Draft Environmental Agriculture...

United States Department of Agriculture Forest Service October 2016

Draft Environmental Assessment Alpine Community Defense Project

Descanso Ranger District, Cleveland National Forest San Diego County, California

Alpine Community Defense Project Draft EA Cleveland National Forest, Descanso Ranger District

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Location of Action: National Forest System lands on the Cleveland National Forest in San Diego County, California

Type of Document: Environmental Assessment Lead Agency: USDA Forest Service Responsible Official: Robert T. Heiar, Descanso District Ranger, Cleveland National Forest Contact Person: Rick Marinelli, Battalion 43 Cleveland National Forest 3348 Alpine Blvd. Alpine, CA 91901

Table of Contents

Introduction ................................................................................................................................................... 2

Alternatives ................................................................................................................................................... 5

Environmental Consequences ..................................................................................................................... 16

Persons, Groups, Organizations, and Agencies Consulted ......................................................................... 41

Responses to Comments ............................................................................................................................. 41

References ................................................................................................................................................... 44

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, gender, religion. age, disability, political beliefs, sexual orientation, or marital or family status. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD).

To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, DC 20250-9410, or call (800)795-3272 (voice) or call (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer.


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Chapter 1: Introduction

The Descanso Ranger District has prepared this environmental assessment (EA) in compliance with the National Environmental Policy Act (NEPA). This EA discloses the environmental consequences of four alternatives: the no-action alternative and three action alternatives. This EA also provides sufficient evidence to determine whether an environmental impact statement (EIS) is needed or if instead a finding of no significant impact is appropriate.

1.1 Background The Alpine Community Defense hazardous fuels treatment project is being designed with two objectives in mind. The first would be to reduce the risk and impact of catastrophic wildfire to the communities of Alpine, Viejas Indian Reservation, and Carveacre. The second would be to limit fires that start on private land and move onto Forest lands. Project area locations and associated treatments would be designed to meet Land Management Plan (LMP) goals and standards through employing program strategies and tactics found in Appendix B of Part 2 (USDA Forest Service, 2005).

1.2 Location The project area is located on National Forest System (NFS) lands, as well as, private lands in three distinct areas within the administrative boundaries of the Descanso Ranger District on the Cleveland National Forest in San Diego County, CA.

Units located along Anderson Truck Trail north of Interstate 8 are contained within Section(s) 14, 15, and 23 of Township 15 South, Range 2 East (San Bernardino Base Meridian). Approximately 72 acres of NFS lands and 15 acres of private lands are proposed for treatment. See figure 1 on page 9.

Units located south of Viejas Creek Trail east to Star Valley Road, south of Interstate 8, are contained within Section 36, Township 15 South, Range 2 East and Section 31, Township 15 South, Range 3 East (San Bernardino Base Meridian). Approximately 32 acres of NFS lands and 51 acres of private lands are proposed for treatment. See figure 2 on page 10.

Units located south of Japatul Road surrounding the community of Carveacre are contained within Section(s) 20, 28, 29, 30, 32, 33, Township 16 South, Range 3 East (San Bernardino Base Meridian). Approximately 195 acres of NFS lands and 24 acres of private lands are proposed for treatment. See figure 3 on page 11.

1.3 Purpose and Need The purpose of this project is to reduce the risks to life, property, and resource values from wildland fire while improving fire suppression abilities and fire fighter safety around the communities near and within Alpine, Viejas Indian Reservation and Carveacre. Alpine is the largest, most populated city within the Descanso Ranger District of the Cleveland National Forest. It is among the Descanso Ranger District’s highest priorities for community protection from wildfire. Viejas Indian Reservation and surrounding communities to the east of Alpine have been threatened repeatedly by wildfire. In early 2000’s, the Viejas Band of the Kumeyaay Indians, as part of the Tribal Forest Protection Act, completed a fuelbreak on non-NFS lands, this project proposes to complete the portion of the project on NFS lands creating defensible space to residents south of the reservation. Carveacre is a rural extension of greater Alpine, and is surrounded by National Forest lands. Carveacre has only one maintained access and egress point for the entire community. The best chance of preventing loss of life and property is to treat and maintain the fuels around the entire community so residents can safely shelter in place if escape is not an option in the event of a large wildfire. Life, property, and resource values could be threatened by a future wildfire event if no action is taken.

In its current state, the proposed project area would support a high-intensity wildfire. In 2003, the Cedar Fire burned through a majority of the project area. In 2001, the Viejas Fire burned the southern Alpine


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block of the proposed project area. These fires were detrimental to improvements and infrastructure within and adjacent to NFS lands. They were high-intensity wildfires that burned in areas where fuels had not been managed. The opportunity now exists to be proactive and treat fuels adjacent to high value resources that burned in the Cedar and Viejas fires before they reach their pre-fire condition. This project would provide the opportunity to maintain the treatments around the community of Carveacre and create strategic fuelbreaks along the Anderson Truck Trail and in eastern Alpine south of the Viejas Indian Reservation.

1.4 Preferred Alternative The preferred alternative would create a series of fuelbreaks for the purposes of community defense from a future wildfire event. These fuelbreaks would consist of an area of modified vegetation in three distinct locations along the outskirts of Alpine, CA. From the North, where the Forest borders the southernmost portion of Capitan Grande Indian Reservation; fuels treatments would extend south approximately 150 feet along either side of Anderson Truck Trail on NFS and private lands till its nexus proximately 0.75 miles north of Victoria Road. To the east of Alpine, a second fuelbreak would occur on NFS and private lands bordering the southern extent of existing dwellings from Viejas Creek Trail east to Star Valley Road. Lastly, in the southern portion of the project area a continuous fuelbreak would be constructed along the ingress into the community of Carveacre tying into an existing fuelbreak, currently in need of continued maintenance, that surrounds the community. The proposed fuel treatments would serve to reduce potential of future wildfire behavior and its effects. The expected result of reduced fire behavior in this area would be increased public and firefighter safety during a wildfire event, improved opportunities for strategic deployment of firefighting resources, and lowered risk of structure loss in the event of a wildfire moving into these rural communities.

Although the Forest Service is not authorized to treat lands outside its administrative boundaries, including these non-NFS lands in this analysis would allow for expenditure of federal funds through existing agreements with local fire safe councils (FSC). The FSC’s would then work with these landowners to treat hazardous fuels adjacent to NFS lands. This action allows for fuels to be treated in the most strategic of settings to increase efficacy of wildland fire suppression tactics in close proximity to structures and roads.

1.5 Decision Framework This EA discloses environmental effects of the no-action alternative and the three action alternatives. The Responsible Official, the Descanso District Ranger, will make a decision based on the review of the EA. The District Ranger’s decision will include: 1) whether to proceed with one of the action alternatives or the no-action alternative and 2) whether the decision that is selected would have significant impacts. If a determination is made that no impact would be significant, then a “Finding of No Significant Impact” (FONSI) would be prepared. Significant impacts would require the preparation of an Environmental Impact Statement [40 CFR 1501.4 (c) and (e)].

The District Ranger’s decision will be documented in a separate Decision Notice (Forest Service Handbook, 1909.15 - 40).

1.6 Public Involvement On October 8, 2014, a letter soliciting interest for a pre-planning field trip was mailed to 79 potentially interested or affected agencies, organizations, and persons, as well as representatives from thirteen Native American Tribes. On October 24, 2014, Forest Service representatives along with 5 attendees representing the Alpine Fire Safe Council, Viejas Fire Department, and Chaparral Lands Conservancy visited proposed project areas to discuss purpose, need, methods, locations, and extent of proposed treatments on the landscape.


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This action was subsequently listed as a proposal on the Cleveland National Forest Schedule of Proposed Action (SOPA) in November 2014. No comments were received in response to the SOPA listing. A legal notice initiating a 30-day public scoping period was published in the San Diego Union Tribune on November 18, 2014. Additionally, a scoping letter containing a description and location of the proposed action was published online and sent to 81 potentially interested or affected agencies, organizations, and persons; including San Diego Regional Water Quality Control Board, Cal Fire, US Department of Fish and Wildlife Service, local fire safe councils, The California Chaparral Institute, Sierra Club, and private land owners that intersected or shared boundaries with the project area. Five comment letters were received during public scoping.

Native American Tribal consultation was conducted in conjunction with the public scoping period. One non-federally recognized and twelve federally recognized tribes were scoped over the course of the 30-day period. One comment letter was received during tribal consultation.

Forest Service responses to all comments can be found in Chapter 5. 1.7 Issues Issues serve to highlight the effects or consequences of a proposed action, giving opportunities during the analysis to identify alternatives, reduce adverse effects, and/or develop mitigation measures. Issues are separated into two groups: significant and non-significant. Non-significant issues are those that are:

1. Outside the scope of the proposed action.

2. Already decided by law, regulation, Cleveland National Forest LMP, or other higher level decision.

3. Irrelevant to the decision to be made.

4. Conjectural and not supported by scientific or factual evidence.

5. Substantially addressed or mooted by project design, standard agency protocols, or mitigation measures.

Based on internal and external scoping, the interdisciplinary team developed the following list of issues (with examples from public comments) that warranted analysis in this EA to determine their significance and contribute to project design:

• Biological Resources, e.g. Endangered and sensitive plant species in or adjacent to project area, increase in invasive plant species.

• Cultural Resources, e.g. Cultural survey had not been completed in this area prior to project initiation, potential for disturbance or destruction to unknown historic and cultural resources

• Soil and Water; e.g. Potential for fuelbreak to increase OHV activity, lead to compaction, increased erosion, and degradation of water quality.

• Fire and Fuels, e.g. Provide information on treatment effectiveness.

• Air Quality, e.g. Effects of smoke from prescribed burning may have on local communities.

1.8 Plan Conformance The Alpine Community Defense Project is consistent with the Cleveland National Forest Land Management Plan (LMP) and directly aligns with the following strategies and tactics from Part 2:

Fire 2 - Direct Community Protection


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• Reduce the number of high and moderate risk acres by using both mechanical treatments and prescribed fire. Identify and schedule for treatment the high risk acres near communities, including the installation of Wildland/Urban Interface Defense and Threat Zone vegetation treatments. Highest priority should be given to those areas with substantial drought and insect-killed vegetation that present a significant threat to life and property in entire communities.

Fire 5 - Fuelbreaks and Indirect Community Protection

• Maintain the existing system of fuel breaks to minimize fire size and the number of communities threatened by fire. On land outside of wilderness or other special designations consider the construction of new fuel breaks.

FH 3 - Restoration of Forest Health

• Protect natural resource values at risk from wildland fire loss that are outside the desired range of variability, or where needed for wildlife habitat improvement: Manage chaparral in selected locations to protect the life and property of human inhabitants (e.g., the urban interface), to improve wildlife forage, and to protect watersheds from the impacts of large, high intensity fires.

Additionally, the project was designed in conformance with the Sweetwater Place Management Area direction which, again, emphases, “Reduce the danger of fire and floods by managing vegetation in community threat zones.” Treatment units are further contained within Developed Area Interface and Back Country Motorized Use Restricted land use zones within the management area where suitable activities include Fuelbreak Construction including Type Conversion.

Furthermore, treatment units fall within the wildland urban interface defense or threat zone as defined by the LMP.

Chapter 2: Alternatives 2.1 Alternative 1 – No Action Under the no-action alternative, no hazardous fuels reduction or vegetation maintenance activities would be implemented. Fuel loading, vegetation types, and current ecosystems would persist in their existing conditions, as described in section 1.3 Purpose and Need on page 2.

2.2 Action Alternatives – Elements Common to Action Alternatives The proposed suite of hazardous fuels reduction treatments for all action alternatives are the same. The alternatives differ in unit size, location, and land ownership status (Table 1, p. 8). Units were carefully selected and specific treatments for each unit were determined through the collaboration of Forest Service fire management and resource specialists.

Treatments proposed for the three action alternatives:

• Initial entry into the mature chaparral vegetation would employ a combination of the following treatments: hand cutting, hand piling, and/or mastication using tracked or tired equipment, followed by prescribed fire through pile or broadcast burning. Masticator work would be completed with an excavator-mounted mastication attachment.

• Units would receive treatments not to exceed 300 feet wide.

• Mechanical treatments would generally occur on slopes up to 35 percent. Under unusual circumstances, short pitches of up to 50 percent slope could be mechanically treated (Forest Plan, S2).


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• With the exception of scrub oak, no oaks would be intentionally cut unless they are a hazard tree.1

• Targeted grazing would only occur on units 10 through 15 adjacent to the community of Carveacre.

• A triclopyr-based herbicide (ex. Garlon 3a), an herbicide, may be used throughout the project area in an effort to reduce regrowth and extend mechanical and prescribed burning maintenance cycles in future years. Design criteria are included to minimize effects to non-target species in all units.

• For initial mastication and hand cut treatments, 60 to 80 percent of the vegetation would be treated, leaving untreated islands of shrubs generally no greater than 0.25 acres in size. These islands would have undulating edges to provide a natural appearance. If possible, the retained islands would consist of differing plant species to maintain plant species diversity.

• If treatment units are masticated or chipped, the residual material would be generally three to five inches in depth and continuous over 25 percent of the treatment unit. A follow-up prescribed broadcast fire would occur only under conditions specified in the design features.

• Obligate reseeding shrub species would be avoided for multiple treatment methods (e.g., mastication and prescribed broadcast burning). These species in particular would be purposefully retained in untreated islands.

• In prescribed burn treatments, the objective would be to treat 60 to 80 percent of the vegetation.

• Firelines would be constructed where natural barriers and roads do not exist to provide control locations for prescribed fire activities and to allow access for ground-based ignition and holding crews. These lines would be constructed by hand. A full range of aerial and ground-based ignition equipment and firing patterns may be used to meet these objectives, but typically, ignition would be completed by hand (i.e., drip torches).

• Key areas of young coast live oaks would be avoided during mastication and prescribed burning.

• Proposed treatments would begin with initial treatments and be followed by maintenance to ensure effectiveness and sustainability of fuelbreak objectives. Various treatment methods would be implemented or withheld, based on the results and successes of achieving objectives. Monitoring and data collection would be used throughout all project phases to guide decisions for treatment implementation.

