glacier loon fuels reduction and forest health...

GLACIER LOON FUELS REDUCTION AND FOREST HEALTH DECISION NOTICE

APPENDIX 5 – RESPONSE TO COMMENTS RECEIVED ON THE ENVIRONMENTAL ASSESSMENT

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E-6. F. L. WHITSELL COMMENT # RESPONSE

From: FLWHITSEL To: FS-comments-northern-flathead-swan-lake; GKnight; CorkP ; clark;

trailsendSubject: Options Date: Friday, September 21, 2012 10:36:43 AM

First you need to understand that the LLHO's worked very hard in the early 1990's to secure the 4 sections of land around Lindbergh Lake to keep it from being logged or otherwise threatened. So now you have a bad plan to undo our many years of effort.

1

Response to Comment #1: Several comments were received on the Environmental Assessment concerned with how proposed treatments could affect scenic and water quality values in the Lindbergh Lake Area. In response to comments such as yours, Alternative D with some modifications was chosen as the Selected Alternative. The Selected Alternative (Alternative D with Modifications) defers treatment of Units 84, 85, and 87; Units 83 and 86 are also deferred in the Selected Alternative. Also located on the west face of Lindbergh Lake, National Forest System Roads #10734, #10732 and #10733 will be fully recontoured and decommissioned under the Selected Alternative. In addition, several acres located on the western slopes of Lindbergh Lake are currently Management Area (MA) 15 under the Forest Plan. Due to public comments received concerning the Lindbergh Lake Viewshed, Alternatives C and D would propose to change the identified MA 15 acres to MA 5. As discussed above with this decision, I am authorizing a project-specific amendment to the Flathead Forest Plan related to a change to Management Areas (MA) for a portion of the Glacier Loon Project Area along Lindbergh Lake. This will change the Visual Quality Objective from “modification/maximum modification” to “retention” which will raise the level of current and future scenic integrity management for that land area. There will be no negative impacts associated with this change and this change will potentially have a long-term beneficial impact for the scenic quality of the Lindbergh Lake Area. Please refer to the “Decision” and “Rationale for My Decision” Sections in the Decision Notice starting on page DN-12 for more details.



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E-6. F. L. WHITSELL COMMENT # RESPONSE

I am against most of your ideas but I could rationalize helicopter logging only for the dead material.

2 Response to Comment #2: Helicopter logging and other methods were considered during the project development stages, and a variety of treatments were considered for the stands in question. Helicopter logging was determined to be not feasible for the small scale, and low volume of material present in the stands within the viewshed of Lindberg Lake. As stated above, treatment of Units 83 thru 87 proposed on the west shore of Lindbergh Lake will not be implemented in this decision.

Did you not understand where LLHO's were and are coming from after so many years of effort to retain the viewshed. You seem intent on ignoring the work of many. Do you, the Government, want to forge ahead with your own agenda when it was clearly stated why the US Forest Service was being given this land as a guardian for it's protection. I would like to see my government respond to the desires of the citizens and the taxpayers. I admonish you not to destroy what so many have worked so hard to preserve. Regards, F.L. Whitsell (Lou) 3317 Hollis Missoula, Mt. 406 544 0087

3

Response to Comment #3: We received 31 comments on the Environmental Assessment. I considered these comments in my decision and used them to help shape the Selected Alternative. In arriving at a decision for this project, I recognized that I would not be able to satisfy all public concerns, as many of them are mutually exclusive. I made a decision that is based upon sound analytical and ecological principles and that I feel appropriately balances concerns expressed while striving to meet the Purpose and Need for this project.

My decision seeks to balance public interests and ecological desired conditions such as managing forest vegetation reducing the threat of wildfire to Federal and private lands; providing for a diverse and healthy ecosystem; meeting threatened, endangered, sensitive plant and animal habitat needs, and reducing water quality effects to streams, riparian areas, and wetlands; and providing forest products and economic opportunities to contribute to local economies.



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E-7. SANNA PORTE COMMENT # RESPONSE

From: sporte To: FS-comments-northern-flathead-swan-lake Subject: Glacier Loon Project comments Date: Friday, September 21, 2012 10:45:43 AM Importance: High

TO: Rich Kehr, District Ranger FROM: Sanna Porte, Lindbergh Lake RE: Glacier Loon project

I appreciate the opportunity to comment on the proposed Glacier Loon Project. I strongly support Alternative A – No Action.

1

Response to Comment #1: Thank you for your comment. I considered your comments and those of others in my decision and used them to help shape the Selected Alternative. In arriving at a decision for this project, I recognized that I would not be able to satisfy all public concerns, as many of them are mutually exclusive. I made a decision that is based upon sound analytical and ecological principles and that I feel appropriately balances concerns expressed while striving to meet the Purpose and Need for this project. Please refer to this Decision Notice and Appendices 1 and 2 for more details on the Selected Alternative. Please refer to Chapter 1 of the Environmental Assessment (EA) which discusses the historical, existing and desired vegetative conditions of the Glacier Loon Project Area in addition to the Purpose and Need of this project. The Glacier Project is aimed at fuels reduction, forest health, and providing wood products. The Flathead Forest Plan embodies the provisions of the National Forest Management Act (NFMA), its implementing regulations, and other guiding documents. The Forest Plan sets forth in detail the direction for managing the land and resources of the Flathead National Forest. The applicable Forest Plan direction for the Glacier Loon Project Area is described on page 2-33 of the EA. The characterization of management in which natural processes are the sole management influence is not a management emphasis for these lands. Several plans and other regulations also provide context to the



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management direction for these lands which include the Missoula County Community Wildfire Protection Plan, the Seeley-Swan Fire Plan, the Northern Region Overview, and the Healthy Forests Restoration Act. In addition, recently adopted national and regional mandates of the U.S. Forest Service stipulate that ecological restoration will be the central driver of wildland and forest stewardship (USDA Forest Service 2012). This is of strategic importance because national forests are the backdrop and neighbor to many rural and urban communities, providing a broad range of value and benefits, including clean drinking water for millions of people across the U.S., vital wildlife habitat and a variety of recreation opportunities, all of which are basic to the health of our communities. Our job is to sustain the ability of America’s forests and to deliver the full range of ecosystem services for generations to come. Another point to consider is the Flathead National Forest includes approximately 1 million acres of land (or nearly 50 percent of Forest total) in which the goal is to manage the area by “protecting the natural dynamic equilibrium associated with natural, complete ecosystems.” The intent is to move the landscape toward more sustainable conditions that allow natural processes to occur. Future treatments in these areas would be determined based upon specific needs at the appropriate time. Without treatment, the risk of losing these ecosystem components continues to increase. Allowing natural processes to return to the landscape is unrealistic, given the amount of human occupancy and property values within the area. After careful consideration of the Purpose and Need objectives, issues identified and public comments received, and review of the management activities analyzed in the Environmental Assessment (EA) I have decided to implement Alternative D, with modifications as my Selected Alternative. I did not select the No Action Alternative because this alternative does not address the concern of the risk of high severity wildfires in the Wildland Urban Interface, forest health,



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nor would it provide forest products to the local economies. No action would mean forest canopies within the project area would continue to become denser and more closed in, and surface and ladder fuels would continue to accumulate. Trees would be less vigorous and less resilient to disturbances. Trees and stand would continue to experience the effects of mountain pine beetle, white pine blister rust, western larch dwarf mistletoe, and root disease. The risk of larger-scale mountain pine beetle activity would increase. Conditions that favor mountain pine beetle population growth, windthrow, increased residual tree damage, and increased mortality would continue. Increasing insect or disease-related mortality would add to the existing fuel load accumulation. Natural fuels would accumulate faster than they are recycled; increasing the natural fuels hazards near private lands. The risk of stand-replacing fire would increase as long as these stand conditions persisted. Selection of the No Action Alternative would be inconsistent with the Purpose and Need for this project. The Selected Alternative will create sustainable forest conditions by reducing forest fuel conditions and improving overall stand health. Growing space, individual tree vigor, and the ability to withstand insect and disease will be improved in treated stands. In addition to creating sustainable forest conditions, I believe my decision will reduce potential fire intensities and improve the opportunity for fire suppression, and lessen the potential for fires on Federal land to ignite private structures. The estimated 6.7 million board feet of timber resulting from these management activities will also provide economic opportunities to the local communities.

My family has had a place at Lindbergh Lake since the 1950s, when my dad and his buddies built our little cabin by hand. I grew up there in the summers. My parents still live there several months each year. We have a deep connection to the lake and surrounding area. In the 1990s, my family joined with other Lindbergh Lake homeowners and many other individuals and groups concerned about another logging project – this one proposed by Plum Creek, which planned to log its holdings around the lake.

There was widespread concern about that project’s threat to water

2

Response to Comment #2: Several comments were received on the Environmental Assessment concerned with how proposed treatments could affect the scenic quality, water quality, and fisheries values in the Lindbergh Lake Area. In response to comments such as yours, Alternative D with some modifications was chosen as the Selected Alternative. The Selected Alternative (Alternative D with Modifications) defers treatment of Units 84, 85, and 87; Units 83 and 86 are also deferred in the Selected Alternative. Also located on the west face of Lindbergh



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quality, fish, wildlife, grizzly corridors, bull trout spawning habitat, and the scenic qualities enjoyed by cabin owners and campers alike. We stopped the Plum Creek project. It was a huge effort, involving Lindbergh Lake homeowners, others who love the lake, conservation groups, and particularly the Trust for Public Land, then-U.S. Senator Conrad Burns, and Montana’s other congressional delegates. The Lindbergh homeowners gave money, paid for research, reached out to others – including Plum Creek itself -- and we got the funding to purchase that land as public land. The Glacier Loon Project threatens water quality, fish and wildlife, scenic views, and the natural character of Lindbergh Lake. Lindbergh is unique. It is the only non-wilderness lake I know of in Montana that has a “wild side.” With no development on the west side of the lake, it offers a wilderness-quality experience for hikers and boaters plus habitat for birds and wildlife. The Glacier Loon Project threatens that unique character. It would affect a vast area of the viewscape. The road building would cause erosion, additional vehicle travel, and the spread of noxious weeds. Weeds such as spotted knapweed already pose a major threat to other plants and animal life in the area – we don’t need any more. And we certainly don’t need more roads over there. It threatens the priceless old growth Ponderosa trees that are such an important part of the character and ecosystem of the lake.

