Draft Environmental Assessment
Tenmile Creek Water Supply Fuel Reduction Project
Helena, Montana
November 7, 2008


















	Federal Emergency Management Agency
	Department of Homeland Security
	500 C Street, SW
	Washington, DC 20472

This document was prepared by


URS Group, Inc.
12120 Shamrock Plaza, Suite 300
Omaha, NE 68154

and

200 Orchard Ridge Drive, Suite 101
Gaithersburg, MD 20878


Prepared for
	
FEMA Region VIII
Denver Federal Center
Building 710, Box 25267
Denver, Colorado 80255-0267


Contract No. HSFEHQ-06-D-0162
Task Order No. HSFEHQ-06-J-0048

15707048.00100

















ACRONYMS AND ABBREVIATIONS	iv
SECTION ONE	INTRODUCTION	1-1
1.1	Background and History	1-1
1.2	Purpose and Need	1-2
SECTION TWO	ALTERNATIVES	2-1
2.1	Alternatives not Retained	2-1
2.1.1	Fire Suppression	2-1
2.1.2	Buried Pipeline	2-1
2.2	Alternatives Considered	2-1
2.2.1	Alternative 1  No Action	2-1
2.2.2	Alternative 2  Tenmile Creek Water Supply Fuel Reduction Project (Proposed Action)	2-2
SECTION THREE	AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES	3-1
3.1	Topography, Geology, and Soils	3-1
3.1.1	Baseline Conditions	3-1
3.1.2	Environmental Consequences	3-3
3.2	Land Use and Zoning	3-3
3.2.1	Land Use	3-3
3.2.2	Floodplain Encroachment (Executive Order 11988)	3-4
3.2.3	Prime Farmland	3-4
3.3	Traffic and Circulation	3-4
3.3.1	Baseline Conditions	3-4
3.3.2	Environmental Consequences	3-4
3.4	Public Health and Safety	3-5
3.4.1	Baseline Conditions	3-5
3.4.2	Environmental Consequences	3-5
3.5	Socioeconomics	3-5
3.5.1	Economic Issues	3-5
3.5.2	Environmental Justice (Executive Order 12898)	3-6
3.6	Visual Resources	3-7
3.6.1	Baseline Conditions	3-7
3.6.2	Environmental Consequences	3-7
3.7	Air Quality	3-7
3.7.1	Baseline Conditions	3-7
3.7.2	Environmental Consequences	3-8
3.8	Public Services	3-8
3.8.1	Baseline Conditions	3-8
3.8.2	Environmental Consequences	3-9
3.9	Noise	3-9
3.9.1	Baseline Conditions	3-9
3.9.2	Environmental Consequences	3-9
3.10	Hydrology and Water Quality	3-10
3.10.1	Baseline Conditions	3-10
3.10.2	Environmental Consequences	3-10
3.11	Biological Resources	3-11
3.11.1	Wetlands (Executive Order 11990)	3-11
3.11.2	Vegetation	3-12
3.11.3	Terrestrial Wildlife	3-13
3.11.4	Aquatic Wildlife	3-14
3.11.5	Threatened, Endangered, and Special-Status Species	3-14
3.12	Cultural Resources	3-22
3.12.1	Baseline Conditions	3-22
3.12.2	Environmental Consequences	3-24
3.13	Recognized Environmental Conditions	3-24
3.13.1	Baseline Conditions	3-24
3.13.2	Environmental Consequences	3-25
3.14	Cumulative Impacts	3-25
3.15	Coordination and Permits	3-26
SECTION FOUR	SUMMARY	4-1
SECTION FIVE	AGENCIES CONSULTED AND REFERENCES	5-1
5.1	Agencies Consulted	5-1
SECTION SIX	REFERENCES	6-1
SECTION SEVEN	LIST OF PREPARERS	7-1
SECTION EIGHT	PUBLIC NOTICES	8-1
8.1	Initial Public Notice	8-1
8.2	Final Public Notice	8-2

Tables
Table 31: Soil Characteristics in the Red Mountain Flume Area	3-2
Table 32: Threatened and Endangered Species in Lewis and Clark County	3-21
Table 33: Summary of Effects Determination	3-22
Table 34: Historic Themes and Heritage Property Types in the Tenmile Watershed	3-23
Table 41: Comparison of Alternatives by Environmental Resource	4-2


Appendices
Appendix A	Exhibits
Appendix B	Montana Open Burning Periods
Appendix C	Agency Correspondence



ASTM	American Society for Testing Materials
BMPs	Best Management Practices
BOR	Bureau of Reclamation
CCC	Civilian Conservation Corps
Census	U.S. Census Bureau
CEQ	Council on Environmental Quality
CERCLIS	Comprehensive Environmental Response, Compensation, and Liability Information System
CFR	Code of Federal Regulations
CO	Colorado
DEQ	Department of Environmental Quality
EA	Environmental Assessment
EDR	Environmental Data Resources, Inc.
EO	Executive Order
EPA	U.S. Environmental Protection Agency
ESA	Endangered Species Act
FEMA	Federal Emergency Management Agency
FINDS	Facility Index System
Flume	Red Mountain Flume
FONSI	Finding of No Significant Impact
FWP 	Division of Fish, Wildlife, and Parks 
GYA 	Greater Yellowstone Area 
Helena	City of Helena
MBTA	Migratory Bird Treaty Act
MINES	Mine Master Index Files
msl	mean sea level
MT	Montana
NA	Not Applicable
NAAQS	National Ambient Air Quality Standards
NEPA	National Environmental Policy Act
NHPA	National Historic Preservation Act of 1966 (as amended)
NPL	National Priority List
NRCS	Natural Resources Conservation Service
NRHP	National Register of Historic Places
PDM	Pre-Disaster Mitigation
REC	Recognized Environmental Condition
ROD	Record of Decision
ROW	Right-of-Way
SHPO	State Historic Preservation Office
SPILLS	Spills or Hazardous Material Spills or Releases Database
T&E	Threatened and Endangered Species
USACE	U.S. Army Corps of Engineers
U.S.C	U.S. Code
USDA	United States Department of Agriculture
USFS	U.S. Forestry Service
USFWS	U.S. Fish and Wildlife Service
USGS	U.S. Geological Survey
VA	Veterans Affairs
WWII	World War II



SECTION One INTRODUCTION 
1.1 BACKGROUND AND HISTORY
The city of Helena (Helena) is located in the eastern foothills of the Rocky Mountains in Lewis and Clark County, Montana (MT). Exhibit 1 shows the location of Helena, MT. Helenas Water Treatment Division is responsible for supplying the city with safe drinking water and maintaining all water plants, pumping stations, reservoirs, head gates, and other equipment necessary to maintain the water treatment system. The main source of Helenas municipal water is the Upper Tenmile Creek Watershed. The Upper Tenmile Creek Watershed, which is predominantly forested, lies south of U.S. Highway 12 about 7 miles west of Helena. The watersheds most prominent landmark is Red Mountain, which lies in the southeast corner of the watershed and has a summit elevation of 8,150 feet above mean sea level (msl). Total acreage of the Upper Tenmile Creek Watershed is approximately 26,300 acres (Helena 2008).
Helena owns the first and second water rights on Tenmile Creek, which equates to approximately 8.9 million gallons of water per day that can be provided to residents of the city following treatment at the Tenmile Water Treatment Plant. Currently, this is the only source of water the city uses for 9 months of the year. During peak water demand in the summer, additional water is obtained from the Missouri River. The Veterans Affairs (VA), VA Hospital, and Montana National Guard facilities at Fort Harrison rely exclusively on the Tenmile Creek Watershed to fill their water storage tanks needed for fire suppression (Helena 2008).
The Red Mountain Flume (Flume) is a critical portion of the water conveyance system for the Helenas water supply. The Flume starts on the west side of Red Mountain near Banner Creeks confluence with Tenmile Creek and follows the contour of Red Mountain to the north and east for a distance of approximately 4.8 miles to Chessman Reservoir. Exhibit 2 shows the location of the Flume. The Flume elevation runs from 6,300 feet msl to 6,220 feet msl. The conveyance is comprised of 13,000 feet of open unlined ditch, 11,800 feet of sheet metal Flume, and 500 feet of pipeline. Wood trestles in nine separate sections support approximately 20 percent of the Flume (4,936 feet) at proper elevations for water to flow. Exhibit 3 shows an example of the trestle sections. Approximately 2.1 miles of the length of the Flume is on private land and 2.7 miles is located on Helena National Forest land (Helena 2008).
Wildland fire is inevitable in this watershed. Fuel, weather, and physical setting determine fire behavior. The combined effects of past fire suppression, heavy fuel loads, an extended drought period, and an active pine beetle infestation have put forests in the Tenmile Creek drainage at risk of a catastrophic wildfire. Approximately 15 percent of the mature Lodgepole pine in the project area has been recently killed as a result of a Western Pine Beetle infestation. The ongoing infestation may result in mortality rates as high as 50 percent over the next 5 years (Montana Prescribed Fire Services, Inc. 2007). The increasing abundance of dead and dying trees contributes to the existing wildfire hazard. Combined effects of a large-scale forest fire in the Upper Tenmile Creek drainage could threaten the major source of Helenas water supply (Helena 2008).
A catastrophic wildfire would destroy the wooden timber and plank trestles of the Flume. Intense heat, fallen burned trees, and other debris would damage the metal Flume, diversions, and waste gates. Sediments and debris would impede water flow. It would also denude the watershed and cause erosion, which would destroy or render the entire Flume useless (Helena 2008).
A severe wildfire in Tenmile Watershed would result in a minimum 23-month loss of water supply from the Tenmile Water Treatment Plant. Municipal water would then need to be supplied by the Missouri River Treatment Plant, which is 50 years old and is only used to supply water for 3 months during peak use. The Missouri River water would have to be purchased from the Bureau of Reclamation (BOR) and would need to be pumped to the city. Helena would need to rely on the Missouri Plant for a minimum of 23 months until the Flume could be replaced with a buried pipeline. Currently, the Missouri Plant has limited capability to provide year-round water to the city (Helena 2008).
Helena has applied for funding through the Federal Emergency Management Agencys (FEMA) Pre-Disaster Mitigation (PDM) Program. This assistance would be used to reduce the fuel load in the Upper Tenmile Creek Watershed along the Flume.
The Council on Environmental Quality (CEQ) has developed regulations to implement the National Environmental Policy Act (NEPA). These regulations, as set forth in Title 40, Code of the Federal Regulations (CFR) Parts 1500-1508, require an investigation of the potential environmental impacts of a proposed Federal action, and an evaluation of alternatives as part of the environmental assessment process. The FEMA regulations that establish the agency-specific process for implementing NEPA are set forth in 44CFR Subpart 10. This Environmental Assessment (EA) was conducted in accordance with both FEMA and CEQ NEPA regulations.
1.2 PURPOSE AND NEED
The purpose of FEMAs PDM program is to substantially reduce the risk of future damage, hardship, loss, or suffering in communities from natural disasters, including wildfires, by providing the affected communities with cost-share funds to reduce future losses.
Based on the continuing potential for a major wildfire in the Upper Tenmile Creek Watershed that could render the Flume useless, Helena has identified the need to protect the Upper Tenmile Creek Watershed system that supplies water to the Helena area by reducing the fuel load near the Flume. 