Initial Treatment:

• Hand cut and pile activity fuels or masticate the existing fuel bed.

• Pile burn or broadcast burn the activity fuels.

• A triclopyr-based herbicide would be applied to the young sprouting woody vegetation to limit regrowth. The herbicide would be mixed to label specifications for foliar applications with a modified seed oil surfactant and a marker dye. The herbicide formulation would be applied using backpack sprayers with a targeted application to re-sprouting perennial woody species that were cut or masticated. The application would occur during the mid- to late summer, the active growing season for perennial woody species, but after many desirable native annual plant species have completed their life cycle.

1 A tree is considered hazardous (by the District’s definition) if it has defects that may cause a failure resulting in property damage, personal injury or death. It must have a structural weakness and something to hit if it falls.


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Maintenance Treatment:

• Maintenance with triclopyr could be introduced as soon as three years after initial application and may be reapplied at a three to five year interval to cut stumps and/or leaves of targeted species as warranted by regrowth in each unit.

• Maintenance with targeted grazing could be introduced two years after initial treatment and could be repeated every two years. Grazing would not follow herbicide application in the same season.

• Maintenance with hand cutting and piling of activity fuels or mastication followed by prescribed fire could be begin three to five years after initial treatment and could be repeated every three to five years as warranted by regrowth in each unit.

2.3 Action Alternatives – Differences among Action Alternatives

The differences among action alternatives involve scale and location of units treated across National Forest System lands and private lands. Differences are described below for each alternative, summarized in Table 1, and shown in the following project area maps as Figures 1, 2, and 3.

2.3.1 Alternative 2 Alternative 2 was developed to create a continuous fuelbreak system that is restricted to National Forest Service Lands only. Hazardous fuels reduction treatments would occur on 361 acres of Cleveland National Forest Lands.

2.3.2 Alternative 3 – Proposed Action The proposed action alternative was developed to create a continuous fuel break across more favorable terrain and proximity to structures than Alternative 2, encompassing private land in addition to Forest Service land. Although the Forest Service itself is not authorized to perform treatments on private lands, including it in this EA would enable federal funding for the Fire Safe Council or other organizations to carry out treatments if authorized by landowners.

Treatments are proposed for 457 acres, with approximately 144 non-NFS acres and 313 Cleveland National Forest acres.

2.3.3 Modified Alternative 3 – Preferred Alternative The Proposed Action treatment units were modified during the analysis phase of the project following scoping to account for two challenges. First, the fuelbreak proposed to extend south of Anderson Truck Trail towards Interstate 8 presented multiple difficulties, including presence of several populations of endangered and sensitive species, overlap with the San Diego County Multiple Species Conservation Plan area, presence of biological conservation easements on the private parcels, potential need for a county clearing permit for this area, potential for a new fuel break to promote OHV activity, and conflict with LMP direction regarding fuel break construction associated with new or proposed developments.

Secondly, some private property owners refused to grant permission for fuels management treatments to occur on their lands.

Proposed units were removed in whole, or reduced in size to mitigate for the above factors.

Treatments are proposed for 389 acres, with approximately 90 non-NFS acres and 299 Cleveland National Forest acres.


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Table 1. Detailed Treatment Index

Unit ID

LocationLand

OwnershipVegetation

TypeNew or Exisitng

FuelbreakMechanical Treatment

TypeHerbicide

AuthorizedPrescribed

Fire*Targeted Grazing

Maintenance Required**

Alt 2 - Acres

Alt 3 - Acres

Alt 3M -Acres

1Anderson Truck Trail

FS Chaparral New Hand Cut & Pile Y Y N Y 13 13 13


NON-FS Chaparral NewHand Cut & Pile OR

MasticateY Y N Y 3 3


FS Chaparral NewHand Cut & Pile OR

MasticateY Y N Y 25 25 25


NON-FS Chaparral NewHand Cut & Pile/Chip

OR MasticateY Y N Y 12 12


FS Chaparral NewHand Cut & Pile OR


6AAnderson Truck Trail

FS Chaparral New Hand Cut & Pile Y Y N Y 48 12 12

6BAnderson Truck Trail


OR MasticateY Y N Y 52

6CAnderson Truck Trail

FS Chaparral NewHand Cut & Pile/Chip


6DAnderson Truck Trail



7 Sweetwater FS Chaparral NewHand Cut & Pile OR


8 Sweetwater FS Chaparral NewHand Cut & Pile OR


9A Sweetwater FS Chaparral NewHand Cut & Pile OR

MasticateY Y N Y 28

9B Sweetwater NON-FS Chaparral NewHand Cut & Pile/Chip

OR MasticateY Y N Y 48 51

10 Carveacre NON-FS Chaparral NewHand Cut & Pile/Chip

OR MasticateY Y Y Y 10 10

11 Carveacre FS Chaparral NewHand Cut & Pile/Chip


12 Carveacre NON-FS Chaparral NewHand Cut & Pile/Chip


13 Carveacre FS Chaparral NewHand Cut & Pile OR

MasticateY Y Y Y 9 9 9

14 Carveacre FS Chaparral ExistingHand Cut & Pile OR

MasticateY Y Y Y 155 155 155

15 Carveacre FS Chaparral Existing Hand Cut & Pile Y Y Y Y 28 28 28

* Pile burning or understory burning may be employed to meet fuels objectives. = Not Included in Alternative** Maintenance may consist of mechanical treatment, prescribed burning, grazing, herbicide application , or any combination there in.


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Figure 1. Treatment unit locations – Anderson Truck Trail


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Figure 2. Treatment Unit Locations – Sweetwater


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Figure 3. Treatment Unit Locations - Carveacre

Alpine Community Defense Zone Project Draft EA Cleveland National Forest, Descanso Ranger District

2.4 Design Features Design features were developed to decrease potential adverse impacts the action alternatives could otherwise cause.

2.4.1 General Wildlife WLD-1 Protect known active or inactive raptor nest areas from project activities. A no-

disturbance buffer around active nest sites would be required from nest-site selection to fledging (Forest Plan S18). This buffer would vary by species but typically ranges from 100 to 300 feet.

WLD-2 In Riparian Conservation Areas (RCA): Within the perennial streams’ 328-foot buffer and intermittent streams’ 100-foot buffer, no cutting/removal of riparian plant species (i.e., willow, coast live oak) would be allowed.

2.4.2 Terrestrial Wildlife Species Migratory Birds

TWS-1 Avoid adverse impacts to nesting birds per Migratory Bird Treaty Act (MBTA), by avoiding treatment activities during bird breeding season (March 15 to September 15) whenever practicable. If work is performed during the breeding season and the Forest biologist feels it is necessary, a walk through survey would be performed by a qualified biologist to identify obvious nests prior to undertaking work. If active nests are located, appropriate exclusionary buffers would be established.

2.4.3 Botany Regional Forester’s List of Sensitive Plant Species (Forest Service Sensitive)

BOT-1 Areas with known sensitive species at Anderson Truck Trail, southwestern most leg of Carveacre fuelbreak, and northwestern corner of Carveacre fuelbreak would be excluded from grazing treatments; sites would be flagged for avoidance prior to unit treatments.

BOT-2 Triclopyr would not be used within sensitive plant species occurrences. Known occurrences would be shown to workers on the ground and/or flagged by a Forest Service Representative prior to spraying.

BOT-3 Where needed, brush barriers would be retained along roads to prevent off-highway vehicle (OHV) activity on the fuelbreaks. This would also help deter the spread of weeds into fuelbreak areas. Pipe rail barriers would be installed as needed to prevent OHV use of the fuel break; this is a known problem along Anderson Truck Trail.

BOT-4 Isolated clumps of oaks and bigberry manzanita (Arctostaphylos glauca) within the project area would be excluded from treatments. These shrubs would not be masticated, and an area around them would be cleared to protect them from damage during prescribed burning.

2.4.4 Threatened, Endangered, and Candidate Species TES-1. Spiny Redberry (Rhamnus crocea) within the project area would be excluded from treatment

to protect this host plant for Hermes Copper butterfly. This would include areas near Anderson Truck Trail, areas in the eastern part of the Viejas Creek fuelbreak, and an area in the southwestern corner of the Carveacre fuelbreak near the power line. See the specialist report for locations (USDA Forest Service 2016a).

TES-2. The San Diego Thornmint population at Anderson Truck Trail would be avoided by constructing the fuelbreak such that it does not overlap with known and potential habitat for


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this species. There would be at least a 100-foot buffer between the occupied habitat and the fuelbreak, which would be marked with flagging prior to fuel break construction or maintenance.

TES-3. Barriers would be installed to prevent OHV activity within the occupied San Diego Thornmint habitat, and the effectiveness of the barriers would be monitored at least twice per year.

TES-4. Quino Checkerspot occupancy is assumed for all treated fuel break areas. For new fuelbreaks (Anderson Truck Trail and Viejas Creek), the current condition of the area is dense chaparral which is not suitable habitat for Quino, so these areas would not be assumed occupied until after the initial fuels treatment. To protect Quino Checkerspot, fuels treatments and broadcast burning would occur in suitable Quino habitat between July 01 and February 28.

TES-5. Fuel break maintenance activities would retain as much litter/ground cover as feasible to reduce the spread and abundance of non-native plant species.

2.4.5 Invasive Plant (Weed) Species WEED-1 All off-road equipment used would be washed before moving into the project area to ensure

that the equipment is free of soil, seeds, vegetative material, or other debris that could contain or hold seeds of invasive plant species. “Off-road equipment” includes equipment, such as masticators and chippers; it does not include chip vans, service vehicles, water trucks, pickup trucks and similar vehicles not intended for off-road use. Equipment would be considered clean after six minutes of washing.

WEED-2 A combination of natural barriers (e.g., rocks, logs, and vegetation), screening and fencing would be used, as required, to prevent/discourage illegal OHV activity and unauthorized recreation (i.e., user-created trail establishment) from occurring during and after the project treatment. Coordination with adjacent landowners, public education and signing would be used as appropriate.

WEED-3 Staging areas for equipment, materials, or crews should be located in areas that have been previously disturbed or are degraded habitat. If treatment activities allow, mulched vegetation may be spread in staging areas after use to inhibit growth of non-native annual grasses.

WEED-4 Before goats are brought in for targeted grazing within the project area, they should be held in quarantine, depending on the origin of the herd, until such time as any seeds from invasive species not already present in the project area would have passed through the intestinal tract of all animals in the herd.

2.4.6 Heritage HER-1 Identified cultural resources within the project area would be flagged for avoidance by a

qualified archaeologist to include a buffer zone of approximately 10 meters around the outside of the boundary of each site. Potential ground disturbing activities prohibited within the buffer zone include use of masticators, targeted grazing, hand piling, and pile burning.

HER-2 At the discretion of the Heritage Program Manager (HPM), certain hazardous fuels treatments may be authorized within site boundaries as long as appropriate on-site historic protection measures are applied.

HER-3 Ground disturbing activities conducted in the vicinity of areas to be flagged and avoided may also be periodically monitored by a qualified archaeologist during project implementation in order to ensure there are no inadvertent effects to historic properties and to enhance the effectiveness of protection measures. The results of any monitoring inspections shall be documented in cultural resources reports and submitted to the HPM.


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HER-4 The Viejas Band of Kumeyaay Indians would be adequately notified prior to any implementation of proposed vegetation management activities in the Viejas Creek or Anderson Truck Trail portions of the proposed project area in order that they or their designated representative may conduct cultural resource monitoring of those activities at their discretion.

2.4.7 Watershed HYD-1 Areal extent of detrimental soil disturbance would not exceed 15 percent of the area

dedicated to growing vegetation. Soil cover would be maintained at levels at least 50 percent of the soil surface in upland area and at least 71 percent in the Riparian Conservation Areas (RCA) (98 feet for intermittent streams and 50 feet for ephemeral streams). Soil cover would consist of rocks, litter, organic matter, low-growing plants, and woody debris. (FSH 2905.18; Veg-2)

HYD-2 Mechanical equipment use (masticator) would require dry soil conditions during project implementation to prevent soil compaction, rutting, and disturbance. (Veg-2; Veg-8)

HYD-3 Mechanical equipment operations would be limited to slopes less than 35% (Veg-2, Veg-8)

HYD-4 No mechanical treatment is permitted within 98 feet of intermittent channels while mechanical equipment is permitted in ephemeral drainages. It is preferable that mechanical crossings of ephemeral drainages be limited and conducted perpendicular to the stream course. (Veg-3)

HYD-5 Prescribed fire could be backed into the RCA. No broadcast burn ignitions would occur within RCAs. (Fire-2, Veg-3).

HYD-6 Hand piles would not be placed in or within 98 feet of an intermittent channel and 50 feet of an ephemeral channel. (Fire-2, Veg-3)

HYD-7 Hand piles would not exceed 15 percent of an area dedicated to growing vegetation. (FSH 2905.18; Fire-2)

HYD-8 Firelines constructed for project implementation would be rehabilitated following project implementation (prescribed burn). Rehabilitation on the fireline includes: pulling back and spreading out berms, and spreading of bush and ground cover across the fireline. (Fire-2)

HYD-9 Water bars or lead out ditches may be constructed in firelines to minimize erosion. Water bars or lead out ditches would be installed according to the following recommended minimum intervals (Fire-2)

Table 1. Recommended minimum interval guidelines for the installation of waters bars.

Fireline Gradient

(% slope)

Distance Between Water-Bars

(feet) (chains)

0 to 5 no water-bars needed no water-bars needed

6 to 15 200 3

16 to 30 100 1.5

31 to 49 75 1

> 50 50 0.5


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HYD-10 Mechanical equipment refueling would occur outside of the RCA and would have spill containment measures in place during operations. For small quantities (5 gallons or less), fueling of gas-powered machinery would not occur within 25 feet of any body of water or stream channel to maintain water quality. (Road-10).