Lake, National Forest System Roads #10734, #10732 and #10733 will be fully recontoured and decommissioned under the Selected Alternative. In addition, several acres located on the western slopes of Lindbergh Lake are currently are Management Area (MA) 15 under the Forest Plan. Due to public comments received concerning the Lindbergh Lake Viewshed, Alternatives C and D would propose to change the identified MA 15 acres to MA 5. As discussed above with this decision, I am authorizing a project-specific amendment to the Flathead Forest Plan related to a change to Management Areas (MA) for a portion of the Glacier Loon Project Area along Lindbergh Lake. This will change the Visual Quality Objective from “modification/maximum modification” to “retention” which will raise the level of current and future scenic integrity management for that land area. There will be no negative impacts associated with this change and this change will potentially have a long-term beneficial impact for the scenic quality of the Lindbergh Lake Area. Please refer to the “Decision” and “Rationale for My Decision” Sections in the Decision Notice starting on page DN-12 for more details.

Logging this close threatens water quality as well. We drink from that lake. The clarity and beauty of the water are unequaled. Logging this close would be devastating.

3 Response to Comment #3: As stated above, the Selected Alternative (Alternative D with Modifications) defers treatment of Units 84, 85, and 87; Units 83 and 86 are also deferred in the Selected Alternative which was originally proposed on the west face of Lindbergh Lake.

All planned road-related work in the project area will contribute to the restoration efforts of the watersheds within the Glacier Loon Project Area. National Forest System Roads #10734, #10732 and #10733 located on the west face of Lindbergh Lake will also be fully recontoured and decommissioned under the Selected Alternative. The Selected Alternative will reduce erosion, provide fish passage and reduce road densities. The



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Selected Alternative will cumulatively reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas, and road maintenance costs. Impacts to water quality will be minimized through the application of Best Management Practices displayed in Appendix 4 of this Decision Notice.

Noise would have a detrimental impact as well. 4 Response to Comment #4: Noise impacts from activities on the west face of Lindberg Lake will be reduced due to the deletion of Units 83, 84, 85, 86, and 87 in the Selected Alternative. All noise will not be eliminated due to other activities located further west of the face but will be considerably less than originally planned based on the above deletions.

I urge you to adopt Alternative A, No Action. Please leave this priceless area in its natural state. That’s what we worked so hard for in the 1990s.

Thank you for considering my comments.

Sanna Porte 127 Jefferson Helena, MT 59601

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5 Response to Comment #5: As stated in previous responses, we received 31 comments on the Environmental Assessment. I considered these comments in my decision and used them to help shape the Selected Alternative. In arriving at a decision for this project, I recognized that I would not be able to satisfy all public concerns, as many of them are mutually exclusive. I made a decision that is based upon sound analytical and ecological principles and that I feel appropriately balances concerns expressed while striving to meet the Purpose and Need for this project.

My decision seeks to balance public interests and ecological desired conditions such as managing forest vegetation reducing the threat of wildfire to Federal and private lands; providing for a diverse and healthy ecosystem; meeting threatened, endangered, sensitive plant and animal habitat needs, and reducing water quality effects to streams, riparian areas, and wetlands; and providing forest products and economic opportunities to contribute to local economies.



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E-8. JULIE WOLF COMMENT # RESPONSE

From: Julie and Jeff Wolf To: FS-comments-northern-flathead-swan-lake Subject: Glacier Loon Fuels Reduction and Forest Health Project Date: Friday, September 21, 2012 3:47:41 PM Attachments: Glacier Loon Fuels Reduction and Forest Health Project.doc

Hello Mr. Kehr, I have attached my comments on the Glacier Loon Project along Lindbergh Lake where my family has had a cabin since 1965. Thank-you.

Julie Wolf

Glacier Loon Fuels Reduction and Forest Health Project

I support Plan B.

1

Response to Comment #1: Thank you for your support of Alternative B. After careful consideration of the Purpose and Need objectives, issues identified and public comments received, and the potential impacts of the management activities analyzed in the Environmental Assessment (EA) issued in August 2012, I have decided to implement Alternative D, with modifications as my Selected Alternative.

This past summer I noticed a lot of brown trees in the area between Sandy Beach and the rope swing along Lindbergh Lake. I would imagine that this situation could worsen in the years to come and that the view across the lake will be worse than it would be if some of these trees were removed. I believe that logging can improve the health of a forest although logging should be done responsibly. Eventually, more food should be available for wildlife.

2

Response to Comment #2: In response to public comments on the Environmental Assessment, the Selected Alternative (Alternative D with Modifications) defers treatment of Units 84, 85, and 87; Units 83 and 86 are also deferred in the Selected Alternative. These units are located on the west face of Lindbergh Lake. Deferring of these units will likely result in additional tree mortality from active bark beetle infestations and cause a deterioration of the visual quality from that perspective. I also weighed this concern you mention in designing the Selected Alternative. Other treatment units retained in the Selected Alternative have a combination of circumstances that either grow worse over time (such as active pine beetle infestation) or where I think the prescriptions and locations will serve to either reduce fuels or improve forest health, without causing significant offsetting impacts. Some of the treatments also provide a degree of timber products from



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E-8. JULIE WOLF COMMENT # RESPONSE

the suitable timber base. I believe the Selected Alternative, as described in this Decision Notice, best meets the Purpose and Need for the Glacier Loon Project, while also being responsive to resource issues and public input identified through the analysis process.

It is a shame that the timber industry is all but dead in NW Montana which is becoming like Appalachia. Unemployment is very high and jobs are desperately needed. Jobs in the timber industry used to support families.

3

Response to Comment #3: Thank you for the comment. As noted in Table 3-99 in the Economics Section of the Environmental Assessment, Alternative B has the largest impacts in terms of direct as well as indirect and induced labor income impacts which would be beneficial in many of Northwest Montana’s communities. However the Selected Alternative will create sustainable forest conditions by reducing forest fuel conditions and improving overall stand health. Growing space, individual tree vigor, and the ability to withstand insect and disease will be improved in treated stands. In addition to creating sustainable forest conditions, I believe my decision will reduce potential fire intensities and improve the opportunity for fire suppression, and lessen the potential for fires on Federal land to ignite private structures. The estimated 6.7 million board feet of timber resulting from these management activities will also provide economic opportunities to the local communities.

Julie Wolf Kalispell, MT 752-1069 Lot 62, Lindbergh Lake



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E-10. FRIENDS OF THE WILD SWAN COMMENT # RESPONSE

Friends of the Wild Swan

P.O. Box 103

Bigfork, MT 59911 September 21, 2012 Rich Kehr, District Ranger Glacier Loon Fuels Reduction and Forest Health Project Swan Lake Ranger District 200 Ranger Station Road Bigfork, MT 59911 Via e-mail to: comments-northern-flathead-swan-lake@fs fed.us Dear Rich, Please accept the following comments on the Glacier Loon Fuels Reduction and Forest Health Project Environmental Assessment on behalf of Friends of the Wild Swan. We requested documents from the project file that we have not received yet so we reserve the right to supplement our comments after we have reviewed those documents. We also incorporate the comments submitted by Swan View Coalition and Alliance for the Wild Rockies.

Our concern that including the wilderness in the project area would dilute the effects of this timber sale is played out in the EA. The vegetation and wildlife analysis are skewed because the Mission Mountain Wilderness is used to offset effects in the heavily logged and roaded non-wilderness. The Flathead must go back and analyze in an Environmental Impact Statement the actual effects of this project in the non-wilderness portion where all the activities take place.

1 Response to Comment #1: We respectfully disagree. The wildlife analysis is not “skewed” due to the location of the proposed project adjacent to the Mission Mountain Wilderness. Forage for different wildlife species is discussed on a stand by stand basis and how many acres of suitable habitat would be affected; security in relationship to road density is described relative to the amount of change from current conditions, so magnitude of effects between different alternatives can be displayed; security relative to potential displacement is discussed predominately within the action area (outside of wilderness); hiding cover is analyzed across the entire project area (including wilderness), but also discussed section by section relative to important habitats like old growth, wetlands, or lynx forage. The Swan Valley Grizzly Bear

Glacier Loon Fuels Reduction and Forest Health Decision Notice

Appendix 5 – Response to Comments Received on the Environmental Assessment

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Conservation Agreement guideline for cover (40%) is based on a Grizzly Bear Subunit. The important factor is how much difference there is in the amount of decrease in hiding cover between alternatives; from 0% reduction in the No Action Alternative to 4% in Alternative B. Under the Selected Alternative, the amount of decrease in hiding cover will be 2%. It would be inappropriate not to include the adjacent wilderness area in the discussion of potential effects, because adjacent areas of security (e.g. refugia) are important for wildlife. Large, secure areas for wildlife are an integral part of several of the forest’s key operational standards and guidelines for wildlife (Amendment 19 Security Core and Subunit Rotation in the Swan Valley).

