appendix f response to scoping commentsa123.g.akamai.net/7/123/11558/abc123/forestservic...skibo...

Skibo Project Environmental Assessment

June 2013 F-1 Appendix F

APPENDIX F RESPONSE TO SCOPING COMMENTS

Table F-1: People Who Submitted Comments on the Skibo Project Scoping Report 1. Don Ostlund 11. Robin Vora

2. Andrew Datko 12. Dennis Barry

3. Dick Artley 13. Annah J. Gardner, Lois Norrgard, and Marc Fink

4. Mike Schrage-Fond du Lac Wildlife Biologist

14. M. Kaluzniak

5. Darren Vogt-Environmental Director, 1854 Treaty Authority and Rose Berens

15. Marlene Pospeck & Carol Youngberg, Superior National Forest Scenic Byway

6. Cliff Crosby 16. Tony Sullins, U.S. Fish & Wildlife Service

7. Lee Radzak-Scenic Byway Council

17. Curt Heikkila

8. Jon Jarvinen

18. Scott Tyo, Chair of Fairbanks Township

9. Minnesota Forest Industries

19. Craig, Engwall-MN DNR

10. Robert Hagstrom

1. Don Ostlund

Comment SS-001-1: “I believe that your “skibo project” should be scaled back enough so that the cost savings could be used to grade and maintain forest service road #118. There are approximately 108 taxpaying cabins on Linwood Lake and Whiteface Reservoir which need to use #118 to access their properties.” Response: Thank you for your comment. Further maintenance of Forest Road 118 is beyond the scope of the Skibo Project. This road is currently maintained approximately five times per year. This is the highest maintenance level that we can maintain these roads at this time based on budget and personnel. We have had discussions with St. Louis County to transfer over management of the road and also about posting it with speed limit signage as it is a major arterial road and used my many in the area; but we have had no success at this time. Feel free to contact our transportation and roads specialist at the district office for more information/concerns. Also, see Ch. 2, p. 2-12-Transportation in the EA for additional information on proposed road changes.



2. Andrew Datko

Comment SS-002-1: “Thank you for the opportunity to comment on the Skibo Project Management Plan. My main comment is in regards to the FS transportation system in this project area. Specifically, the road that goes south from Highway 110 in the Bird Lake area. This road crosses USFS land in section 25, and then State land in section 36. It is an important route as it leads to a public canoe access on the St. Louis River. It is in terrible shape, with potholes almost big enough to swallow a car. It has seen no surface maintenance in years. Could you at least please fill the potholes, and occasionally grade it. This would make the River access much more accessible.” Response: The road that you are inquiring about is FR 1060. This road is a maintenance level-OML 2 road making it accessible to high maintenance vehicles. Based on the FS Handbook 770959, Chapter 60, Level 2 roads are not maintained to be passable to standard four wheel passenger cars. No provision is made for user comfort, user convenience, and speed of travel. Also, no provisions are made to warn users about changing conditions and safety concerns on the road ahead. The next OML, Level 3, are passable to prudent drivers with passenger cars; drivers can expect predictable road conditions, and warning signs and traffic control devises are common. Maintenance improvement may occur on Level 2 roads if there are units that are proposed to receive vegetation management. This would apply to both State and NFS land. For more information on OML classification and standards, please see the transportation section in Ch. 2 in the EA.

3. Dick Artley

Comment SS-003-1: “Please accept these scoping comments for the proposed Skibo Vegetation Management project. Most commercial timber sales have the potential to inflict long-term harm to the natural resources in the forest. Human manipulation of merchantable conifer trees simplifies the forest and eliminates all-important biodiversity. The natural resources in the forest will not function properly unless they exist in a biodiverse environment. Please analyze an alternative in detail that maintains biodiversity and causes no damage to the non-vegetative natural resources in the forest … either short or long term.” Response: Along with our action alternative, the EA will analyze a no-action alternative for the Skibo Project. Comment SS-003-2: “A forest is infinitely more that merchantable conifer tree species. Trading-off the proper functioning of the natural resources in and downstream from the sale area to provide corporate profit opportunities is unacceptable.



If this cannot be done and my tax dollars continue to be spent on this damaging project then please explain to the public why the Forest Service values the exquisite forest resources in terms of the money the resource extraction will provide to a corporation. Also describe why the agency chooses to serve corporations rather than 300 million Americans who enjoy the esthetic forest values and could not care less about corporate profit.” Response: The purpose of the Skibo Project is to implement the Forest Plan and to move the vegetation from its existing conditions towards desired conditions in the Forest Plan. Vegetation management is one part of the proposed activities. Other activities include reducing hazardous fuel levels, improving water quality, maintaining and improving habitat conditions for wildlife, designation of gravel pits, recreation and scenery objectives, and maintaining the transportation system to meet the needs for long-term federal and nonfederal access, including special use permits. The Forest Service manages for multiple functions and resources on National Forest System lands. We are a land management agency with a mission to provide the greatest good in serving the land and people. The Skibo Project is guided by direction for the Superior National Forest Land and Resource Management Plan (Forest Plan). For more information on the Purpose and Need and Proposed Actions, please see Ch. 1 of the EA. Comment SS-003-3: “Please accept these scoping comments on the Skibo project. The essence of the NEPA is to compare and contrast reasonable alternatives with the Proposed Action. My research has yielded hundreds of peer-reviewed, published science documents that describe how commercial logging activity causes long term harm to some important natural resources in the forest. The Purpose & Need for the Skibo project tells the public that the Proposed Action will maintain and enhance and improve 1) T&E species habitat, 2) water quality, and 3) aquatic habitat in the project area. Reputable science indicates that logging will harm these 3 resources. It’s so sad that line-officers are so zealous to meet their volume expectations that they lie to the public. Indeed, the forest service rewards line officers who behave as if a commercial timber sale is a cure-all for problems in the forest (both real and perceived). Please analyze an alternative in detail in the draft NEPA document that 1) harvests no timber, 2) constructs no temporary roads and 3) applies no herbicides that contain the chemical glyphosate. This will improve the 3 resources identified above. Given the magnitude of this timber sale (14.3 square miles of cutting units) I will look forward to reading and commenting on the DEIS. Writing an honest, accurate FONSI will be impossible.”



Response: Along with the action alternative, a no-action alternative which would not move the project area towards Forest Plan direction will be analyzed and considered at the same level as the proposed action in the EA.

4. Mike Schrage-Fond du Lac Wildlife Biologist

Comment SS-004-1: “Thank you for the opportunity to review the scoping report for the Skibo Project Area. The Fond du Lac Band’s initial comments are below. We may have further comments as the process continues. Although the Band appreciates efforts to restore more long-lived conifer to the landscape, the Forest’s long term objective to decrease aspen and convert these stands to conifer may have negative impacts on game species such as deer and grouse. These species are important to tribal members who exercise their treaty hunting rights in the Skibo area. The scoping report discusses impacts to endangered or sensitive species, but has little discussion regarding what the impacts of the proposed actions would be on populations of important game species. We would like to see impacts on important game species addressed more directly in future Forest projects and as the Skibo Project goes forward. The Band would not be in favor of habitat conversions that result in significant reductions of important game species. Recent research by the MN DNR indicates fisher are strongly tied to large (>20” dbh) aspen for den sites and fisher populations are declining statewide. One of the reasons for this decline may be a decreased availability of large aspen for den sites. Therefore the Project’s objective to reduce mature and old aspen may have negative consequences for fisher populations. The Band urges the Forest to retain a component of large diameter aspen in current and future stands where ever possible.” Response: Conifer conversion is a part of this project but it is on a small scale. There would only be 128 acres of stands that would be converted to red and white pine forest out of the approximately 6,300 acres of regeneration harvest. Aspen stands would still be the dominant forest type in this area which is in line with the landscape goals for the landscape ecosystems in the project area. We do recognize the importance of large diameter aspen to fishers. For that reason we include that two trees per acre from the largest size class would be retained as part of our leave trees in any regeneration harvest.

5. Darren Vogt-Environmental Director, 1854 Treaty Authority and Rose Berens

Comment SS-005-1: “Thanks for the information and follow-up phone call on the Skibo Project before public distribution. I reviewed the materials and didn’t identify any opportunities or have any specific comments.



The only thing that stood out in this project area was the proposed use of ground-based broadcast herbicide application to promote birch regeneration (198 acres). It is my understanding that this pilot project would be used to compare the effectiveness of herbicide application versus mechanical methods of vegetation control. Although the proposed work is limited and avoids riparian areas, concern may arise if this technique becomes a widely used procedure in the forest. Impacts on other plants of interest and importance would need to be understood. Unless others see the need or have concerns, I don’t think a meeting is necessary at this time. Thanks, and please contact me with any questions.” Response: Thanks for your response on the project. Application of herbicide under Alternative 2 for the Skibo Project would follow Forest Service Manual section 2150 concerning pesticide use, management, and coordination; the Forest Service Health and Safety Code Handbook chapter 22.1; the Minnesota Department of Natural Resources Voluntary Site-level Forest Management Guidelines for herbicide use; and all manufacturers labeled use guidelines. In following the MN DNR Voluntary Site-level Forest Management Guidelines for herbicide use, it is stated to, “avoid broadcast application methods within filter strips and riparian management zones” (p. 16-Pesticide Use, MFRC). Additional mitigation measures that would be employed during operations can be found in Appendix D; monitoring methods and their corresponding objectives can be found in Appendix C of the EA. Currently we have no plans to do broadcast applications in riparian areas on the Superior National Forest. Moreover, we would be monitoring the response to the plants on the specific sites receiving the application to see the outcome and determine if we would continue to utilize this tool for future vegetation management on the Forest. Comment SS-005-2: “I am very concerned about the use of herbicide as there is quite alot of sage growing in the Skibo area. I pick there every fall. I dont know if anyone else picks in that area.” Response: To meet our monitoring standards, prior to any herbicide treatment we would do a pre-treatment visit and we have noted your concern and could search for sage in the proposed herbicide stands. Please see Appendix C and D (Operational Standards and Guidelines/ Monitoring) for more information on herbicide and pesticide mitigation measures and monitoring techniques.

6. Cliff Crosby

Comment SS-006-1: “I am a snow bird writing this note from Tucson, AZ. I will soon return to my Duluth address. Thank you for your May 10 letter on the Hoyt Lakes project. I am familiar with the area. I also was a US Forest Ranger and served 34 years dealing with multidiscipline projects such as this one. Take heart, I am also aware of extraneous regulations you must meet. The present political climate will soon change and your professionalism will flourish.



The impact of outside agencies such as EPA will reduce. There was a time when we managed timber on a substained yield basis. We contributed to the local community and they knew it. We planned for the future. Many efforts were generated from the ground up by professionals like you. Enough!” Response: Thank you for your comment.

7. Lee Radzak-Scenic Byway Council

Comment SS-007-1: “Thanks for sending this out. Wow, that’s a huge area with a little byway running through it. I’ll look forward to hearing more about the plans.” Response: Thanks for your comment. We will notify you when the environmental assessment is available on our webpage.

8. Jon Jarvinen

Comment SS-008-1: Mr. Jarvinen expressed concern that road decommissioning will block access to a hunting shack. He also requested to remain on the mailing list and is interested in the project. Response: The project leader sent him project maps and spoke with him that his access would not be impacted with the project. He will remain on the project mailing list.

9. Minnesota Forest Industries

Comment SS-009-1: MFI requested hard-copy scoping documents on May 11th, 2012. Response: Hard-copy scoping document were sent to MFI on May 15, 2012.

10. Robert Hagstrom

Comment SS-010-1: Mr. Hagstrom inquired about brush clearing on the NE Grade and Rd 906 in T56, R13 in S 28 and 34. Response: The project leader informed Mr. Hagstrom that the project would not likely involve brushing on the commenter’s road. A copy of the scoping package was mailed to Mr. Hagstrom.



