Pike & San Isabel National Forests
Cimarron & Comanche National Grasslands

Publications - Decision Notice

 DECISION NOTICE
AND
FINDING OF NO SIGNIFICANT IMPACT

Upper South Platte Watershed Protection
and Restoration Project

Vegetation Treatment Subproject in Inventoried Roadless Areas

USDA Forest Service
Rocky Mountain Region
Pike and San Isabel National Forests
South Platte Ranger District
Douglas and Jefferson Counties, Colorado

INTRODUCTION

The Upper South Platte watershed is located in the foothills of the Colorado Front Range of the Rocky Mountains. The Project Area is approximately 140,000 acres in total area (public and private lands) and encompasses three sub-watersheds of the Upper South Platte River watershed, including Horse Creek, Waterton/Deckers, and Buffalo Creek subwatersheds. These watersheds are located in Jefferson and Douglas Counties, southwest of Denver.

The U.S. Forest Service in cooperation with the Colorado State Forest Service and Denver Water assessed the 640,000-acre Upper South Platte Watershed to identify and prioritize restoration opportunities, focusing on forested areas that are not sustainable as evidenced by their departure from historical conditions. The partners determined the primary issues and goals for this project by completing and reviewing the Upper South Platte Watershed Landscape Assessment (Foster Wheeler Environmental 1999). The Waterton/Deckers/Horse Creek subwatersheds were ranked highest for needing restoration management based on their high risk of fire and soil erosion.

The current forested landscape condition does not reflect the historic disturbance regime and is not sustainable. Past land uses and management have resulted in relatively dense, even-aged, closed-crown forest condition throughout the ponderosa pine/Douglas-fir forest with a much higher risk of catastrophic fire compared to pre-settlement conditions. The existing small trees serve as ladder fuels, permitting surface fires to climb into the tree canopy and become crown fires. Wildfire would occur as a high-intensity crown fire under hot, dry, and windy conditions that are common in early summer. Modification of forest structure and composition to pre-settlement conditions would help fire-control efforts and reduce the likelihood of future large-scale fires. The USDA Forest Service prepared an Environmental Assessment (EA) for the Upper South Platte Watershed Protection and Restoration Project that was released for public review in August 2000. The EA describes the proposed actions and the potential environmental effects. The EA describes alternatives to the proposed action and the effects those alternatives may have on the environment.

The EA evaluated four subprojects including: 1) vegetation treatments, 2) Buffalo Creek burn area revegetation, 3) road reclamation, and 4) South Platte River access trail improvements (see EA pages 2-10 to 2-17). Decisions for the four subprojects were anticipated to be independent of one another to best address the purpose and need (see EA pages 1-13 and 1-14). The Decision Notices for the reclamation of unclassified roads, the South Platte River access trail improvements, and the Buffalo Creek burn area revegetation subprojects are separate documents. The Gill Trail Improvement was approved on February 2, 2001 and the Buffalo Creek Tree Planting on March 1, 2001.

Commentors on the EA requested a map showing the entire roadless area boundaries and clarification of the alternatives. A map with the roadless area boundaries is attached. The alternatives are clarified below.

The decision on the vegetation treatment will be made in two parts. This Decision Notice is for vegetation treatment within Inventoried Roadless Areas. A separate Decision Notice for vegetation treatment outside of Inventoried Roadless Areas and Forest Plan Amendment 28 has been signed. The vegetation treatment within Inventoried Roadless Areas is consistent with the Roadless Area Conservation Final Rule and Record of Decision published January 12, 2001 and current Chief’s direction.

DECISION
This decision, on vegetation treatment within Inventoried Roadless Areas, was made following review of the EA, supporting materials referenced by the EA, and additional information contained in the Decision Notice and response to comments in Attachment B to the Decision Notice/FONSI for the Vegetation Treatment Subproject in Non-Roadless Areas. The analysis in the EA was done for all the proposed vegetative treatments, whether outside or inside roadless areas. This decision modifies the selected alternative from that described in the EA and has been adequately analyzed in the EA. This decision adds the Inventoried Roadless Area of the project area to the prior decision for the non-roadless areas (see the Decision Notice/FONSI for the Vegetation Treatment Subproject in Non-Roadless Areas). The potential environmental impacts to the combined Inventoried Roadless Areas and non-roadless areas have been disclosed in the EA.

Vegetation Treatments
I have decided to implement Alternative B (proposed action in the EA) for the Inventoried Roadless Areas portions of the vegetation treatment areas with modifications in response to public and agency input on the project. Alternative B as modified for the Inventoried Roadless Areas includes the following actions:

1. Use adaptive management to treat up to 5,200 acres (See Inventoried Roadless Areas Vegetation Treatment Areas Map).
2. Thin stands on 4,200 acres.
3. Intersperse 1 to 40- acre persistent openings on 1,000 acres.
4. Remove logs from 3,400 acres.
5. Improve Pawnee montane skipper habitat on 1,400 acres.
6. Phase the first two years of work to facilitate adaptive management.
7. Monitor and mitigate OHV use in treatment areas.
    

VEGETATION TREATMENT DESCRIPTION
The vegetation treatment will include thinning, creating openings, prescribed burning, and removing trees on up to 5,200 acres within the Waterton/Deckers/ Horse Creek subwatersheds. The treatments will generally be below 7,500 feet elevation. The purpose of the project is to: 1) reduce the risk of large-scale fires and subsequent erosion in the watershed that could threaten property and human life and exacerbate soil and water quality problems; 2) restore the forest to more sustainable conditions; and 3) improve up to 1,400 acres of habitat used by the federally-listed Pawnee montane skipper. A detailed description of the proposal and effects is in the environmental assessment. The main elements of the proposed project, including elements added or modified to address public and agency input on the project, are listed below.