Roads

1) All alternatives authorize the construction of between 11.5 and 5.8 miles of temporary roads resulting in an increase in open and total road density in the BMU Subunit. The Environmental Assessment defines temporary road as: A road constructed to facilitate forest management activities but is

reclaimed soon after the activity is completed. Amendment 19 to the Forest Plan states: Within BMU subunits with an intermingled ownership pattern and/or are

not predominantly National Forest, Forest Service activities will not

result in an increase in motorized access density or a reduction in

core areas on National Forest system lands. (Appendix A, page 1 – emphasis added)

In these 14 BMU Subunits [that are less than 75% National Forest

System lands] and all others on the Forest, my decision requires no net

loss of habitat security on National Forest System lands, and that

Forest Service activities result in a net gain in habitat security.” (Decision Notice, page 10 – emphasis added)

The Swan Valley Conservation Agreement (SVCA) at page 9 states: The Forest Service hereby agrees not to take management actions that

increase total road density or open road density or to decrease Core Areas on its ownership… The Forest Service also agrees to reclaim

roads to enhance use of preferred and other high quality habitats

2 Response to Comment #2: The Glacier Loon Project is consistent with the Flathead Forest Plan and Amendment 19 in that Forest Service activities will not result in an increase in total motorized access density or reduction in security core. The effects of temporary roads on Threatened and Endangered Wildlife Species are discussed in the EA on pages 3-216 thru 3-241. Temporary roads, restricted roads, and open roads are discussed in detail. Amendment 19 to the Forest Plan provides standards for grizzly bear management through motorized access and security core habitat standards and objectives. The Amendment 19 objective for the Buck Holland and Glacier Loon Grizzly Bear Subunits is “No Net Loss” for Open Road Density (ORD), Total Road Density (TRD), and Security Core. The term “net” under Amendment 19 and the Swan Valley Grizzly Bear Conservation Agreement (SVGBCA) refers to “motorized access” that will not increase as a result of Forest Service activities (EA, page 3-236) at the conclusion of project activities. That is why the term “net” is included in the management direction. Table 3-69 demonstrates that the proposed alternatives for the Glacier Loon Project comply with standards and guidelines outlined in the SVGBCA. Tables 3-70 and 3-71 in the EA also display the ORD and TRD by individual subunit for the alternatives. The road densities are displayed for pre-project



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and to complement adjacent areas of secure habitat. The Forest Service will not take management actions that increase

total road density on its ownership except to the extent required by law to grant access to inholders. The Forest Service agrees to reclaim roads

to the extent necessary to meet its total road density obligations.

(existing), during project, and post-project. The ‘During’ figures include temporary roads. Open Route Densities (ORD) and TRD will temporarily increase during project implementation in whichever subunit activities are occurring; the road densities will be changing on a regular bases, both increasing and then decreasing, as restricted roads and temporary roads are utilized, then closed or reclaimed. Temporary roads will be reclaimed after use (EA, pages 3-224 and 3-343). These roads will then no longer function for motorized use. Temporary roads will not contribute to post-project motorized access in regard to Total Route Density (TRD). The Selected Alternative will also decommission 8.4 miles of system roads. As a result of decommissioning, ORD will decrease in the Glacier Loon subunit and TRD will decrease in both the Glacier Loon and Buck Holland subunit (EA, page 3-236). The decrease in ORD and TRD will increase long-term habitat security for grizzly bears in these subunits (EA, page 3-236). In addition, the Biological Assessment (BA - Project File Exhibit H-16) analyzes the use of temporary roads in detail. The USFWS is interested in how many miles of temporary road are located inside of proposed units and how many miles of temporary road are located outside of proposed units. Under the Selected Alternative, at the conclusion of project activities, open road densities will decrease 0.1% in the Glacier Loon Subunit; total road densities will decrease approximately 3% in the Glacier Loon Subunit and 0.1% in the Buck Holland Subunit (BA – Project File Exhibit H-16). There will be no decrease in security core habitat (BA – Project File Exhibit H-16). The District Wildlife Biologist made a determination of “may affect – not likely to adversely affect” for the grizzly bear and the USFWS concurred with this determination (Project File Exhibit G-2). Design Criteria are incorporated into the project for the Selected Alternative such as subunit rotation, spring restrictions, and distance to cover limit potential long-term displacement of grizzly bears to help provide grizzly bear security (See Appendix 2 - Design Criteria



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in the Decision Notice).

The Flathead claims that temporary roads will not increase total road density and open road densities would increase temporarily but this does not actually result in an increase in road densities in the grizzly bear subunit. However, neither the Conservation Agreement nor the Fish and Wildlife Service’s Biological Opinion on the SVCA distinguish between temporary roads and other roads. The Forest Plan Amendment #19 addresses the issue of the use of reclaimed roads in calculations and states: Reclaimed roads that fully satisfy the definition of a reclaimed road* will

not be included in calculations of open motorized access density, total motorized access density, or security core area. Roads that have been

treated, but that do not yet fully satisfy the definition of a reclaimed

road will be included in calculations for total motorized access route

density. These roads will not be included in calculations for open motorized access route density, or security core area if use is low-intensity and non-motorized. (Emphasis added - Appendix D, page 3)

*A reclaimed road has been treated in a manner so as to no longer

function as a road or trail and has a legal closure order until reclamation treatment is effective.

Amendment 19 also requires all restricted roads be included in calculating total motorized access route density.

In addition, the EA reveals that between 2.3 and 1.4 miles of these “temporary” roads are on historic templates. One of which (Road #12A) was built in the early 1980s and still has a poorly aligned culvert in place. (EA page 3-201) We find it hard to believe that a road that has been in place for ~20 years is considered temporary. If the Flathead is going to reuse road templates then these roads are not temporary and must be calculated in road densities. Given the Forest Service’s definition of a temporary road, the terms of the Swan Valley Conservation Agreement, the requirements of Forest Plan Amendment 19 and the reuse of historic road templates then temporary roads

3 Response to Comment #3: Road #12A is not a system road and it was simply re-discovered during field investigation. As discussed above, the effects of temporary roads on Threatened and Endangered Wildlife Species are discussed in the EA on pages 3-216 thru 3-241. Temporary roads, restricted roads, and open roads are discussed in detail. The Glacier Loon Project is consistent with the Flathead Forest Plan and Amendment 19 in that Forest Service activities will not result in an increase in motorized access density or reduction in security core. Under the Selected Alternative, open road densities will decrease 0.1% in the



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must be included in the calculation of total road density until they are fully reclaimed, have culverts removed and no longer function as a road or trail. In addition, this project does not result in a net gain in habitat security, but results in a net loss.

Glacier Loon Subunit; total road densities will decrease approximately 3% in the Glacier Loon Subunit and 0.1% in the Buck Holland Subunit (BA – Project File Exhibit H-16). There will be no decrease in security core habitat (BA – Project File Exhibit H-16). Please also see Response to Comment #2.

2) Temporary road #191715D which access Unit 71 in Alternatives B and C goes through a sapling stand that is lynx foraging habitat. Temporary road #15C crosses an intermittent stream that flow into Lindbergh Lake creating sediment from the construction and deconstruction of the road that would reach the lake. Temporary road #22B also crosses an intermittent stream that flows into Lindbergh Lake and is expected to generate even more sediment than road #15C and would deposit sediment into a wetland. Temporary road #36C would cross an intermittent stream that directly flows into the Swan River with erosion considered to be inevitable. It also crosses another channel that would create sedimentation that would deposit into a wetland. Temporary road #24A crosses an intermittent channel. These temporary roads will affect wildlife habitat, water quality and wetlands and should not be built.

4 Response to Comment #4: As shown in the EA, Unit 71 is not included in Alternative D in order to display the effect of Temporary Road #19175D. Please note that Unit 71 is not included in the Selected Alternative for this decision. The effects of temporary road construction were analyzed in the EA in various sections including the effects to wildlife habitat, (pages 3-215 thru 3-358) water quality and fisheries, (pages 3-149 thru 3-214). The decision maker has considered these impacts and your request to defer these roads. Temporary Road #15C will not cross an intermittent stream to access Units 67 and 69 in this decision. This temporary road distance has been reduced to access Units 68 and 70 resulting in no sediment being transported to Lindbergh Lake. Under the Selected Alternative, Temporary Road #22B associated with Units 84 and 85 has been deferred from this decision. Temporary Road #36C is included in the Selected Alternative to access Unit 22. Treatment of Unit 22 is necessary to achieve longer term fuels reduction and forest health stand conditions. Design Criteria to construct the road when channel is dry will keep sediment to a minimum (Appendix 2, page 2-5). Temporary Road #24A is included in the Selected Alternative to access Units 12, 13, and 14. Treatment of these units is necessary to achieve longer term fuels reduction and forest health stand conditions. Design Criteria to construct the road when channel is dry will



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keep sediment to a minimum (Appendix 2, page 2-5). Under the Selected Alternative for this project as described in the Decision Notice, the total amount of temporary roads is 5.9 miles, which is less than Alternatives B and C as displayed in the EA. The Glacier Loon Project Area will be left in a long-term improved condition after the projects outlined in this Decision Notice are implemented. Each of the prescribed activities in the Selected Alternative is designed to meet the purpose and need of the project, which were formulated to create an improved future condition.

3) Over 100 miles of roads are in the Glacier Creek analysis area. Yet this whole project will only decommission between 4.1 and 8.4 miles of roads. The transportation analysis does not analyze which roads are necessary to remain on the system as required by the road right-sizing initiative.

