North Whitetail Post Fire...

North Whitetail Post Fire Project Non-commercial 1

North Whitetail Post Fire Project

Background During the 2012 fire season, lightning ignited multiple wildfires that burned 312,418 acres on National Forest System lands, Northern Cheyenne Reservation lands, State, and private lands around Ashland in southeastern Montana. Of that, 143,200 acres burned on the Ashland Ranger District (approximately one third of the District). The largest fire was the Ash Creek Fire, which burned 249,562 acres across numerous land ownerships (88,465 acres on the Ashland Ranger District). The Ash Creek Fire burned across the North Whitetail Post Fire Project Area as a mixed severity fire. Areas that burned at moderate to high intensity resulted in extensive mortality of ponderosa pine. In 2014, the Forest Service completed the Ashland Post Fire Landscape Assessment to assess current conditions, trends and management practices on the post fire landscape. The assessment represents our understanding of the ecosystem components, conditions, processes, and interactions across the District and the ecosystem services (niche) supported by these ecosystems components. It provides context for describing the niche (role for goods and services) the District has fulfilled and continues to fulfill locally and regionally. The Assessment describes existing and desired conditions, conservation goals and management opportunities for the principal ecosystems that occur on the District, including aquatic and riparian systems, hardwood draws and broadleaf deciduous ecosystems, mixed grass prairie ecosystems, ponderosa pine ecosystems, and soils and water resources. Projects proposed on the Ashland Ranger District can utilize information from the Assessment to gather information on Existing and Desired Conditions, and set the stage for the purpose and need for action. Existing Condition The Ashland Ranger District (hereafter District) is comprised of 436,546 acres of National Forest System lands. Ponderosa pine is the dominant tree cover comprising over 97% of the forest cover across the District. Hardwoods (aspen, green ash, box elder, and cottonwood) and juniper occur as small isolated communities and are mixed with ponderosa pine. There are no other conifer species present on the District and the habitat type is considered dry ponderosa pine. From 1988 to 2012, approximately 289,978 acres burned on the District, which amounts to 66 percent of the District. The largest wildfire years were 1988, 2000, and 2012. In 2012, approximately 155,000 acres of the District burned in the Ash Creek, Taylor Creek and Dutch Fires. In the 1990s, the ratio of forest to non-forest cover on the District was approximately equal. As a result of large wildfires, there has been a 47 percent reduction in forest cover across the Ashland Ranger District in the last 30 years. The ponderosa pine in the northern and southern portions of the North Whitetail Post Fire Project Area is predominately dead. Moderate to high intensity wildfire resulted in near 100 percent mortality of the ponderosa pine trees, eliminating a potential seed source for regeneration. See Figures 1 and 2.


Figure 1: Moderate to high severity wildfire resulted in near 100% mortality of the ponderosa pine. The middle portion of the project area burned at more of low to moderate intensity, and contains a mosaic pattern of live and dead trees, especially on the west side of NFSR #4427.

Figure 2: Low to moderate intensity fire in central portion of North Whitetail Post Fire Project Area resulted in a patchwork of green and dead trees.


Hardwood Draws: Approximately 2,133 NFS acres of green ash draws and isolated pockets occur on the Ashland Ranger District. This is less than 1/10 of a percent of the total Ashland landscape acreage of 436,546. Of the 2,133 NFS acres of green ash draws and isolated pockets occurring on the District, approximately 780 acres or 37% were burned in recent fires (since 1988). Of the 780 acres burned, 35% (275 acres) of green ash stands burned with high severity, 38% (297 acres) with moderate severity, and 27% (207 acres) with low severity. Although hardwood species sprout from live subsurface materials following fire, Lesica (2003) reported green ash mortality as high as 80 percent following wildfires in eastern Montana. Figures 3 and 4 below show hardwood draws in the project area that burned at high intensity and resulted in 100 percent mortality to hardwood species. From a hydrological perspective, they are a first order ephemeral draws with no defined channel development.

Figure 3: Sartin Creek Draw near center of Section 36, adjacent to proposed Non-Commercial Treatment Unit 41.

Figure 4: Sartin Creek Draw at road crossing approx. ¼ mile downstream of proposed Non-Commercial Treatment Unit 45.

Prior to recent wildfires, the USFS evaluated about 300 acres of hardwood draws to assess the overall health of these communities and found that approximately 21% were considered healthy, 54% considered at risk, and 25% considered unhealthy. The healthier woodlands have a relatively dense tree canopy, ash trees of all ages and understories dominated by chokecherry, wild plum, hawthorn, serviceberry, Sprengel’s sedge and shade-loving forbs. There are several causes for the decline of green ash woodlands in Montana including woodcutting, grazing, deer browsing, introduction of invasive, rhizomatous sod grasses (i.e. Kentucky bluegrass), and climate. Desired Condition Ponderosa Pine Ecosystems: The Ashland Post Fire Assessment identified existing and desired conditions, overarching conservation goals, and opportunities to move from existing to desired conditions for ponderosa pine ecosystems. The conservation goal for ponderosa pine ecosystems is to:

Manage for a heterogeneous forested landscape with a diverse age and size structure (including old growth), understory structure and composition, patch size, and pattern that are resilient to natural disturbances (e.g. fire, insect/disease, climate change). Maintain watershed processes and soil productivity. Provide habitat diversity, including habitats


associated with standing snags, down wood, savannas, and deciduous woodlands and meet key habitat characteristics for goshawk, whitetail deer, king bird, and big game.

The Desired Condition for ponderosa pine ecosystems is:

That the forested landscape be managed to provide a pattern of life history stages ranging from early development to mature forest that are distributed across the District. The pattern and proportions may change over time in response to disturbance events (e.g. wildfire, insects, disease, flood or wind events) or management activities. The desired condition is to have a resilient forested landscape that contains a diversity of composition, life history stages, and size, density and pattern to respond to disturbance and perpetuate through regeneration. Increased vegetation diversity allows the landscapes the capacity for renewal and recovery form a wide range of disturbances (i.e. wildfire, insects, and climate change), while providing for, recreation, habitat for Management Indicator Species (MIS), common and sensitive wildlife species (i.e. big game, goshawk), defensible space from severe fire, carbon sequestration, and products and services (i.e. saw-logs, grazing), in the short and long term. Where large stand replacement wildfire disturbances have occurred since 2000, the desired condition is to have these fire altered landscapes reforested with reduced fuel loadings (fire killed trees). The intent is to have a low risk for a large re-burn event. Strategic areas selected for long term fuel reduction on the landscape that will allow for better control and containment to reduce large scale re-burns. (Figure 5)

Hardwood Draw and Broadleaf Deciduous Ecosystems: Hardwood draws and broadleaf deciduous woodlands should be managed to maintain or perpetuate a network of multi-layer and multi-age class of herbaceous plants, shrubs and trees. These systems associated with deciduous tree stands should be properly functioning or in an upward trend. Long-term soil productivity and properly functioning water cycles are maintained. Opportunities: The Ashland Post Fire Assessment identified future management opportunities that could restore ecosystems elements, where departed, and improve or maintain ecosystem resilience. The Assessment utilized the following definitions of Ecological Restoration and Ecological Resilience (from Reynolds et al 2013):

Ecological restoration is the process of assisting the recovery of an ecosystem that has been degraded, damaged, or destroyed. Restoration initiates or accelerates ecosystem recovery with respect to its health (productivity), processes, and functions (biodiversity, food webs, and sustainability).

Ecological resiliency is the ability of an ecosystem to absorb and recover from disturbance without altering its inherent functions.

The Assessment noted that next steps include developing strategies that integrate management activities to achieve identified Conservation Goals. Some of the identified management opportunities for ponderosa pine and hardwood draws include:


Ponderosa Pine: • Reduce the potential for large scale wildfire within recent wildfire areas. • Manage remaining mature ponderosa pine forest (MIS goshawk) to minimize additional loss of

habitat to wildfires. • Thin selected remaining sapling to pole sized trees to increase growth and accelerate

development into mature stands. • Design outcome based projects that focus on the grassland – forest mosaic and strategic

reduction in wildfire risk as an outcome rather than acres treated. • Promote stand composition and structure that reduce the size and severity of large crown fire

events to promote lower intensity, less severe, surface fires. Break up the areas of continuous canopy cover (>40%+).

• Design treatments from a landscape scale that build on the grasslands (non-woody fuels) and pine forest (woody fuels) to create a mosaic of fuel levels. Treatments such as prescribed fire would focus on breaking up the continuity of the future sea of saplings and pole stands that would grow in the next 20 to 30 years.

• Promote and manage for low tree densities and longer periods of no ponderosa pine on south, southwest and west aspects.

• Utilize the Forest Reforestation Strategy (delayed natural, natural and artificial regeneration) to implement reforestation efforts on the post-disturbance landscape.

• Treat priority assets sites (historic & cultural) to improve chances for successful suppression and protection. Reduce down and dead fuels from 0 up to ¼ mile away from the site.

• Treat the burned/unburned edge to help maintain existing green areas (plantations and remnant forested areas).

Hardwood Draws: • Consider opportunities to put fire in hardwood (woody) draws. • Investigate/Inventory for opportunities for active Planting/Coppicing (pruning to ground level);

planting nurse shrubs: Minimize High Investment (fence/fence maintenance) by looking at secondary range/enclosures/administrative sites.

• Investigate/Inventory for opportunities for Conifer felling to impede livestock access to draws is a treatment that can be considered to provide moderate to full sun conditions. Unknown locations.

Project Location North Whitetail Post Fire Project Area: The 5,882 acre North Whitetail Post Fire Project Area is located on the northern portion of the District, generally north of East Otter Creek Road (NFSR #4423), up to the Beaver Stacey Road (NFSR #4769), and along the east and west sides of NFSR #4427 north of the Whitetail Cabin. Please refer to the enclosed vicinity map (Map 1) and North Whitetail Post Fire Project Area proposed action map (Map 4). Please refer to the enclosed vicinity map, Map 1, and North Whitetail Post Fire Modified Project Proposed Action Map, Map 4, both of which are contained in Appendix A.

Purpose and Need Purpose: The purpose of the North Whitetail Post Fire Project is twofold:


• Restore moderately to severely burned areas to reduce long term downed fuel accumulations and re-establish forest cover.

• Salvage up to 250 acres of ponderosa pine that were killed by the Ash Creek Fire to reduce downed fuel accumulations and provide timber products to help support local communities.

Need: 1) Fuels Reduction: After large wildfires, where no salvage harvest or other removal of fire killed trees has taken place there is a progression of increased surface fuels. Six to seven years after the fire many fire killed trees have fallen or have had portions wind snapped. Within 10 to 13 years post fire, approximately 95% of the fire-killed trees have generally fallen. This results in a high hazard fuels load and risk for wildfire (Figure 5).

Figure 5: Heavy downed fuels fourteen years after the Stag Fire presents a high fire hazard to regenerating seedlings growing amongst the downed fuels. The effects of a re-burn were demonstrated in 2002 when the Kraft Springs Fire re-burned across 62,000 acres that burned as a large stand replacement fire in 1988 Brewer Fire on the Sioux Ranger District. The 1988 fire left up to 40 tons per acre of down dead fuels intermixed with flashy light fuels (grass, brush and tree regeneration) that dominated the post 1988-pre 2002 burn landscape (Figure 6). In 2002 this fuel complex is what carried the Kraft Springs fire. The continuous large woody debris component was a major carrier of the Kraft Springs Fire and made suppression operations very difficult. The re-burn also set back regeneration that had occurred since 1988 (Figures 7 and 8).

Figure 6: High fuel hazard post Brewer Fire / pre- Kraft Springs Fire

Figure 7: Post Kraft Springs Fire. Downed dead fuels and seedlings burned at high intensity (same site as Figure 6).