SECTION Two ALTERNATIVES
The Presidents CEQ has developed regulations for the preparation of environmental impact documents in compliance with NEPA. CEQ requires an investigation and evaluation of practicable alternatives as part of the environmental assessment process. The following subsections provide a description of alternatives considered but not retained for further evaluation, as well as alternatives that were considered and retained for evaluation in the EA.
2.1 ALTERNATIVES NOT RETAINED
2.1.1 Fire Suppression
Helena considered fire suppression without any fuel reduction as an alternative. However, there is limited road access to the Flume area. Therefore, fires would have to be fought primarily by hand with water dropped by helicopter. Water would be used because fire retardant cannot be used in a municipal water supply watershed. This alternative was determined to be an ineffective way to protect the Flume from fire, and was removed from further consideration.
2.1.2 Buried Pipeline
Replacing the existing Flume with a buried pipeline was considered as a potential action that would satisfy the purpose and need. This alternative would increase the efficiency of the water system, be less costly to maintain, and have minimal risk from wildfire. However, Helenas long range plan is to use the Missouri River as its primary water source, with the Flume used as a supplemental water source. Therefore, converting the Flume to a buried pipeline has less priority than improvements to the Missouri River System. 
Additionally, burying an approximately 5-mile pipeline at an altitude of 6,200 feet in a remote area with limited road access means a short construction season due to heavy snows and frozen ground. The limited road access means that materials would need to be taken to the site via helicopter. It would take 18 months for Helena to obtain funding, project design, environmental reviews, permits, and a contractor before construction could begin on the pipeline. This means that the Tenmile Treatment Plant would not provide sufficient water volume for at least 23 months. Also, Helena would need to lease a mobile water treatment system for 3 months during the peak season to meet demands and to assure fire protection for VA, VA Hospital, and Fort Harrison. Therefore, this alternative was determined to be logistically and fiscally unacceptable.
2.2 ALTERNATIVES CONSIDERED
The potential environmental impacts for two alternatives are evaluated in this report. These alternatives include:
* Alternative 1  No Action 
* Alternative 2  Tenmile Creek Water Supply Fuel Reduction Project (Proposed Action)
2.2.1 Alternative 1  No Action
With the No Action Alternative, no action would be taken to protect the Flume. No treatments such as thinning, hand piling, controlled burning, and debris removal would be done. No vegetative treatments would be undertaken to treat stands. The potential for catastrophic wildfire damaging or destroying the Flume would remain, which could severely affect Helenas water supply. This alternative would include continued maintenance and repair activities on the Flume.
2.2.2 Alternative 2  Tenmile Creek Water Supply Fuel Reduction Project (Proposed Action)
The project area would include approximately 108 acres of privately owned land in Lewis and Clark County, MT, Township 8 North, Range 5 West, Sections 3, 4, 5, 8, and 9. Exhibit 4 shows the project area.
The proposed action would involve the removal of dead timber to greatly reduce the fuel load along the trestle sections of the Flume located on privately owned land. This action would emphasize the removal of dead and beetle-infested Lodgepole pine and small diameter trees that contribute to the wildfire hazard. All deadfall (regardless of tree species) would be removed, along with old trestle timbers and planks that have been stacked near the Flume. 
The project would be completed in three phases, and activities would occur only on privately owned land. The first phase of the work would occur at the ends of the trestle sections located on privately owned land. Vegetation removal would extend 150 feet beyond the end of the trestle at each location and down slope for 300 feet. This distance would reduce the flame length and rate of spread during a fire and would prevent damage to the trestles. All dead and/or fallen timber 3 inches in diameter or larger and all Lodgepole pine would be removed. 
The second stage would concentrate on the length of the Flume on privately owned land. For approximately 100 feet above the Flume, all downed and standing dead timber 3 inches in diameter or larger would be manually cut and removed to reduce fire intensity and to prevent erosion above the Flume. In general, all the removed material would be taken to an area below the Flume to be safely burned. No burning would occur above the Flume except in areas that are predominantly rock.
The third phase would consist of mitigating the fuels for 300 feet below the Flume on privately owned land, connecting with the work previously completed in Phase 1 off the ends of the trestles. 
2.2.2.1 Mechanical Clearing
Mechanical mitigation would consist of using a processor that cuts each tree at the base, removing and piling the limbs for burning, and cutting and stacking the stems to be transported by a forwarder. The forwarder is used to remove the tree stems to an area for transportation by truck. Mechanical clearing would occur between mid-October and mid-December, when the ground is frozen and dry. Mechanical equipment would be used only where road or trail access is present. No new permanent or temporary roads would be constructed as part of this project. Exhibit 5 provides an example of the trails in the project area. 
2.2.2.2 Hand Clearing
Hand clearing would be done in areas where road access is limited and/or areas where slopes are over 30 percent grade. Hand crews would be required to walk into the project area from existing roads or trails. Streamside Management Zones would be established adjacent to all streams and associated riparian areas. These are areas that include stream, lake, or other water body and an adjacent area where management strategies are applied to protect water quality and maintain stream temperature. These zones would extend 50 to 100 feet on each side of the streambank. 
Hand piles would be built not to exceed 8 feet in diameter on slopes less than 20 percent. The hand piles would be placed on the numerous rock outcroppings and rock scree areas to prevent them from rolling downhill. On some rockslide areas, trees would be cut 12 to 18 inches above the rock surface to avoid erosion. Manual treatment would begin around mid-September and continue through November.
2.2.2.3 Burning
When cut material is to be burned in place, an area would be selected with little or no vegetation at least 100 feet below the Flume. Burning of the piles would take place in the late fall when snow cover is on the ground and in the spring during rainy periods. Additionally, the hand piles would be constructed where the canopy is open to prevent scorching of live trees. As indicated above, most burning would occur below the Flume. However, if necessary, burning may occur above the Flume, but only in areas that are predominantly rock.
2.2.2.4 Maintenance
Montana Prescribed Fire Services, Inc. (2007) recommended that the project site be maintained after 10 years. The maintenance would be at a much lower cost than the original treatment and would extend the life of the project for another 10 years, making the total useful life of the project 20 years.


SECTION Three AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
3.1 TOPOGRAPHY, GEOLOGY, AND SOILS
3.1.1 Baseline Conditions
Red Mountain is located less than 15 miles east of the Continental Divide in the northern Rockies and approximately 7 miles southwest of Helena. The mountain is within the Lewis and Clark Range of the Northern Rocky Mountains, a physiographic region of the Cordilleran orogen. The Cordilleran orogen, which encompasses the western part of the United States, extends north and south beyond the Mexican/Canadian borders and from the offshore continental borderlands of the Pacific as far east as the Black Hills of South Dakota. Physiographically, the area includes high mountains, intervening lowlands, and plateaus. The continental margin containing the Cordilleran orogen originated about 600 million years ago, and has undergone extensive deformation since that time (Burchfiel et al. 1992). Two major uplift events have occurred in the area since the end of Cretaceous time, about 65 million years ago, with significant erosion occurring between the events. The first event was compressive, resulting in northwest trending folds and thrust-faults. The second event occurred from about 30 million to 2 million years ago and resulted in block faulting, causing vertical displacement of the rock thousands of feet. Significant erosion occurred between the two events. 
The project area follows the Flume along the contours of Red Mountain. Thus, the area includes some slopes of greater than 30 percent. More level areas occur near Chessman Reservoir. The topography of the area is show in Exhibit 4. 
The following soils were identified in the project area (USDA 2001):
* Andic Cryochrepts, Moraines
* Typic Cryochrepts, colluvial deposits
* Typic Cryoboralfs, bouldery, granitic substratum
* Typic Cryochrepts-Rubble land complex, steep
* Typic Cryochrepts, bouldery granitic substratum, steep
* Cirqueland
* Typic Cryoboralfs-Typic Cryochrepts complex, granitic substratum
Table 3-1 provides the specific characteristics of these soils. 

Table 31: Soil Characteristics in the Red Mountain Flume Area
Map Unit
 Symbol
Map Unit Name
Elevation
(feet msl)
Landform
Parent Material
Slope
(percent)
Vegetation Classification
Typical Profile
12C
Andic Cryochrepts, Moraines
6,000 to 8,000
Moraines
Glacial till
15 to 40 
subalpine fir/smooth wood-rush;
Very cobbly sandy loam






subalpine fir-whitebark pine/grouse whortleberry









14
Typic Cryochrepts, 
colluvial deposits
5,000 to 6,800
Intermontane basins,
toes on mountains
Colluvium
25 to 30
spruce/twinflower; subalpine fir/twinflower
Very cobbly loam








36
Typic Cryoboralfs, bouldery,
granite substratum
5,000 to 6,400
Upland slopes
Colluvium derived from granite
25 to 40
Douglas-fir/pinegrass; Douglas-fir/snowberry
Coarse sand to gravelly sandy clay loam








56A
Typic Cryochrepts-Rubble land complex, steep
6,000 to 7,000
Mountain slopes
Colluvium derived from granite
40 to 60
Douglas-fir/pinegrass; subalpine fir/grouse whortleberry
Extremely cobbly sandy loam








76
Typic Cryochrepts, bouldery, granitic substratum, steep
6,000 to 7,500
Mountain slopes
Colluvium derived from granite
25 to 50
subalpine fir/beargrass; subalpine fir/menziesia; subalpine fir/grouse whortleberry
Very gravelly sandy loam








80
Cirqueland
6,000 to 9,500
Cirque headwalls; basin floors
NA
NA
NA
NA








120
Typic Cryoboralfs-Typic Cryochrepts complex, granitic substratum
5,000 to 6,000
Mountain slopes
Colluvium derived from granite
10 to 25
subalpine fir/dwarf huckleberry; subalpine fir/beargrass; subalpine fir/grouse whrotleberry
Gravelly sandy loam to very gravelly sandy clay loam