11. Robin Vora

Comment SS-011-1: “Thank you for the opportunity to comment on the Skibo project. I don't enough about the project to make specific comments. Please keep me on your mailing list project scoping and NEPA. Thank you.” Response: Thank you for your comment. We will keep you on the mailing list and notify you when the environmental assessment is available on the website.

12. Dennis Barry

Comment SS-012-1: “I would ask that the old rock bridge across the river be left as is. It has been a landmark and a scorce of conversation for 50 years. It brings days of early logging in northern minesota back to be compared to and considered today. My family has enjoyed this landmark for over 40 years. I have state leased land and a cabin north of the bridge near the boat landing. The rest of your proposals for the area look outstandiing...and challanging to say the least.” Response: The “old rock bridge” is actually a logging dam or railroad trestle remnant and has been evaluated by both the National Register of Historic Places (NRHP) and by our own heritage resources staff. The findings were documented in the Great Lakes Restoration Initiative (GLRI) report conducted during 2011-2012. Within this report, the NRHP found this specific site as “not eligible” for the NRHP. We also are in consultation with the State Historic Preservation Officer (SHPO) for concurrence. Recently, we heard back from SHPO for the GLRI report and they concurred that the dam/trestle is not eligible for the NRHP; thus, there are no heritage management concerns for the property. In this case, there are many long-term ecological benefits to removing the structure including restoring and enhancing stream flow and water quality to the St. Louis River. For more information see section 3.10-Water Quality in the EA for a complete effects analysis.

13. Annah Gardner, Lois Norrgard, and Marc Fink

Comment SS-013-1: “The Scoping Letter states that the primary purpose of this project is to maintain and promote native vegetation communities that are diverse, productive, healthy and resilient. The Sierra Club and the Center for Biological Diversity fully support this admirable goal, that if implemented could result in some extremely important benefits for threatened and sensitive species. The problem is that to achieve this goal thousands of acres of timber harvesting is proposed. How can these two competing purposes be jointly combined?”

Response: The two purposes can be combined and met though following the SNF Forest Plan, a thorough and complete effects analysis, and through managing for multiple resources while also producing timber. Providing commercial wood for mills in northern Minnesota is just one



objective of the Forest Plan. Equally important are objectives for other resources such as O-WL-18: Maintain, protect, or improve habitat for all sensitive species, or O-WL-37: Reduce the spread of terrestrial or aquatic non-native invasive species. Thus, an interdisciplinary team of natural resource managers and a concise and complete NEPA process is utilize to adhere to our Purpose and Need for the Skibo Project.

Comment SS-013-2: “VEGETATION MANAGEMENT: The Sierra Club and the Center for Biological Diversity have concerns regarding the amount of harvest proposed and the treatment types that have been chosen. Creating large amounts of young forest can result in damage to soil and water resources, spread of non-native invasive species (NNIS) and most importantly destruction of important sensitive species habitat. Which sensitive species will benefit from clearcutting thousands of acres?”

Response: Throughout the project planning process, effects to sensitive species are highly analyzed from mid-level field assessments to the decision document. Sensitive species were identified during the mid-level assessment for the project area (7D009 in the project record). Certain species such as goshawk and great grey owls benefit from even-aged vegetation management as initially it creates good foraging habitat. Over time the stands grow at that even age creating future nesting and foraging habitat. Following Forest Plan guidelines, measures would be taken to protect nesting, post-fledging, and foraging habitat. For other species, analysis was conducted to maintain and enhance current habitat needs. Projects are designed to avoid or minimize negative impacts to known occurrences of sensitive species. For a specific list of species needs, please see the summary in Ch. 3 of the EA, and the biological evaluation and biological assessment for the EA available on the SNF projects webpage.

Comment SS-013-3: “The Sierra Club and the Center for Biological Diversity are concerned with the vast quantities of clearcuts proposed under this project. Clearcutting does not promote age diversity or species diversity. Instead it leads to fragmentation of the forest and fragmentation of species habitats and simplified stand structure. How will clearcutting patterns mimic the complicated disturbances created in nature, such as fire? Why are there so many units slated for clearcutting without the benefit of any secondary treatments? Why clearcut aspen stands just to let them naturally regenerate back to aspen?

Clearcutting is not the optimal method of “harvest,” especially in terms of achieving age and species diversity, because clearcutting increases habitat fragmentation, which lowers overall diversity by reducing suitable habitat for forest interior species. Clearcutting also leads to stands of single age species. This simplification of forest structure and composition reduces its ability to provide habitat for a diversity of forest wildlife species. The frequency of clearcuts in the project area should be significantly reduced.”

Response: As directed by the Forest Plan D-VG-5 p.2-22, “Vegetation constantly changes through management activities and through naturally occurring disturbances and ecosystem recovery processes such as wind, fire, flooding, insects, disease, and vegetation succession. These fluctuations are within an ecologically and socially acceptable range of variability.” Clearcutting is an even-aged harvest method that is directed from the Forest Plan to harvest species such as jack pine and red pine, spruce-fir, oak, aspen, aspen-spruce/fir, paper birch, and lowland conifer (G-TM-2, p. 2-20). It also provides wood for mills in northern Minnesota and



helps to not only regenerate productive stands, but can bring unproductive stands back to a productive stand. For wildlife species, these even-aged harvests provide browse and habitat conditions that are favorable to many. Finally, these types of disturbances man-made or naturally create conditions of variability within the forest making them adaptive to future stresses such as climate change and forest fires.

Secondary treatments such as planting and seeding are necessary following a clearcut harvest for many species. Other species such as paper birch and aspen naturally regenerate well following even-aged treatments. Sometimes certain species are growing on soils and landscape types that are better for other species such as aspen. These sites may not be planted or seeded and simply allowed to regenerate naturally.

The Forest Plan states in S-TM-4 that five years following a clearcut in seed tree or shelterwood harvest, stands must be adequately stocked (p. 2-20). We recognize the importance of secondary treatments for species that need artificial seeding or other types of treatments to create a healthy seed bed for regrowth. Additionally, the Knutson-Vanderberg Act (K-V) is an authority requiring purchasers of National Forest timber to make financial deposits for sale area improvement activities including reforestation activities.

Harvesting aspen when the stand is still in a productive state and the timber is in good condition, meets many Forest Plan objectives. While providing wood for mills, it also and creates open areas in the forest for a variety of species to browse and utilize that opening for habitat needs. Overtime, these stands provide large patches of older forest that provide interior forest habitat. However, some stands that are currently aspen may not be suitable to continue to sustain aspen based on soil and other conditions. These would be converted from aspen to another stand type as a follow-up treatment. Please see Appendix B for information on units that would be converted or planted to another species type. Finally, clearcutting as a primary treatment type is an acceptable method of treating stands of this type and is the most common tool we have to enable us to implement our Forest Plan. The Forest Plan also states it is an appropriate treatment type (FP, G-TM-2, S-TM-2, and S-TM-5, pp. 2-20 and 2-21). Comment SS-013-4: “The Sierra Club and the Center for Biological Diversity favor reduction of aspen forest to its historical range and percentage of coverage. We understand the desire of many mills to have access to aspen in the 40 year old mature range as they prefer white wood of the diameter of mature aspen for their purposes. However, they do not like aspen as old as 60 years as it contains too much unusable material. We suggest that aspen areas where species age is 45 years and older, especially the 60 year old stands referred to, be allowed to transition to old forest of eventual mixed species. In the areas where you plan to clear and regenerate patches of aspen, we prefer that it be done in such a way as to have the even aged patches distributed so as to maintain a landscape of the uneven age patches, thus capturing some of the benefits of uneven aged stands.

The Sierra Club and the Center for Biological Diversity are concerned with what appears to be a dramatic reduction of old forest in the project area. How many large mature patches are in the project area? How will implementing this project affect large mature patches? Which



units slated to be cut occur within or adjacent to large mature patches? The number of large mature patches should be maintained, as should their size in terms of acreage. Many sensitive species rely on mature forest for habitat. For many species, reductions in current and potential habitat could lead to disastrous future results.” Response: The older aspen stands that mature and succeed, succeed to a spruce/fir forest type, with aspen as a diminished component of the stand. The largest LE in the project area, Mesic Red and White Pine, has most acres to be removed from the older age classes while still seeing a net increase in stands aged 80-120 by roughly 3000 acres. As the stands that are left age, they add onto or begin to form additional large, mature patches across the project area. The Skibo Project Area currently contains 50 large mature 100 acres or larger patches (Table 10-Biological Evaluation). Both of the action alternatives would reduce (four percent) the area of these patches and would maintain all but two mature patches over 300 acres. Utilizing the Forest Plan, the IDT determined that the project area is over the Forest-wide limit for large mature patches so with the action alternatives some harvesting would occur within these patches. In 2012, there was approximately 9,400 acres within large, mature patches. With the treatment of two of the large patches, there is projected to be approximately 10,250 acres in large, mature patches in 2020 within the project area which not only maintains the number of acres in patches, but increases the amount. Certain stands were selected for a single aged treatment and grouped to setup future large, mature patches across the project area. Harvesting in some of these patches helps to create openings of good quality habitat for future patches. Another consideration we keep in mind is adjacency to what is occurring on other ownerships. When other entities are harvesting, we try to harvest around the same time creating future large patches of habitat. With this method of creating new patches and treating old patches, we are able to move patches around the project area to simulate a history of disturbance at both the landscape and stand level. Each patch within the project area will be analyzed for the appropriate management action. Comment SS-013-5: “Tree plantations have little structural or species diversity. They are ecologically unstable and more susceptible to weather, fire and pests. They do not promote healthy diverse forests. They do not contribute to properly functioning self-reliant ecosystems. How many plantations are located within the project area? Where are they and how large are they? Are existing plantations being expanded? How do these tree plantations contribute to the many goals and objectives in the Forest Plan aimed at restoring health, vigor and diversity to the forest? The Agency should start returning tree plantations to their natural range of diversity so they may contribute to the overall health and sustainability of the forest. Instead of using them to provide timber to the timber industry they need to be restored to their historical ecological condition.” Response: The Society of American Foresters defines a plantation as, “a stand composed primarily of trees established by planting or artificial seeding.” http://dictionaryofforestry.org/dict/term/plantation. A traditional forestry plantation is comprised of a single species with all management being directed towards maintaining that single species for maximum financial return. The Superior National Forest manages plantations as a means to establish and reestablish later successional species and to increase the amount of acres representing the structure of old growth stands. This means that plantations are originated from



planting stock, allowed a chance to outcompete early successional species, and then be established as the dominant species within a stand. A large portion of the Forest’s recent plantations are of white pine to encourage the reestablishment of white pine dominated stands with an understory of aspen and assorted primary succession species. There are monoculture or plantation-type vegetation stands within the Skibo Project Area; some dating back to previous Forest Plan and older vegetation management principles. These plantings were generally done by groups such as the Civilian Conservation Corps to stabilize old harvest sites. Plantings done in the past 20 years would likely have more diversity because of increased efforts to plant a variety of species and to retain existing diversity. Plantations do contribute toward both species and age class diversity. Without these areas we would not be able to restore many of the forest species that are declining, such as white pine. The purpose and need for the Skibo Project is to implement the Forest Plan; moving vegetation from its existing condition toward desired conditions as described in the Forest Plan. Forest Plan objective O-VG-2 states to increase the acres of red, white, jack pine, spruce/fir, and northern hardwoods vegetation communities. As plantations age within a project area, interdisciplinary team specialists must decide to either regenerate the stands to an even-aged system, or treat the stands to maintain the forest type while introducing new cohorts and establishing a two-age or multiple cohort stand system; all while meeting Forest Plan standards and guidelines. We do agree that traditional plantations may not provide the same level of structural or species diversity as non-plantations stands; however, they do provide habitat for wildlife. Some of the plantations are proposed for thinning at this time for multiple objectives. Thinning would be used to increase the growth on the residual trees, increase stand structure, within-stand species diversity, and wildlife habitat. This is accomplished by methods such as Variable Density Thin (VDT), which allow for different areas to be thinned to varying basal areas depending on resource objectives. Within these plantations, especially older red pine stands, efforts to open canopy gaps are also made to increase the hardwood components of these stands for wildlife such as raptors. Hardwoods are also favored for retention within these stands. Alternatively, old pine patches that are breaking down may be retained for habitat purposes within a stand of younger pine species. Appendix B shows the units proposed to be thinned. Regeneration harvests are inappropriate for some of the plantation stands due to young age or management objectives to maintain the forest type in the LE. These stands are thinned to increase old growth characteristics of stands by reducing basal area, increasing size of residuals, and opening gaps for additional species to establish within the stand. Comment SS-013-6: “The Sierra Club and the Center for Biological Diversity are concerned with how the use of herbicides will affect water resources and sensitive species. Will the Agency monitor the area after using herbicides to observe how it affects sensitive species, aquatic species and land and ground water resources?” Response: The project is designed to reduce or eliminate potential adverse effects of our actions. Impacts to water resources and sensitive species are analyzed in Ch. 3.4, 3.10, and the BA. All management actions would adhere to the mitigations and project design criteria listed in Appendix C, beginning on p. C-9 and in Appendix H-Herbicide Proposal. In addition, the Forest utilizes two types of monitoring: effectiveness and implementation for projects. See Appendix