HYD-11 The Herbicide Transportation, Handling, and Emergency Spill Response Plan and spill kit would be on-site when herbicide treatment methods occur. The Plan would include reporting procedures, project safety planning, methods of clean-up of accidental spills, and information including a spill kit contents and location as noted in Forest Service Manual (FSM) 2150, Pesticide-Use Management and Coordination and Handbook (FSH) 2109.14, Pesticide-Use Management and Coordination Handbook. (Chem-1).

HYD-12 Herbicide containers must be secured and prevented from tipping during transport (Chem-5).

HYD-13 Equipment used for transportation, storage, or application of herbicides would be maintained in a leak-proof condition. (Chem-5).

HYD-14 To reduce the potential for spills, impervious material, such as a bucket or plastic, would be placed beneath mixing areas in such a manner as to contain any spills associated with mixing/refilling. (Chem-5).

HYD-15 Immediate control, containment, and cleanup of fluids and herbicides due to spills or equipment failure (broken hose, punctured tank, etc.) would be implemented. All contaminated materials would be disposed of promptly and properly to prevent contamination of the site. All hazardous spills would be reported immediately to the Forest Hazardous Spill Coordinator. (Chem-5).

HYD-16 Herbicide usage would be limited to the minimum amount required to be effective. (Chem-1; Chem-2; Chem-3).

HYD-17 Unless prior approval is obtained from a Forest Service hydrologist or biologist; mixing and loading of herbicide(s) would take place a minimum of 150 feet from any body of water or stream channel. (Road-10; Chem-5).

HYD-18 Herbicide spray equipment would not be washed or rinsed within 150 feet of any body of water or stream channel. All herbicide containers and rinse water would be disposed of in a manner that would not cause contamination of waters (Chem-5).

HYD-19 No application of herbicides would occur within 10 feet of streams (Chem-3).

2.4.8 Herbicide

All herbicides would be used according to the design features listed below to minimize negative effects on soils, water, and non-target species.

HERB-1 Herbicides would be applied using hand sprayers or backpack sprayers, potentially with daubing attachments. No aerial application of herbicides would occur. All herbicide application would adhere to all applicable Federal laws and laws of the State of California and San Diego County.

HERB-2 The herbicide would be mixed to label specification with a modified seed oil (MSO) surfactant and marker dye.

HERB-3 Herbicide applications on woody perennial species would occur in the mid- to late summer when plants are translocating nutrients from the leaves to the root systems. This increases the likelihood of initial success and would result in reduced need for follow up treatment. This season also avoids critical breeding seasons for many wildlife species and flowering seasons


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for many native plant species. In addition, this time of year is also a time of reduced stream flows and limits the accidental introduction of herbicides to surface waters.

HERB-4 Where treatment areas occur adjacent to trails or other public use areas, short-term trail closures may occur.

HERB-5 No foliar spray activities would be allowed if wind velocity is expected to exceed five miles per hour.

HERB-6 No herbicide treatments would be allowed when rain is occurring or likely to take place within 48 hours.

HERB-7 Herbicides would not be applied directly to surface waters. Treatments would be timed to minimize the potential for introduction of herbicide to surface waters. When a target species occurs adjacent to surface waters care would be taken to prevent herbicide drift to surface waters, including trimming and folding of plants away from waters.

HERB-8 Work crews would be supervised to ensure that specific safety practices are followed. These practices include the use of appropriate protective clothing. Clean water and soap would be available for emergency washing.

HERB-9 Notification would be given to landowners bordering application area providing information about the nature and dates of applications.

HERB-10 At least a 100-foot buffer would be in place between occupied Acanthomintha ilicifolia habitat and areas where triclopyr is used, and at least a 10-foot buffer would be in place between redberry (Rhamnus crocea) shrubs and areas where triclopyr is used.

Chapter 3: Environmental Consequences 3.1 Fire and Fuels Existing vegetation communities in the project area at Anderson Truck Trail, Sweetwater/Viejas, and the community of Carveacre consist of young to mature chaparral ecosystems. The dominant species is chamise, with lesser amounts of typical cohorts including buckwheat, white sage, and other herbaceous species. Dates from previous disturbance, typically wildfire, tend to make up for differences in stand age and fuel bed depth across the treatment areas. Treatment units around the Anderson Truck Trail were burned in the 2003 Cedar fire, resulting in 13 year old fuels. Sweetwater/Viejas had portions of the treatment units burn in the 1970 Laguna fire, with a small portion consumed again in the 2001 Viejas fire; resulting in 13 to 46 year old fuels. As a result of recent fuels modification treatments around the community of Carveacre, fuels are 2 to 4 years old. Associated fuel bed depths are four, six, and three feet, respectively.

With the exception of Carveacre, current pre-treatment fuels conditions when modeled under a wildfire scenario, produce flame lengths 7 to 17 feet in height with fireline intensity measured in British thermal units per square foot (BTU/sqft) from 414 or 2,805 BTU/sqft. To put this in more relative terms, one four inch wooden kitchen match consumed completely by fire generates approximately 1 BTU.

Proposed fuels treatments, as observed in Carveacre, would initially reduce the current fuel bed depth to 8 inches, with estimated regrowth of up to 18 inches in total height between treatment intervals. Treatments would also convert areas over time from shrub lands to native and non-native grass lands. When modeled under this scenario, flame lengths lowered to between 3 and 5 feet, with an associated fireline intensity of between 62 and 184 BTU/sqft, respectively.


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According to the Surface Fire behavior Fire Characteristics Chart (also known as the Hauling Chart) (Andrews and Rothermel 1982), which shows the limit of fire suppression tactics utilizing direct attack, flame lengths under 6 feet are able to be successfully attacked with fire engines (hoses), which is the primary suppression tactic of Southern California fire agencies. Therefore, maintaining the vegetation at a fuel bed depth less than 18 inches would achieve the direction spelled out in the LMP as well as the Purpose and Need for this project.

3.1.1 Alternative 1 – No Action

Direct and Indirect Effects

This alternative would not treat any portion of the fuel profile. It would not directly increase surface fuel loads and the arrangement of fuels would not change. Over time, however, chaparral canopy would continue to expand across the project area. This alternative would exacerbate the potential for damage to occur during a wildland fire since no areas of strategic vegetation reduction was created. Effects of wildland fire in Southern California always have the potential to be severe as natural resources, improvements, and communities would continue to be threatened.

Under this Alternative, emergency response personnel would find it difficult to implement fire management directions for direct control and perimeter control strategies during any normal or extreme fire weather/fuels conditions. This alternative would not alter the fuel beds or fire behavior. Therefore, it would not affect rates of spread or lower fireline intensity to provide fire personnel with the advantage during initial or extended attack. In the long term, emergency fire responders would be faced with an even greater challenge in implementing LMP direction for direct attack due to the increased recruitment of fuels.

Cumulative Effects

The cumulative effects of the no action alternative are based upon a continuation of the current process of abnormally high recurrence of wildland fire on the landscape, and the potential impact to natural and anthropogenic values at risk. With no action, vegetation occupying strategic areas would continue to increase until disturbance occurs. This disturbance would most likely be wildfire. Damage to the ecosystem that is occurring across Southern California would continue to occur; as well as potential impacts to human infrastructure. Soil structure degradation, seed bank destruction, multi-species habitat loss, and invasion of non-native plant species are likely results of this eventual disturbance.

Other cumulative effects include increased suppression costs for future wildfires (if unable to be stopped early), and increased risk to firefighters due to limited operational areas to engage the fire. As the fuel load remains unabated in areas that could serve to be strategic in nature, fighting the fire would require more resources and would have potential exhibit more extreme fire behavior. Both of these factors increase the cost and risk of fire suppression.

Additionally, under the no action alternative, the cost of future fuels reduction activities would be increased. If the no action alternative is selected now, fuels would continue to increase. If a fuels reduction project is proposed later, the financial cost would be greater in proportion to the additional fuel that would exist then as compared to now.

3.1.2 Alternative 2, 3, and Modified 3 – Fuelbreak Construction and Maintenance

Direct Effects

The direct effects of Alternatives 2, 3, and Modified 3 would be a change or maintenance of vegetative cover type and amount, within the project area boundary. Effects would differ in that Alternative 2 limits vegetation modification to NFS lands only, whereas Alternative 3 and Modified 3 authorize federal funding to modify vegetation cover types on private lands adjacent to proposed treatments on federal lands thus creating a continuous linear reduction of vegetation across the most favorable terrain.


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All treatment areas are dominated by chaparral vegetation, although all areas do possess smaller areas of oak overstory. Areas of oak would not be substantially modified and therefore are not included in this analysis. Chaparral vegetation and associated cohorts would be mechanically severed, burned, grazed, and/or treated with herbicide in order to reduce the overall cover height to no more than 18 inches in height. Additionally, fine fuels such as grasses and forbs would be favored over woody species such as chamise and ceanothus. Direct effects include a change in the existing fuel model from a shrub-dominated one to a grass-dominated one. Although fireline intensity and potential flame lengths would decrease, rate of spread may potentially slightly increase under favorable fire weather conditions.

The positive direct effects of this treatment are the creation of a zone of vegetation that is inherently safer for firefighters to operate within. This zone of reduced vegetation could be used tactically to place a fireline, as a prepared fuel bed for offensive and defensive firing operations, and as an area where aerially-applied retardant would be more effective than when applied to standing chaparral. These positive effects would be felt to a lesser extent with Alternative 2 as treatments would not authorize federal funding for treatments on private lands. This would result in the creation of a discontinuous fuelbreak, in the case of the north half of Anderson Truck Trail and the ingress into Carveacre, where zones of untreated fuels capable of producing higher flame lengths and fireline intensities would still exist. Additionally, in south half of the Anderson Truck Trail and adjacent to the Sweetwater/Viejas community, fuelbreaks would be located away from structures at risk thus leaving untreated fuels in proximity to the community and lessening access to firefighters and equipment.

The effectiveness of firefighting efforts in the wildland/urban interface is driven by mostly flames lengths and secondarily by rates of spread. Firefighters can usually direct attack portions of fires with up to 4 foot flame lengths by constructing hand-lines, burning out where needed and holding. Flames lengths from 4 to 8 feet are too intense for direct attack by firefighters using hand tools. Hand-lines cannot be relied on to hold fire. Equipment such as dozers, engines, and retardant aircraft that support hand crews can be effective. Flame lengths from 8 to 12 feet may present serious control problems. Control efforts at the head of the fire would probably be ineffective. When chaparral vegetation is dry enough, under dry and windy weather conditions the chaparral burns as a crown fire. Nearby tall chaparral poses the greatest risk to homes because under 90th percentile burning conditions in areas that have not had recent treatment or fire, flame lengths would exceed 4 feet. Also, fire ember production would be very high and these embers would cause spotting into yards and onto homes igniting flammable plants, yard furniture, storage items, and flammable portions of homes – wood porches and decks, shake roofs, "ember eddy traps" and possibly get into attic spaces through roof vents.

To a lesser extent the surrounding vegetation extending several hundred feet (Merriam 1999) may also be impacted due to weed infestation, and is more appropriately considered an indirect effect.

The goal of herbicide application would be to increase the interval between required maintenance of woody species within treatment areas.

Indirect Effects

The indirect effects of treatments proposed under Alternatives 2, 3, and Modified 3 would vary depending on weather conditions and fire behavior during a wildland fire event. Indirect effect would also be incurred on other natural resource related (wildlife, water, air, etc.) concerns, but could be mitigated in part by Modified Alternative 3 which provides for a continuous zone of modified vegetation in close proximity to structures at risk while taking into account other natural resource related concerns as previously described above.

Indirect effects of fire and fuels management relate to how a fire may interact with the proposed project areas in a longer timeframe than immediately after a fire, or as having an unforeseen outcome. Possible effects include fires passively stopping at the break in fuels, fire accelerating through the finer fuel bed, fires being halted by direct fire suppression activities, or fire suppression activities failing to succeed at


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the intersections of the proposed project areas. All of these outcomes would depend on timing of fire suppression actions, coupled with ambient weather and fuels conditions.

Additionally, by not authorizing federal funding to treat adjacent private lands, as in Alternative 2, the fuelbreak may not be placed in the most strategic location in terms of topography and proximity to structures and in the case of Anderson would leave “islands” of untreated fuels within the fuelbreak perimeter which would require indirect fire suppression tactics leaving a chance for an increase in fire sizes.

The intended indirect effect of the preferred alternative, Modified 3, is that fires burning under normal fire season (not under Santa Ana wind events) would be able to be engaged at strategically placed points with positive results.

During extreme weather conditions, these alternatives would yield localized reduced fire behavior effects within treated units, which may or may not contribute to an effective result for fire suppression efficacy and safety.

Cumulative Effects

The cumulative effects of Alternatives 2, 3, and Modified 3 are similar in that the desired end state of vegetation is reduced in quantity and density. Fuels within the Anderson and Carveacre treatment areas would continue to be modified as they have for numerous years. The Anderson fuelbreak in particular has been in some state of modification for many years. The Carveacre fuelbreak area has been thinned and burned within the last three years, and was partially burned in 1970. Portions of the Viejas/Sweetwater fuelbreak were burned in 2001.

The cumulative effects are that fuels would continue to be in an altered state of vegetative growth for the foreseeable future. The natural successional pathways, within the treatment area and slightly beyond, would be interrupted from a natural trajectory. If maintained continually, there may be a loss of presence of characteristic species within the treatment area. The likely result would be an increase in non-native grasses and forbs in place of woody chaparral species and associated cohorts. Non-native species would likely spread within and adjacent to the treatment areas.

3.2 Human Health and Safety This section analyzes the potential human health and safety impacts resulting from the use of Triclopyr, a broadleaf-specific herbicide, and its potential toxicity to residents, recreationists and workers. Herbicide treatments would be used in conjunction with mechanical and prescribed fire treatments to reduce costs and increase time between treatments intervals associated with maintenance for ensuring fuelbreak effectiveness.

Affected Environment

Two groups of people might be affected by this project: workers who are performing fuels treatment activities and members of the general public.

Contractors would most likely perform fuel treatment activities for the Cleveland National Forest. Herbicide application would occur under the supervision of a licensed pesticide applicator.