5 Response to Comment #5: The Flathead National Forest Plan identifies the following Forest-wide goals that apply to roads:

1. Construct the minimum number of roads necessary to permit the efficient removal of timber and mineral resources; construct and reconstruct roads only to the minimum standards necessary to prevent soil loss, maintain water quality, minimize safety hazards for a reasonable and prudent Forest user, and provide access for fire protection where needed to meet MA goals; and

2. Maintain a balance of open and closed roads to continue present levels of motorized access, insure big-game habitat security, insure grizzly bear security to meet recovery goals, and reduce road maintenance costs (USDA Forest Service, 2001, II).

Forest roads are an essential part of the transportation system designed to support multiple use of our National Forest lands. They help meet recreational demands and facilitate access to forest commodities. Forest roads provide access needed to manage the many resources of each forest ecosystem.

It is important to develop a long-term transportation plan that provides for a forest road system that best serves management objectives and public uses while protecting the health of our watersheds.



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A Travel Analysis was completed for the Glacier Loon Analysis Area to comply with the administration of the Forest Transportation System Final Rule (36 CFR Part 212) and with the Forest Service Transportation Administrative Policy (FSM Chapter 7700). The revisions and amendments for the final rule were signed into effect on January 12, 2001. The final rule is intended to help ensure that additions to the National Forest System Road network are those deemed essential for resource management and use; that construction, reconstruction, and maintenance of roads minimize adverse environmental impacts; and that unneeded roads are decommissioned and restoration of ecological processes are initiated. Each road within the analysis area was rated based on need for access and resource environmental concerns. As we assessed the benefits and environmental effects of the road system, we identified opportunities for decommissioning, watershed restoration and road maintenance.

The travel analysis identified 4.1 miles of roads that were no longer needed as part of the National Forest Road System and therefore will be decommissioned. These roads were carried forward in the Glacier Loon EA for decommissioning along with an additional 4.3 miles of road identified during alternative development for a total of 8.4 miles of road decommissioning. These roads were then carried forward into this Glacier Loon Decision.

The new policy removes emphasis on transportation development and adds a requirement for science-based transportation analysis. This science-based analysis process is spelled out in the USDA Forest Service Miscellaneous Report FS-643, Roads Analysis: Informing Decisions about Managing the National Forest Transportation System (USDA Forest Service, 1999b). The Glacier Loon Travel Analysis followed the recommended six-step process of this publication (Project File Exhibit R-4).

The Travel Analysis is intended to be a dynamic document that reflects the conditions at the time of analysis. The document may need to be updated in the future as the need arises and conditions warrant. In addition, future projects within the Glacier Loon Analysis



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Area may look at additional opportunities on MT Legacy Lands once the Fiber Supply Agreement ends on December 31, 2018.

4) Road #79W has the potential to be a chronic sediment source and should be removed.

6 Response to Comment #6: As described on page 3-197 of the EA, this road is encumbered by the Fiber Agreement until 2018. The Forest Service is not modifying the transportation system while the fiber supply agreement is in place.

5) Roads within 300 feet of howellia ponds should be removed.

7 Response to Comment #7: Roads within 300’ of Howellia aquatilis predate the listing of the species. They have been in the Upper Swan Valley since the 1930s (mostly from the 1950s) yet howellia still occupy these ponds. Some roads are owned by state and county governments, over which the Forest Service does not have jurisdiction. As discussed in the EA on page 3-104, “In accordance with the FNF Forest Plan Amendment 20, all occupied ponds will be avoided with a 300 foot no-ground-disturbance buffer around the ponds, except in the few cases of a permanent road crossing through the 300 foot buffer. In those cases, the buffer area on the side of the road away from the pond will be available for project activities. The hydrology of the ponds has been altered long ago, before the species was listed, by these roads. Preventing activity in those areas would not meet the intent of the buffers and is unnecessary.” Additional Design Criteria will be implemented to protect water howellia and their habitats associated with hauling and road maintenance, “If ground disturbing BMP-related activities occur within 300 feet to the north and south of these ponds, natural filtration zones, sediment retention structures, or straw bales would be applied to ensure limited sediment deposition into these ponds.” The EA also states on page 3-105, “Any unoccupied suitable ponds would be buffered by a 150-foot no-activity buffer. Design Criteria would avoid wetlands with all ground-disturbing activities, including lakes, ponds, marshes, fens, and streams by establishing buffers around wetlands (See Design Criteria, Table 2-16).



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Temporary road construction is not proposed within the buffers of occupied or unoccupied howellia ponds. There is no new permanent road construction proposed.

6) The EA did not: (a) recognize that storm water runoff from Project logging roads that travels through ditches, culverts, and channels are “point sources” under the Clean Water Act (CWA) per the court decision in Northwest

Environmental Defense Center v. Brown, 2010 WL 3222105 (9th Cir. Aug. 17, 2010), (b) assess whether there will be any discharges of pollutants from any point sources because of the Glacier Loon Project, and (c) demonstrate that the Forest Service is complying with any applicable permit requirement under the Clean Water Act’s National Pollutant Discharge Elimination System.

8 Response to Comment #8: The Glacier Loon EA considered the issue of sediment delivery from the network of roads, ditches, and culverts in the project area (EA, pages 3-149 thru 3-182). As part of the EA for the Glacier Loon Project, the WEPP Model was used to estimate existing potential annual sediment yield from the existing roads in the project area. Stream crossings are the primary introduction point for sediment from the road system into a stream channel. The WEPP Model assumptions and modeling results for the existing potential road associated sediment for each analysis watershed are also displayed in the EA on these pages. The Forest Service will obtain any necessary permits required for implementation (EA, page 3-182). Currently, the future of the “silvicultural exemption” in the Clean Water Act is uncertain; however, the litigation in Oregon does not presently apply to the Forest Service. A NPDES permit from the EPA is currently not needed at this time. All applicable forestry Best Management Practices (BMP) will be applied for activities that occur on FS lands under the Selected Alternative, which address the requirements of the Clean Water Act and the Flathead Nation Forest Land and Resource Management Plan. BMPs will be applied to all roads and crossings to prevent or minimize hydrologic connectivity between the road system and stream network. Please also see Response to Comment #21 Letter – Alliance for the Wild Rockies.

Vegetation and Old-Growth Forest Habitat

1) We appreciate that this project does not log in old-growth forest habitat. However, there is very little old-growth in the non-wilderness part of the project area. The EA did not disclose what the 75% range around the median of historical variability is in the project or cumulative effects area. How

9 Response to Comment #9: The EA states on page 3-309 that “Based on Regional FIA Data for the Glacier Loon Area (fifth code watershed 1701021101), the estimate for percent old growth in the watershed is 9.09 percent, with lower and upper bounds of 0.0 to 20.0 percent (Bush and Leach 2004). There is no proposed treatment in old growth habitat under the Glacier Loon Project Decision. An extensive



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much old growth does that equate to? How this project is moving the Flathead towards or away from the goal to maintain and recruit old growth forests.

survey of old growth forest habitat outside of the treatment area was not conducted due to the fact that all existing old growth habitat will remain; the amount of old growth across the Glacier Loon Project Area landscape will not be affected by this Decision. Old growth recruitment is discussed on pages 3-311, 3-314, and 3-317 of the EA. As discussed, proposed intermediate treatments will, in most cases, keep the stands on a trajectory towards providing old growth habitat conditions for old growth associated wildlife species in the future; many of the larger trees will be retained. The stands proposed for clearcut or seed tree treatment do not currently provide old growth habitat and, due to existing stand characteristics including high mountain pine beetle mortality, will likely not provide potential old growth habitat for a very long time regardless of whether they are treated.

Furthermore, the Flathead has no plan for how it is going to maintain, recruit and connect old-growth forest habitat. There are 22 units adjacent to existing old-growth yet there is no analysis of how logging these units will affect the old-growth habitat. No analysis for blowdown. Four stands slated for logging are on a trajectory towards old growth, but we don’t know why they are being logged and why they aren’t allowed to progress towards old growth.

10 Response to Comment #10: Habitat conditions for old growth associated wildlife species in the analysis area, including the existing condition for old growth habitat, were analyzed and discussed in the EA on pages 3-305 thru 3-319. Old growth species disturbance/displacement, interior integrity of existing old growth, old growth recruitment, and the effects of temporary road construction were analyzed. Stands proposed for treatment were surveyed to assure that no treatment was proposed in old growth habitat. In regards to some older stands (not old growth) being logged – The different alternatives address the Purpose and Need to differing degrees. Many older stands, as well as designated old growth stands, may contain hazardous fuels conditions, or may be affected by insects or disease. There are trade-offs to be considered; hence, a range of alternatives and analysis of effects to different resources, including old growth habitats.

2) The vegetation analysis is inadequate because it does not distinguish between the forest condition in the wilderness and non-wilderness skewing the analysis. There is no description of the forest stands slated for logging, what species composition is in the different units, age classes in the units and why they need to be treated. The EA does indicate that there is multi-layer vertical structure in stands but does not identify which ones.

11 Response to Comment #11: The Forest Service completed an in-depth analysis of each stand before recommending treatments (Project File Exhibit I-3). In some cases this involved modeling potential treatments using the Forest Vegetation Simulator (FVS). Methodologies describing these procedures are presented in the EA on pages 3-31 and 3-32. A sample



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of the stands was modeled and results extrapolated to stands with similar conditions and proposed treatments. These analyses are on file at the Swan Lake Ranger District (Project File Exhibit I-1n).

The EA does not disclose how much western larch will be logged and why it is necessary since this is one of the most disease and fire resistant trees on the landscape. We had to FOIA the silvicultural walk-through exams in order to find out the composition of these stands. When we receive the FOIA documents we will supplement these comments.

