Appendix C-1

APPENDIX C: Response to Comment Letters on Sargents Mesa Timber Sale

Environmental Assessment

April 8, 2010

The Environmental Assessment for the Sargents Mesa Timber Sale Project was made available

for public review and comment between February 4 and March 8, 2010. Two comment letters

were received during that comment period. The first letter was sent by the High Country

Citizens’ Alliance (HCCA), Colorado Wild, Wild Connections, Sheep Mountain Alliance, Sierra

Club, and San Luis Valley Renewable Communities Alliance. The second letter was from Sandy

Shea. Copies of the two comment letters are found at the back of this appendix. Both comment

letters brought up similar points. Points have been highlighted and indexed for discussion. The

discussion in this appendix addresses the points presented by showing where in the

Environmental Assessment a subject was talked about and by providing clarifications to the

Environmental Assessment. Section headings from the HCCA letter are used to group the

discussion.

Purpose and Need/Conclusion

Index: 1 Our impression is that timber production for industry is the driving force behind this

sale. There is no scientific justification for logging high altitude spruce-fir forests.

Index: 30 There is no ecological basis for, nor would there be benefits from, logging in the

project area as proposed.

The Sargents Mesa Timber Sale proposal is included in the Amended Forest Plan. The area is

identified as suited for commercial timber production. The area is within the Forest Plan

management area of 7A, which emphases commercial timber production. Thus a primary

management objective for this Environmental Assessment is the implementation of the timber

production goals outlined in the Forest Plan.

The Sargents Mesa area was identified for potential timber harvest during Forest Planning since

it had been cut before, the road system is in place, and the silvicultural prescription from the

previous sale recommended a shelterwood harvest reentry.

The spruce-fir cover type is the most productive of the cover types found on the Gunnison

Ranger District from a wood fiber perspective. The spruce-fir cover type on the District makes

up 33% of the suited timber base identified in the Forest Plan. Suited spruce-fir is 19% of the

total spruce-fir found on the District. The proposed timber harvesting in Alternatives Two and

Three (793 acres) covers only 0.23% of the spruce-fir found on the district and 0.09% of the

forested cover on the district.

Appendix C-2

There has been concern by some members of the public that the Forest Service is cutting too

much in the spruce-fir cover type. Since 1992 (1991 Amended Forest Plan), Gunnison Ranger

District has sold 20 larger size timber sales. Of those, nine were in lodgepole pine, six in spruce-

fir, three in mixed lodgepole pine-spruce-fir, one in aspen-lodgepole pine-blue spruce, and one in

spruce-fir-mixed conifer. The timber sales sold, and including the proposed Sargents Mesa

Timber Sale, in spruce-fir have been spread relatively evenly across the area by cover types

found in the suited timber base for Gunnison. One-third of the suited timber base is spruce-fir

and one-third of the timber sales are in spruce-fir. Two additional spruce-fir timber sales are

prepared and will be offered for sale in the future.

Timber sale planning for future sale proposals include ideas for timber sales in the lodgepole

pine, mixed-conifer, and aspen cover types. Future timber harvesting in the spruce-fir cover type

will be incidental to harvesting in the other cover types for the time being. This way timber

harvest projects are rotated through the various cover types found on the District over time. For

additional information, the number of timber sales sold by cover type in the table below includes

the 1983 to 1991 time period which goes back to the initial Forest Plan approved in 1983.

Larger Timber Sales by Cover Types on Gunnison Ranger District

Cover Type

Percent

of Suited

Timber

Base

Number of

Sales Sold

1992-2009

Number of

Sales Sold

1983-1991

Total Sales

Sold 1983-

2009

Percent of

Total Sales

Sold

Spruce-fir 33% 6 + 2 Marked 7 13 + 2 Marked 25%

Lodgepole/Spruce-fir 3 8 11 21%

Lodgepole pine 39% 9 9 18 34%

Lodgepole/Aspen/Mixed-conifer 1 1 2 4%

Lodgepole/Mixed conifer 1 1 2%

Aspen/Spruce-fir 1 1 2% Mixed-conifer/Spruce-fir 1 1 2% Aspen 17% 1 1 2% Mixed-conifer (Other Species) 11% 4 4 7%

Ponderosa pine 1 1 1%

20 Sales 33 Sales 53 Sales

Other species includes Douglas-fir, blue spruce, and ponderosa pine.

Mixed-conifer is Douglas-fir and blue spruce.

Other resource benefits can be achieved through active forest management. After the proposed

timber harvesting of Alternatives 2 and 3, a new cohort of spruce and fir seedlings will become

established. These young trees will maintain species-diversity and begin increasing age-class

diversity of the stands. The young trees and the arrangement of the harvesting will provide for

vertical and horizontal stand structures within stands. The young cohort will be in good health

and exhibit vigorous growth. A portion of the less than healthy overstory will be removed,

leaving the relatively healthier overstory trees to continue to grow. The resulting stand

conditions will have greater resilience. Altering forest conditions now will provide improved

wildlife habitat into the future with more favorable stand structures and forage availability.

Appendix C-3

Forest Health

Index: 2 Disagrees that the spruce-fir in the sale area is in poor condition. It is within historic

range of variability (HRV).