3.1.2 Environmental Consequences
None of the alternatives have the potential to affect geology or topography within or adjacent to the project area.
3.1.2.1 Alternative 1  No Action
The No Action Alternative does not involve any activities, other than general maintenance and repair of the Flume on an as needed basis. Therefore, the alternative would not have a direct affect on soils in the project area. However, erosion and sedimentation could result from a precipitation event following a future wildfire. Severe wildfires create hydrophobic soils that do not allow water penetration until vegetation and organic matter can be re-established. Therefore, the No Action Alternative has the potential for significant indirect impacts to soils, which could cause the Flume to fail.
3.1.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The project area includes approximately 108 acres of land. No excavation activities would occur with this action. Mechanical equipment would be used where road or trail access is present. No new permanent or temporary roads would be constructed as part of the proposed project. In areas where rockslides are possible, trees would be cut 12 to 18 inches above the rock surface to avoid erosion. The mechanical and hand clearing activities would be completed in accordance with Best Management Practices (BMPs) for Forestry in Montana, thereby reducing the likelihood of impacts to soils.
3.2 LAND USE AND ZONING
3.2.1 Land Use
3.2.1.1 Baseline Conditions
The project area is in the Upper Tenmile Creek Watershed along the Flume. The Flume itself is owned by Helena. However, the land beneath the Flume is owned by Helena, U.S. Forest Service (USFS), and private individuals. The project area specifically is all privately owned land. An easement was not legally required when the Flume was built in 1864 and 1865; however, Helenas Certificate to Appropriate Water provides the legal documentation and proof of Helenas easement and access rights for the Flume.
3.2.1.2 Environmental Consequences
Alternative 1  No Action
With the No Action Alternative, the current land use within the project area would not change. However, if a wildfire occurred and destroyed the Flume, the potential loss of the Flume would adversely affect Helenas water conveyance system.
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Implementation of the Proposed Action would not change the land use within the project area. The area would continue to be used as part of the drinking water supply system for Helena. However, the fuel reduction project would minimize the potential for future wildfires that could destroy the Flume, which would maintain the current and future land use of the area. 
3.2.2 Floodplain Encroachment (Executive Order 11988)
3.2.2.1 Baseline Conditions
The project area is located in an area designated as Zone Careas of minimal flooding by FEMA (FEMA 1985). According to the PDM subapplication submitted by Helena, the area is not located in a 100-year floodplain.
3.2.2.2 Environmental Consequences
The project area is not located within a designated 100-year floodplain or floodway; therefore, no designated floodplains would be impacted by either alternative.
3.2.3 Prime Farmland
The Natural Resources Conservation Services (NRCS) online soil survey indicated that none of the soils identified in Section 3.1 are considered prime or unique farmland (NRCS 2008). Since no farmland, including prime farmland, is located within either project area, neither alternative has the potential to affect prime farmland and the intent of the Farmland Protection Policy Act is met. Therefore, impacts to prime farmland were not considered further and NRCS Form AD-1006 was not completed.
3.3 TRAFFIC AND CIRCULATION
3.3.1 Baseline Conditions
There are no named roads within the project area. Named roads in the vicinity include Rimini Road, Chessman Road, and Peerless-Jennie Road. In addition, there are several unnamed National Forest roads that provide access to residents and National Forest visitors.
3.3.2 Environmental Consequences
3.3.2.1 Alternative 1  No Action
The No Action Alternative does not involve any activity other than maintenance and repair; therefore, it would have no impact on the traffic in the study area. 
3.3.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Minor impacts to local traffic may occur during vegetation removal activities due to the influx of mechanical tree removal equipment and trucks. Mechanical equipment would use existing roads such as Remini Road, Chessman Road, or Peerless-Jennie Road and National Forest roads to access the general project area. These are two-lane public roads without shoulders; therefore, the ingress and egress of the mechanical equipment could cause short delays in local traffic as equipment is moved into and out of the area. Both local residents and visitors to the National Forest could be affected by the ingress and egress of the equipment on the public roads. This impact would be minor and limited to the duration of the project activities. Helena would notify residents in the area about the clearing activities via letters to individual residents and a public notice in a local newspaper (Hedstrom 2008). 
Within the immediate vicinity of the Flume, Helena would use existing ATV and 4-wheel drive trails to access the project. The movement of equipment on these trails is not expected to have any impact on local traffic.
3.4 PUBLIC HEALTH AND SAFETY
3.4.1 Baseline Conditions
Helena provides water to approximately 68,800 residents in the greater Helena area (Helena 2008). Ensuring access to safe drinking water for residents is a high priority to Helena. For 9 months of the year, water is provided to the city exclusively from the Upper Tenmile Creek Watershed. The Flume is a critical portion of the Upper Tenmile Creek conveyance system. 
3.4.2 Environmental Consequences
3.4.2.1 Alternative 1  No Action
The No Action Alternative would not include any steps to reduce the fuel load in the project area. With the heavy fuel load due to dead and diseased trees, a wildfire in the watershed could result in a stand replacement fire (i.e., loss of all tress) that could potentially damage property, impact air quality, and result in loss of life. 
A severe wildfire could also result in substantial damages to Helenas conveyance water system. It is estimated that a wildfire in the Upper Tenmile Creek Watershed that destroyed the Flume would result in a loss of water supply from this watershed for a minimum of 23 months. Helena would be forced to obtain water from the Missouri River. The existing Missouri River Treatment Plant does not currently have the capacity to provide the amount of water necessary to meet the needs of Helena and its residents. Therefore, if a wildfire were to occur within the Flume area and watershed, potential public health and safety impacts could be significant. 
3.4.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Alternative 2 would reduce the fuel load around the Flume, thereby reducing the potential for wildfires and minimizing the risks to the Flume and Helenas water supply. Additionally, the proposed project would reduce the wildfire risks to residents in the surrounding forested area; therefore, having a positive impact on public health and safety in the area.
3.5 SOCIOECONOMICS
3.5.1 Economic Issues
3.5.1.1 Baseline Conditions
Helena became the territorial capital of Montana in 1875 and the State capital in 1894. Montana State Government is the largest employer in the area. Helena acts as an educational, commercial, recreational, cultural, and political center for the entire State of Montana.
According to the 2000 U.S. Census (Census 2000a), the median family income in Helena is $50,018 and the per capita income is $20,020. Of the individuals over the age of 25, approximately 93 percent are high school graduates and 40 percent have received an advanced degree (bachelors degree or higher). 
Alternative 1  No Action
The No Action Alternative could have a significant economic impact on the Helena area. If a wildfire were to destroy the Flume, the Tenmile Treatment Plant would also be out of service at great expense to Helena and its water consumers. Helena would have to purchase water from the BOR and pay to pump it from the Missouri River to the treatment plant (approximately 700 feet of head). Helena would also need to rent mobile water treatment trailers because the Missouri River Treatment Plant does not have the capacity to meet peak water demands. These actions would be costly to Helena and would result in higher utility fees to consumers.
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The proposed action would minimize the immediate wildfire risk to the Flume, which is an integral part to Helenas current water supply. With this action, Helena would have time to make upgrades to the Missouri River Treatment Plant and convert Helenas main water supply from the Tenmile Creek Watershed to the Missouri River, which is part of the citys long-range plans. Making the conversion over a period of time allows Helena to accumulate funds for the changes without putting a financial strain on its citizens. Therefore, the proposed action represents a long-term, positive impact on the economics of Helena and the water consumers. 
The Helena area would also experience a short-term economic benefit during the life of the project due to the purchase of goods and services.
3.5.2 Environmental Justice (Executive Order 12898)
3.5.2.1 Baseline Conditions
Executive Order (EO) 12898, entitled Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations, directs Federal agencies to make environmental justice part of its mission by identifying and addressing, as appropriate, disproportionately high and adverse human health or environmental effects of its programs, policies, and activities on minority populations and low-income populations. 
The 2000 U.S. Census Bureau information was used to characterize the area. Based on this data, Helena has a population of 25,780, of which approximately 95 percent are Caucasian. The largest minority population is American Indian/Alaska Native, which comprises 2.1 percent of the population. Similarly, 95 percent of the county is Caucasian. The largest minority population in the county is also American Indian/Alaska Native, which comprises 2 percent of the population (Census 2000a, 2000b).
As indicated earlier, approximately 68,800 people rely on Helena for their water supply. The demographics of these residents are not available. The project area involves lands owned by 19 different people. The demographics of these residents are also not available. 
According to the Census data (Census 2000a, 2000b), Helena has a poverty rate of 9.3 percent for individuals and 14.5 percent for families. Lewis and Clark County has a poverty rate of 10.9 for individuals and 7.3 percent for families. 
3.5.2.2 Environmental Consequences
Alternative 1  No Action
The maintenance and repair activities associated with the No Action Alternative would not disproportionately adversely affect any population, including low-income and/or minorities.
If a wildfire were to occur and damage or destroy the Flume and therefore Helenas water system, all populations, including low-income and/or minorities, would be equally affected.
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action) 
The proposed action would reduce the risk of a wildfire destroying the Flume; therefore, providing a long-term positive impact to all populations. 
This federally-funded proposed project would not create disproportionally high and adverse effects on minority or low income populations. 
3.6 VISUAL RESOURCES 
3.6.1 Baseline Conditions
Helena is located approximately 20 miles east of the Continental Divide in the northern Rockies. The city is located in the foothills and extends into a large valley. 
The project area is located in the Upper Tenmile Creek Watershed southwest of Helena, which is predominantly forested and includes Red Mountain, Colorado Mountain, and Black Mountain. The Flume is located on Red Mountain, which has a summit elevation of approximately 8,150 feet. The Flume is located at approximately 6,250 feet. The area is forested primarily by Douglas fir, Engelmann spruce, and Lodgepole pine. However, the area has been infested with Western pine beetles, and dead Lodgepole pines are readily visible within the viewshed. 
The Flume, a City-owned cabin, and the occasional glimpse of a road are the only manmade structures visible within the project area. 
3.6.2 Environmental Consequences
3.6.2.1 Alternative 1  No Action
With the No Action Alternative, the viewshed would not be altered unless a wildfire were to occur in the vicinity of the project area. Such a wildfire would change the forested view to charred mountain slopes with little or no vegetation. This would be a significant impact.
3.6.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The proposed action involves the removal of dead and fallen trees (3 inches in diameter and larger) within approximately 300 feet down slope and 100 feet up slope of the Flume and all Lodgepole pines within approximately 300 feet down slope of the Flume. 
The loss of all Lodgepole pine for 300 feet down slope of the Flume would have both a positive and negative impact on the viewshed. The negative impact would be related to the loss of numerous standing trees, thus there would be fewer standing trees visible when looking at the mountainside. However, long term there would be a positive impact on the viewshed, as the removal of dead and fallen trees would make the viewshed look clearer and more attractive. Additionally, the removal of diseased Lodgepole pines would give the appearance of a healthier forest and give new, healthy trees room to grow. 
3.7 AIR QUALITY
3.7.1 Baseline Conditions
The National Ambient Air Quality Standards (NAAQS), established by the U.S. Environmental Protection Agency (EPA), define the allowable concentrations of pollutants that may be reached but not exceeded in a given time period in order to protect human health (primary standard) and welfare (secondary standard) with a reasonable margin of safety. These standards include maximum concentrations for ozone, carbon monoxide, nitrogen dioxide, sulfur dioxide, lead, and particulate matter (10 microns or less and 2.5 microns or less). 
The East Helena area is considered a NAAQS Attainment Area for all air quality parameters, except lead and sulfur dioxide (EPA 2008). The East Helena area is not located within the project area. The rest of the area surrounding the project area is in attainment for all air quality parameters.
Helena and Lewis and Clark County Health Departments and the Montana Department of Environmental Quality (DEQ) have air quality restrictions and require pile burning be done on the best air quality days. The Montana DEQ operates a year-round open burning program and issues air quality open burning permits for specific types of open burning. The burning program and burning restrictions are included in Appendix B.
3.7.2 Environmental Consequences
3.7.2.1 Alternative 1  No Action
No activities would occur with the No Action Alternative, and air quality would not be affected within either the study area or Helena. However, a wildfire within the area could have a significant short-term negative impact on air quality from smoke and ash.
3.7.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
During vegetation removal activities, the Proposed Action would have temporary, minor impacts on air quality related to increased dust levels generated by the removal of trees. Any adverse impacts would be short-term and localized. 
During hand pile burning, Montana DEQ burn plan rules would be followed to minimize air quality impacts. Helena would also need to coordinate with Montana DEQ to determine if the proposed project is a major burn as defined in the Major Open Burning Guidelines. If the project is determined to be a major burn, Helena would need to submit the written request form prior to conducting any slash pile burns. A permit from the USFS would be required prior to doing any burning. It will also be necessary for Helena to inform the Lewis and Clark County Sheriffs Office before performing any burns. Correspondence with these agencies is included in Appendix C. 
3.8 PUBLIC SERVICES
3.8.1 Baseline Conditions
Public services and associated providers within the Helena area include:
Water/Sanitary Sewer				Wells and Septic Systems
Telephone					Cell Phones
Electrical Power				Northwestern Energy
Emergency Medical Services			St Peters Hospital
Fire Protection	Helena, USFS, Department of Natural Resources and Conservation, Volunteer Fire Departments

