Final Environmental Impact Statement Rio de los Pinos Vegetation ...

United States 

Department of 

Agriculture 

Forest 

Service 

March 2010 

Final Environmental Impact 

Statement 

Rio de los Pinos Vegetation 

Management Project 

USDA Forest Service 

Rocky Mountain Region 

Rio Grande National Forest 

Conejos Peak Ranger District 

Conejos County, Colorado

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Final Environmental Impact Statement Rio de los Pinos Vegetation Management Project 

Rio de los Pinos Vegetation Management 

Project 

Final Environmental Impact Statement 

Conejos Peak Ranger District, Rio Grande National Forest 

Rio Grande County, Colorado 

Lead Agency: USDA Forest Service 

Responsible Official: Jack Lewis, District Ranger 


Rio Grand National Forest 

15571 CR T.5 

La Jara, CO 81140 

For Further Information: Kevin Duda, Interdisciplinary Team Leader 


15571 CR T.5 


(719) 274-8971 

This document is available on the internet: http://www.fs.fed.us/r2/riogrande/projects/decisions/index.shtml 

ABSTRACT: This Environmental Impact Statement is a public document that will provide sufficient evidence and 

analysis for determining whether to manage timber stands to salvage trees infested with the Spruce Beetle. It 

reveals the direct, indirect, and cumulative effects of a proposed action and alternative actions for vegetation 

management through timber harvesting in the Rio de los Pinos Vegetation Management Project Analysis Area. 

This document follows the format established in the Council on Environmental Quality (CEQ) regulations (40 Code 

of Federal Regulations {CFR} Parts 1500-1508). It includes a discussion of the need for the proposal, alternatives 

to the proposal, the impacts of the proposed action and alternatives, and a listing of agencies and persons consulted. 

It is tiered to the 1996 Revised Land and Resource Management Plan, as amended (Forest Plan) for the Rio Grande 

National Forest and the Final Environmental Impact Statement (FEIS) and Record of Decision (ROD) issued for the 

Forest Plan. 

Chapter 1 – Purpose & Need Page 1-ii


SUMMARY 

The Rio Grande National Forest proposes to salvage Engelmann spruce trees that have been 

killed or are infested with spruce beetle and to regenerate areas heavily impacted by the beetle by 

planting Engelmann spruce seedlings in the Rio de los Pinos Analysis Area. The proposed 

treatments would contribute toward providing a sustained yield of forest products from the Rio 

Grande National Forest and would ensure meeting or moving toward Forest Plan and projectspecific 

Desired Conditions. 

The Analysis Area is located approximately two miles northwest of Cumbres Pass, Colorado. 

The Analysis Area falls within Conejos County, Colorado and encompasses approximately 1379 

acres. 

This area was recently analyzed under the County Line Vegetation Management Project EIS, 

signed July 18, 2005. Under the County Line analysis, the area was planned for a preventative 

thinning treatment, in hopes of reducing the impacts of the spruce beetle. A much more severe 

infestation than predicted has occurred, and the actions proposed for this area under the County 

Line EIS would no longer be preventative. 

The need for action is tied to recovering the economic value of dead and dying trees, and 

regenerating heavily impacted areas through artificial regeneration with Engelmann spruce. By 

maintaining a vegetative structure on the Forest that is capable of sustaining timber harvesting 

activities and at the same time contributing to the biodiversity of those forested areas, this project 

helps achieve the Forest-wide Desired Conditions identified in the Forest Plan. This project 

strives to meet the needs of the people of the San Luis Valley and surrounding areas for forest 

and wood products, while protecting resources for future generations. 

Three alternatives were developed in detail for this Environmental Impact Statement (EIS). Each 

action alternative was designed to be viable and consistent with Forest Plan direction. 

Alternatives developed were based on the following themes: 1) No Action, 2) Full Salvage 

Harvesting, and 3) Reduced Salvage Harvesting. Alternative 2 is the Forest Service proposed 

action. 

This EIS discloses the environmental consequences of implementing the proposed action and 

alternatives to that action. A Record of Decision (ROD), signed by the Responsible Official, will 

explain the management and environmental reasons for selecting the alternative to be 

implemented. The ROD will disclose the rationale for choosing the selected alternative; discuss 

the rationale for rejecting other alternatives; and disclose how the decision responds to the 

relevant Key Issues. Based on the effects of the alternatives, the Responsible Official will decide 

whether or not to authorize some level of timber harvesting on all, part, or none of the Analysis 

Area given considerations of environmental consequences and other multiple-use goals and 

objectives. If the decision is made to authorize timber harvesting activities, the management 

framework will be described (including standards, guidelines, project design criteria, and 

monitoring) to ensure that Desired Condition objectives are met or that movement occurs toward 

those objectives in an acceptable timeframe. 

Chapter 1 – Purpose & Need Page 1-iii


Table of Contents 

SUMMARY.................................................................................................................. 1-iii 

CHAPTER 1 ................................................................................................................. 1-1 

1.1 Introduction ........................................................................................................................ 1-1 

1.2 Background ........................................................................................................................ 1-1 

1.3 Proposed Action ................................................................................................................. 1-2 

1.4 Analysis Area ..................................................................................................................... 1-3 

1.5 Purpose of and Need for Action......................................................................................... 1-4 

1.7 Forest Plan Management Area Prescriptions ..................................................................... 1-6 

1.8 Decisions to be Made Based on this Analysis ................................................................... 1-8 

1.9 Key Issues Associated with the Proposed Action .............................................................. 1-8 

1.10 Other Environmental/Social Concerns .......................................................................... 1-10 

1.11 Concerns Outside the Scope of this Analysis ................................................................ 1-10 

1.12 Additional Scoping Comments ...................................................................................... 1-11 

1.13 Opportunities.................................................................................................................. 1-11 

1.14 Public Review and Comment ......................................................................................... 1-11 

1.15 Changes made from the DEIS to the Final EIS ............................................................. 1-12 

CHAPTER 2 ................................................................................................................ 2-1 

2.1 Introduction ........................................................................................................................ 2-1 

2.2 The Process Used to Develop the Alternatives .................................................................. 2-1 

2.3 Alternatives Considered ..................................................................................................... 2-1 

2.3.1 Alternative 1 – No Action .......................................................................................... 2-2 

2.3.2 Alternative 2 (Proposed Action, Preferred Alternative) ............................................ 2-2 

2.3.3 Alternative 3............................................................................................................... 2-4 

2.4 Comparison of Key Issues / Resource Effects by Alternative ........................................... 2-5 

2.5 Project Design Criteria Common to all Action Alternatives ............................................. 2-9 

2.6 Monitoring Measures ....................................................................................................... 2-12 

2.7 Alternatives Considered but Dropped from Detailed Study ............................................ 2-16 

CHAPTER 3 ................................................................................................................ 3-1 

3.1 Introduction ........................................................................................................................ 3-1 

3.2 General Description of the Analysis Area ......................................................................... 3-1 

3.3 Alternatives and their Effects on Key Issues ..................................................................... 3-2 

3.4 Forest Health ...................................................................................................................... 3-4 

3.5 Forest Management ............................................................................................................ 3-9 

3.6 Watershed and Aquatic Resources ................................................................................... 3-13 

3.7 Soils.................................................................................................................................. 3-28 

3.8 Threatened, Endangered and Sensitive Wildlife Species ................................................ 3-34 

3.9 Wildlife ............................................................................................................................ 3-52 

3.10 Fisheries Resources ........................................................................................................ 3-61 

3.11 Scenic Resources ........................................................................................................... 3-66 

Chapter 1 – Purpose & Need Page 1-iv


3.12 Late-successional Forests ............................................................................................... 3-73 

3.13 Threatened, Endangered, and Sensitive (TES) Plant Species ........................................ 3-75 

3.14 Rangeland Management................................................................................................. 3-77 

3.15 Transportation ................................................................................................................ 3-79 

3.16 Recreation Travel Management ..................................................................................... 3-83 

3.17 Economics ...................................................................................................................... 3-87 

3.18 Social.............................................................................................................................. 3-90 

3.19 Heritage Resources ........................................................................................................ 3-94 

3.20 Fire and Fuels Management ........................................................................................... 3-95 

3.21 Noxious Weeds .............................................................................................................. 3-99 

3.22 Cumulative Effects Summary ...................................................................................... 3-101 

3.23 Other Disclosures ......................................................................................................... 3-103 

CHAPTER 4 .................................................................................................................4-1 

4.1 Introduction ........................................................................................................................ 4-1 

4.2 Interdisciplinary Team Members ....................................................................................... 4-1 

CHAPTER 5 ................................................................................................................. 5-1 

5.1 List of Agencies, Organizations, and Persons to Whom Notices of Availability of the DEIS 

were Sent .................................................................................................................................. 5-1 

5.2 List of Agencies, Organizations, and Persons to Whom Notices of Availability of the FEIS 

were Sent .................................................................................................................................. 5-2 

CHAPTER 6 ................................................................................................................ 6-1 

6.1 Introduction ........................................................................................................................ 6-1 

6.2 Responses to Comments .................................................................................................... 6-1 

APPENDIX A- Maps .................................................................................................. A-1 

APPENDIX B- Bibliography ................................................................................... B-1 

APPENDIX C- Terms & Definitions ..................................................................... C-1 

C.1 Terms and Definitions ...................................................................................................... C-1 

C.2 Acronyms ......................................................................................................................... C-3 

APPENDIX D- Watershed Disturbance Table ................................................... D-1 

APPENDIX E- Public Comment ............................................................................ E-1 

E.1 Introduction ....................................................................................................................... E-1 

Chapter 1 – Purpose & Need Page 1-v


1.1 Introduction 

CHAPTER 1 

Purpose of and Need for Action 

The Forest Service has prepared this Environmental Impact Statement (EIS) in compliance with 

the National Environmental Policy Act (NEPA) and other relevant Federal and State laws and 

regulations. This EIS discloses the direct, indirect, and cumulative environmental impacts that 

would result from the proposed action and alternatives. It provides the Responsible Official with 

the information necessary to make an informed decision. The decision will be documented in a 

Record of Decision (ROD) accompanying the final EIS after receiving and considering public 

comment. 

This chapter describes the proposed action, the area and scope, the purpose of and need for 

action, direction from the Rio Grande National Forest (RGNF) Revised Land and Resource 

Management Plan, as amended (hereafter referred to as the Forest Plan [USDA Forest Service 

1996a]), the decisions to be made, public involvement, the Key Issues associated with the 

proposed action, and other environmental and social concerns. 

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

found in the project planning record located at the Conejos Peak Ranger District Office in La 

Jara, Colorado. 

Words in bold italics are defined in Appendix C – List of Terms and Acronyms. 

1.2 Background 

The spruce beetle (Dendroctonus rufipennis) is the most significant cause of mortality in mature 

Engelmann spruce (Picea engelmannii) stands. Large-scale spruce beetle infestations in excess 

of 100,000 acres have occurred over the last 25 years in North America from Alaska to Arizona. 

The scope of spruce beetle outbreaks can be significant, at times killing up to 80% or more of the 

mature spruce trees within a watershed (Holsten et al. 1999). 

Many areas of the Rio Grande National Forest (RGNF) are currently experiencing severe 

infestations of spruce beetle, including the Rio de los Pinos Analysis Area. Endemic spruce 

beetle populations usually live in windthrown trees but as populations increase, they may enter 

susceptible, large diameter standing trees. Spruce stands are highly susceptible to spruce beetle 

when they are on highly productive sites, have an average diameter at breast height (DBH) 

greater than 16 inches, have a basal area greater than 150 square feet per acre, and are in stands 

that are predominantly spruce (Holsten et al. 1999). 

Chapter 1 – Purpose & Need Page 1-1


The Rio de los Pinos Analysis Area contains stands that have become highly susceptible to 

spruce beetle infestation due to recent drought conditions and local epidemic beetle populations. 

Significant spruce beetle activity within standing trees was first noticed in the Analysis Area 

during the summer of 2007. Field reconnaissance has shown that the spruce beetle infestation 

has spread through many stands at an epidemic level which is resulting in significant spruce 

mortality. 

This proposal is not intended to stop or control the spruce beetle infestation but rather to take 

advantage of the existing road system to salvage trees killed by spruce beetle to recover 

economic value, provide a sustained yield of forest products from the RGNF, provide funding to 

regenerate heavily impacted stands, and create areas suitable for artificial regeneration. It is 

also intended to create conditions less favorable to spruce beetle infestations in adjacent stands 

for the next 20 years. The current forest condition represents an unacceptable risk for long-term 

loss of commercial productivity, especially where the potential for effective treatment is 

foregone. 

In the early 1990’s, an analysis of the area was initiated (El Rosa) and scoped. This analysis was 

not finished and no decision was made based on this incomplete analysis. 

This area was recently analyzed under the County Line Vegetation Management Project EIS, 

signed July 18, 2005. Under the County Line analysis, the area we are analyzing in this 

document was planned for a preventative thinning treatment, in hopes of reducing the impacts of 

the spruce beetle. A much more severe infestation than predicted has occurred, and the actions 

proposed for this area under the County Line EIS would no longer be preventative. The 

preventative thinning did not occur. 

1.3 Proposed Action 

The Rio Grande National Forest proposes to salvage Engelmann spruce trees that have been 

killed by, or are infested with, spruce beetle. Additionally, we propose to perform ¼ to 5 acre 

patch cuts across the salvage units to enhance visual resources, and to regenerate areas heavily 

impacted by the spruce beetle by planting Engelmann spruce seedlings within the Rio de los 

Pinos Analysis Area. The proposed treatments would contribute toward providing a sustained 

yield of forest products from the Rio Grande National Forest and would ensure meeting or 

moving toward Forest Plan Desired Conditions for Management Area Prescriptions (MAP) 5.13 

(discussed in detail in 1.7). This proposed action would begin in 2010. 

Salvage harvesting of Engelmann spruce would occur on approximately 607 to 878 acres. 

Anywhere from 38 to 60 trees per acre 8” diameter at breast height (DBH) and above would 

remain in the salvage units for scenic resources. Patch cuts would occur on approximately 60 

acres, harvesting both Engelmann spruce and Subalpine fir. Ground-based logging systems 

would be utilized on the entire area, yielding 8 – 13.1 MMBF (16,000-26,200 ccf) timber 

volume. After harvest, reforestation would occur on approx. 50 to 75 acres of non-stocked and 

under-stocked areas. The exact planting area would depend how well existing natural 

regeneration meets Forest Plan stocking requirements. 



Under this proposal, trees 8 inches DBH and larger would be considered for harvest. With the 

exception of the patch cuts, all live non-beetle infested trees not interfering with operations 

would be left. Rehabilitation of areas experiencing heavy spruce mortality would occur through 

natural and artificial regeneration. 

Most of the treatment areas are accessible using the existing transportation system. Some road 

reconstruction, maintenance, and reopening one or more old, unclassified roads would be 

required. During the project, road reconstruction and/or maintenance (pre-haul, during haul, 

post-haul) would occur on approximately 11.9 miles of classified roads, and up to approximately 

3.3 miles of old roads would be temporarily re-opened, then closed at the end of the project. 

This work would be needed for access, improved safety, and additional resource protection. 

Maintenance may include grading, culvert replacement, and spot gravel applications over a 

number of sections of road. Reconstruction may include drainage installation and surface 

reconditioning and spot gravel applications on native-surface roads. These efforts would reduce 

erosion from these road sections and the resultant sedimentation. Road reconstruction and 

maintenance would involve work on Forest System Roads (FSR) 118, 118.1C, 118.1G, 118.1J, 

118.1K, 118.2, 118.2D, 118,2E, and 118.2G. Upon project completion, all classified roads that 

were closed to motor vehicle travel prior to the project would remain closed. Classified roads 

that are presently closed and old roads that would be reconstructed for log haul would be 

rehabilitated by subsoiling and seeding according to the project design criteria in Table 2.5-6 in 

order to reduce resource impacts and to put the road templates back into resource production. 

1.4 Analysis Area 

The Analysis Area covers approximately 1379 acres. It is located along the Rio de los Pinos on 

the Conejos Peak Ranger District, approximately two miles northwest of Cumbres Pass. (Figure 

1.4-1). 

The legal description is Township 33 North, Range 4 East, Sections 22, 23, 25-27, 34-36, 

NMPM. 

Figure 1.4-1 shows the Analysis Area and vicinity in context to local communities and features. 



1.5 Purpose of and Need for Action 

Figure 1.4-1. Rio de los Pinos Analysis Area 

The purpose of this action is to implement the Forest Plan by making live and dead timber 

available to the timber industry as part of the Rio Grande National Forest’s timber sale program. 

This proposal has been initiated because existing conditions vary from the Desired Conditions 

defined in Forest Plan MAP 5.13. This disparity indicates a need for the salvage of dead trees 

before they lose economic value, provision of wood products to benefit the local and regional 

economy, reforestation of areas severely impacted by spruce beetle, reduced long-term fuel 

buildup in areas severely impacted by spruce beetle, and improved forest stand condition. 

When seeking to reduce the standing dead fuel component, the goal is to reduce the duration and 

intensity of a potential wildland fire, thus influencing the severity of its impact. Standing dead 

fuel is expected to become heavy down fuel within 20-50 years. 

The Rio de los Pinos Vegetation Management Project is designed to achieve Regional and 

Forestwide Objectives identified in Chapter II of the Forest Plan. These objectives are displayed 



below in Table 1.5-1. 

Table 1.5-1. Relevant Regional and Forestwide Objectives. 

Forestwide Objective 2.2 – Manage the Forest to maintain or improve the health and vigor of 

all native plant associations (Forest Plan p. II-2). 

Forestwide Objective 2.10 – Use appropriate vegetative-management methods (e.g., 

Prescribed Natural and Management Ignited Fires, timber harvesting, grazing, etc.) to modify 

unacceptable fuel profiles and reduce potentially unacceptable future high-intensity wildfires. 

Regional Objective 3 – Provide for multiple uses and sustainability of National Forests and 

Grasslands in an environmentally acceptable manner (Forest Plan p. II-3). 

Forestwide Objective 3.2 – Emphasize long-term sustainable production of resources for 

economies, communities, and people (Forest Plan p. II-3). 

Forestwide Objective 3.3 – Use a range of silvicultural prescriptions to achieve ecosystem 

management objectives. These objectives may include supplying forage for wildlife, reducing 

insect and disease infestations, maintaining or improving aspen stands, or enhancing scenery 

(Forest Plan p. II-3). 

Forestwide Objective 3.4 – Use existing roads, instead of constructing new ones (Forest Plan 

p. II-3). 

1.6 Governing Management Direction 

All land management decisions are governed by an array of law and policy which direct or 

provide bounds for those decisions. While some law and policy provide constraints, others 

provide intent and direction for certain actions to occur. This is a general overview of such 

guidance which gives intent or direction for the proposed action. 

Where consistent with other Forest Plan goals and objectives, there is Congressional intent to 

allow timber harvesting on suitable lands (Organic Administration Act of 1897, Multiple-Use 

Sustained-Yield Act of 1960; Forest and Rangeland Renewable Resources Planning Act of 1974; 

Federal Land Policy and Management Act of 1976; National Forest Management Act of 1976). 

Intent is also expressed to allow the salvage of dead timber and to protect against and prevent the 

spread of insects and disease (Forest and Rangeland Renewable Resources Planning Act of 

1974). Such actions are also directed and authorized by Federal Regulation (36CFR221.3; 

36CFR223). In keeping with these intents, it is Forest Service policy to provide timber resources 

to the local and regional economy (Forest Service Manual [FSM] 2402; Forest Plan, pp. II-3 



through II-4), salvage dead trees (FSM 2435), and treat stands experiencing insect or disease 

infestations or to prevent infestations (Forest Plan IV-25 through IV-28). 

Specific management direction for the RGNF is provided in the Forest Plan and its 

accompanying Record of Decision (1996). The Forest-wide Desired Condition for timber 

resources, as provided in the Forest Plan, states: “The vegetative structure on the RGNF is 

capable of sustaining timber harvesting that supplies wood products for humankind while 

providing for the biological diversity of those forested areas.” 

The rationale for the proposed action is tiered to both the Forest Plan and the Final 

Environmental Impact Statement (FEIS) for the Revised Land and Resource Management Plan 

(USDA Forest Service 1996). The Forest Plan FEIS addresses concerns about forest health and 

the potential for spruce beetle epidemics (FEIS pp. 3-219 to 3-221). Forestwide objectives 

include reducing insect and disease infestations and using a range of silvicultural prescriptions to 

achieve ecosystem management objectives (Forest Plan p. II-3). The Forest Plan FEIS also 

addresses the demonstrated and ongoing demand for wood and miscellaneous forest products 

such as firewood and poles (FEIS p. 3-159). 

Any regulated timber harvest activities would occur on lands classified as suitable for timber 

production, as amended by the Timber Suitability amendment to the Forest Plan (3/2/2000). 

1.7 Forest Plan Management Area Prescriptions 

As mentioned above, specific management direction for the Rio Grande National Forest is given 

through the Revised Land and Resource Management Plan, 1996. Within this plan, lands are 

delineated and managed for a particular emphasis or theme known as a Management Area 

Prescription (MAP). Each MAP in the Forest Plan has a description of the theme and physical 

setting for the area, a description of the desired future conditions for the area, and a list of 

standards and guidelines that apply to the area. Figure 1.7-1 shows the relevant MAPs for the 

Rio de los Pinos Analysis Area. 



Figure 1.7-1. Analysis Area Boundary and Management Area Prescriptions. 

The Rio de los Pinos Analysis Area resides primarily in MAP 5.13-Forest Products. No actions 

occur within Inventoried Roadless Areas. Following is a description of the MAP that is 

impacted by the proposed actions. 

MAP 5.13 – Forest Products: The intent of this MAP is to 

allow a full range of activities, with an emphasis on the 

production of commercial wood products. This MAP is 

applied in areas where the potential to grow timber is high, 

and where the harvest of commercial timber is intended. 

Operations are focused on wood production. The intent is to 

maintain suitable forested areas with commercially valuable 

species at ages, densities, and sizes that allow growth rates 

and stand health conducive to providing a sustained yield of 

forest products. The area has a well developed 

transportation system. Wildfires are suppressed and insect and disease populations are 

maintained at endemic levels, to protect commercial forest products (Forest Plan p. IV-27). 



1.8 Decisions to be Made Based on this Analysis 

This EIS discloses the environmental consequences of implementing the proposed action and 

alternatives to that action. A separate Record of Decision (ROD), signed by the Responsible 

Official, will explain the management and environmental reasons for choosing the selected 

alternative; discuss the rationale for rejecting other alternatives; and disclose how the decision 

responds to the relevant issues. 

The decision for the Responsible Official to make in the ROD is whether or not to implement 

some level of timber harvest and other activities described on all, part, or none of the Analysis 

Area given considerations of multiple-use goals and objectives. If the decision is made to 

authorize some level of harvest, the management framework will be described (including 

standards and monitoring) to ensure that Forest Plan Desired Condition objectives are met or that 

movement occurs toward those objectives in an acceptable timeframe. 

1.9 Key Issues Associated with the Proposed Action 

An issue is defined as a point of discussion, debate, or dispute about the effects of a proposed 

action on a physical, biological, social, or economic resource. An issue is not an activity in 

itself; instead, it is the projected effects of the activity that create the issue. For example, timber 

harvesting is an activity, but its effects on a resource can form an issue. 

Some issues are considered Key because of the extent of their geographic distribution, the 

duration of their effects, or the intensity of interest or resource conflict. Key Issues are used to 

develop and compare alternatives, prescribe mitigation measures, and analyze the environmental 

effects. For an issue to be considered Key, it must be relevant to the specific project and 

appropriately addressed at that level. The Forest Service identifies Key Issues through 

internal/external contact and discussion (scoping). External scoping involves the general public, 

tribal governments, State, and other Federal Agencies. 

Once scoping comments were received through external scoping, the interdisciplinary team 

(IDT) used an issue-sorting process to identify Key Issues by which the proposed action and all 

alternatives will be analyzed. The process is intended to ensure that all Key Issues are identified 

and that all relevant issues are appropriately addressed in the analysis. Each concern received 

during scoping was considered as a potential issue and was evaluated to determine whether the 

related issue was addressed through project design, addressed through implementation of projectspecific 

mitigation measures, or beyond the scope of the project. Those concerns addressed the 

same way in all alternatives through design criteria are described in Chapter 2, Section 2.5 under 

“Project Design Criteria Common to all Action Alternatives.” 

Through this process, two Key Issues were identified for this Analysis Area. The Key Issues, 

along with the indicator(s) of each issue, are presented below. Indicators that are quantifiable, 

linked to cause-and-effect relationships, and responsive to the Key Issues are used to compare 

the effects among alternatives. 



 

Key Issue 1 –Watershed Health 

Concerns have been expressed by the public that streams may be 

damaged or impaired by the proposed actions. With implementation of 

Forest Plan standards and guidelines, project impacts on watershed health 

can be kept within established allowable limits. Watershed Health will 

be measured against the Forest Plan standards and guidelines for the 

watershed resource. 

Watershed integrity is tied to structural changes in vegetation type, soil type, moisture 

availability, riparian vegetation, and other ecological characteristics. Structural characteristics 

combine to create functional integrity for the watershed. If the structure or function is 

compromised, the consequences may be apparent and may include impacts such as increased 

erosion, stream sedimentation and lessened subsurface flows. The Interdisciplinary Team (IDT) 

identified watershed integrity and function as a Key Issue in which alternatives will be compared 

against. 

Indicator: a) total acres treated, b) percent area surface disturbance by watershed, c) miles of 

old roads re-opened, d) miles of road maintenance, e) miles of new temporary road construction. 

The indicators are intended to provide a quantitative measure to examine the responsiveness and 

relative differences of each alternative to the Key Issue of watershed integrity and function. 

 

Key Issue 2 –Forest Condition 

While some members of the public expressed support for the proposed 

action, others expressed concern that forest condition may not be improved 

by the proposed actions, and in fact could be worsened. 

As described in the purpose and need, current stand conditions within the 

treatment areas do not meet the Setting and Desired Conditions for Forest 

Plan Management Area Prescription 5.13. 

Forest Condition is defined solely as the condition of the coniferous component in the Analysis 

Area, in this case Spruce-Fir. Condition will be measured against the Setting and Desired 

Conditions for Management Area Prescription 5.13. 

Indicator: 

a) acres salvage harvesting, b) percent of late-successional habitat structural class 

changed, c) spruce beetle risk rating by acres, d) volume of heavy fuels removed from project 

area in tons 

The indicators are intended to provide a quantitative measure of comparison between alternatives 

in regards to Forest Condition. 



1.10 Other Environmental/Social Concerns 

Other environmental and social concerns were identified through this scoping process. As 

mentioned earlier, the IDT used an issue-sorting process to identify which concerns were Key 

Issues. Each concern received during early scoping was considered as a potential issue. It was 

then evaluated to determine whether the concern was already resolved through land use 

designations, implementation of Forest Plan standards & guidelines and Best Management 

Practices (BMP’s), project-specific design criteria or mitigation measures, through processes or 

analyses routinely conducted by the IDT, or was beyond the scope of the project. All concerns 

that fell within these categories were considered resolved. 

On the other hand, concerns that would have to be addressed through spatial location of activities 

or concerns that would drive (or partially drive) an alternative were considered unresolved. 

These unresolved concerns were developed into the resulting Key Issues. 

While not Key Issues, resource concerns addressed through routine processes or analyses are 

also evaluated. These concerns are addressed in Chapter 3. 

1.11 Concerns Outside the Scope of this Analysis 

Some comments received during scoping are not specific to this project or relate to issues that 

are not involved with the scope of this analysis. These include, but are not restricted to, the 

following: 

ATV use on the Continental Divide Trail 

Motorized use on the Rio Grande National Forest is restricted to designated routes. Motorized 

use, including ATV use, occurring off of designated routes is illegal and is a law enforcement 

concern outside the scope of this project. 

Inventoried Roadless Areas 

There are no inventoried roadless areas within the Analysis Area. 

How this project differs from other proposed projects in the Analysis Area 

This concern stems from the El Rosa proposed action. No decision was made on the El Rosa 

timber sale, therefore no on-the-ground actions were taken. 

Overlap with the County Line Timber Sales 

The proposed Rio de los Pinos harvest units were analyzed under the County Line EIS, but they 

were not harvested. 



1.12 Additional Scoping Comments 

Some comments received were considered by the IDT as suggested courses of action, rather than 

concerns about the consequence of the proposed action. These suggestions were captured and 

reviewed for possible incorporation into the project. Many of these comments came in the form 

of project-specific design criteria, while others came as proposed alternatives to the proposed 

action. All such comments were evaluated, but not all fit within the bounds of the project 

purpose and need. Project design criteria and proposed alternatives are further addressed in 

Chapter 2, Section 2.5. 

1.13 Opportunities 

As part of the internal and public scoping process, several other projects within the Analysis 

Area were identified and include: 

Trailhead relocation / improvement 

Noxious weed treatment 

Reforestation for beetle-infested stands 

Wildlife habitat improvements 

Road density reduction 

Planting and seeding 

Road repair and rehabilitation – including disconnecting road drainage from stream 

courses 

Firewood cutting 

Interpretive signing 

Culvert replacement to facilitate fish movement 

Some or all of these projects are incorporated into the proposed actions and may be funded 

entirely or partly by funds generated through the action alternatives (Knutson-Vandenberg Act) 

or other sources. They are listed here to build upon and to encourage additional ideas for future 

actions within the Analysis Area. 

1.14 Public Review and Comment 

Public involvement was a key component in the planning process. The Rio Grande National 

Forest invited public comment and participation regarding this proposal through a variety of 

scoping methods. These methods included listing in the Schedule of Proposed Actions 

beginning in October 2007, an initial scoping letter, public notice in the Valley Courier 

(published January 15 and 16, 2008), the newspaper of record, letters, e-mails, and phone call 

contacts. 



The initial scoping letter was sent on January 11, 2008 to 497 individuals, agencies, and 

organizations on the Rio Grande National Forest Schedule of Proposed Actions (SOPA) mailing 

list. The letter invited comments on the proposed Rio de los Pinos Vegetation Management 

Project. The scoping discussed the background, purpose of and need for action, and the 

proposed action. 

A second scoping effort began on October 9, 2008 after the project became an EIS. The Notice 

of Intent to complete an EIS was filed in the Federal Register on October 9, legal notices were 

placed in the newspaper of record on October 9 and 10, 2008, and a scoping letter was sent out 

on October 9, 2008. The scoping information was also available on the Forest public website. 

Comments from both scoping efforts were considered in the preparation of this EIS. 

On November 19, 2009 the Draft EIS (DEIS) was sent out for Public Comment. A Notice of 

Availability was posted in the Federal Register on December 4, 2009, and public notice was 

published in the Valley Courier (December 1, 2009), the newspaper of record. Several 

individuals, organizations, and agencies were also contacted, providing notice of the availability 

of the DEIS. These parties are listed in Chapter 5. 

Three public comments from four individuals or organizations were received in response to the 

DEIS. A summary of these responses is displayed below in Table 1.14-2. Actual public 

comments are displayed in Appendix E, and USFS responses to the comments are shown in 

Chapter 6. 

Table 1.14-2. Public Comment to the DEIS 

Commenter Contact Type Date Representing 

Joanie Berde Letter 12/11/2009 Carson Forest Watch 

Rocky Smith/Bryan Bird Letter 01/13/2010 Colorado Wild, WildEarth Guardians 

Larry Svoboda Letter 01/14/2010 US EPA, Region 8 

1.15 Changes made from the DEIS to the Final EIS 

The USFS has incorporated changes in the Final Environmental Impact Statement as a result of 

public comments to the DEIS. Following is a brief discussion of the changes made: 

• Public comment pointed out minor errors in the text and figures. These errors were 

corrected. 

• Discussion was added to the Forest Health analysis concerning western spruce budworm. 

See Section 3.4. 

• Public comment expressed concern that potential for windthrow was not evaluated. 

Although windthrow as considered in the DEIS, additional analysis was added specific to 

windthrow. See Section 3.5. 

• Public comment expressed concern that effects to wetlands were not fully analyzed. A 

section specific to the potential effects on wetlands was added to the FEIS to disclose the 

wetlands analysis that was conducted. See Section 3.7. 



• Discussion was added to the Threatened, Endangered, and Sensitive Species section, 

better describing how Objectives, Standards, and Guidelines of the Southern Rockies 

Lynx Amendment are met by the action alternatives. See Section 3.8. 

• Chapter 5, Notifications & Disclosures, was added to the document. This chapter 

identifies which agencies, organizations, and persons received disclosure concerning the 

statement. 

• Chapter 6, Response to Public Comments, was added to the document. This chapter 

addresses public comments received in response to the DEIS. Appendix E, Public 

Comments, was also added to disclose the actual public comments received. Annotation 

was added to comments for reference between Chapter 6 and Appendix E. 

• Minor editorial changes and clarifications were made throughout the FEIS. 

None of these changes had a substantial effect on the comparative evaluation of the alternatives 

or the conclusions drawn from the FEIS. All changes were made as a direct result of internal and 

external scoping and have been fully analyzed in the Final Environmental Impact Statement. 






CHAPTER 2 

Alternatives including the Proposed Action 

This chapter describes the alternatives developed to meet the purpose of and need for action and 

address the Key Issues identified in Chapter 1. The proposed action and alternatives, including 

the No Action alternative, are described and compared. Three alternatives were developed for 

analysis. This chapter also provides a summary of the environmental consequences of the 

alternatives as measured in Chapter 3. 

2.2 The Process Used to Develop the Alternatives 

An Interdisciplinary Team (listed in Chapter 4) considered the elements listed below when they 

developed the alternatives for this analysis: 

The purpose of and the need for this project identified in Chapter 1 (Section 1.5). 

Key Issues identified in Chapter 1 (Section 1.9). 

The goals, objectives, and Desired Conditions for the Analysis Area as described in the 

Forest Plan for the Rio Grande National Forest (Section 1.7). 

Comments and suggestions made by the public, the State, and other agencies during the 

scoping process. 

The laws, regulations, and policies that govern land management on National Forests. 

Site-specific resource information. 

2.3 Alternatives Considered 

Three alternatives were developed in detail for this environmental analysis process. Each action 

alternative was designed to be a viable alternative consistent with Forest Plan direction. Other 

alternatives gained through the scoping process were also considered, but not developed in 

detail. These alternatives are described in Section 2.7. 

The alternatives presented below represent a range of reasonable alternatives, given the purpose 

and need and Key Issues for the proposed action. 

Three alternatives are described and analyzed in detail as follows: 

Chapter 2 – Alternatives Page 2-1


♦ Alternative 1 – No Action 

♦ Alternative 2 – Full Salvage Harvest 

♦ Alternative 3 – Reduced Salvage Harvest (Some proposed harvest areas not treated to 

reduce potential negative impacts to wet areas) 

2.3.1 Alternative 1 – No Action 

The Council for Environmental Quality (CEQ) regulations for implementing the National 

Environmental Policy Act (NEPA) requires that a no action alternative be developed as a 

benchmark from which the agency can evaluate the proposed action. Under Alternative 1, 

natural processes would be allowed to occur without additional human intervention. No 

sanitation/salvage of beetle infested or killed timber would occur. New trees would not be 

planted and no road work would occur beyond normal maintenance. Additionally, activities 

associated with the action alternatives identified in Section 1.13 under Opportunities also would 

not occur. Current activities such as livestock grazing and dispersed recreation would continue. 

The key features of the No Action alternative are summarized below in Table 2.3.1-1. 

Table 2.3.1-1 Key Features of Alternative 1 

Key Feature Description 

Total Area Treated with Salvage Prescription 0 Acres 

Area of Small Patch Cuts within Salvage Units 0 Acres 

Timber Volume-Sawtimber 0 MMBF 

Timber Volume Fuelwood 0 Cords 

Steep slopes logged (35-40% conventional) 0 Acres 

System Road Reconstruction 0.0Miles 

System Road Spot Reconstruction 0.0 Miles 

System Road Maintenance 8.7 Miles 

Existing Road added to System 0.0 Miles 

Temporary Road Construction 0.0 Miles 

Re-opening of Old Roads 0.0 Miles 

Artificial Regeneration 0 Acres 

Noxious Weed Treatment 3 Acres 

2.3.2 Alternative 2 (Proposed Action, Preferred Alternative) 

Alternative 2 (the proposed action) was designed to address the Key Issue of Forest Condition. 

The Rio de los Pinos Spruce Beetle Project was initiated due to the existing forest condition 

within the Analysis Area and as such was identified as a Key issue. Existing Forest Conditions 

consist of timber stands with a high mortality component due to beetle activity. This alternative 

would provide an opportunity to harvest products before they are lost (salvage). It would also 

maintain reforestation of the salvage units through artificial regeneration if needed. 

This alternative proposes to conduct salvage harvest of dead and infested Engelmann spruce 

trees 8 inches DBH and larger on approximately 878 acres. Small patch cuts (¼ to 5 acres) 



would be spread throughout the units to maintain scenic integrity. Outside of the patch cuts, all 

live, uninfested trees not interfering with operations would be left in the salvage areas. After 

harvest of the dead and dying trees, artificial regeneration would occur on all non-stocked and 

under-stocked areas. The exact planting area would depend on how well existing natural 

regeneration meets Forest Plan stocking requirements. 

This alternative also proposes changes to the Forest Service travel system. After harvest, the 

Forest System Trail 736 trailhead would be relocated and 0.8 miles of FSR 118.2 would be 

converted to system trail. Additionally, a separate section of FSR 118.2 would be 

decommissioned and FSR 118.2G would be opened for long-term trailhead access. If funding 

became available, the Maintenance Level for FSR 118.2 & 118.2G would be increased to Level 

3. These actions would move road disturbance away from the Rio de Los Pinos, improve road 

drainage, reduce reconstruction costs, and cause a ½ mile net reduction in open road density. 

The key features of Alternative 2 are summarized below in Table 2.3.2-1. 





Timber Volume-Sawtimber 11.0 to 13.1 MMBF 

Timber Volume Fuelwood 440 to 524 Cords 


System Road Reconstruction 6.7 Miles 



Converted/Decommissioned Road 1.2 Miles 

Temporary Road Construction 0.2 Miles 


Artificial Regeneration Up to 75 Acres 


The planned activities by unit for Alternative 2 are presented in Table 2.3.2-2 below. 

2.3.2-2 Alternative 2 Activities 

Unit Number Acres Harvest Treatment Patch Cut (Acres) 

1 137 Salvage 11 





Most of the treatment areas are accessible using the existing transportation system, but some 

minor specified system road reconstruction would be required to improve safety and to provide 

for additional resource protection. Fill material for this work would be obtained from an existing 

gravel pit at the intersection of FSR 118 & FSR 116, or from outside weed-free sources as 

necessary. Most of the reconstruction/spot reconstruction activities are driven by the watershed 

restoration opportunities listed in Chapter 1, Section 1.13. 



Map A-2 in Appendix A displays the road system and harvest units proposed as part of 

Alternative 2. The road work needed for Alternative 2 is further described in Section 3.15 

(Transportation/Travel Management) and detailed in Table 3.15-1. 

2.3.3 Alternative 3 

Alternative 3 was designed to address the Key Issues of Watershed Health and Forest Condition. 

Existing forest conditions consist of timber stands with a high mortality component due to beetle 

activity. The alternative will treat less area than Alternative 2, eliminating those areas with high 

stream density. It would also maintain reforestation of the salvage units through artificial 

regeneration if needed. 

This alternative proposes to conduct salvage harvest of dead and infested Engelmann spruce 

trees 8 inches diameter at breast height (DBH) and larger on approximately 607 acres. Small 

patch cuts (¼ to 5 acres) would be spread throughout the units to maintain scenic integrity. 

Outside of the patch cuts, all live, un-infested trees not interfering with operations would be left 

in the salvage areas. After harvest of the dead and dying trees, artificial regeneration would 

occur on all non-stocked and under-stocked areas. The exact planting area would depend on how 

well existing natural regeneration meets Forest Plan stocking requirements. 

Like Alternative 2, this alternative also proposes changes to the Forest Service travel system. 

After harvest, the Forest System Trail 736 trailhead would be relocated and 0.8 miles of FSR 

118.2 would be converted to system trail. Additionally, a separate section of FSR 118.2 would be 

decommissioned and FSR 118.2G would be opened for long-term trailhead access. If funding 

became available, the Maintenance Level for FSR 118.2 & 118.2G would be increased to Level 

3. These actions would move road disturbance away from the Rio de Los Pinos, improve road 

drainage, reduce reconstruction costs, and cause a ½ mile net reduction in open road density. 

The key features of Alternative 3 are summarized below in Table 2.3.3-1. 





Timber Volume-Sawtimber 8.0 to 9.9 MMBF 

Timber Volume Fuelwood 320 to 400 Cords 


System Road Reconstruction 5.5 Miles 



Converted/Decommissioned Road 1.2 Miles 

Temporary Road Construction 0 Miles 


Artificial Regeneration Up to 56 Acres 






The planned activities by unit for Alternative 3 are presented in Table 2.3.3-2 below. 

2.3.3-2 Alternative 3 Activities 

Unit Number Acres Harvest Treatment Patch Cuts 

1 0 0 





As with Alternative 2, most of the treatment areas are accessible using the existing transportation 

system, but some minor specified system road reconstruction would be required to improve 

safety and to provide for additional resource protection. Fill material for this work would be 

obtained from an existing gravel pit at the intersection of FSR 118 & FSR 116, or from outside 

weed-free sources as necessary. Most of reconstruction/spot reconstruction activities are driven 

by the watershed restoration opportunities listed in Chapter 1, Section 1.13. 

Map A-3 in Appendix A displays the road system and harvest units proposed as part of 

Alternative 3. The road work needed for Alternative 3 is further described in Section 3.15 

(Transportation/Travel Management) and detailed in Table 3.15-3. 

2.4 Comparison of Key Issues / Resource Effects by Alternative 

A comparison of the Key Issues by alternative is shown below in Table 2.4-1. Key Issues were 

previously listed in Chapter 1, Section 1.9. Alternatives and their effects on Key Issues are 

further addressed in Section 3.3 



Table 2.4-1. Comparison of the Key Issues by Alternative. 

Key Issue 

1. Watershed 

Health 

2. Forest 

Condition 

Indicator(s) 

a. Total area treated (acres) 

b. Disturbance by watershed 

-50501 (6 th Level) 

-5050102 (7 th Level) 

-5050101 (7 th Level Watershed of 

Concern) 

c. Old roads re-opened (miles) 

d. Road maintenance (miles) 

e. New temp road construction 

(miles) 

a. Salvage harvesting (acres) 

b. Late-successional habitat 

structural class changed 

(percent) 

c. Spruce beetle risk rating 

(average) 

d. Heavy fuels removed 

from project area 

(tons/acre) 

1 

No Action 

0 acres 

11.5% 

5.3% 

16% 

0 miles 

8.7 miles 

0 miles 

0 acres 

0% 

Moderate- 

High 

0 

ALTERNATIVES 

2 

Full Salvage 

Harvest 

(Proposed 

Action) 

878 acres 

12.2% 

6.1% 

18.0% 

3.3 miles 

11.9 miles 

0.2 miles 

878 acres 

17.8% 

Moderate 

25 tons/acre 

3 

Reduced 

Salvage 

Harvest 

607 acres 

12.0% 

5.9% 

17.4% 

2.5 miles 

9.9 miles 

0.0 miles 

607 ac 

12.3% 


19 tons/acre 

Table 2.4-2 provides a comparison summary of effects on resources as described in Chapter 3. 

Table 2.4-2. Comparison of Alternatives – Summary of Effects on Resources. 

Resource and 

Unit of Measure 

1 

No Action 

2 

Full Salvage 

Harvest 

ALTERNATIVES 

3 

Reduced Salvage 

Harvest 

--- FOREST CONDITION --- 

Acres of Sanitation/Salvage 0 878 acres 607 acres 

Late-successional habitat structural 

class changed (percent) 

0% 17.8% 12.3% 

Spruce beetle risk rating Moderate-High Moderate Moderate 

Heavy fuels removed from project 

area (tons/acre) 

0 25 tons/acre 19 tons/acre 

--- TIMBER MANAGEMENT/SILVICULTURE --- 

Harvest Volume in Million Board 0 MMBF 11.0-13.1 8.0-9.9 MMBF 

Feet (MMBF) 

MMBF 

Acres of Artificial Regeneration 0 acres 75 acres 56 acres 

--- WATERSHED and AQUATIC RESOURCES --- 

Percent Disturbance by Watershed 

130100050501 (6 th Level) 11.5% 12.2% 12.0% 

13010005050102 (7 th Level) 5.3% 6.1% 5.9% 




Resource and 


1 

No Action 

2 

Full Salvage 

Harvest 

ALTERNATIVES 

3 


Harvest 

13010005050101 (7 th Level 

Watershed of Concern) 

16% 18.0% 17.4% 

Miles of Road Construction 0 miles 0.2 miles 

(temp) 

0.0 miles (temp) 

Road Reconstruction/ Spot 

Reconstruction (miles) 

--- SOIL RESOURCES --- 

0 miles 10.1 miles 8.1 miles 

Total acres treated 0 acres 878 acres 607 acres 

Soil Impacts in Project Area (percent) 2-5% ≤ 15% ≤ 15% 

---WILDLIFE--- 

Threatened and Endangered No Effect to three 

species; may 

effect but not 

likely to adversely 

affect Lynx. 

Sensitive Wildlife Species No Impact to all 

21 species; May 

Impact 8 species. 

Management Indicator Species No discernable 

effect on 

population 

persistence or 

viability of 3 

species. No 

noticeable change 

in habitat 

conditions or 

population trend 

of 2 species. 

Migratory Birds Potential minor 

effects to 

individuals. 

General Wildlife Potential minor 

effects to 

individuals. 

No Effect to 

three species; 

may effect but 

not likely to 

adversely 

affect Lynx. 

No Impact to 

21 species; 

May Impact 8 

species. 

No 

discernable 

effect on 

population 



species. No 

noticeable 

change in 

habitat 

conditions or 

population 

trend of 2 

species. 

Potential 

minor effects 

to individuals. 

Potential 

minor effects 

to individuals. 

No Effect to three 

species; may effect 

but not likely to 

adversely affect 

Lynx. 

