

Bigfork, MT 59911

May 15, 2020

DNRC, Kalispell Unit

Attn: David Hust

655 Timberwolf Parkway

Kalispell, MT 59901

Via email to: [email protected]

Mr. Hust,

1) I received the scoping notice for the Red Owl Salvage Project on May 4th, it is sparse on information related to the project. And scant time is given for the public to submit their concerns since the deadline is today, May 15th.

DNRC Response: We apologize for the relatively short comment window. The Red Owl Timber Salvage Project has been quickly developed in rapid response to widespread winds that blew down many trees in mid-March 2020. Prompt action was warranted to minimize timber theft and loss of value in down logs.

2) There is no map of proposed units, there is no location identified for the road reconstruction and temporary road construction that includes 3 stream crossings. What silvicultural treatments are planned and where? From the notice it appears that it will be clearcuts and other even-aged management.

DNRC Response: No new road construction would occur on the Red Owl Salvage Project, however, some road maintenance activities would be necessary on 4.5 miles of existing roads. Road construction and 2 crossing structures referenced in this comment and mentioned in the original project scoping notice would occur in an additional proposed project in the Schmidt


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Creek area. Detailed project maps are included in the Red Owl Salvage EA and Schmidt Creek Timber Sale EA.

3) Is this all salvage or is there also a regular timber sale included?

DNRC Response: Yes. Given issues related to: 1) the amount of widespread downed trees in the vicinity of the project area, 2) large amount of down trees susceptible to timber theft, and 3) HCP requirements to comply with 4-year active and 8-year rest window requirements for larger projects, separate projects, EAs and contracts are being completed.

4) How does this project comply with the Habitat Conservation Plan?

DNRC Response: Specific HCP commitments that are applied to minimize and mitigate impacts to specific species addressed in the HCP are implemented in relation to habitat importance geographically. The project area contains lynx habitat, and the lands occur within the NCDE Grizzly Bear Recovery Zone. No streams and associated fisheries occur in the project area.

Given these facts, lynx habitat commitments for scattered DNRC lands apply, as do all commitments for grizzly bears that pertain to DNRC scattered lands. A summary of these project-specific requirements are included below which is also provided on p. 14 of the EA. Specific commitments applied on all DNRC projects are reviewed by the DNRC Forest Management Bureau staff and are reported to the US Fish and Wildlife Service each year in an annual report. http://dnrc.mt.gov/divisions/trust/forest-management/hcp/hcp-implementation-and-monintoring

Contractors will adhere to food storage and sanitation requirements as described in the timber sale contract. Ensure that all attractants such as food, garbage, and petroleum products are stored in a bear-resistant manner.

Prohibit contractors and purchasers conducting contract operations from carrying firearms while on duty as per ARM 36.11.444(2).

Prohibit all motorized activities more than 100 feet from open roads from April 1 – June 15 per GB-RZ2 (USFWS and DNRC 2010).

Limit harvesting activities more than 100 feet from open roads in individual HCP parcels to 150 operating days or less during the grizzly bear non-denning season (June 16 – November 15).

Effectively close all restricted roads in the Project Area via a combination of gates, berms, rocks, and stumps.

Retain visual screening along roads to the greatest extent practicable. Protect brush and undamaged trees of all sizes as much as possible. Retain patches of advanced regeneration of shade-tolerant trees as per LY-HB4 (USFWS

and DNRC 2010) in all harvest units. Retain at least 2 snags and 2 snag recruits per acre >21 inches dbh or the next largest

available size class, particularly favoring ponderosa pine, western larch and Douglas-fir for retention. If snags are cut for safety concerns, they must be left in the harvest unit.

Emphasize retention of 15-inch diameter downed logs, aiming for at least one 20-foot-long section per acre in areas away from open roads and private property boundaries.

http://dnrc.mt.gov/divisions/trust/forest-management/hcp/hcp-implementation-and-monintoring



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Old-Growth Forest Habitat

5) Before DNRC logs any old-growth forest habitat they must have a plan for how old-growth forests will be managed. Old-growth habitat must be identified and mapped (preferably with an aerial photograph map). Where does old growth currently exist on the forest? How is it connected? How will connectivity be maintained or improved? These were recommendations of the Technical Review Committee of scientists that were hired by DNRC. (Pfister et al 2000).

Realizing that existing old-growth stands do not last forever, there must be a provision for putting stands on longer rotations so that habitat is connected. Existing old-growth stands must be put on longer rotations so that this component of the forest is retained. Other stands should be put on long rotations so that they develop old-growth characteristics and are able to replace existing old growth. These are not “reserves” but long rotations.