1. Treat vegetation using adaptive management to ensure protection of resources
   1. Monitor operations and treatment areas during the life of this project to ensure management and resource protection objectives are achieved (see monitoring below).
   2. Phase the first two years of work to allow time to evaluate the treatment activities and identify any potential problems that may require remedial measures or modifications to treatment prescriptions. Upon completion of the project approximately 75 to 80% of the treated acres will be thinned, 20 to 25% of the treated acres will be created openings, and up to 100% of the treated acres will be prescribed burned
   3. After the first two years, the area treated annually may be increased based on the outcome of monitoring during the first two years.
2. Thin trees to a canopy closure of about 25 percent on up to 4,200 acres. The residual stand basal area will average 40-60 square feet per acre (or approximately 50-75 trees per acre). The following guidance and constraints will be used:
   1. The residual stand will be resilient to surface fires and have a low risk of sustaining a crown fire. Preference will be given to retaining ponderosa pine over Douglas-fir and retaining larger trees with few low branches. More Douglas-fir will be retained on north aspects and higher elevations with few Douglas-fir retained on east, south, and west aspects in the lower elevations. Larger more mature trees will typically be retained. The spacing will be variable retaining natural clumpy characteristics. Retain existing snags that are not a hazard, for cavity-dependent wildlife.
   2. The landscape is deficient in old-growth forests. Ponderosa pine and Douglas-fir stands that meet old growth standard defined in Old-Growth Forests in the Southwest and Rocky Mountain Regions Proceedings of a Workshop, USDA Forest Service General Technical Report RM-213, and any trees identifiable as being over 150 years old will be retained to help achieve future old-growth conditions. Larger trees will generally be retained throughout the treatment areas, but some larger trees will be cut. Areas that do not meet the old-growth standard but have larger trees where the local residual stocking is greater than 80 square feet of basal area per acre will be thinned to approximately 60 square feet of basal area. Priority will be given to retaining the largest ponderosa pine and then the largest Douglas-fir. The residual stand will be kept on a trajectory to achieve an old-growth condition.
   3. Lop and scatter slash left on-site or crush with yarding and harvesting equipment. Heavy slash will be piled.
   4. Thinning operations will comply with the conservation measures outlined in the Biological Opinion (USFWS 2001); the Water Conservation Practices and BMPs listed in the EA; and the standard and guidelines listed in the Land and Resource Management Plan, Pike and San Isabel National Forests; Comanche and Cimarron National Grasslands (Forest Plan) as amended.
3. Create 1 to 40-acre openings on up to 1,000 acres under the following guidance and constraints:
   1. Openings will be dispersed where they would most likely have naturally persisted the longest. The openings will be in areas that have regenerated in the past 120 years and will primarily be located on south and west aspects. Approximately 80 to 90% of the openings will be 5 acres or less. Openings larger than 5 acres will be created only where there is evidence that a larger opening existed historically. These sites will have few if any trees greater than 100 years old, no stumps, and little or no organic soil development. No openings will be greater than 40 acres. Retain existing snags that are not a hazard, for cavity-dependent wildlife.
   2. Approximately 40% of the acres in openings will have no trees and the remaining 60% will have canopy closures of 1-10%.
   3. Lop and scatter slash left on-site or crush with yarding and harvesting equipment.
   4. Openings and operations to create openings will comply with the conservation measures outlined in the Biological Opinion (USFWS 2001); the Water Conservation Practices and BMPs listed in the EA; and the standard and guidelines listed in the Forest Plan as amended.
4. Prescribe burn up to 5,200 acres under the following guidance and constraints:
   1. Prescribe burn logs and slash after material has sufficiently dried, one to two years after completing mechanical treatments.
   2. Prescribe burn the new openings again 5 to 6 years later if necessary to minimize tree regeneration, then every 10 to 30 years as needed to maintain the openings.
   3. Prescribe burning will comply with the conservation measures outlined in the Biological Opinion (USFWS 2001); the Water Conservation Practices and BMPs listed in the EA; and the standard and guidelines listed in the Forest Plan as amended.
5. Remove logs from up to 5,200 acres under the following guidance and constraints:
   1. Harvesting equipment will not be allowed on slopes greater than 30% to remove logs from an estimated 1,200 acres, unless the contractor can demonstrate ability to remove logs without environmental damage. No vegetation treatments will occur on any slopes greater that 40%. Approximately 1,000 additional acres will not have logs removed because it would be economically infeasible.
   2. Use forwarders or other approved methods to remove logs from approximately 3,000 acres to existing roads. If other methods are approved, they must maintain the roadless character and have effects similar to a forwarder system.
6. Access the treatment areas under the following guidance and constraints:
   1. No roads will be constructed or reconstructed in the 5,200 acres of Inventoried Roadless Areas within the treatment area. Existing roads (both within and outside of the Inventoried Roadless Areas) will be routinely maintained to prevent resource damage.
   2. Vegetation screens will be retained immediately adjacent to open roads where there is potential to increase unauthorized off-road access.
   3. Existing unclassified roads used to access the treatment areas will be obliterated by combination of water barring, scarifying, seeding, and blockading access after treatments are completed. Biosolids may be used as a soil amendment to accelerate revegetation.
7. Monitor project area resources to ensure resource management objectives are achieved:
   1. Monitor federally listed species according to the Biological Opinion and carry out required conservation measures (USFWS 2001).
   2. Monitor Management Indicator Species (MIS) and Forest Sensitive Species that may be directly affected by the project. Species that will be monitored in the project area include: Abert’s squirrel, brook trout, elk, fox sparrow, golden-crowned kinglet, mountain bluebird, mule deer, olive-sided flycatcher, northern goshawk, pygmy nuthatch, three-toed woodpecker, turkey, Wilson’s warbler, and Virginia’s Warbler.

      
      If MIS or Forest Sensitive Species are found during monitoring surveys, then apply the following protection measures as appropriate:

      1. No ponderosa pine with signs of active Abert’s squirrel nesting or feeding will be cut.
      2. No elk and mule deer calving and fawning concentration areas will be modified or disturbed from May 15 – June 30.
      3. No treatment activities will occur within a 650-foot buffer surrounding northern goshawk nest sites.
         iv. No treatment activities will occur within a 2,500-foot buffer surrounding active northern goshawk nests during post-fledgling periods (March thru September).
      4. Protect other raptor nesting sites using measures similar to those for goshawk.
      5. Apply Forest Plan standards and guidelines for wildlife.