No Impact to 21 

species; May 

Impact 8 species. 

No discernable 

effect on population 



species. No 

noticeable change in 

habitat conditions or 

population trend of 

2 species. 

Potential minor 

effects to 

individuals. 

Potential minor 

effects to 

individuals. 

--- FISHERIES --- 

Acres Treated 0 acres 878 acres 607 acres 

Road Reconstruction/ Spot 

Reconstruction 


Aquatic Species No loss of No loss of No loss of viability 

--- SCENIC RESOURCES --viability 

viability 

Scenic Integrity Objectives No change Change to Change to Moderate 




Resource and 


1 

No Action 

2 

Full Salvage 

Harvest 


ALTERNATIVES 

3 


Harvest 

--- LATE SUCCESSIONAL FORESTS --- 

Acres of Old Growth Harvested 0 Acres 0 Acres 0 Acres 

Percent of late-successional 

Spruce/Fir Affected 

0% 17.8% 12.3% 

--- THREATENED, ENDANGERED AND SENSITIVE PLANT SPECIES --- 

TES Plant Species No Impacts No Impacts No Impacts 

Sensitive Plant Species No Impacts No Impact to No Impact to 5 

5 species; species; May 

May Adversely Impact 

Adversely Individuals, but no 

Impact trend toward loss of 

Individuals, viability for 3 

but no trend 

toward loss of 

viability for 3 

species 

species 

--- RANGELAND RESOURCES and INVASIVE PLANT SPECIES --- 

Need for fence construction and/or 

change grazing rotation 

None Low Need Low Need 

Noxious Weed Treatment 3 acres 50 acres 45 acres 

--- ROADS and TRANSPORTATION MANAGEMENT --- 

Miles of Road Maintenance 8.7 miles 11.9 miles 9.9 miles 

Miles of Road Reconstruction 0 miles 6.7 miles 5.5 miles 

Spot Road Reconstruction 0 miles 3.4 miles 2.6 miles 

Temporary Road Construction 0 miles 0.2miles 0.0 miles 

Miles of Road Converted / 

Decommissioned 

--- RECREATION --- 


Recreational Impacts – summer None Low, seasonal Low, seasonal 

Recreational Impacts - winter 

--- ECONOMICS --- 

None Low Low 

Net Present Value N/A $176,811 $49,746 

Benefit/Cost Ratio N/A 1.44 1.14 

Approx. Volume Harvested 0 13.1 MMBF 9.9 MMBF 

--- SOCIAL --- 

26,200 ccf 20,000 ccf 

Benefit to the San Luis Valley 

--- HERITAGE RESOURCES --- 

No Benefit Some Benefit Some Benefit 

Cultural Resource Concerns 

--- FIRE AND FUELS --- 

None None None 

Heavy fuels removed from project 

area (tons/per acre) 

0 25 tons/acre 19 tons/acre 



2.5 Project Design Criteria Common to all Action Alternatives 

The Forest Service uses many measures to reduce or prevent negative impacts to the 

environment in the planning and implementation of management activities. The application of 

these measures begins at the planning and design phase of a project. The Forest Plan standards 

and guidelines and the direction contained in the Watershed Conservation Practices Handbook 

(FSH 2509.25) are the first protection measures to be applied to a project. Both of these sources 

are incorporated by reference and are not reiterated here. Other project design criteria (PDC) are 

then developed as needed. 

The criteria below have been found to be effective in reducing potential impacts. These criteria 

have been organized into logical categories. Each PDC bullet statement applies to a specific 

action alternative as indicated by an “x” in the far right column. 

Table 2.5-1. Wildlife/TES/MIS Resources 2 3 

Retain a minimum of four snags/acre in various conditions of decay and distribution, 

selecting snags with a larger-than-average diameter for the stand where available. 

x x 

Trees with suspected active bird nests will be marked to be left. x x 

In salvage areas, retain all live trees, except for trees that need to be removed for 

operational purposes. 

x x 

Leave large woody debris (10-15 tons per acre) on harvested sites to retain moisture, trap 

soil movement, provide microsites for establishment of forbs, grasses, shrubs and trees, and 

to provide habitat for wildlife. 

x x 

All soft snags will be retained unless they present a safety hazard. x x 

If boreal toads or northern leopard frogs are discovered within the analysis area, a Forest 

Service Wildlife Biologist will be notified. With the aid of the Forest Service Wildlife 

Biologist, protection measures will be developed and implemented based on proposed 

management activities, topography, vegetative cover, and other site specific factors. 

x x 

If an active lynx or wolverine den is identified, a Forest Service Wildlife Biologist will be 

notified, and the den will be protected from disturbance and adverse habitat modifications by 

a buffer around the den site during denning periods. The extent of buffer will be based on 

proposed management activities, species, topography, vegetative cover, and other site 

specific factors, in consultation with the USFWS. 

x x 

Effects to understory vegetation will be minimized to benefit lynx by identifying skid trail 

locations (and avoiding areas of densest understory), spacing skid trails at least 100 feet 

apart. To restrict damage to residual stand, tractor skid trails shall not impact more than 

15% of the harvested area. 

x x 

To benefit lynx and other wildlife, damage to residual trees and regeneration will be 

minimized through implementation of Timber Resource project design criteria. 

x x 

Big game hiding cover will be provided along sections of open road that are not adjacent to 

steep slopes or limited entry riparian areas that may already provide security habitat for deer 

and elk. Vegetative cover will be designated as needed on a site-specific basis to provide big 

game hiding cover within 200 feet of an open road where topography or other 

features do not provide security habitat. 

x x 

The project area has been surveyed for TES and migratory bird species, with a particular 

emphasis on nest and den sites. This will continue to occur during project implementation. If 

species or sites are found they will be protected as indicated in the Forest Plan in 

consultation with the U. S. Fish and Wildlife Service, if required. 

x x 



Table 2.5-2. Range Resources 2 3 

Forest regeneration protection from cattle use: 

During the project and reforestation period, cattle use will still occur, but heavily 

concentrating the cattle will be avoided. This will be accomplished through Adaptive 

Management, i.e., begin with a strategy of approved management tools, then, if that does not 

work, other tools may be implemented. Starting management tools will be: 

• Salt or supplement will not be placed in the Analysis Area 

• Cattle will be allowed to drift into the Analysis Area, large numbers will not be 

pushed into the Analysis Area 

• If large numbers of cattle begin to use the Analysis Area, the herd will be dispersed 

by riders 

• Maintain a pasture rotation to avoid season-long grazing in the Analysis Area 

x x 

Table 2.5-3. Noxious Weeds 2 3 

The timber purchaser will be required to clean all logging and construction equipment that 

operates off roads prior to entry to the project area. Use standard timber sale contract 

provisions to ensure appropriate equipment cleaning. 

Haul routes and highly disturbed areas, such as landings, will be treated for noxious weed 

infestations as needed for five years following harvest. 

Soil disturbance will be minimized to the extent practical, consistent with project objectives. 

Re-vegetate disturbed soil (except travel-ways on surfaced projects) in a manner that 

optimizes plant establishment for that specific site. All organic material used for 

rehabilitation: seed, straw, erosion control material, etc., will be certified weed free. Areas 

where borrow material is used will be documented on a map with location of application. 

These sites will be inspected for three years after project completion. Point of origin of the 

borrow material will also be documented. All of these steps will be completed regardless if 

Noxious Weeds were present at the borrow site or not. 

x x 

x x 

x x 

Road fill and road base material brought in off site will come from a borrow source free of 

Colorado State Listed Noxious Weeds. The Forest Service will inspect and approve the 

borrow source location prior to materials being hauled to the project area. 

x x 

Burn Piles will be mulched, scarified, fertilized and re-seeded after treatment. x x 

Table 2.5-4. Timber Resources 2 3 

In all sanitation/salvage stands that exceed 50 percent removal of overstory spruce, 

reforestation surveys will be conducted, and if the survey indicates that Forest Plan stocking 

standards will not be met, these stands will be artificially reforested with Engelmann spruce 

seedlings to meet or exceed Forest Plan standards. 

To reduce beetle habitat within logging units, all green and/or infested spruce material 6 

inches diameter and larger will be yarded and decked at the landing. This material will be 

treated within one year of decking. 

To protect soil, leave trees, and regeneration, tractor skid roads will be located and approved 

in advance of falling. Skid trails should be located to avoid areas of densest regeneration. 

x x 

x x 

x x 



Table 2.5-5. Aquatic Resources 2 3 

There will be no planned harvest within the water influence zone of all intermittent and 

perennial streams (WIZ-100 horizontal feet from the top of each stream bank) unless needed 

for skid trail or road crossings. In addition, no harvest equipment or skid trails will be 

allowed within the WIZ. Skid trail crossings within the WIZ of all streams including 

ephemeral will be minimized and must be approved by the timber sale Contracting Officer, 

or designee(s). These crossings must be perpendicular to the streams and a one-end log 

suspension must be maintained when skidding across the WIZ. 

Within the WIZ of ephemeral stream channels, harvest equipment can operate to remove 

trees. However, no skid trails are allowed and equipment or mechanical ground disturbance 

in or immediately adjacent to channels (within 25 ft) must be avoided. 

Minimize disturbance during maintenance of existing roads to limit exposure and placement 

of fresh sediment in ditches that could enter stream courses. Prevent sediment loss from 

road surfaces and rutting impacts by appropriate hardening such as the use of gravel rock. 

Existing roads will be evaluated to identify erosion and sediment concerns so they can be 

fixed as part of road maintenance operations. Install additional cross drains if needed to 

divert road drainage into buffer strips or away from sensitive soil areas, and minimize road 

drainage into stream channels. 

Existing road segments used in timber harvest operations that are within the water influence 

zone (100 feet) of intermittent and perennial streams will be inspected by hydrology or soils 

specialists or their designees to ensure sediment sources are disconnected from the stream 

system. If necessary, wattles, silt fence, or other appropriate sediment control will be 

installed to prevent sediment from entering the stream course. 

During temporary road construction and road re-opening activities, direct road drainage near 

stream crossings to filter strips. To limit sediment input from road segments at road 

crossings that cannot be directed to adequate filter strips, utilize timber slash windrows or 

sediment barriers such as silt fences and wattles. 

Harvest units will be inspected for seepages or riparian areas. Where found, these features 

will be protected through sale marking and layout. 

x x 

x x 

x x 

x x 

x x 

x x 

Table 2.5-6. Soil Resources 2 3 

Forest Plan standards for soil productivity (15% allowable soil impact to activity area), will 

be achieved through careful design of skid trails, operating during dry seasons or frozen soil 

conditions, and use of existing skid trails where practical. 

Keep at least 50% of the fine slash (less than 3 inch and smaller branches and limbs) in the 

harvest unit. The materials shall be well distributed throughout the stand and may be 

deposited on skid trails. Tops are preferred due to the high nutrient content of the leaves and 

small branches. All slash left in harvest units shall be lopped and scattered to within 2’ of 

the ground, and left un-compacted, except on skid trails. 

Seeding of disturbed sites would utilize the Subalpine mix and application prescription. Any 

reclamation projects will utilize weed-free certified seed and erosion control materials. 

Skidding is not permitted within 100 feet of wetlands and fens; skidding is permitted at 

designated stream crossings. Harvest of trees within the WIZ of the wetlands may occur 

through field evaluation and approval by a hydrologist or soil scientist. 

x x 

x x 

x x 

x x 



Operate heavy equipment for land treatments only when soils are dry, soil moisture is below 

the plastic limit, or protected by at least 1 foot of packed snow or 2 inches of frozen soil. 

Wet weather operations shall be monitored and if soils become excessively wet (as defined 

in the Forest Plan as exceeding the plastic limit), then operations will be suspended until 

such time as soils become operable again. 

Any minor wet areas and small mass movement areas would be avoided during harvest or 

road building operations. 

Skid trail spacing would be approximately 100 feet apart, allowing for topographic variation 

and skid trail convergence. 

Subsoiling, or comparable reclamation measures, will be used where soil impacts are found 

to exceed Forest Plan standards. Subsoiled area would be planted to trees or native grass 

species for long-term soil health and forest health. 

x x 

x x 

x x 

Table 2.5-7. Recreation Resources 2 3 

Notify the public of logging activity through media such as local newspapers and the Forest 

website. 

Logging operations will not be permitted from December 15 to April 1 to reduce potential 

conflicts with winter recreation activities. 

Post caution signs at key intersections along the haul route to alert the public to logging 

traffic. Post a sign for trail users traveling in to the sale area from the Wilderness. 

Trailhead Parking areas will be designated by the FS within the sale areas during the life of 

the timber sale contract(s) according to safety conditions. 

x x 

x x 

x x 

x x 

Table 2.5-8. Scenic Resources 2 3 

In harvest units 4 and 5 leave 38-40 trees per acre live or dead, 8” DBH and larger. Also 

implement small patch cuts that connect to or mimic natural openings. 

In harvest units 2 and 3 leave 48-50 trees per acre live or dead, 8” DBH and larger. Also 


In harvest unit 1 leave 58-60 trees per acre live or dead, 8” DBH and larger. Also 


2.6 Monitoring Measures 

x x 

x x 

Monitoring is gathering information, observing processes, and examining the results of 

management activities to provide a basis for evaluation. Monitoring is done at both the project 

and Forest Plan level. The Rio de los Pinos Vegetative Management Project contains project 

specific monitoring. It also includes Forest Plan monitoring and evaluation items where 

appropriate. Monitoring in the Rio de los Pinos Vegetative Management Project includes 

implementation monitoring and evaluation to guarantee that standards and guidelines are being 

incorporated during the project activities, as well as effectiveness monitoring and evaluation to 

determine whether objectives of the project are being met. Below are monitoring measures that 

will be incorporated into this project. 

Chapter 2 – Alternatives Page 2-12 

x


WILDLIFE AND TES RESOURCES- MONITORING 

Objective: To ensure that Forest Plan standards and guidelines and project specific wildlife 

design criteria are being properly implemented. This monitoring includes project design criteria 

and Forest Plan objectives for TES and MIS. 

Method: Implementation and effectiveness monitoring during and after treatment 

activities will be performed by the Forest Service. 

Action: Ensure that the project design criteria are understood and properly incorporated 

into the timber sale contracts. 

Wildlife Biologists/Foresters will work closely with the Timber Sale Administrator to 

ensure that the contract provisions are understood and being properly implemented. 

Objective: To determine the presence of wildlife TES. 

Method: The Forest Service will survey sale areas during timber sale preparation 

activities to identify nest and den sites for TES/MIS during implementation of timber 

sales. 

Action: If species or sites are found they will be protected as indicated in the Forest Plan 

and project design criteria with consultation with the U.S. Fish and Wildlife Service, as 

necessary. 

Objective: To assess actual incidental damage to dense horizontal cover resulting from 

management activities. 

Method: Revisit coverboard plots to measure post-harvest affects to the developed 

understory. 

Action: If damage to the developed understory is substantially (+/-20%) different than 

the 30% being estimated, the impacts to lynx habitat would be re-evaluated in an 

addendum to the Biological Assessment. 

RANGE RESOURCES- MONITORING 

Objective: To ensure that range project design criteria are effective. 

Method: Perform site inspections during and after the project is complete to ensure 

livestock are not impacting regeneration within the project area. 



Action: This will be accomplished through Adaptive Management, i.e., begin with a 

strategy of approved management tools, then, if that does not work, other tools may be 

implemented. Starting management tools will be: 

• Salt or supplement will not be placed in the Analysis Area 

• Cattle will be allowed to drift into the Analysis Area, large numbers will not be 

pushed into the Analysis Area 

• If large numbers of cattle begin to use the Analysis Area, the herd will be 

dispersed by riders 

• Maintain a pasture rotation to avoid season-long grazing in the Analysis Area 

The Annual Operating Instructions will be the implementing document for the 

management tools applied. 

NOXIOUS WEED MONITORING 

Objective: To ensure that project design criteria are effective for: 

• Monitoring / Detection – Implement efforts to monitor and inventory the analysis area 

during and after project implementation to locate infestations for early and swift 

treatment to allow for eradication. 

• Control - Eliminate or contain the existing noxious weeds in the analysis area. 

• Prevention - Prevent new infestations of noxious weeds from being introduced into the 

analysis area due to project implementation. 

• Restoration – Restore disturbed sites to minimize niches for noxious weed establishment. 

Method: Site inspections during and after project implementation to ensure that design 

criteria are fully implemented. Perform periodic surveys for noxious weeds. 

Action: Implement those measures to prevent the introduction and spread of noxious weeds. 

Locate and treat noxious weeds in a timely manner as part of the forest noxious weed 

treatment program. Restore disturbed sites to prevent the introduction of noxious weeds. 

TIMBER RESOURCES - MONITORING 

Objective: 

Ensure that all resource protection measures in the Decision are included in the 

timber sale contract and properly implemented. 

Method: 

The timber sale contracts will be reviewed by the District Ranger and certified 

for conformance with the Decision document prior to advertisement of timber sales. 

Implementation monitoring will continue through harvest inspections. As a routine part 

of project implementation, contract administrators monitor harvest and construction 

activities. This monitoring ensures that project elements and Forest Plan standards and 

guidelines are followed as designed. 

Action: The District Ranger will ensure that pre-sale Foresters include required 

protection measures in the timber sale contract. 



The Timber Sale Administrator is responsible for administrating the contract. If required, 

the Timber Sale Administrator will initiate action to repair resource damage and suspend 

operations until problems have been corrected. 

Objective: 

To ensure that the treated stands are reforested to NFMA standards. 

Method: 

Site inspections the first, third and fifth year if necessary after project 

implementation to ensure that the areas are successfully reforested. 

Action: 

If reforestation is inadequate, plant the areas. 

AQUATIC RESOURCES - MONITORING 

Objective: 

To ensure that project design criteria are being properly implemented and that Forest 

Plan standards and guidelines are being met in regard to stream health. 

Method: 

Site inspections along affected streams in the project area during and after 

vegetation management and road activities to assess changes in stream conditions. 

Method: 

Inspect road segments near and at stream crossings after 

reconstruction/maintenance operations have been completed. Inspections will occur prior 

to, during, and following vegetation management activities. 

Action: 

Ensure that the project design criteria are properly incorporated into the timber 

sale contracts and work with the Timber Sale Administrator as necessary to ensure that 

contract provisions are being implemented. Implement additional mitigation if necessary 

to eliminate sediment or other negative impacts to streams if necessary. 

SOIL RESOURCES - MONITORING 

Objective: 

To ensure that project design criteria are being properly implemented and that Forest 

Plan standards and guidelines are being met in regards to soils. 

Method: 

Soil moisture conditions will be monitored during harvest activities by Forest 

Service Personnel. 

Action 

: Timber harvesting operations would be suspended when soil conditions are too 

wet to operate and would result in resource damage. The Forest Service will ensure that 

project design criteria are properly incorporated into the timber sale contracts and ensure 

that contract provisions are understood and implemented. 



Method: Use accepted soil monitoring techniques to assess overall cumulative soil 

impacts after harvest is completed. 

Action: 

Conduct traverses, spot soil sampling, or other soil management handbook 

methods to assess the 15 percent soil productivity standard. 

SCENIC RESOURCES – MONITORING 

Objective: To evaluate whether the planned number of reserve trees remain on-site and to 

determine if the computer modeling accurately depicted the post-harvest effects on scenery. 

Monitoring would be accomplished to determine if the scenic quality objectives are being met. 

Method: Monitoring would be achieved by establishing and using photo points for 

comparing harvest activity results with post harvest computer modeling projections. In 

addition, photo points would be used to determine how well skid trails are located on the 

ground and how much canopy is provided by live trees and standing dead trees left on 

site. 

Action: The Forest Service will make adjustments to the use of computer modeling to 

project post-treatment scenic integrity objectives in order to improve the design of future 

projects. 

2.7 Alternatives Considered but Dropped from Detailed Study 

As the Interdisciplinary Team was developing the proposed actions, three additional alternatives 

were considered but eliminated from further detailed analysis. These included: 

1. A proposal to not harvest below the 13010005050101 7 th level watershed line. It was 

determined by the team that FSR 118.1C would be used as the dividing line. 

2. A proposal to salvage without including small patch cuts. The proposed patch cuts will 

provide texture and mosaic that will match the surrounding landscape and will assist in keeping a 

Scenic Integrity Objective of Moderate. 

3. A proposal to allow helicopter logging. The large landing sizes required for helicopters and 

having an existing conventional transportation system in place eliminated this alternative from 

detailed study. 



CHAPTER 3 

Affected Environment and Environmental Consequences 


This chapter describes the present conditions of the environment in and around the Analysis 

Area. This chapter also discloses the probable consequences (impacts and effects) of 

implementing each alternative presented in Chapter 2 on selected environmental resources. It 

provides the analytical basis to compare the alternatives. 

This chapter begins by briefly describing the location of the Analysis Area. This is followed by 

a brief analysis of how each alternative responds to the Key Issues identified in Chapter 1 

(section 1.9). Then, the chapter is organized by selected environmental and social resources. 

Each resource discussion addresses the following components: 

1) Scope of the analysis. 

2) Past activities that have affected the existing condition. 

3) Existing condition and; 

4) Direct, indirect, and cumulative effects. 

A list of terms and definitions used in the analysis is located in Appendix A of this EIS. 

3.2 General Description of the Analysis Area 

The Analysis Area is located approximately two miles northwest of Cumbres Pass, Colorado, 

which is approximately 13 miles north of Chama, New Mexico, and 36 miles south of Antonito, 

Colorado along Colorado State Highway 17. The Analysis Area falls within Conejos County, 

Colorado and encompasses approximately 1380 acres. See the Vicinity Map in Chapter 1, 

Section 1.4 for an overview of the Analysis Area. 

Not every resource area conducts their specific analysis using the same Analysis Area boundary. 

Some evaluations focus on the specific timber stands units; others might need to use a larger area 

outside the formal Analysis Area. In this Chapter, the “Scope of the Analysis” clearly describes 

the appropriate scale of analysis used for each resource. 

Chapter 3 – Affected Environment &Environmental Consequences Page 3-1


3.3 Alternatives and their Effects on Key Issues 

This section summarizes how each alternative affects each Key Issue. Key issues are displayed 

in Chapter 1, Section 1.9 and the alternatives are displayed in Chapter 2, Section 2.3. Tables 3.3- 

1 to 3.3-3 summarize Key Issues and their indicators by alternative. 

Alternative 1 

Table 3.3-1. Alternative 1 effects on the Key Issues 

Key Issue Indicators Alternative 1 – No Action 



-50501 (6 

1. Watershed 

Health 

th Level) 

-5050102 (7 th Level) 

-5050101 (7 th 0 acres 

11.5% 

Level Watershed of Concern) 


5.3% 

16% 

0 miles 


8.7 miles 

e. New temp road construction (miles) 

0 miles 


0 acres 

b. Late-successional habitat structural class 0% 

2. Forest changed (percent) 

Condition c. Spruce beetle risk rating (average) 

Moderate-High 

d. Heavy fuels removed from project area 

(tons/acre) 

0 

Key Issue 1. 

This alternative would best meet Key Issue #1, having the lowest level of 

watershed disturbance. There would be no acres treated and no road re-opened, or temporary 

road construction. As a result, there would be no structural changes in watershed integrity tied to 

vegetation type, soil type, moisture availability, or other ecological characteristics due to harvest 

activities and road construction as none would occur. 

Key Issue 2 

. Existing forest conditions would persist, which consists of timber stands with a 

high mortality component due to spruce beetle activity. There would be no human caused 

change in habitat structural stage, leaving this to occur naturally over time. The Spruce Beetle 

Risk rating would remain at a Moderate-High throughout the remaining epidemic. There would 

be no heavy fuels removed from the project area. 



Alternative 2 


Key Issue Indicators Alternative 2 – Full Salvage Harvest 



-50501 (6 

1. Watershed 

Health 

th Level) 

-5050102 (7 th Level) 

-5050101 (7 th 878 acres 

12.2% 



6.1% 

18.0% 

3.3 miles 


11.9 miles 


0.2 miles 


878 acres 

b. Late-successional habitat structural class 17.8% 

2. Forest changed (percent) 

Condition c. Spruce beetle risk rating (average) 



(tons/acre) 

25 tons/acre 

Key Issue 1. Approximately 878 acres would be salvaged under this alternative. No new 

system road construction would occur, but 0.2 miles of new temporary road construction would 

occur, to be closed following management activities. Approximately 3.3 miles of old road would 

be re-opened, also to be closed following management activities. Segments of system road 

reconstruction/spot reconstruction (representing 10.1miles) would occur to meet watershed 

restoration opportunities. Project design criteria would be implemented to limit the amount of 

potential structural changes in watershed integrity tied to vegetation type, soil type, moisture 

availability, or other ecological characteristics due to timber harvesting and road 

construction/reconstruction activity. Erosion and stream sedimentation concerns from existing 

road conditions would be repaired. 

Key Issue 2. 

This alternative would treat the largest area, allowing the most utilization of dead 

material, and providing the most opportunity to assist the stands in regenerating by utilizing 

artificial regeneration methods. A sizeable change in late-successional habitat structural class 

would occur, speeding a process that will occur naturally. The largest amount of heavy fuels 

would be removed from the area under this alternative. 

Alternative 3 


Key Issue Indicators Alternative 3 – Reduced Salvage Harvest 



-50501 (6 

1. Watershed 

Health 

th Level) 

-5050102 (7 th Level) 

-5050101 (7 th 607 acres 

12.0% 



5.9% 

17.4% 

2.5 miles 


9.9 miles 


0.0 miles 




Key Issue Indicators Alternative 3 – Reduced Salvage Harvest 

2. Forest 

Condition 


b. Late-successional habitat structural class 

changed (percent) 

c. Spruce beetle risk rating (average) 


(tons/acre) 

607 acres 

12.3% 


19 tons/acre 

Key Issue 1. Approximately 607 acres would be salvaged under this alternative. No new 

system road construction would occur, but no new temporary road construction would occur, to 

be closed following management activities. Approximately 2.5 miles of old road would be reopened, 

also to be closed following management activities. Segments of system road 

reconstruction/spot reconstruction (representing 8.1 miles) would occur to meet watershed 

restoration opportunities. Project design criteria would be implemented to limit the amount of 

potential structural changes in watershed integrity tied to vegetation type, soil type, moisture 

availability, or other ecological characteristics due to timber harvesting and road 

construction/reconstruction activity. Erosion and stream sedimentation concerns from existing 

road conditions would be repaired. 

Key Issue 2. 

This alternative would treat the a smaller area, allowing the utilization of dead 

material, and providing an opportunity to assist the treated stands in regenerating by utilizing 

artificial regeneration methods. A smaller change in late-successional habitat structural class 

would occur in treated stands, speeding a process that will occur naturally. A lesser amount of 

heavy fuels would be removed from the area under this alternative. 

3.4 Forest Health 

Scope of Analysis 

This analysis focuses on the Analysis Area described in Chapter 1, section 1.4 with regard to the 

forest condition resulting from the impacts of spruce beetle (Dendroctonus rufipennis) and to a 

lesser extent Armillaria root disease (Armillaria ostoyae). Western spruce budworm 

(Choristoneura occidentalis) was also considered, but no observable budworm activity was 

found in the analysis area. The spruce beetle has had the greatest impact on the forest condition 

in the Analysis Area and armillaria root disease may have contributed to increased susceptibility 

of some stands to spruce beetle within the Analysis Area. The spruce beetle is a native insect 

that is responsible for substantial tree mortality on the Rio Grande National Forest and has been 

particularly active on the Conejos Peak and Divide Ranger Districts. Armillaria root disease is a 

native pathogen that is present in most spruce/fir stands in the Southern Rockies and usually 

results in scattered, isolated patches of mortality in older stands. The recent history of the Rio de 



los Pinos Analysis Area will be discussed as well as potential future conditions as affected by 

each of the three alternatives. 

Spruce Beetles and Factors Affecting Epidemics 

The potential for an outbreak of bark beetles is determined by three primary factors: current bark 

beetle population levels, the susceptibility of individual stands, and weather patterns. In the case 

of the Conejos Peak Ranger District, these three factors are all indicative of increased spruce 

beetle activity. In order for a bark beetle outbreak to occur, there must be sufficient beetles to 

respond to conditions favorable to spruce beetles. The extent of recent spruce beetle caused 

mortality in the Analysis Area indicates that spruce beetle populations are at a generally elevated 

to an epidemic level. Stand conditions are also a primary determinant of bark beetle activity. 

Stands that are old and dense are generally more susceptible to bark beetles. In the case of 

Engelmann spruce, a risk rating system derived by Schmid and Frye (1976) documented that 

mortality as a result of spruce beetle activity is most likely to be initiated in stands that: a) consist 

of larger size classes, b) stands that are more dense (more trees per acre), c) stands that have a 

higher percentage of spruce and d) stands in the higher site classes. Stands in the Rio de Los 

Pinos drainage meet all of these criteria for stands conducive to beetle activity. The propensity 

of high-risk stands can in a certain sense be attributed to these large dense trees competing for 

sunlight and particularly, moisture. This “competition” for moisture is naturally more intense 

among older, denser stands of trees. 

The Rio Grande National Forest has undergone a severe drought within the past six years (Webb 

et al. 2004). Low availability of moisture has generally reduced the tree’s ability to resist bark 

beetle attack. The overall lack of moisture has allowed spruce beetle populations to increase, 

and has also increased the susceptibility of adjacent stands. For some insects, the end of the the 

drought usually means the end of the outbreak. However, with mountain pine beetles and spruce 

beetles, once the beetles have killed a large number of trees and produced abundant offspring, 

their numbers may become so great that they can overwhelm even healthy trees (Romme et al. 

2006). 

Past Actions that have affected the Existing Condition 

There is no evidence of significant insect or disease activity occurring in the Analysis Area until 

only recently. Increased spruce beetle activity was noted in the adjacent Wolf Creek drainage in 

2003 and has spread across the Analysis Area at epidemic rates since that time. Spruce beetle is 

a native insect and generally occurs at endemic levels in all spruce stands. It is likely that spruce 

beetle has been present in the Analysis Area at endemic levels for many years. 

Past timber management activities in the Rio de los Pinos Analysis Area include the Hanson 

(1957) and Flat (1983) timber sales. The Hanson Timber Sale consisted of a shelterwood 

preparatory cut over 562 acres that reduced the basal area and allowed the establishment of 

spruce and fir regeneration. The past management activities did reduce the risk of spruce beetle 

affecting these stands but could not protect against the elements of high beetle populations and 

drought-related stress. 

Chapter 3 – Affected Environment & Environmental Consequences Page 3-5


Past timber management activities within the Analysis Area may or may not have affected the 

occurrence of armillaria root disease within the Analysis Area. Partial cutting likely had 

multiple, conflicting influences on disease dynamics. On one hand, stumps may provide 

increased food to the pathogen and more energy to attack neighboring trees, but on the other 

hand, partial cutting can lead to increased vigor and resistance of residual trees. Armillaria root 

disease has been observed in the Analysis Area but is believed to be at only endemic levels. 

Existing Condition 

Field surveys were completed in 2005 by Rio Grande National Forest timber personnel and 

Gunnison Service Center personnel. Spruce beetle was found throughout the Analysis Area in 

small numbers, increasing steadily in the southern-most units. In 2007, during an effort to 

prepare a preventative thinning timber sale, crew members found significantly more fresh spruce 

beetle hits. New surveys were conducted in 2007 and 2008 to determine the current extent of 

beetle activity. Small amounts of blown-down spruce were also observed in the units in 2006, 

2007 and again in 2008. Table 3.4-1 shows the degree to which the salvage units have been 

impacted by spruce beetles. 

Table 3.4-1 Percentage of Trees Impacted by Spruce Beetles in 

Salvage Units 

Unit 

Number 

Current Spruce Beetle Risk 

Rating 

(Schmid/Frye) 

Actual Percent 

Infestation 

(2008) 

1 Moderate 20% 

2 High-Moderate 20% 

3 High-Moderate 47% 



The spruce beetle have steadily moved north from the adjacent County Line middle and southern 

units since 2003. Stands that were rated as a Moderate for outbreak potential have been heavily 

infested (stands 4 and 5), indicating that stands 1-3 are on their way to severe infestation. 

According to Forest Service Entomologist Tom Eager, mortality of every infested spruce tree is a 

certainty because of the immense population of beetles present. Spruce trees currently not 

infested are very likely to become infested for the same reason. 

The dramatic increase in spruce beetle activity in the Analysis Area highlights the severity of the 

recent drought conditions in this area and across the Forest. Various indicators of drought 

severity including water yields, fuel moisture content and plant physiology indicators all set 

records in 2002. It is likely that these conditions facilitated the rapid increase in beetle 

population and activity when this outbreak first began. Prolonged drought conditions through 

2006 further endangered the stands and promoted beetle population growth. 

Large spruce beetle populations directly to the south of the Analysis Area are proving to be 

detrimental to the stands in this analysis. Once a full-blown outbreak is underway, the huge 



beetle populations can engulf entire landscapes and kill practically all spruce. Such intense 

outbreaks are not unheard of. Landscape scale outbreaks of spruce beetle have been recorded 

throughout the range of spruce, including locations in Alaska, New Mexico and Utah as well as 

numerous examples in Colorado. On the Rio Grande National Forest, we have experienced this 

phenomena in the County Line, Burro-Blowout, and Big Moose project areas. 

During field visits by the District Silviculturist, armillaria root disease was observed in small 

pockets within the Analysis Area. Extensive surveys for armillaria root disease have not been 

completed. It appears through field reconnaissance that the armillaria root disease in the 

Analysis Area is likely at, or near, endemic levels. Often times trees with armillaria root disease 

will blow down in scattered pockets. Scattered blowdown and stressed trees caused by armillaria 

root disease may have contributed, to a small degree, to the buildup of the spruce beetle 

population within the Analysis Area. 

Direct, Indirect, and Cumulative Effects 

Alternative 1 – No Action 

With no management action, it is likely that the scope and intensity of spruce beetle activity 

would continue. Units that currently have large beetle populations would continue to experience 

intense mortality, most likely until the mature spruce component is killed. During intense beetle 

outbreaks, the outbreak ends only when the beetles deplete their host and food supply. This 

scenario could be duplicated in most stands that have any spruce beetle activity at all, assuming 

that the dry weather conditions of the past several years continue. 

The Rio de los Pinos outbreak currently extends beyond the Analysis Area boundary into 

backcountry areas and into other inaccessible or inoperable spruce stands within and adjacent to 

the Analysis Area. Relatively contiguous suitable spruce beetle habitat is present around the 

Analysis Area and it is not unreasonable to expect spruce beetle activity to increase within the 

Analysis Area by infesting additional trees and spread across the landscape, infesting additional 

stands on the Districts. 

As Engelmann spruce is killed by spruce beetle the Engelmann spruce seed source will be lost. 

This loss of Engelmann spruce seed would affect the future stand composition and favor 

subalpine fir, which is less resistant to armillaria root disease than Engelmann spruce. This 

could potentially increase the future occurrence of armillaria root disease in the Analysis Area. 

Alternative 2 – Full Salvage Harvest 

This alternative proposes to apply Sanitation/Salvage to 878 acres. Salvage includes removal of 

dead trees from which spruce beetles have already exited. Salvage has minimal impact on 

overall beetle numbers. Sanitation harvesting of infested trees implies that immature spruce 

beetles are still infesting the tree and would be removed from the site with the host tree. The 

removal of trees with beetles in them would reduce the overall beetle population, which could 

reduce the rate of spread of the beetles at the stand level. However, it is not realistic to think that 

the proposed treatments would control the spruce beetle outbreak over vast areas adjacent to the 

treated areas. 



Project design criteria for Timber Resources are presented in Chapter 2, Table 2.5-4. One of the 

Project design criteria requires that large green or infested tree segments that are six inches or 

more in diameter would be skidded to landings for treatment within one year. This project 

design criteria is designed to reduce spruce beetle habitat within the treatment areas. This 

method of treating large material has been commonly used on other spruce beetle 

sanitation/salvage timber sales on the Rio Grande National Forest and has been effective at 

minimizing the spread of spruce beetle through logging slash. 

Under Alternative 2, artificial regeneration by planting Engelmann spruce is planned for 75 

acres. Engelmann spruce is susceptible to armillaria root disease, but this disease usually does 

not affect Engelmann spruce until it reaches later seral stages. Engelmann spruce shows greater 

resistance to armillaria root disease than other tree species, such as subalpine fir, that could be 

regenerated on these sites. Any increase in armillaria root disease following sanitation/salvage 

harvesting would not be the result of removing beetle infested or beetle killed trees. Root 

systems of beetle killed trees would not be affected in their suitability as a food base by cutting 

of the stem. No affects to western spruce budworm activity are expected from this alternative, as 

no current budworm activity has been observed within the analysis area. This treatment would be 

expected to reduce stand susceptibility to future budworm activity, as stands would become more 

open and have less vertical structure, thus impeding larvae survival. 

Alternative 3 – Reduced Salvage Harvest 

Like Alternative 2, this alternative would designate units where dead and dying Engelmann 

spruce are removed for the primary purpose of recovering the lost economic value of dead and 

dying trees and to create areas suitable for reforestation. The sanitation/salvage treatment areas 

would be the same as Alternative 2. 

The project design criteria presented in Chapter 2, Table 2.5-4 regarding slash treatments would 

also apply to Alternative 3 but over a smaller area than Alternative 2. 

Under Alternative 3, artificial regeneration by planting Engelmann spruce is planned for 56 

acres. The effects of armillaria root disease and western spruce budworm would be the same as 

those described under Alternative 2 but over a smaller area. 

Cumulative Effects: 

The cumulative effects analysis for forest condition includes all of the spruce/fir forest lands on 

public and private lands within and around the analysis area. The analysis considers spruce 

beetle infestations that have been observed in this area during the last seven years and the 

potential for future outbreaks over the next 10 to 15 years. The probability for future spruce 

beetle outbreaks in this area is high over the next 10 to 15 years due to the current weather 

patterns, current spruce beetle populations in the area, and current stand conditions. The 

spruce/fir forest in close proximity to the Rio de los Pinos Analysis Area is currently undergoing 



a large amount of spruce beetle activity. There are a number of locations where entire groups of 

trees are being killed by spruce beetle. 

The Rio de los Pinos Analysis Area is surrounded to the north, east and west by Backcountry 

MAPs and spruce beetle mortality has been observed in these backcountry areas. The full extent 

of the infestations in these backcountry areas is unknown. Backcountry areas would remain 

untreated and natural processes would continue in these areas without human intervention. 

Nearby efforts to treat spruce beetle activity include the Grouse Salvage Sales, Spruce Hole 

Salvage Sale, La Manga Salvage Sales, and Neff Mountain Salvage Sales. Three sales are under 

contract in the County Line area: Wolf Beetle Salvage, Esacarabajo Salvage, and Spruce Park 

Salvage. All of these sales would contribute toward removing spruce beetle from the forest but it 

is probable that the sum total of these efforts would have little impact on bark beetle populations 

and on forest conditions as a whole. These sales may temper beetle-caused mortality on a 

localized (stand) level and allow some portions of the older age class spruce to survive the 

current wave of mortality. 

The underlying cause of the widespread mortality is the relatively homogeneous stand structure 

found throughout the Rocky Mountain Region. A primary goal of forest management is to 

increase stand heterogeneity so that large-scale outbreaks are not prevalent in the future forests. 

The effects of management activity must be viewed in two lights: the effect of sanitation/salvage 

on dead and dying timber, as well as the potential mortality in currently un-infested spruce trees. 

No increase in armillaria is expected to result from management activities. 

3.5 Forest Management 


This analysis focuses on the proposed management of timber stands within the Analysis Area to 

address spruce beetle infestation and timber productivity. 


Table 3.5-1 shows past timber sales that have occurred within the Analysis Area. 

Table 3.5-1. Past Timber Sales in the Analysis Area. 

Timber Sale Acres Year Harvest Type 

Los Pinos 35 1977 Prep cut Shelterwood 

Hanson 556 1957-1960 Prep cut Shelterwood 

Hanson 6 1957 Seed cut Shelterwood 

Flat 101 1979-1983 Prep cut Shelterwood 

Misc. Dead Removal 100 1981 Sanitation/Salvage 

Pre-commercial Thin 23 1978 Thin trees below 8” dbh 



Shelterwood preparatory cuts (light partial cuts) make up a large portion of the previous timber 

harvest activity that occurred in the Analysis Area. These opened up the stands (removing about 

1/3 of the basal area) to allow the present abundant natural regeneration of spruce and fir to 

become established. The six acres of the Hanson sale was a “shelterwood seed cut” that 

removed approximately 60% of the original basal area. 


The current structure of stands within the Analysis Area is primarily spruce/fir. The average age 

of the spruce/fir stands varies between 160 to 220 years. The stands may be characterized as 

dense, mature to over-mature Engelmann spruce/subalpine fir timber stands, with typical basal 

areas between 126 and 205 square feet. The density, stand age, and high percentage of spruce in 

the overstory made these stands susceptible to spruce beetle attack. Openings created in these 

stands by past timber harvest have regenerated to a dense mix of spruce and fir saplings. 

Table 3.5-2. Regeneration in Harvest Units 

Unit Number Existing Natural Regeneration 

(trees



This alternative provides the opportunity to salvage dead and dying Engelmann Spruce. This 

would be accomplished with ground-based (tractor) logging methods. 

The intent of the salvage is to place timber on the market for the American public in time to 

capture the value of the beetle-killed spruce trees, before the effects of wood decay eliminates 

that value. The object of the silvicultural prescription would be to harvest only spruce trees, 

which were recently killed by, or are currently infested with, spruce beetle. No green, uninfected 

spruce trees would be harvested, and no green or dead subalpine fir would be harvested. 

Exceptions to this are those trees that must be removed from skid trails, landings, or for safety 

reasons, and areas designated for scenic patch cuts. 

The minimum number of spruce/fir snags, live fir, and live uninfected spruce to be left is 

specified by unit in the project design criteria, Chapter 2, Table 2.5-8. The stands are expected 

to have a below average susceptibility of windfall risk. Having been previously managed, these 

trees have been exposed to lower stocking densities and have developed wind firmness over 

time. Soils mapping for the area also shows a windthrow hazard as “slight” (Section 3.7) and 

stand boundaries are on east-facing slopes greater than 2000’ horizontal distance from ridgetops 

and saddles. Field reconnaissance shows only minor evidence of old windfall resulting from past 

management. With all factors considered, these mid-to-low slope units are considered to have 

low-to-moderate risk for windfall (Alexander 1987). Trees most susceptible to windthrow would 

be residual live overstory fir, which have greater wind resistance than snags. Any loss of these 

trees to windfall would not affect management objectives or future management activities within 

the analysis area. 

Following removal of the dead or dying spruce, the Forest Service would plant Engelmann 

spruce seedlings on those areas where post-sale reforestation surveys indicate that stocking is 

below the minimum Forest Plan standard of 150 trees per acre. The logging process itself would 

provide the necessary soil scarification, allowing seeds to reach mineral soil, and helping prepare 

the sites for planting. Light logging slash left in the woods would be used to benefit young 

seedlings by protecting them from excessive sunlight, extremes of temperature, desiccation, and 

grazing animals (Smith 1997). It is anticipated that up to 75 acres could require planting. Actual 

planting acres will be determined through regenerations surveys following management 

activities. 

Some openings (gaps) would be created in the units. Openings also would occur in Alternative 1 

(No Action) when the dead trees fall. An opening in a forest canopy is associated with the death, 

blowdown, or other removal of all or a significant portion of the overstory trees. These gaps are 

often characterized by high structural and species diversity due to the growth of understory flora 

and colonization of new species, which are facilitated by the microclimatic conditions of the gap 

(Dunstar 1996). 

Patch cuts would be implemented across the units to mimic the visual landscape surrounding the 

analysis area. ¼ to 5 acre patch cuts would be placed throughout the units, removing all trees 

above 8 inches. See section 3.11 for a description of the patch cut’s effects on visual resources. 



A map with proposed patch locations is included in Appendix A, Map A-2. A total of 57 acres 

of patch cuts will be implemented. Patch cuts will closely resemble a group selection type 

harvest system. 

In this alternative approximately 13.1 MMBF would be harvested from 878 acres. The 

estimation of timber volume that would be removed is derived from three sources: 1) stand 

exam data taken in the early 1990’s, 2) this stand exam data projected to 2007 by the Forest 

Vegetation Simulation, Central Rockies Variant, and 3) field surveys in 2007 from which the 

estimated percent of infested spruce trees came. All of these sources are subject to some error. 

There is also the uncertainty whether or not the beetles will attack 100% of the spruce trees in 

those stands not already infested to that level. Therefore, these volumes must be considered our 

best estimates, subject to change. More precise data would come when the timber is actually 

cruised during the sale preparation process. 

The project design criteria for timber/silviculture (Chapter 2, Table 2.5-4) are routinely 

implemented in timber sales on the Forest. The design criteria are feasible because they can be 

incorporated into existing timber sale contract provisions. The design criteria have proven to be 

an effective means of assuring regeneration, achieving the desired results for minimizing the 

spread of spruce beetle, and providing for resource protection. 


In this alternative, approximately 607 acres and up to 9.9 MMBF would be harvested. A main 

difference between this alternative and Alternative 2 is that unit 1 and portions of units 2 and 5 

would not be entered for timber harvest. See Appendix A, Map A-3. The effects of no action in 

the portions of these units that will not be harvested have already been discussed under the 

Alternative 1, No Action alternative. Approximately 56 acres are planned for artificial 

regeneration. 

Approximately 42 acres of patch cuts would be placed throughout the units. The effects of these 

cuts have been described under Alternative 2. A map with proposed patch locations is included 

in Appendix A, Map A-3. 

Since the effects of salvage on the remaining units have already been described under Alternative 

2, no further discussion is necessary here. 


Since most of the roads needed to harvest the timber are already in place, new road construction 

would not be a major factor. The sales proposed would share portions of a road system with the 

Wolf Beetle, Escarabajo and Spruce Park Salvage sales. Purchasers of these sales share the 

responsibility of road maintenance for the portions of roads they share. 

With the exception of minor amounts of blow-down salvage, no future timber harvests are 

anticipated in the salvage units in the immediate future. A summary of the acres of treatment for 

present and future timber harvest is presented in Table 3.5-3. 



