Decision Notice and Finding of No Significant...

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Final Decision Notice

Finding of No Significant Impact

North Hebgen Multiple Resource Project

United States, Department of Agriculture, Forest Service

Custer Gallatin National Forest, Hebgen Lake Ranger District,

Gallatin County, Montana

Responsible Official: Mary Erickson, Forest Supervisor

Date: June 2017

For More Information, Contact:

Teri Seth

NEPA Team Leader

Custer Gallatin National Forest

Bozeman Ranger District

3710 Fallon St., Ste. C.

Bozeman, MT 59718

406/522-2520

Or

Jason Brey

District Ranger

Custer Gallatin National Forest

Hebgen Lake Ranger District

330 Gallatin Rd

West Yellowstone, MT 59758

406/823-6961


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Table of Contents

Contents Table of Contents ..................................................................................................................................... ii I. Introduction and Background .......................................................................................................... 1 II. Purpose and Need for Action ............................................................................................................ 2 III. Decision and Reasons for the Decision ............................................................................................. 5

A. Decision ...................................................................................................................................... 5 B. Reasons for the Decision ............................................................................................................ 8

1. How well the management actions analyzed in the Final EA address the purpose and need

of the project. ................................................................................................................................... 8 2. Responsiveness to public comments raised during the comment period, and other

collaborative phases of project development and the environmental issues identified in

association with this project ........................................................................................................... 10 3. Does the alternative comply with applicable laws, policy and direction? ................................. 19

IV. Alternatives Considered ................................................................................................................ 38 V. Public Involvement and Scoping ................................................................................................... 41 VI. Finding of No Significant Impact .................................................................................................. 43 VII. Findings Required by Other Laws and Regulations ...................................................................... 50 VIII. Administrative Review - Objection Process and Implementation ................................................ 54 IX. Contact Person ............................................................................................................................... 55

A. Appendix A – Selected Alternative Map and Alternative Comparison Tables ............................ A-1

Final Decision Notice and Finding of No Significant Impact

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I. Introduction and Background This Decision Notice (DN) documents my decision to select Alternative 2 with modifications (Selected

Alternative) from the North Hebgen Multiple Resource Project Environmental Assessment (EA) for

implementation. The Selected Alternative includes up to 5,670 acres of treatment and 15.6 miles of

temporary road. My decision includes approximately 71 total acres of tree cutting in the inventoried

roadless area. Thirty nine acres includes hand cutting of trees (ie chainsaw) and 32 acres of mechanized

harvest is authorized. The decision eliminates approximately 230 acres proposed for treatment and five

miles of temporary road from alternative 2. Generally, the changes address concerns expressed by the

public related to the amount of temporary road and effectiveness of highway thinning for wildlife safety.

The purpose and need for the North Hebgen Multiple Resource Project was identified during the Hebgen

Duck Landscape Assessment (GNF 20121) as a way to meet standards and move toward goals of the

Gallatin Forest Plan (USDA 1987 as amended) and to address national fire/fuels policy priorities

(Interagency Federal Wildland Fire Policy Review Working Group 2001) (National Fire Plan 2000)

(Gallatin County 2006). A Project Development Summary with background information from those

guiding documents is available on the Gallatin National Forest Webpage at

https://www.fs.usda.gov/project/?project=45491 2

This project area is in the Greater Yellowstone Area, abuts Yellowstone National Park and includes

extensive private land. The project area is located in the Tepee Creek drainage south of the Cabin Creek

Wildlife Management Area to the Madison Arm of Hebgen Lake, and from the Yellowstone National Park

Boundary west to the Horse Butte peninsula and the vicinity of Red Canyon on the North side of Hebgen

Lake. Treatments are proposed in portions of sections 24-26, 35, 36, T 11 S, R 04 E; sections 17, 19, 20,

29-34, T 11 S , R 05 E; sections 2, 11, 13, 15, 22-27, 35, 36, T 12 S, R 04 E; Sections 3-6, 8-10, 19-22,

27-34, T 12 S, R 05 E and Sections 3, 4 , 10, T 13 S, R 05 E. The project area also includes portions of

the Madison 1-549 Inventoried Roadless Area (IRA). Figure 1 in the Final EA , includes a vicinity map

of the Project Area.

My decision is based on the analysis documented in the North Hebgen Multiple Resource Project Final

EA , which incorporates response to comments received during the scoping comment period for the

project, as well as the 30-day comment period on the Draft EA and the objection process. The North

Hebgen EA was prepared pursuant to the requirements of the National Environmental Policy Act (NEPA,

40CFR 1500-1508), the National Forest Management Act, and the 1987 Gallatin National Forest

Management Plan as amended.

This document includes my decision, the rationale for selecting alternative 2 with modifications,

Alternatives considered, Public Involvement, a Finding of No Significant Impact, Findings required by

law, regulation, or policy and information about the Administrative Review process. As the responsible

official, I am responsible for evaluating the effects of the project relative to the definition of significance

established by the CEQ Regulations (40 CFR 1508.13). I have reviewed and considered the Final EA and

documentation included in the project record, and I have determined that the North Hebgen Multiple

Resource Project will not have a significant effect on the quality of the human environment. As a result,

an environmental impact statement will not be prepared.

1 All cited documents in this Decision Notice are available in the Project Record.

2 Reference to documents on the “Project Webpage” can be found on the North Hebgen Project Webpage on the

Gallatin Forest Webpage under Land Management/ Projects at http://www.fs.usda.gov/project/?project=45491

https://www.fs.usda.gov/project/?project=45491

http://www.fs.usda.gov/project/?project=45491


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II. Purpose and Need for Action This proposal is a multiple resource proposal intended to address six management “needs” in the North

Hebgen project area.

Create wildland fuel conditions in the wildland urban interface (WUI) that, in the event of

ignition, result in low intensity surface fire with low resistance to control. These conditions will

provide for public and fire fighter safety and less wildfire risk to homes, improvements,

powerlines and evacuation routes addressing the Gallatin Forest Plan as Amended (FP II-31) and

National Fire Policy Mandates (Interagency Federal Wildland Fire Policy Review Working

Group 2001, National Fire Plan 2000, Gallatin County 2006).

Due to high recreation use as a gateway community to Yellowstone National Park, 68% of fires are

generally human caused (campfires). Eighty percent of the project area is in WUI (wildland urban

interface) and all of the proposed fuels treatments are within designated WUI (GCCWPP 2006). There

are 6.5 miles of critical infrastructure (powerlines) and over 500 structures (values at risk) with additional

outbuildings distributed throughout the project area on the Flats and near the north shore of Hebgen Lake

(Jones 2016). Fire Behavior results were determined for the PRE condition and POST treatment

condition. The modelled flame lengths indicate intense surface fire and likely transition to crown fire for

the existing condition in much of the area (Jones 2016). These conditions have a high resistance to

control. A significant risk to life and property exists wherever forest stands prone to crown fire lie in

proximity to residential or recreational development. Fuel treatments can have positive and desired

effects of reducing flame length, crown fire potential, resistance to control and increased tree survival

(Agee, J.K. 2002).

Create wildland fuel conditions along the Tepee Creek Road that, in the event of ignition, result

in low intensity surface fire with low resistance to control that will help fire managers to

compartmentalize and contain wildfires to specific drainages and to provide for public and

firefighter safety for ingress and egress on this road (FP II-2, II-31)

The six mile length of Tepee Road FSR#986 from Highway 191 north to Tepee Creek Trailhead #151 is a

heavily timbered, narrow road corridor that runs along the divide that separates Johnson/Whit’s Lake area

from the Little Tepee and Tepee Creek drainages. The road corridor currently has a surface ladder and

crown fuel configuration that has a high resistance to control. Modeling indicates that high intensity fire

is expected to occur along most of the route (Jones 2016). Access to the area by responding firefighters is

hazardous due to the limited visual openings and there is potential for entrapment given the one way in

and one way out scenario. The roadway presents an opportunity and strategic location to establish a fuel

break that can help managers to compartmentalize and contain wildfires to specific drainages and improve

safety in an active wildland fire event. Fuel breaks divide fire-prone areas into smaller areas for easier fire

control and provide access for firefighting. (Gallatin County, Community Wildfire Protection Plan; 2006).

Compartmentalization of fires by fuel breaks, which may or may not be laid out in a connected network,

can help to reduce fire size but generally will not reduce damage per unit areas burned outside of the fuel

breaks themselves (Agee and others, 2002).

Remove conifer competition in aspen stands to improve aspen regeneration and growth in aspen

stands (FP II-21).

Aspen is a deciduous tree that contributes to ecological diversity, supports a variety of plant associations,

and provides important habitat for many species of wildlife. Aspen and riparian areas are considered the


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most biologically diverse communities in the West (USDA, FS 20143). These communities are rich in

insect and plant diversity, both of which contribute directly to the diet of grizzly bears. Ungulate species

such as moose and elk rely heavily on young aspen shoots for forage. These areas, therefore, provide

important foraging areas for grizzly bears, gray wolves and their prey species. (Wildlife Report updated

6/2017) Additonal information explaining the importance of aspen habitat and the tools included in order

to manage aspen habitats is in the Gallatin Forest Aspen Restoration Project Decision Memo (2014).

Migratory bird species also rely heavily on aspen communities.

Conifer encroachment has occurred over a long period of time; encroachment includes large conifers as

well as sapling and pole size trees competing with aspen for light, nutrients, and water in aspen clones.

Aspen is scattered throughout the project area and is most notable at lower elevations near the

forest/grassland interface on Horse Butte, in Red Canyon, along Whits Lake Road, on Fir Ridge, and at

the base of Tepee Creek Road. It is expected that aspen would [continue to] decline over time; as field

observations indicate that conifer encroachment represents the greatest threat to aspen sustainability

within the analysis area. Conifers can shade out aspen and severely limit the possibility of aspen

suckering (Shepperd et al., 2006).

Increase the presence of white bark pine forest. The desired condition is to encourage whitebark

pine establishment where cone producing mature trees provide a seed source and/or to reduce

inter-tree competition around healthy whitebark pine trees to allow the forest stands to reach cone

producing age sooner. (Forest Plan p. II-21, III-54).

Whitebark pine (WBP) exhibits influence on ecosystem processes at multiple scales and serves as both a

keystone and foundation species. As a keystone species, WBP maintains subalpine biodiversity and its

nuts provide an important nutritional source of food for several wildlife species, including grizzly bears.

The WBP seed crop is one of the four main food sources sustaining grizzly bear populations in the

Greater Yellowstone Ecosystem (GYE). As a foundation species, WBP is often the initial colonizer on

sites with difficult growing conditions. Once established, it ameliorates site conditions, enabling other

plant species to colonize. Severe population declines in WBP communities are attributed to white pine

blister rust, mountain pine beetle, fire suppression, wildland fire, and climate change (GYCCWBPS,

2011; Keane et al., 2012; Mahalovich, 2013). Within the GYA, large scale mortality of WBP is driven by

a recent mountain pine beetle outbreak, wildland fire, and to a lesser extent, blister rust (Mahalovich,

2013).

In the project area, there are an estimated 20,660 acres of WBP stands ranging from WBP dominated to

WBP mixed stands. (Konen 2015) Virtually all of those stands have a need for protection, and roughly

8,300 acres have a need for restoration. Proposed treatments are limited to Tepee and Little Tepee Creek

near the existing roads in order to balance costs to implement and constraints in the Northern Rockies

Lynx Management Direction (NRLMD) (2007) and the Roadless Rule (2001). Whitebark pine stands be

expected to continue to decrease as a result of competition from more shade tolerant species and

continued susceptibility to insects and disease. Loss of whitebark pine forest would reduce the

availability of this important food source for a number of wildlife species including grizzly bears. While

Costello and others (2014) found that grizzly bear were not necessarily compelled to use less secure

habitats due to declines in whitebark pine seed availability, the likelihood of contacts with humans in the

fall as bears search in lower elevations for alternate food sources may increase.

3 USDA Forest Service, Gallatin National Forest, Aspen Project Decision Memo 2014.


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Create a more resilient forest. The objective of these treatments is to maintain a diverse, vigorous,

and adaptable forest landscape by providing for a mix of species composition, stand structures,

and age distribution. This objective will maintain desired vegetative condition, reduce long term

losses caused by insects and diseases and actively control damaging agents. (FP II-2, 21, 25, III-

56). These proposed treatments were limited to areas that are identified as important for multiple

resource reasons, in addition to potential forest health risk.

Forest insects and disease are major disturbance processes in forests of the Northern Rocky Mountains.

There effects can range from small scale disturbances, killing individual trees, to wide spread outbreaks

causing extensive tree mortality. Native forest pests have been part of our forests for millennia and

function as nutrient recyclers, agents of disturbance, members of food chains, and regulators of

productivity, diversity, and density (Black, 2005). Forested stands within the project area are currently

being impacted, or are at risk of being significantly impacted by a variety of disturbance agents.

Mountain pine beetle, lodgepole pine (LPP) dwarf mistletoe, western spruce budworm (WSB), Douglas-

fir beetle, and white pine blister rust are specifically of concern. The objective of some forest health

treatments will be to reduce long term losses and actively control damaging agents in forested areas.

Some areas, managed in the past are losing vigor due to overcrowding. These stands will be thinned to

improve vigor while at the same time reducing ladder and crown fuels. These units are primarily along

evacuation routes and near private land. This treatment will be concentrated on small trees (less than 5”

in diameter) because small trees dominate the stands.

Douglas fir forest is minimally represented in the area due to stand succession, limited potential habitat

and ongoing attacks from Douglas fir beetle and WSB. Retention of Douglas fir forest is important

because this species is fire tolerant and presence of Douglas fir adds to species diversity, in a landscape

dominated by lodgepole pine forest. A diversity of species increases landscape resiliency in the event of

epidemic level attacks by insects or disease. One desired condition is to maintain or increase Douglas fir

forest. Although aspen and whitebark pine enhancement are discussed separately, those treatments also

increase vegetative diversity in a fairly uniform landscape, resulting in increased resiliency on the

landscape (FP II-21).

There is very little species or age class diversity in lodgepole pine stands in the slopes above Whit’s Lake

Road. A carpet of (LPP) lodgepole pine tends to dominate the slopes allowing very little sun to reach the

forest floor, the end result is little or no forage or age diversity. In these stands, the desired condition is to

create openings that will result in forage and age diversity (FP II-18, 21, III-54, 65).

Increase sight distance to reduce negative human/grizzly bear encounters around Rainbow Point

Campground due to dense forest cover.

The campground is one of the busiest campgrounds in the Northern Region of the Forest Service and is

located in the primary conservation area for grizzly bear. There have been numerous unintended

encounters near the campground that have ended in a range of outcomes from nuisance bear habits that

result in removal of the bear, to human fatalities. This area is to be managed for the safety and enjoyment

of users (FP-III-2). In 2014 the Greater Yellowstone Coordinating Committee (GYCC) ranked USFS

recreation sites in the GYE according to their relative risk to grizzly bears (2014 GYE campground risk

and infrastructure survey). Rainbow Point Campground ranked 3rd in risk to grizzly bear of the 164

USFS recreation sites assessed for the GYE. The treatment objective is to reduce the likelihood of a

surprise encounter between bears and humans by thinning trees to open up the stand.

The environmental assessment (EA) documents the analysis of three action alternatives to meet these

needs.


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III. Decision and Reasons for the Decision Decision criteria:

How well the management actions analyzed in the EA address the purpose and need of the project.

Responsiveness to environmental issues identified in association with this project (Final EA , pp.

32-209) and to public comments raised during the Draft EA comment period, objection period and

other collaborative phases of project development (Final EA , Volume II - Appendix C).

Consistency with applicable laws, policy and direction.

As the project decision maker, I weighed potential benefits of the alternatives against possible adverse

impacts, and considered suggestions and concerns from the public. The design features incorporated in

the decision and changes made in the Selected Alternative result in an environmentally preferred

outcome. I am committed to incorporating all design features/mitigation and monitoring during project

implementation and have begun to seek funding as needed to effectively implement the associated

activities. I anticipate the availability of sufficient resources to ensure the performance of these design

features, mitigation and monitoring. Most of the design features do not require additional funding. They

are incorporated during project preparation and administration. The Finding of No Significant Impact (p.

40) supported the use of an EA as the appropriate level of NEPA analysis. I considered Forest Plan

standards and guidance for the project area, and took into account competing interests and values of the

public.

A. Decision Based upon my review of all alternatives, I decided to implement alternative 2 with a few modifications,

hereinafter referred to as the Selected Alternative. Table 1 summarizes the primary activities in the

Selected Alternative and the changes as compared to Alternative 2. The main changes between

Alternative 2 and the Selected Alternative are that units 33 and 34 (Highway Thin) were eliminated and

5.5 miles of temporary road have been dropped from the decision. Specific unit changes are documented

in the project file (Seth, 10/2016 - Selected Alternative Modifications).

Primary Activities

This alternative meets the purpose and need for action which will implement standards and move the

project area toward goals of the Gallatin Forest Plan as amended, addresses national fire/fuels policy

priorities and addresses concerns expressed during the comment period. Appendix A of the Decision

Notice (DN) includes maps that display the treatment units by treatment prescription and includes the

general location for proposed temporary roads for this Alternative. The map also shows changes from

alternative 2, including units that were dropped or modified and segments of temporary road that were

dropped from consideration. A comparison of all action alternatives by treatment and issus also in

Appendix A.


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Table 1. Selected Alternative – Primary Components of the Selected Alternative.

Purpose of Treatments Acres of Treatment

in the Selected

Alternative

Difference from Alternative 2 in

Acres4

Aspen enhancement

Improved forest resiliency/health

Fuels reduction in WUI, Evacuation

Routes, Powerlines and Fuel break

Whitebark Pine Enhancement

Increased sight distance and reaction

time for improved wildlife/human

safety at Rainbow Point Campground

652

991

2817

1,139

67

-49

+29

-81

+10

-138

Acres to be Treated (rounded) 5,670 -230

Methods or Treatments5 Planned Acres Acres

Daylight by Thinning around

Whitebark Pine

Precommercial Thin

Hand thinning

Post and Pole Thinning

Powerline Corridor Thinning

Group Selection

Intermediate harvest

Regeneration harvest

Highway Corridor Thinning

843

1,076

137

177

127

693

1,990

623

0

=

+56

+121

=

-13

-2

-298

+32

-138

Estimated Total Acres treated 5,670 acres (rounded) -240 total acres with 180 more acres of

precommercial and hand thinning and

an overall reduction in commercial

mechanized harvest of about 420 acres.

Design Features and Mitigation Common to Action

Alternatives Listed in Appendix A of the Final EA

Terms and Conditions added

Temporary Road construction, closure and rehabilitation

– 15.66 miles

-5.4 miles

Site specific Gallatin Forest Travel Plan Modification of

Standard E-4 - to allow treatments in the Little Tepee Creek

and Red Canyon Creek watershed to proceed despite existing

The same

4 Due to inconsistent rounding these numbers between tables vary slightly when comparing against the Alternative 2

estimates. However, the selected alternative estimate in this table represents the maximum levels of treatment. 5 Appendix C of the EA includes a more detailed description of the treatments and associated fuel treatment activity.

A detailed listing of treatment details by unit for the Selected Alternative called “2016_1028Selected

AlternativeTreatmentTableandSummary” is available on the Gallatin Forest webpage at

https://www.fs.usda.gov/project/?project=45491 along with maps that can be viewed at a larger scale.

6 Approximately 2 miles of temporary road included in this total is the Big Sky Trail #151. Under the Gallatin

Travel Plan (2006), the trail is currently motorized and the use will remain motorized after the North Hebgen

project. The trail is not designed for highway vehicles. The routes will be restored to standards that accommodate

trail vehicles.



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instream fine sediment levels of 28.5 and 34% which exceed

the 26% standard for Category A streams.

Associated Activities.

Activities may include, but are not limited to, thinning with mechanized equipment, slashing small trees,

whole tree yarding, yarding unmerchantable material, hand and machine piling, pile and broadcast

burning, hauling of commercial material, firewood removal, biomass reduction such as chipping, erosion

control, construction of and rehabilitation of skid trails, landings and temporary road, creation of small

emergency pullouts along main roads, such as Rainbow Point. Emergency pullouts were requested during

the comment period. Monitoring of project activities and effectiveness is planned and described in

Appendix A of the Final EA .

An estimated 15.6 miles of temporary road will be needed to implement the proposed action. Temporary

roads, when prescribed, are intended to minimize the cost of transporting logs and fuel consumption by

transporting logs by more efficient log trucks rather than ground-based skidding. These roads also protect

resources such as sensitive soils and stream courses that would be adversely affected by repeated ground-

based skidding. Temporary roads, by design, are a single entry access and are not intended to be a

permanent part of the road system. As such, they will be located and constructed to minimize investment,

dirt moving, and disturbance. During the project, use of these roads is limited to administrative use and

will be gated, barricaded or signed as needed to prevent unauthorized use. Following use, these roads will

be permanently closed and rehabilitated to meet adjacent land management objectives with no regard to

future access; this obliteration could include a variety of methods such as recontouring, scarification,

seeding, and slashing of the corridors. The appropriate method will depend on the site specific level of

disturbance. Appendix A of the Final EA includes detailed road management information for system

roads to be used for implementation and design features. Temporary road management information and

intent was compiled in 20161221_Temporary Road Management Compilation which is available on the

project webpage.

Implementation

The project is estimated to take 8-12 years to implement. The activities proposed will be implemented

with Forest Service crews, service contracts, and through multiple timber sale contracts and/or

stewardship contracts. Value from the wood products removed and sold will be re-invested into the

project area through stewardship contracting and other mechanisms. All primary treatments, associated

activities, design features and other restoration projects will be considered for implementation with timber

receipts. Appropriated funding will also be available to implement treatments and associated activities.

Most of the restoration or protection activities will be included in the primary contracts. As a result, the

cost to implement commercial harvest and restorative measures in those contracts are factored into the bid

prices and do not require additional funding. For example, landing and temporary road construction and

closure have provisions in contracts. Other funding sources, such as grants or appropriated funds, will

also be considered for all project related activity.

Selected Alternative Mitigation

No other projects that affect secure habitat below baseline levels will be implemented in the

Madison #2 Bear Management Subunit (BMS) until those project activities affecting secure habitat

have been completed.

