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Inventoried Roadless Area Specialist Report Southwest Jemez Mountains Restoration FEIS Prepared by Jennifer Cramer Final version July 2, 2014 EDITOR’S NOTE: This report was submitted as a draft for the NEPA writer’s use in incorporating relevant information into Chapter 3 of the Draft EIS-Affected Environment and Environmental Consequences. Subsequent reviews, corrections, and additional information, some of which are a result of the response to comments on the Draft EIS, to the Chapter 3 were completed in the Final EIS, rather than in this report Summary There are three Inventoried Roadless Areas (IRA) within the Southwest Jemez Mountains Project Area. IRAs can be characterized by nine values or features which are explored here. The 2001 Roadless Rule places restrictions for timber harvest and road construction or reconstruction within IRAs. The effects of the proposed treatments for the project (alternatives 1, 3, 4, and 5) were compared with the effects of a large wildfire (the no action, which is alternative 2). Overall, the proposed treatments, including timber cutting, will improve or have no effect the IRAs for all of the nine values or features that often characterize IRAs. These improved conditions are particularly apparent when compared with the effects that would be expected from an uncharacteristically severe wildfire, which the entire project area, including the IRAs, are currently at risk for. Inventoried Roadless Areas and the 2001 Roadless Rule Inventoried Roadless Areas (IRAs) are significant parts of the landscape, especially in increasingly developed areas. IRAs provide relatively undisturbed habitats for wildlife, including threatened and endangered species and that are void of non-native species large landscapes important for biological diversity. They also have ecosystem functions to provide for clean water, soil, and air; opportunities for dispersed outdoor recreation; and locations for study and research. To achieve these functions, the 2001 Roadless Area Final Rule (36 CFR Part 294) “prohibits road construction, reconstruction, and timber harvest in inventoried roadless areas because they have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

Inventoried Roadless Area Reporta123.g.akamai.net/7/123/11558/abc123/forestservic...natural ROS, 0.08 acres of semi-primitive motorized ROS, and 3,008 acres of semi-primitive non-motorized

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Page 1: Inventoried Roadless Area Reporta123.g.akamai.net/7/123/11558/abc123/forestservic...natural ROS, 0.08 acres of semi-primitive motorized ROS, and 3,008 acres of semi-primitive non-motorized

Inventoried Roadless Area Specialist Report Southwest Jemez Mountains Restoration FEIS

Prepared by Jennifer Cramer Final version July 2, 2014

EDITOR’S NOTE: This report was submitted as a draft for the NEPA writer’s use in incorporating relevant information into Chapter 3 of the Draft EIS-Affected Environment and Environmental Consequences. Subsequent reviews, corrections, and additional information, some of which are a result of the response to comments on the Draft EIS, to the Chapter 3 were completed in the Final EIS, rather than in this report Summary There are three Inventoried Roadless Areas (IRA) within the Southwest Jemez Mountains Project Area. IRAs can be characterized by nine values or features which are explored here. The 2001 Roadless Rule places restrictions for timber harvest and road construction or reconstruction within IRAs. The effects of the proposed treatments for the project (alternatives 1, 3, 4, and 5) were compared with the effects of a large wildfire (the no action, which is alternative 2). Overall, the proposed treatments, including timber cutting, will improve or have no effect the IRAs for all of the nine values or features that often characterize IRAs. These improved conditions are particularly apparent when compared with the effects that would be expected from an uncharacteristically severe wildfire, which the entire project area, including the IRAs, are currently at risk for.

Inventoried Roadless Areas and the 2001 Roadless Rule Inventoried Roadless Areas (IRAs) are significant parts of the landscape, especially in increasingly developed areas. IRAs provide relatively undisturbed habitats for wildlife, including threatened and endangered species and that are void of non-native species large landscapes important for biological diversity. They also have ecosystem functions to provide for clean water, soil, and air; opportunities for dispersed outdoor recreation; and locations for study and research.

To achieve these functions, the 2001 Roadless Area Final Rule (36 CFR Part 294) “prohibits road construction, reconstruction, and timber harvest in inventoried roadless areas because they have the greatest likelihood of altering and fragmenting landscapes, resulting in immediate, long-term loss of roadless area values and characteristics.”