Figure 8: Kraft Springs Fire. High intensity fire burned in heavy down fuels from the 1988 Brewer Fire. Surface fuel accumulations served as a source of extreme heat intensity that facilitated convective development, increased air drafting, and resultant rapid-fire spread…without these heavy fuels fire spread would have remained a surface spreading fire capable of being contained by a ground fire crew.

Fuels reduction treatments are needed to meet the Desired Post Fire Condition identified in the Ashland Post Fire Assessment: Where large stand replacement wildfire disturbances have occurred since 2000, the desired condition is to have these fire altered landscapes reforested with reduced fuel loadings (fire killed trees). The intent is to have a low risk for a large re-burn event. Strategic areas selected for long term fuel reduction on the landscape that will allow for better control and containment to reduce large scale re-burns. See Figure 9.


Figure 9: Desired Condition in Post Burn Landscape. Light downed fuels represent a reduced fire hazard. Reductions of heavy fuel concentrations would reduce undesirable effects of a re-burn in treated areas, reduce the risk of loss of planted tree seedlings under a re-burn scenario, and promote resilient landscape conditions. Treatments would meet Custer National Forest Land and Resource Management Plan (hereafter Forest Plan) objectives to 1) maintain a healthy diverse timber resource and 2) to improve or maintain wildlife habitat (p. 5). Tree Planting: An effect from large stand replacement fire events is a potential loss of the ponderosa pine forest cover (deforestation) for long periods of time. Ponderosa pine has a thick bark that acts as an insulator and long needles that protect its buds to withstand effects from frequent low intensity fires. Ponderosa pine has a large, heavy seed and does not have the ability to reseed large disturbance areas in short time frames like other small winged pine species such as lodgepole pine. Average seed cast is 1 to 3.5 tree heights (Shepperd and Battaglia 2002; Minore and Laacke, 1992). Ponderosa pines large seed and cone generally are destroyed and do not remain after stand replacement fire events. If all the trees have been killed no seed source is available to reforest the area. Ponderosa pine forests that have had large fires over the last 20 to 25 years in eastern Montana have demonstrated this. Left alone portions of these fires would take several decades to reforest. This loss of the forest has impacts to wildlife that are dependent on forested communities. The Kraft Springs fire is an example of this (Sandbak, Clark, 2005). The forested landscape was reduced (deforested) by 69% (Sandbak and Clark 2005) from fire caused mortality from the 1988 Brewer Fire and the 2002 Kraft Springs Fire. Several thousands of acres were deforested with limited seed sources. Many of these acres were put into a delayed regeneration strategy (forest cover return taking few to several decades) and natural regeneration strategy (forest cover return < 10 years). Areas assessed that were lacking a seed source and on the cooler, moist sites that were deemed important for timely reforestation were artificially reforested. To comply with the National Forest Management Act, Forest Service Directives, and meet forest cover management goals and standards in the Forest Plan the Custer National Forest identified three strategies for ensuring forest lands impacted by fires are maintained or put on a trajectory to return


forest cover post wildfire disturbance: natural regeneration, delayed regeneration, and artificial regeneration (i.e. planting). Generally, natural regeneration is employed when there is an adequate seed source is available to meet the Forest’s certification standards in 5 to 10 years post fire. All low burn severity areas are included due to adequate seed source (low amount fire killed trees) to fill in small burned areas. Seed crops and properly timed moisture (spring and early summer) will drive the time frames that Ponderosa pine will successfully reestablish. Past monitoring on large fires on the Sioux and Ashland ranger districts indicate that in as little as 2 years and up to 13 years when there is an adequate seed crop for successful Ponderosa pine reestablishment. Delayed regeneration is employed when an adequate seed source is not available on dry sites (SE, S, SW, and W aspects). These areas are put into a delayed regeneration status with long natural recovery periods anticipated. These sites may take a decade to several decades for pines to start colonizing. Artificial regeneration is employed when an adequate seed source is not available on moist sites (N, NW, NE and E aspects) to restock to certification standards in 5 to 10 years post fire. In areas that burned on the District between the years 2000 – 2012, approximately 10,312 acres were identified for planting (12% of the total Ponderosa pine acres burned from 2000 to 2012). Tree planting, proposed as part of the North Whitetail Post Fire Project will meet the project purpose to restore forest cover and meeting re-stocking certification requirements under NFMA. In addition, planting of hardwood species in burned areas could meet the Desired Condition for hardwood draws to maintain or perpetuate a network of multi-layer and multi-age class of herbaceous plants, shrubs and trees. Salvage: Salvage is proposed to reduce long term downed fuel accumulations to aid in meeting fuels objectives describe above, and to provide timber products to help support local communities.

Proposed Action: Treatment was initially proposed on approximately 1,574 acres within areas previously harvested under the Fly Wilber Timber Sale in the late 1990s and on approximately 885 acres within areas previously proposed for treatment as part of the Beaver Creek Landscape Management Project (project was withdrawn after the Ash Creek Fire). The size of treatment units ranged from about 2 acres to 223 acres. Site preparation treatments would decrease the amount of large dead and downed fuels (fire killed trees), and facilitate re-establishment of forest cover. Site preparation may have included a variety of tools to meet desired conditions for ponderosa pine ecosystems, including cutting and removing dead trees over 12 inches diameter at breast height (DBH), broadcast burning, pile burning, mastication, and/or lopping and scattering slash. Live trees and dead tress less than 12 inches would be left on site. The long term objective for coarse woody debris on the ground is to average 5 to 13 tons of per acre where available.


Forest cover may be re-established through natural regeneration from the small percentage of live trees remaining, and /or by planting ponderosa pine seedlings. These restoration activities would supplement the 365 acres of tree planting that has already occurred in the Fly Wilbur project area.

Modified Proposed Action Based on public comments, field reconnaissance and other considerations, the proposed action was modified as follows: Fly Wilbur Project Area The Fly Wilbur area was thinned in the late 1990s and proposed treatment units do not have the heavy fuel conditions that are present in North Whitetail Post Fire Project Area. The thinning that was completed was predominately a thin from below as a shelterwood type of harvest. The Ash Creek Fire burned through these areas at low to moderate intensity, creating more of a mosaic burn pattern compared to North Whitetail. Many (but not all) of the units contain live, green trees to serve as a seed source for regeneration. Additionally, proposed treatment areas have already been planted. Public comments identified a concern that broadcast burning and mechanical treatments may damage regenerated and planted seedlings. The project area is already on a trajectory for recovery and the need for action was not supported. For these reasons, all treatments were dropped from the Fly Wilbur project area at this time. North Whitetail Post Fire Project Area In the North Whitetail Post Fire Project Area, the Forest Service completed field reconnaissance to identify areas that were dead and areas that contained green trees. There is a large swath of land in the middle of the project area that is green or a mosaic of live/dead. Units 4, 26, and 27 (totaling 86 acres) were dropped because they had green trees that will serve as a seed source for natural regeneration. All other proposed units (approximately 800 acres) were predominately dead. Next, the Forest Service identified 250 acres of dead timber that could be salvaged with no more than one half mile of temporary road. These areas are adjacent to system roads. See Map 4. The Forest Service made an effort to select treatment areas that were near 100 percent dead. Any incidental green trees within proposed units will not be targeted for removal. In selecting these areas for salvage, the Forest Service reshaped some of the proposed units so that the size of contiguous units did not exceed 60 acres. Some edges were dropped and buffers of 200 to 300 feet were added between salvage units to limit the salvage units to no more than 250 acres total and 60 acres in size. Because some of the unit boundaries shrunk, approximately 98 acres of proposed treatment areas were dropped. For the salvage units, the prescription is to remove dead trees larger than 12” DBH. Follow up noncommercial fuels treatments may be completed to meet coarse woody debris objectives (averaging 5 to 13 tons per acres on the ground where available).

The remaining units would be treated non-commercially to achieve desired fuels objectives (approximately 538 acres). Fuel loads would be reduced through a variety of methods including but not limited to mastication, or pile burning to meet course woody debris objectives (averaging 5 to 13 tons per acres on the ground where available). Noncommercial treatments would target dead trees less than 6 to 8 inches DBH. See Map 4.


In order to safely and efficiently implement broadcast burning, the Forest Service had to look outside unit boundaries. The modified proposed action includes approximately 2660 acres that may be broadcast burned. The boundary utilizes the existing road/trail network and topography for fire perimeter boundaries. The boundary to the west is a motorized trail #41338 and the boundary to the east is NFSR #4427. The Forest Service is not proposing broadcast burning to the east of NFSR #4427 due to some of the difficulty in implementation in regards to slope and proximity of private land. On the north end of the project area the Forest Service evaluated Unit 41, which is proposed for planting. Based on the fuels present and operability, the broadcast burn boundary was extended from NFSR #4769 at the top of the ridge to NFSR #47699 which runs parallel to the bottom of the slope. The entire broadcast burn area would not be burned all at the same time. Prescribed burning would occur in blocks of about 300 acres, with a burn ratio of approximately 50-70 percent burned to 30-50 percent unburned. Burning would start at about year seven post burn depending upon site conditions, and a subsequent burn cycle would be implemented about 10 to 12 years after the first. Lastly, areas that were identified for artificial regeneration in the Ashland Post Fire Assessment were overlaid across the treatment area. Approximately 1,088 acres were identified for planting of ponderosa pine on N, NW, NE and E aspects. In addition, the project area includes small inclusions of hardwood draws that burned in the Ash Creek Fire and resulted in mortality to hardwood species. To the small extent they occur on the landscape, hardwood species may also be planted. Dead ponderosa pine trees may be felled within or adjacent to woody draws or aspen stands to deter livestock grazing and in limited cases fencing may be utilized to preclude grazing. In areas that would be planted within the broadcast burn perimeter, trees would be planted after the area has been broadcast burned, and these areas would be excluded from the second burn cycle to protect regenerating seedlings. Tables 1 and 2 below summarize all acres treated under the Modified Proposed Action for the salvage and non-commercial treatments. All treatments, salvage and non-commercial are also identified on Map 4 (see Appendix A). Table 1: Summary of Modified Proposed Action

Unit Acres Non-commercial 538 Salvage 250 Drop 98 Prescribed Burn 2660 Planting 1088

Table 2: Treatment Type by Unit Number

Unit Number Acres Treatment 01 26 salvage 02 9 noncommercial 03 4 noncommercial 04 36 Obsolete (dropped) 05 4 noncommercial 06 21 salvage 07 20 noncommercial 07 19 salvage

Unit Number Acres Treatment 08 24 salvage 08 2 noncommercial 08 8 Obsolete (dropped) 09 3 salvage 09 2 noncommercial 10 13 salvage 11 1 noncommercial 12 1 noncommercial 13 18 noncommercial


Unit Number Acres Treatment 14 13 noncommercial 15 1 noncommercial 16 6 noncommercial 17 52 noncommercial 18 18 noncommercial 19 11 noncommercial 19 10 salvage 20 9 salvage 20 2 noncommercial 21 45 salvage 21 15 noncommercial 22 15 salvage 23 17 noncommercial 24 34 noncommercial 25 5 noncommercial 26 36 Obsolete (dropped) 27 15 Obsolete (dropped) 28 26 noncommercial 29 16 noncommercial

Unit Number Acres Treatment 29 14 noncommercial 30 9 salvage 31 6 salvage 31 4 noncommercial 32 42 noncommercial 33 11 noncommercial 34 12 noncommercial 35 17 noncommercial 36 12 salvage 37 3 noncommercial 38 37 salvage 38 4 Obsolete (dropped) 39 6 noncommercial 40 44 noncommercial 41 77 noncommercial 42 1 noncommercial 43 3 noncommercial 44 5 noncommercial 45 24 noncommercial

Design Criteria Forest Vegetation: The following forest vegetation design criteria will be implemented in all treatment units unless otherwise specified.

