Vail Intermountain Fuels Project EA - fs.usda.gov

United States Department of Agriculture

Vail Intermountain Fuels Project

Environmental Assessment

Forest Service White River National Forest Eagle-Holy Cross Ranger District

February 2016

For More Information Contact

Cary Green, East Zone Timber Management Assistant

Eagle-Holy Cross Ranger District

White River National Forest

P.O. Box 190, Minturn, CO 81645

[email protected]

970-827-5160

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Vail Intermountain Fuels Project Environmental Assessment

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Contents

Section 1: Introduction .................................................................................................................................. 1 Background ............................................................................................................................................... 1

Location of the Proposed Project Area ................................................................................................. 2 Purpose and Need for Action .................................................................................................................... 2

Management Direction .......................................................................................................................... 4 Nature of the Decision to be Made ........................................................................................................... 5 Public Involvement ................................................................................................................................... 6

Collaboration ......................................................................................................................................... 6 Scoping ................................................................................................................................................. 7 Issues ..................................................................................................................................................... 7

Section 2: Proposed Action and Alternatives ............................................................................................. 11 No-Action Alternative ............................................................................................................................ 11 Proposed Action ..................................................................................................................................... 13 Project Design Features .......................................................................................................................... 16 Monitoring Requirements ....................................................................................................................... 20 Alternatives Considered but Eliminated from Detailed Study ............................................................... 21

Section 3: Environmental Impacts of the Proposed Action and Alternatives ............................................. 21 Silviculture ............................................................................................................................................. 22

Affected Environment ......................................................................................................................... 22 Environmental Consequences ............................................................................................................. 27

Fuels ....................................................................................................................................................... 34 Affected Environment ......................................................................................................................... 34 Environmental Consequences ............................................................................................................. 41

Canada Lynx ........................................................................................................................................... 44 Existing Environment/Environmental Baseline .................................................................................. 44 Environmental Consequences ............................................................................................................. 49

Other Wildlife ......................................................................................................................................... 53 Methodology ....................................................................................................................................... 53 Environmental Consequences ............................................................................................................. 53

Recreation ............................................................................................................................................... 64 Affected Environment ......................................................................................................................... 64 Environmental Consequences ............................................................................................................. 65

Scenery ................................................................................................................................................... 66 Affected Environment ......................................................................................................................... 66 Environmental Consequences ............................................................................................................. 68

Roadless .................................................................................................................................................. 71 Affected Environment ......................................................................................................................... 71 Environmental Consequences ............................................................................................................. 75

Hydrology ............................................................................................................................................... 79 Affected Environment ......................................................................................................................... 79 Environmental Consequences ............................................................................................................. 84

Soils ........................................................................................................................................................ 86 Affected Environment ......................................................................................................................... 86 Environmental Consequences ............................................................................................................. 91

Botany ..................................................................................................................................................... 94 Affected Environment ......................................................................................................................... 94 Environmental Consequences ........................................................................................................... 102 Determinations .................................................................................................................................. 105


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Weeds ................................................................................................................................................... 108 Affected Environment ....................................................................................................................... 108 Environmental Consequences ........................................................................................................... 109

Fisheries and Aquatic Macroinvertebrates ........................................................................................... 111 Affected Environment ....................................................................................................................... 111 Environmental Consequences ........................................................................................................... 112 Determinations .................................................................................................................................. 113

Operations and Safety ........................................................................................................................... 114 Affected Environment ....................................................................................................................... 114 Environmental Consequences ........................................................................................................... 115

Economics ............................................................................................................................................ 119 Affected Environment ....................................................................................................................... 119 Environmental Consequences ........................................................................................................... 119

Cultural and Heritage Resources .......................................................................................................... 122 Affected Environment ....................................................................................................................... 122 Environmental Consequences ........................................................................................................... 122 Determinations .................................................................................................................................. 123

Section 4: Agencies and Persons Consulted ............................................................................................. 123 Federal Agencies .................................................................................................................................. 123 Tribes .................................................................................................................................................... 124 Other Organizations .............................................................................................................................. 124

References ................................................................................................................................................. 125 Appendix A: Summary of Activities Considered in Cumulative Effects Analysis .................................. 126 Appendix B: Summary of Public Comments and Responses ................................................................... 127

List of Tables

Table 1. Proposed action activities by silvicultural prescription ................................................................ 14 Table 2. Silvicultural prescriptions by treatment units (acres) ................................................................... 14 Table 3. Vail Intermountain analysis area by structural stage .................................................................... 24 Table 4. Vail Intermountain proposed treatment unit mortality represented by basal area ........................ 27 Table 5. Proposed action by silvicultural prescription ................................................................................ 28 Table 6. Regeneration results, Vail Valley treatments1 .............................................................................. 29 Table 7. List of past, present, and reasonably foreseeable activities1 by activity type ............................... 31 Table 8. Vail Intermountain analysis area by structural stage, cumulative effects1 .................................... 32 Table 9. Comparison of the no action and proposed action alternatives ..................................................... 33 Table 10. Current distribution of fire behavior fuel models in the project area .......................................... 36 Table 11. Fireline intensity interpretations and associated fire hazard ratings ........................................... 38 Table 12. Potential fire behavior characteristics modeled for the project area ........................................... 40 Table 13. Acres and percentages of lynx habitats within the project area boundary .................................. 47 Table 14. Acres and percentages of lynx habitats by treatment unit........................................................... 49 Table 15. Summary comparison of environmental effects and determination for Forest Service sensitive

species, management indicator species and species of concern .......................................................... 54 Table 16. Soil characteristics for the Vail Intermountain Project ............................................................... 87 Table 17. Sediment and runoff modelled results using disturbed WEPP, Vail Intermountain Project ....... 93 Table 18. Botany analysis area vegetation cover types ............................................................................... 94 Table 19. Threatened, endangered, and proposed plants evaluated ............................................................ 96 Table 20. Region 2 sensitive plants evaluated ............................................................................................ 97 Table 21. Summary of determinations for threatened, endangered, or sensitive plants............................ 107 Table 22. Weed infestations in the analysis area ...................................................................................... 108 Table 23. Weeds indicators and measures for alternative 1 ...................................................................... 109


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Table 24. Weeds indicators and measures for alternative 2 ...................................................................... 111 Table 25. Summary comparison of environmental effects to weeds ........................................................ 111 Table 26. Log truck traffic, noise, and project safety indicators and measures for the existing condition115 Table 27. Additional log truck traffic, noise, and project safety indicators and measures for the no-action

alternative .......................................................................................................................................... 115 Table 28. Typical A-weighted sound and noise levels associated with common sound........................... 117 Table 29. Log truck traffic, noise and project safety indicators and measures for the proposed action

direct/indirect effects ........................................................................................................................ 118 Table 30. Log truck traffic indicators and measures for the proposed action cumulative effects ............. 119 Table 31. Economic indicators and measures for the no-action alternative .............................................. 120 Table 32. Economic indicators and measures for the proposed action direct/indirect effects .................. 122 Table 33. Forest Service cultural resource inventories conducting in the project area in the past ........... 123

List of Figures

Figure 1. Vicinity map .................................................................................................................................. 3 Figure 2. Intermountain area completed treatments and no-action alternative ........................................... 12 Figure 3. Vail Intermountain proposed treatment unit map ........................................................................ 15 Figure 4. Species composition by cover type for Vail Intermountain analysis area (5,822 acres) ............. 23 Figure 5. Existing condition lodgepole pine ............................................................................................... 26 Figure 6. Forest health monitoring plot data by area .................................................................................. 26 Figure 7. Fuel loading levels in the project area ......................................................................................... 36 Figure 8. Canopy base height as it relates to critical flame length (feet) .................................................... 39 Figure 9. Eagle Valley and Camp Hale lynx analysis units with respect to the Vail Intermountain Fuels

Project Area ........................................................................................................................................ 46 Figure 10. Eagle Valley Lynx Analysis Unit, including lynx habitat types ................................................ 48 Figure 11. Adventure Ridge on a mid-week day during the winter at the Vail Ski Resort ......................... 64 Figure 12. The project area scenery in general ........................................................................................... 67 Figure 13. The Game Creek Colorado Roadless Area ................................................................................ 72 Figure 14. Past treatments in the Game Creek Colorado Roadless Area .................................................... 74 Figure 15. Geology of project and direction arrow of prevailing dip in bedding planes ............................ 81 Figure 16. Unit location, buffered hazard streams ...................................................................................... 82 Figure 17. Slope class map ......................................................................................................................... 83 Figure 18. Project area treatment units and soil map units ......................................................................... 88 Figure 19. Project area slope classes and treatment units ........................................................................... 89 Figure 20. Project treatment units and landslide deposits ........................................................................... 90


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Section 1: Introduction This environmental assessment is prepared to determine whether effects of the proposed activities may be

significant enough to prepare an environmental impact statement. By preparing this environmental

assessment, we are fulfilling Agency policy and direction to comply with the National Environmental

Policy Act (NEPA) and other relevant Federal and State laws and regulations, including the Healthy

Forest Restoration Act (HFRA).

This environmental assessment discloses the direct, indirect, and cumulative environmental effects that

would result from the proposed action and no action (baseline) alternatives. The document is organized

into four parts:

Introduction: This section includes information on the history of the project proposal, the purpose

and need for action, and the Agency’s proposal for achieving that purpose and need. This section

also details how the Forest Service collaborated among State, local, and Tribal governments; non-

governmental organizations; and other interested parties as required by HFRA, as well as how the

Forest Service informed the public of the proposal and how the public responded.

Proposed Action and Alternatives: This section provides a more detailed description of the

proposed action and no action alternatives. Also, this section provides a summary table of the

environmental consequences associated with selecting the action alternative versus the no-action

alternative.

Environmental Impacts of the Proposed Action and Alternatives: This section describes the

environmental effects of no action, as well as the trade-offs and effects of implementing the

action alternative. This analysis is organized by resource area. Within each section the existing

environment is described first, followed by the estimated effects of no action that provides a

baseline for evaluation, and finally the estimated effects of the action alternatives.

Agencies and Persons Consulted: This section lists agencies and others consulted during the

development of the environmental assessment, and those who prepared the environmental

assessment.

Additional documentation, including more detailed analyses of project area resources, may be found in

the project planning record located at the Eagle-Holy Cross Ranger District Office in Minturn, Colorado.

Background The Town of Vail and Vail Fire Department are concerned about wildfire risk to private residents and

infrastructure adjacent to National Forest System lands, especially in light of the wildfires that have

affected Colorado front-range communities in recent years. The area of concern is west of the Vail Ski

Area boundary to Dowd Junction, also known as West Vail or Vail-Intermountain.

The project area has been affected by the mountain pine beetle outbreak which swept through central

Colorado between 2004 and 2012. Some small stands and pockets of aspen are intermixed within the

lodgepole pine forest. Forest inventory data from 2014 indicate that mortality rates in lodgepole pine

over 7.0 inches diameter at breast height (d.b.h.) varies between 36 and 59 percent (trees per acre). This

mortality predominantly occurs in trees over 10.0 inches d.b.h. Standing dead trees are deteriorating and

are expected to fall to the ground within the next 10 to 15 years. These dead trees would cumulatively

contribute to hazardous fuel loading within the project area. Hazardous fuels accumulations associated


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with localized tree mortality could create an unacceptable fire hazard that could support future high

severity/high intensity fire behavior in the event of an ignition.

In 2014, White River National Forest vegetation and fuels staff assessed the current forest health and fuels

situation in the Vail Intermountain Project Area. Recommendations were developed for potential

vegetation treatments that would reduce future hazardous fuel loading, reduce wildfire risk, and enhance

forest health within the Vail Intermountain Wildland-urban Interface. The wildland-urban interface is

defined as the line, area, or zone where structures and other human development meet or intermingle with

undeveloped lands or vegetative fuel (2011 Eagle County Community Wildfire Protection Plan, page 13,

figure 2). These staff recommendations and proposed treatments complement the 62 acres of hazardous

fuels reduction treatments completed between 2004 and 2008 on private, county, and Federal lands in the

Vail Intermountain Wildland-urban Interface (see Figure 2).

The Forest Service has been working collaboratively with the Town of Vail, Vail Fire Department, Eagle

County Wildfire Council, Vail Resorts, Eagle River Water and Sanitation District, Colorado State Forest

Service, Colorado Parks and Wildlife, and others interested in the project. The collaborative efforts for

this project are described in the “Public Involvement” section of this environmental assessment.

Location of the Proposed Project Area

The project area is located in the Intermountain Area of Vail on the south side of I-70 and west of Vail

Resorts Ski Area (see Figure 1). This project is located in portions of sections 12, 13, 14, 22, and 23;

Township 5 South; Range 81 West; 6th Principal Meridian, Eagle County, Colorado.

Purpose and Need for Action In 2007, the Deputy Regional Forester for the Rocky Mountain Region of the U.S. Forest Service

declared the current mountain pine beetle outbreak to be an epidemic. The epidemic within Eagle County

affected the mature lodgepole pine vegetation to varying degrees before finally subsiding in 2012.

Proposed treatments would provide an opportunity to reduce current and future hazardous fuel

accumulations and hazardous fuel continuity associated with the lodgepole pine mortality within the

project area. In addition, favorable conditions for aspen regeneration would be expected to occur in

created openings.

The purpose of the Vail Intermountain Fuels Project is to:

Reduce the current and future wildfire hazard to and from adjacent communities by managing

existing hazardous fuels on Federal lands.

Create strategic hazardous fuel breaks and maintain/expand existing aspen diversity on Federal

lands through vegetation management activities while maintaining ecosystem structure and

processes.

The action is needed because:

Moderate to high levels of tree mortality in lodgepole pine from the 2004 to 2012 mountain pine

beetle outbreak exist within the project area which will contribute to current and future hazardous

fuels.

The continuous canopy of mature lodgepole pine in the project area increases the risk of a

running crown fire and reduces the likelihood of protection of valuable infrastructure in the West

Vail area.


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Figure 1. Vicinity map1

1 All maps in this document are reproduced from geospatial information prepared by the U.S. Department of Agriculture, Forest Service. GIS data and product accuracy may vary. They may be:

developed from sources of differing accuracy, accurate only at certain scales, based on modeling or interpretation, incomplete while being created or revised, etc. Using GIS products for purposes other

than those for which they were created may yield inaccurate or misleading results. The Forest Service reserves the right to correct, update, modify, or replace GIS products based on new inventories,

new or revised information, and if necessary in conjunction with other Federal, State, or local public agencies or the public in general as required by policy or regulation. Previous recipients of the

products may not be notified unless required by policy or regulation. For more information, contact the White River National Forest at (970) 945-2521.


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The majority of the aspen within the project area is mature and has been succeeded or will be

succeeded by conifer tree species (lodgepole pine, blue spruce, subalpine fir, Engelmann spruce,

Douglas-fir). Aspen stands act as an effective natural fuel break which will modify fire behavior.

Management Direction

This environmental assessment is tiered to the White River National Forest Land and Resource

Management Plan 2002 Revision, Final Environmental Impact Statement and Record of Decision (2002),

and incorporates by reference the accompanying Revised Forest Plan (2002). The Forest Plan guides all

natural resource management activities and establishes management standards and guidelines for the

Forest. It describes management areas, resource management practices, and the availability and suitability

of lands for resource management. The proposed action aligns with goals, objectives, and strategies from

the 2002 White River National Forest Land and Resource Management Plan (Forest Plan, pages 1-31-

11) specifically:

Goal 1: Promote ecosystem health and conservation using a collaborative approach to sustain the

nation’s forests, grasslands, and watersheds.

Objective 1a – Improve and protect watershed conditions to provide the water quality and

quantity and soil productivity necessary to support ecological functions and intended beneficial

uses.

Objective 1d – Increase the amount of forest and rangelands restored to or maintained in a

healthy condition with reduced risk and damage from fires, insects, disease and invasive species.

Objective 1e – Work cooperatively with individuals, organizations, local, state, tribal and other

federal agencies to promote ecosystem health and sustainability across landscapes.

Goal 2: Provide a variety of uses, products, and services for present and future generations by

managing within the capability of sustainable ecosystems.

Objectives 2c – Improve the capability of national forests and rangelands to sustain desired uses,

values, products, and services.

The management area direction was used to further develop the project purpose and need and proposed

action. The entire Vail Intermountain Fuels Project is located in Forest Plan Management Area 7.1–

Intermix. The theme for this management area states: “ Areas characterized by an interface between

National Forest System lands and other public and private lands are managed to protect natural resources,

provide compatible multiple uses, and maintain cooperative relationships between private landowners and

other governments with jurisdiction” (Forest Plan, page 3-74). The management actions are geared

toward influencing the vegetation composition and structure to promote visual screening and to minimize

hazardous fuel loading patterns (Forest Plan, page 3-74).

The entire project area is within the Game Creek Roadless Area and not part of the suitable timber base as

defined by the Forest Plan. This project was developed to meet the requirements of the Colorado

Roadless Rule (36 CFR 294). Since the Game Creek Roadless Area is a “non-upper tier,”

§294.42(c)(1)(ii) applies to this project. This section of the Colorado Roadless Rule states:

(a) General. Trees may not be cut, sold, or removed in Colorado Roadless Areas, except as provided

in paragraph (b) and (c) of this section.

(c) Non-Upper Tier Acres. Notwithstanding the prohibition in paragraph (a) of this section, trees may

be cut, sold, or removed in Colorado Roadless Areas outside upper-tier acres if the responsible

official, unless otherwise noted, determines the activity is consistent with the applicable land

management plan, one or more of the roadless area characteristics will be maintained or improved


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over the long-term with the exception of paragraph (5) and (6) of this section, and one of the

following circumstances exists:

(1) The regional forester determines if tree cutting, sale, or removal is needed to reduce

hazardous fuels to an at-risk community or municipal water supply system that is:

(i) Within the first one-half mile of the community protection zone, or

(ii) Within the next one-mile of the community protection zone, and is within an area

identified in a community wildfire protection plan.

(iii) Projects undertaken pursuant to paragraphs (c)(1)(i) and (ii) of this section will focus

on cutting and removing generally small-diameter trees to create fuel conditions that

modify fire behavior while retaining large trees to the maximum extent practical as

appropriate to the forest type.

Further, this environmental analysis analyzed the nine roadless area characteristics set forth in 36 CFR

294, Subpart B (§294.11). Roadless area characteristics are defined as: “Resources or features that are

often present in and characterize inventoried roadless areas, including: (1) High quality or undisturbed

soil, water, and air; (2) sources of public drinking water; (3) diversity of plant and animal communities;

(4) habitat for threatened, endangered, proposed, candidate, and sensitive species and for those species

dependent on large, undisturbed areas of land; (5) primitive, semi-primitive non-motorized, and semi-

primitive motorized classes of dispersed recreation; (6) reference landscapes; (7) natural appearing

landscapes with high scenic quality; (8) traditional cultural properties and sacred sites; and (9) other

locally identified unique characteristics.”

This project is being prepared under the Health Forest Restoration Act (HFRA) authorities with an

emphasis on reducing hazardous fuels and implementing forest health treatments in the Vail

Intermountain area west of the Town of Vail. HFRA projects may be applied to Federal land in the

wildland-urban interface to protect at-risk communities from the risk of wildfire. A wildland-urban

interface is defined as: “an area within or adjacent to an at-risk community that is identified in

recommendations to the Secretary in a community wildfire protection plan” [HR 1904, section

101.16(A)]. This project lies within an identified wildland-urban interface, as outlined in the Eagle

County Community Wildfire Protection Plan. Additionally, Vail is identified as an at-risk community in

the Federal Register (Volume 66, No. 160, 8/17/2001). As such, this project meets the authorized

projects described in HFRA, category 1 [HR 1904, section 102(a)(1)].

The project is designed to conform to the Forest Plan and all other laws, regulations, and policies,

including the Colorado Roadless Rule and HFRA. Forest Plan standards and guidelines are applied as

appropriate to meet Forest Plan goals and desired conditions.

Nature of the Decision to be Made The need for the proposal outlined earlier sets the scope of the project and analysis to be completed.

Based on the analysis, the Eagle-Holy Cross District Ranger will determine whether the proposed project

and alternatives could result in a significant impact. If there is a finding of no significant impact, the

responsible official will review the environmental analysis of the proposed action, other alternatives, and

any public comments, in order to make the following decisions:

1. Whether the proposed action will proceed as proposed, as modified by an alternative, or not at all.

2. If it proceeds:

a. Whether to prepare an environmental impact statement;


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b. What design features/mitigation measures and monitoring requirements should be applied to

the proposed action; and

c. Whether the project requires a Forest Plan amendment.

Public Involvement

Collaboration

This project lies within an identified wildland-urban interface, as outlined in the Eagle County

Community Wildfire Protection Plan (CWPP). The CWPP was created in 2005, amended in 2010, and

revised in 2011. This CWPP and the amendment and revision were prepared collaboratively by

individuals and agencies within Eagle County, as described on pages 5 and 6 of the CWPP.

In addition, the Eagle-Holy Cross Ranger District initiated a collaborative group made up of individuals

and agencies to identify treatments and develop a proposed action within the Intermountain area. The

following collaborative efforts were undertaken on this project:

Winter 2014 – District Ranger David Neely was approached by Town of Vail on the possibility of

implementing forest health and fuels reduction treatments in West Vail, Vail Intermountain Area

on National Forest System lands, south of I-70.

Spring 2014 – District Ranger and Forest Service staff met with Vail Fire Chief to discuss

potential project planning, purpose and need, and relation to Town of Vail.

September 16, 2014 – Forest Service staff and Vail Town Council members looked at timber

harvest and fuels reduction treatments in progress or completed around the Town of Vail since

2006.

September to December 2014 – Forest Service staff met and coordinated with Vail Wildfire

Mitigation Specialist to discuss project proposal and seek input.

February 25, 2015 – Forest Service staff made a presentation with a call for public input at the

Colorado Rural Water Association source water protection planning meeting for the Town of

Gypsum. There was no public input for the Vail Intermountain Fuels Project at this meeting.

March 26, 2015 – Forest Service staff hosted a collaboration open house. Members of State,

Federal, and local governments were invited to attend. A press release was issued for individual

public citizens to attend. Seven people attended the open house including representatives from

the following: Vail Fire Department, Eagle County Wildfire Program, Vail Resorts, Eagle River

Water Sanitation District, Eagle River Watershed Council, Colorado Parks and Wildlife, and an

interested citizen.

April 30, 2015 – Forest Service staff presented the Vail Intermountain Fuels Project to the Eagle

County Wildfire Council. Approximately 15 members of the local fire departments attended this

meeting.

June 22, 2015 – A public scoping meeting was held at the West Vail Fire Department held to

provide the public information regarding project. A handful of citizens showed up, mostly in

support of the project.

July 6, 2015 – The public scoping comment period ended.

July 30 – Cary Green (White River National Forest), Paul Cada (Town of Vail Fire Department),

Bill Andree (Colorado Parks and Wildlife), Ryan McNertney and Matt Schiltz (Colorado State

Forest Service) met at the Holy Cross Ranger District Office to discuss logistics and feasibility of


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using Colorado Parks and Wildlife-managed lands for a helicopter landing area. Bill Andree

indicated Colorado Parks and Wildlife supports the project and use of the helicopter landing area.

Paul Cada and Ryan McNertney indicated the Vail Fire Department and Colorado State Forest

Service would coordinate with private landowners for some additional acres adjacent to the

project area to use during implementation.

August 17-19, 2015 – The White River National Forest requested a utility line locate for the

access road to unit 1 in the project area. Utilities located under this access road include two gas

lines (4- and 12-inch) 3- to 4-feet deep, and two water lines (7- to 9-feet deep). One water line

ends at the hydrant on north side of access road.

September 15, 2015 – David Neely and Cary Green (White River National Forest), Paul Cada

(Town of Vail Fire Department), Mark Novak (Town of Vail Fire Chief), Andy Daly (Town of

Vail Mayor), and Stan Zemler (Town of Vail Manager) met to discuss the current status of the

project and implementation costs. The group discussed helicopter yarding compared to hand

treatments, and a possible blend of using both during implementation. The Town of Vail

requested a one-page summary document to present to Town Council on October 20, 2015. The

Town Council would approve project funding for implementation because it is within their budget

authority.

October 20, 2015 – David Neely and Cary Green (White River National Forest), Paul Cada

(Town of Vail Fire Department), and Mark Novak (Town of Vail Fire Chief) attended a Vail Town

Council Meeting. Paul Cada presented the status of the project, and the Council was provided a

one-page summary document of the estimated project costs and timeframes. The Town Council

asked questions related to timing, treatment types (helicopter versus hand treatments), costs, and

potential for Town of Vail funding. The Town of Vail is interested in blended treatment options

(helicopter and hand treatments) to reduce the overall cost of project implementation. Funding

proposals would need to be submitted for Town of Vail Council review and approval after January

1, 2016.

Scoping

This project was listed in the White River National Forest quarterly schedule of proposed actions

beginning in October 2014. In June 2015, a letter providing information and seeking public comment

was emailed to 36 individuals and groups. This included local and State agencies, local Tribes municipal

offices, businesses, interest groups, watershed councils, and individuals. Comments were received from

representatives of Colorado Parks and Wildlife, Eagle River Water and Sanitation District, Town of Vail,

Vail Mountain, and five individuals.

As required by HFRA, a public meeting was held on June 22, 2015, at the West Vail Fire Station in Vail,

Colorado. The meeting was announced in The Vail Daily as part of a legal notice of the public meeting.

Representatives from Vail Fire and Emergency Services, Eagle River Water and Sanitation District, and

interested citizens attended the meeting.

Issues

An issue is an effect caused by some element of the proposed action, or an alternative, around which there

is disagreement or concern. The Forest Service considered information gathered from comments to

identify any potential issues to be addressed in the environmental analysis. Issues may be addressed

through modification of the proposed action, design features, or mitigation measures.

The Forest Service identified issues as those directly or indirectly caused by implementing the proposed

action. Non-significant issues were identified as those (1) outside the scope of the proposed action; (2)


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already decided by law, regulation, forest plan, or other higher level decision; (3) irrelevant to the

decision to be made; or (4) conjectural and not supported by scientific or factual evidence. The Council

on Environmental Quality NEPA regulations explain this delineation in section 1501.7, “…identify and

eliminate from detailed study the issues which are not significant or which have been covered by prior

environmental review (section 1506.3)…”

The Forest Service identified 16 issues from scoping efforts: Issues 1, 2, 3, 5, 6, 7, and 8 are discussed in

the analysis and are addressed by implementing project design features, and Issues 4 and 9 through 16 are

addressed through project design features. The Forest Service did not identify any issues that drove an

additional alternative. All design features are included in the analysis in section 2, “Proposed Action and

Alternatives.”

Issue 1: Project Conflicts with Recreation Opportunities

Project implementation in the Town of Vail, on Vail Mountain, or the Vail Ski Area could conflict with

recreation opportunities, especially on weekends. The project should have the flexibility to work around

events held in the town and on Vail Mountain. All work, including hauling within the Town of Vail

boundaries, should conform to Town of Vail work hours and trucking restrictions, which would mitigate

this concern.

Implementation of design features would mitigate this issue. Also, design features can be modified to

provide for more flexibility to work around events held in the Town of Vail and on Vail Mountain.

Having this type of flexibility can shorten the length of project implementation as well as reduce costs

associated with more narrowly defined implementation timeframes.

Issue 2: Log Truck Traffic

Log truck traffic associated with this project could impact the community. The proposed haul routes for

this project are within the Town of Vail and have pedestrian traffic. It will be essential to have a traffic

management plan, including managing truck speed to safely implement this project.

Contractors and contract operations are required to conform to Town of Vail work hours, traffic

regulations, and trucking restrictions. The project would be phased to minimize the impacts to the

shortest amount of time possible for any one area. All Forest Service contracts require a safety plan that

includes travel routes, timing (times per day and total duration), and traffic control for truck turning,

backing, and sharp curves prior to operations beginning.

Issue 3: Roadless Area Characteristics

The proposed project could degrade some of roadless area characteristics, such as soils and scenic

quality, and the area could no longer serve as a reference landscape.

The current landscape is not undisturbed and is comprised of dense forests susceptible to insect and

wildfire mortality. A mountain pine beetle epidemic has killed approximately 36 to 59 percent of the

lodgepole pine within the project area. Forest regeneration and “greenup” would occur shortly after

treatment and improve the visual appearance of this landscape by resembling an increasingly healthy

forest. Various design features related to roadless area characteristics would be implemented during this

project; these can be found under “Project Design Features” in section 2.

Issue 4: Patch Cut Openings

To balance goals related to vegetation composition and structure for visual screening and minimizing

hazardous fuel loading patterns, openings should be kept to less than 1 acre.


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As mortality rates in lodgepole pine are estimated to be between 36 and 59 percent, it is unlikely that

openings less than 1 acre in size would sufficiently meet the purpose and need of reducing the current and

future wildfire hazard to and from adjacent communities by managing existing hazardous fuels on Federal

lands. Patch cut openings would not exceed 10 acres in size and may only affect up to 50 percent of the

treatment area. Various design features related to visual screening would be implemented during this

project; these can be found under “Project Design Features” in section 2.

Issue 5: Landslide Risk

The project is located on steep terrain that could be at risk of landslides, and removal of vegetation could

cause mass slope failure. The project should be implemented in a way that would not destabilize the

slopes while still reducing the fire hazard.

Landslide risk has been considered in the proposed action, and is evaluated as part of the project soils and

hydrology analyses. Various design features related to slope and soil stability would be implemented

during this project; these can be found under “Project Design Features” in section 2.

Issue 6: Helicopter Noise

The use of helicopters in this project may stress local wildlife and cause disturbance to local residents

because of the high noise levels helicopters create.

A helicopter yarding analysis, with a focus on noise, is included in the “Operations and Safety” section of

section 3. A design feature to close the area and flight path to public use during helicopter yarding

operations is included in the project design for public safety.

Issue 7: Project Cost

The use of helicopters will increase the cost of this project. If helicopters are not used, hand felling would

be labor intensive and could also create a high cost to implement.

Costs of project implementation are disclosed in section 3 of this environmental assessment.

Implementation of the project would be funded by the Town of Vail in partnership with the Forest

Service.

Issue 8: Project Safety

Public safety should be taken into consideration, particularly for the helicopter logging operations.

All Forest Service contracts require a safety plan that includes travel routes, timing (times per day and

total duration), and traffic control for truck turning, backing, and sharp curves, prior to operations

beginning. Also, contractors and contract operations are required to conform to Town of Vail work hours

and trucking restrictions.

A thorough safety plan would also be put in place during helicopter yarding operations. All flight paths

would avoid infrastructure, utilities, roadways, and improvements. A design feature to close the area and

flight path to public use during helicopter yarding operations is included in the project design for public

safety.

Issue 9: Smoke

Burning piles would generate smoke which could be harmful to Vail Valley residents, including adjacent

landowners and their guests.

Pile burning would be conducted using well established smoke management procedures in conjunction

with the Colorado Air Pollution Control Division. Pile-burning operations in the Vail area have been


10

conducted in the past with minimal complaints from residents. Pile footprints would be rehabilitated

post-burn as needed.

All broadcast burning has been dropped from the proposed action based on the analysis conducted by the

interdisciplinary team. This will reduce the overall smoke resulting from this project.

Issue 10: Burn Piles Sterilizing Soils

When large burn piles composed of large diameter material are burned, the soil under them could be

sterilized.

There would be minor and localized soil impact associated with burning piles. This impact is considered

in the soils analysis in section 3.

Issue 11: Noxious Weeds

Ground disturbance associated with the project could provide for the introduction and spread of noxious

weeds.

Project design features are incorporated to address potential noxious weed populations. Although

eradication of a population is not necessarily achievable within a reasonable time before project activities

would begin, pre-treatment would be accomplished, followed by monitoring and additional post-project

control treatments. In addition, measures would be taken to prevent introduction of noxious weeds, such

as requiring equipment to be thoroughly washed before performing the work.

Issue 12: Aspen Regeneration

Instead of clearcutting aspen, conifers could instead be removed to delay the conversion of the stand from

aspen to conifer. Some of the trees could be left to fall naturally and decay into new soil and reduce soil

erosion, or be left as snags for cavity-nesting animals.

It is not desirable to remove conifers from within aspen stands because residual aspen trees would be

damaged by felling or yarding activities. These damaged trees are more likely to become infected with

disease and die. Aspen will likely regenerate where mature aspen currently exists (Shepperd 1986). An

analysis of the project effects to vegetation, including aspen regeneration, is found in section 3,

“Environmental Impacts of the Proposed Action and Alternatives.”

Issue 13: Large Buffer Zones

The proposed silvicultural prescriptions to remove dead trees within 400 feet of private lands to create

defensible spaces around private property seem like a wide area.

The distance recommendations for hazardous fuels thinning included in the proposed action can be found

in “Canopy Fuel Treatment Standards for the Wildland-Urban Interface” (Scott 2003) and is intended as a

fire-behavior-mitigation element for firefighters as well as structures.

Issue 14: Wildlife Timing Restrictions

Timing restrictions on operations from October 16 through June 30 to reduce wildlife impacts in winter

range and corridor should to be included in the project.

The White River Forest Plan includes a General Wildlife Standard #1 (Forest Plan, page 2-16) for

seasonal restrictions to reduce disturbance in key wildlife habitats. The timing restrictions proposed by

Colorado Parks and Wildlife would be included as a design feature and used during project

implementation.

Issue 15: Colorado Parks and Wildlife Department Lands


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Utilizing the Colorado Parks and Wildlife Department’s Vail Deer Underpass State Wildlife Area property

as a helicopter yarding location would require Colorado Parks and Wildlife Department approval and

additional discussions on what steps would be taken to fully protect/enhance the wildlife values in this

area.

The Forest Service will collaborate with Colorado Parks and Wildlife on the potential use of the Vail Deer

Underpass State Wildlife Area for a helicopter yarding location. Design features, such as signage and

barriers, would be included to help prevent winter recreation use and allow for citations to be issued to

offenders. These design features would reduce adverse mule deer impacts until the aspen regenerates in

the cleared areas.

Issue 16: Impacts to Deer and Elk

The project treatments could lead to additional recreation use of the Intermountain area, disturbing the

effectiveness of the staging area for the mule deer migration corridor and elk winter range.

The Forest Service will collaborate with Colorado Parks and Wildlife on the potential use of the Vail Deer

Underpass State Wildlife Area for helicopter yarding location. Design features, such as signage and

barriers, would be included to help prevent winter recreation use and allow for citations to be issued to

offenders. These design features would reduce adverse mule deer impacts until the aspen regenerates in

the cleared areas.

Section 2: Proposed Action and Alternatives This section describes the alternatives and how they were formulated for the Vail Intermountain Fuels

Project. This section is the heart of the document and provides readers and the responsible officials with

a description of the project, displaying the alternatives, design features, and a comparison of effects of the

alternatives. This provides a clear basis for choice among options by the line officer.

No-Action Alternative The effects of not taking action will also be analyzed as required by Council on Environmental Quality

regulations (40 CFR 1502.14(d)). Under the no-action alternative, the proposed action, including

treatment of approximately 319 acres of forested lands, would not occur, and current management would

continue in the project area. Figure 2 shows the treatments that have already been implemented in the

area. This alternative would not implement any new treatments or actions described in the proposed

action.

The no-action alternative would not fulfill the purpose and need for action and represents a continuation

of the existing conditions and management. The fuel hazard would not be reduced. Dead or dying trees

would not be removed and would contribute to the current and future fuel hazard. Natural fuels (downed

wood and other dead vegetation) would not be removed and would continue to accumulate. Natural

processes of decay are not likely to remove the down and dead woody debris before the next fire cycle.

As the available fuel increases, so would the potential for a large stand-replacing wildfire


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Figure 2. Intermountain area completed treatments and no-action alternative


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Proposed Action Approximately 194 acres of hazardous fuels treatments would be implemented within 319 acres

encompassing five treatment units. The entire project area consists of 1,291 acres and is within the Game

Creek Roadless area. There are a couple of minor changes in project acres from those included in the

notice of proposed action sent out on June 5, 2015. During project analysis minor mapping errors were

corrected including: the proposed treatments units’ acreage was adjusted from 316 to 319 acres and the

original project boundary was adjusted from 1,391 acres to 1,291 acres. The proposed treatment acres

within the units remain the same at 194 acres.

Vegetation treatments would occur within the wildland-urban interface adjacent to the Town of Vail (an

at-risk community). Treatments would be designed to mitigate existing and future heavy fuels

accumulations, enhance aspen regeneration, reduce existing surface fuels, and create canopy breaks and

crown separation to minimize crowning potential in the event of a wildfire. Where treatments occur,

areas would be managed for low regeneration stocking levels to delay crown closure and prolong the life

of the hazardous fuels treatment. The proposed action would reduce and maintain surface-fuel loading at

5 to 15 tons per acre within treatment areas.

Helicopter yarding would be utilized for vegetation treatments involving whole-tree removal from

treatment units. Helicopter yarding is defined as a logging method that uses a helicopter to bring logs or

trees from a forest area to a landing area where they can be loaded onto trucks. Trees would be flown to

landing locations on State, Federal, and/or private land where they would be processed and loaded onto

logging trucks for delivery to local forest product markets. These landing areas would be located on

Colorado Parks and Wildlife property near treatment unit 1, Donovan Park near treatment unit 5, and on

National Forest System lands within the Vail Ski Area boundary. Where helicopter yarding is not used,

hand treatments would be used to complete the project. Hand treatments would involve felling, limbing,

and bucking trees. This material would be piled for later burning during the fall/winter seasons.

Landing locations on private lands would be dependent upon agreements made with private landowners

for use associated with the proposed action. Non-Forest System roads necessary for log hauling and

access include; Basingdale Boulevard, Kinnickinnick Road, South Frontage Road, Upper Matterhorn

Circle, Geneva Drive, Matterhorn Circle, Mill Creek Road, and Vail Road. No temporary road

construction would be needed to access treatment units on National Forest System lands.

A variety of silvicultural prescriptions would be used in combination within treatment units including:

Patch clearcut (<10 acres in size) of lodgepole pine stands. Within this prescription, up to 50

percent of the area may be treated. Patch clearcut is defined as a type of stand clearcutting where

patches (or strips) are clearcut within an individual stand boundary in two or more entries to

produce an even-aged stand. The range of tree ages is usually less than 20 percent of the rotation

after harvest of all patches.