The total acreage of secure habitat affected below the baseline in a Bear Management Unit will not

exceed one percent of the acreage of the largest subunit in the BMU.


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Project roads that affect secure habitat below baseline levels in the Madison #2 BMS, collectively,

will be available for project use for no longer than 3 consecutive years and then closed to all

motorized travel. This includes temporary roads to units 23, 25, 36, 41, the units between the

Rainbow Point Campground and Rainbow Point Road and the Horse Butte Units. Project roads that

affect secure habitat below baseline levels in the Madison #2 BMS will be decommissioned, such

that secure habitat will be restored within one year after road closure.

Terms and Conditions from the US Fish and Wildlife Service Biological Opinion 5/17/2017.

Within secure habitat in the Horse Butte area of the Madison #2 subunit, mechanized project-

related activity shall not occur from March 1 through September 30 annually.

Prioritize project-related activity within the Madison #2 subunit in order to complete such

activities in the minimum time-frame as possible.

B. Reasons for the Decision

1. How well the management actions analyzed in the EA address the purpose and need of the project.

Central to making my decision was the extent and effectiveness of treatments toward achieving the

purpose and need for action. This of course is balanced with the direct and indirect effects on the array of

natural, physical, cultural and social resources. Table 1 and 2 in Appendix A is a comparison of the action

alternatives including acreages and issues/effects.

The analysis shows that there will be lower wildfire risks due to wildfire hazard reduction in the treated

areas. In the event of ignition there will be a change in fire behavior resulting in surface fire with low

flame lengths and as a result low resistance to control. (Final EA p. 35-36). The real indicator is whether

important areas are included in the alternative. Alternatives 2, 4 and the Selected Alternative effectively

reduce fuels in the WUI and WUI evacuation routes by reducing ladder, crown and surface fuels adjacent

to “values at risk” and along key evacuation routes. The Selected Alternative, alternatives 2 and 4

effectively provide for firefighter and public safety, which is not only my priority, but a priority

emphasized regionally and nationally (Final EA , p. 6). Alternative 3 does not address firefighter and

public safety objectives or achieve fuel reduction near “values at risk” near Horse Butte or Rainbow Point

Campground which for me, is a very undesirable trade off due to infrastructure, as well as the number of

homes and improvements. In addition to the residential setting near Rainbow Point Campground, it is

one of the busiest Forest Service campgrounds in the Northern Region of the Forest Service. In effect,

only 12 acres of fuels treatment in WUI in Red Canyon is eliminated in the Selected Alternative as

compared to the preferred alternative (2). In my decision, the other changes to units with a fuels

objective, place other resource objectives such as forest health or whitebark pine as a primary objective

by redefining the prescription, while still meeting fuel treatment effectiveness. The fuels treatment

effectiveness along Tepee Creek Road are the same in all action alternatives. Due to the hazard reduction,

an effective fuel break that promotes low severity surface fire will be created and firefighter and public

safety will be enhanced along the road. In addition to forest resources, US Highway 191 and Yellowstone

National Park are in the path of prevailing winds from the Tepee area, which reinforces the benefit of

increased management options in the event of wildfire in the vicinity of Tepee Creek Road.

The analysis also shows that the improvement cuts proposed to enhance aspen forest will improve

sprouting and vigor in treated aspen stands. Again, it is a matter of how much aspen forest is treated. The

Selected Alternative is as effective as alternative 2 except that the treatment in unit 147 is reduced by 49

acres, similar to Alternative 4. As a result, the Selected Alternative more effectively meets aspen

objectives than alternatives 3 and 4, and only slightly less than alternative 2. Alternatives 3 and 4 include


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only 37% and 53%, respectively, of the aspen treatments included in the Selected Alternative and

alternative 2, which to me would be a missed opportunity and is very undesirable at a time when aspen

enhancement is a Forest and regional priority due to the loss of aspen across the landscape. In my

decision, the extent of existing aspen stands will be maintained or improved which will ensure aspen

persistence on the landscape for a wide suite of wildlife species. A more complete discussion is in the

Final EA , on pp. 8, 49, 58 and the Forest Vegetation Specialist Report (Konen 2015).

Again, the analysis shows that whitebark pine (WBP) enhancement by daylighting and small regeneration

harvests will improve growth and support establishment of WBP stands eventually reaching cone

producing age sooner than without treatments (Final EA , p. 9, 49, Konen 2015). Benefits to WBP are

virtually the same as in the Selected Alternative and other alternatives, but the treatment prescription in

my decision was modified in unit 180 to better meet WBP objectives, while at the same time meeting fuel

reduction objectives. Unit 201 was dropped in the Selected Alternative similar to alternatives 3 and 4 due

to the expense of helicopter logging and the inability to meet objectives through other treatment methods.

This change improves the overall cost efficiency while reducing WBP treatments by only about 16 acres.

I consider this a small trade off given the opportunity to enhance over 1,100 acres of this keystone species

within the project area and to enhance the value of these stands for wildlife in the long term. Alternatives

3 and 4 are less effective in comparison, though all action alternatives are very similar relative to WBP

forest. A more complete discussion is in the Final EA , on pp. 49-60. Most whitebark pine stands on the

Forest are in Wildernesss and Inventoried Roadless Areas which allow very limited active management.

The Tepee Creek area is accessible and in management areas designated for proactive management.

There are not many such opportunities in whitebark pine on the Custer Gallatin Forest. For these reasons,

this management opportunity is very compelling to me.

Analysis in the Final EA (pp. 10-12, 52-58) and the Forest Vegetation Analysis (Konen 2015) shows that

the treatments included for forest health will improve conditions in treated areas. Forest health is

enhanced on 29 more acres in the Selected Alternative. The overall effectiveness is very similar to

alternative 2. Alternatives 3 and 4 are less effective. As a reminder, these units were included only when

they were located near areas identified for other resource reasons, such as aspen enhancement or fuel

reduction. The intent of this design consideration was to use existing access routes and to provide

contiguous treatments. If beetles or disease are present in adjacent areas, then the risk of attack or

infestation is higher, which is why forest health treatments are most effective when a more contiguous

landscape is included. Management guidance associated with the Roadless Rule, Grizzly Bear

Conservation Strategy and the Northern Rockies Lynx Management Direction have sideboards in place to

protect those very important resources, which limited my ability to expand the forest health treatments to

a broader landscape.

All action alternatives improve wildlife and human safety near Rainbow Point Campground equally. The

Selected Alternative does not include the highway clearing units for wildlife safety along US 191 that are

in alternatives 2, 3 and 4. The rationale for this decision is discussed on page 12 of the DN.

The No Action Alternative does not address any of the purpose and need for action. However, it is useful

in comparing the effectiveness of action alternatives. Overall, Alternative 2 most effectively addresses

the purpose and need for action while the Selected Alternative is a close second. In an attempt to reduce

temporary roads, Alternative 4 does not include about 530 acres of valuable treatment toward achieving

project objectives. In the end, through the Selected Alternative design, my team was able to more

effectively reduce temporary roads needed while meeting project objectives on more acres of ground

compared to Alternative 4. Alternative 3 compromises the purpose and need too dramatically as it relates

to firefighter and public safety and aspen treatments, for me to select that alternative.


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2. Responsiveness to public comments raised during the comment period, objection and other collaborative phases of project development and the environmental issues identified in association with this project (Final EA, pp. 32-209).

In my decision, it was important not only to understand the effectiveness in meeting the intent of the

project, but also to understand and weigh overall environmental effects and consider key issues

surrounding the project. The EA issues were divided into two categories. The first group of issues was

used in alternative development to resolve conflicts concerning alternative uses of available resources.

They were the focus of alternative development to provide a range of potential impacts. The issues were

the focus of interdisciplinary action. The key issues are discussed below and they included fuels, forest

vegetation - aspen, whitebark pine, forest health, grizzly bear, invasive weeds and scenery. The remaining

issues listed in Table 2 identify other resource concerns that were mitigated equally in all alternatives

and/or there were no impacts or minimal impacts. For more information refer to the EA or specialist

reports. The key to the second category was that there was not a conflict between alternative uses.

During the Draft EA comment period, I received comments on numerous issues, and my staff spent

considerable time responding to comments in Appendix C of the Final EA (Volume II). No new issues

came up but the commenters wanted more explanation, more mapping and data, and wanted consideration

of various articles or reports. The response to comments is expansive; over 130 pages. My specialists

were diligent in attempting to address concerns raised. However, the intent of an EA is to determine

whether to prepare an EIS, so inclusion of extensive analysis and information requests that were generally

not relevant to the FONSI seemed most appropriate in the Appendix. When appropriate, additional

analysis was added to the specialist report and EA.

In general, temporary roads and the highway thinning units to improve wildlife visibility were of greatest

concern expressed by multiple commenters. Other themes related to funding availability to implement

the treatments and protective measures and whether the treatments were backed in science. The primary

issues raised are also discussed in this section.

Fire and Fuels

This issue was identified in the purpose and need for action and in my view, the importance of this work

cannot be overstated. Firefighter and public safety is emphasized in national, regional and local priorities

(DN p. 2). The need for hazardous fuel reduction is a Forest Plan standard. I believe that moving the

project area toward Forest Plan goals and addressing the multiple levels of policy emphasizing this

priority will help the Forest and other government agencies protect values and address safety concerns in

the event of wildfire. I have witnessed large and dangerous fires in the project area that reinforce the

inevitability of large fire and the need to adapt the WUI and evacuation routes in such a way that will

help agencies improve firefighter and public safety and reduce the risk to homes and infrastructure. The

fuel break along Tepee Road will give me and other line officers more management latitude to

compartmentalize and contain wildfire to specific drainages to better adapt to the situation whether it is to

suppress a fire or “herd” a fire to areas where there could be a resource benefit. To the north and east of

the fuel break is a large contiguous expanse of roadless lands, the Cabin Creek Wildlife Management

Area, US Highway 191 and Yellowstone National Park with many competing interests for the role of fire

and public and fire fighter safety. To the south is rugged lands and wildland urban interface. I view the

fuel break as an opportunity to have more influence and options in a wildfire situation. The Selected

Alternative will achieve those goals. For more information, see the DN, p. 2 and Final EA, p. 32-41.

The main comments I received about the fuels issue related to effectiveness of treatments, science based

comments and whether treatments are needed. See the Fire/Fuels section in Appendix C of the Final EA

for detailed responses. During the objection process the issue of whether we considered the best science


11

was again raised as it relates to an article by Tania Schoennagel and others called “The Interaction of

Fire, Fuels and Climate across Rocky Mountain Forests”. While the publication was considered during

analysis and discussed in Volume II of the Final EA, pp. C-14, the citations may not have been clear and

additional context may be helpful and is provided in a memo in the record, Direct Response to

Schoennagel (Jones, F. 2017). In short, the observations that the authors make do not contradict to

actions or intent of the North Hebgen proposal. The Fire/Fuels analysis acknowledges that the forest type

is indeed high elevation subalpine types that often experience infrequent, high severity crown fire.

However, the North Hebgen proposal does not purport to mitigate fire hazard across the landscape.

Rather, fuel reduction treatments are designed to modify fire behavior (reduce potential for crown fire) in

and around wildland urban interface areas near critical infrastructure and are strategically located to

provide a fuel break between distinct drainages. Schoennagel 2004 does not advocate delaying action

until all ecological questions have been answered in these landscapes; the authors acknowledge that in

many places there is an urgent need and a solid basis for restoration and fire mitigation efforts.

Typically WUI and critcal infrastructure is not prevalaent in high elevation subalpine forest, but that is not

the case in Hebgen Basin near the community of West Yellowstone, MT. This area is a gateway

community to Yellowstone National Park, receives high recreation use and 68% of local fires are human

caused. Eighty percent of the area is WUI as identified in the Gallatin County Wildfire Protection Plan

(CWPP) and all proposed fuel treatments are within designated WUI. In this particular location, I have

determined that there is an urgent need and a solid basis for fire mitigation due to the values at risk. The

purpose and need is clear that this is the intent, rather than landscape scale fire hazard mitigation.

Forest Vegetation

The elements of Forest Vegetation that are drivers for the project in the Purpose and Need were discussed

in section B. 1, relative to alternative comparison.

The objectives and treatments in the Selected Alternative move the project area toward goals and meet

several standards in the Forest Plan through project design and intent. I consider forest health and

resilience to be a fundamental goal in managing our national forest system lands especially in situations

like the North Hebgen Project where maintaining and improving forest resources achieves a wide variety

of objectives such as improved firefighter and public safety, providing for habitat persistence (aspen,

WBP) and landscape heterogeneity for wildlife species (including T & E species and their habitat). The

treatments will result in conditions that create and maintain a variety of species, size and age classes and

will increase stand vigor. These attributes increase resilience in the face of insect and disease activity,

drought, climate change and susceptibility to other natural disturbances. For this project we discuss

primary treatment objectives as the purpose and need, but secondary objectives are alsoidentified for most

units in the Treatment Unit Summary Table which is on the Project Webpage. Virtually all of the fuels

treatments provide a secondary benefit to forest health and vigor. Effectively all acres treated in the

Selected Alternative will improve forest health and resiliency whether by increasing stand vigor, reducing

susceptibility to insects and disease or by promoting the presence of preferred or underrepresented

species.

From the standpoint of forest vegetation management, the project intent is compatible with overarching

goals of the agency, as well as the Gallatin Forest Plan. There is extensive discussion in the purpose and

need section of the DN (p. 1-4) and Final EA (pp. 8-12) describing the need and importance of the

treatments. The analysis in the Final EA under forest vegetation and wildlife goes into great detail about

the expected impacts, outcome and consistency with the Forest Plan and the National Forest Management

Act. I considered the effects discussed in the analysis in both the Final EA (pp.41-60) and the forested

vegetation specialist report (Konen 2015) and determined that the treatments will have minimal negative

effects and that they address agency and Forest direction very effectively.


12

Some commenters challenge the validity of the purpose and need and treatments. I consider these

management goals and associated activities fundamental to the Forest and Agency goals and they are

consistent with management intent. Several commenters were skeptical about whether whitebark pine

(WBP) treatments will be successful. This project includes many acres of treatment for WBP and I expect

that it will take several years to complete the work. The post treatment exams included will give us time

to see if there is an immediate response or an apparent need to modify the treatment prescription. The

Custer Gallatin Working Group (CGWG) is also working with the Forest to support long term monitoring

in the WBP thin units to validate effectiveness.

Old growth and mature forest structure were a concern for some commenters. I reviewed the estimates

and analysis related to old growth and over mature forest structure and determined that the project, as

designed, will meet these Forest Plan standards (Final EA, p. 47-49, 58, 60). In addition, the

composition of the successional stages of the trees in the project area indicates up to 78% of the trees are

in a mature size class indicating that recruitment of additional old growth should be readily available

(Final EA, p. 48 ). In November 2015 the Forest amended the Forest Plan relative to old growth and over

mature forest structure which caused some confusion for this project in the early stages. The Forest Plan

as amended in 2015 is the current direction. The amendment (Clean up Amendment) and supporting

NEPA documents are available on the Project Webpage. The Forest Plan standards were established to

ensure those habitat components were maintained at appropriate levels on the landscape, this project

meets or exceed Forest Plan levels. As a result, I believe that habitat needs of old growth and mature

forest reliant species will be maintained.

My staff thoughtfully responded to the comments on forest vegetation in Appendix C of the Final EA .

Several variations of analysis were requested during comment but the specialist report and Final EA

provided sufficient analysis for me to make an informed decision about whether the project was

consistent with applicable direction and whether potential impacts would be significant.

The purpose and need identifies vegetation management as a tool to move the project area toward desired

forested conditions. Emphasis areas include enhancement of aspen, WBP and increasing forest health and

resiliency. The Forest Plan identifies goals for unique habitats such as Aspen and WBP because of their

importance for wildlife and their contribution to species diversity across the forest. Actively managing

against insects and disease to maintain a healthy forest is identified to ensure trees remain on the

landscape and are available as habitat as well as forest products. Whitebark pine and aspen have been

singled out as featured species that are in decline in the Northern Region of the Forest Service. Forest

health treatments are located in areas near other treatments or in stands where multiple objectives can be

met. These treatments address the Gallatin Forest Plan, the Gallatin Forest Programmatic Aspen Decision

Memo (GNF 9/2014) and the Greater Yellowstone Coordinating Committee Whitebark Pine Strategy

(2011). For more discussion about why these treatments are important review the following discussions

(DN, 5, Final EA, pp. 8-12, 41-60. I believe these are very important goals for the forest to pursue.

Wildlife Vehicle Collisions

The Selected Alternative does not include the highway clearing units for wildlife safety along US 191 that

are in alternatives 2, 3 and 4. A report from the Montana Department of Transportation (MDT) showed

that there were not an unusually high number of wildlife/vehicle collisions as compared to other “hot

spots” around the state; an important distinction. There were, however, a number of bison/vehicle

collisions in 2016 alone; numbering 16 collisions along a 7 mile stretch of Hwy. 191 north of West

Yellowstone. To begin to address the issue, representatives from Yellowstone National Park (YNP), the

Forest Service, Montana Highway Patrol and Gallatin County Commission met with MDT. A key

outcome from the meeting was agreement to implement a seasonal night time speed limit of 55 mph from

March 1 through May 31 along this stretch of US 191.


13

Stakeholders continue to have concern about the effectiveness of the highway clearing treatments,

because the Forest Service science behind the treatments was based on incident reporting and not more

rigorous monitoring. While research indicated that collisions could be reduced by clearing alone to an

extent, there was uncertainty whether the proposed thinning would increase foraging opportunities for

wildlife along the road, which could attract wildlife and negate or reduce any benefits resulting from

increased sight distances. In recognition of those concerns, I decided to drop units 33 and 34, which

included up to 138 acres of thinning. I believe the actions the stakeholder group identified to reduce

wildlife vehicle collisions move the project area toward the purpose and need for action. I am satisfied

with that effort until further studies can help to validate the effectiveness of thinning treatments for

wildlife safety.

The highway thinning units would have provided a secondary fuels benefit. The potential fuels benefit

was validated during the Maple Fire of 2016 when fuel reduction on National Forest System lands west of

the Yellowstone National Park boundary were recognized as effective fuel breaks during the suppression

effort that helped to protect the community of West Yellowstone and associated developments. Prior fuel

treatments to the south [of the project area] along the Park boundary afforded the incident management

team more options when managing the Maple Fire. The units to east of the highway thinning units will be

implemented and will create a fuel break similar to the treatments closer to West Yellowstone which were

implemented with the Hebgen Fuel Reduction Project. Comments were also received that perceived the

proposed treatments as an attempt to eliminate fire in the landscape. This is not the case. The proposed

fuels and forest health treatments are designed to alter fire behavior in areas adjacent to values at risk and

along evacuation and ingress/egress routes. Fire (and insect and disease activity) will continue to drive

succession of wildlife habitat in those areas outside treatment units where public and firefighter safety

was a primary concern.

Grizzly Bear

Grizzly bear population recovery began in the 1980’s, grew robustly in the 1990’s, and has slowed since

the early 2000’s. The slowing of population growth is believed to be a density-dependent phenomenon,

and may be indicating that grizzly bears are reaching some carrying capacity in the GYE (Interagency

Grizzly Bear Study Team 2015b). Grizzly bear demographic recovery occurred across the recovery zone

and within the Madison BMU in the context of past and ongoing actions that occurred in the BMU and

Recovery Zone (Interagency Conservation Strategy Team 2007 pg. 39). The actions included extensive

thinning, sanitation, salvage, and regeneration harvests, road building, and access management (Gallatin

National Forest Travel Plan) in the North Hebgen project area. The North Hebgen project will comply

with direction in the Conservation Strategy, which is recognized as incorporating the best and most

current science with respect to grizzly bear management. For these reasons, only minor impacts are

anticipated.

On June 22, 2017 it was announced that the Greater Yellowstone Ecosystem (GYE) population of the

grizzly bear would be removed from the Federal list of endangered and threatened wildlife. The US Fish

and Wildlife Service has determined that the population has recovered to the point where federal

protections under the Endangered Species Act can be removed and overall management can be returned to

the states (Wyoming, Montana, and Idaho). The Final Rule to remove the grizzly bear from the list will be

published in the Federal Register in the near future. The Final Rule will take effect 30 days after

publication in the Federal Register. Existing Custer Gallatin National Forest management direction for the

grizzly bear and its habitat would not change in response to delisting. While the GYE grizzly bear would

be removed from the Endangered Species List, all existing Forest Plan standards for management of

grizzly bear habitat would be retained. The Secure Habitat, Developed Site, and Livestock Allotment

standards and application rules have their basis in the Conservation Strategy for the GYE grizzly bear,

which was designed to provide for the persistence of the recovered population into the foreseeable future.


14

Delisting of the GYE grizzly bear would not change the analysis or conclusions made in the North

Hebgen Multiple Resource Project Environmental Assessment. Formal grizzly bear consultation with the

US Fish and Wildlife Service has been completed, and terms and conditions provided in the Biological

Opinion for the North Hebgen Project will be incorporated into the Final Decision Notice/Finding of No

Significant Impact. When the Rule takes effect, the procedural requirements associated with ESA are no

longer applicable but that will not change the protections or conclusions for this project.

The recent 2016 proposed delisting rule considered all of the available literature, old and new, in

examination of grizzly bear recovery. The revised Grizzly Bear Conservation Strategy was signed in

December 2016. The FWS did not substantially change the content of the Conservation Strategy from the

2007 version with regard to the secure habitat standard because those habitat protections (baseline levels

and application rules) were recognized as a primary reason why the GYA bear population has recovered.

The 2016 Strategy provides for potential future changes to the developed site standard (largely due to

concerns regarding increased visitation within Yellowstone National Park); any future changes in the

developed site standard will not be applicable to this analysis, as no changes in the current number or

capacity of developed sites will occur. The new version provides for clearer interpretation of the secure

habitat standard application rules and also recognizes and endorses that the GNF adopted the Travel Plan

baseline for the 3 subunits in need of improvement in a Forest Plan Amendment. In addition, in its ruling

on the delisting of the grizzly bear in 2009, the 9th Circuit Court ruled on November 15, 2011 that the

regulatory mechanisms in place (i.e. the Recovery Plan and subsequent Grizzly Bear Conservation

Strategy for the GYE) were adequate to provide for the persistence of the population.