      If the Forest Plan general directions, standards, and guidelines for wildlife and fish resources and habitat improvement and maintenance are not achieved, then:

         vi.   Reduce or modify vegetation treatment operations and/or
        vii.   Increase species monitoring to determine the source of impact and apply appropriate mitigation.

       

   3. Monitor vegetation and noxious weeds according to the “Upper South Platte Watershed Protection and Restoration Project Monitoring Strategy.” If the Forest Plan general directions, standards, and guidelines for habitat improvement and maintenance are not achieved, then
      1. Reduce or modify vegetation treatment operations and/or
      2. Increase use of noxious weed control measures
      3. Increase noxious weed monitoring to determine the source of impact and apply appropriate mitigation.
   4. Monitor soil erosion and water quality, including implementation and effectiveness of water conservation practices and other mitigation, according to the “Upper South Platte Watershed Protection and Restoration Project Monitoring Strategy.” If the Forest Plan general directions, standards, and guidelines for soil and water resources are not achieved, then:
      1. Reduce or modify vegetation treatment operations and/or
      2. Increase the use of Water Conservation Practices and BMPs
      3. Increase soil and water quality monitoring to determine the source of impact and apply appropriate mitigation.
   5. Monitor off-highway vehicle (OHV) use within the treatment area. If the Forest Plan general directions, standards, and guidelines for dispersed recreation, including OHV use, are not achieved, then:
      1. Scarify, seed, and block unauthorized OHV trails and/or
      2. Gate and/or sign with “closed to motor vehicles” to discourage use of temporary roads or unauthorized OHV trails and increase law enforcement.
8. Treat vegetation within 500 feet of private property under the following guidelines:
   1. Work cooperatively with private landowners to address their concerns about forest conditions on public lands managed by the Forest Service adjacent to their land. Treat national forest lands adjacent to private lands using the guidance and constraints listed under items 1 thru 7 above.

INFORMATION RELEVANT TO MY DECISION
The following are the key pieces of information related to my decision.

Information contained in the three-volume Landscape Assessment for the Upper South Platte Watershed (Foster Wheeler Environmental 1999) was considered. The U.S. Forest Service in cooperation with the Colorado State Forest Service and Denver Water assessed the 640,000-acre Upper South Platte Watershed to identify and prioritize restoration opportunities within the watershed, focusing on forested areas that are not sustainable as evidenced by their historical conditions. The Waterton/Deckers/Horse Creek subwatersheds were ranked highest for needing restoration management based on their high risk of fire and soil erosion.

The purposes of the proposed vegetation treatments are to reduce the risk of large-scale fires and subsequent erosion in the Upper South Platte watershed, that could threaten property and human life and exacerbate soil and water quality problems, and to create or restore the forest to more sustainable conditions. The proposed action of these treatments also has the goal of improving Pawnee montane skipper habitat in order to reverse the current downward trend of this threatened butterfly.

The current forest conditions combined with greater human encroachment into forestlands have dramatically increased the risk of loss of life and property from wildfires in recent years. The current forested landscape condition does not reflect the historic disturbance regime and is not sustainable. Past fire control (suppression), logging, and grazing allowed smaller, thin-barked trees to proliferate. This resulted in relatively dense, even-aged, closed-crown forest conditions throughout the ponderosa pine/Douglas-fir forest that have a much higher risk of catastrophic fire compared to pre-settlement conditions which were surface and mixed severity fires. Because the forests have very little down wood to permit low-intensity ground fires, prescribed fires alone are unable to modify the forest structure. The existing small trees serve as ladder fuels, permitting surface fires to climb into the tree canopy and become crown fires. Wildfire will carry as a high-intensity crown fire under hot, dry, and windy conditions that are common in early summer.

The 1996 Buffalo Creek fire and the 2000 Hi Meadow fire clearly demonstrated the devastation a large-scale high-intensity fire can cause. The Buffalo Creek fire burned almost 10,000 acres in less than 11 hours and eventually burned a total of 12,000 acres. Fire suppression cost $2.5 million and emergency rehabilitation cost $1.6 million. The fire destroyed several homes and essential forest cover on highly erodible soils. Heavy rainfall and floods following the fire resulted in two fatalities and caused substantial erosion and sedimentation. The fire also severely impacted downstream reservoirs that supply water to the Denver metropolitan area. Nearly 80 percent of the water used by the 2.5 million Denver metropolitan residents comes from or is transmitted through this river drainage. The Denver Water Board spent nearly $1 million on water quality cleanup and dredging operations at Strontia Springs reservoir after the flood. They anticipate spending an additional $10 to 15 million on future cleanup, dredging, and water treatment modifications over the next 10 years because of the Buffalo Creek fire.

In June 2000, the Hi Meadows fire burned nearly 11,000 acres, including a small portion of the Project Area. This fire destroyed 58 structures, including 51 homes. The fire followed a hot and dry period. These conditions, combined with high winds, created a high-intensity, and fast-moving crown fire in portions of the burn area. The fire suppression efforts cost nearly $5 million. Heavy rains have caused erosion and flooding, although not to the extent of the Buffalo Creek fire. The potential for further erosion and flooding from the Hi Meadow fire is unknown at this time because the fire was so recent.

Current research in the Upper South Platte watershed and knowledge of wildfire behavior indicate that modification of forest structure and composition, as proposed in this EA, will help fire-control efforts and reduce the likelihood of future large-scale fires. The Hi Meadow Incident Operations Report (June 2000) examined the impact previous forest management activities had on the behavior of this fire. It was found that “it is evident that thinning and prescribed fire reduced the spread and intensity of the High [sic] Meadow wildfire.”

The proposed actions are also needed to help protect recreational resources, including the highly regarded South Platte River trout fishery, within the Project Area. This project will also increase forest vegetation and wildlife diversity and increase resistance to widespread insect and disease. The project will improve habitat for the threatened Pawnee montane skipper.

