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Peak 7 logging: Project should focus on ‘red zone’

From a distance, Summit County's Tenmile Range offers a classic mountain vista. But up close, the forested slopes are riddled with patches of beetle-killed lodgepoles that present a fire threat in some areas. Local citizens, government agencies and the U.S. Forest Service are currently discussing a major project around Breckenridge to address wildfire hazards and forest health issues.

By BOB BERWYN

Frisco — Local officials  said they will listen to public comment on a proposed forest health logging project in the Breckenridge area, and said the U.S. Forest Service needs to cooperate more closely with the community and try to focus its logging efforts in the critical Red Zone, where homes are at risk from wildfires.

“We’re aware of, and sympathetic to the many citizen comments we’ve heard,” said Summit County commissioner Bob French, speaking in his role as chair of the county’s wildfire council during a Dec. 2 meeting in Frisco.

French was referring to scores of residents of the Peak 7 neighborhood near Breckenridge who have become involved in the effort to shape the proposal so that it balances community values with the need to manage larger swaths of the forest for health and restoration.

Specifically, the Peak 7 residents have raised concerns about the extent of proposed clear cutting close to their neighborhood. In comment letters to the Forest Service, they’ve cited research by the agency’s own researchers showing that, as far as reducing fire risks, the most effective treatments are donewithin a few hundred feet of homes.

Dillon-based Forest Service rangers also said they’ve heard the concerns loud and clear and will make every effort to work with residents to come up with a project that balances large-scale forest health issues with neighborhood concerns.

Read a Summit Daily News story with information about additional public meetings here.

The rangers will walk the area with Peak 7 residents several times in the next few days, including a site visit open to the public. The date hasn’t been set, but interested citizens can call the Dillon visitor center at (970) 468-5400 for details.

“We’re still in a scoping period. The project boundaries could be modified based on public input,” said Forest Service ranger Brett Crary, manager for project.

“After we come up with something more detailed, we’ll have another public meeting in January.”

As Forest Service officials explained the project to the wildfire council, they said, that even though the initial maps show large areas of treatment that look like clear cuts, the agency still has site-specific guidelines requiring avoidance of wetlands and encouraging regeneration of aspen, spruce and fir trees.

The final version of the plan would reflect those rules and incorporate public input, Crary said.”
The areas shown on maps don’t include buffers and wetlands,” he said, explaining that the scoping phase is “coarse” process that requires additional refinements.

See the current maps and documents for the project here.

Ross Wilmore, a Forest Service wildfire expert, detailed some of the agency’s views on buffer areas to protect homes — and firefighters in the event of a dangerous blaze.

“The project in its current form allows for flexibility for that buffer is to be constructed … If you have dense stands of lodgepole about to fall down, it needs to be wider … The wildland-urban-interface strips by themselves aren’t going to serve as a fire barrier. They allow for a drop in (heat) from fire, so that houses hopefully aren’t going to catch fire … They really give firefighters room to work,” Wilmore said.

“I don’t think the vision is to have a narrow strip along the forest boundary … We don’t want to do more than we need to do … the 200-foot bugger is for home defensibility, the extra 200 feet is for firefighter safety,” he added.

Commissioner French said the wildfire council would like to reserve the opportunity to make more detailed comments when there is a more detailed plan on the table.

State Sen. Dan Gibbs, who also serves as the community wildfire protection officer, presented a formal comment letter from the council.

In general, the council supports the Forest Service efforts but calls on the agency to prioritize work within the Red Zone, “in areas where need for fire protection is greatest.”

The letter also requests the Forest Service to adopt standard best management practices, including mitigation of impacts to wildlife and habitat, suspension of log hauling during rain storms to reduce sediment loading in streams and wetlands, and to retain and protect areas of spruce, fir and aspen.

“The council believes many community concerns will be addressed with site specific design criteria,” the letter concludes.

Read a sampling of the public comments here (some names have been deleted for privacy):

To Whom it may concern,
Please reference the attached article for the basis of my comments regarding the proposed clear cut on Peak 7.  While I understand that this is but one opinion, it is one that makes sense to me and one of the few that directly addresses our issue.
It seems to me that there are two fronts to this debate, namely risk and responsibility.  How much risk are the potentially affected homeowners willing to take and who’s responsibility is it to make that decision.  Additionally, what amount of responsibility are those homeowners required and willing to shoulder for the health and lively hood of our forest lands.  Lastly, are there alternatives and/or better uses for the funds allocated to this project.
As I understand it, the primary reason for clear cutting our forest is protect those of us that live next to our greatest resource from a potentially devastating fire.  The article suggests that with the exception of the “red phase,” the risk for fire is no greater with the pine beetle kill than without.  It also states that the greatest risk occurs 20 or so years after the infestation when all the fuel goes to ground.  Part of the forest service plan is to let the cut trees lay and rot.  Isn’t this just accelerating that which occurs naturally?  I understand that because there hasn’t been a major fire in our local forests for quite a while, the risk of one occurring is higher.  I find it interesting that our government’s answer is to destroy the forest before nature can destroy itself.  While it may be well intentioned so as to prevent massive loss and injury, isn’t the machine clear cutting of these lands a little bit like chopping off a leg to save the toe?  I for one; and I believe there are many more like me, would rather take my chances with Mother Nature than with the absolute devastation guaranteed by a cutting machine blade or chainsaw.
Next, and to varying degrees, most of us that live on or near the National Forest boundaries are aware of the inherent fire risk associated with such a choice.  Some of us; especially those that live here full time, have taken proactive measures to reduce the risk of fire damage should the worst occur.  It is a risk that most of us are willing to take to live near and among some of our country’s greatest and most beautiful resources.  As is said in the attached article, one reason for implementing the drastic measures you are considering is to mitigate the potential effect a major fire would have on those that have decided to inhabit these areas that are prone to them.  If we didn’t live here, would this still be an issue and wouldn’t Mother Nature be allowed to take her course?
For the record I; along with many of my neighbors, spend a great deal of time in the forest lands behind our homes on Peak Seven.  Is there beetle kill?  Some.  Will there be more?  Of course.  Is there deadfall?  Absolutely.  For the most part however, the forest is a beautiful, green, apparently healthy area that is home to myriad species of wildlife, provides wind protection for our neighborhood, and provides a wonderful playground for thousands of people a year to freely roam.  It seems incredibly ironic and foolish that our method of preventing the natural destruction of our forests is for man to destroy it first.
Lastly and probably least important, is the effect this direction of mitigation will have on the value of our homes.  For many of us, they are as much an investment as a place to live.  Proceeding with this plan will produce another type of devastation, that being financial.  Certainly the destruction of our homes to wildfire would be devastating but we have all purchased at great expense, insurance for that possibility.  Again, it should be left up to us to decide the level of risk we are willing to take.
Some have suggested that the current proposed solution is motivated by the almighty dollar and the county’s attempt to make a buck on a situation that isn’t as bad as they make it sound.  I hope this not to be the case but it unfortunately always seems to be a part of such dealings.  Complete transparency is required in this situation and if any motive other than public safety is found out, another type of clear cutting should be enacted by the residents of this community.
We are obviously on two extremes as to the best course of action to take to remedy this situation.  It is my opinion that we seriously listen to the folks that this issue affects the most, please work with us to create a solution that addresses our concerns while responsibly mitigating the potential danger.  Lastly, employ us to be part of the responsible solution. I am by no means an expert so I humbly suggest the following .
While the U.S. Forest Service is free to do as they see fit in our remote areas, they are mandated to provide information and workable solutions to those that they work for; namely the US taxpayer.  In this situation let us work in concert with them to implement a process that mitigates the risk to our homes at a level that is acceptable to those this threat affects the most.
As is indicated in the article, clearing and thinning near and around homes, especially those on a steep slope is an absolute.  Include the homeowners of the effected neighborhood in the process.  Provide them with education, funds and manpower to minimize the potential threat.  Use some of the allocated funds and consider a subsidy to promote the use of EPA wood burning appliances so as to utilize the fuel for heating instead of filling up our landfill with woodchips and  the county coffers with cash.
Develop a method of determining which stands of trees truly need to be clear cut.  If a fuel break is required, implement it in such a way as to not destroy that which is important to us.   Just because it’s easier is not a viable answer.  Implement a reasonable combination of thinning and clear cutting to:

minimize the fire risk
minimize the effect on our furry and feathered neighbors
minimize the effect on our investments
minimize the effect on the intangible value we place on the enjoyment of these lands.

Unfortunately, and as is with many issues, this is not a black and white one.  We all agree that something should be done to minimize the fire risk.  It should be accomplished in a way that those of us that are affected can live with.  These are our homes.  This is our forest.  It should be our right to make an informed, responsible decision as to their fate.  Thank you for consideration in this matter.

Dear Scott Fitzwilliams, White River Forest Supervisor;

I recently became aware of the proposed “Breckenridge Forest Health
and Fuels Project”.  As a property owner in the Winterwood subdivision
on Peak 7, I have a number of concerns and suggestions I would like
you to consider.  Our property at 104 Lodgepole Circle does border
National Forest land to the north and west.  Please consider the
following points:

* A wider communication effort need to be implemented.  I only
became aware of the plan through a letter in the Summit Daily
News.  As 70% of property owners in Summit County are 2nd
homeowners… many of the people directly affected by this
proposal are probably not even aware that this plan exists.
* The size of the mechanical clearcut area designated as “104” seems
overly large.  In my opinion, the focus of this exercise should be
on the protection of residential areas and not the harvesting of
biomass to generate revenue.
* I have serious concerns over the mechanical clearcut method
proposed for use in the “104” section.  In reviewing other areas
of the county where this method was used… I am appalled by the
devastation and mess that is left behind.  The slash and stumps
remaining makes the area dangerous and very difficult to hike
through.  Additionally, I feel that this activity would actually
increase the fire danger in the area.
o If limited clear cutting is necessary… I would suggest
performing it in the same manner that is used at the
Breckenridge Ski Area when they clear for a new trail.  They
remove not only the trees… but they also remove all stumps
and slash as well.          o By completely removing all
materials and stumps… the area
will truly be given a jump start on regeneration.
* Careful consideration needs to be given to other species of trees
and unaffected stands of Lodgepole in the designated clearcut
areas.  These areas should not be infringed on.
* New growth areas in the old clearcuts within “104” should not be
intruded on.
* I am greatly concerned with the proposed extensive mechanical
clearcutting on either side of CR3 between the Green Gate and High
Country Lodge.
* What will happen to the local wildlife (moose, bear, elk, deer,
lynx, pine marten, fox, pine squirrel, various species of forest
birds)?
o We have a ferret that visit’s our deck infrequently… how
will his habitat be effected?
* What measures will be taken to limit damage to CR3 (Barton Rd.)?
* I would like to know how the clearing will be done on the very
steep sections behind the Winterwood subdivision.  The hills
backing to the north side of the subdivision are up to a 35 degree
slope or steeper.
* Why is the timeframe for this project from 5 to 10 years?  That
seems like a long time.

One more note… related to my earlier comment on the percentage
second homeowners who are impacted.  Future meetings or open houses
should be conducted when these people are able to attend.  I would
suggest a Friday evening or weekend session.  I wanted to attend this
last Tuesday… but was unable to get off from work and make the drive
up from the Front Range in time.

Comment letter from Colorado Wild:
Scott Fitzwillliams
Peech Keller
Dillon Ranger District
P. O. Box 620
Silverthorne, CO 80498

via e-mail:  wrnf_scoping_comments@fs.fed.us

November 24, 2009

Dear Mr. Fitzwilliams and Ms. Keller,

The following are the comments of Colorado Wild on the Breckenridge Forest Health and Fuels Project, as described in the Project Description (PD)1 and cover letter dated November 4, 2009.

We believe that some treatment of vegetation in the project area is desirable to reduce the fire threat to adjacent private land containing residences. However, there are numerous problems with the proposed action, and considerable modification is needed. The Forest Service should propose a smaller and more focused project, one that is more likely to be fully implemented in a reasonable amount of time. Additional official public involvement must be allowed prior to approval of any project.

I. ALLOW PUBLIC COMMENT ON THE NEPA DOCUMENT.  As is discussed throughout these comments, the proposed action includes some controversial activities, that need clarification and at lest some modification. Also, some proposed units need to have boundaries adjusted and/or cutting methods changed. There is a high level of interest in the project, as demonstrated by the large turnout at the open house meeting on November 17.

Too much remains uncertain about this project. Many details need to be provided. Since many people would be affected by the project, we believe it is critical that the Forest Service allow additional official public involvement prior to the issuance of a decision notice or proposed decision.