The amount of standing dead, the amount of defect, and declining growth rates of trees and

stands are indicative of poor forest health from wood production and forest health points-of-

view. The rate of decline will accelerate as trees die and fall. In the No Action Alternative the

number of living, older, overstory trees will decrease to the point that stands do not provide the

high closed-canopy cover which is preferred by some wildlife species. This declining forest

condition occurs naturally toward the end of the historic range of variability for disturbance. The

decline in condition sets the stage for, and increases the probability of, a stand replacing event.

Index: 3 Question of 120 years as age of maturity.

The use of 120-years as age of maturity in spruce is in terms of tree physiology, tree growth and

wood production as is the reference to 160-years as the beginning of overmaturity. Mature and

overmature in this context are not the same as wildlife habitat structural stage.

Index: 4 Disagrees that there is need to promote stand health and increase resilience to insect

and disease outbreaks.

Index: 5 The forest health indicators in Table 6 on page 32 contradicts the Forest Service

position that the area is in need of preemptive management. The forest is healthy, not unhealthy.

Index: 37 The EA goes out of its way to indicate the potential for disease outbreak, yet admits

the area is not especially threatened from any known pathogen at present. Because this specific

area is relatively healthy, this is not a supportable rationale for vegetative treatment in this case.

The forest health indicators in Table 6 need to be evaluated as a whole for each stand. There is

interpretation necessary to understand what the indicators mean. The discussion of forest health

on pages 31 to 36, and the environmental consequences described on pages 36 to 43 is intended

to provide that interpretation.

The discussion in the Environmental Assessment concerning fuel loading is less about wildfire

potential and more about stand deterioration. As a stand of trees become older, tops and limbs

break-off, trees die and fall down which adds to woody debris/fuel loading on the ground. Here

fuel loading adjectives are used to describe the amount of mortality and decline that has occurred

on the site. As the commenter noted, several stands have “low” fuel loadings. These same

relatively younger stands are identified on page 36 of the EA as having been burned in fires 100-

120 and 150-180 years ago. The fires consumed woody debris on the forest floor. There has

been less time for woody debris to accumulate on the ground as compared to older stands.

Appendix C-4

Index: 6 Disagrees that fire suppression has created an imbalance with the spruce-fir cover

type within the Sargents Mesa Diversity Unit. Age class distribution in the spruce-fir type is not

out of historic range of variability (HRV). Fire suppression has had no effect here. Fire return

interval is 200 to 400 years.

Index: 7 The perceived imbalance asserted by the Forest Service is in fact a historically

natural condition, and the mature and old growth qualities of the forest are an expected response

to a pattern of very infrequent stand-replacing fires.

Index: 8 The Forest Service’s position that the current forest structure is significantly different

from that what would exist through natural succession and disturbance is incorrect and a

misstatement of reality.

Index: 38 The overarching assumption of the EA – that the forest is out of balance and must be

fixed – is not supported by the data presented or by my own field observations.

It has been hundreds of years since the last stand replacement fires in three-quarters of the

project area. As time continues, the condition of the forest will continue to decline and the

severity of fire when they occur will increase.

We agree that fire suppression has not had a large impact on the spruce-fir forest within the

Sargents Mesa project area. Fire suppression has however had an impact on the lower elevation

forest areas of the Diversity Unit.

In terms of HRV and fire frequency, the commenter tends to see disturbances as being at the long

end of the range. The term “range” implies that there is a short end to the spectrum as well.

The context of age-class distribution on page 4 and 26 of the EA is derived from the Forest Plan

Revision Comprehensive Evaluation Report for the National Forest and Comprehensive

Assessment for the Gunnison Basin Geographic Area of 2007. The information from the

evaluation was of National Forest lands within the entire Gunnison Basin Geographic Area

compared to the 13,113 acres Sargents Mesa Diversity Unit.

In Table 3 on page 26 of the EA, the “Target Proportion” columns are the percentage ranges

determined for the Gunnison Basin from modeling disturbance and growth in the Vegetation

Dynamics Development Tool (VDDT). VDDT was used during forest planning to identify

historic range of variability (HRV). The “Current Proportion” columns in Table 3 are for current

conditions within the 13,113 acre Sargents Mesa Diversity Unit.

The spruce-fir potential natural vegetation (PNV) type covers 354,300 acres or 22% of the

Gunnison Basin GA. The table below restates the current versus HRV seral succession stage

distribution for the spruce-fir PNV. The proposed harvest treatments in Alternatives Two and

Three would occur on 0.2% of the spruce-fir PNV in the Gunnison Basin (793/354,300 acres).

Appendix C-5

Seral Stage Distributions for the Spruce-fir PNV type.

Seral Succession Stage

VDDT

Determined

Range

Current

Distribution in

Gunnison Basin

Geographical Area

(354,300 acres)

Current

Distribution in

Sargents Mesa

Diversity Unit

(5,730 acres SF

PNV in 13,113 acre

DU)

Current

Distribution in

Sargents Mesa

Project Area

(1,074 acres SF PNV

in 1,126 acre PA)

Early Seral 27-32% 5% 1% <1%

Early-Mid Seral 20-24% 49% 13% 0%

Late-Mid/Late Seral 43-53% 45% 86% 99%

Note that terms used in “wildlife habitat structural stage” and “seral successional stages”

descriptors are not the same and are not interchangeable. The first describes the structure of a

stand for wildlife habitat, the later term describes ecological process.