REASONS FOR MY DECISION
Substantive Comments on the EA

The EA was available for public review from August 11 to October 16, 2000. The Forest Plan Amendment was available for public review from June 15 to July 16, 2000. The Forest Service received 53 public comment letters on the EA and an additional 33 letters on the amendment. The EA team reviewed and responded to all substantive comments. Issues raised by the public, including a summary of the substantive comments and responses to those comments, are addressed in the Public Review of the Environmental Assessment, Upper South Platte Watershed Protection and Restoration Project and Forest Plan Amendment 28 document.
Key Issues

The interagency group of partners that includes the U.S. Forest Service, Colorado State Forest Service, Denver Water, and Environmental Protection Agency initiated the Upper South Platte Watershed Protection and Restoration Project in August 1998. They were concerned about continued soil and water problems from the Buffalo Creek Fire of 1996 and the potential for future fires to cause problems in other parts of the watershed. The partners also wanted to address issues identified by the Colorado Unified Watershed Assessment which concluded that the Upper South Platte River as a high priority watershed in need of restoration. The partners determined the primary issues and goals for this project by completing and reviewing the Landscape Assessment for the Upper South Platte Watershed (Foster Wheeler Environmental 1999). Key issues addressed in the Landscape Assessment included relationship between the existing forest vegetation, soil erosion and transport to streams, as well as future risks of catastrophic disturbances that could increase soil erosion and transport. The intent of the Landscape Assessment was to study ecological processes and develop recommendations to restore and maintain the health of the Upper South Platte Watershed.

The public scoping and specialist’s input from US Forest Service, project partners, and the NEPA contractor contributed to issue identification and alternative development. Scoping identified three key issues for defining the purpose and need for the proposed action. These issues and the objectives of the actions proposed by the EA are presented in Table 1. The scoping process identified mechanical vegetation treatment activities in roadless areas as a key issue that formed the basis for two alternatives to the proposed action, Alternatives A and C. Alternative C minimized activities in the roadless areas by not allowing mechanical entry or removal of harvested trees, while striving to meet the project’s objective. Alternative A (no action) would have no vegetation treatment activities in Inventoried Roadless Areas, but it would not meet project objectives. Alternatives A and C would not use biosolids.

 

Science
Scientists (Kaufmann et al. in preparation; Huckaby et al. 2000; Kaufmann et al. 2000; Brown et al. 1999; and Kaufmann et al. 1999) have been studying historical landscape conditions on Denver Water’s Cheesman Lake property with the Pike and San Isabel National Forests since 1995. They have shown that the historic Cheesman Lake forest was less dense, more open, and less vulnerable to large-scale fires than the current condition of the surrounding forested landscape. The historical fire behavior in this area followed a mixed severity fire regime characterized by a combination of surface fire and patchy crown fire. They concluded that past logging, grazing, tree planting, and fire suppression has substantially increased the current forest density and amount of Douglas-fir and small trees that act as a ladder fuel for fires. As a result, the current forest conditions favor a crown fire regime, with a high risk of catastrophic stand-replacing fire. These higher-severity fires are more apt to have detrimental effects on soil and watersheds, as well as wildlife habitat (Brown 2000). Because conditions are well outside the historic range of variability within the Forest, research scientists believe that managers must mechanically remove wood to break up the dense, continuous forest (Kaufmann et al. 2000). Dry forests offer the clearest opportunities for thinning in conjunction with prescribed fire to contribute to restoration of wildlife habitat while making the forests more resistant to uncharacteristically severe fire (Brown 2000). Because openings are an important and transient part of the landscape, removing dense, young trees and retaining old trees will do much to restore the ecosystem and at the same time reduce wildfire risk. Such ecological restoration is compatible with reduction of hazard of catastrophic fire and insect outbreak (Veblen et al. 2000). Creating a more open forest will result in a more grassy understory that will burn at lower fire intensities, increase tree, shrub, and grass survival, and reduce soil erosion (Kaufmann et al. 2000).

Kaufmann and others (in preparation) indicated that more than 90% of the historical landscape had a crown closure of 30% or less. In contrast, only 50% of the current nearby forests affected by logging, grazing, tree planting, and fire suppression has crown closure of 30% or less. In other words, the historical forest stands were much more open. They describe four basic stand conditions in the area: 1) openings vegetated primarily with grasses and shrubs, 2) patches that are pure or nearly pure ponderosa pine, 3) patches having both ponderosa pine and Douglas fir, and 4) patches of very old trees, persistent old growth. Historically, approximately 15% of landscape had persistent old-growth patches. Pure ponderosa pine patches accounted for 35-50% of the landscape, primarily on east, south, and west slopes. Ponderosa pine/Douglas fir patches on north slopes and portions of other aspects accounted for 20-30% of the landscape, and at least 25% of the landscape was open, with no more than 10% tree crown closure. Undoubtedly these proportions varied over time, especially when fires created openings, reduced tree densities, or killed young Douglas fir trees invading patches (Kaufmann et al. in preparation). The departure from the historical landscape conditions was used to help develop the purpose and need. Actions to address this departure became the proposed action.

The current conditions resulted as the patch proportions shifted dramatically because the effects of logging, grazing, fire suppression, and tree planting contributed to increased forest density. Logging decreased the amount of old growth. Grazing helped the establishment of new seedlings by reducing the grass that normally carried surface fires and competed for soil moisture. The lack of fire allowed more seedlings to survive. The result was a sharp increase in forest density, expansion of the area having a significant Douglas-fir component, and the loss of openings following a temporary increase during intense logging during the late 1800’s (Kaufmann et al. in preparation). Because the lower montane forests are well outside the historic range of variability, recent vegetation disturbances such as fire and insects have had a greater influence on the vegetation trends than forest management activities (Thinnes 2001; Veblen et al. 2000).