Members of the general public who might be affected by project-related activities include recreationists and residents adjacent to fuel treatment activities. These groups or individuals would likely be in the project areas on a short-term basis. The time frames could vary from several hours to extended amounts of time in areas near treatment sites for the adjacent landowners.

Environmental Consequences

The criteria for significance of impact in relation to human health and safety from herbicide use are discussed in detail in the USDA-Forest Service Forest National Risk Assessment for the herbicide being


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proposed. The risk assessment uses widely accepted levels of exposure, both chronic and acute, to toxic chemicals that are deemed to present a human health risk. As is customary in human health risk assessments, these assumptions are highly conservative and represent exposures generally 100 times less than exposures that produced detectable negative effects in lab settings. The Risk Assessment then develops exposure scenarios for workers and for the general public to determine if it is possible that a person may be exposed to a level of the herbicide that may present a health risk.

The routes of exposure analyzed for workers included contact with herbicides through application spray activities and through accidental exposure (spills on bare skin, contaminated gloves etc.) For the general public, routes of exposure analyzed by the risk assessment included a direct spray on a child, exposure to contaminated vegetation, ingestion of contaminated crops, ingestion of contaminated water or fish, or swimming in contaminated water. Exposure scenarios for the public represent very conservative assumptions that assume exposures much greater than is likely. Therefore, when even under these exposure scenarios, there appears to be negligible or no risk of significant exposure, actual potential exposure risks to the public can be deemed at an acceptable level.

For chronic exposures, chronic reference doses (RfD’s) have been established by the Environmental Protection Agency (EPA) for each herbicide. For example, the dose of 0.05 mg/kg of body weight/day has been determined to be the chronic reference dose, or RfD, for triclopyr. This means that a person could receive a dose of 0.05 mg/kg/day throughout every day of his or her life without suffering adverse health effects. Short-term or acute excursions above the chronic RfD can occur without any known adverse health effects.

Due to the limited time frames of this project, acute exposure scenarios are more likely. The risk assessments use established numbers for the amount herbicide in a single dose which may cause health effects. For example, for triclopyr, the acute RfD is the same as the chronic dose, 0.05/mg/kg of body weight/day for women (0.1/mg/kg for men) and for TCP, its main intermediate metabolite, the value is 0.025 mg/kg/day.

The risk assessment also looked at “inerts” and adjuvants that are found in common herbicide formulations and tank mixes to determine if they may cause human health and safety risks at the use levels being proposed.


The human health and safety effects of the no action alternative are related to resident and firefighter safety in the case of a wildfire impacting the rural communities of the greater Alpine area in eastern San Diego County. These effects are addressed in the previous section.

3.2.2 Alternative 2, 3, and Modified 3 – Fuelbreak Construction and Maintenance

Direct Effects

Exposure to herbicide ingredients and their metabolites is the primary concern for human health and safety in these alternatives. Under these alternatives, exposure to herbicide would mainly be a concern for workers in the project area applying the chemicals and members of public hiking in recently treated areas. This project would occur adjacent to private residences. Exposure of the general public to herbicides would likely only result from exposure to vegetation that has been recently sprayed. Most treatment areas are not heavily trafficked by members of the public.

Triclopyr: Triclopyr is considered moderately toxic to humans, while TCP is slightly more toxic than triclopyr. Routes of exposure for triclopyr include ingestion and absorption through the skin. For chronic exposure, a dose of 0.05 mg/kg of body weight/day has been determined by the Environmental Protection Agency (EPA) to be the chronic reference dose, or RfD, for triclopyr. For triclopyr, the acute RfD is the same as the chronic dose, .05/mg/kg of body weight/day for women (.1/mg/kg for men) and for


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TCP, the value is 0.025 mg/kg/day. Due to the limited time frames of this project, and the environmental degradation of triclopyr, acute exposure scenarios are more likely.

For the general public, the risk assessment for triclopyr concludes that at broadcast application rates of 1.0 lbs. per acre there are no plausible scenarios for exposure to triclopyr that would cause negative effects in the general public (SERA 2016). Consumption of sprayed vegetation or contaminated fruit, or consumption of water immediately after an accidental spill due result in exposures that exceed levels of concern, but these scenarios are considered implausible. For TCP, GLEAMS modeling shows that no hazardous exposure to TCP would occur as a result of this project, even under very conservative assumptions of a child consuming 1 liter of water per day from a treated creek (SERA 2016).

Under typical exposure conditions for workers there would be no means of reaching a hazardous level of acute exposure to triclopyr (SERA 2016). However, in the case of workers, safety measures need to be in place for workers applying triclopyr for more than three weeks in a row to avoid potentially dangerous chronic levels of exposure (SERA 2016). These safety measures include wearing long sleeve shirts and protective gloves, and washing hands and clothing after each work day. These safety procedures are required by state and local laws and would be used in this project. Using these safety procedures, workers would not be exposed to potentially hazardous acute or chronic exposures to triclopyr.

Non-herbicide related direct effects: Under all action alternatives, work crews would be exposed to typical hazards associated with field work, including heat, insects and snakes, and rough terrain. These hazards would be identified and mitigated as much as possible during the project implementation. Work crews would also be exposed to dangers inherit with using hand tools, especially chainsaws. These dangers would be mitigated with appropriate safety gear and training.

Indirect Effects

No indirect effects on human health and safety are expected. The direct effects section analyzes all routes of potential exposure.

Cumulative Effects

Cumulative impacts to human health from herbicide exposure could come from exposure to herbicides on Forest Service land and also from almost identical herbicide use projects on adjacent city/county/private owned lands. On National Forest System lands, and on adjacent lands managed by other jurisdictions, triclopyr-based products are used for the removal of invasive plant species. Also, over-the-counter herbicide products can contain triclopyr. The direct effects section analyzes longer term exposures to herbicides than workers on the project would be exposed to. Members of the public may be exposed to herbicides on National Forest Service lands and on adjacent lands. These potential exposures (both acute and chronic) are within the scenarios used to analyze the direct effects of this project since these scenarios analyze based on application rates per acre over large project areas.

While this analysis did not research total annual triclopyr use in San Diego County, it is important to realize that the total amount of herbicide used by these projects (both on Forest Service and on lands treated by adjacent jurisdictions) would be undoubtedly a tiny fraction of total herbicide used in the counties. Triclopyr is sold over the counter and used extensively in home and commercial landscaping, golf and park maintenance and other similar applications. All proposed herbicides are available by permit to qualified applicators and also used extensively in commercial and agricultural applications. These uses, occurring nationwide, have not led to identifiable risks to human health from the herbicide being proposed. Therefore it is unlikely this project and similar projects would have a cumulative effect that would lead to significant effects on human health.

3.3 Biological Resources The fuelbreak would be treated with one or more of the following methods: cutting of shrubs by hand with chainsaws, manually piling brush by hand, mastication using tracked or tired equipment, prescribed


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fire by way of pile burning or broadcast burning, manual herbicide application, and/or managed targeted grazing. These activities are expected to reduce the woody vegetation on the fuel break and would have the following effects on plant and wildlife species:

Federally Listed Species

One federally-listed plant species, San Diego Thornmint, occurs in the project area. One federal candidate species, Hermes Copper butterfly, occurs in the project area. Project activities are designed to avoid these species and their habitat, which would avoid direct effects on these species.

Regional Forester’s Sensitive Species List

There are no known locations of Regional Forester’s Sensitive list wildlife species at the project site. Potential habitat for the following sensitive wildlife species may occur within the project area: San Diego Ring-necked Snake (Diadophis punctatus similis), San Diego Horned Lizard (Phrynosoma coronatum blainvillii), Coastal Rosy Boa (Lichanura trivirgata roseofusca), and Red Diamondback Rattlesnake (Crotalus ruber).

Sensitive plant species known from the project area include Orcutt’s Brodiaea (Brodiaea orcuttii), Chaparral Beargrass (Nolina cismontana), Ramona Horkelia (Horkelia truncata), Woolly Monardella (Monardella hypoleuca lanata), Morena Currant (Ribes canthariforme), and Hammitt’s Clay-cress (Sibaropsis hammittii). Portions of the project area have gabbro-derived soils. These areas are potential habitat for the species listed above, as well as for Dunn’s Mariposa Lily (Calochortus dunnii) and Gander’s Butterwort (Packera ganderi).

3.3.1 Alternative 1- No Action

Direct Effects

The no action alternative would have no direct or indirect effects on plant and wildlife species. Vegetation would not be modified and current ecological processes would continue. The risk of not being able to directly defend against a future wildfire event would increase which may negatively affect biological resources due to an increase in fire size associated with indirect fire suppression tactics.

Indirect Effects

The no action alternative would have no direct or indirect effects on plant and wildlife species. Vegetation would not be modified and current ecological processes would continue.

Cumulative Effects

The no action alternative would not contribute to cumulative effects on plant and wildlife species.

Summary

Alternative 1 would have no effect on San Diego Thornmint, Quino Checkerspot, or Hermes Copper Butterfly. Alternative 1 would have no effect on designated critical habitat for San Diego Thornmint.

3.3.2 Alternatives 2, 3, and Modified 3 – Fuelbreak Construction and Maintenance

Direct Effects

The action alternatives would all have similar effects as described below. The magnitude of effects would be greater for Alternatives 2 and 3, when compared with preferred modified Alternative 3, as these alternatives affect larger acreages and have greater impacts on federally-listed and sensitive species. In particular, for Anderson Fuel Break, Alternatives 2 (segment 6A) and 3 (segments 6B,C,D) would have substantial direct impacts on San Diego Thornmint and its designated critical habitat along the segment of the fuel break that extends south to Interstate 8.


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Potential direct effects include mortality or injury from increased vehicle traffic, shrub cutting, prescribed fire operations, or targeted grazing associated with the project. These effects are expected to be limited to the treatment area. Sensitive wildlife species typically avoid areas of human activity and may be temporarily displaced from the project area while work is in progress. These effects would be short-term, but would recur about every 5 years as treatments are repeated to ensure fuelbreak efficacy. Maintenance treatments would temporarily decrease the quality of the habitat within the project area.

Herbicides would be used on woody vegetation as part of fuelbreak maintenance. Over time this is expected to reduce the density and abundance of shrubs within the fuelbreak. An increased abundance of grasses and forbs is expected which would decrease the quality of the habitat in the area.

Goat grazing can be an effective way to maintain fuel breaks, and is particularly good at reducing fine fuels (see review by Ingram et al, 2013). Forage intake and digestibility of two common chaparral shrubs, chamise (Adenostoma fasciculatum) and blue oak (Quercus douglasii), as a sole diet are low and do not meet the nutritional requirements for sheep and goats grazing in this type of vegetation (Narvaez 2007). This could reduce the effectiveness of this treatment as much of the fuelbreak area is dominated by chamise. Goat grazing in springtime is likely to result in consumption of palatable sensitive plant species which would include Orcutt’s Brodiaea (Brodiaea orcuttii), Chaparral Beargrass (Nolina cismontana), Ramona Horkelia (Horkelia truncata),Woolly Monardella (Monardella hypoleuca lanata), Moreno Currant (Ribes canthariforme), Hammitt’s Claycress (Sibaropsis hammittii), Dunn’s Mariposa Lily (Calochortus dunnii), and Gander’s Butterwort (Packera ganderi). The short and long-term effects of goat grazing are not well understood and would be monitored in areas where goat grazing occurs.

Indirect Effects

The action alternatives would all have similar effects as described below. The magnitude of effects would be greater for Alternatives 2 and 3, when compared with modified Alternative 3, as these alternatives affect larger acreages and have greater impacts on federally-listed and sensitive species. In particular, for Anderson Fuel Break, Alternatives 2 (segment 6A) and 3 (segments 6B,C,D) would have substantial indirect impacts on San Diego Thornmint and its designated critical habitat along the segment of the fuelbreak that extends south to Interstate 8.

Indirect effects may include increased introduction of weeds, increased off-road vehicle activity, increased soil compaction, and increased risk of soil erosion.

Weeds

Fuelbreaks are deliberate type conversions of chaparral to grassland, and their creation and maintenance is typically associated with an increase in naturalized weedy species such as non-native grasses within the fuelbreak area. Researchers have documented this issue; for example:

“Any fuel reduction treatment, for example fuel breaks, that is directed at removing woody plant cover has the potential for increasing alien plants …fuel breaks too can act as corridors of alien propagules, conducting them deep into otherwise undisturbed wildlands. Fuel breaks by themselves probably have limited direct impact on invasion of adjacent closed canopy chaparral shrublands. However, reduced fuel loads result in lower fire intensity on fuel breaks and thus greater alien seedbank survival during fire. Thus, in the early postfire years, when these developing shrublands are the most vulnerable, those sites adjacent to fuel breaks are subject to an unnaturally high rain of alien propagules.” (Keeley 2004).

Keeley presents similar conclusions in later analyses such as Keeley (2006). At the same time, fuelbreaks can serve as effective tools in fire management as they provide places from which firefighter can attack the fire:


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“The effectiveness of fuel breaks remains a subject of debate within and outside of the fire management community. There are many reasons for this broad range of opinion, among them that objectives can vary widely, fuel break prescriptions (width, amount of fuel reduction, maintenance standards) may also vary, they can be placed in many different fuel conditions, and may be approached by wildland fires under a variety of normal to extreme weather conditions. Furthermore, fuel breaks are never designed to stop fires but to allow suppression forces a higher probability of successfully attacking a wildland fire. The amount of technology directed at the fire, and the requirement for firefighter safety, both affect the efficacy of fuel breaks in the suppression effort. A major criterion of effectiveness may be economic, in balancing creation and maintenance costs against changes in wildland fire suppression expenditures and values (habitat, homes, etc.) protected from loss (Agee et al. 2000).

Other authors such as Conard and Weise (2008) emphasize the value of fuelbreaks in “providing access for burnout operations and other defensive actions in chaparral wildfires.”

Increases in weed abundance after treatments would result in long-term effects on sensitive wildlife and plant species. The increase in weeds would decrease the quality of the habitat in the project area from high-quality to low quality, and these effects would be long term.

