Record of Decision

East Deer Lodge Valley Landscape 

Restoration Management Project

Pintler Ranger District, Beaverhead-Deerlodge National Forest

Powell and Deer Lodge Counties, Montana

United States 

Department of 

Agriculture

Forest

Service

March 2015
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, parental 

status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an 

individual's income is derived from any public assistance program. (Not all prohibited bases apply to all 

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 TDD). 

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 (TDD). USDA is an equal 

opportunity provider and employer.
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Table of Contents

Introduction...................................................................................................................................................2

Location ........................................................................................................................................................2

Background...................................................................................................................................................2

Purpose and Need for Action........................................................................................................................4

Decision ........................................................................................................................................................5

Decision Rationale......................................................................................................................................23

Rationale Based on Meeting the Purpose and Need...............................................................................23

Rationale Based on Minimization of Environmental Impacts................................................................27

Decision Rationale Conclusion...............................................................................................................29

Public Involvement .....................................................................................................................................29

Scoping...................................................................................................................................................30

Forty-Five Day Public Comment Period - DEIS....................................................................................30

Forty-Five Day Public Comment Period - Revised DEIS ......................................................................31

Objection Process Pursuant to 36 CFR 218............................................................................................31

Other Alternatives Considered....................................................................................................................32

Alternative 1 – No Action ......................................................................................................................32

Alternative 2 – The DEIS Proposed Action ...........................................................................................32

Findings Required by Other Laws and Regulations ...................................................................................33

Implementation Date...................................................................................................................................37

Contact Person ............................................................................................................................................37

Appendix A – Selected Alternative Maps...................................................................................................38

Appendix B – Biological Assessments and Concurrence Letters from U.S. Fish and Wildlife Service ....39

Appendix C – Documentation of Review and Consideration of Literature Referenced in Objection........40

List of Tables

Table 1. Selected Alternative - Timber Units...............................................................................................6

Table 2. Selected Alternative restoration units.............................................................................................9

Table 3. Selected Alternative - Culvert Actions.........................................................................................10

Table 4. Selected Alternative - Aquatic and Riparian Restoration Activities.............................................11

Table 5. Selected Alternative- Restoration Activities Related to Roads and Trails ...................................13

Table 6. Comparison of how each alternative meets components of purpose and need.............................24

Table 7. Comparison of actions and effects associated with each alternative ............................................25

Table 8. Modifications made to Alternative 3 in Selected Alternative – Timber Units..............................27

Table 9. Modifications made to Alternative 3 in Selected Alternative - Routes ........................................29
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Introduction

This Record of Decision (ROD) documents my decision for the East Deer Lodge Valley Landscape Restoration

Management Project (EDLV Project) on the Pintler Ranger District, Beaverhead-Deerlodge National Forest (BDNF). 

My decision is based on and supported by the analysis in the February 2015 Final Environmental Impact Statement 

(FEIS) and the project record. 

Location

The EDLV project area (Figure 1) consists of approximately 39,651 acres within the East Deerlodge Management 

Area. The management area encompasses 47,383 acres, of which approximately 39,651 acres are National Forest 

System (NFS) lands managed by the BDNF. It is one of eight management areas included in the larger Clark ForkFlint Landscape (Forest Plan pg. 109) located east and southeast of the city of Deer Lodge in southwest Montana. 

The project area is located in both Deer Lodge and Powell Counties. The management area is bounded by private 

and state-owned lands along the Deer Lodge Valley on the west and by the Boulder Mountains sloping up to the 

Continental Divide on the east.

Background

The Beaverhead-Deerlodge National Forest (BDNF), Pintler Ranger District, proposed the East Deer Lodge Valley 

(EDLV) Landscape Restoration Management Project in response to public interest in conducting landscape 

management activities. In early 2006, the Forest Service was approached by what is now known as the “Forest 

Stewardship Partnership” (FSP), a coalition of governments, nongovernmental organizations, and private industry. 

The FSP proposed a collaborative effort to plan an integrated forest stewardship and watershed restoration project in 

the East Deerlodge Management Area. The goal of this collaboration was to restore resources and conditions on the 

landscape through stewardship contracting, where receipts or credits from timber salvage and thinning, along with 

other sources of potential funding, would be used to implement various restoration activities across the project area.

The East Deerlodge Management Area provides for a wide range of human uses as well as habitat for many fish, 

wildlife, and plant species. Ongoing uses within the project area include motorized and non-motorized recreation, 

hiking, commercial and recreational mining, livestock grazing, timber harvest, firewood cutting, scenic touring, offhighway vehicle (OHV) riding, snowmobiling, hunting, camping, and fishing.

Vegetation within the project area includes coniferous forests – primarily lodgepole pine and Douglas-fir, – meadows 

and quaking aspen groves at higher elevations, aspen along the foothills and moist draws, and sagebrush along 

grassland-conifer interfaces at the tops of large benches and on southerly aspects of mountain streams. Vegetation 

patterns have changed during the past century due to natural forest growth and forest management activities, 

including fire suppression, livestock grazing, and timber harvest. The resulting changes in the composition and 

structure of plant communities include denser stands of timber, multi-storied stands, and more forested areas. This, 

in combination with prolonged drought and recent warmer temperatures over the last decade, has increased the 

susceptibility of trees in the project area to mortality from natural disturbance processes. The mountain pine beetle 

has been the most prevalent cause of mortality with the most widespread mortality being concentrated in lodgepole 

pine stands. Generally, mountain pine beetles act as thinning agents by killing weak individuals in dense stands of 

trees. During epidemics, such as the project area is currently experiencing, widespread tree mortality is readily 

apparent.

2
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Figure 1. Project area vicinity map

3
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Purpose and Need for Action

The purpose and need for the EDLV Landscape Restoration Management Project is to contribute to attainment of the 

following forest-wide goals and objectives for timber management, vegetation, aquatic resources, and wildlife habitat:

Timber Management Goals

o Manage lands suitable for timber production for the growth and yield of sawtimber, crop trees, pulpwood, and 

other forest products, including salvage harvest (Forest Plan, pg. 38). 

o Manage lands where timber harvest is allowed to protect other resource values (Forest Plan, pg. 38).

o Product Utilization: Forest products would be used to provide economic benefits where project objectives, 

Forest Plan objectives, and Forest Plan standards can be met (Forest Plan, pg. 38).

Vegetation Goals and Objectives

o Reduce stand densities in the large size classes of dry forest communities and some lodgepole pine 

communities to maintain or improve resilient forest conditions (Forest Plan, pg. 43). 

o Increase the number of acres of lodgepole pine in the 0-5” inches diameter-at-breast-height (dbh) class by 

approximately 74,000 acres, where burned or insect infested stands are dead or dying (Forest Plan, pg. 44).

o Increase the aspen component within lodgepole pine and other vegetation types on 67,000 acres (Forest Plan, 

pg. 44).

o Reduce conifer encroachment on 74,000 acres of riparian areas, shrublands, and grasslands (Forest Plan, pg. 

44).

Aquatic Resources Goals and Objectives

o Restoration Key Watershed: Fish habitat, riparian habitat, and water quality are recovered to desired conditions 

developed through watershed assessments (Forest Plan, pg. 13).

o Fish Key Watershed: Populations of bull trout and westslope cutthroat trout exhibit numbers, life histories, age 

classes, recruitment levels, and reproductive characteristics representative of historic conditions (Forest Plan, 

pg. 13).

o Watershed Restoration Projects: Projects are designed and implemented to promote long-term ecological 

integrity of ecosystems, conserve the genetic integrity of native species, and contribute to attainment of desired 

stream function (Forest Plan, pg. 13).

o Total Maximum Daily Loads (TMDLs): Management actions are consistent with TMDLs (Forest Plan, pg. 13).

o Roads: Close and stabilize or obliterate and stabilize roads not needed for future management activities (Forest 

Plan, pg. 17).

o Stream Channels: Stream channel attributes and processes are maintained and restored to sustain natural 

desired riparian, wetland, and aquatic habitats and keep sediment regimes as close as possible to those with 

which riparian and aquatic ecosystems developed (Forest Plan, pg. 13). 

o Riparian Areas: Riparian habitat, species composition, and structural diversity of native and desired non-native 

riparian plant communities are maintained or restored to: (Forest Plan, pg. 14):

4
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

• Provide an amount and distribution of woody debris characteristic of functioning aquatic and riparian 

ecosystems;

• Provide adequate summer and winter thermal regulation to support beneficial uses;

• Provide bank stability to maintain rates of surface erosion, bank erosion, and channel migration which are 

characteristic of functioning aquatic and riparian ecosystems;

• Effectively trap and store sediment, build stream banks and floodplains, and promote recovery after 

watershed disturbance.

o Sensitive Aquatic Species: Viable populations of sensitive aquatic species are maintained (R1 Sensitive Species 

list) by managing habitat (Forest Plan, pg. 14).

Wildlife Habitat Goals

o Manage density of open motorized roads and trails by landscape year-round, except fall rifle big game season, 

to achieve levels at or below 1.9 mi/mi2 for the Clark Fork - Flints Landscape (Forest Plan, Table 13, pg. 45)

o Manage open motorized road and trail density by MTFWP hunting units during the fall rifle big game season to 

achieve levels at or below 1.5 mi/mi2 for Hunting Unit 215 (Forest Plan, Table 14, pg. 46).

Decision

Based upon my review of all public comments received, the analysis in the FEIS, and the project record, I have 

decided to select Alternative 3 with some modifications (hereafter referred to as the selected alternative) to achieve 

the purpose and need of the project. The selected alternative will contribute to attainment of several Forest Plan 

goals and objectives through implementation of a mix of actions as described below. Actions described in narrative 

and tabular format in this section are also depicted on the Selected Alternative maps (Appendix A).

Treatments in Timber units

The selected alternative includes treatment in 52 timber units totaling approximately 2,541 acres (Table 1).

Treatments in timber units would consist of commercial salvage and commercial thinning. In summary, the following 

would occur within these units:

1. Commercial salvage of lodgepole pine from 4-15 inches dbh in 43 units totaling 2,038 acres. 

2. Commercial thinning of Douglas-fir from 4-15 inches dbh and commercial salvage of lodgepole pine from 4-

15 inches dbh in 6 units totaling 340 acres. 

3. Commercial thinning of Douglas-fir from 4-15 inches dbh in 3 units totaling 162 acres. 

The following timber units would be harvested in the winter when ground is frozen: 5T, 11T, 17T, 19T, 23T, 25T, 29T, 

37T, 41T, 42T, 45T, 48T, 52T, 53T, 76T, 80T, 82T.

Harvest in most units would generally use ground-based methods (e.g., mechanized harvester, grapple skidder, delimber, and forwarder); although a skyline cable system might be used in portions of some steeper units (3T, 24T, 

25T). Harvested trees would be whole-tree yarded to landings where non-merchantable trees and slash residues 

would be piled and later burned, chipped, and/or utilized as biomass products. Slash may be made available for 

firewood prior to burning. 

Table 1 below also indicates where openings greater than 40 acres would occur. In some units, mixed stands of 

Douglas-fir and lodgepole pine are greater than 40 acres, but would not result in openings greater than 40 acres, as 

shown in the table below.

5
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Table 1. Selected Alternative - Timber Units

Unit Sub- watershed(s) Acresf Treatment 

Creates openings 

greater than 40 

acres?

1T Dry Cottonwood Cr. 7 Salvage LP No

2T Dry Cottonwood Cr. 48 Salvage LP, Thin DF No

3T a, b Dry Cottonwood Cr. 85 (63 ground, 22 

cable) Salvage LP No

5T b, e Dry Cottonwood Cr. 25 Salvage LP No

10T b

Sand Hollow 126

Salvage LP Yes

Dry Cottonwood Cr. 58

11T e Sand Hollow 32Salvage LP No

Orofino 7

15T b Orofino 106 Salvage LP, Thin DF Yes

17Tb, e Peterson (TMDL) c 55Salvage LP Yes

Orofino 28

18T Orofino 29 Salvage LP No

19T b, e Orofino 47 Salvage LP, Thin DF No

20T b Orofino 26 Salvage LP No

21T b Peterson (TMDL) c 106 Salvage LP No

22T Peterson (TMDL) c 2 Salvage LP No

23T e Peterson (TMDL) c 24 Salvage LP No

24T a Peterson (TMDL) c 49 (38 ground,11 cable) Salvage LP Yes

25T a, e Peterson (TMDL) c 217 (184 ground, 33 

cable) Salvage LP Yes

Fred (Fish Key) 13 (9 ground, 4 cable)

26T b Peterson (TMDL) c 24 Salvage LP No

28T b Peterson (TMDL) c 9 Salvage LP No

29T b, e Peterson (TMDL) c 29 Salvage LP No

30T d Orofino 4 Salvage LP No

33T Dry Cottonwood Cr. 21 Salvage LP No

34T Dry Cottonwood Cr. 12 Salvage LP No

36T Dry Cottonwood Cr. 18 Salvage LP No

37T b, e Girard Gulch (Rest’n Key) 57 Salvage LP, Thin DF No

38T b Girard Gulch (Rest’n Key) 25 Salvage LP No

40T Fred (Fish Key) 51 Salvage LP Yes

Peterson (TMDL) c 4 Salvage LP 

41T e Fred (Fish Key) 3 Salvage LP No

42T e Fred (Fish Key) 94 Salvage LP Yes

45T d. e Fred (Fish Key) 92 Salvage LP Yes

46T Fred (Fish Key) 33 Salvage LP No

6
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Unit Sub- watershed(s) Acresf Treatment 

Creates openings 

greater than 40 

acres?

47T Fred (Fish Key) 30 Salvage LP No

48T e Fred (Fish Key) 10 Salvage LP No

52T e Fred (Fish Key) 16 Salvage LP No

53T e Fred (Fish Key) 28 Salvage LP No

56T b Fred (Fish Key) 52 Salvage LP Yes

57T b Fred (Fish Key) 112 Salvage LP Yes

61T Fred (Fish Key) 72 Salvage LP Yes

65T Fred (Fish Key) 7 Salvage LP No

68T b Fred (Fish Key) 61 Salvage LP Yes

70T b Girard Gulch (Restoration Key) 32 Salvage LP, Thin DF No

72T Girard Gulch (Restoration Key) 17 Thin DF No

73T b Girard Gulch (Rest’n Key) 94 Thin DF No

74T Dry Cottonwood Cr. 20 Salvage LP No

75T b Dry Cottonwood Cr. 40 Salvage LP No

76T e Peterson (TMDL) c 20 Salvage LP No

77T b Girard Gulch (Restoration Key) 51 Thin DF No

78T b Fred (Fish Key) 19 Salvage LP No

80T b, e Fred (Fish Key) 150 Salvage LP Yes

82T b, e Fred (Fish Key) 47 Salvage LP Yes

83T b Girard Gulch (Restoration Key) 50 Salvage LP, Thin DF No

85T b Fred (Fish Key) 40 Salvage LP No

86T b Fred (Fish Key) 10 Salvage LP No

Total treatmentsf 2,541 acres, 52 units

Subtotal of LP treatmentsf 2,038 acres, 43 units

Subtotal of DF treatmentsf 162 acres, 3 units

Subtotal of LP/DF treatmentsf 340 acres, 6 units

a. A skyline cable system might be used in portions of some steeper units 3T, 24T, and 25T.

b. Unit would be accessed by a temporary road that would be decommissioned by obliteration following harvest activities.

c. A “Total Maximum Daily Load” (TMDL) has been established for a water body in this subwatershed to control non-point source 

pollutants, per section 303(d) of the Clean Water Act; see Hydrology section of FEIS.

d. Harvest from units 30T and 45T is dependent upon purchaser acquiring access through private property.

e. Unit would be harvested in the winter when ground is frozen. 

f. Unit acres have been rounded to the nearest whole number for purposes of display. Totals and Subtotals have been calculated 

using the non-rounded numbers and therefore may not reflect the sum of the rounded unit by unit acreage numbers.

Implementation of the selected alternative includes log hauling activity on 108.8 miles of haul routes: 65.7 miles 

would occur on existing roads within the project area, including 2.2 miles of temporary roads created from existing 

non-system routes that would be obliterated following harvest; 8.2 miles would occur on newly constructed temporary 

roads that would be obliterated following harvest; and 32.7 miles would occur on existing access routes outside of the 

project area. 

7
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Treatments in Restoration Units

The selected alternative also includes 19 restoration units totaling 8,768 acres. Actions described in narrative and 

tabular format in this section are also depicted on the Selected Alternative maps (Appendix A). A variety of treatments 

will occur within these units as described below:

1. Cut Encroaching Conifers in Parks/Meadows: Conifer encroachment treatments would be implemented in all 

restoration units:

• Within parks or within 11⁄2 tree lengths of parks/meadow edges, conifers up to 12 inches dbh will be cut 

unless they had old growth characteristics or desirable characteristics associated with wildlife values 

(e.g., snags). 

• Cut materials would be left in place until removed or jackpot burned. After jackpot burning, areas will be 

monitored for weeds and treated as needed. 

• The selected alternative allows recovery of merchantable trees from restoration units only within 150 

feet of existing access roads; skid trails will be used, however, construction of new or temporary roads 

would be prohibited in these units.

2. Cut Encroaching Conifers in Aspen: The selected alternative includes actions that retain and protect aspen on 

the landscape. Along park/conifer boundaries (ecotones), draws, and isolated aspen stands within open parks, 

aspen enhancement treatments will be implemented where decadent, declining, or remnant aspen clones occur:

• Cut and leave (jackstraw) conifers up to 15 inches dbh growing in or within 11⁄2 tree lengths of aspen 

clones.