D-Monitoring Plan beginning on p. D-9 for objectives, methods, and responsibility related to herbicide monitoring. Comment SS-013-7: “ROADS- The Sierra Club and the Center for Biological Diversity are concerned with how roads, both temporary and permanent, affect overall forest health and contribute to the decline of certain species. Roads negatively impact lynx, wolves and other species, cause fragmentation of the forest and harm soil and water resources. No new roads should be built, no temporary use authorization roads or special use roads should be allowed and no existing roads should be added to the transportation system.

The numerous negative impacts associated with roads in our National Forests are well documented, there has to be a commitment by the Agency to stop adding roads to our already overly-paved public lands. A road is a road and it will have the same harmful effects regardless of the term attached to it, be it; permanent, temporary, unclassified, special use or temporary use authorization.

The scoping letter states, “The Superior National Forest made a concerted effort to identify all existing unclassified roads on the Forest during the Travel Management Project. Roads that are being addressed in that project will not be included in this project. Recently however, District staff identified several additional unclassified roads. This project would assess whether to decommission these roads or add them to the National Forest System” (4). Why were these roads not identified during planning for the Travel Management Project? This would suggest that other unclassified roads in the Superior National Forest were not identified during the Travel Management Project planning process. Why would these roads be added to the system? What use would they facilitate? These unclassified roads should be immediately decommissioned and not added to the system.

With the discovery of these unknown, unclassified roads it is clear that temporary roads are not being decommissioned after use and are being forgotten about. Temporary roads are supposed to be obliterated when logging is completed. However, the Agency actually has up to 10 years to decommission a temporary road. These roads are often forgotten about or not decommissioned adequately. These roads will have the same effect on species and water and soil resources as a permanent road. No new temporary roads should be built.”

Response: Some roads were constructed after Travel Management Ruling (TMR) field work was completed but most of the roads found in the Skibo Area were missed during the field portion of TMR work. The whole Forest was surveyed in one summer to identify unclassified roads for the TMR project and some were missed. Vegetation projects on the Forest have been identifying any missed roads and reanalyzing TMR decisions when changed situations call for it. Most of these roads in Skibo are being decommissioned but some are being added as OML1 system roads (closed when not in use) where access is needed long term. As for temporary roads, on the contrary, SNF monitoring shows that temporary roads are being closed upon completion of management activities and are not left open. The 2008 Forest Monitoring Report states, “Contractual practices and techniques were effectively implemented for decommissioning temporary roads, including removal of drainage structures, removal of ruts and berms, reshaping and re-contouring, seeding and mulching, drainage control and effective road blockage. Furthermore, over 80 percent of the projects were successful in preventing motorized recreation vehicle travel. Those roads, where unauthorized motorized travel was



noted (20 percent), will be revisited during 2009 and if use is still occurring, appropriate closure practices (additional rocks) and/or administrative action (signing and law enforcement) will be taken” (p. 14.4). Finally, the Superior is taking significant measures in closing roads to comply with Forest Plan objectives. For example, objective O-TS-8: The Forest will decommission approximately 80 miles of road. Based on Appendix J of the 2009 Monitoring Report (p. 3), “133 miles of road will be decommissioned when decisions up to 2009 are implemented.” Comment SS-013-8: “The Sierra Club and the Center for Biological Diversity are concerned that the project area contains a high amount of gravel pits. Is there a need for 17 gravel pits in order to complete this project? Are there currently other uses for these 17 gravel pits? Why not close some of these gravel pits and restore the area? Classifying these gravel pits as ‘continuous use’ suggests that there will be a lot of road building or other projects occurring in the area. The Forest Service needs to focus on reducing the amount of roads in the Superior National Forest not facilitating the means for expanding the system of roads. Which pits are proposed for expansion? Why is the Agency concerned with ensuring that all of these gravel pits are maintained and expanded? Who will be using these gravel pits and for what types of projects? Are these gravel pits anticipated to be used in future mining activities? Existing pits should not be expanded.” Response: These pits are all not needed to complete the Skibo projects. But they are being proposed to provide a source of gravel for construction, reconstruction, and maintenance of roads and trails. There is also some demand for small construction projects such as parking areas and boat ramps and for the development of private land: septic systems and driveways. These pits would also provide gravel for future projects. As for closure of the pits, all pits would be closed and reclaimed when the gravel source is exhausted or not needed anymore. There are currently two pits in the Skibo Area that have been closed and reclaimed. The remaining pits are classified as continuous use simply to maintain that pit as open for future projects. For the Skibo Project, the proposed action has 21.6 miles of existing road miles to be added to the system, with 37.4 existing miles to be decommissioned (see Table 1-4 in Ch.1). All the pits are proposed for expansion if needed on a case-by-case basis. For example, if another weather event like last summer’s flooding which washed out large sections of Forest roads occurs in the future, additional gravel resources may be needed. If we do not classify them for expansion, they we cannot utilize these pits. Various projects would be using the gravel resources from these pits. They would be used by the Forest Service, local governments, and the public. At this point, there are no plans for gravel pit expansion to meet mining activity needs. For more information on gravel, see section 3.14.3 starting on page 3-98. Comment SS-013-9: “The Sierra Club and the Center for Biological Diversity are concerned with how this project will affect sensitive species such as lynx, wolf, northern goshawk and bald eagle. The scoping letter states that this project will enhance, maintain and improve habitat conditions for wildlife (1, 3). Which species habitats will be improved and enhanced as a result of this project? With so much planned timber harvesting and road building it seems probable that habitat for sensitive species will not be maintained or improved but rather will be further



reduced. Focus needs to be put on restoring habitat for sensitive species; such as lynx and northern goshawk.” Response: Please see Ch. 3.3-3.5 in this EA and the BA available on the SNF Projects website for potential effects on federally proposed, candidate, threatened or endangered species and designated critical habitat that could result from proposed vegetation management and associated activities as proposed in the Skibo Project. The project is guided by the SNF Forest Plan which directs that all projects be designed to maintain, protect, or improve habitat for threatened and endangered as well as sensitive species (O-WL-4, p. 2-29). In addition, Forest Plan objective O-WL-6 directs the agency to, “reduce or eliminate adverse effects on threatened and endangered species from the spectrum of management activities on NFS land.” (p. 2-29). Utilizing Forest Plan direction, the interdisciplinary team designed proposed project activities that would meet a multitude of objectives for various resources, while maintaining the protection of the resources and the integrity of the project area as part of the whole National Forest System. For example, as described in Ch. 3.5, action alternatives 2-3 would have no direct, indirect, or cumulative effects to lake sturgeon, shortjaw cisco, Nipigon cisco, Quebec emerald dragonfly, Headwaters Chilostagman, caddisfly, and ebony boghaunter. For Alternatives 2 - 3, the proposed activities may impact individuals of gray wolf, heather vole, little brown myotis, northern myotis, tri-colored bat, northern goshawk, boreal owl, olive-sided flycatcher, bay-breasted warbler, bald eagle, Connecticut warbler, three-toed woodpecker, great gray owl, wood turtle, northern brook lamprey, creek heelsplitter, black sandshell, Taiga alpine, Nabokov’s blue butterfly, Freija’s grizzled skipper butterfly, but are not likely to cause a trend to federal listing or loss of viability. Alternatives 2 - 3 may have a beneficial impact to the olive-sided flycatcher. As described in Ch. 3.6, future nesting habitat of the bald eagle would be improved through project management activities that would plant pine in riparian areas. For the gray wolf, “Alternatives 2 - 3 would improve habitat for prey species (mainly deer) by creating young forest and planting mixed conifer forest, and would reduce human disturbance by decommissioning unauthorized roads.” (Ch. 3.6). Comment SS-013-10: “The Sierra Club and the Center for Biological Diversity are concerned with the potential damage that this project will have on water and soil resources. Of particular concern is the massive increase in young and open age classes where spring snowmelt could result in channel scouring, flooding, erosion, sedimentation and harmful effects on fish and aquatic habitats. Another concern is the large amount of areas slated for clearcut. When clearcutting takes place on steep slopes, soil erosion can occur. Harvesting should not occur on steep slopes because of the risk of erosion. Clearcutting can also lead to soil compaction, reduced water infiltration and loss of soil nutrients. Effects from harvesting may include channel scouring, compaction, erosion, rutting and reduced water infiltration.

Roads, both temporary and permanent, can be detrimental to water and soil resources.



When roads cross streams the structures placed there can interfere with aquatic migration and can cause erosion and sedimentation. What is the condition of stream crossings in the project area? Are there any problems with erosion or passage of aquatic life? What is the condition of stream crossings on the newly discovered unclassified roads? The Sierra Club and the Center for Biological Diversity urge the Agency to repair all failing drainage crossings. Further, the Agency should know which crossings are working properly and which are failing. How many impoundments/dams occur within the project area? Are they all working properly?”

Response: For the Skibo Project, Forest Plan guideline G-WS-8 would be followed. This table and other operational standards and guidelines for soil mitigations are located in Appendix C, pp. C-5 – C-8. This table in particular shows which activities are allowed on the various soil types on the Forest. Steep, rocky soil types (such as ELT 18) generally are not prescribed for timber harvest, especially even-aged timber harvest. Also see the soil analysis in Ch. 3.11 of this EA. Within the project area, there are currently 78 stream crossings. Stream crossings occur on various classes of roads including all season, seasonal, winter roads, non-jurisdictional drivable roads, and system trails. Winter roads and snowmobile trails crossing smaller streams typically do not require installation of road-fill or culverts. Generally, vehicles cross on the ice without damage to the resource. Winter roads and roads closed to public motorized use are not likely to cause significant road erosion issues since they are used during frozen soil conditions, and are used very infrequently for administrative purposes. Thirty two (32) of the 78 stream crossings in the Skibo area occur on winter roads and have no crossing structure. Beginning in 2002, the SNF surveyed the condition of stream crossings on 1,387 sites in all major project areas within the Forest (including 35 crossing surveys in the Skibo Project Area between 2008 and 2010). This work focused on larger stream crossings and on the Forest’s more heavily traveled roads due to the greater potential for impact to water resources. The stream crossing surveys show that approximately 99 percent of stream crossings do not have erosion issues and 93 percent do not have aquatic organism passage issues. Based on the surveys of road crossings within the project area, few National Forest System roads had existing crossings in need of rehabilitation or replacement, and all existing crossings have low potential for effecting aquatic organism passage or water quality. Those crossings warranting replacement are remediated on a Forest-wide basis, outside of the scope of the Skibo Project, through other projects like the Forest-wide Travel Management Project.