12

Response to Comment #12: Some 60% of the project area is in the cool-moist, warm-moist, or warm-dry PVGs (EA, Figure 3-3 and page 3-43). The Flathead National Forest Plan Amendment #21 calls for featuring early seral, fire resistant species on these areas –western larch, Douglas-fir, western white pine, and ponderosa pine (Flathead National Forest Plan Amendment #21 FEIS, page 81, Appendix A pages 11, 13, 15, 31, 32, 33; Appendix I, pages 7-12). Wherever possible, healthy western larch will be retained as the preferred species. Some smaller or diseased (dwarf mistletoe, primarily) trees will be removed where residual stand health may be jeopardized. It is not possible at this stage to quantify how much larch may actually be cut in implementing treatments.

3) This project will negatively impact old-growth associated species due to high contrast edge effects, displacement, logging recruitment old growth, and temporary roads on the edge of old growth stands yet no alternative was developed that favored wildlife.

13 Response to Comment #13: The impacts to old growth and old growth associated species are disclosed in the EA on pages 3-305 thru 3-319. The Glacier Loon Project is consistent with Forest Plan Amendment 21 which provides management direction to maintain old growth stands as well as objectives for structural retention of snags, large trees and down woody debris.

Wetlands and Water Howellia

1) The EA failed to analyze the effects to wetlands and wetland complexes. Temporary roads will contribute sediment to wetlands. Roads are already within 300 feet of wetlands. Seedtree and commercial thin logging will occur around wetlands and the wetland complex in Section 12 as will temporary road construction yet there is no analysis of how this will affect the hydrology of the wetlands or whether it will dry them out.

14 Response to Comment #14: The potential effects of the proposed activities on wetlands, creeks, and watersheds were discussed in several sections of the Glacier Loon EA. The effects to Water Resources of Glacier Creek, Upper Swan River, and Swan River Valley Bottom Area Watersheds were discussed in the Water Resources Section on pages 3-149 thru 3-182 of the EA. The potential effects to wetlands were also discussed in the Fisheries Section of the EA on pages 3-183 thru 3-214.



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The Threatened and Sensitive Plant Species Section of the EA (pages 3-95 thru 3-115) also discusses wetland habitats and the effects of the proposed activities to wetlands and plant species associated with these habitats, which includes the water howellia (Howellia aquatilis). Design Criteria would avoid wetlands with all ground-disturbing activities, including lakes, ponds, marshes, fens, and streams by establishing buffers around wetlands (See Design Criteria, Appendix 2). Forest personnel have been working with the Montana Heritage Program and the University system since the late 1990’s to study the effects of different aspects of forest management on riparian areas, groundwater interaction, and wetland function. An in-depth study of a select number of wetlands containing water howellia in the Swan Valley was published in 2004 (Reeves and Woessner 2004). Modeling data from this study suggested that removal of trees in the micro-watershed basin (clear cutting or stand replacing fire) would temporarily increase water yield in Howellia potholes due to loss of transpirational demand. However, such increases could be short lived or persist for 2-40 years. The authors conclude that that the degree to which the water Howellia life cycle would be altered by such removals is unknown. No evaluations of other partial cutting systems (e.g., seed tree or commercial thinning) were analyzed. Aside from this modeling, there is no quantitative data demonstrating that forest management, of the kind proposed by the Glacier Loon Project, would have any measurable effect on either ground water quantity or quality in the areas’ numerous wetlands. A review of the groundwater depths through Montana’s Ground-Water Information Center (GWIC) demonstrates the groundwater aquifer in this area has fluctuated between about 50 and 59 feet at nearby Condon (Project File Exhibit M-47).With measured groundwater levels of this depth, and given the 300 foot buffers around Howellia sites, timber management as designed for this project would not likely have a direct, lasting effect on groundwater. Consequently, changes to groundwater were not chosen as a measurement indicator for the Water Resource and was not analyzed as such. Please note that in the Selected Alternative proposes the



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least amount of activity in Section 12 as compared to the alternatives displayed in the EA. Unit 53 has been deferred from this decision to eliminate the impacts of harvest in an RHCA. Though there are wetlands in Section 12, the units have been designed to avoid any harvest within wetlands. The reduced ground disturbance should also result in less potential seed bed for noxious weeds. The best available information is that the RHCA buffers adequately maintain the surrounding vegetation. These buffers are 50 feet or 150 feet from the ordinary high water mark of the wetland; depending on the wetland size. The buffers were developed from studies on erodible soils in the Pacific Northwest (USDA Forest Service 1995). Considering the less erodibility of the Swan Valley (Sugden and Woods 2007), they will trap overland sediments (rills or gullies) from adjacent harvested areas before reaching the wetland in all but the steepest terrain. Local monitoring after a 2004 post-fire salvage project found the longest overland erosional gully traveled 52’ (Gardner 2004). Since this monitoring followed a worst-case scenario of harvesting on recently burned ground, it confirms that in normal, unburned areas the ground cover and geology greatly restrict erosion into wetlands. Every wetland in the Glacier Loon Project Area was examined by the District Fisheries Biologist in 2011 to confirm the wetland’s existence and confirm that the RHCA buffer would adequately protect the wetland from adjacent erosion. Most had very gentle topography near them but those that were located in steeply-sloped potholes were still adequately protected since the RHCA buffer extended beyond the top of the break. The RHCA buffers will also provide adequate shade and micro-climate regulation to the wetland. Shade is provided by trees immediately adjacent to the wetland on the south side and since the trees nearest to the wetland are unharvested, there is no change to shade. Riparian plants and forbs will also be unaffected since they cling to the wetland edge and do not extend past the RHCA buffer. The surrounding vegetation will continue to provide leaf, limb and whole tree inputs into



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the wetland as normal. Trees will grow, die, blowdown, decay, or burn up in a fire just as always before.

2) Sediment from road construction will settle out in some wetlands yet there is no analysis of how this will affect their integrity. 3) The EA failed to analyze whether this project will minimize the destruction, loss or degradation of wetlands. Or how it will enhance the natural and beneficial values of wetlands as required under EO 11990.

15 Response to Comment #15: As stated above, sediment delivery from temporary road construction was evaluated in the Soils Section of the EA on pages 3-9 thru 3-27 thru the use of the WEPP Model. The WEPP Model results estimate the potential amount of soil erosion from temporary road construction and log skidding at 1.9 tons/acre/year over the 3-year sale contract period (Table 3-7). These figures represent total erosion from all segments for the anticipated duration of use in all action alternatives (Project File Exhibit L-24). Soil erosion will be controlled through the use of erosion control measures.

Please See Response to Comment #14. 4) The project fails to ensure that threatened howellia will not be adversely impacted. Roads remain within 300 feet of howellia ponds, unoccupied ponds will only be buffered by 150 feet, logging and new road construction can disrupt the hydrology of the ponds, and weeds will be spread into the pond areas. The EA does not analyze how roads impact the hydrology of howellia ponds and instead dismisses the issue by saying that the hydrology of the ponds was altered long ago before the species was listed by existing roads. This is wholly inadequate.

16 Response to Comment #16: We respectfully disagree. The project will not adversely impact Howellia aquatilis due to the large buffers surrounding the ponds. These buffers were specifically designed to prevent new human-caused disturbances to the surrounding habitat, as well as provide a buffer between weed infestations and the ponds. The EA does analyze how roads and harvest activities impact the hydrology of howellia ponds on pages 3-96 thru 3-105. One excerpt from the EA on page 3-105 states, “It is possible that past road construction/maintenance and timber management could have increased groundwater and sediment flow in some wetlands. This could affect seed germination, as discussed in direct and indirect effects section for water howellia. Increased siltation could result in shifts in the wetland vegetation composition, supporting emergent vegetation in place of submergent vegetation types (USDI 1996). Timber management and other development activities may also contribute to these same effects on water howellia.

Cumulative effects would only occur if water howellia



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habitat was impacted by activities associated with the proposed action. Temporary road construction is not proposed within the buffers of occupied or unoccupied howellia ponds. There is no new permanent road construction proposed. Any affected occupied ponds would be buffered by a 300-foot no-activity zone, and unoccupied suitable ponds would be buffered by a 150-foot no-activity buffer. Hauling and associated road maintenance on roads with nearby ponds would be mitigated to prevent sediment from reaching those ponds. There would not be any direct or indirect effects to water howellia habitat from timber and road activities associated with the Glacier Loon Project. The proposed action in combination with all past, present, and foreseeable activities would not contribute to cumulative effects to water howellia habitat.

As stated above in Response to Comment #7, Roads within 300’ of Howellia aquatilis do predate the listing of the species. They have been in the Upper Swan Valley since the 1930s (mostly from the 1950s) yet howellia still occupy the ponds. Roads have affected localized groundwater hydrology and the species has apparently survived and is trending upward. No new road construction will occur within the 300’ buffer in this project or future projects unless the listing of Howellia aquatilis is changed. Stream Management Zones (SMZ) on Plum Creek Legacy Lands leave 10-30 feet of vegetation around ponds yet they are still occupied by water howellia. The Forest Botanist determined that the Glacier Loon Project will have “no effect” on water howellia. This determination is based on the occurrences of occupied ponds within the project area that are located 300 feet from proposed project activities and will not be affected by the proposed action, as well as on the occupied ponds near a haul routes that will have BMP activities as outlined in the project Design Criteria to prevent sediment from reaching the ponds (Biological Assessment, Project File Exhibit J-1).



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Weeds near occupied ponds are a high priority for the Forest’s weed program.