Off-road Vehicle Use

Fuels treatments may make the surrounding area more accessible to off-road use. Brush barriers would be retained, and metal pipe barriers would be installed as needed to prevent this activity. Increases in off-road activity would result in chronic, recurring effects to sensitive wildlife and plant species. Off-road activity typically damages vegetation and compacts soils, resulting in the conversion of high-quality habitat to low-quality habitat.

Soil compaction and erosion

Use of heavy equipment may increase soil compaction. At the same time, loss of vegetative cover may increase the risk of soil erosion. Compaction or erosion would decrease the quality of habitat for sensitive plant and wildlife species, and these effects are expected to be permanent. These risks, addressed in the Watershed and Soils Specialist Report (USDA Forest Service 2016c), can be mitigated through implementation of Best Management Practices (B.M.P’s) for soil and water conservation.

Cumulative Effects The action alternatives would all contribute to cumulative effects on plant and wildlife species as described below. The magnitude of effects would be greater for Alternatives 2 and 3, when compared with the preferred modified Alternative 3, as these alternatives affect larger acreages and have greater impacts on federally-listed and sensitive species.

The majority of acres proposed for treatment is maintenance of existing fuelbreaks, and the project design avoids or minimizes effects on sensitive species. For these reasons, implementation of the proposed project is not expected to contribute to cumulative effects for Regional Forester’s sensitive list species.

Potential future actions that could result in cumulative effects within the project area include expanding development. Since part of the project is occurring on private land, there is the chance that additional clearing would occur on this land or that further development, including houses, roads and trails, may result in encroachment into the natural habitat in the area. Another future threat to consider is climate change that may result in hotter conditions, causing increased occurrence of drought and range shifts in species in the project area. With increased temperature and drought associated with warming, there is an increased risk of fire with the potential for type conversion if the fire regime is disrupted and fires occur more frequently than the native vegetation can withstand. The full extent of the impacts from climate


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change remain to be seen. However the fuel breaks would likely reduce the risk of catastrophic fire, potentially protecting these species in the near future.

Summary

Alternatives 2 and 3 – Fuelbreak Construction and Maintenance

Alternatives 2 and 3 may adversely affect San Diego Thornmint and its designated critical habitat. Additionally, alternatives 2 and 3 may adversely affect Quino Checkerspot Butterfly and Hermes Copper Butterfly.

Modified Alternative 3 – Fuelbreak Construction and Maintenance

San Diego Thornmint is known to occur in and adjacent to the project area. Project activities would avoid occupied habitat for this species. Fuel treatments associated with this project may affect and is likely to adversely affect San Diego Thornmint. Project design features would mitigate impacts associated with treatments, but some San Diego Thornmint individuals may still be impacted by indirect effects such as increased weed abundance. There is 0.8 acres of designated critical habitat for San Diego Thornmint within the project area. Actions associated with the preferred alternative may adversely affect critical habitat for this species.

Quino Checkerspot has suitable habitat in the project area. Project activities would be scheduled or implemented so that they avoid most effects on host plants for this species. Actions associated with the preferred alternative may affect and is likely to adversely affect Quino Checkerspot due to the potential for individual larvae or butterflies to be injured, killed, or displaced by project implementation.

Hermes Copper butterfly is known to occur in and adjacent to the project area. Project activities would avoid occupied habitat for this species and its host plant, Spiny Redberry. Fuel treatments associated with this project may affect and is likely to adversely affect Hermes Copper due associated design features. These project features would limit or avoid indirect effects such as increased weed abundance and increased off-road vehicle activity, but some individual Hermes Coppers may still be affected by project implementation.

Based on the above assessments of direct, indirect, and cumulative effects, the action alternatives would all affect sensitive plant and wildlife species. The magnitude of effects would be greater for Alternatives 2 and 3, when compared with Modified Alternative 3, as these alternatives affect larger acreages and have greater impacts.

There are no known locations of Regional Forester’s Sensitive list wildlife species in the project area; however, potential habitat may occur for sensitive wildlife species. The use of heavy equipment, herbicides, and targeted grazing associated with implementation of the preferred alternative may increase weed abundance in the project area which may affect individuals, but is not expected to result in a trend toward federal listing nor a loss of viability for the Red Diamondback Rattlesnake, San Diego Ring-necked snake, the San Diego Horned Lizard, and Coastal Rosy Boa.

Sensitive plant species are known from the project area as previously described. The use of heavy equipment, herbicides, and targeted grazing associated with implementation of the preferred alternative may increase weed abundance in the project area which may affect individuals, but is not expected to result in a trend toward federal listing nor a loss of viability for Chaparral Beargrass, Ramona Horkelia, Woolly Monardella, Orcutt’s Brodiaea, Dunn’s Mariposa Lily, Morena Currant, Hammitt’s Claycress, or Gander’s Butterwort.

3.4 Cultural Resources The potential of the Alpine Community Defense Project to affect cultural resources was analyzed in R2016050240016 (USDA Forest Service, 2016b). This project complies with Section 106 of the National Historic Preservation Act of 1966, as amended in accordance with provisions of the Programmatic


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Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), the California State Historic Preservation Officer, the Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region (Regional PA 2013). Four alternatives were considered and their potential impacts to cultural resources were assessed. These alternatives included a no action alternative as well as three action alternatives.


In the event that the no action alternative is selected, no hazardous fuels reductions or vegetative maintenance activities would be implemented within the “Area of Potential Effect” (APE). Failure to reduce fuel loading within the project area may result in an increased risk for wildfire within the proposed project APE. As a result, cultural resources and the context in which they exist have the potential to be affected by wildland fire and suppression tactics.

Direct Effects

Generally speaking, direct effects of fire result from combustion, smoke, or ash and have the potential to compromise the integrity of diagnostic artifacts by altering their physical characteristics. In addition historic properties can be adversely affected by actions taken during suppression of the fire. Fireline construction, staging areas, and water/retardant drops are among the risks to resources during emergency response.

Indirect Effects

Indirect effects to cultural resources may include increased soil erosion, or loss of ground cover and subsequent exposure of surface artifacts and features, which can result in vandalism or theft.

3.4.2 Alternatives 2, 3, and Modified 3 – Fuelbreak Construction and Maintenance

The action alternatives differ only in the size, location, and land ownership status of the treatment locations. The three alternatives include the same proposed vegetative treatments discussed in the Cultural Resource Management Report for this project, and were evaluated for their potential effects to cultural resources within all of the proposed treatment units. The APE identified as part of the report included all proposed treatment areas, and an effort was made to identify “At Risk” cultural resources within each of the treatment units. Survey was performed on units associated with the preferred alternative which resulted in the location of one prehistoric resource and one historic resource determined to be at risk from the proposed vegetation treatments.

As recommended in Section B of the Cultural Resource Management Report, direct and indirect effects would be mitigated through the implementation of the design features found in chapter 2.4, as appropriate. Therefore this project would result in no adverse effect to historic properties regardless of the alternative chosen.

3.5 Soil and Water


Under the no action alternative, there would be no condition change to the soil, water, and hydrologic resources within the project area. This is because no cutting/piling or masticating of the existing fuel bed would occur. Further, no pile or broadcast burning would occur with the activity fuels and no target grazing or herbicide application would be permitted.

The purpose of this project is to reduce the risk of catastrophic wildfire to communities and sensitive habitats in and around the Anderson Truck Trail toward Interstate 8, from Viejas Creek Road eastward in eastern Alpine, and around the Carveacre community and access road. Not implementing this project


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increases the risk that a catastrophic fire may occur, potentially impacting soil and water quality through higher intensity wildfire. Fires of these magnitudes have the potential to reduce soil productivity and increase water and sediment yields to project area streams above what would occur after the proposed action alternatives would be implemented. However, the effects and magnitude of any potential wildfire are speculative at this time and depend on whether a wildfire does occur and where it occurs on the landscape. 3.5.2 Alternative 2, 3, and Modified 3 – Fuelbreak Construction and Maintenance

Direct and Indirect Effects of the Action Alternatives

All action alternatives have the potential to affect soil properties through compaction and erosion, water quality through sediment delivery to streams, water quantity through removal of vegetative cover, stream channel and riparian resources through vegetation removal and increases in water yields, and chemical water quality through herbicide use. We feel overall potential effects to soil and water resources are anticipated to be short term and would recover within a few years after project implementation. Detrimental long term effects are not anticipated should project design features, BMPs and mitigation measure be implemented properly. The following sections describe the range of predicted effects to soil, hydrological, and watershed resources.

Soils

Compaction and erosion are the primary potential impacts to soils resulting from vegetation management activities on NFS lands, but are limited depending on how and where those activities occur. For this project, compaction could occur when mechanical equipment, such as a masticator, is used to reduce fuel composition in a unit. Erosion could occur from the initial removal of fuels via mastication or hand removal and then through prescribed fire.

For this project, mastication is the only activity where soil compaction has the potential to occur. According to NRCS Soil Mart data for San Diego County (USDA NRCS 2015), the soils with the highest potential for impacts to occur from compaction by mastication include soil map units CME2, CnE2, CnG2, FaD2, FeE, LrE, and LrG (See Figure 4).


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Figure 4. Soils with low compaction resistance associated with the Alpine CD Project.

Detrimental compaction may occur with a few passes in moist soils but may take many passes in dry soils. Implementation of project design feature HYD-2 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would require that mastication only occurs when soils are dry. This, in addition to the fact that mechanical equipment typically only takes at most a few passes across the landscape during implementation, suggests that only very small increases in compaction would occur with this project, and the Regional soil quality standard of less than 15% detrimental soil disturbance would be met.

Soil erosion during vegetation management implementation generally occurs from mechanical operations on steep slopes or from prescribed fire. In the project area, 4 soils, soil map units CmE2, CnE2, CnG2, and LrG (See Figure 5), have either a severe off road/off trail erosion hazard rating, a high fire damage susceptibility, or a high potential for damage by fire. These ratings are likely due to the slope range of these soils (upwards of 65%). Implementation of project design feature HYD-1, which incorporates Forest Service National BMP Veg-2, would require that at least 50% cover on upland units remain on the


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soil surface after implementation. Implementation of project design feature HYD-2 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would require dry soil conditions during project implementation to prevent compaction, rutting, and disturbance which leads to erosion. Implementation of project design feature HYD-3 which incorporates Forest Service National BMPs Veg-2 and Veg-8 would limit mechanical operations to slopes less than 35% which would reduce potential erosion. Project design features HYD-8 and HYD-9 which incorporate Forest Service National BMP Fire-2 would require the rehabilitation of fire lines through the use of water bars to protect future soil properties and reduce potential erosion. Implementation of these design features suggest that erosion and soil properties would not be impacted beyond acceptable levels describe by the Regional Soil Quality Standards.

Figure 5. Soils with severe off road/off trail soil erosion hazard ratings, high fire damage susceptibility, and high potential for damage by fire associated with proposed project units.


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Sedimentation and Water Quality

Potential effects to water quality would be increased sediment generation associated with vegetation treatments and prescribed burning.

To estimate the potential for sediment generation associated with the proposed action, erosion hazard rating (EHR) values were recalculated for soils associated with streams in map units CmE2, FaD2, FeE, LrE, and LrG. The recalculations were done using projected ground cover and canopy cover percentages, which were predicted for after treatment implementation.

In recalculating EHR, an assumption was made that areas dominated by chaparral would have the shrub cover reduced up to 60%. Typically treatment activities would result in an increase in the EHR value post-harvest when compared to calculated values for the existing condition.

For vegetation treatment units, EHR calculations determined that post-treatment ground cover, for soils with slopes under 35%, would need to range from between 51-70% with a shrub component of 11-30% to keep the soil at a low EHR while for slopes over 35% and a shrub component of between 11-30%, a ground cover percentage of between 51-70% would yield an EHR increase from low to moderate.

By maintaining such a ground cover percentage (51-70%) for soils with slopes below 35%, the EHR model indicates that there would be no increase in overall erosion risk while the model indicates that potential increases in erosion on slopes above 35% are possible even if 50% cover is realized. Therefore, soil map units CmrG, CnG2, and LrG (as shown in Figure 6) would have the highest potential to input sediment to project area streams.


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Figure 6. Soils with the highest potential to input sediment into project area streams for the Alpine Community Defense Project.

Implementation of 98 foot no mechanical buffers (hand work with chain saws permitted) on intermittent streams and 50 feet mechanical buffers on ephemeral streams where at least 71% cover would be kept (Project Design Feature HYD-4) would filter the majority of the anticipated increased sediment (design feature 4). Minor increases in sediment are anticipated to localized streams in the project area, and any sediment that does reach project area streams would not cause detrimental water quality effects. This increase would not be unlike a small pulse of sediment after a naturally-occurring wildfire or landslide or streambank erosion, events that these watersheds have evolved with over time.

Water Quantity

Natural flow in a wildland watershed can be impacted by a variety of land management activities including vegetation manipulation, prescribed fire, and road building. Although any disturbance that


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reduces the density of live vegetation cover has the potential to increase runoff from forested watersheds, flow increases are generally not measurable until about 25 percent of the basal area of a forested watershed has been harvested (Grant et al., 2008 and Ziemer, 1986).

Under the action alternatives, at most approximately 1.4 percent of the Taylor Creek 6th level watershed would be removed, 1.2 percent of the Viejas Creek-Sweetwater Reservoir, 0.1 percent of the Lower Pine Valley Creek watershed and approximately 0.2 percent of the El Capitan Reservoir-San Diego River watershed. As a result of the small amount of treatment area proposed in all action alternatives, no discernible changes to water quantity or timing of peak flows from a watershed perspective would be expected. Should a large storm event occur immediately after implementation localized increases may be seen, but not outside the natural range of variability for these systems.

Stream Channel Conditions

Streams represent systems that are complex and dynamic. The channel morphology, including streambed and streambank stability, reflects the existing balance between streamflow, sediment input, and substrate/bank composition. If one of these components varies, then there is a corresponding change with the other two. As a result, changes in channel morphology (shape), stability, and changes in the streambed or streambank are often seen, especially over time. Increases in peak flow increases the energy available for sediment transport and bank erosion. Increases in sediment input result in a decrease of energy available for erosion, deposition of sediment, channel widening, and a decrease in bankfull depth. These changes, in turn, can potentially result in modifications to water quality and aquatic habitat.