1. Silvicultural Prescription: Preparation and approval of detailed silvicultural prescriptions for all treatment units.

2. Treatment Deviations: Treatment deviations as a result of changed or unidentified conditions

that materially affect the intended treatment as described in the detailed site specific silvicultural prescription will be consulted with by the Project Silviculturist. As needed, the silvicultural prescription will be modified and re-approved by a certified silviculturist.

3. Leave Tree Protection: During implementation, contractor will take all reasonable care to avoid

damage to the roots, bole, and crown of live trees that will be reserved from cutting. When any live tree is damaged beyond recovery (expected to die within 1 year) that was intended to be retained, it can be removed or otherwise treated by the contractor as instructed by the Forest Service.

4. Landing Piles: Landing piles should not occur near live green trees or where natural

regeneration has established.


5. Green Tree Retention: Leave all green trees except those that have had successful beetle attack and are likely to result in mortality. The focus is to maximize to the extent possible all potential cone producing trees. Due to safety concerns in recreation sites and along National Forest System roads guides for determining additional mortality will be used to assess hazard trees for removal. (Refer to Forest Vegetation Specialist Report).

6. Green Tree Retention along Road Corridors: Wherever National Forest System roads are adjacent to treatment units, assessments for hazard trees will occur within 75 feet of road. Trees will be assessed as hazard trees whenever the condition of a tree could result in the tree falling or portions of the tree falling and will be felled and removed or left on site. Future hazard trees will be assessed according to the general rules for determining post fire mortality (see Forest Vegetation report). Where these general rules are met these trees will be felled and removed or left on site.

Wildlife

7. Northern Long Eared Bats: Do not harvest within 0.25 miles of a known, occupied winter hibernacula. Avoid cutting or destroying known, occupied roost trees during the pup season (June 1 – July 31). Avoid clearcuts (or similar harvest methods) within 0.25 miles of known, occupied roost trees during the pup season. Note: There are no known winter hibernacula or occupied roost trees within or near the project area. Salvage harvest prescriptions do not include clear-cutting or similar methods; only snags 12 inches dbh or larger would be removed. Therefore, all applicable conservation measures would be met with the proposed project.

8. All Bats: If a bat or bats (any species) are seen clinging to, crawling on, or flying from, a tree

identified for harvest, the tree will be left standing until either a) no bats are seen on or near the tree, or b) after the pup season (after July 31). This measure should be effective because: 1) any bat species would be protected; i.e. loggers would not be required to identify bat species, 2) northern long-eared bats switch tree roosts often – typically every 2 to 3 days (USDI 2015) and 3) young bats should have sufficient flight skills developed by the end of pup season to escape harm.

9. No broadcast burning during the pupping season for the northern long-eared bat (June 1 – July

31). Water Resources: All pertinent Best Management Practices (BMPs) and design criteria will be implemented. Abbreviated descriptions of BMPs and design criteria are itemized below.

10. Standard timber sale protection provisions would be applied to the commercial harvest and mechanical mastication activities to protect against soil erosion and sedimentation. Timber harvest activities and mastication activities will be conducted in compliance with Water Quality BMPs for Montana Forests (Logan 2001).

11. Streamside Management Zones: All operations adjacent to perennial, intermittent, and/or

ephemeral streams will be in compliance with the Montana Streamside Management Zone (SMZ) law (MCA 77-5-301 through 307.


12. Vehicles and logging machinery would not be driven within 50 feet of wetlands, with the exception of maintenance/reconstruction/decommissioning of existing roads and designated temporary crossings. Streamside Management Zone regulations regarding tree retention would be extended to apply to isolated wetlands. No materials of any sort would be deposited into wetlands.

13. No mechanical treatment would be carried out within riparian areas.

14. All required water quality permits, including but not limited to 124 (Stream Protection Act), 318 (Short Term Water Quality Standard for Turbidity), and Nationwide 404 (Federal Clean Water Act) permits would be acquired by the Custer Gallatin National Forest prior to any ground disturbance.

Soil Resources

15. To ensure future soil productivity (per Graham et al. 1994), retain down 5 to13 tons per acre of woody debris greater than three inches in diameter (where available) in treatment units.

16. Hand and mechanical operations must be in compliance with USFS R1 soil quality guidelines (R1

Supplement No. 2500-99-1). This guideline requires that management activities should not create detrimental soil conditions on greater than 15 percent of the activity area. Any detrimental disturbance exceeding 15 percent in the activity area should be remediated after treatment. Detrimental soil disturbance includes any or all of the following (from FSM 2500 R1 Supplement 2500-99-1 2554.10):

• Compaction resulting in a 15 percent increase in bulk density • Rutting in excess of 2 inches • Displacement of soil of one or more inches depth from a surface soil horizon from a

continuous area greater than 100 square feet • Physical and biological changes to soil resulting from high severity burning • Severe surface erosion, evidenced by rills, gullying, and soil deposition

Commercial and non-commercial mechanical treatments (salvage harvest and mastication):

17. Locate landings on relatively flat ground that can be drained. 18. Mechanical operations in units would be conducted when soils can support the weight of

machinery while meeting R1 soil quality guidelines. 19. Design criteria for operable gradients in ground-based harvest and mastication systems:

a. Ground-based harvest and mastication systems would only be used on slopes having sustained grades less than 35 percent. Per the timber sale contract, a systematic skid trail pattern would be required during logging and an average of at least 75 feet would be maintained between skid trails in harvest units, except where skid trails converge.

b. In units partially or fully underlain by clinker geology (All commercial units as well as all noncommercial units 45, 44, 43, west half of 41, 40, 37, 31, southwest end of 29, 28, 25,24, 20,19,12,11,9,8,7,5, and 2), avoid and/or minimize driving on slopes in excess of 15% wherever possible. Wherever possible, avoid driving on patches of bare soil and take extra precaution to minimize soil disturbance.


20. Noncommercial units 5 and 28 shall be monitored for detrimental soil prior to non-commercial fuels management implementation. These units have been mechanically treated in the past. Should field reconnaissance of existing and legacy soil conditions coupled with the potential for further detrimental soil disturbance present the possibility for exceedance of R1 soil quality guidelines, project work will be delayed until soils are deemed able to support project activities consistent with R1 soil quality guidelines.

21. Ground based skidding equipment would travel off established skid trails only to the extent reasonably necessary to harvest available timber.

22. During mastication activities, efforts would be made to keep depths of piled slash and chips to less than one foot in depth. The purpose of this design criteria would be to a) to minimize extent of high burn severity should the area be subjected to wildfire post-treatment and b) minimize reductions in soil productivity due to forest floor shading.

23. Areas of concentrated soil disturbance such as landings, skid trails, and soils under slash piles would be ripped/scarified where compaction exists and seeded with native species after harvest activities are complete but prior to the following winter season. Erosion control and drainage measures will be applied as appropriate immediately following completion of unit harvest and mastication activities.

Prescribed burning:

24. Prescribed burning would not be conducted until designated units have been deemed sufficiently recovered from past fire activity so as to not impair long-term soil productivity.

25. A site specific burn plan would be developed to prior to prescribed burning. 26. Should unforeseen soil displacement or compaction occur as a result of project implementation,

restoration activities would be undertaken to facilitate site recovery. These activities may include, but would not be limited to, ripping and/or seeding.

27. To allow for recovery of organic matter on site, minimize erosion potential, and ensure maintenance of long-term soil productivity, cattle grazing should be deferred post-burn.

Pile Burning:

28. Use of ground-based mechanized equipment to create slash piles would not occur following mastication unless it has have been determined such equipment use would be consistent with R1 detrimental soil disturbance guidelines.

29. Pile burning would occur during winter or spring to provide for sufficient soil moisture to minimize extent and severity of detrimental soil disturbance.

30. Burn piles shall be no more than 8-12 feet in diameter and 6-8 feet in height. Where feasible, space piles in excess of 50-100 feet of one another.

31. In noncommercial units underlain by clinker geology (same as in DC 20b above), DC 20b would be adhered to for mechanical log piling. In these units, burn piles would only be constructed in locations with slope gradients less than 10%.


Weeds / Range

32. All applicable measures outlined in FS Manual 2080 will be implemented to minimize the spread of noxious weeds. These measures are summarized in the weeds specialist report.

33. Accurate and detailed maps of range management structures would be provided to the Sale Administrator and/or contractor, and prescribed burn organizations, showing the location of the structures. Structures could also be flagged in the project area for identification. It is foreseeable that since the structures have already been established by the Forest Service and associated permittees, any damage to structures would be assigned to the harvest contractor. Repair or repair costs to standard would be expected of the contractor, as well as to the Forest Service during burn operations or other treatments.

Cultural Resources

34. All personnel associated with the proposed North Whitetail Post Fire Project would be informed that no historic or prehistoric site would be disturbed, damaged, destroyed, moved, or removed. If, in connection with operations under the North Whitetail Post Fire Project, any historic or prehistoric resources are encountered activities must cease in the vicinity of the find and the District Ranger and Forest Archaeologist notified. Plans designed to avoid, reduce further disturbance, or mitigate existing disturbance would be formulated in consultation with the MTSHPO, the Northern Cheyenne Tribe and the Forest Service. The discovery must be protected until notified in writing to proceed by the authorized officer (see 36 CFR 800.100, 112: 43 CFR 10.4).

35. Existing Sites: All proposed treatment units were inventoried for cultural resources. No

temporary roads are needed for non-commercial treatments. For context, all sites within treatment units or near routes are discussed. A total of ten recorded cultural resource sites are located within the proposed treatment unit APE, two of which are/have historic and prehistoric attributes. Four sites are located within salvage units, six cultural resource sites are located in non-commercial units. One culturally sensitive site is located within a non-commercial unit. Table 3 summarizes design criteria that will be implemented to remove, reduce, or mitigate disturbances to 10 recorded cultural resource sites located within the Area of Potential Effects (APE).

Table 3. Cultural Resource Site/Type, Proposed Treatment Activity and Stipulations

Site No./Type Treatment Unit Stipulations

24PR0097/lithic scatter Non-commercial unit 24 Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site 24PR0192/lithic scatter Non-commercial unit 04 Treat site to reduce fuels where appropriate; No

machinery, skidding, piling, burning, or seedling tree planting on site

24PR0976/lithic scatter Non-commercial unit 24 Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site


Table 3. Cultural Resource Site/Type, Proposed Treatment Activity and Stipulations

Site No./Type Treatment Unit Stipulations

*24PR1026/CCC camp, lithic scatter

Salvage unit 1; prescribed burn

Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site *24PR1135/cairn, lithic

scatter, quarry Non-commercial unit 5

prescribed burn Treat site to reduce fuels where appropriate; No


24PR2067/lithic scatter Salvage units 20, 21 Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site 24PR2138/lithic scatter, Whitetail Ranger Station

Non-commercial unit 17 Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site *24PR2159/lithic scatter Non-commercial unit 7 Treat site to reduce fuels where appropriate; No


24PR2457/lithic scatter Salvage unit 6; prescribed burn

Treat site to reduce fuels where appropriate; No machinery, skidding, piling, burning, or seedling tree

planting on site 24PR2759/depression,

stone feature Salvage unit 6;

prescribed burn Treat site to reduce fuels where appropriate; No


Table 4 below identifies measures that will be implemented to reduce, remove or mitigate disturbances to six recorded cultural resource sites located on, or adjacent to, existing roads that will be used to access treatment units.