Table 3.5-3. Present and Future Timber Harvest 

Timber Sale Acres Year Harvest Type 

Wolf Beetle Salvage 324 Present Sanitation / Salvage 

Escarabajo Salvage 211 Present Sanitation / Salvage 

Spruce Park Salvage 298 Present Sanitation / Salvage 

Neff Mountain Salvage Sales 122 Present Sanitation / Salvage 

Grouse Salvage Sales 527 Present Sanitation / Salvage 

Rio de los Pinos Sales 878 2009-2012 Sanitation / Salvage 

Past management activities have created age, structural, and species diversity throughout the 

Analysis Area. 

3.6 Watershed and Aquatic Resources 


This analysis discusses watersheds and aquatic environments included in the Rio de los Pinos 

Vegetation Mangement Project. The analysis area lies within sixth level watershed 

130100050501. The Analysis Area and streams within this watershed are shown in Figure 3.6-1. 

All stream channels on a United States Geological Survey (USGS) 1:24,000 scale topographic 

map are included plus streams that were identified through contour crenulation. Precipitation in 

this watershed varies from about 25-45 inches a year, with the proposed harvest units receiving 

30 inches or more. 



Figure 3.6-1 


The sixth level watershed has MAP’s that have allowed timber harvest activities and associated 

road building in the past. The Rio de los Pinos analysis area was previously analyzed as part of 

the County Line Vegetation management project. Other activities that have caused impacts 

include livestock grazing and recreational use, including Truijillo Meadows reservoir and 

campground. 

Roads are causing minor localized impacts to stream health. Project work completed in 1998 

included removal of culverts and closing of several roads. Several closed roads in the upper part 

of the watershed now have good vegetative cover and have a minimal impact to stream health at 

road intersections. 


Watershed condition is evaluated by adding up acreage of surface disturbance, according to a 

method described in the Forest Plan FEIS, pages 3-265 through 3-269. Tables showing types 

and amount of disturbance in each watershed are provided in Appendix D. Regional guidance 

designated watershed assessments for revised Forest Plans to be focused on the 6 th level. 

Therefore, watershed analysis on the RGNF is focused on the 6 th level, but watersheds with high 

acreages where disturbances could be masked or where known disturbances were high were 

broken down to the 7 th level to ensure watershed protection. The Rio de los Pinos is one such 

watershed. 



Current watershed disturbance in the Rio de los Pinos 6 th level watershed is below Forest Plan 

concern levels (


included in the Watershed Specialist Report included in the Project Record. 

6 

Tributaries to Rio de los Pinos 

th Level Watershed 130100050501 

Several intermittent/perennial small tributaries to Rio de los Pinos are located in the analysis 

area. Stream types in the north portion of the project area are predominantly B3/B4 and E-3/4. 

Road density in this area is high due to previous timber harvest activities. Minor sediment input 

to streams in the north part of the analysis area was noted at road crossings. Upstream on these 

tributaries stream health is robust, with healthy riparian cover along the streams and stable banks 

(Photo 1/Figure 3.6-2). Steep stream bank sideslopes and narrow riparian zones are commonly 

seen in this area, with flat areas adjacent. Due to seepage areas, there are some small stream 

channels with flow that are not delineated on topographic maps. An example is shown in Photo 

2/Figure 3.6-3. This small stream is about 3 feet in width and has a bedload of small cobble and 

coarse gravel with some small boulder. These streams are ephemeral/intermittent in years with 

less than normal precipitation and more sustaining when higher amounts of snow pack or 

summer rains occur. 

Figure 3.6-2 - Photo 1 –Upstream 

UTM 366765/4104838 

Figure 3.6-3 - Photo 2-Upstream 

UTM 366745/4104789 

Upstream on these small tributaries, stream health remains robust with some reaches in 

hummocky, steep topography and others in more gentle sloped areas. Bedload consists of large 

cobble and small gravel with some small boulders (Photo 3/Figure 3/6-4). A short segment of old 

haul road is close to the stream channel at this location, but the riparian vegetation provides a 

good buffer to fine sediment. Ephemeral swale channels are present in uppermost reaches. 

Toward the middle of the analysis area, tributary channels have riparian zones in proper 

functioning condition with willow and sedge vegetation (Photo 4/Figure 3.6-5). The riparian 

zone here narrows upstream along a channel with 1-2 foot width. 



Figure 3.6-4 - Photo 3-Stream bed 

UTM 366680/4104345 


UTM 367704/4103761 

The largest tributary in the analysis area trends southeast to northwest through the south-central 

part of the analysis area. The upper part of this small perennial stream is shown in Photo 5/Figure 

3.6-6 and has a riparian zone width of about 30 feet. A small tributary that forks to the west is 

also perennial, with healthy sedge vegetation. This E-3 stream also lies within a wide, wet 

riparian zone. Localized seepage zones with healthy riparian are present along slopes to the west 

of this tributary. In lower reaches of this stream, the riparian/floodplain zone narrows and 

sideslopes steepen. Stream type is A-2 type with coarse gravel. One example of existing old 

roads impacting water quality is shown in Photo 6/Figure 3.6-7. Here an old wooden culvert is 

present, but fill has been partially removed by stream flow. 


UTM 367112/4103863 


UTM 367623/4103192 

In a lower gradient reach of this stream, a large sedge meadow is present (Photo 7/Figure 3.6-8). 

Stream health is robust and type is E-3/2, with healthy sedge and stable banks. Just above FS 

Road 118.2, this tributary is a B-3 stream type approximately 4 feet in width with riparian in 

proper functioning condition. 




UTM 367395/4103344 

Unit 5 

Several areas were more closely reviewed in 2008 due to concerns regarding riparian areas and 

small streams that were perennial that were not indicated as such on USGS maps. In Unit 5, 

stream health conditions are robust. Photo 8/Figure 3.6-9 was taken in the lower part of the unit 

along a drainage that is for the most part intermittent/perennial but does have some short 

ephemeral sections. Riparian vegetation consists of primarily sedge on channel banks and in 

some wider depression areas. Photo 9/Figure 3.6-10 shows the sedge meadow/wetland that is the 

source of water for this stream. 

Several old access roads are present in this area. At stream crossings some minor sediment input 

occurs due to connected drainage and stream width is locally affected, but up and downstream 

stream health remains robust. 


UTM 368189/4102171 


UTM 367700/4102527 

In several areas, these old roads are located within the water influence zone (WIZ) of the stream. 

Sediment from roads is well buffered in most of these areas by healthy riparian vegetation, but 

design criteria to protect these streams will be necessary where the roads are reopened. 

Upper West part of Units 3 and 4 

One area with several small perennial streams is the northern part of Unit 4. As in other areas, 

local impacts due to old road crossings are present. However, overall stream health is robust, 

with stable banks and minimal fines in the bedload (Photo 10/Figure 3.6-11) . 



In the upper northwest part of Unit 4, the water influence zone is wide due to presence of several 

seepage zones. These small streams are healthy, with stable banks and robust vegetation (Photo 

11/Figure 3.6-12). 

Figure 3.6-11 - Photo 10 - Downstream 

UTM 366910/4103214 

Figure 3.6-12 - Photo 11-Downstream 

UTM 366714/4103304 

As gradient increases, hill slopes above the stream channels also steepen (Photo 12/Figure 3.6- 

13).Near the 11,000 ft level in Unit 4, a wide riparian zone is present below the steep slope 

above. Upstream, slope steepens and topography is broken (Photo 13/Figure 3.6-14). In this area 

another small perennial tributary is present. Water influence zone marking by Forest personnel 

did not only include the minimum 100 feet from stream bank edges, but wet seepage areas with 

riparian vegetation beyond that distance. 


UTM 366646/4103324 


UTM 366425/4103569 

7 th Level Watershed of Concern 

Seventh level watershed 13010005050101 is considered a “watershed of concern” because of 

past timber operations and road building. The disturbance level threshold for a “watershed of 

concern” designation is 15% (RGNF Forest Plan). The disturbance level in this watershed will 

be about 16% when the current Spruce Park and Escarabajo timber sale contracts are finished. 

Another factor used in watershed ratings is amount of disturbance in the water influence zone 



(WIZ), mainly roads. The amount of road disturbance in the WIZ is 7.4%, under the 10% 

concern level for this parameter. 

This “watershed of concern” designation does not preclude new land disturbance within the 

watershed but does require specific watershed analysis prior to any new land disturbing activities 

(Dobson, 1996). This watershed was evaluated carefully during field work completed for the 

County Line Vegetation Management Project. In the summer of 2003, the watershed was 

assessed in detail to: 1) determine current stream health; and 2) identify concern areas that may 

need restoration or additional design criteria to correct stream health concerns. A summary of 

this analysis is provided in the following section. The County Line EIS was the NEPA prepared 

to allow for the Spruce Park and two other sales that are currently under contract. 

The main channel in this seventh-level watershed varies from an E-type high in an upper 

meadow to A3/B3 type with large-medium cobble in the lower reach below Forest Road 118.1C. 

In the upper E-reach, bank stability is impacted by a high-use dispersed camp site. At its mouth, 

this stream flows into a large beaver dam complex on the Rio de los Pinos. Stability of small Estream 

reaches and B-streams with large cobble and small boulder is excellent in the analysis 

area. 

Forest Road 118.1C that parallels the main stream channel is well-maintained, and work 

completed in 1998 and 2007 reduced impacts from this sediment source. Although the channel is 

close to the road, thick willow and sedge provide an effective buffer. In smaller subwatersheds 

within this watershed of concern, stable E-stream channels within well-vegetated meadows are 

present. Small trout were observed during field evaluation of these streams. 

Fine sediment sources are limited to a few trail crossings and some steeper slopes where 

vegetation is sparse. Rill and gully sources were not seen. Sediment impacts of road crossings 

on the smaller tributaries are minor. Good vegetation cover is present on several roads in the 

upper parts of the watershed, including Forest Roads 118.1Q, 118.1R, and 118.1S. 

Two natural factors that influence sediment availability in this watershed are rapidly weathering 

bedrock in many areas and soils prone to mass movement. One example of sediment input to 

streams by natural weathering is the sandy conglomerate outcrop along Forest Road 118.1C 

adjacent to the main channel. Slopes prone to mass movement are present in upper parts of the 

watershed and are a natural factor in fine sediment contribution to the overall system. 

To determine relative sediment load impact by the current road system and previous disturbance, 

stream channels above all road disturbance were used as “reference” reaches in analysis of 

stream health. Examination of one B-4 stream reach above all roads and below indicates bedload 

is very similar in composition and that fine sediment is inherent to the streams. Fine sediments 

are present in lower energy areas of the channels and fine to coarse sands and gravels in higher 

energy sections. 

Stream observations conducted in 2003 and 2008 indicate that current input of fine sediment to 

streams in this watershed from previous forest management activities appears to be minor and 

not a major factor influencing fine bed load in streams. A pebble count conducted in 2003 on a 



steeper reach of the main channel dominated by large cobble (B3 stream type) showed 18% sand 

and 4% silt fractions, close to the average fine sediment (15%) determined on reference reaches 

of the same type on the Forest. 

To further evaluate stream water quality and macro invertebrate habitat in the tributaries, 

Tarswell substrate ratios (TSR) were estimated during field evaluation and rocks examined for 

aquatic insects. The T-Walk diversity screen includes a procedure where 10 cobble sized-rocks 

within a riffle reach of stream are examined for macro invertebrates (Ohlander, 1996). Stonefly, 

mayfly, and caddis fly nymphs, larvae, and casings are counted. This information, provided in 

the watershed specialist report, showed substrates productive to biota were present and water 

chemistry is in good condition. 

Overall, streams within watershed 130100050501 are healthy. Sediment sources associated with 

current system roads or other surface disturbances are minor. Although watershed condition has 

been affected by past activities, watershed work completed in 1998 and natural recovery of the 

watershed since timber operations were conducted (see Timber and Silviculture section) 

contribute to the present condition. Stream banks are stable, with healthy riparian vegetation in 

proper functioning condition present along intermittent and perennial stream reaches. 

In the 7 th level watershed of concern where spruce beetle mortality has resulted in a high basal 

areas loss, streams remain healthy and stable. A monumented cross-section established in 2003 

was again surveyed in 2008 and stream width and gradient have not been affected to date by 

reduction in live basal area due to spruce beetle infestation. 

Main Stem 

The main stem of Rio de los Pinos does not lie within but is adjacent to the analysis area. This 

stream is classified as a B4/C4 stream type with much of its watershed within wilderness and 

backcountry. Stream bank stability on the main stem of Rio de los Pinos below the proposed 

treatment area is good, with healthy riparian vegetation in proper functioning condition able to 

withstand high flows. In localized steep areas, bank instability attributable to natural bedrock 

weathering is present, which adds fine and coarse sediment to bedload through sheet erosion and 

slumping. In addition, above Trujillo Meadows Reservoir there are localized unstable bank 

sections present on outside bends of meanders where the stream channel has migrated into higher 

elevation ground. Unstable bank and impact to riparian vegetation due to livestock grazing in 

this area appear to be minimal. 

Upstream from the project area, this stream currently holds a population of Rio Grande Cutthroat 

trout. Stream health is robust. 

Existing Conditions 

Fisheries: The Rio de los Pinos above the analysis area provides habitat for Rio Grande 

cutthroat trout, which is listed as a Region 2 sensitive species, and was recently petitioned for 

listing as a federally endangered species. The Clean Water Act requires that chemical, physical, 

and biological integrity of all waters, stream channels, and wetlands be protected. Standards and 

guidelines that have proven effective would provide that protection. By following these standard 

design criteria impacts to stream health are expected to be minimal. 



Trujillo Meadows, which is just outside of the analysis boundary (Figure 1.4.1, Chapter 1) 

provides an important recreational fishery in this area. Brook, brown and rainbow trout all 

occupy this reservoir. For addititional information regarding Rio Grande Cutthroat Trout 

populations in this watershed, please see the BE/BA and MIS appendices. 


Effects Common to all Action Alternatives 

Disturbed areas within a watershed produce sediment that can be delivered to stream channels. 

Disturbances located close to or connected to channels typically contribute the largest amount of 

sediment and are the most likely to impact proper riparian and floodplain function. Potential 

impacts are described in more detail in the aquatic and riparian sections of the Forest Plan FEIS. 

Effects of fine sediment and damaged banks are generally considered to be detrimental to aquatic 

life, including fish. Fine sediment can suffocate trout eggs or trap emerging trout fry, reducing 

reproductive success. Fine sediment can also reduce primary productivity and invertebrate 

abundance, which reduces trout food availability in a stream. Damaged banks can diminish trout 

cover, shade (important for moderating stream temperatures), and habitat for terrestrial insects 

(an important food source for trout). 

New surface disturbances associated with Alternatives 2 and 3 would include timber salvage 

operations, road reconstruction, and temporary road construction. The planned activities under 

Alternatives 2 and 3 can be found in Chapter 2. 

Severity of a wildfire and associated watershed impacts are potentially reduced under the two 

action alternatives. Detailed discussion regarding fuels loading and fire potential over time is 

provided in the Fire and Fuels management section. 


No surface disturbances would occur. Under Alternative A (No action), only natural effects to 

aquatic ecosystem and special area concerns will occur. However, changes to these parameters 

may likely happen under this scenario. For example, dead trees adjacent to a stream that fall can 

expose soil that could enter the stream, increasing fine bedload locally. 

Stream channels and riparian areas would be left in their existing condition. Less emphasis 

would be placed on identifying and correcting existing road erosion concerns. Closing portions 

of roads as proposed in the action alternatives would not occur. Existing stream health impacts 

would be corrected as time and funds become available without the benefit of funds associated 

with harvesting timber. 

Loss of live basal area due to spruce beetles has already occurred to varying degrees within 

analysis watersheds. Spruce mortality is close to 100% in several timber units in upper Rio de 



los Pinos Creek drainage and overall at the 6 th level could result in loss of about 14% of live 

basal area. In the seventh level watershed of concern, it is projected that about 70% of live basal 

area has been lost. 

A recent white paper by Carlson (2008) summarized research regarding beetle epidemics and 

potential effects to watershed hydrology. Overall, effects of tree mortality would be dependent 

on forest type, percentage of trees killed, and the annual precipitation. Changes that could be 

expected include: 

Moderate increases in annual water yield, mostly in spring snowmelt runoff 

Minor increases in late summer to fall low flows, if any at all 

Variable responses (no change or increases) in peak flow size 

Some earlier timing of peak flows (earlier snowmelt runoff) 

Moderate effects in the early years post-epidemic, greater effects 5 to 15 years out and 

effects persisting at a decreasing rate possibly up to 60 years 

Response depends upon precipitation – greater effects (i.e. larger increases) will be seen 

in wetter years 

Presence of standing dead trees and residual live trees and understory in the watershed 

mitigates increases in water yield 

The effects of climate change on snowfall and snowmelt may make it difficult to isolate 

the specific responses of the bark beetle epidemic on water yield 

Two key factors that can effect the amount of increase in flow include: 1) length of time that 

dead trees continue to have needles that will capture snowfall; 2) understory vegetation and 

subsequent increase due to availability of moisture and sunlight. 

In the Rio de los Pinos project area it is likely that moderate changes in hydrology may occur 

naturally on a 7 th level basis where mortality is high but on a 6 th level these changes will 

probably be subtle at current infestation rates. However, if infestations spread to large areas of 

the entire Rio de los Pinos watershed, cumulative effects to the hydrologic system are possible. 

Effects to stream stability due to a moderate increase in flow is dependent on stream and riparian 

characteristics. Streams with coarse bedload and banks with good riparian vegetation can 

withstand an increase in flow better than streams with finer bedload and especially if bank 

stabilizing vegetation is impaired or lacking. As noted earlier, stream monitoring on the tributary 

to Rio de los Pinos located in the watershed of concern did not show any stream bank 

stability/geometry or gradient changes from 2003 to 2008. 

In any forest area that has high mortality, fire effects due to fuel loading are a concern. Although 

likelihood of a wildfire start is small, severe watershed damage could be increased if dead and 

infected trees are not removed and a fire would occur. Stream water temperature will increase 

slightly along reaches where canopy cover is lost due to spruce mortality. 


Dead and infested spruce trees on approximately 670 acres would be harvested in the Rio de los 



Pinos Creek watershed while complying with all Forest Plan standards and guidelines. Some 

surface disturbances would occur as old roads are reconstructed and temporary roads are 

constructed. Skidding logs would also cause surface disturbances. Adequate buffering would 

prevent eroded sediments from finding their way into stream channels. 

Watershed disturbance analyses are conducted on a 6 th level basis. As can be seen from Table 

3.6-1, total disturbance within the Rio de los Pinos watershed would remain under the 15% 

concern level. Current and projected disturbance levels under Alternative 2 on a 6 th and 7 th level 

are provided in Table 3.6-1. Acreage of additional disturbance includes skid trails, landings, and 

new temporary roads. 

Table 3.6-1. Watershed disturbance levels - Alternative 2. 

6 th Level 

7 th Level 


130100050501 13010005050102 

13010005050101 

Total Acres 

Acres of 

11,420 7,111 1,064 

previous 

watershed 

disturbance 

1,294 --11.3% 379.3 --5.3% 

149.2 --14.0% 

Total +Salvage 67.3 +Salvage 50.5* acres +Salvage 16.8 acres* 

Disturbance acres * 

+Recent Timber Sales: 24.9* 

including 

acres 

acreage of Rio +Recent Timber + Road const./Reopen: 2.54 

de los Pinos 

Salvage, 

Sales: 24.9* acres 

+Road const./Reopen: 0.9 acres 

recent timber + Road 

sales, and new const./Reopen: 5.0 

temporary and 

system road 

acres 

TOTAL % 12.2 TOTAL % 6.1 

TOTAL % 18.0 

* Total equivalent disturbance acreage (as related to road disturbance) within a timber harvest project is 

calculated as 10% of the total harvest unit area. This is disturbance within a land unit that results from 

skid trail spacing of 100 feet. 

The Clean Water Act requires that chemical, physical, and biological integrity of all waters, 

stream channels, and wetlands be protected. Forest Plan standards and guidelines would provide 

that protection. By following these standard project design criteria, impacts are expected to be 

minimal. Standard project design criteria prevents skidding logs down stream courses and keeps 

heavy equipment a safe distance from channels. All surface disturbances are adequately 

buffered to prevent direct impacts to the water influence zone, floodplains and riparian areas. 

Since this harvest is a mainly a salvage, change in live basal area due to harvest (only in scenic 

patch cuts) will be minor. Currently, loss of live tree basal area from beetle infestations in the 

Rio de los Pinos watershed could reach 14% and in the 7 th level watershed may be approaching 

70%. This will occur regardless of harvest operations. 

Potential effects to watershed hydrology due to this natural loss of basal area was discussed in 

the No Action alternative. When harvest of a large percentage of dead trees in a beetle killed 



forest area occurs, Carlson (2008) noted that recent studies and modeling show a potential for 

greater water yields. The harvest of trees eliminates interception of precipitation and shading 

which slow snowmelt. In addition, understory can be removed and amount of fine and coarse 

woody debris is altered. In addition, compaction in skid trails, landings, and roads can affect 

overland flow, routing runoff to streams. 

These negative effects of skid trails and roads are mitigated by following Forest Plan standards 

and guidelines and design criteria in the Watershed Conservation Practices Handbook. Carlson 

(2008) cited recommendations from recent studies to mitigate hydrologic effects of beetle 

mortality and associated logging including: 

Construct, inspect and maintain roads to ensure natural surface and shallow subsurface 

drainage remains intact 

Upgrade drainage networks on permanent roads prior to salvage logging as necessary to 

accommodate expected increases in peak flows 

Minimize harvesting in riparian areas and consider wider riparian buffer widths 

Retain, where possible, all green vegetation (understory and overstory) both inside and 

outside of riparian area. 

Plan harvest units at the watershed scale to minimize road density 

Leave fine and coarse woody slash on-site in openings where possible to provide 

surface roughness which would delay snowmelt, reduce wind speeds (and thus 

sublimation), maintain soil moisture and aid in site regeneration 

Several of these measures either are being completed as standard implementation of Forest Plan 

standards and guidelines or have been adopted as design criteria to the Rio de los Pinos project. 

Due to general watershed concerns, additional project design criteria have been added to ensure 

protection of stream courses within the harvest areas, including the 7 th level watershed of 

concern. These criteria, discussed in more detail below, are simple but effective measures that 

include restrictions to where harvest can occur and proven sediment control techniques to 

prevent impact to streams from road activities. Monitoring by the Rio Grande National Forest 

(“Effective Monitoring-Rio Grande National Forest”, Dobson, 2005) has demonstrated that these 

and other standards and design criteria have proven effective in protecting watershed resources. 

A no harvest buffer has been established along all stream channels (including the crenulated 

network) for 100 feet on both sides of the channel. No heavy equipment would operate within 

the water influence zone (100 ft on each side of a channel) except at designated crossings unless 

authorized by the Forest Service where site-specific conditions would minimize stream and 

riparian impacts. The actual field delineation of the water influence zone in the Rio de los Pinos 

analysis area was usually wider than the basic definition noted above as wet seeps and riparian 

vegetation areas were included. 

Approximately 3.3 miles of existing old roads will require reopening. These roads that have 

been closed for some time have naturally revegetated to varying degrees but would need to be 

maintained or reconstructed. These roads would be evaluated by Forest Service personnel to 

identify erosion and sediment concerns so they can be fixed as part of upgrading operations. 



Existing vegetation on cut and fill slopes would be retained as much as possible to limit sediment 

movement away from road. 

New road locations have been carefully planned to minimize potential for sediment input to 

stream courses. Approximately 0.2 miles of new temporary road would need to be built. 

Locations have been chosen to minimize stream crossings and where one does occur it is at a 

right angle. 

Several segments of existing system road to be reopened are within the WIZ (within 100 feet) of 

small perennial streams. These areas will be the focus of inspections by hydrology or soils 

specialists or their designees to ensure sediment sources are disconnected from the stream 

channels. Hardening, filter fence, timber slash windrows, and straw wattles will be used as 

appropriate where drainage cannot be directed to adequate buffer strips along these reaches. 

Following timber and reforestation operations, new temporary roads constructed for this project 

would be closed and obliterated. Several spur roads off Forest Road118 would be closed and 

rehabilitated. This would further reduce long-term sediment sources that could find their way 

into stream channels. In addition, 0.8 miles of Forest Road 118.2 will be closed, 

decommissioned, and converted to a hiking trail while a separate 0.4 miles of FSR 118.2 would 

also be decommissioned. Closing and decommissioning these road segments that runs parallel to 

the main stem of the Rio de Los Pinos would reduce sediment impacts from travel and 

associated activities along the road. 

As described in the existing condition section and shown in Tables 3.6-1 and 3.6-2, disturbance 

levels within the small 7 th level watershed of concern within the Rio del los Pinos watershed 

would increase under all action alternatives. Stream health was carefully assessed in 2003, 2004, 

and 2008. As described in the current condition section, stream health was determined to be 

robust and has recovered well from past disturbance. Forest Plan standards and guidelines and 

additional project design criteria would ensure impacts to stream health in this small watershed 

are minimal. Monitoring of stream channels within and adjacent to harvest areas would be 

conducted as described in Chapter 2 to verify project design criteria effectiveness. 

Alternative 2 would cause more surface disturbance than alternative 3 because more area would 

be accessed with harvesting equipment. Impacts resulting from this alternative would be 

considered acceptable as long as standards and guidelines and the project design criteria are 

followed. Deteriorated stream health would not be expected. 


Impacts from timber harvest and road work would be similar to impacts described for Alternative 

2. However, amount of old road reopened would be less, 2.5 miles as compared to 3.3 miles. 

No new temporary road construction would occur under Alternative 3. Conversion of 0.8 miles 

of Forest Road 118.2 into a trail would also occur under this alternative, as well as the additional 

0.4 mile of road decommissioning. Less surface disturbance would occur in the watershed with 

most activity occurring in the south and central portion of the project area (Table 3.6-2). The risk 

of direct impacts to watershed and stream health would still be within acceptable limits as 



current standards and guidelines and project design criteria are implemented. Similar to 

alternative 2, project design criteria, including remedial work, should correct watershed 

concernss from the past and allow stream health to improve over time. 

Table 3.6-2. Watershed Disturbance Levels Alternative 3. 

6 th Level 

7 th Level 


130100050501 13010005050102 13010005050101 

Total Acres 

Acres of 

11,420 7,111 1,064 

previous 

watershed 

disturbance 

1,294 --11.3% 379.3 --5.3% 149.2 --14.0% 

Total 

+Salvage 49.8 +Salvage 39.1 +Salvage 10.7 acres* 

Disturbance 

acres* 

acres* 

including 

+Recent Timber Sales: 24.9* 

acreage of Rio 

+Recent Timber +Road 

+Road const/Reopen: 0.65 acres 

de los Pinos 

Sales: 24.9* const/Reopen 1.85 

Salvage, 

acres 

recent timber 

+ Road 

sales, and new 

const/Reopen 3.7 

temporary and 

system road 

acres 

TOTAL % 12.0 TOTAL % 5.9 TOTAL % 17.4 

* Total equivalent disturbance acreage (as related to road disturbance) within a timber harvest project is 

calculated as 10% of the total harvest unit area. This is disturbance within a land unit that results from skid 

trail spacing of 100 feet. 

Table 3.6-3 summarizes the direct and indirect effects of the proposed project disturbances on a 

watershed analysis scale. No alternatives would change chemical quality of water. 

Table 3.6-3. Effects checklist. 

Alt 1 Alt. 2 Alt. 3 

AQUATIC ECOSYSTEMS 

Physical: Sediment No effect Minor effect Minor effect 

Bed/bank stability No effect Minor effect Minor effect 

Flow regimes No effect Minor effect Minor effect 

Chemical: Temperature No effect Minor effect Minor effect 

Water Purity No effect Minor effect Minor effect 

Biological: Aquatic life No effect Minor effect Minor effect 

SPECIAL AREAS 

Riparian ecosystems No effect Minor effect Minor effect 

Wetlands No effect Minor effect Minor effect 

Floodplains No effect Minor effect Minor effect 

CUMULATIVE EFFECTS 

Aquatic ecosystems Major effect* Minor effect Minor effect 

Riparian ecosystems Major effect* Minor effect Minor effect 

NOTE: This checklist ensures that all required effects are analyzed, gives a snapshot of all 

effects, and identifies items to dismiss from rigorous analysis. Effects shown assume full 

implementation of protection measures. 

* Major effect determination is based on: 1) the likelihood of a more intense and severe fire 

if one should occur. 




The accumulation of watershed disturbances from past activities is not a threat to watershed 

health. As explained above, under “Existing Conditions”, on the 6 th level total watershed 

disturbance is below concern levels established in the Forest Plan. The small tributary to Rio de 

los Pinos (7 th level) was identified in the Forest Plan as a watershed of concern, mainly due to the 

amount of roaded area and previous timber harvest. During evaluation of this watershed for the 

County Line project stream health was found to be robust. Currently, two timber sales are active 

in the Rio de los Pinos watershed (Spruce Park and Escarabajo). Other recent sales in the Rio de 

los Pinos watershed included Neff Mountain and a small part of Grouse. These sales were 

included in the effects analyses for the two action alternatives. 

Cumulative watershed disturbances from timber harvest activities are not expected to cause 

serious impacts under any alternative. Disturbances associated with the action alternatives would 

not threaten watershed or stream health as long as Forest Plan standards and guidelines and 

project design critera are followed. Since disturbance levels at the 7 th level are greater than 

concern levels and a high percentage of natural basal area loss has occurred, additional 

monitoring, including a monumented cross section that was established in 2004 and evaluated 

again in 2008, will continue. 

Irreversible and Irretrievable Commitment of the Resources 

Any minor impacts to watershed condition or stream health would heal with time. Successful 

implementation of standards, guidelines, and design criteria should keep aquatic resources 

healthy and prevent their irreversible or irretrievable loss; losses in structural capacities 

downstream would also be prevented. 

3.7 Soils 


This analysis will focus on the soils that are directly and indirectly affected by the proposed 

timber harvest in the Rio de los Pinos Analysis Area. Cumulative effects are also analyzed. 

The Rio Grande National Forest Plan has direction that protects soil productivity. The Forest 

Plan standards are consistent with similar standards from the FSH 2509.18 – Soil Management 

Handbook, R2 Supplement No. 2509.18-92-1, Effective August 15, 1992 (the R2 Supplement), 

and FSH 2509.25 – Watershed Conservation Practices Handbook, 2509.25-96-1, 12/26/96 as 

amended in 2006. 

Soils were not identified as a Key Issue in this analysis, based primarily on the fact that soils in 

the Rio de los Pinos area do not have the same degree of risk for landslides that the County Line 

project area had. The following discussions are based on the best available science. 




There has been past timber harvest in some of the stands proposed for harvest. Soil impacts have 

been evaluated by on-site visits and traverses. On October 2, 2007, the soil scientist conducted 

on-site soils investigations for the proposed Rio de los Pinos sale and documented those results 

on data sheets. One soil resource inventory (SRI) unit comprises the majority of the area based 

on the Soil Resource and Ecological Inventory for the Rio Grande National Forest-West Part 

1996. Important soil interpretations are shown below. 

Table 3.7-1 Soil Interpretations 

SRI 

Unit 

Soil 

Compone 

nt 

Tentatively 

Suitable 

Soils 

Erosion 

Hazard 

Reforestat 

ion 

Potential 

Windthrow 

Hazard 

151 Leighcan Suitable Moderate Good Slight High 

Frisco Suitable Moderate Good Slight High 

Mass 

Movement 

Potential 

Soil unit 151 is suitable for timber production. They are very deep soils, with good rooting depth, 

and good water holding capacity. Site index, as an indicator of soil growth potential is 70 to 95 

feet for Engelmann Spruce in a 100 year base age. These are some of the most productive tree 

growing sites in this area. Mass movement is a concern and the high hazard rating warrants a 

closer evaluation before any management activities are conducted. Erosion is a concern that 

would be mitigated as described in this EIS. 



Figure 3.7-1 Soil Erosion Hazard Map 



Existing Conditions 

The following table describes existing soil conditions and current soil impacts. 

Table 3.7-2 Existing soil conditions and current soil impacts. 

Harvest Units Sum of Soil 

Impacts by 

percent of 

activity area* 

Nature of Impacts 

1 2-4% Some past harvest, compaction 

2,3,4 2-4% Some compaction evident in trails 

5 3-5% Compaction due to light past 

harvests 

* Percent of soil impacts on an aerial extent basis within an activity area. An activity area is defined as: An area of land impacted 

by a management activity or activities. It can range from a few acres to an entire watershed depending on the type of monitoring 

being conducted. It is commonly a timber sale cutting unit. 

During on-site visits, skid trail spacings were measured in the proposed harvest units. The skid 

trail spacing provides an initial estimate of potentially impacted area. Soil samples using a tile 

spade were then observed in the field for compaction to define the percent of skid trails having 

compaction. Platy structure, dense layers and wheel ruts indicate compaction. Estimates of soil 

impacts outside of skid trails are also estimated including landings, eroded areas, severely burned 

soils and displacement. 

The Region 2 Supplement allows for a wide range of soil monitoring tools as described below: 

“2.42 - SOIL SAMPLING TECHNIQUES. Sampling techniques range from extensive visual 

observations to intensive sampling techniques using statistically sound methodologies. The 

intensity of sampling must be determined on a case by case basis depending on the values and 

risks at stake.” 

The sampling techniques conducted on these harvest units is well within the R2 Supplement 

requirements. 

All of the stands proposed for harvest are currently meeting soil quality standards. This means 

that, based on on-site investigations, soil impacts are estimated to be well below the 15 percent 

soil standard. Most stands have had only light logging in the past. Compaction is the primary soil 

impact. 


All standards and guidelines from the Forest Plan would be implemented and are incorporated 

into action alternatives as design criteria. Design criteria are non-discretionary actions that must 

be implemented as part of the action alternatives. One of the key soils standards states the 

following: 

Forest Plan Standard (III-10, Soil Productivity Std #1): “Manage land treatments to limit the 

sum of severely burned and detrimentally compacted, eroded, and displaced land to no more than 



15% of any land unit.” 

This standard does not include the permanent transportation system. 

The direct effects of logging on soils include soil compaction, displacement, erosion and nutrient 

issues. Severely burned soils would occur if slash is piled and burned. Some amount of 

compaction, displacement and erosion would be expected. The goal of the harvest will be to 

meet standards that require the Forest not to exceed 15% of the area in soil impacts. This would 

be accomplished by careful design and layout of skid trails, by harvesting on snow or frozen 

soils, and by limiting operations to dry seasons. If soils become too wet, operations shall cease. 

Using existing skid trails would help keep soil impacts minimized. After operations are 

completed, the use of a winged subsoiler or comparable reclamation measures may be necessary 

in some locations to mitigate soil impacts. 

Soils in the project area have nutrient limitations based on soil criteria. A portion (50%) of the 

fine slash (branches and limbs) would be retained within the forested stand to maintain nutrient 

reserves. 

Soils of the project area have a high rating for potential mass movement (landslides). A high 

rating does not preclude an action but requires more detailed analysis. In order to address 

landslide potentials and hazards, two levels of analysis were completed. One is an investigation 

of land mass stability using recent air photos to look for landscapes that might exhibit recent 

landslide occurrences. The findings of that investigation are contained in a report titled An Aerial 

Photography Analysis of Land Mass Stability Hazards in the Proposed Rio de Los Pinos Timber 

Sale, J. Rawinski, February 27, 2008. There were no locations showing active mass movement 

hazards, and only one small location that would require further ground-checking. 

Another level of landslide analysis was the on-site soil investigations that were conducted on 

October 2, 2007. During that analysis, no recent mass movement issues were observed or 

identified. 

Indirect effects include possible mass movement resulting from changes in vegetation and soil 

water characteristics. While this is not expected, some small slumps could occur due to a variety 

of reasons. Heavy snowpacks, dead trees that no longer transpire soil moisture and other factors 

could contribute to some minor slumps, usually less that ¼ acre in size. To reduce risks, any 

temporary road construction would occur on gentle slopes and away from seeps and wet areas. 


If no action is taken, standing dead trees would soon fall over and begin to rot. As fallen logs 

become moist, fungi would begin to break down the wood and return it to the soil. Rotting logs 

may provide seedbeds for seedlings. Nutrients would be recycled. Soils would remain healthy. 

Wildfire severity might increase as trees fall to the ground, should a wildfire event occur in this 

area in some future decade. 




The amount of soil impact is generally proportional to the acres harvested. The primary soil 

impacts from logging are erosion and compaction. Erosion from skid trails and roads would be 

greater in amounts than erosion from within-stand timber harvested areas, where erosion is 

minimal. Compaction and rutting are a concern on skid trails and landings. Moisture conditions 

would be monitored to assure soils are operable and soil impacts are minimized. Should rutting 

occur in individual locations within a stand, the impact would be short-term and within soil 

standards, as skid trails are closed at the end of each operating seasson and are closed-out and 

rehabilitated at the end of harvest. In any harvest unit, skid trails are designed at 100 foot 

spacing which would keep compaction and other soil disturbances within allowable standards. 

Winter logging or logging on snow or frozen soil conditions best protects the soils from impacts 

and may be done in a number of units of the sale. 

Some erosion would be expected from temporary road construction and re-opening of existing 

and currently closed roads, and road maintenance. Erosion and sedimentation can be kept to 

acceptable amounts by restoring or incorporating proper drainage into adequate buffer areas. 

Buffer areas can filter erosion before runoff enters perennial stream systems. 


The impacts to soils would be similar to those effects described for Alternative 2. Overall, there 

would be slightly less impacts to soils due to less overall acres being harvested. 


Cumulative effects to soils can result from repeated entries into forested stands. The cumulative 

effects to soils can be reduced by implementing the design criteria, including monitoring wet 

weather soil conditions. The winged subsoiler can be used to improve soil health (reduce 

compaction). The winged subsoiler is the state-of-the-art implement that is vastly superior to 

ripping blades. The Rio Grande National Forest has this implement available and uses it 

regularly to decommission roads and restore compacted soils. The subsoiler wings lift the soil, 

creating new voids (soil shatter) within the soil while causing minimal surface disturbance. 

Multiple-tined rippers tend to plow the soil surface more, creating potential weed establishment 

sites. With subsoiling, water is then able to enter the soil as opposed to running off the surface 

and causing erosion. Plants are able to re-establish on such soils since growing conditions have 

been improved. A study in Oregon concluded that the winged subsoiler was able to alleviate 

soil compaction in an area where brush and slash piling had occurred (BLM, 1988). Rippers 

have been compared with subsoilers and the results indicate that the degree of soil shatter was 

deeper and more extensive with a subsoiler than with conventional ripping implement (Carr, 

1989). In a study in California, winged subsoilers proved to be clearly the superior tool for skid 

trail and landing tillage when compared to rock rippers (Cafferata and Sutfin, 1991). Subsoiling 

was one of several road restoration treatments analyzed in a study, and was found to be the most 

economically-viable alternative compared to full recontouring and other road restoration 

treatments (Kolka and Smidt, 2004). 



Other reasonable and foreseeable actions include recreation activities and livestock grazing. 

Wetlands 

Potential impacts specific to wetlands were also considered as part of the soils analysis for the 

project area. Evaluations concerning the presence, health, and adequate protection of wetlands 

were performed by two separate soil scientists as well as the project hydrologist. Locations 

which were identified as having wetland protection needs are displayed in Figure 3.7-1. 

No past actions have affected the existing condition of wetlands in the analysis area. Harvest 

activities have historically occurred around these habitats, but no manipulation has occurred 

within them as a result of management activities. As a result, Appendix D, “Disturbances by 

Watershed,” shows no Wetlands or Riparian Areas altered within either watershed. 

Alternative 1, the No Action alternative, is expected to have no effect upon wetlands. Both 

Alternatives 2 and 3 are expected to have minor effect upon wetlands, due to insignificant levels 

of sediment and nutrient transportation which may reach the outer edges of these wet meadows. 

Increased water yield is expected in all alternatives, including the No Action, due to the loss of 

live basal area as a result of the spruce beetle epidemic. Implementation of the action 

alternatives is not expected to produce any measurable increase in water yield above the No 

Action alternative. Application of project design criteria specific to wetlands will ensure 

adequate protection of these habitats, as documented in the Soils Specialist report and Section 

3.6. Table 3.6-3, “Effects Checklist,” displays the effects of each alternative upon wetlands. 

These actions, when added to other past, present, and reasonably foreseeable future actions, are 

expected to have no cumulative impacts upon wetland resources within the analysis area. No 

past actions have been identified as having impacted wetlands. No reasonably foreseeable future 

actions are planned within the wetlands. Any anticipated minor effects associated with the 

proposed action alternatives are expected to have no long term impacts upon wetlands and would 

represent no irreversible or irretrievable commitment of resources. 

3.8 Threatened, Endangered and Sensitive Wildlife Species 

Scope of the Analysis 

The scope of this analysis discusses Threatened, Endangered and Region 2 designated 

Sensitive terrestrial wildlife. Aquatic species are addressed in section 3.10. The analysis was 

conducted for various species at the appropriate scale as follows: 

Canada lynx – the Analysis Area is the Rito Archuleta Lynx Analysis Unit (LAU). 

All other terrestrial TES species – analyzed within the Rio de los Pinos analysis area boundary 

described in Chapter 1, Section 1.4. 



This section summarizes a more detailed analysis contained in the wildlife Biological 

Assessment (BA) and Biological Evaluation (BE), which is part of this project’s 

administrative record. 


The existing condition in the Rio de los Pinos Analysis Area has been impacted by historic 

activities, including timber, grazing, and recreation (see sections 3.5, 3.14, and 3.16). 


The current composition of stands within the Analysis Area is primarily spruce/fir. The average 

age of the spruce/fir stands varies between 160 to 220 years. The stands may be characterized as 

dense, mature to over-mature Engelmann spruce/subalpine fir timber stands, with typical basal 

areas between 126 and 205 square feet. Openings created in these stands by past timber harvest 

have regenerated to a dense mix of spruce and fir saplings (Section 3.5). 

Cattle grazing continues to occur within portions of the analysis area, (primarily in natural parks, 

meadows, or openings created by past timber harvest). Within the analysis area, there are 241 

acres mapped as suitable rangeland (from the Forest Plan Suitability analysis) for cattle. Of 

these 241 acres, 173 acres are mapped as Transitory rangeland and 68 acres are mapped as 

Primary rangeland. Access to the project area for livestock is primarily along the existing road 

system (Section 3.14). 

Dispersed recreation continues to occur in the analysis area and includes: driving for pleasure, 

sight-seeing, hiking, hunting, fishing, horseback riding, picnicking, firewood gathering, snow 

shoeing and cross-country skiing to a system of yurts, use of all-terrain-vehicles (ATVs) on 

roads, and snowmobiling (Section 3.16). 

Some of the roads in the Analysis Area have been closed with gates or dirt barriers. Many of 

these roads are re-vegetated and in some cases, have blended into the topography but in most 

cases, are still recognizable as travel ways. 

Wildlife species that occur or may occur within the Rio de los Pinos Analysis Area involve those 

species that are most commonly associated with the spruce-fir cover type. Riparian vegetation 

also occurs within or adjacent to the analysis area in association with stream and river channels 

and small ponds and wetlands. A representative sample of these species groups is as follows: 

Reptile and Amphibian Species: Reptile species are relatively scarce in the spruce-fir cover types 

of Colorado, with the western terrestrial garter snake being the only common species. This garter 

snake has semi-aquatic life history needs and could be expected to respond to habitat changes in 

a manner similar to amphibians. The tiger salamander is likely to be found within the Rio de los 

Pinos analysis area. 

Avian Species: There are at least 17 species of birds that are primarily associated with spruce-fir 

forests in the Southern Rocky Mountains of Colorado (Beidleman 2000). An additional 11 



species are common in mixed-conifer forests, many of which also occur in the spruce-fir system 

on the Rio Grande National Forest. Avian species of management interest include the 

American three-toed woodpecker (Forest Service Region 2 (R2) Sensitive), olive-sided 

flycatcher (R2 Sensitive and Colorado Bird Conservation Plan {BCP} Priority Species), boreal 

owl (R2 Sensitive and Colorado BCP Priority Species), hermit thrush (management indicator 

species (MIS)), brown creeper (MIS) and the Hammond’s flycatcher (Colorado BCP Priority 

Species). Other spruce-fir associated species that occur or may occur in the Rio de los Pinos 

Analysis Area include the mountain chickadee, red-breasted nuthatch, pine grosbeak, pine siskin, 

and ruby-crowned and golden-crowned kinglets. 

Mammal Species: Some mammals that occur or may occur in the Rio de los Pinos Analysis Area 

include Rocky Mountain elk (MIS), mule deer (MIS), Canada lynx (Federally Threatened), 

American marten (R2 Sensitive), black bear, short-tailed and long-tailed weasels, southern redbacked 

vole, least chipmunk, red squirrel, snowshoe hare, porcupine, heather vole, hoary bat, and 

little-brown bat. 


Threatened, Endangered, or Proposed Species 

Table 3.8-1 is a summary of the findings for Threatened, Endangered, or Proposed 

wildlife species. 

Table 3.8-1. Summary of Findings for Threatened, Endangered, or Proposed 

species. 

Species General Habitat 1 

No Action 

Canada lynx 

Felix lynx 

canadensis 

Mexican 

spotted owl 

Strix 

occidentalis 

lucida 

Southwestern 

willow 

flycatcher 

Emidonax trailii 

extimus 

Uncompahgre 

fritillary 

butterfly 

Boloria 

acrocnema 

Mixed conifer forests 

and 

aspen/willow/shrub- 

steppe. 

Steep canyons with a 

Douglas-fir, white fir, 

ponderosa 

pine/pinyonjuniper 

component 

Riparian habitats along 

rivers, 

streams or other 

wetlands, 

where dense growths of 

willows or other shrub 

and 

medium-sized trees are 

present 

Alpine habitat above 

11,000 

feet with a snow willow 

component 

2 

Full Salvage 

Harvest 

(Proposed Action) 

NLAA NLAA NLAA 

NE NE NE 

NE NE NE 

NE NE NE 

3 


Harvest 



The Biological Assessment prepared for Threatened and Endangered (T&E) species considered 

four species and determined that suitable habitat exists for only one, the Canada lynx. Canada 

lynx is further analyzed in each alternative for the Rio de los Pinos Vegetation Management 

Project. Mexican Spotted Owl, Southwestern Willow Flycatcher, and Uncompaghre Fritillary 

Butterfly were not further analyzed due to lack of suitable habitat present within the analysis 

area. For this project, there will be no effect to the Mexican Spotted Owl, Southwestern 

Willow Flycatcher, or Uncompaghre Fritillary Butterfly or their habitat. 