Rationale
I selected Alternative B, with the modifications described above, because it provides the best means to reduce the risk of large-scale fires, improve habitat for the Pawnee montane skipper, and restore the forest to more sustainable conditions. Alternative B is science-based and has the support of residents within the Project Area. The required mitigation measures combined with monitoring and adaptive management ensure the Project’s objectives will be achieved while protecting the resources. Alternative B will best achieve the desired landscape conditions and is well supported by scientists, other government agencies, and the local residents. Alternative B meets the purpose and need of the project. Alternative B complies with the Forest Plan by providing for fuels reduction, public health and safety, sustainable ecosystems, merchantable timber from the suitable timber base, health and vigor of all vegetation types, reduced soil erosion, improved water quality, protection of riparian and wetland areas, improved wildlife habitat and diversity, species population viability, recovery of endangered and threatened species, increased elk and deer winter range habitat capability, maintenance of air quality, protection of visual quality, and protection of cultural resources (see EA chapter 4).

Under Alternative C, no logs would be removed from Inventoried Roadless Areas and contiguous unroaded areas greater than 1,000 acres. Thus, Alternative B will leave less downed material than Alternative C. This dried and downed material will be prescribe burned at a later date. The prescribed burns will potentially cause less air pollution, produce less intense heat, be less hazardous, and have less fuel loading under Alternative B than Alternative C, because there will less downed material to burn. Prescribed fires under alternative B will cause less heat-related stress to remaining trees and less potential for bark beetle attack and mortality. Alternative B will generate less smoke and have a fewer number of smoky days affecting local communities. Alternative B will also generate more revenue from logs than Alternative C.
Alternative A would defer restoration action at this time. Deferring actions would not reduce the risk of large-scale fires and the subsequent erosion that would threaten property and human life and exacerbate soil and water quality problems. It also would not create or restore the forest to more sustainable conditions, which are necessary to improve habitat for the Pawnee montane skipper. I have decided that the risk of fire and other consequences by deferring action at this time are not prudent. Alternative A does not meet the purpose and need of the project.

Alternative C is similar to Alternative B for the non-roadless portions of the vegetation treatment areas. Alternative C would not remove logs from unroaded areas in addition to RARE II Inventoried Roadless Areas. Alternative C meets the purpose and need of the project. I have decided that leaving all felled material in the unroaded areas followed by prescribed fire would result in unnecessary smoke emissions. The heavy fuels would result in prescribed fire being less likely to fully achieve the stand and landscape objectives in areas where the logs would be left in place.

Therefore, Alternative B as modified best meets the Purpose and Need for this project area.

PUBLIC INVOLVEMENT
A total of nine public meetings were held from February through May 2000. Over 115 people attended these meetings. A slide show, handouts, and maps about the proposed action were presented at the meetings. Dr. Merrill Kaufmann presented information about his research on the historic forested landscape near the project area. Newsletters were sent out to 607 individuals, agencies, organizations, and elected officials and only a few responses were received. These newsletters contained a description of the proposed activities and a map showing the location of the proposed vegetation treatment areas. These newsletters asked for public input and invited the public to attend three scoping meetings that were held at local communities near the project area between May 2 and May 4, 2000. In addition, the project partners conducted numerous tours with elected officials, agency representatives, and local landowners. The majority of people that attended these meetings and tours expressed support for the project. The public involvement effort is documented in the EA (see pages 2-6 through 2-8).

Over 500 EAs were distributed to individuals, agencies, organizations, and elected officials plus the full EA was posted on the Internet. The EA was available for public review from August 11, 2000 to October 16, 2000. In response to public requests, the comment period on the EA was extended twice to 66 days. The Forest Service received 53 public comment letters on the EA.

The Forest Plan Amendment was also available for public review from June 15 to July 16, 2001. The Forest Service received 33 public comment letters on the amendment.

ALTERNATIVES CONSIDERED
Three alternatives were considered in detail (the No Action, the Proposed Action and one alternative to the Proposed Action). A primary goal of the Proposed Action is to restore the forest to a sustainable condition by reducing tree density and creating persistent openings in the forest canopy. The other two alternatives include the “No Action” alternative and an action alternative that addresses the issue of activity in roadless areas. The alternatives are discussed in Chapter 2 of the EA (pages 2-10 through 2-17). See Table 2, Comparison of Alternatives for Vegetation Treatment Subproject, at the end of this section. An alternative to avoid treatments in Pawnee montane skipper habitat was not considered in detail because the project could improve habitat for this federally-listed species (EA page 2-9).

ALTERNATIVE A – NO ACTION
The No-Action alternative, which is required by National Environmental Policy Act (NEPA), addresses the issue of “no activity in roadless areas”. Current forest management would be continued with no different actions taken to reduce fire risks or stream sedimentation. There would be no landscape restoration to pre-settlement conditions, or reduction of catastrophic wildfire risk. The current fire policy for the Project Area would remain. This policy requires controlling wildfires with emphasis on protecting property or developments. This includes mixed severity fires, which are part of the historical fire regime, in areas of dense forest.

In the Buffalo Creek burn area, natural revegetation processes would be allowed to occur. Riparian sediments would be stabilized over time by natural accumulation of woody debris and reforestation of the uplands by natural succession. The existing sediment deposits would gradually erode into streams until stabilized by natural processes.
Existing roads would be maintained as necessary to control erosion. There would be no active road reclamation, except for the Wildcat Area as determined by previous decisions. All designated trails would be maintained to reduce erosion. There would be no additional trail improvements, except maintenance of drainage structures and vegetation to control erosion.

There would be no habitat improvement for the Pawnee montane skipper.

ALTERNATIVE B – PROPOSED ACTION
This alternative is described in Chapter 2 of the EA. The overall concept of the alternative is to meet the purpose and need for landscape restoration and catastrophic wildfire risk reduction by thinning, creating openings, and using prescribed fire. This alternative would also meet the purpose and need of improving habitat for the federally-listed Pawnee montane skipper. This approach would move the area toward a more historical, mosaic pattern of vegetation than currently exists in the Project Area. Large areas of dense forest would remain untreated. The openings and thinned forest would create firebreaks between areas of dense tree cover. See Table 2 for a comparison of alternatives for vegetation subprojects, including the modifications for alternative B under this Decision Notice.

