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James Creek Fuel Reduction Project

Environmental Assessment

Appendix E

Response to Comments

The Environmental Assessment (EA) for the James Creek Fuel Reduction Project was mailed to

interested and involved members of the public and organizations on June 25, 2004. An invitation to

comment on the proposed action was published in the Daily Camera Newspaper, Boulder, CO, on June

25, 2004, in the legal notice section to initiate the 30-day public comment period to comply with

provisions of 36 CFR 219.27(d)(2)(ii). The comment period ended on July 26, 2004 and letters and e-

mails had to be postmarked or received by that day. By July 30, 45 letters and/or e-mails were received

from individuals and organizations. Comments received in response to this solicitation, including

names and addresses of those who comment, are considered part of the public record for this project.

The substantive comments directed towards the James Creek Fuel Reduction Project are summarized

below. The comments are shown in bold type along with the identifying number associated with each

letter, followed by the Forest Service response. Comments are grouped by natural resource or subject.

Many people wrote similar comments. When similar comments were raised, summarized comments

from the letters are included and a single response is presented. Criteria used to identify comments are

taken from 36 CFR 215.6 (b) (3), "Specific facts or comments along with supporting reasons that the

person believes the Responsible Official should consider in reaching a decision. Comments regarding

personal philosophy, politics, the “1997 Revision of the Land and Resource Management Plan of the

Arapaho-Roosevelt National Forests and Pawnee National Grasslands” (Forest Plan), or the National

Fire Plan (NFP) are broad issues that will be addressed at a policy or forest planning level and we,

therefore, considered to be outside the scope of this project level environmental analysis. Some letters

did not contain substantive comments and did not result in a response (Letters 12, 27-35, 38 & 42). The

Forest Plan is the legally binding document that sets the direction for the Arapaho and Roosevelt

National Forests. We therefore must generate projects that move the Forest towards meeting the goals

and objectives in this Forest Plan and propose activities that are compliant with the Plan.

Several responses resulted in corrections or modifications to the EA and some are reflected in the

decision. The order of comments and responses to comments is not significant. Letters were assigned a

number randomly for tracking purposes.

Letter

No.

Commenter Letter

No.

Commenter

1 Max Greenlee 23 Frank Romano

2 Pat Lehman 24 Wade Henderson

3 Elizabeth & Brad Allen 25 Jim Lunn

4 Marjorie McIntosh 26 Beverly Gholson

5 Shane Milne 27 Karen Trench

6,6A,6B Mark Boslough 28 Charlie Trench

7 Gregg and Geinie Burch 29 J.P. Catasein

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8 Barbara & Edwin Monroe 30 Ellyn Davis

9 Sandy Karng & Ward

residents

31 Jim & Pat Grady

10 Dean & Deandra Rollings 32 Amy Thran

11 John Geier 33 Candis Hurst

12 Judy Catasein 34 Florence Byrd

13 Barbara Monroe 35 Bruce Dunkley Jr.

14 Colleen Williams, The James

Creek Watershed Initiative

36 W. Travis Burch

15 Sandy Karng 37 Milbre Burch

16 Dean & Deandra Rollings 38 Milbre Burch & Berkley Hudson

17 Sandy Cruz 39 Mark Bliesener

18 Cheryl Warner 40 Norman Bowers

19 Rocky Smith, Colorado Wild 41 George Lewis

20 Maya Elrick 42 Mike Gross

21 Ann Gillis 43 Kenneth Lenarcic, Town of

Jamestown

22 Pat Cypher

SLASH TREATMENTS

Comment 1: The treatment selected for slash is not acceptable.

Letters 7, 8, 9,18, 19, 21, 23, 25, 39

o Slash should be removed, not burned.

o Clarify the intended methods of slash disposal.

o Some small amounts of slash should be left in the woods.

o Little to no slash left on the ground on Burnt Mountain will facilitate off-road, off-trail motorized

recreation.

o Creating & burning huge slash piles will not help to create a new healthy forest.

o Ecology requires that dead wood remain throughout the forest for resource benefit (soils,

wildlife).

o Leaving little or no slash on site will make easy access for motorized travelers.

o Some landing slash should be redistributed into the woods for coarse woody debris and resource

benefit.

o How will meet wildlife slash mitigations if all slash will be created and piled?

o Landing slash should be redistributed in the woods.

o Whole tree skidding should not be allowed.

o Leaving slash piles that cannot be burned is unacceptable.

o Slash will remain on the landscape for generations.

o The wood should be left to rot.

Response:

Trade-offs exists for removing, altering, burning or retaining slash generated from treatments. This project was

designed to reduce crown fire initiation and spread without a net increase of surface fuel quantities by using

whole tree harvesting methods (EA, pp. 16-17) for the majority of the treatment units. A balance between

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meeting project objectives to reduce fuel loading while still meeting resource Forest Plan Standards and

Guidelines molded the slash treatments for each unit of the Alternatives. Chapter 2 compares the variety of

slash treatments provided with each Alternative. The trade-offs and effects relating to slash treatments were

analyzed in the EA in Chapter 3 in sections for the resources affected by slash treatments (vegetation, scenery,

recreation, soils, hydrology, and wildlife). Furthermore, mitigation measures found in the EA related to slash

were designed in Appendix A to balance the trade-offs and effects that slash may have on resources while still

meeting project objectives. Some slash may be retained on site in some form under two scenarios: 1) if Forest

Plan Standards and Guidelines or mitigation measures found in the EA on pages warrant it for resource benefit

or 2) if the follow up treatment of prescribed fire is planned for the unit under question. Slash treatments were

listed for individual units in Appendix B (pages 103-105) of the EA. Also see response to comment 3.

Comment 2: The treatments proposed produce too much slash. Slash piles should be kept small.

Letters 2, 7, 1, 18, 7, 23, 9, 25

o Clear cuts produce too much slash.

o Logging produces a ton of slash.

o Large slash piles should not be created or burned.

o Slash should be burned in smaller piles.

o Create piles no larger than 10 feet diameter and four feet high.

o Slash pile burning in Alternative A is excessive.

o Only small piles of slash should be constructed and burned.

o Decrease the size of slash piles.

o Any slash piles that will be burned must be kept small (10ft x 4ft).

o Slash piles up to ¼ acre in size is unacceptable .

o Huge ½ acre slash piles will sit for a year before they are burned are too large.

Response:

The net quantity of slash generated from all three action alternatives is expected to be large given the number of

acres that are being proposed in each action alternative, however implementing treatments from all three action

alternatives over the course of five to eight years will stagger the quantities of slash produced at any one time.

The quantity of usable forest products and consequently the quantity and size of slash piles is indirectly

influenced by future market values as described in the Economic Analysis of Chapter 3 on pages 83-84.

Whenever it is feasible, the disposal of wood through forest product markets will occur in order to reduce the

amount of wood that is put into slash piles as well as to reduce the cost of implementation. For example, the

Forest Service collaborates very closely with the Colorado State Forest Service and other agencies to find other

uses for low to no-market-value wood whenever possible, such as converting slash to wood chips that are used

to power the Town of Nederland Community Center.

Slash pile volumes and quantities will vary from unit to unit based on what exists, what is cut and what is

removed. Trade-offs exists with regards to how much or how little volume slash piles should have relative to

the resources in question. Smaller slash piles mean that more slash piles will cover the ground. More slash

piles on the ground will cost more and will take longer to implement mechanically. Likewise, it will take more

time, cost more money and sterilize a larger percentage of the ground if a larger number of small slash piles are

burned as opposed to fewer large piles that will be placed on landings where disturbance will already occur.

The effects to resources on sizes and quantity of slash piles that are burned with each alternative were analyzed

and disclosed in Chapter 3 of the EA. Mitigation measures found in Appendix A were designed to reduce or

minimize impacts from slash.

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Comment 3: The depth of masticated chunks and chips in the Mitigation Measures will increase the fire

hazard.

Letters 17, 7, 23, 9

o Masticating slash/producing chips 5” deep will increase fire hazard.

o Slash depths for masticated covering 25% with depths 10-12” is unacceptable (because it will

increase the fire hazard).

o Slash heights for lop & scatter of 2-6 tons per acre not-to-exceed 12’ in height will not allow

things to grow.

o Maximum chip depth of 5” with 25% coverage is too much (because it will increase the fire

hazard).

o Total fuel bed of 12” is too much (because it will increase the fire hazard)

o Chipping huge slash piles is creating more of a fire hazard.

o A maximum of 12” of masticated slash and 5 inches for chips will increase fire hazard and will

not allow vegetation to grow.

Response:

This project was designed to reduce crown fire initiation and spread without a net increase of surface fuel

quantities by using whole tree harvesting methods (EA, pp. 16-17). Slash may be retained on site under two

scenarios: 1) if mitigation measures found in the EA on pages warrant it for resource benefit or 2) if the follow

up treatment of prescribed fire is planned for the unit under question. The original wording of the slash

mitigations (EA, pp. 16-17) were edited for clarification. Slash depths and spread pattern mitigations are

designed for those areas requiring this mitigation for resource benefit. Units receiving mastication or chipping

are limited primarily to those units where prescribed fire will be implemented. However these alternative

treatments may be an option for temporary road closure and obliteration or where warranted for resource

benefit. The net quantity increased and the pattern of slash material units will remain near zero.

PILE BURNING

Comment 4: Prescribed pile burning has a risk of escape.

Letters 18, 17, 25

o Burning slash piles comes with a risk of escape.

o Burning should be done when snow is present.

o Wicked winds in Ward will increase the fire hazard while burning.

Response:

It is both Forest Service and National Interagency Fire Center (NIFC) policy that the degree of complexity of a

prescribed fire is always thoroughly assessed and documented prior to ignition to anticipate desired fire

behavior and fire effects. The complexity directs the parameters including needed staffing and equipment on

scene, and strategies used to implement the prescribed fire. Prescribed pile burning is considered to have a low

risk of escape because it is not complex. Pages 14-16 of the EA describe in more detail Forest Service and

NIFC policies regarding the use of prescribed fire. Larger landing piles are typically but not always burned

when there is snow on the ground. Conditions sometimes allow for hand piles and prescribed fire to be burned

without snow cover. Winds do add a certain risk when burning and wind speed limits are incorporated with the

burn plan.

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Comment 5: Slash piles will increase the fire hazard and should be burned within a reasonable

timeframe. Letters 2, 17, 8, 9, 21, 40, 39, 25

o Slash increases fire hazard.

o Accumulated slash could increase the fire hazard (if left to dry for one year).

o Accumulated slash will contradict the project objectives of reducing fire threat.

o Leaving numerous slash piles adds to the fire hazard.

o Get rid of the piles in a timely manner.

o Burning large slash piles will increase the fire hazard.

o Huge ½ acre slash piles will sit for a year before they are burned.

Response:

The timing and implementation of the disposal of slash through prescribed pile burns is dictated primarily by

State of Colorado issued Burn Permits and burn prescription parameters. Any limitations to implementing

prescribed burn piles as the result of State of Colorado regulations or burn prescription parameters is expected

to have a localized and temporary effect on fire hazards. It is expected that slash piles generated from this

project that are intended for burning (and not left for resource benefit) will be burned in a timely fashion

without jeopardizing project objectives or risking public and firefighter safety. Overall, complete

implementation for this project is expected to take five to eight years, which will stagger the amount of slash

produced and influence the number of piles that will be burned per year. Also see response to comment 3.

Comment 6: Local fire departments should be notified prior to implementing prescribed pile burning. Letters 1, 18, 23

o Local fire departments should be notified prior to burning.

Response:

The Forest Service follows a strict interagency policy regarding the implementation of prescribed fire

operations, including pile burning(see Appendix A). As part of this policy, the Boulder County Sheriff’s

Dispatch Office must be notified prior to any prescribed burns. Community members, residents and local

cooperators may be alerted through public outreach and public notification immediately prior to ignition as part

of this Forest Service policy. Further information can be found on pages 14-16 of the EA regarding Forest

Service policies and its prescribed burning program. Also see response to comment 2.