Table 4. Sites Associated With Existing Roads Proposed for Maintenance/Use. Site No./Type Road

Association Stipulations

24PR0442/lithic artifact scatter 4510 Proposed maintenance and use of existing FS Road 4510 will be confined to the existing road template; East Fork Otter Creek Road within the site boundary is a Federal Highway and will not be maintained by the Forest Service during the North Whitetail Project

24PR1026/lithic artifact scatter and Whitetail CCC Camp

4777, 4777B1 Proposed maintenance and use of existing FS roads 4777 and 4777B1 thru site would stay within existing road templates

24PR2361/lithic artifact scatter and historic logging camp

44237 Proposed maintenance and use of existing FS Road 44237 thru site would stay within existing road templates

24PR1151/lithic scatter Road 4769-4512 intersection

Proposed maintenance and use of existing FS Road 4769-4512 will be confined to the existing road template

24PR2135/Beaver Creek-Stacey Road 4769

Provides access to treatment unit 35, 38, 41, 45

Proposed maintenance and use of existing FS Road 4769 will be confined to the existing road template

24PR2137/ Whitetail Creek Road 4423 Provides access to treatment units 17,

18, 21, 22, 23

Proposed maintenance and use of existing FS Road 4423 will be confined to the existing road template


Cumulative Effects Considerations

• Bottom Crib Wildfire - A 130 acre coal seam wildfire burned in March 2016 on north end of project area and in Units 42 and 43 which are proposed for noncommercial treatment.

• Roadside Salvage – 270 acres of hazard trees were cut and decked along existing NFS roads, 60 feet from the centerline throughout the Ash Creek Fire perimeter. Within the project area, roadside hazard trees were cut along NFSR #4427 and #4769.

• Ongoing grazing – Beaver Creek and Liscom Butte Allotments in project area; subject to specifications in their allotment management plans.

• Phoenix Project - 250 Acre Salvage to the south of North Whitetail Post Fire Project Area. • Past Harvest – Summarized in project record from FACTS database.

Decision In this decision, I am authorizing all noncommercial treatments in the North Whitetail Post Fire Project Area with the associated design criteria / mitigation measures described above, including:

• Noncommercial fuels treatments (mastication and pile burning) on approximately 538 acres, • Broadcast burning on approximately 2,660 acres, • Planting ponderosa pine on approximately 1,088 acres • Planting hardwood species in woody draws to the small extent that they occur in the project

area. These activities are displayed spatially on Map 4 – the Modified Proposed Action. The 250 acres of salvage harvest is being authorized under a separate decision. Nearly all of the trees in the noncommercial units are dead; killed in the Ash Creek Fire or subsequent mortality from fire stress and/or insects and disease. Any incidental live trees will not be targeted for removal and are protected through project design criteria. Areas that will be planted are based on fire intensity and aspect as outlined in the regeneration strategy in the Ashland Post Fire Landscape Assessment. Planting of hardwood species will also focus on draws that experienced extensive mortality in the Ash Creek Fire. Existing National Forest System roads used to access the North Whitetail Post Fire Project treatment units will be maintained before, during, and/or after the project. These activities include, where applicable, the following: surface blading/repair, shoulder maintenance, ditch cleaning, and roadway vegetation clearing or cutting. Extensive road improvement including drainage feature construction, localized gravel surfacing, and culvert replacement was undertaken after the Ash Creek Fire. Currently the road system is in good functioning condition. Rationale for the Decision As described in the Fire-Fuels and Forest Vegetation specialist reports in the project file, the North Whitetail noncommercial fuels treatments will meet the purpose and need for action to reduce long term downed fuel accumulations. However, they will not provide timber products to help support local communities. Similar to the salvage treatments, noncommercial treatments will transition to a horizontal fuels profile with a reduced fuel loading. The effect of treatment is a reduction in risk that a high severity wildfire would occur in treated areas.


The 1998 Brewer Fire (58,300 acres) and 2002 Kraft Springs Fire (65,551 acres) on the Sioux Ranger District of the Custer Gallatin National Forest and adjacent private lands demonstrate what can happen under a new wildfire scenario. Up to 40 tons per acre of down dead fuels intermixed with flashy light fuels (grass, brush and tree regeneration) dominated the untreated post 1988/pre-2002 burn area. In 2002 this fuel complex is what carried the Kraft Springs fire. Down logs, snags and grass (representing Fuel Models 12 to 13) burned with the speed of a grass fire, but with the intensity or severity of a logging slash fire. Large logs provided an energy and ember source for short and long range spotting and a ready bed for embers to land on. As indicated by the fire behavior specialist, the continuous large woody debris component was a major carrier of the fire and made suppression operations very difficult (Sandbak, Clark 2005). The end result of this re-burn was a loss of the post fire regeneration (natural and planted) across much of the fire area (Sandbak, 2003). Since the fires of 2000, the Ashland Ranger District has experienced 67 wildfires in areas previously burned, which includes 80 percent of the original Tobin Fire of 2000 (six miles south of this project area) burning again several times throughout the last decade. Of those 67 fires, 25 percent of them have reached sizes greater than 10 acres. Most of those fires have occurred in the last five to seven years. Most recently, the Bottom Crib Fire (2016) burned 130 acres within the Ash Creek Fire perimeter in the northern part of the North Whitetail Project Area. Average surface fuels in the North Whitetail Project Area are currently 5 to 20 tons per acre with some areas exceeding 30 tons per acre (Brennick, 2016). Dead trees (snags) standing post treatment are expected to begin falling with 95% of them down in 5 to 7 years resulting in additional fuel loading on the ground. Please see the Fire-Fuels Specialist’s Effects analysis (Studiner, 2016) in the commercial decision memo. The noncommercial fuels treatments will complement the 250 acres of salvage harvest authorized under a separate decision, and will remove dead trees less than 6 to 8” DBH, thus reducing fuels that will ultimately lie on the ground. Compared to the salvage harvest, the noncommercial treatments will target the smaller diameter snags instead of the dead trees larger than 12” DBH. While it is anticipated that the salvage harvest will be completed in one or two seasons, the noncommercial fuels treatments may occur over an extended time period as funding allows. The project is designed to retain a range of 5 to 13 tons per acre of coarse woody debris on the ground. The overarching objective of fuels reduction is not to “fireproof” the stands, but rather to reduce the likelihood of a new high severity wildfire. Implementation will reduce the fuel loading thereby providing a heterogeneous fuel bed, breaks in fuel continuity, and provide a greater array of strategic and tactical options on future suppression efforts. Broadcast burning will be conducted primarily on the west side of NFSR #4427 (see Map 4), and includes that areas that burned at low, moderate, and high severity in the Ash Creek Fire. Compared to the salvage and noncommercial fuels treatments, broadcast burning authorized under this decision is not restricted to areas that experienced near 100 percent tree mortality in the Ash Creek Fire. As previously described, the central portion of the project area burned at low to moderate severity and contains a mosaic pattern of live and dead trees (See Figure 2). The prescribed fire treatment will initially reduce, and then incrementally serve as maintenance function to achieve desirable CWD objectives on approximately 2660 acres. Broadcast burning will prepare the seed bed for the establishment of desirable tree species (ponderosa pine and green ash) and create a variety of stand ages, composition, and function that will enhance resiliency across the project area. A project design criteria excludes the second burn entry on areas that have been planted to protect regenerating seedlings.


Tree planting, both of ponderosa pine and hardwood species will put the project area on a trajectory to return forest cover post-treatment. Planted areas will be protected from the second broadcast burn entry to protect regenerating seedlings. Where seed producing trees are available, natural regeneration is expected to continue to fill in to meet stocking objectives within 50 to 150 feet of cone producing trees over the next 10 years. However, in moderately to severely burned areas where there is no seed source, ponderosa pine could take ten years to several decades before natural regeneration would begin establishing. This was demonstrated on the Stag Fire on the Ashland District, where burned over transitional forest has largely converted to grassland absent artificial regeneration. Under a reburn scenario such in the 1988 Brewer Fire and 2002 Kraft Springs Fire on the Sioux Ranger district, 69 percent of the forested landscape was deforested with limited seed sources. Regenerating seedlings from the Brewer Fire were impacted by the subsequent Kraft Springs Fire, setting back the return of forest cover. Areas assigned a delayed natural regeneration strategy are still largely void of seedlings today. Planted areas will be stocked to meet the forest stocking goals within five years and jump start the return of forest cover. The project includes design criteria to protect or otherwise minimize impacts to other resources. On steep slopes that are partially or fully underlain by clinker geology where soils are still recovering, a project design criteria will reduce soil disturbance by avoiding and/or minimizing driving on slopes in excess of 15% wherever possible, and by avoiding driving on patches of bare soil (see design criteria above). Standard BMPs, and range and weed mitigation measures will be implemented to protect water and soil resources, range improvements, and reduce the spread of noxious weeds. A project design criteria affords protection to all species of bats by leaving any tree with a bat found on it until either a) no bats are seen on or near the tree, or b) after the pup season (after July 31). The North Whitetail Post Fire Project will result in protection and preservation of cultural resource sites by reducing accumulated fuel loads, which over time, may result in uncontrolled burning that damages lithic artifacts and damages, or totally consumes, historic artifacts or buildings. When combined with the salvage harvest authorized under a separate decision, the total amount of treatments affect 10.3 percent of the ponderosa pine coverage in the project area / 7.2 percent of the ponderosa pine coverage within the Ash Creek Fire perimeter. I find that the North Whitetail Post Fire Project will not result in any extraordinary circumstances that would preclude the use of a Categorical Exclusion. The benefits of treatment are compelling me to approve the project, and analysis has shown that the project will not result in uncertain or significant adverse effects. Effects of the project are described in the various specialist reports in the project record and briefly summarized below.

• The proposed action will maintain and improve habitat for most species across the landscape. The resulting habitat matrix is expected to be adequate for all wildlife resources. Snags and canopy coverage will be maintained for bats. Abundant nesting and foraging habitat for black-backed woodpeckers will remain in the project area and cumulative effects area. Planting and regeneration may provide for future goshawk nesting territories. The matrix of forage, hiding, thermal, and diversity for big game habitat is expected to respond positively to the prescribed treatment. Migratory birds will be affected to varying degrees by prescribed treatments. However, no migratory bird species population is expected to be adversely affected. Prescribed treatments with design criteria and mitigation measures are in compliance with guidelines


established by the Forest Service (USDA 1986A) and no extraordinary circumstances are foreseen.

• Sediment associated with project implementation would likely occur as a short-term pulse or pulses of sediment to ephemeral draw watercourses which have a high demonstrated (by the response to the Ash Creek Fire) capacity for transport and assimilation of sediment. The magnitude and duration of such sediment delivery would likely be miniscule compared to the recent sediment effects of the Ash Creek Fire which produced negligible destabilizing or erosive effects on project area watercourses. Sedimentation would be minimized through implementation of the design criteria and mitigation measures (see design criteria section above), including but are not limited to minimizing area where equipment operates, locating landings on relatively flat ground that can be drained, location of skid trails on gentle slopes, and use of erosion control features such as waterbars. In the long term, reduction of the existing excessive fuel volumes and re-establishment of a higher frequency/low intensity fire regime would help maintain hydrologic conditions and water quality in the project area. The likely result would be a long term improvement in water quality.

• The potential for changes to soil physical properties during mechanized equipment operations

would be minimized under adherence to Region 1 Soil Quality Guidelines along with implementation of design criteria and applicable BMPs. Detrimental soil disturbance is projected to increase within units where mechanized harvest operations have been proposed. Site recovery would be expedited via reclamation activities following project implementation. Changes in organic matter and nutrient cycling associated with harvest activities and prescribed burning are expected to be relatively short-lived through implementation of design criteria and pertinent BMPs, including (but not limited to) implementation of coarse wood guidelines discussed under design criteria/Best Management Practices. Long-term site productivity is not projected to be impaired as a result of project implementation.