The Rio de los Pinos Analysis Area occurs within the Rito Archuleta Lynx Analysis Unit (LAU). 

This LAU encompasses approximately 94,118 acres in size. Potential effects on the Canada lynx 

were assessed by comparing the LAU baseline conditions to changes predicted from the 

alternatives, in addition to analyzing how the project meets the Objectives, Standards, and 

Guidelines in the Southern Rockies Lynx Amendment (2008). 


Under this alternative there are no potential direct impacts upon lynx as no new human activity 

would occur. The analysis area would slowly convert into lynx winter foraging or other habitat. 

Through time, a patchy distribution of deadfall, dead standing and newly regenerating trees and 

shrubs would likely occur across the landscape. Some areas would continue to provide denning 

or foraging habitat for lynx, and may even improve in quality as an abundance of coarse woody 

debris becomes available for denning, and as areas open up and the understory vegetation is 

released. 

Alternative 1 is expected to result in short-term negative influences on lynx due to tree 

mortality and loss of canopy cover. These changes may affect the manner in which lynx 

could potentially use the Analysis Area for denning, foraging, or travel purposes, with utilization 

of the area being reduced as canopy cover is reduced due to natural tree mortality and then, in the 

longer term, the area might provide good winter foraging habitat and some potential den sites. 

Changes may also affect the habitat of lynx primary prey, the snowshoe hare. Overall, changes 

within this area would be expected to benefit snowshoe hare as increased light and nutrients 

reach the ground and understory vegetation is released, providing food and cover for snowshoe 

hares (one of the primary prey items for lynx). 

This area is adjacent to other areas having a backcountry or wilderness prescription, which will 

not be harvested, in addition to being adjacent to the southern County Line vegetation 

management project areas (which are being treated somewhat differently than treatments 

proposed in this area). Cumulatively, if this area is not harvested, it will be expected to respond 

to this event very similarly to the backcountry and wilderness areas surrounding it, resulting in 

more homogeneous habitat across the landscape than would be expected under either of the 

action alternatives. 




Under this alternative there is a small chance of lynx being temporarily displaced during 

harvest activities. Lynx denning and winter foraging habitat would be converted into winter 

foraging or other habitat. The mature spruce trees throughout this Analysis Area are infested 

with spruce beetles to a degree of 95-100% (Tooley personal communication 2009). Therefore, 

stands within the Analysis Area that do not have a multi-storied structure, or areas where the 

current understory is equivalent to a stand initiation structural stage (SISS), would be considered 

unsuitable for lynx. 

Creation of 0.2 miles of temporary road could result in an increased disturbance to lynx. In 

addition, 3.3 miles of closed roads would be temporarily re-opened for harvest activities which 

could disturb lynx until they are re-closed following harvest. Following harvest, this entire 3.5 

miles of roads would be closed. After being closed and re-vegetated, the road may be used by 

hunters or recreationists on foot to access the Forest, potentially putting lynx at more of a risk of 

disturbance or accidental or deliberate shooting, (although this is highly unlikely due to the rarity 

of these types of incidents). Under this alternative, open road density would have an overall 

decrease of ½ mile. 

Lynx could be temporarily disturbed and/or displaced during logging operations, however, they 

would be expected to move into adjacent suitable habitat and would not be expected to be injured 

or killed by logging operations. Preferred lynx denning habitat occurs on north-facing, steep 

slopes. Most of this Analysis Area consists of more gentle slopes, fairly near to roads. Other 

nearby areas have steeper slopes and are further from disturbance associated with roads. The 

majority of these more suitable areas would not be treated, and would continue to provide 

suitable lynx denning habitat. If a den did occur in a treatment area and small lynx kittens were 

still in their dens while logging operations were taking place, they could potentially be injured or 

killed by logging equipment. However, it is highly unlikely that logging would occur during this 

time period (approximately April through early June), due to wet soil conditions, or that a den 

would be disturbed; so the chance of this type of mortalilty as a result of logging operations is 

thought to be insignificant and discountable. In addition, if logging operations were close 

enough to cause a mother lynx to become uncomfortable, she would likely move her young to a 

new, more remote den site. 

Selection of this alternative could decrease lynx habitat effectiveness in the Analysis 

Area in the short term, but the project and the LAU would continue to meet and exceed the 

Objectives, Standards, and Guidelines in the Southern Rockies Lynx Amendment (SRLA, 2008). 

These would be met by both alternatives 2 and 3 in the following manner: 

Objective VEG 01 

Manage vegetation to mimic or approximate natural succession and disturbance 

processes while maintaining habitat components necessary for the conservation of 

lynx. 

• This entire project is a salvage of dead and dying trees from high levels (95-100%) of 

spruce beetle infestation. The removal of some of these trees will create gaps that 



encourage understory initiation and growth while the snags and downed logs that remain 

contribute to successional processes on the forest floor. The project area will resemble a 

disturbance patch within a larger matrix of late-successional, untreated stands when 

activities are complete. 


Provide a mosaic of habitat conditions through time that support dense horizontal 

cover, and high densities of snowshoe hare. Provide winter snowshoe hare habitat 

in both the stand initiation structural stage and in mature, multi-story conifer 

vegetation. 

• As noted in the response to VEG01, the project area is expected to function as a 

disturbance patch within a larger matrix dominated by multi-storied late-successional, 

untreated spruce-fir stands. Stand initiation processes will be encouraged within the 

treatment areas and be surrounded by over 20,000 acres of high-quality habitat within the 

Rito Archuleta LAU. 

• Past treatment openings have been cited as providing good winter snowshoe hare habitat 

based on personal information provided by the lynx tracking crew (Gomez 2009). J. 

Ivans (hare researcher) also indicated that the older openings are similar to good hare 

habitat in the spruce-fir within his study area near Taylor Park, Colorado (Gomez 2009). 

• The combination of existing openings that support healthy immature trees, the proposed 

treatment areas, and the existing matrix of mature, multi-story spruce-fir stands suggest 

that a mosaic of habitat conditions will be provided through time. 


Focus vegetation management in areas that have potential to improve winter 

snowshoe hare habitat but presently have poorly developed understories that lack 

dense horizontal cover. 

• A complete focus on areas of poorly-developed understory cannot be provided because of 

the high-levels of spruce beetle activity. Addressing these areas through salvage and 

reforestation, if needed, are also a key aspect of the proposed action. This treatment will 

remove a majority of the dead overstory trees and allow for the release of live canopy 

foliage and overstory characteristics important to the snowshoe hare as well as suitable 

habitat for the red squirrel, which is an important secondary prey item for lynx in 

Colorado (Shenk 2008). 

• Units having poorly developed understories are expected to be improved (through 

planting if necessary). See Project Design Criteria listed in Table 6. 



Objective ALLO1 

Maintain or restore lynx habitat connectivity in and between LAU’s and in linkage 

areas. 

• Connectivity will be maintained within the project area and LAU through unharvested 

WIZ areas dispersed throughout the Analysis Area, in addition to trees left standing 

(which include understory vegetation, fir trees of all sizes, and snags left standing (38-60 

trees per acre). 

Standard VEG S1 

If more than 30 percent of the lynx habitat in an LAU is currently in a stand 

initiation structural stage that does not yet provide winter snowshoe hare habitat, 

no additional habitat may be regenerated by vegetation management projects. 

• All treatments are consistent with VEGS1. Under current conditions, only 2% of the 

Rito-Archuleta LAU is in a stand initiation structural stage (SISS). Treatment under 

either of the action alternatives would not result in an increase in the percent of habitat in 

a SISS. 


Timber management projects shall not regenerate more than 15 percent of lynx 

habitat on NFS lands within an LAU in a ten-year period. This 15 percent includes 

the entire stand within an even-aged regeneration area, and only the patch opening 

areas within group selections. Salvage harvest within stands killed by insect 

epidemics, wildfire, etc. does not add to the 15 percent, unless the harvest treatment 

would cause the lynx habitat to change to an unsuitable condition. 

• Implementation of this project would be expected to change a very small amount (28 -29 

acres) of lynx habitat into a currently unsuitable (SISS) condition. This does not change 

the percent (currently 2%) of unsuitable lynx habitat within the Rito-Archuleta LAU. 

Therefore, this project easily meets the standard. 


Vegetation management projects that reduce winter snowshoe hare habitat in multistory 

mature or late successional conifer forests may occur only (VEG S6 

Exceptions): 

1. Within 200 feet of administrative sites, dwellings, outbuildings, recreation sites, 

and special use permit improvements, including infrastructure within permitted 

ski area boundaries; 



or 

2. For research studies or genetic tree tests evaluating genetically improved 

reforestation stock; 

or 

3. For incidental removal during salvage harvest (e.g., removal due to location of 

skid trails); 

or 

4. Where uneven-aged management (single tree and small group selection) 

practices are employed to maintain and encourage multi-story attributes as part 

of gap dynamics. 

Project design must be consistent with VEG O1, O2 and O4, except where 

impacts to areas of dense horizontal cover are incidental to activities under this 

exception (e.g., construction of skid trails). 

Exceptions 2 and 4 may not occur in any LAU in which VEG S1 is exceeded. 

• Items #1, 2, and 4 do not apply to this project. 

• All proposed units are a salvage prescription with small, modified patch cuts (where all 

trees 8” dbh and below) are left unharvested. All of the treatments involve salvage 

harvest operations described under VEGS6, Exception #3. While all possible efforts will 

be made to minimize understory impacts to snowshoe hare habitat, it is recognized that 

there will be some incidental removal during salvage harvest. Incidental impacts 

associated with salvage harvest are recognized under Exception #3, and consistent with 

the SRLA. 

Guideline VEG G1 

Vegetation management projects should be planned to recruit a high density of 

conifers, hardwoods, and shrubs where such habitat is scarce or not available. 

Priority for treatment should be given to stem-exclusion, closed-canopy structural 

stage stands to enhance habitat conditions for lynx or their prey (e.g. mesic, 

monotypic lodgepole stands). Winter snowshoe hare habitat should be near denning 

habitat. 

• A complete focus on stem-exclusion, closed canopy stands could not be provided given 

the existing condition of the stands within the analysis area and the purpose and need of 

the proposed action. Under any of the alternatives, the understory vegetation is expected 

to experience a release, promoting a high density of live conifers. Under the two action 

alternatives, areas where Forest Plan regeneration standards are not met will be planted. 

Much of this area is expected to be converted to winter foraging habitat (adjacent to 

nearby denning habitat). 




Habitat for alternate prey species, primarily red squirrel, should be provided in 

each LAU. 

• This treatment will remove a majority of the dead overstory trees and allow for the 

release of live canopy foliage and overstory characteristics important to the snowshoe 

hare as well as suitable habitat for the red squirrel, which is an important secondary prey 

item for lynx in Colorado (Shenk 2008). 


Denning habitat should be distributed in each LAU in the form of pockets of large 

amounts of large woody debris, either down logs or root wads, or large piles of small 

wind thrown trees (“jack-strawed” piles). If denning habitat appears to be lacking 

in the LAU, then projects should be designed to retain some coarse woody debris, 

piles, or residual trees to provide denning habitat in the future. 

• Adequate denning habitat (32% of lynx habitat) would continue to be available following 

treatment. In addition, 38-60 trees per acre (8” dbh and larger) would be left throughout 

the analysis area, providing large amounts of woody debris. Root wads of harvested trees 

would also remain on site. Habitat on the western edge of this analysis area (that will not 

be harvested during this project) is thought to provide more favorable potential denning 

habitat (due to slope, etc.) than the actual project area. 

It is expected that sufficient adjacent cover would remain within the forested matrix that the 

general area and overall LAU would continue to function as and provide lynx denning and 

winter foraging habitat. In addition to harvest, the natural processes impacting lynx denning 

habitat would be allowed to occur similarly as described in Alternative 1. At least 38 to 60 trees 

per acre 8” dbh and above would be left standing in the units. Many of these trees would be 

expected to eventually die and blow down, providing potential lynx denning habitat and/or cover 

and foraging habitat for snowshoe hares (lynx primary prey). 

In addition, 57 acres of small (1/4 to 5 acre) patch cuts are proposed under Alternative 2, which 

would more drastically alter these small areas of lynx habitat, making them unsuitable in the 

short term and lynx winter foraging habitat in the long term. Under this proposal, no trees within 

100 feet on either side of intermittent or perennial streams would be harvested. These areas 

would continue to have dense standing trees and would eventually have an abundance of coarse 

woody debris and standing snags, with interspersed regeneration. These areas could be used as 

travel corridors for lynx at least until the understory throughout the analysis area grew tall and 

dense enough to provide hiding cover. 

Understory trees would be impacted by logging operations. It is estimated that up to 30% 

incidental damage to understory vegetation could occur, although project design criteria would 

be implemented to reduce this impact. Most “damaged” trees which are not killed would still be 

expected to fully retain their function as wildlife habitat. The “damage” would have more of an 

impact on their future timber value than on their habitat value. The remaining understory trees 



that are not killed by operations would be expected to experience a release (more rapid growth as 

a result of increased light, water, and nutrient availability). For a summary of regeneration 

currently present in each of the units, according to recent timber data collection, see Table 3.5-2 

in the Forest Management section. 

Areas not meeting Forest Plan regeneration standards (150 trees per acre) following harvest, 

would be replanted with Engelmann spruce. This would result in a variety of age classes of 

regeneration throughout the area, providing lynx winter foraging habitat (snowshoe hare habitat) 

both now and into the future. Replanted areas would be expected to regenerate more quickly 

than areas not meeting regeneration standards that are allowed to regenerate completely 

naturally. While lynx winter foraging habitat could be immediately degraded by the harvest 

activities, it would be expected to improve thereafter. There is suitable, more isolated habitat 

surrounding this analysis area that would not be harvested, providing sufficient denning and 

alternate winter foraging habitat adjacent to the analysis area. Harvest of the analysis area would 

contribute to a habitat mosaic across the landscape resulting from harvested areas interspersed 

with other areas where natural processes are the primary influence. This would be expected to 

have overall long-term beneficial effects to Canada lynx. 


The potential impacts of this alternative upon lynx and lynx habitat are similar (yet less than) 

impacts of Alternative 2 (see above). Under this alternative, the present closed road density 

would not increase at all, versus the 0.2 mile in Alternative 2. In addition, only 42 acres of small 

(1/4 to 5 acre) patch cuts are proposed which would alter these small areas of lynx habitat, 

making them unsuitable in the short term and lynx winter foraging habitat in the long term. 

Unit 1 and portions of Units 2 & 5 would not be harvested under this alternative, for watershed 

protection purposes. This unit would eventually have an abundance of coarse woody debris with 

interspersed regeneration, similar to land adjacent to the analysis area that is under a backcountry 

or wilderness management prescription having no harvest. Under this alternative, the potential 

effect of lynx disturbance, displacement and/or mortality as a result of logging operations in the 

unharvested areas would not exist. This could benefit lynx in the short-term since these areas 

(with their fairly dense network of streams and riparian vegetation) would not be disturbed. 

Understory and regeneration currently present in the area should remain mostly intact and 

eventually be released as the trees die and fall to the ground. These areas currently contain 

sufficient understory vegetation to provide lynx winter foraging habitat. Under this alternative, 

release of the understory in these areas would be gradual instead of immediate as it would be 

with large tree removal from logging operations, however, mortality of regeneration from timber 

harvest would not be a factor. 

Implementation of this alternative would meet Objectives, Standards, and Guidelines in the 

Southern Rockies Lynx Amendment (see further details under Alternative 2 above). 

DETERMINATION for ALTERNATIVES 1, 2 and 3: The alternatives would all 

result in a given amount of habitat conversion, whether from natural or human-induced 

processes. For this determination, the amount of acre conversion between alternatives is not so 



variable as to warrant a different determination between any of the alternatives. For all 

Alternatives, it is determined that alternative 1, 2, and 3 MAY AFFECT, but are NOT 

LIKELY TO ADVERSELY AFFECT lynx, or lynx habitat. 

Sensitive Species 

Table 3.8-3. Summary of Findings for Region 2 Terrestrial Sensitive Species. 

Species 

General Habitat 1 

No Action 

2 

Forest Condition 

INSECTS 

Great Basin 

silverspot butterfly 

AMPHIBIANS 

Boreal toad 

Bufo boreas boreas 

Northern leopard frog 

Rana pipiens 

BIRDS 

Bald eagle 

Haliaeetus 

leucocephalus 

Black swift 

Cypseloides niger 

Boreal owl 

Aegolius funereus 

Burrowing owl 

Athene cunicularia 

Ferruginous hawk 

Buteo regalis 

Spring fed and/or 

subirrigated wetlands 

at low (7500 feet or 

less) elevation; larval 

food plant Viola 

nephrophylla; wet 

meadows 

interspersed with 

willows and other 

woody wetland 

species; adult nectar 

sources mostly 

composites. 

Spruce/fir near water 

and alpine meadows. 

Riparian and wetland 

areas. 

Nests and roosts are 

usually found in 

open-branched trees 

near larger lakes, 

streams, rivers and 

reservoirs. 

Nests behind or next 

to waterfalls and wet 

cliffs. Forages over 

forests and open 

areas. 

Mature spruce/fir and 

mixed conifer 

forested areas with 

preference for wet 

situations (bogs or 

streams) for foraging 

Open grasslands 

associated with 

prairie dogs. Nests 

and roosts in burrows 

dug by mammals or 

other animals. 

Open grasslands and 

shrub steppe 

communities. Nests 

in tall trees or shrubs 

along streams or on 

steep slopes 

NI NI NI 

MI MI MI 

MI MI MI 

NI NI NI 

NI NI NI 

MI MI MI 

NI NI NI 

NI NI NI 

3 

Watershed 

Health and Forest 

Condition 




Species 


No Action 

2 


Flammulated owl 

Otus flamineolus 

Sage sparrow 

Amphispiza belli 

Brewer’s sparrow 

Spizella breweri 

Northern goshawk 

Accipter gentiles 

Lewis’s woodpecker 

Melanerpes lewis 

Loggerhead shrike 

Lanius ludovicianus 

Depend on cavities 

for nesting, open 

forests for foraging, 

brush for roosting. 

Occupy open 

ponderosa pine or 

forests with similar 

features (dry 

montane conifer or 

aspen, with dense 

saplings). 

Grasslands and open 

situations with 

scattered brush and 

riparian scrub; 

preferring to feed 

near woody cover; 

strongly associated 

with sagebrush for 

breeding. Positively 

correlated with big 

sagebrush, shrub 

cover, bare ground, 

above-average shrub 

height, and horizontal 

patchiness; 

negatively correlated 

with grass cover. 

Strongly associated 

with sagebrush in 

areas with scattered 

shrubs and short 

grass; to lesser 

extent in mountain 

mahogany, rabbit 

brush, and 

bunchgrass 

grasslands with 

shrubs or large 

openings in pinyon- 

juniper. 

Mature forest 

generalist. On the Rio 

Grande, often found 

in mixed 

conifer/aspen stands. 

Open pine forests, 

burnt over areas with 

snags and stumps, 

riparian and rural 

cottonwoods, and 

pinyon-juniper 

woodlands. 

Grassy pastures that 

are well grazed. 

Nests in shrubs or 

small trees, 

preferably thorny 

such as hawthorn. 

NI NI NI 

NI NI NI 

NI NI NI 

MI MI MI 

NI NI NI 

NI NI NI 

3 

Watershed 


Condition 




Species 


No Action 

2 


Olive-sided flycatcher 

Contopus cooperi 

Northern harrier 

Circus cyaneus 

American peregrine 

falcon 

Falco peregrinus 

anatum 

Yellow-billed cuckoo 

(FC) 

Coccyzus 

americanus 

American three-toed 

woodpecker 

Picoides tridactylus 

White-tailed 

ptarmigan 

Lagopus leucurus 

Mature spruce/fir or 

Douglas-fir forests 

with preference for 

natural clearings, 

bogs, stream and 

lake shores with 

water-killed trees, 

forest burns and 

logged areas with 

standing dead trees. 

Marshes, meadows, 

grasslands, and 

cultivated fields. 

Nests on the ground, 

commonly near low 

shrubs, in tall weeds 

or reeds, sometimes 

in bog; or on top of 

low bush above 

water, or on knoll of 

dry ground, or on 

higher shrubby 

ground near water, or 

on dry marsh 

vegetation. 

Cliff habitat over 200 

feet high with suitable 

ledges for nest 

construction. 

Open woodland, 

parks, deciduous 

riparian woodland; 

nests in tall 

cottonwood and 

willow riparian 

woodland. 

Spruce/fir forests 

primarily, dependant 

upon bark beetle 

populations and 

diseased trees. 

Responsive to 

recently burned 

areas. 

Alpine tundra, 

especially in rocky 

areas with sparse 

vegetation. Summer 

habitats include 

moist, low-growing 

alpine vegetation. 

Canopy cover of 

willow at winter 

feeding sites 

preferred. 

MI MI MI 

NI NI NI 

NI NI NI 

NI NI NI 

MI MI MI 

NI NI NI 

3 

Watershed 


Condition 




Species 


No Action 

2 


Gunnison sagegrouse 

Centrocercus 

minimus 

Mountain plover 

Charadrius montanus 

MAMMALS 

Wolverine 

Gulo gulo luscus 

American marten 

Martes americana 

Townsend’s bigeared 

bat 

Corynorhinus 

townsendii 

townsendii 

Fringed myotis 

Myotis thysanodes 

Gunnison’s prairie 

dog 

Cynomys gunnisoni 

Lek sites are 

characterized by low 

vegetation with 

sparse shrubs often 

surrounded by big 

sagebrush dominated 

plant communities 

below 9200' 

elevation. Brood 

rearing habitat is 

characterized by 

riparian vegetation of 

intermittent and 

perennial streams, 

springs, seeps and 

meadows within 

upland vegetation 

communities. 

High plains/short 

grass prairie habitats, 

often associated with 

prairie dog towns. 

Nesting areas 

characterized by very 

short vegetation with 

significant areas of 

bare ground 

Remote subalpine 

and spruce/fir 

forested areas. 

Overall, this species 

utilizes a wide range 

of habitat types as it 

is very mobile. 

Spruce/fir and mixed 

conifer forests with 

complex physical 

structure. 

Forages in semidesert 

shrublands, 

pinyon-juniper 

woodlands and open 

montane forests. 

Roosts in caves, 

mines and mature 

forests. 

Desert, grassland, 

and woodland 

habitats. Roosts in 

caves, mines, rock 

crevices, buildings, 

and other protected 

sites. 

High mountain 

valleys and plateaus 

at 1830-3660 m; 

open or slightly 

brushy country, 

scattered junipers 

and pines. Burrows 

usually on slopes or 

in hummocks. 

NI NI NI 

NI NI NI 

MI MI MI 

MI MI MI 

NI NI NI 

NI NI NI 

NI NI NI 

3 

Watershed 


Condition 




Species 


No Action 

2 


Rocky Mountain 

Bighorn Sheep 

Ovis canadensis 

New Mexico Meadow 

Jumping Mouse 

Zapus hudsonius 

luteus 

Open areas next to 

steep escape cover 

(low elevation to 

alpine). 

Primarily 

associated with 

tall grass and 

sedge 

component in 

riparian areas 

along perennial 

streams; upper 

elevation limit 

suspected to be 

about 9000 feet. 

NI NI NI 

NI NI NI 

3 

Watershed 


Condition 

The Biological Evaluation (BE) prepared for Terrestrial Sensitive species considered twenty nine 

species (Table 3.8-3). 

The BE determined that suitable habitat exists for eight within the Rio de los Pinos Analysis 

Area (boreal toad, northern leopard frog, boreal owl, northern goshawk, olive-sided flycatcher, 

American three-toed woodpecker, wolverine, and American marten) . A more detailed analysis 

of each species habitat needs is included in the Biological Evaluation. These eight species are 

further analyzed in each alternative for the Rio de los Pinos Vegetation Management project. 

Species having no suitable habitat within the analysis area are not analyzed in further detail. 

This project will have no impact on the Great Basin silverspot butterfly, bald eagle, black 

swift, burrowing owl, ferruginous hawk, flammulated owl, sage sparrow, Brewers sparrow, 

Lewis’ woodpecker, loggerhead shrike, northern harrier, American peregrine falcon, 

yellow-billed cuckoo, white-tailed ptarmigan, Gunnison sage grouse, mountain plover, 

Townsend’s big-eared bat, fringed myotis, Gunnison’s prairie dog, Rocky Mountain 

bighorn sheep, New Mexico meadow jumping mouse; or their habitat. 


Under this alternative, there are no potential direct impacts upon the eight sensitive species as no 

activity would occur which could result in direct mortality. Indirect impacts would be positive 

for some species and negative for others. The beetle-infested areas would slowly convert into 

more open habitat to the potential detriment of the amphibians, several of the avian species 

(boreal owl and three-toed woodpecker) and mammal species, however, these changes would be 

expected to occur very gradually, giving individuals sufficient time to adjust and/or disperse to 

more suitable habitat if needed. These same impacts could be beneficial to other species 

(goshawk and olive-sided flycatcher), that commonly utilize canopy openings. Through time, a 



patchy distribution of deadfall, dead standing and newly regenerating trees and shrubs would 

likely occur across the landscape. Some areas may continue to provide suitable habitat for those 

species requiring closed-canopy forested areas and may even improve in quality as more coarse 

woody debris becomes available and the understory vegetation is released. 

Under this alternative, the proposed changes would be expected to mimic beetle infested areas in 

the backcountry and wilderness areas adjacent to the analysis area, creating less of a habitat 

mosaic across the landscape than either of the action alternatives. 

Alternatives 2 and 3 - 

The effects of timber harvesting upon sensitive species and their habitat are similar for both 

action alternatives. The differences between the alternatives is more of a function of the number 

of acres involved with each alternative with fewer treated acres resulting in less potential for 

impacting sensitive species or their habitat than alternatives with more acres to be treated. To 

summarize, the overall potential impacts upon the eight species are addressed below. 

Sensitive Amphibians - There is a slight possibility that direct toad mortality could 

occur during harvest operations through crushing of individuals, eggs, or underground burrows 

by heavy equipment, although given the current scope of the project and lack of both current and 

historic boreal toad documentation in the Analysis Area, this likelihood is low. Leopard frogs are 

much more restricted to water than are boreal toads and as such are less impacted by the effects 

of timber harvest activity, particularly given the harvest restriction in riparian areas (project 

design criteria 2.5-5). 

Removal of a large amount of overstory would change site conditions on the ground 

and could impact boreal toad survival and reproduction by changing the microclimate in 

the understory. Harvest would result in a more open canopy. More openings could impact toad 

habitat by increasing the risk of predation and decreasing surface moisture. Woody debris are 

used by toads as shelter. Regardless of the alternative selected, boreal toads would be expected to 

have sufficient woody debris available for shelter, should they be present within the analysis 

area. 

Sensitive Avians - The proposed sales would result in fewer snags being available in the 

future for nesting and in less structure in the form of woody debris for avian species and their 

prey, particularly boreal owl’s main prey species - the red-backed vole. Removal of beetle 

infested trees could degrade habitat for boreal owls in the immediate project site and may make 

them more vulnerable to predation. However, the spatial distribution and concentration of trees 

remaining should continue to provide suitable habitat for this species within the analysis area. 

Protection measures for existing regeneration (see PDC 2.5-4), would protect some of the 

smaller trees 8” dbh and below, that are currently used by boreal owls for roosting. 

Harvested areas would fairly rapidly convert into more open habitat in the short term and this 

impact would be beneficial to several avian species (goshawk and olive-sided flycatcher). 

Through time, a patchy distribution of deadfall, dead standing and newly regenerating trees and 



shrubs would likely occur across the landscape. Some areas may continue to provide suitable 

habitat for those species requiring closed-canopy forested areas and may even improve in quality 

as more coarse woody debris becomes available and the understory vegetation is released. 

Logging activities could result in limited disturbance to avian species during project 

implementation. There is a chance that nesting birds may be disturbed or suffer direct mortality 

as the result of tree felling activities, but this potential is decreased by project design criteria for 

protection of active bird nests and soft snags. Habitat effectiveness may be impacted but overall 

the analysis area would continue to provide adequate habitat for many avian species. 

Sensitive Mammals - The proposed salvage sale is planned in areas with existing road systems 

in place. Approximately 3.3 miles of currently inactive roads would be re-opened for timber 

operations. Up to 0.2 miles of new, temporary roads will be constructed for timber operations 

which would not be expected to impact wolverines or martens substantially more than reopening 

existing roads. If there are wolverines in the area (although none are known to occur on 

the Rio Grande National Forest), they would be expected to move out of the area (possibly into 

adjacent wilderness or backcountry areas) during logging operations to avoid human activity and 

increased human presence. Open roads would not be expected to have a large impact on marten 

habiat use although individuals could be disturbed or temporarily displaced by timber operations. 

Under both action alternatives, sufficient woody debris will remain available on the forest floor 

for wolverine and marten prey species and for marten denning habitat. The spatial distribution 

and concentration of trees remaining would continue to provide suitable foraging habitat for 

these species within the area of influence and project site. Canopy closure would decrease 

substantially as trees are removed and remaining spruce trees die. This could degrade habitat for 

martens as they prefer areas with overhead cover, however, if the cover became too sparse, they 

would be expected to disperse to nearby areas having more overhead cover. According to 

project design, 38 to 60 trees per acre, 8” dbh and larger will be left standing in the analysis area 

following harvest, which will provide overhead cover. Areas that currently have substantial 

understory/regeneration, preferred by martens, would be expected to release following 

treatments, improving the overall structural quality of marten habitat in this area within 

approximately 15-25 years. 

Logging activities could result in limited disturbance to wolverines and martens if present 

during project implementation. Removal of these trees is not expected to impact 

movement of these species either within their home range or into other adjacent areas should 

they be present. 

Determination for All Sensitive Species for Alternative 1: This alternative allows natural 

processes to occur which may result in temporary conversion of habitat or even for habitat to 

become unsuitable for a period of time for some species. However, as natural processes create a 

mosaic on the land providing a variety of habitat types, it is determined that this Alternative May 

Impact Individuals of some species, but is not likely to cause a trend towards Federal 

listing or result in loss of viability in the planning area (the Forest) for the eight species 

evaluated. 

Determination for All Sensitive Species for Alternatives 2 and 3: The action alternatives 

would result in a given amount of habitat conversion depending upon harvest prescriptions. For 



this determination, the amount of acre conversion is not significant enough to warrant a different 

determination between the two action alternatives. Forest Plan standards and guidelines in 

addition to project design criteria would help reduce potential impacts to all sensitive species. It 

is determined that implementation of alternative 2 or 3 May Impact Individuals, but is not 

likely to cause a trend towards Federal listing or result in loss of viability in the planning 

area (the Forest) for the eight species evaluated. 


The TES cumulative effects analysis for the Rio de los Pinos Vegetation management Analysis is 

based on past, present and future Federal, Tribal, State, or private land activities that are 

reasonably certain to occur within the areas analyzed for TES species which includes the LAU 

for lynx and for all other species, the Rio de los Pinos Analysis Area. 

Rito Archuleta LAU - lynx 

This cumulative effects analysis is based on the Rito-Archuleta LAU, in order to cumulatively 

address effects of this project on lynx. Potential effects to lynx habitat on private lands within the 

LAU have already been accounted for, and the potential changes to lynx habitat on private lands 

already brought forward in the baseline conditions for the LAU (see biological assessment). 

There will be short-term disturbances from project activities to lynx should they be present 

during operations, but sufficient cover and connectivity should remain to provide adequate 

habitat to avoid project activities. Disturbance could add cumulatively to potential disturbance 

from recreation activities within the area, although for the most part, recreationists would likely 

avoid areas being actively harvested. 

Habitat conversions would result in reduced denning habitat, which would decrease the 

likelihood of lynx establishing denning sites within the units being salvaged. However, habitat 

within the LAU continues to meet SRLA objectives, standards, and guidelines, and areas 

adjacent to the salvage units (including backcountry and wilderness areas) would continue to 

provide secluded areas of higher quality habitat more likely to be used by lynx. Feeding, 

breeding, and sheltering requirements of lynx would continue to be adequately met within the 

LAU and larger-scale connectivity would be retained within and between LAUs. On a landscape 

level, harvest of this area, in addition to adjacent wilderness and backcountry areas, would 

provide a mosaic of habitat conditions in time and space, likely improving lynx habitat into the 

future. 

Past projects, including harvest activities associated with the County Line EIS, have already been 

accounted for and this project will be accounted for and reported to the US Fish and Wildlife 

Service. 

In combination with past, proposed, and foreseeable future projects within the LAU, all 

objectives, standards, and guidelines contained within the SRLA would be met with 

implementation of any of the alternatives. 



Rio de los Pinos Analysis Area – all other species 

A variable amount of disturbance and/or habitat conversion would occur within the Rio de los 

Pinos Analysis Area under each alternative, which would be beneficial for some Sensitive 

species and negative for others. Overall, the alternatives May Impact Individuals of some 

species, but are not likely to cause a trend towards Federal listing or result in loss of 

viability in the planning area (the Forest). The proposed project in addition to other past, 

present, or reasonably foreseeable activities within the analysis area would be expected to have 

minor cumulative impacts such as possible disturbance and/or displacement. However, these 

impacts are determined to be fairly minor. Implementation of project design criteria will help to 

alleviate some of these potential impacts. 

3.9 Wildlife 

Scope of the Analysis 

This section addresses non-TES wildlife and it has been categorized into two 

discussions as follows: 1) Management Indicator Species (MIS), and 2) migratory birds 

This section is a summary of more detailed analysis contained in separate reports as 

categorized above. Each report is part of the project administrative record. MIS are 

addressed at the Forest Level. Migratory birds are addressed within the Analysis Area. 

Potential influences on migratory birds were tiered to conservation objectives at the 

Forest-wide scale and the Southern Rockies Colorado Plateau Bird Conservation Region 

(BCR) 16 (additional information on BCR 16 is available online at: http://www.nabcius. 

org/bcrs.htmo). 


See section 3.8, TES Wildlife Species under the same heading since that description 

applies here as well. 


See section 3.8, TES Wildlife Species under the same heading since that description 

applies here as well. 

Management Indicator Species 

Table 3.9-1 is a summary of the Forest MIS species and the rationale for the detail in 

which they were analyzed for this project. Five MIS were evaluated in greater detail for this 

analysis: 1) Brown Creeper, 2) Hermit thrush 3) Elk, 4) Mule Deer and 5) Rio Grande 

Cutthroat Trout. Rio Grande cutthroat trout were analyzed as an MIS in the Fisheries Specialist 

report prepared for this project. 



Table 3.9-1 Summary of the MIS Evaluation. 

Habitats Rationale for Selection in 

MIS 

Represented 

Forest Plan 

Brown creeper Mature to late 

successional spruce/fir 

and mixed conifer 

(LTAs 1 1, 3, 13; 

Structure Class 

5) 2 

Species has a close association with 

structural elements that occur under 

older forest conditions, including large 

tree diameters and older snag 

component. May respond to certain 

threats, management, and conservation 

activities in spruce/fir forests (Colorado 

Bird Conservation Plan). Resident bird 

less affected by management activities 

outside of breeding range. 

Hermit thrush Mature to late 

Species primarily associated with 

successional spruce/fir spruce/fir and is commonly associated 

and mixed conifer with, but not restricted to, older forest 

(LTAs 1, 3, 13; 

structure. May respond to certain 

Structure Class 5) threats, management, and conservation 

activities in spruce/fir forests (Colorado 

Bird Conservation Plan). Tied to 

complex structural forest elements; may 

represent mature to late successional 

forest floor characteristics. Timber 

and/or fire management may affect 

quantity and/or quality of habitat, such 

as coarse woody debris. 

Elk Forest-wide (All LTAs) Special interest locally (i.e., economic 

and recreational value). May be 

competing with other native ungulates 

and livestock. Sensitive to roads and 

related disturbance. 

Mule deer Forest-wide (All LTAs) Special interest locally (economic and 

recreational value). Sensitive to roads 

and related disturbance. A habitat 

generalist but also associated with early 

successional stages for forage. 

Rio Grande cutthroat 

trout 

Riparian (LTA 10 -- 

Forest-wide aquatic) 

Management indicator of the health of 

montane aquatic ecosystems Most 

sensitive of the salmonid species to 

management activities that increase 

sediment, reduce stream cover, create 

barriers to movement, or impact stream 

flows or water quality. 

Rationale for 

Detailed 

Evaluation for the 

Analysis Area 

To assist in 

monitoring whether 

Forest Plan standards 

and guidelines for 

biodiversity are being 

met, with an 

emphasis on snag 

management. 

To assist in 



and guidelines for 

biodiversity are being 

met, with an 

emphasis on coarse 

woody debris. 

To assist in 



and guidelines are 

being met for 

wildlife, with an 

emphasis on 

providing cover to 

maintain screening 

along roads. 

To assist in 



and guidelines are 

being met for 

wildlife, with an 

emphasis on forest 

management issues 

that influence the 

early successional 

stages of plant 

communities. 

Will 

assist in monitoring 

whether Forest Plan 

standards and 

guidelines are being 

met, with an 

emphasis on how 

project activities are 

conducted within the 

water influence zone 

(WIZ) to maintain 

stream health. 

Chapter 3 – Affected Environment & Environmental Consequences Page 3-53 

Rationale for 

Dismissal 

From Detailed 

Analysis


Table 3.9-1 Summary of the MIS Evaluation. 

Habitats Rationale for Selection in 

MIS 

Represented 

Forest Plan 

Pygmy nuthatch Mature to late 

Cavity nester; timber and/or fire 

successional ponderosa management may affect quantity and/or 

pine (LTA 5; Structure quality of habitat, including snags; may 

Class 5) 

represent effects to other primary and 

secondary cavity nesters. 

Lincoln’s sparrow Riparian (LTA 10 -- Riparian species tied to different 

willow) 

structural elements susceptible to 

grazing and other activities within 

riparian areas; monitored as a group 

with Wilson’s warbler due to close 

habitat associations with willow 

communities at various elevations. 

Wilson’s warbler Riparian (LTA 10 -- Riparian species tied to different 

willow) 

structural elements susceptible to 

grazing and other activities within 

riparian areas; monitored as a group 

with Lincoln’s sparrow due to close 

habitat associations with willow 

communities at various elevations. 

Vesper sparrow Grasslands (LTAs 8, 9, Uses a narrow set of habitat conditions 

and 12) 

for nesting – sparsely or patchily 

distributed shrubs with abundant grass 

cover on the Forest; may be affected by 

grazing activities. Indicator of upland 

bunchgrass/shrub communities. 

1 

LTA = Landtype Association (defined in EIS, Appendix B and in the Forest Plan FEIS p. 3-41). 

2 

Structure Class (defined in EIS, Appendix C and in the Forest Plan FEIS p. 3-43). 

Rationale for 

Detailed 

Evaluation for the 

Analysis Area 

Chapter 3 – Affected Environment & Environmental Consequences Page 3-54 

Rationale for 

Dismissal 

From Detailed 

Analysis 

No habitat within 


Very limited habitat 

within Analysis Area. 

Habitat within Analysis 

Area would not be 

impacted by timber 

harvest so no effect. 

Very limited habitat 

within Analysis Area. 

Habitat within Analysis 

Area would not be 

impacted by timber 

harvest so no effect. 

Limited habitat within 

Analysis Area. Habitat 

within Analysis Area 

will not be impacted by 

timber harvest, so no 

effect. 

Table 3.9-2 is a summary of the effects of each alternative upon the MIS evaluated for the Rio de 

los Pinos project. Additional information for each species can be found in the Forest’s MIS 

Species Assessments (USDA Forest Service 2003).


Table 3.9-2. Summary of Effects to MIS, by Alternative. 

ALTERNATIVES 

1 

2 

No Action 

Forest Health 

Habitat / Population 

Information 

Brown Creeper A small percentage of 

Brown Creeper 

Approximately 0.1 percent of spruce 

Breeding Bird survey data spruce fir Forestwide will fir Forestwide will be more rapidly 

indicate a slow population be gradually impacted by impacted by salvage activities. 

increase continent-wide, beetles. Sufficient snags Disturbance could occur from human 

with a larger increase in should remain for brown activity associated with timber 

Colorado and surrounding creepers to nest and forage. harvest. Some nest destruction could 

states. Approximately Some mature green trees also occur with the removal of 

634,000 acres of habitat is will remain, however, timber. Sufficient snags should 

estimated Forestwide. some individuals may remain for brown creepers to nest 

disperse into healthier, and forage. Some mature green trees 

mature spruce-fir habitat. will remain, however, some 


individuals may disperse into 

effect on population healthier, mature spruce-fir habitat. 

persistence or viability No discernable 

at the Forest Level. effect on population 

persistence or viability at the 

Forest Level. 

3 

Forest and Watershed Health 

Less than 0.1 percent of spruce fir 

Forestwide will be more rapidly 

impacted by salvage activities. The 

portion not treated for watershed 

protection will be gradually impacted 

by beetles. Disturbance could occur 

from human activity associated with 

timber harvest. Some nest destruction 

could also occur with the removal of 

timber. Sufficient snags should remain 

for brown creepers to nest and forage. 

Some mature green trees will remain, 

however, some individuals may 

disperse into healthier, mature sprucefir 

habitat. No discernable effect on 

Population persistence or 

viability at the Forest Level. 




ALTERNATIVES 

1 

2 

No Action 

Forest Health 


Information 

Hermit Thrush 

A small percentage of 

Hermit Thrush 

Approximately 0.1 percent of spruce 

Breeding Bird survey spruce fir Forestwide will fir Forestwide will be impacted by 

data indicate a small be gradually impacted by timber harvest. Only 57 total acres of 

population increase beetles. Sufficient coarse small patch cuts would occur 

continent-wide, but a woody debris will remain throughout the analysis area, which 

possible decrease in for hermit thrush habitat. could negatively impact hermit 

Colorado and 

Some small, dense, green thrush although most timber 

surrounding states. trees will remain. 

treatment will be uneven-aged, to 

Approximately 634,000 However, some individuals which they are not as sensitive. 

acres of habitat is 

may disperse into 

Timber treatments may increase the 

estimated Forestwide. healthier, mature spruce-fir rate of understory release which 

habitat. No discernable could benefit hermit thrush. 

effect on population Sufficient coarse woody debris will 

persistence or viability remain for hermit thrush habitat. 

at the Forest Level. Some small, dense, green trees 

preferred by hermit thrush will 

remain. However, some individuals 

may disperse into healthier, mature 

spruce-fir habitat. No discernable 

effect on population 

persistence or viability at the 

Forest Level. 

Elk 

Elk - Population estimates Improvement in forage Would not result in any 

obtained from the 

would likely occur.In noticeable change in habitat 

Colorado Division of some areas, large 

conditions or population trend. 

Wildlife (CDOW) 

amounts of coarse 

Forage would improve following 

indicate that there are woody debris on the timber harvest. Open road 

approximately 6,500 elk forest floor could 

density would slightly increase 

within the Data Analysis decrease habitat 

for the duration of the timber 

Unit (DAU-32) that effectiveness for elk. sale, although these roads would 

encompasses this 

However, this 

not be open to the public so this 

Analysis Area, which alternative would not may temporarily displace elk, 

exceeds the current DAU result in substantial but only for short periods of 

objective of 5,000 

change in habitat 

time. Following harvest there 

(CDOW 2007). All conditions or 

would be a reduction in open 

vegetation types on the population trend. 

roads and one road along a 

Rio Grande National Forestwide, 

riparian area would be moved, 

Forest provide elk habitat. 

benefitting elk. 

3 


Less than 0.1 percent of spruce fir 

Forestwide will be impacted by timber 

harvest. The portion not treated for 

watershed protection will be gradually 

impacted by beetles. Only 44 total 

acres of small patch cuts would occur 

throughout the analysis area, which 

could negatively impact hermit thrush 

although most timber treatment will be 

uneven-aged, to which they are not as 

sensitive. Timber treatments may 

increase the rate of understory release 

which could benefit hermit thrush 

Sufficient coarse woody debris will 

remain for hermit thrush habitat. 

Some small, dense, green trees 

preferred by hermit thrush will remain. 

However, some individuals may 

disperse into healthier, mature sprucefir 

habitat. No discernable effect on 

population persistence or viability at 

the Forest Level. 

Would not result in any noticeable 

change in habitat conditions or 

population trend. Forage would 

improve following timber harvest. In 

some areas, large amounts of coarse 

woody debris could make it more 

difficult for elk to move around in the 

area, although timber harvest would 

decrease the amount of debris. Open 

road density would slightly increase 

for the duration of the timber sale 

although these roads would not be 

open to the public so this may 

temporarily displace elk, but only for 

short periods of time. . Following 

harvest there would be a reduction in 

open roads and one road along a 

riparian area would be moved, 

benefitting elk. 




ALTERNATIVES 

1 

2 

No Action 

Forest Health 


Information 

Mule Deer - This 

As large spruce trees 

Mule Deer 

As large spruce trees are 

Analysis area lies within die and lose foliage, removed, some understory plants 

DAU-35. The current some understory plants would begin to grow, attracting 

population objective for would begin to grow, mule deer. Similar to the elk, 

this unit is 8,500 and the attracting mule deer. deer may avoid areas having 

2005 post-hunt population Similar to the elk, deer large amounts of coarse woody 

estimate is 4,400. Based may avoid areas 

debris as they would not be able 

on the most recent having large amounts to move around easily, although 

CDOW POP II Model of coarse woody debris timber harvest would reduce the 

estimates (2006), annual as they would not be amount of coarse woody debris 

population numbers have able to move around as on the ground. Open road 

fluctuated but have easily. Overall, would density would be reduced 

generally been below the not result in any 

following project 

herd management 

noticeable change in implementation. Overall, a 

objective. All vegetation habitat conditions or slight improvement in habitat 

types on the Rio Grande population trend. 

expected, however, would not 

National Forest provide 

result in any noticeable change 

mule deer habitat. 

in habitat conditions or 

population trend. 