My decision is consistent with Forest Plan direction (p. 84-85) and ESA (p. 83-84). The decision

responded to concerns related to grizzly bear and habitat by reducing temporary road by about 5 miles

from teh preferred alternative. Only a portion of the temporary roads included in my decision will impact

secure habitat; temporary reductions in secure habitat levels below the “baseline level” will only occur in

the Madison #2 Subunit. Those road segments are in the Tepee Creek area (associated with the fuel break

and WBP treatment area), Whits area, Fir Ridge area, Rainbow Point Campground and Rainbow Point

Road area, and the Horse Butte area

I received extensive comments questioning the analysis for grizzly bear and the current grizzly bear

direction. In November 2015 I signed a decision that amended the Gallatin Forest Plan. The “Clean up

Amendment” (USDA GNF 2015) adopted direction in the Grizzly Bear Conservation Strategy and

eliminated previous direction in the Plan. One commenter spent considerable time commenting on that

NEPA analysis, decision process and consultation process with the US Fish and Wildlife Service. The

administrative process for that decision is complete and not within the scope of this site-specific project.

My specialist appropriately redirected the responses to the North Hebgen Project analysis and

conclusions. The Clean Up Amendment Direction related to grizzly bear habitat is based on the best

science available and informed this decision. To be responsive, I provided a document on the Project

webpage, which addresses the comments related to the Clean up Amendment and the Biological Opinion

associated with the decision (2017_0301ResponsetoNECComments outside the Scope of the North

Hebgen Project). However, because that decision was a separate administrative process from the North

Hebgen NEPA process, I did not include those responses in Appendix C of the Final EA .

With regard to grizzly bear, there will be less temporary impact on secure habitat and less human

disturbance with the Selected Alternative compared to Alternative 2 due to the fact that there will be less

overall treatment and less temporary road construction. Under the Selected, there will be 0.6% and 0.3%

more secure habitat available during implementation than under Alternative 2 in the Madison #1 and

Madison #2 Subunits. The temporary reduction in secure habitat below baseline in the Madison #2

Subunit will be less under the Selected Alternative than would occur under Alternative 2. This will likely

result in less displacement of bears during implementation. The potential for negative human-bear

interactions will also be reduced under the Selected Alternative because there will be fewer acres treated


15

and less temporary road construction and use. The Selected will continue to provide for a mix of potential

bear foraging habitat in aspen, whitebark pine, and conifer-dominated stands post-harvest.

The Selected Alternative improves wildlife and human safety near Rainbow Point Campground. In 2014

the Greater Yellowstone Coordinating Committee (GYCC) ranked USFS recreation sites in the Greater

Yellowstone Ecosystem (GYE) according to their relative risk to grizzly bears (2014 GYE campground

risk and infrastructure survey). Rainbow Point Campground ranked 3rd in risk to grizzly bear of the 164

USFS recreation sites assessed for the GYE. Past human-bear interactions at the campground (leading to

grizzly bear and human mortalities) and the dense nature of vegetation in and around the campground

prompted inclusion of the area in the vicinity of the campground as a potential treatment unit. Thinning

the vegetation around the campground and reducing cover in the understory will result in reduced hiding

cover for grizzly bears and increased sight distances from the campground. This condition will, in turn,

reduce the likelihood of a surprise encounter between bears and humans. I acknowledge that people are

drawn to the campground because of the forested environment. However, the thinning treatment will

leave a forested feel while addressing the safety concern. This treatment is a high priority to reduce risk

to both grizzly bear and humans. The Forest will continue to address other risk factors (food storage, etc.)

through infrastructure improvements and education associated with this recreation site to increase the

effectiveness of the thinning treatments.

Invasive weeds

I heard from the commenters and the CGWG that they were concerned about weed spread in the project

area because of existing weed infestation. While we have designed a project with minimal risk of weed

spread, it is likely that some weed spread will occur and that is where post treatment monitoring becomes

important. I included monitoring to locate new infestations. If needed, weeds will be controlled under

the parameters of the Forest Weed Management Decision (USDA, GNF 2005). I have already started to

identify potential funding to ensure the monitoring and weed control design features are implemented as

needed. I am committed to obtaining funds to complete the necessary work. As always, we will strive to

have no net increase in weeds as a result of the project.

In the analysis, the specialist assumed that mitigation that creates a buffer around weed infestation could

not be implemented along Highway 191 units without compromising the effectiveness of treatments.

That meant that weeds would spread from the highway corridor. (Final EA, p. 15) In the Selected

Alternative, I dropped units 33 and 34 which is a benefit to controlling potential weed spread from the

highway corridor because an undisturbed corridor with more shade will remain between the highway and

the powerline clearing units. As a result, the Selected Alternative will result in less weed spread than

anticipated in the other alternatives along that corridor. The Selected Alternative includes extensive

design features to minimize impacts to invasive weeds (Final EA, A-8). The reduction of temporary road

and overall less mechanized harvest will result in less risk of weed spread due to less disturbance overall.

The additional regeneration harvest in place of intermediate harvest that is included in the Tepee Creek

drainage is low risk overall whichever type of harvest is conducted. I reviewed the analysis and

conclusions from the (Final EA, p. 82-90) and the Invasive Weeds Specialist Report (Lamont 2016) and

agree with the specialist that the level of weed infestation anticipated is not likely to reach levels that will

significantly affect biodiversity and site productivity. The project includes design features to minimize

weed spread and infestation (DN, p. 6)(Final EA, A-8 to 12). Monitoring has shown that weed treatments

are effective at containing weeds (Lamont 2015b). Our goal is to prevent new infestations resulting from

the project and all projects. For these reasons I concluded that the potential impacts to weed spread are

acceptable and effectively mitigated.


16

Scenery

During alternative development, I considered scenery concerns expressed by commenters and whether the

project is consistent with visual quality objectives in the Forest Plan. The project area is a popular

recreation destination and many people that live in the area are there for the natural amenities. Some

people would like the forest to look the same to them forever but forests are not static. They do not

remain unchanged. The Forest Plan standards for scenery allow for change, in fact they refer to the

degree of acceptable alterations from the characteristic landscape and not from the existing condition.

Further, the standards are geared to the “casual forest visitor” not professionals in the field or frequent

visitors. I believe this is a reflection of the emphasis on landscape character not day to day appearances,

honoring the fact that forests change whether we manage them or not. The action alternatives reflect a

sensitivity to potential scenery impacts, as well as the mandate/direction to manage the national forest.

The Selected Alternative includes extensive design features to minimize impacts to scenery and to

rehabilitate impacts especially in sensitive viewsheds (Final EA, A-17). The reduction of temporary road

and overall less mechanized harvest will result in fewer short term impacts to scenery due to less

disturbance overall. The additional regeneration harvest in place of intermediate harvest that is included

in the Tepee Creek drainage is consistent with modification standards for visual quality. No doubt the

short term impacts from the project will be visible to our neighbors, but as a steward of National Forest

System lands it is my responsibility to manage for multiple resources like firefighter and public safety,

preferred species composition and overall forest health identified in the Gallatin Forest Plan and agency

policy.

In order to maintain scenic integrity I am committed to implementing the design features which will be

integrated into project preparation and implementation. If additional rehabilitation is needed I have

allowed for that activity as well. Based on analysis in the Final EA (p. 91-97) and Scenery Report (Stiles

2016), I concluded that the Selected Alternative will maintain scenery consistent with FP direction. I

acknowledge that the area may look different to some. That is acceptable under our management

direction and to me as a decision maker.

Fish Species

It is expected that the project will not have negative effects to local fish populations from changes to

water temperature, stream bank stability, riparian cover and large woody debris recruitment because of

treatment unit layout and design (Final EA, p. 101, A-4 to 5). As a result, the effects analysis for

fisheries was focused on sediment delivery.

During scoping, my team identified a concern in the Little Tepee drainage related to an introduced

population of west slope cutthroat trout. Data indicated the natural instream spawning sediment levels in

Little Tepee Creek were high. Instream spawning sediment levels in Little Tepee Creek were projected to

exceed Travel Management Plan Standard (E-4) for Class A streams. To better understand the resource

condition in Little Tepee Creek, my staff completed a comparison study between Little Tepee Creek and

an unnamed tributary to Tepee Creek in the roadless area that had similar geology. The study involved

additional sediment data collection for Little Tepee Creek and the unnamed tributary, as well as macro

invertabrae collection. The habitat survey data indicated that habitat parameters along Little Tepee Creek,

especially those parameters closely related to sediment deposition, are similar or better than in the

unroaded reference reach. The monitoring indicated that existing habitat conditions along Little Tepee

Creek are not a result of past timber harvest and associated activities but rather are natural conditions.

Because of site specific knowledge of the drainage, the biologist and hydrologist concluded that the

majority of the model predicted sediment will not reach Little Tepee Creek due to various routing

obstacles. With or without the implementation of the action alternatives, the recently introduced

population of WCT will continue to increase in population size and continue to occupy the once barren

habitat upon which they were placed. (Aquatic Specialist report, Roberts 2016).


17

While the comparison study in Little Tepee was in progress, the IDT was proactive to minimize impacts

in Little Tepee Creek. First, the proposed action was altered in the Little Tepee drainage between scoping,

when this information came to light, and the formulation of Alternative 2. Units 180-187 were eliminated

or modified (Final EA, Appendix A-52). Design features are incorporated in all action alternatives (Final

EA, Appendix A, p. 4-5). The design features and mitigation measures are such that any of the action

alternatives will have minimal impacts on the existing WCT population and quality habitat will be

maintained. As a result, the project will meet the intent of the Forest travel management standard for

instream fine sediment which is to maintain quality habitat in streams.

In Red Canyon Creek, existing instream fine sediment levels are also high. I concluded that the project

will also meet the intent of Forest Travel Management standards for instream fine sediment to minimize

sediment delivery while maintaining quality habitat in Red Canyon Creek. My conclusion is based on the

facts that the project impacts are effectively mitigated (Final EA, Appendix A, p.4-5); instream fine

sediment levels are expected to increase only slightly (2.9%) along Red Canyon Creek; projected

instream sediment increases are very similar between the Selected Alternative, the other three action

alternatives and the no action alternative; few lacustrine trout use Red Canyon Creek for spawning; and,

the high level of natural sediment delivery from the upstream fault that totally masks projected project

generated sediment delivery.

Design features common to action alternatives (Final EA, Appendix A, p. 4-6) and the Selected

Alternative protect all drainages with stream buffers and other best managementpractices (BMP). The

BMP’s have been shown to be effective through monitoring (Final EA p. 153). All stream channels (both

perennial and intermittent) will be buffered from mechanized operations by at least 50’ with the exception

of those stream channels within the Little Tepee Creek analysis area which will buffer by at least 150 feet.

(Roberts 2016, p. 2) The selected alternative will result in less impact than alternative 2 and 4 due

predominately to less temporary road. The additional regeneration harvest in place of intermediate harvest

that is included in the Tepee Creek drainage incorporates the same BMPS’s for avoidance and protection

so impacts will essentially be the same in those units. I considered the aquatic and amphibian specialist

report (Roberts 2016) and the Final EA discussion (p. 98-107) in order to conclude that the project was

designed in a manner, including mitigation measures, that will result in minimal changes to habitat

suitability for either amphibians or fish. Although existing levels are higher than allowed in Little Tepee

and Red Canyon Creeks, the intent of the Travel Plan Standard is met so I am modifying the standard for

this project to allow the work to proceed in those drainages.

Temporary Roads

Temporary roads were a discussion point throughout the public involvement for this project.

Stakeholders were concerned with the amount of road, the level of closure and the related effect to grizzly

bear and the risk of invasive weed spread. I considered a range of alternatives from 0-21 miles of

temporary road evaluating the potential effects in each alternative.

The Forest has management discretion to build administrative roads. The project is designed to minimize

the need for temporary administrative roads and to minimize impact during construction and use. Further,

there are extensive requirements to fully reclaim the temporary roads. The Agency has contract language

available to incorporate reclamation directly into contractual requirements so that no additional funding

will be needed to accomplish the work. No reasonably foreseeable actions are proposed that will require

use of the proposed temporary roads in the future. The agency has experience that shows successful

reclamation and closure of temporary roads with virtually no visible long term impacts. The management

emphasis on whether to eliminate the footprint from temporary roads has changed over the years. For

North Hebgen and other current projects, management is committed to reclaiming temporary roads and

finishing the work of closing and rehabilitating legacy roads from previous decades. In response to

continued concern, in my decision I reduced the amount of temporary road needed to implement most of


18

the “preferred alternative” by approximately 5.5 miles. I provided a more thorough explanation of road

management plans and my commitment to effectively rehabilitate the temporary roads. I added a memo

to the project webpage that compiled all discussion related to temporary road management,

2016_1221TemporaryRoadManagementCompilation.

Consideration of Science

Long lists of literature cites were submitted for consideration relative to fire/fuels, climate change, water

quality-roads and wildlife. In virtually all cases the commenter did not explain the relevance of the

introduced science to this project or analysis, or what was different from the science specialists used to

support the analysis and conclusions. The comments simply stated that we needed to consider best

science. As a result, our review did not have the benefit of intended perspectives. We reviewed all science

presented and responded in Appendix C of the Final EA (VolumeII). One other document is posted on the

project webpage addressing science requests, 2016_1221CompiledResponseArtleyScienceRequest . The

“Artley” compilation is a summary of our consideration of the literature or memo or letter presented. The

response to Mr. Artley’s request is separated out from Appendix C due to the sheer number of citations

presented and general lack of a clear tie to the project or decision. The Native Ecosystems Council

(NEC) referenced best science on numerous occasions in their comment letter. No additional citations

were provided. My staff made attempts to obtain literature citations from NEC, but telephone calls and

emails went unanswered. During the objection process renewed challenges were introduced and in

response the Supplement to the Wildlife Report (Scarlett 6/17/2017) and an memo related to fire/fuels

science was developed (Jones 2017). The additional discussion provided additional perspective but did

not change the conclusion or effects related to the resources or the project.

My staff thoughtfully considered all science presented for consideration. In their analysis and conclusion

they presented the methodology and scientific basis for the various resource analyses. The conclusions

made are based on data, field review, modelling or other methods of analysis and science, some new and

some long standing, but all widely accepted in the field. I have been presented with no science that

contradicts agency findings. The Agency has implemented these or similar types of vegetation

management projects for decades. The Forest and Agency routinely monitor and study our work and

ongoing habitat conditions, which helps to validate the effectiveness and predictability of desired

outcomes. We employ experts in the field of forest and wildlife habitat management. The findings for this

project are informed by expert knowledge, valuable experience and are based on appropriate science.

Further, I have the latitude to evaluate and incorporate new information that could influence the project or

effects at any time in the future.

Best science has become the word of choice for opponents of forest management implying that any

science provided is better that the information the agency relies on. The NEPA requires that project

analysis have scientific integrity. The NFMA has no project level science requirements. As a practice,

the Agency considers all science presented during the NEPA process and when new information is

presented later on.

Other Issues

I considered several other issues that were either unaffected, mildly affected, or the effects could be

adequately mitigated for all alternatives. To reach this conclusion I relied on the assessment of these

issues in the Final EA starting on the referenced pages and the Specialist Reports referenced in the Final

EA . The following issues are discussed:


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Table 2: Other Issues/Resources unaffected, mildly affected, or the effects could be adequately mitigated.

Design Features common to action alternatives includes practices that ensure compliance with

standards or laws and to minimize impacts to an acceptable levels associated with these resources

(Final EA , Appendix A for design features)7

Air Quality (Final EA , pp. 98)

Aquatic Species (Final EA , p. 98)

(EA P. Heritage (Final EA , pp. 114)

Inventoried Roadless Area Impacts (Final EA , pp.

118)

Recreation and Special Uses (Final EA , pp. 1264)

Scenery (Final EA , p. 91)

Sensitive Plants (Final EA , pp. 132)

Soils (Final EA , pp. 135)

Transportation (Final EA , pp. 140)

Water Quality (Final EA , pp. 143)

Canada Lynx(Final EA , pp. 156)

Bald Eagle(Final EA , pp. 172)

Elk (Final EA , pp. 182)

Northern Goshawk (Final EA , pp. 192)

Bison (Final EA , pp. 199)

Migratory Bird Species (Final EA , pp. 200)

The following resources are analyzed in the EA and either the impacts are very minimal and

acceptable or the analysis is informative for the line officer as a consideration but did not result

in the need for design features or mitigation

Climate Change and Carbon Flux (Final EA , pp.

108)

Economics (Final EA , pp. 111)

Range Allotment Impacts (Final EA , pp. 125)

North American Wolverine (Final EA , pp. 167)

American Peregrine Falcon (Final EA , pp. 170)

Bighorn Sheep (Final EA , pp. 176)

Black backed Woodpecker (Final EA , pp. 177)

Flammulated Owl (Final EA , pp. 178)

Gray Wolf (Final EA , pp. 178)

Harlequin Duck (Final EA , pp. 180)

Trumpeter Swan (Final EA , pp.180)

Townsend Big Eared Bat (Final EA , pp. 180)

Pine Marten (Final EA , pp. 199)

3. Does the alternative comply with applicable laws, policy and direction?

My decision to implement the Selected Alternative is consistent with applicable laws, regulations, and

policies. I present the primary direction in this discussion. More complete listings of applicable direction

are in the EA under each resource section and in Specialist Reports for each resource area. My decision

includes one Travel Plan modification to allow project activities in Tepee Creek and Red Canyon in spite

of high existing levels of instream fine sediment, which is discussed in the Fish Species Discussion above

(p. 14) and under the Travel Plan discussion in this section. There is also discussion under “Findings

Required by Other Laws” (p. 47).

GALLATIN FOREST PLAN as amended 2015

The Gallatin Forest Plan embodies the provisions of the NFMA, its implementing regulations, and other

guiding documents. The Gallatin Forest Plan as amended (2015), hereinafter called the “Plan”,

established Forest-wide goals and standards. The Forest Plan identifies standards at two geographical

levels, Forest-wide and Management Areas (MA). Forest-wide standards, which apply to NFS land that is

administered by the Custer Gallatin National Forests are intended to supplement, not replace, national and

regional policies, standards, and guidelines found in Forest Service manual and handbooks.

7 The issues discussed earlier: Fuels, Forest Vegetation, Invasive Weeds and Grizzly Bear also have design features

common to action alternatives included to minimize impacts, but they were central to alternative development and

are discussed in more detail in earlier sections.


20

The following Gallatin Forest Plan forest wide standards provide the foundation for the purpose and need

for action and the proposed action for the North Hebgen Multiple Resource Project and move the project

area toward the goals listed in this section.

Aspen and Whitebark Pine Treatments

Forest lands and other vegetative communities such as grassland, aspen, willow, sagebrush and

whitebark pine will be managed by prescribed fire and other methods to produce and maintain the

desired vegetative condition. (FP, p. II-21)

Big game habitat will be managed to meet the forage and cover needs of big game species in

coordination with other uses. (FP, p. II-18)

The decision includes approximately 1,800 acres of treatments with a primary objective of producing and

maintaining aspen and whitebark pine on the landscape. The species were identified as a desired species

that are a priority in this landscape.

The project will have long-term beneficial effects for elk and big game forage by removing encroaching

understory and overstory conifers and increasing understory production and/or enhancing aspen

production in the project area. Cover is abundant across the EAUs and the action alternatives will have

minor effects on hiding cover.

Forest Health and Resilience:

Use fire and other management tools to help achieve vegetative size and age class diversity. (FP, p.

II-21)

Long term losses caused by insects and diseases will be reduced by integrating forest pest

management into plans. (FP, p. II-25)

Silvicultural systems will be the primary tool for pest management and will be used to improve the

diversity of tree species and the size and age of trees in various stands. (FP, p. II-25)

A number of techniques will be employed to reduce long–term losses of lodgepole pine stands to

insects, while protecting other values. This includes increasing resistance to attack by harvesting

susceptible stands to gain diversity in age and size between stands, controlling the levels of planting

and the ages of trees in even-aged stands to maintain the vigor of the stand, and changing the

composition of the forest to favor species that are not susceptible to insects. (FP, p. II-25)

The decision includes WBP, aspen and forest health treatments that implement these standards. Forest

Health, is an element of the project purpose and need and project designs and focuses on lodgepole pine

dwarf mistletoe, mountain pine beetle, Douglas-fir beetle and western spruce budworm damaging agents.

The treatments utilize silvicultural systems that increase resistance to insect and disease impacts, harvest

susceptible stands to gain diversity in age and size across the landscape, and change the composition of

the forest to favor species that are not susceptible to insects (Konen 2015, pp. 65-76).

Fuel Hazard Reduction, Snags and down woody debris:

Treatment of natural fuel accumulations to support hazard reduction and management area goals

will be continued. (FP, p. II-31)

The proposed fuel reduction treatments in the action alternatives in the North Hebgen project will begin to

address national, regional and local fire and the fuels direction in the Plan. Approximately 4,900 acres of

treatments achieve this standard.


21

Forest-wide standard E.14 requires that activity created dead and down woody debris will be

reduced to a level commensurate with risk analysis. A wildlife standard states that 15 tons per acre

will be left for nongame wildlife species. (Final EA , p. A-13).

All treatments identified in the decision address this fuel standard because activity fuels will be reduced to

15 tons per acre. Wildland fire starts in an area that have 15 t/a or less of 3 inch plus dead and down fuels

will have less fire line intensity.

Treatments that are included in the proposed action were identified to achieve standards which help to

move the project area toward the following Forest Wide goals (p. II-1, 2). A “goal” is a desired condition

to be achieved over time.

Provide for diversity of plant and animal communities based on suitability and capability of the

specific land area in order to meet overall multiple-use objectives. (p. II-1)

Provide a sustained yield of timber products and improve the productivity of timber growing lands.

(p. II-1)

Provide a fire protection and use program which is responsive to land and resource management

goals and objectives. (p. II-2)

Manage National Forest resources to prevent or reduce serious long lasting hazards from pest

organisms utilizing principles of integrated pest management. (p. II-2)

Other Forest Plan Standards

There is an exhaustive list of all other standards Forest Plan Consistency Compilation (CGNF 2017)

available on the project webpage. The standards are also summarized in the Final EA , from the

Specialist Reports. This discussion highlights the most relevant standards for the NHMRP.

