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

Final Environmental Impact Statement Rio de los Pinos Vegetation Management Project
presented in Table 2.5-5 to minimize sediment input to stream. Stream disconnection is also
noted as an objective on page 3-25.
Forest Service Response to Comment 1-11:
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.
Forest Service Response to Comment 1-12:
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.
Forest Service Response to Comment 1-13:
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.
Forest Service Response to Comment 1-14:
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).
Forest Service Response to Comment 1-15:
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,