The EA does not analyze why only 150 foot buffers are being placed around unoccupied howellia ponds rather than 300 foot buffers.

17 Response to Comment #17: The 150 foot buffers around unoccupied ponds have been developed through past projects (Cooney McKay, Hemlock Elk, and Holland Pierce) and in consultation with the US Fish and Wildlife Service. The 10-year monitoring plan for Howellia aquatilis had shown an increasing trend in occupied ponds, and the recent acquisition of Legacy Lands also included at least 20 new sites. The Howellia aquatilis metapopulation is doing well in the Swan Valley. Unoccupied ponds are deemed to have suitable habitat for water howellia; however they do not contain the species and may never become occupied. Occasionally a new population will be found in a known suitable pond, but there is no way of knowing if these ponds will ever contain water howellia. Since there is no decrease in the water howellia metapopulation, the Forest believes the 150’ buffer around unoccupied ponds will provide ample protection for the suitable habitat. See also Response to Comment #14.

There is no analysis of how sediment will impact howellia ponds.

18

Response to Comment #18: Page 3-104 in the EA states “Road BMPs could cause increased siltation into ponds, which could result in the burying of water howellia seeds too deep for germination or shifting the pond’s vegetation composition, supporting emergent vegetation in place of submergent vegetation types (USDI 1996). There are several ponds within a short distance of roads that would be used for project activities (See Table 3-34). The BMPs associated with these roads would be adapted in the project Design Criteria to ensure no sediment or other deposition occurs in the nearby ponds.” On page 3-105, it is stated “Cumulative effects would only occur if water howellia habitat was impacted by activities associated with the proposed action. Any affected occupied ponds would be buffered by a 300-foot no-activity zone, and unoccupied suitable ponds



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would be buffered by a 150-foot no-activity buffer. Hauling and associated road maintenance on roads with nearby ponds would be mitigated to prevent sediment from reaching those ponds. There would not be any direct or indirect effects to water howellia habitat from timber and road activities associated with the Glacier Loon Project. The proposed action in combination with all past, present, and foreseeable activities would not contribute to cumulative effects to water howellia habitat.”

Water Quality and Fisheries

1) Sediment from road construction will enter Lindbergh Lake yet this is dismissed as insignificant. This is a pure mountain lake that should be treated with respect. Sediment in lakes can reduce oxygen for fish, increase algae blooms and cause irretrievable impacts.

19 Response to Comment #19: The Forest Service greatly values Lindbergh Lake and its fisheries. As reviewed in the Fisheries Analysis from page 3-204 to 205, the temporary road construction and system road decommissioning has potential to generate a short-term, moderate amount of sediment to the lake. In order to evaluate the consequences of this action, it is logical to utilize results learned from monitoring of a similar project completed by Plum Creek in 1989. The EA discloses the monitoring found that water quality in Lindbergh Lake remained excellent after the Plum Creek project, therefore it is expected that the Glacier Loon Project would also result in excellent water quality and no harm to fish habitat. The Forest Service also considered Alternatives C and D that decommission roads on Lindbergh Lake, instead of constructing new ones. These alternatives would result in less sedimentation than the proposed action and likely a long term reduction of sediment from system roads. The District Fish Biologist determined that the Glacier Loon Project will have “no effect” on bull trout or bull trout critical habitat (Biological Assessment, Project File Exhibit N-2) and “May Impact Individuals or Habitat, but will not likely result in a trend towards federal listing or reduced viability for the population or species” for cutthroat trout and a “No Impact to Western Pearlshell Mussel (Biological Evaluation, Project File Exhibit N-3).

2) Sediment will settle in Bunyan Lake. There is no analysis of how sediment will impact this small lake.

20 Response to Comment #20: As stated on page 3-203 of the EA, the replacement of the culvert on FSR #9552 will



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generate only a small amount of sediment during the implementation. Using their professional experience, the District Fisheries Biologist and District Ranger estimate that with the Design Criteria described in this Decision Notice (Appendix 2, page 2-5) this project would mean roughly 7 cubic feet of sediment would transport to Bunyan Lake. Bunyan Lake is approximately 9 acres in size. Assuming the sediment spreads evenly, the sediment layer would be 0.000001 inch deep. This sediment is far too small to detect in the lake and has no impact to fish habitat or water quality.

3) Road #79W is a potential source of chronic sediment yet it will not be decommissioned.

21 Response to Comment #21: Since the purpose and need does not include restoration of roads on Legacy Lands, no action is proposed on this road.

4) The Glacier Creek watershed is ranked as Functioning at Risk in the Watershed Condition Framework yet there is neither mention of this in the EA nor any attempt to improve this watershed with this project. In fact, this project will further degrade this watershed.

22 Response to Comment #22: The Watershed Condition Framework was a 2011 approach for classifying watershed conditions and to prioritize restoration needs on a national scale. The watershed condition classification reflects the level of watershed health or integrity into the following categories: Class 1 = Functioning Properly (1.0 to 1.66) Class 2 = Functioning at Risk (>1.66 to <2.33) Class 3 = Impaired Function (2.33 to 3.0) In 2011, an Interdisciplinary Team classified all 6th level hydrologic unit codes (HUC) on the Flathead Forest. The classification used 12 core national indicators: Water quality, water quantity, aquatic habitat, aquatic biota, riparian vegetation, roads and trails, soils, fire regime or wildfire, forest cover, rangeland vegetation, terrestrial invasive species, and forest health. As a result of the evaluating the 12 core indicators, the Glacier Creek Watershed was calculated to be “Functioning at Risk” as displayed on the Washington Office Website. This score was then entered into the National Watershed Classification and Assessment Tracking Tool (WCATT) maintained by the Washington Office of the Forest Service. In evaluating your comment, we reviewed our data ratings for the 12 core national indicators that the ID



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Team evaluated for the Glacier Creek Watershed. It was determined that our Forest spreadsheet with these ratings was not consistent with the corporate database maintained by the Washington Office. It was determined that an error was made when the spreadsheet data was input into the corporate database for 2 categories (Fire Effects and Regime and Forest Cover). This inconsistency has been updated on the national website to reflect these errors. As a result, Glacier Creek is classified as “Functioning Properly.” The Glacier Loon Project would not degrade Glacier Creek. The Hydrology Analysis in the EA on pages 3-167 to 3-171 concludes all of the action alternatives have negligible impacts to Glacier Creek.

5) All alternatives will log and road in Riparian Habitat Conservation Areas. An alternative should have been developed that protected riparian areas, not cause further degradation.

23 Response to Comment #23: The Selected Alternative does include some timber harvest in RHCAs (Units 19, 24, 57, 61, and 205). However as disclosed on page 3-176, 3-207 and Project File Exhibit N-8, the harvest activity in the RHCA is not expected to have any impact to the wetlands or streams whatsoever. The harvest is proposed in upland areas, on the uphill side of existing roads and there is no potential for any sedimentation or other impacts to water quality. Since there was no potential for sediment delivery, there was no reason to develop an alternative that defers this harvest. As for road construction, both the Fisheries and Hydrology Analyses review potential impacts of temporary road construction in RHCAs in their analysis of sedimentation. One alternative (Alternative C) was developed that deferred any new temporary roads in RHCAs.



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Wildlife The concern we raised during scoping that using the Bear Management Subunit, that includes the Mission Mountain Wilderness, as the project area would serve to dilute the effects in the actual project area is true and correct. The forest condition in the Wilderness is pristine, the forest condition outside the wilderness is heavily roaded and logged. The effects of this project are watered down because the wilderness is part of the project area.

24

Response to Comment #24: As stated in Comment #1, the wildlife analysis is not “skewed” due to the location of the proposed project adjacent to the Mission Mountain Wilderness. Forage for different wildlife species is discussed on a stand by stand basis and how many acres of suitable habitat would be affected; security in relationship to road density is described relative to the amount of change from current conditions, so magnitude of effects between different alternatives can be displayed; security relative to potential displacement is discussed predominately within the action area (outside of wilderness); hiding cover is analyzed across the entire project area (including wilderness), but also discussed section by section relative to important habitats like old growth, wetlands, or lynx forage (EA, pages 3-215 thru 3-358). It would be inappropriate not to include the adjacent wilderness area in the discussion of potential effects, because adjacent areas of security (e.g. refugia) are important for wildlife. Large, secure areas for wildlife are an integral part of several of the forest’s key operational standards and guidelines for wildlife (Amendment 19 Security Core and Subunit Rotation in the Swan Valley).

You must reanalyze the impacts in an EIS using the non-wilderness as your project area.

25

Response to Comment #25: It would be inappropriate not to include the adjacent wilderness area in the discussion of potential effects, because adjacent areas of security (e.g. refugia) are important for wildlife. See Response to Comments #1 and #24.

2) The EA fails to disclose the current population of fisher in the project area except that it is in decline. (EA page 3-286) This project will decrease and eliminate 612 acres of fisher habitat within and adjacent to existing wetlands. The EA concludes that the project “may impact individuals or habitat, will not likely contribute to a trend

26

Response to Comment #26: The comment refers to a citation on EA, page 3-286. The citation specifically reads “Factors outside of the Forest Service’s Control (such as trapping, predator/pest control, or alteration of private forest habitats) could be associated with fisher population decline, management actions taken on the



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towards Federal listing or loss of viability to the population or species.” How can the Flathead possibly make this determination when the Forest Service doesn’t even know what the baseline population is, what the current population is and what the population trend for this species is in the project area? Without this key information the Flathead cannot determine whether it is currently maintaining viable populations of fisher and whether this project or past projects has negatively impacted the fisher. The Forest Plan requires monitoring the distribution of fishers and the change in population status, ensuring projects do not contribute to the loss of viability of fisher, avoiding adverse impacts to fisher or their habitats whenever possible and preparing a fisher management plan or conservation strategy to prevent the loss of population viability. The Flathead has not completed a conservation strategy for fisher. This project does not avoid adverse impacts to fisher and their habitats.