Resource specialists did identify an opportunity to remove of an old logging dam or railroad tressle located on the St. Louis River. Removing this material could help restore stream conditions and increase suitable wood turtle habitat (2B003-Midlevel Meeting Notes 12-7-10, p. 7-8, PR). See also response to comment SS-012-1 for information on the dam removal process. For more information on water quality, see Ch. 3.10. This section analyses direct, indirect, and cumulative effects on three indicators: miles of road construction and decommissioning, number of stream crossings resulting from building new roads, and proportion of upland open and upland young forest within each 6th level watershed. Comment SS-013-11: “The Sierra Club and the Center for Biological Diversity support non-harvest restoration activities in riparian areas so that they may be stronger, healthier and more



resilient ecosystems able to support a diversity of species. Widening riparian areas as proposed is desirable. There are several units slated for clearcut that are adjacent to lakes, rivers and streams. How will creating young age class in these areas affect the water resource and the riparian zone? Harvesting should not take place adjacent to water resources, rather restoration and improvement should occur, where needed, in these areas without harvesting. The Sierra Club and the Center for Biological Diversity are concerned with how management activities may affect the St. Louis River corridor. The following units should be dropped from this project due to their location within the St. Louis River corridor: 2, 7, 8, 9, 24, 25, 26, 27, 28, 32, 33, 34, 37, 38, 39, 40, 41, 77, 78, 79.” Response: All alternatives would follow applicable Minnesota Forest Resources Council (MFRC) Voluntary Site-Level Forest Management Guidelines (MFRC 2005) as well as required Forest Plan Operational Standards and Guidelines included in Appendix C and Site-Specific Design Criteria in Appendix A. All applicable Forest-wide desired conditions, objectives, standards and guidelines contained in the Superior National Forest Land and Resource Management Plan would be followed during project implementation. Riparian areas, lakes, and streams are protected using site-specific design criteria (Appendix A, Table A-5) determined at the site (stand) level. The functional riparian area is delineated based on site conditions and no “management” is permitted in the riparian area unless it is for the explicit reason of restoring or improving riparian function (for example, site preparation to plant long-lived conifer along a lakeshore). For the complete analysis of water resources in the Skibo Project Area, see Section 3.10. As far as the Saint Louis River corridor, approximately 20 miles of the St. Louis River flow through the Skibo Project Area, and NFS land within one-quarter mile of either side of the St. Louis River is in the Eligible Wild, Scenic and Recreation Rivers MA. Within the project area, the river is classified as an eligible “recreational” river. The Forest Plan explains that within “recreational” segments of this MA, “silvicultural practices are allowed provided methods used would have no substantial adverse effect within the river corridor to the river’s free flow, water quality, and outstanding remarkable values” (p. 3-18, GWSR-4). The Forest Plan also encourages vegetation management to promote long-lived tree species, leading toward the development of big-tree characteristics (p. 3-19, G-WSR-6). See Section 3.14 for effects of the Project on Eligible Wild, Scenic and Recreational River. Seven harvest units totaling 165 acres are proposed within the Recreational River MA. Proposed harvests would occur primarily during winter conditions, when recreational use of the river is low. These seven units are being treated to maintain or restore long-lived conifer within the river corridor. They would either be site prepped and planted predominately with white pine or site prepped and seeded with jack pine and/or black spruce. Comment SS-013-12: “CREATING CLIMATE CHANGE RESILIENT HABITATS: The Sierra Club and the Center for Biological Diversity are concerned with the resiliency of our northern forest ecosystems to rising temperatures. Global warming threatens to wipe out many wildlife species. “Warmer winter and summer temperatures may be affecting moose throughout its range in Minnesota. Much of the recent, recorded mortality appears to be health-related,



particularly disease and parasites, and may be linked to heat stress (MNDNR, 2009, p.16)” (Appendix I). The effects of global warming will worsen unless steps are taken to protect and prepare habitats for the effects of climate change.

Some climate change is already happening and with it will come extreme weather, droughts, loss of food sources and new diseases. It is our responsibility to ensure wildlife have the food, water and range they need to breed and survive. Protecting wildlife habitat not only ensures that we will be able to enjoy our outdoor traditions for years to come—it also helps combat global warming. By keeping our wetlands and forests intact, we help clean carbon pollution from the air and stop the worst impacts of global warming. If we want America’s wildlife to survive, we must help them adapt by protecting critical habitat and creating wildlife corridors that will allow for migration as temperatures rise.

Due to the growing need to reduce CO2 in Minnesota’s environment, the Sierra Club and the Center for Biological Diversity request an analysis of the carbon being sequestered by forest stands in their present state (standing timber) versus the carbon release that will inevitably be a part of this logging project. Cutting, especially clearcutting, natural forest trees results in a pulse of carbon to the air, the change in carbon sequestered to carbon in the atmosphere should be measured and monitored for this and all ongoing projects in the future.

How will this Project meet the requirements of the MN 2007 Next Generation Act to reduce emissions of CO2 by 15% by 2015 and 80% by 2050? How will this project affect carbon flows? How does this project combined with past, present and future projects affect carbon flows?” Response: We understand the Sierra Club is concerned about climate change and how changing climate might impact ecosystems and how management actions might in turn impact climate. The Forest Service is also very concerned about these issues and is involved in several studies to help answer the myriad of questions relating to climate change. The Forest Service web page at http://www.fs.fed.us/climatechange/ provides extensive information on climate change and what and how the Forest Service has been studying climate change for the past 20 years. In addition, the Forest Service produced a “Roadmap for Responding to Climate Change”, and a Performance Scorecard (http://www.fs.fed.us/climatechange/pdf/roadmap.pdf). The roadmap points the way to a comprehensive, science-based approach to managing forests and grasslands in an era of climate change. It is possible that climate change would result in a substantially different climate in the long term that would extirpate current forest types and allow different vegetation and wildlife to enter the area such as an oak savanna ecosystem (Frelich and Reich 2009). This degree of long-term climate change would be driven by global greenhouse gas emissions and other factors affecting global climate processes which cannot be stopped or even measurably changed by any actions contemplated in the Skibo Project. This is because any change in greenhouse gas emissions created by the Skibo Project would only be a tiny fraction of global emissions. The effect of changes in greenhouse gas emissions on global climate change effects cannot be evaluated with current scientific knowledge (Climate Change Considerations in Project Level NEPA Analysis, USDA 2009d).



To manage for uncertainty and provide the greatest chance for the forest to adapt to whatever future climate scenario occurs, we will follow Forest Plan direction to maintain and promote native vegetation communities that are diverse, productive, healthy, and resilient by moving the vegetation toward landscape ecosystem objectives described in the Forest Plan. And we will follow Agency direction for assessing current risks, engaging internal and external partners in seeking solutions, and managing for resilience in ecosystems as well as in human communities, through adaptation, mitigation, and sustainable consumption strategies. While there are a variety of effects of the Skibo Project on the multi-faceted variable of resiliency to climate change, we believe that progress towards achieving Forest Plan goals and objectives will result in an overall improvement of the resiliency of the forest in the face of climate change. Section 1.4 of the project EA describes the purpose and need of the project and includes achieving a variety of goals and objectives in the Forest Plan for landscape ecosystems, tree diversity, and wildlife. Effects to vegetation composition and diversity may be found in Section 3.2, and effects to wildlife in Sections 3.3 -3.5, BE, and BA of the EA. Regarding the MN 2007 Next Generation Act, most of the incentive from the Act is related to increasing energy efficiency and is not directly related to the Skibo Project. The Agency as a whole is committed to reducing our carbon footprint through reducing energy consumption across the board (reducing the amount of vehicles we drive, utilizing video conferencing instead of driving to meetings and conferences, updating and constructing more eco-friendly recreation and office buildings, programming office equipment to hibernate when not in use, etc.) In regards to carbon flows, the Superior National Forest has been partnering with researchers at Northern Research Station (www.nrs.fs.fed.us) to identify the carbon flows that result from implementing the 2004 Superior National Forest Plan, including vegetation management projects such as the Skibo Project. This research is also identifying possible management actions to take to increase the resilience of forest ecosystems on the Superior National Forest in the face of climate change. Scientists at Northern Research Station will be finalizing results of this research and submitting these for publication in a peer-reviewed scientific journal and a General Technical Report. Also, there is no requirement for projects to sequester the maximum amount of carbon possible. Forest management involves tradeoffs, and there are multiple goals, objectives, and considerations that go into a decision on the Skibo Project. Examples of these considerations include landscape ecosystem objectives, conserving wildlife, watershed protection, the provision of forest products, the protection of wilderness character, hazardous fuels reduction, as well as climate change. The Deciding Official will consider your concerns on climate change along with other comments in making a decision on this project.

14. M. Kaluzniak

Comment SS-014-1: “Thank you for the opportunity to comment on this project. I am a landowner in the Project Area. My comments relate mostly to the removal of “an old bridge”



cited as part A.4 in your May 10, 2012 Notice. I hope that you will accept these comments in a constructive manner and respond accordingly. Non-substantive Comments 1. Project Communication I would like to describe my experience regarding the public communication of this project. I have received no direct communication for the project sponsors after phoning and sending email. When trying to find project information today, I followed the url listed in your May 10, 2012 announcement (www.fs.usda.gov/superior/projects -> Land and Resources Management -> Projects). This led to the project page with no content (screenshot enclosed). I suggest that there are opportunities for improvement in this area.” Response: We apologize for our url being faulty. We have updated our projects webpage to reflect this, providing a new url. Project information can be found at: http://www.fs.fed.us/nepa/fs-usda-pop.php/?project=37817 or at www. fs.usda.gov/goto/superior/projects. Comment SS-014-2: “2. Public Participation I would welcome any opportunity to participate with SNF forest management activities (e.g. “interdisciplinary teams”, etc.) I am a professional environmental and land use planner.” Response: Thank you for your interest in the project. Hopefully the phone conversation on 26 April 2013 was helpful. We will remain in contact on this project and will notify you of any open house or field trip opportunities for the project. Comment SS-014-3: “Procedural Issue of Purpose and Need versus Proposed Actions 1. The Scoping Report identifies the removal of “an old bridge” as part of the Purpose and Need for the Proposed Action (Item A.4) but this Issue is not identified as a Proposed Action in the Scoping Report itself. I believe that this is a significant error, and ask that you remove this item from further consideration as part of the proposed project.” Response: During the development of the Proposed Action, the resource and heritage specialists identified the “old bridge” as an opportunity to enhance aquatic habitat and improve stream flow during the purpose and need for the project. The Scoping Report identifies the removal as part of the purpose and need and the project is listed in Table 2 as “Improve water quality through watershed restoration projects” as a proposed action. In Table 2 the outcome is listed as “2”, which includes (1) removing road fill from the Reno Creek Floodplain, and (2) removing the remnants of the St. Louis River Structure. As an identified possible project activity by the interdisciplinary team, the required heritage analysis was completed classifying the logging dam. Please see response to comment SS-012-1 and also section 3.10-Water Quality for the effects analysis. Comment SS-014-4: “2. I note also that Section A.4 relates to Water Quality and Aquatic Habitat Enhancement, however the bridge removal appears to have no nexus whatever to either the Proposed Actions (Appendix 2) or the Operational Standards and Guidelines (Appendix 3) in the Scoping Report. Additionally, this type of Action is also not clearly identified or supported



in the Record of Decision for the SNF Final Environmental Impact Statement (see USDA ROD, R9-SU-FEIS-ROD, July 2004). I am unable to determine the origin or specific purpose of this particular action anywhere in the project record.” Response: The opportunity to remove the logging dam was identified during the mid-level process for the project. Additionally, direction comes from the Forest Plan (D-WS-8, p. 2-11) which states that, “Hydrologic connectivity of aquatic ecosystems and wetlands is maintained or restored to assure passage of water, sediment, nutrients, wood, invertebrates, and fish and to facilitate freshwater mussel dispersal. The number of impoundments is minimized. Waters affected by dams are managed as much as practical to mimic natural lake levels and seasonal flows. Stream flows and lake levels on waters not affected by dams are suitable to protect habitat and maintain natural hydrologic processes.” Resource specialists determined that the opportunity of removing the dam could restore the natural hydrologic processes by restoring connectivity. The EA discloses the effects of the project on water resources in section 3.10-Water Quality. Appendix C-Operational Standards and Guidelines lists the standards, guidelines, and other routine practices that would be employed during implementation of the Skibo Project. Additionally, implementation of dam removal would utilize Minnesota Forest Resource Council Voluntary Site-Level Forest Management Guidelines and in accordance with conditions of the anticipated National Pollution Discharge Elimination System (NPDES) permit requirements to fulfill Clean Water Act standards. Comment SS-014-5: “Bridge Removal as Water Quality and Riparian Habitat Improvement. In this section, I would like to provide more site-specific comments and issues related to the proposed removal of the “old bridge”. I will identify specific issues of concern and ask that they be fully evaluated as part of an Environmental Impact Statement for the proposed project. The “old bridge” in question is comprised of the remnants of stone support from a small bridge crossing the river. The earliest known aerial photo of the area was taken on September 22, 1948 and the structure may be over a century old (see enclosed). Today, it appears to the casual observer as three piles of rocks and the area seems otherwise relatively undisturbed. There are no apparent physical remnants of the bridge itself. The photograph referenced above can be found at http://maps.dnr.state.mn.us/landview/historical_airphotos/projects/slc/y1948/slc_036_019.jpg. The photograph provides documentation of the historical conditions in the area. In order to fully analyze the proposed action, I ask that you include the following alternatives and effects.

