United States 

Department of

Agriculture

Forest 

Service

April 2013

Draft Environmental 

Impact Statement

Stonewall Vegetation Project 

Volume 2 – Appendices

Lincoln Ranger District, Helena National Forest

Lewis & Clark and Powell Counties, Montana
Helena National Forest, Stonewall Vegetation Project, Draft Environmental Impact Statement

The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the 

basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, 

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programs.) Persons with disabilities who require alternative means for communication of program information 

(Braille, large print, audiotape, etc.) should contact USDA’s TARGET Center at (202) 720-2600 (voice and 

TTY). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 

Independence Avenue, SW., Washington, DC 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 

(TTY). USDA is an equal opportunity provider and employer.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

i

Table of Contents

Volume 2 – Appendices 

Appendix A – Public Involvement Summary................................................................................................1

Helena National Forest Scoping Summary ...............................................................................................2

Analysis Issues..........................................................................................................................................5

Additional Public Concerns......................................................................................................................7

Specific Alternatives Suggested for Consideration in Public Comments and Forest Service Response ..9

Summary of Public Comments and Forest Service Response ................................................................12

Appendix B – Proposed Treatment Descriptions and Silviculture Summary .............................................67

Treatment Type and Prescription Descriptions.......................................................................................68

Proposed Treatments by Group and Unit................................................................................................70

Fuels Treatments.....................................................................................................................................76

Silviculture Summary .............................................................................................................................77

Appendix C – Cumulative Effects.............................................................................................................107

Stonewall Vegetation Project Cumulative Effects Activities ...............................................................108

Appendix D – Stonewall Roadless Area Characteristics Worksheet ........................................................131

List of Tables

Table A- 1. Scoping contacts Stonewall Vegetation Project______________________________________________ 2

Table A- 2. Summary of public comments and Forest Service responses___________________________________ 12

Table B- 1. Alternative 2 proposed treatments by group and unit________________________________________ 70

Table B- 2. Alternative 3 proposed treatments by group and unit________________________________________ 72

Table B- 3. Treatment unit management area acreages _______________________________________________ 74

Table B- 4. Alternative 1 compliance with Forest Plan forestwide standards _______________________________ 77

Table B- 5. Alternative 1 compliance with management area standards __________________________________ 79

Table B- 6. Alternative 1 compliance with other Forest Service management direction_______________________ 82

Table B- 7. Alternative 2 compliance with Forest Plan forestwide standards _______________________________ 82

Table B- 8. Alternative 2 compliance with management area standards __________________________________ 84

Table B- 9. Alternative 2 compliance with Forest Service regeneration harvest direction _____________________ 87

Table B- 10. Alternative 3 compliance with Forest Plan forestwide standards ______________________________ 88

Table B- 11. Alternative 3 compliance with management area standards _________________________________ 89

Table B- 12. Alternative 3 compliance with Forest Service regeneration harvest direction ____________________ 92

Table C- 1. Number of fires in the Stonewall watersheds by decade and size class _________________________108

Table C- 2. Acres of past fire and fuels activities in the project area* ____________________________________109

Table C- 3. Past activities _______________________________________________________________________110

Table C- 4. Ongoing Activities 2010-present ________________________________________________________117

Table C- 5. Foreseeable future activities ___________________________________________________________120

Table C- 6. Acres of past harvest and fuels activities in the Bear-Marshall-Scapegoat-Swan IRA ______________124

Table C- 7. Ongoing and reasonably foreseeable future actions in the Bear-Marshall-Scapegoat-Swan IRA _____125

Table D- 1. Effects to roadless characteristics_______________________________________________________132

List of Figures

Figure C- 1. Past, Ongoing and Foreseeable Projects within the Cumulative Effects Boundaries (wildfire location 

information not available, not mapped ___________________________________________________________123

Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

1

Appendix A – Public Involvement Summary
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

2

Helena National Forest Scoping Summary

June 7, 2011

The initial ‘scoping’ conducted in January of 2010 received 80 comments from our interested publics.

Table A-1 lists the letter’s number (used as a reference later in this report) tied to names of the 

individuals, organizations, and agencies that provided comments from scoping for the Stonewall 

Vegetation Project, Helena National Forest.

Table A- 1. Scoping contacts Stonewall Vegetation Project

Letter # Name

1 Jean Public

2 Chris Castagne

3 Dick Artley

4 Steve Flynn, Sun Mountain Lumber

5 Michael Garrity, Alliance for the Wild Rockies and Sara Johnson, Native Ecosystem Council

6 Larry Hoffman, Lincoln County Weed Coordinator

7 Bob Bushnell

8 Chris Castagne

9 Richard Debick

10 Don Doyle

11 KD Feeback

12 Dale Gardner, Helena Trail Riders

13 Melvin and Charlette Hagan

14 Bill Hammer

15 Kelly Ingalls

16 Orrin Johnson

17 Richard Juntunen

18 Marc Kneedler

19 Marvin P. Love

20 S.J. Maras

21 Susan Murphy

22 James L. and Maida Paris

23 Harry Poett

24 Ellen Simpson, Mt Wood Products Association

25 Pauline Webb

26 Capital Trail Vehicle Association

27 Ann and Les Bramblett

28 Thomas Kindrick

29 Jim Palagi

30 Bob and Jan Braico

31 Daniel S. Comer

32 Duane Halverson

33 Steven Kloetzel
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter # Name

34 Joe Marino

35 Robert Petritz

36 Marc S. Ryckman

37 Nelson Wert

38 Jim Fortune

39 Julie Fortune

40 Albert Clark

41 Miles Partin

42 Phyllis Clark

43 Linda Pope and Bruce Baker

44 Robert Ruthemeyer

45 Richard Thieltges

46 Becky Thurman

47 Joe Baze

48 Jerry Burns

49 Charles Sherman

50 Jim Suek

51 Mrs. K Reeve

52 Ray Geist

53 Julie A. Dalsoglio, US Environmental Protection Agency, Region 8

54 Diana Reichenberg

55 Lu Gardella

56 Dick Noel

57 Sharon Paul

58 Gary Lee Petersen

59 Emily Rundell

60 Ellen Mulcare

61 Don Pettit Sunny Slope

62 Jeanette Nordahl

63 Robert Berry

64 Heidi Bray

65 Kim Gray

66 Sarah Johnson, Native Ecosystem Council - Michael Garrity, Alliance for the Wild Rockies

67 Gary E. Sutton Sr.

68 DeWayne Williams

69 Gregg Brittain

70 Mr. and Mrs. Mark Aquino

71 Lincoln Restoration Committee

72 Montana Fish, Wildlife and Parks

73 Paul N. Spengler, TRICO

74 Stan Frazier, Helena Hunters and Anglers

75 Janey Holm
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Letter # Name

76 Bill Koehnke

77 Teresa Martinez, Continental Divide Trail Alliance

78 Wayne and Rebecca Shong, B&W Ranch

79 Andrea Stinson

80 Jerry and Ruth Massee

The scoping document listed preliminary issues considered during development of the proposed action: 

1. Restoration of vegetation communities

2. Grizzly bear habitat

3. Lynx habitat

4. Wildfire hazard, risk, and fuels

5. Habitats including ponderosa pine, western larch and aspen

The scoping document noted proposed actions are anticipated to benefit the project area in the following 

ways: 

Restore ponderosa pine, dry Douglas-fir, and western larch sites to a more natural fire regime 

condition

Maintain vigor and restore aspen groves

Enhance wildlife habitat conditions

Summary of Public Scoping Comments

Table A- 2 displays the summary of public comments received during scoping identified by letter number 

(see table A- 1), and then by comment number from within each letter. Table A- 2 also includes each 

comment’s main topic, and the Forest Service response to the comment as well as identification of 

significant issues. The comments from public scoping identify those issues that may have a significant 

cause-effect relationship with the proposal, and determine the scope of issues addressed in specialists’ 

analyses. The evaluation of these issues may also be the ‘driver’ or foundation of developing additional 

alternatives. This discussion of issues is based on the approach in the April 1, 2011 FSH 1909.15 (12.41).

Of the 80 scoping responses received, 30 were in support of the proposed project activities. The majority 

of responses suggested information to include in the analysis documents, identified language to clarify, or 

listed elements pertaining to a specific resource to include in the effects analyses. The final resource 

specialists’ reports would include this information as well as the analysis of the project effects on the 

various resources. The resource specialists’ reports would be filed in the project record and incorporated 

by reference and summarized in Chapter 3 – Affected Environment and Environmental Consequences of 

the EIS.

Eight responses expressed concerns or suggestions regarding travel management of area roads and 

motorized winter recreation opportunities. The Stonewall Vegetation Project is not a travel planning 

project and does not propose to change the permanent road system in the project area. Travel management 

of existing routes is being addressed in the ongoing analyses “Blackfoot-North Divide Winter Travel 

Plan” and the “Blackfoot Travel Plan (Non-Winter)”.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

5

A few responses included items of literature to be considered, some noted as opposing science 

information. As part of the analysis for this project, resource specialists will review and consider relevant 

scientific literature, including submitted articles. The literature review would be included and filed in the

project record.

Comments/Issues that Warrant the Development of Additional Alternatives (Significant 

Issue): 

Table A- 2 includes a full listing of comments received during scoping, by letter and comment number 

(denoted by L#, c#). The interdisciplinary team reviewed the comments received during scoping and 

identified one significant issue theme (see below). We also reviewed the proposed activities and it was 

determined appropriate to develop an alternative to address the following significant issue:

Wildlife Habitat: Proposed actions may impact habitat for: threatened, endangered and sensitive species

and designated critical habitat; management indicator species (MIS); and big game hiding cover, thermal 

cover, and security cover. The public also commented on habitat connectivity. The public is also 

concerned about viability of old-growth and snag-dependent species.

Scoping letters and comments pertaining to this issue: L5, c22; L66, c2, 3, 5, 6, 27, 28, 38; L74, c74

Indicators:

Total and open-road density during and after activities within the project area relevant to grizzly 

bear habitat and elk habitat

Acres of elk hiding cover, thermal cover, and security habitat within the project area and elk herd 

units

Acres of lynx habitat or other species that utilize multi-storied forest habitat within the project 

area

Maintaining or providing habitat connectivity

Acres by type of treatment by alternative versus no treatment

Acres of old growth affected and effects to snag dependent species

Acres of suitable MIS and sensitive species habitat impacted

Analysis Issues

In addition to the significant issue identified above, we would analyze the effects of the proposed action 

and alternatives based on the following issues to display differences between alternatives:

Weed Spread/Infestation: Proposed actions may disturb landscapes allowing existing weed populations 

to expand or allowing additional species to become established.

Scoping letters and comments pertaining to this issue: L5, c2, 3, 4, 5, 29; L33, c33; L48, c17; L62, c1; 

L71, c10

Indicators:

Acres by type of treatment by alternative versus no treatment

Acres of ground disturbance

Costs of weed treatment by alternative
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Use of roads that would be built then obliterated immediately following timber removal and use of 

existing roads: Comments indicated concern for the effects to soil, water quality, fisheries, and wildlife 

habitat from roads that would be built then obliterated immediately following timber removal, road 

reconstruction, and use of existing roads.

Scoping letters and comments pertaining to this issue: L3, c12; L66, c34, 35, 36; L71, c9

Indicators:

Miles of roads that would be built then obliterated immediately following timber removal

Miles of roads that would be built then obliterated immediately following timber removal and 

reconstruction of existing roads within the INFISH buffers

Number of new stream crossings

Miles and location of haul routes

Amount of Prescribed Fire: Concern that the Forest Service has limited experience implementing 

prescribed fire in mixed-severity fire regimes. Concern with the amount of acres proposed for prescribed 

burning; proximity to private land and timing of burns introduce risk to private lands (e.g., loss of homes, 

buildings, smoke effects to air quality).

Scoping letters and comments pertaining to this issue: L1, c3; L57, c1; L75, c4; L79, c1; and public 

meetings

Indicators:

Acres of prescribed fire immediately adjacent to private land and the qualitative values of risk 

and potential consequences 

Acres of prescribed fire by fire regime within the project area

Acres and type of pretreatment prior to use of prescribed fire 

Estimated emissions from burning 

Other Issues

The following lists other issues considered in the analysis; however, they did not rise to the level of 

significant issues. The proposed action is not expected to have significant impacts on these issues. The 

effects are limited in intensity and context. For some of these issues, potential impacts are limited through 

project design. Analysis of potential effects related to these issues would be addressed in Chapter 3; 

however, analysis may not be as in-depth as for the significant issue. The Forest Service response follows 

each issue.

Some members of the public feel use of timber harvest, including regeneration harvest, to achieve 

restoration goals is a contradiction.

Scoping letters and comments pertaining to this issue: L1, c2; L3, c4, c7; and public meetings

Timber harvest and prescribed burning are means to diversify areas to achieve broader restoration 

goals across the landscape. To promote a resilient forest a combination of treatments to restore the 

broader landscape were considered. The proposed action includes regeneration harvests for some 

areas where the majority of the existing overstory trees have been killed by bark beetles. 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

7

Due to the amount of mortality caused by insects and/or diseases across the Stonewall Vegetation 

Project area, restoration opportunities exist to reforest lands for the following purposes:

○ Establishment of tree species most able to cope with disturbance

○ Promote a diverse species mix as well as genetic diversity

○ Promote desired species distribution across the Stonewall Vegetation Project area

○ Enhance regeneration of forested lands to create diverse structures across the Stonewall 

Vegetation Project area

○ Manage for species persistence within/across the Stonewall Vegetation Project area

○ Maintain adequate seed bank of desired species

Resource effects would be noted in Chapter 3 of the DEIS, e.g., wildlife habitat elements that may be 

affected and how the proposed actions may restore those habitat elements. The proposed actions may 

have short-term adverse impacts with long-term benefits for some resources.

Merchantability and Economic Feasibility of Harvest - trees being dead too long, agency action/response 

too slow.

Scoping letters and comments pertaining to this issue: L4, c4; L33, c3; L35, c1

Insect-caused mortality effects are greater than anticipated when the project started. Fuels reduction 

in wildland urban interface (WUI) and restoration goals throughout the broader landscape have 

benefits that would be realized through the proposed actions. In the fall of 2010, timber industry 

representatives made an on-site field review of forested areas on the Lincoln Ranger District

experiencing insect-caused mortality. Industry representatives indicated timber merchantability is still 

present and anticipated to be present at the time of contract award (A.Kamps, personal 

communication).

Proposed treatments would increase sediment and adversely affect cutthroat trout habitat.

Scoping letters and comments pertaining to this issue: L5, c 23, 26, 27, 28, 30; L16, c1

Effects to fisheries would be discussed in Chapter 3 of the DEIS. The proposed action would include 

the best management practices (BMPs) to ensure proper drainage and reduce potential increases to 

sediment from proposed activities. The INFISH management direction would be incorporated to 

reduce potential effects to cutthroat trout habitat. A literature review and local Forest monitoring of 

BMP effectiveness would be discussed in Chapter 3 of the DEIS. 

Additional Public Concerns

The following is a summary list of additional public concerns considered in the analysis of issues; 

however, they did not rise to the level of significant issues. The proposed action is not expected to have 

significant impacts on these issues. The effects are limited in intensity and context. For some of these 

issues, potential impacts are limited through project design. Analysis of potential effects related to these 

issues would be addressed in chapter 3; however, analysis may not be as in-depth as for the significant 

issue. 

These other issues were expressed as concerns. Individual responses to comments are located in table A2. There are concerns that:

Ground disturbance and prescribed fire in the Historic Lincoln Townsite could result in loss of the 

historical integrity of this site
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Dust from increased road use could temporarily reduce sight-distance and cause safety concerns 

on native and aggregate surfaced roads used for timber hauling

Removal of commercial-sized timber and thinning treatments to reduce hazardous fuel conditions 

may increase fine fuels on the ground that exacerbates fire behavior and increases fire risk

To ensure project effects are appropriately disclosed, the analysis needs to use the best science 

available, disclose ecological liabilities from past actions, incorporate past monitoring 

information, and address conflicting science literature brought forward by the public during 

scoping

Ground disturbance from timber removal and prescribed fire may impact threatened, endangered, 

rare and sensitive plant, animal and fish species, or their viability within the project area

Proposed timber removal and prescribed burn activities could exacerbate climate change due to 

the loss of carbon storage

Control lines used for prescribed burning in the inventoried roadless areas may increase 

unauthorized motorized use into new areas, which could affect the inventoried roadless character

Evaluate if jobs would be available due to the proposed actions

The proposed use of fire is going to require a major educational effort before it is acceptable to 

many of the residents

Proposed activities should allow for multiple uses, and timing may impact recreational users 

(road and trail users, campers, berry picking), areas should be open for firewood gathering prior 

to burning 

Concern that proposed treatments may have a visual impact, especially along property lines and 

in-holdings

Proposed timber removal may change densely vegetated areas that currently prevent livestock 

movement and change grazing patterns in the project area

Some concerns raised for the Stonewall Vegetation Project were outside the scope of the proposed action, 

or decision to be made, or were already decided by law, regulation, Forest Plan, or other higher level 

decision. Individual responses to comments are located in table A- 2. These items included:

Management of private lands including building locations and vegetation management, Insurance 

of private structures

Terminology, wording and phrasing used in scoping document

Scope of the Purpose and Need

Designating the contracting process (stewardship and size of commercial harvest sales) for 

potential implementation of project activities

Developing a detailed long-term program for maintaining the safer conditions, including how 

areas would be treated in the future following proposed treatments, or how areas not needing 

treatment now would be treated as the need arises

Travel management concerns regarding the existing National Forest System roads being analyzed 

under the Blackfoot –North Divide Winter Travel Plan and Blackfoot Travel Plan (non-winter).

Items related to Forest Plan programmatic direction (e.g. long-term fire management plans, 

roadless area evaluations)

Need to update allotment management plans

Allocation of funding

Staffing of controlled burns; this would be addressed through the site-specific burn plan

Explore monitoring partnerships
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Specific Alternatives Suggested for Consideration in Public 

Comments and Forest Service Response

Maximize timber harvest and fuels reduction activities, particularly in the WUI. (L1, c2)

The WUI was identified during development of the “Tri-County Regional Community Wildfire 

Protection Plan” (2005). The proposed action was designed to address fuels concerns on National 

Forest System lands adjacent to private lands. Treatments on private lands are outside the scope of 

our proposed action, but past, current and planned treatments would be considered in the individual 

specialist’s cumulative effects reports, where applicable.

We reviewed the project area to identify potential vegetative treatments based on site conditions.

This alternative would be similar to the proposed action, and would not be analyzed in detail.

The roadless areas within the project area were created by the Rare 2 process identifying possible 

additions to the wilderness system. Management should reflect this quality. In addition, burning 

whitebark pine seedling and sapling areas, present in the roadless areas, could reduce white bark pine 

habitat, an important food source for grizzly bears. Consider an alternative that does not include 

prescribed burning in the roadless areas, but allows for the use of natural prescribed fire without 

mechanical treatments, including cutting trees and brush, in the roadless areas. (L5 c7; L48 c8)

The large prescribed burn units in the roadless areas are proposed to improve the mix of vegetation 

composition and structure across the landscape making it more diverse, resilient, and sustainable to 

wildfire and insects. In particular, the burns in the roadless areas would be designed to encourage 

whitebark pine regeneration in proximity to existing mature whitebark pine trees. Portions of some 

units are lacking adequate ground fuels to carry fire across the desired burn unit locations. Without 

the prep work, burn prescriptions could not be implemented and fire lines could not be prepared.

For any action alternative, design features could be incorporated to exclude large concentrations of 

whitebark pine regeneration from burning, and protect mature whitebark trees that may provide seed 

sources.

The no action alternative does not include slash treatments or prescribed burning in the roadless area 

and would address this issue.

This alternative would not address the purpose and need to improve the mix of vegetation 

composition and structure, or modify fire behavior to create conditions that allow the reestablishment 

of fire as a natural process across the roadless area portions of the landscape. This alternative was 

eliminated from detailed analysis.

Burning activities proposed may char merchantable timber and decrease its value in areas managed for 

timber products. Consider an alternative that does not include prescribed burning in areas managed for 

timber products. Prescribed fire units in management areas T1-5 include all of units 2 and 78, and 

portions of units 77, 79, 80, 81, 84, 85, 86 and 87. (L79, c2, c3)

The Forest Plan identifies prescribed burning as an appropriate tool for vegetation and fuels 

management (pages II/33 – 34), and the Forest Fire Management Plan direction in place at the time of 

implementation would be followed. The no-action alternative would include no controlled burning in 

areas managed for timber products. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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This alternative would not address the purpose and need to modify fire behavior to enhance 

community protection while creating conditions that allow the reestablishment of fire as a natural 

process on the landscape. Therefore, this alternative was eliminated from detailed analysis.

Proposed actions may disturb landscapes allowing existing weed populations to expand or allowing 

additional species to become established. Consider an alternative that eliminates units that have noxious 

weeds present on roads within units from fire management proposals. (L5 c2)

The Forest Weeds FEIS (USDA Forest Service 2006) identified most of the roads in the project area 

for weed monitoring and treatment due to the presence of weeds. Appropriate preventive measures 

would be incorporated in the project design features including post treatment spraying of landings in 

year 1 after mechanical treatment, and monitoring at years 3 and 5, with retreatment if needed.

The no action alternative addresses this suggestion.

Eliminating units with noxious weeds would eliminate fire management treatments in all units in the 

WUI accessed by existing roads. Not treating areas within the WUI would not enhance community 

protection. This alternative would not meet the purpose and need for the project of modifying fire 

behavior to enhance community protection while creating conditions that allow the reestablishment of 

fire as a natural process on the landscape.

Eliminating the units within the WUI would not meet the purpose and need for the project of 

modifying fire behavior to enhance community protection. In addition, the appropriate project design 

and mitigation of relevant best management practices would be applied to any developed action 

alternative. Therefore, developing an alternative that eliminates units that have noxious weeds present 

on the roads within them from fire management proposals is not necessary. This alternative would not

be considered in detail.

Public comments noted the continued loss of motorized recreational opportunities as a primary concern. 

A recommendation was made to consider a Pro-Recreation Alternative that would address recreation 

opportunities and include the following characteristics (L26 c1, 2, 4):

1. Dispersed camping within 300 feet of all existing routes

2. Use of seasonal closures, where required, to protect the environment and wildlife with the intention 

of keeping routes open for the summer recreation season

3. All of the existing routes are needed as OHV routes due to the cumulative effects of all other 

closures

4. Additional OHV routes are needed to address the growing popularity of OHV recreation and the 

greater needs of the public for access and motorized recreation

Effects to recreation resources would be addressed in analysis and project design features would be 

included to minimize potential impacts to recreation opportunities within the project area.

Travel management is being evaluated in the current Blackfoot Travel Plan (non-winter) and the 

appropriate project design and mitigation of the relevant best management practices would be applied 

to any developed action alternative. Developing a pro-recreation alternative with additional OHV 

routes was considered, but this would not address the purpose and need identified for this project for 

fuels reduction in the WUI or restoration across the landscape. Therefore, this alternative was 

eliminated from detailed analysis.

Consider a watershed or ecosystem restoration alternative or incorporate restoration elements in the 

alternatives considered. (L53 c6, 10, 11)

The Stone Dry Watershed Assessment (2009) was considered when developing the proposed action. 

The purpose and need includes a restoration element. The proposed action was designed to 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

11

incorporate treatments that move the project area towards a more resilient forest to address restoration 

of vegetative composition and structural diversity elements. Effects to vegetation and watershed 

resources would be discussed in chapter 3 of the EIS.

Watershed restoration and reducing sedimentation is often focused on changes to roads, and includes 

fixing drainage structures, road design or decommissioning roads. Changes to existing road 

alignments and decommissioning existing roads are being evaluated in the current analysis for the 

Blackfoot Travel Management Plan (Non-Winter) and therefore not being considered in this proposal. 

Since many of the watershed elements of concern are being evaluated in the current Blackfoot Travel 

Plan (Non-Winter), and the appropriate project design and mitigation of relevant best management 

practices would be applied to any developed action alternative, a true or purer watershed restoration 

type alternative is not necessary; therefore, this type of alternative will not be considered in detail. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Summary of Public Comments and Forest Service Response

Nonsignificant issues are categorized as those: (1) outside the scope of the proposed action, or decision to be made; (2) already decided by law, 

regulation, Forest Plan, or other higher-level decision; (3) comments pertaining to disclosing the effects to various resources, which are addressed 

by the specialists’ analyses and the discussions in the draft environmental impact statement (DEIS); or (4) comments in support of the project. 

Table A- 2. Summary of public comments and Forest Service responses

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

1 Private land 1. Stop allowing home owners to build near 

the forest. Simply zone out those areas as 

home sites. let home owners who insist on 

building there know that there is always a 

possibility of fire - and try to change their 

minds and you can do that

This analysis pertains to the management of 

National Forest System lands. Management of 

private lands is outside the scope of this 

analysis and beyond the purpose & need of 

this analysis.

Nonsignificant

issue (1)

1 Restoration 2. I am in favor of letting the survivor trees 

that are growing there continue to grow. They 

seem to be taking advantage of what grows 

there and they should be left alone. What 

used to grow there grows there no longer and 

spending huge sums of tax dollars for that 

purpose is a waste.

The no action alternative addresses leaving 

survivor trees alone.

Proposed treatment prescriptions in the 

Stonewall vegetation project include either 

thinning treatments where many trees that 

have survived the recent bark beetle epidemic 

would be retained or regeneration treatments 

where some live trees would be retained for 

shelter and as a seed source.

Nonsignificant

issue (3)

1 Prescribed 

Burning

Air Quality

3. It isn’t the “smoke” which you can see 

easily, but it is the fine particulate matter 

which needs a microscope to [s]ee it gets into 

American citizens bodies and kills and injures 

them. You are causing health problems when 

you burn. Stop harming fellow Americans 

now. 

Air quality impacts, including smoke from 

proposed burn activities, would be analyzed 

and a summary of the effects anticipated 

under all alternatives would be included in the 

DEIS. The no action alternative addresses no 

prescribed or pile burning. 

The Montana/Idaho Airshed Group 

coordinates burning on all forest and range 

lands. They analyze information for proposed 

burns, meteorology and air quality and decide 

if restrictions to burning are needed. The 

airshed group is comprised of members of 

regulatory health agencies and those that 

conduct extensive prescribed burning. Burning 

would be dependent upon site conditions and 

weather conditions, and is generally 

anticipated for fall of the year. Notice of the 

Alternative 3 

proposes a 

reduced level of 

prescribed 

burning, and 

therefore reduces 

total impacts.

The no-action 

alternative would 

not include 

prescribed 

burning.

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

13

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

pile and prescribed burning timeframes, or 

burn windows, would be shared with the public 

through paper notices and announcements on 

the Forest website. Local notices would be 

attempted to ensure people are aware of the 

burning activities.

Smoke sensitive receptors would be identified 

and modeling outputs will show impacts to 

these areas. Smoke management techniques 

such as phase burning and the time of year 

burns are ignited are designed to reduce 

smoke impacts. 

2 Support for the 

Project

1. I do believe with projects like this one, our 

outcome would be far more positive than 

doing nothing.

Thank you for your support Nonsignificant 

issue (4)

3 Opposing 

Science

1. To restrain you from ignoring the opposing 

science attached to this letter, I will educate 

you on 5 recent court cases dealing with 

opposing science. I expect you to comply with 

the precedence set by these cases.

As you can see from reading the judge’s 

opinions in the 5 court cases below, you must 

respond to each scientific statement 

individually. In doing so you have several 

choices:

1) Tell the public that the opposing science 

statement does not apply to your project and 

explain why.

2) Tell the public that the science statement is 

not true and explain why.

3) Tell the public that the science statement is 

true and applies to your project; however you 

choose to ignore it as you plan your project. If 

this is the case, you MUST explain why.

4) Tell the public that the scientist(s) making 

statements that oppose your project are not 

recognized by the USFS as real scientists. If 

this is the case, you MUST provide the reader 

with your reasons. I will then email your 

reasons to the scientist.

Literature submitted in response to scoping 

would be reviewed and considered by the 

interdisciplinary team, with other relevant 

literature for this analysis. The literature review 

would be available in the project record. The 

literature review would discuss why literature is 

relevant or not relevant to the project.

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

14

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

5) Tell the public that the science statements 

have not been peer reviewed. If this is done, 

the USFS line-officer must omit all references 

used to support the project that are not peer 

reviewed.

I highly recommend that you read these 5 

opinions in their entirety. The links are 

included after a key quote from the judge’s 

opinion.

League of Wilderness Defenders et al. v. 

Elaine Marquis-Brong. In the United States 

District Court for the District of Oregon, Judge 

Ancer L. Haggerty,Civil No. 02-75-HA. April 

18, 2003,

League of Wilderness Defenders et al. v. 

United States Forest Service. In the United 

States District Court for the District of 

Oregon, Judge Ancer L.Haggerty, Civil No. 

04-488-HA. November 19, 2004, and

Blue Mountains Biodiversity Project et.al v.

Blackwood, 161 F.3d 1208, 1211 (9th 

Cir.1998). Betty B. Fletcher, circuit Judge. 

Appeal from the United States District Court 

for the District of Oregon Ann Aiken, District 

Judge, Presiding, this direction is clear.

Center for Biological Diversity v. U.S. Forest 

Service, 349 F.3d 1157 (9th Cir. 2003). 

Donald C. Pogue, circuit court Judge. Appeal 

from the United States District Court for the 

District of Arizona, Robert C. Broomfield 

District Judge Presiding.

Friends of the Clearwater et al. v. D. Robert 

Lohn et al., In the United States District Court 

for the District of Idaho, Judge Edward J. 

Lodge, CV04-384-C-EJL, March 31, 2005.

3 Scoping letter 

is vague

2. Nowhere does your scoping document tell 

the public the total acres that would be

logged and the total acres that would be 

burned all in one place. On page 4 the public 

must struggle with 8 different groups to 

The proposed action descriptions would be 

reviewed and revised, where needed, to better 

display the proposed harvest and broadcast 

prescribed burn information. These figures 

would be clearly displayed in chapter 2 under 

Nonsignificant 

issue (3)
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# Topic Comment Response Alternative Issue # Or Category(Ies)

determine what will really occur in each group 

in the treatment descriptions.

Your proposed action for the timber sale 

should be obvious to the public!

alternatives comparison section of the DEIS.

3 Fire behavior 3. To any thinking person, the notion of 

removing commercial-sized timber to reduce 

the risk of wildfire is ridiculous. It is the fine 

fuel that carries a fire. Even more importantly, 

the weather determines the size, intensity, 

flame height and rate of spread of a wildfire.

In your FEIS please include the science 

showing that fuels is more important in 

determining fire behavior than weather. See 

science attachment # 3.

Effects to fire/fuels would be analyzed in the 

fire/fuels report and would be summarized in 

Chapter 3 of the DEIS. Fire models used to 

analyze potential changes to anticipated fire 

behavior (e.g., flame length) would be

discussed in the DEIS. Existing fire models 

consider various factors including existing and 

activity created fuels and the larger dead trees 

that are anticipated to fall over time. Opening 

the forest canopy can reduce crown fire 

potential which would be discussed in Chapter 

3 of the DEIS. The no-action alternative and 

the untreated areas in any action alternative 

would display the effect of leaving existing 

trees and the potential crown fire anticipated. 

Both fuels and weather contribute to fire 

behavior

Nonsignificant 

issue (3)

3 Insects 4. Insect activity in a forest is an indicator of a 

properly functioning forest. The survival of 

some species of birds is dependent on forest 

insects.

Let Nature play out her cycles that have 

occurred for thousands of years. This 

includes insects! 

The project area contains areas of mortality 

that are not proposed for treatment The effects 

to various bird species including management 

indicator pileated and hairy woodpeckers 

along with migratory birds would be analyzed. 

Untreated areas in the project area would 

continue to provide habitat for species 

associated with insect activity. 

The activities of insects are a natural process 

in western forests, and the scale and 

frequency of insect activity can be an indicator 

of a properly functioning forest. However, the 

recent bark beetle epidemic in the western 

United States is of a magnitude never before 

recorded, and can be considered an indicator 

of unhealthy forest conditions created by 

decades of fire exclusion that resulted in very 

large expanses of forest becoming high risk at 

the same time, as stated in the project scoping 

letter. This subject would be discussed in the 

Nonsignificant 

issue (3)
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# Topic Comment Response Alternative Issue # Or Category(Ies)

Vegetation section, in chapter 3 of the DEIS.

3 Wildland 

Urban 

Interface

5. Community protection,” give me a break. 

You are proposing to log 4 miles from the 

town of Lincoln and you actually think it will 

reduce the risk of fire damage to homes in 

and around the city. At the top of page 1 of 

your scoping document you actually say: 

“The project encompasses approximately 

8,640 acres adjacent to the community of 

Lincoln.”

How do you determine that something 4 miles 

away from a community is adjacent to the 

community?

Although the town of Lincoln is 4 miles from 

the project area, there are subdivisions with 

private residences located adjacent to the 

forest boundary and identified in the TriCounty Community Wildfire Protection Plan 

(CWPP) (2005) as wildland urban interface. 

The Tri County CWPP identifies subdivisions 

as “Very High to High Risk” and stands close 

to the forest boundary are proposed for 

harvest treatments to reduce potential for 

crown fire spread into adjacent areas.

Nonsignificant 

issue (3)

3 Wording of the 

document

6. Stop using Meaningless Euphemisms to 

Describe your Project Goals.

When you say you will treat the forest, you 

tell the public nothing!

Other ambiguous, meaningless and 

deceptive terms used so often used by USFS 

line officers are:

● Enhance According to Webster, enhance is 

a verb meaning “to raise to a higher degree; 

intensify; magnify.”

● Mechanical treatment Why is the USFS so 

frightened of using the word logging? Logging 

applies to all commercial extraction of trees . . 

. including “thinning.”

● Restoration Once again, sugar-coated 

words. Webster defines restoration as “a 

return of something to a former, original, 

normal, or unimpaired condition.”

Clearly, USFS logging and road construction 

is the antithesis of restoration.

● Rehabilitate Once again, sugar-coated 

words. Webster defines rehabilitate as “to 

restore to a condition of good health, ability to 

work, or the like.” Clearly, USFS logging and 

road construction is the antithesis of 

rehabilitation.

Terms would be defined in a glossary as 

needed and ‘plain’ language would be used 

where appropriate. 

Nonsignificant 

issue (1)
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# Topic Comment Response Alternative Issue # Or Category(Ies)

I strongly suggest that you purge your NEPA 

document of all words shown above in bold 

type and tell the public what you really intend 

to do!

3 Wording of the 

document

7. How does one enhance a tree species? 

Enhance what? The USFS is so accustomed 

to using euphemistic words that are far 

removed from the issue at hand.

What habitats do you want to enhance . . . 

the tree species habitat or the wildlife habitat 

that exists in aspen, western larch, and 

ponderosa pine?

The meaning of the term enhance according 

to Webster is: “to raise to a higher degree; 

intensify; magnify.”

I suggest you read science attachment #1 

again and tell me about how logging 

enhances anything other than a timber 

corporation’s bottom line.

Enhancing a tree species would be taking 

actions to increase the presence of that 

species within the project area. Effects to tree 

species would be analyzed in the silviculture 

report and discussed in the Vegetation section 

in chapter 3 of the DEIS.

See also response to letter 3, comment 1 

pertaining to submitted literature.

Nonsignificant 

issue (1,3)

3 Purpose and 

Need

8. Your Proposed P&N Violates the CEQ 

Regulations for Implementing NEPA. 

You have identified 5 reasons for the 

Stonewall Deuce Fuels Reduction and 

Vegetation Management Project. You do not 

indicate which of the 5 is the driving issue for 

the sale. This means that 4 of your claimed 

reasons for proposing the project are not 

reasons for proposing the project, but claimed 

benefits of the project.

Mixing up project benefits with the “underlying 

purpose and need” violates the CEQ 

regulations.

In summary, the ‘underlying’ purpose for this 

proposal is to:

have a desired mix of vegetation composition 

and structure across the landscape that is 

diverse, resilient, and sustainable to wildfire 

and insects (FP Goal 4 p. II/1; objective for WL 

and fish p. II/4);

that retains forest stands that allow fire as a 

natural process (FP Goals 4 & 14 pp. II/1-2) 

without risk of catastrophic events;

maintaining desired amounts of aspen, 

Western Larch, & PP (FP Goal 4 p. II/1) ;

while providing forest products including timber 

(FP Goals 11, 12 & 16 pp. II1-2);

and integrating with socioeconomic 

considerations (FP Goals 9, 1, 16 & 12 pp. 

II/1-2; Objective for visual and Roadless p. 

II/3). 

The purpose and need developed for the 

project was designed to address the difference 

Nonsignificant 

issue (1)
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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

between the existing conditions observed in 

the Stone Dry Watershed Analysis completed 

in 2009, and the desired conditions identified 

in the Forest Plan, while striving towards the 

goals and objectives identified in the Forest 

Plan (pp. II/1-6; III/5-7; III/30-52).

3 The Migratory 

Bird Treaty Act 

of 1918

9. On January 10, 2001, President Clinton 

signed E.O. 13186, which described the 

responsibilities of federal agencies to protect 

migratory birds. One of the requirements of 

E.O. 13186 is that ``Each Federal agency 

taking actions that have, or are likely to have, 

a measurable negative effect on migratory 

bird populations is directed to develop and 

implement a Memorandum of Understanding 

with the Fish and Wildlife Service that shall 

promote the conservation of migratory bird 

populations.''

Clearly your proposal to underburn and pile 

brush (in which many species of wild birds 

nest) will result in a take of migratory birds in 

your project area.

Without an MOU from the USFWL approving 

your destruction of nesting habit, you will 

clearly violate this law.

Consultation with the USFWS would be 

completed prior to a decision on this project.

This project would follow the Memorandum of 

Understanding (MOU) with USFWS (FS 

Agreement # 08-MU-1113-2400-264). In 

particular the analysis and project design 

features would address item 3 from the MOU, 

noted here:

“Within the NEPA process, evaluate the effects 

of agency actions on migratory birds, focusing 

first on species of management concern along 

with their priority habitats and key risk factors. 

To the extent practicable:

a. Evaluate and balance long-term benefits of 

projects against any short- or long-term

adverse effects when analyzing, disclosing, 

and mitigating the effects of actions.

b. Pursue opportunities to restore or enhance 

the composition, structure, and juxtaposition of 

migratory bird habitats in the project area.

c. Consider approaches, to the extent 

practicable, for identifying and minimizing take 

that is incidental to otherwise lawful activities, 

including such approaches as:

1. altering the season of activities to minimize 

disturbances during the breeding season;

2. retaining snags for nesting structures where 

snags are underrepresented;

3. retaining the integrity of breeding sites, 

especially those with long histories of use and;

4. giving due consideration to key wintering 

areas, migration routes, and stopovers.”

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

3 Lodgepole 10. Your Wishes to Eradicate Lodgepole Pine Clarification of the proposed actions. Nonsignificant 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

19

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Pine 

Treatments

from your District are Unwarranted

At the bottom of page 2 you lament the fact 

that the insect levels in your LPP are infecting 

the Ponderosa Pine. Why do you not 

understand that insect attacks on mature LPP 

(80+ years) is part of the natural cycle of this 

tree species. Given that LPP has serotinous 

cones, insect attacks and subsequent fire is 

the natural mechanism for LPP regeneration. 

