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

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Colorado Wild Page 8 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 Printed on recycled paper with at least 30% post-consumer content.
Colorado Wild Page 9 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. Printed on recycled paper with at least 30% post-consumer content.
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Final Environmental Impact Statement Rio de los Pinos Vegetation ...

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