FIRE HAZARD AND RISK

Comment 7: Road improvements and temporary road construction will increase the fire risk.

Letters 18, 19, 39, 24

o Increased fire risk from reopening/improving existing roads

o Increased access means an increased threat of human-caused wildfire ignitions

o Building new roads will increase the fire risk.

Response:

Increased recreational use associated with treatments was analyzed and is documented in the EA on pages 37-

39 and pages 43-48. Additionally, the Roads Analysis for James Creek analyzed for increased fire risk

resulting from roads, trails, ways, trailhead, parking facilities and associated recreational uses. The ability for

suppression operations to utilize these roads, trails and recreational developments was also analyzed. Trade

offs exist in fire management regarding roads and their associated fire risk in contrast with their ability to

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enhance suppression operations. As a result, Alternative D, which decreases the number of acres treated by

thinning and clear-cutting, was formulated to address the concerns associated with potential increased use, type

of use and associated risks with specific regards to roads. Additionally, all action alternatives were designed to

close and obliterate temporary roads after implementation to discourage use.

Comment 8: Schedule treatments so that activities and slash do not increase the fire hazard.

Letters 17, 2, 8, 9

o Schedule logging so slash does not increase fire hazard

o Remove logging waste as soon as possible

o Schedule logging so slash does not increase fire threat

o Additional thinning should be halted if slash cannot be burned within one year

o Surface fuel quantities will not remain at or near current levels unless slash piles are dealt with in

a timely manner

o Get rid of the piles in a timely manner

Response:

Implementation of the action alternatives will take three to eight years to implement, which will stagger the

actions and by products produced at any one time. Every effort will be made to complete all phases of

implementation in a timely manner; however, the scheduling of implementation is dependent on a number of

factors, as described on page 5 of the EA. Also see response and comment 5.

AIR QUALITY

Comment 9: Roads, road work and heavy equipment staging areas will increase pollution. Letter 18

o Increased pollution from reopening/improving existing roads

Response:

The road work use of heavy equipment for fuel reduction in all Alternative A has the potential to affect local air

quality. All activities will be conducted in accordance with the State of Colorado air quality requirements. The

benefits of fuel reduction and minimizing the potential for a wildfire, that could produce a significant and

possible dangerous amount of smoke, clearly outweighs the temporary effects to air quality from heavy

equipment operation. Increased pollution from roads and road work as a result of the action alternatives was

analyzed on page 55 of the EA.

Comment 10: Smoke from prescribed fires will affect people’s health.

Letter 18

Response:

The effects from prescribed burning on air quality and public health was analyzed in Chapter 3 on pages 50-56

of the EA. The Forest Service follows strict guidelines set by the Environmental Protection Agency and the

State of Colorado with regards to emissions. Prescribed burning will only be conducted according to legal

parameters set from the Colorado Air Pollution Control Division and the Colorado Department of Public Health

and Environment. Prior to implementation, every prescribed fire is required to have a Smoke Permit issued by

the State of Colorado authorizing prescribed fire smoke emissions within parameters set according to health and

air quality standards.

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THINNING INTENSITY

Comment 11: Thinning intensity is too great. The amount of trees you are proposing to take all at once

in all areas of proposed cutting seems extreme…we can’t fix all the past problems in one fell swoop.

Letters 7, 8, 18, 21, 22, 40

o Reduce the scope of the thinning.

o The proposed thinning intensity needs to be reduced significantly.

o The crown spacing is too great.

o I hope you can adapt the tree spacing as you go along.

Response:

A variety of treatments are planned for the James Creek project depending on the existing conditions of the

stands. The result of treatments will be a mosaic of stand conditions representing a variety of stand and tree

sizes across the landscape. It is our objective to break up the contiguous forest canopy, create a variety of stand

structures and more closely represent historic stand structures.

The crown spacing of 15 to 25 feet for mechanical thinning will meet the purpose and need identified in this

project. Depending on the existing stand characteristics (species mix, size, density, soil conditions and

topographic features), prescriptions will address specific site conditions. For example, a treated lodgepole pine

dominated stand, on an exposed northwest slope with shallow soils will retain groups of trees (8 to 12 trees)

spaced approximately 15 feet (being the norm) apart from the next group of trees. On an easterly slope, where

wind conditions are more favorable, and other characteristics being similar, the spacing will range between 15

and 25 feet.

Units identified as ridge fuelbreaks which will be manually treated generally will have a crown spacing of 5 to

15 feet. In these areas, smaller trees and brush will be cut and handpiled, and the residual trees wwill be pruned

up to 6 feet.

We plan to facilitate an adaptive process based on monitoring and evaluating the prescriptions to improve the

implementation process and achieve project goals. Adjustments can be made to the project if monitoring shows

significant departure from planned objectives.

Comment 12: The percentage of basal area removed will greatly exceed the maximum of 30 percent

recommended by the Forest Service’s own research.

Letters 7, 8, 17

Response:

The literature cited and referred to about thinning intensity is specifically cited for lodgepole pine. Lodgepole

pine has a shallow root system and in stands where pure lodgepole pine will be thinned, we will be removing a

maximum of 30% of the existing basal area and maintaining groups of trees to minimize windthrow potential.

Other conifer species (i.e. ponderosa pine and Douglas-fir) maintain a more substantial rooting system with a

tap root that grows down and is more stable for the tree even in shallow soils. These trees main tap root will

grow down until it reaches the impervious layer at approximately two feet in these soils. Lodgepole pine

rooting systems generally grow just below the surface of the soil (reaching down approximately 6 to 12 inches)

and are more prone to windthrow (see Record of Decision, p.2).

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Comment 13: M0502 and M3202 should be designated for manual clearing, as a number of the slopes

are too steep to be worked by machines without tearing up the hillsides.

Letters 8, 17

Response:

Mechanical thinning will occur on slopes generally less than 30% (EA, p. 5). Where slopes are greater than

30%, a manual thinning prescription will be implemented. Because of slope limitations for mechanical

equipment, portions of units identified to be mechanically treated may be treated by hand or left untreated. In

areas that are too steep for mechanical equipment and manual treatment is implemented, the specific area will

follow the proposed action under Manual Thinning (EA, p.13).

Comment 14: Mechanical thinning is designated for M3201. This does not seem warranted because this

area was thinned 15-20 years ago.

Letters 8, 17

Response:

The forest is a dynamic system and is constantly changing at many scales. Just because a treatment was

completed 15-20 years ago doesn’t indicate objectives at this time are met. Our objectives are to maintain or

enhance the current vegetation structure to minimize the potential for sustained crown fire or crown fire

initiation, regardless of what it is, or how and when it came to be. M3201 has a combination of conifer species

dominated by lodgepole pine. Pockets of trees (larger than what can be addressed with a manual treatment)

within this stand will be thinned to reduce the crown canopy density, ladder fuels, and reduce the potential for

sustained crown fire.

Comment 15: Not all conifers should be killed in every stand treated to enhance aspen.

Letter 19

Response:

There is no intention of cutting all of the conifers within a particular aspen clone. Many aspen stands are

eventually replaced by conifer trees. However, some pure aspen stands occur which do not contain conifers.

Conifers offer characteristics beneficial to certain wildlife species, stand structural diversity, and aesthetic

qualities that are highly desirable. There will be a conifer component with various species and size classes

including snags that will remain in the majority of the treated aspen clones.

EFFECTS FROM CLEARCUTTING

Comment 16: Very dense stands of lodgepole exist but do not dominate this area, so clearcutting is not

needed (Burnt Mountain)

Letter 19

Response:

Clearcut patches are not always identified as a prescription treatment in dense stands. The lodgepole pine stand

characteristics including density, species mix, height to diameter ratio, cone habits, disease and insect

susceptibility, and overall objectives of the project identified in the purpose and need have to be evaluated

before a prescription is developed. Clearcut patches modify the homogenous crown canopy persistent in

lodgepole pine stands by altering the stand structure, both vertically and horizontally, and fire behavior. The

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clearcuts on Burnt Mountain will range in size between three and five acres with a thinning (20-30% basal area

reduction depending on site and stand conditions) in between the clearcuts.

Comment 17: Patch cuts will regenerate trees, which will increase the fire hazard.

Letter 17, 2

o Clear cuts will regenerate trees which increases the fire hazard

o Subsequent tree regeneration following clear cuts will create a future fire hazard.

Response:

Increased fire hazard in patch cut units as the result of regeneration is not expected to occur for 3 to 10 years.

Because the sizes of patch cuts is small (1-5 acres), the fire hazard is expected to be relatively low and overall

project objectives will not be jeopardized. Subsequent treatments in all units is expected to occur as a part of

future projects and is required in order to maintain fuel reduction objectives, especially in the wildland urban

interface. Increased fire hazard as the result of patch cuts regenerating in 5 to 10 years should be addressed

then.

Comment 18: Roads should be used as fire breaks, instead of creating patch cuts. Letter 21

o Roads should be used as fire breaks, not random cuts.

Response:

Small patch cuts from one to five acres were included in the action alternatives of A and D to break up the

continuity of lodgepole pine stands which establish and die by crown fire events. Existing roads serve as

adequate fire breaks during surface fire events, but only occasionally under passive fire events and seldom

under crown fire events. The effectiveness of patch cuts or lack thereof in lodgepole pine stands was analyzed

in Chapter 3 of the EA on pages 31-37.

Comment 19: Clearcut patches in this area (Burnt Mountain) will be unsightly and unnecessary.

Letters 8, 17

Response:

Patch cut locations have been designed to minimize viewing impacts and meet VQO. Also see response to

comment 16.

WINDTHROW

Comment 20: ...the severe thinning intensity should be reduced so that the trees remaining after thinning

will have a much greater likelihood of withstanding the area’s severe winds.

Letters 2, 16, 18, 19, 22, 26, 39, 40

o Clearcutting and mechanical cutting has to be reconsidered due to historical blowdown.

o Clearcutting/large patches: windfall

o The proposed thinning is highly likely to cause significant windthrow.

o The proposed level of thinning is too great and will create problems with tree “blowdowns” in the

intense winter winds.

o Also I have experienced the winds in that area and am concerned about the potential for

blowdown if the proposed severe thinning is allowed.

o I think there will be considerable blowdown with the spacing proposed.

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o The areas exposure to wind, short growing season and shallow top soil are not taken into account

in the current proposal. Windthrow will occur in this area should this proposal go ahead.

Response:

The thinning intensity that is proposed was established to meet the objectives of the project. Ponderosa pine

has a well-developed root system and is one of the more windfirm species in the central Rocky Mountains.

Prescriptions developed for this project include a range of spacing distances between crowns of individual and

groups of trees. Lodgepole pine, due to a shallow root system, is more susceptible to windthrow. Prescriptions

will incorporate lodgepole pine’s susceptibility to windthrow by grouping more trees (approximately 8-12) and

spacing approximately 15’-25’depending on topographic features, soil conditions, and stand characteristics.

Blowdown is a natural disturbance and has been observed in both treated and untreated areas of the James

Creek Project area. An acceptable amount of blowdown at a minimum will provide the down woody debris as

specified in the mitigation measures and a maximum will be 10% of the residual unit.

Comment 21: They (Colorado Wild) point out that taking more (>30% of existing trees) will increase

windthrow significantly.

Letter 7

Response:

The citation that Colorado Wild is referring to is for lodgepole pine and even though there is a risk of

blowdown in other conifer species, it is less likely given the characteristics of the rooting system of other

conifers. The citation also refers to “>30% basal area”, not existing trees. See Record of Decision, p.2 and the

response to comment 12.

Comment 22: The protective measure for the residual legacy (old ponderosa pine) and aspen trees –

leaving three to five trees on the windward side (p. 12) – will likely be ineffective.