Aquatic Species

The projected effects associated with sediment delivery from the Selected Alternative is less than the

effects anticipated in alternative 2 because the treatments are similar, but the decision includes 5 miles

less temporary road as compared to 2. All action alternatives will meet Forest Plan standard a-12 Habitat

for Regionally designated sensitive species on the Gallatin NF will be maintained in a suitable condition

to support these species (FP II-19) and a-14 stating that “the Forest will be managed to maintain and,

where feasible, improve fish habitat capacity to achieve cooperative goals with Montana Fish, Wildlife

and Parks and to comply with State water quality standards (FP II-20).” The effects associated with the

Selected Alternative will: 1) have minimal impacts to westslope sensitive species, and will not cause a

downward population trend staying consistent with the Forest Service’s Sensitive Species Policy; 2)

continue to allow for growth and propagation of salmonid fishes and associated aquatic life as required by

the Clean Water Act; 3) maintain the quantity, function, sustainable productivity, and distribution of

aquatic resources for increased recreational fishing opportunity by evaluating the effects of Federally

funded as required by Executive Order 12962; 4) protect all pure and slightly introgressed (90% or greater

purity) westslope cutthroat trout populations as required by Memorandum of Understanding and

Conservation Agreement (MOUCA) for Westslope Cutthroat Trout in Montana (Powell 2002); and 5)

have no measureable negative effects on populations of Management Indicator Species, because the

project was designed in a manner, including mitigation measures, that will result in minimal changes to

habitat suitability for either amphibians or fish. Forest Plan level monitoring will continue at the

programmatic level. (Roberts 2016)


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Table 3: Biological Evaluation Determination for Aquatic Species

Species Determination Rationale

Yellowstone cutthroat

trout

Northern leopard frog

No Impact The project is outside the habitat range for these species.

Western pearlshell

mussels or their beds

No Impact Nothing is being proposed that will cause occupied stream

reaches to become less stable causing harm to western

pearlshell mussels or their beds.

Western Toads MIIH* High quality habitat surrounding Hebgen Lake will

compensate for loss of individual toads and toadlets.

Plains Spadefoot MIIH Few if any individuals will be directly impacted since they

predominately come above ground on rainy periods and

operations generally cease during rainy periods to avoid

soil damage. There is a slight chance that a few

individuals might be entombed in the ground as a result of

soil compaction related to heavy equipment. It is believed

that the project impacts to plains spadefoot will be very

minimal, if any at all.

Westslope cutthroat

trout population

MIIH Little Tepee creek was recognized for excellent habitat

conditions when the introduction of WCT was completed.

There was naturally high instream fine sediment levels at

that time. The introduction has been successful. Living in

isolation without other non-native trout, abundant food,

and quality habitat will help assure the long-term

persistence of this population. I conclude that the amount

of project-generated sediment delivered, if any, will be

much lower in quantity than what was predicted by

WATSED model for Little Tepee Creek analysis area.

Design features incorporated into the decision will reduce

sediment delivery from area roads and project impacts.

Therefore, impact from the project will be minimal and

will maintain quality habitat.

* May Impact Individuals or Habitat (MIIH), but will not likely contribute to a Trend Towards Federal

Listing or Loss of Viability to the Population or Species”

Forest Vegetation and Snags

Old Growth: The Forest Plan contains a vegetation diversity and Old Growth related standard:

“Use fire and other management tools to help achieve vegetative size and age class diversity. In

part, to achieve this vegetative diversity, strive to maintain a minimum 10% old growth forest on

lands classified as forested at the mountain range scale.

Vegetation management activities will achieve vegetative size and age class diversity by regenerating

stands or thinning stands to improve vigor or promote certain species. Two mountain ranges exist in the

project area. The minimum 10% old growth forest will be maintained in the Madison Mountain Range.

In the Henry Mountain Range the existing condition is approximately 6.2% old growth and there will be

no effect because old growth stands will be avoided. Surveys were completed to ensure that no proposed

units met old growth criteria (Final EA , p. 47, A-6). The area has extensive mature forest (78.7%)

available for future old growth (EA p. 48).

Snags: The Forest Plan contains the following standards (FP, p. A-14) for snag retention.


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Standard A1a: For harvest units not scheduled for broadcast burning: During timber sale layout,

designate for leave an average of 30 snags (greater than 18 ft. in height and greater than 10 inch

DBH) per 10 acres within harvest units. If there are not sufficient dead trees meeting this size

criteria, the largest available dead trees will be left as snags.

Standard A1b: For harvest units not scheduled for broadcast burning: During timber sale layout,

designate for leave an average of 30 live snag replacement trees per 10 acres within harvest units.

For Douglas fir and Subalpine fir on rocky or shallow soils designate 60 trees per 10 acres as

replacement trees.

The North Hebgen Multiple Resource Project (NHMRP) project is consistent with these standards,

because design criteria are incorporated in the Decision (p. 8) to retain snags and snag recruitment trees

commensurate with these standards (Final EA , p. A-7).

Invasive Weeds

The applicable weed prevention activities identified in the FSM2080-Noxious Weed Management have

been incorporated into this project (p. 8, Final EA , p.A-8 to11). The treatment of weeds is consistent with

Executive Order 13112 (1999) which directs all agencies to prevent introduction of invasive species,

provide for their control, and to minimize economic, ecological, and human health impacts that invasive

species cause. With required mitigations in the Decision, all alternatives are consistent with Executive

Order 13112, The Federal Noxious Weed Act, the Montana County Noxious Weed Control Law; Forest

Service Manual (FSM) 2080- Noxious Weed Management Policy; Forest Service Northern Region Weed

Risk Assessment protocol and the 2005 Gallatin National Forest Noxious and Invasive Weeds

Management Plan EIS and the Forest Plan. The mitigation measures in this project will minimize the

spread of weeds by avoiding and treating weeds.

Scenery

Forest Plan Standard (p. II-17) - Environmental analysis and project designs for landscape

altering activities would be evaluated to determine if they are compatible with the assigned

VQOs. Landscape altering projects shall meet the assigned VQOs, or in locations where the

existing situation does not meet the VQO, shall not further degrade the visual condition. (GFP

amended 2015) A visual quality objective is “A desired level of scenic quality and diversity of

natural features based on physical and sociological characteristics of an area” and it[VQO] refers

to the degree of acceptable alterations of the “characteristic landscape.”

The EA includes evaluation of scenery impacts relative to VQO’s. The activities associated with the

Action Alternatives will meet the Forest Plan visual quality standard of retention when viewed from

Hebgen Lake and Partial Retention, when viewed from US Highway 191, 287 and the Rainbow Point

County Road. The VQO of “Modification” will be met in all other locations. These VQO’s will be met

by implementing design features incorporated in the Decision and listed in Appendix A of the EA (p. A-

17 to 21). The Selected Alternative will have similar effects to alternatives 2 and 4.

Sensitive Plants

Habitat for Regionally Designated species on the Gallatin National Forest will be maintained in a

suitable conditions to support these species (FP, p. II-19).

Suitable conditions will be maintained in the project area. Units with potential habitat for “sensitive”

plant species were surveyed in 2014 and 2015. No sensitive plants were located in treatment units except

whitebark pine (WBP). Although activity in the harvest units could damage individual WBP trees, the


24

treatments are intended to benefit WBP pine over the long term. Other sensitive plant species will not be

impacted either because they are not present or design features incorporated in the action alternatives will

avoid impact. Impact to sensitive species will be avoided or minimized in accordance with direction and

treatments will enhance WBP as directed in the Forest Plan. If any sensitive plants are found at a later

date, the site will be protected from disturbance. This is a common provision that is included in timber

contracts to require the site to be protected until a biologist determines the correct course of action (Final

EA , Appendix A-20). The decision will not have a detrimental impact on sensitive plants.

I included the findings from the Biological Evaluation for listed species that could have potential habitat

in the area. There will be NO IMPACT to the following species because suitable habitat is not present:

following species: Musk Root - Adoxa moschatellina, Short-styled Columbine - Aquilegia brevistyla,

Small Yellow Lady’s Slipper - Cypripedium parviflorum, English Sundew - Drosera anglica, Beaked

Spikerush - (Eleocharis rostellata), Giant Helleborine - Epipactis gigantean, Slender Cottongrass -

Eriophorum gracile and Alpine Meadowrue - Thalictrum alpinum. The project May Impact Individuals

or Habitat (MIIH) but action would not likely contribute to a trend towards Federal listing or cause a loss

of viability to the population or species for Large-leaved Balsamroot - Balsamorhiza macrophylla and

WBP - Pinus albicaulis. The Forest will maintain suitable conditions for these species at the Forest Scale

and the North Hebgen Project will have no impact or little impact.

Soils

The Forest Plan for the Gallatin National Forest (USFS-GNF 1987) provides only limited direct guidance

with regard to the management of soil resources.

Forest-wide Objectives B.1.i.: Water and Soils the Forest Plan states that “Watersheds will be

managed by application of best management practices…” (FP p. II-5)

Forest-wide Standards E.8.c.: Timber – Site Preparation and Activity Debris Disposal the Forest

Plan identifies the need to “maintain an adequate nutrient pool for long-term site productivity

through retention of topsoil and soil organisms. (FP p. Ii-24)

Water and Soils Forest-wide Standards ((FP p. II -26-27) indicate in

E.10.1. “The Forest Soil Survey will be incorporated into resource area analyses”,

E.10.2 “Best management practices (BMP’s) will be used…”

E.10.8. “All management practices will be designed or modified as necessary to maintain land

productivity and protect beneficial uses”.

Soil BMP’s are included in the Decision for the NHMRP and are described in the EA (p. A-22).

Maintaining an adequate nutrient pool for long-term productivity is accomplished by ensuring that topsoil

is not lost or degraded during implementation of the treatments, controlling any potential soil erosion

losses of topsoil, and through the wildlife BMP of maintaining 15 tons per acre coarse woody debris on

the ground in all treatment units with closed or partially closed canopy coverage of conifers prior to

timber harvesting.

The Soil Survey for the Gallatin National Forest was included as part of the initial soils analysis for this

project and has been substantially supplemented by field analysis of the Forest soil scientist. All

management practices in this project have been designed to maintain forest productivity and will be

modified if needed to meet the Standard of maintaining land productivity. Implementation of mitigation

to reduce detrimental soil disturbance (DSD) in areas with past harvest areas will result in a net decrease

in DSD in those areas. The project complies with the Region-wide standard (USFS-R1 1999) and as a

result, complies with the Gallatin Forest Plan and the National Forest Management Act.


25

Water Quality

Best management practices will be used on all Forest watersheds in the planning and

implementation of project activities (Forest Plan Appendix C and planning records – “Watershed

Management Guidelines for the Gallatin National Forest”) (FP, p. II-24)

All management practices will be designed or modified as necessary to maintain land productivity

and protect beneficial uses. (FP, p. II-25)

The proposed actions will employ Best Management Practices to mitigate impacts occurring to the

watershed resource from land use activities and meet State of Montana Clean Water Act requirements

which will maintain land productivity and protect beneficial uses. Therefore, the proposed project will

meet this Forest Plan standard.

A formal project implementation review process has been used on the Custer Gallatin NF since 2005 to

review implementation and effectiveness of a wide variety of projects, including vegetation management

projects such as the North Hebgen Project, and to document conclusions and recommendations for

improvement. Among items evaluated in the implementation reviews are mitigation measures and Best

Management Practices (BMP’s). The vast majority of BMP’s have been found to meet requirements and

provide effective and adequate protection of resources. In cases where application objectives or

effectiveness goals have not been fully met, improvements to BMP’s have been developed and instituted

to improve effectiveness. Implementation Review Reports are available on the Custer Gallatin NF

website at: http://www.fs.usda.gov/detail/gallatin/landmanagement/?cid=stelprdb5190912.

Require a watershed cumulative effects feasibility analysis of projects involving significant

vegetation removal, prior to including them on implementation schedules, to ensure that the project,

considered with other activities, will not increase water yields or sediment beyond acceptable

limits.

The effects analysis presented in the Water Resources Report (White 2016), which included cumulative

effects with past, present and reasonably foreseeable future activities, showed that the proposed actions

will not increase water yields or sediment beyond acceptable limits. This standard will be met because

increases in sediment and water yields associated with the project will be minor, temporary, and will fall

within acceptable limits established by the Gallatin National Forest Plan.

Wildlife:

Threatened and Endangered Species: The Forest Plan contains a Forest-wide standard that a biological

evaluation will be completed prior to implementation of activities that have potential to affect threatened

species (p. II-19). The EA and specialist report (Final Wildlife Report 6/2017) includes the required

evaluation for these species (grizzly bear and lynx). In addition, a Biological Assessment – including

pertinent information from the Final EA , was prepared for the project. There are Forest Plan amendments

specific to Canada Lynx and Grizzly Bear. There are no specific FP requirements for wolverine which is

“proposed for listing and under ESA”.

Grizzly Bear

Forest Plan Amendment 51 – Clean Up Amendment that Adopted the Grizzly Bear Conservation

Strategy

The 1993 Grizzly Bear Recovery Plan called for development of a conservation strategy to outline habitat

and population monitoring after recovery (USDI Fish and Wildlife Service 1993, pg. 16). To fulfill this

obligation, the Interagency Conservation Strategy Team was formed in 1993, and the Final Conservation

Strategy for the Grizzly Bear in the Greater Yellowstone Area (GBCS) was finalized in 2003 and updated


26

in 2007 and 2016 (USDI Fish and Wildlife Service 2007c, pg. 14873; Interagency Conservation Strategy

Team 2007 and 2016). This document was designed to provide adequate regulatory mechanisms after

delisting and ensure long-term maintenance of the recovered population (USDI Fish and Wildlife Service

2007c, pg. 14873). The GBCS is generally considered the best, most current reference with respect to

grizzly bear management. In the GNF FP Cleanup Amendment of 2015 (USDA Forest Service 2015a),

guidance included in the GBCS formally replaced and updated former FP standards relevant to grizzly

bear.

The latest revision of the Grizzly Bear Conservation Strategy was signed in December 2016. The FWS

did not substantially change the content of the Conservation Strategy from the 2007 version with regard

to the secure habitat standard because those habitat protections (baseline levels and application rules)

were recognized as a primary reason why the GYA bear population has recovered. The 2016 Strategy

provides for potential future changes to the developed site standard, largely due to concerns regarding

increased visitation within Yellowstone National Park. Any future changes in the developed site standard

will not be applicable to this analysis, as no changes in the current number or capacity of developed sites

will occur. The new version does provide for clearer interpretation of the secure habitat standard

application rules and also recognizes and endorses that the GNF adopted the Travel Plan baseline for the

3 subunits in need of improvement in a Forest Plan Amendment. This project is in compliance with all

GBCS standards adopted under the Cleanup Amendment (Final EA , p. 83-84) and direction provided by

the Gallatin National Forest Travel Plan and related consultation documents (2006 BO and 2013

Amended Incidental Take Statement).

Canada Lynx

Forest Plan Amendment 46 Northern Rockies Lynx Management Direction (NRLMD)

In March of 2007 the FS issued the NRLMD ROD (USDA Forest Service 2007d). The ROD was

amended to forest plans in the Northern Rockies, including the GNF FP, and established management

direction to conserve and promote recovery of the Canada lynx, by reducing or eliminating adverse

effects from land management activities on NFS lands, while preserving the overall multiple use direction

in existing plans. The NRLMD provides standards and guidelines to apply to lynx habitat. Although

developed in 2007, the NRLMD is consistent with more recent science that has been published regarding

lynx habitat and populations. A review of recent information and science concluded that the NRLMD is

consistent with recent information, and, thus, is applicable as a management strategy (USDA Forest

Service 2013a). The NRLMD incorporated the Terms and Conditions of the Incidental Take Statement in

the BO (USDI Fish and Wildlife Service 2007b) for the NRLMD (as explained on pp. 29-30 of the

NRLMD ROD (USDA Forest Service 2007d), and, therefore, compliance with the NRLMD ensures

compliance with the Terms and Conditions of the BO.

The Selected Alternative is in compliance with the NRLMD (Forest Plan) and Terms and Conditions of

the NRLMD Biological Opinion. To summarize, the FS is proposing to treat a total of 542 acres (59 acres

under VEG S58 + 483 acres under VEG S6) of lynx habitat that do not meet the exceptions under VEG S5

or VEG S6. All of the proposed treatments meet the definition of fuels treatment projects as defined in the

NRLMD and all are within the WUI. To date, on the Gallatin side of the Forest, a total of 2,886 acres of

treatments have been scheduled under the exemption for fuels treatment projects in the WUI. This project,

in addition to those already scheduled, will, therefore, result in a total of 3,428 acres (2,886 + 542) of

8 VEG S5 limits precommercial thinning in winter snowshoe hare habitat in the early stand initiation and stand

initiation stages, while standard VEG S6 limits all vegetation management activities that reduce winter snowshoe

hare habitat in multi-story forests


27

fuels treatments projects within the WUI that do not meet the exception criteria across the Gallatin portion

of the CGNF. Lynx habitat modeling in 2007 showed that approximately 870,000 acres of lynx habitat

were present on the Gallatin portion of the CGNF. Six percent of this 2007 total (used in the NRLMD) is

52,200 acres. The cumulative total of 3,428 acres is below 52,200 acres, and, therefore, this project is in

compliance with the requirement that fuels treatments projects within the WUI that do not meet the

exception criteria to VEG S5 and VEG S6 shall occur on no more than 6 percent of lynx habitat on the

Gallatin portion of the CGNF. (EA p. 162-165)

The Selected Alternative will result in less impact to winter snowshoe hare habitat when compared to

Alternative 2 by 38 acres. Given the size of the LAU and the amount of treatment that would occur under

both alternatives, the difference between the two alternatives in terms of changes in existing and future

lynx habitat will be indistinguishable in the long term.

Proposed Species: Proposed species on National Forest System lands are managed under the authority of

the Federal Endangered Species Act (PL 93-205, as amended) and the National Forest Management Act

(PL 94-588). Under provisions of the ESA, Federal agencies shall use their authorities to carry out

programs for the conservation of listed species, and shall ensure that any action authorized, funded, or

implemented by the agency is not likely to jeopardize the continued existence of proposed species (16

USC 1536).

North American Wolverine

The EA and Final Wildlife Report (6/2017) includes the required evaluation for the North American

wolverine. Compliance with the Programmatic Biological Assessment for North American Wolverine

(USDA 2014) is documented in the project file. There are no specific FP requirements for the “proposed”

North American wolverine.

Sensitive Terrestrial Species

The Forest Plan contains a forest-wide standard to manage essential habitat to maintain sensitive species

(p. II-18). The EA concludes that since there is no essential habitat for sensitive species within the project

area, the project is consistent with this direction. Regardless, no habitat is lost because of this project.

There will be temporary changes to some habitats and often there will be benefits.

Table 4: Sensitive Terrestrial Species Determinations from the Biological Evaluation for the Selected Alternative

Species Determination* Species Determination*

American peregrine

falcon MIIH

Gray wolf MIIH

Bald eagle MIIH Harlequin Duck NI

Bighorn sheep NI

North American

wolverine

Proposed for ESA

listing – see

wolverine analysis

for the determination

Black-backed

woodpecker MIIH

Trumpeter swan NI

Flammulated owl NI Townsend’s big-eared

bat

NI


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Notes: NI = No impact. MIIH = May impact individuals and habitat but will not lead to a trend toward

federal listing.

Big Game

The Forest Plan contains forest-wide standards for big game (p. II-18). These standards include direction

that summer and winter range will be managed to meet the forage and cover needs of big game in

coordination with other uses and to maintain at least two thirds of the hiding cover associated with key

habitat components over time.

The project will have long-term beneficial effects on elk and big game forage by reducing forested

overstory and increasing understory production and/or enhancing aspen production in the project area.

Cover is abundant across the Elk Analysis Units (EAU) and the action alternatives will have minor effects

on cover. The total amount of existing cover following implementation of the Selected Alternative will be

well above the 2/3 (67%) at 88% or more (Final Wildlife Report (6/2017) p. 123, Final EA , pp. 189-191).

Riparian areas will be protected through project design and development of mitigation measures that will

be applied during implementation. Treatments were reduced, altered, or eliminated, in many cases, to

avoid impacts to riparian areas. Riparian areas that fall within treatment boundaries will be protected with

the application of Streamside Management Zone rules, which restrict the types of activities within a

designated distance from streams, lakes, and wetlands. See Final EA , Appendix A-4 and for effects, see

White (2015) and Roberts (2015) for water quality, riparian, and aquatic habitat design features and

mitigation measures. Elk is the “indicator species” for Big Game and is therefore the focus of analysis for

this suite of species. There are no standards specific to moose in the Forest plan, however, FWP indicated

that the proposed activities would improve habitat and forage conditions and would not present a

significant negative disturbance to this [moose] species. Overall the selected alternative includes less

temporary road and less overall harvest which has short term impacts to big game, so the short term

impacts are less than in alternative 2. Design features limit potential impacts related to opening size

(Final EA , P. A-7) from additional regeneration harvest (32 acres) to mitigate the potential impact.. Short

term impacts are less overall with the selected alternative as compared to Alternative 2.

Management Indicator Species

The Forest Service is required by NFMA to “provide for diversity of plant and animal communities based

on the suitability and capability of the specific land area in order to meet overall multiple-use objectives”

[16 U.S.C. 1604(g)(3)(B)]. The 2012 Planning Rule makes it clear the intent of this direction would be

met at the planning unit scale through implementation of the Forest Plan. The Forest Service’s focus for

meeting the requirement of NFMA and its implementing regulations is on assessing habitat conditions

based on local information and knowledge, best available science, and/or habitat models to provide for

diversity of animal communities. To aid in meeting this requirement, the FP identifies MIS. MIS are

selected because their population changes are believed to indicate the effects of management activities

(USDA Forest Service 2012). There are no project level requirements or habitat threshholds for MIS as a

category. The following “Indicator” species have been identified as species groups whose habitat is most

likely to be affected by forest management activities: Grizzly Bear, Bald Eagle, Elk, Wild Trout,

Northern Goshawk and Pine Marten. There is a Forest Plan Monitoring requirement “to determine

population trends of indicator species and relationships to habitat changes. The most recent report was

published in December 2016 (Canfield 2016). The previous report was published in 2011 (Canfield

2011b). The project as designed contributes to diversity of a large suite of plant and animal communities

on the Forest through design intent and design features that minimize negative effects while providing

benefits to a variety of habitats and species.