Individual tree selection (dead only) and/or group selection (groups <2 acres in size) of

lodgepole pine. Within this prescription, up to 50 percent of the area may be treated, with no

more than 30 percent of the area treated with group removals.

o Individual tree selection is defined as an uneven-aged regeneration method where individual trees of all size classes are removed more or less uniformly throughout the stand, creating or maintaining a multiage structure to promote growth of remaining trees and to provide space for regeneration. Multiple entries of this activity ultimately results in an uneven-aged stand of three or more age classes.


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o Group selection is defined as an uneven-aged regeneration method in which trees are cut in

small groups and new age classes are established. The width of groups is commonly less than

approximately twice the height of the mature trees. Individual trees in the matrix may or may

not be harvested to provide improved growing conditions for remaining trees. Multiple

entries of this activity ultimately results in an uneven-aged stand of three or more age classes.

Coppice cut (<10 acres in size) of aspen stands. Coppice cut is a regeneration method in which

all trees in the previous stand are cut and the majority of the regeneration is from sprouts or root

suckers.

Individual tree selection (dead only) in aspen stands. This harvest method includes removing

dead trees to create conditions favorable for the establishment or release of more shade-tolerant,

advance regeneration.

Table 1. Proposed action activities by silvicultural prescription

Silvicultural Prescription1 Cover Type Acres

Treatment Area Threshold

Threshold Acres

Patch clearcut <10 acres Lodgepole pine 129 Up to 50 percent 65

Individual tree selection (dead only); group selection <2 acres

Lodgepole pine 118 Up to 50 percent overall, no more than 30 percent in group removal

59

(35 acres in group removal)

Coppice cut <10 acres Aspen 10 None 8

Individual tree selection (dead only) Aspen 62 None 62

Totals 319 194 1 A silvicultural prescription is a document written or approved by a certified silviculturist that describes management activities

needed to implement a silvicultural treatment or sequence of treatments.

These silvicultural prescriptions would focus on:

Hazardous fuels reduction: Concentrate on removal of live and dead trees where lodgepole pine

mortality is 35 percent or more; and/or removal of dead trees within 400 feet of private lands.

Aspen enhancement: Expand aspen stands by removing live and dead conifer in and around aspen

stands, and removing aspen to promote regeneration.

Table 2. Silvicultural prescriptions by treatment units (acres)

Treatment Unit

Total Unit Acres

Individual Tree

Selection (Dead Only)

Acres Coppice Cut

<10 Acres

Patch Clearcut <10

Acres

Individual Tree

Selection (Dead Only),

Group Selection <2

acres Treatment

Acres

1 108 22 7 16 23 68

2 26 0 0 13 0 13

3 95 2 1 26 20 49

4 68 38 0 0 15 53

5 22 0 0 10 1 11

Totals 319 62 8 65 59 194


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Figure 3. Vail Intermountain proposed treatment unit map


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Associated activities would include road maintenance on National Forest System roads. In conjunction

there may also be temporary road use (construction, use, and closure/obliteration) on private roads not

managed by the Forest Service. Vegetation management activities could begin as early as 2016 and be

complete within 5 to 10 years. This project may be implemented using timber sale contracts, stewardship

contracts, agreements, and/or service contracts. Multiple years of vegetation management would likely

occur over the life of the project. Other associated activities such as monitoring (regeneration and fuels

surveys) would be completed by 2025.

Project Design Features The following design features are an integral part of this project and would be carried out if the project is

implemented under the proposed action. In most cases, the effects analysis in section 3 is based on these

design features being implemented. Design features are site-specific elements developed to further define

and guide the proposed action. The following include design features developed for this proposal through

the collaboration process and from the specialist reports.

Silviculture

SI-1. Normal operating season for logging and associated activities would be June 30 through October 16, annually. Providing all design features and contract clauses are being followed, operations may occur outside the normal operating season except when explicitly restricted by other resources such as wildlife or outfitter/guide permittees.

SI-2. During layout, create treatment unit boundaries with irregular edges that utilize existing vegetation or terrain features as natural boundaries.

SI-3. Where feasible avoid unnecessary damage to residual trees.

SI-4. If needed during implementation, the Forest Service would approve or designate skid trails, landings, and temporary road locations outside of the Game Creek Roadless area prior to the start of harvesting activities.

SI-5. Detailed silviculture prescriptions would be prepared for cutting units prior to harvesting.

SI-6. Conduct first-year, third-year, and fifth-year stocking surveys in all patch clearcut, group selection openings, and coppice cut treatment units to monitor natural regeneration.

SI-7. Where feasible, patch clearcut and group selection units would be located in areas that contain predominately dead trees. Favor areas that are adjacent to existing stands of aspen as well as those that are likely to minimize windthrow risk along treatment boundaries.

SI-8. Retain or improve aspen, where possible, to provide a visual screen for treatment units.

Hydrology

HY-1. (Water Conservation Practices Measure #2) Manage land treatments to maintain enough organic

ground cover in each activity area to prevent harmful increased runoff. This is a fundamental

function that precedes all other considerations in the hydrologic hill-slope process.

HY-2. (Water Conservation Practices Measure #3) In the water influence zone next to perennial and

intermittent streams, lakes, and wetlands, allow only those actions that maintain or improve long-

term stream health and riparian ecosystem condition. Default width of buffer for the water

influence zone is 100 feet (horizontal measured) from banks of the channel, or the mean height of

late-seral tree species which may be greater. In the case of this project the approximate centerline

of the draw bottom will serve in regard to delineating bank slope length. Given that side slopes

are generally 60 percent or over, slope distance for a 60 percent gradient equating to horizontal

distance of 100 feet is about 111 feet.


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HY-3. No patch cut will be done on slopes in excess of 60 percent gradient.

Scenery

SC-1. Where possible, aspen would be retained or improved to provide a visual screen for treatment

units.

SC-2. The scenic contrast of timber treatment stands on the landscape, particularly in middle to

background distance zones as viewed from sensitive viewpoints, would be reduced by creating

irregular or indistinct edges. Openings in the canopy should have a natural appearance with

uneven edges. The shapes should be an irregular pattern that mimics existing natural openings

and should avoid straight-line edges.

SC-3. Equipment and construction debris or trash would be removed from the site at sale completion.

SC-4. Where cutting units are adjacent to system recreational trails, within 15 feet on either side of a

trail, stumps would be cut flush (3 inches) for recreation safety. Root wads created by the harvest

activities that are visible in the foreground of a system trail shall be buried or otherwise removed

from sight.

SC-5. When the project is complete, no tree paint shall be visible from open roads adjacent to the

project area or on system trails in or adjacent to the project. Unit boundary paint shall either face

away from the roads or system trails, or be removed or “blacked out” after the sale is complete.

SC-6. Scattered slash and logging debris should be limbed and scattered over disturbed areas to a

maximum depth of 24 inches. After completion of pile burning, any unburned debris and stumps

should be scattered back into harvest units to create visual diversity.

SC-7. Inform visitors about the work in the area and encourage them to use other areas around Vail

during project implementation.

Botany

BO-1. Any locations where threatened, endangered, or sensitive plant species are found would be

identified on the ground and buffered from management actions that would directly or indirectly

negatively impact population viability. The protection buffers would extend a minimum of 100

feet away from the identified population boundaries.

BO-2. These buffers would also include: hand operations; felling trees away from identified buffered

populations; unless identified as a fuel hazard, trees felled in these areas would be left on site; and

do not place or burn slash piles or broadcast burn slash in buffered areas.

BO-3. Where re-vegetation is needed, native species would be used, where feasible, preferably collected

from local genetic stock or seed available from local Forests’ native plant materials programs.

BO-4. Where seeding is appropriate (see “Evaluating Need for Treatment,” Botany Report) the

following seed prescription is recommended for upland habitats: Mountain District Broad

Spectrum Upland Mix. This mix is suggested for the following sites: disturbed ground in aspen or

coniferous cover types, mesic to dry mountain meadows, and sagebrush or mixed mountain shrub

sites with at least moderately deep soils; and foothill, montane, and subalpine zones. See the

Botany Report for suggested seeding rate.

BO-5. Evaluating need for treatment and selecting type of reseeding treatment and re-vegetation

specifications can be found in the Botany Report.


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Weeds

The following project design features would be implemented to prevent or minimize the spread of weed

species.

WE-1. Before activities begin, treat weed infestations within proposed units and along haul routes.

(Source: “USDA Forest Service Guide to Noxious Weed Prevention Practices” [USDA Forest

Service 2001]).

WE-2. Monitor and treat weed infestations and disturbed areas annually for 5 years after project

completion. (Sources: “USDA Forest Service Guide to Noxious Weed Prevention Practices”

[USDA Forest Service 2001]; “White River National Forest Weed Program Standard Operating

Procedures” [USDA Forest Service 2007).

WE-3. Equipment shall not be moved into project area without having first taken reasonable measures to

make sure it is free of soil, seeds, vegetative matter, or other debris that could contain noxious

weed seeds. Reasonable measures include pressure-washing or steam-cleaning in an offsite

location so oil, grease, soil, and plant debris can be contained and provide optimal protection of

project areas.

Operations and Safety

OS-1. Log truck traffic: For public safety, a traffic control and safety plan adhering to Federal, State,

and local regulations shall be in place prior to start-up of operations.

OS-2. Helicopter noise: To minimize noise disturbance to the community, helicopter yarding operations

are restricted on Saturdays and Sundays.

OS-3. Project safety: For public safety during helicopter operations, treatment units and flight paths

shall be closed to the public using a special closure order.

OS-4. Modify helicopter flight paths to fly over the least area of the Colorado Roadless Area as

possible.

OS-5. Require all contractors and contract operations to conform to Town of Vail work hours, traffic

regulations, and trucking restrictions.

OS-6. Require all contractors and contract operations to complete a safety plan that includes travel

routes, timing (times per day and total duration), and traffic control for truck turning, backing,

and sharp curves prior to operations beginning.

Cultural and Heritage

CH-1. The National Historic Preservation Act (NHPA) requires if newly discovered cultural resources

are identified during project implementation, work in that area must stop and the responsible

agency authorized officer notified immediately (36 CFR 800.13).

CH-2. The Native American Graves Protection and Repatriation Act (NAGPRA) requires that if

inadvertent discovery of Native American remains or objects occurs, activity must cease in the

area of discovery, a reasonable effort made to protect the item(s) discovered, and immediate

notice made to the authorized officer, as well as the appropriate Native American group(s)

(IV.C.2). Notice may be followed by a 30-day delay (NAGPRA, section 3(d)). Further actions

also require compliance under the provisions of NHPA and the Archaeological Resource

Protection Act.


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Soils

SO-1. Restore the organic ground cover of degraded activity areas using soil organic amendments (i.e.,

native topsoil, composted wood-chip blends, biochar, biosol) when possible.

SO-2. Manage land treatments to maintain enough organic ground cover in each activity area to prevent

harmful increased runoff.

Wildlife

WI-1. To minimize disturbance within the deer migration corridor and within elk winter range, include

timing restrictions on operations from October 16 through June 30 to reduce wildlife impacts in

winter range and corridor. Colorado Parks and Wildlife would be consulted for permission to burn

piles during this time period.

WI-2. Maintain a minimum of the following types of snags and downed logs for each affected cover

type. The amounts are to be calculated as per-acre-averages for each 1,000 acres over a

silvicultural landscape assessment area.

Spruce-fir: Retention density = three snags per acre (greater than 10 inches d.b.h. and greater than

25 feet tall), one snag per 5 acres (greater than 20 inches d.b.h. and greater than 50 feet tall) and

150 linear feet per acre downed logs (greater than or equal to 10 inches diameter).

Lodgepole pine: Retention density = three snags per acre (greater than 8 inches d.b.h. and greater

than 25 feet tall), one snag per 5 acres (greater than 20 inches d.b.h. and greater than 50 feet tall)

and 100 linear feet per acre downed logs (greater than or equal to 8 inches diameter).

Aspen: Retention density = three snags per acre (greater than 10 inches d.b.h. and greater than 25

feet tall), one snag per 5 acres (greater than 20 inches d.b.h. and greater than 50 feet tall) and 50

linear feet per acre downed logs (greater than or equal to 8 inches diameter).

WI-3. If no snags meet the minimum diameter and height requirements, use the largest snags available.

WI-4. Protect known active and inactive raptor nest areas. The extent of the protection would be based

on proposed management activities, human activities existing before nest establishment, species,

topography, vegetation cover, and other factors. A no-disturbance buffer around active nest sites

would be required from nest-site selection to fledging (generally March through July). Exceptions

may occur when individuals are adapted to human activity.

WI-5 Colorado Parks and Wildlife species-specific buffers and limited operating periods:

Northern goshawk: Up to 0.5-mile radius around active nests, March 15 to August 15; field

surveys conducted in the spring of 2016 would determine exact buffer size.

Red-tailed hawk: 0.33-mile radius around active nests, February 15 to July 15.

Cooper’s hawk: 0.33-mile radius around active nests March 15 to July 15.

WI-6 Retain all snags and trees known to be used consistently as bat roosts.

Fuels

FU-1. Mechanical activity slash generated during processing and loading of logs on landings would be

machine piled and burned, or removed from the landing area.

FU-2. Hand piling of natural fuels and mechanical-activity-generated fuels may occur in units to reduce

fuel loading levels.


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FU-3. Reduce fuel loading of course woody debris to approximately 5 to 10 tons per acre within 400

feet of private lands. Reduce fuel loading of course woody debris to 10 to 15 tons per acre

throughout the rest of the project area.

FU-4. All pile burning would take place under the guidelines set forth in a prescribed fire burn plan

developed specifically for this project area. Prescribed burn plans address parameters for weather,

air quality, and contingency resources.

FU-5. A project-specific smoke management plan would be developed and all burning pre-approved

through the Colorado Air Pollution Control Division. Smoke permits usually specify the number

of acres per day or piles per day that can be burned, and acceptable wind directions.

Recreation

RE-1. To minimize conflicts with recreational events and users specifically on Vail Mountain Special

Use Permit area, prohibit helicopter yarding, log hauling, and associated activities at the landing

area on weekends and holidays.

RE-2. To minimize conflicts with recreationists during project implementation, relocate the Upper

Simba ski area exit point that provides skier access into the project area from Vail Mountain

Special Use Permit.

RE-3. Prohibit use of the unauthorized Matterhorn Trail during project implementation to minimize

conflicts with recreationists.

RE-4. Limit helicopter yarding to the typical summer operating season from June 30 through October

16. No helicopter yarding or log hauling should occur during the winter operating season of Vail

Mountain.

Monitoring Requirements

Weeds

Monitor and treat weed infestations and disturbed areas annually for 5 years after project

completion. (Sources: “USDA Forest Service Guide to Noxious Weed Prevention Practices”

[USDA Forest Service 2001]); “White River National Forest Weed Program Standard Operating

Procedures” [USDA Forest Service 2007]).

Monitor for windthrow and noxious weeds while conducting first-year, third-year, and fifth-year

stocking surveys. If windthrow or noxious weeds are observed, treatments would be developed

based on the extent and species present.

Soils

Site inspections would inventory erosion features such as rills, gullies, and scarps to ensure

compliance with existing policy and regulations. Monitoring of effects on soils, such as

detrimental disturbance and organic matter retention amounts, should be done immediately post-

project, and 1 year after project implementation. Monitoring would follow protocols very similar

to those set forth in the “Forest Soil Disturbance Monitoring Protocol Handbook” (Page-

Dumroese et al. 2009). Depth of organic matter, visual and/or quantitative measurements of soil

compaction, and sedimentation controls should be tracked through monitoring and field visits by

forest resource specialists including the staff soil scientist.


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Silvicultural

The Forest Service would monitor stocking in patch clearcuts in the first, third, and fifth years

following harvest activities.

The Forest Service would monitor stocking in group selection openings in the first, third, and

fifth years following harvest activities.

Fuels

The Forest Service would monitor surface fuel loading following harvest activities.

Alternatives Considered but Eliminated from Detailed Study HFRA requires that only the proposed action be analyzed, with one exception. If the community has

adopted a community wildfire protection plan and the proposed action does not implement the

recommendations in the plan regarding the general location and basic method of treatments, the agency is

required to analyze the recommendations in the plan as an alternative to the proposed action (HFRA

104(d)(2) and (3)). The proposed action is consistent with recommendations in the 2011 Eagle County

Community Wildfire Protection Plan; therefore, no other alternatives were considered or analyzed.

Section 3: Environmental Impacts of the Proposed Action and Alternatives This section presents information on the physical, biological, social, and economic environments of the

affected project area, and the potential direct, indirect, and cumulative effects to those environments due

to the implementation of the alternatives. Each resource area discloses the direct, indirect, and cumulative

effects for that resource area. This chapter analyzes forest vegetation, wildlife habitat, hydrology, soils,

botany, fire and fuels, scenery, recreation, heritage resources, economics, and roadless areas.

The National Environmental Policy Act defines these effects as:

Direct: Effects which are caused by the action and occur at the same time and place;

Indirect: Effects which are caused by the action and are later in time or farther removed in

distance, but are still reasonably foreseeable; and

Cumulative: Impacts that result from the incremental impact of an action, when added to impacts

of other past, present, and reasonably foreseeable future actions, regardless of what agency or

person undertakes such other actions.

The environmental assessment herby incorporates by reference the project record (40 CFR 1502.21). The

project record contains specialist reports, biological evaluations, and other technical documentation used

to support the analysis and conclusions in this environmental assessment. Full versions of these reports

are available in the project record located at the Eagle-Holy Cross Ranger District office in Minturn,

Colorado.


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The environmental assessment:

(i) Shall briefly provide sufficient evidence and analysis, including the environmental impacts of

the proposed action and alternative(s), to determine whether to prepare either an EIS or a finding

of no significant impact (FONSI).

The environmental assessment:

Shall describe the impacts of the proposed action and any alternatives in terms of context and

intensity as described in the definition of “significantly” at 40 CFR 1508.27.

Impacts (direct, indirect, and cumulative) of alternatives may be discussed together in comparison

or separately. If potential effects of several alternatives are the same, the effects discussion may

describe those effects as being the same and focus on describing where effects differ.

Silviculture

Affected Environment

Existing Conditions

The area used to analyze the Vail Intermountain vegetation includes the Lower Gore Creek-West Vail

Subwatershed. This area was selected as the analysis area because it is representative of the vegetation

type in the smaller project boundary. The dominant forest cover types in the 5,822-acre analysis area are

lodgepole pine and aspen (see Figure 4). Cover types are determined by what species is the dominant life

form within the overstory of the stand. The FSVeg Spatial Database was used to determine cover types

within the analysis area.


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Figure 4. Species composition by cover type for Vail Intermountain analysis area (5,822 acres)

Structural stages are used as a way to describe a stand in terms of crown cover and tree size. Structural

stages are broken up into the following categories.

1 = Grass, forb, or short shrub types

2 = Medium-tall shrub, seedlings less than 6 feet in height

2S = Shrub

2T = Seedling

3 = Tall sapling to medium diameter trees

3A = Small/medium, crown cover percent <40

3B = Small/medium, crown cover percent between 40 and <70

3C = Small/medium, crown cover percent ≥70

4 = Large to very large diameter trees

4A = Large/very large, crown cover percent <40

4B = Large/very large, crown cover percent between 40 and <70

4C = Large/very large, crown cover percent ≥70

Based on the FSVeg Spatial Database the Vail Intermountain analysis area is comprised of the habitat

structural stages displayed in Table 3.

Grass / Forb 24%

Spruce / Fir 1%

Shrub spp. 5%

Barren / Water 2% Aspen

41%

Lodgepole Pine 27%


24

Table 3. Vail Intermountain analysis area in acres by structural stage

Cover type 1 2S 2T 3A 3B 3C 4A 4B 4C Total

Percent of Total

(5,822 acres)

Barren/rock/water 95 2

Non-forest (shrubs and grasses)

1,406 305 1,711 29

Lodgepole pine 0 0 0 1,178 0 32 371 1,581 27

Spruce and fir 0 0 0 0 0 39 27 66 1

Aspen 0 234 1,176 857 0 0 102 2,369 41

Forest cover by structural condition (acres)

1,406 305 0 234 1,176 2,035 0 71 500 5,822

Forest cover percent by structural condition

24% 5% 0 4% 20% 35% 0 1% 9%


25

Due to mountain pine beetle mortality it is expected that some stands that contain a high percentage of

dead lodgepole pine may shift structural stage. Structural stage changes would likely include shifts from

a higher crown cover percent class to a lower crown cover percent class. For example a 4C stand may

become a 4A or a 3B depending on the size (diameter) of the live residual stand and the number of trees

providing crown cover. In cases of extreme mortality the stand could shift to the 2T class. There is

ongoing work Forestwide to update the FSVeg Spatial Database to reflect changes to the vegetation layer

caused by the mountain pine beetle epidemic; however, the Vail Intermountain analysis area has not yet

been completed. For purposes of this analysis, all structural stage classes will remain as described in

Table 1.

Lodgepole Pine Cover Type

Lodgepole pine is one of the most dominant cover types across the analysis area (see Figure 5). Stands

are primarily mature, except where past forest management activities have occurred. According to Lotan

and Critchfield (1990) lodgepole pine can exist in the following four successional stages:

Minor Seral: A component of even-aged stands rapidly being replaced by shade-tolerant associates

in 50 to 200 years.

Dominant Seral: A component of even-aged stands with a vigorous understory of shade-tolerant

species that will replace lodgepole pine in 100 to 200 years.

Persistent: The dominant cover type of even-aged stands with little evidence of replacement by

shade-tolerant species.

Climax: The only tree species capable of growing in a particular environment; lodgepole pine is self-

perpetuating.

The lodgepole pine within the analysis area is generally persistent with few stands being dominant seral.

As a result of canopy gaps created by lodgepole pine mortality within proposed treatment units, aspen is

becoming more widely established in the understory as more sunlight hits the forest floor. Spruce and fir

understory exists in a randomly spaced, patchy arrangement.

Lodgepole pine is a shade-intolerant species and there are very few places within the analysis area where

seedlings can become established under the existing overstory. In addition, the mineral soil needed for

seedling establishment only occurs in isolated areas, such as exposed soil under the root ball of a fallen

tree. Ground cover occurring across the analysis area is typically represented by grasses, forbs, and

shrubs, and may include species such as sedge (Carex spp.), common juniper (Juniperus communis),

Oregon grape (Mahonia repens), kinnikinnick (Arctostaphylos uva-ursi), whortleberry (Vaccinium spp.),

russet buffalo berry (Shepherdia canadensis), heart-leaf arnica (Arnica cordifolia), and lupine (Lupinus

argenteus).

Lodgepole pine stands are dominated by mature trees with ages ranging from 100- to 150-years old.

Based on stand exam data collected within the analysis area in 2015, the quadratic mean diameter ranges

between 8.2 and 9.1 inches (includes all trees with diameters 0+ inches). The majority of the lodgepole

pine cover type within the analysis area is characterized as being comprised of small- to medium-diameter

trees with dense canopy cover (see Table 3). Canopy cover percentages may be trending downwards as

the trees affected by mountain pine beetle loose needles.

Mountain Pine Beetle. Mountain pine beetle is a native species and usually occurs at endemic levels. In

the Vail Intermountain analysis area there was a sharp increase in the presence of mountain pine beetles

starting in the late 1990s. Drought, relatively high temperatures, and large expanses of mature forests

provided conditions that enabled beetle populations to reach epidemic levels.


26

Figure 5. Existing condition lodgepole pine

Forest health monitoring plots were established within the analysis area as early as 2006 and have been

visited annually since (see Figure 6). These plots provide an insight to landscape-level trends in mountain

pine beetle-caused mortality in lodgepole pine forests within the analysis area. Data collected on these

plots show many of the lodgepole pine trees infested with mountain pine beetles died prior to 2009, and

that some of the trees infested since 2010 have been able to successfully “pitch-out” the beetles. Annual

aerial flights conducted by the Forest Service to monitor insects and disease suggest that mountain pine

beetles are still active within the analysis area, but at more endemic population levels (Ross 2012).

Figure 6. Forest health monitoring plot data by area

0

10

20

30

40

50

60

70

80

90

100

2008 2009 2010 2011

Pe

rce

nt

Mo

rtal

ity

Year

Vail Ski Area

Red Sandstone

West Vail


27

In addition to forest health monitoring plots, reconnaissance plots were established during the 20142015

field seasons. These plots collected data on a systematic grid across proposed treatment units and provide

a snapshot of the existing mortality. Generally, one plot per 5 acres was established, and data including

species, mortality, height, and diameter was collected.

Table 4. Vail Intermountain proposed treatment unit mortality represented by basal area

Unit Acres # of Plots

Total Stand Basal Area

Average of Plots (Square feet/acre)

Total Basal Area Dead

(%)

Total Basal Area Lodgepole Pine–

Dead

(%)

1 108 21 170 39 42

2 26 8 140 56 56

3 95 9 125 63 72

4 68 8 155 41 46

5 22 8 150 37 60

Average 319 54 150 47 55

Aspen Cover Type

Aspen stands are the most extensive cover type within the Vail Intermountain analysis area. Aspen is a

fast-growing, short-lived species that is quick to occupy disturbed sites. Aspen stands are usually

replaced by slower growing species over the long term (Perala 1990). Based on stand exam data collected

within the analysis area in 2015, the quadratic mean diameter for aspen is approximately 8.1 inches

(includes all trees with diameters 0+ inches). The majority of the cover type within the analysis area is

comprised of small- to medium-diameter trees with moderately dense canopy cover. Stands within the

analysis area may exhibit a variety of damaging agents including insects, diseases, Sudden Aspen

Decline, or browsing damage by elk, deer, or moose.

Environmental Consequences

Alternative 1 (No Action)

Direct and Indirect Effects

Under the no-action alternative natural processes would be expected to continue and there would be no

harvesting of dead, dying, and susceptible lodgepole pine and aspen trees. Mountain pine beetles would

continue to infest more live lodgepole pine trees, although at endemic levels. Mature, live Engelmann

spruce, subalpine fir, and aspen would persist in areas where they currently exist.

Recent studies suggest that the future forest will be largely influenced by pre-outbreak forest condition

and composition (Collins et al. 2011; Pelz and Smith 2012). In stands of pure lodgepole pine with little to

no existing understory, site conditions may favor the establishment of more shade-intolerant species such

as lodgepole pine and aspen. As the existing dead lodgepole pine trees die and lose their needles, more

sunlight would begin to reach the forest floor, aiding lodgepole pine seedling establishment or aspen root

suckering. Seedling establishment is likely to be slow and patchy in nature due to the thickness of the

existing litter and duff layers. Herbaceous vegetation would benefit from the mortality created by the

mountain pine beetle (Stone and Wolfe 1995). Increased sunlight associated with lodgepole pine

mortality would increase herbaceous productivity, which can in turn restrict recruitment of new conifer

seedlings.


28

Recent data collected within the project area documents that an average of over 50 percent of the mature

lodgepole pine has experienced mortality due to the mountain pine beetle. It is expected that over the

next 5 to 20 years, as the roots and bases of standing dead trees decay, trees would continue to fall to the

ground, increasing coarse woody debris accumulations (Klutsch et al. 2009). Stands that have high

concentrations of downed woody debris can make future management less feasible, as well as contribute

to future stand conditions that can support wildfire characterized by high intensity/high severity fire

behavior (Page and Jenkins 2007a, 2007b).

Areas dominated by an aspen overstory would continue to be dominated by aspen in the short term.

Localized tree mortality within aspen stands is common and would continue to occur under the no-action

alternative. Dead lodgepole pine trees located within these stands would be expected to fall to the ground

over the next 5 to 20 years. Mature live subalpine fir and Engelmann spruce within these stands would

continue to grow and provide a seed source for additional shade-tolerant seedling establishment. Over

time aspen stands may be replaced by more shade-tolerant species (Perala 1990).

Cumulative Effects

There are no cumulative effects of the no-action alternative. The proposed treatment areas would not be

treated and natural processes would continue as in other untreated areas.

Alternative 2 (Proposed Action)

The purpose of the Vail Intermountain Fuels Project is to reduce the current and future wildfire hazard to

and from adjacent communities by managing existing hazardous fuels on Federal lands and to create

strategic hazardous fuel breaks and maintain/expand existing aspen diversity on Federal lands. In order to

achieve these goals the White River National Forest proposes to treat approximately 319 acres of forested

land using a variety of silvicultural systems.

Table 5. Proposed action by silvicultural prescription

Silvicultural Prescription Cover Type Acres Treatment Area Threshold

Threshold Acres

Patch clearcut <10 acres Lodgepole pine 129 Up to 50% 65

Individual tree selection (dead only), group selection <2 acres

Lodgepole pine 118 Up to 50% overall, no more than 30% in group removal

59

(35 acres in group removal)

Coppice cut <10 acres Aspen 10 None 8

Individual tree selection (dead only)

Aspen 62 None 62

Totals 319 194

Patch Clearcut

Under this treatment method, within identified patches, all live and dead lodgepole pine and aspen, with

the exception of advanced regeneration, would be felled and removed via helicopter yarding or piled and

later burned by the Forest Service.


Approximately 130 acres have been identified for treatment using a patch clearcut prescription. Within

the 130 acres approximately 50 percent (65 acres) of the area would be treated utilizing small patch cuts.

All live and dead lodgepole pine and aspen greater than 5.0 inches d.b.h. would be removed from

identified patch clearcuts. Patch clearcuts would be 10 acres or less in size and would be located in areas


29

where mortality from the mountain pine beetle epidemic is the greatest or adjacent to areas that contain

aspen.

Lotan and Critchfield (1990) describe the ideal conditions for lodgepole pine seed germination as “full

sunlight on bare mineral soil or on disturbed duff layers that are free of competing vegetation.” Harvest

operations in these areas would create canopy gaps allowing direct sunlight to reach the forest floor.

Harvest operations are likely to include whole-tree removal, meaning whole trees are removed via

helicopter yarding, and if treated by hand the entire tree would be limbed, bucked, and placed into burn

piles. By utilizing these methods of tree disposal little to no ground disturbance would be expected

within treatment units, thereby creating fewer favorable micro-sties for seed germination. Some natural

regeneration would occur since small micro-sites of bare mineral soil may exist naturally within the

treatment area. Where patch clearcuts are located adjacent to aspen areas, aspen would likely become

established due to the species’ ability to regenerate via root suckering following a disturbance (Perala

1990).

Other defensible space projects located in the Vail Valley have utilized a mix of helicopter yarding and

hand treatments. These have occurred in areas dominated by lodgepole pine and aspen. Although

regeneration of lodgepole pine is not an objective of this project, as shown from other treatment areas,

both lodgepole pine and aspen can regenerate after harvesting activities, despite the lack of cone dispersal

and site disturbance.

Table 6. Regeneration results, Vail Valley treatments1

Project Acres Logging Method

Regeneration Success (average across all units)

Regeneration Composition

Eco 07 29 Hand felling; helicopter removal

86% 63% Aspen

28% Lodgepole pine

6% Douglas-fir

2% Engelmann spruce

1% Subalpine fir

Vail Valley IDIQ 37 Hand felling; pile and burn

70% 97% Aspen

1% Engelmann spruce

2% Subalpine fir

Vail Valley IDIQ 53 Hand felling; lop and scatter

71% 99% Aspen

1% Lodgepole pine 1 Regeneration results from treatments outside the project area are included in appendix A of the Silvicultural Report.

Stocking Standards. The Forest Service would monitor stocking in patch clearcuts in the first, third, and

fifth year following harvest activities. If natural regeneration does not become established in this

timeframe, no additional efforts would be made to ensure the harvested areas meet stocking standards.

This is consistent with the Forest Plan standard that states:

When trees are harvested on other than suitable lands, exceptions to the 5-year restocking standards are

appropriate when the harvest meets one of the following:

Where it provides permanent openings that serve specific management direction

Where provided for in specific management practices and prescriptions

Where it is desirable to delay the onset of regeneration and crown closure to meet specific desired

conditions and management objectives


30

The Vail Intermountain Fuels Project occurs exclusively within Management Area 7.1–Intermix. The

Intermix management area is not considered part of the suitable timber land base, and desired conditions

include minimizing hazardous fuel loading patterns. Prescriptions developed for the project were

designed to manage existing hazardous fuels and to create strategic hazardous fuel breaks.

Group Selection

Approximately 35 acres are proposed for treatment utilizing group selection where small group openings

less than 2 acres in size would be placed throughout the 118-acre proposed treatment area. All live and

dead trees within group openings would be removed utilizing helicopter yarding or hand treatments.

Placement of group openings would favor areas affected by the mountain pine beetle epidemic.


The group selection prescription would create small openings in the forest canopy less than 2 acres in

size, where all live and dead trees would be removed. Response of regeneration would be similar to that

of the patch clearcut area. Natural regeneration may become established in these small openings, but may

be limited due to the lack of ground disturbance. The Forest Service would monitor stocking in group

selection openings in the first, third, and fifth year following harvest activities. If natural regeneration

does not become established in this timeframe, no additional efforts would be made to ensure the

harvested areas meet stocking standards.

Individual Tree Selection (Dead Only)

Approximately 87 acres would be treated utilizing individual tree selection harvest method. This harvest

method would include removing dead trees, similar to a salvage treatment. Mortality in the lodgepole

pine component related to the mountain pine beetle may be moderate in areas proposed for this type of

treatment.


Removal of individual dead trees would create conditions favorable for the establishment or release of

more shade-tolerant advance regeneration. Because there is not a strong presence of Engelmann spruce or

subalpine fir in the overstory, there is a lack of a nearby seed source to enable these trees to become

established in the understory. Establishment of shade-intolerant regeneration is not expected to occur due

to the lack of direct sunlight and bare mineral soil. Areas treated using the individual tree selection

prescription should continue to meet stocking standards post-treatment.

Coppice

Approximately 8 acres would be treated utilizing the coppice regeneration method. This harvest method

would remove all live and dead trees within the treatment area similar to the patch clearcut.


The removal of all aspen trees within the treatment unit would provide favorable conditions for the

establishment of a young aspen stand. Because aspen is a disturbance-related species, regeneration

success is closely correlated to the amount of disturbance (Perala 1999). Once the overstory is removed,

the root system would cease to produce a hormone called auxin which supports apical dominance and

suppresses root suckering (regeneration). After apical dominance is eliminated a secondary hormone

called cytokinin can accumulate and initiate root suckering (Perala 1999). Based on other similar projects

conducted in the Vail Valley it can be expected that these areas would regenerate with aspen within 5

years of final overstory removal.


31

Past, Present, and Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis

Temporal Scope. Vegetation management activities that occurred between the 1980s and the present, as

well as any reasonably foreseeable vegetation management activities, are shown in Table 7.

Geographic Scope. Comprised of approximately 5,822 acres located in the Lower Gore Creek–West Vail

Subwatershed.

Table 7. List of past, present, and reasonably foreseeable activities1 by activity type

Type of Activity Logging Method Slash Treatment Acres

Even-aged (clearcut, patch clearcut, coppice)

Hand treatment Pile and burn 38


Helicopter yarding (whole tree)

N/A 53


Hand treatment Lop and scatter 36

Salvage, private Mechanical ground based Pile and burn 3

Salvage, ski area projects Mechanical ground based Pile and burn 21

Proposed action, patch clearcut

Helicopter yarding (whole tree)

N/A 65

Proposed action, coppice Helicopter yarding (whole tree)

N/A 8

Proposed action, individual tree selection (dead only)

Helicopter yarding (whole tree)/hand treatment

N/A

Pile and burn

87

Proposed action, group selection

Helicopter yarding (whole tree)/hand treatment

N/A

Pile and burn

35

Total 428 1 Appendix A includes a complete list of projects considered for cumulative effects.

The proposed action increases the total number of acres affected by relatively recent vegetation

management activities from 233 acres to 428 acres. Since the early 1980s, vegetation management

activities have been completed on approximately 4 percent of the analysis area. Of the 4 percent the

majority of treatments were related to creating defensible space and reducing hazardous fuel loads.

Implementation of the proposed action would increase the percent of managed acres to 7 percent of the

analysis area.


32

Table 8. Vail Intermountain analysis area in acres by structural stage, cumulative effects1

Cover type 1 2S 2T 3A 3B 3C 4A 4B 4C Total

Percent of Total

(18,842 acres)

Barren/rock/water 95 2%

Non-forest (shrubs and grasses)

1,506 305 1,811 31%

Lodgepole pine 0 0 0 1,042 0 32 353 1,427 25%

Spruce and fir 0 0 0 0 0 39 27 66 1%

Aspen 147 222 1,158 797 0 0 99 2,423 42%

Forest cover by structural condition (acres)

1,506 305 147 222 1,158 1,839 0 71 479 5,822

Forest cover percent by structural condition

26% 5% 3% 4% 19% 32% 0% 1% 8%

1 Table includes projected changes from other defensible space projects in the Vail Valley.


33

The proposed action constitutes approximately 3 percent of the total analysis acres. For purposes of this

analysis, in order to analyze the worst possible scenario, it would be assumed that all patch clearcut and

group selection treatments would convert to non-forest habitat. All areas treated with the coppice

regeneration method would be expected to meet stocking standards within 5 years from the completion of

harvest activities. For this analysis all proposed individual tree selection treatments would remain in their

current structural stage.

Following implementation of the proposed action all structural stages would continue to be represented

with only minor shifts in species composition. A slight loss in the number of forested acres may occur if

stocking standards are not met in the patch clearcut and group selection openings. This loss is not

expected to contribute negative cumulative effects within the analysis area.

Summary of Environmental Effects

Proposing 194 acres of treatment in areas where mountain pine beetle exceeds 50 percent of the mature

lodgepole pine component meets the purpose and need of the Vail Intermountain project by reducing the

current and future wildfire hazard and by maintaining/expanding existing aspen diversity. Current and

future wildfire hazard is reduced by removing dead trees that in the future are likely to fall creating

jackstraw conditions. Aspen diversity is expanded by creating openings in or near existing aspen stands

that past actions have shown are likely to regenerate as aspen.