Stands of LPP contain key habitat for a 

variety of birds and mammals. LPP is a native 

species in your area. No reasonable 

management scheme will ever keep insects 

from invading LPP.

I strongly suggest that you stop interfering 

with Mother Nature motivated by greedy 

human needs.

The Forest Plan does not include direction to 

eradicate lodgepole pine. The Stonewall 

Vegetation Project scoping letter recognized 

that fire suppression-an unnatural undertakinghas led to a loss in open forest conditions 

containing ponderosa pine. The proposed 

action was designed to address the purpose 

and need to restore ponderosa pine habitats 

that have been lost and create conditions that 

allow for the establishment of fire as a natural 

process, and to develop a mix of vegetation 

composition and structure that is resilient to 

wildfire and insects.

issue (2,3)

3 Wording in 

Document

11. Stop using Meaningless Euphemisms to 

Describe your Proposed Actions

Same as letter 3, comment 6, but adds the 

word “activities”

Terms would be defined in a glossary as 

needed and ‘plain’ language would be used 

where appropriate. 

See response to letter 3, comment 6 regarding 

language.

Nonsignificant 

issue (1)

3 Road 

Construction

12. The USFS has gone to great lengths to 

convince the public that the construction of 

temporary roads and obliterating system 

roads is ecosystem-benign. Of course this is 

a lie.

See below for the reasons that temp roads 

have more impacts to the aquatic resources 

than system roads:

1) The earth must be handled twice when 

constructing and obliterating temp roads.

2) Temp roads are "designed" by a logger on 

a cat with no knowledge of hydrology and the 

logger is under pressure to work quickly.

3) Most temp roads are outsloped, thus, the 

water on the road drains off the road at 

random places.

4) Temp roads have no surfacing to slow the 

water velocity. High water velocity picks up 

Obliteration of National Forest System roads is 

not proposed. Effects of roads built then

obliterated immediately following timber 

removal would be analyzed for all affected 

resources. Proper design features using best 

management practices would be applied 

minimizing soil displacement and sediment 

delivery concerns. 

See also response to letter 3, comment 1 

regarding the literature considered.

Nonsignificant 

issue (3)
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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

more sediment particles.

5) Temp roads have no ditch. Ditches 

adjacent to system roads control the water 

until the road designer calls for an 

appropriate outlet culvert location.

6) Sediment-laden water leaves the temp 

road at random locations...often in the 

streams.

Please read “Temporary Roads are Like Low 

Fat Ice Cream” by George Wuerthner , 3-17-

09. The link to this article is at:

http://www.newwest.net/topic/article/temporar

y_roads_are_like_low_fat_ice_cream/C564/L

564/

3 Collaboration 13. Taking whatever actions the local 

collaborative group wants is not consistent 

with the requirement to “properly 

accommodate local participation.” The USFS 

specialists have the natural resource 

knowledge and expertise. If the lay members 

of a local collaborative group propose that the 

USFS take action that is either illegal, harms 

the environment or does not maximize the 

protection of public health or safety, the 

USFS should educate the public.

Best science must drive the programs, 

projects, and activities to protect public health 

and safety. If a local collaborative group 

proposes that the USFS take action that is 

contrary to best science, the USFS should 

say no. See: 

http://ceq.hss.doe.gov/nepa/regs/Executive_

Order_13352.htm

During project development, the working group 

recommendations were reviewed by the Forest 

Service. The Forest Service modified the 

group’s recommendations and developed 

additional treatments that we incorporated into 

the project proposed actions to meet the 

purpose and need identified for the Stonewall 

project while following Forest Plan direction. 

Chapter 1 of the DEIS would explain the 

process for development of this project 

proposal.

Relevant literature has been considered in the 

analysis. See response to letter 3, comment 1 

regarding the literature considered.

Nonsignificant 

issue (3)

4 Support for the 

Project

1. I support all aspects of the proposed action Thank you for your support. Nonsignificant 

issue (4)

4 WUI 2. Maximize the salvage of infested LPP and 

fuel reduction treatments on acres located 

within the Wildland Urban Interface.

During development of the proposed action, 

we reviewed all stands for appropriate 

treatments, and while not all WUI acres are 

proposed for treatment, they were evaluated. 

Some were not included to ensure consistency 

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

with Forest Plan direction, or to minimize 

effects to resource areas while meeting Forest 

Plan direction. The purpose and need for this 

project includes:”Modify fire behavior to 

enhance community protection while creating 

conditions that allow the reestablishment of fire 

as a natural process on the landscape.” and 

“Utilize economic value of trees with economic 

removal.” 

4 Use HFRA to 

save time. Do 

not let timber 

deteriorate

3. Utilize the Healthy Forests Restoration Act 

to develop the NEP A on this project. This is 

supported by the Purpose and Need 

statement and the fact that much of the

project is within the WUI. In salvaging high 

risk and infested LPP and thinning mixed and 

DF stands, there is very little difference in the 

on-the-ground treatments for "Restoration" or 

"Fuel Reduction" activity.

4. It is also very important that this proposal 

moves forward in a timely manner. The value 

of the timber that makes this project feasible 

is deteriorating and the longer the analysis 

takes, the less feasible it becomes. The 

HFRA requires analysis of the proposed 

action and the no alternative action. Not 

having to develop a range of alternatives will 

save valuable time.

The Healthy Forests Restoration Act (HFRA) 

process was considered for this analysis. 

The Forest Service is aware of the need to 

move this project along in a timely manner. We 

are evaluating product value and an economic 

analysis is provided in chapter 3 of the DEIS.

Nonsignificant 

issue (1, 3)

4 Collaboration Utilize Stewardship Contracting as the 

primary method for accomplishing the 

identified projects.

Stewardship contracting may be considered 

during implementation; however, this analysis 

does not specify implementation methods.

Nonsignificant 

issue (1)

4 Request to be 

kept informed 

Please keep me informed as the proposal is 

developed.

Commenter would be maintained on the 

project mailing list. 

Nonsignificant 

issue (1)

5 General 

Description of 

the Project

1. The Forest Service must complete a full 

environmental impact statement (EIS) for this 

Project because the scope of the Project will 

likely have a significant individual and 

cumulative impact on the environment.

Following the list of necessary elements, 

Alliance has also included a general narrative 

discussion on possible impacts of the Project, 

The analysis for this project is an EIS.

See response to letter 3, comment 1 regarding 

the literature considered. The literature review 

completed for this project would be available in 

the project record.

Nonsignificant 

issue (1)
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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

with accompanying citations to the relevant 

scientific literature. These references should 

be disclosed and discussed in the EIS for the 

Project. See Letter # 5 for list

5 Weeds 2. Please provide an alternative that 

eliminates units that have noxious weeds 

present on roads within units from fire 

management proposals. Please address the 

ecological, social and ascetic impact of 

current noxious weed infestations within the 

project area. Include an analysis of the 

impact of the actions proposed by this project 

on the long and short term spread of current 

and new noxious weed infestations. What 

treatment methods would be used to address 

growing noxious weed problems? What 

noxious weeds are currently and historically 

found within the project area? Please include 

a map of current noxious weed infestations 

which includes knapweed, Saint Johnswort, 

cheat grass, bull thistle, Canada thistle, 

hawkweed, hound’s-tongue, oxeye daisy and 

all other Category 1, Category 2 and 

Category 3 weeds classified as noxious in the 

MONTANA COUNTY NOXIOUS WEED 

LIST.

3. Are yellow and orange hawkweeds present 

within the project area? Please address the 

cumulative, direct and indirect effects of the 

proposed project on weed introduction, 

spread and persistence that includes how 

weed infestations have been and would be 

influenced by the following management 

actions: road construction including new 

permanent and temporary roads, and skid 

trails proposed within this project; opening 

and decommissioning of roads represented 

on forest service maps; ground disturbance 

and traffic on forest service template roads, 

mining access routes, and private roads; 

removal of trees through commercial and preThe majority of the large prescribed fire units 

are in the roadless area where roads are 

lacking.

An alternative that eliminated units with 

noxious weeds present on roads from fire 

management proposals was considered. 

Eliminating units with noxious weeds would 

eliminate fire management treatments in all 

units in the WUI accessed by existing roads. 

Not treating areas within the WUI would not 

enhance community protection. This 

alternative would not meet the purpose and 

need for the project of modifying fire behavior 

to enhance community protection while 

creating conditions that allow the 

reestablishment of fire as a natural process on 

the landscape.

The no action alternative addresses 

eliminating units that have noxious weeds 

present on roads.

Noxious weeds, including known occurrences 

and potential for spread would be analyzed in 

the noxious weed report and discussed in 

Chapter 3 of the DEIS. 

Preventive measures would be incorporated in 

the project design features including post 

treatment spraying of landings in year 1 after 

mechanical treatment, and monitoring at years 

3 and 5, with retreatment if needed.

The Forest has an active weed treatment

program that will continue annual treatment of 

the known noxious weed infestations along 

roadways within the analysis area. 

Management requirements from the Forest 

Noxious Weed Treatment decision would be 

incorporated into any action alternative (USDA 

Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (3)
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# Topic Comment Response Alternative Issue # Or Category(Ies)

commercial logging and understory thinning; 

and prescribed burns. What open, gated, and 

decommissioned Forest Service roads within 

the project area proposed as haul routes 

have existent noxious weed populations and 

what methods would be used to assure that 

noxious weeds are not spread into the 

proposed action units?

4. What commitment to a long-term, 

consistent strategy of application is being 

proposed for each weed infested area within 

the proposed action area? What long term 

monitoring of weed populations is proposed?

What native plant restoration activities would 

be implemented in areas disturbed by the 

actions proposed in this project? Will 

disturbed areas including road corridors, skid 

trails, and burn units be planted or reseeded 

with native plant species?

5. Which units within the project area 

currently have no noxious weed populations 

within their boundaries? What minimum 

standards are in the Helena National Forest 

Plan to address noxious weed infestations? 

Please include an alternative in the DEIS that 

includes land management standards that will 

prevent new weed infestations by addressing 

the causes of weed infestation. The failure to 

include preventive standards violates NFMA 

because the Forest Service is not ensuring 

the protection of soils and native plant 

communities. Additionally, the omission of an 

EIS alternative that includes preventive 

measures would violate NEPA because the 

Forest Service would fail to consider a 

reasonable alternative.

29. Please disclose how the productivity of 

the land been affected in the project area and 

forestwide due to noxious weed infestations, 

and how that situation is expected to change 

in the coming years and decades.

Forest Service 2006).

Winter harvest, where used, could limit spread 

of weeds and reduce other impacts.

See also response to letter 5, comment 6 for 

effects to rare or sensitive plant species.

See the vegetation section in Chapter 3 of the 

DEIS regarding native forest species 

discussions.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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# Topic Comment Response Alternative Issue # Or Category(Ies)

5 Rare Plants 6. What threatened, endangered, rare and 

sensitive plant species and habitat are 

located within the proposed project area? 

What standards would be used to protect 

threatened, rare, sensitive and culturally 

important plant species and their habitats 

from the management actions proposed in 

this project? Describe the potential direct and 

indirect effect of the proposed management 

actions on rare plants and their habitat. Will 

prescribed burning occur in the spring and 

early summer; please give justifications for 

this decision using current scientific studies 

as reference.

The botany Biological Evaluation (BE) will 

discuss the known information on rare and 

sensitive plant species habitat and analyze the 

effects to known sensitive plant species habitat 

within the project area. The botany BE would 

be incorporated by reference and summarized 

in Chapter 3 of the DEIS. If sensitive plant 

populations are located within the project area,

appropriate mitigation (e.g., site avoidance) 

would be followed upon consultation with a 

Forest Service botanist.

Prescribed burning effects would be analyzed 

and disclosed in the specialist’s report and 

summarized in Chapter 3 of the DEIS. The 

majority of the burns would occur in the fall. 

We would avoid known locations of rare and 

sensitive plants if burns occur during spring 

and early summer. 

Nonsignificant 

issue (3)

5 Whitebark Pine 7. What surveys have been conducted to 

determine presence and abundance of 

whitebark pine regeneration? If whitebark 

pine seedlings and saplings are present, what 

measures would be taken to protect them? 

Please include an alternative that excludes 

burning in the presence of whitebark pine 

regeneration (consider ‘Daylighting’ seedlings 

and saplings as an alternative restoration 

method). Will restoration efforts include 

planting whitebark pine? Will planted seedling 

be of rust-resistant stock? Is rust resistant 

stock available? Would enough seedlings be 

planted to replace whitebark pine lost to fire 

activities? Have white pine blister rust 

surveys been accomplished? What is the 

severity of white pine blister rust in proposed 

action areas?

Whitebark pine in the project area is located 

within the roadless area. Survey information 

would be discussed and planting would be

evaluated in the Silviculture Report and 

discussed in the vegetation section of Chapter 

3 of the DEIS. 

The project design features would include 

hand slashing around whitebark pine seed 

trees to protect existing seed sources. This 

practice has been used and found effective in 

the Alice Creek project area to maintain 

mature whitebark pine seed sources (J.Kurtz, 

personal communication). 

An alternative that excludes burning in the 

presence of whitebark pine regeneration was 

considered. This alternative was dropped from 

detailed analysis since the locations of all 

whitebark pine regeneration are not known, 

and may occur in small, isolated, scattered 

spots. Therefore, avoiding all whitebark pine 

regeneration areas would not be feasible. This 

alternative would not address the purpose and 

need element to Improve the mix of vegetation 

Nonsignificant 

issue (2,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

composition and structure across the 

landscape that is diverse, resilient, and 

sustainable to wildfire and insects. Health and 

resiliency of whitebark pine would be 

discussed in the Silviculture Report in the 

project record and briefed in Chapter 3 of the 

DEIS. 

The no action alternative also addresses no 

burning in the presence of whitebark pine 

regeneration.

5 Safety

Map Fuels and 

Fire Risk

8. Since the project’s goals are to reduce the 

chances that fire will destroy private 

structures, and harm people, the current 

fuel/fire hazard situation on land of all 

ownerships within the WUI (at least the WUI 

that’s relevant to this area) must be displayed 

on a map. More importantly, the fuel/fire 

hazard situation post-project on land of all 

ownerships within the WUI must also be 

displayed on a map. Based on this mapping 

of current and projected conditions, please 

accurately disclose the threats to private 

structures and people under those scenarios, 

for all alternatives. It must be discernable why 

some areas are included for treatment and 

others are not.

9. The FS must have a detailed long-term 

program for maintaining the allegedly safer 

conditions, including how areas would be

treated in the future following proposed 

treatments, or how areas not needing 

treatment now would be treated as the need 

arises. The public at large and private 

landowners must know what the scale of the 

long-term efforts must be, including the 

amount of funding necessary, and the 

likelihood based on realistic funding 

scenarios for such a program to be 

adequately and timely funded.

The FS must assess the fuel and fire risk 

situation across land ownership boundaries to 

Historic fire information was considered. 

Potential effects to private land and structures 

would be considered in cumulative analysis for 

crown fire potential.

Developing a detailed long-term program for 

maintaining the safer conditions, including how 

areas would be treated in the future following 

proposed treatments, or how areas not 

needing treatment now would be treated as 

the need arises is outside the scope of our 

analysis. The long-term program at the 

landscape scale is provided in the Forest Plan, 

SW crown, Blackfoot landscape assessment, 

CWPP or other broad-scale analyses. 

See also response to letter 3, comment 3 

regarding analysis that would be included in 

the fire/fuels report and in Chapter 3 of the 

DEIS.

Nonsignificant 

issue (1,3)
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26

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# Topic Comment Response Alternative Issue # Or Category(Ies)

understand, and disclose to the public, the 

likely fire scenarios across the area’s 

landscape. Only then can the context of your 

proposal be adequately weighed on its merits 

and evaluated on its merits.

5 Thinning and 

Fire spread

10. Please consider that thinning can result in 

faster fire spread than in the unthinned stand. 

Graham, et al., 1999a.

11. Since the scientific literature suggests 

that your thinning activities will actually 

increase the rate of fire spread, you need to 

reconcile such findings with the contradictory 

assumptions expressed in your scoping letter.

Slash from thinning may be more susceptible 

to faster fire spread; however, this activity 

created fuels would be treated reducing this 

concern to levels of little risk. See response to 

letter 3, comment 3 regarding analysis of 

fire/fuels. Fuels discussion would be discussed 

in Chapter 3 of the DEIS regarding effects of 

the proposed actions, including treatment of 

activity created fuels.

See response to Letter 3, comment 1 

pertaining to literature review.

Nonsignificant 

issue (3)

5 Old Growth 

associated 

wildlife species

12. The FS must disclose its transparent, well 

thought-out long-term strategy for old-growth 

associated wildlife species viability in a 

properly-defined cumulative effects analysis 

area.

Old growth management indicator species 

include pileated woodpecker, northern 

goshawk, and hairy woodpecker. Hairy 

woodpeckers are also a snag-associated

species. Effects to old-growth associated 

species, including long-term habitat availability 

and anticipated effects to local viability would 

be analyzed in the wildlife report and biological 

assessment and discussed in the wildlife 

section of Chapter 3 of the DEIS. Both 

temporal and spatial analysis boundaries, 

would be clearly defined for each resource 

area in their methodology sections and 

cumulative effects would be disclosed in the 

specialist’s reports and discussed in Chapter 3

of the DEIS. 

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

5 Old Growth 

associated 

wildlife species

Flammulated 

Owl

18. Please demonstrate that this project will 

leave enough snags to follow the Forest Plan 

requirements and the requirements of 

sensitive old growth species such as 

flammulated owls and goshawks. Loggers are 

required to follow OSHA safety standards. 

Will these standards require snags to be cut 

down? After snags are cut down for safety for 

OSHA requirements will there still be enough 

Snag retention and recruitment would be

considered in the analysis and discussed in 

the wildlife report, biological assessment and 

biological evaluation and in the wildlife section 

of Chapter 3 in the DEIS. While snags that 

pose a safety risk would be removed as 

suggested, a number of project design 

features are in place to ensure that adequate 

snags (both size and amount) are retained to 

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

Significant 

issue #1
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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# Topic Comment Response Alternative Issue # Or Category(Ies)

snags left for old growth sensitive species?

Specifically how will the Stonewall Project 

affect Flammulated owls, cavity-nesters 

usually associated with mature stands of 

ponderosa pine and Douglas-fir?

19. What surveys has the HNF specifically 

designed to detect flammulated owls?

meet the needs of wildlife, including old growth 

dependent species. In addition, not all acres 

are being treated. 

All completed surveys and data collected are 

addressed in Chapter 3 of the DEIS.

Coordinated flammulated owl surveys were 

conducted to protocol across various portions 

of the Forest in 2005, 2008, and 2009 as part 

of the Northern Region Landbird Monitoring 

Program. 

would be 

discussed in the 

DEIS.

5 Cumulative 

Effects-Past 

Management 

Actions

13. Even though ecological restoration is not 

the project’s priority, the NEPA document 

must at least identify all the existing 

ecological liabilities caused by past 

management actions. This includes poorly 

located or poorly maintained roads, high-risk 

fuel situations caused by earlier vegetation 

manipulation projects, wildlife security 

problems by open motorized roads and trails

plus those that are closed but violated—and 

include all those impacts in the analyses.

Cumulative effects analyses considered 

effects from past present foreseeable future 

actions within and adjacent to the project area. 

Baseline/existing conditions discussed in 

Chapter 3 of the DEIS and in the Wildlife 

Report reflect the outcomes of past actions, 

including effects of roads on elk security. A

listing of the known past, present, and 

foreseeable future projects that may contribute 

effects when considered with this project

would be included in the DEIS.

See response to letter 66, comments 15, 16 

and 17 regarding snags.

Nonsignificant 

issue (3)

5 Roads in WUI 14. Any desire to keep a road in the project 

area WUI must be in harmony with the 

alleged priority goals (again, to reduce the 

chances that fire will destroy private 

structures and harm people), not driven by 

timber production goals. The analysis must 

show how all roads will in fact be in harmony 

with the priority goals.

This project does not include changing 

National Forest System roads. 

The Forest is currently analyzing two travel 

management planning processes; Blackfoot 

Winter Travel and Blackfoot Travel Plan (nonwinter). Motorized vehicle use and route 

designations for the permanent Helena 

National Forest System roads would be

addressed in this ongoing analysis and 

documented in the final decisions issued for 

the travel management plans. Travel 

management is outside the scope of this 

analysis but where appropriate would be 

addressed in cumulative effects.

Nonsignificant 

issue (1)

5 Fuels 

Reduction

15. Proposed activities could artificialize the 

forest ecosystem. Lodgepole pine is 

particularly subject to blowdown, once 

The project design features would include 

retaining adequate snags and down woody 

debris to meet Forest Plan direction.

Nonsignificant 

issue (3)
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# Topic Comment Response Alternative Issue # Or Category(Ies)

thinned. And any forest condition that is 

maintained through mechanical manipulation 

is not maintaining ecosystem function The 

proposed management activities would not 

be integrated well with the processes that 

naturally shaped the ecosystem and resulted 

in a range of natural structural conditions. 

Thus, [there is a] need for standards guiding 

both the delineation of zones where 

artificializing fuel reduction actions may take 

place, and that also set snag and down 

woody debris retention amounts.

Effects to fuels and the related analysis would 

be discussed in the relative specialist’s reports 

and summarized Chapter 3 of the DEIS.

Proposed activities were designed to allow 

natural ecosystems to function while providing 

resource protection.

The Tri County Community Wildfire Protection 

Plan defines WUI boundary as area within 4 

miles from communities that possesses a 

population density exceeding 250 people per 

square mile.

5 Fire Policy 16. Since disruption of fire cycles is identified, 

the HNF needs to take a hard look at its fire 

policies. Continued mismanagement of 

national forest lands and FS refusal to fully 

implement the Fire Policy puts wildland 

firefighters at risk if and when they are 

dispatched to wildfires. This is a 

programmatic issue, one that the current 

Forest Plan does not adequately consider. 

Please see Ament (1997) as comments on 

this proposal, in terms of fire policy and 

Forest Planning.

This is a programmatic Forest-level issue 

addressed by the annually updated Forest 

Plan Fire Management Plan. Forest fire policy 

is outside the scope of this analysis. 

The literature review includes a review of 

Ament (1997). 

Nonsignificant 

issue (1)

5 Monitoring 17. For every project proposal, it is important 

that the results of past monitoring be 

incorporated into planning. All 

Interdisciplinary Team Members should be 

familiar with the results of all past monitoring 

pertinent to the project area, and any 

deficiencies of monitoring that have been 

previously committed to. For that reason, we 

expect that the following be included in the 

NEPA documents or project files:

• A list of all past projects (completed or 

ongoing) implemented in the proposed 

project area watersheds.

• The results of all monitoring done in the 

project area as committed to in the NEPA 

documents of those past projects.

• The results of all monitoring done in the 

Existing monitoring information is being 

compiled and would be considered with the 

existing condition for various resources. 

Project related monitoring is identified and 

would be included in Chapter 2 of the DEIS. 

Ongoing forest-level monitoring would 

continue. 

The DEIS will include a list of the known past, 

present, and foreseeable future projects that 

may contribute effects when considered with 

this project.

The direction in the Forestwide Noxious Weed 

EIS (USDA Forest Service 2006)would be 

incorporated 

Monitoring for weed treatments would be 

disclosed in Chapter 3 of the DEIS, and in the 

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

proposed project area as a part of the Forest 

Plan monitoring and evaluation effort.

• A description of any monitoring, specified in 

those past project NEPA documents or the 

Forest Plan for proposed project area, which 

has yet to be gathered and/or reported.

Please disclose the names of all other past 

projects (implemented during the life of the 

Forest Plan) whose analysis area(s) 

encompass the areas to be “treated” under 

this proposal. Please disclose if the FS has 

performed all of the monitoring and mitigation 

required or recommended in any NEPA 

documents, and the results of the monitoring.

31. Please disclose the results monitoring of 

weed treatments on the HNF that have been 

projected to significantly reduce noxious 

weed populations over time, or prevent 

spread. This is an ongoing issue of land 

productivity.

specialist’s weed report.

5 Viable 

populations

20. The FS should firmly establish that the 

species that exist, or historically are believed 

to have been present in the analysis area are 

still part of viable populations. Since Forest 

Plan monitoring efforts have failed in this 

regard, it must be a priority for project 

analyses. Identification of viable populations 

is something that must be done at a specific 

geographic scale. The analysis must cover a 

large enough area to include a cumulative 

effects analysis area that would include truly 

viable populations. Analysis must identify 

viable populations of MIS, TES, at-risk, focal, 

and demand species of which the individuals 

in the analysis area are members in order to 

sustain viable populations.

The wildlife report would include analysis of 

species most at risk including: threatened, 

endangered, sensitive, management indicator 

species, changes in related habitat distribution 

and use from the specific impacts from the 

proposed activities, and how the project area 

contributes to species viability when 

considered with other past, present and 

foreseeable actions.

Overall, viable populations are evaluated at 

the Forest or Regional levels, and are outside 

the scope of this analysis.

Nonsignificant 

issue (1, 3)

5 Old-growth 21. Please disclose how stands to be treated 

compare to Forest Plan or Regional oldgrowth criteria. In order to disclose such 

information, please provide all the details, in 

plain language, of these areas’ forest 

Effects to old growth would be analyzed in the 

specialist’s reports and summarized in Chapter 

3 of the DEIS.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

Significant 

issue #1
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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

characteristics (the various tree components’ 

species, age and diameter of the various tree 

components, canopy closure, snag density by 

size class, amounts of down logs, understory 

composition, etc.).

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

5 ESA, TES, 

MIS

22. Please examine how this project could 

affect grizzly bears, lynx and other species 

listed under the Endangered Species Act. Are 

you complying with lynx critical habitat 

requirements? Please examine how this 

project will affect all MIS and sensitive 

species.

ESA compliance, including Section 7 

consultation with the USFWS would be

completed prior to the decision. Anticipated 

effects on federally listed species would be

discussed in detail in the project Biological 

Assessment and summarized in Chapter 3 of 

the DEIS.

The wildlife report will analyze effects to MIS 

and the Biological Evaluation will evaluate 

effects to sensitive species. These reports 

would be incorporated by reference and a 

summary of the analyses would be included in 

Chapter 3 of the DEIS.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

5 Roadless Area 

boundaries 

and 

Wilderness 

designation

24. Please utilize the NEPA process to clarify 

any roadless boundary issues

25. Please examine if these unroaded areas 

adjacent to roadless areas have wilderness 

qualities.

Inventory and evaluation of roadless areas 

takes place at the Forest Plan level. Unroaded 

areas adjacent to IRAs that overlap with 

proposed treatment areas will be evaluated for 

potential impacts to their roadless and 

wilderness characteristics.

Nonsignificant 

issue (1)

5 fisheries, water 

quality, soil, 

bull trout

23. We request the FS design a 

restoration/access management plan for 

project area streams that will achieve 

recovery goals.

26. We request a careful analysis of the 

impacts to fisheries and water quality, 

including considerations of sedimentation, 

increases in peak flow, channel stability, risk 

of rain-on-snow events, and increases in 

stream water temperature. Please disclose 

the locations of seeps, springs, bogs and 

other sensitive wet areas, and the effects on 

these areas of the project activities. Where 

livestock are permitted to graze, we ask that 

c23: Designing a restoration/access 

management plan is beyond the scope of this 

analysis. See response to letter 5 comment 14 

regarding travel management. 

c26, 27, 28, 30: An intricate part of this 

proposal is the caring for the transportation 

system needed to implement this project. 

Proper maintenance and mitigation would be 

applied. Effects on fish, water and soils would 

be analyzed, incorporated by reference and 

summarized in Chapter 3 in the DEIS. Past 

actions would be reviewed during the 

evaluation of the existing conditions and 

cumulative effects analyses. The proper 

Nonsignificant 

issue (1,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

you assess the present condition and 

continue to monitor the impacts of grazing 

activities upon vegetation diversity, soil 

compaction, stream bank stability and 

subsequent sedimentation. This watershed 

has been proposed as bull trout critical 

habitat. Will you meet the requirements of bull 

trout critical habitat?

27. Please disclose in the NEPA document 

the results of up-to-date monitoring of fish 

habitat and watershed conditions and how 

this project will affect the fish in the project 

area.

28. It is extremely important the FS disclose 

the environmental baseline for watersheds.

Therefore, proper disclosure of baseline 

conditions would mean estimates of stream 

stability, pool frequency conditions, and water 

temperature range—essentially the values of 

Riparian Management Objectives along with 

such parameters as sediment levels.

30. Please provide estimates of current 

detrimental disturbance in all previously 

established activity areas in the watersheds 

affected by the proposal.

Please disclose the link between current and 

cumulative soil disturbance in project area 

watersheds to the current and cumulative 

impacts on water quantity and quality. Please 

disclose if there are any WQLS streams or 

TMDL streams in the project area.

Please disclose measures of, or provide 

scientifically sound estimates of, detrimental 

soil disturbance or soil productivity losses 

(erosion, compaction, displacement, noxious 

weed spread) attributable to offroad vehicle 

use.

32. Please disclose how the proposed 

“treatments” would be consistent with 

Graham, et al., 1994 recommendations for 

fine and coarse woody debris, a necessary 

measures and indicators would be evaluated 

that may be impacted from this proposal. The 

methodology and assumptions sections in the 

specialist’s reports will evaluate and display 

what would be analyzed.

c32: Project design features would incorporate 

meeting Forest Plan standards for down 

woody material; Chapter 2 of the DEIS will list 

the design features developed for this project; 

Chapter 3 of the DEIS and the soils specialist’s 

report will evaluate and display the effects to 

soil productivity. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

consideration for sustaining long-term soil 

productivity.

5 Carbon 

Storage and 

Climate 

Change

33. Published scientific reports indicate that 

climate change would be exacerbated by 

logging due to the loss of carbon storage. 

Additionally, published scientific reports 

indicate that climate change will lead to 

increased wildfire severity (including drier and 

warmer conditions that may render obsolete 

the proposed effects of the Project). The 

former indicates that the Stonewall 

Vegetation Project may have a significant 

adverse effect on the environment, and the 

latter undermines the central underlying 

purpose of the Project. Therefore, the Forest 

Service must candidly disclose, consider, and 

fully discuss the published scientific papers 

discussing climate change in these two 

contexts. At least the Forest Service should 

discuss the attached following studies:

• Depro, Brooks M., Brian C. Murray, Ralph J. 

Alig, and Alyssa Shanks. 2008. Public land, 

timber harvests, and climate mitigation: 

quantifying carbon sequestration potential on 

U.S. public timberlands. Forest Ecology and 

Management 255: 1122-1134.

• Harmon, Mark E. 2001. Carbon 

sequestration in forests: addressing the scale 

question. Journal of Forestry 99:4: 24-29.

• Harmon, Mark E, William K. Ferrell, and 

Jerry F. Franklin. 1990. Effects of carbon 

storage of conversion of old-growth forest to 

young forests. Science 247: 4943: 699-702

• Harmon, Mark E, and Barbara Marks. 2002. 

Effects of silvicultural practices on carbon 

stores in Douglas-fir – western hemlock 

forests in the Pacific Northwest, USA: results 

from a simulation model. Canadian Journal of 

Forest Research 32: 863-877.

• Homann, Peter S., Mark Harmon, Suzanne 

Remillard, and Erica A.H. Smithwick. 2005. 

Effects of the proposed action and alternatives 

to atmospheric carbon storage and release 

would be discussed in the relevant specialist’s 

reports with information to be summarized in 

Chapter 3 of the DEIS.

The effects of a changing climate to current 

and future conditions of the Helena National 

Forest are considered and addressed through 

project objectives and design. See EIS 

Chapter 1 sections titled “Purpose and Need 

for Action” and “Proposed Action;” also, 

“Silviculture Report—Stonewall Desired 

Condition” (Amell 2012) in the project record.

See also, response to letter 3 comment 1 

regarding the review of submitted literature.

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

What the soil reveals: potential total 

ecosystem C stores of the Pacific Northwest 

region, USA. Forest Ecology and 

Management 220: 270-283.

• McKenzie, Donald, Ze’ev Gedalof, David L. 

Peterson, and Philip Mote. 2004. Climatic 

change, wildfire, and conservation. 

Conservation Biology 18:4: 890 -902.

5 Costs and 

Benefits

34. Please evaluate all of the costs and 

benefits of this project. Please include a 

detailed list of all the costs to the agency and 

the public.

An incremental economic analysis would be 

completed and detailed listing of cost factors 

considered would be in the report. This 

analysis would be incorporated by reference 

and summarized in Chapter 3 of the DEIS. The 

specialist reports would be available upon 

request and filed in the project record. A 

summary of economic analysis, including 

financial efficiency would be included in 

Chapter 3 of the DEIS.

Nonsignificant 

issue (3)

5 Literature 

Review

35. It is our intention that you include in the 

record and review all of the literature and 

other incorporated documents we’ve cited 

herein. Please contact us if you have 

problems locating copies of any of them.

See response to letter 3 comment 1 regarding 

the review of submitted literature.

Nonsignificant 

issue (3)

6 Noxious 

Weeds

1. Noxious Weed management plan-per 

harvest or work activities and post 

management plan

See response to letter 5 comments 2,3,4,5 and 

29 regarding noxious weeds.

Nonsignificant 

issue (3)

7 Noxious 

Weeds

1. Weed management when road is 

obliterated

See response to letter 5 comments 2,3,4,5 and 

29 regarding noxious weeds.

Nonsignificant 

issue (3)

7 Noxious 

Weeds

2. Weed management where all the landings 

are

See response to letter 5 comments 2,3,4,5 and 

29 regarding noxious weeds.

Nonsignificant 

issue (3)

8 1. I would like to be kept informed of any 

clubs, groups, and organizations etc. that 

oppose this project.

Table 1 under this section includes a listing of 

the individuals, clubs, groups, organizations 

and agencies that responded to scoping. This 

table lists the contents of the comments 

received.

Nonsignificant 

issue (1)

9 Timing of the 

Project 

1. When would this start and is there a 

proposed completion date for the gulch area?

Implementation of the project would occur after 

the decision. 

Nonsignificant 

issue (1)

9 2. The area on the east side of the Lincoln The area noted is included in the proposed Nonsignificant 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

34

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Gulch Road going north toward the cemetery 

is in dire need of “cleaning up” underbrush, 

deadfalls, and beetle killed trees. The area 

starts at the Forest Line (cattle guard) on 

Lincoln Gulch Roads and proceeds towards 

the cemetery. 

action (unit 12) for a regeneration harvest with 

fuels treatments following activities. The 

Lincoln Gulch Road is included in the Hazard 

Tree removal decision (August 23, 2010)

issue (3)

11 Support for the 

project

1. ...I support the effort the Forest Service is 

(?) to (?) and effectively improve the health 

and vitality of the forest

Thank you for your support Nonsignificant 

issue (4)

14 Support for the 

Project

1. Overall I feel that the proposed action is 

sound and should be carried out

Thank you for your support. Nonsignificant 

issue (4)

14 Wildlife, cavity 

nesters

2. The final plan should recognize that not all 

dead trees should be harvested. A sufficient 

number of “wildlife” trees should be left 

standing for cavity nesting species

Forest plan snag requirements would be met 

on treated areas and additional snag habitat 

would be provided throughout the project area 

in untreated areas. Snags would be discussed 

in the wildlife report and the wildlife section of 

Chapter 3 of the DEIS.

A potential 

alternative 3 was 

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

14 Roadless 3. Post-treatment action should guarantee 

that motorized vehicle use does not increase 

in roadless areas

No harvest is identified in roadless areas. 

Stand density may be reduced through 

prescribed fire in the roadless areas.

A project design feature would be included to 

obliterate the appearance of fire control lines 

adjacent to or that intersect existing trails, if 

warranted, to reduce the potential for 

unauthorized motorized use. 

The Forest is completing a travel management 

planning process for winter and non-winter 

travel. Motorized vehicle use would be

addressed in this ongoing analysis.

Unauthorized motorized vehicle use in 

roadless areas is a law enforcement issue and 

outside the scope of this analysis.

Nonsignificant 

issue (1,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

35

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

15 Support for the 

Project

1. It is good to move forward with this Thank you for your support. Nonsignificant 

issue (4)

15 Treatments 2. The scale of the project should be enlarged 

(i.e., treat more acres)

Chapter 2 of the DEIS will include a 

discussions of the alternatives considered in 

detail and alternatives considered but 

eliminated from detailed analysis.

Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (3)

16 Streams and 

Watersheds

1. When the proposed action is implemented, 

special care needs to be taken to protect 

streams/watersheds.

Project design features and BMPs would be 

incorporated to provide protection of streams 

and watersheds.

Nonsignificant 

issue (3)

16 Support for the 

Project

2. Good job, well presented, hope it soon 

gets implemented

Thank you for your support. Nonsignificant 

issue (4)

17 Support for the 

Project

1. We need more projects like this one Thank you for your support. Nonsignificant 

issue (4)

19 Support for the 

Project

1. Good job putting this together Thank you for your support. Nonsignificant 

issue (4)

21 Support for the 

Project

1. Just wish there wasn’t so much red tape 

and it could start immediately

Thank you for your support. Nonsignificant 

issue (4)

21 Jobs 2. Will there be jobs available? Various portions of the project may be 

implemented through various methods (e.g., 

stewardship contract, timber sale, in-house 

staff). An analysis would be completed to 

address EO 12898 and the accompanying 

Presidential Memo regarding “Environmental 

Justice", which may include possible jobs on 

minorities, etc. This information would be 

discussed in Chapter 3. 

Nonsignificant 

issue (3)

22 Support for the 

Project

1. We strongly support the proposed actions. Thank you for your support. Nonsignificant 

issue (4)

22 Prescribed fire 2. Our only concern is the use of fire. We are 

not opposed to that but we feel the use of fire 

is going to require a major educational effort 

before it is acceptable to many of the 

residents.

Information sharing regarding use of 

prescribed fire and development of burn plans 

is ongoing and would continue on the district.

Nonsignificant 

issue (3)
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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

26 Motorized 

Recreation 

Opportunities

1. Adequate recreational opportunity for all 

visitors is the supreme issue that must be 

addressed by this action.

2. Clearly, the public wants and needs 

adequate recreational opportunity and this 

should be the over-arching theme of this 

evaluation and decision.

3. Reasonable alternatives to motorized 

closures must be pursued. The continual loss 

of motorized recreational opportunities is our 

primary concern. Because of the significant 

cumulative effect of motorized closures at this 

point in time, we feel strongly that there can 

be “no net loss” of motorized recreational 

opportunities with the Stonewall Fuel Control 

Project. We would ask that this project 

address the attached checklist of issues and 

address the goals and needs identified.

4. We ask that management for sharing of 

these lands for multiple-use be selected as 

the preferred alternative. Sharing would 

include a 50/50 sharing and equal opportunity 

of non-motorized to motorized trails.

5. It seems that both the BLM and Forest 

Service are using forest planning and travel 

management planning as an opportunity to 

close as many motorized recreational 

opportunities as fast as possible. We are 

asking that this project establish a baseline 

evaluation and address this significant impact

6. ...we strongly recommend and support the 

development of a Pro-Recreation Alternative.

would include the following characteristics...: 

 1. Dispersed camping within 300 feet of all 

existing routes.

 2. Use of seasonal closures, where 

required, to protect the environment and 

wildlife with the intention of keeping routes 

open for the summer recreation season.