The current fire policy for the Project Area would remain. This policy requires controlling wildfires with emphasis on protecting property or developments. This includes mixed severity fires, which are part of the historical fire regime, in areas of dense forest. However, the potential for large, catastrophic fires will be reduced in the Project Area due to openings and less dense forest conditions that would be created in the treatment areas.

The proposed harvesting would be completed without constructing or reconstructing new roads, permanent or temporary roads. Existing unclassified roads would be used to remove logs. These unclassified roads would be obliterated after use. The treatment areas are designed to use existing roads and stay on gentle slopes as much as possible. Off-road heavy equipment (skidders and forwarders) would be used as necessary to remove logs from areas that are reachable by existing roads, eliminating the need to build access roads to these areas. Where the use of equipment is not feasible, felled-trees would be left on-site. Logs would not be removed from steep slopes, areas too far from existing roads, or areas where the trees are of little to no economic value. The logs and slash left on-site would be crushed by the harvesting and yarding equipment, allowed to dry one to two years, and the burned by prescribed fire.

Mechanical felling and harvest treatment areas would be burned with prescribed fire to reduce fire fuels. To minimize air quality impacts and prescribed fire intensity, the material in the prescribed burns would be limited to slash and existing ground fuels.
 

*See the Decision Notice/FONSI for the Vegetation Treatment Subproject in Non-Roadless Areas for a description of the modified alternative B for the non-roadless areas.


Stream sedimentation is addressed through the landscape modifications, which reduce the risk of large-scale sedimentation from wildfire followed by flooding (See Background Section in EA Chapter 1). Additional measures to reduce existing and potential future erosion problems include burn-area revegetation, road reclamation, and trail improvements. Soil amendments, such as biosolids, may be used to accelerate reestablishment of indigenous plant communities in reclaimed areas. These activities also address the issue of forest restoration.

In the Buffalo Creek burn area, 60 acres of exposed sediments along streams and washes would be planted with certified weed-free indigenous plant material. The stream channel would be stabilized with strategically placed woody debris and boulders, and sediment deposits would be reshaped with conventional equipment to facilitate plant reestablishment. In the upland areas, 1,000 acres of the burn would be planted with Ponderosa seedlings to assist the revegetation of the area. Appropriate types of biosolids would be used to improve conditions for revegetation. Suction dredging in Buffalo Creek would be part of the stream monitoring program.

Twenty-five miles of currently closed, non-system roads would be reclaimed and made impassible. This would be done by ripping and seeding the roadbeds for erosion control and to encourage revegetation. Biosolids would be used to increase soil fertility. Self-maintaining drainage would be created. If necessary to discourage use, the first quarter mile would be obliterated and recontoured. Also trees would be felled across the roads throughout their length.

Seven and a half miles of existing trail along the South Platte River would be improved to increase safety and to control erosion and vegetation loss. This would be accomplished with expansion of the existing trailhead and parking space at Wigwam Campground; new trail construction and trail upgrades on Gill Trail; construction of safe and sustainable river access trails; construction of barrier-free accessible fishing sited and trails; and reclamation of social trails using conventional methods.

ALTERNATIVE C
The overall concept of this alternative is the same as that for Alternative B. However, this alternative would minimize off-road heavy equipment use in unroaded areas. The details of the two action alternatives are the same, except for the differences discussed below.

The amount and type of thinning and opening creation is the same as for Alternative B. The difference is that there would be no removal of logs from the unroaded areas. As in areas where logs are not removed in Alternative B, the felled-trees in the roadless areas would be allowed to dry for one year. After that time, burning would be prescribed to consume the fine fuels. Like Alternative B, this would also be the protocol for areas where logs are left on-site outside of the unroaded areas.

In the Buffalo Creek burn area, this alternative is the same as Alternative B except biosolids would not be used to increase fertility for revegetation, and the sediment deposits in the riparian zone would be reshaped using only hand tools.

Under this alternative, the road reclamation would be the same as for Alternative B except biosolids would not be used to encourage revegetation of the road surfaces.
This alternative is the same as Alternative B for the South Platte River access trail improvements.

FINDING OF NO SIGNIFICANT IMPACT

I have determined that these actions will not significantly affect the quality of the biological, physical or human environment. Therefore, an environmental impact statement will not be prepared. This determination is based on the effects analysis documented in the EA, subsequent analysis associated with the response to comments, and the following factors listed in 40 CFR 1508.27.

CONTEXT
This project is local and would affect only a portion of the Upper South Platte Project Area. The Vegetation Treatment Areas would comprise less than 1% of the forested lands of the Pike and San Isabel National Forests and only 12 percent of the Project Area and less than 3 percent of the larger Upper South Platte Landscape. Project duration is expected to be 5 to 8 years, but could take up to 12 years to complete. Although the project has regional interest, the people most affected by the project would be primarily local residents and recreationists, primarily from the Denver metropolitan area, that frequent the area.

INTENSITY
Environmental Effects
I find that the proposed action can be carried out with no significant effects on socioeconomic, cultural, and natural resources as documented by the EA. Overall, this project will have a long-term beneficial impact on the environment (See EA chapter 4). The treated areas will be less dense, more open, and less vulnerable to diseases, insects, and large intense wildfires. The treatments will result in a more sustainable and heterogeneous natural landscape with diverse habitats that would have a long-term beneficial impact on wildlife in the project area (see EA page 4-37). The US Fish and Wildlife Service has written a Biological Opinion that supports that assessment in the EA. The Colorado Division of Wildlife submitted supportive comments on the EA. Reducing the risks of high-intensity fires will also help decrease the risk of erosion from burned areas and the potential for sediment delivery to streams, specifically the South Platte River. Decreasing the risk of forest fires will improve health and safety conditions for local landowners and firefighters. The local economy will temporarily benefit from vegetation treatment-related employment and expenditures.