Also note that “current cover type” in Table 2 on page 24 of the EA is not the same as the

“potential natural vegetation.” The table above lists acres of spruce-fir based on the potential

natural vegetation determined for individual sites. Part of the current lodgepole pine dominated

sites are included in the potential spruce-fir PNV where they are seral to spruce-fir.

The uneven-aged management proposed in Alternative Two will maintain the harvested stands in

the mature wildlife habitat structural stages and in mid to late seral successional stages through

time. Even-aged management proposed in Alternative Three will move the harvested stands

toward immature sapling/pole and beginning mature wildlife habitat structural stages or the early

and mid seral successional stages within one to sixty years depending on the proposed

shelterwood treatments.

Management under Alternative Two will fail to achieve the goal of increasing the

underrepresented HRV early seral successional stage. Alternative Three will move the National

Forest toward achieving the goal of a more balanced distribution of HRV seral successional

stages, but only to a small degree.

Index: 9 Logging will further increase open areas thus accelerating windthrow.

Index: 10 Group cutting will further open up stands and therefore exacerbate windthrow

rather than providing an effective protection.

Experience and research (summarized by Alexander, 1987) shows that harvesting trees in groups

maintains resistance of the residual stand between cut groups. The size of the cut group opening

is not large enough for wind to create a fetch which has the energy to topple or break trees on the

windward side. By orienting the long axis of a cut group perpendicular to the prevailing wind,

funneling is further minimized. Concentrating the group harvest on those trees which have root

and stem rot, or are otherwise in poor condition, the most vulnerable trees are removed before

they windthrow or stem break. The healthier, more wind resistant trees are left in the

unharvested areas between groups.

Appendix C-6

Group edges are determined by the natural group arrangement and by the presence of healthier,

more wind resistant trees. Trees in a natural group arrangement are close enough together or

have intertwining crowns which provide mutual support with other trees. Natural group

arrangements on Sargents Mesa are between ½ and three tree-heights across. Healthy trees on

the edge of a group often will have foliage on the outside of the group which reaches down

nearly to the ground. Tree crowns on the inside of the group are well elevated from the ground

due to shading. Leaving the natural edge with its extended crown length will provide forage and

cover for snowshoe hares if the crown is near snow depths.

Tree decline, mortality and windthrow in the project area tends to be concentrated in groups as

well. Here, trees in the declining group have thin crowns or are dead, no longer providing wind

protection to neighboring trees. Tree mortality disrupts the integrity of windthrow resistance of

the group. The incidence of stem rot tends to be higher in these declining groups, which makes

trees more vulnerable to stem breakage. It is these declining groups which are recommended for

group selection or group shelterwood harvest while the healthy groups are retained.

Where windthrow does occur, it usually comes from the wind being able to funnel into road

corridors, in very large openings, and in clearcuts over five-acres in size. Skid trail corridors are

narrow enough not to funnel the wind. The road corridors in the proposed Sargents Mesa

Timber Sale area have been in place for nearly thirty years, thus trees along the roads have

stabilized and gained windfirmness.

Following a windthrow event in the Spring of 1993, down and damaged trees along NFSR

578.2A were salvaged for firewood in 1993 and 1994 (pages 44 and 45 of the EA). The

windthrown trees were associated with the road corridor. The salvage sales prevented spruce

bark beetle populations from building up in the down spruce trees and bark beetles moving in

large numbers into standing green spruce. Prompt salvage of windthrown or wind damaged trees

where access is available has been a long-standing practice on Gunnison Ranger District. These

trees are utilized by small-scale purchasers for commercial firewood, houselogs, and some

sawlogs. Where the windthrow is on a good open road near population centers, the public has

been encouraged to salvage trees for personal-use firewood.

Where the project area abuts the large park on top Sargents Mesa and the head of Tank Seven

Creek, the proposed harvest boundary is to be 120 to 200 feet in from the edge of the park. The

unharvested strip will provide protection from wind coming off of Sargents Mesa to the west.

Islands of spruce west of the project area will provide additional protection from high winds.

The unharvested strip also provides screening from the Colorado Trail corridor.

Index: 11 Death of trees creates room for new growth and release of any nearby trees in the

understory. Dead trees and down logs are valuable for wildlife.

The proposed group selection harvest of Alternative Two would retain existing tree conditions

on 75% of the sale area for forty years. In Alternative Three 50 to 75% of the existing tree

conditions would be retained in the harvested area between 20 and 40 years depending on site-

Appendix C-7

specific proposed treatment. Following the snag and down woody debris design criteria outlined

on pages 16 and 17 of the EA will ensure Forest Plan standards are met and exceeded. There

will be sufficient declining live trees, standing dead trees, and down trees to provide adequate

habitat for wildlife between cut groups. Snag and down log survey data collected in the project

area show there is currently three times the Forest Plan standards for such (EA page 77). By

harvesting a portion of the dead and dying trees, society can benefit from the wood products they

contain.