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In addition, the 2001 Roadless Rule lists nine values or features that often characterize IRAs: 1. High quality or undisturbed soil, water, and air. 2. Sources of public drinking water. 3. Diversity of plant and animal communities. 4. Habitat for threatened, endangered, proposed, candidate, and sensitive species

and those species dependent on large, undisturbed areas of land. 5. Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes

of dispersed recreation. 6. Reference landscapes. 7. Natural appearing landscapes with high scenic quality. 8. Traditional cultural properties and sacred sites. 9. Other locally identified unique characteristics (i.e., social, cultural, or historical

characteristics). Affected Environment Within the Southwest Jemez Mountains Project Area there are 3 IRAs (Figure 1). The first two are adjacent to each other - the 1,704 acre West Mesa IRA to the North and the 3,658 acre Holiday Mesa IRA to the South. The northern West Mesa IRA weaves in and out of Virgin Canyon and the West Mesa of Virgin Mesa. The southern Holiday Mesa IRA goes onto the southern portion of Virgin Mesa and extends east into Virgin Canyon and Guadalupe and Holiday Mesa. These two IRAs are within Management Areas C, N, and R. These two IRAs will be analyzed together since they are adjacent to each other.

The second IRA is the Peralta Ridge IRA. Only 93 acres of this 4,025 acre IRA are within the eastern edge of the project area at Peralta Ridge. This portion of this IRA within the project area is in Management Area P.

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Timber Within the IRAs there are many timber types; Ponderosa Pine, Dry and Wet Mixed Conifer, Piñon/Juniper, Rocky Mountain Juniper, and Gambel Oak (Table 1). These vegetation types are not unique to the IRAs within the project area.

Table 1: Timber vegetation types and acreages for the three IRAs within the Southwest Jemez Mountains Project Area. Only timber types are depicted; grasslands, croplands/pasture, and rockland are not specified below. IRA Name Timber Vegetation Acres West Mesa Dry Mixed Conifer 189

Moist Mixed Conifer 96 Piñon/Juniper 343 Ponderosa Pine 1053 Holiday Mesa Dry Mixed Conifer 5

Piñon/Juniper & Rocky Mountain Juniper

3002

Ponderosa Pine 458 Gambel Oak 7 Peralta Ridge Dry Mixed Conifer 49

Moist Mixed Conifer 37

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Figure 1. There are 3 Inventoried Roadless Areas within the Southwest Jemez Mountains Project Area; the West Mesa IRA (1,704 acres), the Holiday Mesa IRA (3,658 acres) and the Peralta Ridge IRA (93 acres in project area).

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The ecosystems in the Southwest Jemez Mountains project area are degraded, making them susceptible to disturbance such as wildfires and insects. The IRAs are part of this landscape and have not been immune to the departure from desired conditions. Some of the areas of Ponderosa Pine are among the worst on the landscape (e.g., Virgin Mesa in the West Mesa IRA), and are overstocked with dense homogenous stands of young, pole-sized trees. Density of timber within the Piñon/Juniper forests is also overly high. Finally, habitat conditions for the Mexican Spotted Owl PACs within the IRA do not meet the habitat requirements for the species.

Roads There is currently a small system of roads in the three IRAs within the project area. West Mesa has just over 10 miles of total road, Holiday Mesa has 5.78 miles of road, and Peralta Ridge has less than 1 mile of road. These roads may currently be in use, closed, or decommissioned.

Values and Features that often characterize IRAs The affected environment for the 9 values and features used to characterize IRAs overall are representative of the general project area without any outstanding features unless specified below.

Soil, Water, and Air The Santa Fe National Forest’s GIS data shows that soil in the inventoried roadless areas is in moderate, severe, or slight condition (Table 2).

Table 2: Soil erosion hazard rating within the three IRAs within the Southwest Jemez Mountains Project Area. IRA Name Soil Rating Acres West Mesa Moderate 993

Severe 711 Holiday Mesa Moderate 3,504

Severe 50 Slight 94 Peralta Ridge Severe 93

The West Mesa IRA is within 3 HUC12s; the majority is within the Virgin Canyon HUC12, small portions of the southwestern area of the IRA are in the Church Canyon – Jemez River HUC12 and the western edge of the IRA is in the Rio Guadalupe HUC12. The Peralta Ridge IRA is within the Vallecita Creek HUC12.

There are 2 areas classified as a Class I area (an area managed for high air quality) within 50 miles of the project; Bandelier National Monument is 15 miles east of project area and San Pedro Parks Wilderness is 25 miles northwest of project area. There are no areas within the project bounds or any of the IRAs that are specifically managed for high quality air.