Letters 7, 19

Response:

“Adjacent to the legacy trees, three to five trees (on the windward side of the legacy tree) will be retained to

offer protection and reduce the risk of blowdown.” This statement was unclear and was intended to mean that

the legacy tree will be offered some protection to windthrow within the patch cut. Residual trees left on the

windward side of the legacy tree will offer protection and stability to the legacy tree. These clumps of trees

where present will offer little to no protection to the leeward side residual trees adjoining the patch cut.

Comment 23: The risk of windthrow in the stands adjacent to the patch cuts will be very high,

depending on the aspect and slope steepness.

Letter 7

Response:

We agree, the risk of windthrow will be higher adjacent to patch cuts. The aspect, slope, topographic features,

soil condition, and stand characteristics all were considered when designing the location of a patch cut.

Comment 24: Feathered edges of patch cuts will be especially vulnerable.

Letter 7

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Response:

As part of the design of each patch edge, trees incorporated into the feathering effect will be the most windfirm

trees (generally larger diameter, low height to diameter ratio, and grouped together). This and other factors (see

response to comment 20) are considered when designing the location of each patch cut.

Comment 25: Burnt Mountain has the elevation, the slope and the aspect (Northwest facing) to create a

severe windthrow problem after the proposed treatment.

Letter 7, 8, 19

o Previous experience tells us that significant windthrow will occur after the prescribed treatment.

The report notes severe wind conditions at this elevation, and these slopes on Burnt Mountain

face the fiercest winds at the highest elevations.

o The threat of blow-down will be especially acute on Burnt Mountain, where patch clear cutting

and thinning are proposed. Unit M0501 is at least partially on a steep west to northwest-facing

slope.

Response:

This unit has been modified and split into two zones. The western zone (Record of Decision, map Alternative

A with Modifications – Map B) will receive patch cuts and thinning in the identified mixed conifer stands

dominated by ponderosa pine. The eastern zone (M0503) will be thinned up to a 30% basal reduction

considering topographic features, soil conditions, and stand characteristics. Stand treatments will reflect a

variety of stand conditions that result in a mosaic or residual densities and groupings to maintain windfirmness.

Comment 26: Another negative effect is the drifting of snow that will occur given the increased wind

speeds and reduced vegetation. This will create significant access problems for us in the winter.

Letter 7

Response:

Wind currents will vary as a result of the treatments within the stand to the referred road. Currently, wind

channels through the road corridor, and drifts are formed along edges and eddies where wind intensities aren’t

as strong. With a more open setting, wind willn’t be as restricted as the road corridor, and drifting snow will be

more dispersed. Even-aged stands, similar to M0501 and M0503, without any understory may have low wind

speeds in the crown, but appreciable winds between the crown and the ground, whereas multi layered forest

communities have reduced wind speeds at all heights below the upper crown. By creating structure within the

stand (ie. patch cuts), the regeneration in the patch cuts will alter the overall intensity and pattern of wind over

time.

Landowners requiring a legal access across Forest System roads are authorized to plow roads under an operator

maintenance plan of the special use authorization.

Comment 27: A quick glance at the maps shows other units likely being similarly susceptible to

blowdown: M1701 near Peaceful Valley, O1501 near Overland Mountain, and M1801 southeast of

Ward.

Letter 19

Response:

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Due to the high winds in the area, each unit is evaluated as to the potential for blowdown in regard to species

mix, aspect, topography, average tree height to diameter ratios, and soil characteristics. Thinning guidelines will

be adjusted to minimize the local blowdown potential.

Comment 28: …significant blowdown in just one unit will necessitate considerable additional work, all

of which could likely be avoided with a more moderate thinning intensity.

Letter 19

Response:

There will be some blowdown as a result of these treatments. However, we do not expect extensive follow-up

treatment resulting from blowdown. Throughout the monitoring process, evaluations will be made to assess

any additional work, if needed.

Comment 29: Local residents support fuel and fire risk reduction, but not at the expense of causing or

exacerbating other problems, like illegal motorized recreation and massive windthrow.

Letter 19

Response:

Thank you for your support of fuel reduction and fire risk reduction. A significant effort has been made to

minimize the potential effects of implementing this project. Mitigation measures are included in this project to

close temporary roads and some existing non-system roads. Thinning along system roads where there is the

potential for illegal motorized use will include a lighter treatment buffer to reduce the potential for user created

road development (see Appendix A).

OLD GROWTH DEVELOPMENT

Comment 30: Treatment to enhance old growth is only sensible in ponderosa stands and mixed conifer

stands with a considerable percentage of larger ponderosa pine in the overstory. Some mature Douglas-

fir plus a few understory trees of this species should be retained, as these trees will likely be present in

natural old growth ponderosa pine stand.

Letters 19, 39

Response:

All of the old growth development units proposed in this project are dominated with ponderosa pine and a

minor component mix of other conifer species and aspen. We recognize the importance of Douglas-fir as a

component in these stands. However, it may be at a lesser level than currently exists. Regeneration of

ponderosa pine and Douglas-fir will be retained and enhanced given site-specific existing conditions.

Comment 31: We recommend that contracts for treatment of old growth development areas require

retention of some down dead material. A way must be found to retain some snags.

Letter 19

Response:

The proposed treatment incorporates this concern. The primary emphasis for treatments in Old Growth

Development areas is to enhance old growth characteristics such as large trees, large down material, snags, and

both vertical and horizontal forest structure (see EA, p.13). Also see response to comment 1.

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Comment 32: The larger trees in the stand should not be cut, as they are the ones that probably existed

prior to the onset of human fire suppression, and thus should be retained as part of the restoration of the

stand to a more natural condition.

Letter 19

Response:

Generally large trees will not be cut in the old growth development areas, but some trees will be removed to

allow for growing space of ponderosa pine seedlings to perpetuate the stand over time. Even if some of these

trees existed prior to the onset of human fire suppression, they may not have survived a fire if one did occur in

proximity to an old growth development stand. A natural condition is dependent on some form of disturbance

(i.e. fire and wind) to affect the structure and all of the components that make up an old growth stand. With fire

exclusion / suppression, this disturbance mechanism will limit the potential to enhance these old growth

development stands. A number of the old growth development stands have a prior human caused disturbance

(i.e. O1501) where ponderosa pine regeneration has begun to establish, but it took the disturbance to initiate the

regeneration. Trees acting as fuel ladders will generally be removed to maintain the large tree component, but

occasionally larger trees will be removed to provide growing space for ponderosa pine regeneration.

INSECTS

Comment 33: Ips breeding in slash and blowdown can kill smaller pine trees, which means the project is

particularly vulnerable to this insect because more than 70 percent of the ponderosa pine/Douglas-fir

stands there consist of sapling/pole sized trees (p.22)

Letters 7, 19

Response:

The key to preventing tree damage from insects is the promotion of healthy forests. Trees in thinned, vigorous

stands are infrequently colonized by pine engraver beetles. During drought years, maintaining stand vigor is

even more important. Stands in which basal area has been reduced to 80-100 square feet per acre have been

found to be less susceptible to beetle attack.

Because there is such a high percentage of slash that will be created from the implementation within the

treatment units, monitoring of insect attacks will be an important component for the overall success of this

project. Post treatment visual surveys will be conducted to evaluate the extent of insect outbreaks. In general,

the low fertility, overstocked tree condition and recent droughts have weakened trees, making them susceptible

to insect caused mortality. The James Creek area is at endemic levels, not epidemic levels of insect

populations. Most of the recent tree mortality patches have been due to mistletoe and drought. Treatments that

reduce tree competition improve the vigor of the remaining trees to ward off insect attacks.

Comment 34: Ips can also topkill large ponderosa pine, trees that are desirable for retention, especially

in developing old growth areas.

Letters 7, 19

Response:

Ips are not an aggressive tree killer, even though large populations commonly infest logging slash, windthrown

trees, or trees broken by wind or snow. The highest risk exists in stands of young unthinned trees (5-8 inches in

14

diameter). Ips attack and occasionally aid in killing large trees and is usually secondary to mountain pine

beetle. If some larger trees are topkilled, they may provide habitat for wildlife (i.e. nests, snags, large down

woody material) over time and add complexity to the old growth development area.

Comment 35: Large landing piles will be especially at risk for breeding this insect (Ips) because logs

near the bottom of the piles but not touching the ground might not dry out for a few years, maintaining a

good breeding ground environment for this beetle.

Letter 7, 19

o …only small slashpiles be constructed and burned, in order to protect soils and reduce the chance

of ips beetle infestation.

Response:

The amount of slash is expected to be large given the number of acres that are being treated, but the projected

duration of the project (three to eight years) will stagger the amount of slash material in any given year. The

size of the project area allows for spreading the treatments so one specific area isn’t as high of risk to the ips

beetle.

According to Kegley et al., 19971, one method of addressing beetle populations in slash is by creating very

large slash piles in the spring before the initial beetle flight. If piles are big enough so that interior pieces do not

dry before beetles from the initial generation emerge, new beetles are attracted deeper into the pile, keeping

them out of the standing trees. Piles should be about 20 feet wide and 10 feet deep, and distributed throughout

the treated area. Also see responses to comment 2 and 8.

MAPS AND BOUNDARIES

Comment 36: Property boundaries in Long Gulch are incorrect on maps included in the EA.

Letter 6

Response:

The Softcopy Primary Base Series (PBS) is a raster image of the USDA Forest Service topographical map geo-

referenced to the Universal Transverse Mercator (UTM) grid.

PBS maps are large-scale Forest Service maps constructed form U.S. Geological Survey (USGS) 7 ½ minute

topographic quadrangle maps. In addition to the information carried on USGS maps, PBS maps contain

additional Forest Service information such as protracted Public Lands Survey System landlines, ownership,

Forest Service route numbers, administrative boundaries and facilities. The Softcopy PBS is a tool used for

administering and managing National Forest system and other public lands.

The Softcopy PBS should not be used to determine exact location of boundary lines due to the high level of

distortion and adjustment involved when creating them. Land survey crews are sent out with these maps to

provide them with an overview of the area only and use other recorded plat information in the determination of

boundary lines.

1 Kegley, Sandra J., R. Ladd Livingston & Kenneth E. Gibson. 1997. Pine Engraver, Ips pini (Say) in the Western United States.

USDA Forest Service Forest Insect and Disease Leaflet 122, 8pp.

15

All National Forest System property boundaries will be surveyed and posted to standard within the treatment

units prior to implementation, as discussed on page 82 of the EA.

TRAVEL MANAGEMENT

Comment 37: Travel management should be completed prior to or during the James Creek project.

Letters 7, 14, 19

Response:

The road system used in the design and planning of this project is the official road system and the same used in

the Forest planning process. There is one official transportation system for the ARNF. Travel management is

planned for this area in the near future. The decision was made to separate travel management from fuels

planning due to the increased emphasis and need for fuel reduction in light of recent fires on the Front Range.

Because of the controversial nature of travel management in Boulder County, these projects were separated to

maximize the potential of accomplishing and implementing the fuel reduction projects and reduce the

complexity in the planning process.

Comment 38: 3.5 management areas clearly indicates that no Ways will be converted into system roads,

no new roads or trails will be added to the system, and obliterations will occur.

Letter 14

Response:

The Forest Service will not be converting any unclassified roads (ways) to system roads or trail in 3.5

management areas. Any unclassified roads in management area 3.5 that are used during this project will be

obliterated and decommissioned. In the EA we are only addressing the roads to be used for the project. The

roads analysis for the project may make recommendations for the future management of roads to be analyzed

during travel management planning.

Comment 39: Access to units M3201 and H3101 is from 385.1, but there is no mention of acquiring a

right-of-way in Table 2.7 on page 18.

Letter 41

Response:

There is no need to acquire a right-of-way to unit M3201. Road Activities – Map B shows a proposed

temporary road located on NFS land to the unit and it is also listed on page 108 of EA as road “X”. Access to

unit H3101 will be in cooperation with interested individual landowners also working on fuel reduction efforts

on their private land and access could be arranged with the landowner or through the Colorado State Forest

Service at that time.

Comment 40: A new road is designated to access M3201. Acquire an easement through the Clay

property instead.