Table 9. Comparison of the no action and proposed action alternatives

Indicator No-Action Alternative (acres)

Proposed Action Alternative (acres)

Acres with favorable site condition for aspen regeneration

0 8

Acres of meadow or young age class creating canopy gaps in mature forest

0 108

Consistency with Laws, Regulations, and Policies

The Vail Intermountain Fuels Project is consistent with the White River National Forest Land and

Resource Management Plan (Forest Plan, pages 1-3–1-11), specifically because:

Goal 1: It promotes ecosystem health and conservation using a collaborative approach through the HFRA

to sustain the nation’s forest, grasslands, and watersheds.

Objective 1a – It improves and protects watershed conditions to provide the water quality and quantity

and soil productivity necessary to support ecological functions and intended beneficial uses by

reducing current and future wildfire hazard and by maintaining/expanding existing aspen diversity.

Objective 1d – It increases the amount of forest and rangelands restored to or maintained in a healthy

condition with reduced hazard and damage from fires, insects, disease and invasive species by

removing dead trees that could fall and create hazardous fuels on the ground.

Objective 1e – The IDT worked cooperatively with individuals, organizations, local, state, tribal and

other federal agencies through the HFRA to promote ecosystem health and sustainability across

landscapes.

Goal 2: It provides a variety of uses, products, and services for present and future generations by

managing within the capability of sustainable ecosystems.

Objective 2c – It improves the capability of national forests and rangelands to sustain desired uses,

values, products and services by reducing the hazard of future wildfire.


34

Fuels


Lodgepole Pine Cover Type

Lodgepole pine is one of the most dominant cover types across the analysis area. Stands are primarily

mature, except where past forest management activities have occurred. As a result of canopy gaps created

by lodgepole pine mortality, aspen is becoming more widely established in the understory within

proposed treatment units as more sunlight hits the forest floor. Spruce and fir understory is randomly

spaced and patchy.

Lodgepole pine is a shade-intolerant species and there are very few places within the analysis area where

seedlings can become established under the existing overstory. In addition, the mineral soil needed for

seedling establishment only occurs in isolated areas, such as exposed soil under the root ball of a fallen

tree. Ground cover occurring across the analysis area is typically represented by grasses, forbs, and

shrubs, and may include species such as sedge (Carex spp.), common juniper (Juniperus communis),

Oregon grape (Mahonia repens), kinnikinnick (Arctostaphylos uva-ursi), whortleberry (Vaccinium spp.),

russet buffalo berry (Shepherdia canadensis), heart-leaf arnica (Arnica cordifolia), and lupine (Lupinus

argenteus). The majority of the lodgepole pine cover type within the analysis area is characterized as

being comprised of small- to medium-diameter trees with dense canopy cover (Table 3). Canopy cover

percentages may be trending downwards as the mountain pine beetle-affected trees begin to loose needles

(Limberis 2015).

Aspen Cover Type

Aspen stands are the most extensive cover type within the Vail Intermountain Fuels analysis area. Aspen

is a fast-growing, short-lived species that is quick to occupy disturbed sites. Aspen stands are usually

replaced by slower growing species over the long term (Perala 1990). The majority of the cover type

within the analysis area is comprised of small- to medium-diameter trees with moderately dense canopy

cover (Table 3). Stands within the analysis area may exhibit a variety of damaging agents including

insects, diseases, Sudden Aspen Decline, or browsing damage by elk, deer, or moose.

Fire History and Occurrence

Fire has played a significant role in the development of the vegetation in the Vail Intermountain Fuels

Project Area. In the past, exclusion of fire from large areas of the forest has resulted in expansive stands

of lodgepole pine. Much of this area is currently at high risk from wildfire and has been affected by

mountain pine beetle infestations.

Since 1986, there have been 173 fires that burned over 500 acres on the Eagle-Holy Cross Ranger

District. There have been five fires in the project area in that timeframe, the largest being 2 acres. This

data indicates the successful fire suppression history in the area. Fire occurrence data is typically digitized

as point source data from historical maps that portrayed fires by year, size class, and cause for the time

period 1920 to 1969. For the period from 1970 to present, fire occurrence information is maintained at the

Kansas City fire database (KCFast). The records from this period have detailed information including

acreage, cost, statistical cause, size class, and physical location. Both natural and human-caused fires

occurred on the district. The high density of recreational activity increases potential ignition sources

significantly. Off-road vehicles, debris burning, discarded cigarettes, children playing with matches,

fireworks, roadway fires, and campfires are just a few of the potential human ignition sources.


35

Fire Behavior Fuel Models

A fire behavior fuel model represents the fuel bed characteristics necessary to predict surface fire

behavior in fire behavior modeling systems. In 2005, Scott and Burgan presented a new set of fire

behavior fuel models that expanded on the original 13 created by Anderson in 1982. Advantages of this

new set include: increased precision in surface fire intensity prediction and subsequent crown fire

behavior prediction, increased ability to simulate changes in fire behavior as a result of fuel treatments,

and improved accuracy of fire behavior predictions outside of the severe period of the fire season (Scott

and Burgan 2005). For these reasons the Scott and Burgan models are used in the fire behavior modeling

systems used in this analysis. The distribution of fuel models mapped in the project area is shown in Table

10.

Approximately 11 percent of the project area is mapped as fuel model TU1 which depicts a combination

of forest litter2 and a low load of grass and shrub fuel as the primary carrier of fire. Fuel model TU5

comprises 35 percent of the area. The primary carrier of fire in fuel model TU5 is heavy forest litter with

a shrub or small tree understory which can likely lead to crown fire due to the abundance of ladder fuels.

Fuel model TL3 comprises 51 percent of the project area. The primary carrier of fire in TL3 is a

moderate load of conifer litter and a light load of coarse fuels. The spread rate and flame lengths are

typically low in this fuel model. Although fire behavior is relatively low in TL5, this fuel model also

includes downed logs which can increase resistance to control by firefighters. With concentrations of dead

fuels, individual trees or groups of trees may torch, and fire may continue through the crowns aided by

high winds.

The majority of the non-forested fuel models within the project area are mapped as GS2. GS2 consists of

a moderate load of dry climate grass and shrub. Shrubs are approximately 1- to 3-feet high and the grass

load is moderate. One can expect a high rate of spread and moderate flame lengths in this fuel model.

The flame length and rate of spread in GS2 is low compared to other grass fuel models and is primarily

used to represent the grassland areas. Fuel models comprising less than 1 percent of the project area were

not discussed in detail. The Vail Intermountain Fuels Project lies within the Vail Valley Fire Management

Unit. The White River Fire Management Plan (2013) states that fire behavior is typically minimal in the

higher elevations due to the cool, moist climate; however, drought conditions can create situations where

conifers can easily torch. Combined with a strong wind event, active crown runs can occur during

extended dry periods. Shrub lands can display very active fire behavior during most of the summer.

Brown’s transects were established in the project area summer of 2015. Results of plot data show downed

woody fuels ranged from 15 to 31 tons per acre.

2 Litter is defined as leaves, needles, fine twigs, and other organic material on the forest or grassland floor that have

undergone little or no decomposition.


36

A stand-replacing fire event is a current risk to the project area due to the fuel types present, topography,

and weather conditions. In addition, fire suppression within the area has been quite effective and the

removal of fire as an important process has affected the current fire regime (fire interval and fire severity).

The location of the Town of Vail and the surrounding community is of concern if a wildfire were to occur

in the project area, as winds associated with cold fronts could push a fire towards the Vail community.

Figure 7. Fuel loading levels in the project area

Table 10. Current distribution of fire behavior fuel models in the project area

Fire Behavior Fuel Model (FBFM) Acres Percentage of Project Area

GR1 0.28 0.02

GR2 0.24 0.02

GS2 17.30 1.34

NB1 5.71 0.44

SH1 0.00 0.00

SH2 0.03 0.00

SH7 10.45 0.81

TL1 4.75 0.37

TL2 0.22 0.02

TL3 662.82 51.33

TL8 0.89 0.07

TU1 141.10 10.93

TU5 447.39 34.65

Grand Total 1,291.18 100.00


37

Fire Hazard

Fire hazard identifies the ability of fuels to propagate and sustain a fire and how effectively it can be

controlled. It can be represented by the potential fire behavior. Fire behavior can be projected utilizing

computer models and then translated into fire hazard. Fire behavior is the manner in which a fire reacts to

available fuels, weather, and topography. A change in any of these components results in a change in fire

behavior (DeBano et al. 1998). Fire behavior is complex, with many contributing factors in the categories

of topography (slope, aspect, elevation), weather (climate, air temperature, wind, relative humidity,

atmospheric stability), and fuels (size, type, moisture content, total loading, arrangement) (Agee 1993).

These three elements comprise the fire environment, surrounding conditions, influences, and modifying

forces that determine fire behavior.

Topography and weather at a given location are beyond the ability of management to control. The fuel

portion of fire behavior is the only controllable factor, and is therefore the one factor that managers can

use to manage fire hazard. Weather conditions such as drought, high temperature, low humidity, and high

wind play a major role in the spread of wildfires and are influenced by topography and location of

mountains as well as global influences such as La Niña and El Niño. Weather conditions are a major

factor in the initiation and spread of all wildfires, but Omi and Martinson (2002) found that stands with

prior fuel treatments experienced lower wildfire severity than untreated stands burning under the same

weather and topographic conditions. Fuel management modifies fire behavior, ameliorates fire effects,

and reduces fire suppression costs and danger (DeBano et al. 1998). Manipulating fuels reduces fire

intensity and severity, allowing firefighters and land managers more control of wildland fires by

modifying fire behavior in the fire environment (Pollet and Omi 2000).

Fuel management can include reducing the loading of available fuels, lowering fuel flammability, or

isolating or breaking up large continuous bodies of fuels (DeBano et al. 1998). Fuels contribute to the rate

of spread of a fire, intensity/flame length, fire residence time, and the size of the burned area (Rothermel

1983; Agee et al. 2000).

Flame length has significance for suppression strategy and tactics, and is a good visual indicator of

fireline intensity at the head of the fire (DeBano et al. 1998). It is also a measure of fire suppression

difficulty. This makes it a good indicator of fire hazard. The following table displays fire hazard, fireline

intensity, and flame length as it relates to suppression difficulty. Flame lengths of less than 4 feet are often

considered a benchmark for effective fire control operations because they can be attacked directly by hand

crews. Low intensity fires (those with 4-foot or less flame lengths) do not normally burn through the

canopy or result in severe fire effects.


38

Table 11. Fireline intensity interpretations and associated fire hazard ratings

Fire Hazard

Flame Length

(Feet)

Intensity BTUs/Second/

Foot Interpretations

Low <4 <100 Direct attack at head and flanks with hand crews; hand lines should stop spread of fire

Low–Moderate 4.1–8 100–500 Employment of engines, dozers, and aircraft needed for direct attack; too intense for persons with hand tools

Moderate 8.1–11 500–1,000 Control problems, torching, crowning, spotting; direct control efforts at the head are likely ineffective

High >11.1 >1,000 Control problems, torching, crowning, spotting; control efforts at the head are ineffective

Note: Based on Rothermel (1983).

Higher intensity fires have greater potential to become crown fires. Crown fires normally are highly

destructive, difficult to control, and present the greatest safety hazard to firefighters and the public. Crown

fires burn hotter and result in more severe effects than surface fires. Crown fires generally spread at least

two to four times faster than surface fires (Rothermel 1983). Fires that spread quickly and at higher

intensities can pose a greater risk to firefighters and the public when they occur. Agee (1996) states that

crown fire potential can be managed through prevention of the conditions that initiate crown fires and

allow crown fires to spread. Three main factors contributing to crown fire behavior can be addressed

through fuels management: (1) initial surface fire behavior; (2) canopy base height; and (3) canopy bulk

density. Omi and Martinson (2002) note that their study of fuel treatments provides strong evidence of

fuel treatment efficacy, and that their results “appear quite similar to those provided by previous authors”.

There is a large body of literature that makes the case for treating the various strata (surface, ladder, and

canopy) of fuels. According to Graham et al (2004):

Qualitative observations, limited empirical data, and modeling provide the scientific basis for identifying

how forest structure can be modified to reduce fire hazard and modify fire behavior. Additionally, research

shows that when activities reduce surface fuels (low vegetation, woody fuel, shrub layer), those activities

decrease the chances that surface fires will be able to ignite ladder fuels and canopy fuels (Pollet and Omi

2002). The most effective strategy for reducing crown fire occurrence and severity is to (1) reduce surface

fuels, (2) increase height to live crown, (3) reduce canopy bulk density, and (4) reduce continuity of the

forest canopy (Van Wagner 1977, Agee 1996, Graham et al. 1999, Scott and Reinhardt 2001, Cruz et al.

2002).

Surface Fuels

Fire behavior is described by flame length, rate of spread, and fireline intensity (Rothermel 1983). Surface

fuels are an important factor in determining how fast a surface fire would spread and how hot it would

burn. Surface fuels consist of needles, leaves, grass, forbs, branches, logs, stumps, shrubs, and small trees.

Surface fire factors are also important to the initiation and spread of crown fires.

Anderson (1982) identifies surface fuels that are up to 3 inches in diameter as those that are used in the

Fire Behavior Model. Surface fuels greater than 3 inches contribute towards intensity, resistance to

control, and spotting, but are not part of the fire behavior model.

Canopy Fuels

Crown fire and crown fire initiation is related to several conditions that must be met. First the intensity of

the surface fire must be high, then foliar moisture content of the live vegetation must be low, crown base


39

heights be low enough to interact with the surface fire, and the crown bulk density must be high enough to

sustain the fire once it gets into the crowns. Canopy base height (CBH) is the lowest height above the

ground at which there is a sufficient amount of canopy fuel to propagate fire vertically into the canopy

(Scott and Reinhardt 2001). CBH incorporates ladder fuels such as shrubs and understory trees as well as

the lower branches of mature trees. The lower the canopy base height, the easier it is for a given surface

fire to initiate a crown fire. Low canopy base heights provide the “ladder” which allows a surface fire to

become a crown fire. Figure 8 displays the CBH as it relates to critical flame length.

Figure 8. Canopy base height as it relates to critical flame length (feet)

In order for a crown fire to initiate, a surface fire must be intense enough and with long enough flame

lengths, to ignite the lowest level of branches that would propagate fire to the upper levels of the canopy

(Figure 8). When the height from the surface fuels to the bottom of the tree crown is low, for example

only 5 feet, a relatively short flame length would ignite the crown. A greater height from the ground

would require a larger flame length to ignite.

Once a fire begins burning in the crowns of the trees, whether that crown fire ignition is sustained or not

is determined by surface fire rate of spread, and crown bulk density (CBD) (Alexander 1988; Van Wagner

1977). Wind and slope are important factors in potential crown fire spread (Rothermel 1991), and species

composition and structure control crown bulk density. Stands with high CBDs can sustain a crown fire

that initiated outside the stand, even when surface fire intensity and CBH are such that fires that start

within the stand itself would not transition into a crown fire.

Reducing stand density has the potential to increase surface fire behavior; however, overall fire behavior

is more significant. Scott (2003) states:

Modifying canopy fuels as prescribed in this method may lead to increased surface fire intensity and spread

rate under the same environmental conditions, even if surface fuels are the same before and after canopy

treatment. Reducing CBD to preclude crown fire leads to increases in the wind adjustment factor (the

proportion of 20-ft wind speed that reaches midflame height). Also, a more open canopy may lead to lower


40

fine dead fuel moisture content. These factors increase surface fire intensity and spread rate. Therefore,

canopy fuel treatments reduce the potential for crown fire at the expense of slightly increased surface fire

spread rate and intensity. However, critical levels of fire behavior (limit of manual or mechanical control)

are less likely to be reached in stands treated to withstand crown fires, as all crown fires are uncontrollable.

Though surface intensity may be increased after treatment, a fire that remains on the surface beneath a

timber stand is generally controllable.

As shown above, in general, lower fuel loading results in less intense surface fires. Lower surface fire

intensity means that fires are less likely to transition to canopy fires which are generally the most

destructive and difficult to control. Given the anticipated weather conditions, the fuel loading and the

associated fire hazard rating for the areas proposed for treatment within the project can be used to

compare the likelihood that the treatments would result in areas within the project that are more resistant

and resilient to natural disturbances such as fires.

Existing Fuels Conditions and Fire Hazard

The project area consists primarily of forested vegetation including lodgepole pine and aspen. Fuel

conditions (surface fuel loading levels and standing dead trees) in the project area are largely a product of

insect and disease activity. The insect and disease activity combined with natural forest succession has

created hazardous fuel levels. Throughout the project area, heavy dead and down fuel loading is

combined with live fuels in the form of shrubs, aspen regeneration, and some conifer regeneration. These

areas represent the surface, ladder, and canopy fuels that would promote high intensity fire under adverse

weather conditions. A potential fire behavior modeling scenario was conducted to evaluate the flame

length and crown fire potential within the project area under weather conditions conducive to high fire

behavior (see Table 12).

Table 12. Potential fire behavior characteristics modeled for the project area

Potential Fire Behavior Characteristic Percent

Flame Length 4 feet 65

>4 feet 35

Fire Type Surface 66

Crown 34

As shown in Table 12, modeling suggests that over a third (35 percent) of the project area has potential

fire behavior characteristics that would make direct suppression strategies ineffective or unsafe for

firefighters. Portions of the project area exhibiting these conditions are of concern due to the proximity of

private land, the Town of Vail, and the ski resort. Conditions like these can lead to high acreage burned

and adverse effects on resources. Significant fire spread is generally due to spotting and wind-driven

crown fires. Areas expected to experience crown fire also have the potential for spotting. Fires initiating

within or adjacent to the project area have the potential to spread through spotting and threaten private

land adjacent to the project area.


41



Direct, Indirect, and Cumulative Effects

There would be no direct effect to fuels under this alternative. The no-action alternative would not alter

the fuel profile to reduce fire behavior and would not meet the purpose and need of this project. In the

absence of human-caused or natural disturbance, such as vegetation treatment activities and wildfire,

there would be an increased accumulation of surface and ladder fuels from insect and disease activity,

blow down, and the progression of forest succession, growth, and change. The result would be increased

surface and ladder fuels that affect flame length, surface fuel loading levels that affect fire intensity and

severity, as well as increased tree crown density that make crown fire initiation more likely. It is likely the

ability of firefighters to safely and effectively suppress wildland fire would become more difficult as fire

behavior characteristics intensify due to increasing fuel loading levels. Once wildfire transitions to the

tree crowns, direct suppression tactics are not effective. Fires burning under these conditions would have

greater potential to escape control, and in the event of a wildfire, would make access and egress to the

area difficult. Fires that escape initial attack are likely to become large and have adverse effects.

Potential fire behavior characteristics would be similar to those described under the existing condition and

summarized in Table 12. Wildfires that escape initial attack may impact adjacent private lands and other

resources. Direct suppression tactics by firefighting forces may not be as effective in the project area

under the no-action alternative. Tree mortality, as a result of insect and disease activity and natural forest

succession, would continue and would exacerbate the amount of standing and downed fuels in the project

area and adjacent to private land. These unprecedented fuel levels have the potential to significantly affect

fire behavior should a wildland fire occur within or adjacent to the project area.

Smoke. Under alternative 1 (no action), no treatments would occur and there would be no anthropogenic

emission contribution to degrade air quality. However, due to the increased accumulation of fuels there is

an increased probability of high intensity wildfire which could result in air quality degradation. Air

quality can be degraded by smoke from wildfires to the point of human illness in some instances. Hardy

(2001) noted emissions from wildfire are typically greater than emissions from a prescribed fire on the

same acreage due to greater emission factor, fuel consumption, and fire intensity. Wildfires are also

known to result in high levels of emissions, and associated NAAQS (National Ambient Air Quality

Standards) violations. Smoke from wildfire can cause visual impacts to the surrounding area and create

hazardous driving conditions on adjacent State, county, and forest system roads for extended periods of

time. Should a wildfire occur, dust emissions from fire suppression equipment could increase. In the short

term, air quality impacts from alternative 1 (no action) would be less because pile burning would not

occur.

Emissions sources contributing to particulate matter and other pollutants would continue to be present.

These sources include wood burning stoves, vehicle exhaust, emissions from recreational campfires,

emissions associated with prescribed fire, fugitive dust, and wildfires within or near the project area.

Wildfire frequency is expected to continue as it has been observed in the past. An unwanted wildfire

could lead to negative cumulative effects, depending on the size and intensity of the wildfire. Visibility

impairment and human health impacts due to sudden and dramatic pollutant release are likely with a large

wildfire event. Cumulative effects of smoke are unknown because the intensity and size of a wildfire is

unknown. Research indicates wildfires can produce nearly twice the amount of smoke as prescribed fire

(Huff et al. 1995).


42



Proposed treatments would reduce surface, ladder, and crown fuels and change the fuel model profile,

thereby decreasing the area with potential for flame lengths greater than 4 feet and reducing potential

crown fire risk. Implementing this alternative would reduce risks to firefighter safety by reducing snags in

the project area and increase the success of firefighters engaging in fire suppression actions. In addition,

alternative 2 would reduce the risk of wildfire impacts to adjacent private lands and other resource values.

Treatments adjacent to private land would afford firefighting forces an added margin of safety engaging

in fire suppression actions near homes. Scott (2003) found that designing canopy fuel treatments to

protect firefighters and homeowners in the wildland-urban interface need a crown-fire-free zone large

enough that tall flames from an active crown fire are unlikely to injure people protecting structures during

a fire. Collins (2010) stated larger individual treatments have a greater potential to reduce fire behavior

and slow fire spread, which ultimately impacts adjacent untreated stands and should enhance suppression

opportunities and increase firefighter safety. By treating these areas, they become more resilient to stand-

replacing wildfire and allow greater protection within the wildland-urban interface zone. National Forest

System lands and adjacent private lands would be positively affected from the reduction of hazardous

fuels and subsequent modification of potential fire behavior.

Deciduous stands often act as natural fire breaks and crown fires typically drop to the ground when they

enter an aspen stand. Fire spread is dependent on the amount and type of understory plants and shrubs.

Because of the usual absence of ladder fuels in deciduous stands, fire does not get carried to the high

crowns of these trees (Alberta Government 2012). Aspen enhancement in the project area would promote

the idea of utilizing natural vegetation as potential fuel breaks in the event of a wildfire. Aspen’s lush

understories along with the lack of ladder fuels would allow aspen stands to serve as natural fire breaks in

landscapes until conifers re-establish to sufficient sizes and densities to once again carry a crown fire

(Shepperd 2008).

Smoke. Prescribed burning treatments would have direct, short-term impacts on air quality in the project

area. Burning of landing piles and hand piles generally occur during late fall, early winter, or spring, and

typically after an area has received significant rain or snow to prevent the pile from spreading and reduce

the risk of escape. All burning operations are conducted under the guidelines set forth in a prescribed fire

burn plan developed by fire managers specifically for the project area. Prescribed burn plans address

parameters for weather, air quality, and contingency resources. All burning would occur over the life

cycle of the project. Transitory smoke could produce some smoky days in the local area, and may also

result in the form of nuisance smoke, smell, or haze. Smoke would also be expected to settle into the

lower draws and drainages during the evening hours following ignition. This would most likely occur

during the burn smoldering phase.

The purpose and need of the project is to reduce the current and future wildfire hazard to and from

adjacent communities by managing existing hazardous fuels on Federal lands. Wildfires present a risk to

public health and result in damage to both the environment and property. Wildfires are known to result in

high levels of emissions and associated NAAQS (National Ambient Air Quality Standards) violations.

Vegetation management treatments provide the opportunity on a long-term basis to reduce the magnitude

of wildfire air quality problems. According to Wiedinmyer and Hurteau (2010), wide-scale prescribed fire

application can reduce carbon dioxide fire emissions for the western U.S. by 18 to 25 percent. The total

amount of pollutants released by landing and hand pile burning under alternative 2 would be spread-out

over several years and would occur when emissions would be unlikely to have significant adverse effects

on human health and visibility. After implementation, it is estimated that subsequent wildfire ignitions in

the project area would produce less pollutants due to less fuel available to burn.


43


Past wildland fire events have had an effect on the landscape and will continue in the future. Decades of

fire suppression in many Western forests have resulted in high tree densities from infilling with shade-

tolerant, fire-sensitive tree species. Cumulative effects from wildfires and past management activities are

discussed in the existing condition section of this report. The existing condition has been influenced by

fire exclusion and historic fire activity, as well as natural and artificial activities including insects and

disease and past timber harvest. It is impossible to predict when a wildfire may occur in the future, or the

subsequent effects of that fire.

The proposed action combined with past, present, and future activities would complement other Forest

Service, State, and private fuel reduction treatments that have occurred or are occurring in the area. These

actions would collectively reduce fire behavior potential by removing surface, ladder, and crown fuels.

Other fuels reduction and vegetation management projects that have occurred within or adjacent to the

project area include the Eco 07, Eagle County, TOV Admin, and Vail Valley. These projects were

implemented in 2005 and 2006. There are several other fuels reduction projects that have occurred in the

surrounding area, and are shown in the appendix. There is an indeterminate amount of fuels reduction

activities (FireWise) work occurring on private lands adjacent to the project area. These combined

treatments would complement the purpose and need goals for fire and fuels management by reducing the

current and future wildfire hazard to and from adjacent communities.

Smoke. Cumulative effects on air quality as a result of landing and hand-pile burning associated with

alternative 2 would result in an incremental decrease in air quality as pollutants from this project combine

with other particles produced by other aspects of this project, including fugitive road dust. Emitted

pollutants from fire do have an effect on an area, which depends on atmospheric conditions at the time of

the fire. Pollutants from fires can be cumulative with emissions from many local and regional sources,

including other fires, woodstove burning, vehicles, industrial sources, and agriculture. Because of the

widespread and short-lived impacts of emissions from fire, no other projects were explicitly considered

for cumulative impact analysis. It is impossible to predict what pollution sources may be present at the

same time of pile burning at an unspecified date in the future.


The no-action alternative would not contribute to the desired condition or respond to the National Fire

Plan goals. The no-action alternative would also be unresponsive to the Healthy Forest Restoration Act

and the Eagle County Community Wildfire Protection Plan. In the long term, the no-action alternative

would not meet the purpose and need of this project, which includes reducing the current and future

wildfire hazard to and from adjacent communities.

The proposed action (alternative 2) would achieve goals set forth in the National Fire Plan and Healthy

Forest Restoration Act, and would comply with the direction set forth in the White River National Forest

Land and Resource Management Plan. All pile burning would be implemented in full compliance with

Colorado Air Pollution Control Division and the Federal Clean Air Act. In addition, the proposed action

would be responsive to the Eagle County Community Wildfire Protection Plan (2011) and promote the

collaborative effort occurring between Federal, State, city, and private stakeholders in the Vail

Community.


44

Canada Lynx

Existing Environment/Environmental Baseline

Status

The lynx was federally-listed as threatened on March 24, 2000. The U.S. Fish and Wildlife Service

concluded that the single factor threatening the contiguous U.S. Distinct Population Segment of lynx was

the inadequacy of existing regulatory mechanisms; specifically, lack of guidance for conservation of lynx

in National Forest land and resource management plans and BLM land use plans (U.S. Fish and Wildlife

Service 2008).

Natural History

Lynx occurs primarily in the boreal forests of Alaska and Canada, but its range extends south into the

northern portions of the western mountains, where environmental conditions at high elevations support

boreal forest habitats similar to those found in northern regions (Koehler and Aubry 1994). The primary

factor driving lynx behavior and distribution is the distribution of snowshoe hare, their primary prey (U.S.

Fish and Wildlife Service 2008).

Although snowshoe hares are the primary food for lynx throughout its range, they also feed on mice,

squirrels, grouse, and ptarmigan. The primary winter prey species of lynx in Colorado are snowshoe hare

and red squirrel, with other mammals and birds forming a minor part of the winter diet (Shenk 2004).

Older forests with a substantial understory of conifers or small patches of shrubs and young trees that

provide dense cover that touches the snow in winter, generally also provide good quality lynx foraging

habitat (U.S. Fish and Wildlife Service 2008). Such older stands may provide snowshoe hare habitat over

a longer time period than stands regenerating following a disturbance. Older stands also support red

squirrel populations, an important alternate prey species for lynx. Red squirrel densities tend to be highest

in older, closed-canopy forests with substantial quantities of coarse woody debris, and lower in young

stands that lack cone production (U.S. Fish and Wildlife Service 2008).

Den sites may be located within older regenerating stands (>20 years since disturbance) or in mature

conifer or mixed conifer-deciduous (typically spruce/fir or spruce/birch) forests (U.S. Fish and Wildlife

Service 2008). The age of the forest stand does not seem as important for denning habitat as the amount

of horizontal structure available (e.g., downed woody debris (Mowat et al. 2000). Lynx have generally

been thought to be nocturnal (active at night) or crepuscular (active at dawn and dusk), but some studies

have shown that lynx may be active at all hours (Ruediger et al. 2000).

Status within the Proposed Project Area

In an attempt to reestablish a viable population, the Colorado Division of Wildlife reintroduced 218 lynx

into the San Juan Mountains from 1999 to 2006 (Colorado Division of Wildlife 2006). As of May 25,

2009 (the last lynx update following the discontinuation of the lynx monitoring program), the Colorado

Division of Wildlife was tracking 42 of the 103 reintroduced lynx still possibly alive in the Southern

Rockies Ecosystem (Colorado Division of Wildlife 2009b). Additional animals are present in the

landscape, but it has become nearly impossible to determine the extent of the lynx population in Colorado

due to reproduction, failed collars, terminated radio tracking, and/or lynx outside of the research area

(Shenk 2006). There are 115 known mortalities and 62 missing animals (Colorado Division of Wildlife

2009b). Colorado Division of Wildlife biologists estimate the number of lynx in Colorado is holding

steady at about 150, with most in the southern mountains (Broderdorp, K., U.S. Fish and Wildlife Service

2008, personal communication, June 18, 2007; Colorado Division of Wildlife 2006). Reproduction has


45

been documented in 2003–2006 and 2009 scattered throughout the Southern Rockies Ecosystem (Shenk

2006, 2010; Andree, B., Colorado Division of Wildlife, personal communication). Between 2003 and

2010, a total of at least 141 kittens was born, including a Colorado born female that produced kittens in

2006 (Colorado Division of Wildlife 2006, 2010b). In 2010, the Colorado Division of Wildlife (2010)

announced that the lynx reintroduction project had successfully accomplished its goal of establishing a

breeding population in the Southern Rockies.

Based on the results from reintroduction and monitoring efforts to date, Colorado’s lynx reintroduction

has successfully achieved the program’s original goals and all benchmarks for successful lynx

reintroduction (Colorado Division of Wildlife 2010). Data collected during a decade of monitoring by

Colorado Division of Wildlife demonstrated that individual lynx can survive long term in at least some

parts of Colorado. Reintroduced lynx have, for the most part, remained in good habitat, have engaged in

breeding behavior, and have produced kittens that were recruited into the Colorado breeding population.

Estimated rates and trends in survival and recruitment seen over the first decade after reintroduction

began, if sustained over the coming decades, should be sufficient to maintain a lynx population of some

reasonable size in Colorado in at least the core reintroduction area without the need for additional

augmentation. Radio tracking is no longer occurring and passive monitoring has been tested and appears

successful. Colorado Parks and Wildlife biologists and researchers are currently working to develop

reliable ways of estimating habitat occupancy and lynx distribution as indices of occurrence. These

biologists are also working to create a proper balance between monitoring the persistence of lynx within

the core reintroduction area and lynx that may be pioneering and expanding their habitat into other

portions of the State. Lynx have been documented in the Eagle Valley Lynx Analysis Unit (LAU).

Eagle Valley Lynx Analysis Unit Baseline Conditions

The proposed Vail Intermountain Project occurs entirely within the Eagle Valley LAU; the Camp Hale

LAU is located adjacent to the southern boundary of the project area (Figure 9). The Eagle Valley LAU

includes the Town of Vail and is approximately 117,500 acres, with 10.2 percent mapped as currently

unsuitable.

Habitat Types within the Proposed Project Area

According to the White River National Forest lynx habitat types GIS layer, the project area boundary

contains less than 1 acre of Eagle Valley LAU denning habitat, 284 acres of winter foraging habitat, 5

acres of other habitat, 894 acres of unsuitable habitat (Table 13, Figure 10). The Camp Hale LAU is

located on the south side of the project area boundary and outside of the proposed cutting units.


46

Figure 9. Eagle Valley and Camp Hale lynx analysis units with respect to the Vail Intermountain Fuels Project Area


47

Table 13. Acres and percentages of lynx habitats within the project area boundary

Lynx Habitat Type Acres

Denning <1

Winter Foraging 284 (22%)

Other 6

Currently Unsuitable 894 (69%)

Total Lynx Habitat 1,185 (92%)

Non-habitat 106 (8%)

Private Land

Total Acres 1,291 (100%)

FSVeg spatial database cover types within the project area include forested (54 acres), grass (19 acres),

true aspen (430 acres), true Douglas-fir (3 acres), and true lodgepole pine (889 acres). Lodgepole pine is

one of the most dominant cover types across the project area. Stands are primarily mature, ranging from

100 to 150 years old, except where past forest management activities have occurred (project Silviculture

Report). Aspen stands are the second-most abundant cover type within the Vail Intermountain Project

Area. Aspen is a fast-growing, short-lived species that is quick to occupy disturbed sites. The majority of

the cover type within the analysis area is comprised of small- to medium-diameter trees with moderately

dense canopy cover. Stands within the analysis area may exhibit a variety of damaging agents including

insects, diseases, Sudden Aspen Decline, or browsing damage by elk, deer, or moose (project Silviculture

Report). Proposed treatment units are primarily lodgepole pine and aspen.

Field verification of the project area by White River National Forest wildlife biologists showed high

lodgepole pine mortality with very little horizontal cover (appendix B, Vail Intermountain Fuels Project

Biological Assessment). Canopy was estimated at 50 to 70 percent dead. Therefore, based on the low

quality of habitat observed during the site visit, the amount of mapped unsuitable lynx habitat (Table 14)

in the project area appears to be accurate. Most aspen patches did not show regeneration in the

understory.

Similarly, reconnaissance plots established in the project area during the 2014–2015 season showed high

lodgepole pine mortality (unit 1, 42 percent; unit 2, 56 percent; unit 3, 72 percent; unit 4, 46 percent; unit

5, 60 percent). Stand exam data collected within the analysis area in 2015 showed the majority of the

aspen cover type within the analysis area was comprised of small- to medium-diameter trees with

moderately dense canopy cover (project Silviculture Report).

The treatment units, alone, contain less than 1 acre of denning habitat, roughly 75 acres of winter foraging

habitat, less than 4 acres of other habitat, and 239 acres of unsuitable habitat (Table 14). Denning and

“other” lynx habitat will be eliminated from further discussion for the remainder of this analysis because

denning habitat makes up less than 1 acre within the project area as a whole and other lynx habitat makes

up less than 5 acres of the treatment units and project area as a whole.


48

Figure 10. Eagle Valley Lynx Analysis Unit, including lynx habitat types


49

Table 14. Acres and percentages of lynx habitats by treatment unit

Treatment Unit

Denning Habitat (Acres)

Winter Foraging

Habitat (Acres) Other Habitat

(Acres) Unsuitable

Habitat (Acres) Total Acres

1 0 34 (11%) 1 (<1%) 73 (23%) 108 (34%)

2 0 2 (<1%) <1 (<1%) 24 (8%) 26 (8%)

3 <1 (<1%) 1 (<1%) <1 (<1%) 91 (29%) 95 (29%)

4 <1 (<1%) 38 (12%) <1 (<1%) 29 (9%) 68 (21%)

5 0 <1 (<1%) 0 (<1%) 22 (7%) 22 (7%)

Total Acres 1–2 (<1%) 75–76 (24%) 1–4 (<1%) 239 (76%) 319 (100%)

Habitat Connectivity (Linkage Areas)

Linkage areas provide landscape connectivity between blocks of lynx habitat. Linkage areas occur both

within and between geographic areas, where blocks of lynx habitat are separated by intervening areas of

non-lynx habitat such as basins, valleys, or agricultural lands, or where lynx habitat naturally narrows

between blocks (USDA Forest Service 2008). A portion of the project area (818 acres), and treatment

units 1, 2, and 3 specifically (about 229 acres), overlaps with the Dowd Junction Linkage Area.

Snow Compaction Designation

The Southern Rockies Lynx Amendment provided a programmatic conservation standard: on Federal

lands in lynx habitat, allow no net increase in groomed or designated over-the-snow routes and

snowmobile play areas by lynx analysis unit. This standard does not apply to existing ski areas, which are

already heavily compacted from existing winter recreational uses. These areas include snow cat ski areas,

trails authorized for special-use winter recreational outfitter/guide use, commonly used trails accessing

back country huts and snow play areas commonly used near those huts, winter roads to private in

holdings, and permitted roads and trails where grooming is allowed.

Snow Compaction in the Eagle Valley Lynx Analysis Unit

The Eagle Valley LAU includes 15,526 acres of snow compaction areas, including the roughly 12,000-

acre Vail Pass Winter Recreation Area, and 117 miles of snow compaction routes.

Snow Compaction in the Proposed Project Area

A limited amount of snow compaction routes occur within the project area: a small portion (0.05 miles) of

route 7-N3059 overlaps with treatment unit 4. In addition, the 50-acre Chair 20 compaction area is

located within the project’s northeastern boundary. It overlaps with a small, approximately 2-acre portion

of treatment unit 4, mapped as winter foraging habitat. It completely overlaps with treatment unit 5,

which is mapped as unsuitable lynx habitat.



By definition, direct and indirect effects (40 CFR 1508.8) and cumulative effects (40 CFR 1508.7) result

from the proposed action, and thus are not germane to the no-action alternative.

If no action is taken, the relative amounts of Canada lynx habitat within the Eagle Valley Lynx Analysis

Unit, the project area, and the treatment units (Table 13, Table 14, and Table 15, respectively) could

change in the short term to long term. As moderate to high levels of tree mortality in lodgepole pine


50

continue to contribute to current and future hazardous fuels, as the continuous canopy of mature

lodgepole pine in the project area continues to increase the risk of a running crown fire, and as aspen

within the project area continues to mature and be succeeded by conifer tree species preventing these

stands from acting as effective natural fuel breaks, the greater the likelihood of wildfire capable of

converting suitable lynx habitat within the project area (primarily winter foraging and linkage habitat),

and perhaps the surrounding area, to unsuitable habitat.