3. Thin Douglas-fir: Non-commercial thinning treatments would be implemented in Douglas-fir dominated stands in 

all restoration units:

• Conifers less than 7 inches dbh located within 1 tree length of larger Douglas-fir will be felled. 

• Trees slashed will be jackpot burned. 

• The selected alternative allows recovery of merchantable trees from restoration units only within 150 

feet of existing access roads; skid trails would be used, however, construction of new or temporary 

roads would be prohibited in these units.

4. Enhance Riparian Habitat: The selected alternative includes the following treatments:

• Construct “worm” fencing where practicable using nearby, smaller diameter lodgepole pine.

• Fell dead lodgepole pine (“tree felling”) along riparian areas.

5. Develop Water Structures: The selected alternative includes installation of off-site water structures to reduce 

riparian impacts from livestock. Off-site water structures include a tank structure with water supplied via pipeline 

from a nearby creek or spring source. A collection device, such as a perforated pipe installed within the creek or 

a headbox installed next to the creek or in the spring, will collect water. A valve will control water flow to the tank. 

Overflow water from the tank will be diverted via buried pipeline to an adjacent drainage or back to the creek 

downstream from the water intake. Water to the tanks will be gravity fed. Installation of the off-site water features 

will be performed under a cooperative agreement with the permit holder for the allotment. The water source will

be protected (e.g., fence) if necessary. The selected alternative includes the following off-site water structures:

• Off-stream water development from North Fork Dry Cottonwood in Dry Cottonwood allotment, adjacent to 

restoration unit 10.

• Off-stream water development from tributary to Orofino Creek Dry Cottonwood allotment, in restoration unit 

14. 

8
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

• Spring development in Lockhart-Whitehouse allotment, in restoration unit 15.

• Off-stream water development from Dieders Fork in Lockhart-Whitehouse allotment, in restoration unit 15.

• Spring development in South Cottonwood allotment, between restoration unit 33 and timber unit 45.

• Pipeline extension in South Cottonwood allotment, in restoration unit 33.

• Off-stream water development from Perkins Gulch in Dry Cottonwood allotment, in restoration unit 7.

Table 2. Selected Alternative restoration units

Unit

Number

Subwatershed Unit Acres Park/Meadow 

Treatment Acresa

Aspen

Treatment 

Acresa

Douglas-Fir 

Thinning Acresa

Riparian 

Treatments

1 Dry Cottonwood 120 44

(12 roadside) 0 b 14 None

2 Dry Cottonwood 1,192 257

(34 roadside) 12 102

(3 roadside) Tree felling

3 Dry Cottonwood 173 57 0 47 None

4 Dry Cottonwood 351 164 0 123 None

6

Girard Gulch 

(Restoration Key) 469

39

(20 roadside) Dry Cottonwood 0 93 None 136

Sand Hollow 147

7 Girard Gulch

(Restoration Key) 973 13

(10 roadside) 12 314

Worm fencing;

tree felling

8 Girard Gulch

(Restoration Key) 634 0 12 196 None

9 Dry Cottonwood 525 105

(34 roadside)

175

(5 roadside) None

10

Orofino 11

424

(67 roadside) 2 455(2 roadside) Dry Cottonwood 1,028 Worm fencing

Sand Hollow 2

11

Sand Hollow 243

8 0 0 None

Orofino 79

13 Orofino 422 5 0 0 None

14 Orofino 347 206

(2 roadside) 0 20(20 roadside) Tree felling

15

Peterson (TMDL) b 1,118

701 0 124

(87 roadside)

Worm fencing;

Orofino 5 tree felling

17 Peterson (TMDL) b 371 89 0 108 None

18 Peterson (TMDL) b 95 7 0 28 None

20

Peterson (TMDL) b 116

54 0 17

(9 roadside) None

Fred (Fish Key) 10

27 Fred (Fish Key) 48 14 0 0 None

28 Fred (Fish Key) 52 25 0 10 None

9
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Unit

Number

Subwatershed Unit Acres Park/Meadow 

Treatment Acresa

Aspen

Treatment 

Acresa

Douglas-Fir 

Thinning Acresa

Riparian 

Treatments

33 Fred (Fish Key) 99 20 0 10 None

19 Units 8,768 2,232

(179 roadside)

43

(3 roadside)

1,836

(126 roadside)

a. Numbers in parentheses associated with the term “roadside” indicate the subset of the displayed treatment acres that are within 

150 feet each side of existing access roads that would be available for commercial recovery. 

b. A “Total Maximum Daily Load” (TMDL) has been established for a water body in this subwatershed to control non-point source 

pollutants, per section 303(d) of the Clean Water Act; see Hydrology section.

Additional Resource Improvement and Restoration Activities

Under the selected alternative, a number of other resource improvement and restoration actions will be implemented

throughout the 39,651-acre project area, but not within specific timber or restoration units. These actions include 

aquatic/riparian habitat improvements and actions related to roads and trails for the purpose of improving aquatic 

and/or wildlife habitat. Actions described in narrative and tabular format in this section are also depicted on the 

Selected Alternative maps (Appendix A).

Aquatic/Riparian Habitat Improvements

The selected alternative includes the following aquatic/riparian habitat treatments to reduce fish passage barriers and 

improve riparian habitat as listed in table 3 and described below: 

1. Remove, replace, or retrofit 12 culverts in the project area that have the potential to prevent upstream fish 

passage as described below in Table 3. The replacement structures will be bottomless arches, bridges, or 

culverts installed at or below grade to allow the passage of all life stages of fish based on Forest Service Region 

1 and USFWS fish passage criteria and allow the passage of bedload material and accumulation of natural 

substrate within the structure. Prioritization is based on compliance with Forest Plan direction and the Clean 

Water Act and direct emphasis on; 1) Fish Key Watersheds, 2) TMDL listed streams, 3) Restoration Key 

Watersheds, and 4) other watersheds supporting westslope cutthroat trout conservation populations.

Table 3. Selected Alternative - Culvert Actions

Subwatershed Forest 

Road Creek Name Treatment Priority Mitigationc

Fred (Fish 

Key)

FR 1504 NF 

Cottonwood Replace 1 Yes

FR 1518 MF 

Cottonwood Replace 12

Peterson

(TMDL)a

FR 19870 Jack Remove 4 Yes

FR 8518 Dieders Fork Replace 7 Yes

FR 8518 Dieders Fork Replace 6 Yes

FR 1504 Peterson Retrofit 

inlet/outlet

5 Yes

Dry 

Cottonwood

FR 78256 NF Dry 

Cottonwood Replace 9

FR 85 NF Dry Replace 8

10
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Subwatershed Forest 

Road Creek Name Treatment Priority Mitigationc

Cottonwood

FR 85 SF Dry 

Cottonwood Replace 10

FR 8634 SF Dry 

Cottonwood Replace 11

Girard Gulch 

(Restoration 

Key)

FR 5165 NF Perkins 

Gulch Replace 2 Yes

FR 5165 Perkins Gulch Replace 3 Yesb

a. A “Total Maximum Daily Load” (TMDL) has been established for a water body in this subwatershed to control non-point source 

pollutants, per section 303(d) of the Clean Water Act; see Hydrology section.

b. The culvert on main Perkins Gulch, FR 5165, must be replaced prior to any haul activity.

c. Actions noted as mitigations are required to meet regulatory standards as explained in further detail in the aquatics and hydrology 

sections of the FEIS.

2. Implement erosion control practices to reduce sediment delivery to North Fork Cottonwood Creek (FR 9330 near 

milepost 0.8) and North Fork Perkins Gulch (FR 5163). 

3. Hand fell available conifers to create barriers and reduce livestock accessibility and riparian and stream bank 

impacts along a 1-mile section of North Fork Cottonwood Creek in the Fred Fish Key Watershed as described in 

table 4.

4. Use dead and dying lodgepole pine to enhance in-stream LWD in 1.9 miles of Baggs Creek between river miles 

3.1 and 5.0 in the Fred Fish Key Watershed as described in Table 4. Trees that would naturally recruit to Baggs 

Creek will not be felled. Additional trees will be brought from upland sites to meet riparian management 

objectives (RMOs) for LWD contained in the 2009 Forest Plan. Since access to this site is via non-motorized 

Trail #8139, movement and positioning of trees into the stream will be accomplished using low-impact methods, 

such as draft horses, chainsaw winches, or other means that limit ground disturbance. 

1. In the Fred Fish Key Watershed, use dead and dying lodgepole pine to enhance in-stream LWD along 1.5 miles 

of Middle Fork Cottonwood Creek between the confluence with North Fork Cottonwood Creek and river mile 1.5, 

where an unnamed tributary flows into Middle Fork Cottonwood Creek as described in Table 4. The trees in 

riparian conservation areas (RCA) that would recruit naturally will be used for the enhancement work to prevent 

them from being harvested for firewood, as currently occurs due to proximity of FR 1504. Additional trees from 

upland sites will be used to meet Forest Plan LWD objectives. Low impact methods will be used such as draft 

horses, chainsaw winches or other means that limit ground disturbance.

2. Implement riparian habitat treatments (tree felling, LWD enhancement, log worm fencing) in other 

subwatersheds as described in table 4. Prioritization is based on compliance with Forest Plan direction and the

Clean Water Act and direct emphasis on; 1) Fish Key Watersheds, 2) TMDL listed streams, 3) Restoration Key 

Watersheds, and 4) other watersheds supporting westslope cutthroat trout conservation populations.

Table 4. Selected Alternative - Aquatic and Riparian Restoration Activities 

Sub-watershed Stream Stream 

Length (mi)

Riparian Area 

(acres) Treatment Restoration 

Unit Mitigationb

Fred (Fish Key)

NF Cottonwood 1 18 Tree felling n/a Yes

Baggs 1.9 N/A Large wood n/a Yes

11
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Sub-watershed Stream Stream 

Length (mi)

Riparian Area 

(acres) Treatment Restoration 

Unit Mitigationb

enhancement

MF Cottonwood 1.5 N/A Large wood 

enhancement n/a Yes

Peterson

(TMDL)a

Dieders Fork 0.3 9 Log worm fence 15 Yes

Dieders Fork 0.5 16 Tree felling 15 Yes

Orofino

Orofino 0.6 10 Tree felling n/a --

Unnamed 

tributary to 

Orofino

0.6 10 Tree felling 14 --

Dry Cottonwood

NF Dry 

Cottonwood 1.6 34 Tree felling na --

NF Dry 

Cottonwood 0.2 17 Log worm fence 10 --

Unnamed 

tributary to SF 

Dry Cottonwood

0.2 5 Tree felling 2 --

Girard Gulch 

(Restoration 

Key)

NF Perkins 

Gulch 0.1 4 Log worm fence 7 Yes

Perkins Gulch 0.4 11 Tree felling 7 Yes

Total -- 8.9 134 -- -- --

a. A “Total Maximum Daily Load” (TMDL) has been established for a water body in this subwatershed to control non-point source 

pollutants, per section 303(d) of the Clean Water Act; see Hydrology section.

b. Actions noted as mitigations are required to meet regulatory standards as explained in further detail in the aquatics and hydrology 

sections of the FEIS.

Restoration Activities Related to Roads and Trails

A number of restoration activities related to roads and trails will occur as part of the selected alternative to improve 

wildlife and/or aquatic resources. Specific route-by-route actions are listed in Table 5 below. Actions include: 

• Add 1.2 miles of non-system roads to the Forest transportation system. These additions generally occur 

where non-system roads used by the public are not currently impairing resources.

• Close and/or decommission 21.8 miles of system and non-system roads and trails. Actions occur on roads

and trails for the purpose of enhancing wildlife security or aquatic resources. Actions on road and trail

segments within RCAs ensure removal of hydrologic connectivity with the associated water body through 

installation of water bars, drain dips, or other mechanisms to eliminate sediment delivery to streams from 

road prism and ditch lines.

• Convert the first 3.7 miles of Trail #8139 - Baggs Creek Trail from motorized to non-motorized use starting 

at the end of FR 19744 and ending at the point where the trail begins its current non-motorized status to 

create a total of approximately 6.5 miles of non-motorized trail. In addition, maintenance and spot 

reconstruction will occur throughout the 6.5 miles of trail #8139, including installation of features to improve 

wet area crossings, reduce erosion, and re-establish a sustainable tread. 

• Maintain and reconstruct the entire 2.7 mile length of the Airplane Park Trail #8047. In certain areas the old 

trail is largely non-existent and in others the trail has been impacted by FR 5182.

12
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

• Convert 0.6 miles of Trail #8442 from motorized to non-motorized. This will be implemented by signing the 

trail closed.

Table 5. Selected Alternative- Restoration Activities Related to Roads and Trails

Route 

ID Action Haul Route Rationale Miles Mitigationa

19727 Close system road, 

convert to ML 1

Removes road from winter range 

and summer wildlife secure area. 0.3

19727

Close system road 

year long, allow 

admin use

No Removes road from winter range 

and summer wildlife secure area. 0.6

19727

Close system road 

year long, allow 

admin use

Yes Removes road from winter range 

and summer wildlife secure area. 0.4

19870

Decommission 

system road 

(obliterate); ensure 

no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a 

watershed that contains a Total 

Maximum Daily Load stream. 

0.2 Yes

19885

Decommission 

system road (sign 

close)

No Segment is already closed. 0.3

5163

Close system road, 

convert to ML 1; 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a Key 

Watershed. Removes road from 

winter range. 

1.1 Yes

5171

Decommission 

system road 

(obliterate)

Yes Reduces impacts to stream. 

Removes road from winter range. 0.5

78070

Decommission 

system road 

(obliterate)

Yes Segment is grown-in. 1.0

78167

Close system road, 

convert to ML 1; 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area and winter 

range.

0.9

78244 Close system road, 

convert to ML 1 No Removes road from summer wildlife secure area. 0.5

78244 Close system road, 

convert to ML 1 Yes Removes road from summer wildlife secure area. 0.3

78253 Close system road, No Removes road from a Riparian 1.2

13
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Route 

ID Action Haul Route Rationale Miles Mitigationa

convert to ML 1; 

ensure no hydrologic 

connection with 

adjacent stream(s)

Conservation Area and removes 

road from winter range and 

summer wildlife secure area. 

Segment is not drivable. 

78254 Close system road, 

convert to ML 1 No Removes road from winter range. Segment is not drivable. 0.4

78258

Decommission 

system road 

(obliterate); ensure 

no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area.

Removes road from summer 

wildlife secure area. 

0.4

78319 Close system road, 

convert to ML 1 No Removes road from winter range. 0.3

78319 Close system road, 

convert to ML 1 Yes Removes road from winter range. 1.3

78321 Close system road, 

convert to ML 1 No Reduces impacts to stream. 0.3

8139

Convert motorized 

system trail to nonmotorized system 

trail

No Reduces impacts to stream and 

maintains wildlife secure area. 3.7

8139

Maintain and 

reconstruct nonmotorized trail 

No

Reduces impacts to stream and 

reestablishes connection between 

the Baggs Creek trail and Airplane 

Park trail.

2.7

8047

Maintain and 

reconstruct nonmotorized trail

No

Reduces impacts to stream and 

reestablishes connection between 

the Baggs Creek trail and Cliff 

Mountain trail.

2.7

8442

Convert motorized 

system trail to nonmotorized system 

trail

No

Reduces impacts in Fish Key 

Watershed and maintains wildlife 

secure area.

0.6

9316

Decommission 

system road (sign 

close)

No Reduces impacts to watershed. 0.7

9320 Close system road, 

convert to ML 1 Yes Segment not drivable. 0.7

9322

Decommission 

system road 

(obliterate); ensure 

no hydrologic 

No Removes road from a Riparian 

Conservation Area. 0.1

14
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Route 

ID Action Haul Route Rationale Miles Mitigationa

connection with 

adjacent stream(s)

9326 Close system road, 

convert to ML 1 No Reduces impacts to watershed. 0.4

9330

Convert system road 

to non-motorized 

system trail - allow 

motorized admin 

use; ensure no 

hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a Key 

Watershed and removes road from 

winter range.

0.2 Yes

9330

Close system road, 

allow motorized 

admin use; ensure 

no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a Key 

Watershed and removes road from 

winter range. 

0.4 Yes

9331

Decommission 

system road 

(obliterate); ensure 

no hydrologic 

connection with 

adjacent stream(s)

Yes Removes road from a Key 

Watershed. Segment not drivable. 0.5

9332 Close system road, 

convert to ML 1 No

Removes road from summer 

wildlife secure area. Segment is 

not drivable.

0.03

9332 Close system road, 

convert to ML 1 Yes

Removes road from summer 

wildlife secure area. Segment is 

not drivable.

0.8

9363 Close system road, 

convert to ML 1 No Removes road from wildlife secure 

area. 

0.4

Temp 

New

Construct temporary 

road, obliterate 

following haul

Yes NA (since temporary road) 8.2 Yes

Temp 

UR8-

120

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.7 Yes

Temp 

UR8-

16

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.2 Yes

15
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Route 

ID Action Haul Route Rationale Miles Mitigationa

Temp 

UR8-

31

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.1 Yes

Temp 

UR8-

35

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.4 Yes

Temp 

UR8-

66

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.7 Yes

Temp 

UR8-

81

Use existing UR 

route as temporary 

road, obliterate 

following haul

Yes Eliminates unneeded non-system 

route. 0.2 Yes

UR8-1

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a Key 

Watershed and removes road from 

winter range. 

0.4 Yes

UR8-

11

Decommission UR 

road (sign close) No Removes road from winter range. 0.5

UR8-

12

Decommission UR 

road (sign close) No Removes inaccessible road 

segment due to closure of UR8-11. 0.1

UR8-

126

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area and removes 

road from summer wildlife secure 

area. No legal access. 