• The main issue or concern for the North Whitetail Project for range resources is that the existing grazing allotment infrastructure supporting livestock grazing within the project area could be impacted by the proposed action. There are over 30 water developments with about 15 miles of associated pipeline that occur in the project area. In addition, there is an estimated 16 miles of fence within the project area. It is unlikely that the proposed action will damage structures within the project area, especially since there is a higher level awareness of their location due to mitigation measures. These mitigation measures will be the up to date mapping with accurate GPS data that will be reviewed and provided for project implementation.

• There is a concern the Ash Creek Fire has exacerbated infestations of certain noxious weed species in the area, and that proposed ground disturbing activities and transportation vectors would introduce noxious weeds in the project area and cause weed populations to spread. About 140 gross acres of Canada thistle and spotted knapweed occur within the analysis area. They are scattered along some of the main travel routes. It is estimated that there is a 6-10% density (canopy cover) of these gross area infestations. This equates to approximately 14 net acres of Canada thistle and 9 net acres of spotted knapweed for a total of 23 net acres within the analysis area. Most noxious weed treatments result from project implementation, as there is commitment to monitor and treat weeds during and after any project implementation. After project activities are completed, three consecutive years of monitoring is required per regional protocol. The proposed project activities will bring more personnel on site, creating more


opportunity for inspection, and eventually weed crews or contractors will be able to traverse these areas for both inventory and treatment; the removal of dead/downed fuels will provide better access to treat weed infestations.

• Implementation of the North Whitetail Post Fire Restoration Project may span a period of ten years. Measures taken to protect heritage resources have been integrated into the North Whitetail Post Fire Restoration Project undertaking as Project Design Features and Mitigation Measures and will be applied as specific projects such as the salvage sales and non-commercial treatments are implemented. All heritage field inventories will be completed for temporary roads and landing locations as they are identified on the ground. When the prescribed fire units and planting units locations are identified heritage inventories will be conducted. Consultation with the MTSHPO and Northern Cheyenne Cultural Committee for these additional undertakings will be conducted prior to ground-disturbing activities. As specific site treatment plans for the ten heritage resource sites are developed, additional consultation on these treatments will be conducted with the MTSHPO and the Northern Cheyenne Cultural committee. Forest Archaeologists will monitor sites receiving protective treatments during project implementation and upon completion of the project to assure the preservation and protection of the heritage resources and to determine the success of the proposed treatments. With these measures in place we find that the North Whitetail Post Fire Restoration Project will have NO EFFECT on historic properties and should proceed as planned.

Monitoring Forest Regeneration: All salvage harvest units would be monitored 1st, 3rd, and 5th year after harvest (Forest Plan Monitoring Item E2, pg. 107) for adequate stocking. Action will be taken if minimum regeneration stocking objectives are not met on the natural regeneration and planting strategy areas. Soils: Noncommercial units 5 and 28 shall be monitored for detrimental soil disturbance by CGNF soils personnel prior to non-commercial fuels management implementation. These units have been mechanically treated in the past. Should field reconnaissance of existing and legacy soil conditions coupled with the potential for further detrimental soil disturbance present the possibility for exceedance of R1 soil quality guidelines, project work will be delayed until soils are deemed able to support project activities without incurring detrimental soil disturbance in excess of R1 soil quality guidelines. Detrimental soil disturbance (DSD) monitoring will be conducted within a stratified random sample in the selected treatment units. Monitoring will sample across soil types, 2012 burn severities and past harvested acres in effort to: a) characterize existing condition prior to harvest; and, b) evaluate post-harvest soil impacts. In doing so, monitoring results can be extrapolated to other applicable units. Soils monitoring will utilize standardized monitoring protocols. Coarse wood monitoring will be coordinated with fuels personnel following implementation. Where feasible, this monitoring will be completed in tandem with DSD monitoring. This monitoring will be completed using a standardized monitoring protocol.


BMP Monitoring: Implementation and effectiveness monitoring will be conducted for the North Whitetail Post Fire Project in a manner that is consistent with biannual monitoring efforts that have been implemented on the Custer National Forest since 2011, as well as Montana Interagency BMP review and FS National Core BMP review. Monitoring will evaluate whether mitigation measures, design criteria, BMPs, and SMZ rules for all resources areas were implemented and effective during the project. Cultural Resources: Treatment at cultural sites will be monitored during and following implementation in accordance with the Wildland Urban Interface and Large Scale Hazardous Fuels Reduction Site Inventory Strategy (SIS) protocol. Any proposed maintenance on existing roads within cultural site boundaries will be confined to the existing road prism and these areas will be monitored by an archaeologist to ensure the cultural sites are not disturbed. Weeds: Consistent with FSM 2080, weed treatment should occur on all known weed infestations within, and adjacent to, proposed activity areas before implementation occurs if during the growing season. If proposed activities would occur outside of the growing season, then weed treatment should occur during the previous growing season. All activity areas must be monitored and treated for noxious weeds during the life of the project. In addition, all activity areas must be monitored and treated for noxious weeds for at least three years after activities reach completion.

Scoping and Public Involvement Scoping is required on all proposed actions (36 CFR 220.4). Scoping consisted of both internal and external efforts to identify important issues, concerns, and analysis needs. The Fly Wilbur North Whitetail Restoration Project was scoped in January 2016, posted to the Custer Gallatin web site, and published in the Schedule of Proposed Actions (SOPA). The Forest received eight public comments on the Fly Wilbur North Whitetail Restoration Project. Based on those comments and a field review, the Forest Service modified the proposed action. A description of the modified proposed action was sent to interested parties in April 2016. Only one letter was received in response to the comment period on the modified proposed action. One local resident expressed verbally that they could not support the project since the Fly Wilbur project area was dropped. Concerns raised by the public during both of the comment periods as well as the USFS response, are summarized below. Black-backed woodpecker conservation / MA D habitat management direction. One person expressed a concern that the USFS is allegedly violating NFMA and MA D direction in the Forest Plan to maintain/improve habitat for the black-backed woodpecker, a R1 sensitive species. The commenter cites a MA D standard that silvicultural prescriptions will identify treatments that will perpetuate or improve key wildlife habitat and noted that they were not aware of any science that indicates that salvage logging maintains or improves habitat for any wildlife species. The commenter noted that black-backed woodpeckers will use burned timber for up to 8 years post fire, that the woodpecker requires at least 500 acres of prime habitat per 1000 acres of landscape, and that there will be cumulative habitat loss combined with the Phoenix Project and roadside hazard clearing along NSFR #4133 and #4427. The commenter further alleges that a Forest Plan amendment would be required because the goal of MA D is to manage habitat for wildlife.

• Science cited: Saab et al 1998, Saab et al 2007, Saab et al 2008, Dudley and Saab 2007


Response: The Wildlife Specialist Report evaluated impacts to the black-backed woodpecker and acknowledges that proposed removal of fire-affected trees in the North Whitetail Post Fire Project has potential to negatively impact black-backed woodpeckers. Treatments are scheduled to begin in 2016, four and five years post fire for the Ash Creek and Mill Creek Wildfires, respectively, and thus during a time when woodpecker use of the area could be at its peak. Disturbance during the nesting season could cause reduced parental care and/or nest abandonment, which could affect nestling survival rates, and possibly result in reproductive failure for some breeding pairs. Birds may change nest locations in response to project-associated disturbance. Public comments regarding black-backed woodpeckers cited Dudley and Saab (2007) as the best available science pertaining to nesting habitat requirements. However, this study was conducted in east-central Idaho in forest types different from those on the Ashland Ranger District. Furthermore, within this article the authors caution against extrapolating their formulas to different forest types. Regardless, in the interest of addressing commenters concerns and following the recommendation of Dudley and Saab (2007) for estimating black-backed woodpecker nesting territories for high quality habitat, estimates for the North Whitetail Post Fire Project were calculated. The analysis discloses that there is sufficient habitat for approximately 47 black-back woodpecker breeding territories within the perimeter of the Ash Creek (2012) and Mill Creek (2011) wildfires even with excluding both the Phoenix and North Whitetail Post Fire Projects. Excluding Phoenix Project, Roadside Hazard Tree Removal, and North Whitetail Post Fire Projects and within the direct, indirect, and cumulative effects area there is sufficient habitat for 87 black-backed woodpecker nesting territories. These estimates are only for the habitat classified as High by the suitability index and do not include those areas classified as Medium or Low, despite the use, albeit at lower intensity, of these areas by black-backed woodpecker populations. The amount of highly suitable habitat for black-backed woodpecker excluding the Phoenix Project, Roadside Hazard Tree Removal, and North Whitetail Post Fire Projects within the direct, indirect, and cumulative effects area is more than 1.5 times greater than the habitat estimated to be needed to maintain a viable population of black-backed woodpeckers for all of Region 1 of the U.S. Forest Service (USDA 2007). Given the recent (2012) large (over 200,000 acres combined) fires on the Custer Gallatin National Forest, there is little doubt that at least 30,000 acres of burned forest habitat exists in the Southern Rocky Mountain eco-province in which the project is located. In fact, approximately 47,694 acres of ponderosa pine forest were affected by fire in 2012 on National Forest System lands within the Ashland Ranger District alone. Nesting and foraging habitat for black-backed woodpeckers is not limited within the project area, and is abundant due to recent large fires across the entire District. Due to the relatively small size of the project (250 acres of harvest, or 1.6% of highly suitable nesting habitat for black-backed woodpecker available in the cumulative effects area), the proposed action may impact individuals and habitat, but would not lead to a trend toward federal listing or affect overall viability of the black-backed woodpecker. This determination is based on the vast amount of suitable habitat produced by large-scale wildfires in the Northern Region, and specifically on the Custer Gallatin National Forest in recent years. Consideration of Opposing Science: Bozeman Daily Chronicle. 2012. Silence in the forest: protection sought for rare western woodpecker. This article is not applicable because 1.) The Ashland Ranger District is not salvaging 100% of burned forests. This decision only authorizes non-commercial fuels treatments (removal of dead trees less than


8” DBH), prescribed fire, and tree planting. 2.) The Black Hills NF is not “just east” of the Ashland Ranger District as the commenter alleges in their letter. The Ashland Ranger District is >70 miles from the nearest portion of the Black Hills NF in Wyoming. 3.) Black-backed woodpeckers on the Ashland Ranger District have not been petitioned to be listed on the Endangered Species List.

Dudley, J. and V. Saab. 2007. Home range size of black-backed woodpeckers in burned forests of southwestern Idaho. Western North American Naturalist 67:593–600. Despite this article reporting numbers from black-backed woodpecker populations in a different geographic area with different forest species composition, calculations for high quality habitat (207ha per male breeding territory) from this article were used to conservatively estimate black-backed woodpecker populations within the project area and cumulative effects area. Estimated populations are more than sufficient to maintain viable populations (USDA 2007).

Saab, V. and J. Dudley. 1998. Responses of cavity nesting birds to stand replacement fire and salvage logging in ponderosa pine/Douglas-fir forests of southwestern Idaho. USDA Forest Service Research Paper RMRS-RP-11. Rocky Mountain Research Station. This article reports black-backed woodpecker population habitat selection from a different geographic area with different forest species composition. Extrapolation of results from this study may not be appropriate to the North Whitetail Post Fire Project. However, the black-back analysis for this proposed action acknowledges that salvage harvest will reduce habitat suitability for this species (authorized in the North Whitetail Post Fire Project Commercial decision memo). The most recent model, and best available science, for estimating black-back woodpecker nest habitat suitability developed by the Rocky Mountain Research Station (the same institution the produced the Saab and Dudley 1998 article) was used to estimate available habitat in the project area and cumulative effects area (Latif et al. 2012). Calculations of available remaining habitat completely excluded treatment units for this project, Roadside Salvage Tree Removal, and the Phoenix project, taking the most conservative scenario that no suitable black-back woodpecker habitat will remain within treatment units. Results indicate that more than 1.5 times the suitable nesting habitat needed to maintain a viable population of black-backed woodpeckers for all of Forest Service Region 1 will remain in the cumulative effects area of this single project (USDA 2007).