Acres and percentage of habitat within the project area and lynx analysis unit with potential for

direct effects (disturbance or displacement of individuals from helicopter yarding, hand treatments,

felling, limbing, bucking, piling, burning, clearing of haul routes, fuels surveys, or monitoring).

Project design features limit implementation to July 1 to October 15; hence, linkage habitat would be the

only habitat type in which there would be potential for disturbance from noise and human presence to or

displacement of lynx, or red squirrels, their primary prey, during helicopter yarding, hand treatments,

felling, limbing, bucking, piling, or burning. The possibility for this type of impact would be greatest

within the 229 acres (28 percent) of the 818 acres of Dowd Junction Linkage Area that overlaps treatment

units 1, 2, and 3. However, it could extend somewhat beyond the treatment units, affecting an additional

portion of the 818 acres of linkage area overlapping with the 1,291-acre project area. Although it is

difficult to determine the flight path for helicopter logging operations, the area in between the project area

and the three landings is a combination of linkage habitat, winter foraging habitat, unsuitable habitat and

non-habitat. In addition, project implementation would require clearing of haul routes along existing

roads on National Forest System lands and Colorado Parks and Wildlife property; this activity has the

potential to contribute a minor amount of noise-based disturbance or displacement of lynx.

Again, lynx utilizing linkage habitat would be those that could be subject to disturbance-based impacts.

However, due to the generally nocturnal and/or crepuscular tendency of the species, individual lynx

within the project area would be inactive during daylight hours when project activities are occurring. The

potential for noise- or human-based disturbance or displacement would be specific to individual lynx and

short term and, therefore, generally insignificant overall.

Acres and percentage of habitat within the project area and lynx analysis unit with potential for

snow compaction. Limiting project implementation from July 1 to October 15 would prevent any

additional snow compaction within the project area.

Acres and percentage of habitat within the project area and Lynx Analysis Unit altered by type.

Within the 319 acres across the five proposed treatment units, 194 acres would be treated (Table 13 and

Table 14). Unit 5 does not contain habitat currently suitable for lynx and units 2 and 3 each contain less

than 1 percent of the total habitat suitable for lynx in the treatment units and, subsequently, less than 1

percent of total suitable habitat in the project area boundary and lynx analysis unit boundary. The two

remaining units, 1 and 4, do not contain lynx denning or other lynx habitat. However, unit 1 contains 34

acres of lynx winter foraging habitat and unit 4 contains 38 acres of winter foraging habitat. Lynx winter

foraging habitat in unit 4 would only be treated by removing individual dead aspen trees; the winter

foraging habitat in unit 1 would be treated using all four of the proposed prescription types. However, the

majority would be treated by removing individual dead aspen trees. Of the lynx habitat within the 1,291

project area boundary, only 25 percent of lynx winter foraging habitat would be temporarily altered, but it

would not be converted to unsuitable habitat. This would be significantly less than 1 percent (0.3 percent)

of lynx winter foraging habitat within the Eagle Valley LAU (Table 14). The majority of the proposed

action occurs within currently unsuitable habitat. Treatments would increase the density of regeneration


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when it begins to grow back, which ultimately accelerates the development of suitable lynx habitat.

Because of the existing stand conditions and the nature of treatment within stands containing functioning

habitat, no conversion of suitable habitat to an unsuitable condition is anticipated. Barring wildfire, or

other major disturbance, classification of lynx habitat would remain the same in the Eagle Valley LAU as

shown in Table 14.

In addition, the Colorado Parks and Wildlife landing consists of aspen; up to 2 acres of aspen would be

cleared. The National Forest System landing is currently open and would not require additional clearing.

The Colorado Parks and Wildlife landing is located in lynx winter foraging habitat; the national forest

landing in non-habitat. As previously noted, project implementation would not occur during the winter

and, therefore, would not affect winter foraging of lynx.

Removing dead lodgepole trees would improve growing conditions for remaining trees. This would lead

to more healthy, mature, cone-bearing trees within the next 10 to 20 years which would ultimately

improve red squirrel habitat.

Linkage Area Effects. As previously described, units 1, 2, and 3 are located within the Dowd Junction

Linkage Area (f). Treatments in those units are isolated to lodgepole and aspen, the dominant cover types

in the project area, and include the removal of individual trees and patch cuts of less than 10 acres. The

Dowd Junction Linkage Area overlaps with mapped unsuitable lynx habitat, though there are patches of

winter foraging and denning that exist on the edges of the units. The project would temporarily alter

vegetation structure by removing dead trees and patches of aspen and lodgepole pine. In addition, foot

traffic associated with chainsaw use and pile burning may temporarily reduce the herbaceous understory.

However, given the lack of conifer regeneration in the area and openness of the stands, it likely is not

highly functioning habitat for lynx or snowshoe hare because there is a lack of understory cover for

snowshoe hares from predators. The units do provide red squirrel habitat, so may temporarily reduce

abundance of this secondary prey resource for traveling lynx. The removal of dead trees may reduce pine

squirrel nesting sites (i.e., tree cavities). Yet patch cut and individual tree removal would facilitate growth

of live cone-bearing trees by opening the canopy, resulting in an increase in cone availability important to

red squirrels. Overstory tree cover would remain due to the small size of the patch cuts. Salvage

operations would facilitate regeneration, improving cover and thus the functionality of the linkage area.

In summary, treatments in a combined area of up to 57 percent of units 1, 2, and 3 would result in a

mosaic of conditions, some of which would temporarily open forest canopy, but maintain sufficient cover

to maintain connectivity for lynx through the linkage area.

Cumulative Effects


The spatial boundary for cumulative effects analysis to lynx is the Eagle Valley Lynx Analysis Unit

because the LAUs are pre-determined analysis unit upon which direct, indirect, and cumulative effects

analyses are evaluated for Canada lynx. This project would not result in additional potential for snow

compaction and it would not result in the conversion of currently suitable habitat to unsuitable habitat.

Therefore, the types of projects relevant to the cumulative effects analysis for this action are those past,

present, and reasonably foreseeable actions that, along with the proposed action, could cumulatively

affect Canada lynx through disturbance or displacement, or result in the temporary alteration of habitat.

Vegetation management projects that could additively impact lynx when combined with the Vail

Intermountain Project were provided by the Forest (appendix C, Vail Intermountain Fuels Project

Biological Assessment). The proposed action would increase the total number of acres affected by


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relatively recent vegetation management activities from 233 to 428 or well under less than 1 percent of

total lynx habitat within the Eagle Valley LAU.

Although privately-held lands are not factored into total lynx habitat (Table 13), undeveloped private

lands may provide some habitat value to lynx. Present and foreseeable future projects planned for

privately-held lands within the Eagle Valley LAU with the potential to disturb or displace Canada lynx

include the following:

Red Draw Ranch Special Use (wedding events venue): In the new application phase; a 74-acre

parcel (multiple parcels under same ownership) located on West Squaw Creek and bordering

Cordillera Planned Used Development and BLM. The proposal is for an events venue (weddings

on weekends, corporate events during week days/nights) for groups up to 300 people, with hours

of operation capped at 11 p.m. and noise ordinance controls impacting music (off at 10:30 p.m.).

Frost Creek (previously Adams Rib Ranch): Located on Brush Creek Road, south of Eagle;

approved several years ago, it has been on hold until recently. The development is under new

ownership and there is a proposal to increase density.

Tree Farm Planned Used Development: Located in the El Jebel area, directly adjacent to Highway

82, and near BLM and Lake Christine Wildlife Area on Basalt Mountain. This is a large, mixed-

use planned used development currently making its way through the preliminary plan approval

process. It includes 400 units, with the majority of density and commercial use located next to

Highway 70.

In summary, the overall cumulative effect on lynx of the Vail Intermountain Project, when combined with

other projects with potential for similar effects on State and privately-held lands, would be insignificant

relative to the size of the Eagle Valley LAU.

Determination of Effects

The Vail Intermountain Fuels Reduction Project may affect, but is not likely to adversely affect Canada

lynx or its habitat. The project has the potential to directly impact individual Canada lynx, primarily

within linkage habitat, through short-term, noise-based disturbance or displacement. The project also has

the potential to temporarily alter vegetation structure. However:

It is expected to maintain connectivity within the linkage area;

The project area contains less than 1 acre of mapped denning habitat;

No lynx habitat would be converted from suitable to unsuitable as a result of vegetation

management activities; and

The activities occur outside of the winter and early spring, critical periods for lynx.


This project is compliant with the White River LRMP and other relevant laws, regulations, policies and

plans, as documented in the biological assessment, table 11including:

The Southern Rockies Lynx Amendment Record of Decision;

The 2008 U.S. Fish and Wildlife Service Southern Rocky Mountains Lynx Assessment;

The Endangered Species Act;

FSM 2600 Direction for Wildlife, Fish, and Sensitive Plant Habitat Management;

Chapter 2670 – Threatened, Endangered and Sensitive Plants and Animals; and


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The Migratory Birds EO 13186 of January 10, 2001.

Other Wildlife

Methodology

Habitat requirements for species occurring on the Region 2 Regional Forester’s Sensitive Species list and

White River National Forest management indicator species, species of concern, and species of viability

concern lists were compared against habitat types occurring in the project area. Species without suitable

habitat occurring in the project area were eliminated from further consideration; those with suitable

habitat within the project area were carried forward for additional analysis. Habitat verification and field

surveys were done by the White River National Forest. Wildlife habitat information was provided to the

project wildlife biologist in the form of photos, field notes and project Vegetation Management Report.

Species’ range, habitat, threats, and existing condition information was determined using the best

available scientific literature and field survey notes. The effects for wildlife species were analyzed by

comparing Vail Intermountain Fuels Reduction Project actions against the most limiting habitat factors for

each species to determine the likely effects or impacts of those actions. Based on issues identified by the

public, the effects of helicopter noise on wildlife species identified above were also be disclosed and

analyzed.


Table 15 is a summary comparison of environmental effects to Forest Service sensitive species,

management indicator species, and species of concern. The full Biological Evaluation and Management

Indicator Species and Migratory Birds Report is in the project record located at the Eagle-Holy Cross

Ranger District office in Minturn, Colorado.


This project is compliant with the White River LRMP and other relevant laws, regulations, policies and

plans, as documented in the biological evaluation, table 17.


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Table 15. Summary comparison of environmental effects and determination for Forest Service sensitive species, management indicator species and species of concern

Species and Determination Resource Indicator Alternative 1 Alternative 2

Regional Forester’s Sensitive Species

American Marten

Because of the lack of denning habitat and the small amount of foraging and connectivity habitat that would be altered, the Vail Intermountain Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing.

Potential for disturbance to or displacement of individuals from helicopter yarding, road maintenance/use, regeneration and fuels surveys/monitoring, and other project-related noise, commotion, or disruption

NA: no action Because marten habitat within the project area consists of foraging and connectivity habitat, impacts to individuals would be limited to those moving through the area and impacts would primarily occur within the 319 acres of treatment units (25% of the project area). Noise-based disturbance or displacement to individuals from human presence and noise associated with chainsaws, helicopters, and roads activities would be minor and short-term and noise would presumably alert individuals so most would be able to avoid injury or mortality.

Potential for habitat alteration

Under the no-action alternative, the fuel hazard would not be reduced. Dead or dying trees would not be removed and would contribute to the current and future fuel hazard. Suitable marten habitat could be eliminated in the event of high severity wildfire. Natural fuels (downed wood and other dead vegetation) would not be removed and would continue to accumulate. In the absence of wildfire, natural processes of decay are not likely to remove the down and dead woody debris before the next fire cycle, so over time marten could benefit from increases in red-backed voles due to increased coarse woody debris accumulations associated with the mountain pine beetle epidemic (Saab et al. 2014).

In addition, there could be an increase in marten resting habitat or in denning habitat in localized areas that may contain large-diameter trees suitable for dens. Restriction of recruitment of conifer seedlings by increased sunlight and resulting forb growth could slow the development of young trees and associated canopy/overhead cover required by

Removing dead lodgepole trees would temporarily open canopy that could negatively alter suitable marten habitat by reducing overhead cover. However, the expected improvement in growing conditions for remaining trees that would lead to more healthy mature, cone-bearing trees within the next 10–20 years would ultimately improve marten and red squirrel habitat. Removal of accumulations of coarse woody debris could locally (within the treatment units) impact marten foraging habitat by degrading red-backed vole habitat in the short term. However, the benefit of removing these accumulations that also act as hazardous fuels may outweigh this impact.

Cumulative Effects: Based upon the cumulative effects information in appendix A, since the early 1980s, vegetation management activities have been completed on approximately 4% of the analysis area. Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of


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marten and cone production that supports red squirrels, a preferred marten prey species.

managed acres to 7% of the analysis area. As previously described, the project area lacks marten denning and resting habitat and proposed vegetation treatments would result in minor, short-term disturbance to or displacement of foraging or traveling individuals. Therefore, the cumulative effect of disturbance or displacement of martens from the proposed action, when combined with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Pygmy Shrew

Because of the lack of preferred pygmy habitat within the project area and the resulting unlikelihood for disturbance, displacement, injury or mortality to individual pygmy shrews, the Vail Intermountain Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing.

Potential for disturbance to or displacement of individuals from helicopter yarding, road maintenance/use, regeneration and fuels surveys/monitoring, and other project-related noise, commotion, or disruption, or potential for injury/mortality to individuals

NA: no action Based upon the amounts of pygmy shrew habitat (lodgepole pine and aspen) within the treatment units and project area, disturbance, displacement, injury, or mortality of individuals could occur within up to 15% of the project area.

However, given the lack of preferred pygmy shrew habitat (spruce fir), the probability of mortality, injury, disturbance, or displacement to individuals from project-related actions, although possible, would be unlikely, and minor and discountable with respect to the population as a whole.


The likelihood of occupancy of the area by pygmy shrews is very low. As a result, taking no action would likely have little impact on pygmy shrew. However, under the no-action alternative treatments expected to improve growing conditions within the lodgepole cover type would not occur and the current higher probability of loss of the cover type to high-severity wildfire would continue.

Based upon the amounts of lodgepole pine and aspen within the treatment units and project area, up to 15% of low quality pygmy shrew habitat could be altered within the project area. However, this estimate does not take fine-scale habitat components (wet boggy, marsh-like areas) into account, so the amount of suitable pygmy shrew habitat within the project area with potential for project-related impacts would actually be much lower.

Cumulative Effects: Based upon the cumulative effects information in appendix A, since the early 1980s, vegetation management activities have been completed on approximately 4% of the analysis


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area. Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area. As previously described, proposed vegetation treatments would have a limited impact to pygmy shrews because fine-scale habitat attributes are largely absent from the project area. Therefore, the cumulative effect of disturbance, displacement, injury, or mortality to pygmy shrews from the proposed action, when combined with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Hoary Bat

Because of the small amount of preferred hoary bat habitat with the potential for disturbance, displacement, injury or mortality to individuals in the treatment units, as well as the potential short-term benefit to hoary bat habitat, the Vail Intermountain Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing.


NA: no action Based upon the amounts of lodgepole pine and aspen within the treatment units and project area, up to 15% of hoary bat habitat could be altered and the potential for disturbance, displacement, or injury/mortality to individual bats roosting within the tree canopy could occur within up to 25% of the project area.

However, this overestimates the amount of suitable habitat because it does not take fine-scale habitat components (forest edge) into account; the amount of suitable hoary bat habitat within the project area with potential for impacts would actually probably be much lower.


Under the no-action alternative natural processes would be expected to continue and the harvesting of dead, dying, and susceptible lodgepole pine and aspen trees would not occur. Hoary bat roosting habitat in the project area is very limited and is not

expected to change within the next 1020 years. Herbaceous vegetation would benefit from the mortality created by the mountain pine beetle (Stone and Wolfe 1995, in project Vegetation Report) because increased sunlight associated with lodgepole pine mortality would increase herbaceous productivity. Therefore, under the no-action

Alternative 2 would treat 194 acres of lodgepole pine and aspen within the 319 acres of five treatment units. Based upon the amounts of lodgepole pine and aspen within the treatment units and project area, up to 15% of hoary bat habitat could be altered and the potential for disturbance, displacement, or injury/mortality to individual bats roosting within the tree canopy could occur within up to 25% of the project area.

However, this overestimates the amount of suitable habitat because it does not take fine-scale habitat


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alternative, hoary bat-preferred foraging habitat could increase in the short term as new forest edge habitat is created as herbaceous productivity increases and dead trees continue to fall.

components (available roosting habitat and forest edge) into account; the amount of suitable hoary bat habitat within the project area with potential for impacts would actually probably be much lower. In addition, the project targets dead lodgepole pine which is not used for roosting habitat. Like the no-action alternative, the action alternative would create short-term forest edge, particularly as the result of lodgepole patch clearcut and aspen coppice cut, which would improve hoary bat foraging habitat in the short term. However, the results would be more immediate and likely in larger patches.

Cumulative Effects: Vegetation management activities have been completed on approximately 4% of the analysis area since the early 1980s (appendix A). Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area (appendix A). Given the small percentage of the analysis area impacted by these types of activities over time, disturbance, displacement, injury, or mortality to individual hoary bats would not have a significant cumulative impact on the population. In addition, proposed action treatments would, overall, improve hoary bat habitat in the short term. Therefore, the cumulative effect of changes in hoary bat habitat from the proposed action, when combined with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Boreal Owl

Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing for

Potential for disturbance to or displacement of individuals from helicopter yarding, road maintenance/use, regeneration and fuels

NA: no action Because the project and boreal owl analysis areas lack spruce-fir cover type, roosting habitat is marginal. Minor, short-term disturbance to or displacement of individual roosting boreal owls would be the most likely impact to the species. Alternative 2 would treat 194 acres of lodgepole pine and aspen within the 319 acres of treatment


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boreal owls due to the lack of suitable nesting or foraging habitat, marginal roosting habitat, and the resulting low probability of minor, short-term disturbance to individuals.

surveys/monitoring, and other project-related noise, commotion, or disruption

units. The potential for noise-based disturbance and/or displacement, particularly from helicopter logging operations, of roosting boreal owls would be greatest within the 319 acres of treatment units, themselves (6% of the boreal owl analysis area), but could include portions of the 1,291-acre project area or the 5,800-acre Lower Gore Creek–West Vail 6

th-field watershed boreal owl analysis area.


Given the lack of preferred large spruce and aspen within the project and boreal owl analysis areas, habitat within the project area is marginal. Therefore, the likelihood of use of the area by boreal owls is limited. As a result, taking no action would likely have little impact on the boreal owl. Areas dominated by an aspen overstory would continue to be dominated by aspen in the short term. Localized tree mortality within aspen stands is common and would continue to occur under the no-action alternative.

Boreal owl habitat within the treatment units and the analysis area is primarily limited to roosting habitat. In Idaho, where owls selected forest with particular structural features, especially during summer (Hayward et al. 1993), study results suggest that a reduction in the abundance or distribution of mature and old spruce-fir forest sites could limit roost sites during summer. Because cool roost locations dispersed throughout the home range may be important in boreal owl thermoregulation, a reduction in the quality of roost sites may influence owl survival rates. Forest change involving type conversion (shift in tree species composition) could similarly influence roosting habitat. Old spruce-fir forest would provide a greater degree of microhabitat amelioration than old lodgepole pine forest. Because the project and boreal owl analysis areas lack spruce-fir cover type, roosting habitat is marginal and proposed vegetation treatments would have little bearing on roosting habitat.

Cumulative Effects: Based upon the cumulative effects information in appendix A, since the early 1980s, vegetation management activities have been completed on approximately 4% of the analysis area. Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area. As previously described, proposed vegetation treatments would, at most, result in minor, short-term disturbance to or displacement of individual roosting boreal owls because preferred nesting and


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foraging boreal owl habitat is absent from the project and boreal owl analysis areas and roosting habitat is marginal. Therefore, the cumulative effect of disturbance or displacement of boreal owls from the proposed action, with other past, present and reasonably foreseeable projects in the analysis area, would not be significant.

Flammulated Owl

Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing for flammulated owls due to marginal available habitat and the resulting low probability of minor, short-term disturbance to individuals.


NA: no action The project area lacks high-quality flammulated owl aspen cavity nesting habitat and preferred roosting and foraging habitat is absent. Therefore, impacts would be limited to minor, missed/failed breeding or short-term disturbance to or displacement of individual roosting owls and unlikely. Alternative 2 would treat only 72 acres of aspen within the 1,291-acre (approximately 6%) project area and injury or mortality to individuals would generally be limited to this area. The potential for noise-based disturbance and/or displacement, particularly from helicopter logging operations, would be greatest within the 319 acres of treatment units, themselves (25% of the project area/flammulated owl analysis area), but could include other portions of the 1,291-acre project area.


Given marginal flammulated owl habitat within the project area, the likelihood of use by flammulated owls is limited. As a result, taking no action would likely have little impact on flammulated owls. Areas dominated by an aspen overstory would continue to be dominated by aspen in the short term. Localized tree mortality within aspen stands is common and would continue to occur under the no-action alternative.

Nesting habitat could be removed in already marginal habitat if larger individual dead trees suitable for nesting are removed. Coppice cut may result in regeneration that provides young aspen, thereby improving foraging habitat.

Cumulative Effects: Based upon the cumulative effects information in appendix A, since the early 1980s, vegetation management activities have been completed on approximately 4% of the analysis area. Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area. As previously described, proposed vegetation treatments would, at most, result in minor, short-


60


term disturbance to or displacement of individual roosting flammulated owls because available habitat is marginal. Therefore, the cumulative effect of disturbance or displacement of flammulated owls from the proposed action, with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Northern Goshawk

Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing because the amount of suitable goshawk habitat within the analysis area that would be treated would be less than 3% of the analysis area, treatments would improve growing conditions that facilitate mature trees in the long term, and limited operating periods would prevent noise-based disturbance to breeding goshawks.

Potential for disturbance to or displacement of individuals from helicopter yarding, road maintenance/ use, regeneration and fuels surveys/ monitoring, and other project-related noise, commotion, or disruption

NA: no action Although nesting goshawks within the immediate vicinity of the treatments could be subject to noise-based disturbance related to project implementation, LRMP direction requires protection of known active and inactive raptor nest areas. Prior to project implementation, annual raptor nesting surveys will be performed within the project area and a no disturbance buffer ½-mile around active northern goshawk nest sites will be required from March 15 – July 15, unless it is determined that the birds are habituated to human disturbance. This would mitigate the potential for noise-based disturbance to nesting goshawks by project-related activities.


Under the no-action alternative, suitable goshawk habitat could be eliminated in the event of high severity wildfire. In the absence of wildfire, restriction of recruitment of conifer seedlings from increased herbaceous productivity could impact goshawk habitat in the long term by slowing the development of mature trees and associated canopy/overhead cover required by goshawks and cone production that supports goshawk prey base.

Under the proposed action, 194 acres of aspen and lodgepole pine (3% of the goshawk analysis area) would be treated. As previously described, goshawk nesting habitat within the analysis area is very limited. Removing dead lodgepole trees would temporarily open canopy that could negatively alter suitable goshawk habitat by reducing overhead cover. However, this would occur within only 194 acres (3% of the lodgepole pine and aspen cover types within the analysis area) and the expected improvement in growing conditions for remaining trees that would increase the amount of healthy, mature, trees within the next 10–20 years would improve goshawk habitat.

Cumulative Effects: Vegetation management activities have been completed on approximately 4% of the analysis area since the early 1980s (appendix A). Of the 4%, the majority of treatments


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were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area (appendix A). As previously described, goshawk nesting habitat within the analysis area is very limited, a seasonal limited operating period would prevent disturbance to nesting goshawks, and short-term reduction of canopy cover would be outweighed by the benefit of overall improvement in habitat. Similar treatments listed in appendix A would likely have had similar short-term and long-term habitat impacts and benefits, respectively. Therefore, the cumulative effect of changes in goshawk suitable habitat from the proposed action, when combined with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Olive-sided Flycatcher

Project may adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor cause a trend toward Federal listing because the amount of suitable olive-sided flycatcher habitat within the analysis area that would be treated would be less than 3% of the analysis area, disturbance-based impacts would largely be confined to 6% of the analysis area, and treatments would provide canopy gaps and forest edge that improve olive-sided


NA: no action Although olive-sided flycatchers primarily nest in live conifers, they also utilize dead and dying conifers. Therefore, proposed treatments have the potential to damage or destroy individual nests or nesting trees within the 194 acres of treatment units (3% of the olive-sided flycatcher analysis area). In addition, short-term, noise-based disturbance associated with treatments could impact nesting or foraging individuals, primarily within the 319-acre project area boundary (6% of the analysis area).


Localized tree mortality within aspen stands is common and would continue to occur under the no-action alternative; dead lodgepole pine trees located within these stands would be expected to fall to the

ground over the next 520 years (project Vegetation Report). As individual trees fall to the ground, gaps created within the canopy would improve foraging

Treatments that remove individual and small groups of dead and dying trees and remove patches of lodgepole pine and aspen would improve olive-sided flycatcher habitat over a shorter period of time and over a larger area than the no-action alternative by mimicking natural disturbance events that create canopy gaps and forest edges and openings. In addition, olive-sided flycatcher habitat would benefit


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flycatcher habitat in the short term.

conditions for olive-sided flycatchers.

Wildfire occurring as the result of the increase in standing dead trees and increased concentrations of coarse woody debris could benefit olive-sided flycatcher habitat by providing additional forest openings, increased edge habitat, the availability of snags, and associated prey, provided it does not burn with high severity in which case olive-sided flycatcher habitat would be eliminated until stands regenerate.

from treatments that could prevent stand destroying, high-severity wildfire.

Cumulative Effects: Vegetation management activities have been completed on approximately 4% of the analysis area since the early 1980s (appendix A). Of the 4%, the majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the percent of managed acres to 7% of the analysis area. Given the small percentage of the analysis area impacted by these types of activities over time, disturbance or displacement of individuals or damage to or destruction of individual nests would not have a significant cumulative impact on the population. In addition, proposed action treatments would, overall, improve olive-sided flycatcher habitat over a shorter period of time and over a larger area than the no-action alternative and olive-sided flycatcher habitat would benefit from treatments that could prevent stand destroying high-severity wildfire similar to other past, present, and reasonably foreseeable actions that reduce(d) hazardous fuel loads. Therefore, the cumulative effect of changes in olive-sided flycatcher habitat from the proposed action, when combined with other past, present, and reasonably foreseeable projects in the analysis area, would not be significant.

Management Indicator Species

Rocky Mountain Elk

Potential for disturbance to or displacement of individuals from helicopter yarding, road maintenance/use, regeneration and fuels surveys/monitoring, and other project-related noise,

NA: no action All of the units overlap with elk winter range; treatment unit 1 overlaps with elk winter concentration areas and severe winter range. Based on Colorado Parks and Wildlife recommendations, a seasonal restriction would be

applied from October 16June 30, annually, to minimize disturbance to deer and elk within their migration corridor and on winter range. However, the entire project area is located in elk summer range, so elk could be subject to disturbance or


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commotion, or disruption

displacement within that area during project implementation.


Under the no-action alternative natural processes would be expected to continue and the harvesting of dead, dying, and susceptible lodgepole pine and aspen trees would not occur. As previously described, herbaceous vegetation would benefit from the mortality created by the mountain pine beetle. Increased sunlight associated with lodgepole pine mortality would increase herbaceous productivity, which can in turn restrict recruitment of new conifer seedlings. Therefore, under the no-action alternative, elk habitat could increase in the short term as new forest edge habitat is created as herbaceous productivity increases and dead trees continue to fall. Habitat would be more susceptible to stand-replacing wildfire that could benefit elk by increasing summer forage.

The proposed action would have short-term impacts to elk habitat by reducing thermal cover across the area of the treatment units. Cover would improve over the long term as regeneration progresses. Reducing the tree cover in the project area would increase sight distances, but also reduce the sense of security of individual animals. Given the level of recreational use of the adjacent area, the reduction in security cover may directly affect elk use of the area during the winter if recreational use of the area increases as the result of the proposed action. However, design features such as signage and barriers would be included to help prevent winter recreation use and allow for ticket writing if unapproved recreation use does happen. These design features would reduce the potential for adverse impacts to big game species until the aspen regenerate in the cleared areas. Conversely, treatments that remove individual and small groups of dead and dying trees and remove patches of lodgepole pine and aspen would improve forage availability over a shorter period of time and over a larger area than the no-action alternative by creating more canopy gaps and forest edges and openings that lead to an increase in forage species. No new roads would be constructed for this project.

Vegetation management activities have been completed on approximately 233 acres within the analysis area since the early 1980s (appendix A). The majority of treatments were related to creating defensible space and reducing hazardous fuel loads. Implementation of the proposed action would increase the number of managed acres to 428 within the analysis area (less than 1% of the analysis area). Given the small percentage of the analysis area impacted by these types of activities over time, they would not have a significant cumulative impact on elk.


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Recreation


Existing Conditions

The project area is located within the Game Creek Colorado Roadless Area adjacent to the Vail Mountain

Special-use Permit area. Refer to Figure 1 for a map of the project area. Interstate 70 (I-70) is just north of

the project are boundary. Residential areas and private lands lie between the project area boundary and I-

70. Due to limited access and the recreational opportunity spectrum setting, little recreation use occurs in

the project area. Recreation use includes hiking and mountain biking along the non-system Matterhorn

Trail that runs through the project area. The Matterhorn Trail connects to the Game Creek Trail just inside

of the southeast border of the project area. A small amount of skiers drop into the project area as they exit

the Vail Mountain Special-use Permit area at the Upper Simba ski area exit. This is not a destination area

for skiers since terrain is difficult and the bottom portion of the project area is fringed by private lands.

The White River National Forest uses the recreation opportunity spectrum (ROS) to manage recreation

opportunities and where those activities may occur. The ROS setting within the project area is semi-

primitive non-motorized covering 1,291 acres. These areas provide naturally appearing settings with

minor interaction of visitors and minor evidence of other users exists. Motorized activities are not

permitted.

The Vail Mountain Special-use Permit authorizes many recreation opportunities including (but not limited

to) mountain biking, hiking, skiing, and snowboarding. Figure 11 shows the Vail area at the start of the

2015 ski season. Additional recreation opportunities such as zip lines, rope courses, tubing, and mountain

tours, are offered at Adventure Ridge within Vail Mountain Special-use Permit area.

Figure 11. Adventure Ridge on a mid-week day during the winter at the Vail Ski Resort


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Dispersed hiking and mountain biking would continue along the non-system Matterhorn Trail. Recreation

activities would continue within the Vail Mountain Special-use Permit area. The risk of fire changing the

recreation setting would remain.

Since there are no proposed activities, there are no cumulative effects.



With the design features implemented, no direct effects to recreationists would occur within the project

area boundary since the unauthorized Matterhorn Trail would be closed during project implementation.

No changes to ROS classes would take place within the project boundary. No changes are anticipated to

the recreation setting within the Game Creek Roadless Area.

Helicopter yarding to and log hauling from the landing within the Vail Mountain Special-use Permit area

would displace some recreationists who seek hiking and mountain biking opportunities along the haul

route. This would be a short-term direct effect. With these design features the displacement would not

occur on weekends or holidays.

The sights and sounds of helicopters hauling logs to the landing in the Vail Mountain Special-use Permit

area would indirectly affect the experience of Forest visitors recreating on the Game Creek Trail, at

Adventure Ridge, and on other trails within the Vail Mountain Special-use Permit in the short term. These

recreationists may also be indirectly affected by the sounds of chainsaws during project implementation.

In the short term, people recreating within the Vail Mountain Special-use Permit area may also experience

the sights and sounds of logging trucks hauling the logs out of the Forest. The closest treatment unit and

the landing in Vail Mountain Special-use Permit area are both a little more than 5 miles away from

Adventure Ridge. Thus, it is unlikely that sound of chainsaws would be dominant. When pile burning is

being conducted recreationists would be indirectly affected by the sights and smells of the smoke from the

burn piles.

Reasonably Foreseeable Activities Relevant to Cumulative Effects Analysis

Several recreation enhancement projects are occurring in the Vail Mountain Special-use Permit area.

These projects would enhance recreation opportunities and the recreation setting within the cumulative

effects boundary. No negative cumulative effects are anticipated when considered with the proposed

action.

Summary

Implementation of alternative 2, including the design features recommended for recreation resources,

would cause short-term indirect effects from the sights and sounds of helicopters, logging trucks, and

chainsaws. The sights and smells of the smoke from pile burning would indirectly affect recreation

experiences. Hikers and mountain bikers seeking opportunities along the haul route would be displaced to

other areas within the Vail Mountain Special-use Permit area boundary by helicopter yarding to and log

hauling from the landing within the Vail Mountain Special-use Permit area. This would be a short-term


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direct effect. With the design features implemented the displacement would not occur on weekends or

holidays.

With the design features for recreation implemented, no direct effects to recreationist would occur within

the project area boundary since the unauthorized Matterhorn Trail would be closed during project

implementation.


Both alternatives are in compliance with the LRMP and other relevant regulations, policies, and plans.

There would be no change in acres of Recreation Opportunity Spectrum, and the effects of alternative 2

would be short-term.

Scenery


The Gore Range to the east and the Sawatch Range to the south of the project area provide a stunning,

rugged, alpine backdrop to the river valleys and round to rugged slopes of the project area. As seen from a

distance, the project area presents views that change markedly with the seasons. The upper slopes that

characterize distant views of the project area present a uniform green and forested canopy during spring

and summer.

The Vail Ski Area is visible as linear, straight-to-curved, green-to-straw colored clearings on the slopes

south of Interstate 70 that provide a textural and color contrast with the surrounding dark-green forested

canopy. During the fall season, the dense green canopy is interspersed with vivid gold colors of aspen

stands. During winter, aspen stands are visible as a brown-to-tan color that has moderate color contrast

with the surrounding green conifer forest. When snow is present, ski runs present a strong color contrast

of white clearings with the dark-green conifer forest.

Lodgepole pine that have died from mountain pine beetle outbreaks first appear throughout the forested

canopy as straw-colored orange-to-red patches that provide a moderate to strong color contrast with the

surrounding green canopy. Currently, the needles have dropped off, leaving tan or gray standing snags not

highly contrasting among healthy lodgepole or aspen trees.

When viewed in the middleground, the landscape exhibits a stippled appearance with light and dark

contrasts between the greens of vegetation and brown-to-tan soils and rock. Dead lodgepole pine are

visible as tan or gray standing snags that also contrast with surrounding green vegetation.

Closer views reveal forest vegetation interspersed with grassy openings and rock outcrops that create a

mosaic of texture, size, and color. Seasonal color contrasts are also strong in the immediate foreground to

middleground views.

A continuous cover of trees characterizes forested areas over much of the project area, with little diversity

of openness in the stands, tree sizes, and crown heights to provide a sense of structure. These

characteristics contribute to the scenic quality of the area. The valley bottoms and lower mountainside

south-facing slopes north of I-70 support aspen, grass, and shrublands. In contrast, north-facing slopes on

the south side of I-70 are characterized by dense stands of lodgepole pine. In general, as altitude is gained,

a greater number of aspen stands are interspersed in dense coniferous forests.

An urban setting dominates the middleground and closer views along the valley bottom in the towns of

Vail and Minturn, and along the Interstate 70 corridor between the towns. The slopes within the project


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area provide a scenic backdrop to the towns, and provide recreational opportunities to residents and

visitors (see Figure 12).

The Game Creek Trail (Forest Service Trail 2130) is located inside and outside the project area. Trail

N251 inside the project area and Trail N240 outside of the project have been decommissioned.

Additionally, there are several roads segments associated with Forest System Road 711 inside Vail Ski

Area just to the east of project boundary, and there is a frontage road just outside the boundary to the

north of the project area.

Figure 12. The project area scenery in general

Existing Conditions

The project area is characterized by extensive stands of lodgepole (some stands mixed with Engelmann

spruce), stands of aspen, and shrublands. The mature lodgepole pine forests are arranged in a mix of

small to very large, contiguous, single-story stands. The vegetation appears as even-aged stands and

represents extremely limited visual and structural diversity due to stand uniformity.

Recently, the Vail Valley experienced a widespread mountain pine beetle epidemic in stands of lodgepole

pine. A tree that has been attacked remains an apparently healthy green color through the attack period

and would remain green through most of the winter. Despite the green coloration, a successfully attacked

tree is essentially dead. The telltale foliage coloration of a beetle-attacked tree would not appear until late

the following spring when the green foliage turns a lemon yellow, which in turn becomes a straw-colored

orange and finally changes to the red of a dead tree to gray of a standing snag. Lodgepole pines with the

gray coloration of dead trees are visible throughout the project area.

Scenic Integrity

The scenic integrity objectives (SIO) are derived from inventories and the integration of other resource

objectives. They describe how a scenic resource will be managed. Management activities are to be

compatible with the SIO classifications. National Forest System lands in the project area are managed

with five SIOs ranging from very low to very high. Most of the National Forest System lands in the


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project area are perceived as slightly altered, and have been classified with a moderate SIO. Moderate

SIO areas include most lands within inventoried roadless areas and National Forest System land that has

not been developed with ski facilities.

The Vail and Beaver Creek ski resort facilities are classified as low SIO because the landscape appears

moderately altered. The Eagles Nest Wilderness outside but visible from the project area has an unaltered

natural landscape character, and an SIO of very high. Lands that have a very high or high SIO appear

unaltered and are located inside designated wildernesses and some inventoried roadless areas. The

condition of untreated aspen stands in inventoried roadless areas may deteriorate over the long term, as

pine trees encroach into aspen stands and replace aspen stands, thus reducing the overall diversity of

vegetation. The existing landscape appearance would also deteriorate, and would deviate to an increasing

degree over time from the existing scenic integrity levels. The portion of the Game Creek inventoried

roadless area is managed to meet a moderate SIO.




The lodgepole pine trees killed by mountain pine beetle are a negative element in the landscape, and

increases the potential for wildland fires. Uniform overstory composition and structure and declining

understory diversity also lessen visual diversity in the landscape. These conditions have resulted in a

decline of the visual quality of the project area.