0.4

UR8-

130

Decommission UR 

road (obliterate) No Removes road from winter range. Segment not drivable. 0.2

UR8-

131

Decommission 

system road (sign 

close)

No Segment not drivable. 0.6

UR8-

24

Decommission UR 

road (sign close) No

Removes road from summer 

wildlife secure area. No legal 

access to road.

1.0

UR8-

25

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a Key 

Watershed. 

1.0 Yes

16
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Route 

ID Action Haul Route Rationale Miles Mitigationa

UR8-

49

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area and removes 

road from winter range and 

summer wildlife secure area. 

0.5 Yes

UR8-

63

Add UR route to 

system as ML2 Road 

closed to motorized 

use from October 15 

to June 15.

Yes Accesses livestock water 

developments. 0.2

UR8-

66

Decommission UR 

road (sign close) No Removes road from winter range. 0.1

UR8-

72

Decommission UR 

road (obliterate) No No legal access to road. 0.6

UR8-

75

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No

Removes road from a Riparian 

Conservation Area within a 

watershed that contains a Total 

Maximum Daily Load stream. 

0.4 Yes

UR8-

83

Add UR route to 

system as ML2 Road 

closed to motorized 

use from October 15 

to December 2.

Yes Provides access to private 

inholding. 1.0

UR8-

85

Decommission UR 

road (obliterate); 

ensure no hydrologic 

connection with 

adjacent stream(s)

No Reduces impacts to stream. 0.3

UR8-

92

Decommission UR 

road (obliterate) No Removes road from summer wildlife secure area. 0.5

UR8-

32

Decommission UR 

Road - Obliterate No Reduces impacts to stream. 0.4

UR8-

67

Decommission UR 

Road - Obliterate No Reduces impacts to stream. 0.2

UR8-

68

Decommission UR 

Road - Obliterate No Reduces impacts to stream. 0.3

UR8-

99

Decommission UR 

road (obliterate) No Removes road from winter range. 0.1

UT05N

08W07

-02

Close motorized use 

on UT trail No Reduces impacts to stream. 0.2

17
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Route 

ID Action Haul Route Rationale Miles Mitigationa

UT06N

08W28

-03

Decommission UT 

trail (obliterate) No Removes trail from a Riparian Conservation Area. 0.1

UT06N

08W31

-01

Decommission UT 

trail (obliterate) No Removes trail from a Riparian Conservation Area. 0.3

a. Actions noted as mitigations are required to meet regulatory standards as explained in further detail in the aquatics and hydrology 

sections of the FEIS.

Project Design Features and Mitigation Measures

The selected alternative includes the following project design features and mitigations to reduce or eliminate potential 

adverse effects to resources. These measures are non-discretionary and an integral component of my decision:

Air Quality

Coordinate all prescribed burning (jackpot pile burning) with the Montana/Idaho Airshed Group smoke management 

program and comply with requirements of the State Implementation Plan and Smoke Management Plan (USDA 

Forest Service 1987, pgs. II-26). Prescribed burning is reported to the Airshed Coordinator on a daily basis. If 

ventilation problems are forecast by the monitoring unit, prescribed burning is either restricted by elevation or 

curtailed until good ventilation exists.

Aquatics and Hydrology

Maintenance or reconstruction will occur prior to and following haul for haul routes. All road work will comply with 

BMPs defined by Logan (2001).

All actions identified in Tables 3, 4, and 5 as mitigations in the Fred, Girard, and Peterson subwatersheds are 

required to be completed during implementation of timber sale activities (including log hauling) by watershed.

Harvest units and timber operations will avoid RCAs (Forest Plan, pg. 300) and seasonally wet areas. Aquatic 

resource specialist(s) will work with the project implementation team to delineate RCAs prior to implementation.

Project related storage of fuels and toxicants within RCAs is prohibited. Refueling within RCAs is prohibited except 

for emergency situations, in which case refueling sites must have an approved spill containment plan (Forest Plan,

pg. 21).

Project activities will avoid known western toad breeding sites and natal areas during breeding and juvenile rearing 

periods. Aquatic resource specialist(s) will work with the project implementation team to identify these areas for 

avoidance.

Road stream crossings will have an appropriate, minimum size culvert. Temporary road culverts will be removed 

when harvest operations are completed.

Livestock Grazing

Protect existing fences and water developments from damage during project implementation.

18
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Construct fences as necessary to replace natural barriers breached during project implementation.

Cultural Resources

Heritage sites will be avoided and/or mitigation measures will be developed in consultation with the Montana State 

Historic Preservation Office prior to project implementation.

If additional previously undiscovered cultural resources are discovered during project implementation, stop work in 

that area immediately until a Forest heritage resource specialist evaluates the site.

Any areas not previously surveyed for cultural resources, such as areas planned for road obliteration work and trail 

work, will require an archaeological survey.

Recreation and Travel Management 

Dust abatement will occur, as needed, along roads within and adjacent to the Orofino Campground and Picnic Area 

while harvest and hauling activities occur in and adjacent to these sites.

No log hauling will occur on NFS roads on weekends and Federal holidays to provide for public safety.

Travel restrictions identified on the map titled Beaverhead-Deerlodge National Forest North Map reflecting the

Beaverhead-Deerlodge Forest Plan Record of Decision II Travel Route Restrictions will be imposed, except on the 

following routes as needed to haul during winter harvest: 705, 1518, 5169, 5170, 5171, 5175, 8518, 9317, 9320, 

9455, 19729, 19731, 19732, 19733, 19735, 19736, 19738, 19869, 78319, 9491A, 9491B, UR8-35, UR8-63, UR8-66, 

UR8-120.

Protect or re-establish trails, trailheads and other recreation facilities impacted by harvest activities following harvest.

Replace and/or reinstall signs and gates damaged or removed during harvest activities. 

Scenic Resources

Visible stumps within 100 feet of the CDNST, FR 82, and Orofino Campground shall be cut as low as possible 

(maximum 6 inches).

In treatment units visible in the foreground from the CDNST, FR 82, and Orofino Campground, slash and felled 

conifers will be burned to 95% consumption as soon as possible following treatment activities. This may require repiling and burning. Scatter remaining material.

Unit form and shape will simulate natural patterns in design and operations, especially in the elements of form and 

line. Meander unit boundaries and avoid obvious human-created boundaries in layout and design of units. Tie unit 

design and layout into meadows and other openings in the surrounding area, where feasible.

Locate roads, landings, slash piles, and other features out of sight of Concern Level 1 and 2 viewing platforms, 

utilizing vegetation and topography for screening, as feasible.

When slashing conifers within restoration units, fall larger diameter trees so cut stems are not facing adjacent viewing 

platforms, if feasible. Cut stumps as low as possible in the foreground of CL 1 and 2 routes and sites. 

Minimize cuts and fills associated with temporary road construction and locate roads and landings to minimize visible 

cuts and fill, and take advantage of natural screening elements such as topography and vegetation as seen from the 

identified CL 1 and 2 routes and sites.

In units 24T, 25T, 40T, 41T, 80T, and 82T minimize any road work, including maintenance, on roads proposed to be 

used for harvest operations, to that which is necessary to use the road. Minimize cuts and fills on these roads. Retain 

19
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

any trees, preferably in natural appearing patterns (such as groups or clumps) that provide screening of these roads 

as seen from the CL 1 and 2 routes and sites in the area.

In thinning activities, vary leave tree spacing and retain groups or clumps of trees where feasible.

In thinning activities, soften edges of the unit adjacent to denser forest so that the percent of thinning within the 

transition zone will be progressively reduced toward the outside edge of the unit. Vary the width of the transition 

zone. 

In thinning activities, soften edges of the unit adjacent to natural or created openings so the percent of thinning within 

the transition zone will be progressively increased toward the outside edge of the unit. Vary the width of the transition 

zone.

Avoid severe thinning along ridgelines in units 25T, 40T, 56T, 57T, 78T, 80T, and 82T. The Forest landscape architect 

shall be consulted regarding treatment units in these situations.

Where feasible, retain small, low-branched trees within 50 feet of edges of units to avoid a bole-edge effect.

Blend visible boundaries of units 21T, 25T, 57T, and 61T as much as possible with adjacent undisturbed areas or 

move if necessary to minimize visible impacts. Follow natural contours and tie edges into existing meadows and 

openings where possible. Avoid straight lines and sharp corners during layout of unit 25T. Coordinate layout and 

design of these units with the Forest landscape architect.

Blend the visible boundaries of units 21T, 22T, 24T, 25T, 40T, 41T, 42T, and 61T as much as possible with the power

line corridor to reduce the existing contrast. Unit edges will be feathered and undulated and tied into existing 

meadows and openings where possible. Coordinate layout and design with the Forest landscape architect to ensure 

the existing contrast created by the power line is softened.

In unit 38T, avoid creating unnatural appearing unit boundaries in the upper portion of the unit. Meander this 

boundary.

In unit 26T, retain adequate leave trees to screen the effects of the temporary road construction as seen from the 

CDNST.

Water developments will use non-reflective, earth-tone color materials in construction and installation. Darker earthtone fiberglass tanks are recommended.

Where feasible, retain Douglas-fir in unit 21T to screen the effects of the temporary road construction in this unit.

Avoid leaving a strip of trees on the north side of unit 20T between the edge of the unit and the forest boundary.

Soils Management

Pile and burn non-merchantable and sub-merchantable material, such as cull logs and tree limbs, within harvest units 

so remaining coarse woody debris (3 inches or greater in diameter) is in the range of 7-12 tons/acre in each timber 

unit. This may be accomplished by felling and leaving trees where necessary or returning slash from the landing that 

results from whole-tree logging (USDA Forest Service 1999).

Space skid trails an average of 75 to 100 feet (SWCP 14.08). Temporary roads and skid trails will be adequately 

drained in order to prevent overland water flow. Place slash on skid trails to prevent erosion and discourage ATV use 

(SWCP 14.15).

20
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Rip or subsoil all temporary roads, seed with native seed, and block at the entrance. Recontour temporary roads 

where necessary.

Monitor disturbed areas to ensure soil stabilization occurs through natural revegetation from the soil seed bank. If 

additional plant seed is required, scarify areas of compacted soil prior to seeding and use only native species 

common to the site. All seed and mulch material will be certified noxious weed seed free. 

Ground-based yarding will not occur on slopes exceeding 35% without a site-specific environmental analysis by a soil 

scientist determining damage is unlikely (Forest Plan, pg. 34; SWCP 14.07).

Harvest will not occur unless soils are dry or frozen as determined by the Forest Service to minimize potential 

compaction and/or rutting (SWCP 13.06).

Harvest the following timber units in the winter when ground is frozen: 5T, 11T, 17T, 19T, 23T, 25T, 29T, 37T, 41T, 42T, 

45T, 48T, 52T, 53T, 76T, 80T, 82T.

Timber operations and harvest units will avoid wet areas. The Forest soil scientist, hydrologist, and fisheries biologist 

would work with the project implementation team to protect these areas (SWCP 13.03).

Pile and burn slash on roads where feasible. Where this is not feasible, pile slash in such a way (tall and narrow) to 

reduce the footprint on the soil and burn piles when soil is cold/frozen and moist.

Sub soiling and/or ripping will occur within unit 37T to restore portions of the unit and ensure compliance with soil 

quality standards.

In restoration units 1, 2, 6, 7, 8, 9, 11, 13, and 14, do not remove conifers in eroded draws/gullies, and above and 

below slope breaks around the flat benches, where soil loss from erosion limits the potential for adequate plant cover.

In restoration units where feasible, use existing roads as main skid trails with only short tributary skid trails within the 

harvest units.

In restoration units, equipment that use the same trail to enter and exit a unit will do so by backing out to avoid 

excessive soils disturbance associated with turning.

In restoration units, use rubber-tired skidders for skidding logs unless otherwise agreed to by the Forest Service.

Vegetation

No cutting or treatments will occur in old growth stands.

Design criteria for harvest activities have been developed to provide protection to the whitebark pine seedlings and 

saplings that occur in units 25T, 40T, and 42T are developed to account for whitebark pine regeneration that may 

occur in other units that field examinations may have missed. The design criteria to protect whitebark pine are: (1) 

retain all whitebark pine of 3” dbh or greater through avoidance; (2) designate skid trails that avoid whitebark pine to 

the extent possible; and (3) directionally fell trees to be harvested to avoid damaging whitebark regeneration to the 

extent possible; and (4) if whitebark pine is found in restoration units, protect individuals during implementation 

activities to the extent possible. This will be done by directionally felling trees and concentrating fuels away from 

whitebark pine and locating jackpot burn piles a safe distance that ensures no potential for scorching.

If undocumented populations of sensitive plants are discovered during project implementation, work would 

immediately stop in that area until a Forest botanist or ecologist could evaluate the site. 

21
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Landings will not be located in natural openings such as grass-shrub parks to reduce impacts to the vegetation types 

in those areas.

Control noxious weeds following the procedures in the BDNF Noxious Weed Control Program ROD including all 

mitigation measures, monitoring requirements, and applicable BMPs (USDA 2002).

Aggressively treat noxious weeds within units and along roads used to access treatment units containing parks. 

Parks include meadows, grasslands, sagebrush steppe communities, and other open areas where trees do not 

dominate the vegetation. Conduct treatments at the appropriate time of year (before flower and seed set).

All heavy equipment will have an undercarriage wash and be inspected prior to entering NFS lands to reduce the 

spread of noxious weeds.

Limit ground-disturbing activities associated with the project to the extent practical. Monitor and treat noxious weeds 

as necessary to reduce potential spread of weeds into new areas.

Post-activity monitoring for, and treatment of noxious weeds will occur on all harvest units. Emphasize monitoring and 

treatment in areas of ground disturbance within units, and in units with existing infestations until populations are 

effectively controlled.

Cheatgrass (Bromus Tectorum) will not be intentionally spread during project implementation. This will be 

accomplished by applying all preventative Best Management Practices identified above for noxious weeds.

Wildlife Habitat

To meet the Forest Plan snag standards, retain all trees (live or dead) over 15 inches dbh in the mechanical 

vegetation treatment units (salvage and commercial thin DF units), as well as non-commercial treatments. Trees 

greater than 15 inches dbh may be cut if they are determined to be a hazard by the purchaser or operator. If a tree is 

cut due to hazard determination, it will not be removed.

Leave at least 0.9 live trees/acre > 10 inches dbh in salvage units for future snag recruitment.

Retain large woody debris, at least six pieces per acre with small end diameter equal to or greater than 8.0 inches 

and at least 10 feet long, in salvage harvest units.

There have been potential, but unconfirmed sighting of goshawks in the vicinity of unit 20T. Survey this unit prior to 

logging operations if logging and hauling occurs during the breeding season (March 1 – August 15). 

If there is an active nest in 20T, apply appropriate mitigation (2009 Northern Region Northern Goshawk Overview 

timing restrictions). For northern goshawks, a 40-acre nest buffer will apply during the 4/15-8/15 breeding season 

limited operating period. For great gray owls, a 30-acre nest buffer will apply during the 3/15-7/17 breeding season 

limited operating period. 

If active nest sites for other threatened, endangered or sensitive raptors, (including northern goshawks and great 

gray owls) are found, mitigate effects of management actions based on species needs and site-specific 

considerations. 

Close temporary roads to the public during project implementation through a forest order and signing. Upon 

completion of harvest operations, obliterate all temporary roads. Temporary roads will not remain open for postharvest treatments including: reforestation exams and pile burning. 

Retain existing large diameter logs in various stages of decay in all treatment units where possible. Methods include 

placement of slash away from down logs to prevent burning and avoiding with equipment to prevent demolishing.

22
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Monitoring for Selected Alternative

Monitor temporary road construction and subsequent decommissioning by obliteration to ensure project design 

features are adequate and comply with Soil and Water Conservation Practices (USDA Forest Service 1988).

A Forest Service archaeologist will monitor all cultural resources in the area of potential effect following project work 

to ensure mitigation measures were followed and sites sustained no damage. 

Post-activity monitoring of worm fencing, riparian tree felling, and off-site water developments: monitor proposed 

riparian improvement projects for effectiveness in reducing livestock impacts in riparian areas.

Monitor units 17T, 28T, and 37T to ensure they meet SQS following Forest Soil Disturbance Monitoring Protocol 

(USDA Forest Service, 2009a).

Monitor a portion of commercial units for implementation of design features to retain trees over 15 inches dbh and 

meet large woody debris requirements.

Decision Rationale

I selected Alternative 3, as modified, because it achieves the project purpose and need in an environmentally sound 

manner and allows accomplishment of Forest Plan goals and objectives to manage timber and improve vegetation 

and watershed characteristics while meeting regulatory standards.

The FEIS discloses the qualitative and quantitative effects on the human and biological environment that we

anticipate will result from implementation of the EDLV Project. The FEIS uses the best available science and 

information as well as sound methodologies, available site-specific data, and monitoring of similar activities in the 

same general area to come to these determinations of predicted effects of the alternatives. I find the effects 

presented in the FEIS adequately address both internal and external comments provided through scoping, comment 

periods, and the objection process and the FEIS discloses potential effects related to those comments in the 

analysis. I considered all resource issues described in the FEIS, and my rationale for choosing Alternative 3 Modified 

is based on careful consideration of several key elements including consistency with the project purpose and need, 

consideration of environmental and social impacts, and responsiveness to the objections raised during the objection 

process as discussed in the following sections.