Law Enforcement
County Sheriff				Lewis and Clark County
State Highway Patrol			State of Montana
Utility Location Service			Utility Underground Location Service
The project area is remote and most residents near the project area are not connected to public utilities. They rely on solar power, private water wells, propane, septic tanks, and satellite for their utility needs. Telephone service is generally through cell phone providers. Utilities Underground Location Center (800-424-5555) provides the utility location service in Lewis and Clark County, MT.
3.8.2 Environmental Consequences
3.8.2.1 Alternative 1  No Action
If no action is taken to reduce the fuel load along the Flume and a major wildfire occurs in the area, the water supply for Helena and the surrounding areas would be adversely impacted. Loss of the Flume would require Helena to purchase, treat, and deliver water from the Missouri River until the Flume is repaired (up to 23 months).
In addition to adverse impacts on Helenas water supply, a wildfire in the vicinity of the Flume would put a strain on local fire protection resources.
3.8.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
There are no buried or overhead utility lines within the project area. Therefore, the proposed action would not cause interruption of Helenas utility service. 
Reducing potential wildfires would have a long-term beneficial impact on Helenas water supply by providing protection to the Flume. 
3.9 NOISE
3.9.1 Baseline Conditions
Sounds that disrupt normal activities or otherwise diminish the quality of the environment are considered noise. Noise events that occur during the night (10 p.m. to 7 a.m.) are more annoying than those that occur during normal waking hours (7 a.m. to 10 p.m.). Noise events within the project vicinity are presently associated with climatic conditions (e.g., wind and thunder) and nature (birds). Traffic noise is minimal, as the Flume is located within a sparsely populated area. 
There are no sensitive receptors within the project area.
3.9.2 Environmental Consequences
3.9.2.1 Alternative 1  No Action
With the No Action Alternative, noise levels would not change or be affected.
3.9.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
With Alternative 2, noise levels within the project area would increase during vegetation removal activities. Impacts would be short-term and localized, and activities would be limited to daylight hours (7:00 a.m. to 6:00 p.m.). All mechanical equipment (vehicles, chainsaws, etc.) would be equipped with proper mufflers and/or properly maintained to minimize the noise produced. These types of noise are not uncommon in a forested area; therefore, the temporary activities associated with the proposed action would not create a significant impact on noise within the project area.
3.10 HYDROLOGY AND WATER QUALITY
3.10.1 Baseline Conditions
The project area is located in the Upper Tenmile Creek Watershed, which encompasses approximately 26,300 acres. There are four perennial streams within 200 feet of the project area: Tenmile Creek, Banner Creek, Beaver Creek, and an unnamed tributary to the Flume. Chessman Reservoir is located at the termination of the Flume.
Tenmile Creek is located west and north of the project area. The creek is approximately 29 miles long and runs from its headwaters in the mountains southwest of Helena to its confluence with Prickly Pear Creek northeast of Helena. Tenmile Creeks designated uses include agriculture, aquatic life, cold water fisheries, drinking water, industrial, and primary contact recreational. The creek is considered impaired for all these uses due to metal contamination, flow alternation, and sedimentation/siltation.
The Flume receives water from Banner Creek, as well as the following non-perennial streams: Lindsay Creek, Eureka Creek, Salle Belle Creek and Wilson Creek. During spring runoff, water from these creeks is diverted into the Flume, which conveys the water to Chessman Reservoir. Chessman Reservoir has no other surface water sources. Banner Creek is a tributary of Tenmile Creek that also starts in the mountains southwest of Helena. The Flume begins at Banner Creek near its confluence with Tenmile Creek on the west side of Red Mountain. Banner Creek was not included on the Montana list of impaired waterways.
The water from Chessman Reservoir is conveyed through Beaver Creek to a headgate located in Remini, MT. At the headgate, water is diverted into a 12-inch, 7-mile-long underground pipe which conveys the water to the Tenmile Water Treatment Facility. The pipeline allows for water collection directly from the Tenmile Creek, Minnehaha Creek, Moose Creek, and Walker Creek. If water in Beaver Creek is not diverted at the headgate, it continues to flow westward to Tenmile Creek. Beaver Creek was not included on the Montana list of impaired waterways. 
3.10.2 Environmental Consequences
Neither alternative has the potential to affect the overall hydrology of the streams in the vicinity of the project area; therefore, hydrology is not discussed further in this document.
3.10.2.1 Alternative 1  No Action
With the No Action Alternative, no changes would occur to the Upper Tenmile Creek Watershed or the streams in the vicinity of the project area. However, if a wildfire were to occur, there could be significant negative impacts on water quality due to the loss of vegetation and the creation of hydrophobic soils resulting in sedimentation rates of 200 to 300 percent greater than normal (Helena 2008). 
3.10.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The proposed project would not adversely impact the water quality of any of the previously mentioned creeks or water sources. Mechanical equipment would be used only where road or trail access is present and perennial streams would be crossed only at existing crossings. Mechanical treatment would be completed on dry or frozen ground. Burning of the hand piles would take place in late fall when snow cover is on the ground and in the spring during rainy periods. These precautions would eliminate or minimize any increased stream sedimentation. 
Streamside Management Zones would be established adjacent to all streams and associated riparian areas. These are areas that include stream, lake, or other water body and an adjacent area where management strategies are applied to protect water quality and maintain stream temperature. These zones would extend for 50 to 100 feet on each side of the streambank and no mechanical equipment would be used in these areas. Additionally, Best Management Forestry Practices would be employed during project activities to minimize any environmental impacts to water resources within the project area. 
3.11 BIOLOGICAL RESOURCES
3.11.1 Wetlands (Executive Order 11990)
Wetlands provide significant ecological functions which include: (1) providing habitat for numerous aquatic and terrestrial wildlife species; (2) aiding in the dispersal of floodwaters; (3) improving water quality through retention and assimilation of pollutants from storm water runoff; and (4) recharging the aquifer. Wetlands also possess aesthetic and recreational values. EO 11990, entitled Protection of Wetlands, requires Federal agencies to take action to minimize the loss of wetlands. Activities disturbing jurisdictional wetlands require a permit from the U.S. Army Corps of Engineers (USACE).
3.11.1.1 Baseline Conditions 
The U.S. Geological Survey (USGS) National Map indicated the only jurisdictional wetlands and areas containing wetland vegetation are located near Chessman Reservoir. However, the Fuel Mitigation Prescription prepared by Montana Prescribed Fires Services, Inc. (2007) indicated there are approximately five riparian areas that intersect the Flume between Banner Creek and Chessman Reservoir. These areas have a heavy concentration of large, old-growth Engelmann spruce. 
3.11.1.2 Environmental Consequences
Alternative 1  No Action
With the No Action alternative, conditions would not change unless a wildfire would occur which could create hydrophobic soils, resulting in an increase in sedimentation. The sedimentation could significantly impact wetlands. 
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The USACE was contacted on August 25, 2008, regarding the proposed project and they indicated a 404 Permit would not be required. The USACE also indicated that if temporary roads would need to be constructed across a steam, a crossing permit from the USACE would be required. Currently, the proposed project does not include the construction of temporary roads; therefore, no crossing permit would be required. Correspondence with USACE is included in Appendix C.
3.11.2 Vegetation
3.11.2.1 Baseline Conditions
The project area is located at approximately 6,250 feet msl and vegetation within the project area consists of two basic habitat types: upper, mixed forest and lower, subalpine forest. These habitat types are described in more detail below. 
Upper, mixed forest. Upper, mixed forest contains habitat types with forest stands generally comprised of Douglas fir/Lodgepole pine, or a mixture of these species (U. S. Department of Agriculture [USDA] 2001). This habitat type group is extensive at elevations ranging from 4,200 to 7,000 feet above msl, which is generally above the cold limits of Ponderosa pine. 
Lower subalpine forest. Lower subalpine forest contains habitat types on which forest stands generally are Lodgepole pine (USDA 2001). This habitat type group is extensive at elevations from 6,000 to 7,200 feet above msl. Douglas fir is not common, although it is sometimes present on southerly aspects at lower elevations. Engelmann spruce and subalpine fir are sometimes dominant in old growth stands. 
Ninety-five percent of the timber on the north aspect of Red Mountain is Lodgepole pine, in a variety of age groups. Fifteen percent of the stand is standing dead timber with recent evidence of Western pine beetle infestation, which has the potential to kill over half the remaining timber in the next 5 years. Approximately 30 percent of the stand is deadfall on the forest floor (Montana Prescribed Fire Services, Inc. 2007).
Exhibit 6 shows the Lodgepole pines that have been infested with the Western pine beetle. Exhibit 7 shows the general vegetation along the Flume. 
Spotted knapweed and Russian thistle are considered noxious weeds and have been observed within the project area (Helena 2008).
3.11.2.2 Environmental Consequences 
Alternative 1  No Action
Vegetation/fuel reduction activities would not occur with the No Action Alternative; therefore, no vegetation would be impacted. However, a wildfire could have significant short-term impacts on vegetation within the project area.
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
With Alternative 2, approximately 108 acres of vegetation would be affected by project activities. The proposed action would clear dead and/or fallen trees 3 inches in diameter or larger of all species from 300 feet down slope of the Flume to 100 feet above the Flume, and 150 feet beyond the ends of each trestle. Additionally, the project would remove all Lodgepole pine downhill of Flume lengths located on private land. These activities would reduce the existing fuel load and lessen the likelihood of a catastrophic wildfire, which would destroy all vegetation within the fire area. Following a wildfire, the grass and other understory vegetation may return quickly; the trees would take years to replace. Finally, the removal of dead, fallen, and beetle-infested trees would contribute to the maintenance of a healthy forest. 
Mechanical clearing would occur only between mid-October and mid-December, when the ground is frozen. This would minimize any impacts to vegetation. Hand clearing would occur between September and November. Hand clearing is low impact and would minimize damage to surrounding vegetation.
Before any slash piles are burned, Helena will contact the USFS and obtain a burn permit. The permits are issued for a period of time and all permits expire on September 30th of the calendar year. In addition, Helena will contact the Lewis and Clark County Sheriffs Office and inform them that a controlled burn will be performed in the project area. 
There is a small possibility of an escaped wildland fire from the debris pile burning. To minimize this threat, burning would be conducted when wildfire risk is low. Cut material would be placed in an area with scant or no vegetation at least 100 feet below the Flume. Numerous rock outcroppings and rock scree areas are available. Hand piles would be built not to exceed 8 feet in diameter on slopes less than 20 percent, to prevent burning material from rolling downhill. Additionally, piles would be constructed where the canopy is open, to prevent scorching live trees. 
As part of the proposed project, all guidelines and recommendations for managing noxious weeds in the Helena Open Lands Management Plan would be followed. These include: 1) the Helena Open Lands Advisory Committee weed sub-committee would inventory the project area for noxious weeds; 2) all vehicles and equipment would be power-washed prior to arrival on the property; 3) any thinning activities which disturb mineral soil would be promptly followed by seeding with a native seed mix recommended by the NRCS; and 4) all disturbed areas would be reseeded. Monitoring and follow-up treatment for noxious weeds would continue for 3 years.
With implementation of project activities and the proper mitigation discussed above, the proposed project would have a long-term beneficial impact on the remaining vegetation, helping to create a more healthy forest and reducing the risk of future wildfires.
3.11.3 Terrestrial Wildlife
3.11.3.1 Baseline Conditions
A review of Foresman (2001) revealed 47 mammal species that have been documented in Lewis and Clark County, with 21 additional species that are suspected of occurring in the county. Mammal species likely to occur in the project area include those species associated with conifer forest habitats ranging from the valley foothills to the subalpine habitats on the summit of Red Mountain, such as deer mouse, yellow-pine chipmunk, red-tailed chipmunk, northern flying squirrel, golden-mantled squirrel, red squirrel, bushy-tailed woodrat, short-tailed weasel, long-tailed weasel, mountain cottontail, snowshoe hare, yellow-bellied marmot, porcupine, bobcat, coyote, mountain lion, black bear, moose, elk, mule deer, and white-tailed deer. 
The Migratory Bird Treaty Act (MBTA), 16 U.S. Code (U.S.C.) 703 was enacted in 1918. The MBTA prohibits the taking of any migratory birds, their parts, nests, or eggs, except as permitted by regulations, and does not require intent to be proven. The U.S. Fish and Wildlife Service (USFWS) consults on issues related to migratory birds. 
3.11.3.2 Environmental Consequences
Alternative 1  No Action
The No Action Alternative would not have any impacts on wildlife or wildlife habitat unless a wildfire were to occur, causing both wildlife and their habitat to be adversely affected or destroyed. For some species it could take years for their habitat to re-establish.
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Conducting fuel reducing activities would have a short-term minor impact on terrestrial wildlife in the area, as the presence of humans may cause some species to vacate the area during project activities. However, wildlife would quickly return to the area when the vegetation management activities have been completed. Additionally, the proposed activities would occur primarily between July and November; therefore, minimizing impacts related to nesting and denning activities by wildlife species. 
The Montana Division of Fish, Wildlife, and Parks (FWP) was contacted regarding this project and had no concerns regarding wildlife. This correspondence is included in Appendix C.
3.11.4 Aquatic Wildlife
3.11.4.1 Baseline Conditions
The Flume itself does not contain aquatic habitat. Although there are several creeks and the Chessman Reservoir in the vicinity of the project area, according to Helena, fish are not diverted by the Flume. Additionally, there are no fish in Chessman Reservoir. Montana FWP was contacted regarding aquatic resources within the project area. They indicated that if work was not performed in a perennial stream, permits would not be necessary. Proposed project activities would not be performed in any perennial stream. Montana FWP correspondence is included in Appendix C.
3.11.4.2 Environmental Consequences
Since aquatic habitat does not occur within or immediately downstream of the project area, aquatic resources would not be affected regardless of the alternative selected.
3.11.5 Threatened, Endangered, and Special-Status Species
3.11.5.1 Baseline Conditions
Montanas Natural Heritage Program
A search of the Montana Natural Heritage Program was conducted for the project area. Four species were identified as having the potential to occur within the project vicinity. These species include three mammals (the gray wolf, the Canada lynx, and the wolverine) and one invertebrate (the Agapetus Caddisfly). The gray wolf and Canada lynx are discussed in more detail under federally listed species. 
Wolverine
The wolverine is ranked globally as G4 (uncommon, but not rare [although it may be rare in parts of its range], and usually widespread. Apparently not vulnerable in most of its range, but possibly cause for long-term concern) and in the State of Montana as S3 (potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas) (Montana Natural Heritage Program 2008). 
The wolverine is a bear-like mustelid with massive limbs and long, dense, dark brown pelage, paler on the head, with two broad yellowish stripes extending from the shoulders and joining on the rump. Variable white or yellowish markings are often present on the throat and chest. The tail is bushy. The feet are relatively large (2.5 to 4.5 inches total length) with robust claws. Wolverines weigh between 15.4 and 70.4 pounds and range from 3 to 3.6 feet in length. Females average about 10 percent less than males in linear measurements and 30 percent less in mass (Montana Field Guide 2008b).
Wolverines in northwestern Montana and Alaska tend to occupy higher elevations in summer and lower elevations in winter. Seasonal ranges are all within a large home range; dispersal movements of more than 186 miles are known (Montana Field Guide 2008b).