Saab, V., R. Russell, and J. Dudley. 2007. Nest densities of cavity nesting birds in relation to post fire salvage logging and time since wildfire. The Condor 109:97–108. This article reports black-backed woodpecker population habitat selection from a different geographic area with different forest species composition, the same study cites as Saab and Dudley (1998). Extrapolation of results from this study may not be appropriate to the North Whitetail Post Fire Project for the same rationale described above for Saab and Dudley 1998.

Saab, V., R. Russell, and J. Dudley. 2008. Nest site selection by cavity nesting birds in relation to post fire salvage logging. Forest Ecology and Management. This article reports black-backed woodpecker population habitat selection from a different geographic area with different forest species composition, the same study cites as Saab and Dudley (1998). Extrapolation of results from this study may not be appropriate to the North Whitetail Post Fire Project for the same rationale described above for Saab and Dudley 1998. Mule Deer / MA D habitat management direction. One person expressed a concern that the USFS is allegedly violating NFMA and MAD D direction in the Forest Plan to maintain/improve habitat for mule deer because salvage harvest:


Creates openings larger than 5 acres; Destroys existing hiding cover provided by large and small green trees that have

survived; Reduces habitat diversity; Retards recovery of hiding cover in burned areas; Removes cover from jack-strawed downed burned trees…important for fawns; and, Science cited: Mackie et al 1998, Gottfried and Jones, 1975, Donota et al 2006,

Lindemayer et al 2004.

The commenter alleges the project is not consistent with a MA D standard that silvicultural prescriptions will identify treatments that will perpetuate or improve key wildlife habitat and another MA D standard that requires habitat goals for mule deer to be identified and assessed (hiding cover, thermal cover, forage-cover ratios, snag densities, spring/summer/fall ranges, fall security). They noted that they were not aware of any science that indicates that salvage logging maintains or improves habitat for mule deer. Response: The North Whitetail Post Fire Project is consistent with all forestwide and MA standards, in particular the MA D management direction that was cited.

The commenter was concerned that “Salvage logging does not promote wildlife.” The North Whitetail Post Fire Project is not “simply a logging project.” This project incorporates non-commercial thinning treatments, prescribed burning, and restoration planting in complement with salvage harvest. Salvage harvest will be used to reduce heavy fuel loads which will help improve success and resiliency of restoration planting, that otherwise would be at greater risk of detrimental wildfire that would not only destroy plantings but possibly adversely affect soil health and potentially compromise the ability of the landscape to recover to desired management conditions. Furthermore, because of the large extent of the Ash Creek Fire (largest recorded wildfire in Montana history) expansive areas of complete tree mortality currently exist on the landscape and lack nearby sources for regeneration. These areas are a relatively uniform “sea of snags”. Selective thinning of these areas by salvage harvest and non-commercial treatments will create a more heterogeneous landscape and possible provide niches for a more biologically diverse complement of species. The commenter was concerned that salvage harvest is larger than the 5 acre openings recommended by Mackie et al. (1998) and will reduce what little cover is currently being provided in these partially-burned areas. Mackie et al. (1998) recommendation of 5 acre openings refer to green forests. The proposed Whitetail Post Fire Project is not in green forest. Salvage harvest units are generally effected by stand replacing fire without nearby seed sources for regeneration. These are much larger than 5 acres. Without regeneration treatments these areas are expected to look similar to the approximate 62,000 acre Stag Fire (2000) within about 10 years where forest conversion to grasslands 10’s to 100’s of acres in size occurred. The commenter was concerned that large salvage areas will reduce the habitat diversity so important to mule deer. The Ash Creek Fire (2012) burned just under 250,000 acres. The proposed North Whitetail Post Fire Project will salvage dead trees >12 inches dbh on 250 acres, the Phoenix Project salvaged dead trees >12 inches dbh on 250 acres. The combined extent of salvage within the Whitetail Post Fire Project and the Phoenix Project is 0.2% of the Ash Creek Fire (2012). This amount of area is not large in the context of the extent of the Ash Creek Fire (2012). Indeed, no combination of adjoining salvage


units is >59 acres. Furthermore, salvage harvest may “break up” the homogeneity of the landscape and actually provide greater habitat diversity to a host of species. Lastly, the habitat provided by burned out stand replaced forests is not long lasting. Without, a source for regeneration or artificial planting catastrophically burned forest will transition to grassland, as has happened with the approximate 62,000 acre Stag Fire (2000). Grasslands are the second least used habitat type by mule deer on the Ashland Ranger District, just ahead of sparse scab lands (see analysis). Completion of the North Whitetail Post Fire Project in the long term should increase habitat diversity so important to mule deer. The commenter was concerned that, “The recovery of hiding cover in burned areas that is developing in ponderosa pine regeneration in the Ash Creek Fire will be significantly retarded with salvage logging (Gottfried and Jones 1975; Donota et al. 2006; Lindemayer et al. 2004). This statement pertaining to the North Whitetail Post Fire Project is unfounded, and the cited literature is not relevant. Each source is discussed below:

• Gottfried and Jones (1975) study site is located in Arizona with different climatic conditions than southeast Montana. Furthermore, this study pertains to impacts of logging (green trees) and not salvage harvest of catastrophically burned stand replacing fires. Finally, the commenter has mis-interpreted this article to claim that logging activities compromise regeneration. To the contrary, this article supports the use of “logging damage to advance regeneration on an Arizona mixed conifer watershed”, in fact this quote is the TITLE of the article. This article reports that “logging damage” reduces the number of regenerated saplings in green forests. For ponderosa pine on the Ashland Ranger District most often we desire to reduce the number of saplings because they regenerate in a hyper-abundance that can become a significant fuel hazard. Thinned saplings produce a more resilient and productive forest. Furthermore, this article reports that non-pine broadleaf vegetation benefits from the “logging damage”. This type of vegetation regeneration is superior hiding and thermal cover for big game and generally more beneficial to most wildlife species. Unfortunately, this project will not realize the type of impacts this article reports because this project will take place in a catastrophically stand replaced burn and the seed source present in typical green harvests is not present at the proposed project location.

• Donota et al. (2006) study site is in southern Oregon in a forest with different climate and tree

species composition. Furthermore, their results are only from one year of data and report only short-term effects and predictions. The North Whitetail Post Fire Project is a long-term endeavor, albeit the commercial salvage harvest will likely be completed in two seasons, restoration and prescribed burning will likely take 10 years or more to complete. This article states that “Postfire logging alone was notably incongruent with fuel reduction goals.” However, the North Whitetail Post Fire Project does not propose postfire salvage alone. The North Whitetail Post Fire Project proposes to holistically approach restoration of a small portion of the Ash Creek Fire (2012) using pine planting, woody draw vegetation planting, prescribed burning, non-commercial thinning, and salvage harvest. Natural regeneration within portions of the Ash Creek Fire proposed for planting is limited, and sapling reduction as described by Donota et al. (2006) will not occur at the same extent.

• Lindemayer et al. (2004) is not applicable to this project. It is a one page editorial in Science

magazine that speaks in generalities that are not relatable to wildfire salvage harvests in southeast Montana. Examples it includes are from: storm damage in the eastern U.S. in 1938 and sometime before 1983, and decreased habitat for species in Australia and Southeast Asia.


This paper does cite Hutto (1995). The analysis for this project cites Hutto’s more recent publications (1998, 1999) and acknowledges that there will be some reduction in cavity nesting availability, however this amount will be insignificant.

The commenter was concerned that “…this salvage logging will destroy existing hiding cover that is being provided by both large and small green trees that have survived in the proposed salvage units.” The Whitetail Post Fire Project will not harvest green trees. This decision only authorizes noncommercial fuels treatments (removal of dead trees less than 8”DBH), prescribed fire, and tree planting. Furthermore the commenter requests that the following be identified as relevant to MA D management:

• Road density pre- implementation and during implementation. Public open road density will not be changed by the North Whitetail Post Fire Project. Up to ½ mile of temporary road will be approved for salvage harvest. The temporary use of ½ mile of temporary road will not significantly affect big game use of the project area. After cessation of temporary road use for salvage harvest road density in the project area will be the same as it was before project implementation. The North Whitetail Post Fire Project is not in western Montana and the influence of roads on big game distribution and habitat use is not uniform across the state. The assumption that roads and associated disturbances are the primary factors is an oversimplification of the complex landscapes and animal movements and interactions that influence big game distribution and habitat use (Agar 2003). Mule deer distribution in particular is not affected by road density in the same way as elk (Agar 2003). The analysis for the North Whitetail Post Fire Project evaluated habitat use of the project area with spotlight data collection on the Ashland Ranger District and the project area. Open road densities in the project area will not change, and are not a meaningful indicator for mule deer in eastern Montana. Therefore they were not analyzed.

• Current and post-implementation levels of hiding and thermal cover. Hiding and thermal cover are typically estimated with percent canopy cover derived from VMap. However, proposed salvage units are classified as transitional forest and canopy cover is not available for this habitat type. The estimated availability of hiding and thermal cover would be zero if a canopy cover standard is used to assess salvage units. Downed and “jack-strawed” snags do have some value as hiding and thermal cover for big game, however this type of habitat is not long-term viable. As snags continue to fall hiding cover decreases and downed snags burn or rot away. Salvage units were identified in part because they lack seed sources for natural regeneration. Over time these areas will convert to grasslands, as has happened in the Stag Fire (2000). Other than sparse scab-lands, grasslands provide the least amount of thermal and hiding cover for big game. Because traditional methods of estimating thermal and hiding cover would produce inaccurate results they were not used to analyze big game effects. More importantly, the current availability of thermal and hiding cover is not relative to assessing the long term impact of this proposed project because cover availability in the project area is not stable. The effect of the North Whitetail Post Fire Project will increase the long-term availability of hiding and thermal cover through the implementation of preparation (salvage harvest, non-commercial thinning, prescribed burning) and restoration (pine planting, woody draw species planting) treatments (see the Wildlife Specialist’s effects analysis for details (Stasey, 2016)).

• Big game security before, during, and after implementation, defined as “contiguous blocks of hiding cover at least 0.5 miles from an open road”.


Mule deer are the species of interest for MA D. The science cited by the commenter is designed for elk, particularly on the western portions of Montana. It is inappropriate and ecologically unsound to use a western Montana elk standard to assess mule deer in eastern Montana. This indicator does not represent best science for mule deer in eastern Montana and was therefore not analyzed. Mule deer were evaluated with spotlight data collected on the Ashland Ranger District and within the project area and by predicted effects to habitat components. The commenter requested a management plan for black-backed woodpecker based on Dudley and Saab (2007). A management plan for black-backed woodpecker is not required by the Custer Forest Plan or NEPA. Furthermore, Dudley and Saab (2007) do not represent the best science for evaluating black-backed woodpecker habitat. Instead, the best available science for evaluating black-backed woodpecker habitat from Latif (2012) was used in the North Whitetail Post Fire Project analysis. The Northern Region Overview for the Black-backed Woodpecker (USDA 2007) contains key research findings and considerations for project analyses in situations where proposed actions could affect black-backs or their habitat. Such considerations include incorporating mitigation and project design measures where necessary to conserve the species. The Overview indicates that if sufficient habitat (at least 30,000 acres of post-fire and/or bark beetle infested areas) exists within the eco-province within which the project occurs, then there is no need to mitigate or provide specific design elements to protect black-backed woodpeckers at the project level. Given the recent (2012) large (over 200,000 acres combined) fires on the Custer Gallatin National Forest, there is little doubt that at least 30,000 acres of burned forest habitat exists in the Southern Rocky Mountain eco-province in which the project is located. In fact, approximately 47,694 acres of ponderosa pine forest were affected by fire in 2012 on National Forest System lands within the Ashland Ranger District alone. Nesting and foraging habitat for black-backed woodpeckers is not limited within the project area, and is abundant due to recent large fires across the entire District. The commenter requested “…map the conservation strategy that will maintain black-backed woodpecker habitat in the project areas, as is required by MA D.” The effects to black-backed woodpecker are disclosed in the North Whitetail Post Fire Project analysis. A map of available suitable habitat within the project area and cumulative effects area is also provided. Effects to black-backed woodpecker populations from the North Whitetail Post Fire Project will be negligible. Nesting and foraging habitat for black-backed woodpeckers is not limited within the project area, and is abundant due to recent large fires across the entire District. Refer to the discussion above. Snag Habitat. One person raised a concern that the USFS is allegedly violating NEPA and NFMA by failing to manage snag habitat for wildlife and that the project will negatively impact cavity-nesting birds that use burned forest. The commenter alleges that:

1. The prescription to leave all green trees and dead trees < 12” will likely not be implemented, which will have a severe impact on cavity nesting birds.