Rio Grande Cutthroat Trout (including proxies – rainbow, brown, and brook trout) 

Trout - Estimated No discernable 



miles of stream 

effect on 

effect on 

effect on 

inhabited Forestwide is population 

population 

population 

1,050 miles, and >1200 persistence or 



lake surface acres. viability at the 

viability at the 

viability at the 

Forest Level. 

Forest Level. 

Forest Level. 

Migratory Birds 

3 


As large spruce trees are removed, 

some understory plants would begin to 

grow, attracting mule deer. Similar to 

the elk, deer may avoid areas having 

large amounts of coarse woody debris 

as they would not be able to move 

around easily, although timber harvest 

would reduce the amount of coarse 

woody debris on the ground. Open 

road density would be reduced 

following project implementation. 

Overall, a slight improvement in 

habitat expected, however, would not 

result in any noticeable change in 

habitat conditions or population trend. 

Neotropical migratory landbirds (NTMB) are those that breed in the U.S. and winter south of the 

border in Mexico, Central and South America. Resident landbirds include those that remain 

during the winter period, or move to winter habitats that occur primarily within the U.S. border. 

Landbirds include many of our passerine songbirds, hawks, owls and woodpeckers, but do not 

include waterfowl, shorebirds, or colonial water birds such as coots and rails. Several landbird 

species may be experiencing population declines and have become an issue of international 

concern (Terborgh 1992, Finch and Stangel 1993). 

Direction concerning landbird conservation in Forest Service Region 2 is to reference the Birds 

of Conservation Concern (BCC) list produced by the U.S. Fish and Wildlife Service when 

completing NEPA evaluations for project activities. There are 37 BCRs in North America with 

four of these occurring at least partially in Colorado. The Rio Grande National Forest occurs 

within the Southern Rockies Colorado Plateau Bird Conservation Region (BCR 16), which 

encompasses portions of Colorado, New Mexico, Arizona, Utah and Wyoming. Information 

from BCR 16 was synthesized for use in Colorado through the development of the Birds of 

Conservation Concern list and the Colorado Landbird Conservation Plan (BCP). The BCPs have 

been or are being developed by every state in the nation based on the individual physiographic 



areas encompassed by the BCR’s. At the finest scale of analysis, the Rio Grande National Forest 

occurs within the Southern Rocky Mountains Physiographic Area (Area 62) of the Southern 

Rockies Colorado Plateau Bird Conservation Region. The following are the Birds of 

Conservation Concern for BCR 16 as updated in December 2008, their status within the project 

area, and projected influence from management activities proposed within the Rio de los Pinos 

Analysis Area EIS. 

Summary of Effects of Alternatives on Migratory Birds: 

A review of the migratory bird table indicates that five species on the Birds of Conservation 

Concern (BCC) List for BCR 16 are excluded from analysis because they do not occur or are 

considered accidental on the Rio Grande National Forest and will therefore not be affected by 

any management actions. These species include the veery, gray vireo, black rosy finch, Grace’s 

warbler, and chestnut collared longspur. Other species that would not be expected to occur or do 

not have habitat present in the area of influence for this project include the American bittern, 

bald eagle, ferruginous hawk, golden eagle, peregrine falcon, prairie falcon, Gunnison’s sage 

grouse, snowy plover, mountain plover, long-billed curlew, willow flycatcher, juniper titmouse, 

yellow billed cuckoo, flammulated owl, burrowing owl, Lewis’ woodpecker, pinyon jay, 

Bendire’s thrasher, Brewer’s sparrow, and grashopper sparrow. Species likely to occur within 

the Analysis Area include Cassin’s Finch (USFWS Birds of Conservation Concern for BCR 16). 

Project design criteria regarding snag retention and not harvesting trees with active bird nests 

would help to conserve this species. 

The following table lists Priority habitats and species from the Colorado Landbird Conservation 

Plan and potential impacts of this project on those species and habitats. 

Table 3.9-3 Priority habitats and species of the Southern Rocky Mountains province and 

their relationship to assessment for the Rio de los Pinos project. 

Table 3.9-3. Priorty habitats and species of the Southern Rockies 

Priority Habitat 

Type 

Alpine 

Tundra 

BCP Priority 

Species 

White-tailed 

ptarmigan 

American pipit 

Brown-capped 

rosy finch 

BCP Potential 

Issues(s) 

Fragile 

Habitats; 

Specialized 

Species 

Potential Influence 

from Project Activities 

Timber harvest 

would not occur 

in alpine tundra 

habitats. 

Effect of 

Alternatives 

White-tailed ptarmigan 

evaluated as R2 Sensitive 

Species. No effects anticipated 

as a result of this project. 





Type 

Aspen 

Cliff/Rock 

High 

Elevation 

Riparian 

BCP Priority 

Species 

Red-naped 

sapsucker 

Purple martin 

Violet-green 

swallow 

Peregrine 

falcon 

Black swift 

Cordilleran 

flycatcher 

American 

dipper 

MacGillivray’s 

warbler 

Wilson’s 

warbler 

BCP Potential 

Issues(s) 

Grazing, snag 

habitat, 

Altered 

disturbance 

regimes 

Rock climbing; 

mining 

Grazing, 

Recreation 

impacts 



No issues 


Minor aspen 

component in 


No issues 


Willow habitat 

will be protected 

from harvest 

activities. 

Harvest activities 

could result in 

temporary 

disturbance to 

individuals. 

Effect of 

Alternatives 

No negative, but potential 

positive impacts (regeneration) 

to aspen habitat as a result of 

this project. 

Peregrine falcon and black 

swift evaluated as R2 Sensitive 

species. Peregrine falcons or 

black swifts are not known to 

occur in Analysis Area. No 

effects anticpated on species or 

habitat. 

Wilson’s warbler evaluated as 

RGNF Management Indicator 

Species. Minimal to no 

impacts to habitat anticipated 

under any of the alternatives. 

Minor disturbance possible 

from nearby harvest activities. 





Type 

Spruce/Fir 

BCP Priority 

Species 

Boreal owl 

Olive-sided 

flycatcher 

Hammond’s 

flycatcher 

Wetlands Willet 

Short-eared 

owl 

BCP Potential 

Issues(s) 

Timber mgmt., 

snags, altered 

disturbance 

regimes 

Wetland loss, 

development 



Timber harvest 

or natural 

processes could 

eliminate snags 

and/or perches 

for Boreal owls 

and olive-sided 

flycatchers, 

respectively. 

No major issues 

or activities 


Effect of 

Alternatives 

Boreal owl and olive-sided 

flycatcher evaluated as R2 

Sensitive species. Potential for 

temporary, minor disturbance 

of individuals of all 3 species. 

Sufficient snags for nesting 

habitat expected to remain 

available under all alternatives. 

Cover for prey species will be 

sparse in some areas until 

understory vegetation is 

released following harvest. 

Sufficient perches for olivesided 

flycatchers would remain 

under all alternatives. These 

habitat features would be 

expected to improve over time 

for both species. Hammond’s 

flycatcher habitat would be 

degraded under all alternatives, 

as they prefer mature and oldgrowth 

forests. Natural and 

management processes change 

this area to be less favorable 

for use by this species. If this 

is the case, individuals would 

be expected to utilize nearby, 

more suitable habitat. Harvest 

of some trees with active nests 

could occur, causing mortality 

to individuals and/or eggs. 

This could have impacts to 

Hammond’s flycatcher within 

the analysis area. However, 

project design criteria includes 

not harvesting trees with active 

nests which has the potential to 

reduce occurrence of this type 

of mortality. 

No effects anticiapted. No 

habitat present. 



Selection of any of the alternatives would be expected to have similar direct or indirect impacts 

to any migratory birds within the area of influence. Under all alternatives, mature spruce trees 

and the habitat that they currently provide would be removed from the area. Under alternative 1, 

all of the trees would be allowed to follow a natural progression and would be present in the area 

for a longer amount of time (likely 10 to 50 years, with most falling in 20-40 years (Tooley, 

personal communication 2010), similar to processes that will occur in adjacent infested 

backcountry and/or wilderness areas. Under alternatives 2 and 3, some spruce trees would be 

left standing (approximately 38-60 trees per acre 8” dbh and above, plus virtually all fir tress, 

plus virtually all spruce trees below 8” dbh), however, most beetle infested trees 8”dbh and 

above would be salvaged, removing them from the area within approximately the next 5 years. 

This project alone is not expected to impact populations of migratory birds. However, 

cumulatively, the spruce beetle infestation could have impacts to local bird populations (with 

some populations increasing and some decreasing). These potential population fluctuations are 

more impacted by the actual beetle infestation than by associated harvest activities. Therefore, 

for this project in addition to other projects within the area of influence, actual harvest activities 

would be expected to have small cumulative impacts on local bird populations. 


Cumulatively, implementation of this project in addition to other activities within the analysis 

area would have minor incremental effects on migratory birds (i.e. increased cumulative chance 

for disturbance or displacement), Forest MIS, federally listed or proposed species, R2 sensitive 

species, and general fish and wildlife species or their habitats. Minor cumulative effects may 

impact individuals but would not likely contribute to a loss of species viability of any animal 

species that occurs on the Forest. 

3.10 Fisheries Resources 


This analysis focuses on the fishery resources that are affected by the proposed timber harvest, 

and activities associated with the harvest, in the Rio de Los Pinos Analysis Area. 


Past activities that have influenced the fishery resources within the analysis area include timber 

harvest, road construction and maintenance, recreation, livestock grazing, reservoir construction 

(Trujillo Meadows), angling, and nonnative trout stockings. 


Nonnative trout are well established throughout the Rio de Los Pinos watershed upstream of 

Trujillo Meadows Reservoir to a large waterfall near the wilderness boundary. The waterfall 



separates nonnative fish from a core population of Rio Grande cutthroat trout (RGCT). Trujillo 

Meadows Reservoir supports a recreational fishery that is maintained by annual nonnative trout 

stockings. In 2008, 14,000 rainbow trout were stocked in the reservoir. Fish stocked in the 

reservoir can freely migrate upstream to the waterfall barrier. Other trout species that have been 

stocked in the reservoir and are now found in the Rio de Los Pinos and associated perennial 

tributaries includes brown trout, brook trout, Snake River cutthroat trout, and a small number of 

Rio Grande cutthroat trout. Rio Grande cutthroat trout stocked into the reservoir in 1999 and 

2003 are considered a recreational fishery with no special angling regulations or restrictions. 

Only two RGCT were collected in reservoir surveys conducted in 2005 and therefore the RGCT 

population is not considered self-sustaining. Brown trout were the dominate fish species 

collected in the survey followed by brook trout and rainbow trout. Rainbow trout are now the 

dominate fish species found in the reservoir because of the large numbers stocked by Colorado 

Division of Wildlife. Introduced populations of brook trout are well established in the Rio de 

Los Pinos and the associated perennial tributaries. 

Most streams within the analysis area are stable E and A/B channel types with relatively silt free 

substrate. Riparian areas are generally healthy with stable banks and good canopy cover. Fine 

sediment deposition is occurring near some road/trail crossings, along some steeper slopes where 

vegetation is sparse, and along some short unstable Rio de Los Pinos stream bank sections 

upstream of Trujillo Meadows Reservoir. 


Direct and Indirect Effects for All Action Alternatives: 

Timber harvest may have negative consequences on trout habitat if harvest results in changes in 

stream flows, increases in sedimentation, and changes in flow and temperature regimes. Timber 

harvest and other silvicultural practices can impact the quantity, quality, and timing of runoff. 

Influences may also include alterations to riparian communities, loss of instream and riparian 

cover, loss of stream complexity, stream fragmentation, stream bank damage, and loss of large 

woody debris recruitment. Roads are often associated with timber harvest, and can affect 

streams and fish habitats by directly accelerating erosion and sediment loading, altering channel 

morphology, creating movement barriers, and changing the runoff characteristics of watersheds. 

Effects of fine sediment and damaged banks are generally considered to be detrimental to aquatic 

life, including fish. Fine sediment can suffocate trout eggs and trap emerging trout fry, reducing 

reproductive success. Fine sediment can also reduce primary productivity and invertebrate 

abundance, which reduces trout food availability in a stream. Damaged banks can diminish trout 

cover, shade (important for moderating stream temperatures), and habitat for terrestrial insects 

(an important food source for trout). Riparian areas and stream habitats are sensitive to 

management activities, and accumulate disturbances that occur not only within this relatively 

narrow band of habitat, but throughout the entire watershed including activities in the upland 

areas. These effects can reduce spawning, rearing, foraging and over-winter habitat by 

increasing flows leading to bank instability and increased sedimentation resulting in loss of pool 

habitat and sediment filled substrates in spawing areas. 



Road work is included in all the action alternatives and some surface disturbances would occur 

during pre-haul road maintenance, during old road reconstruction and during construction of new 

temporary road. The short-term impacts during these activities would be offset by correction of 

drainage concerns that would benefit the area for the long-term. 

Effects from livestock grazing, road construction and previous timber sales in the general area 

have recovered well and there are no significant impacts noted. Some riparian zones within the 

analysis area do receive recreational use such as hiking, camping, vehicle use, and fishing. 

These activities can lead to loss of riparian vegetation and increased sedimentation resulting 

from this use, especially camping and vehicle use within riparian areas, and can result in 

degraded fish habitat. 

Increased sediment into streams from timber harvest and associated activities, as well as the 

large scale loss of trees due to beetle activity, can impact instream fish habitat as well as provide 

suitable habitat for fish disease and disease vectors such as whirling disease. Colorado Division 

of Wildlife has implemented an extensive outreach program informing anglers about aquatic 

nuisance species and diseases which is aimed at reducing the spread of the species/diseases by 

outdoor users. Currently, whirling disease is not known from any of the streams within the 

analysis area. Stocking of trout within the watershed can impact the existing fishery if diseases 

are introduced and also have an impact on the native fish if nonnative fish are stocked. 

Currently, most streams and riparian areas within the project area are in good to robust 

conditions and any fish habitat concerns within the analysis area tend to be site specific and not 

an overall threat to the fish populations throughout the drainage, although some segments of the 

populations may not be at full potential due to habitat limitations. With any timber harvest 

operation there is a chance of impacting streams, but with full compliance with Forest Plan 

standards and guidelines, project design criteria, and Watershed Conservation Practices 

Handbook impacts from timber harvest to the stream systems are expected to be minimal. Some 

population segments may be impacted for short periods of time due to possible increases in 

runoff and siltation but the impacts would not be expected to result in loss of viability of trout in 

the project area. 


Under the No Action alternative, natural processes would be allowed to occur without additional 

human intervention. No salvage of beetle infested or killed timber would occur, new trees would 

not be planted, and system roads would be maintained through normal maintenance schedules. 

Current activities such as livestock grazing and dispersed recreation would continue. 

No new surface disturbances would occur in any watersheds. Watersheds, stream channels, and 

riparian areas would be left in their existing condition. No pre-haul maintenance or road 

reconstruction would occur and no roads would be put to long-term rest under this alternative. 

Road density would remain unchanged from the current condition and road drainage concerns 

would be left until they can be dealt with through normal maintenance operations. 

With no management action it is likely that the scope and intensity of spruce beetle activity 



would continue. Units that currently have large beetle outbreaks would continue to experience 

extensive tree mortality, most likely until the mature spruce component is almost entirely lost. 

Loss of live basal area due to spruce beetles has already occurred to varying degrees within the 

analysis watersheds, with some units experencing over 50% mortality. The loss of live basal 

area could lead to increases in annual water yield and late season stream flows, as well as 

changes in peak stream flows. See Section 3.6 Watershed and Aquatic Resources in the EIS for 

detailed discussion regarding beetle epidemics and potential effects to watershed hydrology. 

The potential effects to stream habitat by the loss of live basal area could be mitigated by 

increased growth in understory vegetation and well established riparian vegetation; as well as 

provide a source for woody debris and large woody structure which is important for many 

aquatic species including trout and macroinvertebrates. On the other hand, high stand-level 

mortality rates can lead to increased runoff and higher flows which can increase streambank 

instablity and rates of soil erosion. Increased sediment loading in the streams could lead to loss 

of spawning and overwintering pool habitat which could be detrimental to trout and aquatic 

insects which are important as a food source. 

The No Action alternative could potentially affect the trout population due to the extensive tree 

mortality rates within the analysis area and the possible corresponding increase in erosion and 

stream sediment loads. 


In this alternative, approximately 13.1 MMBF would be harvested from 878 acres by salvage 

logging dead and dying Engelmann spruce. This would be accomplished with ground-based 

(tractor) logging methods. No green, uninfected spruce trees would be harvested and no green or 

dead subalpine fir would be harvested. Exceptions to this are those trees that must be removed 

from skid trails, landings, or for safety reasons, and scenic patch cuts. 

Following removal of the dead or dying spruce, the Forest Service would plant Engelmann 

spruce seedlings on those areas where post-sale reforestation surveys indicate that stocking is 

below the minimum standard of 150 trees per acre. 

This alternative would cause more surface disturbance than Alternative 1 or Alternative 3 due to 

the increased size in harvest area and harvest volume; and corresponding increase in ground 

disturbance associated with skid trails, roads, and heavy equipment operation. Currently, most 

streams and riparian areas within the project area are in good to robust conditions and any fish 

habitat concerns within the analysis area tend to be site specific and not an overall threat to the 

fish populations throughout the Rio de Los Pinos drainage. All surface disturbances would be 

adequately buffered to prevent direct impacts to the water influence zone and riparian areas. 

New surface disturbances from skid trails and landings would be limited to acceptable levels 

established in the Forest Plan. 

Road work is included in this action alternative and some surface disturbances would occur 

during pre-haul road maintenance, road reconstruction, road closure and rehabilitation, and 

during construction of a short temporary road. The short-term impacts during these activities 



would be offset by correction of drainage concerns that would benefit the area for the long-term. 

This alternative provides an opportunity to correct road drainage concerns by disconnecting 

runoff from streams and/or direct runoff through buffer or filter strips. Also, artificial 

reforestation will allow watershed recovery from harvest to occur more quickly, thereby 

reducing the amount of time harvested areas would be susceptible to erosion. 

With any timber harvest operation there is a chance of impacting streams, but with full 

compliance with standards and guidelines found in the Forest Plan and Watershed Conservation 

Practices Handbook, and additional protection from specific project design criteria, impacts to 

the streams and associated trout populations are expected to be minimal. Some individual trout 

may be impacted for short periods of time due to possible increases in runoff and siltation, but 

the impacts are not expected to result in loss of wide-scale aquatic habitat in the area or the 

viability of the existing trout populations. The correction of existing drainage concerns and 

reforestation will help reduce the affects on the stream habitat. 


In this alternative, approximately 607 acres and up to 9.9 MMBF would be harvested. This 

alternative would cause less surface disturbance than Alternative 2 because less area would be 

accessed with equipment due to some areas being dropped from harvest consideration. Impacts 

to stream health resulting from surface disturbances are not expected, or would be minimal, as 

long as S & G’s and the project design criteria are adhered to. Some individual trout may be 

impacted for short periods of time due to possible increases in runoff and siltation, but the 

impacts are not expected to result in loss of wide-scale aquatic habitat in the area or the viability 

of the existing trout populations. 

The main difference between this alternative and Alternative 2 is that Unit 1 and portions of 

Units 2 and 5 would not be entered for timber harvest. The influence of this alternative on the 

trout population would be similar to Alternative 2, but any potential impacts from timber harvest 

would expect to be less due to the decrease in total disturbance area. 


Effects from livestock grazing, road construction and previous timber sales in the general area 

have recovered well and there are no significant impacts noted. Some riparian zones within the 

analysis area do receive recreational use such as hiking, camping, vehicle use, and fishing. 

These activities can lead to loss of riparian vegetation and increased sedimentation resulting 

from this use, especially camping and vehicle use within riparian areas, and can result in 

degraded fish habitat. 

Increased sediment into streams from timber harvest and associated activities, can impact 

instream fish habitat as well as provide suitable habitat for fish disease and disease vectors such 

as whirling disease. Colorado Division of Wildlife has implemented an extensive outreach 

program informing anglers about aquatic nuisance species and diseases which is aimed at 

reducing the spread of the species/diseases by outdoor users. Currently, whirling disease is not 



known from any of the streams within the analysis area. Stocking of trout within the watershed 

can impact the existing fishery if diseases are introduced and also have an impact on the native 

fish if nonnative fish are stocked. 

At this time, the presence of nonnative trout has the largest impact on native trout across the 

Forest. If RGCT were present within the analysis area, nonnative salmonids would pose a 

serious threat to their continued existence. RGCT readily hybridize with other spring spawners, 

including rainbow trout and nonnative subspecies of cutthroat trout, resulting in a loss of their 

genetic integrity and unique phenotypic characteristics. RGCT are also subject to competition 

and possibly predation by sympatric populations of brook trout and brown trout. 

For all alternatives, the direct, indirect, and cumulative effects to aquatic populations from timber 

harvest, and harvest related activities, would be minimal as long as S & G’s and the project 

design criteria are adhered to. Individuals may be impacted for short periods of time due to 

increased runoff and siltation but the impacts would not be expected to result in loss of viability 

of aquatic species in the project area. 

3.11 Scenic Resources 

It is often difficult to distinguish between natural landscapes and those resulting from historic 

cultural alterations. In the last 50 years, The Rio de Los Pinos Project Area has been influenced 

culturally by grazing, management practices, timber harvest, and most recently high recreation 

use. Recently the Scenic Management Principles have been modified to describe landscapes as a 

dynamic system that changes over time. Unfortunately, ecological time and human timeframes 

are different and dramatic catastrophic events on the landscape are likely to create a mixture of 

negative and positive responses from our visitors. Although some of our visitors are aware of the 

essential need for natural processes on landscapes such as fire, wind throw, and insects and 

disease, a majority of visitors view landscapes as stationary and are attached to the characteristic 

landscape they have grown accustomed to seeing and experiencing. 

The scenic attractiveness of a landscape, which is characterized by particular landforms, 

vegetative patterns, water characteristics, cultural features, and overall appearance of the 

landscape, may change either temporarily or permanently by insects, disease, fire, floods, or 

tornados. A catastrophic event of these types would generally not affect the Scenic Objectives 

for the landscape, however, it would change the character of the landscape itself; giving it a new 

appearance. 

In any case, forest insects and disease in this project area can be considered epidemic due to 

sheer numbers of infected trees. Because of this, the landscape could change from a forested 

canopy to a non-forested opening temporarily (based upon the next 100 years of ecological 

time), or it may slowly regenerate as a forested community over the long term. It is difficult to 

predict the long term results of this event. 


The analysis area for scenic resources is defined by the proposed management treatments 

(Alternatives 2 and 3). 



The Scenic view-shed is contained within the Rio de Los Pinos Drainage. It is characterized by 

slopes of spruce and fir with rock outcrop and wet meadows. The timber is a contiguous dark 

stand within a fairly enclosed landscape and gentle ridgelines above timberline. 


Constituents who visit a landscape only attach to the temporal characteristics of how a landscape 

is seen today. However, Scenic Resources recognizes the dynamic nature of landscapes and 

categorizes the change from a forested to a non-forested landscape as a natural event (regardless 

if this event has been influenced by man over time). Management activities in conjunction with 

large scale events have the potential to effect scenic resources in both positive and negative 

ways. 

Catastrophic events such as insects and disease could cause the characteristic landscape to 

become more or less diverse. As this landscape begins to change vegetation type, there may be a 

possibility that a new mixture of species and an increase in diversity will raise the Scenic 

Attractiveness to a “Class A-Distinctive” from a “Class B-Typical”. An example of increased 

diversity or a “Class A-Distinctive” landscape might include open patches and more diverse 

species (such as aspen, mixed conifer), creating visually interesting patterns on the landscape. 

It is also possible that this event may cause the landscape to stay at a “Typical” or “Class B” 

diversity, if the landscape returns to its current condition, containing a monotonous cover of one 

or two species of trees or an open meadow landscape with very little visual diversity except for 

more patterns on the landscape caused by new openings. 

There are many scenic possibilities for a landscape unaided by timber management. There is a 

distinct possibility that a landscape could maintain a forested appearance as bug hit trees begin to 

die and a new age of trees grows beneath them. Or, there is a possibility that it could be 

converted into a grassland area devoid of trees. 

The Rio de Los Pinos drainage area currently looks “Natural Appearing” with a fairly contiguous 

dark stand of timber that is dark green with many trees turning reddish gray. The surrounding 

area (specifically the County Line Project Area) is currently being harvested. However, during 

harvesting activities in 2007, a large wind event blew down most of the trees that were identified 

to remain in stands for Scenic Resources. Trees marked to remain around the Continental Divide 

Trail in Unit 1 have blown over. This wind event affected the spruce component and the north 

end of the Unit 1 in the Wolf Beetle Timber Sale, however, the fir trees are still standing and 

provide canopy along the Continental Divide Trail in the south end of the unit. In addition to the 

trees that blew over in the northern portion of Unit 1, the adjacent private property owners have 

harvested most of the timber on the top of the ridge west of the Continental Divide. In addition, 

the private land below the Cross Country Ski Yurt in the County Line Analysis Area had 

previous harvesting activities that resemble a second step of a shelterwood timber harvest. This 

harvesting resulted in a trespass on Forest Service Lands and was replanted in the last decade. 

This area now has an open canopy as viewed from FSR 118.1E and from the Cross Country Ski 

Yurt. 



The blow-down and the private land harvesting activities have caused a dramatic change in 

appearance for the County Line Viewshed. The private land harvesting and the harvesting of the 

Wolf Beetle Timber Sale, has changed the characteristic landscape from a densely covered 

canopy to an open landscape between Units 1, 2 and 3. 

There are some openings within the landscape that are small in scale, most are not evident for 

any critical viewing angles and do not dominate the viewshed. In addition, there are some small 

rock outcroppings, but again, they do not dominate the characteristic landscape. 


Currently there are large numbers of trees and a dense canopy of trees on the landscape. The Rio 

de Los Pinos Area has a dense canopy cover with the exception of the private land harvesting 

activities and the County Line timber sale harvesting activities to the south. Most of the area 

falls into a “Natural Appearing” landscape with dense heavy canopy, with existing dead or dying 

trees. It is expected for some areas that there will be sufficient understory to maintain texture on 

the landscape as trees begin to fall over, however, there are some small areas where the 

understory does not exist. Portions of the harvesting units are hidden from view along the main 

access road into the Rio de Los Pinos Area. 

The roads are not evident on the ground from any viewing angle currently, however as the 

canopy begins to change it can be expected that some roads (including old skid trails and closed 

roads) may become more evident. Major recreation destinations, some popular dispersed 

recreations sites, and trails that provide enclosures, openings, and a specific “sense of place” or 

feeling based upon the vegetation may change dramatically as the tree canopy disappears. 

The current Scenic Integrity Objective for this area would be “High”. Any activities in response 

to large catastrophic events would meet the next lowest minimum objective of “Moderate”. The 

Forest Plan standards takes into consideration occurrences of catastrophic events as stated in 

Standard 1: 

“Standard 1. 

The Scenic Integrity Level (s), based on current landscape character, are usually 

accepted as the Scenic Integrity Objectives (s) unless highly unusual or special circumstances 

identify a need to change, and will be limited to: 

*Harvest as a result of disturbance such as fire, wind-throw, or insect and disease 

infestations. 

Variations in the Scenic Integrity Objectives may dominate the valued landscape character, but 

must borrow from the valued attributes such as size, shape, edge effect, and pattern of natural 

openings, and still meet the minimum requirements of the next lower Objective chosen.” 

These variations are discussed further in Alternative 2 and 3. 

The Existing Scenic Integrity or degree to which this landscape has been altered, is classified in 

a category of Type I, II, and III (Type I representing the most natural appearing and Type III 

representing the most altered landscape). Although the private land can have an impact to this 

category, it is not classified like Forest System Lands would be. However, the drastic change in 



character on private land can be softened or mitigated by employing harvesting techniques that 

would allow for a scenic transition from critical viewing angles on or from Forest Service Lands. 

The changed condition as a result of the blow-down on Wolf Beetle Timber Sale was not 

anticipated, therefore, additional planning was considered when identifying the numbers of trees 

to remain on the Rio de Los Pinos Units. For scenic resources, all the units were simulated for 

maintaining texture and color on the landscape using various numbers of trees per acre. 

The numbers of trees to remain on the Rio de Los Pinos Units was determined to meet the Scenic 

Integrity Objectives for the Viewshed of both County Line and Rio de Los Pinos Units. This 

was achieved by leaving 38 trees per acre in Unit 5 of Rio de Los Pinos and tapering back to 60 

trees per acre in the northern-most unit (Unit 1 of Rio de Los Pinos) 



Alternative 1 will not affect the Scenic Resource Objectives on the landscape. Insects and 

Disease are seen as a catastrophic event that only changes the forested canopy to non-forested 

landscape. If the no action alternative is chosen, viewers can expect to see a change in the 

characteristic landscape (from a forested backdrop to a landscape of downed logs, standing dead 

trees, and an understory of spruce and fir trees). The landscape will slowly move from a dark 

green consistent canopy of trees to a canopy of red to grey and has a majority of standing dead 

stems. In addition, there is a potential for this area to convert to a meadow if tree mortality is 

extremely high,-leaving no trees for a seed source. 

There is potential “Rehabilitation” for areas along the current County Line Timber Sale 

harvesting and blow-down area. Rehabilitation helps provide a more natural transition between 

the landscape that has been altered to one that still maintains a natural (or characteristic) look. 

However, the “no action” alternative would not allow for Scenic Rehabilitation in the project 

area 

Under Alternative 1, there will be minimal short-term effects to the Scenic Resources, however, 

it is expected that there will be a long term effect as this area moves from a dense, forested 

canopy to a non-forested, open canopy. It is expected that there will be a change to the diversity 

of vegetation on the landscape. This can include a more diverse landscape or a less diverse 

landscape. It is projected to change the overall appearance of the landscape from one of a 

continuous canopy to one that represents large openings with scattered patches of trees. For a 

long period of time (up to 50 years) there may be the presence of standing dead trees, trees on the 

ground and new grasses as the ground plane begins to open up. Visitors will see beneath the 

canopy of trees as it opens up and they may be able to see some features of the landscape that 

were previously screened. It is expected that viewers may see up to 160 standing dead trees per 

acre on all units (Units 1-5) as these are the areas hardest hit by Spruce Beetle. There is, on 

average, 1507 seedling trees per acre that will help provide texture on the ground, in the 

understory as the larger trees die and fall. No new permanent roads would be constructed under 

this alternative. 



Even though forest insects and diseases are seen as a catastrophic event that only changes the 

landscape character, constituents may be concerned that this landscape has changed so 

dramatically within a short time period. This may cause a mixture of negative and positive 

responses from forest visitors. It is expected that the strongest concerns will come from visitors 

using FDR 118.1A, the Continental Divide Trail, and dispersed recreation areas along heavily 

traveled or “Sensitivity Level 1 Roads and Trails”. It is also expected that constituents will have 

concern over the amount of human caused disturbances on the landscape as a result of insects 

and disease. It is expected that there will be strong opinions on both sides of this issue. 

Cumulative Effects – Alternative 1 

There is a potential for more roads and trails to be seen on the landscape as the canopy opens up 

which can negatively affect the scenic resources. However, there is also the potential that as the 

landscape begins to open, there will be additional scenic diversity as new openings are formed 

and others close in. This scenario can happen in as little as a few hours (if a wind event blows 

through the stand) or several decades as trees begin to die off and fall. Many dead trees can 

remain standing on the landscape for decades before falling over. 


This alternative was designed to harvest trees in a visually sensitive manner while creating 

openings that mimic the characteristic landscape throughout the Project Area. This Alternative 

projects harvesting all 5 Units proposed. 

This Alternative attempts to meet the next lowest Scenic Integrity Objective of “Moderate” 

through management techniques of harvesting in patches as well as salvage prescriptions. The 

harvesting techniques take into consideration the whole Rio de Los Pinos Viewshed and were 

designed to mimic current characteristic openings (either natural meadows or rock outcroppings). 

The placement of these openings within the landscape allows access to the stands and minimizes 

the amount of visual impacts. In addition, this Alternative attempts to mimic natural processes 

on the landscape with an attempt to blend harvesting activities into the characteristic landscape. 

This increases the possibility that harvesting activities remain less evident on the overall 

viewshed. 

This area is highly visible from the Continental Divide National Scenic Trail, Forest Road 118, 

and general forested lands surrounding the project area. Timber harvesting has taken into 

consideration the next lowest Scenic Integrity Objective of “Moderate” on the landscape, to 

allow harvesting activities to take place. For Units #5 the design criteria of the harvesting 

activity leaves 38-40 standing live or dead trees 8” and above per acre to meet the current Forest 

Plan standards and guidelines. This also allows for texture and color on the landscape while the 

landscape transitions from the previous harvesting and the blow-down in the County Line Area 

to the contiguous stands of timber in the Rio de Los Pinos Area. It also allows for understory 

trees to remain (with the exception of trees less than 8” or fir trees that will be removed to access 

larger diameter standing dead trees). As harvesting activities move north from Unit #5 to Units 

#4 and #3 the trees per acre are increased to 48-50 trees per acre (of standing live and dead trees 

8” and above) with small openings that mimic characteristic landscape conditions. As harvesting 



moves into Units #2 and #1 there will be approximately 58-60 trees per acre and Unit #1 will 

begin to transition back into the contiguous stand of spruce evident outside the project boundary. 

Visitors will still see evidence of harvesting activities, but to a lesser extent in Unit #1 than in 

Unit #5. 

Figure 3.11-1 

Photo showing the expected visual outcome with 38 trees/snags per acre in the south and 60 in 

the north. 

(Kelly Ortiz, Visual Nature Studio 2) 

Harvesting activities are expected to affect the Scenic Resources minimally, as most of the 

topography for this area is variable enough to allow the landscape to absorb harvesting activities 

without those activities dominating the landscape. In some areas along FSR 118 harvesting will 

be noticeable. However, these areas are not expected to dominate the landscape. 

Road construction and skid trail layout may affect the scenic resources of the area, as the 

overstory begins to disappear and more ground disturbance is evident. 


It is expected that loss of trees may additionally expose old disturbances from closed roads or 

may open viewsheds not yet known into previously harvested areas. This has the potential to 

expose to the visitor more harvesting activities than they may see if the standing trees were alive, 



however some degree of exposure would be expected under the no action alternative, due to 

falling dead trees across the landscape. This includes areas along the Continental Divide 

National Scenic Trail. 


This alternative was designed to harvest trees in a visually sensitive manner while creating 

openings that mimic the characteristic landscape throughout the Project Area. In addition, there 

will be an attempt to slow the rate of insects and disease on the remaining canopy in the northern 

units. This Alternative harvests only Unit #2 through Unit #5. 

This Alternative will attempt to meet the next lowest Scenic Integrity Objective of “Moderate” 

through management techniques of harvesting in patches as well as salvage prescriptions. The 

harvesting techniques take into consideration the whole Rio de Los Pinos Viewshed and were 

designed to mimic current characteristic openings (either natural meadows or rock outcroppings). 

The placement of these openings within the landscape allows access to the stands and minimizes 

the amount of visual impacts. In addition, this Alternative attempts to mimic natural processes 

on the landscape to blend harvesting activities into the characteristic landscape. This increases 

the possibility that harvesting activities remain less evident on the overall viewshed. Because 

Unit #1 would not be harvested, it is expected that this Alternative will have slightly less impacts 

to the Scenic Resources. 

This area is highly visible from the Continental Divide National Scenic Trail, Forest Road 118, 

and general forested lands surrounding the project area. 

Timber harvesting has taken into consideration the next lowest Scenic Integrity Objective of 

“Moderate” on the landscape, to allow harvesting activities to take place. For Unit #5 the design 

criteria of the harvesting activity leaves 38-40 standing dead trees 8” and above per acre to meet 

the current Forest Plan standards and guidelines. This allows for texture and color on the 

landscape while the landscape transitions from the previous harvesting and the blowdown in the 

County Line Area to the contiguous stands of timber in the Rio de Los Pinos Area. This allows 

for understory trees to remain (with the exception of trees less than 8” or fir trees that will be 

removed to access larger diameter standing dead trees). As harvesting activities move north 

from Unit #5 to Units #4 and #3 the trees per acre are increased to 48-50 trees per acre (of 

standing live and dead trees 8” and above with small openings that mimic characteristic 

landscape conditions. Unit #2 with 48-50 leave trees per acre, will provide a transition back into 

the contiguous stand of spruce evident outside the project boundary. 

Visitors will still see evidence of harvesting activities, but to a lesser extent in Unit #2 than in 

Unit #5. 


As in Alternative 2, it is expected that loss of trees may additionally expose old disturbances 

from closed roads or may open viewsheds not yet known into previously harvested areas. This 

has the potential to expose to the visitor more harvesting activities than they may see if the 

standing trees were alive. This includes areas along the Continental Divide National Scenic 

Trail. 



3.12 Late-successional Forests 


This analysis discusses older forests (termed late-successional forests), including old growth (as 

defined by Mehl 1992). The analysis area for this particular discussion is defined by two 

seventh-level watersheds (i.e., 13010005050101 and 13010005050102) encompassing the 

project boundary. 


There have been previous activities within the project boundary. See section 3.5 Timber 

Management/Silviculture (Chapter 3) under the same heading for more information. 


The Structure Class for forested cover types provides a sense for how heavily forested (canopy 

coverage) and how large the trees (diameter at breast height) are in the analysis area. Structure 

class can also be used to give an approximation for how much late-successional forest exists. 

The majority of the forested portion of the analysis area is dominated by Structure class 5, which 

is late-successional forest. Table 3.12-1 shows a summary of the Structure classes by the 

dominant forested cover type – spruce/fir (Picea engelmannii / Abies bifolia [syn. A. lasiocarpa]) 

for the two seventh-level watersheds. 

Table 3.12-1. Structure Class (percent) by dominant forested cover type in the 


Cover 

Structure Class 

Type 

1 2 3 4 5 Total 

spruce/fir 0.0% 3.6% 2.0% 6.4% 88.1% 100% 

The majority of the analysis area is dominated by late-successional forest, based on the best 

available resource data (from the Forest’s R2Veg database). Presently, there is a large spruce 

beetle (Dendroctonus rufipennis) outbreak in the area that may lead to relatively high tree 

mortality. The existing condition is rapidly changing and difficult to accurately predict. 

Consequently, the proportion of late-successional forest displayed in Table 3.12-1 may actually 

be considerably lower once the insect outbreak subsides. 

An evaluation of old growth was done for the analysis area following an inventory protocol 

developed by Erhard et al. 1998. The protocol provides a screen to determine if suspected old 

growth is present by comparing the Mehl (1992) old growth attributes to the Forest's stand exam 

data. Field verification was conducted on all sites that were both suspected old growth and 

proposed for treatment under one of the action Alternatives. None of the proposed harvest sites 

under any action Alternative is old growth and ties to an analysis completed for the Final 



Environmental Impact Statement for the County Line Vegetation Management Project (USDA 

Forest Service 2005). 



The no action alternative would not harvest the forest stands. The existing vegetation structure 

would continue to evolve under the influences of predominantly natural processes over time. 

The proportion of late-successional forest and old growth would normally be expected to 

gradually increase over time. However, this may be offset to an unknown degree if spruce beetle 

mortality continues or accelerates within the analysis area. Our experience with the nearby 

County Line Vegetation Management Project was that the spruce beetle will result in 

considerable spruce tree mortality. Thus, the No Action alternative may actually result in 

reductions of late-successional forest somewhat similar to the action alternatives. There would 

also be a shift in dominance from Engelmann spruce (a longer-lived species) to subalpine fir (a 

shorter-lived species) due to high spruce mortality. 


Approximately 10.7% of the analysis area would be affected by treatment. The effect of timber 

harvest on Structure Class is shown in Table 3.12-2. Treatment would affect the spruce/fir cover 

type. There would be a reduction in Structure Class 5 with a corresponding increase in the other 

Structure Classes. The analysis area would still be dominated by Structure Class 5 to the degree 

that it has not been already fatally impacted by spruce beetles. Harvesting would thin these 

stands, creating a more open-canopy plant community. There would be no direct impact on old 

growth, since none is proposed for harvest in the analysis area. Structure class 5 in the analysis 

area would continue to evolve and be shaped by predominantly natural processes under this 

Alternative. 

Table 3.12-2. Structure Class (percent) for spruce/fir cover type post 

treatment in the Analysis Area. 

Alternative Structure Class 

1 2 3 4 5 Total 

1 – No Action 0.0% 3.6% 2.0% 6.4% 88.1% 100% 

2 1.2% 3.6% 12.3% 12.6% 70.3% 100% 

3 0.9% 3.6% 8.9% 10.8% 75.8% 100% 

The cumulative impact of this Alternative would be a small increase in the harvested acres 

within the analysis area over time. There would be a small temporary reduction in latesuccessional 

forest. However, the salvage action itself would not create a cover type conversion 

or create a permanent land-use allocation change on the landscape. Late-successional forest is 



relatively abundant in this analysis area. Harvesting spruce within this analysis area would not 

appreciably change this relationship. 


Approximately 7.4% of the analysis area would be affected by treatment. The effect of timber 

harvest on Structure Class is shown in Table 3.12-2. Treatment would affect the spruce/fir cover 

type. There would be a reduction in Structure Class 5 with a corresponding increase in the other 

Structure Classes. The analysis area would still be dominated by Structure Class 5 to the degree 

that it has not already been fatally impacted by spruce beetles. Harvesting would thin these 

stands, creating a more open-canopy plant community. There would be no direct impact on old 

growth, since none is proposed for harvest in the analysis area. Structure class 5 in the analysis 

area would continue to evolve and be shaped by predominantly natural processes under this 

Alternative. 


The cumulative impact of this Alternative would be a small increase in the harvested acres 

within the analysis area over time. There would be a small temporary reduction in latesuccessional 

forest. However, the salvage action itself would not create a cover type conversion 

or create a permanent land-use allocation change on the landscape. Late-successional forest is 

relatively abundant in this analysis area. Harvesting spruce within this analysis area would not 

appreciably change this relationship. 

3.13 Threatened, Endangered, and Sensitive (TES) Plant Species 


This analysis discusses plants that are Threatened, Endangered, Proposed, or Forest Service 

designated Sensitive. The analysis area for this discussion is defined by the areas proposed for 

management treatment under Alternatives 2 and 3. 


There have been previous activities in this Analysis Area. See Chapter 3, section 3.5 Forest 

Management/Silviculture under the same heading for more information. 


There are presently no reported records or suspected occurrences of Threatened or Endangered 

plants on this Forest. Threatened and Endangered plants in Colorado have unique habitats or 

ranges that do not occur on this Forest. There are also no plants Proposed for listing by the US 

Fish and Wildlife Service that occur on the Rio Grande National Forest. Therefore, no further 

effects analysis is conducted below. 



None of the areas proposed for management treatment contain documented Sensitive plant 

species. There are eight Sensitive plants suspected to occur in the areas proposed for treatment 

based on habitat affinity (see Table 3.13-1). 


The analysis below is a summary from a Biological Assessment / Biological Evaluation (BA/BE) 

for plants that was prepared specifically for this project and is part of the project administrative 

record. None of the Alternatives would be expected to result in significant direct, indirect, or 

cumulative effects. 


This Alternative proposes no new management actions. There are no current or foreseeable 

future actions that would be expected to impact Sensitive plants. Therefore, there would be no 

Table 3.13-1. Sensitive plant species suspected in the treatment areas and the effects 

determination by Alternative. 

Determination 

Scientific name 

1 

Alternative 

1 2 and 3 

Botrychium furcatum NI MAII 

Draba smithii NI MAII 

Eriophorum altaicum var. neogaeum NI NI 

Eriophorum chamissonis NI NI 

Eriophorum gracile NI NI 

Machaeranthera coloradoensis NI MAII 

Salix arizonica NI NI 

Sphagnum angustifolium NI NI 

1 NI = No Impact; 

MAII = May adversely impact individuals, but not likely to result in a loss of viability on the 

Planning Area, nor cause a trend to federal listing or a loss of species viability rangewide. 

direct, indirect, or cumulative effect anticipated on any Sensitive plant species (Table 3.13-1). 

Alternatives 2, 3 and Cumulative Effects 

Since all action Alternatives propose some level of timber harvest and minor road work, the 

effects are considered equivalent for this analysis since they affect the same habitat (i.e., there is 

no real distinction of effects between Alternatives for this particular Analysis Area). Proposed 

actions would not impact any documented Sensitive plant populations. Potential habitat exists 

for eight Sensitive plants in the proposed treatment areas. Table 3.13-1 summarizes the effects 

determination made, by Alternative, for these species. 

Five species were judged to be at such low risk from the proposed actions that there would be no 

direct, indirect, or cumulative effect (Table 3.13-1). 



Three species (assuming potential habitat is occupied) were judged to be directly, indirectly, or 

cumulatively affected (Table 3.13-1). Direct effects could be from equipment crushing 

individual plants. Indirect effects could arise from changes in nearby canopy cover of associated 

vegetation due to direct effects. However, the effects of this are unknown. Cumulative effects 

would be a small, incremental increase in ground disturbance on potential Sensitive plant habitat 

affecting Federal lands. However, much of the Analysis Area proposed for treatment has had 

past timber harvest activities. Cumulative effects tied to other past, present, and foreseeable 

activities in the Analysis Area would be expected to be negligible. Cumulatively, there would be 

a very small aggregate increase in land disturbance on potential plant habitat over time from the 

action Alternatives. However, implementing any action Alternative would likely have a minimal 

impact on these plant species by following project design criteria (Chapter 2) along with Forest 

Plan standards and guidelines pertinent to ground-disturbing activities. Overall, cumulative 

effects would be expected to be negligible. 

3.14 Rangeland Management 


This analysis focuses on the effects to rangeland and rangeland management from the proposed 

management of timber stands within the Analysis Area. This analysis encompasses effects to 

rangeland and rangeland management within the Trujillo Meadows Pasture of the Cumbres C&H 

grazing allotment. 


Past permitted livestock grazing has been somewhat limited within the analysis area. Permitted 

livestock grazing has been limited to natural parks, meadows and previously harvested timber 

areas. Domestic livestock grazing has been occurring in the area of the Cumbres Allotment since 

the late 1800’s. 