The best way to do this would be to not authorize the project under the Healthy Forest Restoration Act (HFRA). HFRA provides for only a scoping comment period, followed by a formal objection process for those who submitted scoping comments. It is possible in any project, and very likely for this one, that additional issues concerning possible impacts will arise as a result of disclosure of impacts in the NEPA document. However, interested parties might not be able to object to the project on the basis of any issues they had not raised during scoping. We firmly believe that allowing additional public comment on the possible impacts of the proposed project will lead to an improved project.

Another option would be for the Forest Service to prepare a more refined proposed action, based on scoping comments and additional field work done by the agency. This new proposed action must then be distributed for at least a 30-day public comment period. It would likely be beneficial to also hold another public meeting concerning any updated new proposed action.

If the project is authorized under HFRA, the proposed travel management decisions must be addressed in a separate decision, as such decisions are not authorized under HFRA. See detailed discussion in section IX.

II. MAINTAIN ROADLESS CHARACTERISTICS.  Due to a recent Federal Court decision, the 2001 Roadless Rule is in effect. Under this Rule, logging is prohibited in inventoried roadless areas, with some exceptions. The only exception possibly applicable to the proposed project is the following:

To maintain or restore the characteristics of ecosystem composition and structure, such as to reduce the risk of uncharacteristic wildfire effects, within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic period…

36 CFR 294.13(b)(1)(ii).

All logging done under these exceptions must be “generally small diameter timber” and “maintain or improve one or more of the roadless area characteristics”. 36 CFR 294.13(b)(1) (2001). If the Forest Service intends to approve any logging in roadless areas, it must first demonstrate how such activity would comply with the 2001 Rule. Under current Forest Service internal direction, the Secretary of Agriculture would likely have to approve the project before it can be implemented.

Under the proposed action, eight units and part of another are in the Hoosier Ridge Roadless Area (Figure 4), totaling 234 acres (PD at 3). Almost half of this would be clearcut with leave trees (PD, id.). It is impossible to imagine that roadless area characteristics could be maintained with cutting of this nature. The remainder is “salvage”, under which “lodgepole pine [is] removed from mixed stands”. Id. Depending on the number of trees removed, roadless characteristics could be destroyed or degraded under this silvicultural prescription also.

Another issue is access to the roadless units. “Salvage” implies that trees would be removed, i. e., not disposed in place, as discussed above. This means that access for logging trucks or some form of mechanical equipment would be needed. However, figure 4 in the PD shows no haul routes proposed for the roadless units. Indeed, road construction is prohibited in this area, which is assigned to management prescription 1.31. See Forest Plan at 3-12.

Two roads that currently access the western part of the roadless area (which create areas “cherry-stemmed” out of the IRA) are almost two miles apart. The Pennsylvania Creek Road, which comes with an eighth of a mile or so of the northernmost roadless treatment unit, is about one mile north of the next closest road access. The southernmost treatment unit is about one mile from the nearest road. These roads would not provide sufficient access to treat all the proposed units with any mechanized equipment. Skid or winching distances would be too long for commercial operations. Even if all “treatments would be hand felled” as stated at PD p. 3, the walking distances would be too great for workers carrying hand tools to treat areas furthest from roads without additional access.

If private landowners are allowed to cut trees on adjacent national forest land, design criteria applicable to the remainder of the project must apply here, plus additional criteria as needed to ensure maximum retention of roadless area characteristics. Landowners must be educated about all requirements, and compliance should be regularly checked. Any subcontracting must be approved by the Forest Service, and the subcontractors need to be supervised by Forest Service personnel.

Slash produced by logging, especially in the clearcuts, would have to be treated. Otherwise, the fuel loading would be increased, contradicting the project purposes of creating defensible space and reducing the impact of any wildfire on community infrastructure and forest resources. See PD at 1. If trees are not removed, chipping or piling and burning everything that was logged in the units proposed in the roadless area would not be economically feasible or ecologically acceptable. See further discussion in section V below. We note here that removing material from the units by landowners would be difficult at best without the use of mechanical equipment.

III. RETAIN ALL NON-LODGEPOLE PINE TREES AND LIVE TREES OF ALL SPECIES TO THE MAXIMUM EXTENT POSSIBLE AND PLAN FOR FUTURE FORESTS.  To reduce large areas of mountain pine beetle kill in a future forest (i. e., 60 or more years from now), the Forest Service should design the project to retain existing occurrences of trees other than lodgepole pine to the maximum degree possible. Tree species diversity is the best way to minimize mortality that could be caused by any individual tree-killing agent.

Unfortunately, it does not appear that the current proposed action would accomplish this goal very well:

Cutting units that contain more of a mosaic of lodgepole pine with intermittent expanses of mixed conifer (spruce, fir and lodgepole) would have a clearcut with leave trees prescription. These units would appear as clearcuts with large groups (~1/2 acre – 2-acre) of spruce, fir and dead lodgepole pine left intact within their interior.

PD at 2-3.

There are numerous units with a “clearcut with leave trees” prescription. See Table of cutting units, an Appendix to the PD. Some these units are very large, up to 455 acres. Id. Groups of 0.5 to 2 acres of leave trees would not be very large at all in the context of large treatment units. It is likely that some mixed conifer stands and possibly some stands where a majority of trees are spruce and/or fir would be clearcut under this prescription.

During a four-hour hike through units 516, 104, and 103 on November 17, I and two local residents observed many lodgepole stands with no signs of MPB infestation. We also observed very few trees that were infested with MPB this year (i. e., ones that were green but had obvious signs of infestation). This may mean that the MPB population is declining, and there will be few of the remaining susceptible trees infested in the future. If so, then the many uninfested live lodgepole pine trees should not be logged. It is important to retain live trees in the project area, including lodgepole pine.

Clearcut size would be limited to 40 acres for cuts in trees not affected by insects. See FSM 1920.12e (1). Clearcuts can exceed this size only “after appropriate public notice and opportunity to comment and after review by the officer one level above the Responsible Official”. Id at (2).

Under the proposed action, regeneration of lodgepole pine would be encouraged. See PD at 2, under “Silvicultural Prescriptions”. However, spruce and fir would not regenerate much, if at all, in the open, unshaded environment created by clearcutting. Thus future stands arising in treated units could have less spruce and fir than current stands, and lodgepole pine would be even more prevalent, setting the stage for a future mass-die off if the area is again hit with mountain pine beetle.