I find that the vegetation treatments will cause some insignificant adverse impacts. Most adverse impacts will be short-term. Impacts to soils will be insignificant because surface disturbing activities will occur on slopes that are less than 30 percent and a minimum of 30 to 50 percent effective ground cover will be left on site following activities to reduce short-term erosion (see EA page 4-18). The treatments will reduce the area prone to fire, thus substantially reducing the long-term soil erosion risk. Impacts to water resources will not be significant because stream buffers will reduce sediment yield increases and there will be only a minor effect on peak flow increases (see EA page 4-26). Best Management Practices and Watershed Conservation Practices (see EA Appendix A) and the adaptive management approach of the project will ensure compliance with the Clean Water Act and thus no significant impacts to fisheries or other beneficial uses will occur (see EA page 4-31). Harvest and burning activities will temporarily displace some wildlife. Mitigation measures for wildlife presented in the EA will minimize impacts (see page 4-41). Recreationists and residents may be affected by noise, visual intrusions, or reduced access during the short periods of harvesting or burning (see EA pages 4-47 through 4-51). The proposed action will meet the guidelines and standards for the PM-10 non-attainment areas in Colorado and thus not cause significant impacts to air quality (see EA page 4-57). The proposed action will change the visual character of the landscape but not be visually detrimental and therefore not significant (see EA pages 4-67 through 4-70).
Public Health or Safety

The actions are consistent with the Colorado Prescribed Fire Air Quality Bill and will comply with all state and federal regulations. I find there are no adverse effects on public health and safety because the actions will reduce the risk of large-scale catastrophic fires and the potential for subsequent flooding (see EA pages 4-49 through 4-50).

Unique Characteristics of the Area
I find there are no significant effects on unique characteristics such as historic or cultural resources (see EA page 4-76), park lands, prime farmlands, wetlands (see EA pages 4-22 through 4-28), or wild and scenic rivers. Park lands and prime farmlands will not be affected because they do not occur in the project area. The potential for the South Platte River to be designated as a Wild and Scenic river will not be affected because vegetation treatment activities near the river will comply with guidelines applicable to the Wild and Scenic River Act. The interdisciplinary team evaluated roadless areas. The roadless areas within the analysis area are not considered unique. Logging in the late 1800s has resulted in the Inventoried Roadless Areas being similar to other areas.

Controversy
I recognize there is some level of public controversy associated with the vegetation treatment. Modified Alternative B will help restore ecological processes and water quality in the area. I find this project to be scientifically supported as seen in the discussion under the heading “Science”, above, and in Chapter 3 of the EA.

Uncertainty
The analysis shows the effects are not uncertain and do not involve unique or unknown risk (see EA Chapter 4). Recent testimony by Dr. W. Wallace Covington, a Regents Professor and Director of the Ecological Restoration Institute at Northern Arizona University, before the Committee on Resources, Subcommittee on Forests & Forest Health of the U.S. House of Representatives (Covington 2000), supports this finding. The actions evolved from previous practices. Similar actions have been implemented on adjacent Denver Water lands as well as other lands in the West. Monitoring and adaptive management will ensure effects are within the expected parameters.

Precedent
I find that this decision does not set a precedent for future decisions. The parts of this project that are charting new ground are the collaboration between agencies and private citizens and the management of a project across jurisdictional boundaries. The US Forest Service has 14 other large-scale watershed restoration on-going projects. The project components have all been accomplished throughout Colorado and the Western United States. These types of restoration projects have been accomplished in Colorado, Arizona, Oregon, and other western states in ponderosa pine forests. This project will not create a template for other projects with significant effects. Future similar projects would have to be evaluated under NEPA for the significance of the effects of those specific actions.

Cumulative Impact
I find that the cumulative impacts for the combined Inventoried Roadless Area and non-roadless area treatments are not significant because this activity when considered in combination with other past or reasonably foreseeable actions is not expected to have a cumulatively significant impact (see EA pages 4-20, 4-27, 4-32, 4-40, 4-51, 4-58, and 4-70). Deferring the decision on the revegetation and road reclamation subprojects outside the vegetation treatment areas will not result in adverse cumulative effects because these subprojects are not considered mitigation for offsetting the impacts of the vegetation treatments. Each individual subproject would have beneficial long-term effects and thus result in positive long-term cumulative effects.

Properties On or Eligible for the National Register of Historic Places; Significant Resources
I find the action will have no adverse effect on districts, sites, highways, structures, or objects listed in or eligible for listing in the National Register of Historic Places because no known listings are present in the areas affected by the vegetation treatments (see EA pages 3-54 through 3-57 and 4-71 through 4-75).
I find the action will not cause loss or destruction of significant scientific, cultural, or historical resources because the survey and analysis found no impact. The conclusion is supported by the Colorado State Historic Preservation Office (Letters, September 19, 2000 and January 5, 2000, from Allen E. Kane, Heritage Resources Program Manager, Pike and San Isabel National Forests, Cimarron and Comanche National Grass Lands to Georgianna Contguglia, Colorado State Historic Preservation Officer; Letter, January 22, 2001 from Allen E. Kane to Randy Hickenbottom, Ranger, South Platte District). If cultural resources are found during operations, the work will be stopped and Forest Service archeologists consulted.

Local tribal officials were contacted with letters followed by telephone calls. They did not have any concerns or issues. Therefore, I find the action would not affect local tribes.