Recreational livestock have had the greatest impacts to the vegetation around Spruce Parks due 

to these animals being restrained and/or allowed to graze in the small riparian area located next 

to a large dispersed camp site. This area is used heavily by recreationists during the summer and 

fall and generally includes recreational livestock (horses/mules) due to its proximity to the 

Continental Divide National Scenic Trail and other Forest System Trails. 


As has been in the past, current livestock grazing within the analysis area is limited to natural 

parks, meadows and previously harvested timber areas. The analysis area lies within the Trujillo 

Meadows Pasture of the Cumbres C&H Allotment. Within the analysis area, there are 241 acres 

mapped as suitable rangeland (from the Forest Plan Suitability analysis) for cattle. Of these 241 

acres, 173 acres are mapped as Transitory rangeland and 68 acres are mapped as Primary 

rangeland. 

Access to the project area for livestock is primarily along the existing road system. 



In accordance with the Cumbres EA and Annual Operating Instructions (AOI’s), cattle are in the 

Trujillo Meadows Pasture for about 22 days during the grazing season. There are 2230 cow/calf 

pairs that are permitted to graze within the Trujillo Meadows Pasture. Approximately 125 to 350 

cow/calf pairs will frequent the analysis area during the approximate 22 days each grazing 

season. 

Spruce Park is still a popular area for recreational livestock (horses/mules) use. 



Under Alternative 1, the forested areas heavily impacted by spruce beetle would likely serve as 

transitory range for several years until the trees begin to fall and livestock can no longer access 

the area. If a severe wildfire were to occur in the areas heavily impacted by spruce beetle, a type 

conversion to a grassland similar to the spruce-fir forest burned in the Osier fire would be a 

likely outcome. This would result in an increase in primary or secondary range in the Trujillo 

Meadows pasture. If a severe wildfire does not occur in the areas heavily impacted by spruce 

beetle, access and use by permitted livestock would be limited due to fallen trees creating a 

barrier for livestock movement. 


As timber is harvested, it may open areas to livestock grazing that were not available before. 

This may occur when the reduced canopy allows space and light for increased grass and forb 

production, and/or the area is no longer a barrier to livestock movement, because of road 

construction and reduction of timber as a barrier. Increases in forage availability due to timber 

harvest will not be cause for increasing livestock term permit numbers. Thus the forage is 

temporary (transitory rangeland), in that these sites will eventually return to timber-dominated 

stands (USDA Forest Service LRMP-FEIS 1996). Even though the newly created transitory 

rangeland is temporary in nature, it becomes a desirable permitted livestock grazing area for 

many reasons. For instance, in times of drought, these types of areas are less impacted by 

drought and continually provide lush forage due to the protection from the sun and wind. These 

areas usually have a generous supply of water in the form of creeks, ponds, springs and seeps, 

which provides for rich plant growth as well as providing water for livestock. These areas also 

provide increased forage within the pasture that allows for decreased use in other areas of the 

pasture, such as high recreation areas or riparian areas. The effects from the transitory rangeland 

can carry on for many years, as the herbaceous vegetation and increased access will gradually 

fade with forest succession. 

There would be an indirect effect to rangeland management within the Rio de Los Pinos 

Analysis Area due to the need to manage permitted livestock to prevent damage to forest 

regeneration. Project design criteria (Chapter 2, 2.5-2) outlines the management tools that will 

be implemented to protect forest regeneration if damage is occurring from permitted livestock. 




The same direct and indirect effects as Alternative 2 would apply. By not harvesting timber in 

the wet areas, substantial increases in herbaceous vegetation growth and increased access to 

permitted livestock would not occur in those sites. It may be beneficial to not create an attractant 

or access for permitted livestock in these wet areas for ease of rangeland management in the 

monitoring and management of the livestock. 


There would be no cumulative effects to rangeland or rangeland management within the Rio de 

Los Pinos Analysis Area. 


There would be no irreversible or irretrievable commitment of resources if the proposed action is 

implemented. 

3.15 Transportation 


This section addresses the travel ways that could be used to assess, monitor, and haul timber 

from the Analysis Area. The type of work required for each road and the costs associated with 

the required work are displayed for the action alternatives. The direct and indirect effects of the 

road system on the various Forest resources are addressed in the individual resource sections of 

this document. 

The transportation network that would be required to accomplish the objectives of the action 

alternatives has been carefully analyzed and planned using aerial photography interpretation, 

map analysis, and field reconnaissance. The main goals in preparing the transportation plan were 

to minimize construction disturbance and to control impacts to the environment while safely and 

efficiently accomplishing the goals of the proposed action. 


The transportation system into the Rio de Los Pinos Analysis Area was constructed to allow 

access for recreation, range management, timber harvest, and fire suppression. Forest System 

Road (FSR) 118 and FSR 118.1C provide vehicle access into the Analysis Area road network 

from State Highway 17. Roads were constructed into the mid-portion of the drainage to 

construct the Trujillo Meadows dam in 1956. The Analysis Area road network was added later 

for timber, grazing, and recreation access. The original FSR 118 accessed the Trujillo Meadows 

dam and continued in a north-west trend up the Rio de Los Pinos drainage to the present-day trail 

head location that is used to access the South San Juan Wilderness. This road was originally 

used for logging access. The upper part of Forest System Road 118 was later accessed by a 



different route and the road number for the upper part of the road was changed to match the new 

road. The mid-portion of the road has been decommissioned because of it's proximity to the 

stream. The trail head is now located on FSR 118.2 which is accessed off of FSR 118.1C. 

Forest Service sponsored timber sales in this area began in the late 1950s and the local road 

system was constructed to accommodate those sales in the 1960-70s. Many of these roads were 

not classified (i.e. included in the Forest road system) and so have not received recurrent 

maintenance and are grown over with vegetation. 


The Analysis Area is accessed by a system of Forest roads from State Highway (SH) 17 between 

Antonito, Colorado and Chama, New Mexico. Public vehicle access terminates within or beyond 

the area at a closed gate at the end of FSR 118.1C. It also terminates at the unimproved trailhead 

of non-motorized Forest System Trail (FST) 736, and at a physical road closure on FSR 118.1D. 

The main travel destinations within the Analysis Area are the trailhead and the closed gate. The 

logging roads beyond this closed gate are used by some individuals for indirect non-motorized 

access to FST 813, the Continental Divide National Scenic Trail. 

Forest System Roads 118 and 118.1C are maintained to allow use by passenger cars. Other 

authorized roads in the Analysis Area are maintained for high clearance vehicles. Natural road 

closure measures are in place in several locations to control access to many of the timber roads 

that are unauthorized for motor vehicle travel. Non-motorized uses are accepted on roads with 

travel restrictions. Several miles of old unclassified roads were constructed in the past to 

facilitate timber harvest. These road templates are now grown in with vegetation and are crossed 

with down timber. One or more of these old roads may be reconstructed to a minimal standard 

to permit passage by logging equipment and log trucks. When harvest activities are complete, 

decommissioning will occur to bring the unclassified roads back into resource production. 

Several areas located along some Forest System Roads are contributing to erosion and 

sedimentation concerns. As part of all action alternatives, prior to harvesting, culverts or other 

cross drains will be installed on roads to disconnect road drainage from streams and divert it into 

buffer strips. 

The existing local road system within the analysis area is generally well located and adequate to 

serve the majority of the proposed project needs. 

Table 3.15-1. Roads Information Table 

ROAD 

NUMBER 

MAINT- 

ENANCE 

LEVEL 

LENGTH 

In 

MILES 

CURRENT STATUS COMMENTS 

118 3 1.8 OPEN MAINTAIN 1.75 MILES 

118.1A 1 1.8 DECOMMISSIONED NO USE 

118.1C 3 3.2 OPEN SPOT RECONSTRUCTION 

118.1H 1 0.5 CLOSED NO USE / LEAVE CLOSED 

118.1J 1 0.4 CLOSED RECONSTRUCT / LEAVE CLOSED 

118.1K 1 0.2 CLOSED RECONSTRUCT / LEAVE CLOSED 



Table 3.15-1. Roads Information Table 

ROAD 

NUMBER 

MAINT- 

ENANCE 

LEVEL 

LENGTH 

In 

MILES 

CURRENT STATUS COMMENTS 

2 2.8 

OPEN 

SPOT RECONSTRUCT 2.4 MILE 

118.2 

/ CONVERT 0.8 MILE TO 

TRAIL/DECOMMISSION 0.4 MILE 

118.2A 2 / 1 0.2 / 0.4 OPEN /CLOSED NO USE / LEAVE CLOSED 

118.2B 1 0.4 DECOMMISSIONED NO USE 

118.2C 1 0.1 DECOMMISSIONED NO USE 

118.2D 

2 / 1 0.9 

0.3 

OPEN / 

DECOMMISSIONED 

RECONSTRUCT 1.0 MILE & 

LEAVE CLOSED O.2 MILE 

118.2E 1 0.9 CLOSED 

RECONSTRUCT 0.75 MILE / 

LEAVE CLOSED 

118.2F 1 1.4 CLOSED RECONSTRUCT / LEAVE CLOSED 

118.2G 1 0.7 CLOSED RECONSTRUCT / LEAVE OPENED 



The No Action alternative would require no new disturbance and would result in no change to 

the existing transportation network. 

Several areas along existing roads would continue to contribute to erosion concerns and sediment 

deposition into streams and would be repaired only when this work becomes a priority and when 

funding is available. 


Most of the treatment areas are accessible using the existing transportation system but minor 

road reconstruction and the use of some old unclassified roads would be required for access, to 

improve safety, and to provide for additional resource protection. Two-tenths of a mile of 

temporary road construction would also be needed. Pre-haul maintenance would occur on 

approximately 1.75 miles of FSR 118. Road reconstruction, with concurrent maintenance, would 

be carried out on approximately 10 miles of Forest road. Reconstruction would include some 

culvert replacements, grade dip installation, and road surface reconditioning over a number of 

sections of road. Spot gravel applications may be added to problematic native-material road base 

to harden road surfaces. Fill and surfacing material for this work would be obtained from the 

existing gravel pit at the intersection of FSR 118 & FSR 116, or from outside weed-free sources 

as necessary. These efforts would reduce erosion, and the resultant sedimentation, from these 

road sections. A portion of FSR 118.2 (0.8 miles) would be decommissioned and converted to 

FST 736 once harvest activities are completed and the trail head would be relocated. An 

additional 0.4 mile of FSR 118.2 would also be decommissioned, with long-term road access 

routed along FSR 118.2G. These actions will move road use away from the river and greatly 

improve road drainage. They will also reduce road reconstruction disturbance and cost. All 



classified roads that are currently unauthorized (closed to public motor vehicle travel) would 

remain so following treatment activities, excepting the road reroute just described. These roads 

that are used for harvest activities would receive treatments to stabilize and/or rehabilitate them 

through decommissioning and seeding. The necessary road work for Alternative 2 is detailed in 

Table 3.15-2 below. 

Table 3.15-2 Road Network Needed For Access in Alternative 2. 

Length in 

Road Number 

Miles 

Work Required 

Estimated 

Cost 

Remarks 

118 1.8 Maintenance $2,500 

118.1A 1.8 None No Use / Leave Closed 

118.1C 3.2 


Maintenance 

$15,000 Culvert Replacement 

118.1H 0.5 None No Use / Leave Closed 

118.1J 0.4 


Maintenance 

$13,200 Stream Crossing Installation 

118.1K 0.2 


Maintenance 

$12,600 Stream Crossing Installation 

118.2 2.4 


Maintenance 

$18,000 

Culvert Replacement, 

Reconditioning, and 

Spot Gravel 


118.2B 0.4 None No Use / Leave Closed 

118.2C 0.1 None No Use / Leave Closed 

118.2D 1.0 


Maintenance 

$14,000 

Culvert Installation and Spot 

Gravel 

118.2E 0.75 


Maintenance 

$2,400 Grade Dip Installation 

118.2F 1.4 


Maintenance 


118.2G 0.7 


Maintenance 

$6,400 

Culvert and Grade Dip 

Installation 


Similar types of road work would be necessary to efficiently access timber stands to be harvested 

as found in Alternative 2. The number of roads and the total miles of road needed to implement 

this alternative are less, and no new temporary road construction would be required. The road 

work needed for Alternative 3 is detailed in Table 3.15-3 below. 


Length in 

Road Number 

Miles 

Work Required 

Estimated 

Cost 

Remarks 

118 1.8 Maintenance $2,500 


118.1C 3.2 


Maintenance 

$15,000 Culvert Replacement 

118.1H 0.5 None No Use / Leave Closed 




Length in 

Road Number 

Miles 

Work Required 

Estimated 

Cost 

Remarks 

118.1J 0.4 None Stream Crossing Installation 

118.1K 0.2 None Stream Crossing Installation 

118.2 1.6 


Maintenance 

$18,000 

Culvert Replacement, 

Reconditioning, and 

Spot Gravel 


118.2B 0.4 None No Use / Leave Closed 

118.2C 0.1 None No Use / Leave Closed 

118.2D 1.0 


Maintenance 

$14,000 

Culvert Installation and Spot 

Gravel 

118.2E 0.75 


Maintenance 


118.2F 0.8 


Maintenance 


118.2G 0.7 


Maintenance 

$6,400 

Culvert and Grade Dip 

Installation 


The cumulative effects of implementing the action alternatives are that the existing system road 

network would receive measurable improvement, with 0.8 miles of classified road being 

converted to a trail following the harvest, 0.4 miles of classified road being decommissioned, and 

travel being rerouted to FSR 118.2G. A beneficial impact will be a reduction in the amount of 

on-going erosion and sediment input into streams and a 1/2 mile net reduction of open road 

density within the Analysis Area. Changing segments of FSR 118.2 & FSR 118.2G to 

Maintenance Level 3 would increase long-term maintenance costs on 1.7 miles, but would 

further reduce sediment input into streams. 

3.16 Recreation Travel Management 


The Rio de los Pinos Analysis Area boundary. 


Past activities that affect the existing conditions include livestock grazing, timber harvest, road 

construction, and various forms of dispersed recreation, all within the Rios de los Pinos Analysis 

Area boundary. 




Dispersed Recreation 

A diverse array of dispersed recreation opportunities occur within the analysis area. These 

opportunities include but are not limited to: driving for pleasure, sight-seeing, hiking, hunting, 

fishing, horseback riding, picnicking, firewood gathering, snow shoeing and cross-country 

skiing to a system of yurts, use of all-terrain-vehicles (ATV) on roads, and snowmobiling. 

Resource Opportunity Spectrum (ROS) Settings 

Managed recreation setting for MAP 5.13 is modified roaded. Modified roaded can be described 

as partially modified by road or trails, but does not overpower the natural setting, as highways 

are over ½ mile away. Sights and sounds of humans or their impacts are common, but solitude 

can be found in the area. Facilities are harmonious with the natural setting. 

System Trails/Trailheads/Visitor Use 

Forest system trail, number 736, is located just north of the analysis area, with the access road to 

this trailhead located within the analysis area. Project design criteria would be employed to 

minimize the effects to trail users if Alternatives 2 or 3 are selected. 

Outfitters and Guides 

There is one outfitter who is permitted to use the area, Southwest Nordic Center (SNC). SNC 

has a total of four yurts, one would be affected by winter logging as the access to the yurt is 

along the haul route. Project design criteria are being employed to minimize affects to these 

recreationists. 

Travel Management 

Forest travel regulations restrict motorized travel to designated roads and trails. Trail number 

736 is closed to motorized uses. All of the gated roads are also closed to motorized uses. 

Roads are the only routes open to motorized uses within the analysis area. Additionally, Forest 

regulations allow vehicles to leave roads for a distance of 300 feet to access a suitable campsite 

or for gathering fuelwood, as long as no damage is caused to lands, streams, or other resources. 

Also, game retrieval is allowed within MAP 5.13 during the big game hunting seasons. Game 

retrieval is allowed in the afternoons and only low tire pressure ATV’s under 48 inches in width 

are permitted. 



This alternative could have some impacts to recreationists if the widespread effect of dead trees 

scattered on the ground impedes access and users ability to move around within the area, and the 

safety aspects of many standing dead trees preclude the use of the area. Cross-country skiers 

may not be able to access areas until the snow is deep enough for the same reasons. 

In the long-run, this alternative will not reduce conflicts between motorized and non-motorized 

use below current-day levels because the trailhead for Forest System Trail 736 will not be 



located closer to Forest System Road 118.1C, and a portion of Forest System Road 118.2 along 

the Rio de los Pinos will remain open to motorized use and in poor condition. There would be 

no opportunity under this alternative to decommission any System roads that are no longer 

needed due to location, resource issues or other factors. 


This alternative would have temporary effects to recreation users, especially during the active 

timber sales with heavy truck traffic on the roads leading into the sale areas. There would also 

be somewhat less opportunity for fuel wood gathering than the current situation (only the current 

open roadways get fuel wood traffic). The Outfitter permit with the yurts would be impacted by 

winter logging. Project design criteria would allow logging up until December 15. The project 

design criteria would also include designated trailhead parking areas within the analysis area 

during the life of the timber sale contract. The designated sites are to ensure the public safety. 

This alternative also would result in increasing the length of trail 736, by decreasing the length of 

road 118.2; the amount of change is 0.8 mile. This would be a benefit to non-motorized 

recreation users. This road-to-trail conversion and trailhead relocation would take place 

following the timber sales. Following the harvest, the area would be more open, but the 

recreation use is not expected to change. 

The recreation/travel management project design criteria are feasible because they would be 

incorporated into the timber sale contracts to protect recreation improvements, warn visitors of 

hazards, and minimize impacts to forest users during periods of heaviest use. The project design 

criteria have been used on other timber sales on the Forest and should be an effective means of 

minimizing negative impacts to forest users. 

Currently there is a trail reroute going through the analysis area. A portion of the Continental 

Divide National Scenic Trail (CDNST) is closed just west of the analysis area, from Cumbres 

Pass to just south of the South San Juan Wilderness, due to hazardous conditions. Visitors are 

rerouted onto trail 736, then onto Forest System Road 118.2 to Forest System Road 118.1C, and 

finally to Forest System Road 118 which take them to the CDNST trailhead, traveling south from 

the South San Juan Wilderness. It is anticipated that the conditions that warranted the trail 

closure and reroute will be resolved prior to the implementation of this decision. However, if 

this does not occur and the section of the CDNST is still closed, a determination will be made at 

that time as to a safe route that the public should use if planning to travel through the area for the 

CDNST trail. 

Effects of Alternative 2 on the South San Juan Wilderness Area and backcountry experiences of 

National Forest users focuses on noise from timber harvesting operations. Visual impacts have 

been in section 3.11. The backcountry area to the west of the analysis area would be seperated 

from noise and visual impacts by a major ridgeline, hence there would be minimal or no effects 

to visuals or noise from that area. The South San Juan Wilderness Area sits north of the analysis 

area and users may hear noise from trucks and/or logging equipment during operations, 

depending on wind and other environmental factors. 




This alternative would have temporary effects to recreation users, especially during the active 

timber sales with heavy truck traffic on the roads leading into the sale areas. There would also 

be somewhat less opportunities for fuel wood gathering than the current situation (only the 

current open roadways get fuel wood traffic). The Outfitter permit with the yurts would be 

impacted by winter logging. Project design criteria would allow logging up until December 15. 

The project desgin criteria would also include designated parking areas within the analysis area 

during the life of the timber sale contract. The designated sites are to ensure the saftey of the 

public. Following the harvest, the area would be more open, but the recreation use is not 

expected to change. 

This alternative also would result in increasing the length of trail 736, by decreasing the length of 

road 118.2, the amount of change is 0.8 mile. This would be a benefit to non-motorized 

recreation users. This road-to-trail conversion and trailhead relocation would take place 

following the timber sales. Following the harvest, the area would be more open, but the 

recreation use is not expected to change. 

The Continental Divide National Scenic Trail (CDNST) re-route would be impacted the same as 

Alternative 2. The same steps would be taken if deemed necessary. 

Effects of Alternative 3 on the South San Juan Wilderness Area and backcountry experiences of 

National Forest users would be be similar to Alternative 2 but reduced because a smaller area 

would be treated leading to less time for impacts to occur, and the areas being treated would be 

farther away from the South San Juan Wilderness Area. 


There are no direct, indirect, or cumulative effects to recreation resources within the County Line 

Analysis Area under Alternative 1. Under both Alternatives 2 and 3, there are no cumulative 

impacts to the area’s recreation resources, but there would be temporary impacts to recreation 

users. Implementing the outlined project design criteria and Forest-wide standards and 

guidelines addresses these temporary impacts and provides for the continuation of dispersed 

recreation activities within the analysis area. 



implemented. 



3.17 Economics 


The economic analysis focuses on the financial efficiency associated with commercial harvest 

treatments within the Rio de los Pinos Analysis Area. The purpose of this analysis is not to 

determine if the sales are above or below cost, but rather to compare the financial efficiency of 

each alternative. This economic efficiency analysis does not incorporate monetary values for all 

known market and non-market benefits and costs. 

Assumptions were made in the financial analysis conducted using the software Quick-Silver 

(version 5.004.45) concerning the timing of sales, units included in each sale, and sale 

preparation times. These assumptions may not be reflective of the final decision on how 

preliminary project units will be divided into final timber sales, but rather provides a reasonable 

estimate of expected costs and benefits associated with each of the alternatives, relative to each 

other. 

Specific costs and benefits used in the Quick-Silver economic analysis were based on recently 

published bulletins, previous timber sales, specialist input, and/or experience. 


Past actions that have affected the existing market condition in the Rio de los Pinos Analysis 

Area include a history of management actions. The majority of the areas proposed for salvage 

harvest were originally harvested in the mid-1950’s under a single tree selection system. Portions 

of the southern end of the analysis area were entered into a second time in the mid-1970’s. 

These sales contributed to the transportation system that will be used to access the proposed 

sales. 

Spruce beetle activity has recently increased on the Rio Grande National Forest. Heavy spruce 

beetle infestations was first noted in the winter of 2003 in the southern portions of the County 

Line Analysis Area, located less than two miles south of the Rio de los Pinos Analysis Area. 

Since that time, spruce beetles have progressed northward; heavy infestations were noted in the 

southern portion of the Rio de los Pinos Analysis Area during the 2007 field season. 

As a result of past harvest activity, stand susceptibility to spruce beetle outbreak was locally 

decreased for a period of time compared to areas that were untreated. Based on recent 

experience, and current observations, this past treatment will not preclude epidemic beetle 

populations that exist outside these stands from entering these stands. Advanced regeneration is 

fairly abundant; this is likely a product of past harvest, and will improve project economics by 

reducing the number of acres in need of post-treatment planting. Since dead stumpage rates are 

not as high as live stumpage rates, the recent spruce beetle activity has degraded the commercial 

timber value in the Rio de los Pinos Analysis Area. 




Cost efficiency is a measure of how well inputs (activities) are used in a production process to 

produce a fixed set of outputs. It is only a partial measure because not all benefits and costs to 

society can be quantified. Revenues from sawtimber have been assigned dollar values based on 

current markets and are quantifiable. Other resources such as watershed health, riparian health, 

wildlife abundance and diversity, long-term habitat improvement, social benefits, and scenic 

resources cannot easily be assigned dollar values. This economic efficiency analysis does not 

consider ecosystem services or non-market goods that are not required at the project level by the 

NFMA. Ecosystem services and non-market goods are addressed in the Forest Plan (refer to 

pages 3-445 through 3-469 of the Final Environmental Impact Statement). Alternatives that meet 

the requirements and intents of the Forest Plan achieve net public benefits as stated in NFMA. 

The economic impacts of the various harvest volumes proposed by each of the respective 

alternatives was not directly analyzed due to the Forest’s commitment to provide a stable supply 

of sawtimber to the local and regional timber industry. The Forest’s Allowable Sale Quantity 

(ASQ) at full budget levels is 21 MMBF per year, and the ASQ at experienced budget levels is 

11 MMBF per year (Forest Plan, P-12), and the timber sell volume target for 2008 is 

approximately 13 MMBF. In essence, if an alternative other than alternative 2 were to be the 

selected alternative, less sawtimber would be harvested from the Rio de los Pinos Analysis Area. 

The volume foregone by selecting an alternative other than alternative 2 would then be harvested 

from a different area on the Forest to meet the ASQ and Forest timber sell targets. 

In effect, this proposed project will not have a changing impact on the socioeconomic conditions 

of the area because sawtimber volume is offered under a timber program with the objective of 

selling a steady and sustainable volume of sawtimber. Consequently, this proposed project would 

have a sustained economic impact rather than a changing economic impact. 


One economic analysis with two alternatives (Alternative 2, Alternative 3) was run for the 

project. Table 3.17-1 summarizes the results from Quick-Silver. 

Table 3.17-1. Financial Analysis. 

PV- 

Net Present 

Approx. 

Vol. (Mbf) 

Alternative Benefits PV- Costs Benefit:Cost Value Harvested 

Not Not Not 

Not 

Alternative 1 Applicable Applicable Applicable Applicable 0 

Alternative 2 $582,590 $405,779 1.44 $176,811 13,070 

Alternative 3 $417,875 $368,129 1.14 $49,746 9,838 




Alternative 1 was not included in the analysis because the No Action alternative does not 

generate revenues through the sale of commercial forest products. If an analysis were completed 

for this alternative, it would result in a negative net present value due to costs associated with 

this Environmental Analysis, and administrative costs for the Forest Service to manage the lands 

within the Analysis Area. 

The benefit-to-cost ratio for this alternative would be essentially 0. This alternative would create 

a negative cash flow for the Forest Service. Additionally, this alternative does not provide means 

for site reforestation in timber production areas (Management Area Prescription 5.13) that are 

infested with spruce beetles and lack advanced regeneration, nor does it assist with road 

maintenance or other needed road improvements. This alternative may cause future economic 

degradation to areas managed for forest products because of the abundant downfall that would 

make future harvest activities more expensive. 


Alternative 2 generates a benefit-to-cost ratio of 1.44 under the currently proposed harvests. 

Since the benefit-to-cost is greater than 1.0, this alternative is economically feasible. The net 

present value of this alternative is $176,810. The present value benefit of the forest products 

being offered under this alternative is $582,590; these benefits include sawtimber volume sold 

and personal use firewood. The present value cost associated with implementing this alternative 

is $405,779; these costs include timber sale preparation, road work needed to access the sale 

areas, timber sale administration, slash disposal, reforestation, and monitoring. Under this 

alternative, approximately 13.1 MMBF of sawtimber could be offered. 

This alternative has the largest benefit-to-cost ratio and greatest net present value of the 

alternatives analyzed. Based on experience with recent salvage sales on the Conejos Peak 

District, there is a good possibility that the benefit-to-cost ratios may be higher than analyzed due 

to bid premiums. 


Alternative 3 has a benefit-to-cost ratio of 1.14, and is thus an economically feasible alternative. 

This alternative has an estimated net present value of $49,746. The present value benefit of the 

forest products offered under this alternative is $417,875, and the present value cost associated 

with offering this material is $368,129; these costs include timber sale preparation, road work 

needed to access the sale areas, timber sale administration, slash disposal, reforestation, and 

monitoring. Under this alternative, approximately 9.8 MMBF of sawtimber could be offered. It is 

likely that the benefit-to-cost ratio for this alternative may increase due to bid premiums. 


There are no cumulative effects associated with this analysis 



3.18 Social 


The social effects analysis primarily focuses on Conejos County, Colorado and to a certain 

extent on Rio Arriba County, New Mexico. The surrounding communities include Antonito and 

La Jara, Colorado as well as Chama, New Mexico due to its proximity to the Rio de los Pinos 

Analysis Area. The discussion specific to the timber industry focuses on the State of Colorado. 


Most of the early settlers in Conejos County used the surrounding lands for logging, mining, 

sheep grazing, and cattle grazing. Much of the population lived in rural areas where the National 

Forest lands were important for gathering firewood for heating and cooking, collecting medicinal 

plants such as osha, gathering food such as mushrooms, and for hunting, trapping, and fishing. A 

large portion of the population in Conejos County has historically been dominated by individuals 

of Hispanic origin, with many of the residents being descendents of the original Spanish settlers. 

The influence of the Spanish culture is evident in the local architecture and in the names of 

towns and geographic features of Conejos County, Colorado and Rio Arriba 

County, New Mexico. 

The first notable timber harvest activity in the analysis area was a single tree selection harvest 

that took place in the early- to mid-1950’s. This is likely the time period in which many of the 

roads in the analysis area were constructed for timber purposes. Because of this past timber 

harvest and road construction, access for certain recreational and commercial opportunities that 

are evident at the current time have been enhanced. 


Conejos County is approximately 825,700 acres; the Rio Grande National Forest makes up about 

35.5% (293,000 acres) of the land base (based on Rio Grande NF GIS data), so it is apparent that 

National Forest lands are important to the local population. The U.S. Census Bureau (2008) 

shows that a majority (nearly 55%) of the local population is still comprised of individuals of 

Hispanic or Latino in origin, and that 19.9% of households in Conejos County utilize wood as 

home heating fuel (U.S. Census Bureau 2000). Many of the people who are employed have 

relatively low paying jobs, with a median household income of $27,077 in 2004 (U.S. Census 

Bureau 2008), which makes Conejos County one of the poorest counties in Colorado. 

The local economy in Conejos County has changed over time as recreation has become more 

important. This is particularly true in areas close to the Rio de los Pinos Analysis Area, with the 

Cumbres & Toltec Scenic Railroad, the Caminos de los Antiguos Scenic Byway, the CDNST, 

and the South San Juan Wilderness Area located nearby. There are many local outfitter guide 

services, cabins, second homes, campgrounds, and businesses catering to area visitors. The area 

offers excellent opportunities for site seeing, hiking, hunting, fishing, camping, horseback riding, 

snowmobiling, cross country skiing, snow shoeing and wildlife viewing. All of the recreational 



opportunities and services provided by local businesses have made recreation a very important 

component of the local economy. 

The National Forest lands continue to be an important source of firewood and an important 

source of special forest products for the local population. Livestock grazing has also remained an 

important component of the local economy. Many of the local ranchers graze cattle and sheep on 

Forest Service allotments in Conejos County. 

National Forest lands have also continued to be utilized for their hunting and fishing resources. 

These resource users contribute to local economy during the summer and fall months and support 

the Colorado Division of Wildlife through license fees. 

Timber harvesting and other forest management activities such as tree planting have continued in 

the area. These activities have had mixed benefits to the local population; some timber sales have 

been purchased by local mills that generally utilize local contractors for logging operation, other 

sales have been purchased by mills from outside the local area, sometimes these mills contract 

with local contractors. 

National Forest lands continue to be an important source of sawtimber for the timber industry in 

Colorado. Many of the commercial timber lands in the state of Colorado are in public ownership 

and the availability of private sawtimber is limited. There are roughly 988,000 acres of National 

Forest land designated for timber emphasis in Forest Plans in Colorado. About 3.4 million acres 

of State and private forest lands in Colorado are commercial timber lands, although many of the 

lands in private ownership are not managed for timber production or are subdivided and 

developed. 

Since National Forest Lands make up a large portion of the commercial timberlands in Colorado 

that are managed in part for wood production, federal timber plays a fundamental role in 

sustaining Colorado’s timber industry. In 1999, 109.8 million board feet (MMBF) of timber was 

harvested in Colorado. Of the 109.8 MMBF harvested, 51.5 MMBF, or 46.9% of the harvest, 

occurred on USFS lands (Lynch and Mackes 2001). Timber use in Colorado mills totaled 

196,450 Ccf in 2005 (approximately 98.2 MMBF), taking into account wood provided to 

industry by both public and private sources (Rocky Mountain Region, USDA Forest Service, 

2006). During the period between 2003 and 2005, the Forest Service provided 52.4% of the 

84,000 ccf milled annually at Intermountain Resources, LLC, of Montrose, CO, Colorado’s 

largest currently operating sawmill (Rocky Mountain Region, USDA Forest Service, 2006). As a 

whole, Colorado mills and other buyers purchased 27.6% of their material from National Forests. 

This number cannot be directly compared to the figure cited by Lynch and Mackes (2001), as 

this percentage may include utilization and purchases from outside Colorado, though from both 

figures presented, it is apparent that the USFS is active in supporting Colorado’s timber industry. 





The no action alternative would have negative effects on the local population because the areas 

impacted by spruce beetle would not be treated. If left untreated, these areas would become 

virtually inaccessible due to the number of downed trees, and would be unsafe to enter as trees 

began to fall. A beneficial outcome of the no action alternative would be the abundance of 

firewood that would become available to the public for years to come. In addition, the no action 

alternative would minimize short-term social conflicts between users of Forest System Trail 736, 

the Rio de los Pinos, and the surrounding area. 

The no action alternative would have a negative impact on the timber industry in the state of 

Colorado by making roughly 8 to 13.1 MMBF of sawtimber unavailable to the timber industry. 

There have been numerous mill closures over the last decade in Colorado for a variety of 

reasons, and one of those is reductions in the timber volume offered from National Forest lands. 

The Small Business Administration classifies most of the remaining sawmills in Colorado as 

small businesses and most of these are located in rural communities with limited employment 

opportunities. Since the remaining sawmills in the San Luis Valley are typically at a competitive 

disadvantage when bidding on timber sales against larger operations, particularly when the 

timber sale is located outside the San Luis Valley, this alternative could have negative effects on 

the rural communities where these sawmills are located. 

During fiscal years 2002 through 2006, Conejos County received nearly $85,000 yearly, on 

average (State of Colorado 2003, 2004, 2005, 2006, 2007), from Forest Service timber revenues, 

and the Secure Rural Schools and Community Self-Determination Act of 2000 (SRS), Title I 

(Public Law 106-393, 106 th Congress). The SRS Act of 2000 was designed to stabilize payments 

counties historically received from timber sale receipts and was amended and reauthorized under 

the Emergency Economic Stabilization Act of 2008 (Public Law 110-343). Under this 

alternative, no timber sale revenues would be generated to offset payments to Conejos County as 

set forth by Secure Rural Schools and Community Self-Determination Act of 2000, or the 25 

percent payment to States required by the sixth paragraph under the heading of “FOREST 

SERVICE” in the Act of May 23, 1908 (35 Stat. 260; 16 U.S.C. 500), and section 13 of the Act 

of March 1, 1911 (36 Stat. 963; 16 U.S.C. 500). 


Other areas of the District and Forest have been harvested in the past. These treatments have 

been part of a timber program that is oriented towards providing the wood products industry with 

a stable and sustainable supply of material, while at the same time, meeting resource objectives. 

Under this alternative, the cumulative effects would be subtractive, and negative in nature. To be 

successful, industry needs a fairly stable supply of material. By not offering salvage material 

from the Rio de los Pinos Analysis Area, this supply stability in what the Rio Grande National 

Forest offers as part of its timber program may be disrupted, negatively affecting the timber 

industry, dependent service providers, and the communities in which they reside. 



In summary, this alternative would limit opportunities for local sawmills to benefit from local 

resources. The abundance of dead material would provide an ample source of fuelwood for local 

residents. Abundant Engelmann spruce mortality may make access for forest users limited and 

potentially dangerous as trees begin to fall. Some forest users will likely still choose to use the 

area for various recreational opportunities, despite these changing and potentially hazardous 

forest conditions. 

Alternatives 2 and 3 

Alternatives 2 & 3 would have similar effects. Under these alternatives, approximately 8 MMBF 

to 13.1 MMBF would be available to the forest industry. Providing this volume would allow 

mills in the San Luis Valley to effectively compete for resources because of lower mobilization 

and operational costs. Other beneficial impacts would include the increased safety and usability 

of the area after harvest is completed compared to the no action alternative, and firewood would 

remain abundant under these alternatives. 

Depending on the future status of the SRS Act of 2000, these alternatives may also directly 

contribute to the social welfare of Conejos County by eventually contributing 25% of the gross 

timber receipts back to the State, and subsequently Conejos County to be used for the benefit of 

roads and schools (GAO 1998). 

Each of the action alternatives creates potential for conflict between loggers and other forest 

users. Some forest visitors may choose to use different areas which could negatively impact local 

businesses. It should be noted that the Revised Forest Plan states that management emphasis is 

placed on wood production, while allowing for other uses. In addition, the Forest Plan states that 

Forest visitors can expect to see managed stands of trees in a natural or near-natural forest 

setting. Stands would have evidence of management, including tree stumps, slash, skid trails, and 

soil disturbance (RGNF Forest Plan IV-27). 

These action alternatives, in combination with changes that are occurring naturally on the 

landscape, may shift social uses that take place in the project area, bring new users into the area, 

or direct current users to different locations. 


This analysis area is within two miles of three active or currently prepared timber sale areas; 

these timber sales include Wolf Beetle Salvage, Escarabajo Salvage, and Spruce Park Salvage, 

which total roughly 16 MMBF. In combination with these timber sales, the Rio de los Pinos 

action alternatives have the potential to add additional time to harvest activities accessed by 

Forest System Road 118.1C. Project design criteria have been developed to mitigate and 

minimize conflicts between logging and other activities, but conflicts and interactions may still 

exist and take place during operational logging periods. 

In combination with past, present, and other planned harvest activities, either of the action 

alternatives would help the Forest Service to continue its stable and sustainable supply of timber. 



This in turn would help support the local and regional wood products industry, dependent service 

providers, and local economies. 

In summary, the action alternatives have the greatest potential to benefit the local communities 

and Colorado timber industry. In addition, forest conditions under a schedule of management can 

shape forest development and improve recreational and commercial opportunities while 

increasing safety to Forest users. Potential for conflict between Forest users exists for each of the 

action alternatives. Some forest users may choose to utilize alternative areas, which may affect 

local businesses. Ultimately, recreational opportunities will likely be enhanced if the trailhead for 

Forest System Trail 736 is relocated to the proposed location and if a portion of Forest System 

Road 118.2 is closed. 

3.19 Heritage Resources 


The Rio de los Pinos Analysis Area boundary. 


Past activities in the area have not affected identified heritage resource sites within the Rio de los 

Pinos Analysis Area boundary. 


Historic property 5CN784 was recorded during the cultural resource inventory. The site was 

determined to be eligible to the National Register of Historic Places. The site is located 

immediately outside of the area of potential effect of the project. In a letter dated December 16, 

2003 the State Historic Preservation Officer of Colorado concurred with the “no historic 

properties effected” determination because of the location of the site outside of the area of 

potential effect. 


All Alternatives 

There would be no direct or indirect effects to cultural resources within the Rio de los Pinos 



There would be no direct or indirect effects to cultural resources within the Rio de los Pinos 




3.20 Fire and Fuels Management 


The focus of this analysis for fire and fuels management will be on the 1,379 acre analysis area 

and will be directed to the spruce-fir timber type where harvesting is proposed. Fire and fuels 

concerns outside the analysis area will be analyzed through the district fuels program. No 

assumptions will be made as to whether or not a fire will occur on these lands, since increased 

risk of a wildfire after a spruce beetle outbreak only lasts for two to three years. However, 

intensity and severity, should a fire happen, can be measured by modeling prior to and sampling 

of the area after a fire occurs. Intensity, as predicted by such programs as BEHAVE, BehavePlus 

and First Order Fire Effects Model (FOFEM) can be described in terms of rate of spread, flame 

length and scorch height, and are all described as above the surface. Burn severity relates to the 

subsurface heat regime. It is generally described as residence time of the fire on the landscape, 

and directly relates to consumption of litter, duff, and large diameter fuels. The higher the 

percentage of large diameter fuels on the surface, the longer the residence time, the higher the 

severity and therefore the greater the influence on soils and plants. 


Past fire and fuels management activities in the Rio de los Pinos Analysis Area have been 

limited. See the Silviculture/Timber section for more detailed information on past activities 

related to timber harvest. Fire activity and suppression in this analysis area as well as most other 

spruce-fir forests is very limited due to the moist forest floor and dense canopy closure. The 

combination of past timber harvest practices, fire suppression, and to some degree grazing, has 

jointly contributed to the development of current stand conditions. Almost all of the analysis area 

has been treated by a first entry of a 3 step shelterwood. Throughout the analysis area there has 

been some fire-wood cutting activities that have helped to reduce some of the surface fuel 

accumulation. In the northern portion of the analysis area, timber harvesting of the larger size 

class of Engelmann spruce and sub-alpine fir in the 1950’s and 1970’s created a more open stand 

of timber that has remained less prone to spruce beetle infestation. The lack of timber 

management activities or natural and prescribed fire in the remaining portion of the analysis area 

has allowed the stand to approach a late seral stage and has set the stage for a greater possibility 

of beetle infestation and increased surface litter and debris accumulations. 


The Rio de los Pinos Analysis Area has been logged on at least one occasion in the past 40 years, 

and has been accessible to firewood gathering after that time. There have been sporadic 

outbreaks of spruce beetle over the years but none that have killed large numbers of trees. Due 

to the openness of the stand left behind after the timber harvest the public has been able to 

harvest most trees dying from spruce beetle up until the early 2000’s when the drought has made 

conditions better suited for beetles. The public hasn’t been able to keep the spruce beetles in 

check through firewood collecting in the Rio de los Pinos Analysis Area. Several factors 

contribute to an area’s susceptibility to tree mortality from wildfire and the amount of change 



that a fire may produce within individual tree stands or across a landscape. These include: a 

particular tree species resistance to fire mortality, stand structure, existing fuel loading and fuel 

moisture. 

Spruce-fir stands are not tolerant of fire due to thin bark and shallow roots. Most fires in this 

timber type are very infrequent but of high intensity. In a normal year with normal levels of 

moisture, substantial mortality can be expected in spruce-fir with even a low to moderate 

intensity fire. Stand structure in the analysis area is characterized by a lower basal area due to 

previous harvest activities and smaller diameter trees. The infestations to the south have matured 

and beetles have moved to surrounding stands that were not previously infested, primarily within 

the analysis area. Throughout most of the analysis area, the spruce beetle, has gained a strong 

foot hold in the area and killed most trees 8” DBH and larger. 

Very little has been done to calculate the existing fuel loading within the analysis area and within 

the spruce-fir type on the RGNF, mainly due to its historically low fire occurrence. This fuel type 

is classified as an ecosystem where the vegetation is “fire-initiated” via low-frequency, highintensity 

crown fires as opposed to “fire-maintained” via high-frequency, low-intensity surface 

fires. Fire serves as a stand replacement event which initiates new vegetative cycles (USDA 

Forest Service 1996). Spruce-fir as a rule is a fuel type that has high tons per acre of both large 

and small diameter fuels. One aspect that is known about fuels in spruce-fir is that when a stand 

is under attack by spruce beetle the foliage begins to dry out after the first year and can be very 

dry and flashy even though it is still green in appearance; therefore, the larger the percentage of 

the stand that is under a current attack the higher the volume of dry needles to carry a high 

intensity crown fire. 

Fuel moisture in spruce-fir stands is typically higher than other forest types due to the higher 

elevation, amount of precipitation, and stand structure. Most spruce-fir stands are multi-storied 

and have a relatively high canopy closure. These factors contribute to maintaining high fuel 

moisture content and lowering the risk of fire starts. In dry years when fuel moisture is low, fire 

starts can occur, though less frequently than in mixed conifer or pine stands. This is the case 

within the Rio de los Pinos Analysis Area. 

The interactions between wildfire and spruce beetle infestations were first recognized in 1909 by 

A.D. Hopkins. He concluded that “this additional evidence, together with the known devastating 

work of this class of insects, makes it clear to the writer that there has been a most intimate 

interrelation of destructive bark beetles and forest fires in the denudation of the vast areas once 

heavily forested lands in the Rocky Mountain region, and that in many cases the insects first 

killed the timber, and the fire has then followed, leaving charred trunks and logs as apparent 

proof that the fire alone was {not} responsible.” The publication shows pictures of spruce stands 

on the Pike National Forest and on the Linclon National Forest that were first killed by spruce 

beetle and subsequently burned. Since the time of Hopkins publication, further studies have been 

completed that don’t totally uphold these early findings. In 1990 a publication by William Baker 

and Thomas Veblen concluded that their research did not contradict Hopkins but that the results 

could have been influenced by the high frequency of human-caused fires. They felt that “it was 

difficult to determine whether spruce beetles did or did not increase the susceptibility of these 

forests to natural fire.” Although they also concluded that “interaction between these 



disturbances is apparent and major roles for both spruce beetles and fires are suggested.” A 2003 

publication by Peter Bebi, Dominik Kulakowski, and Thomas Veblen based on a study in the 

Flattops Wilderness concudes that “areas affected by the 1940’s spruce beetle outbreak showed 

no higher susceptibility to subsequent fires.” 

They concluded that any increase in fire risk only lasted two to three years because of the rapid 

decay and fall of dead needles; however, they also said that their results could have been 

influenced by weather conditions and fire suppression activities. Another publication documents 

the occurrence of uncharacteristic stand-replacing wildfires in stands that had been previously 

impacted by spruce beetle in central Idaho (Holsten et al. 1999). The interrelation between 

climate (drought), spruce beetle, and fire is clearly an area in need of further research. Based on 

the documented fires that occurred following spruce beetle outbreaks in the past, it is reasonable 

to assume that wildfire in the Rio de los Pinos Analysis Area is a distinct possibility. This is 

especially true given drought conditions that have occurred in the area in the past. Research has 

shown that there is a correlation between drought and high elevation fires (Sherriff et al. 2001). 

If the current spruce beetle infestation and drought conditions were to precipitate a wildfire in the 

Rio de los Pinos Analysis Area this would be a natural event, with a normal fire occurrence 

interval, and normal intensity and severity for this ecosystem. However, the fire effects would 

not be consistent with the desired condition for the MAPs within the analysis area. 



Both of the action alternatives allow for varying degrees of timber harvest and the subsequent 

treatment of the activity fuels created. The harvest of mid and over-story trees, with severe 

infestation, would serve to remove some of the laddering potential and also increase the present 

crown spacing to a point that the potential for crown to crown fire movement could be greatly 

reduced. 

However, this treatment would not serve to eliminate the potential for a stand replacement fire, 

because even a low intensity surface fire in spruce-fir can cause high percentages of mortality. 

Timber sale contract provisions allow for treating of slash so that fuel build up can be 

minimized. Provisions allow for keeping slash heights below 2 feet. This coupled with the heavy 

snow loads at this elevation, makes slash become part of the duff layer very quickly and 

subsequently a lesser concern as fuel. 

