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

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<strong>Final</strong> <strong>Environmental</strong> <strong>Impact</strong> <strong>Statement</strong> <strong>Rio</strong> <strong>de</strong> <strong>los</strong> <strong>Pinos</strong> <strong>Vegetation</strong> Management Project<br />

1996 Forest Plan revision. They are not related to the regeneration success of previous<br />

management activities.<br />

Forest Service Response to Comment 1-16:<br />

Thank you for the comment. A<strong>de</strong>quate seedling protection is required in Forest Service planting<br />

contracts, whether through hand-stacked logging slash (a common practice) or through artificial<br />

tree shelters, which the Forest already owns.<br />

Forest Service Response to Comment 1-17:<br />

Please see Forest Service Responses 1-12 and 1-13. Planting estimates are based on current<br />

regeneration stocking levels and current overstory mortality within each unit. See also Forest<br />

Service Responses 1-15 and 1-16 concerning regeneration success and a<strong>de</strong>quate seedling<br />

protection.<br />

Forest Service Response to Comments 1-18:<br />

The EIS states a need to reduce long-term fuel build-up (FEIS Section 1.5, italics ad<strong>de</strong>d). The<br />

goal is to reduce the duration and intensity of a potential wildland fire by reducing the heavy fuel<br />

loading that may at some point in the future burn with very high intensities and cause severe soil<br />

damage. The Forest Service agrees that fires are rare in wet, high-elevation areas but<br />

acknowledges that they have and do occur. Analysis is focused on potential severity rather than<br />

fire risk.<br />

Forest Service Response to Comment 1-19:<br />

The Forest Service agrees that once the trees <strong>los</strong>e their needles and the needles become part of<br />

the surface fuels there is little chance of a crown fire. However, later in time when the trees<br />

begin to fall due root rot or wind, the loading of larger diameter fuels on the soils can burn at a<br />

very high intensity and cause high severity to the soil.<br />

Forest Service Response to Comment 1-20:<br />

If a spruce tree falls and a large majority of the bole touches the ground, then rot does begin to<br />

occur. However, if trees crisscross each other and subsequent layers of trees are off the soil<br />

surface, they <strong>de</strong>cay much more slowly. Sound spruce trees that have been standing for many<br />

years, even <strong>de</strong>ca<strong>de</strong>s, do not rot as quickly as stated in the comment when in this condition. The<br />

existing regeneration that would grow up over the years would in<strong>de</strong>ed provi<strong>de</strong> some shelter to<br />

the surface fuels, but the last statement “except during exten<strong>de</strong>d drought periods” is key.<br />

Research has shown that there is a correlation between drought and high elevation fires (Sherriff<br />

et al. 2001). Eventually there will be a dry period and if a fire occurs, the damage to soils could<br />

be very <strong>de</strong>trimental to the watershed.<br />

Forest Service Response to Comment 1-21:<br />

Although harvest units do not adjoin private property, they do lie within ½ mile of approximately<br />

630 acres of private land with structures. If fire becomes established in stands of beetle kill and<br />

there is a heavy surface fuel load, they are very difficult to suppress and can easily move over<br />

large landscapes before weather conditions change or suppression actions are successful.<br />

Chapter 6 -- Response to Comments Page 6-5

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