Letter 14

Response:

The Clay family will be contacted to determine their interest in providing permanent access to the United States

across their land.

16

Comment 41: Public will never benefit from 2 miles of improved system roads because they are behind a

locked gate and not accessible to motorized use.

Letter 6

Response:

Road maintenance is necessary to access the treatment units and prevent resource damage from erosion and

sedimentation. The ongoing upkeep of roads (road maintenance) within the project area is part of routine

maintenance for the Boulder Ranger District. Also, there is legal public access to the area from Riverside.

Comment 42: User-created roads have never been subject to travel management or NEPA and are not

legitimate use of funding to turn these into system roads.

Letters 6, 7, 14, 18

o We question the legality of adding user-created non-system roads (Ways) into the database

system as system roads without formal travel management process.

o It is not a legitimate use of Fuel Reduction Plan funding to turn these into system roads by

improving or maintaining them.

o Creating temporary roads – are there really funds to put them back to wild?

o Apparently the funds are not available to maintain current system roads. We infer that this

problem will only increase with the increase of roads in the inventory.

Response:

The decision to incorporate a user-created (nonclassified) road into the forest’s transportation system is made

during project specific NEPA and through travel management analysis. For this project, any user created roads

used to access treatment units will be obliterated after implementation. One nonsystem road is proposed to be

added to the Forest Transportation System as a result of acquiring administrative access to an isolated piece of

National Forest land. The addition is analyzed in this NEPA decision. Funding for this fuel reduction project is

distributed through the National Fire Plan from Congress. Funding levels can change annually, but Congress

has continued to fund fuel reduction activities across the nation. It is anticipated that funding for this project

will continue. Road work is an important part of fuel reduction projects. All changes to the Forest

Transportation System are supported by a Roads Analysis that is completed in conjunction with this project

analysis.

Comment 43: What is planned with Boulder County Road 87?

Letters 11, 6, 6A, 6B, 14, 20

o EA maps show Boulder County Road 87 continuing through Mark Boslough’s property even

though the Commissioners closed the road.

o When will portion of Boulder County Road 87 be re-closed and what is the future intent of this

area?

o (RAP) Exact route of 87 is ill-defined and has parallel roads. It is not clear which branch is in the

county right-of-way.

o Clearly state in the EA that the section of County Road 87 that is gated closed to the public will

remain the same.

o The plan calls for a very high density of improved and maintained roads in that small area

(county road 87), much greater than anywhere else in the management area.

o Object to major road construction planned in the northwest corner of sec 12 (near the end of

county road 87.

17

Response:

Boulder County Road 87 is closed to the public for motorized travel only, and has not been vacated as a county

road as it crosses NFS land. The Forest Service is using this road for administrative access to the treatment

units. It is up to the Commissioners and Boulder County Transportation Department to make future

recommendations regarding access on County Road 87. Any questions on the county right-of-way location will

be coordinated with the County Transportation Department. Some roads in the area are creating resource

damage and will be improved to reduce the negative impacts to these resources. See the Roads Analysis Report

in the Project File.

Comment 44: Clearly state in EA that the Golden Rule ditch will be used minimally.

Letter 14

Response:

Access along the travelway associated with the ditch will be used by prescribed fire implementation crews to

access treatment units. Access by crews will be by foot and ATV.

Comment 45: On page 107 in the EA change the “No name” road to “Owens Flats”.

Letter 14

Response:

A change will be made in the EA and also some of the road length dropped on the Road Activities – Map D to

reflect road rehabilitation work done in 2002.

Comment 46: Roads 254.1G, 254.1C and 297.1 either do not exist in the location shown or do not exist at

all.

Letter 6

Response:

These system roads exist, but may not be in the exact location as shown on the EA maps, which are based on

Softcopy Primary Base Series maps (Also, see response to comment 42).

Comment 47: The Golden Rule ditch is listed as a road on the EA maps.

Letters 1, 5, 6, 11, 14

Response:

The travelway associated with the ditch is on the Forest Transportation System and the future intent of the

travelway will be analyzed during a future travel management project.

Comment 48: (RAP) 254.1 exact location is ambiguous. The road just above intersection with 297.1 has

one of the largest Colorado Columbine patches and it will be a crime to take them out by widening the

road to 12 feet.

Letter 6A

Response:

18

Road 297.1 has no road maintenance planned with this project and will not widened to 12 feet. Road 254.1 will

be maintained for access by pick-up truck and fire engines; therefore, widening the road to 12 feet will not be

necessary to access the treatment units associated with this road.

Comment 49: (RAP) 254.1C is user created, not needed for fuel reduction and I strongly urge you to

convert it to a hiking trail. (6A, 20)

Letters 6A, 20

Response:

254.1C will be used to access the treatment units and the future intent of the road will be analyzed during travel

management planning in the future. Of all the roads in this area, road 254.1C is the least impacting to resources

and provides the easiest access to the ridge top.

Comment 50: (RAP) 254.1G – Rip and reclaim redundant branch or convert to a single track.

Letter 6A

Response:

Road 254.1G requires road improvement to minimized damage to resources including erosion and gullying.

The future intent of the road or parallel roads in the area will be analyzed during travel management planning in

the future.

Comment 51: (RAP) 297.1 – Widening to 12 feet will be unnecessary destruction of the environment.

Letter 6A

Response:

The Forest Service will not be widening road 297.1 to 12 feet for this project. Road maintenance will occur to

minimize resource damage and stabilize the road.

Comment 52: 268.1 - Doesn’t even exist

Letter 1

Response:

Forest Service Road 268.1 exists and is located outside of any proposed treatment units within Lefthand

Canyon Dispersed Recreation Area. It will be removed from EA map 17.

Comment 53: Two roads shown accessing treatment units RFB17 and PBFB4 are not roads.

Letter 5

Response:

There are several user-created (unclassified) roads and the exact location may vary from the EA map 14. These

roads do appear on the digital orthophoto quad for the area.

Comment 54: (RAP) Road 2103 shows on topographic maps but not on the Road Activities Map in the

EA nor the roads analysis (RAP).

Letter 7

19

Response:

Road 2103 that is shown on the Gold Hill Soft Copy Primary Base Series topographic map (dated 1978) was

renumbered years ago and is NFSR 374.1.

Comment 55: Correct the mistake in the EA on page 46 describing the “Jamestown Loop”.

Letter 19

Response:

The clarification will be made in the EA on page 46 regarding the Jamestown Loop road. The road is open to

non-motorized users and many users refer to this road as the “Jamestown Loop Road”.

Comment 56: Project area has high density of roads.

Letters 19, 24, 26

Response:

The affects of the density of roads within the project area were considered and analyzed for this project.

Alternative D was a proposal for no new roads. The affects of road impacts were analyzed in all alternatives

and compared to the No Action alternative. Refer to page 29, 37-39 in the EA.

Comment 57: I do not like the plans of new roads in our area even if the roads are temporary.

Letters 25, 20, 24, 26, 39

o Object to major road construction planned in the northwest corner of section 12 (near the end of

county road 87).

o No new roads please.

o My primary concern is the addition of roads to the area.

o The proposed new road construction and improvements to existing roads, like the road (373.3B)

by which I access my cabin, will seriously impact my property in particular and the area in

general.

Response:

Temporary roads are necessary to access treatment units for this fuel reduction project. These roads will be

closed and obliterated after they are used. Over three and a half miles of existing non-system roads will be used

and obliterated reducing the road density in the area. Every reasonable effort has been made to minimize the

construction of temporary roads.

Comment 58: There is also no mitigation measure requiring gating during operations.

Letters 3, 5, 7, 14

o We want this road (temporary road E) to be gated and keyed from the beginning to end of its

existence and during operations.

o We request access to this “V” road be blocked to public use during fuels treatment to prevent a

connection of an illegal-created route currently being made from the Owens Flat Road and that

the EA clearly states that.

Response:

20

All temporary roads will be closed to motorized use during project implementation. Gates or barriers will be

used to discourage use if needed, and road closure signs may be used to discourage motorized use. See

Mitigation Measures and Project Design Criteria, p.6). Also see Record of Decision, p. 5.

Comment 59: M0502 and M3202 are already abused by off road vehicles, and a new temporary road

and road improvements (376.1, 376.1a, and 376.1c) will exacerbate this problem by increasing access to

private property and land in the nature conservancy.

Letters 8, 14

o Residents in this area (720 County Rd 100 and 550 County Rd 100) have offered access through

their roads, and any machinery transported into this area could come in through these routes.

Response:

We plan to use system roads wherever possible; however, some temporary roads are needed to access portions

of units that are not reachable with the Forest System roads. We will pursue easements with these residents

after the decision has been made. Once an easement is acquired, trucks removing material, contractors, and

Forest Service personnel will be allowed on the road as well as any machinery moving into the treatment unit.

Roads will need to be constructed on private land for the operation to be completed and will remain in place if

an easement is acquired. Also see response to comment 74.

WATERSHED AND WATER QUALITY

Comment 60: Objects to the road that follows the riparian area of Long Gulch (a.k.a. Balarat Creek).

Improving the roads in the Long Gulch drainage will increase motorized vehicular traffic in an

ecologically sensitive area that has shown deterioration over the last 45 years. The roads have created

negative environmental impacts (e.g. soil compaction, erosion,…decreased water quality..).

Letters 1, 5, 6A, 6B, 20

Response:

Impacts of roads and potential increase in recreation in the James Creek Project Area is addressed in the

EA on page 61 and 65 and in more detailed discussion in the Watershed and Fisheries Specialists’ Report

located in the Project File at the Boulder Ranger District.

In general terms the improvements of these roads are being done under our normal maintenance program

of the roads and will decrease the watershed and water quality impacts from the roads themselves that

are currently occurring. The closure of County Road 87 will still be in place during and after the

treatments are implemented in this area so the level of traffic that occurs now should not increase in the

area. The roads in the Long Gulch area are Forest System Roads 254.1, 254.1C, 254.1G, and 297.1.

There was a typographical error on the maps that were included in the EA. Forest System Roads 254.1

and 254.1C are roads that will be used by the hand crews to access the treatment units in this area. These

roads will actually get normal road maintenance in order to get the hand crew vehicles (pick up trucks) to

reach the units. Forest System Roads 254.1G and 297.1 are roads that need to get normal road

improvement or be relocated during the travel management analysis and decision process because they

are not going to be used for the James Creek Fuel Reduction Project. For this project Forest System

Road 297.1 will get drainage maintenance (water bars, rolling dips, etc.) as needed to reduce the

watershed impacts of this specific road at this time. Looking at the long-term administration, need, and

location of this road will be addressed in the Travel Management Analysis for the James Creek Project

Area.

21

Comment 61: Concern about the location of the access road in relation to the wetland south of

unit MPB1. Will like to see the road that was flagged with Forest Service personnel on July 21,

2004 to be utilized for access into unit MPB1.

Letter 3

o Will like to have this temporary road obliterated and rehabilitated to the greatest extent

possible when treatment is completed.

o Will like to see the land returned to its complete natural state.

Response:

The best alignment of the road which will keep the access road a minimum of 100 ft. away from the wetland

will be utilized. The line flagged on July 21, 2004 may be utilized with some modifications to make

adjustments for the equipment and terrain. The road will be approximately 100 ft. from the wetland when it is

constructed and utilized. This will be a temporary road, which will be rehabilitated after the treatment of the

unit is completed. Among the mitigation measures described in the EA is one specific to wetlands that will be

followed in this unit as well as other units with wetlands present.

This will be a temporary road constructed to the treatment unit MPB1. The temporary roads will be

rehabilitated to reduce any short-term and long-term impacts from the construction of the road to the watershed.

The rehabilitation techniques utilized will bring the area back to a relatively natural state. After the

revegetation is complete the impacted meadow areas should look very similar to the sections of the meadow not

impacted by this temporary road. The forested areas that need to have trees cut will, of course, take many

decades to get trees of the same size to regrow. The roadbed will be rehabilitated so that the grassy meadow

vegetation could revegetate the road prism in the forested area.