Wolverines are limited to alpine tundra, and boreal and mountain forests (primarily coniferous) in the western mountains, especially large wilderness areas. However, dispersing individuals have been found far outside of usual habitats. They are usually in areas with snow on the ground in winter. Riparian areas may be important winter habitat. When inactive, wolverines occupy dens in caves, rock crevices, under fallen trees, in thickets, or similar sites. Wolverines are primarily terrestrial but may climb trees (Montana Field Guide 2008b).
In Montana, wolverines occur in medium to scattered timber, while areas of dense, young timber were used least. Wolverines avoid clearcuts and burns, crossing them rapidly and directly when they enter at all. Wolverines in the Northern Rocky Mountain region are associated with fir, pine, and larch. Aspen stands are also used, as are cottonwoods in riparian areas. Ecotonal areas appeared to be important habitat components. Wolverines may not be dependant on any particular vegetative habitat type, but prefer large, isolated tracts of wilderness supporting a diverse prey base. (Montana Field Guide 2008b)
Wolverines are opportunistic. They feed on a wide variety of roots, berries, small mammals, birds eggs and young, fledglings, and fish. They may attack moose, caribou, and deer hampered by deep snow. Small- and medium-size rodents and carrion (especially ungulate carcasses) often make up a large percentage of the diet. Prey is captured by pursuit, ambush, digging out dens, or climbing into trees. They may cache prey in the fork of tree branches or under snow (Montana Field Guide 2008b).
Wolverines are generally solitary and wide-ranging. They occur at relatively low densities (e.g., 1 per 40 square miles in northwestern Montana). Home ranges of males are larger than those of females, with home ranges of up to several hundred square miles. The mean annual home range of males is approximately 260 square miles in Montana. Female home ranges are approximately 240 square miles in Montana. Males in some areas apparently are territorial, but in Montana there was extensive overlap of the ranges of both the same and opposite sexes. Apparently territory/range size depends on availability of denning sites and food supply. Some individuals travel regularly over the same route. There are no important predators other than humans (Montana Field Guide 2008b).
Agapetus Caddisfly
The Agapetus Caddisfly is an invertebrate that is ranked globally as G2 and in Montana as S2 (at risk because of very limited and/or declining numbers, range, and/or habitat, making it vulnerable to global extinction or extirpation in the State) (Montana Natural Heritage Program 2008). 
The Caddisfly occurs in Idaho, Montana, and Manitoba, and has been reported in Lewis and Clark County. The larvae occur on the upper surfaces and sides of cobbles and boulders in moderate gradient, fast flowing, foothill and mountain streams. This genus inhabits streams with more intermediate characteristics between the higher elevation, cold mountain streams, and the large, warmer transitional rivers downstream. Generally the riparian canopy of the occupied streams is mostly (>50 percent) open, and less shaded than mountain streams. In clear streams and rivers during low flows, it is typical to be able to locate and identify Agapetus larvae on the tops of rocks. (Montana Field Guide 2008a)
Federally Listed Threatened and Endangered Species
According the USFWS Web site (USFWS 2008), five species are federally listed as threatened or endangered in Lewis and Clark County: the grizzly bear, bull trout, black-footed ferret, Canada lynx, and gray wolf. These species are described in the following paragraphs.
Grizzly Bear  Threatened
On September 1, 1975, the grizzly bear was classified as a threatened species by the USFWS throughout its range in the lower 48 States.
The grizzly bear is globally ranked as G4T3T4 (uncommon but not rare [although it may be rare in parts of its range], and usually widespread. Apparently not vulnerable in most of its range, but possibly cause for long-term concern; with the subspecific taxon ranked as potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas to uncommon but not rare [although it may be rare in parts of its range], and usually widespread). The State of Montana ranks the grizzly bear as S2S3 (at risk because of very limited and/or declining numbers, range, and/or habitat, making it vulnerable to global extinction or extirpation in the State to potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas).
The grizzly bears historic range covered much of North America from the plains westward to California. Presently, the grizzly bear is found in only about 2 percent of its former range in the lower 48 States. There are five grizzly bear subpopulations in Wyoming, Washington, Idaho, and Montana. According to the USFWS in Helena, the proposed project area is outside the distribution range for the grizzly bear. 
Bull Trout  Threatened
The bull trout is a Montana Species of Concern and was listed as threatened by the USFWS in 1998. In Montana, bull trout are native to rivers, streams, and lakes in the Columbia (Kootenai, Clark Fork, Bitterroot, Blackfoot, Flathead, and Swan drainages) and Saskatchewan River (St. Mary and Belly drainages) basins.
The bull trout is a long-lived species, generally reaching sexual maturity at 5 years of age. They spawn in small streams between late August and early November, building nests, or redds, in which they lay their eggs. The hatched fry do not emerge from the redds until the following spring. Bull trout can grow to be greater than 3 feet in length and weigh more than 20 pounds. 
Montana bull trout display various life history strategies. Some bull trout are residents, spending their entire lives in a single stream. Other bull trout have migratory life histories, either living in major rivers as sub-adults and adults and then migrating into smaller tributaries to spawn (fluvial), or living in lakes and reservoirs as sub-adult and adults and migrating into tributaries to spawn (adfluvial). Migratory bull trout can move great distances (>150 miles) in response to environmental changes and spawning cues. 
The Bull trout has very specific habitat needs for many of its life stages, making it more vulnerable to environmental degradation than most other salmonids. Adult bull trout require cold water temperatures, clean cobble/boulder substrates, and overhead cover. Spawning redds are only constructed in stream reaches where upwelling ground water is available to aerate the buried eggs. Bull trout eggs are easily smothered by low levels of silt. Emerging fry and juveniles require clean rock stream substrates with sufficient open spaces for them to hide in as they develop into sub-adults. 
Declines in bull trout abundance and distribution have been caused by habitat loss and degradation from land and water management practices; population isolation and fragmentation from dams and other barriers; competition, predation, and hybridization with introduced non-native fish species (lake trout, brook trout, northern pike, and others); historical overharvest; and poaching. Although their numbers and distribution have declined from historical levels, bull trout populations exhibiting resident and migratory life histories can be found throughout their historic range in Montana. 
The bull trout distribution in Montana is limited to areas west of the Continental Divide. Therefore, bull trout are not located within the project area.
Black-Footed Ferret  Endangered
The black-footed ferret was listed by the USFWS on June 2, 1970. Black-footed ferrets are 20 inches to 24 inches long, including a 6 inch tail, and weigh up to 2.5 pounds. They have a yellowish brown body with a distinctive black mask across the face, black on the feet and the tip of the tail. The related long-tailed weasel is about half the size of the ferret and does not have the distinctive black markings. Black-footed ferrets are primarily nocturnal and are active in winter. 
Black-footed ferrets once ranged throughout the Great Plains. Populations declined dramatically in the 1980s. From 1987 until 1991 the black-footed ferret may have been extirpated in the wild. In the fall of 1991, 49 captive animals were reintroduced into the wild in Wyoming. The reintroduced animals were designated an experimental population. Additional ferrets have been introduced each year since 1991. Unconfirmed sightings from other areas continue to be reported. There are still about 400 black-footed ferrets in captivity. 
The black-footed ferret inhabits short grass prairies, always within close proximity to prairie dog towns. Prairie dogs comprise 90 percent of the diet of black-footed ferrets. A ferret family of 4 will consume an average 763 prairie dogs per year. These animals utilize prairie dog burrows for shelter and raising families. Therefore, prairie dogs are essential to black-footed ferrets.
The rapid decline of black-footed ferrets has been linked to the eradication of prairie dogs. Prairie dogs now occupy less than 1 percent of their historic range. Canine distemper also can threaten ferret populations. 
The project area is located within a forested area and contains no prairie dog habitat. As the black-footed ferret inhabits short grass prairies and requires close association with prairie dogs, no black-footed ferrets are expected to occur within the project area.
Canada Lynx  Threatened
The Canada lynx is globally ranked as G5 (common, widespread, and abundant [although it may be rare in parts of its range]. Not vulnerable in most of its range). The Canada lynx is ranked as S3 (potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas) by the State of Montana. On March 21, 2000, the USFWS listed the Canada lynx in the contiguous United States as threatened under the Endangered Species Act (ESA).
The boreal forests of Canada and Alaska are the primary habitat of the Canada lynx in North America. Populations occurring in the western mountains of the conterminous United States occupy peninsular extensions of this distribution. Canada lynx distribution at southern latitudes represents the occupation of marginally suitable habitat that decreases in quality and availability as one moves southward. This pattern of decreasing habitat suitability with decreasing latitude is evident in the Rocky Mountains, with Canada lynx being more common in northwestern Montana, and decreasing in abundance to the south and east.
In the Northern Rocky Mountain Region, the majority of Canada lynx occurrences are in moist sub-alpine forests of Douglas fir, western spruce/fir, and fir/hemlock with a dense understory of woody vegetation. Primary Canada lynx habitat is generally between 4,920 and 6,560 feet above msl.
In Montana, Canada lynx have been documented, historically and currently, throughout the Rocky Mountains, from the Canadian border through the Yellowstone area. Canada lynx presence has also been verified in the majority of the mountain ranges in Montana, including isolated ranges such as the Big Belt, Little Belt, and Crazy Mountains, and trapping records indicate past occupancy in the Big Snowy, Little Snowy, and Highwood Mountains. USFWS has concluded that a resident population of Canada lynx is distributed throughout its historic range in Montana.
Canada lynx lead solitary lives except when rearing young and during a short breeding period from February to March. Lynx seem to prefer to travel through coniferous forests, also using ridges, saddles, and riparian areas. Canada lynx are most active from shortly before dark to shortly after dawn but are sometimes active during daylight hours. They usually bed for the day in, or on the edge of, dense to moderate cover. The home range size of the Canada lynx is 5 to 20 square miles, with reported home ranges of 37 square miles for males and 20 square miles for females.
Canada lynx feed primarily upon snowshoe hares, especially during the winter. Canada lynx also eat other small to medium-sized animals and occasionally larger animals and carrion. The distribution and abundance of lynx are associated with those of their primary prey species, the snowshoe hare. However, the red squirrel is an important alternative prey. In Montana, snowshoe hares are most abundant in young, dense stands of Lodgepole pine.
The project area is located around 6,000 feet above msl and includes stands of Douglas fir, Engelmann spruce, and Lodgepole pine. However, the quality of the forest surrounding the Flume is deteriorating due to pine beetle infestation. Additionally, there are several homes located near the proposed project area. 
Gray Wolf  Endangered
On March 11, 1967, the gray wolf was designated as Endangered in the conterminous United States. In April 2003, the gray wolf was reclassified and downlisted from an endangered to a threatened species. However, a recent court ruling has returned the status of the gray wolf from threatened to endangered, for populations outside of the nonessential experimental areas.
The availability of ungulate prey and isolation from human activities are the most important factors that determine suitable wolf habitat. Wolves are highly social animals that form packs of 2 to 20 individuals organized around a breeding pair. Most packs include a pair of breeding adults (alpha or dominant), other nonbreeding adults and/or yearlings that may be offspring from previous years, and pups of the year. Depending on the number of wolves in the pack and prey availability, each pack occupies a territory of 50 to 300 square miles. 
Wolves are found in varied habitat, including grasslands, sagebrush steppes, coniferous and mixed forests, and alpine areas. Wolves are opportunistic predators and are primarily associated with an ungulate prey base that includes deer, elk, and moose. Wolves prey on ungulates throughout the year, and ungulates account for more than 90 percent of the biomass consumed. Beaver and other small mammals make up a small part of the gray wolf diet.
The gray wolf is ranked globally as G4 (uncommon but not rare [although it may be rare in parts of its range], and usually widespread. Apparently not vulnerable in most of its range, but possibly cause for long-term concern). The species is ranked by the State of Montana as S3 (potentially at risk because of limited and/or declining numbers, range, and/or habitat, even though it may be abundant in some areas). 
In North America, the gray wolf ranges from Alaska, across the Northwest Territories, throughout the Canada provinces, with extensions into Idaho, Montana, and the northern Great Lakes region, and remote parts of the southwest and Mexico. Since 1982, several packs have formed in Montana, primarily from Canadian dispersers. 
In 1987, the USFWS developed the Northern Rocky Mountain Gray Wolf Recovery Plan for the gray wolf in the northern Rockies that identified northwestern Montana, central Idaho, and the Greater Yellowstone Area (GYA) as the three recovery areas. As part of the recovery plan, the USFWS established a biological goal of at least 10 breeding pairs of wolves in each of these three areas for 3 successive years. On November 22, 1994, the USFWS approved a plan to establish nonessential experimental populations of wolves in central Idaho and Yellowstone National Park. In 1995 and 1996, wolves were reintroduced in the central Idaho and GYA recovery areas. The wolves in the two experimental areas are not classified as Threatened and Endangered (T&E). The Red Mountain Flume project area lies within the Northwest Montana recovery area where the gray wolf is listed as endangered under the ESA. 
The Northwest Montana recovery area encompasses an area of more than 19,300 square miles north of Interstate 90 and west of Interstate 15, which is primarily a mixture of public and private land. The proposed project is located entirely within this recovery area. 
Based on monitoring work completed by USFWS since 2005, wolves have been reported within the general project area and are likely to occur in the area again because of the close association with the Continental divide. Wolf packs are known to occur north, west, and south of the project area and have moved through the Tenmile drainage in the past. 
Communications with USFWS indicated that generally speaking, the type of proposed activity (logging/fuel reduction) would not pose a problem for wolves. Timing and location relative to the denning period could be a consideration/disturbance. If there is a den in the project area, deferring activity until the pack left the den (around mid-June) would be the appropriate mitigation. The proposed project activities are scheduled to occur between July and February. 
3.11.5.2 Environmental Consequences
Alternative 1  No Action
The No Action Alternative would not impact any of the threatened and endangered species or their habitat that have the potential to occur in Lewis and Clark County or the project area. However, if a wildfire occurred in the general project area, threatened and endangered species and their habitat could be adversely impacted. 
Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The Montana FWP was contacted about the species included in the Natural Heritage search. Montana FWP comments concerning the gray wolf were included with the text and information provided to USFWS and included in FEMAs determination of effects. Montana FWP did not provide any comments or concerns regarding the Canada lynx, wolverine, or caddisfly. Correspondence with Montana FWP is provided in Appendix C.
Table 3-2 summarizes the T&E species that are known to occur within Lewis and Clark County. As indicated in the table, the grizzly bear, bull trout, and black-footed ferret do not occur within the project area. Therefore, the proposed action would have no affect on these species. The Canada lynx and the gray wolf both have the potential to occur within the project area. 
Determination of Effects
Based on the information provided above, site reconnaissance of the project area, and discussions with USFWS and Montana FWP, FEMA has determined that the proposed project would have a MAY EFFECT  NOT LIKELY TO ADVERSELY EFFECT for the Canada lynx and gray wolf. FEMA also determined that the proposed action would have NO AFFECT on the grizzly bear, bull trout, and black-footed ferret. In a letter dated September 16, 2008 (Appendix C), USFWS concurred with FEMAs determination. A summary of the effects determination is provided in Table 3-2.