DNRC must use the Green et al old-growth definition in its entirety instead of only the minimum number of large trees. Manipulating old-growth forest habitat using the assumption that it will still be old growth after logging is an untested hypothesis and is not supported by science.

Existing old-growth habitat is sparse and fragmented. A priority and goal for this project should be to designate an old-growth network to ensure that this component of biodiversity is maintained over the long term.

The EIS must analyze what the effects of logging will be on existing and recruitment old growth forest habitat, riparian areas, wetlands and other habitats both in terms of blowdown and other effects on the forest itself as well as on old-growth dependent wildlife.

Are there sufficient snags and down woody material? If not, what can be done to restore these attributes?

The project must demonstrate compliance with ARM 36.11.407 so that the amount and distribution of old growth forest habitat is within the historic range, not just at the low threshold.

DNRC Response: Old growth forest that meets the definition of Green et al. (1992) are not present in the project area. As such, the issue was not addressed further in the analysis.

Water Quality and Fish Habitat

6) Water quality and native fish habitat needs to be protected, and where necessary, restored. Important parameters that are measurable and good indicators of fish habitat are temperature and sediment. Bull trout and westslope cutthroat trout are sensitive to fine sediments that can clog spawning gravels. Studies in the Flathead Basin in Montana demonstrate a "significant negative relationship existed between fry emergence success and the percentage of substrate


18

materials less than 6.35 mm in diameter." (Weaver and Fraley, 1991) Juvenile bull trout are also more substrate oriented than other trout species. Streams are considered "threatened" when the percentage of fine materials in spawning gravels in any given year is greater than 35% and "impaired" when the percentage of fine materials in spawning gravels in any given year is greater than 40%. (Flathead Basin Commission, 1991).

Cold water is also necessary for successful spawning and rearing. The EIS should fully disclose the current condition of streams in the timber sale area and develop a plan for restoring streams that are not meeting habitat parameters. Are you planning to log in riparian areas? Are you planning to comply with your HCP?

Just to be clear we do not believe the HCP buffers are adequate to protect bull trout or streams from increases in sediment and temperature nor do they provide for habitat complexity. Buffer zones of 300 feet for fish-bearing streams and lakes, 150 feet for non-fish bearing perennial streams and potholes and 100 feet for intermittent streams should be used for adequate watershed protection. Large woody debris is an important component for pool formation in watersheds. Logging in streamside, riparian areas can alter the complex balance of large woody debris in streams causing changes to stream habitats. Exclusion of logging in riparian areas may be necessary to maintain natural stream morphology and habitat features. (Hauer, et al, 1999, Large woody debris in bull trout (Salvelinus confluentus) spawning streams of logged and wilderness watersheds in northwest Montana).

The Montana Bull Trout Restoration Team’s Science Group suggested a caution zone that ranged from the 100 year floodplain plus 150 feet to the whole watershed. The Forest Service’s Inland Native Fish Strategy required 300 foot buffers on each side of the stream. The USFWS Interim Conservation Guidance states:

The Service believes activities that occur within the caution zone may inherently pose some risk, and should not occur unless sufficient information is available to reliably demonstrate that the activity will not adversely affect habitat characteristics necessary to support bull trout. (emphasis added) USFWS Bull Trout Interim Conservation Guidance, 12/9/98 citing Montana Bull Trout Scientific Group’s 1998 report “The Relationship between Land Management Activities and Habitat Requirements of Bull Trout.”

The caution zone they refer to is the 100 year flood plain + 150 feet for both bull trout core and nodal areas.

How will this project affect native fish? What is the current condition in the Riparian Areas? Are they providing adequate shade and woody debris? How will this project protect rather than adversely impact fish habitat and water quality?

DNRC Response: Because no riparian areas or streams are present in the project area and the terrain is nearly flat, no risk of direct adverse impacts from this proposal would be expected from the action alternative. Indirect or secondary impacts would be limited to potential dust transport


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to surface water. This would have a very low risk of measurable impacts. As such, impacts to water quality and fisheries were not addressed further in the analysis.

Wildlife

7) What conservation strategies does DNRC have to ensure that biological diversity is maintained? The SFLMP rules do not constitute an overall conservation strategy, they are broad guidance. When will DNRC develop conservation strategies for sensitive and old growth associated species? Previous EISs have disclosed that previous logging projects have a negative impact on pileated woodpeckers, fisher, big game and other wildlife. DNRC must mitigate for these previous negative impacts and ensure that future projects do not diminish biological diversity.