Rationale Based on Meeting the Purpose and Need

I chose the selected alternative because it best meets the purpose and need for action while meeting regulatory 

standards. Although some components of the alternatives considered in the FEIS meet aspects of the purpose and 

need better than the selected alternative, those particular components do not meet regulatory standards. As such 

alternative 3 has been modified to remove those units from my decision as explained in further detail below and in 

table 7. Table 6 displays the components of the purpose and need and how each alternative, including the selected 

alternative, addresses them. Table 6 displays Forest Plan goals and objectives that have been incorporated into this 

project’s purpose and need as well as a compares how the alternatives meet these goals and objectives. 

23
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Table 6. Comparison of how each alternative meets components of purpose and need

Components of Purpose and Need for Action

Timber Management 

Goals

Vegetation Goals and 

Objectives

Aquatic Resources 

Goals and 

Objectives

Wildlife Habitat Goals

Alternative 

1- No 

Action

Does not meet the timber 

management goals due to 

a lack of management 

including timber and 

salvage harvest. This 

alternative would produce 

no sawtimber volume and 

therefore would not 

contribute to product 

utilization goals. 

Does not meet the 

Vegetation Goals and 

Objectives due to a lack of 

density management for 

resiliency, would not 

increase the aspen 

component, and would not 

reduce conifer 

encroachment in 

grasslands, sagebrush and 

riparian areas.

Does not meet Aquatic 

Goals and Objectives due 

to a lack of management 

to reduce roads in 

Riparian conservation 

areas, reduce 

sedimentation from roads 

and trails, increase fish 

passage, as well as 

improve riparian habitat.

Does not meet Wildlife 

Habitat Goals to manage for 

increased wildlife security 

because this alternative 

would make no change to 

the existing open motorized 

routes in the project area.

Alternative 

2 – DEIS 

Proposed 

Action

Meets timber management 

goals because salvage 

harvest and Douglas-fir 

thinning would produce 

both sawtimber as well as 

non-sawtimber volume to 

meet product utilization 

goals.

Meets vegetation 

management goals and 

objectives because this 

alternative reduces density 

of Douglas-fir stands for 

resiliency, increases the 

aspen component and 

reduces conifer 

encroachment.

Meets aquatics goals and 

objectives by reducing 

routes in riparian 

conservation areas, 

reducing sedimentation 

from roads and trails, 

increasing fish passage, 

as well as improving 

riparian habitat.

Meets wildlife goals to 

increase wildlife security by 

reducing total number of 

miles of open motorized 

routes, increasing summer 

secure area acres; and 

increasing fall secure area 

acres.

Alternative 

3 –

Preferred 

Alternative

Meets timber management 

goals because salvage 

harvest and Douglas-fir 

thinning would produce 

both sawtimber as well as 

non-sawtimber volume to 

meet product utilization 

goals. This alternative 

produces more saw and 

non-saw timber volume 

than Alts 1 and 2. 

Meets vegetation 

management goals and 

objectives because this 

alternative reduces density 

of Douglas-fir stands for 

resiliency, increases the 

aspen component and 

reduces conifer 

encroachment. Treats fewer 

acres than Alt. 2 due to 

more refined analysis of 

units. Both action 

alternatives meet vegetation 

goals and objectives. 

Meets aquatics goals and

objectives by reducing 

routes in riparian 

conservation areas, 

reducing sedimentation 

from roads and trails, 

increasing fish passage, 

as well as improving 

riparian habitat. Alt 3 

reduces long-term 

sediment more than Alt 2, 

replaces or retrofits 5 

additional culverts for 

Aquatic Organism 

Passage, and develops 4 

additional off-site livestock 

watering facilities than Alt 

2 for increased benefits to 

aquatics.

Meets wildlife goals to 

increase wildlife security by 

reducing total number of 

miles of open motorized 

routes, increasing summer 

secure area acres; and 

keeping constant fall secure 

area acres. Alt 3 increases 

slightly more acres of 

summer secure area, and 

reduces total miles of open 

motorized routes slightly 

more than Alt 2. Fall secure 

area acres increase slightly 

less than Alt. 2 but more 

than the No Action 

alternative. On balance Alt 

3 meets wildlife goals better 

than Alt 2.

24
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Components of Purpose and Need for Action

Timber Management 

Goals

Vegetation Goals and 

Objectives

Aquatic Resources 

Goals and 

Objectives

Wildlife Habitat Goals

Alternative 

3 Modified–

Selected 

Alternative

Similar to Alternative 3 

with the exception of the 

total acres of harvest 

(2,541 acres) and resulting 

sawtimber and nonsawtimber volume is less 

than Alternative 3, 

however still meets 

purpose and need better 

than Alt. 2 and the No 

Action while meeting 

regulatory standards. 

Rationale for not selecting 

several units from Alt. 3 is 

provided in sections 

below.

Similar to Alternative 3 with 

the exception of total acres 

of Douglas-fir thinning is 

less than Alternative 3. 

Meets purpose and need 

better than the No Action 

alternative while meeting 

regulatory standards.

Rationale for not selecting 

several units from Alt. 3 is 

provided in sections below.

Similar to Alternative 3 

with the exception of 

additional miles of routes 

decommissioned in RCAs

and total miles of haul 

routes reduced as 

displayed in table 8. Meets 

aquatics goals and 

objectives slightly better 

than all other alternatives 

for these reasons. 

Virtually the same as 

Alternative 3 with only slight 

modifications to routes 

selected for 

decommissioning (2 tenths 

of a mile less than Alt. 3). 

This slight modification 

makes no change to total 

acres of fall secure area

and very slight reduction in 

summer secure area

compared to Alternative 3.

This alternative increases 

wildlife security more than 

the no action and 

Alternative 2.

Table 7 summarizes the effects for each alternative and provides additional detail to the general comparisons in Table

5 above. Effects are summarized from the resource sections of Chapter 3 in the FEIS, which should be consulted for 

a full understanding of these and other environmental consequences. Important to note is that the calculations 

displayed in table 7 do not specifically account for the modifications made to Alternative 3 in the selected alternative. 

Modifications have been made primarily to meet regulatory standards as explained in more detail in tables 8 and 9 

below. Although alternative 3 is slightly different than Alternative 3 Modified, the effects are within the range of effects 

considered in the FEIS and do not change the decision rationale based on meeting the purpose and need as

explained in table 6 above.

Table 7. Comparison of actions and effects associated with each alternative

Resource Alternative 1 Alternative 2 Alternative 3

Economics

Sawtimber harvest volume – (hundred cubic feet, CCF) 0 7,386 9,998

Non-sawtimber volume – (hundred cubic feet, CCF) 0 32,942 44,591

Appraised stumpage rate ($/CCF) $0 -$60.55 $14.83

Total revenue from harvest - saw timber and non-saw 

timber($)*

$0 $55,000 $249,000

Present net value -- timber harvest and required design 

criteria ($)

$0 -$386,000 -$254,000

Present net value -- timber harvest and all other 

planned non-timber activities($)

$0 -$2,747,000 -$2,383,000

25
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Resource Alternative 1 Alternative 2 Alternative 3

Jobs created (direct + indirect + induced) from all 

activities, total for project)

0 112 118

Vegetation and Aquatics

Timber units (number, acres) 0 50 units, 2,400 acres 57 units, 2,705 

acres

Commercial salvage lodgepole pine stands

(number, acres)

0 42 units, 1,753 

acres

42 units, 1,671 

acres

Commercial thin Douglas-fir and salvage 

lodgepole pine in mixed conifer stands (number, 

acres)

0 8 units, 647 acres 11 units, 840 acres 

Commercial thin Douglas-fir (number, acres) 0 0 4 units, 193 acres

Restoration units (number, acres) 0 19 units, 9,032 acres 19 units, 8,768 

acres

Cut encroaching conifers (acres) 0 2,761 a 2,232 a

Treat aspen (acres) 0 77 a 43 a

Treat DF (acres) 0 1,923 a 1,836 a

Roadside commercial recovery (acres) 0 0 305 a

Riparian tree felling (acres) 0 87 104

Riparian LWD enhancement (acres) 0 196 84

Log worm fencing (acres) 0 31 26

Develop water structures (number) 0 3 7

Remove/replace culverts (number) 0 7 12

Hydrology

Motorized Route miles in RCA within project area by 

watershed

 Fred (Fish Key watershed) 61.2 54.8 52.0

 Peterson (TMDL) 34.7 32.3 33.1

 Orofino 22.9 19.2 19.8

 Sand Hollow 6.9 6.9 6.6

 Dry Cottonwood 53.6 50.7 49.5

 Girard Gulch (Restoration Key watershed) 23.7 23.7 23.1

Sediment from timber units (lbs/acre/yr) 0 0 0

Short-term sediment from roads (lbs/yr) 12,288 19,385 17,081

Long-term sediment from roads (lbs/yr) 12,288 9,640 8,556

Wildlife

Summer open motorized road and trail density over the 

landscape (mi/mi2)

1.7 1.7 1.7

Hunting season open motorized road and trail density 

over Hunting Unit 215 (mi/mi2)

1.5 1.5 1.5

Summer wildlife secure area (acres post-project) 164,770 166,406 167,059

Fall wildlife secure area (acres post-project) 31,133 31,265 31,133

26
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Resource Alternative 1 Alternative 2 Alternative 3

Transportation Network

Haul routes (miles) 0 111.3 109.6

Temporary roads -- new construction (miles) 0 8.2 9.0

Temporary roads -- non-system route (miles) 0 0 2.2

Add roads to system (miles) 0 8.4 1.2

Close or decommission forest roads or non-system

routes (miles)

0 19.9 c 21.9

Convert system road to non-motorized trails - allow 

motorized admin use (miles)

0 0 0.2

Close or decommission motorized trails (miles) 0 3.7 4.9

a. Acres present a subset of the total restoration unit acres that are estimated to be amenable for the particular treatment.

b. A “Total Maximum Daily Load” (TMDL) has been established for a water body in this subwatershed to control non-point source 

pollutants, per section 303(d) of the Clean Water Act; see Hydrology section.

c. Of these 19.9 miles, 0.9 miles are already closed to the public.

Several values presented in Table 7 above show that Alternative 3 meets components of the purpose and need better 

than the other alternatives. As explained in table 6 and the narrative above, the modifications made to Alternative 3 in 

this decision do not change my determination that the selected alternative best meets the purpose and need; in the 

case of the aquatics components of the purpose and need, the modifications further support that determination.

Rationale Based on Minimization of Environmental Impacts

In addition to the rationale described above, I chose the selected alternative because it minimizes negative 

environmental impacts more than Alternative 2. Table 7 above describes several effects of implementing various

alternatives; Alternative 3 minimizes effects more than Alternative 2 as measured by several calculations displayed in 

the table and as described in greater detail in Chapter 3 of the FEIS. In addition to the differences in effects displayed 

in Table 7 above and discussed by resource in Chapter 3 of the FEIS, I have further reduced environmental impacts 

through the modifications I made to Alternative 3 described below.

I modified Alternative 3 by not selecting several timber units for implementation, modifying the prescription for several 

units, and modifying unit boundaries for others. My reasoning for not selecting several timber units and modifying 

others is based on two primary resource analyses in the FEIS: Soils and Wildlife. Several units were projected to 

exceed Regional Soil Quality Standards and could not be adequately restored post-harvest. These units are not 

included in my decision. Several units were projected to not meet the standards in the Northern Rockies Lynx 

Management Direction Record of Decision. These units are not included in my decision. Table 8 below describes the 

modifications to timber units between Alternative 3 and Alternative 3 Modified.

Table 8. Modifications made to Alternative 3 in Selected Alternative – Timber Units

Unit 

Number

Alternative 3

Alternative 3 

Modified

Rationale for Modification

Prescription Acres Prescription Acres

3T

DF Thinning /LP 

Salvage 85 LP Salvage 85

Prescription changed to exclude 

Douglas-fir thinning within unit in 

order to meet Northern Rockies Lynx 

Management Direction

27
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Unit 

Number

Alternative 3

Alternative 3 

Modified

Rationale for Modification

Prescription Acres Prescription Acres

6T LP Salvage 6 --- 0

Unit dropped in order to meet

Regional Soil Quality Standards

14T LP Salvage 20 --- 0

Unit dropped in order to meet 

Regional Soil Quality Standards

16T

DF Thinning /LP 

Salvage 51 --- 0

Unit dropped in order to meet 

Northern Rockies Lynx Management 

Direction 

18T

DF Thinning /LP 

Salvage 29 LP Salvage 29

Prescription changed to exclude 

Douglas-fir thinning within unit in 

order to meet Northern Rockies Lynx 

Management Direction

21T

DF Thinning /LP 

Salvage 106 LP Salvage 106

Prescription changed to exclude 

Douglas-fir thinning within unit in 

order to meet Northern Rockies Lynx 

Management Direction

25T

DF Thinning /LP 

Salvage 229 LP Salvage 229

Prescription changed to exclude 

Douglas-fir thinning within unit in 

order to meet Northern Rockies Lynx 

Management Direction

32T LP Salvage 4 --- 0

Unit dropped because it is adjacent 

to 84T; Temp road that was needed 

to access unit was also used to 

access 84T. Because 84T was 

dropped this unit was dropped.

82T LP Salvage 93 LP Salvage 47

Approximately half of unit dropped 

in order to meet Northern Rockies 

Lynx Management Direction

84T DF Thinning 32 --- 0

Unit dropped in order to meet 

Northern Rockies Lynx Management 

Direction 

As such, Alternative 3 Modified meets both the Regional Soil Quality Standards as well as the Northern Rockies Lynx 

Management Direction because units that were projected to exceed these standards are not included in my decision. 

I also modified Alternative 3 by adding several routes for obliteration that were analyzed in Alternative 2. I also did not 

select obliteration for one route that was mistakenly included in the Alternative 3 description. 

28
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Table 9. Modifications made to Alternative 3 in Selected Alternative - Routes

Route ID Alternative 3 Alternative 3 

Modified Miles Rationale for Not Selecting

Alt3 Temp

Proposed 

Temporary 

Road (New 

Construction)

Temp Road 

Dropped 0.2 Not needed due to unit changes; 

Reduces miles of Temporary road 

implemented

Alt3 Temp

Proposed 

Temporary 

Road (New 

Construction)

Temp road 

dropped 0.6

Not needed due to unit changes; 

Reduces miles of Temporary road 

implemented

UR8-32 Existing Open 

UR Road

Decommission 

UR Road -

Obliterate

0.4

Increases miles of route obliterated in 

Riparian Conservation Areas and reduces 

long-term sedimentation of streams

UR8-67 Existing Open 

UR Road

Decommission 

UR Road -

Obliterate

0.2

Increases miles of route obliterated in 

Riparian Conservation Areas and reduces 

long-term sedimentation of streams

UR8-68 Existing Open 

UR Road

Decommission 

UR Road -

Obliterate

0.3

Increases miles of route obliterated in 

Riparian Conservation Areas and reduces 

long-term sedimentation of streams

UR8-97

Decommission 

UR Road -

Obliterate

Existing Open 

UR Road 1.1

Mistakenly included in Alt. 3 for 

obliteration. Existing condition of this

open route is neutral in terms of 

sedimentation due to location of route 

outside of Riparian Conservation Area

Decision Rationale Conclusion

In conclusion, I selected Alternative 3 Modified in this decision for several reasons. 1. Because it meets the purpose 

and need best when compared to the other alternatives; 2. Because Alternative 3 modified minimizes potential 

negative environmental effects more than the other alternatives; 3. Because the modifications result in compliance 

with all applicable regulatory standards including those of the Northern Rockies Lynx Management Direction and 

Regional Soil Quality Standards. Additionally, my selected alternative complies with all other applicable law, 

regulation, and policy as discussed further detail in a later section of this document. 

Public Involvement

Involving the public is a very important aspect of the decision making process for the public resources that I manage. 

Public involvement efforts made throughout the NEPA process for this project have been valuable in helping me 

reach my decision and are described in detail in the following paragraphs.

29
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Scoping

Public involvement began with publication of a Notice of Intent (NOI) in the Federal Register (73 FR 32676) on June 

10, 2008. The NOI announced plans to prepare an EIS for a proposed integrated restoration project on approximately 

39,000 acres of NFS land in the BDNF. The project as outlined in the NOI was based on a GIS analysis of potential 

harvest and restoration opportunities, and at that time the full extent of project area acres had not been verified for 

actual suitability (i.e., “ground truthed”). During the fall of 2008, after NOI publication, the IDT collected additional onthe-ground data to refine the proposed action that later appeared in the DEIS.

On June 27, 2008, approximately 1,000 scoping letters or postcards were mailed to interested stakeholders, and a 

related news release was issued on July 2, 2008.

In June and July 2009, three public meetings were held in local communities surrounding the project area. The 

purpose of the meetings was to inform the public about the project, describe the proposed action, identify data gaps 

and unaddressed concerns, and provide further opportunities to comment. The meetings took place on June 17 in 

Deer Lodge, June 30 in Butte, and July 7, 2009 in Philipsburg. Notices of the public meetings appeared in Deer 

Lodge’s Silver State Post, Butte’s Montana Standard, and the Dillon Tribune. The meetings included FSP members, 

but were only lightly attended by the public, including fourteen individuals in Deer Lodge, four in Butte, and four in 

Philipsburg. A total of 37 individuals or organizations responded with 326 written comments on the proposed project 

as a result of public scoping and the subsequent meetings (see project planning record). Notes describing issues and 

concerns raised by the public were recorded at each meeting and a sign-in list was distributed; these may be found in 

the project planning record.