Flathead National Forest would provide habitat composition and structure for fisher across the forest.” The population of fisher is unknown at the project level; however the Flathead Forest does not use a proxy on proxy approach for old growth associated species (Amendment 21 ROD 1999 – Project File Exhibit T-8a). Fisher is an old growth associated species. Amendment 21 provides a management strategy to retain all existing old growth habitat. Amendment 21 (A21) directs monitoring of old growth habitat and associated species across the Flathead National Forest. Monitoring requirements under Amendment 21 to the Forest Plan does not require monitoring of fisher specifically, nor does A21 require monitoring of carnivore distribution at the project level. Rather A21 directs monitoring of old growth and old growth associated species at the forest level (Amendment 21 ROD 1999). The Flathead Forest has fulfilled this requirement (Project File Exhibits H-18, T-9, and T-9a). The Flathead Forest has conducted monitoring for carnivore distribution across the forest in cooperation with MT FWP (Project File Exhibit H-18). Monitoring information and the best available science suggests fisher numbers are low but stable and that this species has historically existed at low densities (Project File Exhibits H-18 and H-132).This is consistent with the EA (EA, page 3-279). The Forest Service has been monitoring for fisher presence and distribution since 2004 using hair snares. Since 2004, 4,813 snares have been deployed across the Northern Rockies. From 2007 to 2011, the Flathead Forest has used hair snares across various portions of the forest yielding no fisher detections (Project File Exhibit H-18). From 2000-2011, winter snow tracking transects were conducted for carnivores in the Swan Valley including the Glacier Loon Project Area. During the winter of 2011 and 2012, systematic winter carnivore monitoring was



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conducted throughout the Upper Swan Lake, Seeley Lake and Lincoln Ranger Districts. Systematic monitoring included both snow tracking to collect hair/scat samples and fisher hair snares. Recent results from snow tracking and DNA analysis, did not detect fisher within the Glacier Loon Project Area (Project File Exhibit H-24). Furthermore, DNA analysis did not detect fisher within the Swan Lake, Seeley, or Lincoln Ranger Districts. However, fisher may be difficult to monitor due to low densities and are assumed to be present in the project area (EA, page 3-279). Under the Selected Alternative, 320 acres of fisher habitat would be treated adjacent to existing wetlands (EA, page 3-283). No treatment is proposed in old growth habitat. No harvest would occur in Riparian Conservation areas (Decision Notice – Appendix 2). Downed logs and cover will be retained in these areas. Prescription for treatments would provide for snag and down woody debris (EA, page 3-284). Under Cumulative Effects, the EA states “there would continue to be adequate old growth, riparian habitat, and mid to late-seral forest matrix habitat to maintain connectivity and functional home ranges” (EA, page 3-286). Fisher was analyzed as a “sensitive species.” The Forest Service is currently conducting research on fisher within the Region. A conservation strategy will be developed at the regional level based on this research upon its completion. Monitoring, habitat management direction and the Glacier Loon project analysis support the determination made in the EA (page 3-283) and that there appears to be “little risk of population loss across the Forest and the Region” (EA, page 3-286, Project File Exhibit H-18).

3) The analysis of hiding cover for grizzly bears and big game is skewed because the wilderness is included in the project area. The EA states that approximately 70% of the project area provides hiding cover for grizzly bears, but this includes all NFS lands and wilderness. By including the wilderness there is only a 4% decrease in hiding

27

Response to Comment #27: As discussed in Comments #1 and #24 and #25, hiding cover is analyzed across the entire project area (including wilderness), but also discussed section by section relative to important habitats like old growth, wetlands, or lynx forage (EA, pages 3-215 thru 3-358).



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cover in Alternative B. The 1,453 acres of cover being removed is OUTSIDE the wilderness where cover is scarce and the area is heavily impacted. The analysis must delineate the impacts to bears and hiding cover outside of wilderness.

The Swan Valley Grizzly Bear Conservation Agreement guideline for cover (40%) is based on a Grizzly Bear Subunit. The important factor is how much difference there is in the amount of decrease in hiding cover between alternatives; from 0% reduction in the No Action alternative to 4% in Alternative B. Under the Selected Alternative, the amount of decrease in hiding cover will be 2%. It would be inappropriate not to include the adjacent wilderness area in the discussion of potential effects, because adjacent areas of security (e.g. refugia) are important for wildlife. Large, secure areas for wildlife are an integral part of several of the forest’s key operational standards and guidelines for wildlife (e.g. Amendment 19 Security Core and Subunit Rotation in the Swan Valley) specifically because they are beneficial for wildlife species.

4) This project will result in a decrease in 517 acres of hare habitat, yet because it is within the WUI there is no analysis of how this will affect lynx. No alternative was developed that did not use the WUI exemption. Lynx don’t know the difference between WUI and non-WUI, they just know that their prey is reduced.

28 Response to Comment #28: The Purpose and Need for this project includes Fuel Reduction; the range of alternatives is intended to meet this Purpose and Need. The alternative that does not treat fuels in the WUI would be the No Action Alternative.

5) The EA discloses that all alternatives will have a negative effect on lynx critical habitat. But the EA does not analyze the cumulative impacts of adjacent projects (Cold Jim, Summit Salvage, Colt Summit, Hemlock Elk, and proposed Beaver Creek) that are in the same LAUs as Glacier Loon, how they affected lynx habitat and how much more lynx can take. Once again, saying there is enough habitat in the wilderness is not adequate. In addition, cumulative effects from Highway 83, utility corridors, private land development, trapping and snaring, hound hunting, predation and starvation, high kitten mortality, and logging on other ownerships should be evaluated.

29 Response to Comment #29: The EA discusses cumulative effects to lynx on pages 3-257 thru 3-261. Existing information on habitat in the Elk, Holland and Lower Beaver LAU’s specifically includes effects from the Summit Salvage and Hemlock Elk Projects. The FWS analyzed the effects fuels reduction within the WUI on lynx in their first-tier biological opinion and provided an Incidental Take Statement (ITS) for these activities. Terms and conditions in the Incidental Take Statement limit the number of acres per Forest that can be treated in ways that adversely affect lynx habitat. Forest allocations of activity acres approved in the Biological Opinion for the 2007 decision are reported annually to the FWS. Further, the Glacier Loon Project is consistent with standards and guidelines in the NRLMD (EA, page 3-261).Colt Summit as well as the other projects and effects mentioned in this comment are also addressed



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in the TES Cumulative Effects Worksheet (Project File H-20).

6) The EA does not disclose how the WUI was delineated. It must be consistent with the Northern Rockies Lynx Management Direction. The NRLMD ROD at 20 states: “What limit(s) should be applied: We elected to put a limit on the amount of fuel treatment projects that could exceed the vegetation standards, since WUI has not been mapped on all units. We evaluated the WUI based on a mile of

where people live (FEIS, Vol. 1 p. 217). A one mile buffer from

communities was used because HFRA describes WUI as ½ mile or

1 ½ miles depending on certain features. One mile splits this

difference and is easy to approximate.

30 Response to Comment #30: The EA discusses how the Wildland Urban Interface (WUI) was delineated on page 3-124; “In 2004 Missoula County completed the Seeley Swan Community Wildfire Protection Plan” (CWPP). This plan described areas considered WUI in the project area. The majority of the project area proposed for treatment is designated WUI.” Approximately 14,539 acres of the Glacier Loon Project Area is located within the WUI. The WUI boundary from the Seeley-Swan Community Wildfire Protection Plan was used in this analysis. The NRLMD ROD defines the WUI as “an area adjacent to an at-risk community that is identified in the community wildfire protection plan. If there is no protection plan in place, the WUI is the area 0.5 miles from the boundary of an at risk community.” The Glacier Loon Project is consistent with the NRLMD. Consistency with standards and guidelines of the NRLMD is documented in the EA on pg. 3-261. Please also refer to Project File Exhibit K-43.

7) This project does not favor the needs of the grizzly bear in violation of the Forest Plan.

31 Response to Comment #31: We disagree. As the EA discusses on page 3-241: “Management decisions and design criteria for this project favor, and make this project compatible with, the needs of grizzly bear recovery and conservation by:

Strict adherence to a grizzly bear subunit rotation by major landowners and cooperators (USFS, DNRC, and TNC) that leaves every subunit in the Swan Valley inactive for a minimum of 3 years;

Restriction of commercial activities in spring habitats during the spring period;

Retention of visual screening along open roads; Open and total road density restrictions; Proposed road decommissioning; The maintenance of a minimum of 40% cover

across all ownerships in the affected subunits; Linkage zone designation for grizzly bears in the



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affected subunits; Under all alternatives, the contract for the Glacier

Loon Project would include a clause for the temporary suspension or cessation of activities, if needed, to resolve any grizzly bear/human conflict;

A Special Order (2010) is in effect that requires all users of NFS lands in the Swan Valley, and throughout the Flathead National Forest, to store food, garbage and other bear attractants in a bear-resistant manner. This special order is included in all contracts associated with the project.

Further strategies to manage the lands encompassing the proposed Glacier Loon Project in a manner that favors the grizzly bear include active participation in Bear Smart Community programs, a District Bear Ranger program, and land acquisition endeavors.”

8) The EA does not disclose the existing thermal cover in the project area OUTSIDE of wilderness or how the project will affect thermal cover for big game.