Table 32: Threatened and Endangered Species in Lewis and Clark County
Species
Status
Occurrence
Range-Montana
Grizzly Bear
(Ursus arctos)
Threatened
Not present in project area
Alpine/subalpine coniferous forest; western Montana
Bull Trout
(Salvelinus confluentus)
Threatened; 
Critical Habitat
Not present in project area
Clark Fork, Flathead, Kootenai, St. May, and Belly River basins; cold water rivers and lakes
Critical habitat has been designated in portions of rivers, streams, lakes, and reservoirs within 12 Montana counties, including Lewis and Clark
Black-footed ferret
(Mustela nigripes)
Endangered; Non-Essential Experimental Population
Not present in project area
Prairie dog complexes; eastern Montana
Canada Lynx
(Lynx canadensis)
Threatened;
Critical Habitat
Resident
Western Montana-montane spruce/fir forest
Designated critical habitat is not located within Lewis and Clark County
Gray Wolf
(Canis lupus)
Endangered; 
Non-Essential Experimental Population
Transient
Forest; western Montana


Table 33: Summary of Effects Determination
Species
Summary of Effects Determination
Grizzly Bear
(Threatened)
No Affect; Project area is outside distribution range.
Bull Trout
(Threatened)
No Affect; the bull trout range in Montana is limited to west slope streams and rivers. The proposed project area is located on the eastern slope. Therefore, no bull trout occur within the project area.
Black-Footed Ferret
(Endangered)
No Affect; habitat for the black-footed ferret is limited to the immediate vicinity of prairie dog complexes. No prairie dog complexes occur within the project area. Therefore, no black-footed ferrets are located within the project area.
Canada Lynx
(Threatened)
May Effect, Not Likely to Adversely Affect; resident. This determination is based on the lack of documented lynx use of the project area, no foreseeable change in prey availability during or after the project, and the short-term increase in human activity and related noise associated with the alternative that may temporarily displace lynx.
Gray Wolf
(Endangered)
May Effect, Not Likely to Adversely Affect; transient (recent sightings verified near project area). This determination is based on the lack of documented den or rendezvous sites near the project area, no foreseeable change to prey availability during or after project activities, and the short-term increase in human activity and related noise associated with the project that may temporarily displace wolves.

3.12 CULTURAL RESOURCES
In addition to review under NEPA, consideration of impacts to cultural resources is mandated under Section 106 of the National Historic Preservation Act (NHPA), as implemented by 36 CFR Part 800. Requirements include the need to identify significant historic properties that may be impacted by the Proposed Action or alternatives. Historic properties are defined as archaeological sites, standing structures, or other historic resources listed in or determined eligible for listing in the National Register of Historic Places (NRHP) (36 CFR 60.4).
3.12.1 Baseline Conditions
Archaeological evidence of prehistoric or historic American Indian habitation or use of the Tenmile watershed is scarce. This is probably attributable to lack of survey information, natural processes (flooding and scouring), and historic-modern development. Archaeological sites have been obscured or destroyed. Intact sites may lie buried (or hidden) on higher, less disturbed, terraces and benches on both National Forest and private land. Opportunistic and compliance (project) inventories may eventually yield additional signs of ancient American Indian use, especially given the drainages proximity to Mullan and Priest Passesimportant east-west travel routes in the distant past (Davis 2006).
Historically, the powerful Blackfeet controlled the Helena area until the mid-1700s, having earlier pushed out the Shoshone, Salish, and other western Montana Indian tribes. John Coulter encountered the Blackfeet in the area in 1807 and 1811. The murder of Malcom Clarke, a prominent Helena Valley rancher, by a member of Mountain Chiefs band in 1869 precipitated the Baker Massacre on the Marias River in 1870. The Blackfeet thus relinquished control of the Helena Valley area, easing the way for mining and white settlement. American Indians of different tribal affiliations continued to travel through the Helena Valley area well into the early 1900s, leaving their various Indian reserves in search of game, other foodstuffs, and white goods. The Helena Valley (and Tenmile drainage) area was used over thousands of years by many tribes but it does not lie within ceded treaty lands or reservation boundaries (Davis 2006).
The discovery of gold in Last Chance Gulch created the community of Helena. The Tenmile drainage has served as Helenas water source ever since. William Chessman, seeing the financial benefits of supplying domestic water to the fledging Helena mining community, founded the Helena Water Works in 1864. He then constructed Chessman Reservoir and a series of flumes and ditches. Chessman Dam gave way in 1876, flooding and scouring the Tenmile drainage. In 1886, the various water companies operating in Helena consolidated into the Helena Water Works Company (a New Jersey corporation). In 1911, Helena acquired the company for about $440,000. Tenmile Creek still supplies drinking water to Helena and the water ditch system is perhaps the oldest surviving (major) municipal water system in Montana (Davis 2006).
Table 3-4 summarizes the types of historic activities and surviving historic properties within the Tenmile Watershed.
Table 34: Historic Themes and Heritage Property Types in the Tenmile Watershed
Historic Theme 
Surviving Historic Properties 
American Indian: 12,000 to 1900 
Isolated prehistoric artifacts; 
No archaeological sites identified
White Settlement: 1864-1900 

Chessman-Helena water ditch
Rimini community 
Homesteads 
Mining: 1864-1950

Placer claims and mines 
Lode mines and mills 
Cabins and related ruins
Transportation: 1864-1900 

Old Rimini wagon road 
Helena-Red Mountain Branch Line
Montana Central Branch Line
County road 
Forest Service: 1908-present 

Moose Creek Ranger Station 
Colorado Mountain Lookout 
Moose Creek Villa tract and cabins 
Campgrounds and trails 
Great Depression and World War II (WWII): 1930-1945
Civilian Conservation Corps (CCC) Camp Rimini 
CCC trail and other improvements
WW II Dog Training Camp
 Source: Davis 2006