Under the no-action alternative, activities such as commercial or non-commercial vegetation treatments,

prescribed fire projects, and associated management activities would not take place. Vegetative succession

by natural processes would continue in the project area. Existing management activities and recreational

use of the area would continue and the project area would be managed to protect and maintain existing

improvements and uses. The no-action alternative likely would lead to a buildup of fuels and potential for

increased severity or extent of wildland fire, which potentially would have a greater effect on scenic

resources.

Existing scenic integrity of the landscape would continue throughout the project area over the short term.

The timber stands, including the mature lodgepole pine stands, initially would remain in their current

condition with minimal vegetative diversity. The existing vegetation would not be treated. As the trees

become older, they would gradually die and fall to the ground. A continued increase in dead and down

material on the forest floor would contribute to an increasing fire hazard. Should a wildland fire occur it

would greatly affect the scenic integrity of the landscape, possibly leaving significant scars that would

remain on the landscape for several decades.

Over the long term, the scenic character may change by natural processes such as fires, mountain pine

beetle infestation, or decline of aspen communities. Natural process would continue and eventually a new

generation of forest would grow likely even-aged. Until then, dead and down trees may continue to be

seen in the foreground and middleground views. Overall under this alternative, the scenic integrity level

would remain moderate.


This viewing area has become a regional resource for many recreational activities occurring year-round

and a destination for tourists. Some human and naturally caused fires have occurred in the past with a

high potential for additional fires in the future. There have been 23 clearcut or partial cut sales in the


69

project area between 1982 and 1992. Between 1999 and 2001, there were seven sanitation-salvage sales.

These past harvest activities were listed in the “Vegetation” section of the Vail Valley Forest Health

Project. Between 2005 and 2014, there were 10 forest health and fuels reduction projects. Evidence of

previous timber harvest activities in the viewing area includes landings, stumps, rootwads, piles of slash,

paint on trees, and old logging roads. There is also evidence of historic logging and mining activities

occurring around the beginning of the century. The disturbances caused by human activity in this area

have a scenery impact on the experiences of visitors. There is evidence of human activity throughout the

project area.

Fuels treatment projects have occurred in the project area, including sanitation and prescribed burns

within the Vail Ski Area. Additionally, there were five fuels reduction projects between 2006 and 2009 in

the larger Vail Valley area. There were three large recreation projects on Vail Ski Area between 2004 and

2014. Other management activities that have occurred within the viewing area include road construction,

powerline and utility corridors (water and gas lines), communication sites, campgrounds, day-use

facilities, trailheads, bike paths, hiking trails, ski areas, timber treatment, fuel wood gathering, Christmas

tree treatment, private residences, and commercial developments.

Current management activities are a continuation of existing uses, including a variety of year-round

recreational activities and fuel wood gathering. The Vail Ski Area Summer Uses project components are

under construction; the alpine coaster and a canopy tour are now being built. Additionally, there are

timber removal projects occurring in the Piney area and there are some dead and diseased trees removed

on the ski area every year for hazard tree safety. The long-term effect of the concurrent actions would be

to promote year-round recreation at Vail Resort and to improve the health of affected lodgepole pine

stands, which would enhance the scenic quality of the project area landscape over the long term. There is

also considerable residential and commercial construction occurring throughout the area on adjacent

private lands.

It is anticipated there will be timber salvage harvesting in the Piney area. Year-round recreation activities

would continue with the potential for increased use. There may be future prescribed burn activity in the

area. Additionally, residential and commercial construction is anticipated to continue throughout the area

on adjacent private lands. The Vail Resort Summer Use projects currently being constructed for the Vail

ski resort would add new recreation elements into the landscape. The vegetation treatment project

involves ongoing noxious weed treatment that would enhance ecosystem health and contribute to the

scenic attractiveness of the landscape.

Based on the past, concurrent, and anticipated actions discussed above, the cumulative effects of activities

in the project area would not raise the visual impact to a substantial level.



The lodgepole pine trees killed by mountain pine beetle are a negative element in the landscape, and

increases the potential for wildland fires. Uniform overstory composition and structure and declining

understory diversity also lessen visual diversity in the landscape. These conditions have resulted in a

decline of the visual quality of the project area. The mitigation needed to meet the SIOs is incorporated

into the proposed action under the design features.

Scenic Impacts. Treatment activities can affect scenic resources because of contrasts created between

natural forest landscapes and those modified by management activities. These contrasts consist of changes

in line, form, color, and texture of the vegetation and landform. The effects that alterations have on these


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features are dependent on individual human values. The ability to control how disturbances appear

depends upon the treatment used, landform, soil type, silvicultural prescription employed, slash disposal,

cleanup, design of the treatment unit, the implementation, and the fire control method.

Scenic impacts would be greater where evidence of treatment activities (slash, stumps, landings, skid

trails, or paint) and pile burning are evident in foreground views.

In general, the longest lasting scenic impact comes from soil disturbance or color contrast generated from

tree removal or fire operations. Edges of the units would be designed to have a natural appearance by

avoiding straight edges and unnatural appearing shapes. The type of treatment method may also

contribute to the scenic impact. Opportunities to minimize scenic impacts are greater where slopes are

less steep and unit size and shape can be manipulated more effectively.

Lodgepole pine would be thinned or patch cut, creating more structurally diverse stands. The vegetation

treatment method has a low scenic impact, as the thinned stands would have a natural appearance once

treatment activities have been completed. In areas with high mountain pine beetle infestation and

mortality, up to 70 percent of the basal area may be cut to remove dead, dying, and infested trees. More of

the larger, dominant trees would be cut, creating a more noticeable change to stand structure. Removing

infested and dead trees would reduce their scenic effect on the landscape both from distant and close

vantages. In the short term, thinning of trees would enable better growth and vigor for the younger

individuals. In the long term, the stands would produce healthier trees with a better overall stand

appearance.

Based on the view potential of the units, all lodgepole pine units have been designed to minimize their

scenic impact. Various tools would be used during project design, such as controlling the locations of

openings, designing unit shapes to mimic the adjacent vegetative mosaic, and implementing scenic

resource design criteria. Initially, tree paint marked on trees adjacent to roads and system trails, stumps,

slash, root wads and skid trails would be noticeable to users. Additional scenery design criteria would be

used to reduce the scenic impact of the proposed activities.

Patch-cut clearings would be irregularly shaped with feathered edges. Where possible, the new patch cuts

would be laid out in shape with feathered edges to appear more like natural openings. The removal of

conifers would have a softening effect. A linear appearance would be avoided because of the variable

spacing of residual trees and the uneven width of the vegetation treatments. In the short term, the stands

would have a positive effect on the vegetative mosaic and some existing cuts would have a more natural

appearing edge. In the long term, the vegetative mosaic would be varied with different sizes of natural

appearing openings and diversity in stand character, species, and age class. The texture, color, and canopy

of the stands would have variety and diversity. Evidence of treatment activities would be apparent to users

of the trails in the immediate foreground views.

Landings would be used to process and haul logs. Each landing would contain a slash pile while in use.

The piles would be burned and the landings rehabilitated.

Hand piles would be burned to reduce fuels. These piles would be visible to those who enter the area. In

some situations, however, burned hand piles can have negative scenic impacts until new growth begins,

particularly on vegetation and on the forest floor in the foreground views.

Under this alternative, new growth would begin and eventually diminish any scenic impacts from the

activities proposed. From a background and midground perspective, the project area would continue to be

seen as a forested landscape. Overall, the scenic integrity level would remain moderate under the

proposed action.


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Cumulative Effects

The cumulative effects for alternative 2 (proposed action) would not be expected to vary from those

described for the no-action alternative, except as described below.

The scenic resources of the project area would be positively affected by changes in vegetation that would

increase the diversity of species and age classes, and decrease the risk of future mountain pine beetle

outbreaks using the various vegetative prescriptions. The overall scenery effect and long-term scenic

improvement of the vegetation due to the increased species diversity would create a more pleasing

vegetative mosaic. Areas of high mountain pine beetle damage and mortality that are currently detracting

from the scenic quality of the area would be improved by forest health treatments. The cumulative effects

of past, present, and reasonably foreseeable activities in the project area would not be expected to raise

the scenery impact to a substantial level with the recommended design criteria in place.


Scenic integrity objectives adopted in accordance with the Forest Plan include guidelines, which should

be met wherever possible. The Forest Plan allows scenic disturbances in managed areas, as long as the

alterations meet the SIOs (scenic integrity objectives). The proposed action alternative would meet all

SIOs set by Forest Plan standards and guidelines over the long term.

Roadless


Existing Conditions

The analysis area includes the Game Creek Colorado Roadless Area (Game Creek). Game Creek is

administered by the Eagle-Holy Cross Ranger District. It is adjacent to Colorado Division of Wildlife

property (Vail Underpass) and totals about 7,171 acres (see Figure 13). The eastern boundary of the area

is defined by the Vail Ski Area Permit boundary. The northern, southern, and western boundaries border

private property. The southeastern boundary is bordered by NFSR 709. Two trails cross the Colorado

Roadless Area, NFST 2130 (Game Creek) and NFST 2005 (Two Elk). Game Creek is within the Northern

Parks and Ranges Eco-Section (M331I) with elevations ranging from 7,000 to 11,000 feet. Game Creek

has areas of rolling valleys to very steep slopes and high ridges containing spruce/fir, mountain shrub,

aspen, lodgepole pine, riparian habitat and grassland meadows.

Game Creek provides potential habitat for the Canada lynx, a federally listed species, and potential

habitats for Forest Service sensitive species, wolverine, marten, northern goshawk, olive-sided flycatcher,

American three-toed woodpecker, Brewer’s sparrow, and peregrine falcon.

There is an active peregrine falcon nest on the southwest edge of Game Creek, not within the project

boundary, which also contains part of a 0.5-mile buffer for nesting areas. No units are affected by this nest

area buffer. Game Creek is important habitat for elk and mule deer and contains elk habitat (winter and

severe winter range, winter concentration areas) near Minturn on the western boundary of the Game

Creek area. Elk that range there seasonally are part of the Dowd Junction-Two Elk Creek Herd. The area

provides a transitional area for the herd in between their summer range and winter range locations. Elk

calving and rearing usually occurs at the lower elevations of south-facing slopes within the Two Elk

Creek drainage. The Eagle Valley deer migration corridor runs through Game Creek. In the 1970s the

Colorado Division of Wildlife purchased 119 acres to protect this corridor from development. Deer use

Game Creek as a staging area before migrating under I-70 at the Vail Underpass. Other species with

habitats in Game Creek include black bear, mountain lion, blue grouse, and snowshoe hare.


72

Figure 13. The Game Creek Colorado Roadless Area

Game Creek provides quality big game and small game hunting away from roads. The Game Creek trail

offers popular intermediate back country skiing, and along with trail #2005, is used for hiking and

mountain biking in the summer. The Holy Cross Ranger District office has a Colorado Division of

Wildlife Watchable Wildlife elk viewing station that allows winter viewing of elk in the area. Game Creek

is within a State-defined source water assessment area (municipal water supply).

This area provides a buffer between heavy development in the West Vail and Minturn areas, and the

expanding Vail Ski Area. A large herd of elk use the Game Creek roadless area as a transitional zone

between their winter range at Dowd Junction and their summer range near Stafford Creek. A significant

amount of elk calving occurs in the Two Elk drainage. A sheep grazing allotment lies within Game Creek.

In the surrounding area, trails along Game Creek and Two Elk Creek, and up to Lionshead, are all

extremely popular in summer, and provide an important recreational resource for the towns of Minturn

and Vail. Game Creek is a popular backcountry ski route from Vail Ski Area to Minturn. Fossilized trees

in the Lionshead area are an important educational and scientific resource as well. The area falls within

the semi-primitive non-motorized ROS (recreation opportunity spectrum). In this ROS class, the natural

setting may have subtle alterations that would be noticed, but would not draw the attention of an observer

wandering through the area. A predominantly natural or natural-appearing environment characterizes the

area.


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Three other Colorado roadless areas are located to the north of Interstate 70, Buffehr (sometimes written

as Buffer) Mountain and Spraddle Creek A and B. Recreation uses here include mountain biking,

horseback riding, and hiking. Mountain pine beetle has affected these areas as well.

Past actions in Game Creek include three fuels treatments in 2006 and 2008. These treatments included

hand cutting, mechanical treatments, and helicopter removal, as well as hand piling and burning (Figure

14).

Wilderness Attributes and Roadless Characteristics

Natural: The extent to which long-term ecological processes are intact and operating.

Due to the mountain pine beetle epidemic and decades of fire suppression, the current state of this

attribute is degrading. Reference landscapes of relatively undisturbed areas serve as a barometer to

measure the effects of development on other parts of the landscape. The current landscape is not

undisturbed. It is comprised of dense forests susceptible to insect and wildfire mortality. This mortality

has occurred in individual trees, small groups, and larger patches. A total of 80 acres of Game Creek has

been treated in the past (Figure 14) and those areas appear visually different than the rest of the project

area due to less forested cover.

Undeveloped: The degree to which development and uses are apparent to most visitors.

There are no records of human development in Game Creek. An active grazing allotment for sheep is

located on the top of the ridge separating Game Creek and Gore Creek. There are no developments

associated with this allotment. People traveling along in the higher elevations see human activities and

development within the adjacent areas, particularly the ski resort, subdivisions, and the interstate.

Opportunities for Solitude and Primitive and Unconfined Recreation: Solitude is a personal,

subjective value defined as the isolation from sights, sounds, and presence of others and from

developments and evidence of humans. Primitive recreation is characterized by meeting nature on its own

terms, without comfort and convenience of facilities.

The Game Creek Colorado Roadless Area has a moderate potential for solitude due to popular trails and

proximity to the local community. This limits the opportunity to experience isolation from sights, sounds,

and the presence of others. Pockets of forested slopes provide some potential for solitude. Recreation

occurs year-round in some parts of the Game Creek Colorado Roadless Area.

Special Features and Values: Unique ecological, geographical, scenic, and historical features of an

area.

There are no identified special features in Game Creek.

Manageability: The ability to manage an area for wilderness consideration and maintain wilderness

attributes.

The Town of Minturn is located directly adjacent to the west and south of Game Creek. To the north and

east, the infrastructure of the Vail Mountain Ski Area bounds Game Creek. Roads bound several sides of

the area including Interstate 70. Development on private lands to the south present a wilderness

manageability challenge.

None of Game Creek has been identified as potential wilderness areas or recommended for Federal

wilderness consideration.


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Figure 14. Past treatments in the Game Creek Colorado Roadless Area


75




This alternative would not implement any of the management activities proposed in the action alternative.

Any direct or indirect effects of this alternative would be the result of future tree mortality in the area.

Fuel loading would continue to increase over the project area, as mountain pine beetle-killed trees would

continue to fall. This would create an increased fire risk. The potential for an uncharacteristic fire could

impact the naturalness and/or recreation values in the area. There would be no immediate direct effects;

indirect effects are discussed below in terms of wilderness attributes and associated roadless

characteristics.

Wilderness Attributes.

Natural: Fire would not be reintroduced to the landscape under this alternative. This is a fire-adapted

ecosystem, and the continuation of fire suppression and potential catastrophic, stand-replacing wildfire

instead of mosaic burns that historically occurred here would contribute to the degradation of the natural

attribute. No vegetation treatments would occur in this area, and aspen diversity would not be

maintained; succession by conifer species would continue.

Without treatments, no further manipulation of the environment would occur. The short-term effects of

these types of manipulation would not be present.

Undeveloped: Since no treatments would occur, there would be no affect to this attribute.

Outstanding Opportunities for Solitude or Primitive Unconfined Recreation: The existing condition

for solitude would not be immediately affected under this alternative. However, over time, conditions

could become challenging for visitors to recreate due to fuel loading from mountain pine beetle and

associated downfall. This could increase opportunities for solitude for those who are able and willing to

negotiate an increasingly brushy and inaccessible area. In addition, large wildfires could dramatically

change the landscape, also changing how people access or recreate in Game Creek. In the case of a large

fire, sight distance and topography screening could be changed for decades, impacting solitude, because

sights and sounds of visitors in the area, as well as activities on adjacent lands, would more easily be seen

and heard.

Special Features: No special features have been identified for this area.

Manageability: Choosing the no-action alternative would not change the manageability of the area.

Roadless Characteristics. The nine roadless characteristics would not be affected in the short term.

However, surface fuel loading would continue to pose a threat to other resources should a large fire occur.

The main threats would be to soils; habitat for threatened, endangered, proposed, candidate, and sensitive

species, and for those species dependent on large, undisturbed areas of land; and to natural appearing

scenery. Indirect effects from wildfire to soils could include erosion and higher sediment yield, debris

flows and landslides, and nutrient losses. A large wildfire would change the scenic attributes of Game

Creek for decades. Depending on the severity of the wildfire, habitat for species and those dependent on

undisturbed areas of land would also be affected, causing displacement and mortality.


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Cumulative Effects

Past treatment actions near the north and east boundary have affected 80 acres of the 7,171-acre Game

Creek Colorado Roadless Area. This alternative would not contribute to effects of past actions. However,

the cumulative effect of the no-action alternative, by continuing to not address the mountain pine beetle

outbreak in the majority of Game Creek, could negatively impact its wilderness potential. Increased risk

of large wildfires may impact the primitive recreation characteristic in Game Creek.



Wilderness Attributes. A small portion of Game Creek (within 319 acres) would fall under some type of

treatment under this alternative. The remainder of Game Creek would not be treated. The risk of

catastrophic wildfire would remain in those areas and the effects to naturalness in the untreated areas

would be similar to alternative 1. The semi-primitive non-motorized classification for the area would not

be affected in the long term.

Natural: Vegetation treatments in this fire-adapted ecosystem would begin reversing the trends caused

from past fire suppression and reduce the risk of large, severe wildfires. This would enhance the

characteristic of “naturalness” throughout the area, by establishing forest characteristics that would have

been more typical of this area if fire had been allowed to play its natural role in landscape processes.

There would be a reduced probability of severe impacts to soils from a wildfire, which reduces the

likelihood of severe post-fire erosion and loss of long-term soil productivity. However, since treatment is

only proposed on a small portion of the total acres; this would not restore fire as a natural process

completely in Game Creek.

Management treatments are a form of “modern human control or manipulation” and would to some extent

affect the “untrammeled” and natural character within the roadless areas. There is disagreement about

whether the effects of additional management actions such as prescribed fire (i.e., trammeling) to correct

the effects of previous management actions such as the suppression of natural fire is appropriate (Yung

undated).

Vegetation treatments on 319 acres represent a form of human manipulation of the environment, which

must be balanced against the benefits of treating roadless and wilderness areas. The proposed action

would mimic natural disturbance across the landscape, but with smaller maximum patch sizes. Forest

regeneration and “greenup” would occur shortly after treatment and improve upon the visual appearance

of this landscape cycle by resembling an increasingly healthy forest. Aspen diversity would be increased,

reversing the trend of conifer replacement due to past fire suppression.

In the long term the proposed action would enhance or help to maintain the roadless resources including

high quality soil, water, and air; diversity of plant and animal communities; and habitat for threatened,

endangered, proposed, candidate, and sensitive species, and for those species dependent on large,

undisturbed areas of land.

Undeveloped: Short-term direct impacts would be expected from piling and burning. Stumps from the

hand slashing of trees may remain visible for several seasons following the treatments, which may detract

from the undeveloped character for visitors traveling through the roadless area. Piles would be noticeable

to visitors until the piles were able to be burned, which could be a considerable amount of time depending

on the weather window. The aftermath of pile burning can be seen for at least one season after burning as

burnt circles and remaining unburnt logs.


77

The use of helicopters is proposed under this alternative. Impacts would be more obvious in the short term

and would include the sights and sounds of yarding as helicopters hovered for the hookup. Short-term

effects, while mitigated by careful consideration of routes and times, would be obvious to visitors and

could cause them to avoid the area.

Other short-term indirect impacts on the undeveloped attribute include smells of smoke from pile burning,

which could persist for a few days after ignition. Dust from machinery on adjacent roads could also be

present during operations. These effects would not cause lasting impacts on the undeveloped attribute.

Outstanding Opportunities for Solitude or Primitive Unconfined Recreation: This alternative has a

potential short-term direct effect to solitude. Impacts would occur during project implementation due to

the presence of personnel managing pile burning and noise associated with the use of chainsaws for the

hand slashing of trees. Helicopters overhead and other machinery on adjacent roads would impact

solitude.

Due to the popularity of trails in Game Creek and the proximity of the nearby community, interstate, and

ski resort, existing opportunities for solitude are moderate. In the short term, it could be difficult for

visitors to escape sights and sounds of others while the project activities are occurring. Solitude could

especially be compromised near area roads. There would be a greater sight distance than at present and

for several years visitors could become more aware of other activities in the area as well as on private

lands. This effect would not be as great as potential effects from a catastrophic fire. The greatest impacts

to solitude would be near the private lands.

Effects to primitive and unconfined recreation would be minor and limited to those time periods when

activities were taking place. People could be displaced from favorite areas while project implementation

was occurring. However, very few acres are proposed for this type of treatment; these represent a small

portion of the entire area of Game Creek. Popular trail areas are not included in the treatment units,

although they do fall within Game Creek.

Several studies have identified a greater level of sophistication among fire-affected communities in both

their understanding and acceptance of fire management techniques when compared to the general

population. Additional work in fire-prone areas indicates a number of similar factors influence public

support for fuel treatments despite geographic and economic differences. Though treatments could be

ongoing, visitors who are aware of the drivers behind these treatments may be more willing to recreate in

these areas rather than be displaced by them (Shindler 2003).

Burning piles could produce some smoky days in the local area and generally would last a few hours after

ignition is completed. Smoke may settle into the lower draws and drainages during the evening hours

following ignition. Visitors may choose to avoid favorite areas during this time. Smoke could affect

nearby residential areas as well.

The amount of work proposed is expected to be completed within a matter several years; therefore,

negative effects to solitude and primitive and unconfined recreation would be limited in duration.

Treatments in the Colorado Roadless Area would not occur every day or every week of the time period

and opportunities would still exist for finding solitude during the times that treatments were not

occurring.

Special Features: No special features have been identified for this area.


78

Manageability: The action alternative would have no perceivable impact on the existing manageability

value of the roadless and unroaded lands in the analysis area. There are no new permanent roads proposed

in the project that would complicate potential wilderness boundary management.

Roadless Characteristics: The effects to roadless characteristics are listed in appendix A of the Roadless

Report. This worksheet contains analyses from resource specialists concerning the impact of the action

alternatives on roadless characteristics, such as those involving botanical, wildlife, soils, or hydrological

resources.

In summary, the effects from this alternative are expected to be minor and short term, and no

characteristic is expected to experience a degrading trend. Management activities may cause direct short-

term impacts to air resources from fugitive dust and smoke. While removal of trees can cause increased

ground water through-flow, the project area is small and the trend to this characteristic is expected to

remain stable. The area is not a source of public drinking water. Temporary effects to solitude and

recreation could occur from the project activities, including sights and sounds of people working,

machinery, dust, and smoke. However, long-term impacts to recreation and opportunities for solitude are

not expected to occur. There have been no cultural sites or special features identified in the project area.

Due to vegetation and soil disturbances and the possibility of increased weed infestations, sensitive plant

populations and their habitats may be impacted by the proposed action, but it would not likely result in a

loss of viability in the planning area, nor cause a trend toward Federal listing.

Cumulative Effects

Three past management actions totaling 80 acres are listed as having occurred in Game Creek (Figure 14).

All are located directly adjacent to the northern or eastern boundary, with some activities occurring both

inside and outside of Game Creek.

When combined with past and proposed actions, a small portion of Game Creek (6 percent) would have

been subject to human manipulation. However, the naturalness of the area in the long term would be

improved. In that small area, resource modifications would be evident in the short term.

Most of these effects would ultimately be beneficial because they would increase the resiliency of forest

conditions and reduce the risk of potential negative impacts from severe wildfire, therefore maintaining

the roadless and wilderness qualities currently valued by the public. Most effects would be short term and

experienced during the project implementation phase.

These activities would have a largely neutral effect on potential wilderness attributes in the analysis area,

as they would perpetuate the existing human-modified landscape condition.

A mostly stable or neutral effect on the nine roadless characteristics is expected, since past actions have

been site-specific and small in size, and there are no large-scale foreseeable actions proposed.


Under the no-action alternative, potential impacts to natural and recreation values would result from not

addressing the mountain pine beetle outbreak and the increased risk of uncharacteristic wildfire that a lack

of treatment would produce. Potential impacts of uncharacteristic, high-severity fires could include health

and safety risks to public recreational uses as well as to forest workers and fire suppression crews as well

as impacts to the adjacent community. The purpose and need of the Vail Intermountain Fuels Project

would not be met.

The proposed action (alternative 2) would have short-term direct impacts to roadless resources during

project implementation, such as increased presence of people and noise within the project area. The


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proposed treatments would address the purpose and need for the project, resulting in a more diverse,

resilient, and sustainable forest ecosystem with a reduction in risk of negative impacts from severe

wildfire. The long-term indirect effects from alternative 2 to roadless resources would be generally

beneficial and help to maintain the existing recreation settings and scenic qualities within the project area.

Impacts would be stable or improving for a majority of roadless area characteristics and wilderness

attributes with short-term impacts to the undeveloped character from the hand slashing of small-diameter

trees and pile construction and burning and short-term impacts to solitude during project implementation.

Cumulative effects to roadless resources from alternative 2 would generally be short term and related to

an increased presence of people, vehicles on nearby roads, and the associated noise that may affect

solitude.

Long term, the action alternative would have a neutral to positive impact on roadless values by improving

some components of the natural and undeveloped attributes, such as improved functioning of the natural

ecosystem.


The actions proposed by alternative 2 are consistent with Forest Plan direction for goals and standards

prescribed for management areas located within the Colorado roadless area. The impacts of the proposed

activities on the roadless resource would remain within Forest Plan standards. The alternatives are

specifically consistent with the following plans, direction, and laws:

White River National Forest Plan Revision 2002, Management Goals for Management Areas 7.1.

Forest Service Handbook (FSH) 1909.12 (72.1) – Wilderness Evaluation (that provides

definitions for the wilderness attributes of inventoried roadless areas).

The Colorado Roadless Rule (2012).

Forest Service Manual (FSM) 2300 – Recreation, Wilderness and Related Resource Management

(guides management of recreation and wilderness resources on National Forest System lands).

Hydrology


Existing Conditions

The project area is on the south side (north-facing) slope of Gore Creek Valley directly above the Town of

Vail, Colorado. The slope is mapped entirely of Minturn Sandstone (Pennsylvanian in age), though with

large areas covered in very recent (Quaternary) landslide or colluvium material

(http://coloradogeologicalsurvey.org/geologic-mapping/124000-scale-mapping-program-index-maps/;

Figure 15). The Minturn is actually a thick sequence of sandstone, siltstone, shale, and minor amounts of

limestone or dolomite. All together the sequence represents deltaic deposits from the proto-Rockies to the

west of the project, and occasional, deeper incursion of the sea. Largely the formation in the project area

is coarse-grained, arkosic sandstone, but at least one small portion of project, the northeast corner of patch

cut in unit 5, is underlain by limestone (personal observation, August 2015).

The orientation of the Minturn is the single-most important factor in this author’s view to the issue of

slope stability and in turn, water quality and stream health. Throughout the project area and the entire

Gore Creek Valley, there is a pervasive dip of the bedding planes to the northwest at angles approximating

surface slope. This view is also held by Stover (1985) when investigating the cause of slides on the Vail


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ski slope. Large block slides of early Quaternary in age were probably a result of the retreat of glacier ice

in the valley which had buttressed the bedrock masses. However, there are recorded occurrences of slides

and debris flows.

Mears (1984) investigated the 1984 slides and debris flows in Gore Creek Valley and concluded those

incidences were caused by a combination of rapid temperature rise and unusually heavy snow cover. The

fact the preceding 2 years were also wet, and soil moisture may have been still high, may also have been a

contributing factor. In 2000 the Town of Vail adopted a debris flow hazard map that includes the five

principle draws that run through the project area, all deemed to pose a high hazard (Town of Vail 2000)

(Figure 15).

Depending on a number of factors, including annual precipitation, average temperatures, and prevalent

soil moisture and depth, a relatively consistent wet layer may develop on or near the bedrock surface with

the greater mass of the soil above it. A soil mass at or near saturation is heavier and weaker (reduced

shear resistance) than drier soil mass. On occasions when the entire soil mass is rapidly and particularly

wetted, the bedrock contact is a potential failure zone, slipping under the weight of wet soil above. The

presence of large and deep areas of landslide material is on just those slopes with bedding planes oriented

in the direction and approximate angle of the surface slope.

Other than landslips, debris flows are a definite and potentially greater hazard to infrastructure in the

Town of Vail. Debris flows usually are generated from existing drainage pathways of low 1st- and 2nd-

order streams directly draining hill slopes. The project units border, or avoid altogether, the prominent

1st- and 2nd-order draws with two exceptions in units 1 and 4 (Figure 16). Swale type drainages do cut

through most of the units, but these do not have defined channels, or such features are discontinuous.

Basal vegetation cover is prevalent or complete. These drainages are not listed as debris flow hazards.

Debris flows can not only deliver large amounts of sediment to higher order channels with protected

resource, but alter channel geometry that may adversely affect habitat (i.e., filling of pools).

Slopes are generally over 30 percent gradient with some units predominantly over 50 percent (Figure 17).

Upper story canopy is a lodgepole forest with substantial stands of aspen. Live ground cover is excellent

throughout, with grass, forbs and shrubs; total ground cover including leaf litter may be considered

complete. Exceptions are steeper patch cut areas on the western portion of unit 1. Here, overstory

canopy is dense enough to inhibit basal vegetative growth and leaf litter is thin to absent in patches where

deer and elk are prone to bed down. Understory tree species, particularly later-seral types such as spruce

or subalpine fir, are very scarce throughout the project area, and lodgepole appears overall in a decadent

stage. Bark beetle has taken a toll on trees, and recent blowdown is heavy, thinning the canopy to 50

percent or less. The aspen stands by contrast appear robust; regeneration is thick and recent, perhaps

reflecting the decreasing lodgepole canopy. Evidence of browse by ungulates is of slight use.

Soil creep is pervasive, typically resulting in mounding about the base of the tree, deforming the trunk

(pistol-butted) and occasionally leaning the tree. Past landslip evidence is also widespread in the form of

scallop slopes, troughs, and benches of larger rotational slumps, and the divots and terraces of shallower

failure zones. These features appear largely stable and of uncertain age and occur on slopes greater than

60 percent. One particular hillside in the patch cut of unit 5 has much more recent, even active appearing

shallow-based failure features on a slope exceeding 80 percent. Associated instability indicators are

severely deformed trees and cracked and split trunks on a long series of small terraces or benches.


81

Figure 15. Geology of project and direction arrow of prevailing dip in bedding planes

Note: Qls = landslide material; Qc = colluvium material.


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Figure 16. Unit location, buffered hazard streams


83

Figure 17. Slope class map

Note: 039% dark green, 3959% light green, 5979% yellow, and >79% red.


84

Water Quality

Gore Creek is listed as provisional for aquatic life use by the Colorado Department of Public Health and

Environment, Water Quality Control Division (State of Colorado 2012). Provisional means that no

pollutant was found (State of Colorado 2011), or is unknown. The beneficial use of the stream has been

designated as aquatic life and habitat cold water 1 category. The stream is listed under section 303(d) of

the Clean Water Act to be non-supporting, meaning standards for aquatic life cold 1, assessed through

survey of macro-invertebrates, have not been met in Gore Creek. The stream has been placed in category

5 for TMDL (total maximum daily load)—not meeting one or more designated uses due to one or more

pollutants. A TMDL would be required, but has not been completed. The project area drainages directly

flow into Gore Creek (Figure 15).




There are no direct or indirect effects from taking no action for this project.

There would be the continued risk of high intensity fire due to presence of downed wood and standing

dead, and mortality of some trees is expected to continue. In the case of a high intensity/severity fire that

denuded the forest floor in all or part of the project area, including the current dense basal vegetation, a

very high risk of surface erosion on the hillsides and debris flow(s) in the drainage ways would emerge.

As discussed previously, debris flows from the project area puts a portion of residential and commercial

property in the Town of Vail at risk as well as the main stem Gore Creek channel geometry and its water

quality.



Direct effects of tree removal are the impact of felling and removal itself and, in case of green tree

removal, a decrease of upper story canopy and shading. Patch cuts would result in open areas several

acres in size. No equipment would be involved in felling the trees as this would be accomplished

exclusively by hand (no ground-based mechanical equipment) treatments. Helicopters would be used to

remove whole trees. Otherwise, trees would be felled, limbed, and bucked entirely by hand, the debris

burned in piles during the fall or winter. Ground disturbance from felling and yarding by helicopter

would be minimal, on the order of a few square feet and isolated and slight given the degree of basal

vegetation and its resilience. These disturbances are not expected to contribute measurably to increased

runoff or erosion. Hillside draws will be given stream buffers of 100 feet (horizontal distance) to either

side of the channel to protect against initiation of slides on side slopes, and prevent runoff of water and

sediment from cut areas reaching the channels. In addition, any wetland areas encountered during

implementation would be noted and excluded from treatment and avoidable ground disturbance.

Indirectly, the removal of trees, and particularly green canopy, can measurably increase groundwater

through-flow on a slope and in some cases, destabilize steep slopes (Hart and Lomas 1979; Adams et al.

1991). Interception of precipitation (and loss through evaporation/sublimation) in a thick spruce conifer

forest can be up to 35 percent (Gash and Stewart 1977; Johnson 1990; Xiao 1998; Spittlehouse 2005). In

the project area with its already thinned canopy of pine, this is probably closer to 20 percent. The tall

grass/shrub understory may be nearly as effective. Nevertheless, with canopy removal this effect can add

considerably to snow depth.


85

Studies in a northern New Mexico spruce forest (Musselman et al. 2008; Veatch et al. 2009) found that

the optimal size in openings for increased snow depth was 3 to 5 acres. Over a large proportion of a

watershed, stream yield has been found to measurably increase with just such management (Bosch and

Hewlett 1982; Stednick 1996; Brown et al. 2005). Another factor is the loss of transpiration by the trees

which also increases groundwater. In the case of the heavy basal growth, this may not be a large factor.

There is evidence that low-growth forms of vegetation such as grasses utilize groundwater at different

times than a high canopy forest, but are just as effective in terms of volume of groundwater transpired

over a growing season (Kelliher et al. 1993; James et al. 2003).

A small area, as is the case on this project, would not affect yield on Gore Creek, nor perhaps in the larger

2nd-order draws that principally drain the hillside, because the patch cut units are largely laid out between

the drainages. However, in the presence of large volumes of landslide and colluvial material already on

the hillsides, and the more direct evidence of landslip, there appears to be the possibility of initiating mass

wasting on the steeper slopes. In that view no cutting of live trees (patch cut) would occur on slopes

greater than 60 percent.


The project area is a roadless slope with a lodgepole forest and substantial pockets of aspen and

interspersed aspen. The lowest 300-foot-strip along the Forest boundary has been treated (approximately

10 years past [Green, C.; personal communication, 2015]) with hand removal of conifers that were

limbed, bucked, and largely burned in piles. Basal vegetation regrowth has been excellent, with almost

complete cover and, in portions, strong aspen regeneration. Otherwise there is no evidence of vegetation

management. The fact that the forest is almost entirely lodgepole pine, an early seral species with distinct

affinity for burned ground, suggests that the hill side is still in recovery from a much earlier wildfire.

Understory of later-seral spruce, fir, and lodgepole remains very sparse.

The hillside directly drains into Gore Creek, a 62,000-acre 4th-order stream. Within the Gore Creek

Valley is a substantial urban infrastructure and many ancillary effects to the stream channel, including, but

not limited to, altered floodplains (widths), altered channel path (reduced length), altered channel

resistance, high sediment input from highway fill slopes, and winter surface treatments (sanding).

The project area represents only 0.003 percent of the Gore Creek Watershed. In an undisturbed state the

project area would not exert measurable or observable change to the flow or channel of Gore Creek. In

the event of very high intensity rainfall, or more likely rapid snowmelt runoff, mass-wasting (slope

movement)may be triggered on some of the steepest slopes if impacted by management with direct

consequences to Gore Creek. Under those circumstances, however, mass wasting elsewhere within the

Gore Creek Valley would also be expected. Project design features are specific to avoiding those portions

of the project area that are most vulnerable to slope failure and lowering the possibility of mass-wasting

on those slopes.


The major effect of removal of trees would be increase in snow depth, particularly in patch cut areas, and

reduction of transpiration, also in the patch cuts. This would permanently increase groundwater where

regeneration of aspen does not occur, until later-seral conifer species are present. On steeper slopes (>60

percent) where evidence of landslip is observed, no patch cut would be allowed. Buffers would also be

placed on the larger draws, mostly outside, but bordering on the treatment units. Side slopes in these

draws are generally greater than 60 percent and often greater than 90 percent.


86


Project design features would reduce risks of inducing either slope failure and/or debris flows. Removal

of dead trees and limited patch cut of live trees to slopes less than 60 percent gradient, through hand

methods and helicopter yarding, would not alter the hydrologic function of the slopes’ ability to absorb

precipitation. The five principle stream channels (Figure 17); with a particular hazard of debris flows

would be buffered by 100-foot no-cutting zone to maintain side slope stability. Wetland areas as identified

during implementation will be exclusive of treatment, to protect the integrity of the habitat.

Soils


Existing Conditions

Background soil data for the soil mapping units in the Vail Intermountain Project was obtained from the

Holy Cross Area Soil Survey (USDA Forest Service 1993) and from Natural Resources Conservation

Service soil surveys (NRCS 1990) (see Table 16 and Figure 17). Soil properties relevant to the removal

of forest products, fuels reduction, and subsequent revegetation include soil organic matter content,

erosion risk ratings, surface soil texture, depth, and drainage class. Deep, well-drained soils with higher

organic matter content and relatively low clay percentages are more resilient to the potential impacts of

timber harvest detailed under “Issues” in section 1.