Because the Selected Alternative will result in less overall commercial treatment and less disturbance

associated with existing and temporary roads, it is expected that the impacts on MIS, R1 Sensitive


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Species, and other species of interest will be less than those disclosed in the EA for Alternative 2. Overall,

there will be a considerable reduction in commercial harvest acres; a small increase in regeneration

harvest in the vicinity of the Tepee Creek Road. This increase in regeneration harvest acres will be

mitigated by reductions in intermediate thinning and design features that limit the size of created

openings. Intermediate harvest and regeneration harvest both affect potential elk hiding cover, goshawk

habitat, and marten habitat in the same way with regard to habitat effects disclosed in the EA. On the

ground, those site-specific locations will be more open and have less residual structure than if they were

intermediate thinned. Species that avoid openings, like the marten, will be less likely to move through

these areas. The Selected Alternative will continue to provide for connectivity of habitat by providing a

mosaic of treated stands with varying levels of structure (intermediate harvest, daylighting,

precommercial and hand thinning, etc.) and untreated stands across the planning area. Due to the

relatively low number of acres of additional regeneration harvest and the accompanying decrease in

intermediate harvest (and mechanized treatment overall) in the project area, the overall impacts to MIS

habitat, and other wildlife are expected to be less under the Selected Alternative than Alternative 2.

Compatibility with Management Area (MA9) Direction

The treatments units are primarily in MA 13 (4,103 acres) which includes all of the areas except Red

Canyon, Horse Butte, Fir Ridge and below the main road in the Whits area. About 1,085 acres of

treatment is in MA 15 which includes Horse Butte, Fir Ridge and below the Whits Lake Road. Rainbow

Point Campground area is MA 1 (77 acres) and Red Canyon is made up of MA2 (153 acres) and MA 5

(38 acres). Most of MA 7 (196 acres) is not mapped, as described in the Forest Plan. MA 1, 2, and 15 are

classified as unsuitable for timber production meaning they are not calculated in the allowable sale

quantity on the forest but harvests are programmed as needed to meet multiple use objectives other than

timber production. Only a portion of the treatments in these areas includes harvest and all treatments are

for multiple use objectives, such as aspen or fuel reduction not timber production.

MA 1-This is developed campgrounds and developed recreation. MA goals include: to maintain these

sites and facilities for the safety and enjoyment of users; to maintain developed sites to prevent

deterioration and to manage developed sites in occupied grizzly bear habitat to minimize the potential for

surprise human/grizzly bear encounters. The proposal for Rainbow Point Campground and Boat Launch

Area intends to do just this by reducing the possibility of a large die off of trees due to insect and disease

episodes. A large scale die off would make protection of improvements at Rainbow Point difficult, and

would greatly diminish the recreation experience. The treatments in this area are also intended to reduce

the risk related to wildfire to the public and firefighters and to reduce the risk of surprise grizzly

bear/human encounters, all of which help to maintain the site for the safety and enjoyment of users and

minimize the potential for negative human/grizzly bear encounters. The standards allow management to

maintain healthy and diverse vegetative pattern and to reduce safety hazards. The thinning treatment is

consistent with standards.

MA 2 – Proposed ski area. The ski proposal being considered at the time of the Forest Plan was not

developed. The standards allow timber management to maintain healthy and diverse vegetative pattern

and to reduce safety hazards. The evacuation route treatment and aspen enhancement are consistent with

the standard. The treatments included in this proposal do not preclude meeting the manage area goals

MA 5 - These areas are travel corridors that receive heavy recreation use. Areas included are portions of

the Red Canyon Road (FSR#681). Goals are to maintain and improve the wildlife habitat values and the

natural attractiveness of these areas to provide opportunities for public enjoyment and safety. The

9 A Management Area (MA) Map is available for review on the project webpage. The maps shows the units for

Alternative 2 overlaid with MA’. This representation is accurate for the Selected Alternative because the foot print

for units is essentially the same.


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purpose and need for action is designed to enhance public safety in these areas through evacuation route

treatments. Aspen treatments in these areas improve wildlife habitat consistent with the goals. Proposed

treatments as designed, are consistent with standards.

MA7 - Riparian areas goals include managing protect soil, water vegetation, fish and wildlife dependent

upon it. These areas are often narrow zones and therefore are not mapped (FP p. III-27). Best

management practices (BMP) and buffers incorporated in project design are consistent with these goals

and ensure that standards are met.

MA 13 - Forested, occupied grizzly bear habitat. These productive Forest lands are available for timber

harvest provided grizzly bear habitat objectives are met. (FP, p. III-53-58) The project is consistent with

the Grizzly Bear Conservation Strategy and provides for the protection of grizzly bear habitat. As a

result, proposed vegetation management moves the area toward this goal.

Use vegetative management practices to maintain and improve the quality and quantity of big game

forage and provide for a diversity of habitat for other wildlife species. (FP p. III-54)

The action alternatives will enhance elk forage by allowing more sunlight to penetrate to the ground,

which enhances understory vegetative growth. Effects for other big game species will be similar.

Treatments will enhance structural diversity and vegetative complexity across the landscape as discussed

in the Forest Vegetation Specialist’s Report (Konen 2015) as well as enhance aspen forest which is

beneficial to big game, as discussed earlier.

All vegetative management activities will consider maintaining or enhancing security for grizzly

bear; vegetative treatments to enhance forest habitat components by providing openings in forest

cover to increase production of browse and improving whitebark pine nut availability. (FP, p. III-

54)

These factors were considered in project design. GBCS application rules were followed for management

of grizzly bear secure habitat. Project activities were designed, in part, to enhance big game forage

opportunities (aspen enhancements) and improve whitebark pine nut availability. (Wildlife Report

updated 2017)

Maintain and enhance bald eagle foraging areas around known nest sites. (FP, p. III-54)

Hebgen Lake is the primary foraging area for bald eagles in the vicinity of the project. The project will

not have any effect on the lake or the food items provided by the lake. Areas around nest sites were

protected and habitat enhanced through project design and mitigation measures (Wildlife Report updated

2017).

Vegetation management activities shall not reduce the proportion of over-mature forest structure in

a timber compartment below 30% of the MA 13 acres within that compartment. (FP, p. III-55)

All alternatives will retain at least 30% over-mature forest structure in timber compartments when design

features are applied (Konen 2015). See Design Features Common to Action Alternatives (Final EA , p.

A-6) included in the decision to be applied in compartment 703 and the EA p. 48 for more discussion.

Actively control tree damaging agents. A natural mix of species is desirable. (FP III-56)

The NHMRP Project fuels, aspen, forest health and whitebark pine treatments are designed to actively

control tree damaging agents and to promote species diversity.

MA 15 (FP, III 64-67) Emphasizes grizzly bear habitat and dispersed recreation. Manage vegetation to

provide habitat necessary for the continued recovery of the grizzly bear.


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Grizzly bear habitat improvement, such as prescribed fire, may be scheduled where the need is

identified. Big game habitat improvement such as prescribed fire, planting, and fertilization may be

scheduled where the need is identified (FP p. III-65)

Aspen enhancements proposed on Horse Butte, Whits Lakes, the bottom of Tepee Creek Road, and the

south side of Mount Hebgen will improve foraging habitat for elk and grizzly bear(Wildlife Report

updated 2017)

The GYA Grizzly Bear Conservation Strategy will provide the basis for managing other resource

uses(FP p. III-65).

All proposed alternatives are in compliance with the GBCS (Final EA , p. 80, 81 and 206).

Forest Plan Consistency Summary

My decision complies with all Forest Plan standards and moves the area toward previously discussed

Forest Plan goals. Forest Plan objectives for wildlife will be met consistent with goals and standards

achieved. Objectives for fish will be met with the habitat protections included in the decision. Timber

objectives will be met because timber harvest will achieve vegetation management activities and

emphasis will be placed on lodgepole pine stands susceptible to mountain pine beetle. The standards

discussed in this Decision are not an exhaustive list. Standards and guidelines established in the Forest

Plan that are pertinent to the various resources potentially affected by the alternatives are described in

more detail in the Final EA , the specialist reports and in 2017ForestPlanConsistencyCompilation. These

documents are available on the Project Webpage.

All required interagency review and coordination has been accomplished; new or revised measures

resulting from this review have been incorporated. There is documentation in the record showing

coordination with other agencies such as the US Fish and Wildlife Service, Montana State Historic

Preservation Officer, Montana Department of Fish, Wildlife and Parks and Montana Department of

Environmental Quality (EA p. 207).

GALLATIN TRAVEL PLAN (2006)

No additional system roads will be constructed as part of this project. Proposed temporary roads will be

constructed and used for the life of the project and will be restored to surrounding area vegetation

management objectives as part of the project closeout and not added to the Forest road system. As

proposed in all action alternatives, the temporary roads to be constructed will be built to the minimum

standard needed to implement the alternatives. Use of the temporary road will be limited to

administrative use for as long as needed during project implementation then obliterated as needed. The

need for temporary roads and restoration plans are discussed in the description of the alternatives and

design features common to the action alternatives. These factors are consistent with Goals objectives and

standards in Section C and D (GNF, 2006, pp. I-10-11).

The project is consistent with relevant Travel Management Plan standards for Water, Fisheries and

Aquatic Life as well as Wildlife, direction established under sections E and H (GNF 2006, p. I-12 to 14).

The project is also consistent with the 2006 Travel Plan Biological Opinion and 2013 Amended Incidental

Take Statement for the Travel Plan (Scarlett Memo 2017). My decision includes one site specific

modification of the Gallatin Travel Plan Decision (2007) which is addressed in the issues discussion (p.

14 and Final EA , p. 98-108) The modification allows treatments in Little Tepee Creek and Red Canyon

Creeks even though the instream fine sediment standard is exceeded (GNF 2006, p. I-12). The annual

sediment delivery standards will not be exceeded, only the fine substrate sediment level (Standard E-4, p.

I-12). The goal of the standard is to manage a road and trail system that fully supports the protection of

water quality and habitat for fish, riparian dependent species and other aquatic organisms (GNF 2006, p.


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I-11). The current habitat in Little Tepee is very good and the anticipated fine sediment increases will

ensure protection of fish habitat. In Red Canyon, the high sediment levels are mostly attributed to the

earthquake fault in the upper reaches. In both cases the existing erosive geology results in high existing

fine sediment. The project as designed minimizes sediment additions effectively and water quality and

habitat are protected, which is the intent of the numeric standard. This new information about the

baseline conditions of these streams combined with the potential effects from the project are within the

scope and range of effects considered in the original analysis for the Travel Plan and is consistent with

intent. Therefore a correction or revision of the Travel Plan Decision is not needed.

The proposal is consistent with the direction in the Gallatin National Forest Travel Plan Management Plan

related to recreation. Groomed snowmobile routes will remain open or accessible to the public and

outfitters. Other goals, standards and guidelines are not relevant to this project.

2001 ROADLESS AREA CONSERVATION - Final, RULE, 36 CFR 294

The 2001 Roadless Rule prohibits road construction, road reconstruction and timber cutting, sale and

removal in inventoried roadless areas (IRA) with some exceptions. The NHMRP Project is consistent

with the 2001 Roadless Rule because no road construction is proposed in the IRA and tree cutting is

consistent with the exception categories (EA p.124-125). Approximately 71 acres of tree cutting is

authorized in the decision: 39 acres includes hand cutting of trees and 32 acres includes mechanized

harvest immediately adjacent to Forest System Roads.

The Selected Alternative focuses treatments on generally small diameter timber with residual stand

diameter increasing post treatment. No road construction is proposed in the IRA. The treatments

proposed in the IRA will improve and maintain threatened and endangered species habitat by enhancing

aspen which will improve grizzly bear foraging opportunity. Units 121, 135, 136, 150 and 151 will

maintain desired characteristics of ecosystem structure and function by reducing wildfire effects in

evacuation routes. Over time, wildfires will continue. It is likely that with treatments in lodgepole pine

and mixed conifer forest will mimic understory or mixed severity burns rather than the stand replacement

burns. While stand replacement is typical in these forest types, it is also common to have fires that reduce

surface and understory fuels through surface and mixed severity fire. This is particularly true in Douglas

fir and mixed conifer stands where aspen are present. Several roadless area characteristics will be

maintained or improved. High quality soil, water and air will be maintained (Keck, 2016, White 2016

and Dzomba 2015). Habitat for threatened and endangered species will be maintained or improved (Final

Wildlife Report Updated 6/2017 2016). A diversity of plant and animal communities will be maintained

(Konen 2015, Final Wildlife Report Updated 6/2017 2016, Lamont 2015b)(Roberts 2016). Traditional

cultural properties will be maintained (LaPoint 2015, LaPoint memo2016).

The treatments adhere to exception categories i and ii that allow tree cutting in the IRA(36 CFR

294.13(b)(1)(i, ii)) . One or more roadless characteristics will be maintained or improved. For these

reasons, the project is consistent with the Roadless Area Conservation Rule (i.d.).

BALD AND GOLDEN EAGLE PROTECTION ACT (16 U.S.C. 668)

The Montana Bald Eagle Management Guidelines (Montana Bald Eagle Working Group 2010) was

prepared in cooperation with the Montana Bald Eagle Working Group to address federal bald eagle

regulations that were put in place after the bald eagle was delisted from the threatened and endangered

species list. Montana Bald Eagle Working Group (2010) recommends the use of visual and spatial buffers

around nests, foraging, and roost sites to minimize disturbance to bald eagles. Disturbance buffers

recommended by Montana Bald Eagle Working Group (2010) were incorporated into project design to

minimize the potential for a violation of the BGEPA which prohibits activities that disrupt breeding,

feeding, sheltering, and roosting behavior or that causes or is likely to cause nest abandonment or reduced

productivity. The EA considers the effects of the project on eagles, which are discussed as a sensitive


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species. Design features are included in the Decision that ensure the Forest Plan guidance that provides

additional protection was met (Final EA , Appendix A, p. 32).

FEDERAL CAVE RESOURCES PROTECTION ACT

This Act is to secure, protect, preserve and maintain significant caves to the extent practical. Site features

and field review substantiate that no caves are in the area. No known cave resources will be affected by

this proposal.

FEDERAL CLEAN AIR ACT (CAA)

Anticipated emission will be consistent with Clean Air Act (CAA) standards and visibility impacts will be

limited to nuisance levels within .5 miles. Design features are included to ensure coordination and

adequate dispersion (Final EA , A-1).The Custer Gallatin National Forest will cooperate with the Montana

Department of Environmental Quality (MTDEQ) Air Quality Bureau and meet the requirements of the

Montana State Implementation Plan. The Environmental Protection Agency (EPA) has delegated CAA

compliance authority to the state of Montana, under the auspices of MTDEQ. Thus, compliance with

state environmental laws and regulations also satisfies compliance with the federal CAA and local Forest

Plan requirements tied to the SIP and CAA. The CAA and associated regulations were developed to

ensure protection of public health and safety.

FEDERAL CLEAN WATER ACT (CWA)

The State of Montana maintains primacy with respect to water quality standards and pollutant discharge

management programs. This primacy status requires that the provisions of the State of Montana Water

Quality Act meet or exceed all requirements of the Federal Clean Water Act.

The project will meet State of Montana Clean Water Act requirements to protect, maintain, and improve

the quality of water for beneficial uses for the following reasons and therefore the Clean Water Act

requirements.

Best Management Practices (BMP’s) will be applied.

The Administrative Rules of Montana (ARM 16.20.603) stipulates that "land management activities must

not generate pollutants in excess of those that are naturally occurring", regardless of the stream's

classification. "Naturally occurring" is defined in the ARM as "conditions or material present from runoff

or percolation over which man has no control or from developed lands where all reasonable land, soil, and

water conservation practices have been applied." The ARM 16.20.603(21) defines "reasonable land, soil,

and water conservation practices" as "methods, measures, or practices that protect present and reasonably

anticipated beneficial uses.” These practices include effective Best Management Practices (BMP’s)

employed to protect beneficial uses. All of the proposed alternatives require implementation of effective

BMP’s throughout the project area.

One water body within the assessment area has been designated as water quality Category 5, and thus is

considered an impaired water body and appears on the 2016 303(d) list: Red Canyon Creek from

headwaters to mouth (waterbody MT41F006_020) (MDEQ, 2016c). The listed probable causes for

impairment on this 6-mile long stream are “sediment/siltation,” “physical substrate habitat alterations, and

“alterations in stream-side or littoral vegetative covers” (MDEQ, 2016a). Sources are listed as “grazing

in riparian or shoreline zones,” “natural sources,” and “silviculture activities.” The MDEQ concluded

that the beneficial uses associated with agricultural use and drinking water are fully supported while those

associated with aquatic life and recreation are not fully supported (MDEQ, 2016a). TMDL guidelines

have not yet been developed for Red Canyon Creek. The MDEQ has assigned a TMDL development

status of “in progress” and TMDL priority of “high” to Red Canyon Creek (MDEQ, 2014b).


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Although TMDL development for Red Canyon Creek has not been completed, the Montana Code

Annotated – 2007 75-5-703 Section (10)(c) specifies that “pending completion of a TMDL on a water

body listed pursuant to 75-5-303 new or expanded non-point source activities affecting a listed water

body may commence and continue if those activities are conducted in accordance with reasonable land,

soil, and water conservation practices.” This provision will allow for the project activities to commence

and continue prior to the completion of Red Canyon Creek TMDL since reasonable land, soil, and water

conservation practices (in the form of project BMP’s and project mitigation measures) will be applied. If

the Red Canyon TMDL is finalized prior to implementation, additional sediment analysis and

consultation with MDEQ will be carried out as necessary to ensure compliance with the TMDL.

Custer Gallatin Forest BMP’s are consistently monitored for effectiveness, and improvements are

instituted as needed.

A formal project implementation review process has been used on the Custer Gallatin NF since 2005 to

review implementation and effectiveness of a wide variety of projects, including vegetation management

projects such as the North Hebgen Project, and to document conclusions and recommendations for

improvement. Among items evaluated in the implementation reviews are mitigation measures and Best

Management Practices (BMP’s). In general, rating of the application and effectiveness of BMP’s has

shown them to be very effective. The vast majority of BMP’s have been found to meet requirements and

provide effective and adequate protection of resources. In cases where application objectives or

effectiveness goals have not been fully met, improvements to BMP’s have been developed and instituted

to improve effectiveness. Implementation Review Reports are available on the Custer Gallatin NF

website at: http://www.fs.usda.gov/detail/gallatin/landmanagement/?cid=stelprdb5190912

State and Federal Permit Requirements

The project will be consistent with permitting requirements because all required water quality permits will

be acquired by the Gallatin NF prior to any ground disturbance activities for the proposed action

including 124 permits and Nationwide 404 permit compliance validations for stream crossings. At this

time, there has been no activity identified which will require these permits.

Executive Order 11990 – Protection of Wetlands

Under E.O. 11990, all federal agencies must take action to minimize the destruction, loss or degradation

of wetlands. The Selected Action complies with EO 11990 to minimize the destruction, loss, or

degradation of wetlands. Design/mitigation measures provide that vehicles and logging machinery will

not be operated within wetlands, and materials will not be deposited in stream or wetlands

Executive ORDER 11988 – Floodplain Management

Executive Order 11988 requires federal agencies to avoid to the extent possible the long and short-term

adverse impacts associated with the occupancy and modification of flood plains and to avoid direct and

indirect support of floodplain development wherever there is a practicable alternative.

The NHMRP will adhere to MT Streamside Protection Zones with respect to work that may occur in

riparian areas. Additionally, the project includes a mitigation measure that prohibits cutting of trees

within 15 feet of the ordinary high water mark along any Class 1 or Class 2 (DNRC 2006) stream

segment within any treatment unit. Compliance with MT SMZ and the aquatic mitigation measures will

ensure protection of floodplain values and functions.

FEDERAL LAND FUELS POLICY

Nationally, protection of human life, take positive action to ensure compliance with established safe

firefighting practices and address hazardous fuel build-ups around communities at risk are key messages

http://www.fs.usda.gov/detail/gallatin/landmanagement/?cid=stelprdb5190912


35

(1995 Federal Wildland Fire Management Policy / National Fire Plan). Local direction from the Gallatin

County CWPP and Gallatin NF Plan and Fire Plan provide the following goals and objectives: protect life

and human safety, prevent or limit loss of property and restore and preserve our ecology, provide safe

working area and access for emergency responders, coordinate land and resource management efforts

with other Federal, State, local agencies and private landowners, treatment of natural fuels accumulations

to support hazard reduction. The proposed fuel reduction treatments in the selected alternative in the

North Hebgen project will begin to address national, regional and local fire and fuels direction.

MIGRATORY BIRD TREATY ACT (16 U.S.C. 703-712)

Under the Migratory Bird Treaty Act (MBTA), which implements various treaties and conventions for the

protection of migratory birds, it is unlawful to take, kill or possess any migratory birds, except as

regulated by authorized programs. Executive Order (E.O.) 13186 is associated with the MBTA and

requires agencies to ensure that environmental analyses evaluate the effects of federal actions and agency

plans on migratory birds, with emphasis on Species of Concern (SOC). The EA (p. 202-204) evaluated

the effects of the project on migratory birds. Project activities have the potential to affect migratory birds

by altering habitat and displacing birds through disturbance. In areas where activities are ongoing,

breeding birds may avoid or abandon habitats to avoid human activities and disturbance. While individual

birds, breeding pairs or family groups might be affected, these effects (positive or negative) will be too

minor to have impacts to any species at the population level due to the size of the affected area and the

availability of habitat for these species in the vicinity of affected areas. Treatment activities will promote

a mosaic of structural stages and stand compositions in affected areas following treatment. Project design

criteria will be implemented that will potentially reduce impacts by altering the season of the proposed

activities (winter harvest versus summer implementation for a portion of the area), protecting known, long

term breeding sites for some species, and retaining dead standing wood for wildlife and other ecosystem

functions. The Selected Alternative will result in less overall commercial treatment and less disturbance

associated with existing and temporary roads, and as a result it is expected that the impacts to migratory

birds will be less than those disclosed in the EA for Alternative 2. Due to the relatively low number of

acres of additional regeneration harvest and the accompanying decrease in intermediate harvest (and

mechanized treatment overall) in the project area, the overall impacts to migratory birds is expected to be

less under the Selected Alternative than Alternative 2.