 3. All of the existing routes are needed as 

The Forest is completing two travel 

management planning processes, ‘Blackfoot –

North Divide Winter Travel Planning’ and 

‘Blackfoot Travel Plan (non-winter)’. Motorized 

vehicle use and route designations for the 

permanent Forest System roads would be

addressed in those ongoing analysis and 

documented in the final decisions issued for 

the travel management plans. Travel 

management is outside the scope of this 

analysis and does not address the purpose 

and need for this project.(Items 3, 4, 5 & 6).

Effects of this project on recreation would be

addressed in the Recreation Report and 

summarized in Chapter 3 of the DEIS. (items 

1-2)

Recreation resources would be addressed in 

the analysis and project design features would 

be included to minimize potential impacts to 

recreation within the project area (item 6). 

The attachment provides information 

pertaining to motorized vehicle use trends and 

discussion of allocations between motorized 

and non-motorized uses. This information is 

applicable to the travel management planning 

process, but since no changes to the forest 

transportation system or its use, is proposed 

for this project, it is outside the scope of this 

analysis but similar concerns are being 

addressed in both of the Blackfoot Travel 

Plans.

Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (1,2,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

OHV routes due to the cumulative effects of 

all other closures.

 4. Additional OHV routes are needed to 

address the growing popularity of OHV 

recreation and the greater needs of the public 

for access and motorized recreation...

Attachment: “Information and Issues that 

Support a Pro Motorized Recreation 

Alternative” January 24, 2010.

7. Overall, we are extremely concerned about 

the unequal allocation of trail resources and 

we do not see anything that justifies the 

current imbalance with only 42% motorized 

trails. The facts presented in our comments 

clearly supports a motorized trail allocation of 

50% or greater.

27 Motorized 

Recreation 

Opportunities

1. Our first concern is that no existing 

motorized roads and trails should be closed 

as part of the proposed action.

2. Our second concern is that this area is 

ideal for motorized, multiple-use recreation. 

To adequately address this issue, we request 

that an alternative be considered that would 

provide new OHV routes in the area beyond 

those currently existing.

See response to letter 26, comments 1 to 7. Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS..

Nonsignificant 

issue (1)

28 Camping 1. I hope this includes some consideration for 

camping sites

A project design feature would be included to 

prioritize treatments adjacent to the Pine 

Grove campground and trailheads within the 

project area to avoid high use time periods and 

limit the time these areas may be closed to the 

public.

Project design features would be included to 

coordinate project implementation and haul 

routes with recreation staff to minimize impacts 

to popular dispersed recreation areas and high 

use time periods (i.e.: fall hunting season), and 

to ensure that the public is aware of the 

scheduled projects.

Effects of this project on recreation would be 

analyzed in the recreation report, incorporated 

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

38

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

by reference, and summarized in Chapter 3 of 

the DEIS. 

28 Support for the 

Project

2. I really appreciate and support your efforts Thank you for your support. Nonsignificant 

issue (4)

29 Support for the 

Project

1. We like the proposal. We are private 

landowners in Lincoln Springs Subdivision, 

and are interested in fuel reduction in the 

area.

Thank you for your support. Nonsignificant 

issue (4)

31 Archaeological 

Resources

1. As an archaeologist I am strongly 

concerned about the possibility of the 

disturbance/destruction of archaeological 

resources while completing this project. From 

what I can discern from studying the map on 

the website at least part of the area in which 

the primary townsite of old Lincoln is situated 

will not have actions performed there. 

However that area is highly covered with thick 

brush and blow downs. In order to be able to 

properly document and preserve historic 

remains in this area these need to be 

removed; but with as little actual ground 

disturbance as possible.

3. In addition to the protection of the Old 

Lincoln townsite those conducting this 

operation need to be aware of other 

undocumented historical remains throughout 

the entire project area; but especially around 

the old cemetery area and between Moon 

Lane and the Lincoln Springs Subdivision. A 

high chance of encountering cultural remains 

also exists on the west side of Lone Point 

before Moon Lane.

4. An archaeologist should regularly inspect 

work when the ground is disturbed in order to 

minimize destruction of resources.

Effects to cultural resources would be 

analyzed and appropriate protection measure 

(e.g. avoidance) would be followed.

The Forest archaeologist would visit known 

sites, including the Historic Lincoln Townsite, 

and identify appropriate project design 

features for inclusion in Chapter 2 of the DEIS.

Project design features would include 

protection of existing and newly discovered 

heritage sites, along with appropriate 

monitoring and would be listed in Chapter 2 in 

the DEIS.

Nonsignificant 

issue (3)

31 Support for the 

Project

2. Overall the project appears to be well 

planned and is extremely overdue.

Thank you for your support. Nonsignificant 

issue (4)

32 Support for the 

Project

1. I appreciate the Lincoln District moving 

forward on any management proposal that 

Thank you for your support. Nonsignificant 

issue (4)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

39

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

includes timber harvest – dead or alive.

32 General 

Project Design

2. I would like to voice my concern that the 

NEPA process for this project seemed to go 

by the wayside. I saw no announced dates or 

comments about NEPA.

The notice of intent to prepare an 

environmental impact statement for the 

Stonewall Vegetation Project was published in 

the Federal Register on January 13, 2010. 

Scoping documents for this project were 

mailed to known interested and affected 

parties on January 15, 2010. The scoping 

documents were also available on the forest 

website. A press release was issued January 

16, 2010 that announced a public meeting on 

February 3, 2010 and noted the deadline for 

comments was February 16, 2010. 

The Stonewall Vegetation Project has been 

listed on the Forest’s schedule of proposed 

actions since April 2010.

Public involvement efforts would be disclosed 

and discussed in Chapter 1 of the DEIS.

Nonsignificant 

issue (3)

32 Multiple Use 3. Represent multiple use in an adequate 

solution for the project

The purpose and need for this project was 

developed to address fuels and restoration 

concerns and address the gap between the 

existing conditions and the desired conditions 

of the vegetation in the project area.

Specialists for various resources reviewed the 

Forest Plan goals and objectives and 

developed actions to address the purpose and 

need for this project. Effects to the various 

resources would be disclosed in Chapter 3 in 

the DEIS.

Nonsignificant 

issue (2,3)

32 Roads 4. The roads established for the project 

should remain open for recreation, fire 

suppression, etc.

Changes to the permanent forest 

transportation system are not proposed with 

this project. See response to letter 5, comment 

14.

Nonsignificant 

issue (1,3)

33 Ground 

Disturbance

1. Heavy equipment operations should be 

conducted at a time that minimizes ground 

disturbance – frozen and/or snow.

2. Seed disturbances (roads, skid roads, burn 

piles with a cheatgrass and noxious weed 

free NATIVE GRASS/FORB mix. No fertilizer 

(native plants won’t need it)

Winter operations are an option, and may 

reduce impacts to soils and related resources. 

These concerns would be addressed in the 

Soils Specialist’s Report and summarized in 

Chapter 3 of the DEIS.

Seeding would be done with approved seed 

mixes as noted in the Forest Plan.

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

40

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

33 Economics 3. All sales should be conducted with a “no 

net loss” to the taxpayer.

An incremental economic analysis would be 

completed and results disclosed in Chapter 3 

of the DEIS. 

Nonsignificant 

issue (3)

33 Prescribed 

Burning

Support

4. Conduct as much control/prescribed 

burning as possible, no mimic natural 

processes.

Thank you for your support of prescribed 

burning.

Nonsignificant 

issue (4)

33 Motorized use 5. Consider how you are going to limit offroad and off-trail O.R.V. use once the forest 

is “opened up.”

Effects of ORV use would be discussed in 

Chapter 3 of the DEIS and in the specialist’s 

Recreation Report.

The Forest is completing a travel management 

planning process for winter and non-winter 

travel. Motorized vehicle use would be 

addressed in those ongoing analysis. 

Unauthorized off-road motorized vehicle use is 

a law enforcement issue and an ongoing 

concern for the Forest.

Nonsignificant 

issue (3)

34 Mountain Pine 

Beetle

1. It’s too bad about the Mountain Pine 

Beetle. The Western larch is a beautiful tree. 

Its number should be increased.

Any regeneration activities planned would 

consider appropriate species mix, including 

western larch to move toward the desired 

conditions.

Nonsignificant 

issue (2,3)

34 Prescribed 

Burning

Support

2. I like burning slash piles and prescribed 

burning.

Thank you for your support Nonsignificant 

issue (4)

35 Mountain Pine 

Beetle

1. What are the time periods, how long to do 

these projects, could they continue as the 

beetle-kill continues on?

Project activities would be anticipated to be 

completed within a ten year time period. Other

areas affected by beetle-kill would be analyzed 

separately.

Nonsignificant 

issue (3)

36 Roadless 1. You can’t mine it, log it, farm it, ride on it, 

so yes, burn it.

Comment noted. Support for fire. Nonsignificant 

issue (4)

37 Support for the 

Project

1. I support the actions proposed in the 

Stonewall Vegetation Project

Thank you for your support Nonsignificant 

issue (4)

38 Motorized 

Recreation 

Opportunities

1. Our first concern is that no existing 

motorized roads and trails should be closed 

as part of the proposed action.

2. Our second concern is that this area is 

ideal for motorized, multiple-use recreation. 

To adequately address this issue, we request 

that an alternative be considered that would 

See response to letter 26, comments 1 to 7. Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

Nonsignificant 

issue (1,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

41

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

provide new OHV routes in the area beyond 

those currently existing.

DEIS.

39 Motorized 

Recreation 

Opportunities

1. Our first concern is that no existing 

motorized roads and trails should be closed 

as part of the proposed action.

2. Our second concern is that this area is 

ideal for motorized, multiple-use recreation. 

To adequately address this issue, we request 

that an alternative be considered that would 

provide new OHV routes in the area beyond 

those currently existing.

See response to letter 26, comments 1 to 7. Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (1,3)

40 Motorized 

Recreation 

Opportunities

1. Our first concern is that no existing 

motorized road s and trails should be closed 

as part of the proposed action.

2. Our second concern is that this area is 

ideal for motorized, multiple-use recreation. 

To adequately address this issue, we request 

that an alternative be considered that would 

provide new OHV routes in the area beyond 

those currently existing.

See response to letter 26, comments 1 to 7. Alternative 

considered but 

eliminated from

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (1,3)

41 Firewood 1. Would it be open for firewood? Areas would be closed to firewood gathering 

during harvest implementation. Consistent with 

the forest plan, slash piles would be made 

available to the public prior to burning.

Nonsignificant 

issue (3)

43 Pine Beetle 

Restore 

diversified 

species

1. The proposed thinning and restoration 

makes perfect sense. Let us get the trees 

infested with the pine beetle out, to put in 

diversity only makes sense. Let’s get in there, 

thin out the diseased trees, plan for some 

viable species, and help our forests to once 

again regain their beauty for all to enjoy.

Thank you for your support. Nonsignificant 

issue (4)

45 Support for the 

Project

1. I agree with the proposal. Thank you for your support Nonsignificant 

issue (4)

45 Forest Health 2. As much wood as possible should be 

removed for the health of the forest.

Thank you for your support. Nonsignificant 

issue (4)

47 Support for the 

Project

1. Project sounds like a good plan Thank you for your support Nonsignificant 

issue (4)

48 Forest Health 1. I am not opposed to vegetation Thank you for your support. Nonsignificant 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

42

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

management in the project area but I want it 

to be driven by good resource management 

and within the direction of the Helena 

National forest Land use Plan and not fire 

hysteria.

issue (4)

48 Visuals 2. A landscape analyses should be 

completed to show the changes that would 

occur from the proposed actions.

3. A feathering of Timber harvest along the 

existing straight line harvested areas would 

benefit the existing visual condition. Property 

lines adjoining private in holdings, state and 

BLM lands should be considered for this type 

of timber harvest also.

Design features would be incorporated to 

reduce the appearance of lines to meet the 

visual quality objectives for units adjoining 

private in holdings, state and BLM lands would 

be displayed in Chapter 2 in the DEIS. Effects 

to the visual resources would be disclosed in 

Chapter 3 in the DEIS.

Nonsignificant 

issue (3)

48 Cultural 

Resources

4. Lincoln Historical town site and cemetery: 

These two historical sites are eligible for 

nomination to the registrar of historical sites; 

this process should be completed to insure 

that adequate management, monitoring and 

protection occur.

5. Immediate restrictions should be 

implemented to closes these two area to 

personal fire wood gathering.

6. Other cultural resources that need 

protection are lower and upper stonewall 

ditches, and Lincoln ditch from Reservoir 

Lake to Lincoln Gulch. This project area is 

rich with early mining history and a cultural

inventory is needed.

Project design features would be incorporated 

to provide appropriate protection for cultural 

resources.

Heritage surveys and anticipated effects to 

cultural resources would be discussed in 

Chapter 3 in the DEIS. 

Nonsignificant 

issue (3)

48 Grazing 7. An updated allotment plan would be need 

to reflect the changes to the grazing patterns 

associated with the proposed timber harvest.

Adaptive management practices may be 

incorporated as needed to address grazing 

patterns affected by the project, which may 

include measures such as herding or adjusting 

season of use. 

No changes to livestock grazing are proposed. 

The allotment management plan is outside the 

scope of this analysis.

Nonsignificant 

issue (1,3)

48 Prescribed 

Burning

8. The roadless areas within the project area 

were created by the Rare 2 process 

identifying possible additions to the 

Slashing is proposed in identified prescribed 

burn units to help achieve desired results (e.g. 

to help carry the fire across the unit) where 

Alternative 

considered but 

eliminated from 

Nonsignificant 

issue (2,3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

43

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Roadless 

Areas

wilderness system. Management should 

reflect this quality. Prescribed fire in these 

areas should be under a natural prescribed 

fire plan and no mechanical fuel treatment 

done in these areas.

On June 21, 2010 commenter J. Burns was 

contacted by J. Kurtz of the Forest Service, 

resulting in two points of clarification 

concerning “natural prescribed fire” and “no 

mechanical fuel treatment done in these 

areas”.

Natural prescribed fire is in reference to the 

fact that J. Burns would like to see the 

roadless area within the Stone Dry project 

area be treated similar to the wilderness, 

turned into a FMU-3 so the Forest Service 

can allow natural ignition to take place and 

managed for resource benefit.

Mechanical fuel treatment is in reference to 

not only mechanized equipment but also 

hand slashing in road less areas. J. Burns 

referenced the hand slashing work being 

done in Alice Creek and does not like what he 

sees. Also J. Burns does not want to see 

hand slashing with chainsaw around 

whitebark for whitebark restoration “the 

beetles will kill all of them anyway” 

adequate fuels may not currently exist on the 

ground. Hand slashing would also allow areas 

around individual mature whitebark pine trees 

to be cleared to encourage seedling 

establishment. Concentrations of whitebark 

pine regeneration may be protected through 

clearing of slash to reduce potential for fire 

caused mortality. The proposed hand slashing 

of small diameter trees within roadless areas 

will be evaluated for potential impacts to 

roadless and wilderness characteristics.

See response to letter 5, comment 7 regarding 

alternatives considered.

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

48 Thinning in 

past timber 

harvest areas

9. These areas are T-l lands to be managed 

for timber production. Pre commercial 

thinning was part of the silvicultural objectives 

for these areas, but was not done. With the 

timber maturity of these stands any thinning 

now should be commercial and the wood 

products removed used and not burned as 

slash. If no market exists the thinning should 

be postponed until a market for these types of 

products exist.

Meeting the stated purpose and need for the 

project, as well as stand characteristics such 

as tree species and size, may be used to 

determine whether the proposed treatments 

involve commercial thinning, pre-commercial 

thinning, or a combination of the two 

treatments. These assessments would be in 

the project record.

Nonsignificant 

issue (3)

48 Cumulative 

Effects

10. The effect of additional timber harvest

that has occurred and will occur on state and 

private lands bordering this project area 

should be considered in this analyzes. The 

Cumulative effects would be analyzed with the 

available information on past, present and 

reasonably foreseeable projects.

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

44

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Lincoln ranger district is also proposing a 

hazard tree removal along system forest 

roads, if this project occurs would this timber 

harvest be in addition to what is proposed in 

this project?

The decision was signed on August 23, 2010 

for the “Forest-wide Hazardous Tree Removal 

and Fuels Reduction- Healthy Forests 

Restoration Act Project.” This project is in 

addition to this proposal and would be 

considered in the cumulative effects analyses.

48 Recreation 11. A recreation activity that has increase in 

this area is personnel huckleberry picking 

how will the proposed actions effect 

huckleberry production, both for people and 

wildlife?

Recreation opportunities may be enhanced in 

the burn and harvest areas with a potential 

increase in huckleberry regeneration. The 

anticipated vegetative response to the 

proposed activities would be discussed under 

soft mast (e.g. berries) in the wildlife report. 

Short-term loss and long-term enhancement 

would be evaluated in detail in the wildlife 

specialist report and summarized in Chapter 3 

in the DEIS.

Nonsignificant 

issue (3)

48 Forest Health 12. Timber harvest will open new areas for 

snowmobiling. How will this be addressed in 

winter travel Plan? Past timber harvest areas 

have become unofficial play areas for 

snowmobiling this activity has caused some 

major damage to the leader growth of new 

plantations.

See response to letter 26, comments 1 to 7. Nonsignificant 

issue (3)

48 Wildlife 13. Timing of all these activities would be

very important not to interrupt and displace 

wildlife. If all this occurs at the same time 

there would be major displacement of wildlife. 

Critical season, calving, winter ranges, 

nesting, security during big game hunting,

both archery and rifle must be considered.

Project design features would be incorporated 

to minimize impacts to elk calving and winter 

range, and ensure, that un-disturbed elk 

security and hiding cover is available. Project 

design features would be incorporated, as 

necessary, to restrict activities within breeding 

habitat for species with viability concerns 

(threatened, endangered and sensitive), as 

well as big game. Forest Plan compliance 

would be for these concerns would be 

evaluated.

See response to letter 66, comments 6 and 7 

regarding big game.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

48 Economics

Low timber 

market

14. The cost effectiveness of this of this 

proposed project should be analyzed.

15. With the local timber market very low, will 

additional timber products bring the market 

See response to letter 5 comment 34 

regarding economic analysis for this project.

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

45

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

even lower?

48 Economics

Logging 

Systems and 

New Roads

16. Five miles of temporary road systems just 

cannot be justified. Helicopter logging would 

be cheaper.

See response to letter 5 comment 34 

regarding economic analysis for this project.

Nonsignificant 

issue (3)

48 Economics 17. This project will need ongoing weed 

control, planting, thinning, monitoring, road 

maintenance, ECT. The president in his state 

of the union address said that federal 

spending would be frozen for three years. 

How will this affect the needed maintenances 

of this proposed action?

The President’s comments regarding Federal 

budgets pertain to the overall Federal Budget. 

Individual forests prioritize implementation of 

site-specific projects that include the road 

work, weed control, etc as part of a potential 

purchaser’s contract. The Helena National 

Forest Plan and management decisions would 

continue to guide ongoing weed control, 

planting, thinning, monitoring, road 

maintenance activities across the Forest.

See also the response to letter 5 comment 34 

regarding economic analysis for this project.

Nonsignificant 

issue (3)

49 Haul Route 

Maintenance

If the roads in Lincoln SP Subdivision are 

used to facilitate equipment in and out of the 

area, will they be maintained after the job is 

finished? or during the process as needed

Haul routes are identified along state, county, 

or NFS roads. Forest Service use of roads not 

under FS jurisdiction would require an 

agreement before use. Road maintenance 

would be performed in accordance with the 

terms of these applicable agreements. 

Nonsignificant 

issue (2)

53 Purpose and 

Need

1. We encourage you, therefore, to consider 

expanding the project purpose and need to 

include enhancement of watershed health, 

fish habitat and water quality.

The decision maker will review the purpose 

and need to determine if changes are 

warranted for this project.

Project design features and BMPs would be 

incorporated and evaluated for effectiveness 

regarding potential effects to soils, water 

quality and fisheries. Results would be 

discussed in Chapter 3 in the DEIS.

Nonsignificant 

issue (1,3)

53 303(d) listed 

waters

2. It is important that all 303(d) listed waters 

within the project area be identified. It would 

appear that activities proposed with the 

Stonewall Vegetation Project have potential 

to affect sediment/siltation in the Blackfoot 

River watershed.

The watershed report will discuss potential 

effects to 303(d) listed waters as well as 

evaluate the effectiveness of project design 

features and BMPs designed to reduce 

potential effects to watershed resources.

Nonsignificant 

issue (3)

53 TMDL 3. We recommend that the Helena NF 

coordinate with MDEQ TMDL program staff to 

The watershed report will analyze potential 

effects to water quality and would be 

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

46

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

assure consistency of proposed Stonewall 

Vegetation management actions with TMDLs 

and Water Quality Plans prepared by MDEQ

summarized in Chapter 3 in the DEIS. 

53 Roads 4. The NOI states that the proposed action 

may include five miles of roads. We 

encourage minimization of new road 

construction as much as possible, particularly 

permanent new roads, and location of any 

needed new roads away from streams and 

riparian areas.

No new permanent roads are proposed. The

new roads proposed in this project would be

obliterated following timber harvest. 

Nonsignificant 

issue (3)

53 Logging 

Systems

5. We also encourage use of timber harvest 

methods that minimize ground disturbance 

(e.g., skyline, helicopter, and logging during 

winter on snow or frozen ground)...

Units proposed for treatment would be 

evaluated for accessibility for removal method 

and discussed in the DEIS. Logging during 

winter on snow or frozen ground may occur. 

Effects to soils and watershed would be 

discussed in Chapter 3 in the DEIS. 

Nonsignificant 

issue (3)

53 Restoration 6. ...inclusion of watershed rehabilitation 

activities such as road obliteration, road BMP 

upgrades road drainage improvements, 

revegetation, stream and bank stabilization, 

and other watershed restoration activities as 

much as possible.

Project design features would include 

applicable BMPs to reduce impacts to water 

quality. Effects to watershed resources would 

be discussed in Chapter 3 in the DEIS with 

further detailed analysis available in the 

watershed and fisheries reports filed in the 

project record. 

Nonsignificant 

issue (3)

53 Vegetation 

Management

7. EPA generally favor understory thinning 

from below, slashing and prescribed fire 

treatments for managing vegetation to reduce 

fuels and fire intensity, as well as address 

forest insect, disease and other forest health 

issues, with retention of large, healthy, fire 

resistant trees, particularly retention of 

declining tree species (e.g., Ponderosa pine, 

whitebark pine, aspen), and retention of 

adequate snags and woody debris to 

maintain wildlife habitat and soil productivity.

Thank you for your support. Nonsignificant 

issue (4)

53 Fuels 

Reduction in 

the WUI

8. We are supportive of efforts to reduce 

hazardous fuels and fire risks in Wildland 

Urban Interface (WUI) areas near homes and

structures where there is high fire risk, and to 

reduce wildfire intensity.

Thank you for your support. Nonsignificant 

issue (4)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

47

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

53 Maps 9. A good watershed map showing streams, 

lakes, wetlands and other surface waters in 

the project area in relation to proposed 

actions should be included in the DEIS to 

allow clear understanding of water quality 

impacts.

The proposed action maps included watershed 

features. The project design features would 

include applicable BMPs to reduce impacts to 

water quality. Effects to watershed resources 

would be discussed in Chapter 3 of the DEIS. 

Nonsignificant 

issue (3)

53 Adaptive 

Management

10. We particularly support the need for 

monitoring and evaluation and incorporation 

of principles of adaptive management in the 

alternatives, and highly support strategies 

that maintain and/or restore watershed 

condition and water quality to fully support 

beneficial uses.

Monitoring expectations would be discussed in 

Chapter 2 of the DEIS.

Nonsignificant

issue (3)

53 Collaboration 11. If there are local groups focusing on 

watershed/ecosystem recovery, we 

encourage the Forest Service to consider 

including a watershed or ecosystem 

restoration alternative for detailed evaluation, 

or at least to include watershed/ecosystem 

restoration elements in the reasonable 

alternatives.

The Stone Dry watershed assessment was 

considered when developing the proposed 

action for the project. The purpose and need 

includes a restoration element. 

The proposed action addresses restoration of 

vegetative composition and structural diversity 

elements. Effects to vegetation and watershed 

resources would be analyzed in the silviculture 

and watershed specialist reports and would be 

summarized in Chapter 3 of the DEIS.

Nonsignificant 

issue (3)

53 Connected 

Actions

12. Also, if there are any proposed nearby 

actions or adjacent developments that are 

closely related to the proposed action it would 

be appropriate to analyze and discuss those 

related developments as a connected action 

(40 CFR 1508.25).

See response to letter 5 comment 13 

regarding consideration of cumulative effects.

Nonsignificant 

issue (3)

53 Mitigation 13. Mitigation measures should be discussed 

in sufficient detail, rather than merely listed, in 

order to ensure that potential detrimental 

environmental effects and measures to 

mitigate those effects have been fairly 

evaluated.

The project design features would be 

discussed in Chapter 2 of the DEIS and the 

effects considered in the various resource 

discussions in Chapter 3 of the DEIS. 

Effectiveness of design and mitigation would 

be evaluated.

Nonsignificant 

issue (3)

53 Monitoring 14. Monitoring plans are also needed for 

measuring the effectiveness of the mitigation 

measures (quantitatively-if possible, and/or a 

qualitatively), and determining the need for 

Monitoring would be discussed in Chapter 2 of 

the DEIS and anticipated results a discussed 

in Chapter 3.

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

48

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

modifying mitigation.

53 Cumulative 

Effects

15. NEPA requires that cumulative impacts 

be addressed as a summary of the individual 

impacts of this and all other past, present, 

and "reasonably foreseeable" future projects, 

including activities on private adjacent land 

irrespective of what agency/entity has 

decision-making authority or analysis 

responsibility.

See response to letter 5 comment 13 

regarding consideration of cumulative effects.

Nonsignificant 

issue (3)

54 Fuels 

Reduction in 

the WUI

1. The trees above Lincoln Springs on Lone 

Point Road are also dead and need logging 

to prevent burning homes.

These would be included to the extent 

possible.

Nonsignificant 

issue (3)

55 Haul Route 1. I am all for this project; but wonder if we 

will see haul trucks in Lincoln Gulch using our 

roads. My concern would be dust, speed of 

trucks, and general concern for our kids.

Thank you for your support of the project.

Project design features include safety signing 

of roads when trucks are hauling and dust 

abatement measures, as needed, for air 

quality and public safety.

Nonsignificant 

issue (3)

57 Prescribed 

Burning

Safety

1. Concerned about the close proximity to 

private property of at least one of the 

prescribed burn areas. Quite close to private 

residences.

A prescribed fire burn plan would be prepared 

for all burn units prior to burning and would 

identify the range of conditions appropriate for 

implementing the burn. 

Risk management is a foundation for all 

prescribed fire activities. Risk and 

uncertainties relating to prescribed fire 

activities are analyzed, communicated and 

managed as they relate to conducting or not 

conducting the activity. A complexity analysis 

is done for each prescribed fire plan. Identified 

risk are analyzed and then mitigated. If risks 

factors are identified with a “high” rating, they 

would be documented and discussed in the 

Complexity Rating Rationale of the fire plan.

Prescribed fire prescriptions would be defined 

showing a range of conditions during which a 

prescribed fire may be ignited. The plan 

prescription will describe a range of low to high 

limits for the environmental parameters 

(weather, topography, fuels, fire behavior 

(flame length, rate of spread, spotting)) are 

required to meet the RX fire plan objectives 

Nonsignificant 

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while also meeting smoke and control 

objectives. Additional elements included in 

prescribed fire plans: (list is not all inclusive) 

contingency resources are identified, expected 

weather and fire behavior, ignition plan for the 

burn unit as well as a plan for holding the fire 

once ignited.

58 Motorized 

Recreation 

Opportunities

1. Our first concern is that no existing 

motorized roads and trails should be closed 

as part of the proposed action.

2. Our second concern is that this area is 

ideal for motorized, multiple-use recreation. 

To adequately address this issue, we request 

that an alternative be considered that would

provide new OHV routes in the area beyond 

those currently existing.

See response to letter 26, comments 1 to 7. Nonsignificant 

issue (1)

59 Support for the 

project

1. The sooner this gets taken care of the 

safer the valley and town of Lincoln would be

Thank you for your support Nonsignificant 

issue (4)

62 Noxious 

Weeds

1. I would like to make sure that with the 

entire Stonewall Vegetation Project a weed 

control plan would be in place for the entire 

area after the project.

See response to letter 5 comments 2 through 

5 and 29 regarding noxious weeds.

Nonsignificant 

issue (3)

63 Firewood 1. Firewood access? The project design features include forest-wide 

standard for firewood (Forest Plan p. II/24).

Nonsignificant 

issue (2)

63 Recreation 

Facilities 

2. Money left over to improve roads and trails 

and establish campgrounds

Allocation of’ left over’ funds to improve 

facilities is outside the scope of this analysis. 

Some of these suggestions are already 

incorporated into the design of this proposal 

e.g. road improvements for haul.

Nonsignificant 

issue (1)

64 Project Design 1. No trespassing on private property. 

Respect fences for livestock containment. No 

damage to, or repair if damaged

Project design features would include

measures to protect existing livestock 

management fencing, or repair if damaged 

during operations. 

Nonsignificant 

issue (3)

66 Forest Plan 

Amendment

1. It seems like extensive Forest Plan 

amendments would be required to implement 

the project, amendments that were not 

identified in the scoping notice.

The Forest Plan direction was considered 

when developing the proposed action. Design 

features would be incorporated to meet or 

move towards Forest Plan desired conditions. 

Upon review of updated information it was 

determined a site-specific forest plan 

Nonsignificant 

issue (2,3)
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amendment is needed to address 

noncompliance with elk habitat standards.

66 Lynx Habitat 2. There is no discussion as to why this 

project will restore habitat for the lynx, so the 

purpose of the project is quite confusing. The 

agency needs to define what the current 

problem is with lynx habitat, and why logging 

and burning will improve and/or restore its 

value to the lynx.

27. This project will result in extensive 

destruction of lynx habitat, from burning to 

commercial harvest to pre commercial 

thinning. Please complete formal consultation 

with the USFWS.

28. The Forest Plan Amendment for lynx 

prohibits thinning of structurally diverse lynx 

habitat, as well as young plantations that 

provide hare habitat. Is the Forest Service 

planning on completing Forest Plan 

amendments to allow this project?

The proposed action includes a mix of 

treatments designed to: reduce the risk of 

wildfire, restore Forest System Land that has 

been affected by large-scale insect-caused 

mortality, and improve forest sustainability by 

increasing species diversity and promoting fire 

tolerant species/communities.

Potential impacts to lynx would be identified 

and evaluated in the BA. All activities would be 

consistent with the 2007 Northern Rockies 

Lynx Management Direction (USDA Forest 

Service 2007), which ensures that the 

conservation and recovery of lynx in the

Northern Rockies ecosystem is maintained, 

that all activities comply with applicable laws 

and policy and that standards and guidelines 

are in place that reduce impacts, while 

maintaining lynx habitat. Further, Section 7 

consultation with the USFWS would be 

completed prior to any decision. Effects to lynx 

habitat would be analyzed in the biological 

assessment and would be disclosed in 

Chapter 3 of the DEIS. 

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

66 Wildlife: Road 

Density and 

Forest Plan 

Direction 

specifically 

regarding 

Grizzly Bear 

Habitat. Elk is 

mentioned.

3. In particular, what are the goals for open 

and total road densities during project 

implementation, in order to avoid 

displacement of any bears using this habitat?

4. Please include a discussion in the draft 

NEPA document regarding how the Forest 

Plan direction for the grizzly bear, which 

originated in 1986, or over 20 years ago, has 

been evaluated as per effectiveness and 

relevance. It seems like some updating may 

be needed for management of this threatened 

species.

5. Please include a description of open road

densities DURING project implementation, 

and define how this will affect habitat 

effectiveness levels of wildlife, from elk to the 

Potential effects to grizzly bear and other 

threatened, endangered and sensitive species 

were considered early during project design. 

Effects of roads on grizzly bears, including 

definitions of and an assessment of total and 

open road densities and effects to bears and 

their habitat, including whitebark pine, would 

be fully evaluated in the Biological Assessment 

and summarized in Chapter 3 of the DEIS. 

Open and total road density during 

implementation and post implementation 

would be analyzed. New roads would be

obliterated immediately following timber 

harvest and all roads that are currently closed 

would remain closed to general traffic during 

project implementation.

Alternative 3 was 

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue 1
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grizzly bear.

38. Please define what condition new roads 

will have to be in order not to count towards 

the total motorized access route density for 

grizzly bear habitat

6. Please map all current hiding cover and 

thermal cover for both the current and 

proposed levels, and define what percentage 

of the landscape these currently and will 

comprise in the future.

7. Please evaluate and map elk security 

cover as per the Hillis et al. (1991) criteria, 

which includes both cover and motorized 

routes, and discuss how this project will affect 

elk and deer vulnerability.

The amount and location of and effects to elk 

hiding, thermal and security cover would be 

analyzed and discussed under the wildlife 

section in Chapter 3 of the DEIS.

Upon review of updated information it was 

determined a site-specific forest plan 

amendment is needed to address 

noncompliance with elk habitat standards. 

Roads are managed in a manner to maintain 

big game capability and hunting opportunity.

Elk security per the Hillis et al. criteria would 

be analyzed and discussed under the wildlife 

section in Chapter 3 of the DEIS

66 Old Growth 8. Please provide an inventory for old growth 

habitat as per Green et al. (1992), and define 

how the Forest Plan direction would be met.

9. Please define how the old growth plan for 

this landscape will ensure viability of 

associated species, including the goshawk, 

pine marten, and various bird species of 

conservation concern as per the Montana 

Natural Heritage Program.

Old growth would be discussed in the 

vegetation and wildlife specialist reports and 

would be summarized in the respective 

sections in Chapter 3 of the DEIS. The 

silviculture and wildlife reports will clarify and 

describe how and what information would be 

used under their respective methodology 

sections.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

66 Migratory 

Songbirds

10. Please define how this project will 

incorporate the Chiefs directive on 

conservation of migratory songbirds.

Effects to migratory birds would be analyzed in 

the wildlife specialist report and would be 

summarized in Chapter 3 of the DEIS.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

66 Restoration: 11. It is not clear why the agency has Support for the purpose and need, including Nonsignificant 
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Fire and 

Wildlife

determined that fire has been excluded from 

this landscape, and that logging and burning 

will constitute "restoration." Please provide 

the current science that both supports and 

refutes this contention, as it is clearly a 

controversial assumption upon which the 

entire project is based.

12. Please refer to the recent publication by 

Baker, 2009, regarding fire ecology of the 

Northern Rocky Mountains, in your 

discussion on the restoration needs of your 

project.

18. What data did the working group use to 

determine that wildlife habitat problems exist 

that would be corrected with logging and 

burning?

19. It seems like the restoration efforts do not 

specifically address wildlife habitat. Why is 

this?

that of restoration would be discussed and 

displayed in project specialist reports and 

other associated documents. The Fire Regime 

Condition Class (FRCC) analysis provides 

reference and desired conditions for 

vegetation in terms of fire return intervals and 

composition. The Forest Plan standards are 

the basis of wildlife desired habitat needs as 

compared to the habitat existing condition. 

Methodology and assumptions used in this 

analysis and used in the development of the 

proposal would be clarified in the wildlife 

methodology section in the specialist’s report 

and would be summarized in Chapter 3 of the 

DEIS.

issue (3)

66 Management 

Indicator 

Species

13. Please define the conservation strategies 

that would be implemented for Helena Forest 

management indicator species, including the 

goshawk, pine marten, and pileated and hairy 

woodpeckers.

Effects to these species, including 

conservation strategies and project design 

features would be discussed in detail in the 

Biological Evaluation (BE) (goshawk, pine 

marten, etc.) and would be summarized in the 

wildlife section of Chapter 3 in the DEIS.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

66 Wildlife 

Surveys

14. Please define the level of wildlife 

inventories that would be completed for this 

project, as well as their reliability in locating 

occupied breeding habitat for MIS, sensitive 

species, and species of special concern.

The wildlife analysis process, including 

inventories and monitoring would be discussed 

in the wildlife report, BA and BE, and 

summarized in the wildlife section of Chapter 3

of the DEIS. 

Nonsignificant 

issue (3)

66 Snag 

Management

15. Please define the specific snag 

management strategy for each treatment 

type, including post-logging snags 

immediately after logging, and how long-term 

Stand and landscape level changes to dead 

wood, including snag retention and recruitment 

of future snags and applicable snag 

management protocols would be discussed in 

Nonsignificant 

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recruitment of snags would be maintained

16. Please define what the management 

strategy would be for snags, whether it is the 

Helena Forest Plan or the Northern Region 

Snag Management Protocol.

17. Please define why snag habitat needs to

be restored in this landscape, and how this 

would be accomplished.

the wildlife report and summarized in the 

wildlife section of Chapter 3 of the DEIS. 

Project design features would be incorporated 

to ensure activities are consistent with Forest 

Plan direction related to snags and downed 

woody debris. 

66 WUI 20. Please map the wildland-urban interface 

area, and include the occupied structures that 

lie within this.

33. Please discuss Jack Cohen's work 

regarding the use of small fuels buffers to 

protect structures, and how this science 

would be applied to the current project.

The Wildland Urban Interface was mapped 

during development of the Tri-County 

Community Wildfire Protection Plan (CWPP) 

and is in the project file.

Structures are located on private lands, whose 

management is outside the scope of this 

project. 

There are subdivisions with private residences 

located adjacent to the forest boundary and 

identified in the “Tri-County Community 

Wildfire Protection Plan” (CWPP) as wildland 

urban interface. The stands in close proximity 

to the forest boundary are proposed harvest 

treatments. Subdivisions adjacent to the 

project are categorized as “Very High to High 

Risk” as identified in the Tri County CWPP.

Treatments adjacent to private land are 

designed to remove dead material to reduce 

fuel loading on National Forest System lands.

The fire/fuels analysis will include a map and 

discussion of wildland-urban interface. See 

response to letter 3 comment 3 regarding the 

fire/fuels analysis.

The Forestwide Hazardous Tree Removal and 

Fuels Reduction Project is being implemented 

to remove dead trees that pose a hazard along 

Forest System Roads to provide safer access 

routes within the project area.

A literature review of Jack Cohen’s work would 

be completed and considered during analysis 

for this project. 

Nonsignificant 

issue (1,3)

66 Forest Health 21. What specific information is available to The Stone Dry watershed analysis (USDA Nonsignificant 
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demonstrate that the current watershed 

conditions are "unhealthy?"

22. Please define how forest health is being 

measured. What are the specific criteria used 

to define health, and what is the rating 

system used. Is a forest rated as either 

"healthy" or "unhealthy," or is there a sliding 

scale of health? Please identify the health 

level of each unit that is planned for 

treatment.

Forest Service 2009) reviewed the existing 

conditions and the desired conditions identified 

in the Forest Plan.

Existing condition of the vegetation and effects 

from proposed actions would be discussed in 

Chapters 1 and 3 of the DEIS. The silviculturist 

would analyze and discuss the anticipated 

effects of insect activity in relation to natural 

endemic levels of insect activity.

issue (3)

66 Roadless 

Areas

23. There is no map of the inventoried

roadless area boundaries. This should be 

clearly defined.

24. If fire has to be restored to roadless

lands, it must be demonstrated that fire has 

been eliminated. Please provide the current 

best science that demonstrates that the lack 

of fire in the roadless lands has resulted in a 

disturbed ecosystem, as define what 

particular portions of the ecosystem, including 

wildlife such as the lynx, have been harmed 

as a result.