1. Historical Significance. The original use of the bridge is unknown and I would request that the historical significance of the bridge be fully evaluated.”

Response: We also recognized the importance of evaluating the feature for historical significance. Thus, we have been working with the National Register of Historic Places and the State Historic Preservation Officer on determining if the feature is eligible for the National Register of Historic Places. Recently we heard back from SHPO with a determination that it is not eligible for the National Register of Historic Places. Please see response to Comment SS-012-1 for a more detailed response to this inquiry.



Comment SS-014-6: “2. Riparian Habitat. While it is clearly desirable to maintain and improve riparian habitat in the SNF, removal of these remnants are unlikely to result in improvement considering:

a. The existence of a significant mature turtle population that uses the immediate upstream area for breeding and nesting purposes. There are more than one species of turtles present and the proposed action may irrevocably impact their habitat. Removal of the old bridge would appear contrary to the USDA’s guidance (refer to How to Create Wood Turtle Nesting Areas, Buech and Nelson, USDA Forest Service, Mary 14, 1991).”

b. The proposed action may adversely affect the natural biota, including a wild rice stand immediately adjacent downstream. Other existing beneficial native plants at the site include high bush cranberry, hawthorn, etc.”

Response: Effects to the wood turtle (a sensitive species on the Superior National Forest) and mitigation measures can be found in the Biological Evaluation of the EA on the SNF projects webpage. Appropriate monitoring would occur at known nesting sites as specified in the BE. This site does not provide nesting habitat for wood turtles due to the lack of exposed nesting substrate. Wood turtle use in the area will continue to be monitored. Upon development of our Purpose and Need and Proposed Action, we did reach out to State, county, and tribal representatives. They did not respond with any concerns regarding the removal of the dam remnants. The EA will disclose any effects related to the removal of the dam. Comment SS-014-7: “The Scoping Report Purpose (section A.4) refers the reader to several pages of Objectives within the Forest Management Plan. The Plan itself does provide support for this proposed action, especially as it relates to improved water quality. For example, the reference to page 2-8 “Riparian Direction in the Forest Plan”, doesn’t specify how this proposed action would protect and enhance the area, and instead provides ambiguous statements such as: “Facets of the Forest Plan that differ from specific MFRC guidelines for riparian management are a matter of approach rather than substance or intent.”

The proposed action is directly contrary to other Objectives from Page 2-10 of the Forest Plan. See, for example:

i. D-WS-2 (subsistence uses) ii. D-WS-3 (conservation of genetic integrity of native species)

iii. D-WS-4 (management activities do not reduce existing quality of surface waters)

iv. D-WS-5 (altered stream flow does not limit aquatic biota or recreational uses)

D-WS-10 actually provides weight to leave the bridge in place (“Openings in riparian area vegetation …. occur infrequently and result in minimal alterations of riparian ecological function.”), not its removal. This objective is currently best met by a No-Action alternative. Similarly, several Objectives do not support the proposed action:



v. Objective O-WS-10 relates to soil disturbance during management activities themselves, and is seemingly unrelated to justification of the proposed action.

vi. O-WS-3, O-WS-4 and O-WS-5 relate to vegetation management and increasing basal areas. These items are seemingly unrelated to the removal of rocks within the river itself.

Based on this information, I respectfully request that if you intend to proceed with this project that a compete evaluation of this action be undertaken as part of an environmental impact statement.” Response: Direction for this project comes from the Forest Plan (D-WS-8, p. 2-11) which states that, “Hydrologic connectivity of aquatic ecosystems and wetlands is maintained or restored to assure passage of water, sediment, nutrients, wood, invertebrates, and fish and to facilitate freshwater mussel dispersal. The number of impoundments is minimized. Waters affected by dams are managed as much as practical to mimic natural lake levels and seasonal flows. Stream flows and lake levels on waters not affected by dams are suitable to protect habitat and maintain natural hydrologic processes.” Resource specialists determined that the opportunity of removing the bridge could restore the natural hydrologic processes by restoring connectivity. The EA discloses the effects of the project on water resources. Direction from D-WS-10 speaks to a desire to limit openings and alterations in riparian areas that result from infrastructure such as, “road crossings, trails, campsites, water access, or other recreational uses.” The removal of the infrastructure at the St. Louis River site would create an initial disturbance and loss of cover; however, after the restoration activity the area would be re-vegetated to the desired condition with native species. In the long term, this would fully satisfy D-WS-10. Objective O-WS-10 relates to the avoidance, minimization, and mitigation during soil disturbance activities such as the removal of floodplain berms and other materials associated with the site; similarly, S-WS-2, S-WS-3, G-WS-1 and G-WS-2 have outlined standards and guidelines for projects of this nature (i.e. disposal of “construction debris, spoils, or debris from dredging” and “topsoil”). Standard S-WS-6 provides additional best management practices for using heavy equipment within riparian areas that would be employed during project design and implementation. Comment SS-014-8: “Vegetation Management

a. The use of phosphate-based herbicides is of questionable value. The cumulative effects of applying phosphate-based materials are anathema to the natural conditions of SNF. Please evaluate the cumulative effect of increasing phosphates on the native plant communities.

b. Native plant species have evolved to adapt to low-phosphate conditions. Providing phosphate may result in opportunities for non-native species to establish themselves within SNF. Please evaluate the potential for increased invasive species as a result of applying phosphorus and include other alternatives (such as mechanical means) for vegetation management.



c. Section A.1 refers to increasing young aspen, yet the cited objective (O-VG-2) states that the objective is to decrease acres of aspen vegetation communities.

d. I would encourage a more granular evaluation of species within the Project area in order to develop plans which more closely relate to species diversification as identified in the Forest Management Plan.”

Response: Direct, indirect, and cumulative effects to implementing the proposed action (Alternative 2) on native plant communities can be found in the plant BE for the Skibo Project and Section 3.7-Non-native Invasive Plants. Additionally, the Superior National Forest Non-Native Invasive Plant Management Project EA has thoroughly analyzed the effects of herbicides on plants (USDA Forest Service 2006). Finally, please see Appendix H-Herbicide Proposal for information on herbicides proposed, risk assessments completed, and mitigations and project design criteria. Objective O-VG-2 should be replaced with O-VG-13 as the acres of young aspen are increasing while the overall acres of aspen forest type are decreasing. The statement discusses age class objectives while the listed Forest Plan objective discusses forest type composition. Acres currently in the aspen forest type are being managed with even age treatments to establish more acres in the youngest age class. Acres from the aspen forest type are also being managed to transition to other forest types. These two types of treatments are not mutually exclusive; however, the wrong objective was listed and should have been justified with O-VG-13.

Comment SS-014-9: “Restoration of SNF to Desired Conditions

a. I would ask that OHV and snowmobile usage within SNF be evaluated within the context of maintaining the minimum road system and riparian enhancement.

b. I would encourage the Forest Service to direct any clear-cutting activities to areas where they support other Objectives of the Forest Plan (e.g. Fire Protection, species diversity, etc.).

Thank you again for the opportunity to participate in this process. I appreciate the extreme challenges you face in this endeavor and look forward to the development of this project.” Response: Analysis of OHV and snowmobile use on the SNF was conducted as part of the Travel Management Project (Travel Management Project, SNF May 2008). In addition, Superior National Forest is directed from the Forest Plan (D-TS-2, p. 2-47) to maintain the minimum road system. Chapter 3.10 Watershed (Hydrology and Soils) beginning on page 3-35 of the Travel Management Project contains analysis conducted for effects to riparian areas. Superior National Forest roads and trails inventory will continue to be updated; as part of any new project, there may be a need to make changes to the road system. Each route proposed for closure or open to OHVs or snowmobiles would receive further analysis on any effects to natural resources and the social landscape. Also see the Recreation and Transportation sections of the EA for changes related to the Skibo Project. Stands that are proposed to use clearcutting as a primary vegetation management tool are meeting multiple objectives through that method. Clearcutting is the preferred method to regenerate some vegetation species and creates a disturbance as directed from the Forest Plan (G-TM-2 and D-VG-7). These openings also create spatial landscape patterns that are important for



many resources such as wildlife and plant species that require these types of disturbances and even-aged forests to thrive. Comment SS-014-10: “Thanks again for the opportunity to participate in this planning process. I have a couple additional items I’d like to offer. 1. Access to the St. Louis River in T58-R14W-S36. Although there are many separate access points for the St. Louis River, the one that connects to the Minnesota Department of Natural Resource (DNR) Land in T58-R14W-S36 has become hazardous. The road has many large ruts and vegetation has encroached upon the path. Additionally, the drain tile appears to have become exposed and is possibly not functioning properly. In addition to its use as public access (canoe launch) to the SLR, there are state leased tenants now use this land to access their cabins. The DNR classifies the road as “minimum maintenance” and therefore is unlikely to provide maintenance support. I note that there is a gravel pit identified within a mile of the road’s connection to Highway 110. I believe that this action is consistent with both the proposed project’s stated need and purpose and is supported by the Forest Plan desired conditions and objectives (D-TS-1 and D-TS-5, and O-TS-1 to- O-TS-8).” Response: The road you are describing is most likely FR 1060. This road is maintained as an OML 2 level road. Please see response to Comment SS-002-1 for more information on maintenance level. Improving this road has not been identified as an objective for the Skibo Project and is outside the scope of this project. Comment SS-014-11: “2. Forest Plan & Project Monitoring and Evaluation: I note that Forest Plan provides guidance for project monitoring and evaluation. As a planner, I observer that this crucial activity is often overlooked and encourage you to enhance the project plan to continue the improvements identified in the Project Scoping Report. It is also worth noting that the ‘shelf life’ of the Forest Plan is stated to be approximately 15 years (approximately 2019). I would encourage you to incorporate Monitoring and Evaluation objectives (including development of adaptive management actions) into the plan’s implementation strategies.” Response: Please see Appendix D-Monitoring Report in the EA describing the types of monitoring conducted on the Superior National Forest and those resource areas that would be monitored as part of the Skibo Project. In addition, the Superior National Forest also conducts Forest-wide monitoring on various resources. These reports are available on our website at http://www.fs.usda.gov/detail/superior/landmanagement/planning/?cid=FSM91_049718 Comment SS-014-12: “Related Actions to the Hardrock Mineral Prospecting Permit Project: I note that several maintenance activities of this project entail several actions similar (if not connected with) those of the Hardrock Mineral Prospecting Permit Project. I would encourage the Forest Service to evaluation opportunities for synergy and public involvement as they relate to these two projects. For example, restortation for exploration areas may provide unique opportunities for creating habitat for Rare Natural Resources as identified in Appendix A



of the Forest Plan. Similarly, members of the public may welcome an opportunity to help guide the specific restoration activities of these actions. Again, thank you for listening.” Response: The Skibo Project is not considered a connected action to the Federal Hardrock Mineral Prospecting Permit Project. The purpose and need for the Skibo Project is related to vegetation management, whereas the purpose and need for the Federal Hardrock Mineral Prospecting Permit Project is related to minerals management. Neither projects purpose nor implementation depends on completion of the other. That being said, if there are habitat restoration opportunities that exist in the Skibo Project area that would meet the Skibo Project purpose and need (see EA Section 1.4), we welcome public input on those opportunities. The more specific these suggestions, the more useful they are for considering a modification of the proposed action or alternatives. Habitat improvement opportunities may exist due to past or reasonably foreseeable disturbance such as from timber harvest, fire, or minerals management, or other activities. We would also note that stipulations already included in the decision on the Prospecting Permits Project require reclamation or restoration of disturbance from temporary roads and drill pads authorized in the Prospecting Permit Project.