To help encourage regeneration, whole-tree skidding (WTS) should generally be prohibited. This yarding method usually delivers a large percentage of the cones to the landings, leaving little seed to regenerate trees in the cut areas. WTS can be allowed if it is found through on-site experimental practice that cones break off trees as they are felled and skidded, or if they have already fallen off by the time of treatment. This is likely to occur only on trees that have been dead for at least a year or more. If WTS is allowed, units must be surveyed to ensure that there are enough cones well-distributed for adequate regeneration, in areas where regeneration is desired.2 If not, the contractor must be required to redistribute cones over the treated areas.

Advance regeneration of all tree species must be conserved to the maximum extent possible. Young conifers provide lynx winter foraging habitat. See further discussion in section VII below. Logging operations, i. e., felling and skidding, frequently destroy a sizable percentage of any seedlings and saplings present. Logging units and skid trails will have to be carefully designed and located to save this regeneration.

Any roads constructed for the project must be fully obliterated, i. e., removed from the landscape. This is necessary to avoid encouraging motorized recreation in undesirable places.

The Forest Service has an opportunity to increase the diversity of the future forest. To encourage such diversity, spruce, fir, and aspen should be retained. Aspen stands should expand after cutting with no additional effort required, other than perhaps some treatment of slash. Some mixed conifer stands (with or without aspen) should be retained, even if they contain some dead or dying lodgepole pine. Retention should be in larger groups, consistent with the project purpose of creating defensible space. The possibility of windthrow of residual stands must also be considered in designing cutting units and retention stands.

IV. THE PROPOSED “COMMUNITY PROTECTION ZONE” IS LARGER THAN NECESSARY.  Under the proposed action, a 400-600 foot community protection zone (CPZ) would be created. PD at 1. It is clear from Forest Service research that adequate protection for structures is achieved by treating the “home ignition zone”, which extends a maximum of about 40 meters (130 feet) from homes. Fires, no matter how hot, will not directly ignite even a wood structure beyond this distance. See Cohen, 1999 and 20003.

Firebrands, or burning embers, can travel a considerable distance to start new fires. However, if defensible space has been properly created around homes, there would be very little to burn and thus little threat to the structures involved. In other words, if residents fully implement Firewise principles, particularly if their structures do not have wood roofs, there would be very little chances of their structures igniting.4

Two proposed units go well outside even the proposed 600-foot maximum CPZ. Parts of units 103 and 104 are more than a half mile from private property. Part of unit 104 has already been logged. Logging here could affect use of the popular Peaks Trail. Both of these units should be greatly reduced in size.

Under the proposed action, almost 5700 acres would be treated. It is not clear that money will be available for doing the desired treatment on anywhere near all of this acreage. Trees will likely be worthless for sawtimber within five years of death. Thus it is questionable whether the mechanical felling units, where commercial removal is proposed (see PD at 3), could be implemented as proposed. Trees dead for a longer time could probably be used for some kinds of biomass, but the ability of such industry to operate economically, if at all, and to take material from the proposed project area, is far from certain.5 Also, the overall demand for wood is currently quite low, with a low number of housing starts. The onset and pace of recovery of the economy in general and of housing starts in general, is uncertain at this time.

Thus we recommend a smaller, more focused project which concentrates treatment in about the first 200 feet from the boundary of private and municipal properties. This would allow more areas to get treated, rather than treating a smaller number of areas for a larger distance from property boundaries. It would also focus treatment where it will accomplish the greatest protection of houses and people.

V. SLASH MUST BE TREATED USING ECOLOGICALLY ACCEPTABLE METHODS.  A big issue that must be addressed in the proposed project is how to dispose of slash, especially for the hand felling units. The goal would be to fell trees so that “the boles of the tree lie directly on the surface of the ground to accelerate decomposition”. SD at 3. However, this is not likely to be possible in many units, especially the ones treated with hand felling and either clearcut or clearcut with leave trees. The number of boles produced in such units would make it impossible for anywhere near all of them to completely touch the ground. We suspect that the same would be true in at least some of the units proposed for hand felling and salvage. Notably, the hand fell units with clearcut or clearcut with leave trees comprise a sizable portion of the project area. See Unit Table.

Even if the boles all could be made to touch the ground, there would still be the issue of other slash, i. e., limbs, tops, and any cull logs. Leaving this material on top of or adjacent to the boles would create a potentially dangerous fuel situation, as small-diameter, easily ignitable material would be close to larger, longer burning logs.

If boles could all be placed in complete contact with the ground, so much ground would be covered that revegetation of any kind, let alone tree regeneration, would be severely inhibited, if not thwarted altogether, for many years.

In any case, decomposition of wood will be very slow in at least some of the Barton Road portion of the project. During our November 17 hike, I observed small diameter wood pieces  from treatments over 20 years ago that completely touched the ground yet showed only minor decomposition.

Finally, trees infested with breeding bark beetles at the time of logging must not be left on the ground.6 This is especially important for Englemann spruce, as spruce bark beetles are known to prefer freshly downed trees (either from blowdown or logging). Though mountain pine beetles are not known to attack freshly downed lodgepole pine trees, any beetles in trees that are then felled as part of project operations would be able to complete their breeding cycles and infest new trees.

Therefore, it is important that any logged trees with beetles in them be:  1) treated on site; i. e., be burned, chipped, or have the bark striped off the entire bole;  or 2) removed and treated offsite either before beetle flight or in a place where any beetles that do escape are not likely to find other pine trees to attack. There must be contract provisions to ensure this, and they must be very strictly enforced. Any burning of a large number of tree boles, would not be possible in residential neighborhoods, due to smoke and the possibility of a fire escaping and damaging homes or infrastructure. Fires in large diameter material also damage soils. Chipping would have to be very limited unless the chips could be hauled offsite. See further discussion in this section below.

Unless there is assurance that any tree boles that will not be hauled offsite can be treated onsite in a ecologically acceptable manner (see further discussion below), prior to beetle flight for those containing breeding beetles, the hand fell and leave units should not be approved.

The PD (p. 2) also mentions other methods that might be used to treat or remove slash, and another one is mentioned in the design criteria (id. at 5). Each is addressed below.