BMPs, which have been proven effective in preventing or mitigating non-point sources of sediment, were incorporated into the development of the action alternatives in order to protect both soil and water resources (Schuler and Briggs, 2000, Seyedbagheri, 1996, USDA Forest Service, 2002).

Soil project design features were designed not only to minimize impacts to soil hydrology and nutrient cycling, but also to protect soil stability and to prevent or limit any sediment increases found on associated uplands.

Hydrologically related BMPs were selected and designed to prevent, or limit, upland sediment introduction into streams. This includes project-specific RCA requirements.

Appendix E of the LMP (USDA Forest Service, 2005) requires that an RCA of 98 feet be analyzed for intermittent streams. A 50 foot RCA width for protection of ephemeral drainages was determined to be adequate during a site visit associated with project analysis. For this project, project design features HYD-4-6 were developed to protect stream channels from mechanical treatment and prescribed fire through exclusion of mechanical treatment within 98 feet of the intermittent channel and no direct ignition of fire within 98 feet of intermittent stream channels and 50 feet within ephemeral stream channels. However, under-burns would be allowed to back into these areas and hand treatments to reduce fuels, which are expected to be limited in extent. These RCA buffers would function as buffer strips which would slow any overland flow, depositing upland related sediment, and preventing additional sediment contributions to streams. As mechanical treatment (in intermittent buffers) and fire ignition would not be allowed in the RCA buffer, combined with the prescribed buffer widths, increased sedimentation to associated stream drainages would be minimal. As a result, no change outside the natural range of variability to sediment load and stream channel morphology would be expected.

Based on the discussion above in the Water Quantity section and the implementation of BMPs and project design features, no discernible change in flow volume or alteration to timing of peak flows would be expected due to the implementation of the proposed action. As a result, no discernable direct and indirect effects, either short or long term, would be expected.

Riparian Conservation Areas

Appendix E of the LMP requires screening for projects proposed in RCAs.


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The purpose of the RCA is to reduce sediment from the activity area reaching the stream channel and to preserve adequate canopy for streamside cover, shading and recruitment of large woody material into the future. Effective ground cover within an RCA and for preventing soil erosion in general was determined by using the EHR method (USDA Forest Service 1990). By using this method, it was determined that the rating of LOW on project treatment area soils, the existing minimum effective ground-cover is 71-90 percent for the project RCA (See project file, EHR modeling). Ground cover consists of a combination of rocks, living plants, litter, slash and duff.

Project resource protection measures state that prescribed fire ignitions would not be set within Riparian Conservation Areas, but would be allowed to back burn into these areas. This would ensure that adequate post-implementation groundcover would be preserved. As result, no discernible direct and indirect effects, either short or long term, would be expected if burning occurs under recommended conditions.

Wetlands

There are no wetlands within the proposed project area; hence, there would be no direct or indirect effects under this alternative.

Floodplains

Floodplain development within treatment units in the project area is limited. BMPs, and project resource protection measures, would be expected to protect any of the very limited floodplain development within the project area. Hence, there would be no direct or indirect effects to floodplains under this alternative.

Municipal Watersheds

As stated, implementation of project design features and BMPs is anticipated to protect water quality in the cumulative effects drainages, therefore municipal watershed resources are expected to be protected

Chemical Water Quality Potential impacts from herbicides to be analyzed include chemical effects to beneficial uses and water quality. Currently, all of the waterbodies within the project area are meeting their beneficial uses as related to chemical water quality.

Triclopyr Background

Triclopyr is the herbicide proposed to be used for the project. Triclopyr is a dicot (broadleaf) specific herbicide that is usually used to treat woody vegetation. Triclopyr does not harm monocot species such as grasses, onions, lilies and yuccas. It is not active in the soil, and so if drift is avoided effects to non-target species are easily minimized. For the foliar applications proposed for this project, the amine salt form of triclopyr (triclopyr TEA), which is found in the trade formulation Garlon 3A, would be used. The average triclopyr application rate is 1 lb. active ingredient (a.i.)/acre for Forest Service activities nationwide (SERA 2016). On the Cleveland National Forest, at Cottonwood Creek, application rates for initial treatments of the largest and most dense tamarisk infestation on the Forest was 2 lbs. a.i./acre. Retreatment of re-sprouts at the same site the following year had application rates of 0.5 lbs. a.i./acre of triclopyr. This project is expected to have an application rate on average of 1 lb a.i. per acre.

Triclopyr TEA requires the use of a non-ionic surfactant mixed with the herbicide before use. This project would use modified seed oil (MSO) type surfactants. Trade formulations of MSO surfactants include Hasten, Competitor, JLB Oil Plus, and Cide-Kick. These types of surfactants are being used due to their favorable environmental profile. No petroleum or petrochemical-based surfactants would be used. No POEA surfactants (the surfactant found in the commercial glyphosate formula RoundUp) would be used (Bakke 2007).

A dye would be added to the mixture to help ensure adequate herbicide coverage and to avoid double-spraying. Dyes also make accidental spills easier to detect and track (Tu 2001).


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Triclopyr amine quickly breaks down to triclopyr acid in the environment. Triclopyr acid degrades completely in the environment to carbon dioxide and water. The major intermediary metabolite of triclopyr is TCP. TCP is slightly more toxic to mammals and fish than triclopyr itself.

Both triclopyr and TCP photo degrade rapidly and are not detectable on sprayed plant material or the soil surface within days of spraying. Triclopyr is rapidly broken down by sunlight in surface waters and has a half-life in these conditions of less than one day. TCP has a half-life ranging from approximately 4-8 days in these conditions. Triclopyr binds to clay and organic matter in the soil and is broken down by soil microbes. It has a half-life in soil of 46 days. The metabolite TCP is more mobile in soils and has a half-life of 90 days. Neither of these compounds shows indications of accumulating in the environment nor bioaccumulation (SERA 2016).

Most herbicides require the use of adjuvants, or additives to the tank mix. Surfactants are a particular type of adjuvant used to increase an herbicides effectiveness by increasing its ability to be absorbed by plants. In addition, herbicide formulations also contain other ingredients beyond the active ingredient called “inerts” that serve various purposes in the formulation. Any assessment of potential human health and ecological risk of herbicide use also needs to consider the toxicology of inerts and added adjuvants that are in the product or would be added to the herbicide in the field.

The risk assessment for triclopyr looked at “inerts” and also surfactants that are contained in Garlon 3a, the trade formulation likely to be used. The authors of the risk assessment were able to obtain a complete listing of ingredients but were unable to disclose them in the risk assessment for proprietary reasons. Formulations of triclopyr TEA like Garlon 3A are known to contain ethanol (drinking alcohol). The risk assessment concluded that, based on known information, exposure to these adjuvants would not have negative effects at levels of exposure to Garlon 3A that would result in negative effects for triclopyr exposure (SERA 2016). Therefore, exposure rates below levels of concern for triclopyr would not result in negative effects from adjuvants or surfactants in the trade formulations or with the addition of modified seed oil surfactants.

Colorants would also be added to the herbicide mixture. These aid in helping herbicide applicators not miss plants or treat plants twice. They are also helpful for helping reduce worker or public exposure to treated vegetation. This project would utilize Hi-Light Blue dye or similar colorant. This colorant is a water soluble dye and contains no listed hazardous chemicals. It is considered virtually non-toxic to humans (Bakke 2007).

Effects to Watersheds and Water Quality for all Action Alternatives (Alt 2, 3 and 3 modified)

Risk assessments for herbicides include the USDA FS GLEAMS modeling worksheets that have been developed by SERA for the Forest Service. GLEAMS modeling is used to make predictions about how much of the herbicides or their degradates may enter surface waters. GLEAMS modeling is an agricultural standard model to determine the effects of runoff after pesticide applications. The Risk Assessments try to predict how much herbicide would be introduced to surface water as a result of a modeled scenario where a 10-acre block of land is treated with herbicide adjacent and draining into a small stream or pond. This scenario is analyzed for a variety of soil conditions and rainfall rates. This scenario represents much greater and more concentrated application rates than are called for in this project.

The potential direct and indirect effects for the various proposed treatments are grouped into 1) herbicide treatments and 2) hand and mechanical treatments. It is likely that at any given treatment site a combination of the proposed treatments would be used.


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Direct and Indirect Effects from Herbicides

GLEAMS and Beneficial Uses

GLEAMS modeling worksheets, developed by SERA for the Forest Service, were run for Triclopyr and are included in the project record. The model runs scenarios for toxicity to organisms (human, wildlife and plant) from the potential exposure to herbicides by contact or consumption of contaminated water through both the proposed use (non-accidental) and accidental (spills of herbicide) introducing herbicides to waters. Hazard quotients less than 1 are considered lower risk while hazard quotients greater than 1 are considered higher risk. The worksheets give the range and central value for the modeled hazard quotient. In the analysis below, the upper limit of the hazard quotient is used to reflect the greatest risk.

To minimize risks to beneficial uses listed below, implementation would utilize design features and BMPs listed in the Design Features and Mitigation Measures common to Action Alternatives (pp. 15-16). These practices would reduce risks of spills, transport of, transmission of, and exposure to herbicides.

Domestic and Municipal Water Supply

Potential risk to municipal and domestic water quality was determined by the results of water consumption from three scenarios: 1) from an accidental acute exposure, 2) from a non-accidental acute exposure, and 3) from chronic long term exposure. No non-accidental scenarios were shown to have the potential to impact this beneficial use for any of the proposed herbicides. For accidental exposures, triclopyr scored a hazard quotient greater than 2 in scenario 1, accidental acute exposure to a child through water consumption. This scenario assumes immediate consumption of untreated contaminated water after spill. The design criteria would prevent the potential for spills of the magnitude modeled to occur. In scenario 3, modeling longer term exposures, triclopyr herbicides did not have a hazard quotient greater than 1.

Recreation Uses

Potential risk to recreational users is determined from the hazard quotients of exposure through water consumption and swimming. Water consumption is discussed above. Triclopyr does not have a hazard quotients above 1 in the swimming for one hour scenario.

Agricultural use

This project would not be treating any areas near sources for irrigation waters, and project design criteria would prevent the non-accidental contamination of water by any herbicides, so this beneficial use would not be affected.

Ground Water Recharge and Freshwater Replenishment

While herbicides would not affect the quantity of water available for ground water recharge or freshwater replenishment, herbicides could affect the chemical water quality of surface and ground water. Direct spills, leaching and runoff would be the pathways for contamination. This scenario assumes application directly followed by a runoff producing storm.

Triclopyr has a hazard quotients above 2 for exposure of herbicide sensitive species to contaminated runoff.

This project would avoid application of herbicides within 48 hours of potential rainfall, so potential to impact non-target plants with contaminated runoff is low.

Mobility and Environmental Factors

Mobility of a given herbicide is reliant on the combination of climate, herbicide, and soil characteristics. The solubility and adsorption potential of the herbicide can affect risk of herbicide transport. However, the soil characteristics such as permeability and runoff can contribute to transport of herbicides to


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groundwater and/or surface waters. Climate can determine the likelihood of storm events and precipitation available to transport herbicides.

Most of the soils in the analysis area are well to excessively drained which indicates that water moves quickly through the soil. Triclopyr has the potential for transport through runoff and leaching. Triclopyr has potential to be transported off site because it is soluble and does not strongly bond to soils. However, triclopyr breaks down readily in both groundwater and surface water and therefore is not expected to contaminate groundwater or surface waters.

Direct and Indirect Effects Summary

No matter which action alternative is selected, there is little to no difference in the effects to soils, stream channels, riparian areas, hillslope stability, and water quality should the design features and mitigation measures listed in this report be implemented. Alternative 2 proposes approximately 361 acres, Alternative 3 approximately 457 acres, and Alternative 3 modified approximately 384 acres. This small difference in proposed project acreage does not constitute a discernable difference in direct and indirect effects between action alternatives.

Cumulative Effects

Four 6th field HUC watersheds are involved with this project as defined. They include the Taylor Creek (180703040802), Viejas Creek-Sweetwater Reservoir (180703040803), Lower Pine Valley Creek (180703050203), and El Capitan Reservoir-San Diego River (180703040505) watersheds. See the specialist report for sizes and their location in reference to the project area (USDA Forest Service 2016c). Cumulative effects are only analyzed for the Taylor Creek and Viejas Creek-Sweetwater Reservoir 6th field HUCs in this report. This is due to the small amount of disturbance proposed in the Lower Pine Valley (28 acres or 0.1% of the watershed) and El Capitan Reservoir-San Diego River 6th field HUC (76 acres or 0.2% of the watershed).

For the Taylor Creek watershed, the WCAT protocol currently lists this watershed as properly functioning. With this project, approximately 193 acres of treatment is proposed (around the Carveacre area), which accounts for approximately 1.4% of the drainage. All other projects are ongoing and minor in terms of disturbance and water quality issues. Because of the minor and localized effects anticipated from the project within this watershed, and the project design features and BMPs proposed, this rating of properly functioning is not anticipated to be affected.

For the Viejas Creek-Sweetwater Reservoir watershed, the WCAT protocol currently lists this watershed as functioning at risk for fair riparian/wetland vegetation, soils, and aquatic habitat conditions. The positive effects to soils and watershed function include the decommissioning of approximately 1.6 miles of unauthorized routes (Roberts Ranch Road). Negative effects include the implementation of approximately 220 acres of the project area. There are no additional roads or trails to be constructed or decommissioned in the watershed, no further fuels management projects proposed (other than small ones on private and tribal lands) . Because of the project design features and BMPs proposed, localized short term direct and indirect effects are anticipated and the functioning at risk rating for this watershed would remain in the future due to the non-project related impacts to soils, riparian/wetland vegetation, and aquatic habitat.

3.6 Air Quality


Under the no action alternative, no treatments would be conducted for the Alpine Community Defense project in any unit. The project site would remain in its current state.