On October 23, 2009, the Forest Service, members of the FSP, and representatives of other organizations toured the 

project area. Data collected by the IDT was used in conjunction with input from FSP members and public scoping to 

develop the Proposed Action which appeared in the DEIS.

Forty-Five Day Public Comment Period - DEIS

In February 2010, the DEIS was published. Copies of the DEIS were mailed to the U.S. Environmental Protection 

Agency (EPA), who published a Notice of Availability (NOA) of the EIS in the Federal Register (75 FR 10255) on 

March 5, 2010. Publication of the NOA initiated a 45-day public comment period on the DEIS which ended on April 

19, 2010.

On April 9, 2010, the Forest Service hosted an open house in Deer Lodge to answer questions about the DEIS. That 

same morning, a local Deer Lodge radio station featured the project through a 30-minute radio interview with the 

Pintler District Ranger.

A total of 22 organizations, companies, government agencies, and individuals commented on the DEIS. Many public 

comments on the DEIS supported a larger treatment in the project area to respond to the extensive mountain pine 

beetle epidemic. The IDT conducted field reviews of the proposed larger treatment area, and collected site-specific 

data throughout the project area during the summer and fall of 2010. In units where potential timber harvest 

opportunities were identified, the field reviews and data collected addressed potential timber yield, access, and 

resource concerns. Comments and subsequent analysis helped establish Alternative 3.

On December 15, 2010, the Forest Service attended a meeting hosted by the FSP and answered questions about 

the project status.

On January 12, 2011, the Forest Service mailed a project status update postcard. The postcard was sent to local, 

state, Federal, and tribal governments; media contacts; and individuals and groups who had commented during 

scoping, commented on the DEIS, or who had otherwise expressed interest in the project.

30
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Forty-Five Day Public Comment Period - Revised DEIS

In January 2012, the Revised DEIS was published. A notice of availability (NOA) of the Revised DEIS appeared in 

the Federal Register (77 FR 4318) on January 27, 2012. The document was published for a 45-day public comment 

period which ended on March 12, 2012. It was also posted on the BDNF NEPA Projects web page. A legal notice in 

the Montana Standard was published on February 2, 2012 and an open house was held the same day in Deer 

Lodge. A total of 30 organizations, companies, government agencies, and individuals commented on the Revised 

DEIS. These comments and Forest Service responses to those comments are disclosed in FEIS Appendix C.

Objection Process Pursuant to 36 CFR 218

As this project implements a land management plan and is not authorized under the HFRA it is subject to subparts A 

and B of 36CFR 218 and subject to the objection process. The October 2014 FEIS and Draft Record of Decision 

were mailed to all people and organizations that commented during any prior designated opportunity for public 

comment. A legal notice of opportunity to object was published on October 12, 2014 in the Montana Standard, the 

Forest’s newspaper of record. Two objections were received during the objection filing period, one from the Alliance 

for the Wild Rockies, and one from Native Ecosystems Council. 

Written Response to Objections and Instructions to Forest

On January 8, 2015, the objection reviewing officer issued a letter to the objectors that responded to their objection 

points in writing. The letter instructed the Forest to address and clarify several areas in the analysis that were brought 

up during the objection process. In response to this letter and instructions, I have:

• Clarified the regulatory framework for grizzly bear in the Terrestrial Wildlife section of the FEIS by stating 

clearly that the regulatory standards for the Northern Continental Divide Ecosystem (NCDE) do not apply to 

the BDNF. NCDE regulatory standards are used as context to discuss overall population, habitat status, 

and distribution of grizzly bears in the analysis area.

• Completed consultation with the U.S. Fish and Wildlife Service (USFWS) on the threatened Bull Trout. 

Concurrence with the Not Likely to Adversely Affect call for Bull Trout was received from the USFWS on 

March 6, 2015. Both the Biological Assessment and Concurrence letter are included as appendices to this 

Record of Decision.

• Clarified and expanded the effects to Bull Trout as well as their presence/absence in the analysis area and 

provided supporting data for that information in the Aquatic Resources section of the FEIS.

• Included a brief natural history, regulatory framework, and additional discussion of cumulative effects to Bull 

Trout in the Aquatic Resources section of the FEIS.

• Clarified why temperature will not be affected in Peterson Creek and explained the connection between this 

and Bull Trout. Further clarified why the temperature portion of the TMDL will be unaffected and why.

• Further explained and provided supporting information for the legality of water diversions in question, as well 

as ensured consistency between the aquatics and hydrology analyses regarding this issue.

• Corrected typographical errors in the FEIS to remedy the inconsistencies describing silvicultural 

prescriptions for timber units, clarified how salvage harvest relates to 40-acre opening limitations, and 

elaborated on impacts from past logging on wildlife connectivity.

• Corrected the typographical error in the table showing during-project road densities.

• Updated the Terrestrial Wildlife section of the FEIS to display how leaving larger Douglas-fir trees authorized 

in this decision meets Christensen’s recommendations for maintaining thermal cover for elk.

31
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Additional Responses to Objections – Review of Literature Submitted 

In addition to the above clarifications and updates made to the analysis in the FEIS based on objections received, I 

also instructed the ID team to review literature submitted by objectors during the objection process to ensure that we 

have not missed any important aspects of the effects analysis to natural resources. I did this despite the fact that 

these references were never submitted or discussed in any previous opportunity for public comment on the project as 

described in the paragraphs above (scoping, two comment periods). In summary, the review resulted in the following: 

several references submitted were already used by resource specialists in their analysis; several others were 

relevant and had not been used but were subsequently used to inform the analysis after review; and finally many 

others (the majority) were deemed not applicable for a variety of reasons. Please see appendix C of this ROD for 

further detail on the references submitted, our evaluation of these references, and determination of the references 

applicability to the project area and analysis. In conclusion, although some of the literature was applicable and used 

to inform the analysis, I find that the literature submitted did not illuminate a failure on our part to consider an 

important aspect of the natural resource effects analyzed in the FEIS and upon which this decision is made.

Attempts to Resolve Objections – Objection Resolution Meeting

An objection resolution meeting was scheduled with the objectors for January 6, 2015 in Deer Lodge. The meeting 

was primarily scheduled to accommodate the objectors and the Objection Reviewing Officer’s schedules and 

secondarily to accommodate members of the FSP collaborative who had participated in the planning stages of the 

project. Much to my dismay, the objectors did not attend this meeting, neither in person nor via conference phone. As 

such, no resolution was reached with the objectors. However, I sincerely appreciate efforts made by the FSP 

collaborative who, not only actively participated in this 7-year process, but took time out of their schedules to attend 

the resolution meeting.

Full objection content and Forest Service responses to objections are available in the project file and on the 

Beaverhead-Deerlodge National Forest website. Further detail regarding Forest Service responses to and attempts 

to resolve the objections are discussed in the Objection Reviewing Officer’s letter. I am satisfied we have adequately 

addressed the concerns raised to date regarding potential effects of the project on the resources in the project and 

analysis areas. Public comments helped not only improve the analysis, but influenced decisions that I made as the 

responsible official throughout the process and ultimately my final decision.

Other Alternatives Considered

In addition to the selected alternative, I considered one other action alternative, which is discussed below. Alternative 

3 is the environmentally preferred alternative. Additional detail regarding the development of alternatives for this 

project can be found in the alternative development section of Chapter 2 in the FEIS.

Alternative 1 – No Action

The no action alternative provides a means for evaluating the current ecosystem conditions as a baseline. Under the 

no action alternative, current management plans would continue to guide management of the project area. None of 

the actions described in Alternatives 2 and 3 would be implemented.

I did not select this alternative because it does not meet the goals and objectives of the Forest Plan incorporated into 

the purpose and need as discussed in further detail in the Decision Rationale section above.

Alternative 2 – The DEIS Proposed Action

Alternative 2 is the proposed action published in the February 2010 DEIS with minor changes made since then. In 

general, Alternative 2 includes the following components.

1. Timber Units: Conduct salvage and commercial thinning in 50 timber units totaling approximately 2,400 acres to 

improve forest condition and recover economic value.

32
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

2. Restoration Units: Conduct treatments in 19 restoration units totaling approximately 9,032 acres to improve 

vegetation communities, wildlife habitat, and aquatic/riparian habitat. Note that Table 3 in the DEIS displayed a 

total of 9,422 acres of restoration units – this number incorrectly included private inholdings.

3. Outside Those Units: Conduct specific safety, resource improvement, and restoration treatments in areas outside 

timber and restoration units.

I did not select this alternative for reasons discussed in detail in the Decision Rationale section above.

Findings Required by Other Laws and Regulations

The National Forest Management Act of 1976

On April 9, 2012, the Department of Agriculture issued a final planning rule for national forest system land 

management planning (2012 Rule) 77 FR 68 [21162-21276]). None of the requirements of the 2012 Rule apply to 

projects and activities on the Beaverhead-Deerlodge National Forest, as the 2009 Forest Plan was developed under 

a prior planning rule (36 CFR §219.17(c)). Furthermore, the 2012 Rule explains, “[The 2012 Rule] supersedes any 

prior planning regulation. No obligations remain from any prior planning regulation, except those that are specifically 

included in a unit’s existing plan. Existing plans will remain in effect until revised” (36 CFR §219.17).

I have determined the selected alternative is consistent with the following provisions of the National Forest 

Management Act (NFMA): 

A. Forest Plan Consistency: NFMA requires projects and activities be consistent with the governing Forest 

Plan (16 USC 1604 (i)).

In reaching my decision, I have thoroughly reviewed the FEIS and the project file. I find my decision is in full 

compliance with, and responds to, applicable 2009 Beaverhead-Deerlodge National Forest Land and Resource 

Management Plan (Forest Plan) goals, objectives, and standards. This project is designed to be consistent with 

Forest Plan standards. I have included certain Forest Plan Standards in my decision that apply only to regeneration 

harvest even though this decision does not authorize regeneration harvest. This is due to the fact that ongoing 

mountain pine beetle infestations in the project area have progressed to the point where widespread mortality has 

occurred and stands have already regenerated naturally as described in more detail in the vegetation section of the 

FEIS.

Forest Plan timber management standard 2 limits the maximum size of openings created by one regeneration 

harvest operation to 40 acres on lands suitable for timber production. Exceptions are allowed where natural events 

such as fire, insect infestation (such as the current mountain pine beetle epidemic), or disease create an undesirable 

opening and require public notice and review, and approval by the officer one level above the responsible official 

(Forest Plan, page 39). Forest Service Manual 2471.11 also requires approval by the Regional Forester of all 

openings created by regeneration harvest greater than 40 acres under similar conditions, provided the public is 

notified and the environmental analysis supports the decision. Although my decision does not authorize regeneration 

harvest, I initiated the approval process during a point in project development where natural regeneration had not yet 

begun. 

Fourteen units will exceed 40 acres in size. The public has been notified of the intent to harvest units greater than 40 

acres during the 45-day comment period for the DEIS as well as the RDEIS, and the Regional Forester granted 

approval of the 14 units on January 25, 2013. All units were approved for treatment because these are openings that 

will occur regardless of human intervention as the forests in these areas are comprised mainly of lodgepole pine that 

are dead and dying from mountain pine beetle attack. These trees will fall down in 5-15 years and openings will be 

created through natural processes.

33
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

B. Other NFMA Consistency Requirements (findings): 

1. 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 units in my decision utilizing commercial harvest (either salvage, thinning, or a mix of the two treatment types) 

are on lands suitable for timber production or on lands not suitable for timber production but timber harvest is 

permitted to meet other resource objectives, as defined in the Forest Plan.

The other resource objective for lands not suitable for timber production is to reduce stand densities in the large 

size classes of dry forest communities and some lodgepole pine communities to maintain or improve resilient 

forest conditions (Forest Plan, pg. 43). I decided Douglas-fir thinning will occur in some of these areas to meet 

this Forest Plan vegetation objective; the remaining harvest type on lands not suitable for timber production but 

where timber harvest is permitted to meet other resource objectives is salvage. 

2. Timber Harvest on National Forest Lands (16 USC 1604(g)(3)(E)): A responsible official may authorize 

site-specific projects and activities to harvest timber on national forest system lands only where:

a. Soil, slope, or other watershed conditions will not be irreversibly damaged (16 USC 

1604(g)(3)(E)(i)). 

Mitigation measures provided in the alternatives are incorporated into the project design to ensure soil, 

slope, and watershed conditions are adequately protected (see alternatives section in Chapter 2 of FEIS). 

The selected alternative will not cause irreversible resource damage, such as to soil productivity or 

watershed condition as discussed in further detail in the soils and hydrology sections in the FEIS. Long-term 

improvements in watershed conditions are forecasted in the analysis of hydrology and aquatic resources as 

discussed in further detail in the FEIS.

b. There is assurance that the lands can be adequately restocked within five years after final 

regeneration harvest (16 USC 1604(g)(3)(E)(ii)). 

My decision does not authorize regeneration harvest because regeneration is not an objective of salvage 

treatments. Natural regeneration has already begun in lodgepole pine and mixed conifer stands authorized 

for salvage harvest in this decision.

c. Protection is provided for streams, streambanks, shorelines, lakes, wetlands, and other bodies of 

water from detrimental changes in water temperatures, blockages of water courses, and deposits of 

sediment, where harvests are likely to seriously and adversely affect water conditions or fish habitat 

(16 USC 1604(g)(3)(E)(iii)).

Protection is provided for streams, stream banks, wetlands and other bodies of water from detrimental 

changes. Protection of stream, riparian and fish habitats will be assured through best management 

practices, streamside protection rules and project specific design features and mitigations (see “Decision” 

section of this document) and as discussed in further detail in the Hydrology and Aquatics sections of the 

FEIS. The selected alternative mitigates adverse impacts during implementation of timber sale activities and 

will benefit aquatic resources in the long term.

d. The harvesting system to be used is not selected primarily because it will give the greatest dollar 

return or the greatest unit output of timber (16 USC 1604(g)(3)(E)(iv)).

Harvesting systems in the selected alternative meet the purpose and need most effectively and were not 

selected because they give the greatest dollar return or the greatest unit output of timber. The selected 

34
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

alternative has been chosen based on the rationale listed in the “Rationale for My Decision” section of this 

document. 

3. Clearcutting and Even-aged Management (16 USC 1604(g)(3)(F)): Insure that clearcutting, seed-tree

cutting, shelterwood cutting, 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 applicable.

No even-aged management or regeneration harvest prescriptions are authorized in this decision. Due to 

extensive mortality from mountain pine beetle, natural regeneration has already begun in lodgepole pine and 

mixed conifer stands. Salvage of the dead and dying lodgepole pine trees authorized in this decision will set the 

stands up for future management options and meet Forest Plan goals and objectives. Douglas-fir commercial

thinning units will not receive any regeneration silvicultural prescriptions.

4. Stands of trees are harvested according to requirements for culmination of mean annual increment of 

growth (16 USC 1604(m)).

Requirements for culmination of mean annual increment do not apply to salvage harvest or commercial thinning, 

as they are not even-aged management or regeneration harvests.

5. Construction of temporary roadways in connection with timber contracts, and other permits or leases: 

Unless the necessity for a permanent road is set forth in the forest development road system plan, any 

road constructed on land of the national forest system in connection with a timber contract or other 

permit or lease shall be designed with the goal of reestablishing vegetative cover on the roadway and 

areas where the vegetative cover has been disturbed by the construction of the road, within 10 years 

after the termination of the contract, permit, or lease either through artificial or natural means. Such 

action shall be taken unless it is later determined that the road is needed for use as a part of the National 

Forest Transportation System (16 USC 1608(b)).

Temporary roadways used in connection with project activities will be obliterated following use and vegetation 

will be reestablished as described in detail in the FEIS. Forest Service Soil and Watershed Conservation 

Practices are incorporated into project design features and include the reestablishment of vegetative cover after 

obliteration of temporary roads.

6. Standards of roadway construction: Roads constructed on national forest system lands shall be 

designed to standards appropriate for the intended uses, considering safety, cost of transportation, and 

impacts on land and resources (16 USC 1608(c)).

System road re-constructed in conjunction with this project will be designed to standards appropriate for the 

intended uses, considering safety, cost of transportation, and impacts on land and resources. Impacts of roads, 

both temporary and system, are considered in the analysis of this project (see Transportation Section of FEIS).

Other NFMA Findings

Sensitive Species

The sensitive species analysis disclosed in the FEIS meets requirements for a biological evaluation as outlined in 

FSM 2672.42. Sensitive species are administratively designated by the regional forester and managed under the 

authority of NFMA. The Act directs that guidelines for land management plans provide for diversity of plant and 

animal communities based on the suitability and capability of the specific land area in order to meet overall multipleuse objectives [16USC 1604 Sec 6 (g)(3)(B)]. The regional forester has designated a list of sensitive plants and

animals for which population viability is a concern (FSM 2670-5). Effects to sensitive species listed as occurring or 

possibly occurring in the project area have been analyzed in the FEIS (Sensitive Plants, Wildlife, and Aquatics

35
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

sections). I concur with the findings for these species. The findings document that the selected alternative will not 

contribute to a trend toward Federal listing or cause a loss of viability to the population of any species. 

Best Available Science

I am confident the analysis of this project was conducted using the best available science. My conclusion is based on 

a review of the record that shows my staff conducted a thorough review of relevant scientific information, considered 

responsible opposing views, and acknowledged incomplete or unavailable information, scientific uncertainty, and risk. 

Please refer to the resource analysis section in Chapter 3 of the FEIS for specific discussions of the science and 

methods used for analysis and for literature reviewed and referenced. 