As shown in Table 16, many of the soils mapped for the project area have a loamy surface texture. Soils

represented by the Anvik, Eyre, and Gateview series represent 61 acres of the project area and have

mollic epipedons comprised of organic-rich surface horizons that provide an ideal medium for

revegetation, compaction mitigation, and soil-water function. Skeletal soils (those with at least 35 percent

rock fragment content by volume) inventoried in Table 16 are more resistant to erosion, as demonstrated

by the lower Kw values for the Eyre and Gateview soils. For units 1 and 2, soils had intact but very thin

O soil horizons (1 to 3 centimeters on average, based on shallow excavations with sharpshooter). Very

little rill/gully erosion was found, and minor amounts of sheet flow. Soil profiles in units 1 and 2 were

Entisols, and have little or no soil horizon (pedogenic) development.

For the purposes of this analysis, K-factor values were used as a proxy for erodibility. K factors are

values used to predict the susceptibility of soil to displacement by water and are used in erosion models

and equations that predict soil loss across landscapes (USDA NRCS 2010). The K factor scale ranges

from 0.02 to 0.64; lower K factor values indicate more erosion-resistant qualities to a soil due to favorable

textures and rock fragment content. All K factor ratings used were based on the surface horizon. K factor

values for the rated soil components within this project area greater than 0.26 were considered “erodible”;

the confidence of this rating can be increased by examining the taxonomic classification and geologic

parent materials. The reported K factors are only for the surface mineral soil horizons; removal of

organic-rich surface horizons often exposes much more erodible, clayey subsoils. A total of 259 acres of

the project area has soils with K factors higher than 0.26. Maintenance of soil organic matter and surface

O and A-horizon integrity is paramount in avoiding erosion in these areas, and avoiding compaction and

hydrology problems potentially associated with the proposed fuels treatment.

Soil stability in the project area varied both within soil mapping units (Table 16). Soil stability in this

area is highly dependent on slope, and ratings varied from slight to severe. Figure 19 shows slope classes

for the project area, with slopes predominantly in the 20 to 60 percent range, with small inclusions of

higher slope areas outside of units. Figure 20 shows mapped landslide deposits in the project area.


87

Further discussion on slope stability concerns is discussed in the geology analysis included in the

hydrology section of this chapter.

Table 16. Soil characteristics for the Vail Intermountain Project

Soil Map Unit Acres Stability Description

Erosion Factor

(Kw) Surface Texture

Soil Order

CO8654-AG9

61 Slight Ansel-Anvik association, 2545% slopes

0.37 Loam Alfisol

CO8654-AG11

3 Slight Anvik-Skylick-Sligting association,

2550% slopes

0.24 Loam to clay, cobbly

Mollisol

CO8654-349C

1 Slight to moderately low

Eyre-Quander families complex,

4060% slopes

0.15 Loamy, skeletal

Mollisol

CO8654-346C

46 Slight to moderately low

Gateview-Handran-Eyre families

complex, 4065% slopes

0.15 Loamy, skeletal

Mollisol

CO8654-351C

8 Slight to severe Scout family, 4065% slopes 0.08 Loamy, mixed

Inceptisol

CO8654-385D

1 Moderately low to severe

Scout-family-Rock outcrop-Hechtman family complex,

4150% slopes

0.08 Loamy, mixed

Inceptisol

45 1 Slight Forsey cobbly loam, 312 percent slopes

0.15 Cobbly loam Mollisol

9 198 Slight to severe Ansel-Anvik association, 2545 percent slopes

0.32 Loam Alfisol

11 11 Slight to severe Anvik-Skylick-Sligting association,

2550 percent slopes

0.24 Loam Mollisol

104 5 Slight to severe Torriorthents-Camborthids-Rock

outcrop complex, 665 percent

NA Variable Entisol

Note: All soils are well drained.


88

Figure 18. Project area treatment units and soil map units


89

Figure 19. Project area slope classes and treatment units


90

Figure 20. Project treatment units and landslide deposits


91




Under the no-action alternative any potential direct and indirect impacts to soil resources such as soil

compaction, productivity losses, and erosion resulting would not occur.

Wildfire would continue to be at high risk in the project area. Indirect effects from wildfire include

erosion and higher sediment yield, debris flows and landslides, and nutrient losses. Typically soil erosion

rates can substantially increase after fires because soils would have reduced ground cover. Water

infiltration is often severely affected after wildfire, increasing runoff rates. Landslide frequency and

magnitude can increase, including soil creep, debris flows, rockfall, and slumping.

Nutrient loss from wildfire could occur to varying degrees depending on fire occurrences. The largest

flush of nutrient loss would occur during the combustion of organic materials where nutrients (primarily

nitrogen) would be volatilized and lost to the atmosphere as gas and particulates. Soil nutrients left in ash

and partially-combusted organics would be susceptible to loss from the project area which is largely

dependent on burn severity, slope, and future weather events.

Slope instability is a geologic process that is not, for the most part, an active phenomenon in the project

area, though it could potentially affect some proposed units. Occasional geologic mass movement/wasting

would naturally occur in the project area over time; a more complete discussion of these risks can be

found in the “Hydrology” section of this chapter.

Alternative 2 (proposed Action)


Direct and indirect effects to soils from timber harvesting and fuels treatment activities are well-

documented and the body of research literature supports the issues and indicators that are the focus of this

analysis. Soil compaction is a direct effect to soils as a result a physical change in soil density, usually as

a result of mechanical ground-based equipment use or from other impacts such as felling trees. Soil

productivity losses are generally indirect effects as a result of soil disturbance, and soil erosion is an

indirect effect that can happen following vegetation removal or other soil disturbances.

Under the proposed action, risks of wildfire and the indirect effects to soils resulting from wildfire, such

as increased erosion, landslide risk, and nutrient losses, would be less likely to occur than under the no-

action alternative.

Soil Compaction and Productivity. Soil compaction is caused when there is a decrease in pore space

volume—the gas and liquid-filled voids between mineral grains and/or organic matter in a given mass of

soil. When pressure is exerted downward on soil from logging and hauling equipment, the pore structure

through which roots, water, and nutrients pass collapses, ultimately reducing vegetative growth and vigor.

Anaerobic conditions and elevated carbon dioxide levels are often found in compacted soils; these alter

growth conditions for soil micro- and macrofauna (USDA Forest Service 2010). Compaction is quantified

through metrics including soil bulk density (usually expressed in grams per cubic centimeter) and

resistance to penetration (kilopascals or bars of pressure). Increases in compaction reduces root

penetration and elongation; when compaction is to the point of plant impairment, this threshold is referred

to as the “growth limiting bulk density” and is most influenced by soil texture and associated pore size

distribution (Daddow and Warrington 1983). Finer-textured soils dominated by the silt and clay fractions


92

of the soil textural triangle have smaller pore space diameters than coarser, sandier-textured soils and are

therefore inherently more susceptible to compaction. Conversely, rock fragments and soil organic matter

create macropores and resist compaction. Soil moisture content is another important controlling variable

of bulk density and penetration. As clay and organic-rich soils dry out both penetration resistance and

bulk density increase. However, increases in soil resistance to penetration do not always correlate to

higher soil bulk densities; again, soil texture is an important determinant of this process (USDA Forest

Service 2010).

Soil compaction from implementation of the proposed action is expected to be minimal. Treatments

include helicopter harvesting of timber and treating fuels through hand cutting and piling and burning in

treatment areas on approximately 194 treatment acres. Soil compaction would be minimal because no

ground-based equipment would be used for harvest. Further, Forest Plan standards, guidelines, and

project design criteria would be adhered to that provide operational guidelines for project activities that

would protect soils from compaction and maintain soil productivity.

Pile burning would not lead to increased soil compaction because it would be done by hand. Damage to

soil productivity in the form of organic matter loss, nutrient volatilization, and surface exposure does

occur from the burning of unwanted woody biomass (McMullen 2015). These effects are localized and

can be minimized and/or controlled through project design and implementation of mitigation measures. A

list of these is found in the appendix of this report and would ensure compliance with Forest policy and

management direction.

High levels of rock fragments in many areas offset compaction risk in project area. The ability of the soil

to function as a substrate for future forest growth (soil productivity) is unlikely to be constrained under

the proposed action. Management and policy directives that provide for retention of specific levels of

coarse and fine woody debris following timber harvest should help provide for adequate supplies of

nutrient and organic matter pools on the forest floor.

Soil Erosion and Soil Stability. Of all the activities associated with forest management, road networks

have the greatest impact on soil erosion and sedimentation (USDA Forest Service 2010). Transportation

networks are necessary for logging operations, but their compacted surfaces have miniscule infiltration

rates and could generate surface runoff as a result. Undisturbed forest soils can accept 1.5 to 3 inches of

moisture per hour following precipiation events (Robichaud 2000). Road surfaces and associated

infrastructure (ditches, fill slopes, cut slopes) have infiltration rates of 0.004 to 0.4 inches per hour, with

resultant overland flow, soil erosion, and stream sedimentation. Slash filter windrows, proper road

surfacing and tire inflation, ideal sizing of road aggregate, and armoring of ditches can mitigate some of

the deleterious effects of road construction and use on forests.

Timber harvesting temporarily reduces forest cover and consequently decreases the interception and

transpiration of atmospheric moisture (USDA Forest Service 2010). The subsequent effects of this to soil

erosion and water yields varies according to precipitation regime, the amount of canopy removal, and

underlying soil compaction. Similarly, direct effects from harvesting equipment differs with the intensity

of operations, harvesting practice (clear-cutting or shelterwood cuts versus single-tree or group selection),

and the amount of bare ground and existing soil disturbance prior to the current logging operations. Hand

felling with helipcopter removal of material would decrease soil erosion relative to harvesting methods

that use skidding and yarding, because the former method typically does not drag logs across the ground.

Helicopter yarding has intrinsically low rates of soil disturbance due to the lack of ground contact.

Modelling of soil responses to the project was done on unit 2 using the U.S. Forest Service Diturbed

WEPP model (USDA Forest Service 2000). Results showed that under current pre-project conditions

there was a small amount of surface runoff from the site. This is likely because older, mature trees tend to


93

use less water than younger trees. Once vegetation treatments ccur, little to no runoff is estimated from

unit 2, mainly because younger trees grow more vigorously and transpire more soil moisture. If a large-

scale high-severity wildfire were to occur in unit 2, a larger increase in runoff occurs (Table 17), and

sediment levels exported from the site increase. Increased soil moisture after wildfires can lead to

increases in landslides and debris flows. Modelling shows that there is a benefit to treating fuels and thus

reducing wildfire risk. Fuel treatments can reduce the risk of increasing post-wildfire site runoff and

erosion, and possibly even reduce landslide risk by decreasing wildfire risk.

Table 17. Sediment and runoff modelled results using disturbed WEPP, Vail Intermountain Project

Patch Cut Unit 2; 10 Year Period

Modelled Condition Runoff (in) Sediment (tons/ac)

Pre-project 0.02 0

Forest Thinning 0 0

Wildfire 0.07 0.01

Damage to soils in the form of organic matter loss, nutrient volatilization, and surface exposure would

occur from the pile burning of unwanted woody biomass (slash). However, these effects would be

localized, not exceed detrimental soil standards, and would be minimized and/or controlled through

project design crtieria and implementation of best management practices that would ensure compliance

with Forest policy and management direction.

Predicted site soil stability for the Vail Intermountain Project Area ranges from slight to severe hazard.

Much of the project area consists of landslide deposits, and this reflects a past history of landslides in this

area. This project is not expected to have a direct or indirect effect on landslide frequency or magnitude.

Hand-falling trees and helicopter removal or burning onsite within the units would not substantially

increase soil instability. Where live trees are removed from an area such as in patch cut units, increased

soil moisture is not expected to lead to direct or indirect effects on soil instability because slopes are

relatively lower in these areas, and they are not located in areas with recent landslide history.

Two soils mapped (Table 16) within the bounds of the proposed timber sale have erosion factors (K)

values that exceed 0.26, the threshold for what are considered erodible soils on this project. However, no

erosion was observed in these soil types during field surveys. Hand falling, helicopter yarding, and pile

burns are not likely to increase erosion risk even on soils with higher K values. Reclamation of landings

on Forest Service land should offset some of the increases in soil erosion, sedimentaion, and runoff that

may accompany landing construction and use in the project area.

Cumulative Effects

Cumulative impacts result from the incremental impact of the proposed action when added to other past,

present, and reasonably foreseeable future actions.

The cumulative effect area for the project soils is the project treatment units. Within the temporal and

spatial bounds of the Vail Intermountain Project, a variety of land use and management activities have

had variable impacts to soil resources of the area. Past timber harvests, road use and construction, grazing

by wildlife and livestock, and recreation have all contributed to minor amounts of localized soil

disturbance. Historic, current, and future outbreaks of mountain pine beetle mortality in lodgepole pine

can reasonably be expected to shape the landscape of the project area and the surrounding environs.

Despite these realities, existing soil conditions are likely to remain relatively stable in spite of the

cumulative effects of the past, present, and future activities. The additive impacts of this project on the


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project area are not anticipated to contribute significantly to cumulative effects on soil resources if design

criteria and management directives are followed.

Irreversible and Irretrievable Commitment of Resources

Soil is a very slowly renewable resource as estimates for rates of soil formation range from 0.0056 to

0.00078 centimeters per year (Alexander 1998). Globally, rates of soil formation are not keeping pace

with erosion, leading to widespread soil loss that is due in part to logging operations on public lands. In

this sense, logging-induced erosion is essentially an irreversible and irretrievable commitment of

resources. The loss of soil organic and mineral matter and earth materials through timber harvesting

would potentially be offset by soil organic matter accumulation that accompanies regenerative growth of

the trees, shrubs, grasses, and forbs on forest land. The scale of soil loss is not expected to be such that

the proposed action cannot proceed; adherence to design criteria and best management practices should

keep soil erosion to minimal levels that fall well within tolerances for acceptable loss.


This project is consistent with Forest Plan and other regulatory direction for soils management. To ensure

Forest Plan compliance, mitigation measures including best management practices and project design

criteria are prescribed for this project and are listed in the appendix.

Botany


The botany analysis area contains elevations between approximately 7,800 and 10,400 feet; however,

activities are proposed only in areas with elevations of approximately 8,000 to 9,200 feet. The vegetation

is dominated by lodgepole pine and aspen communities. Within proposed treatment units as a result of

canopy gaps created by lodgepole pine mortality, aspen is becoming more widely established in the

understory as more sunlight reaches the forest floor. Spruce and fir understories are randomly spaced and

patchy. Aspen stands are usually replaced by these slower growing species over the long term. Table 18

shows the mapped Region 2 vegetation cover types found in the analysis area.

Table 18. Botany analysis area vegetation cover types

Cover Type Acres Percent of Analysis Area

Grasslands 776 24

Forblands 103 3

Aspen 958 30

Cottonwood 4 <1

Blue spruce 44 1

Douglas-fir <1 <1

Lodgepole pine 1,289 40

Engelmann spruce/subalpine fir <1 <1

Bare 42 1

Water 21 <1

TOTAL 3,237 100


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Existing Conditions

Extensive surveys for rare plants and invasive species were completed in a portion of Vail Ski Area

immediately east of the project area in 2010. As might be expected, several infestations of invasive plants

were located, but very few rare plants were found. Three occurrences of unidentified Botrychium species

were discovered toward the top of the ski slopes. In 2015, White River National Forest biologists

conducted a survey of the project area and no additional threatened, endangered, or sensitive plants were

found. No threatened, endangered, or sensitive plants are known to exist in the project area or near

landings or haul routes, but habitat may be present for some species.

Threatened, Endangered, and Proposed Plants

Table 19 lists threatened, endangered, or proposed plants identified as present or suspected on the White

River National Forest (USDA Forest Service 2015b), and were assessed for the possibility of suitable

habitats being present in the analysis area.


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Table 19. Threatened, endangered, and proposed plants evaluated

Scientific Name/ Common Name/ (Status) Habitat

Species present?

Habitat present?

Effects analysis needed?

Eutrema penlandii Penland alpine fen mustard (Threatened)

Alpine tundra, stream banks and wetlands; Mosquito Range above 11,800 feet; Dillon Ranger District

No No No. No Effect.

The project area is outside the geographic and elevation range of this species.

Phacelia submutica DeBeque phacelia (Threatened)

Semi-desert shrublands and pinyon-juniper; Wasatch Formation; below 6,700 feet; Rifle Ranger District



Sclerocactus glaucus Colorado hookless cactus (Threatened)

Semi-desert shrublands and pinyon-juniper; Wasatch Formation; below 6,200 feet; Rifle Ranger District



Spiranthes diluvialis Ute ladies’-tresses (Threatened)

Seasonally moist soils and wet meadows of drainages and margins of ditches; below 7,200 feet; suspected in Eagle, Garfield, and Pitkin counties


The project area is outside the elevation range of this species.

Because no suitable habitats for threatened, endangered, or proposed plant species exist in the project

area, there would be no effect to Eutrema penlandii, Phacelia submutica, Sclerocactus glaucus, or

Spiranthes diluvialis. There is no need to consult with the U. S. Fish and Wildlife Service for these

species; these will not be discussed further in this document.

Region 2 Sensitive Plants

The Region 2 Sensitive Species List was recently updated with the addition of one plant (Packera

mancosana [not suspected on the Forest]), removal of two plants (Botrychium lineare and Eriophorum

altaicum var. neogaeum), and nomenclature changes for several species (USDA Forest Service 2015a). In

a separate document, Region 2 sensitive plants are identified as present or suspected on the White River

National Forest (USDA Forest Service 2015b). The current Region 2 sensitive plants (Table 20) were

assessed for the possibility of suitable habitats being present in the analysis area.


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Table 20. Region 2 sensitive plants evaluated

Scientific Name/ Common Name Habitat

Species present?

Habitat present?


Armeria maritima ssp. sibirica Siberian sea thrift

Grassy tundra slopes, wet, sandy or spongy organic soils on south-facing slopes; Hoosier Pass and Hoosier Ridge; 11,900 to 13,000 feet

No No No. No Impact.

The analysis area is below the elevation range of this species.

Astragalus leptaleus

Park milkvetch

Moist, sedge-grass meadows, swales, turfy hummocks on edge of meandering brooks, and typically on level to gently sloping ground; 6,500 to 9,500 feet


Low-gradient streams or sedge-grass meadows are not present in areas of proposed activities.

Botrychium ascendens

Trianglelobe moonwort

Road sides, trails, earthen dams, and old ski runs; Montane short and tall riparian willow communities with high moss, gravel and cobble ground cover, on volcanic or granitic alluvium; 8,000 to 10,845 feet

No Yes Yes

Braya glabella

Smooth northern-rockcress

Alpine; on sparsely vegetated, gravelly slopes of calcareous substrates above timberline; on disturbed sites related to inactive mines; 11,200 to 13,200 feet


The analysis area is below the elevation range of this species.

Carex diandra

Lesser panicled sedge

Fen on peat or on mossy floating logs in spring fed ponds; 6,100 to 8,600 feet


Fens or ponds with mossy floating logs are not present in the analysis area.

Carex livida

Livid sedge

Fen on peat; often calcareous or rich fens; above 6,398 feet


Fens do not exist in the analysis area.

Cypripedium parviflorum

Yellow lady’s slipper

Riparian/wetlands or transitional to cottonwood, aspen and conifers; 7,400 to 8,500 feet

No Yes Yes

Draba exunguiculata

Clawless draba

Alpine fell fields; 11,700 to 14,000 feet


The analysis area is below the elevation range for this species.

Draba grayana

Gray’s draba

Alpine in gravelly slopes and fell fields; 11,500 to 14,000 feet



Draba weberi

Weber’s draba

Splash zones, among the rocks along streams and lakes and spruce forests; above 11,000 feet



Drosera rotundifolia

Roundleaf sundew

Fens which are poor or intermediate poor on floating mats, also in iron fens; 9,100 to 9,800 feet




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Species present?

Habitat present?


Epipactis gigantea

Giant helleborine

Seeps on sandstone cliffs and hillsides; springs, especially hot springs when elevation above 8,500 feet

No Possible Yes

Eriophorum chamissonis

Chamisso’s cottongrass

Bogs, swamps, and marshes in montane and subalpine zones; 7,350 to 8,320 feet



Eriophorum gracile

Slender cottongrass

Fens on floating mats of peat; often calcareous; 6,900 to 12,000 feet



Kobresia simpliciuscula

Simple bog sedge

Fen in flooded marshy areas often with Carex simulata and Triglochin spp.; 6,000 to 12,800 feet



Machaeranthera coloradoensis

Colorado tansyaster

Mountain parks to dry alpine tundra, little competing vegetation; open exposure; 7,675 to 12,940 feet


Mountain parks to dry alpine tundra habitats do not exist in the analysis area.

Parnassia kotzebuei

Kotzbue’s grass of Parnassus

Riparian subalpine and alpine wet, rocky ledges, in mossy streamlets; 10,000 to 12,000 feet


The areas of proposed activity are below the elevation range for this species.

Penstemon harringtonii

Harrington’s beardtongue

Open sagebrush slopes or among pinyon-juniper; calcareous parent material; 6,800 to 9,200 feet


Open sagebrush slopes and pinyon-juniper habitats do not exist in the analysis area.

Ptilagrostis porteri

Porter’s false needlegrass

Fens on hummocks among willows, mostly on peat soils; 9,200 to 12,000 feet



Ranunculus grayi

(previously Ranunculus karelinii)

Ice cold buttercup

Among rocks and scree on exposed summits, slopes; 12,000 to 14,100 feet



Rubus arcticus ssp. acaulis

Dwarf raspberry

Riparian/wetland species with willow or wet partially shaded under spruce; 8,600 to 9,700 feet

No Possible Yes

Salix candida

Sageleaf willow

Fens which are calcareous, among other willows; 6,600 to 9,200 feet



Salix serissima

Autumn willow

Fens which are calcareous, among other willows; 7,800 to 9,720 feet




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Species present?

Habitat present?


Sphagnum angustifolium

Peat moss

Nutrient-poor fens including iron fens and intermediate poor fens; found in depressions between hummocks or on large hummocks or “carpets” of peat mosses; 9,600 to 11,483 feet



Sphagnum balticum

Baltic bog moss

Wet portions of acidic peatlands (iron fens); iron fens, strongly acidic yet high calcium content; hollows of fens or bogs rather than hummocks; 9,600 to 11,483 feet



Thalictrum heliophilum

Cathedral Bluff meadow-rue

Steep talus slopes; open, hot, dry sites; soils from Green River Formation; light colored saline/clays; shifting substrates harsh sites 6,300 to 8,800 feet


Steep talus slopes on hot, dry sites are not present in the analysis area.

Utricularia minor

Lesser bladderwort

Fens in shallow water; open grown or partially shaded; 5,500 to 9,000 feet



Viburnum opulus var. americanum

American cranberrybush

Riparian and riparian transition to cottonwood, river birch and hawthorn; 6,000 to 7,000 feet


The analysis area is above the elevation range for this species.

Although no occurrences are known in the analysis area, the absence of four Region 2 sensitive plants

cannot be reasonably established because comprehensive botanical surveys have not been completed and

suitable habitats may be present. For this analysis, they are assumed to be present in areas of suitable

habitat. Only the following species will be carried forward into the effects analysis:



Epipactis gigantea


For the remaining 24 sensitive plants, no suitable habitats are present and, therefore, the Vail

Intermountain project would have “no impact” on these species, and they will not be discussed further.

Species Information


Botrychium species (moonworts) are small perennial ferns, and produce just one short-lived leaf with

sporangia above ground each year. For a number of years, new plants exist entirely underground as the

juvenile plants mature into reproductive individuals. It is also common for individual mature moonwort

plants to remain dormant underground in a given year and produce no above ground leaf (Ahlenslager and

Potash 2007). Some moonwort habitats, especially those created by human disturbances as well as fire,

are considered to be ephemeral, and moonworts must colonize newly available habitats to stay ahead of

successional changes (Zika et al.1995). They commonly occupy previously disturbed sites, where

exposed mineral soil provides conditions necessary for germination of its spores. In addition, moonworts


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require endophytic mycorrhizae for at least a portion of their life cycle, and the presence or absence of

this fungal associate probably plays a major role in the initiation of new populations. Moonworts tend to

occur in areas where some mineral soil is exposed or has been exposed within the last 10 to 30 years. This

probably has to do with the ability of arriving spores to percolate into the soil and perhaps also with the

establishment and ecology of the appropriate mycorrhizal fungi. Moonworts generally occupy mesic

habitats such as those found near lakes, streams, springs, and other damp sites, but they can also occur in

relatively dry locations, including roadsides and openings at higher elevations. It is common for several

Botrychium species to occur together in “genus communities”, where individuals of different species are

growing side-by-side in the same habitats (Beatty et al. 2003).

Botrychium ascendens generally prefers open or early successional habitats. While it is sometimes found

in the understory of forested habitat within its distribution in Oregon, most sites are in open, mesic

meadows (Beatty et al. 2003). Within Region 2, Botrychium ascendens is found within short and tall

riparian willow communities with significant moss, gravel, and cobble groundcover on volcanic or

granitic alluvium at 8,000 to 9,000 feet. On the Shoshone National Forest, Botrychium ascendens occurs

within openings of a dense willow canopy cover.

The major threat to moonwort species from logging and other vehicular activities is the actual physical

disturbance of the soil that may break root and mycorrhizae connections or uproot the moonwort plants

(Ahlenslager and Potash 2007). Additional effects from vegetation management activities can result from

changing habitat conditions such as shading, soil moisture, and possible weed influxes.

In the botany analysis area, Botrychium pinnatum and unidentified Botrychium species were documented

in 2010 on open ski runs near the top of the ridge at “Eagles Nest” (Colorado Natural Heritage Program

2015). Of the Region 2 sensitive species suspected in the analysis area, Botrychium ascendens has the

highest probability of being present because other Botrychium species are documented here and surveyors

are more likely to overlook the small plants. Potentially suitable and occupied habitats are assumed to be

present within areas of proposed activities.


Cypripedium parviflorum occurs in all five states of the USDA Forest Service Rocky Mountain Region. It

is a long-lived perennial orchid, usually 1 to 2 feet in height, with large, distinctive, showy flowers,

mostly restricted to calcareous derived soils. It is often associated with moist to saturated soils, but it may

also be found in dry soils. This species is associated with many different plant communities, elevations,

and aspects. The Colorado Rare Plant Guide (Colorado Natural Heritage Program 1997) describes its

habitat as aspen groves and ponderosa pine/Douglas-fir forests. Habitat of this species is quite variable

and cannot be described precisely (Mergen 2006). The Cypripedium parviflorum life cycle is associated

with mycorrhizal fungi, which are required for the survival of seedlings. Very little information is known

about the ecology or biology of C. parviflorum, and less is known about the mycorrhizal fungi (Mergen

2006). Cypripedium parviflorum is more common on shaded, cool, north-facing slopes (Mergen 2006);

therefore, the north-facing slopes of the analysis area may provide suitable habitat.

Plant collecting, timber harvest, road construction, grazing, and all other activities that cause habitat loss

are probably the greatest risks to Cypripedium parviflorum (Mergen 2006). Some management activities,

such as plant collecting and livestock grazing, may cause direct damage to plants while other activities

indirectly impact plants by altering their habitat. Most management activities, like recreation, weed

control, fire suppression, mining, fuelwood harvest, and prescribed fires, may kill individual plants or

change the habitat beyond a threshold that C. parviflorum can survive. Environmental risks to this species

include drought, flooding, and wildfire (Mergen 2006).


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Cypripedium parviflorum is not known to occur in the analysis area, but one occurrence is present on

lands managed by the White River National Forest in the Roaring Fork Valley (Davidson, B.; personal

observation, 2008). Cypripedium parviflorum has a relatively low probability of being present in the

analysis area because of the long distance from known occurrences and because its moderate size and

conspicuous stature is not easily overlooked. Potentially suitable and occupied habitat is assumed to exist

within areas of proposed activities.

Epipactis gigantea

Epipactis gigantea is a showy perennial orchid, 1 to 3 feet in height, which occurs from southern British

Columbia through the western United States, reaching inland as far as Texas, with one collection from

central Mexico. Throughout its wide range, it occurs infrequently, but can be locally abundant. Epipactis

gigantea occupies a variety of habitats; because it requires a constant supply of water, suitable habitats

include seeps, springs, and perennial streams (Rocchio et al. 2006). Most Colorado occurrences occupy

seeps, streambanks, and hanging gardens between 4,800 and 6,500 feet. The two highest occurrences in

Colorado (7,900 and 8,800 feet) are associated with geothermal springs. The fact that Epipactis gigantea

appears to prefer geothermally supported wetlands at higher elevations indicates that temperature may be

a limiting factor (Rocchio et al. 2006). This orchid species also requires mycorrhizal fungi for successful

establishment of seedlings. Within Region 2, occurrences are located in both shady and sunny locations.

Observations of known occurrences suggest several potential threats to Epipactis gigantea. In order of

greatest to least concern, these threats include recreation, exotic species invasion, water development,

domestic livestock grazing, urban development, timber harvest, and utility line construction/maintenance

(Rocchio et al. 2006). Maintaining an intact hydrological regime is the most significant conservation

element for Epipactis gigantea (Rocchio et al. 2006).

Epipactis gigantea is not known to occur in the analysis area or on the White River National Forest, and

the nearest documented occurrence is about 120 miles to the west in Mesa County, Colorado (Colorado

Natural Heritage Program 2015). Epipactis gigantea has a relatively low probability of being present in

the analysis area because of the long distance from known occurrences and because its moderate size and

conspicuous stature is not easily overlooked. Potentially suitable and occupied habitats are assumed to be

present within the analysis area, but it is not likely to occur in areas of proposed activities. It will be

analyzed for possible indirect effects.


Rubus arcticus ssp. acaulis (dwarf raspberry) is a small, perennial, herbaceous plant in the rose family

that is restricted to North America and possibly Siberia. Although a relatively widespread species,

occurrences of Rubus arcticus ssp. acaulis are few and tend to be widely separated and particularly

disjunct within the continental United States. In Region 2, this plant is known from mountainous areas in

Colorado and Wyoming. It is similar in appearance to wild strawberry, but with pink- to rose-colored

flowers.

Rubus arcticus ssp. acaulis typically requires mesic to wet conditions. It has been found in the understory

of moderate to dense canopy cover in spruce, spruce/willow, and occasionally willow dominated

communities (Fertig 2000), but generally prefers more open habitats. It has also been reported to grow in

boggy woods, marshes, mountain meadows, and alpine tundra (Fertig 2000).The current distribution data

suggest that this taxon may be found in any bog or fen area above 7,000 feet within Region 2 (Ladyman

2006).

The most likely immediate and potential threat to Rubus arcticus ssp. acaulis occurrences is habitat loss

(Ladyman 2006). Anthropogenic causes of habitat loss include human recreation activities, livestock


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grazing, and extraction of natural resources (e.g., timber and peat). Logging, recreation, and water

impoundments have been reported as the main threats to Rubus arcticus ssp. acaulis populations in

Wyoming. Road construction and improvements may pose a threat to some occurrences, particularly

those in Region 2. Water availability may be one of the most critical environmental variables for Rubus

arcticus ssp. acaulis, and any circumstance that leads to drier habitat conditions is likely to pose a

substantial threat (Ladyman 2006).

Rubus arcticus ssp. acaulis is not known to occur in the analysis area or on the White River National

Forest, and the nearest documented occurrence is about 55 miles to the northeast in Boulder County,

Colorado (USDA Forest Service NRM 2015). Rubus arcticus ssp. acaulis has a relatively low probability

of being present in the analysis area because of the long distance from known occurrences. Potentially

suitable and occupied habitats are assumed to be present within the analysis area, but it is not likely to

occur in areas of proposed activities. It will be analyzed for possible indirect effects.




Under the no-action alternative, current management would continue in the analysis area. There would be

no new treatments or actions as described in the proposed action; therefore, no direct or indirect effects

would result from this alternative. Because there would be no direct or indirect effects, no cumulative

effects would occur.

Alternative 1 (no action) would have “no impact” to any Region 2 sensitive plant species.


Direct effects occur at the same time and place as the action causing the effect. Direct impacts may

include breaking, crushing, or uprooting sensitive plants from contact by equipment, materials, or

personnel. Individual plants or populations may be covered by slash, chips, or soil and could also have

trees fall on them, potentially damaging the plants or interrupting photosynthesis and reproduction

processes. Individuals or populations could also be burned by prescribed fire.

Indirect effects occur at a later time or in a different location as the action causing the effect. Examples of

indirect effects include changes in microclimate conditions such as increased light or reduced moisture

caused by canopy thinning or removal, the introduction of invasive plants and subsequent changes in

plant communities and competition, or increased erosion caused by bare, disturbed soil. The proposed

action could indirectly impact sensitive plants through the following processes:

Causing changes in vegetation composition and cover;

Changing local hydrologic functions in plant habitat;

Changing soil characteristics and erosion potential;

Introducing and creating habitat for invasive plants; and

Impacting pollinators or mycorrhizal fungi associated with sensitive plants.

Direct Effects

If present, threatened, endangered, or sensitive plants may be damaged or killed by the felling of trees and

associated trampling of vegetation by project personnel. Equipment may also damage threatened,


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endangered, or sensitive plants during road maintenance activities and the creation and/or use of landings.

Pile burning may scorch or consume threatened, endangered, or sensitive plants. These direct effects

could result in the loss of individuals or small occurrences if they are present. Because their habitats may

be present within areas of proposed activities, direct effects are possible for Botrychium ascendens and

Cypripedium parviflorum. Due to the limited area of activity, continued existence of known occurrences

throughout their ranges, and future protection of sensitive plant occurrences if they are found, these direct

effects would not likely result in loss of viability or a trend toward Federal listing for these plants.

Because Botrychium ascendens is small and easily overlooked, and related species are known to occur in

the analysis area, it is the one threatened, endangered, or sensitive plant most likely to be affected. Other

threatened, endangered, or sensitive plants have a much lower probability of occurring in the analysis

area.

Indirect Effects

The removal of trees (living or dead) would increase the amount of light reaching the forest floor. This

often results in increased growth of understory species. Increased light may increase vegetation cover and

possibly cause shifts in species composition toward dominance by those plants that prefer more open

habitats. Canopy removal may be beneficial to those species which prefer open habitats, including

Botrychium ascendens and Rubus arcticus ssp. acaulis, by creating or maintaining sunny conditions.

Canopy closure does not appear to affect a habitat’s ability to support Epipactis gigantea or Cypripedium

parviflorum, because both species can be found in shady and open habitats (Ladyman 2006; Mergen

2006). Due to stream and wetland buffers, the canopy openings created by the proposed action would not

affect wet areas, and thus Epipactis gigantea and Rubus arcticus ssp. acaulis habitats would not be

affected by canopy removal. The longevity of the resulting canopy openings is not anticipated to last

beyond a few years because aspen regeneration is expected to quickly respond with vigorous growth of

new shoots. The amount of light reaching the forest floor would likely return to pre-project conditions

within 5 to 10 years. Areas with little or no aspen present would return to shaded conditions less quickly,

with young conifers beginning to intercept much of the sunlight within 10 to 20 years.

Varying levels of soil disturbance would occur from several activities, including tree removal, trampling

by project personnel, road maintenance, use of landings, pile burning, and movement of vehicles and

equipment. In addition to potential direct impacts to threatened, endangered, or sensitive plants, these

disturbances could provide suitable conditions of exposed mineral soil, which are important conditions

for seed or spore germination of Botrychium ascendens and the two orchid species, Epipactis gigantea

and Cypripedium parviflorum. Because Epipactis gigantea is more strictly associated with wet habitats,

and such habitats would be buffered from disturbance by a minimum of 100 feet, the disturbances are not

likely to offer suitable conditions for it to become established. Cypripedium parviflorum can occur in

drier sites as well as wet sites, so it is possible that soil disturbances could provide suitable sites for

colonization. Disturbed sites are also preferred by Rubus arcticus ssp. acaulis, but the riparian/wetland

buffers would likely prevent any modification of habitat for this species.

However, soil disturbance and movement of vehicles and personnel in the area would also provide

opportunity for invasive plant species to become established or spread within the analysis area. If invasive

plants become established within occupied habitat, individuals or whole populations of threatened,

endangered, or sensitive plants could be lost as a result of the change in plant community and resulting

competition for resources. With project design features specifying treatment and monitoring of weeds as

well as requiring weed-free equipment, the risk of increased weed infestations is low (Davidson 2015).

Soil disturbances may also negatively affect the soil biota, including mycorrhizal fungi needed for the

successful germination and establishment of new Botrychium and orchid plants. The magnitude of effect


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to the soil biota is not expected to be enough to prevent the possible establishment of new threatened,

endangered, or sensitive plants.

Piling and burning slash material has localized negative effects to the vegetation and soils. Fire would be

concentrated in small locations for an extended time. Vegetation would be scorched or consumed, and soil

properties are altered, resulting in bare patches of exposed, often hydrophobic soils. Invasive plant species

can easily colonize these sites if given the opportunity. The exposed soil may also provide suitable

conditions for Botrychium species to become established (Zika 2005).


Vail Mountain Recreation Enhancements Project. For decades, the Vail ski area has operated under a

special use permit allowing extensive recreational activities in the eastern portion of the botany analysis

area, such as downhill skiing, infrastructure maintenance, and visitor service improvements. While the ski

area has traditionally focused on winter recreation, increasing attention has been directed in recent years

towards summer and multi-season activities to accommodate demand for year-round recreation in the

Eagle Valley. Partially within the botany analysis area, Vail has operated summer and multi-season

activities since 1996 at “Adventure Ridge”, currently offering guests a variety of activities, including

pony rides, horse tours, jeep tours, disc golf, mountain biking, zip lines, and more. The Vail Mountain

Recreation Enhancements Project analyzed and authorized these activities, but did not authorize

implementation of a proposed mountain coaster or a wedding venue (USDA Forest Service 2014a).

The Biological Evaluation/Biological Assessment for the Vail Mountain Recreation Enhancements Project

analyzed in detail nine Region 2 sensitive plant species which could occur in the project area. That

analysis concluded that the project “may adversely impact individuals, but is not likely to result in a

loss of viability on the Planning area, nor cause a trend towards Federal listing or a loss of species

viability rangewide” for Botrychium ascendens, Botrychium lineare, and Botrychium paradoxum,

because undiscovered individuals may be affected. No occurrences of any Region 2 sensitive species

were documented in the project area, and a determination of “no impact” was made for the remaining six

plants (Astragalus leptaleus, Cypripedium parviflorum, Festuca hallii, Machaeranthera coloradoensis,

Parnassia kotzebuei, and Rubus arcticus ssp. acaulis) that may have had suitable habitats present (USDA

Forest Service 2014b).