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Sources of public drinking water There are three public water supply intakes1 (as defined by the Drinking Water Bureau and Safe Drinking Water Act) within the project area. None of these intakes are directly within any of the IRAs.

Diversity of plant and animal communities and habitat for threatened, endangered, proposed, candidate, and sensitive species and those species dependent on large, undisturbed areas of land. Two of the three Management Areas that are part of the West Mesa IRA have management emphases for wildlife. Management Area C is managed with dual emphases on developed recreation and protecting essential wildlife habitat and riparian zones. Management Area N is managed with an emphasis on protecting essential wildlife habitat. Management Area P, where the Peralta Ridge IRA is located, is not managed with an emphasis on wildlife habitat.

In general wildlife habitat throughout the project area, including within the IRAs, is poor. There is a lack of structural and vegetative species diversity as a result of homogenous stands of even-aged trees and the absence of older, large trees. In addition, understory plant diversity is currently poor given the dense closed canopies without gaps. Gaps are needed to support vegetative ground cover like grasses and shrubs. The absence of this understory vegetation also reduces quality of wildlife habitat and ultimately wildlife diversity.

The West Mesa and Holiday Mesa IRAs have parts of four different Peregrine Falcon nest sites, although only two have Zone A and B (closest to the nest) within the IRA. This IRA also has parts of 2 MSO PACs within the Northern portion. A small portion of a Northern Goshawk Forging area is found in the western edge of the IRA. There is a small portion of New Mexico Jumping Mouse Habitat in the northern portion of the IRA. There is no Jemez Mountain Salamander critical habitat or occupied stands.

The Peralta Ridge IRA only has a small portion of Zone D (farthest from the nest) of a Peregrine Falcon nest site. There are no MSO PACs, Goshawk Foraging areas, New Mexico Jumping Mouse Habitat, or Jemez Mountain Salamander critical habitat or occupied stands.

Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of dispersed recreation. Within the IRAs there are three types of Recreation Opportunity Spectrums (ROS). Within the West Mesa IRA there are 1,703 acres of semi-primitive motorized ROS and 0.4 acres of semi-primitive non-motorized ROS. In the Holiday Mesa IRA there are 636 acres of roaded natural ROS, 0.08 acres of semi-primitive motorized ROS, and 3,008 acres of semi-primitive non-motorized ROS.

The entire Peralta Ridge IRA has 15,547 acres of the semi-primitive motorized ROS, not all of this is in the project area.

1 Data from the NMED Drinking Water Bureau

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Reference landscapes “Reference landscapes of relatively undisturbed areas serve as a barometer to measure the effects of development on other parts of the landscape”(2001 Roadless Area Final Rule, pg. 3245). The current Santa Fe National Forest Plan doesn’t identify any reference landscapes.

These roadless areas are not suitable reference landscapes because the conditions here do not represent desired conditions for ecosystem composition, structure, or processes. For this reason these areas are part of the proposed treatment areas for this project. Similar to other parts of the project area, the landscapes that compose the IRAs are severely “out of whack” with desired conditions for most vegetation types.

Natural appearing landscapes with high scenic quality Only one of the three management areas within the West/Holiday Mesa IRA should be managed for a visual quality objective (VQO) of “retention.” The definition of retention is, “Provides for management activities that are not visually evident. Activities may only repeat the form, line, color, and texture frequently found in the existing landscape.” Management Area C has a management emphasis on enhancement of visual quality and all resource activities throughout this management area should be managed for retention. This is a small portion in the southern section of the IRA. Although the other two management areas, N and R, have components that are managed for retention, these areas are not within the IRA (e.g., FR10, Hwy 122, and the San Antonio River area).

The Peralta Ridge IRA is in Management Area P. Although this Management Area has specific locations that are managed for retention (FR10 and FR271), none of these areas are within the IRA.

Traditional cultural properties and sacred sites The West Mesa/Holiday Mesa IRA has a high density of cultural sites. Within the IRA there are 244 known sites and a projected additional 617. Virgin Mesa, which this IRA is on part of, has the highest site density in the Jemez Mountains and is considered an ancestral homeland for the Jemez Pueblo. This highly significant site could be considered a “district” because of its density.

The portion of the Peralta Ridge IRA within the project area has little to no archeological survey. Given its location, surrounding area, vegetation, and elevation, it is likely that the sites that occur there are small such as lithic scatters and possibly historic sites (cabins).