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With no action, no fuels reduction treatments would be implemented. Air pollution emissions from other sources would not change from current conditions. In the short term, the air quality impacts from the No Action Alternative would be less than the other alternatives which include treatment such as: pile burning and equipment use (e.g. chain saws, vehicles, tractors, etc.) which generate emissions.

In the long term, the No Action Alternative would not allow the opportunity to reduce the availability of fuels for fire. The presence of ground fuels may increase the potential for high intensity wildfires in the future. Smoke from wildfires can be at a minimum a public nuisance or a threat to human health when concentrations are high.

Cumulative Effects

Past, present, and reasonably foreseeable activities were reviewed to determine cumulative effects to air quality. In the long term, the No Action Alternative would not allow the opportunity to reduce the potential of wildfire ignition in the treatment areas. Occurrences of wildfire can pose a risk for life and property for impacted communities. In addition, untreated vegetation may contribute to higher emissions when a wildfire occurs due to larger quantities of material available for fire consumption. In certain settings, wildfires are thought to produce nearly twice the amount of smoke as prescribed fire (Huff et al 1995).

3.6.2 Alternative 2 – Fuelbreak Construction and Maintenance

Under Alternative 2, multiple actions would be conducted. Each treatment would be completed over several days. Under this alternative, all units would be a maximum of 300 feet wide with distance measured outward from the forest property boundary. Fuel breaks would have a “feathered edge” where treatment intensity varies from high to low with islands of existing vegetation left untreated


Emissions from the prescribed fire activities were modelled using the Bluesky Playground web model. The model was run with conservative assumptions such as: complete fire-consumption of vegetation in the six units, all treatments completed within a single day, and fire was the sole tool used to treat vegetation. In reality, not all vegetative matter would be burned; by project design (e.g. “feathered edges”) and the incomplete combustion process which is the nature of open burning. The results therefore represent the highest possible emissions from fire treatments.

The model indicates that the proposed project would result in minor amounts of criteria pollutants such as Particulate Matter (PM10 and PM2.5), Carbon Monoxide (CO), Nitrogen Oxides (NOx), and Volatile Organic Carbons (VOCs). Other pollutants (such as greenhouse gases) are also released: Carbon Dioxide (CO2), methane (CH4), and other miscellaneous gases (identified as GHGs). Results can be found in Table 2.

Emissions were compared to the applicable daily Screening-Level-Thresholds (SLTs). In addition, emissions were compared to the hour and day thresholds. Yearly thresholds were not examined since model results indicate that the more stringent daily threshold would not be surpassed. The comparison of model outputs to hourly SLTs indicate that thresholds would exceed limits for CO. In reality, the project would be implemented over several days therefore; the total of CO produced on any given hour would be a fraction of the total modeled output. The comparison of model outputs to daily SLTs indicate that thresholds would exceed limits for VOCs. The project would be implemented over several days therefore; the total of VOCs produced on any given day would be a fraction of the total modeled output. All other SLTs were met. Results can be found in Table 2.

Implementing the treatments proposed for Alternative 2 would result in emissions and therefore, a reduction in air quality. However, the impacts from smoke and machinery emissions would be spread out


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over many days. Conservative modeling results indicate that air quality standards would not be exceeded during implementation of the project.

Table 2 Alternative 2 total modeled emissions (fire treatments, vehicles, and pesticide application) compared to the hour and day Screening-Level Thresholds. The model was run conservatively and results were rounded-up to the next full number. Implementation would take place over an estimated 50 days, those days may be spread over multiple seasons and years.

Total Emissions by Pollutant Types (in tons) PM 2.5 PM10 CO CO2 GHGs CH4 NOx VOCs NH3 SO2

42 49 426 8510 9480 22 66 109 8 6

Hourly Limits Screening-Level Thresholds (in tons)

N/A N/A 100 N/A N/A N/A 25 N/A N/A 25

Daily Screening-Level Thresholds (in tons)

55 100 550 N/A N/A N/A 250 75 205 250

Cumulative Effects

Past, present, and reasonably foreseeable activities were reviewed to determine cumulative effects to air quality. Wildfires have occurred periodically in the past and are likely to occur in the future. The potential air quality impacts from wildfire can be lessened through reducing the amount of available material to burn such as the activities proposed by the Alpine Community Defense project (Huff et al 1995). Reductions to air quality caused by this project are temporary and occur only while treatments are being implemented.

Impacts are likely to be greatest in areas adjacent to the project’s working areas and areas downwind. The San Diego Air Pollution Control District’s Smoke Management Program regulates smoke from prescribed fires to minimize impacts. Emissions from Alternative 2 are modelled to be below the Screening-Level-Thresholds (SLTs) throughout the implementation period of the project. Emissions below the SLTs are considered insubstantial to overall air quality of the San Diego County Air Pollution Control District (SDAPCD).


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3.6.3 Alternative 3 and Modified Alternative 3– Fuelbreak Construction and Maintenance Multiple actions would be conducted under Alternative 3 similar to Alternative 2. Alternative 3 was developed to create a continuous fuel break that encompasses private land as well as Forest Service land and therefore differs only in total acreage treated and proximity of treatment. Alternative 3 was subsequently modified to remove lands where private property owners were unwilling to coordinate fuels treatments on their lands and to remove units at the south end of Anderson truck trail, limiting impacts to biological resources thus lowering the acres to within the range of Alternative 2 and 3. Under both alternatives, all units would be a maximum of 300 feet wide. Fuel breaks would have “feathered edges” where treatment intensity varies from high to low with islands of existing vegetation left untreated. Each treatment would be completed over several days over multiple seasons and years.


Implementation of this alternative is similar to the previously described Alternative 2 with the exception of additional units on private land. The comparison of model outputs to hourly SLTs indicate that thresholds would exceed limits for CO. In reality, the project would be implemented over several days therefore; the total of CO produced on any given hour would be a fraction of the total modeled output. The comparison of model outputs to daily SLTs indicate that thresholds would exceed limits for VOCs. The project would be implemented over several days therefore; the total of VOCs produced on any given day would be a fraction of the total modeled output. All other SLTs were met. Results for Alternative 3 can be found in Table 3.

Table 3 Alternative 3 total modeled emissions (fire treatments, vehicles, and pesticide application) compared to the hour and day Screening-Level Thresholds. The model was run conservatively and results were rounded-up to the next full number. Implementation would take place over an estimated 50 days.

Cumulative Effects

Past, present, and reasonably foreseeable activities were reviewed to determine cumulative effects to air quality. Wildfires have occurred periodically in the past and are likely to occur in the future. The potential air quality impacts from wildfire can be lessened through reducing the amount of available material to burn such as the activities proposed by the Alpine Community Defense project (Huff et al 1995). Reductions to air quality caused by this project are temporary and occur only while treatments are being implemented.

Impacts are likely to be greatest in areas adjacent to the project’s working areas and areas downwind. The San Diego Air Pollution Control District’s Smoke Management Program regulates smoke from prescribed fires to minimize impacts. Emissions from Alternative 3 are modelled to be below the Screening-Level-Thresholds (SLTs) throughout the implementation period of the project. Emissions below the SLTs are

Total Emissions by Pollutant Types (in tons) PM 2.5 PM10 CO CO2 GHGs CH4 NOx VOCs NH3 SO2

51 61 526 10531 11732 28 68 133 9 7

Applicable Screening-Level Thresholds (in tons) for hourly limits

N/A N/A 100 N/A N/A N/A 25 N/A N/A 25

Applicable Screening-Level Thresholds (in tons) for daily limits

55 100 550 N/A N/A N/A 250 75 205 250


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considered insubstantial to overall air quality of the San Diego County Air Pollution Control District (SDAPCD).

Chapter 4: Persons, Groups, Organizations, and Agencies Consulted

• Viejas Band of Kumeyaay Indians

• Chaparral Land Conservancy

• Cal-fire, San Diego Unit

• San Diego Air Pollution Control District

• San Diego Regional Water Quality Control Board

• US Fish and Wildlife Service – Carlsbad Field Office

• Greater Alpine Fire Safe Council

• East County Fire Safe Council

• Adjacent Landowners

For a complete list of individuals and interest groups, including all adjacent landowners, refer to the project record available at the Descanso Ranger District Office.

List of Preparers:

• Andrew Weinhart, NEPA Writer and Resources Forester, Cleveland National Forest

• Rick Marinelli , Technical Specialist and District Fuels Battalion, Cleveland National Forest

• Lance Criley, Forest Rangeland Management Specialist and Pesticide Use Coordinator, Cleveland National Forest

• Stephen Fillmore, Forest Fuels Officer, Cleveland National Forest

• Chad Hermandorfer, Hydrologist, AMSET Enterprise Team

• Eraina Nossa, Staff Archaeologist, Cleveland National Forest

• Kirsten Winter, Forest Biologist, Cleveland National Forest

• Andrea Nick, Air Resource Specialist, R5 Fire & Aviation Management

Chapter 5: Responses to Comments

Comment #1: States the 300 foot width is excessive and does not comply with the best available science. We strongly recommend the Forest Service reexamines the necessity of this width (the length of a football field) as the science has clearly indicated anything over 100 feet has observable diminishing returns in terms of the efficacy.

CNF Response: The 300 foot buffer is the maximum allowable and would only be utilized when deemed necessary by the fire managers on the District. If 300 feet is chosen, it would be stratified to lessen the impact to the vegetative structure including leaving small islands of refuge. This distance is allowed under the CNF LMP and is consistent with all applicable mitigations and design criteria measures herein. See Section 3.1 beginning on p. 16 for detailed analysis. Commenter has referenced the Syphard (2014) paper to make the argument that defensible space greater than 100 feet from structures showed little additional


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efficacy, although even at 300 feet of defensible space, structures were still lost. No negative effects were demonstrated with defensible space distances greater than 100 feet although they raised concerns about the potential for conversion to grassland-type vegetation. The paper also did not address the effects of wind, home construction, or other operational firefighting considerations such as flame and radiant heat separation distances. The paper does address the fact that ember wash and not direct flame impingement is the primary cause of structure ignition, however it does not address the fact that firefighters are better able to deal with ember wash and small ignitions on a home if the radiant heat source is further away from the structure (more defensible space). Therefore, this paper has limited applicability to the proposed action. District fire managers will create the least amount of defensible space that still meets the purpose and need of the project, complies with the Cleveland NF LMP, and the design criteria of this EA.

Commenter has referenced the Keeley (2005) article from 2005 in Fire Management Today. This article discusses the fact that large fires have been shown to burn through younger age class fuels, which shows that fuel age is not always a positive indicator for stopping or slowing a fire’s progression. This article is not relevant to the proposed action, as no age class reduction for the purpose of stopping or slowing a fire is proposed. Instead, as demonstrated by many other papers including Syphard 2005 and 2014, the planned action is to create areas of defensible space or fuelbreaks where active operational involvement by fire personnel is expected to predicate a successful result.

Comment #2: States treatments should include minimum habitat disturbance by creating functional islands of undisturbed vegetation throughout. The proposal currently indicates such islands “may” be left.

CNF Response: The forest has revised the project description to include quantitative numbers for leaving shrubs intact across the project area. See Section 2 for the revised project description common to all action alternatives being analyzed.

Comment #3: The county safety officer stated at a Sunrise Power Link EIR meeting that the power link constitutes the primary fire danger to Alpine and Cleveland National Forest and suggested sprinklers be placed along the its route to protect from fire. The national forests in other parts of America clear brush and growth along the route of power line in power line cuts…clear the brush under the Sunrise Power Link which will provide a fire break through the forest and protect Alpine and the forest from fire danger.

CNF Response: Although the Sunrise Powerlink may constitute as a possible wildfire ignition source; reducing vegetation solely underneath its pathway does little to protect life and property from all other possible wildfire ignition sources that may occur naturally, e.g. dry lightning, or human caused, e.g. malfunctioning catalytic converters, cigarette butts, and abandoned campfires, on lands adjacent to the project area. Additionally, it would not create defensible space in a strategically placed zone of reduced fuels in close proximity to resources at risk where access is easily gained by firefighter personnel increasing the efficacy of wildland fire suppression tactics near infrastructure. Lastly, creating a firebreak along the path of the Sunrise Powerlink is outside the scope of this project and would not align with Land Management Plan goals, strategies, and tactics associated with fuels management and community protection.

Comment #4: The brush burning is extremely dangerous to our property and if it flares up in after-hours we cannot enter the forest to put it out without a forest adventure pass. This can result in our house and property being burned out.

CNF Response: Activity fuel burning would be completed under an approved prescribed fire plan, which includes patrol of the prescribed fire until there is no threat to the adjacent vegetation. There is no law, regulation, or ordinance that states a homeowner cannot take defensive action to protect their property from a wildfire. Finally, an Adventure Pass is not needed for this portion of the Cleveland National Forest.

Comment #5: The Environmental Protection Agency (EPA) lists herbicide as a pollutant in drinking water in the EPA Safe Drinking Water Act. The herbicide will be applied to a slope near our well where it


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can leach down and contaminate our drinking water. Herbicide is toxic and can lead to severe health problems.

CNF Response: The forest understands the concern of herbicide use adjacent to private lands and has therefore analyzed the effects of Triclopyr in depth. Triclopyr was chosen due to its ability to inhibit growth on target species while not adversely affecting soil integrity, water quality, and human health & safety. See Section 3.2, 3.5, and 2.4 for detailed analysis and associated design features for managing herbicide applications.

Comment #6: States primary concern for this Project is the increased fire risk that will result from the Project’s inevitable type-conversion of native vegetation to highly flammable, non-native, invasive grass and herbaceous weeds in the proposed fuel breaks

CNF Response: Fire risk is a broad term that is unclearly defined in this comment, therefore is difficult to address. In terms of increased fire ignition potential, there has been research produced that states that fire ignition is more possible when areas have been converted to fine fuels. However, this increased risk is only relevant during the off-season or winter months when relative fire danger is typically low. Locally, there has been little- to no evidence to support an increased risk of wildfire ignition in constructed fuelbreaks due to a change in vegetation type. Winter months tend to have higher humidity’s and high fine fuel moisture content. Also, during the winter months the surrounding chaparral vegetation tends to be of higher fuel moisture content and thus unable to burn even if fine fuels were available, except under very strong winds. A fire burning in a fine fuel type of fuel bed would be inherently easier to control and would be confined by the surrounding vegetation. There has been little to no evidence that converting areas to a fine fuel bed has increased fire risk within the project areas. See Section 3.1 beginning on p. 16 for detailed analysis.