Throughout the rest of the stands where harvesting occurs, slash would be treated with standard 

contract provisions to lop and scatter the tops and limbs. This would create, over time, less fine 

fuels that have a vertical arrangement and a decreased exposure to the drying effects of wind and 

sun. In most areas, the proposed harvest activities would be as much a fuels treatment as a timber 

production action. 




With no action, there is the potential for a short-term build-up of fuels on the forest floor and in 

the canopies of the spruce trees as they begin to die. The first year or so after an Engelmann 

spruce is infested by spruce beetle, the tree begins a slow drying process, brought about by the 

larvae eating the phloem layer of the tree. During the second summer of an attack most needles 

turn yellowish-green and begin to fall (Holsten et al. 1999). This period is when the potential for 

large crown fires would be at its highest. After the needles have fallen the potential would 

significantly decrease until many years later when there would be a greater potential for a heavy 

build-up of fuels as the roots of snags begin to rot and snags begin to fall. As noted by Veblen 

and others (1994) in some areas large outbreaks of spruce beetle and root rot in subalpine fir 

have also resulted in heavy loadings of large woody fuels, which would support future standreplacement 

fires. This could take from ten to thirty years or more. If fine fuels, weather 

conditions, and ignition sources are available for a potential future fire event, the heavy fuels that 

have fallen to the forest floor could increase the severity of the burn and possibly damage soils, 

watersheds, and the ability of the area to regenerate. 


Since the action alternatives allow for salvage harvest of the large diameter fuels (1000 hour 

timelag fuels) and the slash left in the harvest units can be treated, this is the most ideal situation 

for avoiding a severe fire event that could severely damage soils and the watershed. Contract 

provisions allow for treating slash to make it less than 2 feet in height, creating fuels that are 

more compact and part of the duff and litter layer. The only difference between the action 

alternatives, as it relates to fire and fuels management, would be in the acreage treated by 

salvage. 

Alternative 2 would have the most positive effect on fuels and fire management from the 

standpoint that it is the largest acreage treated with some sort of harvest activity. Removing trees 

infested with spruce beetle and the resulting slash treatment would remove the largest amount of 

potential fuels from the stands. However, it would not serve to eliminate the potential for a stand 

replacement fire, because even a low intensity surface fire in spruce-fir can cause high 

percentages of mortality. 

Alternative 3 would concentrate its treatment to only the infested areas in the center portions of 

the analysis area and eliminating areas with high stream concentrations. This would key in on the 

concern at hand by treating the fuels generated by dying trees and then subsequently treating the 

slash in areas proposed for harvest, but not within areas around streams, thus leaving the area at 

risk for a wildfire damage soils due to high concentrations of fuels remaining on site. 


There is a risk of a future fire impacting the analysis area in the short term following treatment. 

This increased risk of wildfire could increase the potential danger to life and high-value property, 

both on private and federal lands. With the high density of dead and live material adjacent to and 

within the analysis area, a favorable environment exists for ignition and rapid spread of wildfire 

during periods of extremes in temperature, winds, and low fuel moistures. 



Logging slash would be available to carry a fire, but in most areas it would be lopped and 

scattered to a level that the intensities of a fire would not be as great as untreated areas. Within 

the analysis area there would be very little dead fine fuels in a state that could readily carry a fire 

but the regeneration of grasses and forbs would create some live fine fuels. In this condition 

there is a chance that only a low intensity surface fire would carry through the analysis area. 



implemented. Under the no action alternative there could be adverse environmental effects to 

other resources that could lead to an irreversible and irretrievable commitment of resources if a 

severe wildfire were to occur. 

3.21 Noxious Weeds 


The scope of the analysis for noxious weeds is the Rio de Los Pinos Analysis Area 

boundary and haul route to Colorado Highway 17. 


All infestations that have been located and/or treated within the Analysis Area have been 

alongside roads or areas of disturbed soils. Road construction and maintenance is the primary 

activity that has had impacts to the vegetation and soils within the analysis area. 


Observations have identified Canada thistle (Cirsium arvense) as being the only noxious weed 

species present within the Analysis Area. There have been very few sites of Canada Thistle 

located within the Analysis Area. Sites of Canada Thistle that have been treated within the 

Analysis Area in the past, have been very small in size (less than 1 acre). Since this area has a 

relatively low population of Canada Thistle, the management priority is for eradication rather 

than containment. 



This alternative will have a low risk for noxious weed spread and/or introduction. This is 

primarily because this alternative will have the least amount of soil disturbance. Additionally, 



less equipment and activities in the area will also lessen opportunities for noxious weed spread 

and/or introduction. 

There is still a low risk of spread and/or introduction of noxious weeds in the Analysis Area, 

even without the implementation of the project. The existing road infrastructure within, and 

leading to the Analysis Area will still be maintained. This will allow for periodic soil disturbance 

along roadways and heavy equipment activities that may be hosts for weed seed transport. 

Established noxious weed infestations, if not treated will likely continue to spread and provide a 

seed source for new infestations. Other activities and users of the area may also be carriers of 

weed seed and may cause soil disturbance that may contribute to the establishment and/or spread 

on noxious weeds within the Analysis Area and the proposed haul route. There will also be a 

certain amount of natural soil disturbance from trees falling, wildlife digging, etc. and natural 

seed dispersal from wind and wildlife. Additionally, without the project implementation, 

monitoring of the area would be of lower priority and additional funding that would have been 

generated by the project would not be available for noxious weed control. 


This alternative will have a moderate risk for noxious weed spread and/or introduction. There 

have been infestations of Canada Thistle in and near the Analysis Area. This elevates the 

potential for noxious weed seed to be available in the soil. Additional soil disturbance besides 

the normal road maintenance will also occur with the upgrading of the current roads and 

possibility of borrow material and gravel being hauled in for use on the roads. The increased 

activity with haul trucks, pickups and heavy equipment will heighten the possibility for transport 

of weed seed. Soil disturbance from the log skidding operation could be a seed transport 

possibility and soil disturbance possibility. Log skidding may also present an opportunity for 

noxious weed establishment in areas out of site from the main roads, which makes it difficult to 

locate infestations early on. 

Factors that are contributing to the project presenting moderate risk instead of high risk are: 

• Canada Thistle is the only noxious weed known to be in or near the Analysis Area. 

• Canada Thistle is not very common in the Analysis Area 

• Canada Thistle is very treatable and easy to control if caught early 

• Project design criteria are in place to lessen the introduction of new weed species and the 

spread of Canada Thistle. 

• KV funds are planned for monitoring and treatment of the area after the project is 

completed 


This alternative will have the same effects as Alternative 2 but with a low moderate risk for 

noxious weed spread and/or introduction. By not harvesting timber in the wettest areas, the risk 

is reduced primarily because of these factors: 

• The wettest areas provide the greatest risk for noxious weed establishment and spread 

because of the excellent growing conditions 

• Often times, wet areas or riparian areas preclude the use of many herbicides due to label 

restrictions, which makes eradication very difficult and expensive 




There may be cumulative adverse effects to the analysis area from all alternatives due to the 

potential increase of Canada Thistle and/or introduction of new species of noxious weeds. As 

explained above, all of the alternatives present a risk to some degree. 


There would be no irreversible or irretrievable commitment of resources if the 

proposed action is implemented. 

3.22 Cumulative Effects Summary 

The Council for Environmental Quality (CEQ) defines cumulative impacts as, “the impact on the 

environment which results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions regardless of what agency (Federal or non- 

Federal) or person undertakes such other actions.” 

“Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time.” In other words, cumulative effects are simply the sum total 

of past, present, and reasonably foreseeable environmental, social, and economic effects of land 

management activities which, when taken in context of this specific project, affect the conditions 

and trends of resources and values within the project area and adjacent area of influence. 

Each resource specialist addressed both the past actions that have affected the existing condition 

and cumulative effects within their section in Chapter 3. 

Overall, as described within Chapter 3, past timber sales, roading, and other activities (grazing, 

camping, hunting...) have helped shaped the Analysis Area into the present condition. Presently, 

the Analysis Area provides for a wide variety of recreational and scenic activities, provides 

suitable habitat for numerous wildlife species and contains soils and watersheds in healthy 

conditions. The vegetative community contains a diversity of plant communities which are well 

distributed across the landscape. Heritage, social and economic resources are generally limited. 

Forest condition is in a state of decline, due to the current beetle infestation. Spruce beetle 

impacts are a new factor which is capable of affecting all other resources in varying degrees. 

Reasonably foreseeable activities within the Analysis Area are few. Routine road maintenance 

would occur. With the exception of minor amounts of blow-down salvage, no future timber 

harvests are anticipated in the immediate future. However, re-entry into previously managed 

areas, to carry out past Silvicultural Prescriptions, could occur within the next ten to twenty 

years. There are no private, state or tribal lands within the Analysis Area whose actions would 

contribute to the cumulative effects. 



Cumulative effects are summarized by alternative below. 


Alternative 1, when taken in context of this specific project, and added to the sum total of past, 

present, and reasonably foreseeable environmental, social, and economic effects of land 

management activities, would have little effect upon the conditions and trends of resources and 

values within the project area and adjacent area of influence. 

Alternative 1 would continue to provide for a wide variety of recreational and scenic activities 

within the Analysis Area. Areas of beetle killed trees would be noticeable and foot access into 

these specific areas would become more difficult as dead trees begin to fall to the ground. The 

attributes of the IRA would not be changed, other than what is occurring due to the current 

spruce beetle outbreak. 

Suitable habitat for wildlife species would continue to be present, although the distribution and 

amount of older mature spruce fir would be reduced, reducing the habitat effectiveness for 

species requiring this habitat type. The value of the mature spruce-fir component to wildlife 

species would be impacted, but not to the extent of impacting population trends on the Forest as 

a whole. 

Soils and watersheds would remain in healthy condition. The vegetative community would 

continue to contain a diversity of plant communities, well distributed across the landscape. 

These vegetative communities may be at a greater risk for crown fire in the immediate two years 

following infestation, due to beetle-killed trees. They may also have a greater risk for fire 

severity and intensity in both the short and long term, due to heavy dead fuels. 

Heritage, social and economic resources would remain limited with the exception of increased 

firewood collection opportunities. 

Forest condition as a whole in the Analysis Area would decline in the short and mid-term, due to 

the current beetle infestation. Infested areas would be left to regenerate naturally, which would 

take more time than if artificially replanted. If current spruce beetle infestation rates continue, 

the overall appearance of the Analysis Area would be impacted and some economic values 

would be lost due to lost opportunities for timber salvage. 


Specialist analyses and reports included within Chapter 3 address the potential impacts of the 

action alternatives upon the various resources. Overall, the impacts of the action alternatives 

vary by the amount of acres proposed for harvesting and are separated by only a few percentage 

points between alternatives. Therefore, the cumulative effects of all action alternatives are 

discussed jointly. 



The action alternatives, when taken in context of this specific project and added to the sum total 

of past, present, and reasonably foreseeable environmental, social, and economic effects of land 

management activities, would have little effect upon the conditions and trends of resources and 

values within the project area and adjacent area of influence. The minor impacts anticipated 

would be mitigated through project design criteria, which are incorporated into all action 

alternatives. 

The action alternatives would continue to provide for a wide diversity of recreational and scenic 

activities within the Analysis Area. Areas of beetle-killed trees would be noticeable and foot 

access into these specific areas may be more difficult as dead trees begin to fall to the ground. 

However, salvaging a portion of the infested acres would improve foot access into these units. 

Suitable habitat for wildlife species would continue to be present regardless of the action 

alternative. The distribution and amount of older mature spruce fir would be reduced, but more 

as a result of beetle activity than the action alternatives themselves. Temporary road construction 

would be rehabilitated following management activities and would have little additional impact 

upon wildlife species. Minimal or no effects are expected for TES, MIS, migratory birds, or 

their habitat. 

Soils and watersheds would remain in healthy condition. Project design criteria are in place for 

all action alternatives, with specific criteria in place for the proposed temporary roads. The 

vegetative community would continue to contain a diversity of plant communities, well 

distributed across the landscape. The risk of fire intensity and severity in these vegetative 

communities would be decreased, due to the harvest proposed by the action alternatives reducing 

the amount of dead fuels present. 

Heritage and social resources would remain limited. Economic values would be increased and 

improved through harvest and planting activities, in addition to the other forest products 

retrieved. 

If current spruce beetle infestation rates continue as expected, the overall appearance and forest 

condition of the Analysis Area would be impacted. Forest condition in the Analysis Area as a 

whole would rebound more quickly, however, due to limited, localized control of beetle 

populations and artificial regeneration. 

3.23 Other Disclosures 

Global Climate Change 

The Forest Service acknowledges that global climate change is an important emerging concern 

worldwide. However, there is no established scientific methodology to measure the effects of 

small-scale projects such as this project on global climate. This analysis briefly addresses global 

climate change in two ways: 1) effects of climate change on a proposed project, and 2) effects of 



a proposed project on climate change. Each of these is briefly discussed below relative to this 

project. 

Effects of climate change on a proposed project 

The National Environmental Policy Act (NEPA) does not specifically require analysis of how 

environmental factors, such as global climate change, might impact a proposed action. Any 

differences in effects of climate change on the project between alternatives (including no action) 

would be negligible. 

Effects of proposed project on climate change 

The proposed activities are extremely small in scope and magnitude relative to a planetary scale. 

Although it may be possible to quantify a project’s direct effects on carbon sequestration and 

greenhouse gas (GHG) emissions, there is no certainty about the actual intensity of individual 

project indirect effects on global climate change. Cumulative effects would be a consideration of 

GHG emissions affecting climate from multiple projects over time. But, as GHG emissions are 

integrated across the global atmosphere, it is not possible to determine the cumulative impact on 

global climate from emissions associated with any number of particular projects. Nor is it 

expected that such disclosure would provide a practical or meaningful effects analysis for project 

decisions. Any differences between alternatives (including no action) would be negligible at a 

global scale. 




CHAPTER 4 

List of Preparers 

This chapter identifies the individuals on the Rio de los Pinos Vegetation Management Project 

Interdisciplinary Team who were responsible for preparing this Environmental Impact 

Statement. It also briefly describes the roles of responsibility for each team member. 

The Forest Service employs various resource specialists who have the responsibility to provide 

for their individual resource. Whenever a project is proposed, the individual resource specialist 

reviews and analyzes the proposal regarding the potential impacts upon their resource. If a 

project is expected to have unacceptable impacts upon any one resource, the project is pursued 

no further. 

In the case of the proposed Rio de los Pinos Vegetation Management Project, internal scoping 

indicated that the project should have little impact upon resources. Therefore, external scoping 

was initiated. Utilizing input from the public, the IDT identified two action alternatives for the 

Responsible Official to consider, and those alternatives and their potential impacts upon the 

resources are described within this EIS. 

4.2 Interdisciplinary Team Members 

Below are the Interdisciplinary Core Team Members, along with their resource responsibility: 

Table 4.2-1 ID Core Team Members 

Member Title Responsibility 

Kevin Duda Forester Timber Management/Silviculture/ 

ID Team Leader 

Phil Reinholtz Hydrologist Watershed & Aquatic Resources 

John Rawiniski Soil Scientist Soil Resources 

Andrea Jones Wildlife Biologist TES, Sensitive & MIS Wildlife, 

General Wildlife Species 

Michael Tooley Forester Forest Condition 

Chapter 4 -- List of Preparers Page 4-1


Table 4.2-2 lists the Supporting Resource Specialists who also conducted or assisted with 

resource analysis. 

Table 4.2-2 Supporting Resource Specialist 

Member Title Responsibility 

Barry Wiley Fisheries Biologist Fisheries Resources 

Kelly Ortiz/ 

Landscape Architect/ 

Scenic Resources, 

Social Resources 

Dean Erhard Ecologist TES & Sensitive Plant Species, 

Late-Successional Forest 

Kelly Garcia Rangeland Management Specialist Rangeland Resources, 

Invasive Plant Species 

Gary Frink Engineering Technician Transportation/Travel Management 

Amanda Walker Natural Resource Specialist 

(Recreation) 

Recreation/Travel Management 

Kevin Duda Forester Economics / GIS / Social Resources 

Angie Krall Archeologist Heritage Resources 

Paul Minow District Fire Management Officer Fire and Fuels Management 

Tom Eager Forest Entomologist Forest Condition 

Chapter 4 -- List of Preparers Page 4-2


CHAPTER 5 

Notifications & Disclosures 

5.1 List of Agencies, Organizations, and Persons to Whom Notices of 

Availability of the DEIS were Sent 

Table 5.1-1 Draft EIS Notice Of Availability Contacts 

Contact Format 

Steve Vandiver Letter 

Kristi Mountain Sports Letter 

Rio Grande Headwater Restoration Project Letter 

Carson Forest Watch Letter 

L.J. Quinn Letter 

Intermountain Forest Industry Association Letter 

Wild Earth Guardians Letter 

Jorge Andromidas Letter 

West Range Reclamation Letter 

Advisory Council on Historic Preservation Letter 

NRCS National Environmental Coordinator Letter 

USDA APHIS PPD/EAD Letter 

Satterwhite Log Homes Letter 

Colorado Wild Letter 

USDA National Agricultural Library Letter, Hardcopy, CD 

US EPA Office of Federal Activities EIS Filing Section Letter, Hardcopy 

US EPA Region 8 Letter, Hardcopy, CD 

DOI Office of Environmental Policy & Compliance Letter, Hardcopy 

DOE Office of NEPA Policy Letter 

Helen Moore Letter 

San Luis Valley Ecosystem Council Letter 

San Juan Citizens Alliance Letter 

US Army Engineer Northwestern Division Letter 

US Army Engineer South Pacific Division Letter 

US Coast Guard Environmental Management CG-443 Letter 

FAA Northwest Mountain Region Letter 

Chapter 5 -- List of Recipients Page 5-1


5.2 List of Agencies, Organizations, and Persons to Whom Notices of 

Availability of the FEIS were Sent 

Table 5.1-1 Final EIS Notice Of Availability Contacts 

Contact Format 

Colorado Wild Letter 

Carson Forest Watch Letter 

WildEarth Guardians Letter 

Advisory Council on Historic Preservation Letter 

USDA APHIS PPD/EAD Letter 

NRCS National Environmental Coordinator Letter 

USDA National Agricultural Library Letter, Hardcopy, CD 

US Army Engineer Northwestern Division Letter 

US Army Engineer South Pacific Division Letter 

EPA Office of Federal Activities EIS Filing Section Letter, Hardcopy 

EPA Region 8 Letter, Hardcopy, CD 

DOI Office of Environmental Policy and Compliance Letter, Hardcopy 

US Coast Guard Environmental Management CG-443 Letter 

FAA Northwest Mountain Region Letter 

DOE Office of NEPA Policy and Compliance Letter 

Chapter 5 -- List of Recipients Page 5-2



CHAPTER 6 

Responses to Comment 

As a result of a 45-day comment period, the Forest Service received three letters or e-mails in 

response to the EA for Comment. The Interdisciplinary Team reviewed these letters, identified 

the substantive comments, and replied to those comments. Some comments resulted in changes 

to the EIS, while others resulted only in an explanation of the rationale for the analysis 

conducted. For an overview of the public involvement process and participants, see section 1.14. 

To review changes to the EIS which resulted from public comment, see section 1.15. 

Forest Service responses to comments are addressed within this chapter. Each response 

references an indexed letter and a specific comment. For example, Public Comment 1-1 can be 

found in Letter 1, comment 1 of Appendix E. As indicated, all received letters are indexed and 

displayed in Appendix E. Table 6.1-1 displays the index number assigned to each letter 

received. 

Table 6.1-1. Index of Public Comments in Appendix E 

Index # Commenter Contact Type Date Representing 

1 Rocky Smith Letter 01/13/2010 Colorado Wild, WildEarth 

Bryan Bird 

Guardians 

2 Joanie Berde Letter 12/11/2009 Carson Forest Watch 

3 Larry Svoboda Letter 01/14/2010 US EPA Region 8 

6.2 Responses to Comments 

Following are the Forest Service responses to Public Comments. 

Forest Service Response to Comment 1-1: 

Thank you for the comment. The stated acreage of the 7 th level watershed of concern 

(13010005050101) that lies within the WIZ (100 feet of all stream channels) in the DEIS was 

inaccurate and has been corrected. Its acreage is approximately 216 acres, or 20 percent of the 

total watershed area. No harvest activities are permitted within wet areas, so no damage from 

heavy equipment would occur within them. 


As noted in the response to Comment 1-1, the amount of acreage in the WIZ is approximately 

216 acres. In Map A-2, the harvest exclusion zones include the WIZ adjacent to stream channels 

and other wet or riparian areas identified during field marking. No logging will occur in these 

zones and any stream crossings or other entry by equipment would need to be approved by the 

Chapter 6 -- Response to Comments Page 6-1


sale administrator with assistance from hydrology and soil specialists. Disturbance within the 

WIZ in the watershed of concern would be limited to upgrading existing system road crossings. 

With regard to the two wetland features noted on page 3-29, they were visited by the TEAMS 

soil scientist in August 2009 (see report dated 10-06-09). These features were delineated during 

tree marking operations and placed within streamside management zones marked for protection. 

As a result of this comment, soils design criteria was improved to ensure that wetland protection 

is evaluated and determined adequate before project implementation. 


The third sentence in the comment “One important criterion is to keep activity 100 feet away 

from the WIZ” is incorrect. That would result in a 200 ft buffer on streams. The limitations on 

activity pertain to the area within the WIZ, or within 100 feet of intermittent and perennial 

stream channels. With regard to percent of the watershed within the WIZ, please see response to 

Comment 1-1. No logging will be allowed in the WIZ (FEIS Table 2.5-5) unless needed for 

designated road crossings and these are limited. 


The discussion in the DEIS regarding the wet seepage areas was intended to show that not only 

will the 100 ft WIZ adjacent to streams be protected from disturbance, but that any areas having 

riparian vegetation or wet conditions due to seeps will also be protected (See Appendix A maps 

and FEIS p. 3-24). 

The project area was evaluated by qualified experts. During this analysis, it was evaluated by a 

watershed hydrologist and two soil scientists, including a 2009 field evaluation by the Enterprise 

Team soil scientist. The area was also previously analyzed for the County Line Vegetation 

Management Project by the Forest soil scientist and hydrologist. In response to this comment a 

section specific to wetlands has been added to the FEIS. 


Soil moisture will depend on growth of regeneration that has not been killed by spruce beetles 

and the amount of shrub and grass vegetation that will increase in beetle impacted areas. If some 

areas do become more saturated, monitoring by the sales administrator and application of design 

criteria in Table 2.5-6 will keep detrimental impacts to soils within Forest Plan standards. 


Logging over frozen soils or packed snow has been proven to reduce impacts to soil resources. 

The commenter is correct in that snow and frozen ground conditions will vary from year to year, 

depending on timing of snow and onset of cold-warm weather. However, limitations on logging 

on saturated soils will apply regardless of these fluctuations (FEIS Table 2.5-6, p. 3-31). 

Logging activities would continue once soil conditions have improved. 


No harvest will occur within the WIZ, unless site-specifically approved by a hydrologist or soil 

scientist. As described in response to Comment 1-2, only limited disturbance and equipment 

entry associated with road or skid trail crossings will occur within the WIZ. 




Soil impacts by percentage of activity areas were determined by the soil scientist and were 

between 2 and 5 percent (FEIS Table 3.7-2, p. 3-30). The commenter is misapplying soil quality 

standards (FSH 2509.18-Soil Management Handbook-R2 Supplement No. 2509.18-92-1; 

Effective August 15, 1992) used in soil effects analysis to disturbance concern levels used in 

watershed analysis. Soil effects analysis on a project level scale is much different than watershed 

disturbance level analysis. Differences between these analyses are described below. 

The 15% limit as used in soil effects analysis applies to compacted, eroded, or displaced land in 

a specific activity area. Activity area is defined as: An area of land impacted by a management 

activity or activities. It can range from a few acres to an entire watershed depending on the type 

of monitoring being conducted. It is commonly a timber sale cutting unit, a prescribed fire burn 

unit, or an allotment pasture. This definition is consistent with other Regions. Acreage of roads 

within the permanent transportation system are not applicable to the 15% limit of detrimentally 

compacted, displaced, puddled, severely burned, and/or eroded lands within an activity area. 

Roads are considered dedicated uses, and soil quality standards do not apply to roads. 

Watershed analysis is based on a much broader scale, and acreages considered “disturbed” 

include roads, timber harvest areas, recreational areas, areas inundated by reservoirs, residential 

areas, poor range conditions, etc. These were calculated for each 6th and sometimes 7th level 

watershed on the Forest for the 1996 Forest Plan EIS. Equivalent roaded disturbance levels were 

then compared to each other and risk levels determined. Although those that exceeded specific 

disturbance levels (10 to 15%, depending on sensitivity factors) were designated “watersheds of 

concern,” these concern levels are not thresholds that cannot be exceeded (Watershed 

Assessment-A White Paper for the Forest Plan Revision”, Dobson, 1996), but watersheds in this 

category must be carefully evaluated to confirm recovery from previous disturbance before 

additional management activities can be completed in the watershed. This process was 

completed for the 7 th level “watershed of concern” during analysis for the Rio de los Pinos 

project and the County Line Vegetation Management Project. 


The reference noted by the commenter to Road 118.1C was related to rapidly weathering 

bedrock that adds sediment to the creek, not mass movement. The FEIS language has been 

revised to clarify this point. Harvest units within the project area, including those on steeper 

slopes, were evaluated during the Rio de los Pinos and County Line Vegetation Management 

Project analysis. Potential impacts from these steep slope treatments are minimized by project 

design criteria and remain within Forest Plan standards. Areas determined to have high mass 

movement potential were removed from harvest consideration. 


As described in the WCP Handbook, connected disturbed areas (CDAs) are high runoff areas 

like roads and other disturbed sites that have a continuous flow path to a stream that can multiply 

sediment input. Disconnection of disturbed areas (mainly roads) was recognized during the 

effects analysis process as essential in protecting stream health during project implementation. 

The emphasis placed on disconnecting drainage is shown by the four specific design criteria 



presented in Table 2.5-5 to minimize sediment input to stream. Stream disconnection is also 

noted as an objective on page 3-25. 


The impacts of each alternative have been considered and Forest Plan standards can be met for 

soil and watershed resources through the implementation of project design criteria and WCP 

design criteria. 


Planting will occur in non-stocked and under-stocked areas within each harvest unit. Although 

stand averages look good, not every acre is uniformly stocked; some areas are high and some are 

low. Harvest activities are not expected to create these areas (FEIS Table 3.5-2). Rather, we 

expect them to be created because areas with severe mortality have lost their seed source and 

currently have low number of seedling and saplings. We will be promoting reforestation in these 

areas. We agree that mortality in the overstory will release regeneration where it is present. 

Thank you for the footnote; the text was corrected in Section 3.11 of the FEIS. 


The Forest Service recognizes that some amounts of damage to seedlings and advance 

regeneration will occur through logging activities. However, these activities are not expected to 

cause the need for regeneration. See FS Response 1-12. If incidental planting areas are created 

by harvest activities, Project Design Criterion in Table 2.5-4 (FEIS) ensures they would be 

surveyed and reforested as needed. This design criterion is triggered by a NFMA requirement 

that adequate stocking exists at the end of a 5-year period and has proven to be an effective 

means of assuring regeneration. 


The Forest Service agrees that not entering an area would protect regeneration where it exists for 

the short term. But it would not create regeneration where it does not currently exist. We 

disagree that larger trees resist damage from falling snags better than small trees. To the 

contrary, juvenile wood fiber exhibits far greater flexibility without structural damage than 

mature wood fiber. Younger trees also exhibit more rapid growth, and thus healing of wounds, 

than mature trees. We agree that rotting logs would likely contribute to a good seed bed in the 

future; however, regeneration postponed for 50+ years does not meet the Desired Condition for 

the Management Area Prescription (FEIS Section 1.7). 


The Forest Service disagrees with this assumption. The DEIS does not go into specific detail 

about our reforestation success, but there are two major areas that have been planted with spruce 

in the past decade, the Grouse Timber Sale on the Conejos Peak District, and the Twister Timber 

Sales on the Divide Ranger District. All units planted in the Grouse area were certified as 

stocked at the end of a 5 year period. Recent surveys in the Twister spruce planting areas show 

that over 129 acres, an average of 66% of the seedlings planted have survived the first 3-5 years. 

Additionally, Appendix D of the DEIS was misinterpreted. The references in the table to 

silviculture (i.e. “Regen,


1996 Forest Plan revision. They are not related to the regeneration success of previous 

management activities. 


Thank you for the comment. Adequate seedling protection is required in Forest Service planting 

contracts, whether through hand-stacked logging slash (a common practice) or through artificial 

tree shelters, which the Forest already owns. 


Please see Forest Service Responses 1-12 and 1-13. Planting estimates are based on current 

regeneration stocking levels and current overstory mortality within each unit. See also Forest 

Service Responses 1-15 and 1-16 concerning regeneration success and adequate seedling 

protection. 

Forest Service Response to Comments 1-18: 

The EIS states a need to reduce long-term fuel build-up (FEIS Section 1.5, italics added). The 

goal is to reduce the duration and intensity of a potential wildland fire by reducing the heavy fuel 

loading that may at some point in the future burn with very high intensities and cause severe soil 

damage. The Forest Service agrees that fires are rare in wet, high-elevation areas but 

acknowledges that they have and do occur. Analysis is focused on potential severity rather than 

fire risk. 


The Forest Service agrees that once the trees lose their needles and the needles become part of 

the surface fuels there is little chance of a crown fire. However, later in time when the trees 

begin to fall due root rot or wind, the loading of larger diameter fuels on the soils can burn at a 

very high intensity and cause high severity to the soil. 


If a spruce tree falls and a large majority of the bole touches the ground, then rot does begin to 

occur. However, if trees crisscross each other and subsequent layers of trees are off the soil 

surface, they decay much more slowly. Sound spruce trees that have been standing for many 

years, even decades, do not rot as quickly as stated in the comment when in this condition. The 

existing regeneration that would grow up over the years would indeed provide some shelter to 

the surface fuels, but the last statement “except during extended drought periods” is key. 

Research has shown that there is a correlation between drought and high elevation fires (Sherriff 

et al. 2001). Eventually there will be a dry period and if a fire occurs, the damage to soils could 

be very detrimental to the watershed. 


Although harvest units do not adjoin private property, they do lie within ½ mile of approximately 

630 acres of private land with structures. If fire becomes established in stands of beetle kill and 

there is a heavy surface fuel load, they are very difficult to suppress and can easily move over 

large landscapes before weather conditions change or suppression actions are successful. 




The commenter is correct in noting that the demand for timber is low; according to a November 

5, 2009 news release from the Western Wood Products Association (WWPA), 2009 lumber 

demand declined for the fifth consecutive year, and was at a level not seen since the 1930’s. The 

WWPA sees 2009 as the low point, and is forecasting an 11% increase in lumber demand in 

2010. Though regional and global timber market conditions are beyond the scope of this project, 

it appears likely that sales from the Rio de los Pinos Analysis Area will sell in upcoming years. 


The Rio de los Pinos EIS does not make anticipatory decisions on how harvest units will be 

divided into individual timber sales, these decisions are made in the timber sale preparation 

phase of the project and are based on a multitude of factors, of which salability is included. 


Engelmann spruce deteriorate and fall at an extremely slow rate and will remain marketable for 

many years. According to Schmid and Frye (1977), beetle-killed Engelmann spruce in past 

spruce beetle outbreak areas fell at rates between 1.3% and 1.5% per year, and on some sites 

have found 84% of the Engelmann spruce still standing after 25 years. Decay of Engelmann 

spruce has averaged approximately 1% per year, and after 10 years, 11% of the volume had been 

lost to decay; some trees may remain suitable for certain applications 50 years after infestation 

(Schmid and Frye 1977). After beetle infestation, trees generally remain merchantable for 

sawlogs for 5 years, and trees that have been dead for more than 5 years are usually cut for house 

logs (Schmid and Frye 1977) or timbers. 


As discussed in the DEIS (p. 3-87) and Forest Plan ROD (pp. 22-24) , Rio Grande National 

Forest’s timber program is designed to offer a stable and sustainable supply of wood in 

recognition the tight inter-linkage between the local economy, National Forest lands, and 

industry’s need for dependable sources of wood. The commenter’s suggestion to forego 

treatment in the Analysis Area because 16 MMBF of timber has been sold in areas in the vicinity 

of the Rio de los Pinos Analysis Area is not a viable suggestion to help maintain a stable and 

sustainable supply of timber. 

Forest Service Response to Comments 1-26 thru 1-29: 

Individual soft or wet spots can generally be found in any harvest area, no matter the timing or 

location of the harvest, even when the surrounding stand conditions are considered dry and 

below the plastic limit. These spots are avoided as much as possible, but when experienced, are 

rehabilitated during the close-out of the skid trail. As long as skid trail spacing is maintained at 

an appropriate distance, soil disturbance, which includes soil displacement and puddling (FSH 

2509.18 section 2.2(2), Forest Plan III-10) is kept at or below 15 percent and remains within 

Forest Plan standards. We acknowledge that minor amounts of rutting may occur and have 

included it in our soils analysis in Section 3.7. We agree that a Forest Service employee cannot 

be present every time a unit becomes too wet for operations, but recognize that contract 

provisions prohibit the operation of equipment on wet soils when excessive damage will result 

and provide recourse against contract violations. 




The Forest Service acknowledged, considered, and disclosed the risk of blowdown within the 

harvest units in Section 3.5 of the DEIS. As a result of this comment, a lengthier discussion of 

blowdown risk has been added to the analysis within Section 3.5 of the FEIS. 


The Forest Services has measured and evaluated the presence of snowshoe hare and lynx habitat 

within the project area. The impacts of each alternative upon these resources have been analyzed 

and disclosed in the FEIS and Biological Assessment. This project is in compliance with 

management direction contained in the Southern Rockies Lynx Amendment (2008) including 

Standard Veg S6. Incidental damage to the understory has been estimated (with agreement from 

the US Fish and Wildlife Service), accounted for, and would be refined with post-project 

monitoring. 


Incidental damage is the vegetation removal or damage that results from, but is not the purpose 

of, the harvest operations. Regeneration damage or loss is not the purpose of the harvest, and 

thus is incidental to the operation. Because this is a salvage harvest, it meets exception 3 of 

Forest Plan standard VEG S6. The Forest Service must estimate, evaluate, disclose, and track 

the amount of incidental damage that would result from each alternative. Post-harvest 

monitoring of incidental damage would be implemented under both action alternatives. 


Impacts to Region 2 Sensitive Species (including the boreal toad and northern leopard frog) were 

considered within the Biological Evaluation prepared for this project. Potential habitat for both 

of these species is protected in all action alternatives by the exclusion of wet areas, wetlands, and 

water influence zones from harvest activities. If these species were discovered within the 

Analysis Area, measures would be taken to protect them, as specified in the project design 

criteria. Project design criterion was changed between draft and final to specifically include 

protection for the northern leopard frog. 

Neither the boreal toad nor the northern leopard frog would be expected within the analysis area, 

since none are currently known to occur on the Conejos Peak Ranger District. Therefore, this 

project would not likely impact either species. 


Thank you for the comment. Three toed-woodpeckers were considered within the Biological 

Evaluation prepared for this project. 


Field surveys were conducted for all sensitive plant species with habitat suspected in the analysis 

area. A field reconnaissance was documented in the project biological assessment/biological 

evaluation for plants. No sensitive species were found. 



Forest Service Response to Comments 1-46 thru 1-47 

The project design criteria proposed to protect regeneration from livestock damage (cattle) is 

built on an adaptive management principle. This means that if the starting rangeland 

management tools proposed (FEIS Table 2.5-2) do not work, other tools will be implemented. 

The starting point rangeland management tools are the most reasonable, cost efficient, and least 

intrusive management tools for keeping livestock from damaging regeneration in the analysis 

area. 

Following are reasons why these tools are expected to be sufficient in protecting regeneration 

from livestock damage: 

• One of the tools proposed is to maintain a pasture rotation. This has been normal practice 

for many years. A pasture rotation results in the cattle only being in the pasture which 

contains the analysis area for more or less 25 days a year, along with varying the time of 

year it is grazed. The pasture is large enough that all of the cattle are unlikely to be in the 

analysis area at the same time. 

• Past timber sales adjacent to the analysis area have large amounts of tree regeneration. 

Few, if any, attempts were made to keep livestock out of those areas after harvest. This 

indicates that cattle-grazing has not been a major factor in adversely affecting tree 

regeneration within the area. Therefore, starting with drastic measures is not needed. 

• Current rangeland management is even better than past management on this grazing 

allotment, so response time to correct or makes changes can occur quickly. 

Additionally, the analysis area is a small portion of the entire grazing pasture. The forage within 

the analysis area is not the primary forage for the grazing allotment nor is it used in determining 

the grazing capacity (i.e. the grazing operation is not dependent on the transitory forage that will 

become available after timber harvest). The Forest Service believes the project design criteria 

provide adequate protection for forest regeneration establishment. 


Thank you for the comment. The number on page 1-3 has been corrected. 

Forest Service Response to Comment 1-48a: 

Thank you for the comment. The text has been corrected. 


These concerns are addressed within the Environmental Impact Statement, as well as the 

preceding responses. 


An adequate range of alternatives was analyzed to meet the purpose and need of this project and 

address the Key Issues. Natural processes, such as beetle infestation, were considered as part of 

the No Action alternative. Undeveloped alternatives were also considered in this process and are 

discussed in Section 2.7 of the FEIS. The process used to develop and analyze reasonable 

alternatives is discussed in Section 2.2. How each alternative addresses the purpose and need and 

Key Issues is discussed in Section 2.3-2.4. The action alternatives developed give a full spectrum 



of treatment options which accomplish the purpose and need while addressing Key Issues and 

comply with NEPA direction. 


The DEIS does not discuss risk of blowdown near the Continental Divide Trail because no 

harvesting is proposed near the trail. The CDT is approximately ½ mile upslope and to the west 

of proposed harvest activities. The trail closest to the project is the 736 “Los Pinos” trail, which 

starts at the northern tip of Unit 1. The trailhead is the only trail feature within proximity of the 

harvest area; the trail tracks away from the project. Forest Plan standards are also met for 

retaining wildlife trees within each unit. 


Effects to Canada Lynx have been fully disclosed in the Biological Assessment and Specialist 

Report for Threatened and Endangered Species prepared for this project. There are no 

designated lynx linkage zones within this Analysis Area. Effects upon other species are 

addressed in the Wildlife Biological Evaluation and Specialist Report for Sensitive Species under 

each individual species’ heading. Wildlife corridors were considered in the effects analyses as 

appropriate, and (for some species) no-cut Water Influence Zones are expected to provide a longterm 

contribution to the existence of these corridors within the project area (FEIS section 3.8), 

and between the project area and adjacent areas. Harvest boundaries are approximately 2000’ 

below timberline, which provides additional corridors for wildlife travel. Additionally, the 

Forest Service believes that buffers are not needed along no-cut areas (Wilderness areas, 

Roadless areas, Backcountry, WIZ, etc.). These management prescriptions and resource 

protections provide adequate habitat for wildlife within the respective analysis areas, as 

determined in the FEIS. 


The effects of all alternatives on wildlife habitat were considered for Threatened & Endangered 

Species, Region 2 Sensitive Species, Forest Management Indicator Species, and other wildlife 

species (FEIS section 3.8 to 3.9). Changes in habitat for many species would occur under all 

alternatives, including the no action alternative. Project design criteria have been included for 

both action alternatives to help conserve important habitat attributes. 


The Forest Service already protects wildlife corridors and linkage areas for wildlife passage. See 

response to comment 2-3. The San Luis Valley Public Lands Center has already begun working 

with the states of Colorado and New Mexico regarding this M.O.U., and intends to continue 

involvement as this effort progresses. 


The Forest Service disagrees with this comment. As calculated from Table 2.3.2-1 and Table 

2.3.3-1 (DEIS) and compared to Alternative 2, Alternative 3 decreases road maintenance by 

16.8%, decreases combined road reconstruction by 19.8%, totally eliminates temporary road 

construction, and reduces the length of old road to be temporarily re-opened by 24.2%. The 

comment also fails to acknowledge the No Action alternative, which proposes no road 

reconstruction, temporary road construction, or old road re-opening. Road costs are absorbed by 



timber sales, and most road drainage issues which currently affect the watershed cannot be fixed 

without this revenue. 


The number and location of reopened roads have been carefully chosen to minimize impacts to 

stream and watershed health. The reopened old road segment and new temporary road segment 

in the 7 th level watershed of concern are on dry ridge areas and do not lie within the water 

influence zone. As discussed in the DEIS on page 3-19, a “watershed of concern” designation 

does not preclude new land disturbance within the watershed but does require specific watershed 

analysis prior to any new land-disturbing activities (Dobson, 1996). This EIS provides that 

specific analysis. See also Forest Service Response 1-8 concerning allowed disturbance levels. 

As stated previously, locations of roads to be reopened have been chosen to minimize impacts to 

watershed resources. In addition, strict design criteria regarding roads will further reduce 

sedimentation impacts at stream crossings (FEIS Tables 2.5-5 and 2.5-6). 

Alternative 3 varies from Alternative 2 in that it avoids areas with higher drainage density in the 

southwest portion of the 7 th level watershed of concern and reduces harvest are by 40%. No 

steep slope areas are harvested in this watershed. Overall, Alternative 3 does reduce harvest 

acreage on steep slopes by about 50% in units to the north. 


Patch cuts were incorporated in the action alternatives to meet scenic integrity objectives (FEIS 

section 1.3; table 2.5-8; section 3.5). The affects of these patch cuts on wildlife species were 

fully considered in the analysis (FEIS sections 3.8 to 3.9). Although patch cuts would be 

expected to help improve overall habitat diversity, these particular patch cuts would be very 

similar to the rest of the harvest areas, since trees under 8”dbh would remain uncut. 


The project meets Forest Plan standards and complies with NFMA direction concerning wildlife 

habitat. 

Forest Service Response to Comment 2-9a: 

Please see Forest Service Responses 2-3 and 2-4 concerning wildlife habitat analysis. Various 

wildlife species, including the Boreal Owl, were analyzed for this project (see Biological 

Evaluation). 


The affects of the action alternatives on boreal owls and boreal owl habitat were considered in 

the Biological Evaluation prepared for this analysis, in addition to sections 3.8 and 3.9 of the 

FEIS. All alternatives, including the no action, are anticipated to impact boreal owls due to 

habitat loss to the ongoing beetle infestation. However, the anticipated cumulative effect on the 

species is “May impact individuals, but would not likely contribute to a loss of species viability” 

for all alternatives (FEIS section 3.8). 




Please see Forest Service Response 2-3 concerning wildlife corridors, Response 2-4 concerning 

consideration of impacts to wildlife habitat, and Response 2-10 concerning impacts specific to 

the boreal owl. 


Effects of this project on Birds of Conservation Concern were analyzed in the Migratory Bird 

Report and Biological Evaluation prepared for this project. Forest Plan Standards and 

Guidelines and Migratory bird habitat will change regardless of whether or not this area is 

harvested, due to the large beetle infestation. Project Design Criteria (for Alternatives 2 and 3) 

are in place (Table 2.5-1 in the FEIS) to protect and/or reduce potential impacts to migratory 

birds. 


Determinations and rationale for impacts to viability of R2 Sensitive Species as a result of this 

project have been documented in the Biological Evaluation. Project design criteria (conservation 

measures, see Table 2.5-1 in the FEIS) and Forest Plan Standards and Guidelines will reduce 

impacts to species and help ensure their continued viability. These measures would also help 

protect bird Species of Concern, which have been analyzed in the Migratory Bird report. 


This area is not part of the South San Juan Wilderness; no harvesting is permitted or proposed in 

wilderness areas. The analysis does take in consideration past, present, and future actions in 

determining cumulative impacts to lynx (FEIS section 3.8). See also Forest Service Response 2- 

3 concerning linkage and corridors. The Biological Assessment provides a detailed analysis of 

the anticipated impacts of this project upon Canada Lynx. This project meets the Objectives, 

Standards, and Guidelines in the Southern Rockies Lynx Amendment, which provides current 

direction for the conservation of lynx in this area. 


The removal of timber, the temporary opening of roads, and the increased opportunity for human 

interaction are all considered in section 3.8 of the FEIS, as well as in the Biological Assessment. 

The proposed activities are allowed under the Southern Rockies Lynx Amendment (SRLA) to 

the Forest Plan and are measured against thresholds established within it. The SRLA is a lynx 

conservation plan focused on lynx recovery. Impacts to Region 2 Sensitive Species and 

associated conservation measures were analyzed in the Biological Evaluation for this project. 


Thank you for your comments. These concerns are addressed within the Final Environmental 

Impact Statement, as well as the preceding responses. 

Forest Service Response to Comment 3-1 thru 3-3: 

Thank you for your comments concerning the scope, clarity, and subsequent rating of this 

analysis. 





APPENDIX A 

Maps 

Appendix A – Maps Page A-1

µ 

Unit 1 

Unit 4 

Unit 3 

Rio de Los Pinos - Alternative 2 

118.2D 

118.2E 

!B 

118.2F 

118.1J 

Unit 5 

D D D D D 

118.2G 

D 

118.2 

Unit 2 

118.2D 

118.1K 

118.2 

0 0.125 0.25 0.5 0.75 1 

Miles 

Legend- Alternative 2 

!B Proposed Trailhead Location- FST 736 

D D System Road Decommissioned 

Temporary Road 

Old Road Re-opened 

System Road Converted (Post-activity) 

System Road Used 

Harvest Exclusions 

Small Group Cuts 

Salvage Units 

Rio de los Pinos Analysis Boundary 

To Hwy 17 

Cumbres Pass 

Rio de los Pinos FEIS 



M.J.M. 03/2010 

118.1C 

A-2

µ 

Unit 3 

Unit 4 

Rio de los Pinos - Alternative 3 

118.2D 

118.2E 

!B 

118.2F 

Unit 5 

D D D D D 

118.2G 

D 

Text 

Legend- Alternative 3 

118.2 

Unit 2 

118.2D 

!B Proposed Trailhead Location- FST 736 

D D D System Road Decommissioned 

Old Road Re-opened 

System Roads Used 

System Road Converted (Post-activity) 

Harvest Exclusions 

Small Group Cuts 

Salvage Units 

Rio de los Pinos Analysis Boundary 

0 0.125 0.25 0.5 0.75 

Rio de los Pinos FEIS 


1 Conejos Peak Ranger District 

Miles M.J.M. 3/2010 

118.2 

To Hwy 17 

Cumbres Pass 

118.1C 

A-3


APPENDIX B 

Bibliography 

Alexander, Robert. 1987. Ecology, Silviculture, and Management of the Engelmann Spruce- 

Subalpine Fir Type in the Central and Southern Rocky Mountains. Forest Service 

Agriculture Handbook No. 659, pp 12-14; pp 47-49. 

