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

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Final Environmental Impact Statement Rio de los Pinos Vegetation Management Project Forest Service Response to Comment 1-22: 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. Forest Service Response to Comment 1-23: 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. Forest Service Response to Comment 1-24: 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. Forest Service Response to Comment 1-25: 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. Chapter 6 -- Response to Comments Page 6-6
Final Environmental Impact Statement Rio de los Pinos Vegetation Management Project Forest Service Response to Comment 1-31: 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. Forest Service Response to Comments 1-32 thru 1-36: 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. Forest Service Response to Comments 1-37 thru 1-39: 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. Forest Service Response to Comments 1-40 thru 1-42: 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. Forest Service Response to Comments 1-43 thru 1-44: Thank you for the comment. Three toed-woodpeckers were considered within the Biological Evaluation prepared for this project. Forest Service Response to Comment 1-45: 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. Chapter 6 -- Response to Comments Page 6-7
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Final Environmental Impact Statement Rio de los Pinos Vegetation ...

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