DNRC Response: DNRC adopted rules (ARM) for forest management activities in 2003 that incorporate resource management standards and specific mitigation measures for wildlife consistent with the State Forest Land Management Plan (SFLMP). DNRC manages forested state trust lands under coarse filter and fine filter approaches that recognizes that addressing impacts of all species is not reasonable or necessary (SFLMP ROD, 1996). However, species more sensitive to habitat changes associated with forest management activities such as state-listed sensitive species and federally listed threatened and endangered species, are considered in detail using a fine filter approach (SFLMP ROD, 1996 ). The EA addressing the proposed Red Owl Salvage Project addresses activities and related anticipated impacts regarding the prompt salvage of down trees. Comments regarding programmatic policy concerns and differences of opinion are noted, but are beyond the scope of this proposed action and are not considered in further detail in the analysis. All applicable laws, rules, and policies will be followed during the development and implementation phases of this proposed action. Existing habitat availability, quality and potential impacts from the proposed action on wildlife is discussed in more detail in the Wildlife Section of the EA (pp. 8-14). This includes discussion and analysis of grizzly bear, Canada lynx, sensitive species (e.g. fisher) and big game habitat.

8) For all wildlife DNRC needs to quantify what does current habitat availability, local population monitoring, and current status of the species indicate about current population health in this landscape, or in other words, is the current habitat enough? If it is, how much more can you take and still not trigger significant population impacts? If there currently isn’t enough habitat, how can you justify taking more?

DNRC Response: Existing habitat availability, quality and potential impacts from the proposed action on wildlife is discussed in detail in the Wildlife Section of the EA (pp. 8-14). This includes discussion and analysis of grizzly bear, Canada lynx, sensitive species (e.g. fisher) and big


20

game habitat. The scope and detail contained in the analysis is appropriate and consistent with the small scope and limited complexity of this project.

9) Wildlife require corridors to move for foraging, denning, nesting and seasonal habitats. The EIS must disclose: Where are these corridors? What is the habitat quality in them? What size are they? Are they wide enough to protect from edge effects and provide security? Are they fragmented by roads or past logging units? How much canopy cover, thermal cover or hiding cover is in them? How much down woody debris is in them? What type of habitat is considered suitable?

Once these questions have been answered then the project must ensure that adequate habitat linkages are delineated and protected. This is especially important in the project area due to the fragmented habitat. Corridors of interior forest habitat between old growth habitat have been recommended by the old growth Technical Review Team, and they recommend a minimum width of >100 meters. Do you have any actual width criteria you are using at present to define corridors in the project area? DNRC needs to map all corridor habitat in the project area, and define both current and long term objectives for maintaining these corridors over time.

DNRC must disclose whether there have been sightings, nests and/or dens of sensitive, threatened and endangered species in the project area and what is being done to protect them.

DNRC Response: The Project Area contains of variety of habitat conditions for native wildlife species, including open-canopy forest with scattered large trees and dense patches of mature forest. All of these parcels are in the wildland-urban interface and bordered by private lands containing low-density housing developments or private industrial timberlands. No known important corridors or identified linkage zones occur in the project area. No nest sites or den sites are known to occur in the project area that would be affected by the removal of down trees. Approximately 5.2 miles of open roads are present within the Project Area, of which 1.5 miles are comprised of Montana Highway 83 and an adjacent Department of Transportation (DOT) administrative site. Remaining open roads serve adjacent neighborhoods or as access to powerlines that traverse the parcels. Daily motorized use occurs throughout the Project Area. Because of the proximity of these lands to occupied homes and open roads habitat quality and security for many species is adversely influenced. Snags and large downed wood are typically reduced within 300 feet of open roads due to firewood cutting by the public. However, strong wind events in March of 2020 have created large amounts of blown-down, wind-damaged and root-pulled trees throughout the Project Area. Prior to the wind events, the project area contained approximately 165 acres of mature forest stands (trees ≥9” dbh with ≥40% canopy closure. The blowdown event created openings less than an acre in size within this habitat. Approximately 42 acres consist of unforested areas such as Montana Highway 83, gravel pit,


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marshland and the DOT administrative site. Overall, habitat conditions within the project area are suitable for wildlife species that prefer sparsely forested or open forest conditions that are generally tolerant of human disturbance. Additional information is provided on pp. 8-14 of the EA for this project.