The proposed action map would be edited to 

depict the inventoried roadless boundaries.

Past fires and effects to fire/fuels and effects to 

wildlife would be discussed under silviculture, 

fuels, and wildlife section in Chapter 3 of the 

DEIS as well as additional detailed discussions 

in the respective specialist reports filed in the 

project record.

Nonsignificant 

issue (3)

66 Aspen 25. What are the indicator species that are 

going to be used to define the need for aspen 

treatments? If no wildlife species are going to 

be used to justify needs for treatment of

aspen, what criteria are these treatments 

being based?

26. Some current science has concluded that 

aspen are in a natural cycle of conifer 

encroachment from the last fire cycle, and 

that a decline in aspen is natural. What 

information in the project area is being used 

to suggest that aspen conditions are 

unnatural at this time, and that treatment is 

needed for restoration?

Effects to vegetation, including aspen 

management, and effects to wildlife, including 

management indicator species would be 

discussed in the respective specialist reports 

(silviculture, wildlife) and summarized in 

Chapter 3 of the DEIS.

Nonsignificant 

issue (3)

66 Timber 

Harvest and 

Past Harvest

29. Please identify all clearcuts, and what 

their size would be.

30. Please map and define the areas of past 

harvest.

A listing of silvicultural prescriptions and a map 

of areas of known past harvest recorded in the 

forest database would be developed and 

provided in the DEIS. The eight groups of 

Nonsignificant 

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treatments would be described in Chapter 2 of 

the DEIS. Exact locations of small clearcuts 

(under 40 acres in size) would be determined 

based on actual ground conditions (e.g., 

mortality present, topography) and would

follow treatment prescriptions.

66 Wildlife 

regarding bark 

beetle

31. Please discuss the significant values of 

bark beetle infestations and spruce budworm 

infestations to wildlife.

32. Please discuss the differences between 

habitat conditions for wildlife if the beetleinfested forests are left undisturbed, versus if 

they are clearcut, for both the short and long 

term.

Effects to wildlife species are discussed In 

Chapter 3 of the DEIS and further explored in 

the wildlife report and subsequent BE & BA. 

Untreated portions of the project area would

provide undisturbed habitat for species 

associated with bark beetle-killed trees (e.g., 

hairy woodpeckers). 

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects

would be 

discussed in the 

DEIS.

Significant 

issue #1

66 Roads 34.Please provide a complete inventory of 

ALL roads in the analysis area, from 

nonsystem roads, to system roads, to 

motorized trails, to proposed new temporary 

roads; include information on how these 

roads are individually identified (a number), 

the length of the road/trail in mileage, its 

current management, whether the road would 

be opened for the proposed project, whether 

any roads would be used for public firewood 

harvest, and the specific time when 

temporary roads would be closed after project 

completion.

35. Please define the long-term need for the 

temporary roads that would be constructed 

for this project.

36. Please identify what the difference would 

be between new temporary roads constructed 

for this project, versus old logging roads that 

are still in use or would be used for this 

project. Why won't new roads also be needed 

for future management?

37. Please address the fragmentation 

The existing road information and roads 

needed for the proposal would be discussed in 

Chapters 1 and 3 in the DEIS. 

Existing routes would be used wherever 

possible to minimize additional impacts. New 

roads that would be obliterated following 

timber harvest were identified by forest 

specialists where needed to support the 

actions proposed with this project. The new 

roads that would be obliterated immediately 

following timber harvest are not anticipated to 

be needed for management actions after this 

project. No change to the permanent forest 

transportation system is proposed with this 

project. Effects from new roads that would be

obliterated following timber harvest would be

considered in the resource analyses in their 

individual reports and summarized Chapter 3

of the DEIS, including fragmentation impacts 

on wildlife species. 

Nonsignificant 

issue (3)
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impacts of any new roads.

67 Support for the 

Project

1. I believe this to be a great idea Thank you for your support. Nonsignificant 

issue (4)

67 Prescribed 

Burning

Safety

2. I do have a concern about controlled 

burns...I would appreciate see more 

firefighters present at the time of burn as 

assurance of a containable situation should 

sudden winds or other agents cause spread 

in a dangerous way.

3. Ensure that all structures are insured to full 

replacement if anything should go wrong.

Burn plans would be prepared for each 

proposed unit and would be designed to be 

consistent with the Forest Plan. 

Insuring structures for full replacement is 

outside the scope of this analysis.

Nonsignificant 

issue (1,2)

68 Support for the 

Project

1. The LWG and FS have done a great job in 

addressing all of the issues and concerns. 

The EIS should be comprehensive and easily 

implemented as a result.

Thank you for your support Nonsignificant 

issue (4)

68 Willow in 

Riparian

2. Willows were not indicated by name as 

seral species. If they are, and would be 

replanted where burned or in any [ripped or 

riparian] areas, may I suggest the use of a 

[stinger or auger?] mounted on the front of a 

backhoe. This would be quick, successful and 

inexpensive and allow planting of rootless 

willow slips up to 6-feet-long. 

The effects of the proposed treatments on 

willow would be discussed in the silviculture 

and botany specialist reports. The project 

would follow Forest Plan guidelines for riparian 

protection. At this time, no treatments are 

proposed in riparian areas with willow, and no 

planting of “upland” willow is proposed.

Nonsignificant 

issue (3)

69 Prescribed 

Burning

Safety

1. Ms Kamps, my name is Greg Brittain. I 

own the cabin and 40 acres just off Sucker 

Creek Road that is in sector 6 on your map. I 

am just below Doc Shields place. I am 

currently serving overseas and am unable to 

get to Lincoln until summer. Will precautions 

be taken to ensure that these burns do not 

spread beyond their intended areas? Thanks 

a lot!!

Mr. Brittain was contacted to clarify that 

precautions would take place to keep the 

prescribed fire where proposed. Additional 

information was provided and Mr. Brittain is on 

the mailing list to receive more project 

information.

Nonsignificant 

issue (3)

70 Prescribed 

Burning

Safety

1. Could be dangerous to those living in the 

Lincoln Gulch area if there are not enough 

people at the prescribed burns with enough 

fire suppression equipment.

See response to letter 57, comment 1 

pertaining to burn plans.

Nonsignificant 

issue (3)

70 Economics 2. I don’t see how you are going to get much 

from large commercial harvest sales. ...open 

the sales to small loggers in 10-20-acre 

An incremental economic analysis would be 

completed and would be discussed in Chapter 

3 of the DEIS.

Nonsignificant 

issue (1,3)
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sales. Large companies can bid more than

one sale. ...this would allow all local loggers 

to bid. Most of the timber slated for removal is 

not economically or commercially valuable, 

especially to big logging operators.

Designating contract type is outside the scope 

of this analysis and combinations of “Sale” 

packages would be evaluated if an action 

decision is made.

71 Project Design 1. First, we respectfully request that the 

Stonewall Vegetation Project be designed 

and implemented consistent with the MFRC 

Principles as well as all existing 

environmental laws and regulations including 

the Roadless Area Conservation Rule. 

Second, we ask that this project be designed 

consistent with the requirements of the 

National Forest Management Act, the Forest 

Landscape Restoration Act and the 

Collaborative Forest Landscape Restoration 

Program (CFLRP) Field Guide to ensure 

maximum eligibility for forest restoration 

funding.

This project has been designed to comply with 

the Forest Plan, applicable laws, regulation 

and policy. 

Funding of implementation is outside the 

scope of the environmental analysis, but is 

considered in the economic analysis discussed 

in Chapter 3 and other laws and regulations 

sections of the DEIS.

Nonsignificant 

issue (2,3)

71 Project Design 2. For each stand that is proposed for 

treatment, either by USFS or LRC, please 

describe the agency’s perspective on current 

stand condition, the stand’s specific 

restoration need(s), how the proposed 

treatment meets these needs, the ecological 

basis for each treatment, the desired 

restoration outcome(s) and what monitoring 

measure(s) you will employ to determine 

whether and to what extent the restoration 

needs have been met.

Information for each proposed treatment unit 

has been collected. A series of formal stand 

exam plots has been established to be used in 

characterizing the current condition and would 

be used to estimate expected changes due to 

treatments using the Forest Vegetation 

Simulator, a forest modeling program.

Nonsignificant 

issue (3)

71 Monitoring 3. We would also like to see both 

implementation and effectiveness monitoring 

with a defensible statistical design including 

repeated sampling of plots or transects 

before and after treatment applications. This 

type of monitoring is laid out in the MFRC 

principles (principles 2 and 4).

Monitoring would be discussed in chapter 2 of 

the DEIS. 

Nonsignificant 

issue (3)

71 Collaboration 4. We strongly encourage you to explore the 

possibility of a monitoring partnership 

between the Lincoln Ranger District and the 

Partnerships for monitoring would be 

considered as opportunities arise for the 

forest. Developing these partnerships is 

Nonsignificant 

issue (1)
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University of Montana’s College of Forestry 

and Conservation.

outside the scope of this analysis.

71 Restoration 5. To ensure maximum consistency with the 

Montana Forest Restoration Principles, 

please explain how each of the proposed 

silvicultural treatments qualify as “restoration” 

with respect to the MFRC principles

The effects of silvicultural treatments and how 

they would be accomplishing the purpose and 

need for the project, which includes restoration 

objectives would be discussed in the 

silviculture specialist report and summarized in 

Chapter 3 of the DEIS. This discussion would 

include MFRC principles.

Nonsignificant 

issue (3)

71 Silviculture 6. Regarding the regeneration harvests of 

Project 1, it does not appear that these 

treatments are consistent with either the 

MFRC principles or the requirements of 

CFLRP. Please describe the specific goals of 

regeneration treatments described in Groups 

3 and 4 and their relevance to the Montana 

Forest Restoration Principles. Assuming 

these treatments are designed to enhance 

stand replacement, please explain what the 

expected or desired species composition of 

the next stand would be, how this is 

consistent with the Montana Forest 

Restoration Principles and how the next 

stands would be managed.

The effects of regeneration treatments and 

how they would be accomplishing the purpose 

and need for the project, which includes 

restoration objectives would be discussed in 

the silviculture specialist report and would be 

summarized in chapter 3 of the DEIS. This 

discussion would include MFRC principles.

Nonsignificant 

issue (3)

71. Silviculture 

Mountain Pine 

Beetle

Adaptive 

Management

7. ...we would like to know whether it is 

possible to leave large patches (1 to 5 acres) 

of uncut forests within the regeneration 

harvests. Through rigorous monitoring efforts,

these patches could be used to monitor how 

stands regenerate following MPB mortality 

compared to regeneration harvests. While 

there is much area with MPB mortality in the 

surrounding areas, a robust design could be 

used as part of understanding species 

responses to treatments. We believe that this 

type of study is consistent with the ‘adaptive 

management’ principle adopted by MFRC 

and with language in the CFLRP Field Guide.

Effects to vegetation, including proposed 

reforestation planting, would be analyzed in 

the silviculture specialists report and 

summarized in Chapter 3 of the DEIS.

Nonsignificant 

issue (3)

71 Silviculture 

Reforestation

8. At sites where trees would be planted, 

what species of trees would be planted, at 

Effects to vegetation, including proposed 

reforestation planting, would be analyzed in 

Nonsignificant 

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what density, and from what population or 

nursery will the seedlings originate? Please 

explain why the chosen mix of seedlings is 

used and how the chosen mix will facilitate 

meeting future stand conditions that fit our 

restoration principles.

the silviculture specialists report and discussed 

in Chapter 3 of the DEIS. 

71 Roads 9. Please explain how, when and to what 

standard the temporary roads would be

decommissioned and restored, and how this 

would be monitored.

See response to letter 3 comment 12 

regarding new roads that would be obliterated 

immediately following timber harvest.

Nonsignificant 

issue (3)

71 Noxious 

Weeds

10. Please explain how invasive plant species 

would be managed should they invade the 

temporary roads or treatment areas following 

implementation, and how invasive species 

would be monitored.

See response to letter 5 comments 2,3,4,5 and 

29 regarding noxious weeds. 

Nonsignificant 

issue (3)

71 Prescribed 

Burning

Slashing

11. Please explain and clarify the use of 

“slashing” with prescribed burning activities, 

and explain what slashing prior to prescribed 

burning achieves.

In prescribed burn units, slashing (cutting of 

small diameter material and spreading it on the 

ground), is identified in areas to help achieve 

desired results where adequate fuels may not 

currently exist on the ground.

Nonsignificant 

issue (3)

71 Prescribed 

Burning

Severity

12. Please use and reference appropriate fire 

models to analyze treatments, and then 

clearly state how treatments would change 

fire behavior across the Stonewall Vegetation 

Project area. Utilize a fire severity description 

for each habitat to be treated in these 

proposals that describe how the treatments 

will mimic the natural fire impacts for low, 

mixed and lethal fire regimes.

See response to letter 3 comment 3 regarding 

fire/fuels analysis.

Nonsignificant 

issue (3)

71 Prescribed 

Burning and 

Silviculture

Fire Intensity

13. Identify stands or treatment areas that 

can be brought back into the naturally 

projected fire intensity levels either by using 

silvicultural treatments or prescribed fire.

The effects of stand treatments on proposed 

treatment units and how those effects relate to 

achieving the stated purpose and need, which 

includes “creating conditions that allow the 

reestablishment of fire as a natural process on 

the landscape” would be discussed in the 

silviculture and fuels specialists’ and would be 

summarized in Chapter 3 of the DEIS.

Nonsignificant 

issue (3)

71 Prescribed 

Burning

14. Please outline the steps you will take to

ensure that prescribed burning does not 

Project design features identify measures to 

be taken to ensure conifer mortality is within 

Nonsignificant

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

60

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Mortality of 

large trees

increase mortality of large trees in the project 

area. For example, if duff is thick and roots 

are shallow, even low severity fire can kill 

large trees and you might consider timing 

burning to ensure that only the top of the duff 

is burned, slash pull back or even raking the 

duff from away from the bole root collar.

an acceptable range.

Individual trees may be protected by clearing 

brush and slash around the base of selected 

trees.

71 Restoration 15. Given that many of the large trees are 

missing, take into account the need to restore 

the large Ponderosa pine population.

Part of purpose and need is to “enhance & 

restore aspen, western larch, and ponderosa 

pine species and habitats.” The silviculture 

specialist report will discuss forest type and 

stand conditions and other project records will 

identify stands that have lost their large 

ponderosa pine component due to recent bark 

beetle mortality and how proposed treatments 

are anticipated to push the stands toward 

restoring that component.

Nonsignificant

issue (3)

71 Prescribed 

Burning

“Prescribed 

Mixed Severity 

Fire”

16. Regarding “Prescribed Mixed Severity 

Fire” we request the development of clear 

objectives for achieving a mixed severity fire. 

We would like you to describe what response 

you expect in terms of post-fire stand 

structure and landscape structure.

Treatment objectives would be discussed in 

the Silviculture and fuels specialist and 

summarized in Chapter 3 of the DEIS.

The objectives of the mixed severity units are 

to create openings between 10-75 acres 

resulting in the breakup of continuous 

vegetation in higher elevations, promote age 

class diversity and enhance white bark pine 

habitat by creating openings suitable for 

regeneration.

Nonsignificant

issue (3)

71 Stone Dry 17. ...regarding the Stone Dry portion of the 

project as described in your recent scoping 

notice, we believe that the activities you 

envision for this area could be consistent with 

the Montana Forest Restoration Principles, 

especially Principles 5 and 6 which are 

included here for your reference:

5) Reestablish fire as a natural process on 

the landscape

6) Consider social constraints and seek 

public support for reintroducing fire on the 

landscape

Thank you for your support. Nonsignificant 

issue (4)

72 Native Fish 1. ...it is unclear if the project would Effects to fisheries would be discussed in the Nonsignificant 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

61

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Habitat adversely influence cutthroat trout (and bull 

trout) habitat; however, the project appears to 

have this potential given the scale and nature 

of the project. As the project moves forward, 

it would be important to ensure that special 

riparian protection measures are appropriate 

to protect riparian values associated with 

native fish habitat.

This would include maintaining appropriate 

riparian buffers as part of the larger project, to 

offset potential effects from possible upland 

disturbance. There may also be opportunities 

to correct historical problems--related to 

streams--within the footprint of the project 

(e.g., replacing undersized culverts). If so, 

perhaps this project could provide a 

mechanism to correct any such problem.

fisheries report and in Chapter 3 of the DEIS. 

Project design features would include INFISH 

direction to provide appropriate resource 

protection. INFISH direction would be met.

issue (3)

73 Support for the 

Project

1. The Tri-County Fire Safe Working Group 

supports the Stonewall Vegetation Project 

because it will reduce the risk of a 

catastrophic wildfire in the Lincoln area.

Thank you for your support. Nonsignificant 

issue (4)

74 Big Game 1. How will big game winter range be 

affected?

Effects to big game winter range would be 

analyzed in the wildlife report and summarized 

in Chapter 3 of the DEIS.

A potential 

alternative 3 was

developed to 

reduce potential 

impacts to various 

wildlife habitat 

elements. This 

alternative and 

anticipated effects 

would be 

discussed in the 

DEIS.

Significant 

issue #1

74 Grazing 2. How will livestock grazing be managed? There are no changes proposed to the existing 

livestock management. Effects to livestock 

grazing would be discussed in chapter 3 of the 

DEIS with more detailed discussion in the 

range specialist report.

Nonsignificant 

issue (3)

74 Harvest 3. How many green trees would be removed? Effects to vegetation would be discussed in 

Chapter 3 of the DEIS. Providing an estimate 

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

62

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

of green trees to be removed is not anticipated 

to be specifically identified, particularly with the 

ongoing insect mortality. 

74 Economics 4. What will this cost the taxpayers? The results of an incremental economic 

analysis would be disclosed in Chapter 3 of 

the DEIS.

Nonsignificant 

issue (3)

74 Noxious 

Weeds

5. Do you have a plan to deal with weeds? Noxious weed treatments are ongoing across 

the Forest. Noxious weed treatments would 

continue with this project. Project design 

features would be incorporated to reduce 

potential for spread of noxious weeds.

Nonsignificant 

issue (2,3)

74 Visuals 6. What are the visual impacts? Effects to visual resources would be analyzed 

and VQO forest plan compliance would be 

disclosed in chapter 3 of the DEIS.

Nonsignificant 

issue (3)

74 Private lands 7. What are the private landowners doing to 

make their property more firesafe?

Management of private lands is beyond the 

scope of this project. However, any identified 

private land activities would be accounted for 

in cumulative effects analysis in the affected 

resource(s).

Private landowners are working in cooperation 

with Federal and State agencies in managing 

lands to move toward the goals identified the 

Community Wildfire Protect ion Plan and the 

goals for the Southwest Crown of the 

Continent areas.

Nonsignificant 

issue (1)

75 General 

Project Design

1. I have nothing to add to the proposal. I 

agree with the practices being discussed to 

use on this project, as long as they are used 

wisely and not to the extreme-the most 

minimum effective way to get the job done, 

leaving as much authentic beauty around 

Lincoln. Heavy on conservation and 

restoration.

Thank you for your support. Nonsignificant 

issue (4)

75 Timber 

Harvest

2. I'm worried about how much timber is cut 

out and where. The last time they cut around 

us it created a severe wind tunnel, blowing 

down dozens of my trees ...

Proposed treatments would be discussed in 

Chapters 1 and 2 in the DEIS. Proposed action 

treatments were developed t following Forest 

Plan and regional guides to ensure treatments 

are appropriate for the stand types and 

conditions present. The project design features 

Nonsignificant 

issue (1, 3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

63

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

may include feathering along private lands to 

blend with the vegetation to avoid creating 

abrupt visual lines.

Thinning of any kind would increase air 

movement through forest canopies. In units 

where trees are proposed to be “thinned” the 

increase wind movement would be relatively 

moderate due to the remaining tree canopies.

The greatest increases would be in 

regeneration units, however even in the 

regeneration units trees would remain to 

provide shelter and seed, moderating winds.

Also, regeneration units would be patchy, with 

patches of heavy mortality being regenerated 

and patches of healthy trees of a desirable 

species being retained and thinned as needed. 

Any modifications of treatments to prevent 

wind impacts on concerned landowners can be 

discussed, as long as the locations where the 

concerns are known. The effects of those 

medications on achieving the purpose and 

need could then be discussed.

75 Prescribed 

Burning

Safety

3. The wind problem also concerns me in the 

burning process of this project; it is very gusty 

around us and unpredictable. How well will 

the burning be managed is a concern.

A prescribed fire burn plan would be prepared 

for all burn units prior to burning and would 

identify the range of conditions appropriate for 

implementing the burn. 

Risk management is a foundation for all 

prescribed fire activities. Risk and 

uncertainties relating to prescribed fire 

activities are analyzed, communicated and 

managed as they relate to conducting or not 

conducting the activity. A complexity analysis 

is done for each prescribed fire plan. Identified 

risk are analyzed and then mitigated. If risks 

factors are identified with a “high” rating, they 

would be documented and discussed in the 

Complexity Rating Rationale of the fire plan.

Prescribed fire prescriptions would be defined 

showing a range of conditions during which a 

prescribed fire may be ignited. The plan 

prescription will describe a range of low to high 

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

64

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

limits for the environmental parameters 

(weather, topography, fuels, fire behavior 

(flame length, rate of spread, spotting)) are 

required to meet the prescribed fire plan 

objectives while also meeting smoke and 

control objectives. Additional elements 

included in prescribed fire plans: (list is not all 

inclusive) contingency resources are identified, 

expected weather and fire behavior, ignition 

plan for the burn unit as well as a plan for 

holding the fire once ignited.

75 Prescribed 

Burning

Air Quality

4. The extent of the burning, when and where 

and how long could cause heavy smoke 

creating breathing problems for the nearby 

residence.

See response to letter 1 comment 3 pertaining 

to air quality.

Nonsignificant 

issue (3)

75 Restoration 5. Conservation and restoration need to play 

a big part in this project. The steep hillsides 

need great consideration and the streams 

and springs. We rely on Stonewall Creek for 

irrigation and a spring for a source of water to 

the cabins. These sources would have to be 

protected from damage or change.

Project design features and applicable best 

management practices would be listed in the 

DEIS.

Nonsignificant 

issue (3)

76 General 

Design of the 

Project

1. More details on what you are going to do The proposed actions and alternatives, 

including project design features, would be 

discussed in chapters 1 and 2 of the DEIS. 

The applicable BMPs would be included in the 

DEIS,

Nonsignificant 

issue (3)

77 Identify the 

Project Area

1. Based on the maps provided in the scoping 

package, it is difficult to determine if this 

project lies near the CDNST or any of the 

project activities would be visible from the 

CDNST in the area. CDTA requests that the 

CDNST proximity to or location within the 

project area be identified.

The project vicinity map has been revised to 

include the CDNST for reference. There are no 

activities proposed from this project within a 5 

mile radius of the CDNST (CDNST Plan 2009)

Nonsignificant 

issue (1)

77 Visuals 2. ... activities should only take place within 

the CDNST corridor in a manner that is 

consistent with Trail values expressed in the 

CDNST Comprehensive Plan and when they 

are consistent with the Scenery Management 

System Objectives for the CDNST. Therefore, 

There are no activities proposed from this 

project within a 5 mile radius of the CDNST. 

(CDNST Plan 2009)

VQO compliance is addressed using VMS and 

summarized in chapter 3.

Nonsignificant 

issue (3)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

65

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

CDTA recommends the use of the Scenery 

Management System and the consultation of 

the CDNST Comprehensive Plan direction 

(2009) for assessing impacts of the Stonewall 

Vegetative Management Project on the 

CDNST.

A crosswalk between the VMS and SMS would 

be included in the visual resource report that 

would be available in the project record.

77 Visuals 3. Specifically, CDT A requests that if the 

Trail lies within the project area, that careful 

attention be paid to the foreground zone (or 

Trail Corridor) and activities that may be seen 

from the Trail have the potential to negatively 

impact the Trail Users experience. We 

suggest the use of small group 

selections/thinning activities, and/or 

feathering of vegetation to soften the edges 

of any management activities that remove 

vegetation from the area. We would also like 

to discourage the any commercial harvesting 

activities within the CDNST corridor. For 

activities that occur beyond the Trail corridor, 

but are visible from the Trail. We request that 

careful attention be paid to minimize impacts 

to the visual aesthetic of the area. Again we 

suggest the use of feathering, small group 

selections/thinning, and careful use of fire in 

these areas to address management 

concerns.

There are no activities proposed from this 

project within a 5 mile radius of the CDNST. 

Forest plan compliance would be determined 

using VMS per forest plan direction. VQO 

forest plan compliance of the project area from 

the CDNST would be addressed in the visual 

resource report and summarized in chapter 3

of the DEIS.

Nonsignificant 

issue (3)

78 Timber 

Harvest

1. We believe the mature timber should be 

logged. Also, the beetle infested timber needs 

to be salvaged rather than left to waste and 

catch fire causing more problems.

Thank you for your support of the proposal. Nonsignificant 

issue (4)

78 Roadless 2. We would like to see more roadless areas. See response to letter 5 comments 24 and 25 

regarding roadless.

Nonsignificant 

issue (1)

78 Roads 3. We support closing more roads on public 

land in an effort to control damage to both 

public and private deeded lands.

See response to letter 5 comment 14 

regarding the ongoing travel management 

analysis. 

Nonsignificant 

issue (1)

79 Prescribed 

Burning

1. Air quality for the Lincoln community from 

prescribed burning.

See response to letter 1 comment 3 regarding 

air quality impacts.

Nonsignificant 

issue (3)
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

66

Letter 

# Topic Comment Response Alternative Issue # Or Category(Ies)

Air Quality

79 Loss of value 

from wood 

products

2. Loss of value from burning wood products. 

3. Would request that no control burning take 

place. Chip only, lop and scatter limbs where 

equipment depressions are left and terraced 

for rain runoff and quicker nutrient base for 

remaining trees. Trees that are not sold 

should be stored on ranger district property 

for proposals to use for pellet startup 

company, firewood sales or siding production.

The no action alternative would include no 

controlled burning.

The forest plan identifies prescribed burning as 

an appropriate tool for vegetation and fuels 

management (pages 11/33 – 34), and burn 

proposals would be completed following the 

Forest Plan Fire Management Plan direction in 

place at the time of implementation. 

Many of the proposed prescribed fire units are 

located in the Inventoried Roadless Areas 

(IRAs) where timber management is currently 

uneconomical or environmentally infeasible. 

Timber harvest is not proposed in the IRAs 

(management area M1).

Forest Plan standard Firewood 2. Logging 

areas would be open to public firewood 

gathering after the sale is closed and prior to 

burning logging debris and closing roads, if 

wood is available and other resource values, 

such as wildlife snags, down logs, and soils, 

can be protected.

An alternative was considered that would not 

use prescribed fire in management areas T1 

through T5. This alternative would not address 

the purpose and need to modify fire behavior 

to enhance community protection while 

creating conditions that allow the 

reestablishment of fire as a natural process on 

the landscape. Due to not addressing this 

purpose and need this alternative was

eliminated from detailed analysis. This would 

be disclosed in Chapter 2 of the DEIS.

Alternative 

considered but 

eliminated from 

detailed analysis, 

this would be 

discussed in 

Chapter 2 of the 

DEIS.

Nonsignificant 

issue (2),3

80 Support for the 

Project

1. Do what is needed Thank you for your support Nonsignificant 

issue (4)
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

67

Appendix B – Proposed Treatment Descriptions and 

Silviculture Summary
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

68

Treatment Type and Prescription Descriptions

Improvement Cut, Underburn - An improvement cut is an intermediate harvest that removes the less 

desirable trees of any species in a stand of poles or larger trees, primarily to improve the composition and 

quality. These treatments would generally be ‘from below’ to favor retaining larger trees over smaller 

trees, however, thinning regimes would favor retaining smaller trees of a more desirable species over

larger trees of a less desirable species, and would favor keeping smaller, healthier trees over larger, 

damaged or diseased trees. The species preference for retention would be aspen, western larch, ponderosa 

pine, Douglas-fir, lodgepole pine, Engelmann spruce, and subalpine fir in descending order. Trees would 

be thinned to an average spacing of 20 to 40 feet (109 to 27 TPA), but spacing could vary widely. 

Thinning would be by hand and/or machine. All dead and live cut trees considered merchantable, except 

as needed to meet other resource concerns (e.g., snag and downed large woody debris requirements) 

would be removed for utilization. Following thinning, the units would be underburned, which are 

“Prescribed burns of low intensity covering a majority of the burn unit consuming surface fuels, but not 

the overstory canopy.” 

Improvement Cut, Jackpot burn – The improvement cut would be as described previously. The 

thinning would be followed by a jackpot burn, which is “prescribed burning of fuels in scattered 

concentrations” and in addition does not cover a majority of the unit.

Precommercial Thin, Handpiling, Burn Piles – These treatments involve cutting small trees of little to 

no merchantable value to decrease stocking and reduce fuels. Trees would be thinned by hand or by 

machine. Post-thinning average tree spacing would range from 12 to 20 feet (109 to 303 TPA). Thinning 

debris in several units would be piled by hand and the handpiles would be burned to reduce fuels. See the 

fuels report for handpile and burning specifications.

Precommercial Thin – These treatments involve cutting small trees of little to no merchantable value to 

decrease stocking and reduce fuels. Trees would be thinned by hand or by machine. Post-thinning average 

tree spacing would range from 12 to 20 feet (109 to 303 TPA). 

Shelterwood (Group) with Reserves, Site Prep Burn – These treatments involve removing all trees 

except for those needed for shelter and seed production. Leave trees would be grouped, and would be 

aspen, ponderosa pine, Douglas-fir, Engelmann spruce, or subalpine fir, in descending order of 

preference. All dead and live cut trees considered merchantable, except as needed to meet other resource 

concerns may be removed for utilization. Following cutting and removal, the units would be burned to 

prepare sites for natural regeneration. Expected natural regeneration species are Douglas-fir and 

lodgepole pine. Areas may be planted with ponderosa pine and western larch to achieve the desired 

species composition. The leave trees would be retained following regeneration.

Low Severity Fire, Openings less than 5 acres – These treatments would involve cutting of small trees 

(slashing) to create fuel beds in areas less than 5 acres in size, and underburning to reduce fuels, cause 

additional mortality of undesirable trees, and prepare sites for natural regeneration. Desired natural 

regeneration species are Douglas-fir, ponderosa pine, and lodgepole pine depending upon the unit.

Low Severity Fire, Openings less than 10 acres – These treatments would involve cutting of small trees 

(slashing) to create fuel beds in areas less than 10 acres in size, and underburning to reduce fuels, cause 

additional mortality of undesirable trees, and prepare sites for natural regeneration. Desired natural 

regeneration species are Douglas-fir, whitebark pine, and lodgepole pine.

Seedtree with Reserves, Slashing, Handpiling, Burn Piles – These treatments involve removing all 

trees except for those needed for seed production. Seed trees are expected to be Douglas-fir. All dead and 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

69

live cut trees considered merchantable, except as needed to meet other resource concerns, may be 

removed for utilization. Undesirable, damaged, or diseased small trees would be cut (slashed), handpiled 

and burned. Leave trees would be retained following regeneration. Regeneration is expected to be 

Douglas-fir and lodgepole pine.

Shelterwood (Group) with Reserves, Jackpot Burn – The shelterwood treatment would be as described 

previously. All dead and live cut trees considered merchantable, except as needed to meet other resource 

concerns, may be removed for utilization. Following cutting and removal, concentrations of fuels 

involving less than a majority of the unit area would be burned. Expected regeneration would be some 

combination of Douglas-fir, lodgepole pine, Engelmann spruce, and aspen. Some combination of 

ponderosa pine, western larch, and Douglas-fir may be planted.

Seedtree with Reserves, Jackpot Burn - These treatments involve removing all trees except for those 

needed for seed production. Seed trees are expected to be mainly Douglas-fir with ponderosa pine, 

Engelmann spruce, and aspen depending on unit. All dead and live cut trees considered merchantable, 

except as needed to meet other resource concerns, may be removed for utilization. Following cutting and 

removal, units would be jackpot burned. In some units, ponderosa pine and Douglas-fir may be planted.

Seedtree with Reserves, Broadcast Burn - These treatments involve removing all trees except for those 

needed for seed production. Seed trees are expected to be Douglas-fir. All dead and live cut trees 

considered merchantable, except as needed to meet other resource concerns, may be removed for 

utilization. Following cutting and removal, units would be broadcast burned. Ponderosa pine and 

Douglas-fir may be planted.

Shelterwood with Reserves, Site Prep Burn - These treatments involve removing all trees except for 

those needed for shelter or seed production. Leave trees would be relatively uniformly spaced and would 

be Douglas-fir, western larch, ponderosa pine, and aspen at about 30-40 BA. All dead and live cut trees

considered merchantable, except as needed to meet other resource concerns, may be removed for 

utilization. Following removal, the area would be prescribe burned for site preparation. Expected 

regeneration would be Douglas-fir and lodgepole pine.

Shelterwood (Group) with Reserves, Slashing, Handpile/Burn – The shelterwood treatment would be 

as described previously for group shelterwoods with reserves. Leave trees are expected to be Douglas-fir. 

All dead and live cut trees considered merchantable, except as needed to meet other resource concerns, 

may be removed for utilization. Following cutting and removal, undesirable small trees would be cut, 

handpiled and burned. Expected regeneration would be Douglas-fir and lodgepole pine. 

Shelterwood (Group) with Reserves - The shelterwood treatment would be as described previously for 

group shelterwoods with reserves. Expected natural regeneration would be Douglas-fir and lodgepole 

pine. Ponderosa pine may be planted. All dead and live cut trees considered merchantable, except as 

needed to meet other resource concerns, may be removed for utilization. These units do include some area 

of ponderosa pine plantation that would be thinned.

Clearcut with Reserves, Jackpot Burn – These treatments involve removing all trees except for 

scattered Douglas-fir and ponderosa pine. All dead and live cut trees considered merchantable, except as 

needed to meet other resource concerns, may be removed for utilization. Natural regeneration of Douglasfir and lodgepole pine is expected. Ponderosa pine may be planted. Following cutting and removal, units 

would be jackpot burned.

Clearcut with Reserves, Site Preparation Burn – These treatments involve removing all trees except 

for scattered clumps of Douglas-fir, ponderosa pine and western larch. All dead and live cut trees 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

70

considered merchantable, except as needed to meet other resource concerns, may be removed for 

utilization. Natural regeneration of Douglas-fir and lodgepole pine is expected. Ponderosa pine, Douglasfir, and western larch may be planted. Following cutting and removal, units would be prescribed burned to 

prepare sites for regeneration.

Clearcut with Reserves, Broadcast Burn - These treatments involve removing all trees except scattered 

clumps or individual Douglas-fir for structure. All dead and live cut trees considered merchantable, 

except as needed to meet other resource concerns, may be removed for utilization. Following cutting, the 

area would be broadcast burned for fuels reduction and site preparation. Natural regeneration of lodgepole 

pine is expected. Douglas-fir and western larch may be planted. 

Sanitation, Slashing, Handpiling, Burn Piles – These treatments involve removing trees to improve 

stand health by stopping or reducing the actual or anticipated spread of insects and disease. In these units, 

all dead and dying trees considered merchantable would be cut and removed except as needed to meet 

other resource concerns. No additional live trees would be cut. Small, undesirable, damaged, or diseased 

trees would be cut, handpiled and burned. Following treatment, trees would average 10- to 15-foot 

spacing (194 to 436 TPA).

Mixed Severity Fire, Openings – These treatments would be burned with a mixed-severity fire, creating 

various sizes of openings depending upon forest type and site factors. Patches of trees may be cut in the 

units to facilitate burning as well as to enhance regeneration of whitebark pine and other species. 