–Cable or helicopter yarding. We doubt this is realistic, given the very high cost of such yarding systems and the likely low value of the product being cut, even if it is free of defect.. Also, the residents of greater Breckenridge would likely not want to hear the persistent noise of helicopters. Whole-tree yarding could probably not be done, meaning there would still be slash from tops, limbs, and cull to be disposed.

–Winching out logs.  This could be done for a short distance in some areas where the terrain allowed, i. e., on slopes with a fairly consistent grade which are largely free of large rocks or other impediments to winching. But the winching distance is limited even with good terrain, and some slash movement or treatment might first be needed to ensure that logs being winched did not get stuck in other debris.

–Firewood gathering.  Where road access is sufficient, allowing public removal of firewood is a possible method of disposing of material. However, this would be limited to areas within, at most, a few hundred feet of open roads. Such firewood gathering would have to be supervised by the Forest Service to ensure that vehicles were not illegally driven off roads, to the detriment of soils and other resources. Firewood gatherers would not take the small diameter material, leaving this to be treated by some other method.

–Piling and burning.  This a common practice, but it is not an ecologically favorable one. Burning of large piles of any material and of smaller ones composed of larger-diameter (say greater than about 3”) slash can burn long and hot, sterilizing the soil beneath them. See DeBano et al, 1998. If any pile burning is done, soils may have to be tilled to break up hydrophobicity.

–Lopping and scattering.  This is another common practice, but its use would have to be limited in the project area for the goal of reducing fuels to be met. Placing lopped and scattered slash over a sizable area creates a continuous fuel bed. Any ignition in it could cause a ground fire to spread rapidly, and possibly ignite residual trees, other vegetation, and even buildings on adjacent private land. If this practice is used, it must be kept out of the home ignition zone, and no slash should be placed near any trees designated for retention. Areas with lopped and scattered slash must be discontinuous.

–Chipping.  Chipping is expensive, and thus could not be used to treat more than a minor amount of the slash likely to be produced under full implementation of the proposed action. Also, most of the chips would have to be removed from the site7, as they could not be allowed to cover a large portion of any cutting unit. Such coverage of chips would inhibit, if not prohibit, revegetation and regeneration for a long time period. Soil nitrogen might be depleted by the long, slow decomposition of the chips. The decomposition might also send an acid pulse into the soil, making it difficult for most plants to sprout and grow. If chipping is used, depth and coverage must be limited in each unit where it is used.

In short, any one method described in the PD for disposing of slash would not, under the best of circumstances, be appropriate to treat all the slash that would be produced. Before approving the project, especially one with so many acres in hand fell units, the Forest Service must show how the remains will be disposed of in an ecologically acceptable and economically feasible manner.

VI. PROTECT RIPARIAN AREAS.  During our hike on November 17, we notice numerous small wet areas in the Barton Road-Peak 7 area treatment units. These areas must be delineated and flagged for avoidance by contractors. The management measures in the Forest Service’s Watershed Conservation Practices Handbook (FSH 2509.25) must be strictly applied. See especially section 12.1 of the WCPH. There are also many areas with steep slope that should be avoided.

The Indiana Creek area, which feeds Goose Pasture Tarn, is part of the Town of Breckenridge’s water source and does not appear to be near any residences. Deletion of these units, or at least a  considerable reduction of the amount and intensity of logging, must be considered. Mechanized clearcutting, proposed for unit 116, may especially be inappropriate for this area. See Figure 4. In any case, all logging must be done carefully.

Proposed haul route 3.1A in unit 104 is currently a trail that runs along a creek(see Figure 2). It would be very inappropriate to construct a road here and use it as a haul route, as it is too close to the creek. Constructing a new road on the slope to the north would also be inappropriate, as the slope is fairly steep in places.

VII. PROTECT WILDLIFE AND PLANT HABITAT.  The logging of 5700 acres of land could affect numerous species of wildlife and plants. At a minimum, the Forest Service must address possible impacts to the ones described below.

Lynx.  It is important to retain any advanced regeneration. Small conifers that stick out of the snow provide winter food for snowshoe hare, the lynx’ chief prey species. Mixed conifer stands (with or without aspen) that have various age classes also should be retained, even if they have some dead lodgepole within them. The lodgepole may form denning habitat after they fall to the ground. Such habitat would be mixed in with winter foraging habitat provided by the young conifer, thus the habitat would be high quality.

Generally, some standing and down dead trees should be retained in areas not adjacent to private land in order to provide future denning habitat. See Guideline Veg G11 in Southern Rockies Lynx Management Direction (SRLMD).

Even though standing dead lodgepole pine is considered to be unsuitable habitat for this lynx, it may still provide some travel cover or “other” habitat. Thus some standing dead or dying lodgepole pine near mixed conifer stands should be retained in areas not immediately adjacent to private property.

Mature spruce trees should be retained, as they provides habitat for lynx’ main secondary prey species, red squirrel. See Guideline Veg G5 in the SRLMD.

Maintaining lynx denning habitat would also help provide habitat for marten. Accumulations of down logs is a critically important habitat component for the latter species, as it allows winter foraging, and in some cases also provides nesting habitat.

American three-toed woodpecker.  This species is known to eat bark beetles. It nests in holes in snags. All “soft” snags, i. e., those with signs of internal rot, should be retained where they do not pose a hazard.

Boreal toad.  This species needs shallow, non-flowing water for breeding and other life activities. A sizable population exists in Cucumber Gulch, part of which is in the project area. Since this species can travel several miles over land to find new habitat, proposed treatment units, especially on the west side of Highway 9, should be thoroughly surveyed prior to commencement of any ground disturbing activities. Wet areas should be located, marked with 100 foot or other appropriate buffers, and avoided during all operations.

Moose are frequently cited in the Peak 7-Barton Road units. The extensive clearcutting planned for these units could remove too much cover for these animals. Cover must be retained for these animals, and for deer and elk, especially in stands containing a considerable percentage of live trees, as discussed above in section III.

Rare plants.  Prior to any ground disturbance, all areas where operations could occur must be surveyed for threatened, endangered, proposed (for such listings), and Forest Service sensitive  plants. Any populations found must be avoided. The avoided areas should include some area around each population so that the rare plants have a chance to reproduce and increase their coverage.