Comment 62: Concerned about potential water contamination of Long Gulch (a.k.a. Balarat Creek) if

road maintenance is to occur near the Last Chance mining claims (a.k.a. Pine Shade), which has

contaminated soil from the past mining activity.

Letter 6

Response:

Location of past mining activity is taken into account when locating roads and when doing road

maintenance to minimize the potential for off-site pollution or contamination of streams, wetlands, and

water bodies in the Project Area. Depending on the type of past mining material left behind at a site also

influences how much potential for pollution there is. For example, if the mineral ore was milled on site

there will be fine waste materials left behind called tailings. These are generally the processed ore and

are more of a contamination concern than if the ore was milled off-site. If the ore was hauled away from

the mine site and milled elsewhere there will be waste rock piles left behind at the mine site. Waste rock

is generally less of a contamination concern because the ore has been separated from the waste rock and

these rocks are coarse waste materials left at the mine site.

Andrew Archuleta, Forest Abandoned Mine Lands Coordinator, field checked the roads in this area and

went to the Last Chance Mine. He found that there are several exploration pits in the area, an open

shallow adit, a shallow (approximately 30 ft deep) shaft, and areas of surface excavation and possible

drilling. There are mounds of waste rock, but he did not find any tailings or evidence of milling in the

area. The waste rock is primarily granitic and does not appear to be highly mineralized. He did not see

22

any mine features that will cause soil or water contamination as a result of maintenance or improvements

to Forest Roads 297.1 or 254.1G. With the exception of shallow exploration pits, the mine features are

not adjacent to either road. With this field reconnaissance it is felt that the roadwork will not cause a

water quality impact or soil contamination impact because the waste rock is not a contaminated rock

source.

Comment 63: Concerned about the water quality impacts of the road system especially due to the use of

the roads in the James Creek Project Area by off-highway vehicles (OHV). The EA notes that the

extensive road network and OHV use in the James Creek Project Area may be affecting water quality

and riparian areas (page 85). Please be mindful of this as you finalize the road system needed to

implement the fuel project and consider using a minimal road network to accomplish your goals.

Letter 14

Response:

The road network in the James Creek and Left Hand Creek watersheds is extensive as stated in the EA.

This includes Forest System Roads, private roads, county roads, state roads, and user created roads that

existed when the Forest Plan was revised in 1997. The Forest Service only has jurisdiction over forest

roads on National Forest System lands. Through the fuels reduction project there will be fewer roads on

National Forest System lands because the user created roads that the Forest utilizes for temporary roads

will be rehabilitated and closed after the units are treated. Overall, this will lead to a decrease in the road

network. Some units will need construction of new temporary roads that do not currently exist. Because

these will be temporary roads these too will be rehabilitated and closed after the treatment is completed.

The location of the road network and the maintenance to the Forest System Roads will be done such that the

Clean Water Act is met. Discussion of impacts of roads on water quality and watershed resources is located in

the EA on pages 58-61. More detailed description of the analysis is located in the Watershed Specialist’s

Report in the Project File at the Boulder Ranger District.

Comment 64: Also, please consider using your Emergency Closure to close roads that are currently

delivering sediment to these creeks and violating water quality standards.

Letter 14

Response:

The Forest Service will consider this type of action during the Travel Management Analysis in the area. The

Roads Analysis Report has identified recommendations on several Forest System Roads that will be addressed

in the Travel Management Analysis for James Creek Geographic Area. Closure of Forest System Roads is not

within the scope of the fuels reduction project; however, closure and rehabilitation of user created roads that are

used for temporary roads are within the scope of this analysis and will be rehabilitated after treatment.

Comment 65: Concerned about potential impacts to Fair Day Meadow in Unit RFB7 during treatment.

Please make sure that the area is identified in the EA as a past restoration area that will be protected

during fuels treatment.

Letter 14

Response:

23

Unit RFB 7 will be a manual (hand treated) unit where the fire crew or a hand crew will go into the unit and do

the thinning. The crews will be parking at the gate at the meadow and walking through the meadow to the

treatment areas. The treatment will be concentrated on the ridgeline surrounding the meadow and not in the

meadow itself or where the rehabilitation occurred on the hillside. Also, this fuels reduction work will be

coordinated with the clean up of the Fair Day Mine so that there is no conflict between the two projects.

Because this is a hand treatment concentrating on the ridgelines and not in the meadow and because of the work

on the mine clean up it is felt that the district personnel understand the sensitivity of the meadow and that it is

not necessary to include any additional statements about protecting the area in the project record.

Comment 66: Additionally, this increased access may lead to …and increased soil erosion and

sedimentation of creeks (p. 65). The EA further notes “that continued growth of off trail ATV use” (p.

67), and that routes for such use are “a source of sediment and may be affecting water quality and

riparian areas (p. 85). OHV trails are a source of sediment.

Letters 7 and 19

Response:

The disclosure of the effects in the EA is as you stated in your comment; however, in the sections under

Watershed Resources (pages 56-61) and Aquatic Species and Habitats (pages 65-69) the environmental

consequences of all the alternatives including the No Action (Alternative B) is discussed in more detail.

Admittedly, if there is an increase in trails and road density there is increased watershed impacts;

however, they are generally on a smaller scale than a wildfire as is locally evidenced by the post-fire

effects of the Overland Fire which occurred in Jamestown, CO.

As discussed in the Watershed Resources section of Chapter 3 in the EA potential sedimentation is far

greater due to wildfires than to the potential increase in recreational uses in the Project Area. More

detailed analysis and description of these impacts can be found in the Watershed and Fisheries

Specialists’ Report in the Project File at the Boulder Ranger District. Some of this information includes

the post-fire research conducted in the Front Range (Benavides-Solorio and MacDonald, 2001) and other

post-fire research (Debano et. al. 1996 and Robichaud et. al. 2000), which indicated the level of erosion

that occurs following fires. Generally, post fire erosion and potential sedimentation is greater than the

erosion and sedimentation that could be generated by the treatments as described in the EA in Chapter 3.

More detailed analysis is in the Watershed and Fisheries Specialists’ Report in the Project File at the

Boulder Ranger District.

The specific ratings of the impacts of the different alternatives to watershed and fisheries resources are outlined

on pages 56-61 and 65-69 of the EA. In general, the analysis has outlined and disclosed the potential impacts to

water quality, specifically with regard to sedimentation with or without treatment. This information is available

for the Responsible Official to use in their decision making process.

Comment 67: The James Creek Fuel Reduction needs to be accountable to the guidelines identified in

the Forest Plan. The project needs to be accountable to the Clean Water Act.

Letter 14

Response:

The James Creek Fuel Reduction Project EA was planned and designed to comply with Forest Service policy,

all applicable laws including the Clean Water Act and Standards and Guidelines described in the 1997 Revision

24

of the Land and Resource Management Plan for the Arapaho and Roosevelt National Forests and Pawnee

National Grasslands (see ch.1, p.13-15 and ch. 3, p. 91-143). There is more detailed analysis in the Watershed

and Fisheries Specialists’ Report located in the Project File at the Boulder Ranger District.

WILDLIFE

Comment 68: The project will disturb wildlife habitat.

Letters 5, 16, 26, 39

o The proposed treatment will degrade and destroy habitat for a number of wildlife species.

o Clear cutting and mechanical cutting will not maintain a forest that can sustain and enhance

wildlife populations.

o Road construction will lead to increased ORV use that will have a dramatic adverse impact on

native wildlife.

o M0502 and M3202 should be thinned by hand to avoid tearing up steep slopes and disturbing a

bear cave in the vicinity.

Response:

The project is designed to enhance wildlife habitat. Estimated effects indicate generally improved habitat

conditions and only short-term, temporary disturbance and/or displacement of individual animals. Both habitat

and inhabitation by wildlife are expected to quickly respond. Forest thinning will improve habitat for numerous

species. Increased human disturbance associated with road construction and project operations will be

temporary. Public use of temporary roads during implementation will be discouraged and temporary

constructed roads will be closed and obliterated after implementation. Since temporary roads will be closed,

habitat effectiveness will be maintained as a result of project activities. The details of proposed treatments and

effects on wildlife species and habitat were considered and analyzed in the Biologist Report.

Comment 69: Management Indicator Species (MIS) and Forest Service Sensitive Species were not

adequately analyzed.

Letter 17

o The Forest Service must designate and monitor MIS and sensitive species.

o Determinations of effects are based on effects to habitat rather than effects to populations.

o The flammulated owl and the northern three-toed woodpecker are listed as MIS for the Forest,

but were not chosen as MIS for this project.

Response:

The 1997 Revised Forest Plan (FP) designates MIS and describes the monitoring approach. Population

monitoring of MIS is conducted at a scale broader than the project, at the Forest level.

The environmental analysis (EA) summarizes effects by alternative for various species. Discussions in the EA

only display that certain species have Forest Plan MIS status, but does not discuss the selection and analysis of

MIS for the project. MIS selected for the project are analyzed in detail in the Biological Report for wildlife.

The summarized information in the EA is consistent with the detailed information in the Biological Report.

From the entire FP MIS list, four project MIS were selected based on likely influence to the species or habitat,

and analyzed as MIS. Selected MIS for the project are boreal toad, elk, pygmy nuthatch and warbling vireo.

For MIS, changes to populations as well as habitats are estimated, and Forest-wide population trends are

considered. Forest-wide population trends of the four MIS selected for this project are referenced in the

25

Wildlife Biological Report (pages 38-42). An editing error occurred in the review EA that used an incorrect

table to display the selected MIS species for this project. The correct table was used in the Biological Report

and the findings and impacts in the EA were based on that report. The correct information is listed above and

the EA Table 3.11 has been edited.

Forest Service sensitive species and Forest Plan (FP) MIS were considered for analysis. All sensitive species

(some of which are FP MIS but not selected as project MIS) having habitat in the project area and/or potentially

influenced by the project were analyzed as sensitive species. This is the case for flammulated owl and three-

toed woodpecker. For sensitive species, determinations of viability are estimated.

Determinations for sensitive species (population viability) and effects to MIS (population changes) are

estimated considering both expected human activities and habitat changes, since these are the factors of

influence for the project. For a complete discussion of species considered and estimated effects due to the

project on certain species, see the Biological Report for wildlife (on file in the Boulder Ranger District Office).

Comment 70: Goshawk nesting areas need more attention.

Letter 19

o Potential nesting areas should be thoroughly surveyed for nests before ground-disturbing

activities.

o Approximately 420 acres surrounding active or inactive nests should remain untreated for use in

post-fledgling training.

Response:

The wildlife biologist identified potential habitat in the project area, and all identified areas were thoroughly

surveyed. Table 2.1 of the Environmental Assessment states that goshawk nest monitoring will take place

during project planning, layout, and implementation. Any known or discovered active nest sites will be

protected according to recommendations or mitigation measures stated in the Biological Report and EA. Also,

see the Mitigation Measures in Appendix A.

Comment 71: The project area is important elk habitat. Letters 5, 6, 17, 19, 39

o The creation of new roads, improvement of existing roads, and the difficulty of closing roads will

decrease the already low habitat effectiveness for elk.

o It is likely that the security of elk winter range will decrease as a result of project activities.

o The Indian Peaks elk herd uses Section 12 T2N R72W as part of their migratory corridor.

o The high density of roads in this elk migration corridor will have negative impacts on this

animal’s habitat.

o Manual thinning will be most appropriate in elk habitat.

Response:

Effects of the project to elk were considered during the planning process. See the Biologist Report for wildlife

on file in the Boulder Ranger District Office for the complete analysis. The Colorado Division of Wildlife

reviewed the Biologist report. The analysis determined that treatments will have beneficial effects to elk habitat

due to an increase in forage and structural diversity. No changes in population numbers are expected as a result

of project activities. Timing mitigations are in place to protect elk during calving and on winter range.