Other locally identified unique characteristics (i.e., social, cultural, or historical characteristics). No other characteristics of this roadlessa area would qualify as “locally unique”, so effects to this feature will not be analyzed.

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Measures The effects of this project on IRAs are evaluated in two sections. The first is for the effects of timber cutting and road construction or reconstruction within the IRAs. The final section 294.13 of the 2001 Roadless Area Final Rule (36 CFR Part 294) prohibits the cutting, sale, or removal of timber in IRAs except for limited purposes. Among the exceptions that allow for the cutting, sale, and removal of small diameter timber are improving habitat for threatened, endangered, proposed or sensitive species and maintaining or restoring the characteristics of ecosystem composition and structure, such as to reduce uncharacteristic wildfire effects, within the range of variability that would be expected to occur under natural disturbance regimes of the current climatic periods. Timber cutting in this report is evaluated based on acres of timber harvest for Ponderosa pine and mixed conifer, aspen, and piñon-juniper within the IRA.

The 2001 Roadless Rule prohibits new road construction and reconstruction within the IRAs. Road reconstruction is defined as “Activity that results in improvement or realignment of an existing classified road”. Road improvement is “Activity that results in an increase of an existing road’s traffic service level, expansion of its capacity, or a change in its original function. Realignment is “Activity that results in a new location of an existing road or portions of an existing road and treatment of the old roadway”.

The second section represents the nine values or features used to characterize IRAs. This section is evaluated based on the effects of treatments to these resources in comparison to the effect of high intensity wildfire.

Acres and miles for all quantitative data were calculated using GIS.

Unless specified, effects for alternatives 1, 3, 4, and 5 are not differentiated because the differences for the treatments within the IRAs do not cause a difference in effects.

Direct and Indirect Effects Timber Cutting Uneven aged mechanical treatments is identified for Ponderosa Pine and Mixed Conifer (approximately 350 acres alternative 3, and approximately 450 acres for alternative 1 and 4, and 5). These treatments are designed to restore the structure and function of the forest. Cut and removed trees will reduce tree density and provide age and size class diversity within the stands treated. An additional 330 acres of potential thinning is identified for Piñon/Juniper stands for all alternatives. There are also approximately 600 acres of Old Growth potential treatments, 53 acres of potential aspen treatments, as well as 470 acres of potential treatments for meadow restoration identified within the IRA.

Timber cutting across the landscape, including in the IRAs, is an essential component of meeting the purpose and need for the project. Cutting timber within the IRA as described in alternative 1, 3, 4, and 5 should return these ecosystems to a healthier and more resilient state and ultimately preserve all of the desired characteristics of the IRA. All of these alternatives implement uneven aged thinning mechanical treatments which reduce the density of trees and thereby make the forest more able to withstand disturbance and stress like wildfire and

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climate change. The alternatives have different scales of beneficial effects in terms of resiliency and forest stand conditions. Alternative 2 would not improve resiliency because the lack of any treatment would result in in an overstocked forest. Alternative 3 would reduce the amount of treatment in the IRA because a temporary road outside the IRA is necessary to access the southern portion of the IRA (approximately 180 acres). Alternative 4 would reduce the quality of the treatments and the ability to maintain the treatments because prescribed fire, which is eliminated in this alternative, is an essential tool to complete these treatments. Additionally, the slash that remains could increase fire hazard. Alternative 5 would reduce the amount of treatment within the Mexican spotted owl PACs within the IRA (including burning in the core, percentage of PACs that can be treated, and maximum size of trees that can be cut) and so would marginally reduce treatment efficacy. Reduced treatment and treatment efficacy could leave the IRA overstocked and vulnerable to an uncharacteristically severe fire, insect outbreaks, and heavy dwarf mistletoe infections.

This project is proposing small diameter timber cutting and removal in the IRA. Within the Forest Service, the authority to approve specific types of small diameter timber cutting in IRAs lies with the Regional Forester (May 31, 2012 letter from Chief Thomas Tidwell). Among the types of timber cutting that the Regional Forester can approve include: “To improve threatened, endangered, proposed, or sensitive species habitat;” and “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”. The effects described above clearly demonstrate how alternatives 1, 3, 4, and 5 meet the second of these objectives. In fact, the primary purpose of the project is identical to that objective. This project also improves wildlife habitat as per the first objective. More information on the specifics for wildlife habitat improvement can be found in the section below “Diversity of plant and animal communities and habitat for threatened, endangered, proposed, candidate, and sensitive species and those species dependent on large, undisturbed areas of land.”