Comment #7: States to achieve Project objectives, roads that access Project fuel breaks should be closed to motorized vehicle access by the general public during periods of high fire risk

CNF Response: This comment falls outside the scope of the project and does not support the mission of the US Forest Service to provide for use opportunities for the public. Prevention and detection would continue to be our tools to keep fires small or prevented.

Comment #8: Requests Forest Service includes a revised Carve Acre Alternative Three that shifts the western portion of Unit 14 to the east, and shifts units 15 and 16 to the north, onto private property closer to homes.

CNF Response: Shifting locations of the unit boundaries, at this point in time, would not fulfill the purpose and need of the project. In addition, it would negate the impacts that have already occurred and create new ones. That being said, a concurrent EA is being produced by the Greater Alpine Fire Safe Council to examine opportunities to shift work onto private lands in the future.

Comment # 9: Fuelbreak construction and maintenance adjacent to Carveacre and Viejas Indian Reservation conflict with Forest Service’s Back Country Motorized Use Restricted Land Use Zone and High Scenic Integrity Objectives.

CNF Response: This project would adhere to guidance contained within the Cleveland National Forest LMP as it pertains to Back Country Motorized Use Restricted Land Use Zone. The Zone allows for motorized use restricted to administrative purposes only that include Forest Service, other agency, or tribal government needs. This includes locating community protection vegetation treatments that require permanent roaded access (such as fuelbreaks) within this zone. Additionally, Table 2.2.4 in Part 2 of the LMP shows Fuelbreak Construction including Type Conversion as a suitable use or activity to occur within the Back Country Motorized Use Restricted Land Use Zone.

The Project area falls into High or Moderate Scenic Integrity Objectives (SIO). Aesthetic Management Standards shown in Part 3 of the LMP, allow for minor adjustments not to exceed a drop of one SIO


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level. Appendix L, Part 3 of the LMP, defines Moderate SIO as a landscape appearing slightly altered. Project Design Features described in Section 2, e.g. creating an undulating edge and retaining approximately 20-40 percent of the shrubs irregularly spaced throughout the project area; would mitigate the drop in SIO levels. Additionally the fuelbreak would account for a small percentage of the actual viewshed and is located in close proximity to infrastructure and other developments where an altered landscape is already present.

Comment #10: States concern for prescribed burning in Sweetwater River Channel; fuels treatments in the two canyons between Bells Bluff and Japatule Valley Road; a need for a review of the Gaskill Ridge to Lawson Peak, Lawson Valley, Lions Valley, and Deer Horn valley Areas, Goats effectiveness at maintaining fuelbreaks and introduction of non-native plants by goats.

CNF Response: Treatment units are located well to the north of the Sweetwater River drainage and outside of the riparian conservation area that governs actions in and adjacent to perennial water features. Design Features stated in Section 2 and Section 2.4 would be employed to mitigate impacts to natural resources while creating defensible space in case of a future wildfire event. Prescribed burning would not be conducted in the Sweetwater River drainage.

As for the remaining areas listed by commenter, none of the action alternatives listed plan to treat those areas and is therefore outside the scope of this document and analysis.

Recent experience indicates goats are most effective during the maintenance cycles when existing vegetation consists light forbs, grasses, and woody species in a succulent growth phase (USDA Forest Service 2016e). Design features have been developed to mitigate introduction of non-native species through targeted grazing. See Section 2.4.

Comment #11: States the range of alternatives as proposed is not adequate. Alternatives should be considered that comport to a greater degree with scientific evidence as to what vegetation treatments are likely to be effective in achieving project goals of community and resource protection. The circumstance of wind-driven fire should be the focus.

CNF Response: Wind-driven fire is specifically not being managed for because the level of vegetative clearance that would be required to adequately protect structures would be beyond Land Management Plan standards. In fact it is a long-held understanding that USFS fuels management activities are undertaken to protect against 90th percentile, typical fire season fire events, and not extreme weather/fire incidents, as that is impractical.

Comment #12: States evidence to date and the scientific literature support a "structure-out" approach, rather than treatments distant from structures. Specifically, CAL FIRE recommends limited clearing around structures, roughly 100 feet (in different tiers).

CNF Response: This project has been designed to incorporate alternatives that seek to work near structures on private land within the zone of most protection, which is the WUI defense and threat zone as defined by the CNF LMP. The USFS cannot fund structural improvements to privately owned property. The construction of fuelbreaks provides for linear continuity for fire suppression activities that would not be possible if fuels were only treated immediately around the structures. See Section 3.1 beginning on p. 16 for detailed analysis.

Comment #13: States limited clearing along roadways, roughly 30 feet, for staging and evacuation purposes is also defensible. Strategic “fire breaks" to allow access for firefighting purposes, also make sense and appear beneficial.

CNF Response: 30 feet of clearance along the roadways may not be sufficient to meet the purpose and need. Radiant heat from vegetation burning along roadsides has been a cause of injury and fatalities in the past. Creating a zone of sufficient separation from burning vegetation would enable civilians to safety evacuate areas even if fire is encroaching. Civilians do not typically have the protections of Personal


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Protective Equipment that fire personnel do when driving by sources of radiant heat. A fire break is by definition an area of land cleared to bare mineral soil. This type of treatment is outside the design scope of this project, and is unnecessary to achieve the purpose and need. See Section 3.1 beginning on p. 16 for detailed analysis. A commenter referenced the Syphard (2011) paper that examines the roles of fuelbreaks in southern California. This paper indicates that fuelbreaks that are located along roadways (or areas that are easily accessible) are more effective in nature. The agency proposed and preferred alternatives both move the fuelbreaks to areas that are much more accessible, either along existing roadways or directly behind structures. Therefore they are expected to be as effective as possible according to this research.

Comment #14: States vegetation treatment, as proposed, will result in type conversion of scrub to flammable weeds that rapidly carry fire. Wind-borne embers will not be affected by the actions proposed, though these are the major culprit in structure loss.

CNF Response: This project is not attempting to modify ember generation. This project is attempting to create zones of reduced vegetation where firefighters can safely engage embers and other products of combustion. It is unlikely that true type conversion would occur within the treatment areas. The LMP allows for fuels management within the parameters given in this purpose and need. Fire behavior, rates of spread, and intensity of fuel models post-treatment are much more favorable than that of pre-treatment. While rate of spread is one metric that is applicable, and indeed may increase in a GS2 versus a SH7, the fireline intensity and flame lengths would be much lower and thus easier to control. Fireline intensity and flame lengths are more important metrics than rate of spread in the context of fire suppression. See Section 3.1 beginning on p. 16 for detailed analysis.

Comment #15: Urges an up-to-date approach that does not consume time and resources in non-productive or counter-productive actions. The NEPA documentation should back up all proposed actions with scientific evidence and a current literature review.

CNF Response: All actions proposed in the purpose and need are supported by science-based evidence. Anecdotal and empirical observations have shown that modifying the fuelbed is an effective strategy for making fire behavior more suitable for direct attack suppression methods. The commenter does not support their comments with evidence that the approach proposed is inconsistent with science and reason.

Comment #X: Supports limiting the amount of new subdivision and development approved by the County of San Diego adjacent to federal lands, which is of upmost importance in reducing fire hazard to life, property, and natural resources.

CNF Response: Limiting the amount of new subdivision and development approved by the county of San Diego adjacent to federal lands is outside the scope of this analysis and outside the jurisdiction of the Forest Service.

Comment #16: States there is no mention of increasing the fire-resistance of structures, such as removing flammable roofs and flammable ornamental plantings.

CNF Response: This comment falls outside the scope of this project. The Forest Service has no jurisdiction over building code enforcement on private lands, furthermore Calfire and local fire municipalities are responsible for enforcing local and state fire prevention regulations on private lands located within San Diego County.

Comment #17: States early egress for residents should also be a priority, such as by helicopter, if necessary. Shelter-in-place has failed elsewhere.

CNF Response: This comments falls outside the scope of this project. Community evacuations, when caused by wildfire, are handled by state and local emergency responders based on the perceived threat to life and property.

Comment # 18: States project site may have cultural significance or ties to Viejas. Request that a Viejas Cultural Monitor be on site for Viejas Creek and Anderson Truck Trail.


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CNF Response: The Forest recognizes that areas within the proposed project boundary have cultural significance and/or ties to the Viejas Band of Kumeyaay Indians. The Viejas Band of Kumeyaay Indians would be adequately notified prior to any implementation of proposed vegetation management activities in the Viejas Creek or Anderson Truck Trail portions of the proposed project area in order that they or their designated representative may conduct cultural resource monitoring of those activities at their discretion.


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References

Andrews, PL and Rothermel, RC (1982) Charts for interpreting wildland fire behavior characteristics. Intermountain Forest and Range Experiment Station General Technical Report 131

Bakke, David 2007. Analysis of Issues Surrounding the Use of Spray Adjuvants With Herbicides. Written December 2002, revised 2007. Available online at: http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsbdev3_045552.pdf

Elliot, William J.; Ina Sue Miller; and Lisa Audin; Eds. 2010. Cumulative watershed effects of fuel management in the western United States. Gen. Tech. Rep. RMRS-GTR-231. Fort Collins, CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 299 p. Available online at: http://www.fs.fed.us/rm/pubs/rmrs_gtr231.pdf

Grant, Gordon E.; Lewis, Sarah L.; Swanson, Frederick J.; Cissel, John H.; McDonnell, Jeffrey J. May 2008. General Technical Report PNW-GTR-760, USDA Forest Service, Pacific Northwest Research Station, Portland, OR. 76 p.

Huff, M.H., Ottmar, R. D., Alvarado, E., Vihnanek, R.E., Lehmkuhl, J. F., Hessburg, P. F., Everett, R.L. 1995. Historical and current forest landscapes in eastern Oregon and Washington. Part II: Linking vegetation characteristics to potential fire behavior and related smoke production. Gen. Tech. Rep. PNW-GTR-355. Portland, OR: USDA Forest Service, Pacific Northwest Research Station. 43 p.

Keeley, KE. 2005. Chaparral fuel modification: what do we know – and need to know? Fire Management Today. Issue No. 4, Volume 65; 11-12.

Merriam, KE, Keeley, JE, and Beyers, JL. (1999) Fuel breaks affect nonnative species abundance in California plant communities. Ecological Applications 16(2):515-527

Schuler, Jamie L.; Briggs, Russell D. 2000. Assessing Application and Effectiveness of Forestry Best Management Practices in New York. National Journal of American Forestry 17(4): 125-134.

SERA - Syracuse Environmental Research Associates, Inc. 2016 Triclopyr –Human Health and Ecological Risk Assessments. Final report. Jul 2016 - Corrected. Manlius, NY. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml

Seyedbagheri, Kathleen A. 1996. Idaho Forestry Best Management Practices: Compilation of Research on their Effectiveness. USDA Forest Service Intermountain Research Station, General Technical Report INT-GTR-339. 89 p

Syphard, AD, Brennan, TJ, and Keeley, JE. 2011. Comparing the role of fuel breaks across southern California national forests. Forest Ecology and Management. 261; 2038-2048.

Syphard, AD, Brennan, TJ, and Keeley, JE. 2014. The role of defensible space for residential structure protection during wildfires. International Journal of Wildland Fire: 23; 1165-1175.

Tu, Mandy, Callie Hurd, and John M. Randall. 2001. Weed control methods handbook: Tools & Techniques for Use in Natural Areas. Version April 2001 (Some chapters updated in 2003 and 2004). The Nature Conservancy. Available online at: http://www.invasive.org/gist/handbook.html

USDA Forest Service. 1990. Soil and Water Conservation Handbook, Region 5 Amendment, 2509.22

USDA Forest Service. 2002. Best Management Practices Effectiveness Monitoring Report, Lolo National Forest. Compiled by Renee Hanna.

USDA Forest Service, 2005. Land Management Plan: Cleveland National Forest. San Diego, California.

USDA Forest Service. 2010. Forest Service Handbook 1909.15—National Environmental Policy Act Handbook. Chapter 40—Environmental Assessments and Related Documents.

http://www.fs.fed.us/r5/spf/fhp/pesticide/index.shtml

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USDA Forest Service. 2013. Programmatic Agreement among the U.S.D.A. Forest Service, Pacific Southwest Region (Region 5), the California State Historic Preservation Officer, the Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation Regarding Processes for Compliance with Section 106 of the National Historic Preservation Act for Management of Historic Properties by the National Forest of the Pacific Southwest Region. Cleveland National Forest files.

USDA Forest Service. 2016a. Biological Evaluation/Assessment for Terrestrial Wildlife and Sensitive Plant Species, Migratory Bird Report. Alpine CD. Cleveland National Forest files.

USDA Forest Service 2016b. Heritage Resources Report. Alpine CD. Cleveland National Forest files.

USDA Forest Service. 2016c. Soils and Hydrology Report. Alpine CD. Cleveland National Forest files.

USDA Forest Service. 2016d. Air Quality Report. Alpine CD. Cleveland National Forest files.

USDA Forest Service. 2016e. Fire and Fuels Report. Alpine CD. Cleveland National Forest files.

USDA Forest Service 2016f. Triclopyr TEA Formulations: Terrestrial Applications (1. lb. /acre, Directed Backpack Foliar). Prepared by Lance Criley using SERA Worksheet Maker Version 5.00.64. Cleveland National Forest files. USDA Natural Resources Conservation Service 2015. Custom Soil Resource Report for San Diego County Area, California.

Ziemer, Robert R. 1986. Water Yields from Forests: An Agnostic View. California Watershed Management Conference, November 18-20, West Sacramento, CA

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