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Road construction or improvement will displace elk temporarily but not permanently. Road improvements will

not require major construction or removal of vegetation currently providing habitat. All improved roads will be

maintained at the current maintenance level so use will not change as a result. All new temporary roads will be

closed and obliterated after implementation and uses other than fuel treatment will be discouraged during

implementation.

Comment 72: Thinning in lynx habitat may delay future thinning projects Letter 17

o Intense thinning during the project will lead to dense regeneration that will need to be thinned in

10-20 years. Lynx habitat considerations may delay that thinning.

Response:

There are approximately 325 acres of lynx habitat within the James Creek project units. Of those 325 acres,

approximately 20 acres are patch cut units. In the patch cut units, dense lodgepole regeneration is expected to

begin establishing within 10 years after cutting. In stands where thinning will be implemented, trees will

generally not be spaced far enough apart to promote extensive regeneration in this entry. At the time when the

regeneration areas (patch cuts) need to be thinned, it is possible that thinning may or may not be allowed due to

management restrictions in lynx habitat.

Comment 73: Construction of temporary roads will lead to increased traffic, which will have an adverse

impact on native wildlife.

Letters 5, 13, 26, 19, 39

Response:

Discussion in the Biological Report for wildlife indicates that only temporary disturbance will occur due to

roads, and habitat effectiveness will be maintained. Also see responses to comments 68 and 71.

INCREASED USE

Comment 74: To open up this area for more motorized traffic is a major concern.

Letters 1, 7, 16, 19, 25, 26

o New roads could increase potential for OHV use, causing erosion and increased fire danger from

existing fire rings and campsites. Treatment will increase the potential for OHV use, and reduced

vegetation will induce the creation of new trails.

o The plan, as it now stands, the roads to be developed, will be devastating to this environment.

Dirt bikes, ATV’s, four-wheeler’s and campers, already a problem, will ruin this protected area.

o … thinning, combined with whole tree skidding (with little to no slash left in the woods) will

facilitate off-road, off-trail motorized recreation.

o New roads mean more people destroying our area and more four wheelers and off roaders going

places that they will not be going before.

o My primary concern is the addition of roads to the area. ORV use is growing exponentially and I

am concerned that the construction of temporary roads will lead to those areas being opened up

(legally or informally) to ORV traffic which will have a dramatic adverse impact on native

wildlife. And affect the quiet enjoyment of the area.

Response:

27

Alternative D was designed in response to the concerns for increased access and use due to vegetation

treatments and road construction. Alternative A with Modifications will obliterate and close 1.4 miles of non-

system roads in the Owens Flats area and 3.5 miles of non-system roads will be obliterated and closed at the

conclusion of the fuel treatment within the specific unit. Along system roads a 50’ buffer with less intense

thinning will be in place to minimize off road motorized traffic. Additionally, treatment units were designed

around existing System Roads. Furthermore, all temporary roads will be closed and obliterated to prevent

further motorized use.

Comment 75: Many off-road enthusiasts know the closed portion of CR87 and I fear some may take

these improvements and maintenance as a reason to re-enter this non-motorized area.

Letter 5

Response:

Road improvements or maintenance is proposed only for Forest System Roads. We are maintaining County

Road 102J and it is likely that these roads will result in increased use and/or maintain existing use. All Forest

System Roads are open to the public unless they are closed by a special order.

Comment 76: The claim is these roads (temporary roads) will not be available to the public at any time.

Trouble is, the OHV’s won’t care about that, the roads follow the ski and hike trails we currently use,

and will thereafter be prohibited from using. Although they will be closed at the end of the project, they

will only be blocked “if needed.”

Letter 7

Response:

A correction was made on page 17 of the EA, “These roads (temporary roads) will not be available to

motorized access”. Hence, motorized use will not be permitted in these areas. Other kinds of recreation, such

as hiking and cross-country skiing will be permitted. Closing (temporary roads) involves obliteration following

fuels treatment activities. The definition of obliteration was added to the glossary. See Appendix D - Glossary,

pages 109-112.

Comment 77: Constructing new roads and improving existing ones (system and non-system) will increase

the travel opportunities and the associated adverse impacts, and make roads difficult to close and

obliterate.

Letters 8, 7, 6, 6B, 14, 17, 20, 39

o Improving non-system roads will make them even more difficult to close and obliterate, especially

if they are widened to 12 feet as proposed.

Response:

Temporary (new) roads will be obliterated following fuels treatment activities. The intent of obliteration is to

discourage use. Road maintenance is proposed only for Forest System Roads and it is likely that these roads

will result in increased use and/or maintain existing use. These roads will be maintained at a design width of 12

feet. Many of the roads have narrowed due to erosion or encroachment of existing ground cover and have not

been maintained for a number of years. Some non-system roads may be improved to access and treat units, and

then they will be closed at the conclusion of the fuel reduction treatment. All Forest System Roads are open to

the public unless they are closed by a special order. Temporary roads will be located on exiting non-system

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road prisms if they are available and in areas where rock, terrain or vegetation will discourage bypassing the

closures (See Record of Decision, p.6.)

Comment 78: The vegetation, soil and beauty of the area, including the wetlands, will be in extreme

danger if unauthorized motorized vehicles began to use the area for road or off-road recreation.

Letter 3

Response:

We have attempted to design this project to minimize the potential for damaging uses after treatment. See the

other responses in this section, “Increased Use,” for more information.

Comment 79: OHV users already access marked and unmarked roads on Burnt Mountain. New and

improved roads will increase that access.

Letter 7

o We also insist that the currently unimproved and unusable portions of 373.1 be closed at the end

of treatment to reduce illegal OHV use.

Response:

OHV use on all Forest System Roads is legal unless roads are signed otherwise. Temporary (new) roads will be

obliterated following fuels treatment activities. The intent of obliteration is to discourage use. Road

improvements or maintenance is proposed only for Forest System Roads, and it is likely that these roads will

result in increased use and/or maintain existing use. Some non-system roads may be improved to access and

treat units, and then they will be closed at the conclusion of the fuel reduction treatment. All Forest System

Roads are open to the public unless they are closed by a special order. The southern portion of the loop on

Road 373.1 from the cabins at the east end to the point where Road 373.1 converges will be blocked to

discourage motorized use. When travel management is analyzed in this area, it will be re-evaluated at that time.

Comment 80: There seems to be little doubt that recreation abuse already occurs in the project area.

This will likely get even worse because of the new and improved roads, and the difficulty of closing them,

as discussed in section II.

Letter 19

Response:

Temporary (new) roads will be obliterated following fuels treatment activities. The intent of obliteration is to

discourage use. Road improvements or maintenance is proposed only for Forest System Roads and it is likely

that these roads will result in increased use and/or maintain existing use. All Forest System Roads are open to

the public unless they are closed by a special order.

SCENERY

Comment 81: Clearcutting will indeed have some impact on scenery, and I think you may have

underestimated how long it will take for new growth to get going.

Letter 4

Response:

29

The affects of patch cuts (clear cutting) on scenery in the Proposed Action and Alternative C are designed to

meet the Forest Plan high and moderate Scenic Integrity Objectives. New growth has appeared in the second

growing season in the patch cuts on the Winiger project, south of Boulder Canyon. Lodgepole seedlings,

though small, have also emerged within the treated area. Please see Specialists Report for the Scenery

Resource, dated February 2004, and the Record of Decision.

Comment 82: I am also greatly concerned with the visual impact on the scenery of Units O0401, O0402

and O0403. Letters 6, 7

Response:

The affects of Units O0401, O0402 and O0403 on the scenery resource in the Proposed Action and Alternative

C, and Unit O0401 in Alternative D are designed to meet the LMRP moderate scenic integrity objectives. See

Specialists Report for the Scenery Resource, dated, August 2004, page 16. Additionally, project design criteria

for Unit O0401, and mitigation measures for all units are included in Appendix A - Project Design Criteria and

Mitigations.

Comment 83: The standard of flush cutting trees and a maximum of 6” stump will apply to all of Burnt

Mountain although that is not clear in this language document. Letter 7

o The key element noted in the EA is openings that are visible from key viewpoints. Since our part

of Burnt Mountain is not visible in the foreground from viewpoints, there will not be as great a

concern with the appearance.

Response:

Your comments resulted in additional scenic analysis and documentation for the Burnt Mountain area; analysis

included the affects of the Proposed Action and alternatives on the scenery resource from Road 373.1. The

above referenced mitigation (Appendix A) has been revised to reflect this analysis, and is included below:

In all mechanical and/or thinning units, tree stumps should be flush cut or cut as low as possible (maximum

height 6”) in foreground Retention and Partial Retention areas if treatment areas are visible from system roads

or trails, including the Peak-to-Peak Highway, Lefthand Canyon Drive, and/or the Switzerland Trail. The

District Landscape Architect will field verify visible areas, and train implementation crews, as needed, on

stump cutting technique on flat and sloping ground.

Mitigations are addressed in Appendix A - Project Design Criteria and Mitigations. For more information refer

to the Specialist’s Report for the Scenery Resource.

Comment 84: The management emphasis described in the EA indicates that scenery (3rd

) and residential

(5th

) concerns are not high on the list. Public lands adjacent to our properties are part of the

homeowner’s experience. We value the scenic quality, the views and the natural habitat. Our quality of

life will be negatively impacted by the implementations of this plan. Letter 7

Response:

30

The effects of implementing the Proposed Action and/or alternatives and residents within the project area were

addressed in the Specialist’s Report for the Scenery Resource, pages 5-9 and 21.) The inclusion of resident

concerns, desires, values and expectations helped interdisciplinary team members formulate overall alternative

designs and treatment prescriptions and were considered by the Deciding Official before the decision was

made. The design of this project and the anticipated effects are within the scope of activities and impacts

analyzed in the 1997 Revised Forest Plan.

Comment 85: Intense thinning of stands will certainly violate the retention VQO, and probably the

Partial Retention VQO as well. Patch cuts will not meet either VQO. And certainly the combination of

patch cuts and intense mechanical thinning in the Burnt Mountain area, will not meet the VQO of partial

retention.

Letters 7, 19

Response:

The effects of the Proposed Action and the alternatives on the scenery resource within the project area are

discussed in Chapter 3 of the EA. In summary, with project design criteria and/or mitigation measures in place,

the effects of thinning and patch cuts will meet the Retention and Partial Retention VQOs. However, in the

Burnt Mountain area, and as a result of additional analysis of the effects from Road 373.1, the proposed

treatment for unit M0501 was modified in the Record of Decision, p.2 and will meet the Partial Retention visual

quality objectives as viewed from Road 373.1. Additional analysis and discussion with the scenery resource

and Burnt Mountain has been included in the Specialist’s Report for the Scenery Resource, dated August, 2004,

and is addressed in the Record of Decision.

Comment 86: Mechanical thinning and patch cuts will result in reduced scenic quality due to slash piles,

stumps, equipment staging areas, not to mention temporary road excess slash left behind and burn pile

residual.

Letter 7

Response:

Yes, this is correct. However, mitigation measures are designed to ensure that the affects from management

activities on the scenic resource meet the Retention and Partial Retention VQOs (see Appendix A – Project

Design Criteria and Mitigations). Also see response to comment 1.

Comment 87: According to the EA, slash piles visible in foreground Retention areas should be burned

within one year of treatment. Burnt Mountain is in the Middleground Partial Retention area, and we

have no guarantee that the burning will be done within a year.

Letter 7

o Burn piles, especially in landing zones will be a terrible eyesore. It is not clear in this document

that the one-year maximum will apply.

o Slash piles in “visible foreground retention areas” should be burned in one year. … this standard

will apply to Burnt Mountain even though it is middleground partial retention area that is not

visible. However, the EA does not say this. We will like a commitment to this approach

o Slash piles visible in foreground retention areas.

Response:

31

You are correct, slash piles visible in foreground Retention areas should be burned within one year following

treatment. The Burnt Mountain area is in foreground Partial Retention, and slash piles visible from trails or

roads in foreground Partial Retention areas should be burned within three years. This mitigation measure was

added to Appendix A - Project Design Criteria and Mitigations. Also see responses to comments 1 and 7.