In a letter dated December 5, 2007, the Montana State Historic Preservation Office (SHPO) indicated that the Red Mountain Flume was part of the Chessman Dam/Reservoir site (24LC0876) and probably used for mining in the area as well as for water for Helena. The site has previously been determined eligible for listing in the NRHP. The Montana SHPO indicated that the proposed project was not likely to impact the Flume or dam.
3.12.2 Environmental Consequences
3.12.2.1 Alternative 1  No Action
The Flume, eligible for listing on the NRHP, could be affected or destroyed if a wildfire were to occur. Other historic sites could also be negatively impacted. 
3.12.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
The 100-year old Flume is eleiglbel for listing on the NRHP. The Flume would not be altered by any of the proposed project activities. The purpose of the project is to reduce the potential for damage to the Flume from wildfire. Activities would occur on the ground surface; therefore, unidentified archeological resources would not be adversely affected. For the proposed project activities, FEMA recommended a finding of no historic properties affected in accordance with Section 106 [36 CFR 800.4 (d)]. In a letter dated October 8, 2008, the Montana SHPO concurred with FEMAs finding. 
In the unlikely event that cultural resources are encountered during project activities, work would be stopped and the Montana SHPO and FEMA Region VIII Environmental Officer would be contacted. Project activities would not resume until appropriate coordination has been completed.
3.13 RECOGNIZED ENVIRONMENTAL CONDITIONS
The American Society for Testing and Materials (ASTM, 1994) Standard E 1527-94 defines a recognized environmental condition (REC) as the presence or likely presence of any hazardous substances or petroleum products on a property under conditions that indicate an existing release, a past release, or a material threat of a release of any hazardous substances or petroleum products into structures on the property or into the ground, groundwater, or surface water of the property. 
3.13.1 Baseline Conditions
Two Environmental Data Resources (EDR) database searches were completed on August 21, 2008, with an extended search radius to provide adequate coverage of the project vicinity. The EDR searches identified two National Priority List (NPL) sites. The project area is located within the Upper Tenmile Creek Mining Area NPL site. The second NPL site is the Basin Mining Area located in Jefferson County, Montana. 
The Upper Tenmile Creek Mining Area is essentially centered on the town of Remini, Montana, which is several miles northwest of the project area. The site itself covers approximately 53 square miles. The main contamination associated with this site is elevated metals concentrations in the surface water of Tenmile Creek. EPA, Montana DEQ, and the USFS have all been involved in resolution of the surface water contamination. A Record of Decision (ROD) was issued for this NPL site in June 2002. Efforts are underway to construct a community water system for the town of Remini. This site was also identified in five other databases including Comprehensive Environmental Response, Compensation, and Liability Information System (CERCLIS); U.S. Engineering Controls; U.S. Institutional Controls; ROD; and Facility Index System (FINDS). 
The Basin Mining Area is located near Basin, Montana over 3 miles south of the proposed project area. This site includes the community of Basin and the surrounding watersheds of Basin Creek, Cataract Creek, and part of the upper Boulder River. A ROD for the area around Basin was completed in March 2001. This site was also identified in five other databases including CERCLIS; U.S. Engineering Controls; U.S. Institutional Controls; ROD; and FINDS. 
The EDR also identified one site on Mine Master Index File (MINES) from the Department of Labor, Mine Safety, and Health Administration and one additional FINDS site. These sites are both over 2 miles from the project area.
Two sites were identified on the spills or hazardous material spills or releases database (SPILLS). Both of these sites have been closed under the program and require no further action.
Twenty orphan sites (inadequate address to map the location) were listed in the EDR reports. Based on site reconnaissance and further address investigation, none of the orphan sites appear to be located in or near the project area. 
3.13.2 Environmental Consequences
3.13.2.1 Alternative 1  No Action
With the No Action Alternative, only maintenance and repair activities would occur. These activities would not impact any of the identified REC sites. 
3.13.2.2 Alternative 2  Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Although the project area is located within an NPL site, the proposed project activities would not increase the concentrations of metals in Tenmile Creek. Additionally, since all the project activities would be limited to the specific project area, there would not be any impact to the other identified REC sites.
3.14 CUMULATIVE IMPACTS
Section 1508.7 of the CEQ Regulations defines cumulative impacts as the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable actions. Cumulative effects are not wholly different effects from direct or indirect effects of an action. Cumulative effects are merely a way of placing seemingly isolated or insignificant direct and indirect effects in context with respect to overall impacts, both over time and in an area larger than that evaluated for direct and indirect effects. Cumulative effects are discussed in terms of being additive, synergistic, or reductive.
Over the past couple of years, Helena has completed a forest land assessment of Helena lands within the Tenmile Creek Watershed to determine the potential for a wildfire in the watershed and possible measures to reduce that risk. Helena has been working with the Tri-County Fire Working Group to establish a plan to minimize the potential for fire in the Tenmile Creek Watershed. Additionally, Helena is working on a resolution to form a committee that would include personnel from Helena, the Helena National Forest, Lewis and Clark County, Montana DEQ, Montana Department of Natural Resources and Conservation, volunteer fire departments, and private citizens. The Tenmile Watershed Collaborative Committee will bring forward recommendations for options for sustainable forest and watershed management that will preserve and protect Helenas water supply. If realized and put into action, these recommendations would have a beneficial long-term impact on the Tenmile Creek Water Supply system. 
3.15 COORDINATION AND PERMITS
The following Federal, State, and local agencies were contacted and consulted during the preparation of this EA. Additional coordination and permits that are required prior to implementation of an alternative are also identified.
U.S. Fish and Wildlife Service
No additional coordination or permits will be required regarding threatened and endangered species unless project activities change. 
U.S. Army Corps of Engineers
No additional coordination will be required unless project activities change.
U.S. Forest Service
Helena will need to obtain a permit for the controlled burning of the slash piles. 
U.S. Environmental Protection Agency
No addition coordination will be required unless project activities change.
Natural Resources Conservation Service
No additional coordination or permits will be required unless project activities change
Montana State Historic Preservation Office
No additional coordination or permits will be required unless project activities change. If cultural resources are encountered during project activities, work will be stopped and the Montana SHPO and FEMA Region 8 Environmental Officer will be contacted. Project activities will not resume until appropriate coordination has been completed.
Montana Division of Fish, Wildlife, and Parks
No additional coordination or permits will be required unless project activities change.
Montana Department of Environment Quality
Helena will coordinate with Montana DEQ to determine if the proposed action is a major burn, as per Montana DEQs guidelines. If it is determined that the project involves a major burn, Helena will need to submit the required written request form prior to conducting any slash pile burns.
Lewis and Clark County Sheriffs Office
Helena would need to inform the Lewis and Clark County Sheriffs office prior to initialing controlled burns.

SECTION Four SUMMARY
Two alternatives were evaluated in this EA. They included: (1) No Action, and (2) Upper Tenmile Creek Watershed Fuel Reduction. Potential environmental impacts for each alternative are summarized in Table 4-1 (page 4-2).
With the No Action Alternative, no action would be taken to reduce the fuel load in the vicinity of the Red Mountain Flume.
Alternative 2 would involve the removal of all dead and/or fallen timber 3 inches in diameter or larger and all Lodgepole pine 300 feet down slope from the trestles that support sections of the Flume and 150 feet beyond the end of the trestle at each location. The project would also remove all of the downed and standing dead timber 3 inches in diameter or larger for approximately 100 feet above the Flume. Alternative 2 would include both mechanical and hand clearing, and burning of hand piles. 


Table 41: Comparison of Alternatives by Environmental Resource
Environmental Resource
Alternative 1
No Action
Alternative 2
 Upper Tenmile Creek Watershed Fuel Reduction (Proposed Action)
Topography/Geology and Soils
No impact on topography or geology.
If a wildfire should occur, project area soils could be converted to hydrophobic soils. This would be a significant impact. 
No impact on topography or geology.
Clearing of vegetation and removal of trees would not have a significant impact on soils. Helena would implement BMPs for Forestry to minimize impacts to soils. 
Land Use and Planning
No direct impact on land use. If a wildfire were to destroy the flume, the project area would no longer be used for water conveyance. 
No impact on prime farmland or floodplains.
No impact on land use, floodplains, or prime farmland.
Traffic and Circulation
No direct impact. The potential for a wildfire in the area of the flume would remain.
Short-term impacts on traffic during vegetation management activities. 
Residents in the vicinity of the project area would be notified in advance via individual letters and a public notice in the local paper.
Public Health and Safety
No impact.
A reduction in the potential for a catastrophic wildfire in the area of flume. Long-term positive impact on Helenas water supply. 
Socioeconomics
No direct impact. A catastrophic wildfire could result in economic issues for Helena and users of the water supply.
Long-term beneficial economic impact to Helena and the area residents by allowing Helena to maintain an affordable water supply.
The purchase of goods and services during the project would have a short-term beneficial effect on local business community.
There would be no disproportionate adverse effects on any minority or low-income population.
Visual Resources
No direct impact. However, a wildfire could have a significant impact on the viewshed of Red Mountain and the Flume area.
Short-term negative visual impact related to the loss of trees and other vegetation near the flume. 

Long-term positive impact on visual resources by reducing the likelihood of a wildfire and providing for a healthier forest near the flume.
Air Quality
No direct impact. A wildfire would have a short-term negative impact on air quality.
Minor, short-term reduction in air quality caused by increased particulates during vegetation management activities and open burns.
Requires a permit from USFS, coordination with Montana DEQ, and notification of Lewis and Clark County Sheriffs Office.
Public Services and Utilities
No impact unless a wildfire damages for destroys the Flume.
No impact on public services and utilities in the project area. Long-term beneficial impact on Helenas water supply.
Noise
No impact.
Short-term increase in noise levels near the project area due to machinery and chainsaws. All equipment would be equipped with proper mufflers and construction would be restricted to daytime hours. With these mitigation measures, the temporary increase would not be considered significant.
Hydrology/Water Quality 
No direct impact on hydrology or water quality. However, a wildfire could have a significant impact on the water quality in area streams if hydrophobic soils are created. 
No impact on hydrology.
Long-term positive impact on water quality by reducing the likelihood of a catastrophic wildfire.
BMPs and including Streamside Management Zones would be employed to minimize soil erosion and the transport of sediment. No adverse effect on water quality would be expected with these mitigation measures
Wetlands
No impact.
No wetlands would be impacted by project activities.
Vegetation
No direct impact. However a wildfire would have a significant impact on vegetation. 
Long-term positive impact on vegetation in the vicinity of the project.
Approximately 108 acres of vegetation would be impacted by project activities. However, the vegetation management activities focus on removing dead, fall, and diseased trees. 
Wildlife Resources
No direct impact. However, a wildfire would have short-term negative impact on wildlife.
Short-term minor impact during project activities which may cause wildlife to leave the immediate vicinity of the project area. 
Aquatic Resources
No impact.
No impact.
Threatened and Endangered Species
No direct impact. However, a wildfire would have a negative impact on any threatened and endangered species within the fire area.
No impact on the grizzly bear, bull trout, and black-footed ferret. 
May Affect  Not Likely to Adversely Affect the Canada lynx and gray wolf.
Cultural Resources
No direct impact. A wildfire may have a negative impact on cultural resources within the fires area. 
No impact. 
Recognized Environmental Conditions
No impact.
No impact. 