NATIONAL ENVIRONMENTAL POLICY ACT (NEPA)

The provisions of the National Environmental Policy Act (NEPA) have been followed as required under

40 CFR 1500-1508. This Decision Notice, FONSI and EA comply with the intent and requirements of the

NEPA. Alternatives in the EA were developed and analyzed under full public disclosure. This Decision

Notice discusses the decision and the reasons for making the decision. I determined that the Selected

Alternative will not result in significant impacts beginning on page 40. Therefore, preparation of an

Environmental Assessment (EA) and Finding of No Significant Impacts (FONSI) is consistent with the

NEPA regulations.

Scoping was conducted to determine issues and concerns but also to determine issues that will be

analyzed in depth. The NEPA provides for the identification and elimination from detailed study those

issues which are not significant or have been covered by prior environmental review thus narrowing the

discussion of those issues to brief statements as to why they will not have a significant effect on the

human environment or by providing reference to their coverage. 40 CFR 1501.7(3). The North Hebgen

EA presents five issues that were used in alternative development to resolve conflicts concerning

alternative uses of available resources. It was these issues that became the focus of interdisciplinary

interaction and alternative development. There were several issues of interest and all issues were

mitigated effectively or were not affected by the proposal (EA). The EA was available for comment for


36

30 days in June 2016. The interdisciplinary team responded to comments, updated the EA and

contributed to the draft FONSI in March 2017.

As a reminder, an EA 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

FONSI (40 CFR 1508.9). The EA may discuss the direct, indirect, and cumulative impact(s) of the

proposed action and any alternatives together in a comparative description or describe the impacts of each

alternative separately and may incorporate by reference data, inventories, other information and analyses

(40 CFR 1508).

I received comments that the environmental assessment was too long and therefore, difficult to

understand. I agree, the documentation is extensive. Interestingly, the comments came from some of the

same individuals that submitted 10-40 page comment letters asking for more explanation, data, maps,

science consideration and consideration of issues that were not relevant to the proposal. As is the intent,

the EA is focused on whether there will be significant impacts from the proposal and whether preparation

of a finding of no significant impact or EIS is appropriate. In an effort to be responsive to the public and

address concerns, my staff invested additional effort to address all comments received whether relevant to

the FONSI or not. The project record and Volume II, Appendix C are voluminous and they demonstrate

the analysis and consideration that was given to, not only the relevant resource issues and their level of

impact, but to these other concerns and requests for information. Some individuals would prefer that all of

this supporting information is part of the EA but that is not true to the regulatory requirements for an EA.

Based on the EA and project record I made a finding of no significant impact. I am confident that there

will be no significant impacts so an environmental impact statement is not necessary. I am also confident

that the selected alternative as designed, is completely lawful. The record provides considerably more

information than is needed for these determination. However, I considered all of the information, then

incorporated changes to the selected alternative. I believe that for this project, the NEPA disclosure and

supporting information are a more than reasonable balance in meeting the intent of and conflicting

demands between agency mission, regulatory requirements, level of analysis needed to be certain about

impacts from my decision and the difficult balance in finding a middle ground between supporters of

forest management and staunch opponents.

NATIONAL HISTORIC PRESERVATION ACT

The National Historic Preservation Act (NHPA) and its implementing regulations require Federal

Agencies to consider the effects of their undertakings on historic properties. Effects to “cultural resources

of traditional religious and cultural importance” must be considered under the NHPA. In carrying out the

responsibilities under Section 106 of the NHPA, the Forest Service is required to consult with any tribe

that attaches religious and cultural significance to such properties when any federal undertaking may

affect them {16 USC 470a(d)(6)(A)}. The North Hebgen Project Area lies within traditional Crow and

Shoshone-Bannock Indian territories, as defined by the Ft. Laramie Treaties, and the Ft. Bridger Treaties.

The CGNF designed the Wildland Urban Interface and Large Scale Hazardous Fuels Reduction Site

Identification Strategy (SIS) to address the effects that large scale, landscape level hazardous fuel

reduction projects may have on cultural resources and identify measures to reduce or eliminate those

effects. The SIS was approved as part of the programmatic agreement between the USDA-Forest

Service-Northern Region, the Advisory Council on Historic Preservation and the Montana State Historic

Preservation Officer (MT SHPO). The SIS protocol is followed for this project in compliance with the

NHPA. As designed, the project will have no adverse impacts on cultural resources. The Forest Service

received clearance from the MT. SHPO in June 2017 (SHPO, 2017).

Tribal Consulation


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No properties with religious or cultural significance will be affected by the project. The agency met

consultation requirements with tribes that attach religious and cultural significance to properties in the

area, in this case the Crow and Shoshone Bannock. The Shosone Bannock, Crow and several other tribes

received all notices related to the project. The Interagency Bison Management Committee has been

briefed regularly on this project since the early project development stage. The IBMC includes several

tribal interests. The Forest Archeologist (Pablo 2013) discussed the project in coordination meetings with

tribes. No comments were received or interest expressed from the affected tribes. The Forest routinely

coordinates with Tribal interests about work on the Forest, in cluding this project.

As a result, the project is consistent with federal laws including the National Historic Preservation Act

(NHPA), the Archeological Resources Protection Act (ARPA), the American Indian Religious Freedom

Act (AIRFA), and the Native American Graves Protection and Repatriation Act (NAGPRA). Sacred and

culturally important places fall under this purview of the NHPA, AIRFA, and the Sacred Lands Executive

Order (Executive Order 13007). Native American graves are protected under NAGPRA. My decision

does not affect treaty rights.

SUMMARY

In making my decision I considered the purpose and need for action and the importance of moving the

area toward the desired condition identified in the Forest Plan, in national policy and other documents

discussed in the analysis. I understand that there is some mistrust about our motives for introducing

vegetation management in this area. Agency direction could not be more clear about the importance of

and intent to manage fuels in the wildland urban interface for firefighter and public safety, to manage for

forest health and resilience, and to manage for species that are important on the landscape, in this case

aspen and whitebark pine. The North Hebgen Multiple Resource Project capitalizes on an opportunity to

achieve management goals and standards for multiple resources, which is also an emphasis in the agency.

A few commenters questioned the effectiveness of design features and mitigation included in my decision

to minimize adverse effects. Standards and guidelines that are applied relative to wildlife, water quality,

forest vegetation and all other resources have been established based on experience and /or science. The

Forest Service has been implementing vegetation management practices for decades. Much has been

learned over time about minimizing effects and achieving vegetation goals. The Gallatin Forest has an

implementation monitoring program in place to evaluate and improve our projects and management.

Those lessons learned are incorporated in project design. There is also extensive monitoring built into

project implementation to ensure the project is designed, and implemented as intended and that we

continue to learn (Final EA Appendix A).

The project, as designed is consistent with all applicable direction, such as the Forest Plan and Best

Management Practices. I considered the potential effects from the activities associated with my decision.

I am confident that the project, as designed, will minimize negative effects and achieve intended purpose

and need. The project encompasses a large area which was a concern for some commenters, but the

interdisciplinary team (IDT) conducted extensive analysis to carefully evaluate potential effects. Based

on that analysis, I determined that there will be no significant effects. I acknowledge there will be short

term minor negative effects. I believe the benefits of the management actions will far outweigh the

negative effects.

My staff worked closely with the Custer Gallatin Working Group (CGWG) to collaborate on project

design and to address their concerns, as well as the interests of the public and other commenters. The

CGWG represents 24 interests in their working group and the collaborative meetings were open to anyone

who wanted to be involved. Working with the public and members of the Collaborative helped to make

for a better and more widely accepted project. I received only 18 comment letters on the Draft EA

(6/2016) both support and opposition versus 52 during the scoping comment period, indicating to me that


38

most of the concerns raised during scoping were addressed. My staff spent months responding to

comments and those responses are included in Volume II, Appendix C of the Final EA . The comments

influenced my decision to modify alternative 2 in the decision.

I understand that some people oppose management on NFS lands or activity near their favorite places but

“no action” does not assure status quo. The Forest is a dynamic environment with natural disturbance

processes always in motion. Additionally, the Forest Service is a multiple use agency with a multitude of

management goals, objectives, standards and laws that have competing interests. The project location in

the Greater Yellowstone Area and near Yellowstone National Park warranted thoughtful consideration of

the larger landscape. As a land manger on national forest system lands I have a different mission that

allows me to use different types of management activities to help make positive changes to the landscape.

These changes have positive outcomes for protection of Yellowstone National Park resources, as was seen

during the Maple Fire of 2016. I believe that the North Hebgen project presents a similar opportunity.

On balance, having given consideration to all of the practical and passionate concerns, comments and

potential benefits, I believe that the North Hebgen Multiple Resource Project will move these landscapes

toward long term goals, minimize negative effects, is consistent with direction and applicable laws, is

responsive to public input and represents a well-reasoned decision.

IV. Alternatives Considered In addition to the Selected Alternative, I considered three other action alternatives (Final EA , p. 15-30).

The Final EA includes a more complete description of the Alternatives. The resource analysis in the

Final EA compares the effects from the alternatives for all issues [Final EA , pages 33-209]. For

information, Appendix A includes a comparison of Alternatives, including the Selected Alternative.

Alternative 1 No Action

Under the No Action alternative, current management plans would continue to guide management of the

project area. The proposed action would not occur under this alternative. The processes of vegetation

succession and forest insect dynamics would continue without management intervention. Ongoing uses

would continue such as firewood gathering, Christmas tree cutting, recreation, road and trail use,

permitted uses, wildfire suppression consistent with Gallatin Forest Plan direction. Not implementing the

proposed treatments and associated activities would forgo the benefits of implementing fighter and public

safety mandates, forest vegetation /forest health improvement, aspen and whitebark pine enhancement

and wildlife safety objectives near Rainbow Point Campground.

Alternative 2 – Proposed Action

Alternative 2 - The proposed action alternative was designed to meet the purpose and need for action

which would implement standards and move the project area toward goals in the Gallatin Forest Plan and

address national fire/fuels policy priorities. A more complete description of this alternative, including

maps is in the Final EA on pages 16-20. This alternative meets the purpose and need most effectively

and has the most temporary road. While the impacts from temporary roads would be mitigated through

project design features, this issue remains a concern expressed by commenters and the Custer Gallatin

Collaborative Working Group. The Selected Alternative achieves nearly the same amount of treatment

with 5.5 fewer miles of temporary road, and as a result fewer impacts.

Alternative 3

This alternative was designed to address the purpose and need and to minimize concerns related to

impacts from temporary roads. Elimination of nine miles of temporary road and the units associated with

them would:


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Reduce impacts to grizzly bear secure habitat in Madison 2 Bear Management Subunit;

Reduce impacts to risk of invasive weed spread;

Reduce effects of displacement of wildlife in high use areas and migration routes;

Reduce impacts from changes to sense of place related to the recreation experience and scenery

impacts near Horse Butte, Rainbow Point Campground and Fir Ridge.

A more complete description of this alternative, including maps is in the Final EA on pages 21-24. This

alternative meets the purpose and need least effectively as discussed on pages 7-10. Alternative 3 does

not address firefighter and public safety objectives or achieve fuel reduction near “values at risk” near

Horse Butte or Rainbow Point Campground. Firefighter and public safety is one of the most compelling

mandates I am balancing given the national emphasis and risk to life and property that we have identified.

Alternatives 3 includes only 37% (or 460 fewer acres) of the aspen treatments as compared to the

Selected Alternative, which to me would be a missed opportunity and is very undesirable at a time when

aspen enhancement is a Forest, and regional priority due to the loss of aspen across the landscape.

Alternative 4

Alternative 4 was designed to minimize concerns related to impacts from temporary roads, while at the

same time providing an option that achieves purpose and need related to fire fighter and public safety and

aspen enhancement more effectively than Alternative 3. Changes in Alternative 4, including the

elimination of 4 miles of temporary road compared to Alternative 2 would:

Reduce impacts to grizzly bear secure habitat in Madison 2 Bear Management Subunit;

Reduce risk of invasive weed spread;

Reduce displacement of wildlife in high use areas and migration routes;

Reduce impacts from changes to sense of place related to the recreation experience and scenery

impacts near Horse Butte, Rainbow Point Campground and Fir Ridge;

Improve fire fighter and public safety compared to Alternative 3;

Reduce conifer competition in more aspen forest than Alternative 3.

A more complete description of this alternative, including maps is in the Final EA on pages 25-28. This

alternative meets the purpose and need almost as effectively as Alternative 2 but still includes less aspen

treatment (< 270 acres) in an effort to reduce temporary road needs. The Selected Alternative includes all

but 49 acres of the aspen treatment lost in this alternative and incudes fewer temporary roads.

Alternatives Considered but not Studied in Detail10

Scoping Alternative

During the scoping timeframe, preliminary analysis by specialists and public comments daylighted some

flaws. As a result, several changes were made to the “Scoping Alternative” to improve consistency with

Forest Plan direction and intent, increase overall efficiency and effectiveness while reflecting sensitivity

to valuable wildlife habitat along the lakeshore and Cougar Creek. Issues addressed from the changes

included potential impacts to westslope cut throat trout (WCT) habitat in Little Tepee Creek;

inconsistencies with current Lynx Direction (NRLMD 2007) related to a prescribed burn proposal;

increased protection for the riparian and wildlife travel corridor near the lakeshore; modifications to more

effectively contain invasive weeds, reduced visual impacts and designs to meet the intent of the Roadless

10 These alternatives are discussed in more detail in the EA on pages 29-31


40

Rule (2001). Temporary roads were evaluated and about four miles were eliminated. The proposed action

was reduced from about 8,200 acres to 5,900 acres and from 25 miles to 21 miles of temporary road. A

summary of these changes is documented in Appendix A, p. 52. The scoping alternative was then

eliminated from detailed study. Alternative 2, the proposed action reflects changes from the scoping

alternative and the new “starting point” for alternative consideration.

Helicopter Alternative

The agency received a request to consider an alternative that eliminated all temporary roads by requiring

only helicopter logging for the proposed units. In summary, electing all helicopter harvest in order to

avoid temporary roads does not eliminate the impacts from temporary roads because some roads would

still be needed to access landings. Helicopter logging is not as effective at achieving fuel reduction

because of the high costs and technical difficulty associated with effectively treating activity slash in

helicopter units. A helicopter logging operation and associated fuel treatment costs would incur

considerable expense for the taxpayer, in excess of $6.6 million while ground based harvest would

provide an estimated $708,000 in receipts.

With mitigation and design features that have been identified for this project, ground based harvest and

associated temporary road effectively achieves the treatment needs, mitigates potential impacts from

temporary roads, adheres to Forest and Travel Plan standards and is consistent with other direction, such

as state laws. In addition, the value of the wood product generally covers the cost to implement the unit

work without additional appropriated dollars when implemented using ground based harvest methods.

Because the project can be implemented without incurring excessive helicopter costs, it is undesirable to

incur the costs of helicopter logging to avoid temporary road construction (Seth Memo 12/2015). In

addition to being an acceptable activity on National Forest System lands, monitoring has shown that the

undesirable impacts associated with temporary roads are indeed temporary and can be effectively

mitigated (Lamont 2015c). For these reasons, a helicopter alternative was eliminated from detailed study.

Other Alternative requests11

The Forest Service (FS) received a request to consider a speed limit reduction to reduce wildlife vehicle

collisions (WVC) along 191 rather than implement the proposed thinning treatment. The commenters

also recommended additional signage, wildlife crossings with funnel fencing, and modification of the

highway design itself.” The FS did not analyze this alternative in detail because we lack jurisdiction but

instead joined forces with agencies such as MDT to address this issue independent of the North Hebgen

Project and in the decision, eliminated the highway thinning units (see page 5-7, Appendix A).

We received a request to consider prescribed burning on the south facing slopes from Johnson Lake

Trail to Red Canyon, the south facing slopes of Mount Hebgen and the south facing slopes of Horse

Butte. The interdisciplinary team considered this request early in the planning process and determined

that aspen are doing well in these areas and burning would set the aspen back rather than speed up

regeneration and there is not enough fuel on the ground to carry a prescribed burn in some areas. This

alternative was not studied in detail because prescribed burning was determined to be ineffective at

achieving the intended goal.

We received a request to remove dead trees only and to let locals do the harvesting for their personal

use. This tool is limited in effectiveness and would not meet the purpose and need for action. Firewood

removal by locals would not address excessive surface, ladder or crown fuels that are at issue in fuel

reduction treatments near homes, improvements, powerlines, evacuation routes and the Tepee Creek

Road. Further, firewood removal would not meet the objectives for aspen, whitebark pine or reducing

undesirable wildlife encounters along Highway 191 and near the campground. Consequently, firewood


41

removal is included as an associated activity that could help to achieve the desired future condition and to

accommodate firewood access requests. For these reasons, this alternative was not considered in detail

but was incorporated in all action alternatives as a tool.

Commenters wanted consideration of an alternative that limits treatments to those needed to reduce home

ignition per Cohen, 1999 and consideration of treatment only within 100 feet of structures. Cohen, 1999

considers only radiant heat to propagate home ignition. Cohen, 1999 is not consistent with the purpose

and need of this project in that his recommendations only address structure protection and the ‘home

ignition zone’ and discourages community fuel management protection objectives and firefighter and

public safety. The North Hebgen Multiple Resource Project includes more objectives than reducing

wildfire risk to homes. There are other values besides homes that are at risk, such as powerlines,

evacuation routes and Forest Service improvements (infrastructure). The other purposes for the project

would not be met including, enhancement of aspen and whitebark pine, evacuation route safety, ability to

contain or compartmentalize a wildfire from the Tepee Creek Road or reducing the risk of undesirable

wildlife/human encounters. Although fuel reduction near homes is an important part of the action

alternatives, it is only one part of this multipurpose project. For that reason this type of alternative was

not studied in detail.

A commenter would like to see an alternative developed that develops safety zones instead of escape

routes. The weakness in this consideration is that safety zones are only effective if you can get to them so

the evacuation route must be treated to assist with safe passage. In effect, the treatments would serve as

both. Commenters requested less treatment along roadways (50 feet and 15 feet) that are proposed to

create safer evacuation routes. Public evacuation by law enforcement and firefighters requires routes that

reduce the threat of harm and loss of life. Safety zone guidelines in the IRPG (Incident Response Pocket

Guide, 2014) were used to determine the needed fuel treatment for evacuation routes. A safety zone is an

area where firefighters, law enforcement and the public can survive a wildfire without a fire shelter.

Excessive radiant heat to skin and supper heated air to the lungs can be fatal. Calculations were based on

flat terrain, radiant heat only and tree heights of 50 feet that produce a continuous flame height of 100 feet

(crown fire). The needed separation distance between humans and flames is four times the continuous

flame height. Therefore, to ensure human safety along evacuation routes, a distance of 400 feet would

need to be treated to meet the minimum criteria for a safety zone. Treatments also need to thin over-story

trees, reduce ladder and surface fuels to eliminate crown fire potential. Treatments limited to a lesser

distance would not meet the objective of providing safer evacuation routes so these alternatives were not

studied in detail.

A “No Roads Alternative” was requested. The ‘helicopter alternative’ and the ‘no action’ alternatives

address this request but a short discussion was included in Final EA , Appendix C, C-43 to 53.

V. Public Involvement and Scoping Collaboration with the public started in 2011 for this project as the interdisciplinary team (IDT) worked to

complete the Hebgen Duck Landscape Assessment. The District Ranger and IDT members met with

numerous entities such as the Interagency Bison Management Plan (IBMP) partners, the Hebgen Basin

Fire Department, local Homeowner groups, local, state and federal government representatives, the

Greater Yellowstone Coalition, Defenders of Wildlife, tribal representatives from the Nez Perce Tribe and

the Confederated Salish Kootenai Tribe (CSKT) and concerned citizens. Public outreach was conducted

through the West Yellowstone News and other regional newspapers, at scheduled meetings for various

organizations and on an individual basis. We held meetings and field trips with these groups, as well as

Montana Fish Wildlife and Parks and Yellowstone National Park representatives.


42

The Custer Gallatin Working Group (CGWG) formally began collaboration for this project in the spring

of 2015. The CGWG is a collaborative established in July, 2014 to develop agreement around priority

areas and approaches for project work on the Custer Gallatin National Forest, and to help facilitate

completion of those projects at the local level. CGWG members represent a wide range of stakeholder

interests in the management of the Custer Gallatin. The twenty-four designated seats on the collaborative

include County Commissioners, representatives of Conservation NGO’s, the Skiing industry, Agriculture

and Ranching, Quiet and Motorized Recreation, Hunters, Anglers, Outfitters, Mining, Recreation and

Economic Development, and the Timber industry. The CGWG submitted a letter of support for the

Decision in May 2017.

During scoping, comments were solicited from 1/6/2015 until 2/10/2015 with an extension for those that

requested additional time. The Forest received fifty two comment letters from 45 individuals and 12

entities including advocacy groups, businesses and agencies. Comments were received on numerous

issues relating to aesthetics, aquatic and amphibian species, aspen, clarification of the purpose, need and

proposed action, climate change, costs to implement, cumulative effects, fire/fuels, forest health, forest

plan consistency, implementation requests, invasive weeds, inventoried roadless area, NEPA process and

disclosure, recreation and special uses, roads, snags, social issues, soils, vegetation (old growth, diversity,

other), wildlife – diversity, elk, birds, bison, general (multispecies requests), management indicator

species, threatened and endangered species - grizzly bear, Canada Lynx and wolves. The comments were

extensive and included many nuances. Key messages are summarized in a few categories in a Summary

of Public Comments (IDT 3/2015). The issues were addressed in a number of ways. Analysis and

information disclosure was provided in the specialist reports, in supporting analysis or disclosure

documents provided on the project webpage and in the Final EA to answer information requests. Design

features common to action alternatives address many of the concerns, reduce potential impacts and

provide a more complete description of associated activities (Appendix A of the Final EA ). Last, five

issues were used in alternative development to resolve conflicts concerning alternative uses of available

resources (Final EA p. 32).