32 Response to Comment #32: Thermal cover is discussed briefly on page 3-338. As discussed in the Management Indicator Species - Commonly Hunted Big Game Section of the wildlife analysis, thermal cover is very important on winter range, but most of the project area is not designated winter range. Most of the project area is summer range; important habitat characteristics for summer range include wetland habitats, which are discussed thoroughly in the Commonly Hunted Big Game Section (EA, pages 3-333 thru 3-346).

9) Moose are declining the mountain west, yet there is no analysis of how this project will impact moose and the riparian, wetland habitat that they depend upon.

33 Response to Comment #33: Potential effects to moose are analyzed in the EA in the Management Indicator Species - Commonly Hunted Big Game portion of the Wildlife Section (pages 3-333 thru 3-345). White-tailed deer, mule deer, and elk are Management Indicator Species (MIS) for commonly hunted big game species on the Flathead National Forest (USDA 1985). At the forest level, meeting the habitat needs for white-tailed deer, mule deer, and elk would indicate that the habitat needs for other commonly hunted big game species, such as black bear, mountain lion, and moose, would also be met. Potential impacts to big game species, including moose, particularly impacts to riparian and wetland habitats are discussed in the EA on pages 3-337, 3-340, and 3-342.



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Other

1) There is no analysis for why the change in Management Area allocation is MA5 rather than MA2. There were previous commitments by the Forest Service to change the MA to the more protective MA2 yet no rationale is given why it should be MA5 instead.

34

Response to Comment #34: According to the Flathead Forest Plan on page III-5, Management Area 2 consists of unroaded lands suited for dispersed recreation that meet the Recreation Opportunity Spectrum classification of “primitive.” Primitive is defined in the Forest Plan as “Area is characterized by essentially unmodified natural environment of fairly large size. Evidence of humans would be unnoticed by an observer wandering through the area” (Forest Plan, Appendix A, pages A-1 and A-2). Management Area 5 consists of roaded timberlands in areas of high scenic value. Due to past Plum Creek Timber Company harvest and the associated existing roads located on the west hillside facing Lindberg lake, this area was not considered as “primitive.” The primary value in this area is preservation of scenic quality. In addition, management areas are designated dependent upon the management areas of the adjacent lands and the parcels characteristics CFR 36 254.3 (f). Due to the adjacency of MA 5 to this land area and the characteristics of this land area, MA 5 was selected as the appropriate designation. There was no previous commitment or decision to change the management area designation to MA 2. The current District Ranger discussed this issue with the previous District Ranger. The previous District Ranger said that changing the management area designation was considered but it was not brought to closure. The Glacier Loon Decision addresses this issue through selection of Alternative D with Modifications.

2) The EA did not analyze the cumulative effect of logging which opens up the forest to increased off highway vehicle travel.

35 Response to Comment #35: As described in the Decision Notice, the total acres treated and the amount of temporary roads under the Selected Alternative is the least amount in acres treated and temporary road construction from what was proposed in the other action alternatives. Existing open roads and closed roads (currently bermed or gated) will be used to conduct the vegetation management operations. Use of open roads will not change from the existing conditions. Roads that are currently closed but will



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be used for proposed activities will be closed to the public during the time they are used for timber management activities (See Design Criteria – Appendix 2 of this DN). Decommissioning of 8.4 miles of system road, half of which is planned to be recontoured, will reduce opportunity for unauthorized motorized use. Design Criteria to prevent unauthorized motorized use are incorporated into the project (See Appendix 2 - Design Criteria in the Decision Notice). Temporary roads will be reclaimed and existing regulations prohibiting cross-country motorized use are in place and will be enforced. The direct effects of temporary roads and their use are analyzed throughout the Wildlife Section of the EA. If the question is based on the presumption of significant amounts of unauthorized use occurring post-harvest, we believe the temporary roads and reclamation and legal closures and patrol and law enforcement work will keep such activities in check. The use of existing Legacy Roads will also minimize creation of temporary road from off open system as all the Legacy Roads to be used are gated and not open for public motorized travel.

3) The purpose and need for this project does not include any restoration of water quality, fish or wildlife habitat and is entirely aimed at logging. It is inappropriate to use CFLRP funds for a project that destroys wildlife habitat and wetlands, spreads weeds, and negatively impacts wildlife.

36 Response to Comment #36: The Glacier Loon Project, while not developed under the auspices of the Southwestern Crown Collaborative or CFLRP, due to the project planning beginning prior to CFLRP, nevertheless, addresses the three primary objectives of both the CFLRP program and the Southwestern Crown: (1) fuels mitigation; (2) forest restoration; and (3) watershed improvement. Fuels mitigation will be accomplished through (a) Regeneration of dead or dying stands weakened by abnormal insect and disease outbreaks occasioned by historic fire suppression; (b) thinning to reduce ingrowth of shade-tolerant species that create ladder fuels, thus reducing risk of crown fires; and (c) reducing high concentrations of dead and down fuels in conjunction with stand thinning. Forest restoration will be accomplished through (a) re-establishment of important early seral species (western



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larch, ponderosa pine, white pine) in some areas now occupied by low vigor, high density lodgepole pine; (b) thinning from below to remove encroaching shade-tolerant species and shift stand structures in favor of larger, early seral species; (c) releasing larger trees with old-growth attributes; and (d) re-introducing fire to the landscape where practicable in conjunction with stand treatments. Watershed improvement will be accomplished through implementing road decommissioning, resource enhancement projects, best management practices, and management area changes as discussed below.

Under the Selected Alternative, an estimated 8.4 miles will be decommissioned. Included in this decommissioning is the full recontouring of Roads #9575, #10732, #10733, and #10734 totaling 3.9 miles. In addition, decommissioning of NFS Road #561F will halt erosion on the single largest known sediment point-source in Glacier Loon Analysis Area. Decommissioning will contribute to the restoration efforts of the watersheds and reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas. Decommissioning these road corridors will also restrict human vectors from moving existing weed infestations and allowing the native vegetation to grow back over the corridor. Resource Enhancement Projects: One Resource Enhancement Project (Resource Enhancement Project #1 on Map 2) will re-establish vegetation on an historic road (unmapped, with no number) or skid trail that was discovered about 0.25 miles from the end of NFS Road #9591Y. This travelway is located in the bottom of a small draw and now collects enough water to scour a stream channel that runs down the middle of the draw bottom. Although the amount of water is small and does not appear to cause much erosion, it is likely to be affecting the groundwater by flowing on the surface before it connects with the wetland. The wetland is an occupied Howellia pond whose habitat should be protected. This project will plant approximately 400 shrubs and seedlings on about 250 feet of the valley



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bottom to diffuse water flow so it can to go back into the ground.

A new culvert on NFS Road #9552 at Meadow Lake outflow will be designed for aquatic fish passage and will be sized for 100-year flood event. This work is also a restoration project and not a road concern (Resource Enhancement #2 – Map 3). The culvert is undersized and has developed about one foot high waterfall on the outlet. The existing road is poorly designed where it crosses the unnamed stream that flows between Meadow Lake and Bunyan Lake. The culvert is a seasonal fish migration barrier and the road surface erodes into the creek. Both Bunyan and Meadow Lake have wild (self-sustaining) cutthroat trout and the barrier is not desirable. This project will replace the culvert with either a larger culvert that provides fish passage or a bridge. The road will be reconstructed so that it does not erode into the stream. In the long-term, addressing the chronic erosion at the fish barrier on Road #9552 will reduce sedimentation to fish habitat. Minor work will also take place at the trailhead to reduce erosion. Please see the Hydrology and Fisheries Sections of this document for more information.

Temporary Road #12A is a historic road with a culvert already in place. The culvert was poorly installed in early 1980s, and the stream almost breached the road in the prolonged 2011 runoff. Under the Selected Alternative, this road is not needed to access harvest units but Design Criteria (Appendix 2) for this alternative will require removal of the culvert, the channel restored, and the road reclaimed. This is considered more advantageous to the Hydrologic Resource, specifically water quality, than leaving the old road along with the potential for the culvert to wash out at some point in the future resulting in potential sediment delivery.

Under the Selected Alternative, an estimated 29.3 miles of road will have Best Management Practices (BMPs) installed Given there are currently 101.4 miles of road in the Glacier Loon Project Area, this means 29 percent of the total road network would receive BMPs. BMPs will reduce the small amount of erosion that occurs annually



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on area road systems.

All planned road-related work in the project area will contribute to the restoration efforts of the watersheds within the Glacier Loon Project Area. The Selected Alternative will reduce erosion, provide fish passage and reduce road densities. The Selected Alternative will cumulatively reduce the long-term effects of the road system on water quality, wildlife security, wetlands/riparian areas, and road maintenance costs.

CFLRP funding is appropriate for project work that meets the intent of the Forest Landscape Restoration Act. Please see Project File Exhibit T-14 for further description of what restoration work is discussed in the Act. The Forest Service does not make timber sales simply for generating volume. Timber sales are the means of implementing forest health and fuel reduction treatments. They do this in two main ways: (1) by applying the vegetation treatments necessary to accomplishing the objective; and (2) by paying for the cost of treatment. Without timber sales, many restoration treatments would not get accomplished.

The Flathead needs to prepare an Environmental Impact Statement that does not skew the analysis by including the wilderness and addresses all the concerns that are raised in our comments and those of Swan View Coalition and Alliance for the Wild Rockies.

37 Response to Comment #37: The Forest Service respectfully disagrees. The environmental analysis did not indicate any significant effects; therefore, an EIS is not required.

Sincerely,

Arlene Montgomery Program Director

glacier loon fuels reduction and forest health...

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