The environment for young tree growth in the harvested groups will allow more rapid growth

(due to more sunlight and less competition with overstory trees) than in the shade of standing

dead or near dead trees in a gap phase setting. Within a shorter time, the young cohort of trees in

the group cuts will begin providing an additional source of cover and forage for wildlife

including snowshoe hare. Seedlings and saplings in cut groups will be 4 to 6-feet tall by 20 to 30

years of age. For seedlings to grow to 4 to 6-feet tall under a partial canopy, that age range is 60

to 100 years, and their crowns will be thin. Seedlings under a closed-canopy often do not grow

to 4-feet height, or take over 100 years to do so. Cut groups will have more herbaceous forage

for wildlife compared to surround uncut areas.

Experience has shown that nonmerchantable soft snags in cut groups, especially larger-diameter

broken-top snags, can be left standing. Logging equipment can work around the snags.

Where a live tree is so badly damaged or rotten as to preclude processing into dimensional

lumber, that tree is left uncut. The cull tree, by default, is a “living wildlife tree” or “legacy

tree.” This type of tree can be avoided in cutting group layout and by logging equipment during

cutting. These living wildlife trees retain a part of the decadence component in the stand which

could contribute to the identification of the stand as old growth wildlife habitat structural stage in

the future as the harvested stand recovers.

Old Growth

Index: 12 With only a small percentage of North America’s original old-growth forests

remaining, should protect any remnants.

Index: 31 The EA states that there’s too much ‘overmature’ spruce, and logging is needed to

‘restore species diversity’. Almost every last acre of this place has already been logged – only

10% of the forested area is still classified as ‘old growth’. And the proposed action would

decrease this percentage by half.

Index: 33 The problem stems from the definitions of ‘old growth’ and continued use of terms

such as decadent and overmature.

From Mehl (1992): “Old growth is not necessarily “virgin” or “primeval.” It could develop

following human disturbances. It could also develop from man’s indirect influence on the

landscape by the control of fire.”

Appendix C-8

The definition of “old growth wildlife habitat structural stage” is intended to describe a stand

structure and a set of stand attributes which benefit certain wildlife species. The definition “old

growth wildlife habitat structural stage” is not intended to describe stand history or the absence

of previous anthropological disturbance.

Old growth wildlife habitat structural stage is more than old trees, it is a collection of stand

structure and attributes. “A stand may contain some trees that meet the criteria for old growth,

but the stand as a whole could lack the functions and interactions of an old-growth ecosystem

and would not be considered old growth.” (Mehl, 1992)

Terms including decadence and overmature describe condition of a tree or a forest. The meaning

of a term varies based on the context of the discussion.

For the purpose of our analysis, and in the context of the public concern, candidate old growth

wildlife habitat structural stage sites were assessed within the Diversity Unit based on the criteria

(Forest Plan, 1991 and Mehl, 1992 definitions recorded in old growth scorecards) that consider

all the elements that provide quality old growth wildlife habitat structural stage (including

decadence, old/large trees, multiple canopy layers, etc…). The expected impact to the old

growth wildlife habitat structural stage resource is based on this inventory, and most mature

wildlife habitat structural stage stands that are proposed for treatment do not currently meet the

criteria for old growth wildlife habitat structural stage in this context.

As displayed in Table 7 on page 38 of the EA, post harvest percentage of old growth wildlife

habitat structural stage 5 in the project area (6%) will be within the Forest Plan standard of 5% to

12%. At the diversity unit level where the 5 to 12% old growth standard is intended to be

applied, post harvest old growth under both harvest alternatives will decrease from 9.9% to

9.5%.

At the Diversity Unit scale, mature wildlife habitat structural stage 4B, 4C and old growth 5 in

combination currently cover 63% of the area. For the Sargents Mesa project area the current

combined portion of the area in stages 4B, 4C and 5 is 86%.

Query of the potential natural vegetation (PNV) data for the entire Gunnison Ranger District

shows that for forest currently classified as spruce-fir, mature wildlife habitat structural stage 4B

and 4C covers 61% of the area. The old growth wildlife habitat structural stage 5 classification

is not included in the PNV or R2Veg databases pending site-specific data and verification. Old

growth stands are classified as either 4B or 4C wildlife habitat structural stages.

Appendix C-9

Index: 13 Unhealthy trees will become old growth if left alone. Harvesting removes decadent

trees which are a character of old growth. Decadent trees take centuries to grow. Removal will

leave the stand unsuited as old growth habitat. There will be no recovery in 20-30 years.

Decadence and poor condition are important to old growth and will be lost if cut.

Index: 14 There would be few signs of decadence remaining in the treated area after timber

harvest.

Index: 32 As for increasing species diversity, the bulk of the re-growth will be mostly spruce,

some lodgepole, not much fir. The proposed action will fail to accomplish much in terms of

either species-, or age-class diversity goals.

Index: 15 With the lack of large fires at this location, these old growth trees are well within

their HRV, and should be left alone to complete their natural cycle of growth and decay.