2. Larger snags remain standing longer than small snag, and are more valuable to nesting birds. 3. The salvage logging will reduce the time period when these burns provide nesting habitat for

cavity nesters. 4. What is the effect, including cumulative impact, of salvage logging on snag density and size, post

project and next rotation cycle (100 years)? 5. Appendix A shows salvage logging in an old burn west of Ashland did not leave any snags. 6. Science cited: Hutto 1995


Response: 1. The North Whitetail Post Fire Project does not target green trees for salvage. Refer to the description of the Modified Proposed Action and Design Criteria 2, 3, 4. The analysis of the North Whitetail Post Fire Project acknowledges that snags will be reduced in the treatment units. However, the Ash Creek Fire (2012) burned just under 250,000 acres. The proposed North Whitetail Post Fire Project, inclusive of all treatments, will only affect 10.3 percent of the ponderosa pine coverage in the project area / 7.2 percent of the ponderosa pine coverage within the Ash Creek Fire perimeter. Snag availability and connectively will not be significantly reduced for snag and cavity dependent species. 5. The fire in question is believed to be on the Northern Cheyenne Indian Reservation, it is not in the jurisdiction of the Ashland Ranger District. 6. The analysis for this project cites Hutto’s more recent publications (1998, 1999) and acknowledges that there will be some reduction in cavity nesting availability, however this amount will be insignificant.

Noxious Weeds. Several people raised a concern that the proposed project may spread noxious weeds and asked that the project including monitoring and treatment of all infestations of noxious weeds. Response: The project will be consistent with noxious weed mitigation outlined in the 2006 Custer National Forest Weed Management EIS, Forest Service Manual (FSM) 2080, and in the Noxious Weed Specialist Report. Salvage Costs: One person asserts that given the cost of logging is about $1400 per acres asks the Forest Service to summarize all the costs that are expected to be triggered by these salvage activities, including weed management and why they are a priority by the Custer/Gallatin National Forest. Response: In this case, logging costs are not something towards which the Forest Service allocates funds. This project is the salvage of forest products and the purchaser assumes the costs of getting the material from the site to the mill. Weed spraying and road maintenance activities are part of the Forest’s regular program of work and priority areas are treated annually. Noncommercial fuels treatments are implemented within the annual fuels program of work as funding allows. In some instances, the Forest Service could allocate funds towards tree removal, as in the case of a service contract to accomplish Forest Plan objectives. Landscape Strategy. A couple people submitted comments asking about the long term management of the Ashland Ranger District. One person asked that a landscape strategy for management burned forest should be developed prior to salvage logging, and felt that management actions would occur at the expense of the black-backed woodpecker. Another person submitted a comment that the USFS should have a plan to manage the forest to keep it healthy and that doing nothing will create a mess in 75 to 100 years. Response: The Custer Gallatin National Forest prepared the Ashland Post Fire Landscape Assessment in 2014. This landscape assessment describes human (social and economic), biological and physical conditions, processes and interactions across the District in consideration of the large wildfires that have occurred over the past 20 to 30 years. The assessment focuses on specific issues or management questions, values and uses associated with watersheds and mixed grass prairie, riparian and hardwood draws, and ponderosa pine ecosystems that comprise the District landscape. For each of the principal


ecosystems, the assessment describes past trends, existing conditions, and desired conditions for both biophysical and social elements that are essential for making sound management decisions. Utilizing a framework centered on the major ecosystems, management opportunities will be identified for later project specific NEPA analysis and decision making. This assessment sets the stage for identifying purpose and need, desired conditions and future NEPA projects on the Ashland Ranger District and is consistent with the Forest Plan. Proposed Action: Several local residents provided comments on the proposed action that resulted in development of the Modified Proposed action. A concern was raised about broadcast burning in the Fly Wilbur project area near private lands. The person felt there had been enough fire and didn’t want to see any more. Several people raised a concern about potential impacts to range structures including fences, pipelines, and stock tanks. Concerns were also raised about the viability of tree planting with future broadcast burning. Response: Public comments were used to develop the Modified Proposed Action and associated design criteria/mitigation measures.

Findings and Reasons for Categorically Excluding this Action The Council on Environmental Quality (CEQ) regulations at 40 CFR 1507.3 provide that agencies may adopt categories of actions that do not normally have significant impacts on the human environment and that do not require preparation of an environmental assessment (EA) or environmental impact statement (EIS). Pursuant to direction provided in 36 CFR 220.6 and FSH 1909.15, a decision may be categorically excluded from further analysis and documentation in an EIS or EA only if it is a routine action, there are no extraordinary circumstances related to the action and if the action is within a category listed in 36 CFR 220.6 and FSH 1909.15. Based on environmental analysis of this project, I find that, per requirements of 36 CFR 220.6 and FSH 1909.15 Chapter 30, my decision to approve the North Whitetail Post Fire Project (noncommercial fuels treatments, prescribed fire, and tree planting) fits with the following categories:

• 36 CFR 220.6(e)(5) / FSH 1909.15 Section 13.2, Category 5

Regeneration of an area to native tree species, including site preparation that does not involve the use of herbicides or result in vegetation type conversion.

• 36 CFR 220.6(e)(6) and FSH 1909.15 Section 32.2, Category 6

Timber stand and/or wildlife habitat improvement activities that do not include the use of herbicides or do not require more than 1 mile of low standard road construction.

• is a routine action; • will not result in the existence of extraordinary circumstances; and, • will not result in uncertain or significant effects.

This project was analyzed under the National Environmental Policy Act of 1969 (NEPA), as amended. NEPA analysis included consideration of specific resource conditions to determine whether


extraordinary circumstances warrant further analysis and documentation in an EA or an EIS (36 CFR 220.6(b)). It should be noted the mere presence of one or more of these resource conditions does not preclude use of a category or categories and preparation of a decision memo. It is the degree of the potential effect of a proposed action on these resource conditions that determines whether extraordinary circumstances exist. The results of this test for extraordinary circumstances are as follows: Federally Listed Threatened or Endangered Species or Designated Critical Habitat, Species Proposed For Federal Listing or Proposed Critical Habitat, of Forest Service Sensitive Species The Wildlife Specialist Report / Biological Assessment discloses the effects on federally listed threatened or endangered species and designed critical habitat, as well as sensitive species that are found or may potentially be found within the project area. Northern long-eared bat: A Biological Assessment was completed, and the analysis concludes that the project may affect, is not likely to adversely affect (NLAA) the northern long-eared bat. The NLAA determination is based upon implementation of Design Criteria 8, 9, and 10. There are no known northern long-eared bat winter hibernacula or occupied roost trees within or near the project area. Harvest prescriptions do not include clear-cutting or similar methods; only snags 12 inches dbh or larger would be removed. All applicable conservation measures from the US Fish and Wildlife Service would be met with the proposed North Whitetail Post Fire Project. Additionally, Design Criteria 9 will effectively protect any species of bat because 1) any bat species would be protected; i.e. loggers would not be required to identify bat species, 2) northern long-eared bats switch tree roosts often – typically every 2 to 3 days (USDI 2015b) and 3) young bats should have sufficient flight skills developed by the end of pup season to escape harm. On 6/7/2016, the USFWS concurred with this determination. Black-backed woodpecker: Effects to black-backed woodpeckers were disclosed in the Wildlife specialist report. Nesting and foraging habitat for black-backed woodpeckers is not limited within the project area, and is abundant due to recent large fires across the entire District (47,694 acres of ponderosa pine forest burned in 2012 on the District). A regional assessment of habitat required for a minimum viable population indicates that if sufficient habitat (at least 30,000 acres of post-fire and/or bark beetle infested areas) exists within the eco-province within which the project occurs, then there is no need to mitigate or provide specific design elements to protect black-backed woodpeckers at the project level (Ibid:25). Given the recent (2012) large (over 200,000 acres combined) fires on the Custer Gallatin National Forest, there is little doubt that at least 30,000 acres of burned forest habitat exists in the Southern Rocky Mountain eco-province in which the project is located. In fact, approximately 47,694 acres of ponderosa pine forest were affected by fire in 2012 on National Forest System lands within the Ashland Ranger District alone. Cumulative effects from the proposed action are expected to be minimal. Combined the Phoenix Project and North Whitetail Post Fire Project commercial and noncommercial treatments represents 1.3% of the transitional forest available on National Forest System lands within the Ashland Ranger District. Only about 4% of the total acres of burned forest habitat on the Custer portion of the Forest were harvested between 1999 and 2010 (Canfield 2012). Since the 2012 fires, approximately 270 acres have been harvested along roadsides where fire-affected trees posed hazards to the public and/or administrative personnel. No additional fire salvage harvest is reasonably foreseeable beyond the North Whitetail Post Fire Project, because burned trees are progressing beyond the point where they are merchantable.


Due to the relatively small size of the project (250 acres of harvest, or 1.6% of highly suitable nesting habitat for black-backed woodpecker available in the cumulative effects area), the proposed action may impact individuals and habitat, but would not lead to a trend toward federal listing or affect overall viability of the black-backed woodpecker. This determination is based on the vast amount of suitable habitat produced by large-scale wildfires in the Northern Region, and specifically on the Custer Gallatin National Forest in recent years. Sensitive Bat Species: A number of bat species have been detected in the project vicinity over time (Lenard et al. 2009), but no sensitive bat species have been detected in the project area since the Ash Creek fire burned in 2012 (B. Maxell, pers. comm. 2015). Bat species on the Regional Forester’s list of sensitive species that are also sensitive in the state of Montana, and were either known or suspected to occur in the project vicinity pre-fire include the pallid bat (Antrozous pallidus), spotted bat (Euderma maculatum) and Townsend’s big-eared bat (corynorhinus townsendii). Of these, only the Townsend’s big-eared bat has actually been documented within the project area (pre-fire). There was a single detection of a pallid bat outside, but near the project area; again this detection was made pre-fire. There have been no spotted bats detected in the project vicinity. Design criteria #9 will minimize effects to sensitive bat species. Since burned forest is not necessarily the preferred roost habitat for these species, and this type of foraging habitat is clearly not limited in the project area or surrounding vicinity, the proposed action may impact individuals or habitat, but would not lead to a trend toward listing for the pallid bat, spotted bat or Townsend’s big-eared bat. Floodplains, Wetlands, or Municipal Watersheds The project area is not part of a municipal watershed. Project mitigation measures would ensure that vehicles and logging machinery would not be driven within 50 feet of wetlands (with the exception of maintenance/reconstruction/decommissioning of existing roads and designated temporary crossings), Streamside Management Zone regulations regarding tree retention would be extended to apply to isolated wetlands, and no materials would be deposited into wetlands. In addition, no mechanical treatments would be carried out within riparian areas. These project mitigation measures would adequately protect project area wetlands and riparian areas from impacts associated with Non-Commercial or Salvage treatment units. Because of the project mitigation measures it is likely that effects (if any) upon wetlands, riparian areas, or floodplains would be negligible. Based upon the Custer Gallatin NF record of success in implementing Best Management Practice (BMP) and MT Streamside Management Zone (SMZ) requirements, the chance of long-term detrimental impacts to wetlands, riparian areas, and floodplains through project implementation is minimal. Custer Gallatin National Forest watershed personnel will work with timber sale administrators to avoid and/or minimize impacts as well as to monitor these resources during project implementation. Congressionally Designated Areas, including Wilderness, Wilderness Study Areas, or National Recreation Areas; Inventoried Roadless Areas, Potential Wilderness Areas, & Research Natural Areas The project area does not include any Wilderness Areas, Wilderness Study Areas, National Recreation Areas, Inventoried Roadless Areas, Potential Wilderness Areas, or Research Natural Areas. The Cook Mountain Hiking and Riding Area is located approximately five miles to the west of the North Whitetail Project Area and will not be impacted by the project. There will be no effects to any of these areas.