Comment 88: Remnants of burn piles will remain and affect the scenic quality of the area.

Letter 7

o The huge slash piles and the remnants of piles that will remain after burning will have an

extremely negative effect on the scenic qualities of Burnt Mountain.

o The slash piles will be a tremendous degradation of the scenic quality until they are burned. We

can expect that some of the material will not burn, and will be left on the ground, impacting

scenic quality for years.

Response:

You are correct; the amount of residual material that does not burn in a slash pile may not meet the objectives in

foreground areas of moderate and high Scenic Integrity. Typically 85-95% of all material in a slash pile is

consumed during combustion. Residual material on the perimeter of the burn pile is raked into the center to

facilitate complete combustion. Your concern has resulted in a mitigation measure to minimize the potential

impacts to the scenic resource. The following mitigation was added to Appendix A - Project Design Criteria

and Mitigations.

Residual slash pile material that is not consumed during pile burning will be scattered to meet soil rehabilitation

or ground cover requirements and Scenic Integrity Objectives in the treatment area.

Comment 89: Violations will likely not be temporary, as slash and stump; plus other remains of logging

(skid trails or other pathways, and trash) underneath a very open stand will remain on the landscape for

a long time. Wood does not decompose rapidly in the area. Because of the above, we believe that the

EA’s analysis (pp. 40-43) greatly understates the impacts on scenery likely to occur from implementation

of the action alternatives, especially the preferred alternative. The statement on p. 43 that the scenic

integrity of the area will increase in the treated areas is simply false.

Letters 7, 19

Response:

There will be evidence of fuel reduction management for many years past the initial treatment, possibly until

the next fire passes through the area. In very dry environments, such as ours, decomposition may be

exceedingly slow, with relatively little change in the slash litter other than oxidation and minor fungal

decomposition. Skid trails will be visible at different levels depending on the amount of use each one requires.

See definition of scenic integrity in Appendix D.

Comment 90: “Pockets of severely burned areas are expected” (p.14). These areas may need

rehabilitation to meet the visual quality objectives. Letter 7, 19

Response:

Direct effects of the scenic quality will be anticipated due to the blackened ground, and in some areas due to

clumps of blackened tree trunks and branches. However, the burned clumps will not dominate the landscape,

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will appear as a natural event, and therefore will meet the Retention and/or Partial Retention VQO’s. Refer to

discussion on page 41 of the EA.

Comment 91: Where are the proposed landings and how large are they? Letter 21, 18

o The landing area near Smitty’s home could be a danger to him not to mention ruin his view.

Response:

All of the landings will be located within the boundaries of the treatment units. They will vary in size

(generally 1/4 to 1 acre) and be dependent on the intensity of the treatment within the unit. The landings are not

identified and generally left up to the contractor to identify with Forest Service approval during

implementation. The EA identified only those landings in areas near proposed patch cuts, and patch cuts are

not proposed near Smitty’s home. See response to comment 2.

Comment 92: No landing zones within 500 feet of Burnt Mountain property line.

Letter 7

o No landing zones visible from 373.1 on Burnt Mountain.

Response:

The proposed treatment in this area has been modified (see Record of Decision, p.2) and will meet the Partial

Retention visual quality objectives as viewed from Road 373.1. Landing zones will be located out of view as

much as possible while meeting the partial retention guidelines. In Partial Retention areas, landing zones for

the treatment units will be visible for a relatively short time, between two and three years (see response to

comment 87).

SOILS

Comment 93: The treatments will not retain sufficient amounts of wood on site.

Letters 23, 25

o “Sensible ecology requires that dead wood remain throughout the forest to protect the earth from

runoff and regenerate the soil”

o “Instead of creating large burn piles, wood should be scattered to rot and rebuild the soil”

Response:

Downed wood plays an important role in nutrient cycling and erosion protection. Retention of at least 50 linear

feet/acre of coarse woody debris is required to meet Forest Plan requirements (Page 19, 1997 Revision of the

ARPNG Land and Resource Management Plan). More than 50 linear feet/acre is highly likely to remain on site

following treatments. Some limbs and needles will break off trees during felling and skidding, providing fine

downed wood (slash) to remain on site following treatment (EA, p.63). Downed wood retention is balanced

against fuels reduction goals in the planning process.

Comment 94: Proposed activities will jeopardize soil productivity.

Letters 7, 18, 19, 39

o “Large staging areas (up to 10 acres in size) will result in large areas of compaction and possible

erosion”

33

o “The proposed mechanical thinning prescription allowing 15-25 foot spacing will arguably violate

the following provisions of the planning regulations:

Conserve soil and water resources and not allow significant or permanent impairment of

the productivity of the land

Minimize serious or long lasting hazard from erosion”

o “Thinning leads to exposure of mineral soil”

o “Sites most sensitive to loss of soil productivity by operation of heavy equipment are rocky,

shallow, coarse textured soils with thin surface layers and low organic content. These are the

conditions on Burnt Mountain and these soils are particularly vulnerable if the surface layer is

disturbed or removed”

o “Three passes of heavy equipment will cause compaction. According to the EA, we are prepared

to accept the loss of up to 15% of the soils and there is no plan for full mitigation. Detrimentally

compacted portions of skid-trails will be considered for tilling within 100 feet of the landings,

leaving many skid-trails untreated. Due to long recovery periods, compaction is considered to be

an irretrievable impact”

o “Due to long recovery periods, soil erosion is considered to be an irretrievable impact”

o “Proposed patch cuts on Burnt Mountain do not reflect the ecology and elevation of the area.

Exposure to wind, short growing season and shallow top soil are not taken into account in the

current proposal”

Response:

The Burnt Mountain Area is in the upper montane climatic zone. North and west facing slopes are exposed to

high winds, increasing the potential for windthrow. Area soils are commonly shallow, rocky, coarse textured,

have thin surface layers and low organic content (EA, p.62). These soils currently support dense mid-seral

stands dominated with lodgepole pine with minor components of other conifer species and aspen. Past

disturbance caused by timber harvesting operations in similar environments throughout the Front Range have

not impacted soils to the extent that they lose the capability to support the forested environment that existed

prior to treatment.

Disturbances such as fires and windthrows occur in cycles characteristic of the climate, soils, and species. Both

of these disturbance mechanisms for lodgepole pine are characteristic in this area. With the expansion of the

urban interface deeper into forested ecosystems, the threat of fire and destruction to personal lives and property

increases. This project is addressing the threat through vegetation management (ie. thinning and patch cuts).

Patch cuts resemble natural processes more so than thinning in lodgepole pine. Ecologically, disturbance is key

whether it’s through natural processes or human caused. The forest is a dynamic system. Stands were

evaluated and the most effective treatment prescription will be applied to meet the purpose and need, adhere to

the Forest Plan standards and guidelines, and account for the specific site conditions.

The primary objective of Watershed Conservation Practice 14.1 (FSH 2509.25) is to maintain long-term soil

productivity by limiting detrimental soil impacts to less than 15% of an activity area.

Detrimental compaction is defined as a 15% increase in soil bulk density (FSH 2509.18_2). Where detrimental

compaction occurs, it is likely to take 50-100+ years to recover naturally. However, area soils are not highly

susceptible to compaction and, under dry soil conditions, detrimental compaction is only likely to occur on

landings and primary skid trails (EA, p.63). Detrimental erosion is defined as any indication of sheet, rill and

34

gully erosion (FSH 2509.25). Retention of ground cover to meet requirements, outlined in the Soil

Management Handbook (Forest Service Handbook 2509.18_92_1), minimizes potential for soil erosion.

No more than 15% of an activity area will be left in a detrimentally compacted, displaced, puddle, severely

burned and/or eroded condition. This does not include the permanent transportation system. If the extent of

detrimental soil impacts exceeds this limit, mitigation measures must be applied to ensure compliance.

Watershed conservation practices and mitigations to minimize detrimental soil impacts are outlined Forest

Service Handbooks 2509.25, 2509.18, and the mitigations section of the James Creek EA on pages 99-100.

Implementation monitoring will be conducted during and following implementation to determine compliance

with the Watershed Conservation Practices. Pages 9 and 10 of the James Creek EA contain a table showing

monitoring commitments for the James Creek project.

Comment 95: Revegetation following home construction

Letter 7

o “Where we disturbed soils during home construction, there is little recovery after 2 years”

o “High elevation, wind erosion and sloping ground made re-vegetation difficult”

Response:

The soils report acknowledges the relative sensitivity of shallow, rocky and coarse textured soils to disturbance.

However, the degree and extent of soil disturbance, mitigation measures and recovery associated with home

construction was not analyzed in this document.

Comment 96: “Fuels reduction activities in the Fair Day Meadow area will damage previously restored

lands, resulting in erosion and sediment entering James Creek”

Letter 14

Response:

Fuels reduction activities will not be implemented on the restoration site.

Comment 97: “At 9000 ft+ , building 12 ft road beds for use by logging tractor trailers will result in an

irreversible and irretrievable impact on soils. On Burnt Mountain, using existing road beds and

traveling through areas already significantly impacted is an imperative”

Letters: 7, 1, 5, 39, 19

o “New roads could increase potential for OHV use, increasing soil erosion hazard”

o “Grading for tractor-trailer access vs grading for a rubber tired skidder is will cause excessive

erosion, damage and recovery will be limited by elevation”

o “The currently usable portions of Road 373.1 should be maintained to reduce erosion”

o “Existing user created roads have eroded and improving them is not necessary”

o “Compaction, erosion and drainage problems exist on system and non-system roads in the

87J/Long Gulch Area”

o “Proposed new road construction and improvements to existing roads will increase OHV use,

causing erosion”

o “Current OHV use, dispersed camping and user created trails increase soil erosion”

o “Project area system road density is 3.9 miles/square mile. System and Non–system road density

is 6.1 miles per square mile. High road density causes soil compaction and erosion”

35

o “New roads and improvement of existing roads could increase dispersed and motorized

recreational use of the area, increasing soil erosion and sedimentation of creeks”

Response:

This response addresses roads used to access James Creek fuels reduction units. These include existing Forest

Service system roads, proposed new temporary roads and non-system roads. Activities include road

maintenance, construction, closure and obliteration.

The designated/permanent transportation system provides access to private property, access for forest

management and fire suppression activities, and public access to National Forest lands. On National Forest

lands, all system roads are open to the public unless closed by special order.

Roads are generally heavily compacted to function as roads, not productive vegetation growing sites. Proper

road location, design and maintenance reduce erosion from these surfaces and minimize their impact on

watershed health.

Where possible and practical, existing road will be used to access units. System roads may be maintained to

provide access to units. Maintenance is done under contract as part of the Forest’s road maintenance program

and may include grading the road surface, improving road drainage and / or widening to 12 feet. Depending on

the existing stability of the road, grading and road drainage improvements may decrease erosion, sedimentation

and other road related impacts.

Temporary and user created roads are not part of the permanent transportation system. Temporary roads are

created to access treatment units. The project proposes the creation of temporary roads and these roads will be

obliterated as needed following treatment (EA, p.101).

Obliteration (EA, p.111), involves de-compacting and re-contouring the road prism, and applying erosion

control measures to stabilize the area and promote natural re-vegetation of the roadbed. Road obliteration

removes adverse soil impacts, reduces potential for illegal expansion road/trail network and sets the stage for

natural re-vegetation of the roadbed.

User created roads and trails exist throughout the James Creek Project area and, based on current use patterns,

there is potential for illegal expansion of the network of user created roads and trails (EA, p.45). The James

Creek EA also acknowledges direct and indirect effects of roads and trails on soil productivity and watershed

hydrology (EA, p.64). However, full analysis user created roads and trails is outside the scope of the James

Creek Fuels Reduction Project and will be fully analyzed in future Travel Management Planning.

Comment 98: Burning piles and the effects on soils were not adequately analyzed.