15. Marlene Pospeck & Carol Youngberg-Superior National Forest Scenic Byway

Comment SS-015-01: “Thank you for the opportunity to comment on the proposed vegetation management actions in the Skibo Project Area. The Superior National Forest Scenic Byway (SNFSB) carries a high volume of tourism traffic along with the tremendous amount of industry traffic. We appreciate your efforts to maintain the scenic qualities of the route as you maintain and promote native vegetation. Because of the existing intrinsic qualities of this Byway, we respectfully request that you engage in best management practices for visual qualities within this project area. For example, we request that you consider eliminating all slash that would be visible from the road, use the landforms or provide islands of vegetation to provide visual screening between the road and clear cuts, and not allow harvest activity landings visible from the roadway. We ask that your staff be sensitive to the tourism nature of this Byway.” Response: Thank you for your comment. We also value and appreciate what these scenic areas provide to us and to Forest visitors. Appendix C-Operational Standards and Guidelines, which are the standards, guidelines, and other routine practices that would be employed during implementation includes a section on these practices for scenic resources. Guideline G-SC-5 would be included for the screening of log landings from travel ways, recreational sites, and bodies of water. This guideline also would reforest or rehabilitate these areas to mimic natural openings. Guideline G-SC-6 states to schedule mechanized activities during periods of low recreation use if mechanized activities can be viewed from travel ways, etc. These and other standards and guidelines will be included in the Skibo Project EA.



Comment SS-015-02: “SNFSB Council would also suggest that you consider leaving a pull off after work on a site is completed. We understand that roads will be built for equipment to enter onto specific sites. When work is done, there is opportunity to interpret forest management practices for the traveling public if there is a wide spot available on the shoulder, or a drive-in parking area off the road.” Response: Interpretations of actions and resources along the Byway are being looked at and planned for (three sites specifically). The development of parking and pull-in’s along temporary roads along the Byway is outside the scope of this particular management proposal but may be considered in the future for recreation and scenic enhancement. Comment SS-015-03: “We also request that work on this project be sensitive to the historic site where the old town of Fairbanks was located, which appears to be adjacent to a proposed clear cut. The local residents are developing a side tour, off the Scenic Byway in the Toimi/Fairbanks area, which will incorporate this site and others.” Response: The Skibo Project will be sensitive to the town remnants of Fairbanks. If there are harvest areas near the historic site, heritage crews would survey the area and flag and avoid the site to keep it out of timber activities. Comment SS-015-04: “While we understand that interpretation of forest management is not a part of this project, we respectfully request that you consider every opportunity to provide this for the traveling public. We are in the process of creating an Interpretive Plan for the SNFSB which addresses the importance of enhancing the travelers’ experience with information about what they are seeing along the route. Options are endless including simple signs that state, for example, “Norway Pine, planted 19__”, to more comprehensive information such as what we see at Heartbreak Hill on the Tofte Ranger District. We look forward to hearing more about this and other projects along the SNFSB. We appreciate the opportunity to partner with the Forest Service in managing and interpreting the Scenic Byway corridor, promoting the intrinsic qualities of the route and providing travelers with a high quality experience.” Response: Thank you for your comment. We have informed the recreation/scenery resource specialist of your request.

16. Tony Sullins, U.S. Fish & Wildlife Service

Comment SS-016-01: “This responds to your May 10, 2012, letter regarding the proposed Skibo Project to be conducted on the Laurentian Ranger District of the Superior National Forest (Forest). The Forest is proposing vegetation management actions in St. Louis County, Minnesota. The purpose of the Skibo Project is to maintain and promote native vegetation communities that are diverse, productive, healthy and resilient. The project would involve various types of vegetation management including; regeneration harvest, thinning, planting, site



preparation and herbicide application. In addition, this project proposes to manage current transportation infrastructure by adding roads and decommissioning unneeded roads. There is one federally-listed endangered species as described under the Endangered Species Act of 1973 (ESA), as amended, within St. Louis County, Minnesota; Canada Lynx (Lynx Canadensis). Additionally, the proposed project is located within designated Canada lynx critical habitat. If the project may affect listed species or their critical habitat, the Forest should initiate consultation under Section 7 of the ESA.” Response: Thank you for your comment. Canada Lynx was analyzed in the BE and appropriate mitigations would be taken during implementation. Comment SS-016-02: “The Bald Eagle (Haliaeetus leucocephalus), which is also found in St. Louis County, is protected under the Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act (Eagle Act). There may be bald eagle nests within or nearby the project area. Please note that nesting data provided by the Minnesota DNR’s Natural History Database may not reflect current eagle nest status. New nests could have been built, and older nests may no longer exist. For this reason, the Fish and Wildlife Service recommends the Forest visit historic nest sites, as well as conduct eagle nest surveys within 660 feet of the project area for normal activities, or ½ mile for things involving loud noises (e.g. use of explosives). The Service is available to discuss nest survey protocol, and will work with you to determine if a disturbance permit is needed.” Response: During the midlevel field assessment period for the project, field checks were completed for the project area. This included historic nest sites and searching for new or occupied nest locations. One active eagle territory/nest was located within the project area. Additionally, crews located one nest south of the project area. Recovery Plan guides would be followed for this species. These include protecting nests with concentric zones of 0 - 330 ft. - no activities except those to protect nest site; 330 - 660 ft. - allow only activities not making a significant change in the landscape; 660 – 1320 ft. activities allowed during “low” and “non-critical” periods or approximately between July 15 and March 30. Maintain potential nest, roost, and perch trees. For more information on mitigation measures for bald eagle, please see Appendix C, pg. C-14 and 15.

Comment SS-016-03: “Wetland disturbance within the project areas should be minimized to the greatest extent possible. All temporary and permanent wetland impacts should be permitted as appropriate through Section 404 of the Clean Water Act, administered by the U.S. Army Corps of Engineers, and the Minnesota Wetland Conservation Act, administered by the State-appointed Local Government Unit.” Response: Effects of management activities on water resources are analyzed in the section 3.10 of the EA. Site-specific mitigations and Forest Plan direction would be adhered for all project activities. Specific management direction can also be found in Appendix C, under Watershed Health, Riparian, and Soil Resources (WS), beginning on p. C-3.



17. Curt Heikkila

Comment SS-017-01: Mr. Heikkila phoned to receive more information on Units 191-194, near his property. He is interested in logging his properties when the USFS units are harvested. He would like information on the logger when that information is available. The project leader spoke to Mr. Heikkila, answering his questions and providing information on the process and timeline for the Skibo Project. Response: The project leader spoke to Mr. Heikkila, answering his questions and providing information on the process and timeline for the Skibo Project. Timber administrators make an effort to contact local landowners prior to harvesting National Forest System lands nearby.

18. Scott Tyo Comment SS-018-01: “The Fairbanks Township Board thanks you for the opportunity to comment on the proposed vegetation management actions in the Skibo Project Area, particularly those that affect Fairbanks Township. We support responsible forest management practices. We further support the concerns presented by the Superior National Forest Scenic Byway Council as they pertain to visually maintaining the qualities of the entire Scenic Byway. We request that consideration be given to maintaining the integrity of the Byway, especially where opportunities for historic interpretations might be jeopardized by clear-cutting and slash piles, such as near the old town of Fairbanks. It appears that a major clear-cutting is proposed near the entrance to Otto Lake Road. We do not object to a possible pull off area, after work on a site is completed, but would ask that the Board be advised of any plans to that effect. Responsibility for maintaining such an area would have to be determined, particularly within Township boundaries.” Response: Thank you for your comment. All stands that would receive primary, secondary or reforestation treatments will be identified in the EA. We will pass your concerns for prior notification onto the Sale Administrator to contact you prior to treatment. Regarding your comment on maintaining the scenic integrity of the area, please see the response to comment SS-016-01 in regards to Operational Standards and Guidelines that would be applied to all scenic areas within the project area, especially the Superior National Forest Scenic Byway. Comment SS-018-02: “Please add Fairbanks Township to your mailing list of interested parties in T.56N – R.12W & 13W, Laurentian Ranger District of the Superior National Forest. We welcome the opportunity to be kept informed of and comment on projects and progress in our area. Thank you.” Response: Fairbanks Township will remain on the Skibo Project mailing list.



19. Craig Engwall-MN DNR

Comment SS-019-01: “The Minnesota Department of Natural Resources (DNR) appreciates the opportunity to review and comment on the Skibo Project Scoping Report. The scoping document lays out a reasonable plan to manage vegetation and forest roads in the area. Topics of concern identified by DNR staff include ensuring adequate access for mineral exploration activities and protection of water quality/fish habitat when managing vegetation in riparian zones. There are private mineral exploration companies with ongoing activities in the Skibo project area and it is possible some of them may have concerns with specific road decommissioning proposals. We recommend that the USFS coordinate the road management proposals with the exploration firms to ensure adequate access for mineral exploration activities.” Response: Thank you for your comment. We appreciate your partnership and will outreach to mining companies that may be drilling surrounding the Skibo Project area to see if they have any comments. Comment SS-019-02: “A number of the proposed vegetation treatments are designed to improve water quality and riparian habitat by planting or seeding long-lived conifer species within riparian corridors. The DNR supports these treatments as long as they incorporate BMPs for riparian harvest and will not be using herbicide treatments adjacent to water bodies.” Response: Specific Forest Plan Operational Standards and Guidelines would be applied to all stands identified by resource specialists within the project area. These would include mitigations found in Appendix C-Operational Standards and Guidelines (Watershed Health, Riparian Areas, and Soil Resources (WS). Units within the Skibo Project Area that would be part of the pilot study to be treated with herbicide have been identified to avoid proximity to all lakes, rivers, streams, and campgrounds. Comment SS-019-03: “The DNR also offers the following resource information that may be relevant to your environmental assessment of the Skibo project. In T56 R12 Sec19 northeast of Wolf Lake there is a rich fen through a cedar and tamarack swamp. There are upland stands proposed for treatment to the north and east in Sec19 and 18. Timber harvest may be compatible, but be aware that there is significant subsurface water flow in the area.” Response: This will be noted on out prescription cards and will be looked at during the site visit. If needed, the prescription will protect areas that could be negatively affected by timber harvest. Currently unit 327 is a winter only harvest. Units 325 and 326 are dry or frozen ground harvests. If the site visits shows a chance of ground disturbance from summer harvest it will be changed to a winter only harvest. Comment SS-019-04: “MBS has recently released final GIS datasets delineating 1) MBS Sites of Biodiversity Significance for the Toimi Uplands Subsection and 2) native plant communities within MBS Sites of Outstanding and High Biodiversity Significance for the Toimi Uplands



Subsection. The Skibo Project intersects some of these data. The DNR Biotics Database (i.e. rare features data) is also up-to-date for the project area. A cursory review of this database found 27 Biotics within 0.25 miles or less of Skibo proposed project polygons. A more detailed review of these data is warranted as part of Skibo Project assessment. Data are available from the DNR Data Deli or by contacting Bruce Carlson, Regional Plan Ecologist ([email protected]) if needed. The MN DNR looks forward to continued interagency coordination of resource management actions as the Skibo project moves through the environmental assessment and implementation stages.” Response: Thank you for this knowledge. We also look forward to continued interagency coordination of natural resource planning of the Skibo Project and future projects on the SNF.