10) The EIS must evaluate the impacts of blowdown on forest structure and edge effects. Will your non-salvage operations lead to more blowdown?

DNRC Response: Past human activities and natural disturbances in this area have greatly influenced the size, shape and density of forest patches on both DNRC lands and neighboring ownerships in this area. Removal of down trees under this proposed action will not create additional edge effect or fragment existing forest patches further. Influenced of green harvest that would occur in the vicinity of the project area will be addressed in the Schmidt Creek Timber Sale EA.

11) Has DNRC defined how much deer and elk winter range needs to be maintained over time on this landscape to maintain stable big game populations? What are your management goals for big game winter range and associated populations on state lands? Do you have any limitations on the amount of big game winter range that you can remove over a given period of time?

How will this project affect those elk, mule deer and whitetail deer habitat attributes such as thermal cover, hiding cover, security, etc? How will this project affect moose?

Guidelines for elk security are a minimum of 250 acres for providing security under favorable conditions; under less favorable conditions the minimum must be >250 acres. Effective security areas may consist of several cover-types if the block is relatively unfragmented. Among security areas of the same size, one with the least amount of edge and the greatest width generally will be the most effective. Wallows, springs and saddles may require more cover than other habitats.

DNRC Response: Under forest management ARMs for management of habitat for big game, habitat considerations are addressed with Montana Fish, Wildlife and Parks on a project by project basis. Given the type and location of the project, impacts to big game species including elk, mule deer, white-tailed deer and moose, would be minimal. Thermal cover would not be affected by removing down trees on the project area. Habitat patches suitable as elk security do not occur within the project area.


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12) Where is the current lynx foraging and denning habitat located? How will it be maintained, how will it be improved, how is it connected? How will it be impacted by this project? What are the effects to critical habitat for lynx? Will it be adversely modified? Lynx avoid clearcuts, will this project expand clearcuts and negatively impact lynx? Winter foraging habitat is limited – how much is there? Where is it?

DNRC Response: Approximately 134 acres of suitable Canada lynx habitat occur within the proposed project area. Scattered blowdown harvest would occur across 120 acres of this habitat (89.6% of habitat present). Proposed blowdown harvest would not appreciably alter habitat suitability for use by lynx. Following proposed harvesting, coarse woody debris would remain within levels outlined by Graham et al. (1994) and some large logs (>15 inches in diameter) would be retained within lynx habitat. While lynx use of the project area is possible, it is unlikely due to low snow depths expected at these low elevations, poor connectivity due to interspersed unsuitable habitat, and surrounding human developments. Additional details are provided on pages 8-14 of the Red Owl Timber Salvage EA.

13) What is the current total and open road density? How much grizzly bear core area is there? Will new roads be built? Will roads be

decommissioned? How does this project favor the needs of the grizzly bear?

DNRC Response: Approximately 5.2 miles of open roads are present within the Project Area, of which 1.5 miles are comprised of Montana Highway 83 and an adjacent Department of Transportation (DOT) administrative site. This equates to a very high level of approximately 5 miles per square mile open road density. Grizzly bear security core does not occur in the project area and no additional roads would be constructed or decommissioned under the proposed action. All applicable HCP commitments for grizzly bears would be applied as discussed under the DNRC response to number 4 above.

14) How will this project contribute to viability of sensitive species?

DNRC Response: The proposed removal of down trees would minimally influence sensitive species. Additional details relevant to each species considered can be found on pages 8-14 of the Red Owl Timber Salvage EA.


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15) What monitoring will be done for wildlife? fish? old-growth dependent wildlife? sensitive plants? other? What past monitoring has been done to determine whether the proposed treatments actually achieve the desired results?

DNRC Response: DNRC conducts monitoring of key aspects of the forest management program and provides results annually to the US Fish and Wildlife Service regarding HCP requirements as well as 5-year reports on the forest management program to the Board of Land Commissioners as required under the SFLMP. Information regarding the monitoring program and reports can be found at the following link. http://dnrc.mt.gov/divisions/trust/forest-management/hcp/hcp-implementation-and-monintoring

16) New research shows that the Rocky Mountain Fisher selects for large, old trees, snags and dense overhead cover more than had been previously thought. Research also shows that Fisher do not select and use riparian areas as much as biologists had hypothesized. Retention and recruitment of connected old-growth forest habitats is very important to maintain viability of fisher; relying on riparian buffer zones is not adequate.

How will this project impact fisher and its habitat? The current ARMs are outdated and do not reflect the best available science for fisher. Fisher are currently being evaluated for Endangered Species Act protection.