Letters: 7, 8, 14, 18, 19, 39

o “Burning very large piles will cause damage to underlying soils…high temperatures are likely to

sterilize soil by killing all micro-organisms and creating a water-repellent layer”

o “Slash piles should be no larger than 10 ft in diameter and 4 ft high to limit soil damage”

o “Soil underneath piles of any size must be tilled to break up hydrophobicty and compaction

caused by fire”

o “Scarification of landing piles will mix remaining topsoil with lower layers”

o “Burning of large slash piles could cause soil erosion”

36

Response:

For the purposes of this analysis, it is assumed that, regardless of pile size, pile burning creates a high burn

severity impact due to heat and residence time of the fire. Larger piles do generate more heat and burn longer.

Formation of water repellent layers and mortality of microorganisms is likely to occur but the extent of these

impacts is limited to the burn pile site. One large pile impacts less ground (area) than several small piles. In

units where trees are processed on a landing, the burn pile is also created on the landing and burn pile impacts

are limited to that site. Additionally, landing sites are generally flat, reducing erosion potential. The primary

objective of Watershed Conservation Practice 14.1 (Standard 13) is to maintain long-term soil productivity by

limiting severely burned areas to less than 15% of an activity area (FSH 2509.25). Mitigations such as

tilling/scarifying will promote recovery by breaking up water repellent layers and increasing water infiltration.

Distributing woody debris on the burn pile adds some protective ground cover and provides organic material for

decomposition, jump-starting nutrient cycling processes. Also see response to comment 1.

BOTANY/NOXIOUS WEEDS

Comment 99: Invasive plant species have the ability to colonize areas that have recently been disturbed

Letters 5, 19

o With the amount of roadwork to be performed and the amount of acres to be treated, invasives

will certainly need to be managed so as not to lose our native plant and animal communities.

o It is very important to take whatever steps are necessary to prevent or greatly reduce the

introduction and spread of noxious weeds from project activities.

Response:

Vegetation treatments will produce disturbances that could increase the risk of invasion by noxious weeds. The

project will address this risk through prevention, inventory, monitoring and treatment as outlined in the invasive

plant specialist report and the mitigations in Appendix A of the Environmental Assessment. Most potential

treatment areas were inventoried for weeds in 2002, 2003, or 2004 and identified occurrences were mapped.

Mitigations include pre-project activities to prevent the spread of known occurrences of noxious weeds,

directions for activities during project implementation, and post-project activities to address monitoring and

treatment.

Comment 100: Weeds should be eliminated prior to project implementation. Letters 7, 19

o There is a need for a proactive plan to eliminate weeds before treatment and prevent weed

infestation during and after the project.

o It is best to eliminate as much of the existing weed populations as possible before beginning

treatment.

o High priority weed occurrences are not defined in the EA, so it is impossible to tell what

percentage of occurrences will be treated prior to fuels treatment.

o All treatment units should be surveyed for weeds prior to project implementation and any weeds

should be treated and eliminated as much as possible.

Response:

As the comments indicate, control of noxious weeds is an important issue in planning this project and treatment

of as many populations as possible before implementation will provide the best control. Most treatment units

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for the James Creek Fuel Reduction Project were surveyed for noxious weeds in 2002, 2003, and 2004. Given

the abundance of weeds in the project area, it may not be possible to treat all occurrences prior to project

implementation. In order to make best use of available resources, occurrences have been prioritized by

treatment unit based on aggressiveness of the species, current area occupied, potential to eliminate the species,

and status according to the Colorado Noxious Weed Law (see the Invasive Plant Specialist Report on file at the

Boulder Ranger District). Approximately 20% of treatment units in the project area are rated as having high or

very high estimated risk. Since fuels treatments will be spread over several years, it is possible that weeds in

units with an estimated risk rated as low or moderate may be treated or eliminated before ground-disturbing

activities begin in those units.

Comment 101: Heavy equipment is likely to introduce noxious weeds. Letters 3, 7, 39

o Equipment might introduce noxious weeds to the area.

o Because of the shallow, nutrient-poor soils in the area, native vegetation will not be able to

compete.

o Machinery should be washed before entering MPB1 to prevent the introduction of weeds where

they do not occur now.

Response:

Heavy equipment may spread noxious weeds from one site to another. Project design criteria and mitigations

are listed in Appendix A of the EA and include pre-project activities to prevent the spread of known

occurrences of noxious weeds, directions for activities during project implementation, and post-project

activities to address monitoring and treatment. The Invasive Species Specialist Report states that clean

equipment should be used in unit MPB1.

While disturbance does increase the risk of invasion by noxious weeds, the occurrence of shallow, nutrient-poor

soils in the project area does not necessarily increase the risk of establishment of noxious weeds. Many native

plants in this area are adapted to shallow, nutrient-poor soils.

Comment 102: Burning may encourage weed infestation.

Letter 7

o Weed infestations may occur after intense burns.

Response:

Intense burns from prescribed fires, pile burning or wildfire may increase the risk of invasion by noxious

weeds. One goal of the current treatment is to prevent intense burning by wildfire. Prescribed fire intensity

will be variable and pockets of severely burned areas are expected (see EA, p.14).

Species react differently to burning. Some species of noxious weeds such as cheatgrass are especially likely to

increase with burning. However, burning followed by reseeding reduce cheatgrass cover. Other species such

as diffuse knapweed may be controlled by burning. The effects of fire on many noxious species are not well

known.

Comment 103: The infestation of Canada thistle near treatment unit H3101 should be eliminated prior

to project implementation.

Letter 8

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o There is an infestation of Canada thistle off County Rd. 100 that will provide a source of seeds to

treatment unit H3101. The EA states that high priority occurrences will be treated before project

implementation. This infestation should be eliminated before treatment.

Response:

Most treatment units for the James Creek Fuel Reduction Project were surveyed for noxious weeds in 2002,

2003, and 2004. The Invasive Plant Specialist Report prioritizes occurrences by treatment unit based on

aggressiveness of the species, current area occupied, potential to eliminate the species, and status according to

the Colorado Noxious Weed Law.

It has been found that prevention is key to controlling invasive species. For that reason, top priority is generally

given to eliminating weeds new to an area and especially species that are particularly aggressive. Although

Canada thistle is very aggressive, it is already so widespread that it is not considered eradicable. For

perspective, it is on List B of the Colorado Weed Law; for species on List B treatment is recommended but not

required.

Given the current number and extent of weeds in the James Creek project area, it may not be possible to treat all

occurrences. Weed occurrences in unit H3101 are rated as low priority in the Invasive Plant Specialist Report,

meaning that relative to all infestations, this one is a low priority for treatment.

ROAD CONSTRUCTION

Comment 104: Please commit to closing and obliterating all new roads used for the project.

Letters 2, 8, 14, 17, 40

o These roads will likely remain as scars for decades.

o Any temporary roads built on Burnt Mountain must be obliterated and closed after the project.

o Temporary roads and entrances off Gold Lake Road need to be closed and obliterated

o Please do not build any new roads unless the USFS can commit to completely obliterating the

roads and rehabilitating the forest afterward.

o I don’t see any guarantee that any new or improved road will be closed.

Response:

Temporary roads are not part of the permanent transportation system and are created to access treatment units.

The project proposes the creation of temporary roads and these roads will be obliterated as needed following

treatment (EA, p.101).

Comment 105: Grading the roads for two-wheel tractor trailers versus grading them for articulated

rubber tired skidders is excessive. Letters 7, 8

Response:

The roads are graded so that equipment needed for the fuels reduction treatment can access (both in and out) the

project area. Tracked equipment, chip vans, truck trailers, rubber-tired skidders, are but a few of the types of

equipment that may be used to implement this project.

Comment 106: We should not build temporary roads where system roads exist.

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Letters 7, 14, 18, 19

o Walking this road (2103) will demonstrate that needed treatment areas can be accessed from 2103

and (temporary road) R is not needed.

o Use system roads 2103 (374.1), 373.1, and 373.3B to access units.

o Why build a new temporary road when an existing system road allows access to the same areas

without crossing the steeper terrain that R will cross.

o The lack of maintenance and poor condition of this road (373.1) demonstrates why we must

minimize the creation of new roads and the improvement of roads that are fading into the forest

today.

o We request that you delete this temporary road “TT” and treat only the area you can access off

373.3B.

o Creating temporary roads – why are some roads proposed to be built right up against private

property lines?

Response:

We prefer to utilize existing system roads instead of creating temporary roads whenever possible. Land

ownership, the location of system roads, topography, and the location of the areas to be treated sometimes

require temporary roads to be built. Road 2103 will be used to access the western portion of unit M0501

(identified as M0503, see Record of Decision p. 2 and corresponding maps) following old roads in the area up

to an old mining site. This road system does not access the southeastern portion of the unit. Temporary road

“R” accesses the southeastern portion of the unit and will be accessed from system road 373.1. Temporary road

“R” will follow existing road prisms from the last management entry as much as possible. Part of system road

373.1 has become overgrown and will be maintained to its designated standard. Some temporary roads will be

built along private property due to the topography and the location of the treatment area.

Comment 107: We constantly expressed our concern that no additional permanent roads be created

Letter 14

Response:

While no new temporary roads will become permanent with this project, 2 nonsystem roads that were

previously built to access old timber sales will become part of our transportation system. The United States has

an opportunity to acquire two permanent easements to National Forest System lands for administrative use only

and neither road will be open to the public.

Comment 108: To access proposed treatment units in the proposed action, either 8.6 miles (p. 18) or 12.1

miles (p. 27) of temporary road will be constructed.

Letter 19

Response:

Thank you for pointing this out. In reference to the 12.1 miles on p.27, the sentence will be clarified in the final

decision to read as follows: “Approximately 12.1 miles (8.6 miles of temporary roads and 3.5 miles of non-

system roads to be improved) will be constructed under this alternative.”

Comment 109: …this user created road (Owens Flat Road) could be blocked to prevent further

degradation by motorized recreationists who remove Forest Service signage…

Letter 14

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Response:

At the completion of the planned treatment in the Owens Flat area, the non-system road will be blocked and

obliterated.

Comment 110: Temporary roads will not be obliterated thus increasing recreational use

Letters 2, 7, 8, 10, 17, 18, 21, 24, 25, 26, 40

Response:

Temporary roads have been addressed in the EA, pp101-102. Under obliteration of temporary roads at the

conclusion of project implementation, the document states the following items as needed:

Pulling culverts and restoring stream crossings to natural grade.

Re-establishing natural drainage patterns with waterbar placement.

Seeding or planting along the ripped or recontoured sections with native vegetation.

Recontouring the road prism to the original land contours for the entire disturbed length.

Also see Mitigation Measures and Project Design Criteria, p. 6 and Record of Decision, p. 5.

NEPA

Comment 111: Based on some of the evaluation of alternatives C and D in the EA, it is questionable

whether an objective analysis has occurred.

Letters 7, 19

Response:

Alternatives C and D were developed in response to issues identified during the many public meetings and

from letters and comments received during the public scoping process. All alternatives were analyzed and

treated equally during the project planning process. The finding that alternative C will “likely jeopardize the

project objective” is based on analysis performed using the Farsite fire behavior model.

The proposed action was designed to meet the purpose and need of reducing the potential for crown fire

initiation and spread. No single treatment unit can achieve this goal; ridge fuel breaks will not stop a running

crown fire. Those treatments will serve as an area for aerial attack and retardant drops, safety zones or hand

line construction. It is the combination of all units and treatments in the proposed action that is the most

effective. The other alternatives will achieve the project goals as well, but with a lower probability of success.

This finding is described in the EA, pages 33-37. The need for treatment encompasses the entire project area.

The proposed action was designed to meet this need. Every reasonable attempt has been made to minimize

potential problems that may result from implementation through the use of design criteria, mitigation measures

and the application of appropriate policies and laws. It is our opinion that the EA has “rigorously explored and

objectively evaluated all reasonable alternatives” as prescribed in the CEQ regulations.