VIII. FOLLOW FOREST PLAN REQUIREMENTS.  Numerous Forest-wide standards and guidelines from the White River Forest Plan may apply to the proposed project. We identify a few of note below:

FORESTWIDE STANDARDS AND GUIDELINES
Scenery. Guideline 1 under Scenery Management states:

Management activities should be designed and implemented to achieve, at minimum, the level of scenic integrity shown on the scenic integrity objective map.

Forest Plan at 2-34. The project should be designed to have the minimum impact on scenery, consistent with reducing fuels. The less acreage cut, especially via clearcutting, the lower the impact on scenery. Blending treatment unit shapes with the terrain and having irregular edges will help reduce impacts to scenery.

Coarse woody debris. The Forest Plan has standards for coarse woody debris (p. 2-5) and snags and down logs (p. 2-9). See also guideline 5 under silviculture (id. at p. 2-15). Other than in the home ignition zone, where fuel levels need to be low to reduce the risk of fire, these standards should be met. Retaining woody debris in clearcuts will be especially important to reduce soil erosion, help trap snow, retain moisture, and reduce soil erosion. Snags in all treated areas are important for wildlife. Design criteria should require retention of all  “soft” snags, i. e., those than show signs of rot, except where they could fall onto private property or across any open road. Snags are also future coarse woody debris.

Wildlife.  The Forest Plan, pp. 2-17 through 2-25, has numerous standards and guidelines for wildlife, some of which will be applicable to the Breckenridge Project. It will be important to survey prospective treatment areas for wildlife, and to avoid activities when wildlife are likely to be nesting or congregating. See also section VII above.

Heritage resources.  All areas need to be surveyed for heritage resources prior to any ground disturbing activities. Any resources found must be protected, per 36 CFR 800 et seq. and Forest Plan standards and guidelines (Plan p. 2-33). Pursuant to 36 CFR 800.3(a), the Forest Service should assume that this project “has the potential to cause effects on historic properties”.

During our hike on November 17, we saw some historical artifacts, mainly from the mining era of the late 19th century. Areas containing these artifacts must be avoided, even if they are not eligible for the National Register of Historic Places. Buffers should be delineated around such areas to prevent artifacts from becoming exposed after removal of surrounding trees.

Recreation.  Many treatment units are in or close to areas that are popular for various forms of recreation year-round. Notably, large proposed unit 104 crosses the Peaks Trail. Any logging here must be designed to protect the trail and be done in a manner that causes the least disruption to public use of this trail. Effects on other trails must also be carefully considered before final decisions on where and how to cut are made. Logs must not be felled across trails.

MANAGEMENT AREA PRESCRIPTIONS
The project area is in several Forest Plan management areas (MAs). Any approved project must follow the applicable desired conditions, standards, and guidelines. Below we identify some requirements.

In MA 1.31, road construction is prohibited, and scenic integrity objectives (SIOs) range from moderate to very high. Plan at 3-12. It is at best questionable whether the SIO of moderate would be met after the proposed clearcutting was implemented. There is absolutely no question that an SIO of very high would not be met with this activity.

In MA 3.31, recreational opportunities are semi-primitive, and any alterations via vegetation management must be “small and not generally evident to visitors”. Plan at 3-33.

In MA 4.3, “[r]esource management activities are compatible with, and reduce impacts to, recreation resources and opportunities”. Plan at 3-44. Large clearcuts in this MA would not be consistent with this requirement. Rather, cuts should be limited to protecting trails, dispersed camping sites, and any roads that access trailheads and camping areas.

MAs 5.41, deer and elk winter range, and 5.43, elk habitat, are designed to protect big game wildlife during the season(s) when they are vulnerable to human disturbance. It is important to prohibit vegetation management activities during these periods, and also to ensure that the resulting vegetation conditions retain habitat for these species, to the maximum extent possible.

MA 8.32, utility corridors, has the following standard and guideline:

Standard   Vegetation management plans…are designed to minimize and rehabilitate visual impacts.

Guideline   The boundaries of the cut areas bordering utility corridors are blended into the surrounding vegetation in locations visible from key viewpoints.

Plan at 3-89. A proposed design criterion (PD at 5, next to last bullet point near the top) addresses this issue for all units, and should be retained.

IX. THE PROPOSED ADDITION OF SYSTEM ROADS MUST BE CONSISTENT WITH NATIONAL FOREST TRAVEL MANAGEMENT AND WITH SUMMIT COUNTY PLANS.  Under the proposed action, portions of five roads would be added to the transportation system. PD at 3. There would also be significant upgrades to three roads. Id. at 4. This could have impacts on travel management in the project area, in that travel by passenger cars, or even high-clearance vehicles, which is now difficult, would be much easier after any reconstruction or repair, leading to an increase in vehicle use of the roads in question and an increase in human use of trails in the area.

Any such decision to change travel management must be done only after a consideration of the impacts of such action. Any changes must also be consistent with travel management for the White River National Forest and also with decisions made by Summit County on roads and trails in the Golden Horseshoe area, where at least five of the six segments to be added to the system and two of the roads to be upgraded are found.

Any decision to add these road segments to the system, or not, is better addressed as part of travel management for the White River National Forest or in a separate decision, rather than being mixed in with a vegetation management project. At a minimum, the travel management decisions cannot not be done under the Healthy Forest Restoration Act (HFRA). Thus any decisions on travel management would have to be done with a full public comment period on the NEPA document and allowance of post-decisional appeals, per 36 CFR 215.

X. FIGHT NOXIOUS WEEDS.  Any kind of ground disturbance creates excellent conditions for the introduction and spread of noxious weeds. Before any ground-disturbing activity occurs in any given area, there must first be a thorough search for weeds. Any weeds must be eradicated. There must also be follow-up surveys and eradication for at least two full growing seasons after work in any area has concluded.

Numerous Forest Plan standards and guidelines apply. See Plan at 2-30.

CONCLUSION.  The proposed project is much too big. It proposes more logging than is needed to protect private property and community infrastructure. It is likely too large to be fully implemented, especially given the current low demand for wood. The project must be redesigned to focus on areas in the home ignition zone, and to conserve as many non-lodgepole pine and live lodgepole pine trees as possible.

Before any logging is approved, the Forest Service must show how slash will be retained, treated in place, or removed, or a combination, in an ecologically acceptable and economically feasible manner. Before any logging is approved in the roadless area, the Forest Service must show that such activity is allowed under the 2001 Rule. Impacts to the roadless area must be minimized.