How will making sure that fisher habitat is sufficient provide for the needs of other wildlife?

DNRC Response: Approximately 22 acres of potential fisher habitat would be subject to salvage harvesting activities (68.3% of fisher habitat available in the project area). Snags and coarse woody debris would be maintained to meet ARMs 36.11.411 through 36.11.414. Crown closure of live trees would not be appreciably affected, as only dead and dying trees would be removed. Habitat suitability of these 22 acres for fishers would be reduced to a minor degree. No new roads would be constructed that could fragment habitat or increase access for trapping and riparian fisher habitat is not present in the project area. Considering the low availability of suitable habitat in the surrounding area, lack of fisher observations within the last 30 years, and prevalence of dry ponderosa pine forest types, which are avoided by fishers, the likelihood of appreciable use of the project area by fishers is low. Additional details regarding effects of the proposed action on fisher can be found in the analysis on pages 8-14 of the Red Owl Timber Salvage EA.




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17) Wolverine are proposed for listing under the Endangered Species Act. The SFLMP does not contain any standards for wolverine and needs to be revised to account for this changed circumstance. New scientific studies are emerging about landscape effects from logging and other human activities on wolverines so habitat usage, prey availability and motorized use must be considered in the EIS.

For example, Fisher, et al Wolverines (Gulo gulo luscus) on the Rocky Mountain slopes: natural heterogeneity and landscape alteration as predictors of distribution found: Wolverines were more abundant in rugged areas protected from anthropogenic development. Wolverines were less likely to occur at sites with oil and gas exploration, forest harvest, or burned areas, even after accounting for the effect of topography.

Wolverines elsewhere avoid human-disturbed areas (Carroll et al. 2001; Rowland et al. 2003; May et al. 2006) and recreational and industrial activity (Krebs et al. 2007). Human activities such as trapping, poaching, and road mortality have accounted for 46% (North America; Krebs et al. 2004) to 52% (Scandinavia; Persson et al. 2009) of known-cause wolverine mortalities across their range.

Wolverines avoid roads and other human development in British Columbia (Krebs et al. 2007), Norway (May et al. 2008), Idaho (Copeland et al. 2007), Montana (Carroll et al. 2001), and throughout the northwestern United States (Rowland et al. 2003).

Wolverine occurrence also increases with topographic ruggedness, where there is a combination of low- and high-elevation habitats. Bighorn sheep (Ovis canadensis Shaw, 1804) (Festa-Bianchet 1988), mule deer (Odocoileus hemionus (Rafinesque, 1817)) (D’Eon and Serrouya 2005), and other ungulates winter at lower elevations; in Scandinavia, wolverines showed significant selection for lower elevation habitats during winter months (Landa et al. 1998). It is possible that wolverines require lower elevations for foraging and higher elevations for predation refuge. Persistent spring snow cover has been hypothesized as important (Schwartz et al. 2009; Copeland et al. 2010) but is not a good predictor at this scale, since spring snow cover was sufficiently persistent across our study landscape to prevent modelling but wolverine occurrence still varied.

Southwest Crown of the Continent monitoring detected wolverines at elevations ranging from 3,346-7,567 feet. Are wolverine currently being displaced by roads? How much more displacement will occur for wolverine as well as other wildlife from this project?


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DNRC Response: No suitable wolverine habitat exists within the project Area. Deep snow does not persist into late spring on parcels within the project area and high-elevation alpine habitat is not present. While wolverines could pass through the project area during normal or exploratory movements, appreciable use of the area is not expected due to unsuitable habitat conditions and high ongoing levels of human disturbance on nearby private lands. Given the large home range area (average 150+ sq. miles) wolverines occupy, and long distances wolverines typically cover during their movements, the proposed activities would not be expected to measurably affect use of the area by wolverines.

Habitat Fragmentation

18) Habitat fragmentation is generally defined as the process of subdividing a continuous habitat type into smaller patches, which results in the loss of original habitat, reduction in patch size, and increasing isolation of patches. (Heilman et al. 2002)

Habitat fragmentation is considered to be one of the single most important factors leading to loss of native species (especially in forested landscapes) and one of the primary causes of the present extinction crisis. Although it is true that natural disturbances such as fire and disease fragment native forests, human activities are by far the most extensive agents of forest fragmentation. For example, during a 20-year period in the Klamath–Siskiyou ecoregion, fire was responsible for 6% of forest loss, while clear-cut logging was responsible for 94% (emphasis added) (Id.)