The change in wildlife habitat structural stage shown in Table 7 on page 38 of the EA comes

from reduction in canopy closure, and in certain situations reduction in average tree size. The

recovery time shown in Table 5 on page 28 of the EA is derived from observed increase in

canopy closure following disturbance from regeneration of trees, tree growth, and crown spread

(page 27). The observations were made by Foresters in the Gunnison District during the past

several decades and can be measured on aerial photographs through time.

In group selection and group shelterwood, only a part of the stand is harvested, the residual stand

between cut groups remains. In the example of group selection (Alternative Two), a stand with

75% canopy closure prior to harvest has 25% of the stand area cut. The residual 75% of the

stand contributes 56% of the canopy closure (75% of 75%). This would change a wildlife

habitat structural stage of 4C to 4B. With time, regeneration occurs in the cut group, young

understory trees left in the cut group release and grow, trees around the edge of the cut group

extend their branches into the open space, and the canopy in the uncut part of the stand (75% of

the area) becomes more dense as crowns grow. The observed rate of crown closure increase in

partial cut spruce stands on the Gunnison District is 10% per decade (EA page 27). So for the

example stand, in two decades the overall stand canopy closure would recover from 56% back to

76%. Wildlife habitat structural stage would change from 4B to 4C.

On Sargents Mesa, the lack of consistent vertical structure is one of the attributes which prevents

mature wildlife habitat structural stage 4C stands from being identified as old growth wildlife

habitat structural stage 5. An important component in vertical structure is an understory of

seedlings and saplings. The seedling and sapling layer provides food and cover for wildlife

species at and near the ground surface and winter snow surface.

In most stands in the proposed Sargents Mesa Timber Sale, there are not enough seedlings and

saplings which are tall enough, present in enough of a consistent arrangement to be considered

an understory and to provide the vertical structure component for old growth designation. Where

older aged seedlings and saplings are present, they tend to be in clumps or fir thickets. Half to

three-quarters of these older seedlings and saplings are too suppressed to develop any height

growth if growing space is provided to them.

Appendix C-10

Spruce and fir seedlings which germinated following the 1985-1986 timber harvest are heavily

shaded so their height growth is suppressed. This cohort currently averages one-foot tall. These

seedlings are not yet contributing to the vertical structure or canopy closure in the stand. Given

the current overstory density, it will be 60 to 100 years before they do define an understory for

wildlife, if they survive the suppression.

Where spruce and fir seedlings become established in cut groups after harvest, in 20 to 30 years

they will have grown tall enough to define an understory for wildlife use including snowshoe

hare. The cut groups are not stand-alone, they are a component of the larger stand area, and thus

provide vertical structure and horizontal structure (patchiness) within the stand. Vertical and

horizontal structure are attributes of old growth wildlife habitat structural stage.

Uneven-aged management using group selection as suggested by Alternative Two will maintain

sufficient old growth habitat components in stands that they will continue to function as old

growth (5) or near old growth wildlife habitat (mature 4A, 4B, or 4C). See Table 7 on page 38

of the EA.

In Alternative Three, shelterwood harvesting will move resulting stand structures away from

functioning as old growth or near old growth wildlife habitat toward younger sapling/pole

wildlife habitat structural stages (3A, 3B, or 3C). None of the suggested shelterwood treatments

would take stands back to the grass/forb wildlife habitat structural stage (1T) or seedling stage

(2T) this entry or after future shelterwood entries.

Following the No Action Alternative, at current overstory mortality rates, several of the stands

will no longer have much of an older overstory cohort left in 30 to 70 years (Table 6 on page 32)

even without catastrophic bark beetles, windthrow or stand replacement wildfire. Only a few

overstory trees will be left to provide the 350 or 500 year old trees spoken of by commenters.

Stands will not become deforested since any vacant growing space will be filled in with a

younger cohort of trees. Vulnerability to stand replacement wildfire would significantly

increase, which if one occurred would shift burned stands back to a grass/forb wildlife habitat

structural stage (1T) for a prolonged period of time (100 to 300 years).

In the absence of fire, stands could conceivably persist at climax stage through booms and busts

in stand structure which is described by Oliver and Larson (1996) as “old growth successional

stage” of ecological function. However during the persistent climax stage only periodically

would a stand area be stocked with trees which would have sufficient attributes to be classified

as “old growth wildlife habitat structural stage 5.” “Old growth successional stage” of ecological

function and “old growth wildlife habitat structural stage” are two different concepts. Oliver and

Larson stated at a seminar in February, 2009 that the probability of a forest spending much time,

if at all, in “old growth successional stage” without having a catastrophic stand reinitiating

disturbance is highly remote (Haines, personal communication, 2010).

Appendix C-11

Index: 34 The GMUG is proposing a 160-year rotation scheme for this species in this area.

Should increase its rotation age so more actual old growth structure is allowed to be created,

and persist, on the forest over time.

As stated on page 29 of the EA, the rotation period for even-aged management in Alternative

Three is 160-years. This period is determined by culmination of mean annual increment (CMAI)

as directed by the National Forest Management Act of 1976. Prescribing extended rotation

periods beyond the time of CMAI is an available option where timber production is not the

primary management objective. In the case of the proposed Sargents Mesa Timber Sale, the

Amended Forest Plan has identified this area for commercial timber production (management

area 7A).