Proposed Treatments by Group and Unit

Table B- 1. Alternative 2 proposed treatments by group and unit 

Group Unit Treatment Type Prescription Acres

1 6 Intermediate Harvest Improvement Cut, Underburn 14

1 7 Intermediate Harvest Improvement Cut, Underburn 17

1 8 Intermediate Harvest Improvement Cut, Underburn 62

1 15 Intermediate Harvest Improvement Cut, Underburn 15

1 23 Intermediate Harvest Improvement Cut, Underburn 29

1 24 Intermediate Harvest Improvement Cut, Underburn 5

1 26 Intermediate Harvest Improvement Cut, Underburn 65

1 28 Intermediate Harvest Improvement Cut, Underburn 22

1 30 Intermediate Harvest Improvement Cut, Underburn 14

1 31 Intermediate Harvest Improvement Cut, Underburn 16

1 32 Intermediate Harvest Improvement Cut, Underburn 45

1 33 Intermediate Harvest Improvement Cut, Jackpot Burn 17

1 44 Intermediate Harvest Improvement Cut, Underburn 97

1 45 Intermediate Harvest Improvement Cut, Underburn 38

1 46 Intermediate Harvest Improvement Cut, Jackpot Burn 251

1 47 Intermediate Harvest Improvement Cut, Jackpot Burn 220

1 54 Intermediate Harvest Improvement Cut, Jackpot Burn 20

1 55 Intermediate Harvest Improvement Cut, Underburn 29

2 3 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 37

2 14 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 11
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

71

Group Unit Treatment Type Prescription Acres

2 16 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 3

2 18 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 21

2 21 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 6

2 48 Intermediate Harvest Precommercial Thin 141

2 49 Intermediate Harvest Precommercial Thin 49

2 50 Intermediate Harvest Precommercial Thin 49

2 51 Intermediate Harvest Precommercial Thin 193

2 59 Intermediate Harvest Precommercial Thin 16

2 60 Intermediate Harvest Precommercial Thin 25

2 61 Intermediate Harvest Precommercial Thin 34

2 62 Intermediate Harvest Precommercial Thin 37

2 63 Intermediate Harvest Precommercial Thin 17

2 64 Intermediate Harvest Precommercial Thin 30

2 65 Intermediate Harvest Precommercial Thin 25

2 66 Intermediate Harvest Precommercial Thin 26

2 67 Intermediate Harvest Precommercial Thin 20

2 68 Intermediate Harvest Precommercial Thin 15

2 69 Intermediate Harvest Precommercial Thin 31

2 70 Intermediate Harvest Precommercial Thin 39

2 71 Intermediate Harvest Precommercial Thin 40

2 72 Intermediate Harvest Precommercial Thin 85

2 73 Intermediate Harvest Precommercial Thin 33

2 75 Intermediate Harvest Precommercial Thin 148

3 1 Regeneration Harvest Shelterwood (Group) with Reserves, Site Prep 

Burn 96

3 2 Prescribed Fire Low Severity Fire, Openings <5 Acres 146

3 9 Regeneration Harvest Seedtree with Reserves, Slashing, Handpiling, 

Burn Piles 18

3 11 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 23

3 12 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 80

3 13 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 41

3 20 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 32

3 22 Regeneration Harvest Shelterwood with Reserves, Site Prep Burn 30

3 25 Regeneration Harvest Seedtree with Reserves, Broadcast Burn 29

3 29 Regeneration Harvest Shelterwood (Group) with Reserves, Slashing, 

Handpile/Burn 25

3 34 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 12

3 39 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 42

3 40 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 11

3 41 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 12

3 42 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 65

3 43 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 104

3 53 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 17
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

72

Group Unit Treatment Type Prescription Acres

3 57 Regeneration Harvest Shelterwood (Group) with Reserves 93

3 58 Regeneration Harvest Shelterwood (Group) with Reserves 15

4 10 Regeneration Harvest Clearcut with Reserves, Jackpot Burn 18

4 17 Regeneration Harvest Clearcut with Reserves, Jackpot Burn 38

4 19 Regeneration Harvest Clearcut with Reserves, Jackpot Burn 15

4 27 Regeneration Harvest Clearcut with Reserves, Site Prep Burn 31

4 35 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 24

4 36 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 20

4 37 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 8

4 38 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 7

4 52 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 22

4 56 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 17

4 74 Regeneration Harvest Clearcut with Reserves, Site Prep Burn 23

5 4 Intermediate Harvest Sanitation, Slashing, Handpiling, Burn Piles 7

5 5 Intermediate Harvest Sanitation, Slashing, Handpiling, Burn Piles 18

6 76 Prescribed Fire Low Severity Fire, Openings <10 acres 123

6 78 Prescribed Fire Low Severity Fire, Openings <5 acres 38

6 85 Prescribed Fire Low Severity Fire, Openings <5 acres 143

7 80 Prescribed Fire Mixed Severity Fire, Openings <20 acres 326

7 86 Prescribed Fire Mixed Severity Fire, Openings <10 acres 47

7 87 Prescribed Fire Mixed Severity Fire, Openings <5 acres 36

8 77 Prescribed Fire Mixed Severity Fire, Openings <30 acres 736

8 79 Prescribed Fire Mixed Severity Fire, Openings <30 acres 337

8 81 Prescribed Fire Mixed Severity Fire, Openings <30 acres 629

8 82 Prescribed Fire Mixed Severity Fire, Openings <75 acres 776

8 83 Prescribed Fire Mixed Severity Fire, Openings <75 acres 457

8 84 Prescribed Fire Mixed Severity Fire, Openings <30 acres 831

8 88 Prescribed Fire Mixed Severity Fire, Openings <30 acres 892

Table B- 2. Alternative 3 proposed treatments by group and unit

Group Unit Treatment Type Prescription Acres

1 15 Intermediate Harvest Improvement Cut, Underburn 15

1 23 Intermediate Harvest Improvement Cut, Underburn 29

1 24 Intermediate Harvest Improvement Cut, Underburn 5

1 28 Intermediate Harvest Improvement Cut, Underburn 22

1 46b Intermediate Harvest Improvement Cut, Jackpot Burn, Handpiling, Burn 

Piles 27

1 47b Intermediate Harvest Improvement Cut, Jackpot Burn, Handpiling, Burn 

Piles 9

1 47c Intermediate Harvest Improvement Cut, Jackpot Burn, Handpiling, Burn 

Piles 31

1 6 Intermediate Harvest Improvement Cut, Underburn 14
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

73

Group Unit Treatment Type Prescription Acres

1 7 Intermediate Harvest Improvement Cut, Underburn 17

1 8 Intermediate Harvest Improvement Cut, Underburn 62

2 14 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 11

2 16 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 3

2 3 Intermediate Harvest Precommercial Thin, Handpiling, Burn Piles 37

2 48 Intermediate Harvest Precommercial Thin, Underburn 141

2 50 Intermediate Harvest Precommercial Thin 49

2 51 Intermediate Harvest Precommercial Thin, Underburn or Slash 

Treatment along PVT 193

2 59 Intermediate Harvest Precommercial Thin 16

2 61a Intermediate Harvest Precommercial Thin, Handpile Underburn 9

2 62 Intermediate Harvest Precommercial Thin 37

2 63 Intermediate Harvest Precommercial Thin 17

2 66 Intermediate Harvest Precommercial Thin 26

2 67 Intermediate Harvest Precommercial Thin 20

2 68 Intermediate Harvest Precommercial Thin 15

2 69 Intermediate Harvest Precommercial Thin 31

2 70 Intermediate Harvest Precommercial Thin 39

2 71 Intermediate Harvest Precommercial Thin 40

2 72 Intermediate Harvest Precommercial Thin 85

2 73 Intermediate Harvest Precommercial Thin 33

2 75b Intermediate Harvest Precommercial Thin, Jackpot Burn, Handpiling, 

Burn Piles 20

3 1 Regeneration Harvest Shelterwood (Group) with Reserves, Site Prep 

Burn 96

3 11 Regeneration Harvest Shelterwood (Group) with Reserves, Underburn 23

3 12 Regeneration Harvest Shelterwood (Group) with Reserves, Underburn 80

3 13 Regeneration Harvest Seedtree with Reserves, Jackpot Burn 41

3 22a Regeneration Harvest Shelterwood with Reserves, Site Prep Burn 22

3 25 Regeneration Harvest Seedtree with Reserves, Broadcast Burn 29

3 34 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 12

3 39 Regeneration Harvest Seedtree with Reserves, Underburn 26

3 40 Regeneration Harvest Seedtree with Reserves, Underburn 11

3 41 Regeneration Harvest Shelterwood (Group) with Reserves, Underburn 12

3 42 Regeneration Harvest Seedtree with Reserves, Underburn 65

3 43 Regeneration Harvest Seedtree with Reserves, Underburn 104

3 53 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 17

3 57 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 93

3 58 Regeneration Harvest Shelterwood (Group) with Reserves, Jackpot Burn 15

3 9 Regeneration Harvest Seedtree with Reserves, Slashing, Handpiling, 

Burn Piles 18

4 10 Regeneration Harvest Clearcut with Reserves, Underburn 18
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

74

Group Unit Treatment Type Prescription Acres

4 27 Regeneration Harvest Clearcut with Reserves, Site Prep Burn 31

4 35 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 24

4 36 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 20

4 37 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 8

4 38 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 7

4 52 Regeneration Harvest Clearcut with Reserves, Broadcast Burn 22

4 74 Regeneration Harvest Clearcut with Reserves, Site Prep Burn 23

5 4 Intermediate Harvest Sanitation, Slashing, Handpiling, Burn Piles 7

5 5 Intermediate Harvest Sanitation, Slashing, Handpiling, Burn Piles 18

6 2 Prescribed Fire Low Severity Fire, Openings <5 acres 146

6 78 Prescribed Fire Low Severity Fire, Openings <5 acres 38

6 85 Prescribed Fire Low Severity Fire, Openings <5 acres 143

7 87 Prescribed Fire Mixed Severity Fire, Openings <5 acres 36

8 79 Prescribed Fire Mixed Severity Fire, Openings <30 acres 337

8 82 Prescribed Fire Mixed Severity Fire, Openings <75 acres 776

8 83 Prescribed Fire Mixed Severity Fire, Openings <75 acres 457

8 84 Prescribed Fire Mixed Severity Fire, Openings <30 acres 831

8 88 Prescribed Fire Mixed Severity Fire, Openings <30 acres 865

9 17a Prescribed Fire Underburn 38

9 19a Prescribed Fire Underburn 15

9 20a Prescribed Fire Underburn 24

9 29a Prescribed Fire Underburn 25

9 30a Prescribed Fire Underburn 14

9 31a Prescribed Fire Underburn 16

9 32a Prescribed Fire Underburn 45

9 44a Prescribed Fire Underburn 97

9 45a Prescribed Fire Underburn 38

9 80a Prescribed Fire Jackpot Burn 326

10 46a Intermediate Harvest Improvement Cut, Jackpot Burn, Handpiling, Burn 

Piles 223

10 47a Intermediate Harvest Improvement Cut, Jackpot Burn, Handpiling, Burn 

Piles 180

Table B- 3. Treatment unit management area acreages

Unit MA Acres Unit MA Acres Unit MA Acres

1 T4 96 37 T3 8 63 T3 17

2 T4 146 38 T3 7 64 T3 30

3 T4 37 39 T3 42 65 T3 25

4 T4 7 40 T3 11 66 T3 26

5 T4 18 41 T3 11 67 T3 20
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

75

Unit MA Acres Unit MA Acres Unit MA Acres

6 T4 14 42 T2 39 68 T3 15

7 T4 17 42 T3 26 69 T3 31

8 T4 62 43 T2 104 70 T3 39

9 T4 18 44 T1 93 71 T3 40

10 T1 1 44 T3 4 72 T2 85

10 T3 5 45 T1 26 73 T4 33

10 T4 12 45 T3 12 74 T3 23

11 T1 22 46 T2 248 75 T2 148

12 T1 80 46 T3 3 76 T3 99

13 T1 7 47 M1 2 76 W1 24

13 T3 34 47 T2 218 77 T1 90

14 T1 10 48 M1 56 77 T3 619

15 T1 15 48 T2 85 78 T1 38

16 T1 3 49 M1 13 79 M1 267

17 T1 38 49 T2 37 79 T1 59

18 T1 21 50 M1 48 79 T3 7

19 T1 15 51 M1 19 79 W1 3

20 T1 32 51 T1 173 80 M1 318

21 T1 6 52 T3 22 80 W1 8

22 T3 30 53 T3 17 81 M1 583

23 T3 29 54 T3 20 81 T1 6

24 T3 5 55 T3 29 81 W1 40

25 T3 29 56 T3 17 82 M1 13

26 T3 65 57 T1 92 82 W1 763

27 T3 31 58 M1 6 83 M1 201

28 T3 17 58 T1 9 83 W1 256

28 T4 5 59 T3 16 84 M1 795

29 T4 25 60 T1 1 84 T1 28

30 T4 14 60 T3 22 84 T2 7

31 T4 16 60 T4 2 85 M1 143

32 T4 45 61 T3 21 86 M1 47

33 T3 17 61 T4 12 87 M1 25

34 T3 12 62 T3 21 87 T1 12

35 T3 24 62 T4 16 88 M1 740

36 T3 20 88 W1 124
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

76

Fuels Treatments

The MRFC discusses Forest Types and Fire Regimes and is quoted below:

The following briefly describes major forest ecotypes in Montana and ascribes to each an approximate 

historical fire regime and a very general picture of historical stand structure. Because there is overlap 

between each ecotype and no black and white distinctions in historical fire regimes or stand structures, 

these elements should be considered in the planning and design of restoration projects.

Restoration by Forest Type

Low-to-mid elevation ponderosa pine, Douglas-fir, and western larch forests typify the low- and mixedseverity fire regime with average fire return intervals of 5 to 30 years. 

Pure ponderosa pine experienced frequent, low-severity fires and primarily exhibited an open 

stand structure across the landscape. 

Mixed ponderosa pine/Douglas-fir/western Larch (in all combinations) forests exhibited less 

frequent fire, more variable stand structures across the landscape, and variable fire intensity and 

severity. 

Historically, these low elevation forests were subject to the greatest amount of timber 

management and fire suppression activities and thus are likely the furthest from their natural 

range of variability. 

These forest types are the most likely and appropriate candidates for restoration activities to reestablish natural fire return intervals, but especially in the case of mid-elevation mixed-fire 

severity forests, restoration activities should be taken on a case-by-case basis.

Mid-elevation lodgepole pine, Douglas-fir, and subalpine fir forests exhibit dense stand structures and 

historically experienced mixed and stand replacing fire regimes. 

Mixed fire regimes may be more widespread than stand replacement regimes in the Inland 

Northwest and have fire intervals averaging between 30 and 100 years. Stand replacement 

regimes have average natural return intervals of about 100 – 200 years. 

Mixed severity forest types were likely historically dominant and may not require any specific 

management activity to allow them to maintain function within their historic range of variability, 

but again they would have to be considered on a case by case basis.

High-elevation subalpine fir, lodgepole pine and Engelmann spruce forests historically experienced fire 

on a 200- to 300- year fire return interval where subalpine forests of whitebark pine historically 

experienced fire on a mean fire return interval of 50 – 300 years. These forest ecotypes are likely the 

closest to their natural range of variability and likely require minimal restoration efforts.

The treatment groups include both timber management and fuels management treatments. Treatment 

descriptions for the fuels management treatments are as follows:

Low-Severity Fire- is applied to meet fuel reduction objectives and reintroduce fire to the landscape. 

Low severity fire would topkill some of the understory vegetation, effects to soils would be minimal. 

Some over story canopy openings of less than 5 acres may be created with this treatment. Small diameter 

trees may be cut in areas to create a continuous fuel bed to carry the fire (included in treatment groups 6 

and 9).

Mixed Severity Fire- is applied to meet fuel reduction objectives and reintroduce fire to the landscape. 

Mixed severity fire would exhibit a wide range of effects on the vegetation. Some areas would result in 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

77

low severity fire effects; other areas would exhibit moderate fire severity with some over story mortality 

but not complete replacement; and yet other areas would result in higher severity fire resulting in 

complete over story mortality. Overstory canopy openings of various sizes would be created with this 

treatment. Small diameter trees may be cut in areas to create a continuous fuel bed to carry the fire 

(included in treatment group 8).

Hand pile/pile burning—fuels would be piled by hand and piles would be burned when burning 

conditions are favorable (included in treatment groups 2, 3, 5, 9, and 10).

Jackpot Burning—burning of concentrations of fuels within the unit. These concentrations occur from 

harvest operations, insect and disease activity or natural forest succession. This does not include burning 

of hand and machine piles included in treatment groups 1, 3, 4, 9, and 10).

Machine pile/pile burning—natural and residual activity generated fuels are piled using equipment to 

reduce fuel accumulations and preparesites for planting (where necessary). Piles are generally burned 

during the fall/winter when burning conditions are favorable and risk of escape is low. Sufficient down 

woody material is retained onsite to meet objectives for soil nutrient and habitat needs included in 

treatment groups 2, 3, and 5). 

Prescribed Under Burning- consists of controlled burning with flame lengths generally 3 feet or less and 

would be utilized as a stand-alone treatment or following thinning. Under burning would be used to 

reduce natural and activity fuels and shrubs and prepare sites for planning. Cutting and piling of ladder 

fuels may occur to reduce potential fire behavior and scorch to residual trees (included in treatment 

groups 1, 3, 4, and 9).

Site Prep Burn – Following harvest activity designated units would be under burned prior to tree 

planting (included in treatment groups 3 and 4.

Slashing—Cutting of small diameter conifers (less than 6 inches in diameter) using chainsaws. The 

treatment is conducted prior to burning to ensure there are sufficient surface fuels to carry the fire 

(included in treatment groups 3, 6, 7, and 8).

Silviculture Summary

Compliance with Forest Plan and Other Relevant Laws, Regulations, 

Policies and Plans

Alternative 1

Compliance of alternative 1 (no action) with Forest Plan forestwide standards pertinent to this discussion 

is displayed in Table B- 4. Note that forestwide standard statements refer to appendices in the Forest Plan 

and not of this document.

Table B- 4. Alternative 1 compliance with Forest Plan forestwide standards

FORESTWIDE STANDARDS COMPLIANCE

Timber

1. Silvicultural examinations and prescriptions 

will be required before any timber manipulation 

or silvicultural treatment takes place. 

Exceptions include cutting of trees that block 

vision along roads, cutting hazard trees, 

clearing right-of-way, clearing for mineral 

No timber manipulation or silvicultural 

treatment other than ongoing activities 

would take place under this alternative. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

78

FORESTWIDE STANDARDS COMPLIANCE

development, minor and incidental amounts of 

free use, and cutting personal firewood. Final 

determination of what silvicultural system will 

be used for a particular project will be made by 

a certified silviculturist after an on-the-ground 

site analysis. This site-specific analysis will 

determine the appropriate even or uneven age 

silvicultural system that best meets the goals 

and objectives of the management area. 

Standards for applying all silvicultural systems, 

as well as supporting research references are 

in the Northern Region guide (June 10, 1983). 

In addition, broad guidelines are found in 

Appendix H and M. Even aged management 

methods will be used only where it is 

determined to be appropriate to meet 

objectives. Clearcutting will be used only 

where it is the optimum method. 

2. Tree improvement will be conducted in 

accordance with the current Regional and 

Forest level tree improvement plans. 

No tree improvement activities would 

be conducted under this alternative.

4. Timber stand openings created by evenaged silvicultural systems will normally be 40 

acres or less. Creation of larger openings will 

require a 60-day public review and Regional 

Forester approval. Exceptions are listed in the 

Northern Regional Guide. 

No timber stand openings would be 

created by even-aged silvicultural 

systems under this alternative.

Protection 

Insect and 

Disease

1. Silvicultural systems will be the primary tool 

for preventative pest management. Use 

silvicultural systems to: (1) improve species 

diversity, growth, and vigor for stands and (2) 

increase the size diversity and class diversity 

between stands. 

No silvicultural systems would be 

proposed under this alternative.

2. During ongoing infestations, control insects 

and disease through silvicultural and biological 

practices. Chemical controls will be limited to 

high value areas or used on a broader scale 

only when all other measures have failed and 

other resource values can be protected. 

Emphasize cooperative control measures 

between Federal, State, and private 

landowners.

No activities would be proposed under 

this alternative.

3. Biological practices will be considered in 

controlling insect and disease infestations.

No activities would be proposed under 

this alternative.

4. If possible, harvest stands which are a high 

risk for mountain pine beetle attack before 

harvesting moderate or low risk stands.

No activities would be proposed under 

this alternative.

Wildfire 2. Locate timber sales, or cutting units within a 

sale, to break-up contiguous natural fuel.

No timber sales would be proposed 

under this alternative.

Wildlife/Snags

Larch, ponderosa pine, Douglas-fir, spruce, 

and subalpine fir, in that priority, are the 

preferred species for snags and replacement 

trees (live trees left to replace existing snags).

Tree mortality and potential snag tree 

species would continue as is under 

this alternative.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

79

Compliance of alternative 1 (no action) with Forest Plan management area standards pertinent to this 

discussion are displayed in Table B- 5.

Table B- 5. Alternative 1 compliance with management area standards

MANAGEMENT AREA STANDARDS COMPLIANCE

M-1

Timber - Timber harvest, such as salvage and firewood removal, may 

occur where access exists. Slash created by any management practice will 

be disposed of in a manner consistent with the management area goals. 

Forested lands are classified as unsuitable for timber management.

No timber harvest 

is proposed.

Protection - Salvage of dead, dying, or high-hazard trees is permitted to 

prevent disease and insect population build-up. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are stated in the Fire 

Management Direction in Appendix R.

-Evaluate areas periodically for significant insect and disease problems. 

Endemic levels will be accepted as normal. If epidemic levels develop and 

control is necessary, the control method should minimize impacts on 

watershed and other resource values.

No actions are 

taken to prevent 

disease and 

insect population 

build-up.

No prescribed fire 

is proposed for 

the enhancement 

and maintenance 

of resources.

No areas are 

evaluated for 

insect and 

disease 

problems.

T-1

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest practices include clearcut, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and silvicultural objectives. Precommercial thinning and intermediate 

harvest may occur where needed as determined by silvicultural objectives 

and project planning. (Appendices H and M of the Forest Plan provide 

broad guidelines for various habitat groups.) 

- As a minimum, a cutover area will not be considered an opening when: 

(1) a new forest stand is established and certified as stocked, and (2) 

vegetative conditions reach the point where harvest of additional timber 

can occur and the combined area can still meet watershed management 

objectives. 

- Prescribed burning or other techniques may be used for slash disposal, 

site preparation, silvicultural, and livestock objectives. In habitat groups 

where fire is not a useful treatment tool, lopping and scattering, yarding 

unmerchantable material (YUM), or other methods will be used to reduce 

fuel accumulations and prepare sites for regeneration. 

- Project level planning will provide for stand regeneration within five years 

of final harvest. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, management for experimental or 

research purposes and to meet other resource objectives. CMAI for 

primary species on the Helena National Forest is shown in Appendix H. 

No timber harvest 

activities are 

proposed.

Protection 

- Insect and disease control should emphasize reduction and prevention 

through timber harvest and timber stand improvement. The use of other 

approved integrated pest management techniques may be necessary at 

No forest 

protection 

measures are 

proposed.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

80

MANAGEMENT AREA STANDARDS COMPLIANCE

times. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling.

T-2

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes will be adjusted as necessary to 

meet big game winter range needs. Even- or uneven-aged silvicultural 

systems may be used. (Appendix M provides guidance for vegetative 

management practices by habitat groups.)

- Openings created by timber harvest should meet hiding cover 

requirements of big game before adjacent areas can be harvested. 

- Schedule sale activities outside winter periods (December 1 to May 15). 

- No more than 25 percent of the timber-perimeter around natural or 

artificial parks should be nonthermal cover at one time. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in 

Appendix H.

No timber harvest 

activities are 

proposed.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

No forest 

protection 

measures are 

proposed.

T-3

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes may be modified as necessary to 

achieve the management area goals.

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include salvage or sanitation harvest and 

management for experimental or research purposes and to meet other 

resource objectives. CMAI for primary species on the Helena National 

Forest is shown in Appendix H. Appendix M provides guidance for various 

vegetative management practices by habitat group.

- Stocking control may be maintained through precommercial and 

commercial thinnings. The timing and planning of thinning operations will 

be coordinated with a wildlife biologist.

- Vegetative diversity will be encouraged.

- Openings created by timber harvest will be reforested to the extent 

necessary to meet the hiding cover requirements of big game before 

harvesting adjacent areas.

No timber harvest 

activities are 

proposed.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions may be used in this management 

No forest 

protection 

measures are 

proposed.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

81

MANAGEMENT AREA STANDARDS COMPLIANCE

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

T-4

Timber - This management area is suitable for timber management 

activities. 

- Even-aged stands may be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in 

Appendix H. 

- Timber harvest practices include clearcutting, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and visual quality objectives. Precommercial thinnings and intermediate 

harvest will occur where needed as determined by silvicultural objectives, 

project planning, and visual quality objective. (Appendices H and M 

provide broad guidelines for various habitat groups.) 

- Openings created by timber harvest will be reforested to the point where 

harvest of adjacent timber can occur and the combined area can still meet 

the VQOs of the area. 

- Use timber harvest to rehabilitate existing harvest units, to improve the 

VQO. 

- Prescribed burning will be used to accomplish slash disposal, site 

preparation, and silvicultural objectives. In habitat groups where fire is not 

a useful treatment tool, loping and scattering, YUM yarding, or other 

methods will be used to reduce fuel accumulations and prepare sites for 

regeneration provided the area goals are met.

No timber harvest 

activities are 

proposed.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

No forest 

protection 

measures are 

proposed.

W-1

Timber - Timber will be harvested only if it can be used as a tool to 

maintain or enhance wildlife habitat values. Productive forest land is 

classified as unsuitable for timber management

No timber harvest 

activities are 

proposed.

Protection - Areas will be evaluated periodically for significant insect and 

disease problems. Endemic levels will be accepted as normal. If epidemic 

levels develop and control is necessary, the control method should 

minimize impacts on big game and other wildlife values. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are detailed in the 

Fire Management Direction in Forest Plan Appendix R.

- Prescribed fire may be used as a tool to reduce natural fuels and improve 

quantity and quality of wildlife forage.

No forest 

protection 

measures are 

proposed.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

82

Table B- 6 below displays this alternatives compliance with Forest Service management direction for 

regeneration harvest.

Table B- 6. Alternative 1 compliance with other Forest Service management direction

Management Direction Compliance

Suitability for timber production. No timber harvest, other than salvage sales or sales to 

protect other multiple-use values, shall occur on lands not suited for timber production (16 

USC 1604 (k)).

No timber harvests 

are proposed.

Prior to regeneration harvest, stands of trees must have generally reached CMAI of growth 

(FSH 1909.12, ch. 60; 16 U.S.C. 1604 (m)(1); FSM 1921.12f).

No regeneration 

harvest is proposed.

The size of harvest openings created by even-aged silviculture in the Northern Region will be 

normally 40 acres or less with some exceptions. Creation of large openings will require 60-

day public review and Regional Forester approval, with several exceptions including: “Where

natural catastrophic events such as fire, windstorms, or insect and disease attacks have 

occurred” (FSM 1900-2006-2; FSM R1 Supplement 2400-2001-2).

No regeneration 

harvest is proposed.

Clearcutting and Even-aged Management 916 USC 1604(g)(3)(F)): Insure that clearcutting ... 

and other cuts designed to regenerate an even-aged stand of timber will be used as a cutting 

method on National Forest System lands only where for clearcutting, it is determined to be the 

optimum method ... to meet the objectives and requirements of the relevant land management

plan.” “Clearcutting will be used only where it is the optimum method” (Helena Forest Plan, 

USDA Forest Service 1986).

No regeneration 

harvest is proposed.

Alternative 2

Compliance of alternative 2 with Forest Plan Forest-wide standards pertinent to this discussion are 

displayed in Table B- 7. Note that the forestwide standard statements refer to appendices in the Forest 

Plan and not in this document.

Table B- 7. Alternative 2 compliance with Forest Plan forestwide standards

Forestwide Standards Compliance

Timber

1. Silvicultural examinations and prescriptions 

will be required before any timber manipulation 

or silvicultural treatment takes place. 

Exceptions include cutting of trees that block 

vision along roads, cutting hazard trees, 

clearing right-of-way, clearing for mineral 

development, minor and incidental amounts of 

free use, and cutting personal firewood. Final 

determination of what silvicultural system will 

be used for a particular project will be made by 

a certified silviculturist after an on-the-ground 

site analysis. This site-specific analysis will 

determine the appropriate even or uneven-age 

silvicultural system that best meets the goals 

and objectives of the management area. 

Standards for applying all silvicultural systems, 

as well as supporting research references are 

in the Northern Region guide (June 10, 1983). 

In addition, broad guidelines are found in 

Appendix H and M. Even-aged management 

methods will be used only where it is 

determined to be appropriate to meet 

objectives. Clearcutting will be used only 

where it is the optimum method. 

Silvicultural exams and prescriptions 

would have been done and approved 

by a certified silviculturist. Site-specific 

analysis has been done to determine 

the optimum method of treatment. 

Clearcutting is being used where it is 

the optimum method. See project 

records.

2. Tree improvement will be conducted in 

accordance with the current Regional and 

Tree improvement would be conducted 

following the applicable Regional and 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

83

Forestwide Standards Compliance

Forest level tree improvement plans. Forest direction.

4. Timber stand openings created by evenaged silvicultural systems will normally be 40 

acres or less. Creation of larger openings will 

require a 60-day public review and Regional 

Forester approval. Exceptions are listed in the 

Northern Regional Guide. 

Proposed regeneration harvest units 

exceed 40 acres in seven units 

(appendix L). All of the units have 

been severely impacted by recent 

mountain pine beetle mortality and can 

be excepted from 60-day review and 

Regional Forester approval. The 

Stonewall Vegetation Project EIS 

process serves to notify the public and 

document the need for the unit size.

Protection 

Insect and 

Disease

1. Silvicultural systems will be the primary tool 

for preventative pest management. Use 

silvicultural systems to: (1) improve species 

diversity, growth, and vigor for stands and (2) 

increase the size diversity and class diversity 

between stands. 

Silvicultural systems are proposed in 

this alternative to meet the project 

purpose and need which includes 

species diversity, growth, and vigor for 

stands and size diversity and class 

diversity between stands.

2. During ongoing infestations, control insects 

and disease through silvicultural and biological 

practices. Chemical controls will be limited to 

high value areas or used on a broader scale 

only when all other measures have failed and 

other resource values can be protected. 

Emphasize cooperative control measures 

between Federal, State, and private 

landowners.

Silvicultural practices are proposed to 

address recent past, ongoing, and 

future insect and disease concerns. No 

insect and disease chemical controls 

are proposed.

3. Biological practices will be considered in 

controlling insect and disease infestations.

No biological practices are being 

considered beyond vegetation 

management.

4. If possible, harvest stands which are a high 

risk for mountain pine beetle attack before 

harvesting moderate or low risk stands.

Proposed timber harvests addressed 

recently impacted and high risk stands 

as well as those where treatment was 

considered necessary to meet the 

purpose and need for the project.

Wildfire 2. Locate timber sales, or cutting units within a 

sale, to break-up contiguous natural fuel. 

Cutting units were located to reduce 

current and potential fuels created as a 

result of the MPB epidemic and modify 

fuels to meet the purpose and need to 

modify fire behavior for community 

protection and to allow for the 

reestablishment of fire as a natural 

process on the landscape

Wildlife/Snags

Larch, ponderosa pine, Douglas-fir, spruce, 

and subalpine fir, in that priority, are the 

preferred species for snags and replacement 

trees (live trees left to replace existing snags).

Treatment design includes artificial 

and natural regeneration of ponderosa 

pine and western larch as well as 

retaining these species over several 

others in thinning operations. Larch 

and ponderosa pine would increase 

due to the treatments.

Compliance of alternative 2 with Forest Plan Management Area standards pertinent to this discussion are 

displayed in Table B- 8.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

84

Table B- 8. Alternative 2 compliance with management area standards

Management Area Standards Compliance

M-1

Timber - Timber harvest, such as salvage and firewood removal, may 

occur where access exists. Slash created by any management practice will 

be disposed of in a manner consistent with the management area goals. 

Forested lands are classified as unsuitable for timber management.

Six acres of Unit 

58 is proposed 

for a regeneration 

harvest due to 

high mortality. 

Slash would be 

treated through 

jackpot burning.

Protection - Salvage of dead, dying, or high-hazard trees is permitted to 

prevent disease and insect population build-up. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are stated in the Fire 

Management Direction in Appendix R.

-Evaluate areas periodically for significant insect and disease problems. 

Endemic levels will be accepted as normal. If epidemic levels develop and 

control is necessary, the control method should minimize impacts on 

watershed and other resource values.

The proposed 

regeneration 

harvest and 

jackpot burning is 

consistent with 

the removal of 

dead, dying or 

high-hazard trees 

and prescribed 

burning.

T-1

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest practices include clearcut, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and silvicultural objectives. Precommercial thinning and intermediate 

harvest may occur where needed as determined by silvicultural objectives 

and project planning. (Appendices H and M of the Forest Plan provide 

broad guidelines for various habitat groups.) 

- As a minimum, a cutover area will not be considered an opening when: 

(1) a new forest stand is established and certified as stocked, and (2) 

vegetative conditions reach the point where harvest of additional timber 

can occur and the combined area can still meet watershed management 

objectives. 

- Prescribed burning or other techniques may be used for slash disposal, 

site preparation, silvicultural, and livestock objectives. In habitat groups 

where fire is not a useful treatment tool, lopping and scattering, yarding 

unmerchantable material (YUM), or other methods will be used to reduce 

fuel accumulations and prepare sites for regeneration. 

- Project level planning will provide for stand regeneration within five years 

of final harvest. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, management for experimental or 

research purposes and to meet other resource objectives. CMAI for 

primary species on the Helena National Forest is shown in Appendix H. 

Proposed 

treatments are 

consistent with 

timber harvest 

practices, are 

determined by 

silvicultural 

objectives and 

project planning 

to meet the 

purpose and 

need. Prescribed 

burning is 

proposed where 

necessary for 

fuels reduction 

and site 

preparation. See 

table 25 below for 

regeneration and 

CMAI 

consistency.

Protection 

- Insect and disease control should emphasize reduction and prevention 

through timber harvest and timber stand improvement. The use of other 

approved integrated pest management techniques may be necessary at 

times. 

- - Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling.

The project 

purpose and 

need and 

proposed 

treatments 

address creating 

a landscape that 

is diverse, 

resilient and 

sustainable to 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

85

Management Area Standards Compliance

wildfire and 

insects.

T-2

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes will be adjusted as necessary to 

meet big game winter range needs. Even- or uneven-aged silvicultural 

systems may be used. (Appendix M provides guidance for vegetative 

management practices by habitat groups.)

- Openings created by timber harvest should meet hiding cover 

requirements of big game before adjacent areas can be harvested. 

- Schedule sale activities outside winter periods (December 1 to May 15). 

- No more than 25 percent of the timber-perimeter around natural or 

artificial parks should be nonthermal cover at one time. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in 

Appendix H.

Treatments 

would be 

adjusted to meet 

wildlife needs see 

wildlife design 

criteria (appendix 

P), and wildlife 

report.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

-- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

See T-1 above.

T-3

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes may be modified as necessary to 

achieve the management area goals.

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include salvage or sanitation harvest and 

management for experimental or research purposes and to meet other 

resource objectives. CMAI for primary species on the Helena National 

Forest is shown in Appendix H of the Forest Plan. Forest Plan Appendix M 

provides guidance for various vegetative management practices by habitat 

group.

- Stocking control may be maintained through precommercial and 

commercial thinnings. The timing and planning of thinning operations will 

be coordinated with a wildlife biologist.

- Vegetative diversity will be encouraged.

- Openings created by timber harvest will be reforested to the extent 

necessary to meet the hiding cover requirements of big game before 

harvesting adjacent areas.

Proposed 

treatments are 

modified to meet 

wildlife needs. 

See the see 

wildlife design 

criteria (appendix 

P), and wildlife 

report. The 

project purpose 

and need and 

proposed 

treatments 

address 

increasing 

vegetative 

diversity. See 

below for CMAI 

consistency.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

See T-1 above.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

86

Management Area Standards Compliance

activities will meet visual quality objectives.

T-4

Timber - This management area is suitable for timber management 

activities. 

- Even-aged stands may be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in Forest 

Plan Appendix H. 

- Timber harvest practices include clearcutting, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and visual quality objectives. Precommercial thinnings and intermediate 

harvest will occur where needed as determined by silvicultural objectives, 

project planning, and visual quality objective. (Forest Plan Appendices H 

and M provide broad guidelines for various habitat groups.) 

- Openings created by timber harvest will be reforested to the point where 

harvest of adjacent timber can occur and the combined area can still meet 

the VQOs of the area. 

- Use timber harvest to rehabilitate existing harvest units, to improve the 

VQO. 

- Prescribed burning will be used to accomplish slash disposal, site 

preparation, and silvicultural objectives. In habitat groups where fire is not 

a useful treatment tool, loping and scattering, YUM yarding, or other 

methods will be used to reduce fuel accumulations and prepare sites for 

regeneration provided the area goals are met.

Proposed 

treatments are 

consistent with 

timber harvest 

practices, are 

determined by 

silvicultural 

objectives and 

project planning 

to meet the 

purpose and 

need. Prescribed 

burning is 

proposed where 

necessary for 

fuels reduction 

and site 

preparation. 

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

See T-1 above.

W-1

Timber - Timber will be harvested only if it can be used as a tool to 

maintain or enhance wildlife habitat values. Productive forest land is 

classified as unsuitable for timber management

No timber harvest 

is proposed in W1.

Protection - Areas will be evaluated periodically for significant insect and 

disease problems. Endemic levels will be accepted as normal. If epidemic 

levels develop and control is necessary, the control method should 

minimize impacts on big game and other wildlife values. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are detailed in the 

Fire Management Direction in Forest Plan Appendix R.

- Prescribed fire may be used as a tool to reduce natural fuels and improve 

quantity and quality of wildlife forage.

Prescribed fire is 

proposed to meet 

purpose and 

need to increase 

species and 

structural 

diversity and 

landscape 

resilience to 

wildfire and 

insects. See 

wildlife design 

criteria in table 9, 

chapter 2 for

additional 

information.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

87

Table B- 9 that follows displays compliance with Forest Service management direction for regeneration 

harvest for alternative 2.

Table B- 9. Alternative 2 compliance with Forest Service regeneration harvest direction

Management Direction Compliance

Suitability for timber production. No timber 

harvest, other than salvage sales or sales to 

protect other multiple-use values, shall occur 

on lands not suited for timber production (16 

USC 1604 (k)).

All timber harvest would take place in land classified as suitable for 

timber harvest under the Helena Forest Plan (MA T-1, T-2, T-3, T-4) 

with the exception of six acres in Unit 58 which is in MA M-1 

(appendix J). All proposed treatments involving timber harvest are 

designed to meet the project purpose and need (stated above) and 

are not designed for timber production other than salvage. Timber 

harvest may occur in M-1 where access exists.

Prior to regeneration harvest, stands of trees 

must have generally reached CMAI of 

growth (FSH 1909.12, ch. 60; 16 U.S.C. 

1604 (m)(1); FSM 1921.12f).

Average CMAI for forests in the area ranges from 100 to 120 years 

(USDA Forest Service 1986 appendix H). Trees in most of the 

suitable units are of an age where they probably had reached CMAI 

(appendix K) however, the question of culmination of mean annual 

increment of growth in these units has been rendered moot by the 

severe levels of mortality. The units are not proposed for treatment 

for timber production purposes, but to restore the forests, modify fire 

behavior, and capture economic value of timber and so the CMAI 

growth requirement would not apply as stated above. 

The size of harvest openings created by 

even-aged silviculture in the Northern 

Region will be normally 40 acres or less with 

some exceptions. Creation of large openings 

will require 60-day public review and 

Regional Forester approval, with several 

exceptions including: “Where natural 

catastrophic events such as fire, windstorms, 

or insect and disease attacks have occurred” 

(FSM 1900-2006-2; FSM R1 Supplement 

2400-2001-2).

Proposed regeneration harvest units exceed 40 acres in seven units 

(appendix L). All of the units have been severely impacted by recent 

mountain pine beetle mortality and are exempt from 60-day review 

and Regional Forester approval as described in FSM 1900-2006-2. 

FSM R1 Supplement 2400-2001-2. The Stonewall Vegetation Project 

EIS 45-day comment period serves to notify the public and is 

sufficient in documenting the need for the unit size.

Clearcutting and Even-aged Management 

916 USC 1604(g)(3)(F)): Insure that 

clearcutting ... and other cuts designed to 

regenerate an even-aged stand of timber will 

be used as a cutting method on National 

Forest System lands only where for 

clearcutting, it is determined to be the 

optimum method ... to meet the objectives 

and requirements of the relevant land 

management plan.” “Clearcutting will be 

used only where it is the optimum method” 

(Helena Forest Plan, USDA Forest Service 

1986).

Proposed regeneration treatments utilize clearcutting with reserve 

trees in 11 units with severe mortality and few remaining live trees. 

Clearcutting has been determined to be the optimal method for 

regenerating these units to the desired seral species in order to meet 

the project purpose and need as documented in project records.

There is assurance that the lands can be 

adequately restocked within five years after 

final regeneration harvest (16 USC 

1604(g)(3)(E)(ii); FSM 1921.12g).

Each regeneration harvest treatment area has been field reviewed by 

a certified silviculturist and treatment designed to ensure that the 

stands can be adequately stocked following final harvest. Restocking 

would be through natural and artificial methods to levels established 

for each unit. As displayed in appendix G table 35, 3,842 acres 

regeneration harvest are recorded to have taken place in the project 

area. Examination of these past regeneration harvest units shows 

that regeneration success in the project area is very good. Stocking 

criteria would be established for each unit based upon site conditions, 

treatment objectives, and Forest Plan direction and would be 

documented in silvicultural prescriptions developed for the project. 

Regeneration treatments would be monitored (FSM 2472.4) to 

access treatment success and schedule additional corrective work if 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

88

Management Direction Compliance

the units are not adequately proceeding toward desired stocking 

guidelines.

Compliance of alternative 3 with Forest Plan Forestwide standards pertinent to this discussion is 

displayed in Table B- 10. 

Table B- 10. Alternative 3 compliance with Forest Plan forestwide standards

Forestwide Standards Compliance

Timber

1. Silvicultural examinations and prescriptions 

will be required before any timber manipulation 

or silvicultural treatment takes place. 

Exceptions include cutting of trees that block 

vision along roads, cutting hazard trees, 

clearing right-of-way, clearing for mineral 

development, minor and incidental amounts of 

free use, and cutting personal firewood. Final 

determination of what silvicultural system will 

be used for a particular project will be made by 

a certified silviculturist after an on-the-ground 

site analysis. This site-specific analysis will 

determine the appropriate even or uneven-age 

silvicultural system that best meets the goals 

and objectives of the management area. 