Wildlife habitat, especially for lynx, American three-toed woodpecker, boreal toad, moose, deer, and elk, and all populations of rare plants, must be retained. Historical artifacts must be conserved. Impacts to scenery must be minimized, consistent with reducing fuels.

Any travel management decisions must be separate from the decision to approve vegetation management. It cannot be done under HFRA. The vegetation management portion of the  project should also not be done under this Act so that issues and concerns can be clarified and the public can comment on a more fully designed project and on possible impacts from implementing it that are disclosed in the draft NEPA document.

Sincerely,

Rocky Smith
Colorado Wild
1030 Pearl #9
Denver, CO 80203
303 839-5900
rocky@coloradowild.org

REFERENCES

Cohen, Jack D., 1999.  Reducing the Wildland Fire Threat to Homes:  Where and How Much?  USDA Forest Service, General Technical Report PSW-GTR-173.

Cohen, Jack D., 2000.  What is the Wildland Fire Threat to Homes?  Paper presented at Northern Arizona University, Flagstaff, AZ, on April 10, 2000.

DeBano, Leonard F., Daniel G. Neary, and Peter Ffolliot, 1998. Fire’s Effects on Ecosystems.  John Wiley and Sons, Inc.

Town of Breckenridge draft comment letter and staff report:
Memorandum 

To:    Town Council 
From:  Open Space Staff 
Re:  Breckenridge Forest Health and Fuels Project 
Date:  November 24, 2009 


On November 4, 2009, the Dillon Ranger District announced its proposed forest health and fuel reduction project in the vicinity of Breckenridge.  As stated by the U.S. Forest Service (please refer to Forest Service correspondence in your packet), the project will  “focus on treating forests within the wildland/urban interface that have been severely affected by the mountain pine beetle epidemic.”  The deadline for public comments on this proposed project is December 3, 2009. 

Town staff has been working with the White River National Forest interdisciplinary team on defining this project. We believe that the stated purposes of the project are on target for the protection of human and forest resources in our area.  These purposes are as follows: 

Provide defensible space adjacent to communities, Reduce impacts of a potential wildfire to National Forest and community infrastructure, Reduce impacts of a potential wildfire on the forest resource, Increase lodgepole pine and aspen regeneration, andUtilize some materials removed to generate salvage revenues and supply forest products or biomass to local industries. 

Town staff has been in the field with Forest Service staff to evaluate the focus areas and to discuss the specific prescriptions for each area.  We are working to dovetail our open space forest health efforts where appropriate with what the Forest Service will be doing to maximize our resources and prevent duplicative processes. 

The draft letter in your packet was written to express support for the stated purpose and need for this project, with specific recommendations to address environmental issues that are important in the areas and ecosystems within which the proposed actions would  occur.  We have included a vicinity map, but please go to http://www.fs.fed.us/r2/whiteriver/projects/breckenridge-forest-health-fuels/index.shtml and refer to Figures 1-4 to see the specific treatment areas and their numbers that are mentioned in our letter. 

Please keep in mind that this response falls within the public scoping phase of a truncated NEPA process, as this type of project falls under the stipulations of the Healthy Forests Act.  As it now stands, the Town will not have another opportunity to comment on this project.  We do ask in our letter to have the chance to review the draft Environmental Analysis once it completed, but we do not know if we will be granted this opportunity.
In the event that we are not able to have another level of review, this letter is meant to bring up the broad questions and issues related to the Project that the Town would like to see addressed in the final plan.   

November 18, 2009 

Scott Fitzwilliams 
White River Forest Supervisor 
c/o Peech Keller 
P.O. Box 620 
Silverthorne, CO  80498  

To Whom It May Concern, 

The Town of Breckenridge (“Town”) would like to commend the White River National Forest for taking the initiative to address forest health and fire mitigation within the wildland/urban interface in the Upper Blue River Valley through the Breckenridge Forest Health and Fuels Project (the “Project”).  

The Town agrees with the need to address heavy fuels accumulations that could support large-scale wildfire caused to a large degree by the mountain pine beetle epidemic.   

We also agree with the stated purpose of the proposed action, to the degree that it addresses community health and safety, the risk to community infrastructure, and increasing stand diversity and regeneration.  

At the same time, we do feel like it is very important to look at the specific 
environmental impacts of each treatment, particularly as they relate  to potential habitat fragmentation, wildlife displacement, erosion, and impacts to sensitive ecological systems.   

The Town believes that the road improvements recommended to facilitate the Project will be beneficial for many reasons beyond their basic function as haul roads, including the reduction of environmental impacts from old roads in disrepair, increased serviceability, better access for emergency fire response, and an improved recreational experience.  

We would like to make certain, however, that all improvements are consistent with the recommendations that came out of the Golden Horseshoe citizens planning efforts and the White River National Forest Travel Management Plan to be released in the near future.  This means that any temporary haul roads that will not be left as a system route need to successfully be decommissioned in order that they don’t become unmanaged motorized routes in the future.  We also believe that erosion control and mitigation should be directly or indirectly built into any roads plan. 

Our comments on specific project areas and their prescriptions are as follows:

101.  This is the Claimjumper Parcel, slated to be divested to the Town as a part of the Peru Creek Land Exchange.  The soils in this area were disturbed by mining activities resulting in residual heavy metals with potential impacts to human health.  The soils with the highest toxic levels and the greatest chance for human contact were removed and taken to a repository site in French Creek to be capped and contained. However, less- accessible piles of heavy metals were left onsite.  We believe that the potential soil impacts and increased erosion from mechanical clearcutting could be problematic on this site and that a hand/limited mechanical prescription should be substituted.  We would like to see that  contaminated soils be delineated and represented on maps to ensure that harvest units, haul routes and other ancillary activities do not directly or indirectly impact these areas.  We are concerned with increased snow deposition,  sheet flow or water delivery to these contaminated soil areas and subsequent surface or subsurface mobilization of toxins.  We would appreciate full disclosure of these potential impacts addressed in the EA or available in the Administrative Record for our review. 