Clean Air Act

Implementation of this project will be compatible with Montana State Air Quality Bureau (under the Montana 

Department of Environmental Quality [MDEQ]) goals for clear air based on Forest Service participation and 

compliance with burning restrictions set by the Montana/Idaho Airshed Group. The practices established by the 

Airshed Group are considered Best Available Control Technology by the Department of Environmental Quality. All 

prescribed burning will be implemented in full compliance with MDEQ air program with coordination through the 

Montana/Idaho Airshed Group. 

Clean Water Act and State Water Quality Standards

Implementation of this project will be consistent with the Clean Water Act and State Water Quality standards, which 

support an A-1 classification. One State Permit will be obtained to meet Federal and State of Montana water quality 

regulations prior to project implementation.

The Endangered Species Act 

The Endangered Species Act of 1973 requires Federal agencies to ensure that any agency actions (any action 

authorized, funded or carried out by the agency) are not likely to jeopardize the continued existence of any 

threatened, endangered or proposed species. Effects to listed and proposed species have been analyzed in the 

FEIS. I reviewed the analysis and projected effects on all listed species that may be present in the project and 

analysis areas; and concur with the findings for these species. 

A Biological Assessment for terrestrial wildlife species was submitted to the US Fish and Wildlife Service on July 2, 

2014. This assessment determined that the project may affect and is likely to adversely affect grizzly bears and may 

affect but is not likely to adversely affect Canada lynx. A letter was received from the US Fish and Wildlife Service on 

August 26, 2014. In addition, an updated letter was issued by the USFWS on February 20th, 2015. The letter 

specifies that the Service’s opinion is that the project is not likely to jeopardize the continued existence of the grizzly

bear; in addition they concur with the determination that the project is not likely to adversely affect Canada lynx. 

The findings in the FEIS indicate bull trout have the potential, albeit unlikely, to be present within the aquatics 

analysis area. Due to this potential we conducted informal consultation with the U.S. Fish and Wildlife Service on 

potential project effects to bull trout consistent with the ESA Section 7 consultation requirements. We prepared a 

Biological Assessment and sent this to the USFWS on January 22nd, 2015. A letter form the USFWS concurring with 

the findings of the BA that the project is not likely to adversely affect bull trout and bull trout critical habitat was 

received from the US Fish and Wildlife Service on March 6, 2015.

Biological Assessments and USFWS concurrence letters are included as Appendix B to this decision.

Environmental Justice

Executive Order 12898, issued in 1994, ordered Federal agencies to identify and address any adverse human health 

and environmental effects of agency programs that disproportionately impact minority or low-income populations. The 

36
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Order also directs agencies to consider patterns of subsistence hunting and fishing when an agency action may 

affect fish or wildlife. Based on public involvement and analysis in the Social and Economic section of Chapter 3 in 

the FEIS this decision will not adversely impact minority or low-income populations. 

National Environmental Policy Act

NEPA provisions and all regulations for implementation of NEPA (as required under 40 CFR 1500) have been 

followed in the development of the environmental impact statements and record of decision. Expected impacts of this 

project are disclosed in the FEIS. This record of decision describes my rationale for selecting it. 

National Historic Preservation Act, Archaeological Resources Protection Act

Implementation of the selected alternative will not result in direct impacts to heritage or cultural resource values. A 

compliance report for the project was submitted to the Montana State Historic Preservation Office; a letter of 

concurrence, signed December 19, 2011, agreed that the EDLV project will not have an adverse effect on historic 

properties. Their concurrence relies on the ability of the BDNF to implement avoidance strategies identified in the 

analysis in the FEIS.

Executive Order 131866

Executive Order 131866, outlines responsibilities of Federal agencies to protect migratory birds. Upon review of the 

effects regarding migratory birds in the Wildlife section of Chapter 3 of the FEIS, I find that this project will not 

adversely impact migratory bird populations or their habitats.

Executive Order 11990

Executive Order 11990 outlines responsibilities of Federal agencies to avoid long and short-term adverse impacts 

associated with the destruction or modification of wetlands and to avoid new construction in wetlands whenever there 

is a practical alternative. Upon review of the analysis in the Aquatics and Hydrology sections of the FEIS, I find that 

this project will not adversely affect wetlands.

Implementation Date 

The project may be implemented immediately.

Contact Person

For additional information concerning this decision or the East Deerlodge Valley Landscape Restoration Management 

Project, contact Alex Dunn, Interdisciplinary Team Leader, 406-683-3864; adunn@fs.fed.us

_/s/ Melany Glossa_____ __March 30, 2015____

MELANY GLOSSA DATE

FOREST SUPERVISOR

37
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Appendix A – Selected Alternative Maps

These maps are published as separate PDF files (either on CD, the WWW, or hard copy) due to their large file size.

38
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Appendix B – Biological Assessments and 

Concurrence Letters from U.S. Fish and Wildlife 

Service

These documents are published as separate PDF files (either on CD, the WWW, or hard copy) due to their large file 

size.

39
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Appendix C – Documentation of Review and 

Consideration of Literature Referenced in Objection

This appendix documents the results of the review of references submitted during the objection process. 

The purpose of this review of submitted references is to consider the applicability of the submitted 

document to the project area, proposed activities, and the analysis of effects to the resources analyzed in 

the FEIS. Additionally, this review aimed to answer a more basic question of whether the existing 

analysis failed to analyze an important aspect of the natural resources present in the project and analysis 

areas.

These pieces of literature had not been previously referenced to support comments on the DEIS or 

RDEIS. As such a detailed reference review had not been previously conducted. We reviewed the 

literature with the intent of considering important aspects of the subject area being addressed by the 

author of the literature and relating those aspects to the project area and proposal. The summary of the 

literature is in the first paragraph followed by how the literature was considered in italics.

1. Bull, E., C. Parks and T. Torgersen. 1997. Trees and Logs important to wildlife in the Interior 

Columbia River Basin. USDA Forest Service, General Technical Report PNW-GTR-391

This publication provides managers with a description of ecological processes that create wildlife trees, 

snags and logs and provides qualitative and quantitative information on these distinct structures specific 

to the Columbia River basin. It presents information specific to the Columbia River Basin managers to 

use to make decisions regarding conservation and enhancement of dead wood structures that are most 

valuable to wildlife. The document states clearly that the information included in the document applies to 

coniferous forest lands in the interior Columbia River Basin and the specific habitats found in that area. 

Only select pages of this document were provided therefore the entire document could not be review for 

relevancy. Of the pages provided, emphasis was on snag management direction and requirements of 

woodpecker species from research conducted in Oregon.

The East Deerlodge Valley Landscape Restoration Project (EDLV) is not within the Interior Columbia 

River basin or associated habitats described in the document. Science used in the EDLV document for 

snag and other wood structures (such as downed wood) was specific to the habitat types found on the 

Beaverhead-Deerlodge National Forest and information collected and management recommendations 

specific to this area of Montana. Specifically, the size recommendations for snag retention in the EDLV 

are supported by analysis conducted by a similar process (Bollenbacher et al. 2008) and 

recommendations from this document were used to develop the BDNF Forest Plan Standards for snags 

and large woody debris. 

2. Raley, C., E. Logroth, R. Truex, J. Yaeger and J. Higley. 2012. Habitat ecology of fishers in 

western North America. Pages 213-254 in: Biology and conservation of martens, sables and fishers: 

a new synthesis. 

This publication on fisher habitat ecology was only provided with pages 231, 242, 245-246, and 248. Of 

the pages provided, detailed information regarding fisher habitat needs and selection were presented 

focusing on the fisher being a structure dependent species that does not prefer deep snow and selects for 

areas that contain relatively high proportions of mid-to-late seral conditions and a moderate to dense 

forest canopy. However, because investigators used different field and analytical methods to estimate 

canopy cover, the authors were not able to make direct comparisons among studies or evaluate critical 

thresholds of canopy cover for fishers.

40
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Fisher habitat and effects to fisher were analyzed in detail in the EDLV FEIS following the R1 Fisher 

habitat model which was developed considering the best available science and information on fisher 

which is specific to Montana and northern Idaho. These habitat values used in the R1 model support the 

information provided in this document.

3. Balda, R. and N. masters. 1980. Avian communities in the pinyon-juniper woodland: a 

descriptive analysis. Pages 146-164 in: Proceedings: management of western forests and grasslands 

for nongame birds. R. Degraff and N. Tilgham, Eds. USDA Intermountain Forest and Range 

Experiment Station, INT-GTR-86.

This document describes the bird communities known to breed in the pinyon-juniper woodland in the 

western United States. It describes foraging behavior and the importance of juniper berries and pinion 

pine seeds to these species.

The EDLV project is not within the pinyon-juniper woodland habitat type therefore the information 

presented in this piece of literature cannot be specifically incorporated into the EDLV analysis. Impacts 

of the project on conifer seeds and the importance of conifer seeds as a food source was analyzed in 

detail however more specifically for the species and habitats present in the project area. 

4. Benkman, C. 1993. Logging, conifers and the conservation of crossbills. Conservation Biology 

7:473-479.

This article is a survey of forestry literature that displays relationships between logging and conifer cone 

production and the impact to the red crossbill. In western North America there are at least 5 different 

species of the red crossbill and each specializes on a different species or a single variety of conifer. 

Measures for conserving this diversity of crossbills include protecting mature and old growth stands.

The red crossbill is considered common, widespread, and abundant and not vulnerable in most of its 

range in the State of Montana therefore this species was not analyzed in detail as a bird of conservation 

concern or a species of interest in the FEIS. The recommendations for conserving crossbills is consistent 

with the EDLV project as the project does not remove old growth habitat, retains the largest trees which 

are the ones that produce the most cones and produce consistently. Additionally, treatments proposed 

move conifer stands in the project area quicker to a more mature age class and are designed to enhance 

the Douglas-fir habitat for the red crossbill by reducing competition on remaining trees to promote a 

stand of larger trees which over time produce more conifer cones than smaller trees. 

5. Bodin, M. 2014. Flying High: protecting West Virginia’s northern flying squirrel from extinction 

requires a lot of science, land protection and 300,000 new trees. Pages 50-60: Nature Conservancy 

Magazine, April/May 2014.

Only page 57 of this document was provided. This page of the document details the size, diet, range and 

nests of the West Virginia northern flying squirrel. This squirrel eats fungi, weighs 5 ounces and can nest 

in woodpecker holes in hardwood trees or build stick nests in the branches of conifers. This page of the 

article also details the partnership the Monongahela National Forest has to plant saplings of red spruce in 

areas where non-native spruces were previously plant.

It is unclear how the West Virginia northern flying squirrel and habitat restoration of red spruce on the 

Monongahela NF relate to the EDLV project. The northern flying squirrel in Montana is considered 

secure at the state level and is not a species of concern. 

41
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

6. Bull, E., M. Henjum, and R. Rohweder. 1988. Nesting and foraging habitat of great gray owls. 

Journal of Raptor Research 22: 107-115.

This study researched 46 great gray owl nests in northeastern Oregon from 1982-1986. Site characteristics 

of the nest were detailed as well as foraging habitat, nest success. Approximately 76% of nests were 

located in western larch. The forest types where nests were found included: Douglas-fir-grand-fir, western 

larch-lodgepole pine, ponderosa pine-Douglas-fir and ponderosa pine. No management recommendations 

for great gray owls were proposed. The presence of logging activity was recorded as a variable of nest site 

characteristics; however there was no definition of logging activity. 

Great gray owls were analyzed as a species of interest in the EDLV analysis based on Great gray owls 

are known to use spruce-fir, lodgepole pine and Douglas-fir cover types on the BDNF. This species is not 

a sensitive species for the BDNF and Surveys for this species were conducted and the species was not 

detected. There have been no records of this species in the project area. The foraging habitat and nest 

characteristics described in this research are consistent with the information presented in the EDLV 

FEIS. Mitigation measures in the alternatives minimize activity during the majority of owl nesting season. 

Because it was unclear in the literature the definition of logging activity, no recommendations for great 

gray owls in respect to logging were presented; no new information was present in this document that 

was inconsistent with the EDLV analysis. The EDLV increases vegetation resiliency, maintains old 

growth, and to retains large snags which is consistent with the great grey owl habitat described in this 

literature.

7. Bull, E., and M. Henjum. 1990. Ecology of the great gray owl. USDA Forest Service, General 

Technical Report PNW-GTR-265

This piece of literature was referenced and incorporated into the FEIS.

8. Bull, E., A. Wright, and M. Henjum. 1990. Nesting habitat of flammulated owls in Oregon. 

Journal of Raptor Research 24:52-55

This research located 33 flammulated owl nests in northeastern Oregon during 1987-1988. It 

characterized nest sites, including the tree size and other nest habitat variables. Management 

recommendations for Flammulated Owls in Oregon would be to leave dead trees (>50cm (20 inches) and 

>6m tall) with cavities as large as a northern flicker cavity on ridges or upper slopes with east and south 

aspects of large diameter ponderosa pine/Douglas fir or grand fir forest types with Ponderosa pine in the 

overstory. 

The Flammulated owl was analyzed in detail as a Sensitive Species in the EDLV FEIS. The EDLV project 

retains large snags and live trees which is consistent with the size recommendations described in this 

literature. The forest types described in this research are not present in the EDLV analysis area; 

therefore the precise recommendations cannot be followed as the habitat does not exist. No new 

information was present in this document that was inconsistent with the EDLV analysis.

9. Bull, E., and R. Holthausen. 1993. Habitat use and management of pileated woodpeckers in 

Northeastern Oregon. Journal of Wildlife Management 57:335-345.

This research determined home range size and habitats used by pileated woodpeckers in northeastern 

Oregon in 1989-1990. The study determined that habitat use in the study area was not random and that 

pileated woodpeckers selected for stands with old growth, grand fir, no logging and greater than 60% 

canopy cover. Recommendations for management of pileated woodpeckers in this area of Oregon were to 

increase density of snags and downed wood and increasing the size of management areas for pileated 

42
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

woodpeckers with 75% of the land being in grand fir forest type, 25% being old growth and the remainder 

mature stands and at least 50% have greater than 60% canopy closure and at least 40% be unlogged.

The EDLV project area was surveyed for the presence of woodpeckers and pileated woodpeckers were 

documented and analyzed in detail. The project area does not contain the grand fir forest type as 

presented in this research and this forest type is not present on the BDNF. Large diameter trees (live and 

dead) would be maintained in the EDLV analysis area and old growth mitigation is incorporated into the 

design of the project. Potential habitat (large diameter snags and old growth) would continue to be 

widespread and abundant in the analysis area. Because the forest type presented in this analysis is very 

different than present in the EDLV analysis area, it is difficult to apply the recommended standards from 

this literature. Best available science was considered in the analysis conducted on woodpeckers in the 

EDLV project. No new information was present in this document that was inconsistent with the EDLV 

analysis.

10. Bull, E., and A. Blumton. 1999. Effects of fuels reduction on American martens and their prey. 

USDA Forest Service Research Note: PNW-RN-539.

The effects of a fuels-reduction treatment in northeastern Oregon on small mammals were investigated. 

The study specifically stated that the researches do not recommend extrapolating the data beyond the 

particular study because the changes observed could have resulted from a variety of reasons. 

The type of treatment proposed in this study is not similar to EDLV as the EDLV is not a fuels reduction 

project and the action alternatives retain downed woody debris and snags following Forest Plan 

direction. Impacts to snowshoe hare and snowshoe hare habitat were analyzed in detail in the EDLV 

analysis. Additionally, study specifically stated that the researches do not recommend extrapolating the 

data beyond the particular study because the changes observed could have resulted from a variety of 

reasons. Additionally, this piece of literature was discussed in the FEIS (Response to Comment L-17 

Comment 65). The proposed lodgepole pine salvage units in this project are dominated by dead lodgepole 

pine with sparse understory vegetation and are not similar to stands studied by Bull and Blumton (1999), 

nor are fuels reduction treatments proposed. This project incorporates Forest Plan direction for snag and 

downed log retention and is consistent with the referenced literature. Therefore, there is no additional 

information presented in this study that could be extrapolated to the EDLV project. 

11. Bull, E., N. Nielsen-Pincus, B. Wales and J. Hayes. 2007. The influence of disturbance events on 

pileated woodpeckers in northeastern Oregon. Forest Ecology and Management 243:320-329

This study compared the effects of natural and human-caused disturbances on pileated woodpeckers over 

a 30 year period in northeastern Oregon. In the Pacific Northwest, the pileated woodpecker is a species of 

conservation concern and an indicator of mature and old forest habitat conditions. High tree mortality and 

loss of canopy closure from insect outbreaks in grand fir and Douglas-fir did not appear to be detrimental 

to pileated woodpeckers provided that dead trees and logs were abundant and stands were not harvested. 

Density of nesting pairs decreased as existing habitat was impacted from logging regeneration harvest. In 

summary, the study concluded that insect outbreaks are an integral part maintaining habitat for this 

species in northeastern Oregon in grand fir/Douglas-fir and Ponderosa pine forest habitats. The species is 

able to adapt to using a wide variety of tree species and habitat conditions, although large trees appear to 

be essential. Closed canopy forests were not essential for use by pileated woodpeckers. 

The EDLV project does not contain the forest habitats as described in this study in northeastern Oregon. 

This species was analyzed in detail and the recommendation in this study (retaining large trees) is 

incorporated into the design of the action alternatives. Regeneration harvest is not proposed in lodgepole 

pine habitats or Douglas-fir, which was discussed in the study. The areas proposed for salvage harvest in 

43
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

EDLV are small diameter lodgepole pine stands currently dead and falling over creating large openings. 