Depending on the severity of the fragmentation process and sensitivity of the ecosystems affected, native plants, animals, and many natural ecosystem processes (e.g., nutrient cycling, pollination, predator–prey interactions, and natural disturbance regimes) are compromised or fundamentally altered. For many species, migration between suitable habitat patches becomes more difficult, leading to smaller population sizes, decreased gene flow, and possible local extinctions. (Id.)

As native forests become increasingly fragmented, ecosystem dynamics switch from being predominantly internally driven to being predominantly externally driven. Simultaneously, remnant patches become altered by changes within the patches themselves as the remnants become more and more isolated, thereby resulting in further ecological degradation across the landscape. Declines in forest species as a result of fragmentation have been documented for numerous taxa, including neotropical migrant songbirds, small mammals and invertebrates Forest fragmentation has also been associated with increased susceptibility to exotic invasion


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(Id.)

Among the common changes in forests over the past two centuries are loss of old forests, simplification of forest structure, decreasing size of forest patches, increasing isolation of patches, disruption of natural fire regimes, and increased road building, all of which have had negative effects on native biodiversity. These trends can be reversed, or at least slowed, through better management. (Noss 1999)

This project must reduce fragmentation and edge effects and increase patch size and core areas. Past management through even-aged silvicultural prescriptions have contributed to the fragmentation of forest habitat to the detriment of many bird and wildlife species. Large and small openings should be allowed to be created through natural processes rather than clearcut logging.

DNRC Response: Past human activities and natural disturbances in this area have greatly influenced the size, shape and density of forest patches on both DNRC lands and neighboring ownerships in this area. Removal of down trees under this proposed action will not create additional edge effect or fragment existing forest patches further. Influenced of green harvest that would occur in the vicinity of the project area will be addressed in the Schmidt Creek Timber Sale EA.

Roads and Soils

19) How will soils be impacted by this project? Opening up stands will dry them out, how will this impact mychorizal fungi and other soil organisms? How much soil damage is there? Does DNRC have a standard for soil disturbance?

No new roads should be built, not even temporary roads. The existing road network is already too large. Roads fragment habitat and increase mortality for wildlife such as elk, grizzly bear and lynx. Roads degrade stream habitat for fish. Roads take acres out of the timber-growing base.

Roads, even temporary roads, have negative impacts on wildlife and fish habitat including:

a. The greatest surface erosion from roads occurs during the construction phase and first year after.

b. Soil erosion and compaction (as always occurs with roads) causes long-term loss of soil productivity.

c. The loss of topsoil and attendant loss of soil productivity is permanent.

d. Road obliteration does not immediately stop severely elevated soil erosion from roads.

e. Even "temporary" roads have enduring impacts on aquatic resources.


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f. Roads and increased sedimentation cause long-term negative impacts on a variety of aquatic species.

DNRC Response: Physical disturbance from compaction and displacement would be expected on skid trails and landings, though previous trails and lands will be reused if possible. Erosion associated with timber harvest (not including roads) would be expected to have a low risk of occurring because of the nearly flat terrain and the implementation of appropriate Forestry Best Management Practices. Coarse and fine woody debris provide a crucial component in forested environments through nutrient cycling, microbial habitat, moisture retention and protection from mineral soil erosion (Harmon et al., 1986). As required in the DNRC Timber Sale Contract, both fine and coarse woody debris would be retained to reduce potential impacts to forest productivity. Further effects analysis to soil resources can be found in the Red Owl EA.

Cumulative Effects

20) The Environmental Impact Statement must evaluate the cumulative effects of past, present and foreseeable future logging plans in this area. This EIS must include the cumulative effects of that project on wildlife, fish, and water quality.

DNRC Response: Cumulative effects were considered and disclosed under each section of the EA.

Economically Unsuitable Lands

21) The EIS should disclose the net economic gain or loss of logging lands unsuitable for timber management for biological or economic reasons. We request that DNRC permanently remove all unsuitable lands from the timber base as they are identified. This will provide added certainty for wildlife security and reveal a more accurate picture of the forest's economic potential in the future.

DNRC must identify all lands that are unsuitable for timber production. The EIS should disclose what the rate of growth is from past cutting units, and the number of times past logging units have been replanted. Continuing to log in similar areas that have had regeneration problems does not provide any benefit to the school trust.

DNRC must disclose the basis for the growth and yield calculation. What differences are there between past project yield and current project yield? What additional actions is DNRC taking to improve yield? What is present net value?

How will climate change affect growth and yield of these forests and habitat for species? How is DNRC planning to mitigate these effects?