Uneven-aged management as suggested by Alternative Two allows for trees to be left on site for

more than 160-years. The retention or harvest of a tree is not based on age, but on the physical

condition of the tree. Trees in good condition are retained, trees in poor condition are removed.

In reality, the Forest Service through inaction during the 1900’s has allowed the rotation length

on Sargents Mesa and in other spruce-fir areas of the Forest to extend beyond the average CMAI

time of 160-years. As stated on page 24 of the EA, the age of most overstory trees in the

proposed timber sale area is 160 to 250-years. The previous 1980 Sargents Mesa #3 Timber Sale

Decision Notice specified a 20-year shelterwood reentry schedule. It now has been 30 years.

Wildlife

Index: 16 Cochetopa Hills is a movement corridor for wildlife.

Index: 17 Lynx discussions are inadequate.

Index: 18 Logging impacts including roads and skid trails cause fragmentation.

Index: 19 Logging removes snowshoe hare foraging habitat.

Index: 20 The logging of mature and old growth forests would likely have a negative impact on

sensitive species.

Index: 21 Impact on wildlife from erosion and road and skid trail construction.

Index: 22 Fragmentation of habitat for lynx and other wildlife species.

While much of the discussion below is directed toward Canada lynx, it is applicable to other

wildlife species which use the Sargents Mesa area.

The Sargents Mesa project area is not within the identified lynx linkage corridors. The Poncha

Pass lynx linkage corridor lies six miles to the northeast. The North Pass/Cochetopa Hills lynx

linkage corridor is five miles to the west. See Map C-1. Although the project area is not within

a lynx linkage, lynx and other wildlife can use the project area to move through as the

commenters state.

Appendix C-12

Guidance provided in Section 5 of the Southern Rockies Lynx Amendment (SRLA)

Implementation Guide describes lynx habitat connectivity as cover in sufficient quantity and

arrangement to allow for the movement of lynx. Lynx use different vegetation cover depending

on season and movement pattern (within home range versus long distance dispersal). For

Sargents Mesa the habitat characteristic desired for movement is mature multi-storied

Engelmann spruce-subalpine fir with greater than 40% forest canopy cover that supports

snowshoe hare populations. Currently 86% of forested habitat in the 1,126 acre project area

meets this description. Alternative Two group selection harvesting would reduce this to 79% of

the project area as some stands will have less than 40% canopy cover immediately after harvest.

Alternative Three shelterwood harvesting would reduce the lynx movement habitat to 69% of the

project area. Since there will be no harvesting between the group cuts prescribed in Alternatives

Two and Three, the residual areas (75% of the stand area in Alternative Two and 50-75% in

Alternative Three) will continue to provide cover. Remember that the group cuts are only a part

of the larger stand mosaic.

In the discussion of the Rationale for the Decision concerning Forest Roads (Page 16 of the

Record of Decision for the Southern Rockies Lynx Amendment) it is pointed out that low-speed,

low-traffic-volume roads do not present a barrier to lynx movements. The discussion refers to

research by Koehler and Brittell 1990, McKelvey et al, 2000, Ruggiero et al 2000 and Apps

2000. This discussion about lynx use and roads is also found in the Canada Lynx Conservation

Appendix C-13

Assessment and Strategy (2000). Low-speed, low-traffic-volume roads are defined in the SRLA

glossary as less than 20 miles per hour design speed and less than 100 vehicles per day. The

Sargents Mesa road system falls into that classification.

Wildlife may be temporarily displaced from and/or avoid the area while harvest is occurring.

Disturbance impact during logging activities will be temporary. Area avoidance by wildlife will

stop after operations are complete (EA page 87). During active logging, wildlife will be able to

use the surrounding forest to live in and move through. Refer to Map 3 in Appendix A of the EA

to view the arrangement of surrounding forest on Sargents Mesa.

Woody debris which could potentially be used for lynx denning and other wildlife species use is

not removed from the forest. Fuel treatment is not an objective of this proposed project except

for eliminating landing debris piles. Other than the sawlogs felled for timber utilization, only

green unmerchantable spruce logs (YUM) are yarded to the landing to minimize spruce beetle

population build-up. Woody debris in cut groups could be crushed during felling and skidding

operations, or pushed into small piles or windrows to clear a pathway. During reforestation

machine scarification following a timber harvest, occasional small slash piles of tops and limbs

are created in cut groups as slash is moved out of the way to obtain the desired mineral soil seed

bed. These small slash piles usually are two to four-feet tall and are referred to as “bunny piles”

since they provide shelter for small mammals.

Woody debris in the residual stand between group cuts is not altered. The design criteria

outlined on pages 16 and 17 of the EA will ensure that Forest Plan standards for snags and

woody debris are met or exceeded as discussed on pages 86 and 87 of the EA.

The group selection and group shelterwood harvests proposed in Alternatives Two and Three are

intended to focus on removing trees of declining condition. Trees in declining condition usually

have thin, well-elevated crowns which are not accessible to snowshoe hares. Those trees which

do have green crowns which extend down to an accessible height are generally in better physical

condition, and are thus desired as leave trees for the future.