The habitat in these units is not preferred by pileated woodpeckers, as described in this research. Large 

diameter trees (live and dead) would be maintained in the EDLV analysis area and old growth mitigation 

is incorporated into the design of the project. Potential habitat (large diameter snags and old growth) 

would continue to be widespread and abundant in the analysis area. Best available science was 

considered in the analysis conducted on woodpeckers in the EDLV project specifically regarding pileated 

woodpeckers and known use in Montana. No new information was present in this document that was 

inconsistent with the EDLV analysis.

12. Buskirk, S., S. Forrest, M. Raphael, and H. Harlow. 1989. Winter resting site ecology of marten 

in the central Rocky Mountains. Journal of Wildlife Management 53:191-196.

This study investigated resting site ecology of American martens in the Medicine Bow Mountains in 

southeastern Wyoming. The study found 8 marten and these marten rested primarily in subnivean sites 

associated with coarse woody debris, including logs and stumps in lodgepole pine and Engelmann 

spruce/subalpine fir forests. The study stated the importance of resting where coarse woody debris is 

available to provide thermal cover may explain the apparent dependence of marten on old-growth forest 

in the central Rocky Mountains in the winter. The most common nesting sites were in spruce/fir stands in 

the coldest weather in areas with greater availability of coarse woody debris than other areas. The reason 

for proximity of resting sites to streams and lakes was less clear; however prey availability is likely higher 

in riparian settings. In summary, the study concluded retention of spruce-fir stands and the dispersion of 

those stands in relation to foraging areas may be important to marten populations. The size, shape and 

properties of coarse woody debris and its position in relation to the snow surface should be considered 

when managing for marten. 

Pine marten are ranked G5 (common, widespread and abundant locally) and S4 (populations apparently 

secure in the state) by the Montana Natural Heritage Program. They are not on the State’s Species of 

Concern list and are not considered to be at risk. The Forest Plan ensures viability for wildlife, including 

pine marten, through application of the Forest-wide goals, objectives and standards. Forest Plan 

direction ensures management of a variety of habitats in various successional stages so as to ensure the 

viability of a variety of species associated with those different habitats. In addition, retention of specific 

habitat components (snag, live tree and down woody debris retention) is addressed through incorporation 

of Wildlife Standards 3, 4 and 12 into this project.

Discussed in the FEIS, Ruggerio et al. (1998) did identify important den structures as rock crevices, 

snags, red squirrel middens and logs. They concluded that large logs, large snags, and large, live spruce 

and fir trees are important characteristics for marten den sites in the central Rocky Mountains. This 

project incorporates Forest Plan direction for snag and downed log retention and is consistent with the 

above referenced literature and does not propose in spruce fir forests. Therefore, there is no additional 

information presented in this study that could be extrapolated to the EDLV project.

13. Clough, L. 2000. Nesting habitat selection and productivity of northern goshawks in westcentral Montana. MS-Thesis, University of Montana.

This report was not present in whole, only pages 25-27, and 61. Of the pages presented, goshawk habitat 

and the importance of snowshoe hares were detailed. The study also demonstrated that the habitat 

availability in the central and northern Rockies is more limited simply because forest cover types change 

more abruptly with increases in elevation. Snowshoe hares were the goshawks primary prey species in the 

study; however goshawks preferred to nest in more open-grown, lower-elevation areas, where habitats are 

drier and thought to support fewer snowshoe hares. Goshawks avoided subalpine-fir, spruce-fir and 

higher elevation lodgepole in the study area which supports the hypothesis that there is an upper density 

limit for tree and understory development. 

44
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

This document was referenced in the FEIS with incorporation of the R1 Northern Goshawk Overview as 

this document was used in the Overview. Snowshoe hare habitat and impacts to snowshoe hare were 

analyzed in detail in the lynx analysis section of the FEIS. Habitat for goshawks and impacts to goshawks 

were analyzed in detail and is consistent with the information presented in this study. 

14. Dixon, R., and V. Saab. 2000. Black-backed woodpecker. Pages 10-20 in the Birds of North 

America, No 509

Pages 10, 11 14 and 15 of this document on the black-baked woodpecker were provided. The information 

presented in these pages provided contain breeding information which includes nest site characteristics, 

population status trends and conservation and management recommendations. The conservation and 

management recommendations are specific to post fire salvage logging, burned forests (the habitat 

preferred by this species), recommendations from research conducted in eastern Oregon in old growth and 

mature lodgepole pine stands and elevation limits (<4500ft) in central Oregon.

Nest site characteristics are consistent with the information with presented in the EDLV analysis. The 

conservation recommendations are for habitats not present and or not proposed for treatment in the 

EDLV project. The elevation limits for central Oregon is not applicable to habitat in Montana as 

elevation limits for this species are much higher as a majority of elevations in the state are above 4500 ft. 

15. Davis, J. and L. Williams. 1964. The 1961 Irruption of the Clark’s Nutcracker in California. 

The Wilson Bulletin Volume 76: No.1, pages 10-18.

This document details the irruption (to undergo a sudden upsurge in numbers especially when natural 

ecological balances and checks are disturbed). During these irruptions, numbers of nutcrackers left the 

usual montane winter range in California and spent the winter in the coastal and desert regions, some 

remaining well into the following spring or even summer. The cone crops on the west slope of the Sierra 

Nevada for 1959-1961 for ponderosa, sugar and Jeffrey pine and white fir were presented. These tree 

species were considered to be of primary importance for winter seed storage for the Clark’s nutcracker in 

this area of California. All of these tree species had a low cone crop in 1961. The poor cone crop years 

were preceded by two or more years in which there were heavy cone crop years which suggest that the 

populations of nutcrackers built up during those years. However, 1961 was not preceded by two years of 

high cone crops and the role of population buildup and overcrowding in California was not clear. This 

irruption was similar to other neighboring states during 1961. The researchers concluded that the role of 

population irruptions was not clear and that they could not clearly explain why irruptions did not occur in 

some years of cone shortage. 

The Clark’s nutcracker and impacts of conifer cone habitat on species that utilize these cones were 

analyzed in detail in the EDLV FEIS. There is no information presented in this study on the California 

irruption of 1961 that conflicts with any information presented in the EDLV analysis. The habitats studied 

in California are not present in the EDLV analysis area and the large cone crop species differ therefore 

the importance of the tree species presented in the study cannot be incorporated into the EDLV analysis. 

16. Fager, C. 1993. Fox of the treetops. Pages 28-31 in Montana Outdoors, November/December 

1993. 

Not all pages of this document were submitted for review. The pages presented (28-31) describe the 

natural history of the American marten, including size, behavior characteristics and preferred habitat. The 

pages presented also detail the southwest Montana pine marten project conducted in 1988-1999. One 

martens was documented traveling distances up to 25 miles in one direction and one marten traveled 9 

45
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

miles overnight. The effects of clearcut logging on marten were generalized in this article, however not 

specifically attached with data associated with the research. Generally the study showed that martens 

rarely used large openings. Old growth forests were noted to probably represent some of the best marten 

habitat available but are not considered the only forests that support marten. The study taught the 

researches that in southwestern Montana martens pose a degree of adaptability that goes well beyond their 

customary classification as an old growth dependent species. The effects of fur harvest on marten were 

not presented in full in the pages provided.

The study showed that martens rarely used large openings; however there was no definition of a large 

opening. Therefore it is difficult to apply a recommendation to EDLV that incorporates this information 

as there is not threshold in this study. The natural history information present on marten is consistent 

with the information presented in the EDLV FEIS response to comments on marten. There is no 

additional information in this study that was not considered in EDLV.

17. Fisher, R. and M. Myers. 1979. A review of factors influencing extralimital occurrences of 

Clark’s nutcrackers in Canada. Canadian Field-Naturalist 94(1): 43-51.

Only pages 43 and 48 were presented for review. Of these pages, the abstract, the intro, one paragraph of 

results, diet, caching behavior, winter system effects and one paragraph of density effects were included. 

The abstract detailed the researches documented 67 occurrences of Clark’s nutcrackers outside of its 

normal range in Canada from 1904-1976. Approximately 86% of the occurrences were recorded from 

August to November. Recurring failure of coniferous seed crops in the normal range of the nutcracker and 

the passage of weather systems were considered the most likely factors influencing extralimital 

occurrences of Clark’s nutcrackers. The diet of Clark’s nutcrackers was documented from other studies 

and listed as Limber pine and Whitebark pine seeds in Alberta, and to a lesser extent Douglas-fir 

(personal communication reference). Caching behavior and seed crop failure was also discussed from 

studies Tomback (1978) and Davis and Williams (1957). Weather patterns were discussed as having 

impacts to bird species as severe weather and strong winds move birds to other areas. 

Information specific to Clark’s nutcracker in Montana was presented in the EDLV analysis area and does 

not conflict with the information presented in this literature. Impacts of weather on bird species is a 

factor that is unpredictable but documented. Because the impacts of severe weather is difficult to predict 

or measure and has not been identified as a threat to the species analyzed in the EDLV document, this 

variable was not used in the effects analysis of any bird species. There is no information presented in the 

2 pages of this document that have not been considered, are inconsistent with the information in EDLV or 

warrants further analysis. 

18. Franklin, A. 1988. Breeding biology of the great gray owl in southeastern Idaho and northwest 

Wyoming. The Condor 90:689-696

This study documented the existence of a breeding population of Great Gray Owls in southeastern Idaho 

and northwestern Wyoming. Fifteen nests were documented and 40% of them in old stick nests and 60% 

on tops of broken-top snags. Nests were frequently reused and owls nesting near clearcuts had higher 

percentages of pocket gophers in their diet while those nesting near meadows had higher percentages of 

voles. Fledgling success was highest at nests where high percentages of pocket gophers were present in 

the diet. The DBH measurements of nest trees in lodgepole pine were 50.8 cm (20 inches) +/- 6.7cm. 

Incubation dates, mean date of first egg laid and when young left their nest was also recorded. 

Productivity was high in this study with a mean of 3 young fledged per successful nest. Nests in spruce/fir 

snags were more productive and stable than nests in lodgepole pine snags and stick nests. The use of 

snags as nests may be related to nest-site availability within different proportions of the species’ breeding 

46
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

range. Survival of fledged young probably depends on availability of roosts, and the existence of forested 

habitat within a 500m radius surrounding the nest. 

Great gray owls were analyzed in detail in the FEIS and the information presented in this study from 

Idaho and Wyoming is consistent with the information used in the FEIS. The largest trees of all species 

would remain in each harvest unit which is consistent with the information presented in this research that 

owls use large diameter trees and snags. Fledgling success was documented as the highest with high 

numbers of pocket gophers in their diet which corresponded to nests near clear cuts. This variable was 

not analyzed in detail however, if utilized in the analysis, could draw conclusion that clear cut habitats 

(large openings) could contribute positively towards nesting success of great gray owls. This could 

potentially reduce impacts from the project as analyzed however clearcutting is not proposed in the 

EDLV project. Regeneration harvest (clearcutting) is not proposed because the stands proposed for 

salvage are already regenerating. Therefore, there may not be increased benefits to owls from the 

treatment type. 

19. Goggans, R., R. Dixon, and L. Seminara. 1988. Habitat use by three-toed and black-backed 

woodpeckers, Deschutes National Forest, Oregon. Oregon Department of Fish and Wildlife 

Nongame report 87-3-02.

The pages submitted were numbered in an order by the submitter that is not the sequential order of the 

document. There were no original page numbers in the document so the order they were originally in and 

the number of missing pages is unclear. Of the pages submitted, the abstract, one page of management 

implications, pages of results and other pages (without headings and out of sequence) were included 

possibly from similar sections, but it was unclear. In summary, the emphasis of the management 

application page was on maintaining mature and over mature lodgepole pine and lodgepole pine/mixed 

conifer stands for woodpeckers in Oregon. The size and elevation of this habitat was specific to the 

Deschutes National Forest. In conclusion the researchers stated that the recommendations presented are 

intended to evolve as more information becomes available.

Mature and over mature lodgepole pine is not targeted for treatment in the EDLV project area as over 

90% of the habitat is dead and dying from mountain pine beetle. The size of the woodpecker management 

areas would not be possible in this project as the habitat is not available due to the mountain pine beetle 

epidemic. The elevation used in the study is also not comparable to the EDLV analysis area, as it is at 

elevations are much higher than those in Oregon where the study was conducted. The natural history 

information that was presented is consistent with the woodpecker analysis in the EDLV document and no 

new information was present in this document that was inconsistent with the conclusions in the EDLV 

analysis. 

20. Hagar, D. 1960. The interrelationships of logging, birds and timber regeneration in the Douglasfir region of Northwestern California. Ecology 41: 116-125

The purpose of this study was to determine changes in species composition, numbers, food habits and 

activities of bird populations immediately after the forest is logged and during the first few years after 

logging in a Douglas-fir stand in Northwestern California. Only the first page and the last page of this 

piece of literature were provided, making it difficult to understand the results, the study method, and draw 

conclusions. The first page detailed the study areas which consisted of twenty cutover and virgin forest 

areas. Of the cutovers, 7 were weed-stage cutovers (1-2 years old), 8 were in the brush-stage (3-7 years 

old) and 5 were virgin forest areas. The Friday Ridge Forest was documented as the most typical of the 

region at elevations below 4,000ft. This forest consists of a nearly homogeneous stand of mature and 

over-mature Douglas-fir with a dense brushy understory of tan oak. The most plant producing animal 

food in the region is considered Douglas-fir, tan oak and Pacific madrone. Juncos were noted to be 

47
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

capable of consuming up to 17% of the seed crop that is likely to fall on a cutover area in a good seed 

year in this area of California. The researchers recommended that when making an estimate of the seed 

potential from a cone crop in Douglas-fir, the forester should note other important crops for wildlife food. 

In this area of California, the crops of the other important wildlife foods greatly influence the degree of 

bird depredation on fir seed. In the summary section, logging was noted to cause a definite increase in 

bird population size and species composition. The junco became the predominant on cutovers where an 

abundance of weed seeds, berries and insects were present. They turned to Douglas-fir seeds when 

available. A list of other seed eating birds was presented.

The Douglas-fir forest presented in this study is a drastically different Douglas-fir forest type that is 

present in the EDLV analysis area. The climate of northwestern California is much different, resulting in 

species that are not present in Montana. It is documented in EDLV that conifer seeds, particularly from 

Douglas-fir are an important food crop for many wildlife species, including birds. Because the habitat 

types are so different, the specific increase in bird species and changes in composition after logging in 

this study cannot be easily carried over to expected results from the EDLV project because the plant 

composition and bird species are not identical. There is no additional information in this piece of 

literature that contradicts information presented in EDLV or would challenge the conclusions in EDLV. 

The analysis in EDLV was consistent with the information from this that was applicable, As mentioned 

previously, the entire document was not presented, which made drawing additional conclusions (on the 

applicability of the study to EDLV) difficult. 

21. Heinemeyer, K. 2002. Translating individual movements into population patterns: American 

marten in fragmented forested landscapes. Ph.D. Thesis, University of California, Santa Cruz.

Pages 114-120 of this thesis were provided. Of the pages provided, the researcher stated marten were 

found to rarely cross any clear-cuts and when they do, tend to be narrower at the point of crossing. 

Clearcuts that are crossed in the winter nearly always had structural features above the snowpack. Marten 

appeared to more readily cross clearcuts when snow was soft and uncrusted under the tree canopy, but 

crusted in the wind-blown habitat. In soft snow, energy expenditure for movement is high and marten 

may be willing to take greater risks to travel in open habitat because of the ease of travel and shorten 

travel distance. Marten moved an average of 80 m across open clearcut habitat and wider clear cuts 

seemed to represent movement barriers to marten in similar systems. Standing trees, islands of trees and 

snags were considered security features for marten. Clearcuts less than 50m wide or ones with high 

numbers of residual trees, snags or forested islands were considered crossable. The number of trees was 

not included. In the management recommendations section, tree retention policies were mentioned as 

providing connectivity benefits to marten. Martens were known to forage in slash piles of clear cuts but 

rarely in the clearcut. In larger clearcuts, martens followed the edges as travel routes. Martens preferred to 

forage within interior forests at average distances of 200m from a clearcut. Emphasis was put on the value 

of mature mixed conifer stands, complex lodgepole habtiats and naturally structured lodgepole pine 

habitats well distributed across the landscape. The researcher recommended that clearcuts should be less 

than 20-25% of the landscape to minimize effects to marten. Thinning of lodgepole pine habitats where 

all of the residual coarse woody debris was removed also was documented as reducing habitat for marten. 

Recommendations in this thesis focused on minimizing the amount of the landscape that has been 

clearcut. The EDLV project does not propose clearcutting however is well below the threshold of 

treatment (20-25%) amount in a landscape. Therefore the project is consistent with the recommendations 

in this literature. Additionally, the thinning areas studied in this project were documented to have had all 

of the residual coarse woody debris removed which is not similar to the EDLV. Coarse woody debris 

requirements are included in both action alternatives as mandated by the BDNF Forest Plan. The salvage 

harvest proposed in this project is not a regeneration harvest as is a clearcut, as the stands proposed for 

treatment are already regenerating and have large amounts of downed debris due to the beetle kill. The 

48
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

EDLV is consistent with the recommendations presented in this analysis and there was no additional 

information presented that could be included in the analysis as proposed actions are different than those 

studies in the thesis. 