Standards for applying all silvicultural systems, 

as well as supporting research references are 

in the Northern Region guide (June 10, 1983). 

In addition, broad guidelines are found in 

Appendix H and M. Even-aged management 

methods will be used only where it is 

determined to be appropriate to meet 

objectives. Clearcutting will be used only 

where it is the optimum method. 

Silvicultural exams and prescriptions 

would have been done and approved 

by a certified silviculturist. Site-specific 

analysis has been done to determine 

the optimum method of treatment. 

Clearcutting is being used where it is 

the optimum method. See project 

records.

2. Tree improvement will be conducted in 

accordance with the current Regional and 

Forest level tree improvement plans. 

Tree improvement would be conducted 

following the applicable Regional and 

Forest direction.

4. Timber stand openings created by evenaged silvicultural systems will normally be 40 

acres or less. Creation of larger openings will 

require a 60-day public review and Regional 

Forester approval. Exceptions are listed in the 

Northern Regional Guide. 

Proposed regeneration harvest units 

exceed 40 acres in six units (appendix 

M). All of the units have been severely 

impacted by recent mountain pine 

beetle mortality and can be excepted 

from 60-day review and Regional 

Forester approval. The Stonewall 

Vegetation Project EIS process serves 

to notify the public and document the 

need for the unit size.

Protection 

Insect and 

Disease

1. Silvicultural systems will be the primary tool 

for preventative pest management. Use 

silvicultural systems to: (1) improve species

diversity, growth, and vigor for stands and (2) 

increase the size diversity and class diversity 

between stands. 

Silvicultural systems are proposed in 

this alternative to meet the project 

purpose and need which includes 

species diversity, growth, and vigor for 

stands and size diversity and class 

diversity between stands.

2. During ongoing infestations, control insects 

and disease through silvicultural and biological 

practices. Chemical controls will be limited to 

high value areas or used on a broader scale 

Silvicultural practices are proposed to 

address recent past, ongoing, and 

future insect and disease concerns. No 

insect and disease chemical controls 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

89

Forestwide Standards Compliance

only when all other measures have failed and 

other resource values can be protected. 

Emphasize cooperative control measures 

between Federal, State, and private 

landowners.

are proposed.

3. Biological practices will be considered in 

controlling insect and disease infestations.

No biological practices are being 

considered beyond vegetation 

management.

4. If possible, harvest stands which are a high 

risk for mountain pine beetle attack before 

harvesting moderate or low risk stands.

Proposed timber harvests addressed 

recently impacted and high risk stands 

as well as those where treatment was 

considered necessary to meet the 

purpose and need for the project.

Wildfire 2. Locate timber sales, or cutting units within a 

sale, to break-up contiguous natural fuel. 

Cutting units were located to reduce 

current and potential fuels created as a 

result of the MPB epidemic and modify 

fuels to meet the purpose and need to 

modify fire behavior for community 

protection and to allow for the 

reestablishment of fire as a natural 

process on the landscape

Wildlife/Snags

Larch, ponderosa pine, Douglas-fir, spruce, 

and subalpine fir, in that priority, are the 

preferred species for snags and replacement 

trees (live trees left to replace existing snags).

Treatment design includes artificial 

and natural regeneration of ponderosa 

pine and western larch as well as 

retaining these species over several 

others in thinning operations. Larch 

and ponderosa pine would increase 

due to the treatments.

Compliance of alternative 3 with Forest Plan management area standards pertinent to this discussion are 

displayed in Table B- 11.

Table B- 11. Alternative 3 compliance with management area standards

Management Area Standards Compliance

M-1

Timber - Timber harvest, such as salvage and firewood removal, may 

occur where access exists. Slash created by any management practice will 

be disposed of in a manner consistent with the management area goals. 

Forested lands are classified as unsuitable for timber management.

Six acres of Unit 

58 is proposed 

for a regeneration 

harvest due to 

high mortality. 

Slash would be 

treated through 

jackpot burning.

Protection - Salvage of dead, dying, or high-hazard trees is permitted to 

prevent disease and insect population build-up. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are stated in the Fire 

Management Direction in Appendix R.

-Evaluate areas periodically for significant insect and disease problems. 

Endemic levels will be accepted as normal. If epidemic levels develop and 

control is necessary, the control method should minimize impacts on 

The proposed 

regeneration 

harvest and 

jackpot burning is 

consistent with 

the removal of 

dead, dying or 

high-hazard trees 

and prescribed 

burning.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

90

Management Area Standards Compliance

watershed and other resource values.

T-1

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest practices include clearcut, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and silvicultural objectives. Precommercial thinning and intermediate 

harvest may occur where needed as determined by silvicultural objectives 

and project planning. (Appendices H and M of the Forest Plan provide 

broad guidelines for various habitat groups.) 

- As a minimum, a cutover area will not be considered an opening when: 

(1) a new forest stand is established and certified as stocked, and (2) 

vegetative conditions reach the point where harvest of additional timber 

can occur and the combined area can still meet watershed management 

objectives. 

- Prescribed burning or other techniques may be used for slash disposal, 

site preparation, silvicultural, and livestock objectives. In habitat groups 

where fire is not a useful treatment tool, lopping and scattering, yarding 

unmerchantable material (YUM), or other methods will be used to reduce 

fuel accumulations and prepare sites for regeneration. 

- Project level planning will provide for stand regeneration within five years 

of final harvest. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, management for experimental or 

research purposes and to meet other resource objectives. CMAI for 

primary species on the Helena National Forest is shown in Appendix H. 

Proposed 

treatments are 

consistent with 

timber harvest 

practices, are 

determined by 

silvicultural 

objectives and 

project planning 

to meet the 

purpose and 

need. Prescribed 

burning is 

proposed where 

necessary for 

fuels reduction 

and site 

preparation. 

Protection 

- Insect and disease control should emphasize reduction and prevention 

through timber harvest and timber stand improvement. The use of other 

approved integrated pest management techniques may be necessary at 

times. 

- - Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling.

The project 

purpose and 

need and 

proposed 

treatments 

address creating 

a landscape that 

is diverse, 

resilient and 

sustainable to 

wildfire and 

insects.

T-2

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes will be adjusted as necessary to 

meet big game winter range needs. Even- or uneven-aged silvicultural 

systems may be used. (Appendix M provides guidance for vegetative 

management practices by habitat groups.)

- Openings created by timber harvest should meet hiding cover 

requirements of big game before adjacent areas can be harvested. 

- Schedule sale activities outside winter periods (December 1 to May 15). 

- No more than 25 percent of the timber-perimeter around natural or 

artificial parks should be nonthermal cover at one time. 

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in Forest 

Plan Appendix H.

Treatments 

would be 

adjusted to meet 

wildlife needs see 

wildlife design 

criteria in table 9, 

chapter 2.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

91

Management Area Standards Compliance

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

-- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

See T-1 above.

T-3

Timber - This management area is suitable for timber management 

activities. 

- Timber harvest methods and volumes may be modified as necessary to 

achieve the management area goals.

- Even-aged stands will be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include salvage or sanitation harvest and 

management for experimental or research purposes and to meet other 

resource objectives. CMAI for primary species on the Helena National 

Forest is shown in Appendix H of the Forest Plan. Forest Plan Appendix M 

provides guidance for various vegetative management practices by habitat 

group.

- Stocking control may be maintained through precommercial and 

commercial thinnings. The timing and planning of thinning operations will 

be coordinated with a wildlife biologist.

- Vegetative diversity will be encouraged.

- Openings created by timber harvest will be reforested to the extent 

necessary to meet the hiding cover requirements of big game before 

harvesting adjacent areas.

Proposed 

treatments are 

modified to meet 

wildlife needs. 

See the see 

wildlife design 

criteria in table 9, 

chapter 2. The 

project purpose 

and need and 

proposed 

treatments 

address 

increasing 

vegetative 

diversity. See 

below for CMAI 

consistency.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions may be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

See T-1 above.

T-4

Timber - This management area is suitable for timber management 

activities. 

- Even-aged stands may be scheduled for final regeneration harvest when 

they generally have reached the culmination of mean annual increment 

(CMAI) of growth. Exceptions include thinning or other stand improvement 

measures, salvage or sanitation harvest, and management for 

experimental or research purposes and to meet other resource objectives. 

CMAI for primary species on the Helena National Forest is shown in Forest 

Plan Appendix H. 

- Timber harvest practices include clearcutting, group selection, and 

shelterwood harvest, depending on habitat group, physical site conditions, 

and visual quality objectives. Precommercial thinnings and intermediate 

harvest will occur where needed as determined by silvicultural objectives, 

project planning, and visual quality objective. (Forest Plan Appendices H 

and M provide broad guidelines for various habitat groups.) 

- Openings created by timber harvest will be reforested to the point where 

harvest of adjacent timber can occur and the combined area can still meet 

the VQOs of the area. 

- Use timber harvest to rehabilitate existing harvest units, to improve the 

Proposed 

treatments are 

consistent with 

timber harvest 

practices, are 

determined by 

silvicultural 

objectives and 

project planning 

to meet the 

purpose and 

need. Prescribed 

burning is 

proposed where 

necessary for 

fuels reduction 

and site 

preparation. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

92

Management Area Standards Compliance

VQO. 

- Prescribed burning will be used to accomplish slash disposal, site 

preparation, and silvicultural objectives. In habitat groups where fire is not 

a useful treatment tool, loping and scattering, YUM yarding, or other 

methods will be used to reduce fuel accumulations and prepare sites for 

regeneration provided the area goals are met.

Protection - Insect and disease control should emphasize reduction and 

prevention through timber harvest and timber stand improvement. The use 

of other approved integrated pest management techniques may be 

necessary at times. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Fuel reduction methods for activity created fuels include burning, 

removing residue, or rearranging, such as dozer trampling. Disposal 

activities will meet visual quality objectives.

See T-1 above.

W-1

Timber - Timber will be harvested only if it can be used as a tool to 

maintain or enhance wildlife habitat values. Productive forest land is 

classified as unsuitable for timber management

No timber harvest 

is proposed in W1.

Protection - Areas will be evaluated periodically for significant insect and 

disease problems. Endemic levels will be accepted as normal. If epidemic 

levels develop and control is necessary, the control method should 

minimize impacts on big game and other wildlife values. 

- Prescribed fire with planned ignitions will be used in this management 

area, for the enhancement and maintenance of resources. 

- Prescribed fire with unplanned ignitions may be used in this management 

area, for the enhancement and maintenance of resources, when within 

pre-established prescribed fire criteria. These criteria are detailed in the 

Fire Management Direction in Forest Plan Appendix R.

- Prescribed fire may be used as a tool to reduce natural fuels and improve 

quantity and quality of wildlife forage.

Prescribed fire is 

proposed to meet 

purpose and 

need to increase 

species and 

structural 

diversity and 

landscape 

resilience to 

wildfire and 

insects. See 

wildlife design 

criteria in table 9, 

chapter 2 for 

additional 

information.

Table B- 12 below displays compliance with Forest Service management direction for regeneration 

harvest for alternative 3.

Table B- 12. Alternative 3 compliance with Forest Service regeneration harvest direction

Management Direction Compliance

Suitability for timber production. No timber 

harvest, other than salvage sales or sales to 

protect other multiple-use values, shall occur 

on lands not suited for timber production (16 

USC 1604 (k)).

All timber harvest would take place in land classified as suitable for 

timber harvest under the Helena Forest Plan (MA T-1, T-2, T-3, T-4) 

with the exception of six acres in Unit 58 which is in MA M-1 

(appendix J). All proposed treatments involving timber harvest are 

designed to meet the project purpose and need (stated above) and 

are not designed for timber production other than salvage. Timber 

harvest may occur in M-1 where access exists.

Prior to regeneration harvest, stands of trees 

must have generally reached CMAI of 

growth (FSH 1909.12, ch. 60; 16 U.S.C. 

1604 (m)(1); FSM 1921.12f).

Average CMAI for forests in the area ranges from 100 to 120 years 

(USDA Forest Service 1986 appendix H). Trees in most of the 

suitable units are of an age where they probably had reached CMAI 

(appendix K) however, the question of culmination of mean annual 

increment of growth in these units has been rendered moot by the 

severe levels of mortality. The units are not proposed for treatment 

for timber production purposes, but to restore the forests, modify fire 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

93

Management Direction Compliance

behavior, and capture economic value of timber and so the CMAI 

growth requirement would not apply as stated above. 

The size of harvest openings created by 

even-aged silviculture in the Northern 

Region will normally be 40 acres or less with 

some exceptions. Creation of large openings 

will require 60-day public review and 

Regional Forester approval, with several 

exceptions including: “Where natural 

catastrophic events such as fire, windstorms, 

or insect and disease attacks have occurred” 

(FSM 1900-2006-2; FSM R1 Supplement 

2400-2001-2).

Proposed regeneration harvest units exceed 40 acres in seven units. 

All of the units have been severely impacted by recent mountain pine 

beetle mortality and are exempt from 60-day review and Regional 

Forester approval as described in FSM 1900-2006-2. FSM R1 

Supplement 2400-2001-2. The Stonewall Vegetation Project EIS 45-

day comment period serves to notify the public and is suffice in 

documenting the need for the unit size.

Clearcutting and Even-aged Management 

916 USC 1604(g)(3)(F)): Insure that 

clearcutting ... and other cuts designed to 

regenerate an even-aged stand of timber will 

be used as a cutting method on National 

Forest System lands only where for 

clearcutting, it is determined to be the 

optimum method ... to meet the objectives 

and requirements of the relevant land 

management plan.” “Clearcutting will be 

used only where it is the optimum method” 

(Helena Forest Plan, USDA Forest Service 

1986).

Proposed regeneration treatments utilize clearcutting with reserve 

trees in 8 units with severe mortality and few remaining live trees. 

Clearcutting has been determined to be the optimal method for 

regenerating these units to the desired seral species in order to meet 

the project purpose and need as documented in project records.

There is assurance that the lands can be 

adequately restocked within five years after 

final regeneration harvest (16 USC 

1604(g)(3)(E)(ii); FSM 1921.12g).

Each regeneration harvest treatment area has been field reviewed by 

a certified silviculturist and treatment designed to ensure that the 

stands can be adequately stocked following final harvest. Restocking 

would be through natural and artificial methods to levels established 

for each unit. As displayed, 3,842 acres of regeneration harvest is

recorded to have taken place in the project area. Examination of 

these past regeneration harvest units shows that regeneration 

success in the project area is very good. Stocking criteria would be 

established for each unit based upon site conditions, treatment 

objectives, and Forest Plan direction and would be documented in 

silvicultural prescriptions developed for the project. Regeneration 

treatments would be monitored (FSM 2472.4) to access treatment 

success and schedule additional corrective work if the units are not 

adequately proceeding toward desired stocking guidelines

Data Sources

The following are short discussions of data sources used for this analysis.

Aerial Insect and Disease Detection Survey (ADS)

Aerial Insect and Disease Detection Survey (ADS) data for Region 1 is collected annually by the USDA 

Forest Service Region 1 and 4 Forest Health Protection Aviation Program (USDA Forest Service 2011). 

The purpose of the ADS program is to: 

Detect new outbreaks or identify previously undetected outbreaks of forest pests 

Monitor existing outbreaks 

Provide timely information for management planning 

Provide information for forest health assessments and project plans.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

94

The surveys are conducted primarily using fixed-wing aircraft that fly patterns over survey areas 

beginning in the first part of July and continue through the end of September and often into October. 

During the flights, personnel sketches the observed insect and disease damage and mortality spatial 

locations and estimates the degree of the damage (trees per acre affected), the insect or disease causing 

the damage or mortality, and the tree species being affected. 

The ADS is conducted according to well-established and documented survey standards (USDA Forest 

Service 1999). The results of the survey are digitized into GIS layers following established procedures 

(USDA Forest Service 2005). The GIS layers produced from the surveys are used in this analysis.

Because the ADS data relies on ocularly estimated insect and disease damaging agent, degree of damage 

or mortality, and spatial location, the information is useful for detecting, describing and analyzing insect 

and disease damage and establishing trends on a landscape over time. However, due to limitations in the 

ocular estimation process, care should be taken in applying the ADS at a stand, or smaller, degree of 

resolution.

Northern Region Vegetation Map (R1 VMap)

Region 1, Northern Region Vegetation Map (R1 VMap) data is derived from satellite imagery, and 

provides consistent and continuous data at several levels of accuracy and utility as part of the R1 Multilevel Vegetation Classification, Mapping, Inventory, and Analysis System (R1-CMIA, Berglund et al. 

2009). The R1-CMIA data collection program meets the requirements of the Existing Vegetation 

Classification and Mapping Technical Guide, which describes agency data needs, vegetation classification 

standards, and mapping standards (Brohman and Bryant 2005). Levels of accuracy in the VMap data 

include: (1) broad-level data used for forest, multi-forest, and regional-level assessments, (2) mid-level 

data which is intended to support forest and district integrated vegetation treatment plans, and (3) baselevel data which is meant to be used for stand-level analysis purposes (Berglund et al. 2009). The VMap 

data used in the Stone-Dry EWAS (Milburn et al. 2006) and the Stonewall project is mid-level data that 

has been edited in 2010 and 2011 to reflect changes in vegetation attributes due to (1) recent wildfires, (2) 

site- and stand-specific data, and (3) the recent bark beetle epidemic (USDA Forest Service 2011). 

Attributes in the VMap data used in this analysis includes tree dominance type, tree canopy cover class, 

tree size class.

National Agriculture Imagery Program (NAIP)

The National Agriculture Imagery Program (NAIP) acquires aerial imagery during the agricultural 

growing seasons in the continental U.S. NAIP imagery used in the Stonewall Vegetation Project was 

acquired in 2009, and is 1-meter resolution available in color or infrared.

Fire Regime Condition Class (FRCC)

Fire Regime Condition Class (FRCC) is an interagency, standardized tool for determining the degree of 

departure from reference condition vegetation, fuels and disturbance regimes (FRCC 2005). Helena NF 

personnel classified vegetation and analyzed FRCC for the Stone Dry EWAS (Milburn et al. 2006, 2009). 

VMap data served as the spatial database for the FRCC analysis. The spatial data and FRCC analysis was 

updated for the Stonewall project analysis (Olsen 2010). For the Stonewall Vegetation Project, we used 

attributes from the updated FRCC analysis spatial data for biophysical setting.

Stand Data and Silvicultural Diagnoses

Individual stand attributes and detailed silvicultural diagnoses were done in the field in 2008, and updated 

in 2009 for proposed treatment units. Information collected for each includes: tree species composition, 

tree stocking levels, understory species compositions and coverage, insect activity, disease presence, 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

95

vigor, mortality, past harvest, snag availability, and other pertinent information. Personnel measured and 

recorded selected stand attributes in informal plots (non-statistical). The Forest silviculturist performed 

most diagnoses in person, although several were done by another certified silviculturist and a forester, 

under the direction of the Forest silviculturist. Diagnoses represent the most current on-the-ground 

assessment of all proposed units.

Forest Inventory and Analysis (FIA) and FIA Intensification Plots

The Forest Inventory and Analysis (FIA) Program of the USDA Forest Service serves as the Nation's 

continuous forest census (USDA Forest Service 2011b). The program has established a set of permanent 

plots on a national grid that can be measured to characterize changes in forest attributes over time. Forest 

Inventory and Analysis plots are used at the Forest and landscape scales to set the context for forest 

conditions and effects, and assessments of insect hazard. Forest Inventory and Analysis plots are 

maintained at the National level on a periodic remeasurement schedule. In Region 1, FIA plots have been 

used to estimate the amount of old growth forest and snag density (Czaplewski 2004). The R1 Summary 

Database, using the NRIS Access Tool, was used to summarize Forest and landscape FIA and grid 

intensification data. This database is continually updated and was used to derive estimates of snags, old 

growth habitat types, and insect hazard ratings and forest structure characteristics. The use and limitations 

of this database is documented (USDA Forest Service 2008).

Models and Assumptions

Forest Vegetative Simulator

The Forest Vegetation Simulator (FVS) was developed in the early 1970’s as the “Prognosis” model

(Stage 1973). Since that time, FVS has undergone continual and continuing research and development 

efforts to expand FVS’s range and capabilities, validate, update, and modify FVS’s predictions, and 

increase the FVS program’s usefulness and usability. Over the last three decades, the USDA Forest 

Service has invested a substantial amount annually on research and development of FVS, and are 

continuing to do so within the Forest Service and through partnerships with educational institutions, other 

government agencies, and other countries (USDA 2011c).

Currently, the FVS is used almost exclusively by the USDA Forest Service, and is used heavily by other 

US government agencies such as the Bureau of Land Management, Bureau of Indian Affairs, National 

Park Service, Natural Resource Conservation Service, Army Corps of Engineers, Fish and Wildlife 

Service, Department of Defense, and Department of Energy. At least five state forestry agencies utilize 

FVS and it is heavily used in the private forestry sector. Most major university forestry programs in the 

US teach the use of FVS.

International use of FVS includes use in the Canadian provinces of British Columbia, Ontario, Alberta 

and Nova Scotia. FVS is also being used, or variants are being developed for use in Russia, China, 

Austria, South Korea, Japan, Costa Rica, Portugal, Indonesia, and the United Kingdom as well as other 

European countries.

Over the last several decades, the Forest Vegetation Simulator has become the most used forest vegetation 

modeling program in the United States and the world.

The Forest Vegetation Simulator is the product of hundreds of contributors over the past three decades 

(Dixon 2010). It is not a single growth and yield “model” but consists of a number in integrated models 

including those for predicting large-tree height and diameter increment, small-tree height and diameter 

increment, tree mortality, crown change, tree regeneration establishment, shrub development, shrub and 

tree vertical canopy distribution, mountain pine beetle risk, Douglas-fir tussock moth hazard and impacts, 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

96

economic analysis, western spruce budworm hazard and impacts, western root disease impacts, dwarf 

mistletoe impacts, white pine blister rust impacts, and fire effects.

The Forest Vegetation Simulator has expanded its range of applicability from its original Northwest US 

roots through the creation of “geographic variants” that utilize research from various geographic regions 

of the US to tailor equations such as those for tree growth, mortality and volume to those regions. There 

are currently over 20 variants representing forests within the US. In developing some the variants, the 

Forest Vegetation Simulator has evolved from a growth and yield model into a framework supporting 

regional models such as TWIGS (Miner et al. 1988) and GENGYM (Edminster et al.1991) further 

incorporating the extensive research undertaken in developing these models into FVS.

Since FVS uses stand exam data, geographical variant equations for growth are further calibrated using 

the stand data. This calibration process, coupled with the use of site variables such as slope, aspect, 

elevation, habitat type, plant association or ecoclass code, location (nearest National Forest, and in some 

cases Ranger District), site index, and stand density index maximums or basal area maximums, and tree 

measurements such as species, diameter-at-breast-height, total tree height, tree height to a dead or broken 

top, diameter increment, age, crown ratio, and damages or diseases, enables FVS to make very accurate 

individual tree and stand-level growth and yield predictions.

Dixon (2010) describes FVS as “a semi-distant-independent individual tree growth and yield model”. He 

considers it semi-distant-independent because certain parts of FVS localize competition and site variables 

to a plot (or point) basis within a stand where other parts do not. Because FVS uses stand exam data, it 

keeps track of the plot on which trees are located enabling the user to simulate group selection or 

differentially treat a stand based on density within a stand. One must realize when one is modeling 

treatment simulations based upon plots that although the plots may be modeled independently in FVS, the 

FVS outputs will still be showing the average of all trees on all plots. Portions of the FVS that do not 

model on a plot basis are the VSS classification module and the Fire and Fuels Extension.

Fire Fuels Extension

Fire behavior and effects are modeled in FVS through the Fire and Fuels Extension (FFE) which 

simulates fuel dynamics and potential fire behavior over time in the context of stand development and 

management (Reinhardt and Crookston 2003). The Fire and Fuels Extension models changes to surface 

and crown fuels over time due to treatments. Surface fuels attributes include tons-per-acre of fuels by 

fuels size class. Crown fuels attributes modeled include crown bulk density (CBD) and canopy base 

height (CBH). The FFE uses existing fire fuel models for fire behavior and effects and adds new 

submodels for snag and fuel dynamics. The FFE uses Rothermel’s (1972) fire behavior model as 

implemented by Albini (1976) in FIREMOD and subsequently by Andrews (1986) in Behave to predict 

fire intensity, approaches developed by Van Wagner (1973, 1977) and Scott and Reinhardt (2001) to 

predict the onset of crowning, and methods from FOFEM (Reinhardt et al. 1997) for predicting tree 

mortality, fuel consumption and smoke production.

Limitations of the Models

“It should be noted a model is a simplification or approximation of reality and hence will not reflect all of 

reality” (Stratton 2006). The use of models such as FVS depends upon sample data, validity of the model 

itself and assumptions made by the modeler. All three affect the results. The use of FVS in this analysis is 

to generally characterize and display existing conditions and the nature and magnitude of treatment 

effects to inform decisions to be made. The modeling results are not to be taken as reality. 

Historic Stand Conditions

Historic stand structures and species compositions were shaped by a number of factors including 

climate/weather, site conditions, and the historic fire regime. These factors determined whether any one 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

97

fire, whether naturally or artificially ignited, would burn any particular forested patch and how severe the 

fire would be when it burned the patch. Dryer sites such as south-facing slopes tended to burn more 

frequently which resulted in lower downed woody fuel loads, a higher occurrence of herbaceous 

understory vegetation, and forests dominated by trees that are relatively resistant to fire, such as 

ponderosa pine and larger Douglas-fir (Wright and Bailey 1982, Agee 1993, Arno 2000, Beaty and Taylor 

2001, Beaty and Taylor 2007). Moister sites tended to burn less frequently in what can be called “mixedseverity” fire regimes which may consist of a combination of understory and stand-replacement fires such 

as the seral ponderosa pine-western larch forests in western Montana that were burned with standreplacement fires at long intervals (150+ years) with nonlethal fires at short intervals (20 to 30 years 

average (Arno 2000) or mixed-severity fire regimes could consist of fires that tended to burn with a finegrained pattern, killing a large portion of the fire-susceptible species but sparing many of the fire-resistant 

trees (Arno 2000). The coolest and moistest sites tended to burn with stand-replacing fire regimes. 

A number of studies have displayed stand structures and species compositions in terms of diameter 

distribution charts. Available studies include: 

In western Montana, Arno et al. (1995) found that most old growth ponderosa pine/Douglas-fir plots 

sampled had burned with frequent (13 to 50 year intervals) non-lethal underburns prior to 1900. They 

attributed the fire regime to having maintained open, nearly all-aged stands (Arno et al. 1995). Tree 

species composition and diameter distribution charts for these plots show mixed-species stands 

dominated by ponderosa pine with western larch and Douglas-fir as a co-dominant in lesser and 

varying presence, and lodgepole as a minor species with stand diameter distributions being very flat 

except for the smaller size classes which displayed increased tree numbers due to fire exclusion. They 

did find one plot containing even-aged ponderosa pine and western larch which they related to a pre1900 fire history characterized by patchy stand-replacing events at intervals of 150 or more years. 

Tree species composition and diameter distribution chart for this plot shows a mixed-species stand

dominated by ponderosa pine with western larch and Douglas-fir as co-dominants, and lodgepole as a 

minor species with a diameter distributions having a prominent “peak” at 16-18 inches d.b.h., 

characteristic of an even-aged stand. Arno et al. (1995) in their western Montana study found that in 

recent years, all stands had developed an understory of Douglas-fir which they related to fire 

exclusion. 

Holden et al. (2007) in studying tree density, diameter-class distribution, and stocking levels among 

areas that had burned under two different fire frequencies since 1972 in New Mexico stands found 

that more frequent burns resulted in more open stands with fewer small trees. They display tree 

diameter distributions that are almost flat compared to the unburned control stand diameter 

distributions in which TPA increases greatly with decreasing tree diameter.

Fulé and Covington (1997) studied fires regimes and forest structures in the Sierra Madre occidental 

and displayed diameter distributions showing almost flat distributions for burned sites as opposed to 

increasing numbers of small trees and increases in fire-susceptible species at unburned sites.

Minnich et al. (2000) displays diameter distributions for six forest types in the Sierra San Pedro 

Martir under un-managed fire regimes, showing flat diameter distributions for all forest types and 

dominance by fire-resistant species.

Minnich et al. (1995) studied forest stem densities from data collected on plots in 1932 and 1992 and 

displayed diameter distributions for the historic measurements to be relatively flat and from the 1992 

measurements to have substantial numbers of small trees, which he attributed to forest densification 

due to fire exclusion. They also displayed increases in understory shade tolerant and fire-susceptible 

trees over time. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

98

As the studies above indicate, for any combination of fire-resistant and fire-susceptible tree species, 

frequent fire regimes will result in stands that tend to be uneven-aged, multi-story with open understories 

and slightly sloping to flat diameter distributions. 

Bark Beetles and Fires

Work in a variety of forest systems has generally shown that measures of fire intensity and severity are 

positively associated with tree susceptibility to bark beetle attack (Ryan and Amman 1996, Bradley and 

Tueller 2001, Sullivan et al. 2003, McHugh et al 2003, Wallin et al. 2003, Six and Skov 2009). Factors 

most mentioned in these studies include: crown scorch volume, cambial damage (bole char), root damage, 

stocking level, and tree size. 

Fire damage to trees is determined by characteristics of the fire and of the trees. The height of crown 

scorch is determined by fire-line intensity, wind speed, and air temperature (Van Wagner 1973) as well as 

tree characteristics such as needle size, bud mass, and crown volume. Tree bole cambial and root damage 

by fires is related to the intensity and duration of heat on tree bases and roots and tree bark thickness and 

root depth (Ryan and Reinhardt 1988). Tree characteristics tend to be linked, with shallow-rooted conifers 

tending to have thin bark and conversely deeper-rooted trees tending to have thicker bark. Younger trees 

tend to have both thinner bark, and lower crowns. Young Douglas-fir tend to have relatively thin bark and 

small thin needles with compact crowns that are heated quickly and so are less fire-tolerant than small 

ponderosa pine with their thicker, platy bark, thicker, linger needles and open crown structures. Larger 

Douglas-fir are relatively fire resistant with thick bark.

In this discussion, we will address the effects of burning by wildfires and controlled prescribed burns on 

Douglas-fir beetle (DFB) and mountain pine beetle (MPB) mortality.

Mountain Pine Beetle

Elkin and Reid (2004) studied attack and reproductive success of MPB in fire-damaged lodgepole pines 

and found that beetle attack preference or reproductive success was not affected by fire damage. They 

suggested that fire damage only affects mountain pine beetle reproduction and population growth in areas 

where attack densities are low otherwise fire damage will have negligible effects on beetle attack and 

reproductive success.

In western Montana, Six and Skov (2009) studied the response of bark beetles and their natural enemies 

to prescribed burning-only, thinning-only, and thinning-and-prescribed-burning treatments in mixedconifer forests in western Montana. They observed no increase in MPB due to the treatments. They 

attributed that to mountain pine beetles preference for relatively vigorous trees and its ability to maintain 

outbreaks in such, reflected in avoidance of burned trees

Douglas-fir Beetle

The link between fire damage and Douglas-fir beetle attack has been identified for many years, and there 

are a number of studies concerning DFB increases following wildfires but the number concerning DFB 

increases following low-intensity and severity prescribed burns is limited. 

Furniss (1965) examined the susceptibility of fire-injured Douglas-fir to bark beetle attack in Southern 

Idaho following the Poverty Flat Fire (920 acres). The Poverty Flat Fire burned as a relatively intense fire 

during dry weather on steep slopes. He found that 70 percent of the trees in his plots had been attacked by 

the Douglas-fir beetle one year after the fire. Even small or lightly burned trees were being attacked and 

the incidence of attack increased with the size of tree and severity of crown and cambium fire injury. He 

mentioned that due to the nature of the burn the number attractive, fire-damaged trees were plentiful.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

99

Ryan and Amman (1996) found that the relationship between bark beetle attack and tree damage in areas 

affected by the 1988 Yellowstone Fire indicated that stress resulting from fire injury led to increased bark 

beetle activity. They observed that bark beetle populations appeared to have increased in fire-injured trees 

and then infested uninjured trees. The 1988 Yellowstone fire was a fall wildfire that burned under 

relatively severe fire conditions, the result being a large fire and an abundance of fire-injured trees. They 

also suggested that droughty conditions prior to the fire had resulted in relatively stressed trees and high 

Douglas-fir populations prior to the fire which contributed to the post-fire population increases.

Cunningham et al. (2005) studied Douglas-fir beetle attack on a range of fire-injured Douglas-fir and 

found that one year after the fire event the DFB selected and attacked large-diameter Douglas-fir with 60-

80 percent bole char and 60-80 percent crown volume scorch. The following year beetle preference 

shifted to smaller trees with lighter fire injury because most of the larger trees had already been colonized 

the previous year. In the third year host selection shifted to green trees along the burn perimeter but beetle 

populations did not reach outbreak levels. The burn was an August wildfire. 

Hood and Bentz (2007) found in their study of post-fire Douglas-fir beetle attacks and tree mortality that 

beetles attacked trees with greater crown scorch, but that beetle attack and mortality was also related to 

cambium damage and stand stocking. They noted that trees within their Yellowstone data set that died 

within 4 years after the Yellowstone wildfire had greater crown scorch (52 percent versus 22 percent) and 

cambium damage (2.9 versus 2.2 tree base quadrants damaged) than live trees. 

Hood and Bentz (2007) also included in their study data from a prescribed fire in Western Montana. In 

that data they found that dead trees had greater crown scorch (68 percent versus 15 percent) and cambium 

injury (2.9 versus 0.5 quadrants damaged). They also noted that only 2 percent of the trees in the 

prescribed burn were attacked by Douglas-fir beetles. 

In western Montana, Six and Skov (2009) studied the response of bark beetles and their natural enemies 

to prescribed-burning-only, thinning-only, and thinning-and-prescribed-burning treatments in mixedconifer forests. They describe their burns as being in late spring with relative humidities of 20-48 percent 

and flame lengths of 0.2 to 1.2 m (0.7-3.9 feet) in the burn-only treatment and 0.2 to 2.7 m (0.7-8.9 feet) 

in the thin-and-burn treatment. Their fires were relatively patchy with some areas burning fairly hot 

resulting in considerable mortality of small diameter trees, while other areas remained relatively 

untouched. The thin-and-burn treatments were less patchy in nature than the burn-only treatment. They 

observed that Douglas-fir beetle activity increased following the treatments but decreased the following 

year. During the four years studied, they recorded that 20 percent of the trees attacked in the thin-andburn treatment were attacked successfully and 6 percent of the attacked trees in the burn-only treatment 

were attacked successfully. They observed that mean crown scorch height, percent circumference charred, 

ground charring, and d.b.h. were higher in the attacked trees than in the un-attacked trees. They concluded 

that the increase in Douglas-fir beetle was short lived, and occurred on fire-weakened trees with the beetle 

unable to successfully move to residual green trees. They stated a mean crown scorch height of 11.59 m in 

the thin-and-burn treatment and a mean flame length of 7.98 in the burn-only treatment.

In Oregon, Youngblood et al. (2009) studied delayed mortality in ponderosa pine and Douglas-fir 

following thinning, thinning and burning and burning only treatments. They found that bark beetle 

mortality was low overall with only 0.03 percent across all species, but was higher in the treatments 

involving prescribed burning. 

Summary

Of the two bark beetles we are concerned with and addressing in this report, we can conclude that 

prescribed burning in the project area would not increase MPB, would likely increase DFB to a small 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

100

degree for a short time, and would decrease the potential for wildfires in the future to cause an increase in 

DFB. 

Mountain pine beetle risk is now low in the project due to the recent outbreak, and damage by fires does 

not appear to substantially increase MPB activity. 

Douglas-fir beetle can increase following fires, with the beetles initially targeting the largest, moderately 

to highly damaged Douglas-fir, and when they are depleted would turn toward smaller diameter trees, 

trees with light damage, and eventually green trees. The impacts from DFB following wildfires can be 

substantial. The impacts from DFB following prescribed burning would be much lower because of the 

substantially lower tree crown, bole, and root damage caused by the prescribed burn.

Thinning Effects on Bark Beetle Risk

Bark beetles are characterized by foresters as primary and secondary. Aggressive bark beetles thought of 

as primary killers of trees are those that attack and kill apparently healthy trees. These primary killers 

include Douglas-fir beetle (Dendroctonus pseudotsugae), mountain pine beetle (Dendroctonus 

ponderosae), western pine beetle (Dendroctonus brevicomis), pinyon engraver (Ips confusus), 

roundheaded pine beetle (Dendroctonus adjunctus), spruce beetle (Dendroctonus rufipennis), and fir 

engraver (Scolytus ventralis). Secondary bark beetles infest severely stressed, dying, or freshly dead trees 

as well as stressed tree tops and branches. Pine engraver (Ips pini), red turpentine beetle (Dendroctonus 

valens) and striped ambrosia beetle (Trypodendron lineatum) are mostly considered secondary bark 

beetles. Depending upon stand conditions and beetle population levels, some bark beetles that typically 

act in a secondary role can act as a primary killer of trees. Pine engraver, for example, normally 

reproduces in logging slash, wind-blown trees, broken limbs, and severely stressed trees like other 

secondary bark beetles, but when populations increase due to an abundance of host material, it frequently 

invades and kills small live trees or the tops of larger trees. Bark beetle risk concerns in the project area 

involve primary bark beetles, not secondary, and the following discussion addresses only those listed 

above as primary bark beetles.

Researchers began to recognize the importance of tree stocking control to reduce bark beetle activity in 

about 1941 (Eaton 1941). In 1953, Clements recognized the relationship between stand density and 

mountain pine beetle activity in sugar pine in 1953 (Clements 1953 in Oliver 1995). Since then, Sartwell 

and Stevens (1975) worked to further establish the links between tree stocking levels and bark beetle 

activity. Based upon the works of Sartwell and others, Oliver (1995) investigated the relationship between 

the stand density index (SDI) threshold of self-thinning mortality due to competition and SDI thresholds 

for mortality due to bark beetles. Oliver (1995) concluded that stand density for ponderosa pine stands 

was limited by Dendroctonus bark beetles to lower levels than the level of self-thinning. He found that 

there appears to be a “limiting stand density index” of 365, and stands approaching that limiting SDI 

usually suffered large losses from bark beetle epidemics that equal or exceed periodic growth for the 

stands experiencing the bark beetle mortality. He suggests that endemic levels of bark beetle mortality 

could start in stands when they reached an SDI of 230. The 230 SDI level could be considered a “zone of 

imminent bark beetle mortality.”

Within the last several decades, a number of studies examined the relationships between tree thinning to 

reduce bark beetle activity and risk. Many of the studies observed decreased bark beetle activity with 

decreased tree stocking levels. These studies include: (1) observations of low bark beetle activity within 

thinned stands during long term stocking studies (Cochran and Barrett 1995, Cochran and Barrett 1999a, 

Cochran and Barrett 1999b, Cochran and Dahms 2000), (2) control studies measuring bark beetle 

mortality within pine stands thinned to various stocking levels and un-thinned areas (Amman 1988a, 

Amman 1988b, Amman et al. 1988a, Amman et al. 1988b, Cole and McGregor 1985, Cole et al. 1983, 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

101

Fiedler and Morgan 2002, Fiddler et al. 1995, McGregor et al. 1987, Mitchell et al. 1983, Safranyik et al. 