American Indian and Alaska Native religious or Cultural Sites & Archaeological Sites, or Historic Properties or Areas The project includes design criteria that remove, reduce, or mitigate any disturbance to 10 recorded cultural sites within the Area of Potential Affects (APE), as well as 6 cultural sites located on, or adjacent to, existing roads that are proposed for maintenance/use to access treatment units. A proactive approach that includes, where possible, treatment of cultural resources rather than avoidance/exclusion would benefit the cultural resources and eliminate the creation of “untreated islands or donuts” within the North Whitetail Post Fire Project Area. Excluding site locations from seedling pine tree planting would benefit cultural sites by eliminating ground disturbance due to hoe-dad planting, reducing tree growth across the site, and reducing potential wildfire and tree uprooting effects. Prior to implementing the proposed North Whitetail Post Fire Project, the Heritage Specialist Report, and any other changes to the proposed project, will be submitted to the MTSHPO for consultation. All sites would be avoided by new ground disturbing activities. If any new actions are planned that are not specifically identified under the Proposed Action an archaeological assessment, and possibly consultation with the MTSHPO, would be required prior to implementing the new action. All personnel associated with the proposed North Whitetail Post Fire Project would be informed that no historic or prehistoric site would be disturbed, damaged, destroyed, moved, or removed. If, in connection with operations under the North Whitetail Post Fire Project, any historic or prehistoric resources are encountered activities must cease in the vicinity of the find and the District Ranger and Forest Archaeologist notified. Plans designed to avoid, reduce further disturbance, or mitigate existing disturbance would be formulated in consultation with the MTSHPO, the Northern Cheyenne Tribe and the Forest Service. The discovery must be protected until notified in writing to proceed by the authorized officer (see 36 CFR 800.100, 112: 43 CFR 10.4).

Findings Required by Other Laws National Forest Management Act of 1976 & the Forest and Rangeland Renewable Resources Planning Act It is policy that all forested lands in the National Forest system be maintained in appropriate forest cover with the species of trees, degree of stocking, rate of growth, and conditions of stand designed to secure the maximum benefits of multiple use sustained yield management. The National Forest Management Act and Forest Service Manual direction require that clearcutting must be justified as the optimum method to meet management objectives when prescribed. Clearcutting of live trees is not being proposed in the traditional sense. The fire is what initiated the loss of trees and the initiation of a new crop of trees. Salvaging of dead trees is intended to reduce future long term fuel loads while providing wood products to the local community. This was determined to be the optimum method for meeting these management objectives by the project silviculturist. Previous regeneration harvests in the project area and salvage harvesting across the district since 1981 with a regeneration purpose have been successfully stocked within 5 years. Forest Service Manual 2471.1 states that the size of harvest openings created by even-aged silvicultural in the Northern Region is normally 40 acres or less. However, where natural catastrophic events such as


fire, windstorms, or insect and disease attacks have occurred, 60 acres may be exceeded without 60-day public review and Regional Forester approval, provided the public is notified and the environmental analysis supports the decision. The North Whitetail Post Fire Project will not create openings larger than 60 acres. Custer National Forest Management Plan: The Forest Plan includes forest wide objectives to maintain a healthy diverse timber resource, improve or maintain wildlife habitat, salvage dead timber, control insects and disease, and reduce natural fuel loading. I find that the selected action is consistent with Forest Plan’s goals, objectives and management area direction for the Custer National Forest, and Forest Service direction contained in the Forest Service manual and handbook system. Fuels treatment that reduces downed heavy fuels is responsive to forest plan management direction to provide a safe environment for public use and resource management activities as well as a cost-efficient fire protection and fuels program (Forest Plan page 5). Salvaging dead timber and providing timber products to support local industry is also a desirable Forest Plan objective (Forest Plan, page 5). Tree planting (authorized under a separate decision) and monitoring of regeneration will help to meet reforestation and stocking objectives in the Forest Plan and Forest Service manuals (see forest vegetation report). Design criteria will be implemented to adequately protect other resources and no forest plan amendments are required. Almost all of the noncommercial treatments are located in lands designated as MA D. Approximately 0.26 acre Unit 3 – Noncommercial fuels treatment is located in MA G. MA D: Management Area D is a multiple use management area that includes areas that are important to the perpetuation of selected wildlife and fish species. The goal of MA D is to maintain or improve the long-term diversity and quality of habitat for the selected species identified by Ranger District, as well as accommodate other resource management activities such as timber harvest, livestock grazing, and oil and gas development. Some short-term habitat impacts may be necessary to achieve long-term wildlife goals. This goal will be achieved through direct wildlife habitat improvement, as well as selecting, scheduling and implementation of cultural practices associated with other multi-resource management activities. Efforts will be made to avoid or mitigate resource conflicts. If the responsible official determines that conflicts cannot be adequately mitigated, she/he will resolve the conflict in accordance with the management area goal, and if necessary, in consultation with affected parties. (Forest Plan, p 53).

The Project is consistent with all applicable MA D standards. No Forest Plan amendment is required to implement the salvage harvest. The wildlife specialist report evaluates impacts to wildlife species and their habitats found in the applicable analysis area for species analyzed in detail. Proposed vegetation management activities in will help maintain forest health, vigor, and productivity. Long-term diversity and quality of wildlife habitat will have a higher improved probability to be maintained under proposed action.

MA G: The goal of MA G is to manage these areas for the maintenance and improvement of a healthy diverse forest and as a source of wood products for dependent local markets. In MA D, the Forest Plan has a standard to retain two snags per acre, where they exist. Even-aged management is preferred, and silvicultural systems that favor natural regeneration will be emphasized. The objective will be to


regenerate harvested areas within five years. Less than one-half acre of noncommercial fuels treatment is planned in MA G and is consistent with applicable MA G goals and standards.

Endangered Species Act In accordance with the Endangered Species Act (ESA), Forest Service Manual 2670, and Forest Service Region 1 policy, this project was analyzed for potential effects to Federally Listed Threatened and Endangered wildlife species. The wildlife biologist’s biological assessment discloses that implementation of this decision will have no adverse effects to Threatened or Endangered Species. The project-level analysis determined that the proposed action would have no effect on the Canada lynx, least tern, black-footed ferret, and grizzly bear since either the species, or their habitat, or both, are lacking in the project area. The USFWS determined threatened species status for the northern long-eared bat (Myotis septentrionalis) in April 2015 (USDI 2015). The USFWS list of threatened and endangered species indicates that the northern long-eared bat range is in Powder River County, Montana which encompasses the proposed project (USDI 2015). Powder River County is presumed to be on the western edge of the northern long-eared bat’s range. However, no information exists to confirm its presence. The only record known of northern long-eared bat in Montana are from a single male collected from Richland County in 1978 from a now sealed coal mine. No additional detection of the species has occurred in Montana since 1978, even though surveys have been conducted in the eastern portion of the state (Montana Field Guide 2015 cited in USDI 2015). There is no designated critical habitat for the northern long-eared bat. The project is located >500 miles outside the buffer area for white nose syndrome (WNS) infection in bat species, and therefore falls under the 4(d) rule exception that became effective on 16 February 2016 (USDI 2016). The District wildlife biologist determined that the project with mitigation measures, may affect, but is not likely to adversely affect northern long-eared bats or their habitats in the project or cumulative effects area. On 6/7/2016 the US Fish and Wildlife Service concurred with the Forest Service’s wildlife biologist’s determination. National Historic Preservation Act The National Historic Preservation Act of 1966 as amended requires that areas held in Federal ownership must be surveyed for the presence of Cultural Resources prior to ground disturbance. The project area was surveyed for cultural resources. The cultural resources found and recorded will be avoided by design as documented in the Heritage Resource Survey and Project Recommendations by the CGNF Archaeologists (Design Criteria #27 and 28). There will be no adverse effects to cultural resources. The Forest Service will obtain project concurrence from the MT State Historic Preservation Officer prior to any ground disturbance. 2009 Ashland Travel Decision This decision is consistent with the 2009 Ashland Travel Decision, which established the current level of use on the forest road network on the Ashland District. The road system in the project area is located mainly on ridgetops, although roads exist near draw bottoms in Stacey and Whitetail Creek draws. Extensive road improvement including drainage feature construction, localized gravel surfacing, and culvert replacement was undertaken after the Ash Creek Fire. Currently the road system is in good functioning condition. Existing National Forest System roads used to access the North Whitetail


treatment units will be maintained before, during, and/or after the project. These activities include, where applicable, the following: surface blading/repair, shoulder maintenance, ditch cleaning, and roadway vegetation clearing or cutting. Others Laws or Requirements I find that my decision is consistent with all applicable Federal, State, and local laws or requirements for the protection of the environment. A Project File containing additional information supporting the environmental analysis and findings in this decision has been prepared and is available for review at the Ashland Ranger District or Billings Office.

Implementation Date, Administrative Review or Appeal Opportunities On January 17, 2014, the President signed into law the Consolidated Appropriations Act of 2014 (Pub. L. No. 113-76). Section 431 of that Act directs that the 1992 and 2012 legislation establishing the 36 CFR 215 (post-decisional appeals) and 36 CFR 218 (pre-decisional objections) processes “shall not apply to any project or activity implementing a land and resource management plan … that is categorically excluded ….under the National Environmental Policy Act [NEPA].” On February 7, 2014, the President signed into law the Agricultural Act of 2014 (Farm Bill) (Pub. L. No. 113-79). Section 8006 of the 2014 Farm Bill repealed the Appeals Reform Act (ARA) (Pub. L. No. 102-381). The ARA’s implementing regulation was 36 CFR 215. The 2014 Farm Bill also directs that the pre-decisional objection process established in the Consolidated Appropriation Act of 2012 shall not be applicable to categorically excluded projects or activities.

As a result of these two statutes, the Forest Service will no longer offer notice, comment and appeal opportunities pursuant to 36 CFR 215 for categorically excluded projects. These legislative changes and new direction do not limit the public’s ability to comment on Forest Service projects and activities. The Forest Service will continue to offer public involvement opportunities for categorically excluded projects as provided for in its NEPA procedures found in 36 CFR 220. The Forest Service will continue to provide notice, comment and pre-decisional objections as provided for in 36 CFR 218 for proposed projects and activities that are documented with an environmental assessment or environmental impact statement.

Contact Person Any questions related to this project or decision should be directed to Ron Hecker, District Ranger, Ashland Ranger District, 2378 Highway 212, Ashland, MT, 59003; 406-784-2433. Detailed records of the


APPENDIX A

Map 1 – Fly Wilbur/North Whitetail Restoration Project Map 4 – North Whitetail Post Fire Modified Proposed Action


Map 1. Fly Wilbur/North Whitetail Restoration Project Vicinity Map.


Map 4. Modified Proposed Action.

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