SECTION Five AGENCIES CONSULTED AND REFERENCES
5.1 AGENCIES CONSULTED
Federal Emergency Management Agency Region VIII; Denver, CO
Ms. Donna Rakocy, Mitigation Environmental Coordinator		(303) 235-4750
U.S. Fish and Wildlife Service; Helena, MT
Mr. Mark Wilson, Field Supervisor	(406) 449-5225
Ms. Katrina Dixon, Biologist	(406) 449-5225
U.S. Army Corps of Engineers; Helena, MT
Mr. Allan Steinle, Regulatory		(406) 441-1375
U. S. Forestry Service; Helena, MT
Ms. Molly ODonnell, Information Assistant	(406) 449-5201
U.S. Environmental Protection Agency; Helena, MT
 Mr. Mike Bishop, Superfund Project Manager			(406) 457-5041
Montana Office of Emergency Management; Helena, MT
	Mr. Kent Atwood, Hazard Mitigation Officer			(406) 202-0583
Montana Division of Fish, Wildlife, and Parks; Helena, MT
Mr. Steve Dalbey, Fisheries	(406) 495-3263
Mr. Martin Miller, Montana Natural Heritage Program	(406) 444-3290
Mr. Quentin Kujala, Management Bureau Chief, 	
Wildlife Division	(406) 444-2612
Ms. Carolyn Sime, Wolf Program Coordinator	(406) 444-2612
Montana State Historical Preservation Office; Helena, MT
Mr. Josef Warhanks, 106 Compliance Officer	(406) 444-7715
Mr. Mark F. Baumler, State Historic Preservation Officer	(406) 444-7715
Montana Department of Environmental Quality; Helena, MT
Ms. Debbie Skibicki, Air Quality Program	(406) 444-1472
Ms. Julie Merkel, Air Quality Specialist	(406) 444-3626
Lewis and Clark County Sheriffs Office; Helena, MT
Ms. Jeanne Welch	(406) 447-8235
City of Helena; Helena, MT
	Mr. Donald Clark, Public Works Department			(406) 447-1593
	Ms. Keldah Hedstrom, Natural Resource Coordinator		(406) 447-8454
	Ms. Amy Teegarden, Director, Parks and Recreation		(406) 447-8462


SECTION Six REFERENCES
American Society for Testing and Materials (ASTM). 1994. Standard Practices for Environmental Site Assessments: Phase I Environmental Site Assessment Process. Designation E 1527-94.
Burchfiel, B.C.; P.W. Lipman; and M.L. Zoback (editors). 1992. The Cordilleran Orogen: Conterminous U.S. The Geology of North America, Volume 3. 
Davis, Carl. 2006. Heritage Resources Report. March 27.
Federal Emergency Management Agency (FEMA). 1985. Flood Insurance Rate Map. Community Panel Number 3000381625D. Revised September 4. 
Hedstrom, Keldah. 2008. Personal communication. Natural Resource Coordinator for the City of Helena. August 20. 
Helena. 2008. Tenmile Creek Water Supply Fuel Reduction Project PDM Grant Application. January 30, 2008.
Montana Prescribed Fire Services, Inc. 2007. Fuel Mitigation Prescription. Red Mountain Flume/Tenmile Creek Watershed. Prepared by Mike McFerrin. 
Montana Field Guide. 2008a. An Agapetus Caddisfly  Agapetus montanus. Web site accessed August 20. http://fieldguide.mt.gov/detail_IITRI33040.aspx
Montana Field Guide. 2008b. Wolverine  Gulo gulo. Web site accessed August 22. http://fieldguide.mt.gov/detail_AMAJF03010.aspx
Montana Natural Heritage Program. 2008. Search for Tenmile Creek Water Supply Project. August 14.
Natural Resources Conservation Service (NRCS). 2008. Soil Data Mart. Lewis and Clark County, Montana. Helena National Forest Area. Web site accessed August 12. http://soildatamart.nrcs.usda.gov/State.aspx 
U.S. Bureau of Census (Census). 2000a. Census 2000 Summary File, American FactFinder, Helena, Montana. Website accessed August 13, 2008. http://www.factfinder.census.gov/
U.S. Bureau of Census (Census). 2000b. Census 2000 Summary File, American FactFinder, Lewis and Clark County, Montana. Web site accessed September 16, 2008. http://www.factfinder.census.gov/
U.S. Department of Agriculture (USDA). 2001. Soil Survey of Helena National Forest Area, Montana. United States Department of Agriculture, Forest Service, Natural Resource Conservation Service, and Montana Agricultural Experiment Station.
U.S. Fish and Wildlife Service (USFWS). 2008. Mountain-Prairie Region. Federal endangered and threatened species list. Lewis and Clark County, Montana. Web site accessed August 5. http://www.fws.gov/montanafieldoffice/Endangered_Species/Listed_Species/countylist.pdf
U.S. Environmental Protection Agency (EPA). 2008. EPA Greenbook Nonattainment Area Map. Last updated in June. http://www.epa.gov/oar/oaqps/greenbk/mapnpoll.html


SECTION Seven LIST OF PREPARERS
This EA was prepared by URS Group, Inc., for FEMA Region VIII in Denver, CO.
URS Group staff includes:
Mr. Quentin Bliss, Senior Environmental Planner - Over 37 years of progressive experience in the environmental field and has been involved with NEPA since it was enacted in 1969. Has extensive experience with all aspects of NEPA, including: the scoping process, identification and evaluation of alternatives, identification of appropriate mitigation, and agency coordination. Project experience includes over 100 multidiscipline projects that involved NEPA compliance.
Ms. Susan Volkmer, Environmental Planner I - Over 12 years of experience with environmental assessments involving human and ecological resources. Project experience includes over 60 multidiscipline projects that involved NEPA compliance.
Mr. Brian Osborn, Environmental Planner - Over 8 years of experience in the environmental field. Specialized expertise in environmental planning and NEPA compliance studies, including environmental document preparation. Project experience includes over 40 multidiscipline projects that involved NEPA compliance.


SECTION Eight PUBLIC NOTICES
8.1 INITIAL PUBLIC NOTICE
Public notification is hereby given by the Department of Homeland Securitys Federal Emergency Management Agency (FEMA) of the intent to prepare an Environmental Assessment (EA) for a proposed project submitted by Helena, Montana to perform vegetation management activities to reduce the risk of damage from wildfire to Helenas Tenmile Creek potable water delivery system. A portion of the funding would be provided by FEMAs Pre-Disaster Mitigation grant program. This program assists state and local governments with implementing cost-effective hazard mitigation planning and project activities that complement a comprehensive mitigation program. 
The main source of Helenas municipal water is the Upper Tenmile Creek Watershed. The Upper Tenmile Creek Watershed is predominately forested. The Red Mountain Flume is a critical portion of the water conveyance system for Helenas potable water supply. The Flume starts on the west side of Red Mountain at the confluence of Banner Creek and follows the contour of Red Mountain to the north for a distance of 4.8 miles in an easterly direction to Chessman Reservoir. The Flume elevation runs from 6,300 feet to 6,220 feet. The conveyance is comprised of 13,000 feet of open unlined ditch, 11,800 feet of sheet metal Flume, and 500 feet of pipeline. Trestles that total 4,036 feet in nine sections support approximately 20% of the Flume. The trestles are constructed of wood timbers and planks to hold the Flume at the proper elevation for water to flow. Approximately 2.1 miles of the Flume is located on private land and 2.7 miles is located on the Helena National Forest. 
In the case of a catastrophic wildfire, the wooden timber and plank trestles would be destroyed; intense heat, fallen burned trees, and other debris would damage the metal Flume, diversion structures, and waste gates; sediments and debris would impede water flow, all resulting in erosion and likely destruction of the water conveyance system.
The Presidents Council on Environmental Quality (CEQ) has developed regulations to implement the National Environmental Policy Act (NEPA). These regulations require an investigation of the potential environmental impacts of a proposed federal action, and an evaluation of alternatives as part of the environmental assessment process. FEMA also has regulations that establish the agency-specific process for implementing NEPA. An EA will be prepared in accordance with both FEMA and CEQ NEPA regulations. Two alternatives will be considered in this EA: 
The NO ACTION ALTERNATIVE, which considers the consequences of taking no action to reduce the fuel load surrounding the Tenmile Creek Flume.
The PROPOSED ACTION ALTERNATIVE, which would reduce the fuel load around that portion of the Flume located on 2.1 miles of private land, approximately 108 acres, located in Lewis and Clark County. The proposed action would remove all dead and/or fallen timber 3 inches in diameter and larger 100 feet uphill of the Flume, and dead and/or fallen timber 3 inches in diameter and larger plus all Lodgepole pines 300 feet downhill of the Flume. Harvestable timber would be sold. The remaining timber would be cut and piled for burning when climatic conditions are favorable and away from fire hazards and riparian areas.
A second action alternative considered by Helena was the replacement of the century-old Flume with a pipeline, but it was determined it was not feasible at this time because of the difficult terrain and cost. 
The President of the Untied States has issued Executive Orders that require Federal Agencies to focus attention on the environment and on human health and safety when considering the funding of an action. Particular attention is paid to Executive Orders 11988  Protection of Floodplains, 11990  Protection of Wetlands, and 12898  Environmental Justice. FEMA also considers the effects of the proposed action and its compliance with the Endangered Species Act and National Historic Preservation Act.
A public comment period related to the alternatives as outlined above or other possible alternatives will remain open for 15 days following publication of this notice. In addition to this initial comment period, a final comment period will be opened for notice of availability of the Draft EA. 
Interested parties may obtain more detailed information about the alternatives from Helena by calling Keldah Hedstrom at (406) 447-8454, or by e-mail at khedstrom@ci.helena.mt.us. Additionally, comments or question regarding the EA process can be directed to Donna Rakocy, FEMA Region VIII Mitigation Environmental Coordinator by calling (303) 235-4750 or by e-mail at donna.rakocy@dhs.gov. 

8.2 FINAL PUBLIC NOTICE
Notice is hereby given to the public that it is the intent of the Department of Homeland Security-Federal Emergency Management Agency (FEMA) to provide funds to Helena, Montana, to reduce the risk of damage from wildfire to Helenas Tenmile Creek potable water delivery system  the Red Mountain Flume (the Flume). 
FEMA is required under the National Environmental Policy Act (NEPA) to consider all reasonable alternatives for protecting the potable water delivery system from damage due to wildfires. The purpose of the proposed action is to reduce the risk of future damage, hardship, loss, and suffering by reducing the fuel load near the Flume. The Draft Environmental Assessment (EA) considered the following two alternatives: 1) a no action alternative, which considers the consequences of taking no action; and 2) reducing the fuel load along the Tenmile Creek water supply. 
The President of the United States has issued Executive Orders that require Federal agencies, when considering an action for funding, to focus attention on the environment and human health with respect to Floodplain Management, Executive Order 11988; Protection of Wetlands, Executive Order 11990; and Environmental Justice, Executive Order 12898. Compliance with Executive Orders, other environmental laws, and NEPA has been documented in this Draft EA.
FEMA or the applicant has coordinated with the following agencies: Montana State Historic Preservation Office; Montana Division of Fish, Wildlife, and Parks; Montana Office of Homeland Security/Emergency Management Agency; Montana Department of Environmental Quality; Lewis and Clark County Sheriffs Office; U.S. Fish and Wildlife Service; U.S. Forest Service; and U.S. Army Corps of Engineers.
Based upon agency comments, and the EA process, there does not appear to be any significant environmental impact on the human environment associated with the proposed action if documented mitigation measures and requirements stated in the EA are followed. Therefore, an Environmental Impact Statement will not be prepared, and if no comments are received, a Finding of No Significant Impact (FONSI) will be signed fifteen (15) days from the date of this notice, and the project will proceed. 
Interested persons may submit comments, request additional information, or request a copy of the FONSI by contacting FEMAs Region VIII Office located at the Denver Federal Center, P.O.Box 25267, Denver, CO, 80225 or by calling (303) 235-4750 between 8:00 a.m. and 4:30 p.m. Mountain Time, Monday through Friday. Comments or requests should be submitted in writing to Ms. Donna Rakocy, Region VIII Mitigation Environmental Coordinator at the above address, or by e-mail at Donna.Rakocy@DHS.Gov
The Draft Environmental Assessment is on repository with Ms. Amy Teegarden at the Parks Department, 316 North Park Avenue, Room 428, Helena, MT. Business hours are 8:00 a.m. to 5:00 p.m. Mountain Time, Monday through Friday. She may also be contacted at (406) 447-8463.


APPENDIX A
EXHIBITS

List of Exhibits
Exhibit 1	Project Location
Exhibit 2	Location of Red Mountain Flume
Exhibit 3	Example of a Trestled Section of the Flume
Exhibit 4	Project Area
Exhibit 5	Examples of Trails in the Project Area
Exhibit 6	Western Pine Beetle Infested Lodgepole Pine
Exhibit 7	General Vegetation Along the Flume


APPENDIX B
MONTANA OPEN BURNING PERIODS















APPENDIX C
AGENCY CORRESPONDENCE




TABLE OF CONTENTS

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Acronyms and Abbreviations

Introduction

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Alternatives

	Affected Environments and Environmental Consequences

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Summary

Agencies Consulted and References

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References

List of Preparers

Public Notices



	

Appendix A
Exhibits

	A-1