2004, Schmid and Mata 2005, Whitehead and Russo 2005) and (3) control studies measuring bark beetle 

activity as a function of the number of beetles trapped in stands thinned to various stocking levels as well 

as unthinned stands (Bartos and Booth 1994, Sanchez-Martinez and Wagner 2001, Schmitz et al. 1981, 

Zausen et al. 2005). Of the mortality studies, only Mitchell et al. (1983) did not demonstrate a difference 

in mortality between lightly thinned stands and unthinned controls, but they did observe that the heavily 

thinned stands had no mortality. Only one trapping study, Sanchez-Martinez and Wagner (2001), did not 

observe fewer trapped beetles in thinned stands compared to unthinned. Sanchez-Martinez and Wagner’s 

(2001) measurements found no significant difference between bark beetles trapped in thinned and 

unthinned ponderosa pine stands on the Coconino plateau in Arizona. However, their data was collected 

during low levels of bark beetle activity (endemic) in the area and they observed that the average tree size 

within the unthinned stands was very small, (22.2 cm) making the trees undesirable habitat for the most 

aggressive bark beetles found in the area--western pine beetle and mountain pine beetle. Given the results 

all studies mentioned above, we conclude that available research provides overwhelming evidence for the 

utility of thinning to reduce tree stocking and therefore the level of bark beetle mortality and the risk of 

epidemic levels of mortality.

Restoration

Whitebark Pine Restoration

Whitebark pine (Pinus albicaulis) is a subalpine conifer that is relatively slow growing, intolerant of 

shade, and tolerant of poor soils, steep slopes, windy exposures, and cold environments (Arno and Hoff 

1990). Whitebark pine cones are indehiscent, that is, they do not open sufficiently to release the seeds 

when ripe but they may be shed from the tree and decay on the ground, releasing the seeds (Arno and 

Hoff 1990, Owens et al. 2008). Seeds are large and wingless. The combination of indehiscent cones and 

large wingless seeds limits unaided dispersal of seeds. The major mechanisms for dispersing whitebark 

pine seed depends primarily upon the seed-harvesting and caching behavior of Clark’s nutcracker 

(Nucifraga columbiana) (Tomback 1982, Hutchins and Lanner 1982), although a number of other birds 

and small mammals take the seeds for eating and for storage as winter food. Wildlife species that eat 

whitebark pine seeds include woodpeckers, jays, ravens, chickadees, nuthatches, finches, chipmunks, 

ground squirrels, bears and probably mice (Hutchins and Lanner 1982, Tomback 2001). Pine squirrels 

(Tamiasciurus spp.) harvest and cache whitebark pine cones in middens (Hutchins and Lanner 1982, 

Kendall 1983). Whitebark pine seeds serve as an important food source for grizzly bears (Ursus arctos) 

and black bears (U. americanus) which raid the middens (Kendall 1983).

Whitebark pine grows in a wide range of plant communities. It can be found in pure stands as the climax 

species on the coldest and driest sites where harsh growing conditions keep out the less hardy species 

(Pfister et al. 1977). At the highest elevations, it can be found growing as small stands of short, shrublike 

trees (krummholz) mixed in with alpine herblands; but on less harsh sites, it achieves larger size and 

straighter form. Whitebark pine grows as a co-climax species on sites capable of supporting shadetolerant tree species such as subalpine fir, but on which they are unable to grow vigorously enough to 

replace the whitebark pine. These are described as whitebark pine-subalpine fir (Abies lasiocarpa) habitat 

types (Pfister et al. 1977) and whitebark pine phases of subalpine fir habitat types (Steele et al. 1983). On 

moister subalpine fir habitat types within the analysis area, whitebark pine can be present as a major seral 

species stand component, and on dryer subalpine fir habitat types as a minor seral species stand 

component.

Whitebark pine’s presence as a seral species in subalpine fir habitat types is maintained by disturbances, 

mainly fires (Arno 2001). Prior to 1900, fires burned through whitebark pine forests at average intervals 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

102

ranging from about 30 to and 400 years, usually with mixed-severity (Arno and Peterson 1983, Morgan 

and Bunting 1990, Barrett 1994, Brown et al. 1994, Keane et al. 1994, Tomback et al. 2001, Murray 2008, 

Larson et al. 2009), although the longest fire return intervals were associated with a stand-replacing fire 

regime (Romme 1982). Some of the seral whitebark pine stands have been perpetuated by low-intensity 

fires that kill understory fir and spruce (Arno 1986, Arno 1976, Fisher and Bradley 1987, Arno and Hoff 

1990, Bradley et al. 1992). Severely burned patches within mixed-severity fires create openings that are 

used by nutcrackers for caching seeds, resulting in even-aged, whitebark pine stands. 

Whitebark pine has been declining throughout major portions of its range for the last 50 years due to the 

effects of diseases, insects, and succession (Kendall and Keane 2001) with a rapid decline since the 1960s 

(Keane et al. 1996). White pine blister rust (Cronartium ribicola) has led to the most rapid and precipitous 

decline in whitebark pine. Impacts from the disease have been highest in the more mesic parts of 

whitebark pine range, but although the coldest and driest whitebark pine stands have been impacted to a 

lesser degree, all whitebark pine can be considered at risk. White pine blister rust (WPBR) enters trees 

through tree needles and grows from the infected needles through branches to the main stem. Smaller 

trees die more quickly than larger trees. Although larger trees take longer to die, the ends of branches can 

be killed long before the tree dies, which reduces or eliminates cone production since whitebark pine 

cones are produced at the ends of branches in the upper portion of the tree crown.

During the last 100 years, the area of whitebark pine cover type in the interior Columbia River Basin and 

the Bob Marshall Wilderness Complex in Montana is estimated to have declined 45 percent with the 

whitebark pine in areas where it is a major seral species declining by 98 percent (Keane et al. 1996). In a 

disease study of white pines (Pinus albicaulis and P. flexilis) of the Intermountain West, Smith and 

Hoffman (2000) found the incidence (present within the sampled stands) of WPBR to be 55 percent in the 

middle Rocky Mountains. In the Bob Marshall Wilderness Complex of Montana, Keane et al. (1994) 

reported an 83 percent infection intensity (percentage of live trees infected) with a 33 percent average 

crown kill in 1990. They found that snags were common, ranging from 0 to 123 trees/ha and attributed 

most of the whitebark pine mortality to blister rust because they found no evidence of extensive bark 

beetle mortality. South of the project area in the Grand Teton National Park, Kendall et al. (1996a) found 

an average of 7 percent dead (ranging from 0 to 50 percent), and in Yellowstone National Park found an 

average of 7 percent dead (ranging from 0 to 64 percent). Kendall et al. (1996b) on the Gallatin National 

Forest found 10 percent dead (ranging from 0 to 43 percent). These mortality values have almost certainly 

increased within the last 15 years due to additional WPBR-related mortality and due to the recent 

mountain pine beetle epidemic. Blister rust surveys of whitebark pine in two stands south of the 

Stonewall project area on the Helena National Forest done in 2007 and 2009 found 74 and 97 percent 

WPBR infection levels (see WBP Survey_granite.xls and WBP Survey_redmtn6253.xls in project 

records).

Whitebark pine in the Northern Rocky Mountains depends upon fire to maintain its dominance or 

presence on sites where it is a successional species (Arno 2001, Keane 2001, Kendall and Keane 2001, 

Morgan and Murray 2001). It often can survive low-severity fires that kill its competitors. Many fires can 

kill most fir, spruce, and young whitebark pine, but few larger whitebark pines. Fire frequency has 

decreased in many whitebark pine forests since the late 1880s, with the greatest change in the last 60 

years (Brown 1994, Murray et al. 1998, Rollins et al. 2000). This fire exclusion has allowed an increase in 

competition from shade-tolerant and fire-intolerant species and advanced the age of whitebark pine stands 

(Arno 1986, Kendall and Keane 2001, Keane et al. 1994) making whitebark pine trees more susceptible to 

WPBR and mountain pine beetle. Keane et al. (1994) reported that in the Bob Marshall Wilderness 

Complex, their sampled stands typically consisted of an overstory of old whitebark pine and spruce with 

an understory of almost exclusively subalpine fir (8 to 1500+ trees/ha, 30 to 250 years of age). They 

found whitebark pine regeneration in only about 9 percent of their sample plots. The number and size of 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

103

forest openings suitable for nutcracker caching and whitebark seedling growth has declined. Increases in 

fuel loads as stands transition to dominance by subalpine fir and Engelmann spruce has led to increases in 

fire-severity, which threatens the survival of even the largest and most fire resistant whitebark pine trees 

(Morgan and Bunting 1990).

Mountain pine beetle attacks whitebark pine in addition to lodgepole pine. Increases in stand age, average 

tree size, and competition, increases whitebark pine tree and stand susceptibility to attack from mountain 

pine beetle as it does with lodgepole pine. White pine blister rust infection also stresses whitebark pine 

trees, making them more attractive or susceptible to mountain pine beetles (Keane et al. 1994). The recent 

mountain pine beetle epidemic has killed whitebark pine, along with lodgepole and ponderosa pine.

Restoring whitebark pine must address the major factors causing its decline; competition, succession and 

white pine blister rust (Tomback et al. 2001). To be successful in the long term, restoration should 

emphasize the return of ecosystem processes rather than simply historic stand conditions (Keane and Arno 

2001). The primary ecosystem process that should be returned is fire.

Techniques that can be used to restore whitebark pine (Keane and Arno 1996, Keane and Arno 2001, 

Tomback et al. 2001) include:

Planting rust-resistant whitebark pine seedlings

Release cuttings

Thinning

Tree understory removal

Selective tree removal

Cutting small openings (50 m diameter) for caching by Clark’s nutcracker

Natural stand-replacement fire

Prescribed stand-replacement fire with or without cutting for fuel enhancement

Variable intensity prescribed burning in natural fuels

Variable intensity prescribed burning with cutting for fuel enhancement

Underburning

Keane and Parsons (2010a) describe the results of a study to restore white pine ecosystems using 

treatments that emulate the historic fire regime—primarily combinations of prescribed fire, silvicultural 

cuttings, and fuel enhancement cuttings. They found that all treatments that included prescribed burning 

created suitable nutcracker caching habitat, and many birds were observed caching seeds in the burned 

areas. After 5 years, however, they had not found a significant increase in regeneration of whitebark pine.

They attributed the lack of regeneration to the high level of blister rust in the surrounding area that had 

reduced available seed and forced the nutcrackers to reclaim most of the cached seed, as well as site 

severity, a lack of plant cover, and a relatively short time since disturbance. Keane and Parsons (2010b) 

recommended that an evaluation of natural regeneration in the treatments must be made at least a decade 

after burning. In four of the five study sites, they recorded 88 to 95 percent mortality from blister rust, 

with less than 1 percent mortality on the fifth study site. Based upon their findings, their 

recommendations included:

Emulating historical fire regimes

Using prescribed burning and augmenting fuelbeds by cutting trees where necessary

Letting wildland fires burn under acceptable conditions
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

104

Planting potentially rust-resistant trees where whitebark pine blister rust-caused mortality was above 

20 percent, rust infection levels were above 50 percent, or bark beetle mortality levels were high

Treatment Groups 7 and 8 in the Stonewall project would be prescribe burned with mixed-severity fires.

The treatments in Group 7 would create mortality patches less than 5, 10, or 20 acres depending upon the 

unit and in Group 8 would create mortality patches less than 30 or 75 acres depending upon the unit.

Where necessary, the treatments would involve cutting trees with chainsaws prior to burning to enhance 

increase surface fuel loadings. During cutting operations, individuals and patches of whitebark pine 

would be thinned around where available to reduce competition and to protect them from the prescribed 

burn. The result of the treatments would be to create a mosaic of lightly burned timbered areas and more 

severely burned patches. The patches would provide areas for nutcracker caching and for whitebark pine 

to establish and grow. These practices are consistent with recommendations stated above by Keane and 

Parsons (2010a), Keane and Arno (1996), Keane and Arno (2001), and Tomback et al. (2001) to emulate 

historical fire regimes, use variable intensity prescribed burning, augmenting fuels where necessary, thin 

to release whitebark pine trees, remove understories, and create small openings.

Aspen Restoration

Quaking aspen (Populus tremuloides) is the most widely distributed tree in North America (Perala 2004). 

It is a fast-growing, short-lived, deciduous tree that reproduces by seed and vegetatively. Although aspen 

can produce an abundance of highly viable seeds, few aspen seedlings survive in nature due to the short 

period of seed viability (2-4 weeks following maturity under favorable conditions and perhaps much less 

under unfavorable), unfavorable moisture during seed dispersal, high soil surface temperatures, fungi, 

adverse diurnal temperature fluctuations during initial seedling growth, and the unfavorable chemical 

balance of some seedbeds (Maini and Cayford 1968, Meyer and Fechner 1980). Aspen forms clones, 

which are aggregations of stems mainly produced asexually from a single sexually produced individual 

through root suckers, although some root collar and stump sprouts can be produced (Perala 2004). Aspen 

clones typically produce root suckers in response to a disturbance, for example fires, that affect the clone 

and produce changes in the production of growth regulators (i.e. auxin and cytokinin) soil temperatures, 

and available moisture. In general, the greater the disturbance the greater the number of suckers produced 

due to increases in cytokinin-to-auxin ratios in the root systems, increases in soil temperatures, and 

increases in available site resources such as water and light. Root system carbohydrate reserves are also 

involved. Carbohydrate reserves provide the suckers with energy until they can provide their own through 

photosynthesis, and so the density of aspen regeneration following disturbance depends upon the level of 

those reserves. Although aspen stems are short-lived relative to other trees, aspen can reproduce through

suckering following disturbance and so aspen clones can be quite old. 

Aspen can grow on site conditions that preclude the establishment of conifers but which have adequate 

subsurface moisture for a long-lived aspen clone to survive (Jones and DeByle 1985, Mueggler 1988). 

These self-perpetuating clones can be considered “stable” and “climax” and are not seral to a conifer 

species (Pfister et al. 1977). Most, if not all, of the aspen clones within the Stonewall Project area are 

growing within conifer stands and can be considered a seral species to a conifer species, either subalpine 

fir or Douglas-fir. They are usually small and have apparently been perpetuated by periodic wildfires 

(Pfister et al. 1977). As a seral species, without disturbance, over time the aspen can be expected to be 

overtopped by taller conifers and outcompeted for site resources. 

Thinning within and around aspen clones has been shown to be an effective treatment for increasing 

aspen regeneration and restoring aspen (Arikian et al. 1999, Huffman et al. 1999, Shepperd 2001, Prévost 

and Pothier 2002, Jones et al. 2005, Groot et al. 2009, Lennie et al. 2009). The heavier the thinning, the 

greater the number of aspen suckers produced (Huffman et al 1999, Prévost and Pothier 2002) and 

removing all competing trees from within and around aspen has been shown to produce the greatest 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

105

increase in aspen suckering (Stone et al. 2001, Groot et al. 2009, Lennie et al. 2009, Prévost and Pothier 

2002).Prescribed burning has also been shown effective at promoting aspen regeneration (Brown and 

DeByle 1987, Bartos et al. 1991, Kay 2001, Shepperd 2001, Durham 2008, Paragi and Haggstrom 2007). 

The effects of prescribed burning on aspen vary because fuels and flammability vary considerably within 

the aspen and mixed aspen-conifer overstory types (Brown and Simmerman 1986, Brown and DeByle 

1987). In general, the fuel types in order from high potential fire intensity and rate of spread to low are: 

mixed conifer-aspen/shrub, aspen/shrub, mixed conifer-aspen/forb, aspen tall forb, and aspen low forb 

(Brown and Simmerman 1986). Brown and Simmerman (1986) rate the probability of successfully 

applying prescribed fire to aspen forests as moderate to high in the aspen/shrub, aspen/tall forb and mixed 

aspen-conifer fuel types. The aspen within the Stonewall area is present in mixed aspen-conifer fuel type.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

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Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

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Appendix C – Cumulative Effects
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

108

Stonewall Vegetation Project Cumulative Effects Activities 

The area analyzed in cumulative effects analysis is usually not limited to the project area, and it varies 

with the resource or species analyzed. Each resource has different “boundaries” for its effects analysis.

Quantified, detailed information regarding effects, leading to specific reasoned conclusions can be found 

in the cumulative effects section of each specialist report located in the project record.

Available information was reviewed. Many fires in the affected watersheds had no accompanying written 

information; however, fire occurrence data provides a glimpse of the fire suppression history in the 

project area. Fire information within all ownerships in the Stonewall Vegetation Project area and adjacent 

areas was considered. Records note there were 188 fires reported from 1920 till 2009. Acreage for fire 

size classes are as follows: (A) less than 0.25 acres, (B) 0.26-9.9 acres, (C) 10-99 acres, (D) 100 – 299 

acres, (E) 300-999, (F) greater than 1,000 acres.

Table C- 1. Number of fires in the Stonewall watersheds by decade and size class

DECADE A B C D E F TOTAL

1920-1929 2 2

1930-1939 12 1 13

1940-1949 14 1 15

1950-1959 9 2 1 12

1960-1969 20 1 21

1970-1979 9 6 1 16

1980-1989 15 5 1 21

1990-1999 40 9 1 1 51

2000-2009 27 8 1 1 37

2010-2012 1 1 1 3

Total number of fires 148 31 6 1 2 1 191

(Kurtz 2009; updates L.Burns personal communication)

Fires that escaped detection are not included. Fire occurrence data was digitized as point source data from 

historical maps that portrayed fires by year, size class, and cause for 1920 to 1969 (Kurtz 2009). For 1920 

to 1969, no more than 1,243 acres on all ownerships have burned based on the maximum acreage per size 

class and the number of fires that occurred in that size class. For the period from 1970 to 2009, fire 

occurrence information was developed from Kansas City fire database (KCFast). The records from this 

period have detailed information including acreage, cost, and physical location. During the period from 

1970 to 2009, 125 fires burned approximately 531 acres within the watershed area. Therefore, no more 

than 1,774 acres have burned across all ownerships since 1920, or less than 4 percent of the project area. 

The Snow/Talon fire burned 37,905 acres adjacent to the project area in 2003, approximately 87 acres 

burned within the project boundary. The Keep Cool Fire burned 302 acres within and adjacent to the 

project area in 2006, approximately 261 acres burned within the project boundary. In 2007, the Bull 

Mountain Fire burned 30 acres.

The following tables of past, present, and reasonably foreseeable activities have been used by the 

interdisciplinary team members in determining the cumulative effects for their respective resource. Each 

resource specialist has determined which of the following activities are applicable to their analysis, 

depending on their cumulative effects boundary.

Areas considered in the tables below include the Stonewall Vegetation project area (Stonewall), 

watersheds (6th Code HUCs) in and adjacent to the project area, and Stonewall project area and combined 

boundary (Stonewall Combined Boundary) (used for selected specific species). These represent the
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

109

cumulative effects areas required for most resources, except for the Inventoried Roadless area. Activities 

are sorted by decade. Information on past activities beyond the HUC areas is available from the Forestwide Hazardous Tree Removal and Fuels Reduction – Healthy Forests Restoration Act Project analysis.

Harvest/fire records prior to 1950 are not available. Harvest and fuel treatments are noted in the table 

below by the respective boundaries. Harvest activities are sorted by intermediate and regeneration 

treatments (see definitions). “Fuels activities” includes prescribed fire (including hand slashing), pile 

burning and jackpot burning. Timber harvest and/or fuel treatment acres could overlap on the same piece 

of ground so total acres reflected in the table may double count some parcels of ground; refer to Figure C1for clarification. Current stand conditions as a result of past disturbances are reflected in existing 

condition reports by resource area. Present or ongoing projects are those projects in the implementation 

phase. Reasonably foreseeable projects are in the planning phase, which means there is potential for 

change due to public input, changed conditions, etc. In addition, natural processes such as succession and 

natural events such as droughts are always occurring.

Past Activities

Table C- 2. Acres of past fire and fuels activities in the project area*

Row Labels 1950s 1960s 1970s 1980s 1990s 2000s

Grand 

Total Acres

Fuels treatments 25 1,751 1,097 1,569 2,460 1,020 7,922

Prescribed burns 2,841 2,841

Other 382** 382

Grand Total 25 1,751 1,097 1,569 2,460 4,243 11,145

* Past fire and fuels management activities obtained from Helena National Forest GIS spatial and tabular databases.

**Forestwide Hazardous Tree Removal and unspecified amount of public fire wood
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

110

Table C- 3. Past activities

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

1950- 1959

Forest Service 

Timber Harvest Pre 1960 See GIS 

Map

Timber harvest primarily tractor logging, use of skid trails and haul use of local 

roads.

Stonewall 

Regeneration harvest: 198 acres

by HUCs

Beaver Creek: Regeneration harvest: 199 acres

Humbug Creek, Keep Cool Creek, Lincoln Creek No records

Stonewall Combined Boundary

Regeneration harvest: 305 acres

Harvest/regeneration treatments 

created an early-seral stage 

following the treatment and of which 

a few are still providing most of the 

early-seral in the project area. A 

reduction in wildlife cover and forage 

occurred immediately following 

harvest; sites affected by these 

treatments now provide increased 

levels of herbaceous and woody 

forage on most sites, although some 

stands have closed canopy 

conditions and provide hiding and 

thermal cover with little forage. 

Effects of these disturbances on 

vegetation are reflected in the 

existing condition. 

Fire/Fuels pre 1960 multiple

Stonewall

Fuels treatments: 25 acres

by HUCs

Beaver Creek: Fuels treatments: 25 acres

Humbug Creek, Keep Cool Creek, Lincoln Creek: No records

Stonewall Combined Boundary

Fuels treatments: 25 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, which have since been 

restored. Effects of these 

disturbances on vegetation are 

reflected in the existing condition. 

Mining 1950s Multiple Small scale hard rock mining

Small localized temporary 

disturbance to soils and streamside 

banks.

Private and 

State lands

Timber harvest

1950s Multiple Unspecified acres; primarily tractor logging, haul use of local existing roads.

Removal of live and dead and dying 

trees and potential for the spread of 

invasive species. Habitat for species 

that utilize mature forest was 

reduced on some of the acres 

affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

111

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

adversely affect movement of 

wildlife species that are sensitive to 

fragmentation and human activity.

1960 - 1969

Forest Service 

Timber Harvest 1960 - 1969 See GIS 

Map

Stonewall

Regeneration harvest: 1,608 acres; Sanitation harvest: 37 acres; Intermediate: 

254 acres; Reforestation: 1,144 acres

By HUCs: 

Beaver Creek: Regen harvest: 589 acres; Intermediate harvest. 126 acres

Humbug Creek: No records

Keep Cool Creek: Regen harvest: 1,241 acres; Intermediate harvest. 1 53 acres:

Lincoln Creek: Regen harvest: 258 acres; Sanitation harvest: 37 acres

Stonewall Combined Boundary

Regeneration Harvest: 3,535 acres; Intermediate Harvest: 254 acres; Sanitation 

Harvest: 60 acres; Reforestation: 2,340 acres

Regeneration and salvage 

treatments created an early-seral 

stage following the treatment and of 

which a few are still providing most 

of the early-seral in the project area. 

Intermediate treatments reduce 

stand densities to improve vigor of 

remaining trees. Reforestation 

efforts increases stocking of desired 

tree species. A reduction in wildlife 

cover and forage occurred 

immediately following harvest; sites 

affected by these treatments now 

provide increased levels of 

herbaceous and woody forage on 

most sites, although some stands 

have closed canopy conditions and 

provide hiding and thermal cover 

with little forage. Effects of these 

disturbances on vegetation are 

reflected in the existing condition. 

Fire/Fuels 1960-1969

See GIS 

Map and 

table 1

Stonewall

Fuels treatments: 1,751 acres

By HUCs

Beaver Creek: Fuels treatments: 729 acres; 

Humbug Creek: Fuels treatments: 11 acres; 

Keep Cool Creek: Fuels treatments: 1,633 acres; 

Lincoln Creek: Fuels treatments: 78 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, which have since been 

restored. Effects of these 

disturbances are reflected in the 

existing condition. 

Livestock 

Grazing on 

federal and 

private lands

1960-1969 Multiple Stonewall, HUC and Stonewall combined boundary: Grazing of cattle, sheep and 

horses. 

Grazing removed wildlife cover and 

forage on the site, reduced species 

diversity and increased the spread of 

invasive plants. While impacts still 

exist, these effects have been 

reduced due to more recent grazing 

management regimes, monitoring 

and mitigation. Effects of these 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

112

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

disturbances on vegetation are 

reflected in the existing condition.

Mining 1960s Multiple Small scale hard rock mining

Small localized temporary 

disturbance to soils and streamside 

banks.

Private and 

State lands

Timber harvest

1960s Multiple Unspecified acres; primarily tractor logging, haul use of local existing roads.

Removal of live and dead and dying 

trees and potential for the spread of 

invasive species. Habitat for species 

that utilize mature forest was 

reduced on some of the acres 

affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or 

adversely affect movement of wildlife 

species that are sensitive to 

fragmentation and human activity.

1970 - 1979

Forest Service 

Timber Harvest 1970 - 1979 See GIS 

Map

Stonewall:

Regeneration harvest: 502 acres

Sanitation harvest: 82 acres

By HUCs

Beaver Creek: Regeneration harvest: 388 acres; Sanitation harvest: 21 acres

Humbug Creek: Regeneration harvest: 37 acres

Keep Cool Creek: Regeneration harvest: 116 ac.; Sanitation harvest: 24 ac.

Lincoln Creek: Regeneration harvest: 116 acres; Sanitation harvest: 61 acres

Regeneration and salvage 

treatments created an early-seral 

stage following the treatment and of 

which a few are still providing most 

of the early-seral in the project area. 

Intermediate treatments reduce 

stand densities to improve vigor of 

remaining trees. Reforestation 

efforts increases stocking of desired 

tree species. A reduction in wildlife 

cover and forage occurred 

immediately following harvest; sites 

affected by these treatments now 

provide increased levels of 

herbaceous and woody forage on 

most sites, although some stands 

have closed canopy conditions and 

provide hiding and thermal cover 

with little forage. Effects of these 

disturbances on vegetation are 

reflected in the existing condition. 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

113

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

Fire/Fuels 1970-1979

See GIS 

Map and 

table 1

Stonewall

Fuels activities 1,097 acres

By HUCs

Beaver Creek: Fuels treatments: 875acres

Humbug Creek: Fuels treatments: 49acres

Keep Cool Creek: Fuels treatments : 524 acres

Lincoln Creek: Fuels treatments: 161 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, which have since been 

restored. Effects of these 

disturbances are reflected in the 

existing condition. 

Livestock 

Grazing on 

federal and 

private lands

1970-1979 Multiple Grazing of cattle, sheep and horses. 

Grazing removed wildlife cover and 

forage on the site, reduced species 

diversity and increased the spread of 

invasive plants. While impacts still 

exist, these effects have been 

reduced due to more recent grazing 

management regimes, monitoring 

and mitigation. Effects of these 

disturbances on vegetation are 

reflected in the existing condition.

Mining 1970s Multiple Small scale hard rock mining

Small localized temporary 

disturbance to soils and streamside 

banks.

1980 - 1989

Forest Service 

Timber Harvest 1980 - 1989 See GIS Map

Stonewall:

Regeneration harvest: 575 acres

Sanitation harvest: 17 acres

By HUCs

Beaver Creek: Regeneration harvest: 371 acres

Keep Cool Creek: Regeneration harvest: 8 acres

Lincoln Creek: Regeneration harvest: 205 acres

Sanitation harvest: 17acres

Regeneration treatments created an 

early-seral stage following the 

treatment and of which a few are still 

providing most of the early-seral in 

the project area. Sanitation and 

intermediate treatments reduce 

stand densities to improve vigor of 

remaining trees. Reforestation 

efforts increases stocking of desired 

tree species. A reduction in wildlife 

cover and forage occurred 

immediately following harvest; sites 

affected by these treatments now 

provide increased levels of 

herbaceous and woody forage on 

most sites, although some stands 

have closed canopy conditions and 

provide hiding and thermal cover 

with little forage. Effects of these 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

114

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

disturbances on vegetation are 

reflected in the existing condition. 

Fire/Fuels 1980-1989

See GIS 

Map and 

table 1

Stonewall

Fuels activities 1,569 acres

By HUC’s

Beaver Creek: Fuels treatments: 791 acres

Humbug Creek: Fuels treatments:11 acres

Keep Cool Creek: Fuels treatments: 141 acres

Lincoln Creek: Fuels treatments: 780 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, which have since been 

restored. Effects of these 

disturbances are reflected in the 

existing condition. 

Livestock 

Grazing on 

federal and 

private lands

1980-1989 Multiple Grazing of cattle, sheep and horses. 

Grazing removed wildlife cover and 

forage on the site, reduced species 

diversity and increased the spread of 

invasive plants. While impacts still 

exist, these effects have been 

reduced due to more recent grazing 

management regimes, monitoring 

and mitigation. Effects of these 

disturbances on vegetation are 

reflected in the existing condition.

Private and 

State lands

Timber harvest

1980s Multiple Unspecified acres; primarily tractor logging, haul use of local existing roads.

Removal of live and dead and dying 

trees and potential for the spread of 

invasive species. Habitat for species 

that utilize mature forest was 

reduced on some of the acres 

affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or 

adversely affect movement of wildlife 

species that are sensitive to 

fragmentation and human activity.

Mining 1980s Multiple Small scale hard rock mining

Small localized temporary 

disturbance to soils and streamside 

banks.

1990 - 1999
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

115

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

Forest Service 

Timber Harvest 1990 – 1999 See GIS 

Map

Stonewall

Regeneration harvest: 787 acres

Sanitation harvest: 220 acres

Intermediate harvest: 17 acres

By HUCs

Beaver Creek 

Regeneration harvest: 275 acres

Intermediate harvest: 16 acres

Sanitation harvest: 186 acres

Humbug Creek

Intermediate harvest: 49 acres

Keep Cool Creek

Regeneration harvest: 393 acres

Intermediate harvest. 78 acres

Sanitation harvest: 279 acres

Lincoln Creek

Regeneration harvest: 432 acres

Intermediate harvest: 17acres

Sanitation harvest: 28 acres

Regeneration treatments created an 

early-seral stage following the 

treatment and of which a few are still 

providing most of the early-seral in 

the project area. Sanitation and 

intermediate treatments reduce 

stand densities to improve vigor of 

remaining trees. Reforestation 

efforts increases stocking of desired 

tree species. A reduction in wildlife 

cover and forage occurred 

immediately following harvest; sites 

affected by these treatments now 

provide increased levels of 

herbaceous and woody forage on 

most sites, although some stands 

have closed canopy conditions and 

provide hiding and thermal cover 

with little forage. Effects of these 

disturbances on vegetation are 

reflected in the existing condition. 

Fire/Fuels 1990-1999

See GIS 

Map and 

table 1

Stonewall

Fuels activities: 2,460 acres

By HUCs

Beaver Creek: Fuels treatments: 1,196 acres

Humbug Creek: Fuels treatments: 1,145 acres

Keep Cool Creek: Fuels treatments: 1,957 acres

Lincoln Creek: Fuels treatments: 779 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, which have since been 

restored. Effects of these 

disturbances are reflected in the 

existing condition. 

Livestock 

Grazing on 

federal and 

private lands

1990-1999 Multiple Grazing of cattle, sheep and horses. 

Grazing removed wildlife cover and 

forage on the site, reduced species 

diversity and increased the spread of 

invasive plants. While impacts still 

exist, these effects have been 

reduced due to more recent grazing 

management regimes, monitoring 

and mitigation. Effects of these 

disturbances on vegetation are 

reflected in the existing condition.

Private and 1990s Multiple Unspecified acres; primarily tractor logging, haul use of local existing roads. Removal of live and dead and dying 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

116

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

State lands

Timber harvest

trees and potential for the spread of 

invasive species. Habitat for species 

that utilize mature forest was 

reduced on some of the acres 

affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or 

adversely affect movement of wildlife 

species that are sensitive to 

fragmentation and human activity

Mining 1990s Multiple Small hand-scale placer mining

Small localized temporary 

disturbance to soils and streamside 

banks.

2000 - 2010

Forest Service 

Timber Harvest 2000-2010 See GIS 

Map

Stonewall

Regeneration harvest: 154 acres

By HUCs:

Beaver Creek: No records; 

Humbug Creek: Intermediate harvest: 60 acres;

Keep Cool Creek: Regeneration harvest: 5 acres;

Lincoln Creek: Regeneration harvest: 154 acres

Sanitation harvest. 16 acres

Regeneration treatments created an 

early-seral stage following the 

treatment and of which a few are still 

providing most of the early-seral in 

the project area. Sanitation and 

intermediate treatments reduce 

stand densities to improve vigor of 

remaining trees. A reduction in 

wildlife cover and forage occurred 

immediately following harvest; sites 

affected by these treatments now 

provide increased levels of 

herbaceous and woody forage on 

most sites, although some stands 

have closed canopy conditions and 

provide hiding and thermal cover 

with little forage. Effects of these 

disturbances on vegetation are 

reflected in the existing condition. 

Fire/Fuels 2000 to 2010

See GIS 

map and 

table 1

Stonewall 

Fuels activities: 1,020 acres

By HUCs

Beaver Creek: Fuels treatments: 181 acres

Humbug Creek: Fuels treatments: 166 acres

Effects included a short-term (<10 

years) reduction in fuels, cover and 

forage, some which may have since 

been restored. Effects of these 

disturbances are reflected in the 

existing condition. 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

117

Activity/Name Decade/Year Drainage Scope Of Activity Resource Effects

Keep Cool Creek: Fuels treatments: 285 acres

Lincoln Creek: Fuels treatments: 571 acres

Pheromone 

Control 2002 Lincoln 

Gulch Placement of MCH caps, occurred just w/in Stonewall Vegetation area. Small localized temporary 

disturbance from site visits

Livestock 

Grazing on 

federal and 

private lands

2000-2010 Multiple Grazing of cattle, sheep and horses. 

Grazing removed wildlife cover and 

forage on the site, reduced species 

diversity and increased the spread of 

invasive plants. Effects of these 

disturbances on vegetation are 

reflected in the existing condition.

Mining 2000s Multiple Small hand-scale placer mining

Small localized temporary 

disturbance to soils and streamside 

banks.

Ongoing Activities

Table C- 4. Ongoing Activities 2010-present

ACTIVITY/NAM

E

DECADE/YEA

R

DRAINAG

E SCOPE OF ACTIVITY RESOURCE EFFECTS

Pine Grove 

Campground

Fencing

2011 Beaver 

Creek

Fence exclosure of 8 acres to keep livestock out of the developed campground 

area. Removed impact from livestock use 

Alice Creek, 

Hogum Creek, 

and Poorman 

prescribed 

burns

2010-present

BMSS IRA 2,841 acres

Specimen Creek IRA 793 acres

Hand pile, hand slashing, pile burning and prescribed burns for wildlife habitat 

improvement. 

Temporary localized disturbance during 

operations. Some felling of small diameter 

trees and reduction in fuels. Short-term 

increase in growth of shrubs and forbs. 

Potential for weed persistence or spread. 

Forest-wide 

Hazardous Tree 

Removal and 

Fuels Reduction 

HFRA Project

Ongoing Forest 

wide

Stonewall: 382 acres

BMSS IRA: 82 acres

By HUCs: total 568 acres

Beaver Creek: 172 acres

Keep Cool Creek: 270 acres

Lincoln Creek: 127 acres

Temporary localized disturbance during 

operations. Felling and removal of dead 

and damaged “hazardous” trees from 

roadsides. Very minor effects on live tree 

stocking, stand structures, and species 

compositions. Potential for weed 

persistence or spread. 

Pine Grove 

Campground

Ongoing 

annual use & 

Upper 

Beaver 

Developed recreation site, overnight use (free-use facility). Season of use 5/15 –

11/15. Localized noise disturbance, road use. 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

118

ACTIVITY/NAM

E

DECADE/YEA

R

DRAINAG

E SCOPE OF ACTIVITY RESOURCE EFFECTS

maintenance Creek

Livestock 

Grazing Permits Ongoing

The Stone Dry area includes 3 allotments; 1 sheep and two cattle (see Stone Dry 

NFMA Report for more detail – pp. 1-3). 

Keep Cool Liverpool allotment: project area 3,171 acres

Stonewall allotment: project area 2,000 acres

By HUCs: total 4,486 acres

Beaver Creek 3,510 acres; Keep Cool Creek HUC 785 acres; Lincoln Creek HUC 

191 acres

Portions of several allotments overlap the Bear-Marshal-Scapegoat-Swan (BMSS) 

IRA.

Keep Cool Liverpool allotment: BMSS IRA 4,344 acres, Keep Cool Creek 7,500 

acres

Stonewall allotment: BMSS IRA 203 acres, LG IRA 124 acres

Arrastra allotment: LG IRA 202 acres

Alice Creek allotment: BMSS IRA 12,963 acres

Potential impacts on aspen and conifer 

regeneration in proposed treatment units 

analyzed. Proposed Unit 57 (93 acres) 

and most of Unit 43 (about 80 acres) are 

within livestock allotments. Grazing 

removes wildlife cover and forage on the 

site, and reduces species. Potential for 

spread of existing weed populations as 

well as introduce new populations, but 

with implementation of BMPs populations 

should not expand substantially. 

Continued potential negative effects to 

riparian areas, water quality, fish and fish 

habitat, with some potential for 

improvements from current conditions in 

some locations. 

Livestock 

Grazing on 

private lands

Ongoing Multiple Grazing of cattle, sheep and horses. May result in riparian vegetation, stream bank 

and upland impacts.

Removal of live and dead and dying trees 

and potential for the spread of invasive 

species. Habitat for species that utilize 

mature forest was reduced on some of the 

acres affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis area, 

most activities did not reduce landscape 

level connectivity or adversely affect 

movement of wildlife species that are 

sensitive to fragmentation and human 

activity. Potential for spread of existing 

weed populations as well as introduce 

new populations. Continued potential 

negative effects to riparian areas, water 

quality, fish and fish habitat, with some 

potential for improvements from current 

conditions in some locations.

Mining Activity Ongoing Multiple Overall, permitted mining activity on the Lincoln Ranger District in recent years has 

been limited to small operations with mainly hand work.

Small localized temporary disturbance to 

vegetation, soils and streamside banks.

Noxious Weed 

Treatment Ongoing Multiple

Herbicide treatment is primarily along roads and in patches that are accessible to 

mechanized equipment, and backpack/horsepack equipment; some biocontrol 

treatment (insects), grazing control (sheep), and mechanical.

Potential impacts to small trees along 

roadsides and in proposed regeneration 

units. Of the 1,111 acres within the project 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

119

ACTIVITY/NAM

E

DECADE/YEA

R

DRAINAG

E SCOPE OF ACTIVITY RESOURCE EFFECTS

Stonewall Vegetation Project area 1,111 acres

Bear-Marshall-Scapegoat-Swan IRA 386 acres

Lincoln Gulch IRA 261 acres

area, 443 acres are within intermediate 

treatment units, 50 acres are in prescribed 

burn units, and 492 are on roadsides. 

Applying herbicides for control of noxious 

weeds would have little potential impact to 

desirable tree stocking in these areas. 126 

acres are within proposed regeneration 

harvest units, with herbicide application 

having minimal impacts if appropriate 

application methods are used.

Potential short-term impacts to water 

quality if stream set-backs are not 

adhered to or if spills occur. Potential 

impact to sensitive plant populations, 

known populations would be protected 

from disturbance, but some habitat or 

individuals could be impacted. 