Please refer to the environmental consequences for Vegetation in Chapter 3 of the FEIS for more detailed information on the effects of vegetation treatments on the health, composition, and structure of the forest throughout the project area and for all alternatives. Effects in the IRAs are not discernibly different from the rest of the project area.

Roads construction and Reconstruction No road construction or reconstruction is being proposed within any of the IRAs. No temporary roads are being built within the IRAs. Only roads that are currently open and can be used for vegetation treatment without road construction or reconstruction will be used to access the West portions of the Virgin Mesa IRA. There is no difference in effects between alternatives 1, 3, 4, or 5. Since there is no road construction or reconstruction proposed, the effects on roads is also the same for alternative 2, the no action.

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Values and Features used to characterize the IRA Soil, Water, and Air There are only minor differences in the effects of alternatives 1, 3, 4, and 5 on soil and water. Reduced treatments in alternatives 3, 4 and especially 2 increase the risk of severe wildfires. Severe wildfires can cause intense heat which can increase soil runoff after a wildfire, whereas the mechanical treatments and prescribed burning will reduce this risk and directly maintain high quality soil. Soil runoff after high intensity wildfire increases sediment within the streams. Therefore, treating the area to reduce the risk of high intensity wildfire will also help maintain high quality water. Refer to the environmental consequences for Soil and Water Resources in Chapter 3 of the FEIS for more detailed information on the effects of the alternatives to Soil and Water throughout the project area. Effects in the IRAs are not discernibly different from the rest of the project area.

Overall, the entire project area has good quality air. The effects of the proposed prescribed burns to air quality via smoke emissions will be short-term. Smoke emissions would be about the same in alternatives 1, 3, and 5. Alternatives 4 and 2 have 39% and 19% of the smoke emissions, respectively, of the other alternatives. Please refer to the environmental consequences for Air Quality in Chapter 3 of the FEIS for more detailed information on the effects of the alternatives to Air Quality throughout the project area. Effects in the IRAs are not discernibly different from the rest of the project area.

Sources of public drinking water. The increased potential for a severe wildfire in alternative 2 could cause severe soil erosion which could affect water quality and drinking water supplies of downstream communities for decades. Please refer to the environmental consequences for Soil and Water resources in Chapter 3 of the FEIS for detailed information on the effects of the alternatives to sources of public drinking water. Effects in the IRAs are not discernibly different from the rest of the project area.

Diversity of plant and animal communities and habitat for threatened, endangered, proposed, candidate, and sensitive species and those species dependent on large, undisturbed areas of land. Overall, all treatments are aimed at making habitats for wildlife species more resilient to disturbances such as wildfire. Treatments are designed to meet standards for species recovery plans. Compared to wildfire (alternative 2), habitat conditions will improve, whereas wildfire puts individuals and habitat at risk for complete eradication.

The majority of vegetative diversity in these ecosystems comes from the understory vegetation. Proposed treatments for alternatives 1, 3, 4, and 5 would reduce the dense canopy of trees and provide more light to the understory thereby encouraging understory plant growth. Prescribed burning would also help stimulate herbaceous plant growth and remove thick layers of dead plant debris. Increased plant diversity will also increase animal diversity by providing more habitat and forage. In comparison, a wildlfire with high

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intensity burn which is more likely in alternative 2, could result in increased tree mortality and the possibility of reduced vegetation diversity available from seed or resprout.

Habitat for threatened, endangered, proposed, candidate, and sensitive species would benefit from proposed treatments for alternatives 1, 3, 4, and 5 because they would become more resilient (i.e., able to quickly recover) to wildfire or other disturbance or stress. In current conditions, the habitat of many of these species, be they canopy or ground dwelling, are incredibly susceptible to high severity burns during a wildfire.

The mosaic patchiness proposed for Ponderosa Pine communities would improve prey base for Mexican Spotted Owl, Goshawk, and Peregrine Falcon. Alternative 3 improves less habitat for the animal’s prey base because less area would be treated. Alternative 4 may provide reduced forage availability because chipped or masticate slash that would remain on the ground.