102, 103, 104.  The drainages in this area have extensive wetlands, riparian areas, and  important habitat for species of management interest, such as the lynx, boreal toad, elk and moose.  A blanket mechanical clearcut prescription for this entire 654 acre area may have significant direct or indirect impacts to these species.  We would like to see and review more specific prescriptions and cutting unit boundary delineations to address both community and ecosystem needs.  Given the potential indirect impacts to downstream wildlife and wetland resources, we would like to see that individual harvest units incorporate riparian buffers, and implementation of best management practices to reduce the risk of fine sediment delivery to permanent as well as intermittent water resources.  While forest management activities are exempt from regulation under section 404 of the Clean Water Act, we are concerned about direct and/or indirect impacts to wetland and riparian habitat on-site and off-site and we believe that the USFS should present mapping of wetland resources, incorporate buffers and present their methodology in protecting 
downstream waters and riparian habitats from fine sediment delivery and all-too-common 
incidental spills from heavy equipment.  We are especially concerned with runoff from landings and skid trails where fine sediment mobilization is common, and petroleum based contaminants are regularly spilled.  We would also like to see residual trees left to help leave some habitat components for wildlife species, and we would like to see protection of spruce and fir seedlings/saplings from equipment trampling and cutting.   

We support an allowance for the creation of firebreaks behind Peak 7 homes in this area, but believe that the higher quality habitat areas with mixed conifer stand components should either be left alone entirely or given a less impactful silvicultural prescription.  Although clearcuts may improve habitat for certain wildlife species, they can create detrimental habitat fragmentation for interior forest carnivores and may reduce snowshoe hare utilization in the near-term.  We would like for this issue to be carefully studied for this area as a part of the environmental analysis. We also believe that the spruce/fir component and healthy lodgepole stands within this area should remain.  In any event, we would like for the Forest Service to ensure that soil scarification is limited within 100 feet of drainages, and the fine sediment transport is limited.   While silvicultural activities are exempt from section 404 of the Clean Water Act, we request that no clearing in any riparian areas or wetlands should occur, even over snow. We are concerned with skid roads, roads and landings being placed in proximity to, or crossing, wetlands and/or riparian areas. Best management practices for silvicultural treatments near wetlands and riparian areas should be employed by contractors, with strict oversight by Forest Service staff. Further, Town staff would appreciate the ability to review and comment on individual units which may directly or indirectly impact downstream water resources which may then fall under the regulatory authority of the Town.   


Lastly, based on some of the public comments from the November 17 open house, it appears that the development of more specific stand maps would provide a greater level of comfort for area homeowners. We recommend that the U.S. Forest Service staff develop more specific stand maps and cutting unit boundaries to assist with the public education and planning for this area.

105, 120.  This is what the Town and Summit County open space programs refer to as the 
“Western Bench.”  There are existing and planned summer and winter recreational trails within this area that are very important to the community.  We have attached for your review a map of the trails to be included as part of the Gold Run Nordic trail system expansion.  We request that the Forest Service consider a mechanical clearcut with leave trees prescription in this area, as opposed to strictly clearcutting.  We also request that the road and cutting activities carried out in this area are done in conjunction with and will not negatively affect the future recreational plans for this area.   

108.  We would recommend that this area be included with the adjacent 303 mechanical salvage prescription. 

109-111. Lincoln Park.  This area contains very high natural resource values and sensitive soils.  We would highly recommend that the Forest Service leave most of this area in its current state, with the exception of the portion of area 111 on top of the ridge to the north and east of the existing road that connects Spruce Road (as it was known in the Golden Horseshoe process) with Brown Gulch. 

112.  This area is used for winter backcountry recreational skiing, so the Town would like to request that it be assigned a hand/limited mechanical prescription that leaves some remaining tree stands and cover. 

114.  We recommend that this area be included within the prescription for the adjacent area 613. 

115.  We recommend that this area be included within the prescription for the adjacent area 615. 

116.  This area is extremely important to the Town as the main water source for the Goose Pasture Tarn.  We appreciate the attention given to this area by the U.S. Forest Service, and request that the Forest Service staff study this entire drainage and appropriate silvicultural prescriptions very carefully in its decision-making process.  We are concerned that summertime clearcutting may cause connected disturbances leading to wetlands and riparian areas, thus delivering fine sediments to the Towns water supply.    Given the importance of this area to the Towns water supply, it will be especially important in this area to leave sufficient buffers from all water sources and wetlands, employ best management practices around wetlands, and increase the protection of all aquatic resources.  All wetlands should be delineated and storm water control systems should be utilized.  Appropriate leave trees should be identified and left to the degree practicable.  All efforts should be taken to prevent oil spills or leakage from machinery, and the Town would request the ability to review landings and equipments storage 
areas for spillage.  Given that roads are often the greatest generators of erosion and fine sediment mobilization, road impacts need to be minimized to the maximum degree possible.  We would therefore request that haul routes not be located within 100 feet of wetlands or riparian areas. 

118.  We would recommend that the Forest Service consider including this area within area 515 with the associated prescription. 

119.  We would recommend that the Forest Service consider including this area within area 514 with the associated prescription. 

Some other more general comments include the following: 

While clearcuts may be the best way to stimulate lodgepole pine generation, we feel that in many areas the protection of water resources, minimization of fine sediment 
mobilization and erosion, and retention of coniferous habitat components can be better 
achieved through salvage harvesting with more retention of spruce and fir trees where 
they occur.    We would like to see riparian and wetland areas delineated and then buffers employed to protect onsite habitat values, as well as downstream water quality and habitat values, which are directly under the regulatory authority of the Town and County.  A combination of salvage cutting. leave tree cutting units, and the incorporation of riparian and wetlands buffers will still allow the Forest Service to meet the purpose and needs of this project.    We would like to see these treatment areas prioritized, with each of them finished within one field season, as budgets allow.    We would like to see that the Forest Service  coordinate the prioritization of these treatments with our local Community Wildfire Protection Plan and other local  fire mitigation and forest health plans and projects.    We feel like it is important that treated stands should be evaluated in 15 to 20 years and potentially thinned to further address the purpose and need of the stated Project. 

Lastly, the Town requests that we be able to review and officially comment on the draft 
Environmental Assessment for this Project.   

In closing, the Town sincerely appreciates and supports the efforts of the U.S. Forest Service to mitigate the challenging impacts resulting from the mountain pine beetle epidemic, while still producing long-term stand diversity in the area for the benefit of wildlife, protecting our water resources, and maintaining our recreational experiences and the intrinsic beauty of the Upper Blue River Valley.  We appreciate your consideration of our comments and recommendations.

Sincerely, 


John Warner 
Mayor

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