Experience in logging operations shows that concentrations of desirable seedlings and saplings

within group cuts can be maneuvered around and for the most part protected during logging and

site preparation. Better developed concentrations or thickets of seedlings and saplings are

generally excluded from group cuts altogether. Damage to advanced regeneration seedlings and

saplings is counter-productive for reforestation needs, and for wildlife habitat vertical and

horizontal structure. This vertical and horizontal structure provides dense horizontal cover for

snowshoe hare. As part of the prescription, harvest units would be designed to avoid dense

horizontal cover.

Advanced regeneration is not the only source for a future seedling and sapling understory. The

intent of the group harvest and site preparation treatment is to provide a microenvironment which

is conducive to the establishment and growth of a new cohort of spruce and fir trees. This has

previously been discussed in this Appendix and in the Environmental Assessment.

Appendix C-14

Soils

Index: 23 Soil compaction from past harvest and proposed harvest.

Index: 26 Forest Service needs to determine if the 15% impact limit identified in Watershed

Conservation Practices and Soil Management Handbooks will be exceeded.

The discussion in the Soil Resource section in the EA on pages 64 to 66 addresses the concerns

presented by the commenter. A detailed study of the project area using aerial photographs shows

that only 6.3% of the area has been potentially impacted. With the proposed shift to group

selection or group shelterwood, harvest impacts will be more concentrated than during the

previous timber sale. Logging operators generally reuse old skid trails during harvest. By

harvesting in groups, only every other or every third existing skid trail will be required to remove

the wood.

Using modern mechanized felling equipment in group selection and group shelterwood cuts

allows the machine to reach out and cut several trees from a single location (usually on the skid

trail) and bundle the cut trees on the skid trail. The skidder then can pick up the bundle of logs

without leaving the skid trail. In this type of operation, machine use is concentrated in a small

part of the harvested area. The area which is impacted by multiple machine passes is limited to

the skid trail. The general rule-of-thumb is that on unfrozen and non-snow covered ground, a

parcel of soil can be ran over three times before soil compaction begins to occur. This will vary

depending on soil type, rock content, soil moisture, wheeled versus tracked equipment, and the

ground pressure of the wheel or track. Wheeled equipment is usually more impactive than

tracked equipment.

A common feature of current logging operations is that as a skidder returns to the forest for

another turn of logs, the skidder operator will grab a tong full of topwood or woody debris,

dropping the load in the skid trail or in cut groups to form a slash mat on which the equipment

runs on. The woody debris in the skid trail cushions the soil in the trail from soil compaction

particularly during winter logging. Slash mats also provide protection to the soil from erosion

and return a portion of the nutrients found in the woody debris back to the forest. Finally, slash

mats make off-road vehicle travel on skid trails after the timber sale unappealing.

In the Reforestation discussions on pages 30, 40, and 43 of the EA, site preparation following

timber harvest is expected to treat 7% of the 793 acre sale area under Alternative Two, and 12%

of the area under Alternative Three. These percentage figures include the site preparation in cut

groups and that portion of the 6.3% of the area in existing skid trails quoted above which would

be reused during this harvest entry.

On the next page are images of ground conditions found in a similar group selection harvest area

after reforestation site preparation.

Appendix C-15

West Pinos Timber Sale 2007. Ground conditions after site preparation in group selection of spruce stand.

Site was logged during the winter.

West Pinos Timber Sale 2007. Big Meadows Timber Sale 1999.

Cut group with advanced regeneration left unscarified. Regeneration and residual trees in cut group

after scarification.

Index: 24 Unable to control operations to minimize impacts.

Depending on the activity on a timber sale, the Timber Sale Administrator is on site every other

day or every third day. On very active operations, the Administrator is on site daily. The worst

potential for wet ground operations would be during spring snow melt, but logging will already

be shutdown to protect the roads before the snow in the forest melts. Logging operations are

then on hold until the ground firms up after spring snow melt.

Past experience with timber sale administration has not indicated that controlling operations is a

problem, and we do not expect this to change. The U.S. Forest Service has rigorous training

requirements for timber sale administrators, and timber sale contracts provide many provisions to

effectively control logging operations.

Appendix C-16

Index: 25 Winter logging operations would not be practical due to snow plowing expense.

Winter logging operations are common on the Gunnison Ranger District. The previous Sargents

Mesa #3 Timber Sale was winter logged during the winter of 1985- 1986. Similarly, about half

of the Cameron Park Timber Sale, all of the Big Bend Timber Sale, and portions of the Sawmill

Park Timber Sale were winter logged.

Roads

Index: 27 Roads impact soils, water quality and wildlife habitat, and facilitates the

introduction and spread of noxious weeds. Roads discourage use by lynx and goshawk.

The road system for the proposed Sargents Mesa Timber Sale is in place and has had nearly

thirty years for soils to stabilize. Management of the road system for Alternatives 2 and 3 is

identified on page 6 of the EA. Temporary roads would be constructed and closed following the

provisions of the Watershed Conservation Practices Handbook and Design Criteria for Water

Quality on page 14-15 and Transportation System on page 18.

The environmental consequences of roads and timber harvest on soils are presented on pages 64

to 66 of the EA. For water quality, see pages 71 to 72 of the EA.