June 2013 G-1 Appendix G

APPENDIX G SKIBO ROAD PROPOSALS

The following table displays information on the specific roads that would be decommissioned, added to the road system, or granted special use permits under all action alternatives. See alternative maps for locations of roads to be decommissioned. Table G-1: Skibo Project - Proposed Road Changes with Alternatives 2 and 3 Map ID INFRA ID Miles Decision TMR decision1

D2 U111805A 0.0 deco

D3 U1SC11016 0.3 deco

D4 U1TR10284C 0.6 deco

D5 U1SC11001 0.3 deco

D6 U179103 0.1 deco

D7 U179109 0.5 deco

D8 U179101 0.1 deco

D9 U179105 0.1 deco

D10 U113020 0.0 deco

D11 U1SC11007 0.2 deco

D12 U1RR0103 0.5 deco

D13 U1RR0104 0.4 deco

D14 U1SCRR02 0.2 deco

D15 U1128E01 0.5 deco

D16 U1128C05A 0.2 deco

D17 U1128CC01 0.2 deco

D18 U1128CC01A 0.1 deco

D19 U1128E 0.1 deco

D20 U1SC56902 0.3 deco

D21 U113011 0.3 deco

D22 U1TR1100114A 0.1 deco

D23 U1TR1100113 0.0 deco

D24 U1TR1100115A 0.2 deco

D25 U1TR1100115B 0.8 deco

D26 U1130E02A 0.2 deco

D27 U1130C05 0.5 deco

D28 U1130C05A 0.6 deco

D29 U1130C05AA 0.1 deco

D30 U113017A 0.1 deco

D31 U1130C06 0.3 deco

D32 U1130C06A 0.5 deco

D33 U1130C07 0.4 deco



Table G-1: Skibo Project - Proposed Road Changes with Alternatives 2 and 3 Map ID INFRA ID Miles Decision TMR decision1

D34 U1130C08 0.1 deco

D35 U11301501 0.7 deco

D36 U11301502 0.3 deco

D37 U113015 0.3 deco

D38 U11301503 0.1 deco

D39 U112902 0.1 deco

D40 U1TR1100112 0.1 deco

D41 U113019 0.1 deco

D42 U113003 0.2 deco

D43 U1130KA01 0.2 deco

D44 U1130KA02 0.2 deco

D45 U1128F01A 0.3 deco

D46 U1SFRSC01 0.5 deco

D47 U1128BA 0.4 deco

D48 U1128F04A 0.1 deco

D49 U1128F06C 0.2 deco

D50 U1128F06A 0.1 deco

D51 U1128F06B 0.2 deco

D52 U11602E 0.3 deco

D53 U11602C 0.2 deco

D54 U11602C01 0.5 deco

D55 U11602G 0.3 deco

D56 U11602D 0.2 deco

D57 U11602F 0.2 deco

D58 U1SU1118B01 0.1 deco

D59 U1118A01 0.6 deco

D60 U1SC345 0.2 deco

D61 U1SC345 0.2 deco

D62 U1TR110010601 0.1 deco

D63 U111805A 0.2 deco

D64 U1118G01 0.1 deco

D65 U1SU17760201 0.8 deco

D66 U1SU17760203 0.3 deco

D67 U1SU17760202 0.1 deco

D68 U1111805 0.5 deco

D69 U111803A 0.0 deco

D70 U111801 0.4 deco

D71 U1771D01 0.3 deco

D72 U1771D02 0.1 deco




D73 U1771D05 0.3 deco

D74 U1112102 0.1 deco

D75 U1112103 0.2 deco

D76 U11121A 0.5 deco

D77 U1118HA03 0.9 deco

D78 U1112106 0.1 deco

D79 U11121C02 0.1 deco

D80 U11121B01 0.2 deco

D81 U111901 0.9 deco

D82 U1416GC01 0.1 deco

D83 U1416GAA 0.4 deco

D84 U1416GC02 0.9 deco

D85 U1121AAA 0.4 deco

D86 U141603 0.6 deco

D87 U1413H01A 0.1 deco

D88 U1413H04 0.5 deco

D89 U1128F03 0.1 deco

D90 U1771D01 0.7 deco

D91 U1771D01A 0.1 deco

D92 U1TR1100110 0.1 deco

D93 U1416A01 0.2 deco

D94 U1RR0105 0.2 deco

D95 U1413H01 0.2 deco

D96 U1413H03 0.3 deco

D97 U1413H02A 0.4 deco

D98 U1PVTRR01 0.6 deco

D99 U141601 0.3 deco

D105 U1128BA 0.1 deco

D106 U1SC11014 0.3 deco

D107 U179104 0.2 deco

D108 U112903 0.4 deco

D109 U1SC11019 0.1 deco

D110 U1SC11020 0.2 deco

D111 U11112A 0.1 deco

D112 U11112B 0.1 deco

D113 U1SC1610 0.2 deco

D114 U1SC 1607B 0.2 deco

D115 U1SC1607A 0.1 deco

D116 U1SC1608 0.2 deco




D117 U1111901 0.3 deco

D118 U1SUSC11002 0.2 deco

D119 U1SUSC11002 0.1 deco

D120 U1RR0101 0.1 deco

D121 U1SC11005A 0.2 deco

D122 U1128C01 0.1 deco

D123 U1RR0103 0.3 deco

D124 U1RR0108 0.2 deco

D125 U1SCRR01 0.1 deco

D126 U11121A03 0.1 deco

D127 U1SU1111401 0.1 deco

D128 U11121C01 0.1 deco

D129 U1771D05 0.3 deco

D130 U1118IA 0.1 deco

D131 U1118HA01 0.2 deco

D132 U1118HA02 0.2 deco

D133 U111121A02 0.2 deco

D134 U111121A01 0.3 deco

D135 U1PVT11180401A 0.4 deco

D136 U177103BA 0.1 deco

D138 U1TR1100114 0.1 deco

D139 U113018 0.4 deco

D140 U11301502 0.2 deco

D141 U113015 0.2 deco

D142 U112902 0.1 deco

D143 U11602C 0.1 deco

D144 U1128CC01 0.0 deco

D145 U1111805A 0.1 deco

D146 U1111201 0.1 deco

D147 U11112 0.6 deco

D148 U1106101 0.1 deco

D149 U1106101 0.2 deco

S1 13017 0.1 cs1 deco

S2 1606 0.6 cs1 deco

S3 118HA 0.1 cs1 deco

S4 160201 0.1 cs1 deco

S5 1110 0.3 cs1 deco

S6 1122 0.4 cs1 deco

S7 1110 0.2 cs1




S8 42201 0.3 cs1

S9 160201 0.5 cs1

S10 U1128C02 0.3 cs1

S11 1822A01 0.4 cs1

S12 13001A 0.1 cs1

S15 128F01 0.2 cs1

S16 128F02 0.4 cs1

S17 128F03 0.5 cs1

S18 1100 1.5 cs1

S19 1100A 0.1 cs1

S20 1115 0.3 cs1

S21 771D01 0.3 cs1

S22 771D02 0.3 cs1

S23 118HA 0.4 cs1

S24 416B 0.1 cs1

S25 416E 0.0 cs1

S26 42201 0.1 cs1 deco

S27 416GB 0.3 cs1

S28 1110 0.2 cs1

S29 1110 0.3 cs1

S30 U1SC11018 0.3 cs1

S31 13017 0.4 cs1

S32 110D 0.1 cs1

S33 1115 0.1 cs1

S34 1602AA 0.3 cs1

S35 1606 0.2 cs1 deco

S36 U1128C02 0.2 cs1

S37 LAU1002-23 0.1 cs1

S38 MP&L100 0.2 cs1

S39 MP&L100 0.2 cs1

S40 1100 0.7 cs1

S41 128F01 0.1 cs1

S42 13001 0.3 cs1

S43 128C 0.2 cs2

S44 1180401 0.6 cs2 deco

S45 41301 0.1 cs2 deco

S46 110C 0.1 cs2

S47 417E 0.1 cs2

S48 118H 0.5 cs2




S49 1121E 0.1 cs2

S50 1121D 0.0 cs2

S51 RR01A 0.1 cs2

S52 413A 0.1 cs2

S53 413B 0.0 cs2

S54 416D01 0.1 cs2

S55 118H 0.4 cs2

S56 110E 0.2 cs2

S57 1121AA 0.0 cs2

S58 U1SFRSC01 0.4 cs2

S59 1180401 0.1 cs2

S60 1600 0.9 cw1

S61 128C01 0.9 cw1

S62 1123 1.2 cw1

S63 1123A 0.3 cw1

S64 56902 0.3 cw1

S65 56902 0.1 cw1

S67 56902 0.2 cw1

S68 1600 1.2 cw1

S69 1123 0.8 cw1

S70 1600A 0.1 cw1

SP1 SU11121A01 0.3 sup sup

SP2 SU1121A01 0.4 sup

SP3 SU1SC1601 0.1 sup deco

SP4 SU1SC11001 0.1 sup deco

SP5 LAU1071-56 2.4 sup

SP6 SU1118B01 0.1 sup

SP7 SU1SC1602 0.3 sup

SP8 SU111805 0.1 sup

SP9 SU1118H01 0.2 sup

SP10 SU1118E01 0.7 sup

SP11 SU1SC61802 0.2 sup

SP12 SU1SC61802 0.1 sup

SP13 SU1SC61801 0.2 sup

SP14 SU177602A 0.1 sup

SP15 SU11121A02 0.0 sup

SP16 SU141301 0.2 sup

SP17 SU1SC1601 0.5 sup

SP18 SU1SFR20501 0.3 sup




SP19 SU1112101 0.1 sup

SP20 SU1118B01 0.1 sup

SP21 SU1SC61801 0.1 sup

SP22 SU111805 0.3 sup

SP23 SU111804 0.1 sup

SP24 SU1112101 0.4 sup



SP27 LAU1002-36 0.3 sup

SP28 LAU1071-55 0.2 sup

SP29 LAU1002-36 0.2 sup

SP30 LAU1071-56 0.0 sup

T1 PeqTr1 0.3 tr

T2 PeqTr2 0.3 tr 1 – Documents changes to previous Travel Management decisions

Abbreviations used in Table: Deco – Decommission road Cs1 – Classified Operational Maintenance level 1 road – closed when not in use Cs2 – Classified Operational Maintenance level 2 road – open to high clearance vehicles Cw1 – Classified winter operational maintenance level 1 road – closed when not in use Sup – Special use permit – some short-term access and some long-term access Tr – Trail reroute