The IDT also sponsored a series of public meetings with the Custer Gallatin Working Group

Collaborative Committee and the public. Meetings and/or field trips were held in 2015 on: 1/27, 4/21,

7/15, 8/5 and 9/16. These were opportunities for the Forest Service to provide more detail about the

purpose and need, proposed actions and the alternative development process in response to the requests

for better explanation. The public also had the opportunity to ask questions and visit the treatment areas.

After the public meetings, the Public Comment Summary was updated on October 27, 2015 (IDT

10/2015) to reflect feedback from the field trips and public meetings. The update was sent to all

commenters and interested persons. The scoping documents and comment summaries were posted on the

Custer Gallatin Webpage at https://www.fs.usda.gov/project/?project=45491, along with other supporting

documents and documents requested by the public. The project has been listed in the Schedule of

Proposed Actions (SOPA) since October 2014.

A 30 day EA comment period was held in June 2016. Eighteen letters were received. I interpret that to

mean that we addressed concerns of a large majority of the original 52 commenters. A public meeting

was held and seven people signed in. The interdisciplinary team went to great lengths to be responsive to

comments in Volume II, Appendix C in the Final EA which includes 138 pages of responses. In addition

there were updates to several specialist reports. The Final EA was modified but most updates were

included in Appendix C and specialist reports. It was apparent that some commenters did not read the EA

and asked for information that was already addressed. The main comments related to temporary roads,

highway thinning units along US 191, science consideration and the desire for more analysis or

information. In response to the concerns expressed the Selected Alternative is a modified version of the

preferred alternative two addressing concerns related to the amount of temporary road proposed and the

highway thinning units for wildlife safety.



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The North Hebgen Multitple Resource Project was subject to the pre-decision objection process pursuant

to 36 CFR 218, subpart A. The Objection Period ended April 24, 2017. This process provided yet another

opportunity to participate in review of the Draft Decision, Finding of No Significant Impact and

Environmental Assessment (3/2017). A discussion of the objection process and outcome is in Section

VIII.

VI. Finding of No Significant Impact In accordance with 40 CFR 1 508.13 and direction provided in the Forest Service Handbook (FSH 1909.

15, Chapter 40, Section 43.1), I have determined that the management actions included in the Selected

Alternative of the North Hebgen Multiple Resource Project (NHMRP) do not constitute a major federal

action, and that the implementation of the proposal will not significantly affect the quality of the human

environment. Accordingly, I have determined that an Environmental Impact Statement need not be

prepared for this project. I have followed the implementing regulation for NEPA (40 CFR 1508.27) and

other criteria for determining the significance of effects.

Before making my determination, I carefully reviewed and considered the following information:

The Selected Alternative will implement activities that are limited in scope, affecting only the

immediate area in and around the treatment units. The project is designed to minimize environmental

effects through unit location, treatment methods, silvicultural prescriptions and other design features

for the project. The design features included in my decision (Appendix A of the Final EA ) are

provisions required to meet Forest plan standards or regulatory requirements. A few are tailored to

the project but still required in order for the project to be consistent with the plan. They all contribute

to an environmentally preferred outcome as well.

The direct, indirect, and cumulative effects of these actions as documented in the Environmental

Assessment;

The analysis documentation in the Project Record for the NHMRP Project;

Past experience with resource management projects on the Custer Gallatin National Forests.

The interdisciplinary team and I "screened" the management actions included in the NHMRP for

"significant impact." The results of this screening are summarized below.

Context

I have determined that the appropriate scope for weighing the significance of impacts is within the general

vicinity of the project area. The extent of most impacts are not discernable beyond about .5-1 mile. The

cumulative effects analysis area varies widely between resources, the actual effects become very minimal

beyond about a mile and negligible within 5-10 miles for wide ranging wildlife species. Consequently, the

context for addressing significance for the Forest actions is limited to the locale rather than in the nation,

state or Forest as a whole.

The project activities will take from 8-12 years to implement. Design features (Final EA , Appendix A)

and alternative design (DN p. 16) for the Selected Alternative minimize or avoid adverse impacts to the

extent that such impacts will be difficult to detect after a few growing season and negligible, even at the

local level. Displacement or disturbance impacts will be limited to the duration of activities in a given

treatment area. Operations are not likely to occur in any one locale longer than one or two operating

seasons. Some lingering impacts will occur for multiple seasons such as sediment recovery, these types

of impacts will be mitigated to reduce effects to acceptable levels. Finally, some impacts will be

discernable to a trained eye for several seasons, such as changes in vegetation density. These types of

impacts are characteristic of the landscape and mimic natural processes.


44

Within the context of the landscape as whole, or at the stand level, the ecological consequences are not

found to be significant in either the short term or long term. In conclusion, the extent, duration and scope

of anticipated effects is limited and reflective of natural conditions therefore, the impacts will not be

significant in terms of context.

Intensity

Intensity is a measure of the severity, extent, or quantity of effects, and is based on information from the

effects analysis of this Final EA and the references in the project record. The effects of this project have

been appropriately and thoroughly considered with an analysis that is responsive to concerns and issues

raised. The agency has taken a hard look at the environmental effects using relevant scientific information

and knowledge of site-specific conditions gained from field visits. My finding of no significant impact is

based on the context of the project and intensity of effects using the ten factors identified in 40 CFR

I508.27(b) and discussed in the following paragraphs.

Impacts may be both beneficial and adverse. A significant effect may exist even if the Federal

agency believes that, on balance, the effect will be beneficial.

Both beneficial and adverse effects have been taken into consideration when making a determination

of significance for this project. While there will be beneficial effects, this action does not rely on

those effects to balance adverse environmental impacts. The individual resource sections in the EA

(pp. 6-13, 33-209) and the supporting information in the project record contain comprehensive effects

analyses, and the findings from these resource-specific reports form the basis for my decision. These

activities have varying effects on the physical, biological, or social components of the affected

environment. Some of these effects are more favorable to a particular resource component than to

another resource component. Below is a synopsis of the effects of the activities associated with issues

used to develop alternatives; however, none of the effects, whether favorable or unfavorable,

beneficial or adverse, are significant.

Implementation of proposed fuel treatments in the Selected Alternative will modify fire behavior

characteristics to lessen wildfire risk near values, including structures such as businesses and homes,

powerlines and infrastructure like campgrounds and trailheads similar to Alternative 2. Treatments

will provide the lowest resistance to control and least potential for fires spreading from private land to

national forest and vice versa (EA p. 41).

The action alternatives move the vegetative condition in the project area toward the desired

conditions identified in the purpose and need while achieving Forest Plan goals and standards. There

will be beneficial impacts of increasing forest resilience through increases in diversity of age, size and

species composition, along with improved growing conditions for trees. There will be an increase in

under-represented species including aspen and whitebark pine (WBP). Old growth forest and over

mature forest structure will be maintained at current levels in the Henrys Mountain Range and

maintained above levels prescribed for the Gallatin Range in the Gallatin Forest Plan (amended

2015). There will be incidental damage to individual trees and a minimal amount of windthrow is

expected. There will be a reduction of snags and coarse woody debris (CWD) in harvest units but the

Forest Plan standard for snag and CWD retention will be met ensuring adequate snags and CWD in

the units. These components will be unaffected in adjacent areas and across the broader landscape in

the project area leaving extensive snag and coarse woody debris habitat. The forest vegetation

changes associated with the treatments represent changes that could occur naturally under natural

disturbance conditions such as fire. The action alternatives will improve forest vegetation conditions

on a relatively local scale relative to the desired conditions identified in the purpose and need for

action (Final EA , p. 6-13, 57-58).

Existing weed infestations will be avoided and buffered for most of the project area which will limit

potential spread from existing weeds. Design features will limit the risk of new plant invasions.


45

Overall, the increased emphasis on weed control in this area could decrease the existing weed

population (e.g. treating weeds prior to disturbance and follow-up weed survey /treatments for five

years). (Final EA , p. 89)

The action alternatives will help to reduce (though not eliminate entirely) risk of large portions of the

view shed in the project area being affected by a crown fire which is often perceived as undesirable

from a scenery standpoint. Treatments will increase aspen presence, which is visually desirable.

There will be changes to the vegetative character as it relates to scenery but those impacts will

represent the characteristic landscape after implementation. More noticeable impacts, such as

disturbance associated with skid corridors and temporary roads will be short term. (Final EA p. 96-

97)

The design features included in the decision are standard operating procedure with the exception of a

few that are tailored to the site specific project. These practices are effectively required in the Forest

Plan or by regulation, so they will be implemented whether they are listed as part of the decision or

not. The design criteria/resource protections for the following resource areas are implementing

standard forest practices: air quality, aquatic species, cultural resource, forest vegetation – old growth,

over-mature forest structure, snags and coarse woody debris, tree protections and silvicultural

requirements, sensitive plants, nest tree area avoidance and timing restrictions for listed bird species,

water quality, soil and invasive weed best management practices, grizzly bear. The remaining

resource protections are also designed to adhere to Forest plan or other established guidance and they

were tailored based on the site specific project to most effectively achieve the environmentally or

socially preferred outcome: aquatic species, inventoried roadless protections, recreation and scenery

protections. There is an explanation following the design feature listing in Appendix A of how

various practices are incorporated in project implementation.

The analysis considered not only the direct and indirect effects of the projects, but also their

contribution to cumulative effects. Past, present and reasonably foreseeable future actions have been

included in the analysis. Adverse effects from the Selected Alternative have been minimized or

eliminated through project design criteria. Any adverse effects from the action will be minimal and

localized. The actions are being undertaken to provide for long-term beneficial effects to public

health and safety through fuel reduction in the wildland urban interface, to provide long term forest

health and resilience by increasing species, age class and size diversity. Treatments to enhance or

maintain aspen and whitebark pine also offer a long term benefit to various wildlife species. As such,

I find that the Selected Alternative is beneficial but is not a significant federal action.

The degree to which the proposed action affects public health or safety.

There will be no significant effects on public health and safety. Fuel reduction treatments are

designed to improve public and fire fighter safety. The treatments are intended to change fire

behavior to improved effectiveness of suppression and to allow safe ingress and egress in the event of

a fire (Final EA , p. 34). All burning of slash and natural fuels will comply with State Air Quality

Standards and be coordinated through the Montana Airshed Group (Final EA , p. 98). The water

resource analysis indicates no degradation of water quality that could constitute a public health threat.

The proposal will comply with the Clean Water Act (Final EA , p. 154). Herbicide treatments of

weeds will comply with label directions and be consistent with the mitigation measures outlined in

the Gallatin National Forest Weed Management Record of Decision (USDA 6/2005) (Final EA , p.

88). In order to provide a safe and efficient road system capable of responding to the additional road

objectives and to ensure safe roads for mixed traffic and increased volume, a series of road

management requirements are included in all action alternatives (Appendix A – Table 2: Road

Management and Treatment by Route).

Unique characteristics of the geographic area, such as proximity to historic or cultural resources,


46

park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.

There will be no significant effects to unique characteristics of the area. There are no prime

farmlands, wild and scenic rivers or ecologically critical areas.

Yellowstone National Park is adjacent to some of the treatment units but there will be no significant

impacts to the park resources because design features and the design of treatments adjacent to the

park and elsewhere in the project area will minimize any potential direct or indirect impacts from the

project thereby limited cumulative impacts. Representatives of the Park have been included in

ongoing public involvement related to the project and indicated appreciation at the opportunity to

coordinate on habitat issues (2015_0508NPSEmail). The project area is in the Greater Yellowstone

Area (GYA), given that there will be no significant impacts in the project area, the integrity of the

GYA will be maintained.

A small number of acres is in an Inventoried Roadless Area (IRA). However, no new roads are

proposed in the IRA. Tree cutting is limited to generally small diameter trees. The analysis

concludes that the roadless characteristics will be maintained and the project complies with the 2001

Roadless Rule (p. 28). Appendix A includes design features that will minimize the short term

impacts to the lands in the IRA. The roadless lands impacts are immediately adjacent to or straddled

by Forest System Roads. The treatments will not have significant impacts on the IRA. (Final EA p.

123).

Historic and cultural resources, as well as wetlands, will be protected by incorporation of Design

Features in the Final EA , Appendix A. See the Environmental Effects Section of the Final EA p.

116, 155 for more information.

4. The degree to which the effects on the quality of the human environment are likely to be highly

controversial.

This factor pertains to any disagreement between experts in a given field over the potential effects of

this proposal. Although some may oppose the authorization of vegetation treatments and associated

activity, opposition does not constitute controversy over effect. The Final EA (p. 13, 207) discusses

public involvement and lists the agencies, groups, and organizations contacted about this proposal.

The technical analysis and foundation for the proposal is supported by accepted techniques, reliable

data, established scientific concepts and professional judgement. Some commenters indicated that the

analysis is not based on best science but did not provide alternate science or citations or explanation

of the relevance of publication that were provided. My staff reviewed science that was provided and

did not find contradictory science (see also p. 17). I conclude that the effects of the proposed action

are not highly controversial for professionals, specialists, and scientists from associated fields of

forestry, wildlife biology, soils, hydrology, fisheries and fire/fuels management.

5. The degree to which the possible effects on the human environment are highly uncertain or

involve unique or unknown risks.

The Forest Service has considerable experience implementing actions like those proposed. The

consequences of such actions are well established and predictable. Based on the analysis in the Final

EA , agency experience and monitoring, and expertise of our partner agencies, I conclude that the

effects are not uncertain, and do not involve unique or unknown risk. The technical analysis is

supported by accepted techniques, reliable data and professional judgement. I believe that the

impacts of implementing this decision are within the limits that avoid thresholds of concern and the

potential effects are predictable.


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6. The degree to which the action may establish a precedent for future actions with significant

effects, or represents a decision in principle about a future consideration.

The action is not likely to establish a precedent for future actions with significant effects, because this

decision implements a site specific project that does not set precedence of future actions or represent

a decision in principle about future considerations. Any proposed future project must be evaluated on

its own merit and effects. The proposed action is consistent with the Gallatin Forest Plan as amended

2015 and the capabilities of the land.

7. Whether the action is related to other actions with individually insignificant but cumulatively

significant impacts.

Consistent with the Council for Environmental Quality (CEQ) guidance, the past, present, and

reasonably foreseeable activities are considered in the cumulative effects analysis for each resource

area relative to the specific potential future effects of the proposal. Because the project’s direct and

indirect effects vary in time and space, each resource issue has a defined specific cumulative effects

analysis area and timeframe that is pertinent to the specific resource and the issue being considered.

Each resource discussion evaluates the degree to which past, present, and future actions influenced or

would influence the affected environment. No significant cumulative impacts are expected for any

resource. (Final EA pp. 33-208).

8. The degree to which the action may adversely affect districts, sites, highways, structures, or

objects listed, or eligible for listing, in the National Register of Historic Places or may cause loss

or destruction of significant scientific, cultural, or historical resources.

A comprehensive evaluation of potential effects to heritage resources was conducted and no impacts

are anticipated due to design features to protect these resources (Final EA p. A-2 to A-3). Those

identified are protected by design features. As a result, the Selected Alternative, like alternative 2

will have no significant adverse effect on districts, sites, highways, structures, or objects listed in or

eligible for listing in the National Register of Historic Places (Final EA page 118, 2016LaPointMemo

available in the project record).

9. The degree to which the action may adversely affect an endangered or threatened species or its

habitat that has been determined to be critical under the Endangered Species Act of 1973.

Critical habitat. The action will not adversely affect any endangered or threatened species habitat

that has been determined to be critical under the Endangered Species act of 1973, because there is no

designated critical habitat for any species in the project area. The project is entirely outside of

Designated Canada lynx Critical Habitat (USDI 2014)

Grizzly Bear. The Selected Alternative is in compliance with all FP standards. Ungulates will likely

be displaced by project activities, causing bears to follow suit, but shifts will be local and at a small

scale in relation to the size of the Bear Management Subunits (BMS) and the scale at which grizzly

bears operate across the landscape. Grizzly bear will shift their use to areas elsewhere in their home

ranges while disturbance is occurring. Whitebark pine and aspen will be enhanced in the long term,

which will benefit foraging for grizzly bears. Increased understory vegetation production will also

benefit foraging for grizzly bears. Riparian areas will be protected through project design and

avoidance, so there will be no effect on grizzly bear use of these areas except for possible

displacement when operations are occurring. The action alternatives will result in minor reductions in

the amount of available denning habitat or denning habitat quality but denning habitat is plentiful at

the BMS scale.

The Selected Alternative may affect, and is likely to adversely affect the grizzly bear. The

determination is based on the following rationale:


48

1) This project will temporarily reduce secure habitat below the baseline (the level at full

implementation of the Travel Plan) in the Madison #2 Subunit, which was previously identified as a

Subunit in need of improvement due to its already degraded baseline condition for secure habitat.

2) Secure habitat will be reduced in the Madison #1 Subunit, but will not be reduced below the

baseline level (1998).

3) This project will be consistent with the application rules provided by the GBCS and Forest Plan

for the Gallatin National Forest (incorporated through the Clean-Up Amendment, USDA 2015) for

temporary changes in secure habitat below baseline levels.

4) Disturbance associated with project implementation (human presence, traffic, noise) will result in

individual grizzly bears moving to adjacent areas with more secure habitat and less disturbance.

Disturbance will be temporary and will last for the period while activities are occurring and will be

limited in extent at any one time. Given the scale at which grizzly bear use the landscape and the

availability of habitat within the Subunits, it is expected that grizzly bear will quickly adapt by

shifting their use to adjacent areas.

5) This project could increase the risk of individual grizzly bear mortality during project

implementation due to a greater potential for human-bear conflicts resulting from increased human

presence in the project area. Design criteria, including enforcement of the CGNF Food Storage Order,

will minimize this risk. Post implementation recreational use of decommissioned roads, especially by

ungulate hunters, could have a longer-term effect on increased mortality risk for grizzly bears through

an increased potential for chance encounters with humans. Decommissioned roads are often not

desirable walk routes due to uneven terrain from scarification and heavier than normal slash for

erosion control.

6) Overall project effects on grizzly bear foraging habitat are expected to be beneficial since

activities will reduce canopy closure and stimulate growth of understory shrubs, forbs, and grasses.

Treatment to promote the persistence and establishment of a new age class in aspen and promote cone

production in whitebark pine stands will improve forage for this species in the long term. Disturbance

to grizzly bear and shifts in ungulate (potential prey) distribution in the vicinity of active treatment

units will be temporary.

7) Design criteria and other measures incorporated into the proposed action (e.g. food storage order

enforcement, measures to eliminate public use of temporary project roads, and decommissioning of

project routes as activities are completed) will reduce potential for mortality of grizzly bears due to

human conflicts or food rewards.

8) The cumulative effects of this project will be insignificant.

Consistent with the Forest Plan, which adopted the Application Rules in the Grizzly Bear

Conservation Strategy (2007), the Selected Alternative will temporarily affect grizzly bear security by

causing displacement of bears from treatment units during project implementation, temporarily

increasing TMARD above current levels and temporarily affecting the amount of grizzly bear secure

habitat. The spatial scale at which project activities will take place is very small in relation to the

scale at which grizzly bears operate across the landscape. Grizzly bear will be able to adjust their use

of the landscape in their home range to find areas that provide higher levels of security. By meeting

the secure habitat standard and the application rules in individual bear management subunits, there

will be no substantial impacts at either the BMS or larger scales (e.g. adjacent Bear Management

Units). Effects on grizzly bears are expected to be minor (Final EA , p. 61-82), especially at the scale

of the BMS.

Canada Lynx have evolved to adapt to a shifting boreal forest composed of a mosaic of species,

stand ages, and structures to support snowshoe hares (USDA Forest Service (2007c), Appendix P, pg.


49

40083). That document also stated that lynx operate at large scales and an activity would have to

occur across a very large area (at least several home ranges) to significantly impact a local lynx

population (USDA Forest Service 2007c pg. 40083). The action alternatives will maintain a mosaic

across the LAU and the changes will occur at such a small scale so as to have a minimal effect on

lynx. The alternatives are consistent with the Northern Rockies Lynx Management Direction

(NRLMD) which is the applicable Forest Plan direction (See Final EA page 156-166).

The biologist determined that the NHMR Project may affect, and is likely to adversely affect the

Canada lynx. The determination is based on the following rationale:

1) The NHMR Project will affect approximately 1.9% of the existing snowshoe hare habitat in the

Upper Madison LAU. The project will affect approximately 1.4% of the lynx habitat in the LAU.

2) Effects will be restricted to the eastern portion of the LAU; the majority of the LAU will not be

affected.

3) Treatment will create or accentuate complexity in homogeneous stands; treatments in mid-seral

and stem exclusion structural stages, accounting for 58% of affected lynx habitat, should improve

potential lynx habitat by accelerating the development of a multi-story stand structure (snowshoe hare

habitat) in the future.

4) Proposed treatment that creates early stand initiation structures will provide for stand initiation

snowshoe hare habitat in the future.

5) The project is in compliance with the Northern Rockies Lynx Management Direction standards

and is not expected to preclude any future use of the area by resident (if present) or transient lynx

should they pass through the area.

6) The project does not impede lynx movement and does not reduce habitat connectivity.

7) The cumulative effects of this project will be insignificant.

All activities will be consistent with the exception criteria under Standard Veg S5 and the WUI

exemption under the NRLMD. The cumulative total (for the Gallatin portion of the Forest) of

activities under the exceptions to Veg S5 (133 acres) and the WUI exemption (3,428 acres) will be

less than the limits (1,310 acres and 52,200 acres, respectively) placed on these under the NRLMD

Biological Opinion.