The roads which are open now and are proposed to be open in all alternatives are low-use, low-

speed road (design speed less than 20 mph and a seasonal average daily traffic load of less than

100 vehicles per day as defined in the Southern Rockies Lynx Management Direction). Traffic

use is actually considerably less than this, about ten vehicles per week during the summer with

not much more during the early big game hunting seasons. Vehicle traffic is unlikely to be a

significant impact to lynx or goshawk use.

Noxious weeds have been addressed in the EA on pages 105 to 107 of the Environmental

Consequences, in the Project Design Criteria on page 15 and in Monitoring on page 19.

Index: 28 Road closures will not be effective due to ATV’s.

The type of physical road closure proposed for NFSR 578.2B and 578.2C has been found to be

effective at discouraging off-road ATV use. This is particularly true when snow is on the ground

as often is the case during hunting seasons. It is impossible to eliminate all illegal off road use of

ATV’s on the Forest, however, Sargents Mesa is a relatively low use area. Furthermore, recent

closure procedures applied by the Gunnison Ranger District have employed the use of multiple

physical barriers along the entire length of the road – rather than a gate. This physical closure

method has proven to be very effective.

Appendix C-17

Livestock Grazing

Index: 29 Impact of cattle on regeneration in treated areas. Control of grazing will be needed.

Observation of cattle grazing patterns in the Sargents Mesa area indicate cattle will generally

remain in the meadows. Little grazing impact has been found in the Sargents Mesa #3, Cameron

Park, and Big Bend Timber Sale areas. Roads on the mesa facilitate cattle movement through

forested areas between the parks, but the livestock do not spend much time along the way.

NFSR 578 is the route most noticeably used between Cameron Park and Sawmill Park. The

roadside clearcuts of the Cameron Park Timber Sale do receive some grazing, but little impact on

these young lodgepole pine stands has occurred.

Issue Determination

Index: 35 Several key issues that the EA states are significant are given short shrift, or go

unmentioned.

Index: 36 Exclusion of these and other important issues that the EA has identified from this

comparison table is arbitrary, and skews the analysis in downplaying the potential impacts from

either action alternative.

The determination of which issues to be addressed in the EA is discussed on pages 9 to 11 of the

EA, and in Appendix B (particularly pages B-9 to B-11). Issue determination was made by an

interdisciplinary team of specialists during several interdisciplinary team meetings. Issues were

obtained from public scoping, internal scoping, and from review of law and policy as described

on page 9 of the EA.

Table 1 on page 22 of the EA was intended to provide a quick comparison of each alternative in

terms of the identified issues. Table 1 was not intended to replace descriptions, discussions, and

determinations of resources and related resource issues found in Chapter 3 – Affected

Environment and Environmental Consequences of the EA.

Appendix C-18

References:

Alexander, Robert R. 1987. Ecology, silviculture, and management of the Engelmann spruce-

subalpine fir type in the central and southern Rocky Mountains. USDA Forest Service

Agriculture Handbook No. 659. Washington, D.C. 144 p.

Haines, A.L. 2010. Personal communication from Forest Stand Dynamics short course.

February 2 to 6, 2009. University of Washington & Yale University. USDA Forest

Service, Gunnison Ranger District, Gunnison, CO

Mehl, Mel S. 1992. Old-Growth Descriptions for the Major Forest Cover Types in the Rocky

Mountain Region. In Old-Growth Forests in the Southwest and Rocky Mountain

Regions, Proceedings of a Workshop, General Technical Report RM-213, USDA Forest

Service, Rocky Mountain Forest and Range Experiment Station, Fort Collins, Colorado.

Oliver, Chadwick D. and Bruce C. Larson. 1996. Forest Stand Dynamics, Updated Edition.

John Wiley & Sons, Inc. New York, New York.

Ruediger, Bill, Jim Claar, Steve Gniadek, Bryon Holt, Lyle Lewis, Steve Mighton, Bob

Naney, Gary Patton, Tony Rinaldi, Joel Trick, Anne Vandehey, Fred Wahl, Nancy

Warren, Dick Wenger, and Al Williamson. 2000, amended in 2003. Canada lynx

conservation assessment and strategy. USDA Forest Service, USDI Fish and Wildlife Service,

USDI Bureau of Land Management, and USDI National Park Service. Forest Service Publication

#R1-00-53, Missoula, MT. 142 pp.

USDA Forest Service. 1991. Amended Land and Resource Management Plan, Grand Mesa,

Uncompahgre, and Gunnison National Forests. U.S. Department of Agriculture, Forest

Service, Rocky Mountain Region, Denver, Colorado.

USDA Forest Service. 2008. Southern Rockies Lynx Management Direction, Record of

Decision. USDA Forest Service, Rocky Mountain Regional Office (R2), Lakewood, CO.

USDA Forest Service. 2009. Implementation Guide to the Southern Rockies Lynx

Amendment. May, 2009. USDA Forest Service, Rocky Mountain Regional Office (R2),

Lakewood, CO.

Appendix C-19

Appendix C-20

Appendix C-21

Appendix C-22

Appendix C-23

Appendix C-24

Appendix C-25

Appendix C-26

Appendix C-27

Appendix C-28

Appendix C-29

Appendix C-30