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June 2013 H-1 Appendix H

APPENDIX H HERBICIDE PROPOSAL

Competition from early-successional vegetation (herbaceous and woody) is often an obstacle land managers face in forest management in northeastern Minnesota. Historically, with disturbances such as fire, pioneer species like paper birch would easily reestablish itself within 30 years of the event. With fire suppression and previous land management objectives, today’s remaining stands of paper birch have begun to decline due to their short lifespan. Paper birch regeneration has proven difficult and expensive in the last several years on the Superior National Forest. Successful regeneration of paper birch has been limited due to competition from other species. Fire suppression over the last 70 years, along with challenges of implementing prescribed burns (due to seasonality constraints, safety, and budget) has allowed only a limited amount of restoration by reintroducing fire. Mechanical site preparation has been the primary method used for paper birch regeneration on the Superior National Forest in recent years. Another common tool used in forestry to aid in regeneration survival and growth is site prep with an herbicide treatment previous to planting or natural regeneration. The Skibo Project Area has opportunities to use herbicide on a limited basis as a tool for enhancing the presence of paper birch and pine species through competition control. The use of herbicide during site preparation would be considered on a trial basis to determine ecosystems benefits, treatment efficiency, and cost savings in comparison to prescribed fire and mechanical treatments. Increasing or maintaining the amount of paper birch and pine within our landscape is an objective of our Forest Plan and highlighted in many of our NEPA documents. Paper birch also has cultural significance to local Native American bands which includes the traditional use of the bark for basketry and canoe building. Broadcast applications of herbicide in combination with some form of mechanical treatment (timber harvest, rock rake, disc trench, etc.) would increase the amount and survival of paper birch and pine regeneration by giving seedlings a few years with reduced competition for water, light, and other resources. This would allow for increased diameter growth and a greater photosynthetic area to allow for seedlings to survive competitor influence into the sapling stage. Dominant competitors of early-successional forests can take on a variety of growth forms (i.e. tree, shrub, forb, grass, and fern). Herbaceous competition can be up to 30 percent more competitive towards seedling survival than woody competition (Bell et al. 2000). Through the utilization of herbicide for an initial treatment, costs for establishing a stand of paper birch or pine could be lowered due to a reduced need for maintenance activities such as release in comparison to a mechanical or prescribed fire treatment. For example, following a mechanical site prep or prescribed fire treatment without herbicide, young stands will typically need up to three releases to successfully establish themselves to a “free to grow” state. With herbicide we could see this reduced to a single site prep entry followed by minimal amounts of follow-up treatments. Costs associated with initial field work, along with future contract administration and follow-up field surveys would be less than mechanical or prescribed fire treatments. In turn, this financial savings could free up funds to meet Forest Plan objectives on other sites as needed.



Treatments would be carried out through a broadcast ground application on a tractor mounted boom. Application methods may include:

Broadcast application following harvest in combination with a mechanical scarification treatment.

Pre-harvest application in combination with a mechanical scarification treatment. Broadcast application following harvest with no other site preparation treatment.

Figure H-1: Examples of broadcast applications of herbicide from a rubber-tired skidder tractor on a post-harvest site.



For this project, the gross treatment area would be approximately 200 acres on seven of the proposed units. Approximately 1 to 3 gallons/acre of herbicide would be used on this project depending on the application method, herbicide used, and species treated. Minnesota Forest Resources Council Site-Level Guidelines for herbicide application as well as label guidelines would be strictly adhered to. Herbicide would only be applied to upland units and would avoid any wetland inclusions. The proposal would also utilize prescribed fire and mechanical site prep treatments in combination with hand release treatments as tools to treat similar-size areas with similar biotic and abiotic site features. This would enable a comparison of costs, staffing needs, and effectiveness of treatments in meeting the Forest Plan objectives. Example of the Kinds of Herbicides Proposed for Use Recent studies have examined the impacts of commonly used herbicides in forestry and have found these chemicals to have little effect because the active ingredients are designed to only effect plant biochemical systems, degrade quickly in soil, and to have low amounts of soil mobility (Stoleson et al. 2011, Shepard et al 2004, Miller and Wigley 2004, Sullivan 1996, Tatum 2004). In some cases, herbicides can have temporary impacts to non-target resources (e.g. herbaceous plant diversity after the first few years of treatment) (Ristau et al. 2011). Direct dietary exposure of fauna to the proposed herbicides would be minimized by choosing less desirable foraging sites, and season of application. The indirect dietary exposure to predators through prey that had been exposed is very unlikely because none of the proposed herbicides bioaccumulate and all proposed herbicides would be excreted rapidly from prey animals’ bodies (NNIP EA 2006, Tatum 2004, Koeppe et al. 1991). The following table (Table H-1) displays herbicides that could be used for site preparation. They are all chemicals that can be purchased at local garden and farm centers. Sulfometuron methyl would be used to control perennial and annual grasses as well as broadleaf plants; it does not require a surfactant. Tryclopyr is used to control woody and herbaceous broadleaf plants including willow and maple. Tryclopyr does not impact grasses and may require a surfactant. Glyphosate is used to control herbaceous plants, brush and trees including aspen. Glyphosate requires a surfactant. All three of these chemicals may be combined in a tank mixture to target individual species. Effects to non-target resources are expected to be minimal when design criteria are followed. Risk assessments performed by the Forest Service have evaluated the risk of impacts to human health and fish and wildlife (SERA 2011a, SERA 2011b, SERA 2004). A risk assessment done by the Bureau of Land Management also evaluates the risk of impacts for sulfometuron methyl (ENSR 2005). The risk of impacts towards non-target resources increases with poor weather conditions during application, high winds that perpetuate drift and inadequate buffers to protect resources such as waterways and crops. Resource specialists would analyze the effects of these treatments and chemicals for the Skibo Project Area. If necessary, additional design criteria could be added to further address concerns for non-target resources.



Table H-1: Herbicides Used for Site Preparation

Common Chemical

Name

Some Examples of

Trade Names

Targeted Use

Risk Assessment (Link found in Literature

Cited )

Triclopyr

Garlon3A®; Garlon4®; Brush-B-Gone® Habitat®; Vine-X®

Boom spray (Broadcast foliar)

SERA 2011a

Glyphosate

Rodeo®; Accord XRT® Aquamaster®


SERA 2011b

Sulfometuron Methyl

Oust®; OustXP®


SERA 2004

Specific herbicides that could be used as appropriate are the following:

Glyphosate (N-[phosphonomethyl] glycine) is a non-selective, broad spectrum, systemic herbicide with no soil residual activity that is used to control many annual and perennial plants. Glyphosate by itself is of relatively low toxicity to birds, mammals, and fish, but the surfactants in some formulations are highly toxic to aquatic organisms (Tu et al. 2001).

Triclopyr ([{3, 5, 6-trichloro-2-pyridinyl} oxy] acetic acid) Triclopyr is a selective systemic herbicide used to control woody and herbaceous broadleaf plants along right-of-ways, in forests, and in grasslands and parklands. It has little or no impact on grasses.

Sulfometuron Methyl (2-[[[(4-methoxy-6-methyl-1,3,5-triazin-2-yl)amino]-oxomethyl]sulfamoyl]benzoic acid methyl ester) is a non-selective, sulfonyl urea herbicide used in the control the growth of broadleaf weeds and grasses.

Cost/Benefit Analysis: The cost for site preparation and follow-up treatments with mechanical site preparation alone is roughly two times more expensive than a treatment with herbicide (Figure H-2). This assumes that there would need to be three releases on a mechanical treatment vs. one follow-up release treatment on an herbicide treatment in combination with a mechanical treatment. Other assumptions are a $200/acre contract rate would apply for release treatments (current contract rate), a mechanical site prep contract rate of $130/acre (current contract rate) and an herbicide treatment cost of $120/acre (based on correspondence with St. Louis County, price includes application and chemical). Overall costs, without inflation or overhead, would be approximately $730/acre on a normal mechanical site prep site compared to approximately $450/acre on an herbicide treatment site.



Figure H-2: Cost Comparison of Mechanical Treatment and an Herbicide with Mechanical Treatment on 200 Acres

Mitigations and Project Design Criteria: The project is designed to reduce or eliminate potential adverse effects of our actions. All management would adhere to the following design features:

Minnesota Forest Resources Council Site-Level Guidelines for herbicide application as well as label guidelines would be strictly adhered to.

All guidelines presented in Forest Service Manual 2150, Pesticide Use Management and Coordination, in Forest Service Handbook 2109.14, Pesticide Use Management and Coordination Handbook, and in the Forest Service Health and Safety Code Handbook Chapter 22.1 would be observed. Also, compliance with all federal, State, and local regulations regarding herbicide use would be ensured.

Coordinate with the 1854 Authority for sage concern.

Herbicide Application

o All treatments would be planned to minimize undesired impacts on non-target vegetation.

o No herbicides, even those labeled for aquatic use, would be applied to streams, lakes, wetlands or vernal pools.

o No usage of herbicide within filter strips and riparian management zones of streams, lakes, or open water wetlands (Minnesota Forest Resource Council – Voluntary Site Level Forest Management Guidelines).

o Notices would be posted near all areas which have been recently treated with herbicides.

All treatments would be designed to ensure that they do not negatively impact Threatened, Endangered, or Sensitive species.

$0

$20,000

$40,000

$60,000

$80,000

$100,000

$120,000

$140,000

$160,000

Mechanical Herbicide +Mechanical

Mechanical

Herbicide + Mechanical



o If any TES species are observed during implementation of control activities (other than raptors flying by overhead or a wolf passing by), work would stop until the District Wildlife Biologist is consulted. Treatments would be revised as necessary to avoid impacts to the subject species.

o No treatments would be conducted within 860 feet of known nests occupied by the northern goshawk or bald eagle during the breeding season (March 1 to August 30). This distance represents a nest area of roughly 50 acres, centered at the nest.

o No treatments would be conducted within 300 feet of known nest sites of boreal and great gray owls during the breeding season (March 1- June 1).

o No herbicide application would occur at known occurrences of Nabokov’s Blue or Freija’s Grizzled Skipper.

o When work is conducted in areas containing rare or sensitive plant species, those plants would be flagged or marked and operators would be trained to visually recognize the protected plants and would not apply herbicide on or near those plants.

To protect terrestrial adult frogs and toads; formulations of glyphosate which contain polyethoxylated tallow amine (POEA) surfactants would not be used.

Environmental Variables

o Herbicide application would only occur when wind speeds are less than 10 mph, or according to label direction to minimize herbicide drift.

o Weather forecasts would be obtained prior to herbicide treatment and would not be conducted if forecast is unfavorable (such as during high winds or impending storms). Treatment activities would be halted, if necessary, to prevent runoff during heavy rain events.

Storage and Handling of Herbicides

o Mix and load herbicides outside of wetlands, areas with poorly drained soil, filter strips, and riparian management zones.

o Herbicide label directions would be carefully followed. This could include temporary closure of treatment areas for public health and safety.

o Appropriate protective gear would be worn by herbicide applicators per label direction.

o Herbicide containers would be disposed of following label specifications, State and federal laws, and Forest Service guidelines.

o Herbicides stored on-site would have Material Safety Data Sheets per Forest Service guidelines.

o All individuals working with herbicide would review corresponding Material Safety Data Sheets.

o Rinse water for cleaning or rinsing actions in conjunction with herbicide treatment would be disposed of according to label instructions.



Contractor and any employees must be licensed as a commercial pesticide applicator with categories in “Forest Spraying” and “General Ground” application as required by the MN Dept of Agriculture.

Equipment

o Broadcast application will be applied using a tractor, skidder, tracked vehicle, or a pull-behind trailer mounted spraying device.

o Field operator’s mechanical ground spraying systems will be equipped with GPS navigation and mapping system when applying herbicide. The system will be capable of logging and downloading spray application data.

o Equipment will be capable of precise calibration to assure that the prescribed rate of herbicide is applied on each tract. In no cases should applied rates exceed the maximum rate indicated on the product label.

o Chemical injection equipment is an acceptable and preferred method to tank mix methods of chemical mixing and application.

o Liquid Holding Tanks carrying spray solution will possess and at all times have operating a self-agitation system. To avoid unequal distribution of herbicide in the tank, tanks will be agitated and mixed for at least 10 minutes before spraying.

o A backflow prevention device or fixed air gap will be used on all chemical application equipment.



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