Wolverine were recently proposed for listing as a threatened species. In response to this status

change (from a Region 1 sensitive species to a proposed species (for the contiguous United States

DPS of the North American wolverine), Region 1 of the Forest Service prepared a Programmatic

Biological Assessment for North American Wolverine (USFS 2014). The purpose of this

programmatic biological assessment was to describe and analyze projects routinely conducted on

National Forest System lands within the Northern Region that are not likely to jeopardize the

continued existence of the North American wolverine. These activities were sub-divided into the

following general categories: timber harvest, mechanical equipment use, existing gravel pit use, roads

and road maintenance, silvicultural activities, range management, recreation management, forest

products, habitat maintenance and restoration, prescribed fire, watershed restoration, weed control,

and administrative and non-recreational special uses. A letter of concurrence for the programmatic

BA was received on May 23, 2014; in it, the US Fish and Wildlife Service concurred with the Forest

Service determination that these types of projects are not likely to jeopardize the continued existence

of the DPS of the North American wolverine.

The North Hebgen Multiple Resource Project will include activities that fall within several of these

categories, including timber harvest, mechanical equipment use, roads and road maintenance,

silvicultural activities, habitat maintenance and restoration, prescribed fire (activity fuels and pile

burning in units), and weed management (connected action). The programmatic BA determined that


50

these project types and associated activities are not considered a threat to the wolverine and are

therefore not likely to jeopardize the continued existence of the DPS of the North American

wolverine. For this reason, formal consultation is not required for this species. Compliance with the

screening criteria for the included project types will be documented in the appropriate North

American wolverine Screens Compliance Summary Sheet and included in the project file. Individual

project activities and cumulative actions will result in relatively small-scale disturbances in relation to

the large wolverine home range size. Wolverines are capable of adjusting to and co-existing with

moderate levels of disturbance. Project and cumulative effects will not result in barriers to dispersing

individuals. Therefore, the action alternatives are not likely to jeopardize the continued existence of

the wolverine. (See Final EA page 167-170)

10. Whether the action threatens to violate Federal, State, or local law or requirements imposed for

the protection of the environment.

The action will not violate Federal, State, and local laws or requirements for the protection of the

environment. Applicable laws and regulations were considered in the Final EA (see Final EA pages

33-208) and summarized on pages 28-34 in this document. The action is consistent with the Gallatin

Forest Plan as amended 2015 (pp.17-28).

Based on the Final EA and project record, I determined that there will be no significant impacts as a

result of this decision.

VII. Findings Required by Other Laws and Regulations

NATIONAL FOREST MANAGEMENT ACT (1976)

The National Forest Management Act (NFMA) of 1976 (P.L. 94-588) governs the administration of

national forests, and was an amendment to the Forest and Rangeland Renewable Resources Planning Act

of 1974. NFMA requires that resource plans and permits, contracts, and other instruments for the use and

occupancy of National Forest System lands shall be consistent with the land management plan (i.e. the

Forest Plan). NFMA also requires public participation, including adequate notice and the opportunity to

comment on projects that affect NFS lands. The North Hebgen Decision to use vegetation management

tools to reduce wildland fuels, increase aspen and WBP and enhance forest health and resiliency is

consistent with the intent of the forest plan's long term goals and objectives listed on pages [II-2 to 6]. The

project was designed in conformance with land and resource management plan standards discussed on

pages 17-21 of this Decision.

On April 9, 2012 the Department of Agriculture issued a final planning rule for National Forest System

land management planning (2012 Rule) 77 FR 68 [21162-21276]). On the Gallatin National Forest, the

Gallatin Forest Plan was developed under a prior planning rule. The 2012 Rule explains, “[The 2012

Rule] supersedes any prior planning regulation. No obligations remain from any prior planning

regulation, except those that are specifically included in a unit’s existing plan. Existing plans will remain

in effect until revised” (36 CFR §219.17).

NFMA requires that several specific findings be document at the project level for forest management,

including the following:

Suitability for Timber Production

NFMA requires no timber harvesting shall occur on areas classified as not suited for timber production,

except salvage sales, sales necessary to protect other multiple-use values, or activities that meet other

objectives on such lands if the forest plan established that such actions are appropriate.


51

The silvicultural diagnosis process and the Forest Plan were used to determine that all areas associated

with this project are suitable for timber harvest using the following criteria:

Meet the definition of forestland

Technological feasibility exists to protect soil productivity and watershed protection. Forest plan

standards, project design criteria, and applicable Best Management practices will be used to protect

these resource values.

There is reasonable assurance that lands can be restocked within five years of final harvest.

None of the areas considered for harvest have been withdrawn from timber production

Where timber harvesting is proposed in Management Areas not classified as suitable within the Forest

Plan, all treatments are in response to protecting multiple-use values or meeting resource objectives

identified in the project purpose and need and/or the Forest Plan.

Maintenance of the Diversity of Plant and Animal Communities

Forest Plan goals, objectives, standards, and guidelines address maintaining a diversity of vegetation and

habitats across the forest to meet a variety of wildlife species needs and to provide for sustained yield of

timber products. This requirement is intended to be met at the forest scale through Forest Plan

Implementation. The purpose and need for the project incorporates a number of forest wide goals and

standards moving the project area toward the goals. Forest Plan consistency was discussed in a previous

section.

In addition to applying forest plan direction, project design/mitigation prescribed by the project

silviculturist, wildlife biologist, fisheries biologist and the sensitive plant specialist address plant and

animal community needs (Final EA , Appendix A).

Appropriateness of Even-Aged Management and Optimality of Clearcutting.

NFMA directs that clearcutting be used only where “it is determined to be the optimum method”. Other

even aged methods can be used where “determined to be appropriate”. Clearcutting is proposed on 200-

257 acres depending on alternatives. All of these areas are dominated by lodgepole pine. Clearcutting

was determined to be the optimum regeneration method for meeting management objectives for each of

these areas by the project silviculturist. Criteria used to make this determination included; species

composition relative to management direction and availability of desired species for seed sources, species

susceptibility to observed insect agents, presence of disease infections which would be transmitted to the

regenerated stand, and stands subject to wind throw if residual trees were retained. Other even aged

methods are proposed as they are most compatible with the disturbance regimes found in the analysis area

and the adapted silvics and regeneration strategies of desired tree species.

NFMA Findings for Vegetation Manipulation

All proposals that involve vegetation manipulation of tree cover for any purpose must comply with the

following requirements.

Best suited to the multiple-use goals stated in the Forest Plan for the area with impact. All proposed

treatments are consistent with multiple use Forest Plan direction and address the project purpose and

need.

Assure that the lands can be adequately restocked within 5 years. 3,352 acres of even-aged

regeneration harvests have occurred since the 1960’s in the analysis area. All of these acres have

been certified in FACTS as stocked following harvest either through natural regeneration or planting.


52

There are no indications that with appropriate planning proposed regeneration treatments could not be

stocked within 5 years.

Not chosen because they will give the greatest dollar return. Although timber harvest associated with

this project will generate revenue, all treatments have been designed to meet project objectives and do

not have a primary goal of revenue generation.

Be chosen after considering the effects on residual trees and adjacent stands. The effects to residual

trees and adjacent stands were considered in the interdisciplinary development and the forest

vegetation analysis of this project. Residual tree protection measures are included in the design

features section of this report.

Be selected to avoid permanent impairment of site productivity and to ensure conservation of soil and

water resources. The Soils and Water resources section of the Environmental Assessment discuss the

effectiveness of design features that include protection and enhancement designs sufficient to ensure

conservation of the resources (Final EA p. 140, 153-155). Soil and water resources will be

conserved.

Be selected to provide beneficial effects to water quality and quantity, wildlife and fish habitat,

regeneration of desired tree species, forage production, recreation uses, aesthetic values, and other

resource yields. Following Forest Plan and management area direction, an interdisciplinary team

considered all of these resources in the context of the surrounding landscape and this project as

documented in the Environmental Assessment.

Be practical in terms of transportation and harvesting requirements and total costs of preparation,

logging, and administration. Standard logging systems and log hauling is prescribed for this project

and has been determined to be practical for this project and a sale feasibility analysis has been

conducted.

Prior to harvest, stands of trees throughout the National Forest System shall generally have reached

the culmination of mean annual increment of growth. This is the age at which average rate of annual

tree growth stops increasing and begins to decline. The regeneration harvests included in my decision

indicated serious declines in growth rate and were determined to have reached their culmination of

mean annual increment by the silviculturist. In addition, the Forest Plan states that the average age of

mean annual increment in lodgepole pine is 90 years. Stand data collected in 2014 and 2015 in some

of these stands suggests lodgepole pine (dominant species) trees with >6” DBH have ages ranging

from ~ 70-160 years old. The intermediate harvest also indicated that growth has slowed due to over

stocking.

NFMA Findings related to Roads:

Construction of temporary roadways in connection with timber contracts, and other permits or leases.

Unless the necessity for a permanent road is set forth in the forest development road system plan, any

road constructed on land of the National Forest System in connection with a timber contract or other

permit or lease shall be designed with the goal of reestablishing vegetative cover on the roadway and

areas where the vegetative cover has been disturbed by the construction of the road, within ten years after

the termination of the contract, permit, or lease either through artificial or natural means. Such action

shall be taken unless it is later determined that the road is needed for use as a part of the National Forest

Transportation System (16 USC 1608(b)).

Roads constructed on National Forest System lands shall be designed to standards appropriate for the

intended uses, considering safety, cost of transportation, and impacts on land and resources (16 USC

1608(c)).


53

Finding: The Gallatin National Forest Travel Plan (2006) analysis and decision has rigorously

determined the management objectives of the entire road system throughout the Forest, including this

area. This fulfills the roads analysis requirements for project level analysis. In the Travel Plan,

disposition of “project roads” was left to the project level decision-making process. Project roads are

those roads not open for motorized public use or those open for administrative use.

No additional system roads will be constructed as part of this project. Proposed temporary roads will be

constructed and used for the life of the project and will be restored to surrounding area vegetation

management objectives as part of the project closeout and not added to the Forest road system. As

proposed in all action alternatives, the temporary roads to be constructed will be built to the minimum

standard needed to implement the alternatives. The need for temporary roads and restoration plans are

discussed in the description of the alternatives and design features common to the action alternatives.

ENDANGERED SPECIES ACT

Under Section 7 of the Endangered Species Act, each Federal agency must ensure that any action

authorized, funded, or carried out is not likely to jeopardize the continued existence of any threatened or

endangered species. If a threatened or endangered species, or species proposed for listing occurs in an

area where a project is proposed, a Biological Assessment (BA) must be prepared. If the action would

result in a "may affect, likely to adversely affect" determination for the species, formal consultation with

the U.S. Fish and Wildlife Service (USFWS) must occur and they would issue a Biological Opinion.

A Biological Assessment (BA)(Scarlett 2016) was submitted to the Service in December 2016. The

Biological Assessment for the project concluded that the project “may affect, likely to adversely affect” for

grizzly bear and Canada lynx. There is no designated or proposed critical habitat for either species in the

project area. Pursuant to 50 CFR 402.13 (a), formal consultation was completed on May 17, 2017 when

the US Fish and Wildlife Service issued their Biological Opinion (BO) for the project.

The proposed activities meet the definition of actions that are not considered a threat to this species in the

Programmatic Biological Assessment For North American Wolverine (USDA 2014), the Selected

Alternative is “not likely to jeopardize the continued existence” of the wolverine. This determination and

the consistency of this project with the programmatic screening criteria for wolverine is documented in

the project file.

With regard to the Canada lynx, the US Fish and Wildlife Service determined that adverse effects were

adequately analyzed in the 2007 programmatic biological opinion and that the project conforms to the

2017 amended incidental take statement. It was the Service’s biological opinion that the North Hebgen

Project is not likely to jeopardize the continued existence of Canada lynx.

With regard to the grizzly bear, the US Fish and Wildlife Service found that the existing, baseline access

condition of the Madison #1 and Madison #2 grizzly bear subunits is consistent with the analysis of

effects on grizzly bears in the 2006 programmatic biological opinion (Travel Plan) and that the proposed

action will be in compliance with the 2013 amended incidental take statement associated with that

biological opinion. The amount of incidental take that is expected will be low and no mortality of grizzly

bears is anticipated. The North Hebgen Project is not likely to reduce the numbers, distribution, or

reproduction of grizzly bears in the Yellowstone Grizzly Bear Ecosystem. The Service determined that

the level of anticipated take under the North Hebgen Project is not likely to jeopardize the continued

existence of the grizzly bear. The USFWS provided non-discretionary terms and conditions for grizzly

bear that are incorporated in the Decision (page 7). These terms and conditions implement actions to

meet the reasonable and prudent measures identified by the USFWS by reducing general and site-specific

displacement of grizzly bears in the North Hebgen project area, specifically the Madison #2 Subunit.


54

On June 22, 2017 it was announced that the Greater Yellowstone Ecosystem (GYE) population of the

grizzly bear would be removed from the Federal list of endangered and threatened wildlife. The US Fish

and Wildlife Service has determined that the population has recovered to the point where federal

protections under the Endangered Species Act can be removed and overall management can be returned to

the states (Wyoming, Montana, and Idaho). The Final Rule to remove the grizzly bear from the list will be

published in the Federal Register in the near future. The Final Rule will take effect 30 days after

publication in the Federal Register. Existing Custer Gallatin National Forest management direction for the

grizzly bear and its habitat would not change in response to delisting. The decision or conclusions in this

decision will not change. Procedural requirements associated with ESA would no longer apply to this

species.

The evolution of management direction for grizzly bear on the Gallatin portion of the Custer Gallatin

National Forest is summarized in a memo titled “Grizzly bear habitat guidance under the Gallatin Forest

Plan (2015), Gallatin Travel Plan (2006), and Travel Plan Amended Incidental Take Statement (2013)”

(Scarlett Memo 2017). The purpose of this memo was to ensure that the Forest Service and the USFWS

have a consistent understanding of current direction and Opinions and how the direction applies to

ongoing and future projects, inlucuding North Hebgen. The US Fish and Wildlife Service, agreed that the

interpretation was accurate, in keeping with their intent. (Dixon 2017, personal communication).

Executive Order 12898 - Environmental Justice

Executive Order 12898 directs Federal agencies to integrate environmental justice considerations into

federal programs and activities. Environmental justice means that, to the greatest extent practical and

permitted by the law, all populations are provided the opportunity to comment before decisions are

rendered, or are allowed to share in the benefits of, are not excluded from, and are not affected in a

disproportionately high and adverse manner by government programs and activities affecting human

health or the environment (RO 13898 and Departmental Regulation 5600-002, “Environmental Justice”).

My decision will not have a discernible effect on minorities, American Indians, or women, or the civil

rights of any United States citizen, nor will it have a disproportionately high and adverse impact on

minorities or low-income individuals. The Final EA details the public involvement that occurred for this

project including outreach to the local community and Native American tribes. As the project will not

disproportionately impact environmental justice populations (Final EA , p. 114), my decision is consistent

with EO 12898.

VIII. Administrative Review - Objection Process and Implementation This decision is not subject to further administrative review. The project will be implemented

immediately.

Four entities presented pre-decision objections. The Objectors included the Alliance for Wild Rockies

and Montana Ecosystems Defense Council, the Native Ecosystems Council, Rob French and Vladmir

Kustanovich. None of the objectors responded to the invitation to meet with Objection reviewing Officer

(ORO). The objections were reviewed by a panel of specialists from the Northern Region of the Forest

Service. The ORO responded to Objectors on June 8, 2017. No instructions were presented to the Forest

as a result of the Objections recieved. However, in response to information presented from objectors,

some clarifications were incorporated in the final Decision. Minor errors were identified in the EA and

Wildlife Report and these were finalized in June 2017. A supplemental Wildlife Report (Scarlett,

6/17/2017) was prepared to respond to new information that was introduced from objections. The


56

In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and

policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA

programs are prohibited from discriminating based on race, color, national origin, religion, sex, gender identity

(including gender expression), sexual orientation, disability, age, marital status, family/parental status, income

derived from a public assistance program, political beliefs, or reprisal or retaliation for prior civil rights activity, in

any program or activity conducted or funded by USDA (not all bases apply to all programs). Remedies and

complaint filing deadlines vary by program or incident.

Persons with disabilities who require alternative means of communication for program information (e.g., Braille,

large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or USDA’s TARGET

Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339.

Additionally, program information may be made available in languages other than English.

To file a program discrimination complaint, complete the USDA Program Discrimination Complaint Form, AD-

3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or write a letter

addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the

complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by: (1) mail: U.S. Department

of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 Independence Avenue, SW, Washington, D.C.

20250-9410; (2) fax: (202) 690-7442; or (3) email: [email protected].

USDA is an equal opportunity provider, employer and lender.

http://www.ascr.usda.gov/complaint_filing_cust.html

Final Decision Notice and Finding of No Significant Impact Appendix A

A-1

Figure A-1. North Hebgen Multiple Resource Project Selected Alternative – North Half Map. This map is available on the Project

Webpage for better viewing at https://www.fs.usda.gov/project/?project=45491or upon request.

North Hebgen Multiple Resource Project Appendix A

A-2

Figure A-2. North Hebgen Multiple Resource Project Selected Alternative – South Half Map. This map is available on the Project

Webpage for better viewing at https://www.fs.usda.gov/project/?project=45491or upon request.


A-3

Table A-1. Comparison of the Action Alternatives for the North Hebgen Multiple Resource Project

Primary

Components of the

Alternatives

Alternative 1

No Action

Alternative 2

Proposed Action Alternative 3 Alternative 4 Selected Alternative

Vegetation

Management

Total Acres

0 5,900 4,830 5,300 5,670

Temporary Road

(miles)

0 21.2 miles 12 miles 17 miles 15.6 miles

Travel Plan

Modification No Yes Yes Yes Yes

Design Features

Common to Action

Alternatives

No Yes Yes Yes Yes

Purpose and Need Achieved by Category and Acres

Relative Overall

Effectiveness No +++ - + ++

Aspen Enhancement 0 701 acres 192 acres 372 acres 652 acres

Forest Health &

Resiliency

Improvement

0 962 668 753 acres 991 acres

Fuels reduction in

WUI/Evacuation

Routes/Powerlines

and Fuel break

0 2,898 acres 2,670 acres 2,870 acres 2,817 acres

Whitebark Pine

Enhancement 0 1,129 acres 1,097 acres 1,097 acres 1,139 acres

Wildlife Safety 0 205 acres 205 acres 205 acres 67 acres


A-4

Table A-1. Comparison of the Action Alternatives for the North Hebgen Multiple Resource Project

Primary Treatment Acres by Alternative

Daylight thinning 0 843 843 843 843

Group Selection

harvest 0 695 467 514 693

Hand thin 0 16 16 16 137

Highway Corridor

Thin 0 138 138 138 0

Intermediate Harvest

Improvement

Commercial Thin

Sanitation Salvage

0 2,288 1,612 1,920 1,990

Post & Pole 0 177 170 177 177

Precommercial Thin 0 1,020 960 1,004 1, 076

Powerline Corridor 0 139 132 139 127

Regeneration Harvest

Seed Tree Harvest

Overstory Removal

Clearcut

0 591 494 534 623


A-5

Table A-2. Comparison of issues used in alternative development to resolve conflicts concerning alternative uses of available resources

for the North Hebgen Multiple Resource Project.

Issue/Resource Alternative

1

Alternative 2 Alternative 3 Alternative 4 Selected Alternative

Impacts to

Grizzly Bear

Secure Habitat

No Impact Consistent with the FP

direction

Madison 1 BMS –

secure habitat levels

maintained above

baseline.

Madison 2 BMS -

temporary reduction in

secure habitat (-0.9%).

However, the activity is

consistent with the

application rules in the

Conservation Strategy

Consistent with the FP

direction

Madison 1 BMS –

secure habitat

maintained above

baseline.

Madison 2 BMS – no

reduction in secure

habitat. So the



do not apply.


direction

Madison 1 BMS –


maintained above

baseline.

Madison 2 BMS -


secure habitat (0.3%).

However, the activity

is consistent with the




direction

Madison 1 BMS –


maintained above

baseline.

Madison 2 BMS -


secure habitat (-0.6%).

However, the activity

is consistent with the



Risk of Invasive

Weed Spread

Biodiversity and

Site Productivity

No project

related weed

impacts

All alternatives are consistent with applicable direction.

For all alternatives, 1% of area has existing weeds, the patches have low to moderate density,

mitigation measure will keep weeds near current level, thus maintaining current biodiversity and site

productivity

Existing weeds

within 100 feet of

units and within

high risk

vegetation types

0 211 current weed acres

within 100 feet of

proposed units -

177 ac in high risk

vegetation types

201 current weed acres

within 100 feet of

proposed units -

168 ac in high risk

vegetation types


within 100 feet of

proposed units -

176 ac in high risk

vegetation types


within 100 feet of

proposed units -

177 ac in high risk

vegetation types


A-6

Issue/Resource Alternative

1

Alternative 2 Alternative 3 Alternative 4 Selected Alternative

Impacts to sense of

place and scenery

Adverse impacts would be minimized through design features incorporated in all action alternatives.

For all action alternatives, scenery standards would be met. Activity that displaces users would be

short term. All proposed treatments would be compatible with management area direction in the

areas of concern. Alternative 3 avoid treatment of some portions of resident’s special places. The

other alternatives include treatment of the areas. The areas of interest from commenters were Horse

Butte, Rainbow Point, Fir Ridge, and portions of Whits Lake and Red Canyon areas.

No

immediate

change

Includes the most

treatment in areas of

concern

Least treatment in the

areas

Less treatment than

Alt. 2, more than Alt.

3 and Equal to the

Selected Alternative

Less treatment than

Alt. 2, nd more than 3

Equal to Alt. 4

Aquatic Species

habitat impacts

Instream Fine

Sediment

No increase

in fine

sediment

For the issue of fine sediment delivery and associated effects on fisheries, there is little difference

between the action alternatives because all alternatives are similarly designed to minimize impacts.

Within the Red Canyon analysis area and Tepee estimated increases do not change between

alternatives. For Little Tepee there is a 1/10th % difference between Alternative 2 and the others.

With or without the implementation of the action alternatives, the recently introduced population of

west slope cutthroat trout would continue to increase in population size and continue to occupy the

once barren habitat upon which they were placed. The design features and mitigation measures are

such that any of the action alternatives would have minimal impacts on the existing westslope

cutthroat trout population.

Decision Notice and Finding of No Significant...

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