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The failure to complete an adequate economic analysis in the past has created an inflated view of the value of logging over other positive economic assets found on the forest. MEPA alternatives must fully examine other viable economic options. A short-term, cash-flow analysis is not adequate, especially if DNRC must then conduct another timber sale in the future to clean up damage from past sales.

DNRC Response: No economically unsuitable lands occur within the project area. The State is required by law to establish a salvage timber program that provides for the timely salvage of logging of dead or dying timber on State Trust Lands. Under this requirement, the Department shall, to the extent practicable, harvest dead and dying timber before there is substantial wood decay and value loss (Section 77-5-207, Montana Codes Annotated [MCA]). DNRC is responding to this requirement by putting forward the proposed action. Anticipated economic returns are provided on page 18 of the EA. Programmatic considerations addressing growth and yield and program economic viability are beyond the scope of this proposal. Additional details regarding DNRC’s sustainable yield calculation and growth and yield considerations can be found at the links provided below.

http://dnrc.mt.gov/divisions/trust/forest-management/sustainable-yield-calculation/2020SYC/FinalSYC_2015_FinalReport_20150910.pdf

Climate Change

22) Climate change is happening, it is affecting plant growth, stream flows, forests and weather patterns and it will intensify. Neither DNRC's Administrative Rules for Forest Management and Streamside Management nor the Habitat Conservation Plan for listed species fully considers the impacts of climate change.

Past conditions will not predict the future in the wake of climate change. The Montana Climate Assessment (MCA) [Found at http://montanaclimate.org/] is an effort to synthesize, evaluate, and share credible and relevant scientific information about climate change in Montana. It must be considered in development of HBRC. Following are key messages and conclusions:

KEY MESSAGES

• Annual average temperatures, including daily minimums, maximums, and averages, have risen across the state between 1950 and 2015. The increases range between 2.0-3.0°F (1.1-1.7°C) during this period. [high agreement, robust evidence]



http://montanaclimate.org/


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• Winter and spring in Montana have experienced the most warming. Average temperatures during these seasons have risen by 3.9°F (2.2°C) between 1950 and 2015. [high agreement, robust evidence]

• Montana’s growing season length is increasing due to the earlier onset of spring and more extended summers; we are also experiencing more warm days and fewer cool nights. From 1951-2010, the growing season increased by 12 days. In addition, the annual number of warm days has

increased by 2.0% and the annual number of cool nights has decreased by 4.6% over this period. [high agreement, robust evidence]

• Despite no historical changes in average annual precipitation between 1950 and 2015, there have been changes in average seasonal precipitation over the same period. Average winter precipitation has decreased by 0.9 inches (2.3 cm), which can mostly be attributed to natural variability and an increase in El Niño events, especially in the western and central parts of the state. A significant increase in spring precipitation (1.3-2.0 inches [3.3-5.1 cm]) has also occurred during this period for the eastern portion of the state. [moderate agreement, robust evidence]

• The state of Montana is projected to continue to warm in all geographic locations, seasons, and under all emission scenarios throughout the 21st century. By mid century, Montana temperatures are projected to increase by approximately 4.5-6.0°F (2.5-3.3°C) depending on the emission scenario. By the end-of-century, Montana temperatures are projected to increase 5.6-9.8°F (3.1-5.4°C) depending on the emission scenario. These state-level changes are larger than the average changes projected globally and nationally. [high agreement, robust evidence]

• The number of days in a year when daily temperature exceeds 90°F (32°C) and the number of frost-free days are expected to increase across the state and in both emission scenarios studied. Increases in the number of days above 90°F (32°C) are expected to be greatest in the eastern part of the state. Increases in the number of frost-free days are expected to be greatest in the western part of the state. [high agreement, robust evidence]

• Across the state, precipitation is projected to increase in winter, spring, and fall; precipitation is projected to decrease in summer. The largest increases are expected to occur during spring in the southern part of the state. The largest decreases are expected to occur during summer in the central and southern parts of the state. [moderate agreement, moderate evidence]

This EIS must fully evaluate whether logged areas will regenerate and how changes in precipitation patterns affect streams.