Vail Valley Forest Health Project. In 2006 the Vail Valley Forest Health Project authorized vegetation

treatments in lodgepole pine, aspen, and mixed shrublands across a large area, including the current Vail

Intermountain Project Area. Within the Vail Intermountain Project Area, only aspen treatments were

authorized. The Final Environmental Impact Statement for the Vail Valley Forest Health Project disclosed

that the project “may adversely impact individuals, but is not likely to result in a loss of viability on

the Planning area, nor cause a trend towards Federal listing or a loss of species viability rangewide”

for Penstemon harringtonii, and that there would be “no impact” to three other Region 2 sensitive plant

species (Cirsium perplexans, Machaeranthera coloradoensis, and Ptilagrostis porteri) suspected of

occurring in that project area. No effects to Region 2 sensitive plant species were expected in the area that

overlaps the Vail Intermountain Project Area.

Other Activities. Ongoing activities by recreational users on National Forest System lands in the

currently proposed units include hiking, snowshoeing, and probably some out-of-bounds skiing. These

ongoing activities are not expected to have any effects on Region 2 sensitive plants or their habitats. No

other current uses have been identified.


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Discussion

Although the ground disturbances from all of the activities described above have potential to harm Region

2 sensitive plant individuals and habitats, they also may provide suitable sites for establishment of some

species, particularly Botrychium ascendens and Cypripedium parviflorum. Together, the combined effects

expected from all these activities is expected to have minimal influence on the presence of Region 2

sensitive plant species and their habitats.

Because there are policies and standards and guidelines that limit effects to sensitive plant species

habitats, the cumulative effects are not expected contribute to any change in status or viability. Also, the

cumulative effects are not expected to contribute to an increase in any current or predicted downward

trend in population numbers or density or to current or predicted downward trends in habitat capability

that would reduce the existing distribution of any of the Region 2 sensitive plant species carried forward

into this analysis.

Determinations

Although no occurrences are known in the analysis area, the absence of four Region 2 sensitive plants

cannot be reasonably established because comprehensive botanical surveys have not been completed and

suitable habitats may be present in the analysis area. For this analysis, they are assumed to be present in

areas of suitable habitat.


Although Botrychium ascendens is not known to exist in the analysis area, it is the most likely of all the

threatened, endangered, or sensitive plants to be present due to the presence of other Botrychium species

and their affinity for disturbed habitats. It is the determination that alternative 2 (proposed action) of the

Vail Intermountain project “may adversely impact individuals, but is not likely to result in a loss of

viability in the planning area, nor cause a trend toward Federal listing” for Botrychium ascendens.

Rationale for this determination:

No occurrences are known to exist in the analysis area, but suitable and possibly occupied habitat

may exist within areas of proposed activity.

The small size of this species makes it more likely that it may have been overlooked during field

reconnaissance.

Project activities may directly affect undiscovered occurrences, possibly damaging or killing

individuals.

Ground disturbances may create or maintain suitable conditions for establishment of new

occurrences or persistence of undiscovered occurrences.

Ground disturbances and movement of vehicles, equipment, and personnel may provide

opportunities for introduction or expansion of weed infestations.

Adverse effects are expected to be none or minimal due to the small area of activity and project

design features for protection of sensitive plants and prevention of weed infestations.

Riparian/wetland buffers would prevent or minimize impacts to a portion of the potentially

suitable habitats for these species.


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It is the determination that alternative 2 (proposed action) of the Vail Intermountain project “may

adversely impact individuals, but is not likely to result in a loss of viability in the planning area, nor

cause a trend toward Federal listing” for Cypripedium parviflorum.



may exist within areas of proposed activity.

Project activities may directly affect undiscovered occurrences, possibly damaging or killing

individuals.

Ground disturbances may create or maintain suitable conditions for establishment of new

occurrences.


opportunities for introduction or expansion of weed infestations.

Adverse effects are expected to be none or minimal due to the small area of activity and project

design features for protection of sensitive plants and prevention of weed infestations.

Riparian/wetland buffers would prevent or minimize impacts to a portion of the potentially

suitable habitats for these species.

Epipactis gigantea



cause a trend toward Federal listing” for Epipactis gigantea.



may exist within the analysis area; however, these would not be present in areas of proposed

activity.

Suitable and possibly occupied habitat may exist within the analysis area, but are not present in

areas of proposed activity.


opportunities for introduction or expansion of weed infestations, which may encroach into the

species’ riparian/wetland habitat.

Adverse effects are expected to be none or minimal due to the project design features for

protection of sensitive plants and prevention of weed infestations.

Riparian/wetland buffers would prevent or minimize impacts to the potentially suitable habitats

for these species.




cause a trend toward Federal listing” for Rubus arcticus ssp. acaulis.



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may exist within the analysis area; however, these would not be present in areas of proposed

activity.


opportunities for introduction or expansion of weed infestations, which may encroach into the

species’ riparian/wetland habitat.

Adverse effects are expected to be none or minimal due to the project design features for

protection of sensitive plants and prevention of weed infestations.

Riparian/wetland buffers would prevent or minimize impacts to the potentially suitable habitats

for these species.

Summary of Effects

No threatened, endangered, or sensitive plants are known to be present in the Vail Intermountain Project

Area. Within the project area, habitat may be present for the following Region 2 sensitive plants:



Epipactis gigantea


Due to vegetation and soil disturbances and the possibility of increased weed infestations, these plants and

their habitats may be impacted by the proposed action, but it would not likely result in a loss of viability

in the planning area, nor cause a trend toward Federal listing. Effects include the possibility of direct

damage to undiscovered occurrences as well as the possibility of habitats being maintained or created by

the disturbance (for Botrychium ascendens and Cypripedium parviflorum). Even though design features

would reduce the risk of increased weed infestation to a low level, there is the possibility that some

increases in weeds could occur and may affect all of the Region 2 sensitive plant habitats present. All

other threatened, endangered, or sensitive plants would be unaffected by the proposed action because their

habitats are not present.

The table below summarizes biological determinations by alternative for the four sensitive plant species

that were carried forward in this analysis.

Table 21. Summary of determinations for threatened, endangered, or sensitive plants

Species Alternative 1 (No Action) Alternative 2 (Proposed Action)

Botrychium ascendens No Impact MAII1

Cypripedium parviflorum No Impact MAII1

Epipactis gigantea No Impact MAII1

Rubus arcticus ssp. acaulis No Impact MAII1

1 Assuming presence, may adversely impact individuals, but not likely to result in a loss of viability in the planning area, nor cause a

trend toward Federal listing.


Alternatives 1 and 2 would comply with the Endangered Species Act because no federally listed or

proposed species or their habitats would be affected. Both alternatives would maintain viable populations

of all native and desired nonnative plants, and the proposed activities were reviewed for potential effects

on rare species, and thus would be compliant with Forest Service Manual direction. Both alternatives


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would also comply with the White River National Forest LRMP because there would be no disturbance to

sensitive species which would result in a trend toward Federal listing or loss of population viability.

Weeds


Existing Conditions

The White River National Forest weeds program implements prevention, education, and control activities

in accordance with the White River National Forest Invasive Plant Species Management Environmental

Assessment (USDA Forest Service 2007). Weed inventory, control, and monitoring activities are

scheduled and implemented as funding and other priorities allow.

Extensive surveys for rare plants and invasive species were completed in a portion of Vail Ski Area

immediately east of the project area in 2010. As might be expected, very few rare plants were located, but

several infestations of invasive plants were found. Proposed landing #3 and haul route #3 are located

within this portion of Vail Ski Area (see map in appendix A, Weeds Report). In 2015 White River

National Forest biologists conducted a survey of the project area and discovered additional weed

infestations within the project area. Documented weed infestations are listed in the following table.

Table 22. Weed infestations in the analysis area

Scientific Name Common Name

Colorado Weed Rating

# Infestations in Analysis

Area # Infestations Within or Near Areas of Proposed Activities

Carduus acanthoides Spiny plumeless thistle B 3 1 infestation about 200 feet northwest of landing #3

Cirsium vulgare Bull thistle B 2 0

Cynoglossum officinale Houndstongue B 2 1 infestation in a meadow just south of unit #4

Leucanthemum vulgare Oxeye daisy B 16 6 (5 infestations within 300 feet of haul route #3; 1 infestation within treatment unit #3)

Linaria dalmatica Dalmatian toadflax B 4 2 infestations within 300 feet of haul route #3

Linaria vulgaris Butter and eggs, yellow toadflax

B 10 8 (2 infestations within 300 feet of haul route #3; 6 infestations within or near treatment units #2, 3, and 4)

Onopordum acanthium Scotch thistle B 2 1 infestation within 300 feet of haul route #3


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In the no-action alternative no proposed activities would contribute to the current level of weed

infestation in the project area. There would be no direct or indirect effects to weeds, and hence there

would be no cumulative effects.

Existing weeds would continue to occupy the infested areas, and would provide seed sources for

establishment of additional infestations. Recreational use, administrative access, wildlife movement, and

even wind events may introduce new weed species or spread existing infestations, as these are common

vectors for seed dispersal. However, weed control activities would also continue to occur in accordance

with the White River National Forest Invasive Plant Species Management Environmental Assessment.

With ongoing control treatments and no additional activities and disturbances planned, no substantial

increase in weed infestation is expected under the no-action alternative. There would be a low risk of

spreading or introducing weeds with this alternative.

Table 23. Weeds indicators and measures for alternative 1

Resource Indicator Measure Alternative 1

Weed risk of spread/infestation

Level of weed risk Low risk



With increased vehicle traffic and ground disturbance, each of the infestations listed in table 22 has

potential to expand. Although the weed species known to occur in the analysis area are the most likely

ones to present a risk of further infestation, any of the weed species listed in appendix B of the Weeds

Report could be introduced to the area.

Soils disturbed by project activities can provide ideal habitat for weeds. Many weeds take advantage of

disturbance to invade native plant communities. Weed seeds and plant parts can be carried in soil

clinging to machinery, vehicles, and clothing, to be deposited in weed-free areas. Roads can also

facilitate invasion and spread by altering habitat conditions, stressing or removing native species, and

allowing easier movement of wild or human vectors. Gelbard and Belnap (2003) found that wider

roadsides, often a result of road improvements, create more disturbed habitat in which native vegetation

has been removed, and can be easily colonized by weed species. The direct effect of ground disturbing

activities on weeds is to increase the area available for weed colonization. Indirect effects of project

activities such as vegetation removal and hauling wood products would include the possible establishment

of new weed populations or the expansion of existing populations into newly disturbed areas.

Effects to other resources associated with weed population expansion may include declines in the

palatability or abundance of wildlife and livestock forage, declines in native plant diversity, reductions in

the aesthetic value of the landscape, encroachment upon rare plant populations and their habitats,

potential reductions in soil stability and subsequent increases in erosion, and an overall decline of

ecosystem health.


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The greatest potential for the establishment of weeds comes from activities that disturb the soil and open

the canopy. The risk of weed spread increases as the extent of disturbance increases and the tree canopy

opens. The proposed vegetation management activities would produce localized soil disturbance and

increases in light to the forest floor. The resulting conditions would be highly favorable for weed

colonization.

Design features for reducing the spread of weeds include preventive measures such as cleaning equipment

and monitoring for new weed infestations, and control measures to be implemented and monitored for

effectiveness. Full implementation and priority of these measures would substantially reduce the risk of

increasing weeds as a result of the proposed activities from moderate to low. If prevention and control

measures do not receive a high priority and result in less than full implementation, the risk of increasing

weeds due to proposed activities would remain moderate.


Vail Mountain Recreation Enhancements Project. For decades Vail ski area has operated under a

special use permit extensive recreational activities in the eastern portion of the botany analysis area,

including downhill skiing and its associated activities of infrastructure maintenance and visitor service

improvements. While the ski area has traditionally focused on winter recreation, increasing attention has

been directed in recent years towards summer and multi-season activities to accommodate demand for

year-round recreation in the Eagle Valley. Partially within the botany analysis area, Vail has operated

summer and multi-season activities since 1996 at “Adventure Ridge”, currently offering guests a variety

of activities, including pony rides, horse tours, jeep tours, disc golf, mountain biking, zip lines, and more.

The Vail Mountain Recreation Enhancements Project analyzed and authorized these activities, but did not

authorize implementation of a proposed mountain coaster or a wedding venue (USDA Forest Service

2014).

With design features similar to those described above for the Vail Intermountain Project, the noxious

weeds analysis for Vail Mountain Recreation Enhancements Project disclosed the presence of six noxious

weed species in that project area. The preventive measures and required monitoring and treatments are

assumed to result in a low risk of spreading noxious weeds due to the Vail Mountain Recreation

Enhancements Project.

Vail Valley Forest Health Project. In 2006 the Vail Valley Forest Health Project authorized vegetation

treatments in lodgepole pine, aspen, and mixed shrublands across a large area, including the current Vail

Intermountain Project Area. Within the Vail Intermountain Project Area, only aspen treatments were

authorized. The Final Environmental Impact Statement for the Vail Valley Forest Health Project disclosed

that the project area contained 11 weed species. An estimated 1,340 acres within the project area were

infested with noxious weeds. Approximately 800 infested acres were within 0.5 mile of proposed

treatment areas. The design criteria such as revegetation, as well as treatment of known populations,

would reduce the likelihood of colonization after disturbance, and are assumed to result in a low risk of

spreading noxious weeds due to the Vail Valley Forest Health Project.

Other Activities. Ongoing activities by recreational users on National Forest System lands in the

currently proposed units include hiking, snowshoeing, and probably some out-of-bounds skiing. These

ongoing activities are not expected to have any effects on Region 2 sensitive plants or their habitats. No

other current uses have been identified. These uses carry a low risk of introducing or spreading noxious

weeds, especially snowshoeing and skiing. Because many weed seeds can easily attach themselves to

clothing, summertime hikers may inadvertently pick up and/or deposit weed seeds and thus contribute to

the spread of weeds.


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Weed treatments would continue as part of the Forestwide weeds program, and would likely occur in

various places according to available funding and other priorities.

Discussion

Soil disturbances from the Vail Mountain Recreation Enhancements and Vail Valley Forest Health

Projects would likely result in conditions suitable for colonization by weeds. However, project design

features to prevent or minimize weed increases should be effective. In addition, these project activity

areas have been and will be monitored and treated for weeds for 5 years after implementation. These

measures greatly reduce the likelihood of weed infestations expanding due to the projects. When the low

likelihood of weed increases from the currently proposed Vail Intermountain Project is added to the

expected level of weed increases from the current and previous activities, the cumulative level of risk

from expanding weed infestations would still be low, due to additional monitoring and treatments of

weeds.

Table 24. Weeds indicators and measures for alternative 2

Resource Indicator Measure Alternative 2

Effects of Past, Present, and Future Actions

Alternative 2 with Cumulative Effects


Level of weed risk

Low risk Low risk Low risk

Seven weed species, including spiny plumeless thistle, bull thistle, houndstongue, oxeye daisy, Dalmatian

toadflax, yellow toadflax, and Scotch thistle, are present in the areas proposed for activity, including

treatment units and access roads. To prevent undesirable effects to several resources, project design

features would be implemented. Weeds would receive control treatments before the project activities

begin. Monitoring and additional control treatments would occur after project activities are completed.

Reasonable measures, including equipment washing, would be taken to ensure that any off-road

equipment brought into the project area would be free of weed seeds or propagules. These measures

would significantly reduce the risk of introducing or spreading weed infestations due to project activities.

Table 25. Summary comparison of environmental effects to weeds

Resource Indicator Measure Alternative 1 Alternative 2


Level of weed risk Low risk Low risk


With the evaluation of project effects, risk of weed spread, and implementation of design features for

weeds, the proposed project would be in compliance with the White River National Forest Land and

Resource Management Plan, Forest Service Manual 2900, Rocky Mountain Region’s Invasive Species

Strategy, and Executive Order 13112.

Fisheries and Aquatic Macroinvertebrates


The project area is located within the Gore Creek Watershed, a 62,000-acre 4th-order stream (Figure 1 and

Figure 2). Five small ephemeral 1st- and 2nd-order non-fish bearing streams of between 100 and 300 acres

in watershed area drain most of the project area.


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Existing Conditions

All Trout. All streams in the project area are high-gradient ephemeral streams that are absent of trout

populations. Gore Creek immediately downstream of the project streams, but outside of the project

boundary, contains various species of trout.

Colorado River Cutthroat Trout. The project area streams draining into Gore Creek do not have habitat

that could support Colorado River cutthroat trout. The primary factor limiting the presence of Colorado

River cutthroat trout in streams within the South Gore Creek Subwatershed is the dominance of nonnative

trout populations. Nonnative brown, rainbow, and brook trout, with an occasional cutthroat trout,

dominate the Gore Creek stream reach immediately downstream of the project area (Grove, M.; personal

communication, 2015).

Macroinvertebrates. Samples collected near the confluence with Gore Creek indicated impairment,

most likely influenced by urbanization that starts just below the Forest boundary. The segment of Gore

Creek that receives Buffehr and Red Sandstone creeks is listed for impairment under the Clean Water Act,

section 303(d).

None of the samples collected in this segment of Gore Creek received attaining multi-metric indexes

scores. The segment flows from the confluence with Black Gore Creek to the confluence of the Eagle

River and is heavily influenced by urbanization from the Town of Vail. Impacts include unmanaged and

untreated storm water, waste water treatment effluent, golf courses, loss of riparian habitat, loss of

floodplain, and other urban development. It does not appear at this time that sediment is a limiting factor

or source of degradation in Gore Creek (Grove, M.; personal observation, 2015). Sampling stations

located on national forest land upstream of this segment meet attaining multi-metric indexes scores.

Again, urban development and influence begins just below the Forest boundary and appears to be the

main source of degradation in this reach.



Direct, Indirect, and Cumulative Effects for All Trout and Macroinvertebrates

Under the no-action alternative, vegetation management treatments would not occur. Lodgepole pine in

this area may continue to experience mortality from bark beetle infestation, and standing dead trees would

weaken and eventually fall to the ground. Timber harvest activities would not take place and water yield,

water quality, stream health, riparian area conditions, macroinvertebrate communities, and fish

populations would remain in their current condition and would not be altered. Trout and

macroinvertebrate communities in Gore Creek segments downstream of the project area would be

expected to maintain current community levels.


Direct, Indirect and Cumulative Effects for All Trout and Macroinvertebrates

No temporary roads would be built inside the project boundary or to access units. Incremental increased

water yield, mainly in the form of spring runoff, is not expected as a result of the proposed action. There

would be no timber felling or skidding in the water influence zone and no temporary roads would be built

that may have crossed any perennial or intermittent stream channels. Perennial or intermittent streams

would have buffer widths for the water influence zone of 111 feet of either side of the channel as a project

design feature.


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By protecting the water influence zone, stream health is expected to be maintained in its current condition

and would not negatively affect aquatic management indicator species habitat. There are no detectable

effects expected to aquatic management indicator species habitat as a result of the proposed action. Trout

and macroinvertebrate communities are expected to maintain current community levels in the project

area. The project would not negatively or positively affect Forestwide trends for these species.

Furthermore, 303(d) listed segments in Gore creeks are not expected to be negatively or positively

affected by the proposed action. These segments appear to be degraded by urban development. By

protecting the water influence zone stream health is expected to be maintained in its current condition and

the proposed project activities would not negatively affect 303(d) impaired segments downstream of the

project area.

Cumulative Effects

Management activities that occur or have occurred within or in the vicinity of the project include bark

beetle hazard tree clearing along roads and trails, grazing by wildlife and livestock, road use and

construction, vegetation management, and fuels reduction projects. These past, present, and ongoing

activities have the potential to affect stream habitat in the project area. However, there are no negative

affects expected as a result of the proposed action and stream health, both physical and biological, is

expected to be maintained. Since there are no significant negative direct or indirect effects expected to

aquatic resources as a result of the proposed action, there are no expected cumulative effects above the

baseline condition associated with the proposed action.

Summary of Effects to Aquatic Management Indicator Species

The implementation of the proposed action would neither contribute towards nor negatively affect

meeting aquatic management indicator species objectives at the Forestwide scale. Physical habitat quality

would be maintained in its current condition under both alternatives. Long-term effects to trout or aquatic

macroinvertebrate populations as a result of the proposed alternative would not result in any measurable

population trends at the project or Forestwide scale.

Determinations

Colorado River Cutthroat Trout

Alternative 1 (No Action). Under the no-action alternative, vegetation management treatments would not

occur. There would be no increased risk due to water yield increase or sediment impacts as a result of

timber management activities. Colorado River cutthroat trout habitat in the project area would remain in

its current state with nonnative trout dominating most of the available stream habitat. Therefore, the no-

action alternative would have “no impact” to Colorado River cutthroat trout (Oncorhynchus clarkii

pleuriticus) and their habitat.

Alternative 2 (Proposed Action). Under the proposed action alternative, vegetation treatments would

take place on approximately 194 acres in the project area. Ground-based mechanical equipment would be

used to harvest and remove timber throughout the project area. Incremental increases of water yield are

expected as a result, but would likely be offset by the storage capacity and resiliency of wetland

complexes found in project area streams. Physical stream health would likely maintain its current

condition, with no measurable effects either positive or negative. The presence of nonnative trout in

project area streams reduces the possibility that Colorado River cutthroat trout populations are occupying

project area streams. Colorado River cutthroat trout habitat in the project area would remain in its current

state with nonnative trout dominating most of the available stream habitat. Therefore, the proposed action

alternative would have “no impact” to Colorado River cutthroat trout (Oncorhynchus clarkii pleuriticus)

and their habitat.


114

Threatened, Endangered, and Proposed Fish Species

No water depletions are associated with this activity, therefore “no effects” are expected to bonytail (Gila

elegans), Colorado pikeminnow (Ptychocheilus lucius), humpback chub (Gila cypha), and razorback

sucker (Xyrauchen texanus). The greenback cutthroat trout (Oncorhynchus clarkii stomias) is the only

federally threatened, endangered, or proposed aquatic species found on the White River National Forest.

Based on current genetic analysis, there are four known greenback cutthroat populations on the Eagle-

Holy Cross Ranger District. However, greenback cutthroat trout do not occur in the project area or

streams directly downstream of the project area and therefore “no effects” are expected to greenback

cutthroat trout (Oncorhynchus clarkia stomias). No further analysis will be considered in detail in this

document.

Sensitive Species

No further analysis is needed for species that are not known or suspected to occur in the project area, and

for which no suitable habitat is present. No suitable habitat is found within the project area watershed for

bluehead, flannelmouth, and mountain suckers; roundtail chub; Colorado River cutthroat trout; boreal

toad; or northern leopard frog. Therefore, it is expected that there would be “no impact” to bluehead

sucker (Catostomus discobolus), flannelmouth sucker (Catostomus latipinnis), mountain sucker

(Catostomus platyrhynchus), roundtail chub (Gila robusta), Colorado River cutthroat trout

(Oncorhynchus clarkii pleuriticus), boreal toad (Anaxyrus boreas boreas), or northern leopard frog

(Lithobates pipiens) as a result of the proposed project.


The greenback cutthroat trout is listed as a threatened species under the Endangered Species Act which

directs all Federal departments and agencies to “conserve endangered and threatened species” and “utilize

their authorities in furtherance of the purposes of this Act.” Under section 4(f)(1) of the Act, the Secretary

shall develop and implement “recovery plans” for the conservation and survival of endangered species

and threatened species and their habitats (Public Law 93-205.) Perennial stream habitat that would

support greenback cutthroat trout is not found in the project area. Furthermore, receiving streams (Gore

Creek) are occupied by nonnative trout and greenback cutthroat trout do not occupy this habitat.

When the White River National Forest Plan was completed in 2002, no known populations of greenback

cutthroat trout were documented on the Forest. As a result, fish biologists apply the Forest Plan standards

developed for the protection and recovery of the Colorado River cutthroat trout to projects that affect

greenback cutthroat trout. Through project design criteria this project is meeting Forest Plan standards by

maintaining stream health in the project area and in receiving streams.

Operations and Safety


Existing Conditions

Log Truck Traffic. Interstate 70 and Town of Vail transportation systems would accommodate log

truck/chip van traffic. Some of the Town of Vail roads are narrow and wind through neighborhoods

before they collect on the south frontage road which parallels Interstate 70. The majority of these roads

are paved and meet Colorado Department of Transportation (CDOT) Gross Vehicle Weight Restriction

(GVWR) specifications. Forest Service roads on the Vail Resorts ski area are native surface roads able to

accommodate log truck/chip van traffic.


115

Noise. The West Vail area is subject to a variety of common noises associated with an active resort

community. Interstate 70 is a major transportation route through central Colorado and divides the Town

of Vail for approximately 10 miles. Highway traffic noise from Interstate 70 is prevalent during most

hours of the day and night. Construction projects such as a pedestrian underpass on Interstate 70, home

construction and re-modeling, and resort improvements are all common adjacent to the project area.

Project Safety. Projects undertaken within or adjacent to the project area need to follow local and State

permitting requirements, which include traffic control and safety plans. Each project may have different

requirements dependent on the size, location, and complexity of the project.

Table 26. Log truck traffic, noise, and project safety indicators and measures for the existing condition

Resource Element Resource Indicator Measure Existing Condition

Log Truck Traffic Logging trucks/chip vans Total number of trucks/chip vans 2040

Helicopter Noise Noise Decibels N/A

Helicopter Noise Noise duration (daily) Hours per day N/A

Helicopter Noise Noise duration (project) Days N/A

Project Safety Area closure Days 0




Fuel reduction treatments and associated activities with those vegetation treatments would not occur

under this alternative.

Log Truck Traffic. No additional logging truck/chip van activity beyond what is listed in Table 27 would

be expected since helicopter operations would not occur.

Helicopter Noise. No helicopter noise would be anticipated since helicopter operations would not occur.

Project Safety. No area closures would be anticipated since helicopter operations would not occur.

Table 27. Additional log truck traffic, noise, and project safety indicators and measures for the no-action alternative

Resource Element Resource Indicator Measure No Action


Helicopter Noise Noise Decibels 0

Helicopter Noise Noise duration (daily) Hours per day 0

Helicopter Noise Noise duration (project) Days 0


Cumulative Effects

There are no effects from the no-action alternative so no cumulative effects would occur.


116



Effects for log truck traffic, helicopter noise, and project safety are summarized in Table 27.

Log Truck Traffic. Direct Effects: The proposed action would add approximately 485 log truck/chip vans

to transportation system roads if the entire project was implemented using helicopter yarding. This log

truck/chip van traffic would most likely occur over two operating seasons (120 days) or approximately

243 log truck/chip vans per operating season. Log truck activity would be dispersed on various

transportation system roads based on the active landing area where trees are being processed. It may be

possible that two of the three landing areas could be used at the same time to improve efficiency of the

helicopter operation. Log truck traffic activity would be concentrated during active helicopter operations

because landing areas are expected to be small and compact. As many as ten log truck/chip vans per day

could be expected during operations.

Although helicopter operations would be restricted on weekends in all areas, other operations such as log

processing and log/chip hauling could occur on Saturdays and Sundays to shorten the operational periods

needed to remove forest products. The exception would be in the Vail Mountain Special Use Permit Area,

where all logging operations would not be permitted on weekends.

Traffic control and safety plans would be in place for all log truck/chip van hauling activities. Contractors

would be required to follow all Federal, State, and Town of Vail ordinances during the implementation of

the project.

Indirect Effects: Log truck/chip van activity on transportation system roads during project implementation

may add some inconveniences and traffic delays to local residents due to log truck/chip van traffic

maneuvering through narrow and winding Town of Vail transportation system roads.

Helicopter Noise. A KMax helicopter, the most efficient and widely used helicopter for heavy payloads

at elevations near 9,000 feet, would be the helicopter of choice.

Sounds from any source that are undesirable, extraneous, or interfere with hearing can be considered

noise. Noise is considered a human health concern because it can interfere with speech communication

and hearing. Unwanted noise varies by individuals and is often subjective. Individual’s response or

reaction to noise is influenced by the type of noise, the sensitivity of the individual to noise, the area

around the individual in relation to the noise, and the time of day (or other factors).

Sound is measured in decibels on the A-weighted scale (dBA) and is 1 based on a logarithmic scale to

account for the wide range of audible sound intensities. Under the logarithmic scale for sound (and noise), a

10-dBA increase would increase sound intensity by 10 times; a 20-dBA increase would increase sound

intensity by 100 times. As a result, methods have been developed for weighting the sound frequency

spectrum to approximate the response of the human ear. The dBA scale is widely used for environmental

noise assessments because of its relative convenience and accuracy in correlating with people’s judgments

of what constitutes noise.3

Typical A-weighted sound and noise levels associated with common activities or situations are shown in

Table 28.

3 EIS for Previously Issued Oil and Gas Leases in the White River National Forest, Preliminary Draft, 13.6-7.


117

Table 28. Typical A-weighted sound and noise levels associated with common sound

Noise (Source: CEQ 1970) Noise Level (dBA) Source

Fireworks at 3 feet 150 (CEQ 1970)

Firearms, jet engine 140 (CEQ 1970)

Jackhammer 130 (CEQ 1970)

Auto horn at 3 feet 120 (CEQ 1970)

Chipper 120 Hass1

Chainsaw at 10 feet 100106 LFPDC#582

Gas lawnmower, snowblower 106 (CEQ 1970)

Heavy truck at 50 feet 90 (CEQ 1970)

Helicopter (in flight), at 500 feet (KMax) 82 Swanson3

Skidder at 20 feet 8288 LFPDC#58

Loader at 20 feet 8290 LFPDC#58

Freeway traffic at 50 feet 70 (CEQ 1970)

Light automobile traffic at 50 feet 60 (CEQ 1970)

Normal speech at 15 feet 50 (CEQ 1970)

Moderate rainfall 50 (CEQ 1970)

Living room 40 (CEQ 1970)

Soft whisper at 15 feet 30 (CEQ 1970)

Broadcasting studio 20 (CEQ 1970)

Threshold of hearing 0 (CEQ 1970) 1 http://home.earthlink.net/~dnitzer/4HaasEaton/Decibel.html

2 Some Measured Levels of Noise Produced by Logging Equipment in 1998. August 7, 2003. Louisiana Forest Products

Development Center Working Paper #58.

3 Reference from www.swansongroupaviation.com (KMax noise comparison chart)

OSHA standard 1910.95 (i) (l) requires hearing protection to be worn when sound levels exceed certain

limits (generally, a daily average of 85 or 90 decibels, depending on the circumstances).

Direct and Indirect Effects: A noise comparison in of a KMax helicopter in Table 28 shows that the 82

decibel reading for a Kmax helicopter is lower than heavy truck traffic (90 decibels) and higher than

freeway traffic (70 decibels). The table shows the KMax decibel reading significantly lower than a gas

lawnmower (106 decibels), chainsaw (100 to 106 decibels) and automobile horn (120 decibels) noise.

Skidders and log loaders have decibel readings of approximately 82 to 90 decibels at full throttle.

Helicopter noise from any one point in the project area would fluctuate due to the distance of the

individual hearing the noise and the constant movement of the helicopter. There would be a higher

duration of noise near landing locations as more helicopter time would be spent at those locations

hovering. The loudest noise from helicopter operations would be referred to as rotor chop. Rotor chop

tends to increase in intensity and fade as the helicopter’s position (angle and distance) changes relative to

the individual hearing the noise.

Noise duration during daylight hours is cyclical and dependent upon flight conditions and fueling

operations. Flight time between treatment areas and landings would be typically 1 to 5 minutes,

depending on the distance of the flight. Helicopters refuel approximately every hour of flight time. A

refueling period could last 15 to 45 minutes. This cycle could continue from sunup to sundown, but is

limited to pilot flight time of no more than 8 hours.

http://www.swansongroupaviation.com/


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Helicopter operational time to complete the entire project is 71 to 85 days. This would most likely occur

over two operating seasons that run from June through October.

There would also be noise from chainsaws, skidder, chipper, log loader and logging trucks/chip vans.

Chainsaw activity would be concentrated in cutting units, and skidder, log loader, chipper, log truck/chip

vans would be concentrated at the landing areas. Chippers, if used, would have the highest noise output

at 120 decibels. Individuals near the landing areas would experience a higher level of noise than those

farther away. The noise effects for helicopter yarding and associated activities are local and short term in

nature and would not be significant to the human environment.

Wildlife are less tolerant to noise than humans. Noise from helicopter and associated activity would

disrupt their normal patterns. Wildlife would seek seclusion from activity noises. Each wildlife species

may have a different comfort zone for noise and how far they travel to seek seclusion depends on their

comfort zone.

Project Safety. The harvest and transportation of forest products ranks as one of the most dangerous

occupations. Helicopter and logging operations are highly regulated due to numerous safety concerns.

Direct and Indirect Effects: All Forest Service contracts require traffic control and project-level safety

plans. These plans would need to meet all Federal, State, and local regulations prior to being approved.

All landing areas, helicopter flight paths, and haul routes would be designated prior to operations.

Helicopter operation flight paths would be prohibited from flying over homes, roads, utility infrastructure

and any other feature that could be at risk from an object falling from under the helicopter. In order to

further secure the area for public safety during operations, an area closure from public within the project

area would be implemented. This would provide an additional measure to ensure public and project

safety.

Table 29. Log truck traffic, noise and project safety indicators and measures for the proposed action direct/indirect effects

Resource Element Resource Indicator Measure Proposed Action


Helicopter Noise Noise Decibels 82

Helicopter Noise Noise duration (daily) Hours per day Up to 12

Helicopter Noise Noise duration (project) Days 7185


Cumulative Effects: Present logging activities adjacent to or within the project area include Vail Mountain

Recreational Enhancement Projects. Approximately 20 to 40 log truck trips annually would be using

Forest Service and Town of Vail transportation system roads to haul forest products.

Log Truck Traffic. The proposed action would add approximately 485 log truck trips to traffic on

predominantly Town of Vail transportation system roads. The increased traffic would be dispersed among

the haul routes from the three landing areas identified on the project area map. Only the road system

associated with the landing area on Forest Service land within the Vail Resorts ski area boundary would

have cumulative log truck traffic of approximately 50 to 100 log trips spread out over two operating

seasons. This increase log truck traffic would be short term in nature and not have a significant

cumulative effect to the human environment.


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Helicopter Noise

There would be no cumulative effects.

Project Safety

There would be no cumulative effects.

Table 30. Log truck traffic indicators and measures for the proposed action cumulative effects




The proposed action would be in compliance with the Forest Plan along with Federal, State and Town of

Vail ordinances related to timber harvest contracts.

Economics


Existing Conditions

The project can be accomplished using a direct timber sale, stewardship agreement, and/or service

contract. Implementation of the project would be funded by the Town of Vail in partnership with the

Forest Service. The financial analysis focuses on the revenues and the costs related to the removal of

forest products for fuels reduction purposes.

Forest product markets are indicative of existing infrastructure, supply and demand for manufactured

wood products, and their by-products. Currently, demand for forest products associated with this project

includes dimensional lumber and biomass for bioenergy production. The working circle for product

utilization for this project is expected to be Montrose Forest Products, LLC (Montrose, Colorado) and

Colorado Timber Resources, LLC (Parshall, Colorado). Other potential forest product outlets are

Confluence Energy (Kremmling, Colorado), K&K Lumber (Silt, Colorado) and Eagle Valley Clean

Energy, LLC (Gypsum, Colorado).

Although there are markets for the forest products associated with this project, the forest products have

low revenue values. Helicopter yarding systems are expensive and these costs have always exceeded the

value of the forest products removed from these types of projects. Contractors with helicopter yarding

capabilities from outside of Colorado would most likely be used to implement the project. Helicopter

yarding can be a valuable tool to accomplish fuel reduction objectives in hard to access and sensitive

areas.




The financial analysis summarized in Table 31 indicates that the no-action alternative would result in a

net present value of $0 for the project as a whole, the Forest Service, and the Town of Vail. A benefit/cost

ratio is not applicable since no revenues or expenses have been incurred by the project. No additional

investment road systems or vegetative planning would be undertaken within the next 10 years.


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Non-market benefits, such as protecting critical infrastructure from wildfire within communities, are

important factors to consider in combination with the present net value of the project as a whole. The

West Vail area has an assessed land value of $1,065,384,1004. This land value in itself is a factor that

should be considered as a non-market value at risk for the no-action alternative.

Table 31. Economic indicators and measures for the no-action alternative


Project Cost Present net value Financial benefits (dollars) $0

Project Cost Benefit/cost ratio Ratio of financial benefits to cost N/A

Project Cost Present net value (Forest Service)

Financial benefits (dollars) $0

Project Cost Benefit/cost ratio (Forest Service)

Ratio of financial benefits to cost N/A

Project Cost Present net value (Town of Vail)

Financial benefits (dollars) $0

Project Cost Benefit/cost ratio (Town of Vail)

Ratio of financial benefits to cost N/A

Cumulative Effects

There are no direct or indirect effects so there are no cumulative effects for the no-action alternative.

Alternative 2 (proposed Action)

The financial analysis includes 131 acres of the proposed harvest treatments to be considered regeneration

harvest treatments and revenue/cost time period would be carried to the estimated year of stand rotation

(2101). The remaining 63 acres would be considered non-regeneration/fuels reduction treatments and not

taken to stand rotation, rather an annual expense for 2 years. Helicopter costs and hand treatment costs

are incorporated into the financial analysis as partner contributions from Town of Vail.


The financial analysis summarized in Table 32 indicates that the proposed action would result in a

negative return overall to the Forest Service and to the Town of Vail, exclusive of costs.