Endangered or Threatened Species
I find the action will not jeopardize the continued existence of any federally listed or proposed endangered or threatened species or US Forest Service listed sensitive species or their critical habitat. The Biological Evaluation and revised Biological Assessment support this conclusion. (see EA pages 4-41 and B-17). The USDI Fish and Wildlife Service issued a biological opinion (Attachment C to the Decision Notice/FONSI for the Vegetation Treatment Subproject in Non-Roadless Areas) to the Forest Service on impacts to federally-listed endangered and threatened species associated with the Upper South Platte Watershed Restoration and Protection Project (Final Biological Opinion, January 10, 2001, from LeRoy W. Carlson, Colorado Field Supervisor, Fish and Wildlife Service to Randy Hickenbottom, District Ranger, Forest Service, South Platte Ranger District). The biological opinion was based on the Biological Assessment for the Upper South Platte Environmental Assessment submitted to the Fish and Wildlife Service on November 27th, 2000. Conservation measures described in the Biological Opinion will be carried out to minimize the impacts of the proposed action and to further the recovery of threatened and endangered species. The biological opinion concluded that the effects of the proposed action, which include the conservation measures, will not jeopardize the continued existence of the Pawnee montane skipper, Mexican spotted owl, Preble’s meadow jumping mouse, or the bald eagle. The Fish and Wildlife Service also concluded that the proposed action will not adversely modify or destroy proposed critical habitat for the spotted owl. Therefore, I find that the action can be carried out with no significant adverse effect to federally listed species.

Legal requirements for environmental protection
I find the action is consistent with federal, state, and local laws and requirements for the protection of the environment. Applicable laws and regulations were considered in the EA (see EA page 4-90).
The action is consistent with the Forest Plan, as amended (See EA Chapter 2 pages 3-9).
ADMINISTRATIVE REVIEW OR APPEAL OPPORTUNITIES AND IMPLEMENTATION DATE
This decision is subject to appeal under 36 CFR Part 215. A written appeal must be submitted within 45 days of the day after notice of this decision is published in the newspaper of record to:

USDA, Forest Service, Region 2
Attn: Appeal Deciding Officer
POB 25127
Lakewood, Colorado 80225-25127
Appeals must meet the following requirements:

1. State that the document is an appeal filed pursuant to 36 CFR 215
2. List the name and address of the appellant and, if possible, a telephone number
3. Identify the decision document by title and subject, date of the decision, and name and title of the Responsible Official
4. Identify the specific change(s) in the decision that the appellant seeks or portion of the decision to which the appellant objects
5. State how the Responsible Officials decision fails to consider comments previously provided, either before or during the comment period specified in 36 CFR 215.6 and, if applicable, how the appellant believes the decision violates law, regulation, or policy.

The appellant is responsible for submitting an appeal on or before the last day of the appeal filing period. Where there is a question about timeliness, the U.S. Postal Service postmark on a mailed appeal or the time and date imprint on a facsimile appeal will be used to determine timeliness.
A copy of the EA and analysis file is available for public review at the Upper South Platte Ranger District Office, 19316 Goddard Ranch Court, Morrison, Colorado 80465. Please direct questions about this DN/FONSI to Fred Patten, Project Leader, South Platte Ranger District, 303-275-5641.

Pursuant to 36 C.F.R. Sec. 215.10(a), if no appeal is filed, implementation of this decision may occur on, but not before, 5 business days from the close of the appeal filing period. If an appeal is received, implementation may not occur for 15 days following the date of the appeal disposition (36 CFR 215.10(b)).
For further information contact Fred Patten at (303) 275-5641.

SIGNATURE AND DATE

__________________________________                 ___________________
Abigail R. Kimbell, Forest Supervisor                             Date
Pike and San Isabel National Forests
Responsible Official


REFERENCES
Brown, P.M., M.R. Kaufmann, W.D. Shepperd. 1999. Long-term patterns of past fire events in a montane ponderosa pine forest of central Colorado. Landscape Ecology 14:513-532.

Brown, R. 2000. Thinning, Fire and Forest Restoration: A Science-Based Approach for National Forests in the Interior Northwest. Defenders of Wildlife.

Covington, W.W. 2000. Testimony of Dr. W. Wallace, Regents’ Professor and Director of the Ecological Restoration Institute, Northern Arizona University, before the Committee on Resources, Subcommittee on Forests and Forest Health, U.S. House of Representatives, Oversight Hearing on Preventing Wildfires through Proper Management of the National Forests.

Foster Wheeler Environmental Corporation. 1999. Landscape Assessment, Upper South Platte Watershed. Volumes 1, 2, and 3. Prepared for the U.S. Forest Service, Colorado State Forest Service, Denver Water Board, and U.S. Environmental Protection Agency.

Huckaby, L.S., M.R. Kaufmann, J.M. Stoker, and P.J. Fornwalt. 2000. Landscape patterns of montane forest age structure relative to fire history at Cheesman Lake in the Colorado Frant Range. Conference: Steps Toward Stewardship: Ponderosa Pine Forest Ecosystem Restoration and Conservation, Flagstaff, AZ, April 24-28, 2000.

Kaufman, M.R., P.J. Fornwalt, L.S. Huckaby, and J.Stoker, in preparation. Cheesman Lake – a historical ponderosa pine landscape guiding restoration in the South Platte Watershed of the Colorado Front Range. USDA Forest Service General Technical Report RMRS-GTR-XXX. Rocky Mountain Research Station, Fort Collins, CO.

Kaufmann, M.R., L. Huckaby, and P. Gleason. 1999. Ponderosa pine in the Colorado Front Range: long historical fire and tree recruitment intervals and a case for landscape heterogeneity. Proceedings, Joint Fire Conference and Workshop, Boise ID, June 1999.

Kaufmann, M.R., C.M. Regan, P.M. Brown. 2000. Heterogeneity in ponderosa pine/Douglas fir forests: age and size structure in unlogged and logged landscapes of central Colorado. Can. J. For. Res. 30:698-711.

Thinnes, J. 2001. Pike and San Isabel National Forests lower montane forest vegetation trends. USDA Forest Service, Pike and San Isabel National Forests, South Platte Ranger District unpublished report.

USDI Fish and Wildlife Service. 2001. Biological Opinion for the Upper South Platte Environmental Assessment. January 10, 2001.

Veblen, T.T., P.M. Brown, and J. Donnegan. 2000. Historical Range of Variability Assessment for Forest Vegetation of the Pike and San Isabel National Forests, Colorado. USDA Forest Service, Agreement No. 1102-0001-99-033, with the University of Colorado, Boulder.

 

USDA Forest Service, Pike & San Isabel National Forests, Cimarron & Comanche National Grasslands
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Last modified December 28, 2006