Lincoln 

Compound Ongoing Humbug Creek Humbug Creek HUC 110 acres Continued disturbance within a developed area.

Outfitting Ongoing Multiple Outfitter and guide special use permits for big game and spring bear seasons, day 

use and overnight camping. Temporary displacement of use of area. 

Road 

Maintenance Annual Multiple Grading and spot-gravelling performed as needed. Culvert maintenance may 

include clean out and or replacement where warranted for water flow.

Potential impacts to water quality from 

inadvertent side casting of road material 

into stream channels and erosion of 

freshly bladed surface, but longer-term 

benefits based on road-drainage 

improvements and fish passage. .

Road Special 

Use Permit Ongoing Multiple Re-issuance of existing road access permit for long-term. Continuation of existing use.

Personal use 

firewood cutting. Ongoing Multiple Dead trees with approximately 100 feet of existing travel routes within the analysis are being removed by the public for firewood.

Temporary disturbance, reduction of some 

down wood within travel corridors. 

Potential for weed spread.

Private Land 

Timber Sale Ongoing

Private 

property, 

State 

Property 

Unspecified acres; primarily tractor logging using existing roads for hauling.

Temporary localized disturbance during 

operations. Removal of live and dead and 

dying trees and potential for the spread of 

invasive species. Habitat for species that 

utilize mature forest may be reduced on 

some of the acres affected. Because offforest lands occur at lower elevations in 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

120

ACTIVITY/NAM

E

DECADE/YEA

R

DRAINAG

E SCOPE OF ACTIVITY RESOURCE EFFECTS

highly fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or adversely 

affect movement of wildlife species that 

are sensitive to fragmentation and human 

activity. Felling and removal of trees, 

potential for weed persistence or spread. 

Private Land 

Development Ongoing Multiple Development for housing in several areas in the vicinity of the town of Lincoln.

Increased disturbance and road use may 

displace wildlife. Habitat alteration for 

developed sites.

Reasonably Foreseeable Future Activities

Table C- 5. Foreseeable future activities

ACTIVITY/NAME ESTIMATED 

IMPLEMENTATION DRAINAGE SCOPE OF ACTIVITY RESOURCE EFFECTS

Blackfoot Travel 

Plan (non-winter)

and 

Blackfoot-North 

Divide Winter 

Travel Plan

Currently Under 

analysis Lincoln RD

The Lincoln Ranger District is currently developing the Blackfoot Travel Plan 

(non-winter) that would change existing non-winter motorized public access 

routes and prohibitions within the Blackfoot travel planning area. The overall 

objective of this proposal is to provide a manageable system of designated public 

motorized and non-motorized access routes and to designate motorized public 

access routes on a Motor Vehicle Use Map. The following changes are 

proposed:

Approximately 98 miles of roads would be closed to public wheeled motorized 

use (348 miles of National Forest System roads would still be available)

Approximately 30 additional miles of motorized trails would be designated (92 

miles of motorized trails would be available)

Approximately 18 additional miles of non-motorized trails would be designated 

(89 miles of non-motorized trails would be available)

Approximately 2 miles of new road and motorized trail would be constructed 

Approximately 21 miles of roads would be considered naturally reclaimed per 

field investigations (roads that are vegetated to the point that they are not 

drivable and thus are reclaimed on their own)

Approximately 62 miles acquired through land exchange would be identified for 

closure and possible decommissioning.

Approximately 39 miles not previously part of the road or trail inventory 

Action alternatives would reduce 

overall road density and related 

effects such as potential for weed 

spread, sedimentation delivery from 

roads to area streams, and 

disturbance to wildlife. Under the 

action alternatives use of roads may 

change from motorized to nonmotorized; opportunities for both 

motorized and non-motorized 

recreation would continue to be 

available across the district. 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

121

ACTIVITY/NAME ESTIMATED 

IMPLEMENTATION DRAINAGE SCOPE OF ACTIVITY RESOURCE EFFECTS

(unclassified routes) would be identified for closure and possible 

decommissioning

Approximately 133 miles of roads would be stored

Approximately 8 miles of roads would be decommissioned

The Blackfoot-North Divide Winter Travel Plan would provide for a variety of 

motorized and non-motorized winter recreational opportunities.

These plans are under analysis and are being developed in accordance with 36 

CFR 212, Subpart B, Designation of Roads, Trails, and Areas for Motor Vehicle 

Use

Road 

Maintenance Continuation Multiple Grading and spot-gravelling performed as needed. Culvert maintenance may 

include clean out and or replacement where warranted for water flow.

Temporary displacement of animals 

due to human activity. Potential 

impacts to water quality from 

inadvertent side casting of road 

material into stream channels and 

erosion of freshly bladed surface, but 

longer-term benefits based on roaddrainage improvements and fish 

passage.

Livestock 

Grazing on 

federal and 

private lands

Continuation Multiple Grazing of cattle, sheep and horses. 

Potential impacts on aspen and 

conifer regeneration. Grazing 

removes wildlife cover and forage on 

the site, and reduces species. 

Potential for spread of existing weed 

populations as well as introduce new 

populations. Continued potential 

negative effects to riparian areas, 

water quality, fish and fish habitat, 

with some potential for 

improvements from current 

conditions in some locations. 

Private Land 

Timber Sale Continuation

Private 

property, 

State 

Property 

Unspecified acres; primarily tractor logging using existing roads for hauling.

Removal of live and dead and dying 

trees and potential for the spread of 

invasive species. Habitat for species 

that utilize mature forest may be 

reduced on some of the acres 

affected. Because off-forest lands 

occur at lower elevations in highly 

fragmented portions of the analysis 

area, most activities did not reduce 

landscape level connectivity or 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

122

ACTIVITY/NAME ESTIMATED 

IMPLEMENTATION DRAINAGE SCOPE OF ACTIVITY RESOURCE EFFECTS

adversely affect movement of wildlife 

species that are sensitive to 

fragmentation and human activity.

Noxious Weed 

Treatment Continuation Multiple

Herbicide treatment is primarily along roads and in patches that are accessible to 

mechanized equipment, and backpack/horsepack equipment; some biocontrol 

treatment (insects), grazing control (sheep), and mechanical.

Stonewall Vegetation Project area 1,111 acres

Bear-Marshall-Scapegoat-Swan IRA 386 acres

Lincoln Gulch IRA 261 acres

Potential impacts to small trees 

along roadsides and in proposed 

regeneration units. Applying 

herbicides for control of noxious 

weeds would have minimal impacts 

to desirable tree stocking if 

appropriate application methods are 

used.

Data source: HNF Lincoln RD GIS. Codes categorized as follows:

Fuels treatments: 1111,1112,1113,1115,1117,1120,1130,1150,1152,1153,1154

Regeneration treatments: 4111,4112,4113,4117,4121,4131,4132,4133,4134,4141,4142,4148,4211

Intermediate treatments: 4151,4152,4210,4220

Sanitation treatments: 4230, 4231, 4232

Reforestation treatments: 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

123

Figure C- 1. Past, Ongoing and Foreseeable Projects within the Cumulative Effects Boundaries (wildfire location information not available, not mapped
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

124

Past, Ongoing and Future Activities in the Bear-Marshall-Scapegoat-Swan IRA

Table C- 6. Acres of past harvest and fuels activities in the Bear-Marshall-Scapegoat-Swan IRA

Past Harvest and Fuels Activity Acres within IRA

Prescribed Burning 38,636.0

Wildfire 9,460.6

Man Caused Fire 653.2

Fuels Treatment (yarding, rearranging, compacting, crushing, piling) 4,493.5

Thinning (hazardous fuels reduction, fuel break) 7,992.5

Range Improvement 870.9

Timber Harvest (patch clearcut, stand clearcut, shelterwood establishment cut, 

seed tree seed cut, shelterwood staged removal cut, single tree selection cut, 

group selection cut, liberation cut, commercial thin, sanitation salvage, 

precommercial thin)

2,962.3

Reforestation Needs Created 2,708.7

Reforestation/Planting/Regeneration activities 6,856.3

Wildlife/T&E activities 337.8

TOTAL 74,971.8
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

125

Table C- 7. Ongoing and reasonably foreseeable future actions in the Bear-Marshall-Scapegoat-Swan IRA

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

Flathead NF/Spotted 

Bear RD

Soldier Addition II EA 

(Decision Notice signed 

December 2011)

The portion of the district 

affected by the vegetation 

treatments in this project are 

bounded to the east by the 

Hungry Horse Reservoir and the 

South Fork Flathead River, to 

the north by Sullivan Creek, to 

the south by Bunker Creek, and 

to the west by Bruce Ridge

1,333 acres 

prescribed 

fire

and

1 acre of 

hand cutting 

of small trees

1,333 acres of prescribed burning to sustain 

the role of fire in the ecosystem and help 

restore whitebark pine habitat.

and

1 acre of hand treatment to reduce 

hazardous fuels around the Stony Hill 

Electronic Site to protect the site from future 

wildland fire.

Implementation expected: 2012 - 2022

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation would be 

minimal due to the increased 

presence of people and noise 

during project implementation.

Helicopter use is expected to 

occur over a 1 to 2 day period 

during the ignition process; 

however, helicopter use is not 

unusual in the area. During the 

implementation of the fuels 

treatment at the Stony Hill 

Electronics Site, solitude may be 

interrupted by the power saws 

used in thinning and the presence 

of personnel on the site for 

several days.

Short-term effects to the

undeveloped characteristics while 

cut stumps are visible at the site; 

however, when viewed from offsite the area would resemble 

other subalpine openings. 

Thinning treatments would not 

affect the remoteness 

characteristic of the area. 

Burning would be expected to 

enhance the natural integrity and 

apparent naturalness of the area. 

Burning would not affect the feel 

of remoteness in this IRA.

Flathead NF/Spotted 

Bear RD

Spotted Bear River 

(Decision Notice signed August 

2011)

The project area is bounded on 

the west by the Hungry Horse 

436 acres of 

prescribed 

fire

Prescribed burning on 436 acres to sustain 

the role of fire in the ecosystem and improve 

the availability of seasonal habitat for 

ungulates, grizzly bears, and other wildlife 

species

Expected implementation: 2012-2022. Some 

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation would be 

minimal due to the increased 

presence of people and noise 

during project implementation. 

Helicopter use is expected to 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

126

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

Reservoir and the South Fork 

Flathead River, on the north by 

South Fork Dry Park Creek, on 

the south by a minor ridge off 

Spotted Bear Mountain just 

north of the mouth of Cedar 

Creek, and on the east by the 

Great Bear Wilderness and Bob 

Marshall Wilderness boundaries.

of the prescribed burning could begin in 

2012. Due to the infrequency of achieving

the desired combination of weather and 

fuel/vegetative conditions, implementation of 

the prescribed burning may take up to 10 

years before completed.

occur over a 1 to 2 day period 

during the ignition process; 

however, helicopter use is not 

unusual in the area. People who 

use the area for primitive 

recreation opportunities would still 

be able to use the area as they 

did before, although they may be 

restricted during the time the area 

is actively burning. Additionally, 

instead of the area being “green” 

as it was before, portions of the 

area would now be considered 

“black,” but this should not affect 

their recreational use of the area.

Short-term effects to the 

undeveloped characteristics while 

cut stumps and areas blackened 

by fire are visible. 

Proposed burning is designed to 

produce effects similar to those 

expected in a historic natural fire

and result in more resilient forest 

conditions for long-term benefits. 

The vegetation slashing and 

subsequent burning is not 

anticipated to detract from IRA 

characteristics such as natural 

integrity and apparent 

naturalness.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

127

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

Lewis and Clark 

NF/Rocky Mountain RD

Benchmark Fuels EA 

(Analysis Complete – EA being 

revised due to remanding on 

appeal)

T19N R09W and T20N R10W

388

Use of Prescribed fire and mechanical fuels 

treatments to reduce fuel hazards. 

Expected implementation: chainsaw and 

hand-piling Summer/Fall 2013, Mechanical 

removal of trees may begin Winter 2013. 

Prescribed burn implementation anticipated 

to occur over the course of several years.

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation due to the 

increased presence of people and 

noise during project 

implementation. 

Short-term effects to the 

undeveloped characteristics while 

cut stumps and areas blackened 

by fire are visible. 

Long-term benefits to naturalness 

as fuel hazards are reduced.

Lewis and Clark 

NF/Rocky Mountain 

Ranger District

Rocky Mountain Ranger District 

Travel Plan EIS—Badger -Two 

Medicine Area

(Analysis Complete)

The project area extends from 

Birch Creek which is situated 

about 17 miles west of the town 

of Dupuyer, Montana, north 

about 20 miles to Glacier 

National Park near Highway 2 

and west to Marias Pass and the 

Continental Divide.

(7.59)

3.74 miles of road to be converted to nonmotorized system trails

0.26 road miles to be decommissioned

3.59 trail miles to be decommissioned

Long-term benefits to 

opportunities for primitive and 

unconfined recreation, more 

effective management of 

unauthorized motorized use

Lewis and Clark 

NF/Rocky Mountain 

Ranger District

Rocky Mountain Ranger District 

Travel Plan EIS—Birch Creek 

South Area

(Analysis Complete)

The project area extends from

Birch Creek which is situated 

about 17 miles west

of the town of Dupuyer, 

Montana, south about 70 miles 

to Red Mountain near Highway 

200.

(20.2)

2 miles of undetermined road adopted as 

part of the designated transportation system 

within the IRA.

12 miles of non-system trail adopted as part 

of the designated transportation system 

within the IRA (4 of these miles motorized 

trails).

6.2 miles of unneeded existing roads and 

trails decommissioned.

Long-term benefits to 

opportunities for primitive and 

unconfined recreation, more 

effective management of 

unauthorized motorized use
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

128

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

Helena NF/Lincoln RD

Forest-wide Hazardous Tree 

Removal and Fuels Reduction—

HFRA

(Analysis Complete)

approximately 

82 

(2.86) 

Removal of trees that are dead or present a 

hazard (falling) within 1 1⁄2 tree lengths of the 

edge of an open road. The trees to be 

removed in the IRA are all on existing, open 

roads that provide access to trailheads, 

trails, private lands, dispersed recreation 

sites, campgrounds, administrative sites, 

recreation opportunities and general forest 

access. Implementation began Fall 2010.

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation due to the 

increased presence of people and 

noise during project 

implementation. 

Short- term effects to the 

undeveloped characteristics while 

cut stumps are visible. 

Helena NF/Lincoln RD

Blackfoot Winter Travel Plan—

EA 

(Under Analysis)

N/A Designate motorized and non-motorized 

trails for winter use

Long-term benefits to 

opportunities for primitive and 

unconfined recreation, more 

effective management of 

unauthorized motorized use

Helena NF/Lincoln RD

Blackfoot Travel Plan (nonwinter)—EIS 

(Under Analysis)

N/A Designate motorized and non-motorized 

trails

Long-term benefits to 

opportunities for primitive and 

unconfined recreation, more 

effective management of 

unauthorized motorized use

Helena NF/Lincoln RD

Alice Creek Wildlife 

Enhancement Project 

(Under Analysis)

13 miles northeast of Lincoln, 

MT. Bordered by the Continental 

Divide along the north and 

eastern edge, and the 

Scapegoat Wilderness along the 

western side.

2,823

Improve big game winter range by reducing 

conifer encroachment within native 

grasslands. In addition to creating and 

maintaining natural openings and improving 

stand structure, burning would improve 

forage quality and quantity. 

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation due to the 

increased presence of people and 

noise during project 

implementation. 

Short term effects to the 

undeveloped characteristics while 

cut stumps and areas blackened 

by fire are visible. 

Long-term benefits to naturalness 

as winter range and forage are 

improved.

Helena NF/Lincoln RD Dry Creek Rx Fire (planned 

future activity in SW Crown) 2,000 Use of Prescribed fire and mechanical fuels 

treatments to reduce fuel hazards.

Short-term effects to solitude and 

opportunities for primitive and 

unconfined recreation due to the 

increased presence of people and 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

129

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

noise during project 

implementation. 

Short-term effects to the 

undeveloped characteristics while 

cut stumps and areas blackened 

by fire are visible. 

Long-term benefits to naturalness 

as fuel hazards are reduced.

Helena NF/Lincoln RD Weed Treatments (ongoing) 388 Ground based herbicides applied to reduce 

invasive weed infestations.

Short-term effects to solitude 

during project implementation, 

Long-term beneficial effects to 

naturalness as weed infestations 

are reduced.

Helena NF/Lincoln RD Grazing Allotments (ongoing) 17,511 Ongoing grazing in the Alice Creek, Keep 

Cool Liverpool, and Stonewall Allotments

No new impacts to roadless 

resources are anticipated, there 

may be minor long-term (ongoing) 

impacts to naturalness due to the 

presence of livestock.

LoloNF/Seeley Lake RD

Dick Creek Fuels Management 

Project (Analysis complete, 

Decision signed 4/26/2008)

Located near McCabe Point 

within the “Monture Area” of the 

BMSS

1,075

This project includes prescribed burning on 

approximately 1,075 acres of transitory 

range and winter range located near the 

Blackfoot Clearwater Wildlife Management 

Area.

Implementation of approximately 775 acres 

of prescribed burning was conducted in 

2011.

Implementation of remaining approximately 

300 acres of prescribed burning planned for 

fall of 2012, or later depending on available 

burn window. 

This project would not alter the 

natural character of the BMSS 

and when completed would

appear as a natural fire would; 

leaving a mosaic of burn patterns 

on the landscape. Ignition would

be conducted aerially, and control 

lines would utilize natural 

topographic breaks. No tree felling 

would be conducted as part of this 

project that would alter the 

character of the IRA. The feeling 

of isolation and solitude could be 

reduced for a short time period 

while aerial ignition activities 

occur. The sight and sounds of 

the helicopter would affect the 

feeling of solitude in the lower 

reaches of eh Dick Creek 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

130

Forest and District Project Name and Location Acres(miles) 

in BMSS IRA Type of Activity in BMSS IRA Effects

drainage for own to two days.

Lolo NF/Seeley Lake RD

Swan Face Prescribed Burn 

(Analysis Complete, Decisions 

signed 7/25/2011)

Located near Clearwater Lake in 

the Swan Front Area.

2,500 

This project includes the reintroduction of 

fire to restore the role of fire and enhance 

ecosystem processes. Ignition would be 

conducted by hand and aerially, and control 

lines would utilize natural topographic 

breaks.

Implementation of prescribed burning 

planned to be conducted in the fall of 2012.

No tree felling would be 

conducted as part of this project 

that would alter the character of 

the IRA. The feeling of isolation 

and solitude could be reduced for 

a short time period while ignition 

activities occur. The sight and 

sounds of the helicopter would

affect the feeling of solitude in the 

vicinity of the burn for two to three 

days.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

131

Appendix D – Stonewall Roadless Area 

Characteristics Worksheet
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

132

Roadless Areas: The Bear-Marshall-Scapegoat-Swan Inventoried Roadless Area (IRA) is 866,330 acres and managed by the Helena, Lewis and 

Clark, Lolo and Flathead National Forests. The portion of the Bear-Marshall-Scapegoat-Swan IRA managed by the Lincoln Ranger District of the 

Helena National Forest covers 53,995 acres, and the Stonewall Vegetation Project area overlaps with 12,254 acres. The Lincoln Gulch IRA covers 

8,246 acres, and the Stonewall Vegetation Project area overlaps with 3,193 acres.

Table D- 1that follows displays effects to roadless characteristics.

Table D- 1. Effects to roadless characteristics

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

Soil, Water and Air resources

These three key resources are the foundation upon 

which other resource values and outputs depend. 

Healthy watersheds catch, store, and safely release 

water over time, protecting downstream communities 

from flooding; providing clean water for domestic, 

agricultural, and industrial uses; helping maintain 

abundant and healthy fish and wildlife populations; and 

are the basis for many forms of outdoor recreation.

Identify any unique or critical watershed resources. 

Describe how the project will affect these key resources 

areas and the habitats that depend on them.

Yes, Short 

Term

Yes, Short 

Term

Yes, 

Temporary

Stable

Improving

Stable

Soil: 

There would be some immediate effects to soils as fire consumes the organic layer.

Project design features would minimize soil erosion and sediment delivery to 

streams is not likely.

Water:

Decreased forest canopy would lead to an increased risk of surface erosion for about 

a year after a high severity fire or mixed severity burns. High severity burns would

not pose an adverse risk of sedimentation unless they are over more than 10-20 acres 

and on steeper slopes. High severity burns near streams pose the highest risk for 

sedimentation. However, riparian buffers would provide protection and reduce the 

risk of sedimentation reaching streams. After about a year, vegetative recovery and 

reduced wildfire risk would improve conditions compared to present conditions. 

Air:

Management activities would likely cause direct short-term impacts from dust and 

smoke.

Dust would be generated through various activities including transportation of 

material. These activities are not anticipated to result in significant impacts to 

regional air quality because of the transitory nature of fugitive dust.

Smoke from burning operations could produce some smoky days in the local area 

and generally lasts 1-3 days after ignition is completed. Smoke may settle into the 

lower draws and drainages during the evening hours following ignition. 

Permissible burn days are determined based on metrological conditions that tend to 

disperse smoke.

Sources of public drinking water Maybe Stable, then after a No sources of drinking water would be affected by the project.
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

133

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

National Forest System lands contain watersheds that 

are important sources of public drinking water. 

Roadless areas within the National Forest System 

contain all or portions of 354 municipal watersheds 

contributing drinking water to millions of citizens. 

Maintaining these areas in a relatively undisturbed 

condition saves downstream communities millions of 

dollars in water filtration costs. Careful management of 

these watersheds is crucial in maintaining the flow and 

affordability of clean water to a growing population.

Identify any public drinking water systems or sources 

within the project area or that would be affected by the 

project. Describe how the project would affect water 

quality and quantity of the public drinking water 

source.

year Improving

Diversity of plant and animal communities

Roadless areas are more likely than roaded areas to 

support greater ecosystem health, including the 

diversity of native and desired nonnative plant and 

animal communities due to the absence of disturbances 

caused by roads and accompanying activities. 

Inventoried roadless areas also conserve native 

biodiversity by serving as a bulwark against the spread 

of nonnative invasive species.

Discuss the diversity of plant and animal communities.

Identify any unique plant and animal communities 

within the area. Describe effects to the diversity of 

communities and impacts to populations in the areas.

Yes Stable/Improving Project IRA’s provide habitat for large number of wildlife species that depend on 

their remote forested character including nine threatened, endangered and sensitive 

species (discussed below). These areas provide critical lynx habitat, grizzly bear core 

and den habitat and wolverine den habitat. While activities proposed under 

alternatives 2 and 3 would result in short-term disturbance, because no new roads are 

proposed, all alternatives would maintain the remote character of the area and longterm human access would be unchanged under all alternatives. Approximately 

23,000 acres have recently burned and due to elevated fuel conditions, the likelihood 

of stand replacing wildfire and a long-term loss of suitable wildlife habitat is greatest 

under alternative 1, whereas alternatives 2 and 3 both reduce the risk of catastrophic 

wildfire. Vegetative diversity would be relatively unchanged under alternative 1, 

although a continued reduction in whitebark pine and aspen is likely to occur. 

Treatments proposed under alternatives 2 and 3 would enhance stand and landscape 

level vegetative and habitat diversity, including maintenance or improvement of 

white-bark pine and aspen.

Habitat for TES and species dependent on large 

undisturbed areas of land

Roadless areas function as biological strongholds and 

refuges for many species. Of the nation’s species 

currently listed as threatened, endangered, or proposed 

Yes Stable/Improving Plants:

Under both alternatives, all treatments in the roadless areas would be prescribed 

burning with hand preparation. More area would be treated under alternative 2. TES 

plants: Pinus albicaulis (whitebark pine) is the only sensitive species found in the 

project area. Sensitive plant habitat has not been mapped in the project area, but 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

134

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

for listing under the Endangered Species Act, 

approximately 25% of animal species and 13% of plant 

species are likely to have habitat within inventoried 

roadless areas on National Forest System lands. 

Roadless areas support a diversity of aquatic habitats 

and communities, providing or affecting habitat for 

more than 280 threatened, endangered, proposed, and 

sensitive species. More than 65% of all Forest Service 

sensitive species are directly or indirectly affected by 

inventoried roadless areas. This percentage is 

composed of birds (82%), amphibians (84%), mammals 

(81%), plants (72%), fish (56%), reptiles (49%), and 

invertebrates (36%). 

Identify any TES or sensitive species within the 

Roadless area. Describe how the project would affect 

the habitats or populations and whether this effect is 

significant across the normal range and distribution of 

these habitats and populations.

there is likely to be potential habitat for eight additional herbaceous sensitive plant 

species. None of the herbaceous sensitive plants would be directly affected unless 

there are undiscovered occurrences in the roadless area. Treatment in the roadless 

area would be prescribed burns, generally of mixed severity that would create 

openings less than 75 acres in size. Low severity burns would be expected to have 

minimal impacts since these herbaceous species have adaptations to fire and all 

typically grow in moist to wet areas that would be less likely to burn. Large openings 

in the canopy could reduce the shade that is needed by several of these species. 

These species and their habitat would be expected to be similarly affected by 

wildfire. Occurrences of whitebark pine would be protected by the project design 

feature SILV-2 which is designed to protect individuals and enhance habitat for the 

species. Thus, while there is the potential for individuals to be charred or physically 

damaged during the treatment, beneficial effects for whitebark pine (in the form of 

habitat enhancement due to the removal of shade-tolerant species and creation of 

caching sites for Clark’s nutcrackers) are expected in the long-term.

Invasive plants: Small areas of spotted knapweed overlap roadless area units 80, 82, 

and 84. Effects of fire on spotted knapweed are variable but available studies have 

shown that fire may kill above ground plant parts but the sturdy perennial taproot is 

likely to survive all but the most severe fires. For the most part, spotted knapweed 

may be expected to establish, persist, or spread following fire. In some cases hot 

fires have shown the greatest increase in spotted knapweed cover after several years 

(Zouhar 2001). Project design features and the ongoing weed management program 

on the Helena National Forest (which treats 1/3 of infested acres each year) would 

reduce the potential for new establishment and spread of spotted knapweed in the 

roadless areas as a result of proposed actions.

Animals:

Project IRA’s provide habitat for two federally listed species including the grizzly 

bear and Canada lynx and seven Regionally Sensitive Species including the gray 

wolf, wolverine, fisher, Townsend’s big-eared bat, black-backed woodpecker, 

flammulated owl and western toad. The following is a brief discussion of anticipated 

effects to these species. 

Grizzly Bear – All but approximately 2,700 acres of Project level IRA’s are 

considered occupied grizzly habitat and these areas contain 39,000 acres of grizzly 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

135

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

bear core habitat and over 8,000 acres of den habitat. Because there are no roads 

proposed in the IRA, core habitat and Total Motorized and Open Motorized Road 

Densities would be unaffected under all alternatives. Under alternative 1, den habitat 

would be unaffected. Also while suitable habitat would be largely unchanged, over 

the long-term due to the absence of fire, whitebark pine would continue to decline 

under alternative 1. Under alternatives 2 and 3, localized short-term increases in 

human disturbance would occur during burning. Due to proposed low and mixed 

severity burning there would also be a reduction in cover on 4,845 acres and 3,564 

acres under alternatives 2 and 3 respectively, although cover would be maintained 

within and adjacent to all units. Of this, potential short-term impacts to 979 acres of 

den habitat would occur under alternative2 and 920 acres of den habitat would be 

affected under alternative3. Unaffected den habitat would be widely available under 

both alternatives. Both alternatives 2 and 3 would maintain or promote development 

of white bark pine.

Canada Lynx – Project level IRA’s contain 32,587 acres of Lynx critical habitat. 

Because there is no hare habitat proposed for treatment within the IRA, lynx 

foraging habitat would remain relatively unchanged under all alternatives. Also due 

to the absence of treatment, lynx cover would be unchanged under alternative 1.

Under alternatives 2 and 3, low and mixed severity fire would occur on 3,349 acres 

and 2,410 acres of suitable den habitat respectively and cover would be reduced on 

most of this acreage. However considering that up to 25 percent of the treatment 

sites would have unburned lands, suitable cover would continue to occur on all 

treatment sites. Also due to establishment of understory vegetation, proposed actions 

would increase long-term foraging habitat on the acreage treated. Large blocks of 

unaffected suitable habitat would be available in all watersheds and connectivity and 

landscape level habitat would be maintained under all alternatives. All alternatives 

are consistent with NRMLD standards and guidelines. 

Gray Wolf – Due to its remote nature, virtually all of the project IRA’s provide 

suitable gray wolf habitat, although no known den or rendezvous sites would be 

affected under any alternative. Also because there are no new roads proposed, longterm human access would be unchanged under all alternatives, although alternative 2

and 3 would increase short-term human access 4,845 and 3,565 acres respectively.

Gray wolf foraging habitat would likely continue to decline in some areas but would

generally be maintained under alternative 1, whereas under alternatives 2 and 3, wolf 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

136

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

foraging would be maintained in the short-term and increased in the long-term.

Wolverine – Project level IRA contain approximately 16,500 acres of wolverine den 

habitat. Prey availability and landscape connectivity would be largely unchanged 

under all alternatives. Den habitat under alternative 1 would be unaffected, whereas 

mixed severity burning would affect 1,648 acres or 10 percent of the suitable IRA 

den habitat under alternatives 2 and 3. Also there would be a short-term increase in 

human activity on this acreage, as well as a long-term reduction in cover. However 

90 percent of the suitable habitat would be unaffected and suitable den and foraging 

habitat would continue to be available in all affected watersheds under all 

alternatives.

Fisher – Project IRAs contain 478 acres of fisher summer habitat and 21,800 acres 

of winter habitat. Under alternative 1 suitable habitat and prey availability would be 

largely unchanged. Also because there would be no new roads, long-term human 

access would be unchanged under all alternatives. Due to proposed low and mixed 

severity burning, short-term disturbance to foraging individuals and a reduction in 

cover would occur on 39/1,189 acres of summer/winter habitat under alternatives 2 

and 49/718 acres of summer/winter IRA habitat under alternative3. Also due to the 

canopy openings associated with mixed severity burning, suitable summer/winter 

habitat would be reduced 4/207 acres and 1/66 acres under alternatives 2 and 3 

respectively. Preferred riparian habitat and travel corridors would be maintained 

under all alternatives. 

Townsend’s big-eared Bat – Most of the project IRA’s provide suitable foraging 

habitat for this species and under alternative 1 foraging habitat would be unaffected.

Proposed burning would create more open understory conditions and improved 

foraging habitat on 3,564 and 4,845 acres under alternatives 2 and 3 respectively.

While habitat would be reduced on sites where canopy openings would be created 

through mixed severity burning under alternatives 2 and 3 (up to 900 acres), suitable 

foraging habitat would continue to be widespread under all alternatives.

Black-backed Woodpecker – Project IRAs contain approximately 23,000 acres of 

recently burned high quality black-backed woodpecker habitat. In the absence of 

future wildfires, habitat may decline under alternative 1. Under alternatives 2 and 3, 

high intensity burning would create high quality habitat on approximately 1,500 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

137

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

acres and 1,000 acres respectively.

Flammulated Owl – Suitable flammulated owl habitat occurs on approximately 

4,300 acres of project IRAs. Under alternative 1, preferred open canopy habitat 

would continue to decline. Proposed burning under alternatives 2 and 3 would 

increase open canopy habitat on 3,900 acres and 2,900 acres respectively. 

Western Boreal Toad – Suitable breeding habitat would be largely unchanged 

under all alternatives. While proposed burning would affect upland habitat on 

approximately 4,600 acres under alternatives 2 and 3, suitable habitat would

continue to occur on all sites and foraging habitat would be improved on the acreage 

affected. Unaffected suitable upland habitat predominates across all watersheds 

under all alternatives.

Primitive and semi-primitive classes of recreation

Roadless areas often provide outstanding dispersed 

recreation opportunities such as hiking, camping, 

picnicking, wildlife viewing, hunting, fishing, cross 

country skiing, and canoeing. While they may have 

many Wilderness-like attributes, unlike Wilderness the 

use of mountain bikes, and other mechanized means of 

travel is often allowed. These areas can also take 

pressure off heavily used wilderness areas by providing 

solitude and quiet, and dispersed recreation 

opportunities.

Describe current recreation opportunities within the 

Roadless area. Identify the effects of your project on 

the area and these activities. Describe the effect in 

terms of availability for similar experiences in 

surrounding areas or within the region of use. Consider 

link to ROS mapping.

Yes Stable The ROS classification in the Bear-Marshall-Scapegoat-Swan and Lincoln Gulch 

IRAs is primarily Semi Primitive Motorized with areas of Roaded Modified and 

Roaded Natural. The primary recreation activities occurring within the roadless areas 

include hunting, hiking, dispersed camping, use of motorized trails in the summer 

and snowmobiling and cross-country skiing in the winter. In the short term, visitors 

may be temporarily displaced during implementation of the proposed activities 

(prescribed burning, hand slashing of small diameter trees and construction of hand 

fireline). Noise associated with hand slashing of small diameter trees and hand 

fireline construction would affect the expected experience associated with the areas’ 

roadless character, however this would only impact visitors traveling through the 

area during project implementation. The proposed low severity and mixed severity 

prescribed fire would create openings ranging from 5 to 75 acres in size, the more 

open forest canopy is not expected to affect the recreation activities or experience 

within or adjacent to the project area in the long term. However, the prescribed fire 

activities would be noticeable by the area users, affecting the on-site management 

component of the expected setting. No road construction, reconstruction or 

maintenance is proposed within the IRA acreage; therefore the current IRA roadless 

characteristic would not change. There would be no long term impacts to recreation 

opportunities within the project area. Ecosystem restoration and a reduction in the 

risk of negative impacts from severe wildfire would help to maintain the recreation 

settings and opportunities.

Alternative 2 would treat 4,846 acres out of the total combined 71,256 acres of both 

IRAs (managed by the Lincoln Ranger District); the prescribed fire would be 
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

138

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

implemented on 6.8 percent of the total Lincoln RD IRA acreage. Alternative 3 

would treat 3,564 acres out of the total combined 71,256 acres of both IRAs 

(managed by the Lincoln Ranger District); the prescribed fire would be implemented 

on 5 percent of the total Lincoln RD IRA acreage. Opportunities to continue the 

popular dispersed recreation activities would exist over the vast majority of the IRA 

acreage during project implementation and would continue to exist on all of the IRA 

acres after project completion. 

Reference landscapes for research study or 

interpretation

The body of knowledge about the effects of 

management activities over long periods of time and on 

large landscapes is very limited. Reference landscapes 

of relatively undisturbed areas serve as a barometer to 

measure the effects of development on other parts of 

the landscape.

Describe the landscape that is present. Describe any 

unique reference landscapes that exist within the 

Roadless area. Describe how the project activities 

might affect the reference landscape values of the 

Roadless area. Consider how the landscapes within the 

Inventoried Roadless area fits within the broader 

landscape and if the project creates any overall change.

Consider landscape character descriptions in SMS.

No Stable No documentation regarding reference landscapes within the project area were 

found. The current landscape is comprised of dense forests susceptible to insect and 

wildfire mortality (Douglas-fir and lodgepole pine). In addition, a large-scale 

mountain pine beetle epidemic has killed most of the mature lodgepole pine and 

ponderosa pine. The proposed action would result in a landscape setting that 

resembles a wildfire event which naturally follows a pine beetle event. Forest 

regeneration and “greenup” would occur shortly thereafter and improve upon the 

visual appearance of this landscape cycle by resembling an increasingly healthy 

forest.

Natural appearing landscapes with high scenic 

quality. 

High quality scenery, especially scenery with naturalappearing landscapes, is a primary reason that people 

choose to recreate. In addition, quality scenery 

contributes directly to real estate values in nearby 

communities and residential areas.

Describe the current scenic quality and character of the 

area. Describe project effects to the scenic integrity of 

the area and changes to the character of the area.

Consider existing scenic integrity.

Yes Stable The current scenic quality of the unroaded areas resembles that of landscapes with 

high scenic integrity. Although visually unappealing to many, the scenes created by 

large scale beetle kill and wild fires (within their natural regime) do not change a 

landscapes scenic integrity or visual quality per the visual or scenery management 

systems. However, events that occur outside of a natural regime due to management 

decision (i.e., fire suppression) can. The proposed prescribed fire would help ensure 

the forest maintains a visual appearance characteristic of a wildfire within its natural 

regime as opposed to an unnaturally intense wildfire.

The scenic integrity within the IRAs may decrease from the viewpoint of a user 

traveling through the proposed prescribe fire treatment units. The fire handlines 

would create a linear disturbance within the roadless area and stumps from the hand 
Stonewall Vegetation Project Draft Environmental Impact Statement – Appendices 

139

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

Scenic Quality- essential attributes of the landscape. 

(Glossary 5, Landscape Aesthetics Handbook)

Landscape Character – Particular attributes, qualities, 

and traits of a landscape that give it an image and make 

it identifiable or unique. (Glossary 3, Landscape 

Aesthetics Handbook)

slashing of small diameter trees may remain visible for several seasons following the 

prescribed fire, which would be an unexpected characteristic for the IRA landscape.

The creation of openings in the forest from low and mixed severity prescribed fire 

ranging from 5 to 75 acres in size would create a more natural and visually appealing 

mosaic in the landscape, enhancing the overall existing landscape character. Less 

than 4,846 acres out of the combined 71,256 acres of both IRAs (managed by the 

Lincoln Ranger District) would be affected and only the users who travel through 

these areas would notice these changes.

Traditional cultural properties and sacred sites

Traditional cultural properties are places, sites, 

structures, art, or objects that have played an important 

role in the cultural history of a group. Sacred sites are 

places that have special religious significance to a 

group. Traditional cultural properties and sacred sites 

may be eligible for protection under the National 

Historic Preservation Act. However, many of them 

have not yet been inventoried, especially those that 

occur in inventoried roadless areas.

Identify generically any significant cultural resources 

within the Roadless area and describe the effect of the 

project on these resources. Typically mitigation will be 

designed to prevent significant effects to these 

resources.

Yes Degrading Hand slash pile burning within sites could affect historic structures and could alter 

prehistoric site artifacts. Hand lines within sites could alter historic and prehistoric 

sites.

Other locally unique characteristics

Inventoried roadless areas may offer other locally 

identified unique characteristics and values. Examples 

include uncommon geological formations, which are 

valued for their scientific and scenic qualities, or 

unique wetland complexes. Unique social, cultural, or 

historical characteristics may also depend on the 

roadless character of the landscape. Examples include 

ceremonial sites, places for local events, areas prized 

for collection of non-timber forest products, or 

exceptional hunting and fishing opportunities.

No N/A The proposed action would not impact the special features or values of the BearMarshall-Scapegoat-Swan IRA because they do not fall within the Stonewall project 

area. In the long-term, the proposed action would potentially enhance the productive 

and primitive Elk hunting opportunities within the Lincoln Gulch IRA.
Appendices – Stonewall Vegetation Project Draft Environmental Impact Statement

140

Roadless Characteristics

As described in 36 CFR 294 – Roadless Area 

Conservation Final Rule, 2001

Is there an 

effect?

Yes or No

Is the effect 

improving, stable 

or degrading?

Describe the actual effect. Use descriptive terms that discuss the 

effect, not the activity. Explain if the proposal would alter or modify the 

landscape.

Identify any locally unique characteristics and describe 

how the project would affect these values.