Alternatives 1, 3, and 4 may have some short-term, adverse effects on the Mexican spotted owl within the IRAs because of disturbance to their habitat while treatments are being implemented. Alternative 5 would have insignificant effects on Mexican spotted owl because of the more restrictive management guidance. These short-term impacts will likely result in long-term benefits. Treatments would ultimately build habitat resilience to large severity wildfire and these beneficial effects for Mexican spotted owls would last longer under alternatives 1, 3, and 4 than under alternative 5 because more trees are cut. It is also expected that because of this reduced density, these alternatives would grow larger trees slightly faster than alternative 5.

All treatments (alternatives 1, 3, 4, and 5) are expected to move New Mexico meadow jumping mouse habitat towards recovery.

Habitat for Mexican spotted owl, Jemez Mountains salamander and other wildlife would continue to decline in alternative 2.

Please refer to the Wildlife, Fish and Rare Plants section in Chapter 3 of the FEIS for detailed information on the effects of the alternatives to Mexican Spotted Owl, Goshawk, and Peregrine Falcon, New Mexico Meadow Jumping Mouse and other wildlife species. Effects in the IRAs are not discernibly different from the rest of the project area. Information on Mexican spotted owl and Jemez Mountains salamander habitat may also be found in the vegetation section in Chapter 3 of the FEIS.

Primitive, Semi-Primitive Non-Motorized, and Semi-Primitive Motorized classes of dispersed recreation There are no discernible effects to the roadless areas for primitive, semi-primitive non- motorized, and semi-primitive motorized classes of dispersed recreation. Timber cutting is proposed only for the semi-primitive motorized portion of the West Mesa IRA. Timber cutting is appropriate within semi-primitive motorized ROS. Gravel pits are not proposed within this section of the IRA unless already existing. All other proposed treatments including burning, riparian area restoration, road decommissioning, cultural resource protection, invasive plant control, and terrestrial and aquatic wildlife habitat improvement are consistent with all ROS settings within the IRAs. In contrast, the absence of treatments

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could affect any type of recreation, as it increases the risk for wildfire, which could degrade recreation opportunities.

Please refer to the conclusions about the effects in the Recreation section of Chapter 3 of the FEIS for detailed information on the effects of the alternatives to these ROS classes. Effects in the IRAs are not discernibly different from the rest of the project area.

Reference landscapes Since no reference landscapes are identified, proposed actions or absence of actions would have no effects to this characteristic of IRAs. However, treatments proposed in Alt 1, 3, 4, and 5 will bring the project area, including the IRAs, closer to a reference landscape condition.

Natural appearing landscapes with high scenic quality. In alternatives 1, 3, 4, and 5, there would be short-term negative effects on scenery from mechanical treatments and fire, but long-term beneficial effects on scenery. Both short and long-term effects on scenery are slightly reduced in alternative 3 because there are no temporary roads, resulting in less area of the IRA that can be treated. In alternative 4 there are fewer impacts to scenery associated with smoke, but more associated with viewing slash and woddy debris. Alternative 2 would not improve scenery because the areas would not be treated to meet forest plan scenery guidelines. Please refer to the environmental consequences of the Scenery section in Chapter 3 of the FEIS for detailed information on the effects to scenic quality. Effects in the IRAs are not discernibly different from the rest of the project area.

Traditional cultural properties and sacred sites. Part of the purpose and need for the project is to provide for the sustainability of archaeological sites, traditional cultural properties, sacred sites, and forest resources associated with traditional practices. As such, alternatives 1, 3, 4, and 5 have treatments designed to improve conditions around and protect cultural resources. Given the density and importance of cultural sites in the IRA, the beneficial effects of this project to protect those sites from wildfire are significant. In alternative 2, sites would not be treated and remain to have high fuel loads and be at risk from uncharacteristically severe wildfire and erosion.

Please refer to the environmental consequences of the Cultural Resources and Tribal Relations section in Chapter 3 of the FEIS for more detailed information on traditional cultural properties and sacred sites. Effects in the IRA are not discernibly different from the rest of the project area.

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Cumulative Effects The IRAs are an integral part of this project area. Integrating the project treatments into the IRAs as well as the immediate surrounding landscape assures that whole area will be more resilient to large scale wildfire and that ultimately the characteristic of the IRA are preserved. The inclusion of the IRAs would result in beneficial cumulative effects for the surrounding area. There are no additional projects occurring or in the reasonably foreseeable future in the IRAs within the project area. Please refer to the cumulative effects for individual resources throughout Chapter 3 of the FEIS for more detailed information on cumulative effects. Cumulative effects for resources in the IRA are not discernibly different from the rest of the project area.