Baker, William L. and Thomas T. Veblen. 1990. Spruce Beetles and Fires in the Nineteenth- 

Century Subalpine Forests of Western Colorado, U.S.A. Artice and Alpine Research, vol. 

22, no. 1. pp 65-80. 

Bebi, Peter, et al. 2003. Interactions Between Fire and Spruce Beetles in a Subalpine Rocky 

Mountain Forest Landscape. Ecology, vol. 84. 10p. 

Biedleman, C. 2000. Partners in Flight Land Bird Conservation Plan, Colorado. 

http://www.blm.gov/wildlife/plan/pl-co-10.pdf. Estes Park, CO. 320p. 

BLM. 1988. Use of Winged Subsoiler in Ameliorating Compacted Clayey Forest Soils. Eugene 

District, BLM, USDI. 13 P. 

Cafferata, P. H. and T.W. Sutfin, 1991. Impacts of Ground-based Logging Skidding on Forest 

Soils in Western Mendocino County 

Carlson, Joan. 2008. Potential Risks and Impacts to Soil and Water Resources from Mountain 

Pine Beetle Mortality, Treatments and Wildfire in Colorado and Wyoming National Forests. 

40p. 

Carr, W. 1989. An Evaluation of Forest Soil Tillage Using the Winged Subsoiler on landings in 

the Prince george Forest District. Ministry of Forests, Victoria, B.C. 20p. 

Dobson, Les. 1996. Watershed Assessment: A White Paper for Forest Plan Revision. 8p. 

Dobson, Les. 2005. Effectiveness Monitoring Report: Rio Grande National Forest. 11p. 

Dunstar, Julian and Katherine. 1996. Dictionary of Natural Resource Management. Pp 144-145. 

Finch, D.M. and P.W. Stangel. 1993. Introduction, Pp. 1-4 in D.M. Finch and P.W. Stangel, eds; 

Status and Management of Neotropical Migratory Birds; 1992 September 21-25, Estes park, 

CO. USDA Forest Service General Technical Report RM-229, Rocky Mountain Forest and 

Range Experiment Station, Fort Collins, CO. 

GAO. 1998. United States General Accounting Office. Forest Service: Distribution of Timber 

Sales Receipts, Fiscal Years 1995 through 1997. GAO/RCED-99-24. 

Holsten, E.H., R.W. Their, A.S. Munson and K.E. Gibson. 1999. Forest insect and disease 

leaflet 127, the spruce beetle. United States Department of Agriculture, Forest Service. 

Washington, D.C. 6p. 

Hopkins, A.D. 1909. Barkbeetles of the Genus Dendroctonus. USDA Bureau of Entomology 

Bulletin No. 83, Part I. 7p. 

Kolka, R.K. and M. F. Smidt. 2004. Effect of road amelioration techniques on soil bulk density, 

surface runoff, sediment transport, soil moisture, and seedling growth. Forest Ecology and 

Management 202(2004) p 313-323. 

Lynch, Dennis L. and Kurt Mackes. 2001. Wood use in Colorado at the turn of the twenty-first 

century. Research Paper RMRS-RP-32. Fort Collins, CO; U.S. Dept. of Agric., Forest 

Service, Rocky Mountain Research Station. 23p. 

Mehl, Mel S. 1992. Old-Growth Descriptions for the Major Forest Cover Types in the Rocky 

Mountain Region. 16p. 

Appendix B -- Bibliography Page B-1


Ohlander, C.A. [Unpublished, 1996]. Clean Water Act: Monitoring and Evaluation; Part 7. 

Stream Health. T-Walk Course Workbook. pp 54-55, 76-77. 

Rocky Mountain Region, USDA Forest Service. 2006. The Role of Timber Sales in Managing 

Forest Vegetation: A Strategy for Achieving Resource Objectives. Sept. 2006. 

Romme, W.H. et al. 2006. Recent Forest Insect Outbreaks and Fire Risk in Colorado Forest: A 

Brief Synthesis of Relevant Research. 24p. 

Rosgen, Dave. 1996. Applied River Morphology. pp 4-4 to 4-5, 5-6. 

Schmid, J.M. and R.H. Frye. 1976. Stand Ratings for Spruce Beetles. USDA Forest Service 

Research Note RM-309. 4p. 

Schmid, J.M. and R.H. Frye. 1977. Spruce Beetle in the Rockies. USDA Forest Service GTR- 

RM-49, pp 23-24. 

Shenk, T.M. 2007. Post Release Monitoring of Canada Lynx (Lynx Canadensis) Reintroduced 

to Colorado. Colorado Division of Wildlife. 57p. 

Sherriff, Rosemary L. et al. 2001. Fire history in high elevation subalpine forests in the 

Colorado Front Range. Ecoscience, vol. 8, no. 3. pp 369-380. 

Smith, David M. et al. 1997. The Practice of Silviculture. pp 92-93, 196-197, 474-475. 

State of Colorado. 2003. Department of Treasury Statement of Federal Land Payments. Report 

Control Number 1487. 









Terborgh, J. 1992. Perspectives on the conservation of Neotropical migratory birds. Plenary 

Address, Pp. 7-12 in J.M. Hagan III and D.W. Johnston, eds.; Ecology and Management of 

Neotropical Migrant Landbirds. Papers from the Symposium on Ecology and Conservation 

of Neotropical Migrant Landbirds, December 6-9 1989, Woods Hole, Massachusetts. 

U.S. Census Bureau. 2000. Quick Tables. DP-4. Profile of Selected Housing Characteristics: 

2000. Conejos County, Colorado. Accessed on 03/17/2008. 3p. 

U.S. Census Bureau. 2008. State and County Quickfacts: Conejos County, Colorado. Accessed 

on 03/17/2008. 3p. 

USDA Forest Service. 1996. Draft Soil Resource and Ecological Inventory for the Rio Grande 

National Forest-West Part. pp 3-92 to 3-94. 

USDA Forest Service FSH 2509.18 - SOIL MANAGEMENT HANDBOOK, R2 Supplement 

No. 2509.18-92-1. August 15, 1992. 3p. 

USDA Forest Service Handbook FSH 2509.18 - SOIL MANAGEMENT HANDBOOK, 41p. 

USDA Forest Service Handbook FSH 2509.25- WATERSHED CONSERVATION 

PRACTICES HANDBOOK. 62p. 

USDA Forest Service. 2003. Species assessments; management indicator species. Rio Grande 

National Forest. Unpublished internal document. 

USDA Forest Service. 2004. Biological Assessment for County Line Timber Sale. Rio Grande 

National Forest. Unpublished internal document. 



USDA Forest Service. 2005. Migratory bird assessment for the Rio Grande National Forest. 

Unpublished internal document. 

USDI Fish and Wildlife Service. 2002. Birds of conservation concern. U. S. Fish and Wildlife 

Service Division of Migratory Bird Management. Arlington, VA. 

USDA Forest Service and USDI Fish and Wildlife Service. [Unpublished, 2009]. 

Implementation Guide to the Southern Rockies Lynx Amendment. Tab 7a, pp 1-4. 

Veblen, Thomas T. et al. 1994. Disturbance Regime and Disturbance Interactions in a Rocky 

Mountain Subalpine Forest. Journal of Ecology, vol. 82, issue 1. pp 125-135. 

Webb, Robert H. et al. 2004. Climatic Fluctuations, Drought, and Flow in the Colorado River. 

USGS Fact Sheet 3062-04. 16p. 

Annotated Bibliography 

References provided by the public to be considered in analysis. 

USDA Forest Service. 1998. Peatlands on National Forests of the Northern Rocky Mountains: 

Ecology and Conservation. Rocky Mountain Research Station, General Technical Report 

RMRS-GTR-11. 





C.1 Terms and Definitions 

APPENDIX C 

List of Terms and Acronyms 

Artificial Regeneration: A group or stand of young trees created by direct seeding or by planting seedlings or 

cuttings. 

Decommission: To remove a road from active service and further use. At a minimum decommissioning involves 

reestablishing former drainage patterns, stabilizing slopes, and restoring vegetation. 

Desired Conditions: A set of ideal conditions established for a Management Area Prescription within the Forest 

Plan. These conditions are the goals for the Management Area and the intended end results for all actions taken 

within it. Desired Conditions for each specific Management Area Prescription are outlined in Chapter IV of the 

Revised Land and Resource Management Plan of the Rio Grande National Forest. 

Existing Scenic Integrity: The status of the landscape and the degree to which it has been altered. This is a 

baseline measurement for Scenic Resources. The following is a list of the Scenic Integrity Levels: 

-Type I (Natural Appearing Landscapes) - areas in which only ecological change has taken place except for 

trails needed for access. They appear untouched by human activities. This includes wilderness and primitive 

areas. 

-Type II (Slightly Altered Appearing Landscapes) - areas where some human activity has occurred. Usually 

these areas can be described as near natural appearing or slightly altered. 

-Type III (Altered Appearing Landscapes) - areas where human modification has occurred and is obvious. 

Usually these areas are described as altered. 

Fen: Geographically restricted wetlands where perennial groundwater discharge occurs on the time scale of 

millennia and where little erosion or mineral sediment deposition occurs. Fens are generally characterized by their 

stable presence on the landscape for thousands of years and associated plant and animal communities that may be 

relics from historic glaciation periods. 

Habitat Structural Stage: A tree-size and canopy closure classification for forested cover types defined as 

follows: 

Structure 

Class 

Habitat 

Structural 

Stage 

Description 

1 1 & 2 GRASS/FORB/SHRUB/SEEDLING. Stand dominance by grasses, forbs (broadleaved 

herbaceous plants), shrubs and/or tree seedlings up to 1” DBH for softwoods 

and 2” DBH for hardwoods. 

2 3a SAPLING/POLE. Stand dominance by trees in the majority of the 1-8.9” DBH size 

for softwoods and 2-8.9” DBH for hardwoods with a canopy closure of less than or 

equal to 40%. 

3 3b & 3c SAPLING/POLE. Same as Structure Class 2 except canopy closure is 41-100%. 

4 4a MATURE. Stand dominance by trees in the majority of the 9” or larger DBH size 

and tree age under 200 years for softwoods and under 100 years for hardwoods. 

Canopy closure is 40% or less. 

5 4b, 4c, & 5 LATE-SUCCESSIONAL FOREST. Two conditions are possible for meeting this 

category: 

a) Stand dominance by trees in the majority of the 9” or larger DBH size and 

Appendix C -- Terms and Acronyms Page C-1


tree age under 200 years for softwoods and under 100 years for 

hardwoods. Canopy closure is greater than 40%. 

b) Stand dominance by trees in the 5” DBH or greater size with tree age over 

200 years for softwoods and over 100 years for hardwoods. Tree crown 

cover is over 70%. 

Indicator: A measurement of a resource quantity or quality, which is linked to a cause-and-effect relationship and 

responsive to a Key Issue. Indicators are used to compare the effects among alternatives, and are most generally 

quantitative, rather than qualitative, in measure. 

Key Issue: A concern expressed over the potential effects of a proposed action on the human environment, due to 

the geographic extent, duration, or intensity of interest or resource conflict. Key Issues are used to develop and 

compare alternatives, prescribe mitigation measures, and analyze the environmental effects. For an issue to be 

considered Key, it must be relevant to the specific project and appropriately addressed at that level. 

Landscape Character: An overall visual and cultural impression of landscape attributes; the physical appearance 

and cultural context of a landscape that gives it an identity and “sense of place.” It includes existing land use 

patterns, ecological unit descriptions, and existing landscape character descriptions. 

Landtype Association: An ecological mapping unit based on similarities in geology, soils, and plant associations. 

Repeatable patterns of soil complexes and plant communities are useful in delineating map units. LTAs are an 

appropriate ecological unit to use in Forest- or area-wide planning and watershed analysis. On the RGNF, soil 

mapping units were aggregated into 13 distinct LTAs. 

Long-Butt: A section cut from the bottom log of a tree and culled because of rot or other defect. 

Natural Regeneration: The establishment of a plant or a plant age class from natural seeding, 

sprouting, suckering, or layering. 

Non-system Road: Also termed “Unclassified Roads.” Roads on National Forest System lands that 

are not managed as part of the forest transportation system, such as unplanned roads, abandoned 

travelways, and off-road vehicle tracks that have not been designated and managed as a trail; and those 

roads that were once under permit or other authorization and were not decommissioned upon the 

termination of the authorization (36 CFR 212.1). 

Noxious Weeds: A plant specified by law as being especially undesirable, troublesome, and difficult to control. 

Reforestation: The re-establishment of forest cover, either naturally or artificially. This process usually maintains 

the same forest type and is done promptly after the previous stand or forest was removed. 

Road Maintenance: The ongoing upkeep of a road necessary to retain or restore the road to the approved road 

management objective (FSM 7712.3). 

Road Construction (New): Activity that results in the addition of forest classified or temporary road 

miles (36 CFR 212.1). 

Road Reconstruction: Activity that results in improvement or realignment of an existing classified road as defined 

below: 

-Road Improvement - Activity that results in an increase of an existing road’s traffic service level, expands its 

capacity, or changes its original design function. 

-Road Realignment - Activity that results in a new location of an existing road, or portions of an existing road, 

and treatment of the old roadway (36 CFR 212.1). 

Road Spot Reconstruction: Road reconstruction activities on very short sections of road. Generally involve 

activities such as culvert replacement and surface rock replacement. 



Sanitation/Salvage: The removal of trees that are a) under attack or potentially under attack of insects or disease, 

or b) recently dead—for the purpose of minimizing current or future loss of wood products. 

Scenic Integrity Objectives: measures how much human alteration can deviate from the existing landscape 

character being viewed. The following is a list of the Scenic Integrity Objectives: 

-Very High Preservation – refers to landscapes where the valued landscape character is intact with only minute if 

any deviations. 

-High Retention – refers to landscapes where the valued landscape character appears intact. Deviations may be 

present but must repeat the form, line, color, texture, and pattern common to the landscape character so 

completely and at such scale that they are not evident. 

-Moderate Partial Retention – refers to landscapes where the valued landscape character appears slightly altered. 

Noticeable deviations must remain visually subordinate to the landscape character being viewed. 

-Low Modification – refers to landscapes where the valued landscape character appears moderately altered but 

they borrow valued attributes such as size, shape, edge effect, and pattern of natural openings, vegetative type 

changes or architectural styles in the surrounding landscape. 

-Very Low/Maximum Modification – refers to landscapes where the valued landscape character appears heavily 

altered but may not borrow from valued attributes such as size, shape, edge effect, and pattern of natural 

openings, vegetative type changes, or architectural styles within or outside the surrounding landscape. 

Structure Class: A classification of forested cover types which aggregates Habitat Structural Stage into broader 

categories. 

Silvicultural system: A planned series of treatments for tending, harvesting, and re-establishing a stand. The 

system name is based on the number of age classes (i.e. even-aged, two-aged, uneven-aged) or regeneration method 

(i.e. clear-cutting, seed tree, shelterwood) used. 

System Roads: Also termed “Classified Roads.” Roads wholly or partially within or adjacent to 

National Forest System lands that are determined to be needed for long-term motor vehicle access, 

including State roads, county roads, privately owned roads, National Forest System roads, and other 

roads authorized by the Forest Service (36 CFR 212.1). 

Temporary Road: A road needed to access timber for the current project but not needed for long term resource 

management. 

Trap Tree: A log or tree felled or treated in a manner to invite insect infestation, particularly bark beetles. 

C.2 Acronyms 

AOI – Annual Operating Instructions 

AMP – Allotment Management Plan 

CDT – Continental Divide Trail 

CEQ – Council on Environmental Quality 

DBH – Diameter at Breast Height 



DEIS – Draft Environmental Impact Statement 

DN – Decision Notice 

FEIS – Final Environmental Impact Statement 

FSR – Forest System Road 

FST – Forest Service Trail 

IDT – Interdisciplinary Team 

LTA – Landtype Association 

LAU – Lynx Analysis Unit 

MAP – Management Area Prescription 

MBF – Thousand Board Feet 

MIS – Management Indicator Species 

MMBF – Million Board Feet 

NEPA – National Environmental Policy Act 

NFMA – National Forest Management Act 

PDC – Project Design Criteria 

RGNF – Rio Grande National Forest 

TES – Threatened or Endangered Species 

WIZ – Water Influence Zone 



APPENDIX D 

Disturbances by Watershed 

Water Pollution Sources (Safeguarded) Water Pollution Sources (Safeguarded) 

GEOPHYSICAL MODIFICATION 130100050501 GEOPHYSICAL MODIFICATION 130100050501 

Agriculture Silviculture 

Irrigated crops Regen, new cut, no recvry CC 

Dry land crops Regen,< ¼ hydric recvry CC 

Fragile range lands, poor condition 10.0 Regen, ¼ to < ½ h. recrvy CC 186.0 

Durable range lands, poor condition Regen, ½ to < ¾ h, recrvy CC 

Corridors Regen, ¾ & > hydrl. recvry CC 

Buried pipelines Regen, new cut, no recvry PC 506.97 

Canals & ditches Regen,< ¼hydric recvry PC 1002.5 

Deforestation Regen, ¼ to < ½ h. recrvy PC 954.2 

Forest to burn Regen, ½ to < ¾ h, recrvy PC 295.0 

Forest to grass Regen, ¾ & > hydrl. recvry PC 

Brush to grass Salvage Operations 

Vegetation to non-vegetation Non-regenerated 

Heavy use sites Water collection/transfer 

Outdoor recreation 129.0 Stream flow decreased 

Residential/business 144.0 Stream flow increased 

Rural subdivision Historic channel “drives” 

High hazard lands Historic flood effects 

Chronic wind erosion Operations, spills & flush 

Severe O.M & nutrient loss Channelized/straightened 

Mass Failure: active Water storage surface 

“High” hazard potential Natural lakes & ponds 28.0 

“Moderate”hazard potential Stock ponds 

Gullies & Severe sheet erosion Impound W/pernent wtr level 75.0 

Mining, milling, & mfg sites Impound W/seasonal drawdown 

Active metallic sites Impound W/rapid fluctuations 

Active non-metallic sites Wetlands & Riparian altered 

Abandoned metallic sites Water level lowered 

Abandoned non-metallic sites High water table induced 2.0 

Roads & trails 310.7 Sites filled or drained 

Tree cover reduced/removed 

Brush cover reduced/removed 15.0 

Soil infiltration reduced 

Watershed Acreage 11,420 

Appendix D – Watershed Disturbance Page D-1


Water Pollution Sources 

(Safeguarded) 

Water Pollution Sources 

(Safeguarded) 

GEOPHYSICAL MODIFICATION 

Watershed 

13010005050101 GEOPHYSICAL MODIFICATION 

Agriculture Silviculture 

Irrigated crops Regen, new cut, no recvry CC 

Dry land crops Regen,< ¼ hydric recvry CC 

Fragile range lands, poor condition Regen, ¼ to < ½ h. recrvy CC 

Durable range lands, poor condition Regen, ½ to < ¾ h, recrvy CC 

Corridors Regen, ¾ & > hydrl. recvry CC 

Buried pipelines Regen, new cut, no recvry PC 97.97 

Canals & ditches Regen,< ¼hydric recvry PC 200.53 

Deforestation Regen, ¼ to < ½ h. recrvy PC 148.17 

Forest to burn Regen, ½ to < ¾ h, recrvy PC 

Forest to grass Regen, ¾ & > hydrl. recvry PC 

Brush to grass Salvage Operations 

Vegetation to non-vegetation Non-regenerated 

Heavy use sites Water collection/transfer 

Outdoor recreation Stream flow decreased 

Residential/business Stream flow increased 

Rural subdivision Historic channel “drives” 

High hazard lands Historic flood effects 

Chronic wind erosion Operations, spills & flush 

Severe O.M & nutrient loss Channelized/straightened 

Mass Failure: active Water storage surface 

“High” hazard potential Natural lakes & ponds 

“Moderate”hazard potential Stock ponds 

Gullies & Severe sheet erosion Impound W/pernent wtr level 

Mining, milling, & mfg sites Impound W/seasonal drawdown 

Active metallic sites Impound W/rapid fluctuations 

Active non-metallic sites Wetlands & Riparian altered 

Abandoned metallic sites Water level lowered 

Abandoned non-metallic sites High water table induced 

Roads & trails 64.3 Sites filled or drained 

Tree cover reduced/removed 

Brush cover reduced/removed 

Soil infiltration reduced 

Watershed Acreage 1,064 

Appendix D – Watershed Disturbance Page D-2 

Watershed 

13010005050101


E.1 Introduction 

APPENDIX E 

Public Comments 

This appendix contains the actual public comments received. Annotation is added to comments 

for the purpose of categorizing and referencing public comments to the Response Section 

(Chapter 6). 

We received three letters in response to the Draft Environmental Impact Statement. These letters 

are assigned numbers 1 through 3. Each comment within a letter is assigned a unique identifier. 

The first number in the identifier represents the letter received; the second number represents the 

comment location within that letter. For example, Comment 1-2 is the second comment in letter 

1. 

Readers can cross-reference letters and comments to the Forest Service Responses in Chapter 6 

by utilizing the unique identifiers. 

Appendix E – Public Comments Page E-1

Jack Lewis 

Conejos Peak RD 

15571 CR T.5 


via e-mail: comments-rocky-mountain-rio-grande@fs.fd.us 

January 13, 2010 

Dear Mr. Lewis, 

The following are the comments of Colorado Wild and WildEarth Guardians on the proposed 

Rio de los Pinos Project, as described in the draft environmental impact statement (DEIS). 

After reviewing the project, we believe it should not be implemented, or at least it must be 

greatly reduced in size before approval. 

I.. MUCH OF THE PROJECT AREA IS SO WET THAT SIGNIFICANT IMPACTS TO 

AQUATIC RESOURCES AND SOILS WOULD BE UNAVOIDABLE. 

According to the DEIS, 50.7 percent of the 7 th level watershed of concern within the analysis 

area is in the water influence zone (WIZ). DEIS at 3-19. Heavy equipment used in logging 

(harvesters, tractors, etc.) would cause considerable damage if used in wet areas. Thus this would 

be a good area to stay out of altogether. 

However, logging is proposed throughout the project area and appears to cover more than 50 

percent of the project area. See Alternative 2 map at DEIS p. A-2. The 7 th level watershed 

appears to include proposed treatment units 4 and 5. Compare DEIS map A-2 with Figure 3.6-1, 

p. 3-13. Logging proposed in these units would unquestionably cover more than 50 percent of 

the land within them. It would be impossible to log this area as proposed and stay completely out 

of the WIZ. It is not even clear that proposed logging would stay away from fens. Compare map 

at DEIS at 3-29 showing fens with the map of Alternative 2 (DEIS at A-2). 

The Forest Service has a strong policy for protecting fens, which states, in part: 

The U.S. Fish and Wildlife Service, Mountain-Prairie Region, has made 

conservation and protection of fens one of their wetland priorities… Furthermore, 

the Mountain-Prairie Region has determined that all functioning fens fall within their 

Resource Category 1. This means that the goal is no loss of existing habitat value, 

and that every reasonable effort should be made to avoid impacting these habitats. 

Mitigation for loss of fens is problematic, as there are no known methods to create 

new functional fens. 

Colorado Wild/Rocky Smith ◊ 1030 Pearl St. #9 ◊ Denver, CO 80203 

www.coloradowild.org

Colorado Wild Page 2 

R-2 Fen Policy, March 19, 2002. It is clear the damage to fens is essentially irreversible. See 

USDA Forest Service, 1998 at 31. 

The DEIS claims that there would be only minimal impacts to watersheds if Forest Plan 

standards and guidelines and project design criteria are followed. DEIS at 3-23. One important 

criterion is to keep activity 100 feet away from the WIZ. See DEIS at 2-11, 3-24. However, if 

more than 50 percent of the 7 th level watershed is in the WIZ, it would be impossible to log more 

than 50 percent of it as proposed and still stay 100 feet way from the WIZ. 

In unit 4, there is riparian vegetation in “wet seepage” areas more than 100 feet from the nearest 

stream. DEIS at 3-18. A such, these and other parts of the project area may be classifiable as 

wetlands. We find no discussion of this in the DEIS. The Forest Service must ensure that 

qualified experts carefully check to see if any parts of the project area are wetlands. Any such 

areas must be avoided. The Clean Water Act’s allowance of wetland modification for normal 

silvicultural activities without 404(b)(1) permits (33 U. S. C 1344(f)(1)(E)) does not apply if 

“modifications of the hydrological regime are necessary to resume operations”. 33 U. S. C. 

1344(f)(2) and 33 CFR 323.4(a)(1)(ii). 

With death of overstory spruce, less soil moisture would be taken up by trees. Though existing 

trees would grow faster and use more water, there still might be an overall increase in soil 

moisture, meaning the area would be even more wet than it now is, making it even more difficult 

to avoid wet areas during operations. This condition occurred on the Flattops after the spruce 

beetle epidemic of the 1940s. 

Another measure suggested to reduce impacts is to log over snow or frozen soils. DEIS at 3-31. 

However, a design criterion prohibits operations from December 15 to April 1 to minimize 

conflicts with recreation. Id. at 2-12. This would not leave much time each season for logging 

over snow or frozen soils, as such logging could be done only with at least two inches of frozen 

soil or one foot of packed snow. Id. at 2-11. In some winters, there would not be a foot of packed 

snow before December 15. And in spring, heavy snow plowing would be required, and plowed 

roads would be very wet and get damaged from vehicle use creating deep ruts. The DEIS states 

that logging from April to June is unlikely due to wet soil conditions. DEIS at 3-37. 

Under the Forest Service’s Watershed Conservation Practices Handbook (WCPH) actions are 

limited in wet areas: 

In the water influence zone next to perennial and intermittent streams, lakes, and 

wetlands, allow only those actions that maintain or improve long-term stream health 

and riparian ecosystem condition. 

WCPH, FSH 2509.25, section 11.2. 

It is hard to imagine how the proposed action could improve stream health, with operations in the 

WIZ. Notably, design criterion 1a3 under this management measure prohibits the use of heavy 

equipment in “streams, swales, and lakes”, except to cross streams at “designated points”. See 

also WCPH design criterion 1a in section 12.4. 

Printed on recycled paper with at least 30% post-consumer content.


Under alternative 2, the total disturbance in the 7 th level watershed of concern would be 18 

percent. DEIS at 3-23. Given the very wet nature of this area, it is likely that much of this 

disturbance would be detrimental to soils, as heavy equipment will easily compact or displace 

wet soils. This detrimental disturbance is well over the maximum 15 percent of any area that can 

have detrimental impact under the Region 2 Soil Management Handbook, FSH 2509.18, section 

2.2 (3). Indeed, the disturbance in this watershed is already 14 percent, and will rise to 16 percent 

once two currently active timber sales are completed. DEIS at 3-19. The Soil Management 

Handbook prohibits operations in such areas that would increase detrimental impacts: 

If a standard is exceeded in an initial entry, future entries must have no additional 

detrimental effect unless mitigative measures have been applied or natural recovery 

has taken place between entries. 

Soil Handbook at 2.2 (4). 

Adding to the problems would be the proposed treatment on 45 acres on steep slopes, those 35 to 

40 percent steep. DEIS at 2-3. 1 

Mass movement potential is high in the project area (id. at 3-28), 

including areas near Road 118.1C (id. at 3-19) . There should be no operations on or across steep 

slopes. Any mass soil movement would likely add sediment to water courses and would be a 

permanent adverse impact o soils. 

The DEIS states that “[r]oads are a concern in [the sixth level] watershed”. DEIS at 3-14. Road 

density is high, with a concentration in the southwest half of the area. Id.; see also DEIS Figure 

3.6-1 at p. 3-13. Under the proposed action, there would be considerable roadwork – 6.7 miles of 

reconstruction, 3.4 miles of “spot” reconstruction, 11.9 miles of road maintenance, 3.3 miles of 

reopening old roads, and 0.2 miles of new temporary road construction. See DEIS at 2-3. 

Since the closed roads have good vegetative cover (DEIS at 3-14; see also id. at 3-25), the effects 

of reopening them might be more like new construction. Certainly if they are now having a 

minimal effect on streams at road-stream crossings as stated (id.), this impact would greatly 

increase if they are reopened because several segments to be reopened are within 100 feet of 

streams. DEIS at 3-25. 

It is thus not clear that the project would minimize connected disturbed area, as required by the 

WCPH: 

In each watershed containing a 3-rd (sic) order and larger stream, limit connected 

disturbed areas so the total stream network is not expanded by more than 10%. 

Progress toward zero connected disturbed area as much as practicable. 

WCPH, FSH 2509.25, section 11.1, design criterion 1a. We do not find a discussion of 

connected disturbed area in the DEIS. 

1 Notably, we do not see any discussion of the impacts of this in the DEIS. 



In sum, it is highly unlikely that the proposed logging could take place without considerably 

adverse effects on watersheds and soils. Thus at a bare minimum, units 4 and 5 must be dropped, 

and logging reduced in the other proposed units. 

II. LOGGING IS NOT NEEDED IN THE PROJECT AREA. Even if logging could be done 

without damaging soils and watersheds, there is no need to log in the area. 

A. REFORESTATION WOULD OCCUR WITHOUT LOGGING BUT MIGHT NOT 

OCCUR VERY WELL AFTER LOGGING. Part of the need for the project is said to be 

reforesting areas “severely impacted by spruce beetle”. DEIS at 1-4. There is already a fairly 

dense understory of trees throughout the area. DEIS at 3-38. 2 

In other words, the future forest is 

already there. As spruce trees die from bark beetle attack and shed their needles, the understory 

will be released and grow faster, forming a new forest. 

Logging, however, would destroy much of this understory. Felling and skidding would break or 

uproot many seedlings. Larger trees in the understory could be damaged during operations. 

Indeed, some regeneration would be deliberately destroyed to reach trees targeted for removal. 

See DEIS at 3-64, which says that fir trees and trees less than eight inches in diameter “will be 

removed to access larger diameter standing trees“. 

Not entering the area would protect existing regeneration. By the time a sizable number of the 

dead standing spruce begin to fall, probably 50 years or so from now, the currently small trees 

will be large enough to resist much of the damage they might otherwise receive from falling 

trees. The down spruce will quickly begin to deteriorate in the wet soils, which would by then be 

shaded considerably by the new forest. The rotting logs might provide a good seedbed for 

regeneration then. See DEIS at 3-31. 

Attempts at reforestation after logging, particularly in the proposed patch cuts, will have a high 

failure rate. Englemann spruce is difficult to regenerate because it needs shade in the early years 

to prevent desiccation and death from too high a dose of ultraviolet radiation. Previous clearcuts 

in and near the project area have not regenerated, or have only partially regenerated. See DEIS 

Appendix D. 

We do not believe that retention of light logging slash would increase regeneration success. In 

spite of what is stated, we do no see how such material would “protect[ seedlings] from 

excessive sunlight, extremes of temperature, desiccation, and grazing animals” DEIS at 3-11. 

Logs with a pretty good diameter (at least several inches) would be needed to provide shade and 

other protection for seedlings. A substantial amount of such material would be needed to protect 

existing and any future regeneration. Such an amount would probably not a constitute a “light” 

accumulation of slash. 

Regeneration after logging would require planting. Intuitively, planting would be most needed in 

the patch cuts, as these would be clearcuts, meaning there would be no shade from standing trees 

2 The Table on this page shows more than 1000 less than eight inches in diameter in all proposed logging units. Page 

3-63 states that there are an average of 750 seedlings per acre. 



to help provide areas capable of regeneration. Page 3-10 shows 74 acres of anticipated planting, 

all in units 3-5, with the large majority in unit 5. But DEIS p. 2-3 shows 74 acres of patch cuts, 

almost all of it in units 1-3. In other words, the units with the most patch cutting are least likely 

to need planting, except for unit 3. This does not make sense. If planting is needed in non-patch 

cut areas, regeneration throughout the project area would be even more difficult because 

regeneration failures in patch cut areas are more likely, and the overall success of regeneration 

via planting is thus far from assured. 

B. LOGGING IS NOT NEEDED TO REDUCE THE FUTURE THREAT OF FIRE. A need 

for the project is said to be to reduce fuel build up. DEIS at 1-4. However, fires are rare in wet, 

high-elevation areas like the project area. See DEIS at 3-89, 3-90. 

Also, once spruce trees attacked by bark beetles die and lose their needles, there is very little 

opportunity for a crown fire to spread because there is no way for fire to jump between standing 

dead trees. See DEIS at 3-88. 

Spruce there were sound when killed by beetles (i. e., have no root or heart rot) are likely to 

remain standing for decades. When they do fall to the ground, they will begin to decay quickly, 

as soils are wet in the area, and snow covers the area for the majority of the year. See DEIS at 3- 

91, which notes that slash quickly becomes part of the duff layer; i. e., former woody debris soon 

decomposes. As discussed above in subsection A, existing regeneration would by then be 

sufficient to shade much of the ground, preventing it from thoroughly drying out except during 

extended drought periods. 

Finally, there is little private land in the immediate vicinity, so fuel reduction effort in the project 

area is not needed to protect human habitation. 

C. DEMAND FOR TIMBER IS LOW, THUS THE SALE MAY NOT SELL OR BE 

IMPLEMENTED IN A TIMELY MANNER. Currently, the demand for timber is quite low, due 

to the recessed state of the economy. Housing starts are very low, so demand for dimension 

lumber, which would be the most likely product from the project area, is especially low. 

Also, there is probably only one mill that could handle the large volume proposed for offering 

from the project area. That mill, Intermountain, in Montrose, may not be able to take on another 

large sale like Rio de los Pinos. Alternatively, it might have to forgo implementing other sales to 

harvest the wood in Rio de los Pinos. We do not see how offering the large proposed volumes 

under the action alternatives (8 to 13.1 million board feet) would allow the small mills in the San 

Luis Valley to compete for resources, as suggested at DEIS p. 3-87. These mills could simply not 

handle the large sales that would be offered from the project area. 

Thus it may not be possible to get timber from the project area on the market before decay 

eliminates any wood product value, as is the intent of the proposed action. DEIS at 3-11. 



D. WOOD CAN BE PRODUCED IN OTHER AREAS. There is no need to enter the Rio de 

los Pinos project area to produce wood. As discussed above, demand is currently very low, so 

any sales might not sell, or if they did sell, the wood might not get to the mill before it 

deteriorates to a point where it cannot be made into any salable wood product. Also, there are 

three active or prepared sales that can provide a volume of 16 MMBF in the vicinity of the 

proposed project area. DEIS at 3-87. 

III. PROTECT SOILS. The project area receives a considerable amount of snowfall and a 

moderate amount of rain in the summer. In many years, snow does not melt until well into July, 

thus the area is frequently wet. Soil impacts from the use of heavy equipment during periods 

when soils are wet can be severe, as natural healing of soil compaction and displacement would 

take a very long time at this cold location, which has a short growing season. 

A design criterion addresses this: 

Operate heavy equipment for land treatments only when soils are dry, soil moisture 

is below the plastic limit, or protected by at least 1 foot of packed snow or 2 inches 

of frozen soil. Wet weather operations shall be monitored and if soils become 

excessively wet (as defined in the Forest Plan as exceeding the plastic limit), then 

operations will be suspended until such time as soils become operable again. 

DEIS at 2-11. 

However, it is clear that this criterion has not been followed in operations in the adjacent County 

Line Sale. See exhibits 1 and 2, attached to these comments. These photos were taken October 

16, 2008 in the County Line project area, after some snowfall had occurred, followed by warm 

weather which melted much of the snow. 

The R-2 Supplement to the Soil Management Handbook prohibits more than 15 percent of any 

area to be “detrimentally compacted, displaced, puddled, severely burned, and/or eroded 

condition”. FSM 2509.18, section 2.2 (3). 3 

Detrimental compaction is defined as “[a] 15% 

increase in bulk density from the average undisturbed density”. Id. at section 2.05 (10 a). 

Ensuring compliance with soil standards and design criteria is likely to be difficult, given the late 

snowmelt and frequent summer rains. Operating on snow is not likely to be practical for more 

than a few weeks each year, as frequent, and often heavy, snowplowing would have to be done to 

maintain roads for access. (See also discussion in section I above.) Machinery, especially that 

used for cutting trees, is not easy to safely operate in cold temperatures. 

Before approving any logging in the Rio de los Pinos project area, the Forest Service must prove 

that soils will be protected and that standards and design criteria will be met. The FEIS must 

discuss the possibility of soil damage occurring if operations are not suspended during wet 

periods. The latter is likely to occur because: a) it has already occurred in adjacent area, and b) 

3 This is also a Forest Plan standard. Plan at III-10. 



it is difficult for a Forest Service employee to be present any time the area may be too wet for 

operations. 

IV. DESIGN ANY LOGGING TO MINIMIZE BLOWDOWN. When part of a stand is cut, 

blowdown of remaining trees is always a possibility. Indeed, considerable blowdown in the 

adjacent County Line project area after logging, as in 2007, “a large wind event blew down most 

of the trees that were identified to remain in stands for Scenic Resources”. DEIS at 3-61. 

Retention of standing trees is very important for wildlife habitat and to help foster regeneration 

of the project area. See section V below and section II A above. 

The Forest Service must show how the proposed logging will not result in more than minor 

blowdown, even though similar logging in an adjacent area caused extensive blowdown. 

V. PROTECT WILDLIFE AND PLANT HABITAT. Logging is likely to adversely affect 

habitat for some species of wildlife. Logging should be reduced and design criteria strengthened 

to minimize such impact. 

A. LYNX. Lynx appear to frequently use the project area and surrounding land. See Shenk, 

2007 at 30, 31, showing high density of lynx use detected by both aerial and satellite means. 

Based on the number of smaller trees in the area, it would appear that there is good habitat for 

lynx’ favorite prey, snowshoe hare. See fn 2. Thus, there is likely some hare and lynx habitat in 

all units. 

The proposed action would remove standing dead trees, which would reduce future denning 

habitat. Logged areas would be very open, with limited cover. Logging would also damage or 

kill many small trees. Indeed, fir trees and trees less than eight inches in diameter would be 

removed to access larger diameter standing dead trees under both action alternatives. DEIS at 3- 

64, -66. Thus at least some lynx habitat in the treatment units would be converted to unsuitable 

habitat after logging. Up to 50 percent of the understory could be damaged, with 20 percent 

mortality. DEIS at 3-38. 

Under the no action alternative, the short-term effects of bark beetle mortality might be negative 

(DEIS at 3-36), but hare habitat at least would persist, as the understory and fir trees of all sizes 

would both remain intact. And in the longer term, 

The analysis area would slowly convert to winter foraging and other habitat. 

Through time, a patchy distribution of deadfall, dead standing and newly 

regenerating trees and shrubs would likely occur across the landscape. Some areas 

would continue to provide denning or foraging habitat for lynx, and may even 

improve in quality as an abundance of coarse woody debris becomes available for 

denning, and as areas open up and the understory vegetation is released. 

DEIS at 3-35. 



Leaving 38-60 trees per acre at least eight inches in diameter, as proposed under the proposed 

action would not compensate for much of the habitat degraded or destroyed by logging. Such 

leave trees probably would not be well distributed across the treated areas, meaning that there 

would be large open areas. But even if this number of trees was retained on nearly every acre, 

habitat would at best still be considerably degraded from what exists now. Leave trees could also 

blow down, as they did in the adjacent County Line project areas. DEIS at 3-61. Not logging 

would retain dead and dying trees for future lynx denning habitat and smaller trees for hare 

habitat. 

Providing or retaining piles or concentrations of down dead logs, necessary for lynx denning, 

would also provide for marten, a species for whom down dead material is critical, as it allows 

under-snow foraging. Marten is a sensitive species in Region 2. 

Standard VEG S6 in the Southern Rockies Lynx Amendment limits destruction of snowshoe 

hare habitat: 

Vegetation management projects that reduce winter snowshoe hare 

habitat in multi-story mature or late successional conifer forests may occur only: …. 

3. For incidental removal during salvage harvest (e.g., removal due to location 

of skid trails);…. 

Removal of trees providing hare habitat would not be “incidental” because many such trees 

would be destroyed during felling and skidding, even though they would not be the target trees 

logged. Again, see DEIS at 3-64, -66. Proposed logging could reduce the 35 percent or greater 

“Dense Horizontal Cover” said to be needed to provide hare habitat. DEIS at 3-37. Indeed, such 

cover is said to already be below 35 percent in units 3 and 5. Id. 

The design criterion for skid trails requiring avoidance of areas with the densest understory and 

limiting skid trail impacts to 15 percent of a unit (DEIS at 2-9) is good but insufficient. Dragging 

logs would impact more than just the skid trail, as logs would break or uproot small trees nearby. 

This would especially be the case if whole-tree skidding is allowed. 

Proposed logging would likely not comply with standard VEG S6. 

B. BOREAL TOAD AND NORTHERN LEOPARD FROG. There is likely good habitat for 

both of these amphibian species because the area is very wet. Boreal toad populations have 

decreased greatly over the last 20 years. The Fish and Wildlife Service recently accepted a 

petition on northern leopard frog to see if this species should be listed under the Endangered 

Species Act. Thus is it very important to protect both of these species. 

Both species are sensitive, thus procedures at FSM 2672.43, R-2 supplement 2600-2006-1, must 

be followed. Before any ground disturbance occurs, areas where road construction or 

reconstruction, skid trail placement, or logging may occur must be thoroughly surveyed for these 

species. Any populations found must be avoided. And as stated above, wet areas in general must 



be avoided to minimize soil damage and decreases in water quality, as well as to reduce impacts 

to aquatic and amphibian species. 

A design criterion requiring a biologist to “help develop and implement protective measures” if 

boreal toads are found (DEIS at 2-9) is good. However, habitat should not be destroyed or 

degraded, even this species is believed to not currently be present. 

C. NORTHERN THREE-TOED WOODPECKER. This species is known to be a voracious 

consumer of bark beetles. While it will not terminate a bark beetle outbreak, it can greatly reduce 

beetle populations locally. It is thus very important to protect habitat for this species, especially 

nesting habitat, which is snags. Snags should be retained in groups of live trees and/or other 

snags, to reduce blowdown and to provide protection against any predators. Retaining all soft 

snags that are not safety hazards, as required by a design criterion (DEIS at 2-9) would help 

maintain habitat for this species. 

This species is also sensitive in Region 2, requiring a biological evaluation, per FSM 2672.42, R- 

2 supplement 2600-2006-1, et seq. 

D. PROTECT RARE PLANTS. Surveys must be conducted for all sensitive plants that may 

have habitat in the analysis area, especially the three listed at DEIS 3-70 as possibly existing in 

the area. Any populations discovered must be avoided during operations. 

VI. RESTRICT LIVESTOCK GRAZING AFTER LOGGING. Current grazing in the project 

area occurs in various parts of the analysis area, including openings from previous logging. DEIS 

at 3-31. New openings, particularly the proposed patch cuts, would attract cattle, as there would 

be new growth of ground vegetation soon after the completion of logging. See DEIS at 3-72. 

Regenerating spruce will be difficult, as discussed in section II A above; any trampling or 

consumption by cows would make it even more difficult. Thus livestock should be kept out of 

areas where regeneration is desired for as long as is necessary to assure successful regeneration. 

Under the design criteria on DEIS p. 2-10, cows would be allowed in the area, and 

concentrations of them would be dispersed by riders. But if large numbers of cows entered 

regenerating areas, the damage might already be done before the cows could be chased out. Thus 

design criteria must be strengthened to prohibit cows from adversely affecting regeneration 

success. The Forest Service should work with the grazing permittees to find alternate pastures as 

needed. 

VII. MISCELLANEOUS 

DEIS p. 1-3 says about two miles of old road would be reopened under preferred alternative 2, 

but pp. 2-3 says 3.3 miles would be reopened. The latter figure is repeated in the text on p. 3-3. 



DEIS p. 3-86 states uncertainty about reauthorization of the Secure Rural Schools and 

Community Self-determination Act of 2000. This law was amended and reauthorized as part of 

the Troubled Assets Relief Program in early 2009. 

CONCLUSION. The undersigned believe the Rio de los Pinos area should not be entered, or if 

any logging is approved, it should be much less than that proposed under alternative 2. The 

probability of damage due to operating in wet areas is too great. Regeneration success would be 

decreased due to creation of openings via patch cutting. Lynx habitat would be degraded in the 

short and long term. 

Before any logging is approved, the Forest Service must: a) show that damage to watersheds and 

water quality will be minimized, and if any wetlands exist, that they will be avoided altogether; 

b) adequately protect existing and future habitat for lynx and comply with all standards and 

guidelines; c) prove that soils will be adequately protected; and d) show how blowdown will be 

minimized. 

Sincerely, 

Rocky Smith 

Colorado Wild 

1030 Pearl #9 

Denver, CO 80203 

303 839-5900 

rocky@coloradowild.org 

Bryan Bird 

WildEarth Guardians 

312 Montezuma 

Santa Fe, NM 87501 

505.988.9126 x 1157 

bbird@wildearthguardians.org 

Exhibit 1: County Line Soil Ruts I (separate attachment 

Exhibit 2: County Line Ruts II (separate attachment) 

REFERENCES 

Shenk, T. M., 2007. Post Release Monitoring of Canada Lynx (Lynx Canadensis) Reintroduced 

to Colorado. Colorado Division of Wildlife, 2007. 



USDA Forest Service, 1998. Peatlands on National Forests of the Northern Rocky Mountains: 

Ecology and Conservation. Rocky Mountain Research Station, General Technical Report 

RMRS-GTR-11. 


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Final Environmental Impact Statement Rio de los Pinos Vegetation ...

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