Fuel reduction projects often times have negative net present values because non-market benefits are not

required to be accounted for in the financial analysis. Non-market benefits, such as protecting critical

infrastructure and communities from wildfire, are an important factor to consider in combination with the

present net value of this project as a whole. The West Vail area has an assessed land value of

$1,065,384,100. This land value, or value at risk, should be considered as a non-market factor for the

proposed action alternative. Due to many factors that affect wildfire intensity and severity, there is no

way to analyze the economic effects and loss of infrastructure to the community. There is research and

literature that do support and recognize the efficacy of hazardous fuel treatments on wildfire severity. For

case studies, “Researchers found that for the forest ecosystems that were examined, the evidence suggests

that restoration treatments can reduce fire severity and tree mortality in the face of wildfire…”5. In

4 From Paul Cada, Wildfire Mitigation Specialist, Town of Vail, West Vail Properties Eagle County Records,

October 21, 2015. 5 Ecological Restoration Institute. 2013. The efficacy of hazardous fuels treatments: A rapid assessment of the

economic and ecologic consequences of alternative hazardous fuel treatments: A summary document for policy

makers. Northern Arizona University. 4 p.


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addition, “Modeling demonstrates that fuel reduction treatments are effective at reducing fire behavior

(severity) where implemented, and can successfully reduce fire risk to communities.”6

Present Net Value. Direct Effects: The proposed action implemented entirely with helicopter yarding has

a negative net present value of ($2,505,721). The present net value of helicopter yarding can be further

separated between the Forest Service ($17,380) and the Town of Vail ($2,488,341) expenditures. The

Forest Service does expect to receive minimum forest product values from the project, but the revenues

do not compensate for the expenses necessary to manage the forest stands into rotation. The Town of Vail

would incur the implementation costs of the fuels reduction project and any forest product revenues from

the project would result in reduced costs of implementation.

The proposed action implemented entirely with hand treatments has a negative net present value of

($230,587). The present net value of hand treatments can be further separated between the Forest Service

($30,422) and the Town of Vail ($200,165) expenditures. No forest product revenues or utilization would

be realized through the implementation of hand treatments.

Indirect Effects: Local businesses in the Town of Vail and Eagle County would gain business during the

implementation of the project. Contractors for both helicopter and hand treatment options would rely on

the local businesses for food, housing/lodging, fuel, supplies and miscellaneous services over the life of

the project. This would bring economic activity to the locality. Forest products removed from the project

area via helicopter yarding would be utilized on the western slope primarily as sawtimber and biomass

products. These products would contribute to local economies as sawtimber would be remanufactured

into dimensional lumber and biomass products would be utilized as feedstock for energy production.

Benefit/Cost Ratio. The benefit/cost ratio equals the sum of the discounted benefits divided by the sum

of the discounted costs. This ratio measures the efficiency of specified inputs (i.e., costs) to produce

specified outputs (i.e., benefits). A benefit/cost ratio of less than 1.0 is indicative that expenses are greater

than monetary returns and consistent with the project’s negative present net value.

The proposed action shows an overall benefit/cost ratio of 0.01 for helicopter yarding. This benefit/cost

ratio can be further separated between the Forest Service (0.52) and the Town of Vail (0.0). The Forest

Service benefit/cost ratio is positive because of the forest product values expected to be received from the

project. The Town of Vail benefit/cost ratio is zero because no forest product receipts are anticipated.

Indirect Effects: Although the benefit/cost ratios are less than 1.0, local businesses in the Town of Vail and

Eagle County would gain business during the implementation of the project. Contractors for both

helicopter and hand treatment options would rely on the local businesses for food, housing/lodging, fuel,

supplies and miscellaneous services over the life of the project. This would bring economic activity to the

locality.

6 Ecological Restoration Institute. 2013. The efficacy of hazardous fuels treatments: A rapid assessment of the

economic and ecologic consequences of alternative hazardous fuel treatments: A summary document for policy

makers. Northern Arizona University. 4 p.


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Table 32. Economic indicators and measures for the proposed action direct/indirect effects

Resource Element Resource Indicator Measure

Proposed Action

(Helicopter Yarding)

Direct/Indirect Effects

Proposed Action (Hand Treatments)

Direct/Indirect Effects

Project Cost Present net value Financial benefits (dollars) ($2,505,721) ($230,587)

Project Cost Benefit/cost ratio Ratio of financial benefits to cost

0.01 0.0

Project Cost Present net value (Forest Service)

Financial benefits (dollars) ($17,380) ($30,422)

Project Cost Benefit/cost ratio (Forest Service)

Ratio of financial benefits to cost

0.52 0.0

Project Cost Present net value (Town of Vail)

Financial benefits (dollars) ($2,488,341) ($200,165)

Project Cost Benefit/cost ratio (Town of Vail)

Ratio of financial benefits to cost

0.0 0.0

Cumulative Effects


Past hazardous fuels reduction treatments adjacent to or within the project area include, Town of Vail, Eco

07, Eagle County and Vail Valley forest health projects. Approximately 75 acres of hazardous fuels

treatments have been accomplished between 2006 and 2010.

Present Net Value. Past treatments do not add cumulatively to the net present value of the project.

Benefit/Cost Ratio. Past treatments do not add cumulatively to the benefit/cost ratio of the project.


There are no Forestwide goals and objectives or management area standards and guidelines to directly

apply to the financial analysis of the project alternatives. This analysis is in compliance with Forest

Service Manual and Forest Service Handbook direction relating to economic and financial analysis at the

project level.

Cultural and Heritage Resources


Existing Conditions

Cultural and heritage resources were initially considered for analysis because ground disturbance related

to construction of the proposed project has the potential to impact archeological sites. After a search of

previous archaeological inventories and an investigation of new archaeological sites, it was determined

that no cultural resources exist within the project area.


The project area has received several cultural resource inventories in the past. These include the reports

listed in Table 33.


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Table 33. Forest Service cultural resource inventories conducting in the project area in the past

FS Report No. SHPO Report No. Title Year

R1990021507026 EA.FS.R10 Cultural Resource Survey of Vail Mountain Improvements, Vail Ski Area, Eagle County, Colorado

1990

R1993021506006 Pipeline corridor 1993

R1993021507017 West Vail to Dowds Junction Utility Line and Water Pipeline

R2003021507020 EA.FS.R43 Level Three Cultural Resource Inventory and Evaluation of Fourteen Previously Surveyed Sites, Vail Valley Cultural Resources Survey, White River National Forest, and Addendum

2002

EA.LM.NR21 A Cultural Resource Inventory of a Sixteen Foot Telephone Cable Right of Way, West of Vail, Colorado

1979

EA.CH.R1 Archaeological Survey Of Eagle Vail To Vail, Eagle County, Colorado

1988

A few portions of treatment units 1 and 4 were not inventoried due to steep slopes (over 30 percent)

because sites are not usually found in areas with slopes over 30 percent. No cultural resources were

identified in the areas that were inventoried.

Determinations

In summary, it is the finding that the 2002 survey is adequate for this project. Methodology used is current

with today’s standards. Field conditions have not changed since this inventory was conducted, and no

further inventory is recommended.

Section 4: Agencies and Persons Consulted The Forest Service consulted the following individuals, Federal, State, Tribal, and local agencies during

the development of this environmental assessment.

Federal Agencies USDI Bureau of Land Management

USDI Fish and Wildlife Service

State Agencies Colorado Department of Water

Colorado Parks and Wildlife

Colorado State University Extension

State of Colorado, Division of Fire Prevention and Control

Upper Colorado River Inter-agency Fire Management Unit (BLM and Forest Service)

Local Government Eagle County

Eagle County Commissioners

Eagle County Sheriff's Office

Town of Gypsum


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Town of Minturn

Town of Vail

Upper Eagle Water and Sanitation

Vail Fire Department

Vail Fire and Emergency Services

Tribes Ute Mountain Ute Tribe of Colorado

Southern Ute Indian Tribe of Colorado

Ute Indian Tribe of the Uintah and Ouray Reservation

Other Organizations American Red Cross

Eagle River Fire Department

Eagle River Watershed Council

Eagle River Fire

Eagle Valley Humane Society

Greater Eagle Fire

Gypsum Fire Protection District

Holy Cross Energy

Pine Marten Logging

Salvation Army

Vail Board of Realtors

Vail Resorts

Wilderness Workshop


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References References for the Vail Intermountain Fuels Project are found in the specialists reports for the project and

are incorporated by reference in this environmental assessment. The specialist reports are available at the

Holy Cross Ranger District Office in Minturn, Colorado.


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Appendix A: Summary of Activities Considered in Cumulative Effects Analysis Table A-1 includes a summary of documented past, present, and reasonably foreseeable activities

considered in the cumulative effects analysis occurring in the Vail Intermountain Fuels Project Area.

Table A-1. Past, present, and reasonably foreseeable projects for the cumulative effects analysis for the Vail Intermountain Fuels Project

Project Name Date Decision Signed Project Type

Piney Salvage Project (present) September 2014 Forest health and fuels reduction

Vail Mountain Recreation Enhancements Project August 2004 Recreation

Vail Valley Forest Health Project August 2005 Forest health and fuels reduction

Vail Mountain Recreation Enhancements October 2014 Recreation

Vail Resort Improvements Project December 2009 Recreation

Vail Ski Area Forest Health Project April 2011 Forest health and fuels reduction

Indian Creek Project September 2014 Forest health and fuels reduction

Moniger Park Project September 2014 Forest health and fuels reduction

Red Sandstone Project 1980s Vegetation management

North Sandstone Project 1980s Vegetation management

Buffer Project 1980s Vegetation management

Dickson Project 1980s Vegetation management

Forestwide Hazardous Tree Removal and Fuels Reduction Project

September 2009 Public safety and forest health

Eco 07 March 2006 Fuels reduction

Town of Vail Project March 2006 Fuels reduction

Eagle County Project March 2006 Fuels reduction

West Grouse Project May 2008 Forest health and fuels reduction

Tigiwon Salvage Project May 2008 Forest health and fuels reduction

Minturn Wildland-urban Interface Project May 2008 Forest health and fuels reduction

Beaver Creek Project June 2011 Forest health and fuels reduction

Grouse Lake Project September 2009 Fuels reduction

Martin Creek Project September 2009 Fuels reduction


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Appendix B: Summary of Public Comments and Responses Nine comment letters were received during the notice and comment period for the Vail Intermountain Fuels Environmental Assessement.

Comments were copied from the letters and inserted into the following comment analysis table (Table B-1), numbered, and responded to by the

interdisciplinary team.

Table B-1. Summary of public coments and responses

Comment Number Comment Comment Source Response

1 I have owned a home in InterMtn for 22 years. I remember years back how hard it was for some Agency just to get the permit to cut down the dead trees above InterMtn and all the fears more extreme environmentalists were spreading, but it looks very good today. It looks like natural, grassy meadows above my house. So, with that history in mind, I'm all for you taking further steps to remove fallen trees and reduce fuels. It'll never hurt the hillside and it will make it easier for elk & deer to move through. It could save a home or two someday, maybe my own.

Thomas Sorensen Thank you for your comment and the support of the project.

2 We totally endorse and support the proposed action. There is a great need to protect the public infrastructure and protect valuable assets. We must reduce the hazardous fuel accumulations. We need to do everything possible to protect the SAFETY of our residents in the areas adjacent to National Forest System lands. The Impact of doing nothing is unacceptable! Please proceed with this necessary project.

Bob and Mary Lou Armour

Thank you for your comment and the support of the project.

All USFS contracts require a safety plan that includes travel routes, timing (times per day and total duration) and traffic control for truck turning, backing and sharp curves prior to operations beginning. Also, contractors and contract operations will be required to conform to Town of Vail work hours and trucking restrictions.

3 Thank you for the opportunity to comment on the Vail Intermountain Project. Eagle River Water & Sanitation District (ERWSD) is in support of the fuel reduction project, and is willing to allow USFS personnel and their contractor's ground access to USFS land via the gates to our Intermountain Water Storage Tank and our Highland Meadows Water Storage Tank.

Peter J. Miller, Raw Water Resources Operator, Eagle River Water and Sanitation District

Thank you for your comments and the support of the project.

4 In reviewing the Notice of Proposed Action (June 5, 2015), we Thank you for the support of the project and offer to use


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noticed that the design features included a statement that the action would "Follow all Water Conservation Practices and Best Management Practices to improve or maintain water quality." ERWSD would like to formally request that any damage resulting from the project to our property be mitigated. An example of this might be to repair ruts, so that runoff would not scour sediment from them.

your property as an access point to the project area. If Eagle River Water Sanitation District property is used in any way that involves any ground disturbance, a temporary road access permit will be initiated with terms and conditions in place for rehabilitation of any disturbed areas.

5 ERWSD feels that the fuels reduction project will likely add a measure of protection from potential wildfire threat to our community, our water infrastructure, and our watershed.

Thank you for your comment and support of the project.

6 Thank you for the opportunity to comment on the currently proposed Vail Intermountain Project. This area is of high importance to the Town from an aesthetic, wildfire hazard and forest health perspective. The Town of Vail would like to formally support this proposed action as it is currently proposed with the following specific comment regarding the proposed design features.

Stan Zemler, Town Manager, Town of Vail

Thank you for your comments and the support of the project.

7 The fourth design feature references prohibiting yarding, hauling and associated activities on weekends. We propose that instead of an outright prohibition of these activities on weekends that this project would have the flexibility to work around events held in the town and on Vail Mountain. All work including hauling within the Town of Vail boundaries will be required to conform to Town of Vail work hours and trucking restrictions which will mitigate this concern.

This design feature can be modified to provide for more flexibility to work around events held in the Town of Vail and on Vail Mountain. Having this type of flexibility can shorten the length of project implementation and reduce costs associated with more narrowly defined implementation timeframes.

Project design features to reduce the impacts of the project for recreational users on Vail Mountain will be included in the project.

All contractors and contract operations will be required to conform to Town of Vail work hours (sunup to sundown) and trucking restrictions.

8 We would also like to reiterate the concerns voiced by several citizens during the open house held at Vail Fire Station 3 regarding truck traffic associated with this project. All of the proposed haul routes for this project are within the Town of Vail and have pedestrian traffic. A robust traffic management plan will be critical to safely implementing this project.

All USFS contracts require a safety plan that includes travel routes, timing (times per day and total duration), and traffic control for truck turning, backing, and sharp curves prior to operations beginning. Also, contractors and contract operations will be required to conform to Town of Vail work hours and trucking restrictions.

9 The Town would like to thank you for the time that you have taken to fully analyze this project and collect broad community

Thank you for the support of the project. Community involvement and collaboration is a central part of the


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comment. process for a Healthy Forest Restoration Act project.

10 PROTECT ROADLESS AREA CHARACTERISTICS. The project area is entirely in the Game Creek Roadless Area (RA). Under the Colorado Roadless Rule (CRR), activities to reduce fuel are allowed within one-half mile of RA boundaries, provided that such activities comply with the Forest Plan and “one or more of the roadless area characteristics will be maintained or improved over the long term”. 36 CFR 294.42(c)(1).

The roadless area characteristics are as follows: Resources or features that are often present in and characterize Colorado Roadless Areas, including: (1) High quality or undisturbed soil, water, and air; (2) Sources of public drinking water; (3) Diversity of plant and animal communities; (4) Habitat for threatened, endangered, proposed, candidate, and sensitive species, and for those species dependent on large, undisturbed areas of land; (5) Primitive, semi-primitive nonmotorized and semi-primitive motorized classes of dispersed recreation; (6) Reference landscapes; (7) Natural-appearing landscapes with high scenic quality; (8) Traditional cultural properties and sacred sites; and (9) Other locally identified unique characteristics. Id. at 294.41.

The proposed project would degrade some of these characteristics: soil would no longer be undisturbed, the landscape would no longer be natural-appearing or have high scenic quality, and the area could no longer serve as a reference landscape. The NEPA document for the project needs to show what characteristics would be maintained or enhanced by the proposed action and also discuss what measures would be used to minimize degradation of other characteristics.

Rocky Smith Thank you for your comments.

Manipulating the project area through the treatments would cause short-term direct impacts to roadless resources. However, the proposed action would result in a more diverse, resilient, and sustainable forest ecosystem with a reduction in risk of negative impacts from severe wildfire. The long-term indirect effects from the proposed action to roadless resources would be generally beneficial.

Impact to solitude while people are recreating during project implementation from the presence of crews in the field and equipment in the field may be a concern.

Design features could include scheduling the work during the week, modifying helicopter flight paths to fly over the least area of the IRA as possible, and informing visitors about the work in the area and encouraging them to use other areas around Vail during project implementation.

Impacts would be stable or improving for a majority of roadless area characteristics and wilderness attributes, with short-term impacts to the undeveloped character from the treatments and short-term impacts to solitude during project implementation.

Reference landscapes of relatively undisturbed areas serve as a barometer to measure the effects of development on other parts of the landscape. The current landscape is not undisturbed. It is comprised of dense forests susceptible to insect and wildfire mortality. In addition, a large-scale mountain pine beetle epidemic has killed most of the mature lodgepole pine. The proposed action would result in a landscape setting that resembles a wildfire event which naturally follows a pine beetle event. Forest regeneration and “greenup” would occur shortly thereafter and improve upon the visual appearance of this landscape cycle by resembling an increasingly healthy forest.

Due to a history of fire suppression in the roadless areas, critical disturbance has been excluded from a


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disturbance-dependent ecosystem. Because of this, the existing scenic quality is on a downward trajectory. The condition of untreated aspen stands in inventoried roadless areas may deteriorate over the long term, as pine trees encroach into and replace aspen stands, thus reducing the overall diversity of vegetation. The existing landscape appearance would also deteriorate, and would deviate to an increasing degree over time from the existing scenic integrity levels. The portion of the Game Creek IRA (inventoried roadless area) is managed to meet a moderate SIO (scenic integrity objective).

Various design features would be implemented with this project. Scenery design features would include:

Resource protection measures proposed for erosion control, vegetation, and wildlife would be used to mitigate impacts to visual quality.

Where possible, aspen would be retained or improved to provide a visual screen for treatment units.

The scenic contrast of timber treatment stands on the landscape, particularly in middle to background distance zones as viewed from sensitive viewpoints, would be reduced by creating irregular or indistinct edges. Openings in the canopy should have a natural appearance with uneven edges. The shape should be an irregular pattern that mimics existing natural openings and should avoid straight-line edges. Feathering techniques and scalloped edges (75-feet-wide minimum) should be used to reduce contrast of line, texture, and form. Blend with natural landscape features such as natural meadows or openings and rock outcrops when possible. Straight line edges should also be avoided along roadless area, wilderness area, and private property boundaries.

When leaving trees within treatment units, leave in clumps or groups and avoid leaving single “whip” trees. Groups of “leave trees” should occur at random distances and spacing for a more natural appearance (avoid regular spacing of leave trees).

Because the project would not use ground-based equipment for fuel reduction activities, there would be


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little effect on soils. There would be minor soil disturbance as a result of other fuel reduction activities such as piling and burning material, but this would be done by hand.

11 Under the Forest Plan, the project area is assigned to management area (MA) 7.1, Intermix. Forest Plan Management Area Map, and NOPA at 2. In these areas, Management actions are geared toward influencing the vegetation composition and structure to promote visual screening and to minimize hazardous fuel loading patterns. Plan at 3-74. In the short term at least, the project might reduce hazardous fuel but would remove trees which provide visual screening. To balance both of these goals of MA 7.1, we recommend minimizing clearcutting, and keeping any openings small, probably less than one acre.

Instead of clearcutting aspen, conifers could be removed to at least delay the conversion of the stand from aspen to conifer. Even in pure lodgepole pine where all the trees are dead, not all stems need to be removed. Some can be left to fall down and decay into new soil. These future down dead logs would help reduce soil erosion. Some dead trees with rot should be retained for cavity-nesting animals.

Mortality rates in lodgepole pine are estimated to be between 36 and 59 percent; hence, it is unlikely that openings less than 1 acre in size would sufficiently meet the purpose and need of reducing the current and future wildfire hazard to and from adjacent communities by managing existing hazardous fuels on Federal lands. Patch cut openings would not to exceed 10 acres in size and may only affect up to 50% of the treatment area.

It is not desirable to remove conifers from within aspen stands because residual aspen trees would be damaged by felling or yarding activities. These damaged trees are more likely to become infected with disease and die (Shepperd 1986). An analysis of the project effects to vegetation would be conducted.

Various design features would be implemented with this project. Scenery design features would include:

Where possible, aspen would be retained or improved to provide a visual screen for treatment units.

The visual contrast of timber treatment stands on the landscape, particularly in middle to background distance zones as viewed from sensitive viewpoints, would be reduced by creating irregular or indistinct edges. Feathering techniques and scalloped edges (75-feet-wide minimum) should be used to reduce contrast of line, texture, and form.

When the project is complete, no tree paint shall be visible from open roads or trails. Unit boundary paint shall either face away from the roads or trails, or be removed or “blacked out” after the sale is complete.

Post-treatment fuel loading will be described in the analysis.

LRMP Standards and Guidelines, including Biodiversity Standards 2 [Develop prescriptions during project planning to identify the amount, size(s), and distribution of downed logs and snags to be left onsite, as well as


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live, green replacement trees for future snags. On forested sites, retain snags and downed logs (where materials are available) in accordance with the average minimums specified in table 2-2 (LRMP, page 2-7)] and 3 (If no snags meet the minimum diameter and height requirements, use the largest snags available) would be applicable to the project, and the project will meet forest plan standards.

The Forest Plan will be met regarding maintaining soil organic material.

12 PROTECT SOILS AND SLOPE STABILITY. Almost the entire project area is on at least moderately steep terrain, and most of it is in an area of high landslide risk. See Vail Valley Forest Health Project Final Environmental Impact Statement, August 2005, at Figure 3-1. In fact, it appears that parts of proposed units 3 and 4 are on a “prominent landslide feature”. Compare ibid. with NOPA Figure 2 (p. 6). But surprisingly, there is no mention of landslide risk in the NOPA.

Landslide risk has been considered in the proposed action, and will be evaluated for the project soils analysis.

13 It appears from the NOPA (p. 4) that the intent is to yard cut material via helicopters. If so, this would reduce or eliminate the need for roads on national forest land. However, the use of helicopters stresses wildlife and might be annoying to local residents. Yarding distance from unit 3 to any of the landings would be more than one mile, and it would be just slightly less from unit 2.

The impacts of copter use must be disclosed. Where copter yarding would not be used, treatments would be by hand: Hand treatments would involve felling, limbing and bucking trees. This material would be piled for later burning during the fall/winter seasons. NOPA at 4. Could large diameter logs be piled by hand? Dead lodgepole pine trees are “predominantly…over 10.0 [inches diameter at breast height]”. NOPA at 1. Trees of this size would have to be cut up into a large number of small pieces to enable hand piling. This is very labor intensive. The project would already be quite expensive, given the use of helicopters.

Implementation of the project would most likely involve a mixture of helicopter yarding and hand treatments. Helicopter yarding would be analyzed disclosing the environmental and economic effects.

Hand treatments may be used in areas where helicopter yarding has limitations. These hand treatments would be very labor intensive where piling of large diameter logs is undertaken.

The economic analysis of the project would disclose a range of costs for hand treatments and helicopter yarding.

Past hand treatments in the Vail area have been completed using CCI (Juniper Valley) crews, with the piles burned by USFS personnel. Precedence for this approach is well established in Vail and Summit County Wildland-urban Interface treatments.

The potential impacts of helicopter yarding on threatened, endangered, proposed, candidate, and Forest Service sensitive species, as well as management indicator species and migratory birds will be disclosed.


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14 Burning piles would generate much smoke, which would be harmful to Vail Valley residents, including adjacent landowners and their guests. Also, burn piles composed (at least partially) of large diameter material would burn long and hot, sterilizing the soils beneath them.

There would be minor and localized soil disturbance associated with burning piles; this would be considered in the soils analysis for the project.

Pile burning would be conducted using well established smoke management procedures in conjunction with the Colorado Air Pollution Control Division. Past Vail pile-burning operations have been conducted with no impacts to residents. Pile footprints would be rehabbed post-burn as needed.

Effects from smoke will be analyzed for the project.

15 In general, even without construction or reconstruction of roads or use of heavy equipment, removal of vegetation could cause mass slope failure. The more vegetation removed, the more likely landslides would be to occur. The Forest Service must show that the proposed cutting, in amount, arrangement, and implementation, would not destabilize the slopes and that it would still reduce the fire risk to the adjacent lands. It is possible that slope instability would prevent removal of sufficient fuel to reduce the fire hazard. It would do the residents of the West Vail-Intermountain area no good to remove vegetation to reduce the fire hazard only to have the treatments cause landslides that would unleash a torrent of soil, rocks, trees, etc. into their backyards. The EA must describe all of the mitigation measures that might be used to prevent mass slope failure, and discuss how effective they would be.

Soil stability and landslide risk will be evaluated for this project.

Proposed fuels reduction treatments can be modified and mitigation measures implemented if the soils analysis shows potential for erosion. This will be addressed in fuels analysis.

16 FIGHT NOXIOUS WEEDS. Any ground disturbance provides a good environment for the introduction and spread of noxious weeds. Any areas proposed for treatment need to be first surveyed for weeds, and any populations found must be eradicated before operations begin. Then surveys and eradication should continue for at least two full growing seasons after project completion.

These are mitigation actions that can be taken to prevent the spread of noxious weeds. Project design features will be incorporated to address potential noxious weed populations. Although eradication of a population is not necessarily achievable within a reasonable time before project activities would begin, pre-treatment followed by monitoring and additional post-project control treatments would be accomplished. In addition, measures would be taken to prevent introduction of noxious weeds, such as requiring equipment to be washed clean before performing the work.

17 CONCLUSION. We appreciate the need for some vegetation treatment on national forest lands to reduce the fire hazard on adjacent private lands. However, the Forest Service must

There would be short-term direct impacts to roadless resources during project implementation. However, the proposed action would result in a more diverse, resilient,


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demonstrate that such treatment would: 1) not increase the risk of slope failure, 2) be practical in terms of costs and impacts, 3) be effective in reducing fire hazard, and 4) minimize impacts to the roadless area while maintaining or enhancing at least one roadless area characteristic.

and sustainable forest ecosystem with a reduction in risk of negative impacts from severe wildfire. The long-term indirect effects from the proposed action to roadless resources would be generally beneficial and help to maintain the existing recreation settings and scenic qualities within the project area.

Impacts would be stable or improving for a majority of roadless area characteristics and wilderness attributes with short-term impacts to the undeveloped character from the treatments and short-term impacts to solitude during project implementation.

Soil stability and landslide risk will be evaluated for this project.

Costs of project implementation will be disclosed in the analysis. Implementation of the project would be funded by the Town of Vail in partnership with the Forest Service.

Treatment effectiveness and practicality of implementation will be described in the analysis.

18 We are concerned about the logging truck traffic on Basingdale Blvd and the ability to enforce the 15 mph downhill speed limit. There are many kids in the neighborhood. We also want this project to be a "one and done" for the drop at the top of Basingdale and the trucks on our street. Once the project starts complete it and move on to other drops and truck out.

Chip Novick Thank you for your comments.

Contractors and contract operations would be required to conform to Town of Vail work hours, traffic regulations, and trucking restrictions. The project would be phased to minimize the impacts to the shortest amount of time possible for any one area.

19 We understand that a purpose of the project is to reduce current and future wildfire hazard to adjacent communities. We anticipate that any further analysis of this project will set forth the degree to which this will actually occur as a result of the project and how this was determined.

Mike Heaphy and Melissa Decker

Thank you for your comment.

Reduction of current and future wildfire hazard will be described in the analysis via modeling and a literature review.

20 We further understand that the other purpose of the proposed project is to maintain/expand existing aspen diversity by, essentially, opening up new areas for new aspen growth. We anticipate that any further analysis of the proposed project will set forth the scientific and logical basis for your belief that the

Based on the silvics of aspen, we anticipate that aspen regeneration is likely where mature aspen currently exist (Shepperd 1986). An analysis of the project effects to vegetation will be conducted and will disclose regeneration expectations.


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project will actually achieve this end. In this respect, we note that another recent project in the area, the Upper Eagle River Beetle Salvage Project (UERBSP), had similar regeneration goals. However, at least based on our observations of the UERBSP treatment areas, the hoped for regeneration has largely not occurred, particularly in those treatment areas subject to clearcutting. Accordingly, we are concerned about the basis for believing the hoped-for regeneration will actually occur and, by extension, the basis for the belief that the proposed project will achieve the desired ends.

21 We understand that you perceive the proposed action to be needed due to the recent mountain pine beetle outbreak has or will contribute current and future hazardous fuel loads. This perceived need appears to fly in the face of a CU-Boulder authored study published in the Proceedings of the National Academy of Science in March 2015, the gist of which was that beetle-infested western forests are no more likely to burn in a wildfire than uninfected forests. We anticipate that any further analysis of this project will explain this apparent discrepancy.

The referenced study (Area Burned in the Western United States Is Unaffected by Recent Mountain Pine Beetle Outbreaks, by Hart and others [2015]) draws broad conclusions based on limited work and has received sharp criticism from prominent researchers in the field (Letter to PNAS, Alexander and Cruz [2015]). Other, more comprehensive research supports fuels management projects similar to that described in the proposed action and will be cited in the analysis where appropriate.

22 We understand that another identified need for the proposed project is the concern that a continuous canopy of mature lodgepole pine in the project area increases the risk of crown fire. It would seem that this concern has been substantially abated, if not eliminated by the recent mountain pine beetle infestation which, of necessity, has significantly reduced the continuous canopy of mature lodgepole pine. We anticipate that any further analysis of this project will explain why or how there is a continued risk of crown fire at the same time the beetle outbreak has eliminated much of the crown.

Problematic crown fire behavior in the Intermountain area is still possible given the current lodgepole pine stand structure; similar stands adjacent to nearby communities have produced significant crown runs in recent years (Church’s Park Fire in 2010 on the Arapahoe Roosevelt National Forest, Big Meadows Fire in 2013 in the Rocky Mountain National Park). Potential fire behavior within the project area will be described in the analysis.

23 We understand the proposed project will employ helicopter yarding. Given the fact that you engaged in substantial helicopter yarding just around the corner in Minturn a few years back, we anticipate that any further analysis of the project will draw on that experience, rather than abstract decibel analyses of somewhat limited relevance. We can certainly say that the experience in Minturn during helicopter yarding was by no means insignificant.

A helicopter yarding analysis will be included in the environmental analysis, with a focus on economics and noise. Effects from helicopter noise on recreation will be included in the analysis.

24 The definitions of "individual tree selection" and "group selection" set forth in footnotes 5 and 6 of the Notice of

The two silvicultural definitions do have different


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Proposed Action are identical. We can only assume from the fact that these two types of treatment are separately identified that they are, in fact, different in some respect. Unfortunately, this cannot be determined because the provided definitions are identical. We anticipate that this will be cleared up in subsequent analysis.

meanings in the footnotes and will be corrected.

Individual tree selection is defined as an uneven-aged regeneration method where individual trees of all size classes are removed more or less uniformly throughout the stand creating or maintaining a multiage structure to promote growth of remaining trees and to provide space for regeneration. Multiple entries of this activity ultimately results in an uneven-aged stand of three or more age classes.

Group selection is defined as an uneven-aged regeneration method in which trees are cut in small groups and new age classes are established. The width of groups is commonly less than approximately twice the height of the mature trees. Individual trees in the matrix may or may not be harvested to provide improved growing conditions for remaining trees. Multiple entries of this activity ultimately result in an uneven-aged stand of three or more age classes (Source: FACTS User Guide [2/23/2014]; page 496, FACTS Activity Codes, Appendix B).

25 * We understand that the proposed silvicultural prescriptions will focus on removing dead trees within 400 feet of private lands. We presume this intended to create defensible spaces around private property. However, the proposed 400 foot buffer substantially exceeds any recommendation we can find. We expect that further analysis will explain why such a large buffer zone is in order.

The distance recommendations for hazardous fuels thinning included in the proposed action can be found in Canopy Fuel Treatment Standards for the Wildland-Urban Interface (Scott 2003) and are intended as a fire behavior mitigation element for firefighters as well as structures.

26 We expect any further analysis of the proposed action will thoroughly explain the economics of the project, particularly the different economics if helicopter yarding is not utilized, the different economics if some or all of the yarding sites are not available and how the project will be paid for.

An economic analysis of the project will be included in the analysis for this project. A range of costs for helicopter yarding will also be disclosed for project implementation. Project implementation would be funded by the Town of Vail.

27 Thank you for the opportunity to identify other issues related to helicopter yarding. I certainly appreciate the follow up. That said, subject to one exception, I'm not sure there is anything else I am concerned about with helicopter yarding other than noise and economics.

The one exception would be public safety. During the Minturn helicopter yarding a few summers back, it struck me that the

Mike Heaphy (follow-up response to an e-mail to Mr. Heaphy to clarify his question on helicopter logging)

See response to comment 23.

A design feature to close the area and flight path to public use during helicopter yarding operations would be included in the project design for public safety.

A thorough safety plan would also be put in place during helicopter yarding operations. All flight paths would avoid infrastructure, utilities, roadways and


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transportation methodology seemed pretty precarious, with one or more large logs dangling from the helicopter with seemingly minimal connection or protection. This raised the question in my mind of just how securely the logs were attached. Admittedly, I was viewing things from the ground so really couldn't see exactly how the logs were attached. It's entirely possible they were very securely attached with minimal risk of logs falling from the sky.

Furthermore, in Minturn, the flight path didn't appear to pass over any improvements so there really didn't seem to be any danger of logs falling from the sky and damaging property and/or people. I assume the anticipated helicopter flight paths for the Vail Intermountain Project would similarly avoid improvements but, if not, I think any further analysis of the project should address the risk of damage to property and/or people from falling logs.

improvements.

28 We are supportive of the efforts to protect the community through the removal of hazardous fuel loading on National Forest. We appreciate the United States Forest Service statement that the Proposed Action Design Features would follow all Water Conservation Practices and Best Management Practices to improve or maintain water quality, follow White River National Forest Plan Standards and Guidelines, and minimize conflicts with recreational events and users on the Vail Mountain permit area by prohibiting helicopter yarding, log hauling and associated activities at the landing area within the Vail Ski Area boundary on Saturday/Sundays and holidays.

Chris Jarnot, Executive Vice President and Chief Operating Officer, Vail Mountain

Thank you for your comments and support of this project.

29 While we acknowledge that we do not have an exclusive permit, we are concerned that the timber removal and disposal project as currently defined will materially interfere with the rights and privileges authorized by our Ski Area Term Special Use Permit. To help minimize project impact to Vail Mountain and its guests, we request that the project timber activities on Vail Mountain be scheduled to take place before mid-June and after September 15 \ and phased over multiple years.

There needs to be a balance between implementing the project and considering wildlife and recreation needs. Use of the landing area on Vail Mountain would be appropriate and would take into consideration time periods where there are more guests. For example, helicopter/hauling operations could be limited to Monday through Thursday (excluding holidays).

The White River National Forest (Forest) followed up with Mr. Jarnot regarding how this project may impact resort visitors and the special use permit the Forest has issued Vail Mountain. The Forest confirmed that Mr. Jarnot’s concerns were related to the haul routes and


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landing areas and not the project area as a whole. A design feature included in this project would establish specific locations, timing, and rehab measures related to the haul routes used during implementation.

Vail Valley has a lot of dead lodge pole pine due to the mountain pine beetle epidemic and there other local projects occurring that are removing these trees, so visitors are already experiencing this type of project implementation.

See response to comment 8 regarding safety.

30 We have invested a tremendous amount of resources in order to bring guest to Vail and the public lands on Vail Mountain during the summer. We have been successful in making Vail Mountain a summer destination. On any given day between mid-June and early September we have between 2-4000 guests participating in dispersed recreation on Vail Mountain. It is our highest priority to provide a safe and positive experience for our guest as they enjoy their public lands on Vail Mountain.

Operations will adhere to all safety requirements. Additionally, signage would be placed in coordination with Vail Mountain so guests and employees know when and where hauling operations would be located. The White River National Forest will also coordinate with Vail Mountain on issuing public notices and newspaper articles to inform the greater public on these operations; leading up to, during, and once the operations are complete.


31 The CPW’s Vail Deer Underpass State Wildlife Area was purchased in the 1970’s to protect the mule deer migration corridor. Any proposal to utilize this property as a helicopter yarding location would require CPW approval and additional discussions on what steps would be taken to fully protect/enhance the wildlife values in the Vail Deer Underpass State Wildlife Area.

Perry Will, Area Wildlife Manager, Colorado Parks and Wildlife

The Forest Service will collaborate with Colorado Parks and Wildlife on the potential use of the Vail Deer Underpass State Wildlife Area for helicopter yarding location.

Design features such as signage and barriers would be included to help prevent winter recreation use and allow for ticket writing if unapproved recreation use does happen. These design features would reduce adverse mule deer impacts until the aspen regenerate in the cleared areas.

32 Timing restrictions (October 16th thru June 30th) on operations to reduce wildlife impacts in winter range and corridor.

Based on Forest Plan General Wildlife Standard #1 (Land and Resource Management Plan, page 2-16, “Seasonal restrictions would be applied to reduce disturbance in key wildlife habitats”). Timing restrictions and coordination with the Colorado Parks and Wildlife would occur during project implementation related to pile burning in particular.


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33 Will these treatments lead to additional recreation use of the Intermountain area? The Intermountain area does contain the staging area for the mule deer migration corridor and elk winter range. Increased recreation use of this area will impact the effectiveness of this area for wildlife habitat.

Vail Resorts does not have a ski area exit point along their western permit area boundary. The area is signed with ski area boundary signs. Any recreation use in the proposed project area originating from the ski area is subject to skiers losing their privileges. There is no proposal from Vail Resorts to create a ski area exit point into this location. There may be an increase in illegal access initially, although most of the use in the area is primarily local skiers and not destination resort skiers. The scope of this illegal use would be concentrated along the eastern unit of the project area boundary and decrease towards the west. There is potential that some skiers may enter the area off of the resort.


Management Area 7.1 desired conditions (“Wildlife viewing is encouraged in areas not identified as winter range or sensitive habitats, and discouraged in those habitats considered sensitive,” Land and Resource Management Plan, page 3-74) will be met. In addition, potential for increased recreational use of the area will be disclosed in the Recreation Report, and resulting potential effects on wildlife will be disclosed in the Wildlife Report and mitigations will be developed, if necessary.

Documents

Vail Intermountain Fuels Project EA - fs.usda.gov