DNRC Response: We agree that important information is contained in the Montana Climate Assessment (2017) -- particularly the findings in Chapter 4 that specifically address climate influences on forest conditions. Effects are likely to vary given how precipitation amounts and patterns may be influenced through time, and the possibility of growing season being extended due to warming trends etc. Influences of changing wildfire risk are also important considerations. Removal of down trees proposed in this project would have no effect on global


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climate change. Further, carbon emissions associated with short-term use of mechanized logging equipment would have an additive, but minimal effect on global climate emissions. DNRC continues to believe that managing for natural disturbance patterns, processes and species representations on forested state trust lands is the best way to manage in support of biodiversity and species endemic to Montana. Future changes in forest conditions and compositions will continue to be noted, tracked and addressed in conjunction with future sustainable yield calculations as influenced by each current forest inventory.

Weeds

23) Controlling weeds and preventing their spread is a huge issue that DNRC does not have a grip on. Current methods are obviously not working, weeds spread on forest roads, in cutting units, landings, burn piles, and on to private property. The best way to prevent weeds from spreading out of control is not to disturb the native vegetation.

So what plan does DNRC have for weeds in the project area?

It is likely that this project will spread more weeds, they must be eradicated not spread. Washing equipment does not work, please do not attempt to dupe the public into believing that the same past failed mitigation measures to control weeds will somehow miraculously work in this project. DNRC cannot just resigns itself to the fact that there will be an invasive species problem in the project area indefinitely. This is not adequate.

DNRC Response: Under the proposed action, approximately 3 acres would be covered using spot spraying treatments. Spot spraying would target log landing areas and roadways. Upon reclamation and final blading, roads would also be grass seeded to mitigate spread. Logging equipment would be washed prior to entering the sale area and would be inspected by the forest officer on the sale to ensure that it is done to meet contract standards. Follow up spot treatments would occur in harvest units and on skid trails following logging as needed. The DNRC has a noxious weed management plan they follow as well to try to mitigate the spread of noxious weeds due to timber sales. Weed-related effects associated with the proposed action are addressed on pages 4 and 5 of the project EA.

Costs

DNRC must track the costs expended to plan and implement this timber sale. Without this information it cannot accurately determine whether revenue is being generated for the school trust.

DNRC Response: Revenue received from each timber sale is tracked and recorded using an accounting database. Total project revenue is computed by summing all project payments received and recorded. Operational expenses are tracked and recorded at the land office level in a separate accounting database. Costs are primarily DNRC wages and are not project specific but are averaged across all timber sales managed in a given accounting period across each land office. Costs relating to contracted development work are estimated by comparing the development work to previous contracts executed on timber sales in the same region. Detailed revenue information is published yearly by DNRC in the Fiscal Year Annual Report. Detailed


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expense information is published yearly by DNRC in the Return on Assets Report. Both reports are available on DNRC Trust Land Management Division’s website.

http://dnrc.mt.gov/divisions/trust

24) Given the paucity of information in your scoping notice and scant time given the public to comment you should extend the comment deadline, provide more information and publicize this project so that folks are aware of it. We expect our comments to be fully considered in the EIS.

DNRC Response: We apologize for the expedited timeline to address the urgent circumstances associated with this project. Thank you for your comments.

Sincerely, /s/Arlene Montgomery Program Director

Literature Cited

Fisher, J.T., S. Bradbury, B. Anholt, L. Nolan, L. Roy, J.P. Volpe and M. Wheatley. 2013. Wolverines (Gulo gulo luscus) on the Rocky Mountain slopes: natural heterogeneity and landscape alteration as predictors of distribution. Canadian J. Zool. 91:706-713.

Hauer, F.R., G.C. Poole, J.T. Gangemi and C.V. Baxter. 1999. Large woody debris in bull trout (Salvelinus confluentus) spawning streams of logged and wilderness watersheds in northwest Montana. Canadian Journal of Fisheries and Aquatic Science (56):915-924.

Heilman, Gerald E. Jr., Strittholt, James R., Slosser, Nicholas C., Dellasalla, Dominick A., 2002. Forest Fragmentation of the Coterminous United States: Assessing Forest Intactness through Road Density and Spatial Characteristics. BioScience, Vol. 52 No. 5.

Noss, R.F. 1999. Assessing and monitoring forest biodiversity: a suggested framework and indicators. Forest Ecology and Management 115:135-146.

Pfister, R.D., W.L. Baker, C.E. Fiedler, J.W. Thomas. 2000. Contract review of old-growth management on school trust lands: Supplemental Biodiversity Guidance 8/02/00. 30 p.

Weaver, T. and J.J. Fraley. 1991. Fisheries habitat and fish populations. Pages 53-68 in: Flathead Basin Cooperative Program Final Report. Flathead Basin Commission. Kalispell, MT.

http://dnrc.mt.gov/divisions/trust


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