22. Herbers, J. and W. Klenner. 2007. Effects of logging pattern and intensity on squirrel 

demography. Journal of Wildlife Management 71:2655-2663

This study examined harvesting intensity and pattern on red squirrels, northern flying squirrels and 

yellow-pine chipmunks. From 2-4 years after logging, red squirrel density was lower in stands with 50% 

basal-area tree removal. From year 1 and up to 4 years after logging, northern flying squirrel density 

averaged lower in harvested treatments regardless of intensity or pattern. Density of yellow-pine 

chipmunks increased with logging intensity. The study recommended leaving greater than 10 sq. meters 

per ha of live residual stand structure in mature inland Douglas-fir forests to retain habitat for species 

such as the red squirrel and northern flying squirrel. Researchers recommended different harvesting 

systems should be applied in a coordinated manner as there was no single best harvest treatment that was 

suitable for all 3 species. How to apply the different harvesting systems and to coordinate them was not 

specified. The loss of snags and reduction of mature confer seed-producing trees from harvest was 

mentioned as influencing the reduction of squirrels. 

The red squirrel, northern flying squirrel and yellow-pine chipmunk are not considered species at risk in 

Montana and are considered secure at the state level. This research does not contradict any information 

present in the EDLV analysis area, as it was noted that the removal of habitat has the potential to impact 

numerous species that may be present in the analysis area. Large trees, snags and the trees that produce 

the most seeds for wildlife would be retained in the action alternatives, minimizing impacts to conifer 

seed dependent wildlife. Salvage logging and thinning are proposed in the EDLV project, which seems 

consistent with the recommendation that different harvesting systems should be applied in areas to 

diversify effects. There was no additional information presented in this study that contradicts the analysis 

in the EDLV FEIS or would cause conclusions to become null. Additionally, there are no other specific 

recommendations that are applicable to the actions proposed in EDLV. 

23. Herbers, J., R. Serrouya, and K. Maxcy. 2004. Effects of elevation on forest cover on winter 

birds in mature forest ecosystems in southern British Columbia. Canadian Journal of Zoology 82: 

1720-1730.

Not all pages of this piece of literature were provided. The pages provided were 1720, 1721, 1725, 1726, 

and 1729, which was half of the document (1720-1730). In the pages provided, the abstract stated that 

winter diversity, distribution and density of nonmigratory birds were studied in six mature forest 

ecosystems in southern British Columbia. Mature forests at low elevations had more species and more 

birds than at high elevation. The researchers also found that low species richness and low bird densities 

were found in lodgepole pine stands and was likely related to the low levels of vegetation structure and 

foliage volume. Conservation priorities in the document focused on maintaining mature habitat at low 

elevations away from intense human land use for the purpose of bird conservation. The researchers also 

stated that when forest managers replace non-pine or mixed species conifer stands with stands dominated 

by lodgepole pine, they should anticipate lower winter habitat quality for birds.

The conservation recommendations in this document are consistent with the EDLV proposal as the 

largest trees are identified to be retained, Douglas-fir treatments will increase resiliency of the stands, 

maintain old growth characteristics and allow the trees to continue to grow with decreased competition. 

Dead and dying lodgepole pine that is proposed for salvage is currently in lodgepole pine forest and will 

continue to naturally regrow as a lodgepole pine stand. This project does not replace non-pine or mixed 

species conifer stands with lodgepole pine and has no influence on the elevation of the forest types. 

49
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

24. Holloway, G. and J. Malcom. 2006. Sciurid habitat relationships in forests managed under 

selection and shelterwood silviculture in Ontario. Journal of Wildlife Management 70:1735-1745

Relationships between flying squirrels and chipmunks in managed and unmanaged stands in Canada were 

studies in this article. The researchers studied the effects of shelterwood silvicultural system in white pine 

stands and single-tree selection silvicultural system in hardwood stands. The harvest systems studies 

seemed to have little effect on southern flying squirrels or eastern chipmunks as densities were higher in 

the cut sites than the non-cut sites. In pine sites, northern flying squirrels and red squirrels had lower 

densities in the recent cut stands. There was no analysis performed for northern flying squirrels or red 

squirrels in the hardwood stands due to low capture rates. The study concluded that there is a link 

between high densities of northern flying squirrels and forests that are not treated. Recommendations 

were to retain more large spruce and hardwood trees to mitigate impacts of shelterwood harvesting on 

northern flying squirrels and red squirrels. Spruce is associated with a fungus found in the Appalachians 

that is associated with fungi eaten by squirrels. 

The EDLV project does not treat hardwood stands nor are there hardwood stands similar to the ones 

studies in this research present in the project area. Additionally, the EDLV project does not propose a 

shelterwood silvicultural system in the pine stands proposed for treatment. Because stand characteristics 

and treatment types are drastically different than the study, a direct relationship between the results of 

this study and the EDLV project are not possible. The recommendation to retain large spruce trees 

however is consistent with the design of the EDLV as the largest trees will remain in all treatment types. 

The applicable information in this piece of literature is consistent with the design of the EDLV and there 

was no additional information presented that is applicable to this type of project in the forest types 

present. 

25. Hutto, R. 1995. USFS Northern Region songbird monitoring program: distribution and habitat 

relationships. USFS Contract #R1-95-05, Second Report. 

Only certain pages of this document were provided. Pages provided were one page each on the Rubycrowned Kinglet, the solitary vireo and the Cassin’s finch. These pages displayed distribution and habitat 

use and management considerations. The Ruby-crowned Kinglet is widely distributed throughout the 

middle portion of the region within conifer forest cover types. Despite its widespread occurrence across 

most conifer types, including harvested types, the report noted that the species shows a decrease in 

abundance with increasing amounts of timber removed. The solitary vireo is widespread throughout the 

westernmost portions of the region and is restricted to coniferous forest cover types and is not uncommon 

in harvested forest types. The solitary vireo is common in moderately cut forests however its occurrence 

decreases with increasing levels of tree removal. To the researcher this suggested that there is some 

implication that there is some degree of dependence on the retention of some older, relatively uncut 

conifer forests. The stellar’s jay is a bird of the westernmost portion of the region and occurs primarily in 

higher elevation spruce-fir forests. It is common in a variety of harvested forest types. The species was 

abundant in harvested forests, but the researcher suspected that nesting activity was limited and the 

species frequented these areas for other reasons. Recommendation was to study nest success in cut 

forests.

This report was utilized and cited in the EDLV analysis. The ruby-crowned kinglet and the Steller’s jay 

are considered S5 species in Montana, which is common, widespread and abundant. These species were 

not analyzed in detail in the EDLV as there are not considered birds of conservation concern and it 

appears that the actions proposed in the EDLV project are not documented risks for the species. The 

50
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

Cassin’s finch is considered an S3 in Montana which is potentially at risk due to limited or declining 

numbers and is a bird of conservation concern analyzed in detail in the EDLV analysis. Cassin’s Finches 

are one of the more abundant birds in early postfire conifer forests, where their numbers can increase 

significantly regardless of fire severity. They also are attracted to harvested forests and stands where 

postfire salvage logging has occurred. The Cassin’s finch seems to prefer harvested areas therefore there 

is no reason to believe that the project as proposed would impact the Cassin’s finch. The information 

presented in the above literature is based on presence/absence data and is not meant to predict the cause 

of the patterns observed. Additionally, there are numerous acres in the EDLV project area that would 

remain unharvested, if these were species that relied on unharvested habitats for survival (which is not 

definitive in this report). 

26. Montana Natural Heritage Program and Montana Fish, Wildlife and Parks. 2009. Montana 

Animal Species of Concern. 

This document provided was a 2 page list of bird species of concern. The report is a list of species that are 

considered ‘at risk’ due to declining population trends, threats to their habitats and or restricted 

distribution. 

The bird species of concern associated with conifer or mixed conifer forest habitats (ones present and 

proposed for timber treatment in EDLV project area) are the brown creeper, the Cassin’s finch, the 

Clark’s nutcracker, flammulated owl, great gray owl, northern goshawk, pileated woodpecker and the 

winter wren. All species except the winter wren and brown creeper were analyzed in detail in the EDLV 

analysis. The winter wren is currently considered by the Montana Natural Heritage Program (2015) an 

SNA, not an S3. An SNA is: A conservation status rank is not applicable because the species or ecosystem 

is not a suitable target for conservation activities as a result of being: 1) not confidently present in the 

state; 2) exotic or introduced; 3) a long distance migrant with accidental or irregular stopovers; or 4) a 

hybrid without conservation value. The brown creeper is more common in mature western redcedarwestern hemlock, spruce-fir, and mixed-conifer forests than in pine or younger forests in western 

Montana and Idaho. They winter in the same habitats used for breeding but also use a wider diversity of 

forest types, including uplands dominated by deciduous trees, urban and suburban parks and residential 

areas that contain large trees, and riparian cottonwoods. The consistent factor appears to be the need for 

large trees and snags (dead trees) for foraging and nesting microsites. Brown Creepers are the only 

North American birds that build their nests behind loose pieces of bark on tree trunks. They prefer to nest 

in large dead or dying trees within dense forest stands. Trees targeted for treatment in the EDLV are not 

large dead trees as a majority of the lodgepole proposed for salvage is small diameter and this species 

does not prefer to nest in pine stands. The largest Douglas-fir trees within treatment units will remain, 

therefore impacts to the brown creeper are considered unlikely. Concern for this species results from its 

strong association with unlogged old-growth forest, especially stands of cedar-hemlock, which are 

uncommon in Montana and are highly productive for timber. This type of habitat is not present in the 

EDLV project area or proposed for treatment. Additionally, old growth characteristics would be retained 

where present in the EDLV project area, minimizing potential adverse effects. Other bird species of 

concern associated with sagebrush habitats (also proposed for treatment in the EDLV project) are the 

brewer’s sparrow, greater sage-grouse, sage thrasher, sage sparrow. These species were also analyzed in 

the migratory birds section of the EDLV analysis. The grassland associated species in the table are not 

not suspected in the EDLV analysis area as the habitat available is not a true grassland habitat. There is 

no information present in this document that is inconsistent with the EDLV analysis. 

51
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

27. Johnson, S. 1988. Old growth/forest plan monitoring project. Gallatin National Forest, 

Bozeman, Montana. Unpublished.

This report was written by the objector in 1988 while working on the Gallatin National Forest on an old 

growth/Forest Plan monitoring project. The project was designed because of concerns the author had 

about old growth management on the Gallatin National Forest in 1988. During this time on the GNF, 

there were no GNF Plan monitoring guidelines for wildlife. The study took place in one summer in 

harvest units associated with the funding of the past timber sale in the Bridger Mountains of the GNF and 

the author conducted bird counts to complete a bird species list and estimate density of breeding birds.

The information presented in this report is a summary of one survey of information. Due to the fact that it 

was not peer reviewed, is opinion based, and not similar to the habitats and treatment types proposed in 

the EDLV project; there is no apparent information that is applicable to the EDLV analysis. Old growth 

and snag management on the BDNF is based on best available information specifically for the BDNF and 

habitats found on the BDNF. The EDLV project is in compliance with all wildlife standards, snag 

standards and old growth standards in the 2009 BDNF Forest Plan.

28. La Sorte, R., R. Mannan, R. Reylonds and T. Grubb. 2004. Habitat associations of sympatric 

red-tailed hawks and northern goshawks in the Kaibab Plateau. Journal of Wildlife Management 

68:298-308.

Not all pages of this piece of literature were provided. Of the pages provided, only the abstract, discussion 

and management implication sections were included. The abstract stated that habitat association of redtailed hawks and northern goshawks at 2 spatial scales were studied. At both scales, red-tailed hawk 

associations were more variable than goshawk associations. At fine scales, goshwaks were associated 

with open understories, tall trees and gentle slopes while red-tailed hawks were associated with steep 

north facing slopes and dense understories. Forest fragmentation was greater around red-tailed hawk 

nests. Management recommendations from this study were to retain goshawk breeding habitat within the 

goshawks range of association because if goshawk habitat is altered beyond the association found in the 

study, it could turn into red-tailed hawk habitat. 

Impacts to the Northern Goshawk were analyzed in the EDLV analysis. The analysis that based on recent 

broad-scale habitat and inventory and monitoring assessments conducted in the Northern Region, found 

that breeding goshawks and associated habitats appear widely distributed and relatively abundant on 

NFS lands (USDA Forest Service 2009) and on the BDNF. Habitat through time was predicted to 

increase across the BDNF therefore is not a limiting factor for goshawks. The information presented in 

this literature is consistent with the information presented in the EDLV analysis. 

29. McCallum, A. 1994. Flammulated owl (Otus flammeolus). In Birds of North America No. 93. A 

Poole and F. Gill, Eds. The Academy of Natural Sciences; Washington, D.C.: The American 

Ornithologists Union.

Pages 1, 9, 13, 15 and 18 of this document were provided. The pages provided included excerpts on 

range, breeding biology, effects of human activity and management. The effects of human activity 

included loss of snag habitat by cutting dead trees for firewood and impacts to the woodpecker population 

which create cavities for flammulated owls. Insecticides and change in forest structure were also noted as 

things that may change the insect community and impact owls. The biggest threat to the species is 

destruction of forests in its winter range (Mexico). Intensive management of forests was documented as 

compatible as long as old growth aspects were provided (nest sites, roost sites, foraging substrate). 

52
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

The information presented in this document is consistent with the flammulated owl analysis in EDLV. 

Destruction of flammulated owl habitat in winter range is not impacted by the EDLV project.

30. McClelland, B., and P McClelland. 1999. Pileated woodpecker nest and roost trees in Montana: 

links with old-growth and forest ‘health.’ Wildlife Society Bulletin 27:846-857.

This article documents characteristics of nest and roost trees of pileated woodpeckers from 1973-1995 in 

northwestern Montana in western larch/Douglas-fir forests. Nest tree dbh was 73 cm (~29 inches) and 

were typically snags with broken tops. Old-growth stands with western larch were common nesting sites. 

Old growth ponderosa pine, black cottonwood and trembling aspen were also important. Researchers 

suggested that the optimum tree size for pileated woodpecker nest and roost sites be greater than 75 cm 

for western larch, ponderosa pine and black cottonwood. The importance of decay in woodpecker trees is 

important and because larch are such long lived trees (maximum >900 years) old larch may survive fires 

over centuries providing nest and roost sites. Dead and decaying trees are essential components for the 

long-term presence of pileated woodpeckers in western larch forests. 

The project area in EDLV is not a western larch forest as what is described in this literature. Pileated 

woodpeckers were document in the project area and are analyzed in detail in the EDLV analysis. The 

information presented in the EDLV analysis is consistent with the applicable information presented in 

this literature; however a majority of the information is in forest types not represented in the project area. 

Old growth characteristics and/or old growth would not be impacted in the EDLV project which is 

consistent with the information in this analysis that large older trees are important to this species. 

However, western larch is not present in the analysis area and therefore all of the information specific to 

western larch forests is not applicable to this area (forest habitat type is not similar).

31. Montana Partners in Flight. 2000. Montana bird conservation plan. Version 1.0 January 2000, 

Unpublished.

The pages of this document provided were 30, 105-106, and 145-146. One page of this document detailed 

a Priority bird species list for the state of Montana with Priority 1, 2, and 3 level species. It was unclear if 

the entire list was on the page provided. The next pages of the document provided (105-106) detailed 

ecology information on the red crossbill, management recommendations and habitat and population 

objectives for the ‘dry forest’ type. Management recommendations for the red crossbill were to maintain 

some element of Douglas-fir and emphasize seed production in conifers for silvicultural treatments. The 

habitat objectives for dry forest included managing for minimum old-growth characteristics according to 

Green et al. 1992, retain all current old growth stands, do not eliminate large trees or snags, maintain 

(long-term) 25% of the dry forest habitat per 4th watershed as old growth, restore the role of fire and use 

thinning as necessary, retain all snags and broken trees greater than 9” dbh, manage for single and double 

storied stands with open conditions and manage for a variety of habitat conditions with varied 

understories. On pages 145-146, habitat requirements for the Townsend’s warbler were listed as well as 

management issues and habitat objectives for moist Douglas-fir and Grand-fir habitat types. Townsend’s 

warblers are associated with old growth forests in wet forests and are sensitive to timber harvest. 

Objectives for management of Moist Douglas-fir and Grand-fir habitats are to maintain old growth, target 

dense young and mature stands for forest health treatments to reduce fire risk, encourage snag retention of 

at least 8 snags/ha and 100 logs/ha, and retain from cutting insect-killed trees within 20% of lands 

managed for old growth, produce a diversity of stand structure in timber harvests and vary timber harvest 

methods using even-aged prescriptions in areas that would have had stand replacement fires.

The EDLV project retains all old growth characteristics in the proposed units following Green et al. 

1992. The proposed project retains snags and downed wood following direction in our Forest Plan. 

Townsend’s warblers and red crossbills are not analyzed in detail as they are considered common, 

53
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

widespread, and abundant (although it may be rare in parts of its range), not vulnerable in most of their 

range in Montana. The EDLV considers all of the aspects addressed in these pages of the document and 

the information presented in the EDLV is consistent with information. There is no additional information 

presented that would change the analysis as old growth is avoided and maintained where present 

throughout the EDLV analysis area. 

32. Pfister, R., B. Kovalchik, S. Arno, and R. PResby. 1977. Forest habitat types of Montana. USDA 

Forest Service General Technical Report INT 34

This document was utilized and referenced in the EDLV analysis where applicable.

33. Reynolds, R., R. Graham, M. Reiser, R. Bassett, P. Kennedy, D. Boyce, G. Goodwin, R. Smith 

and E. Fisher. 1992. Management recommendations for the northern goshawk in the southwestern 

United States. USDA Forest Service General Technical Report RM-217

This document was utilized and referenced in the EDLV analysis where applicable.

33. Saab, V., and M. Dresser. 2012. Habitat characteristics at woodpecker nest locations and at 

non-nest random locations in the Elkhorn Mountains, Helena National Forest before (2002-2006) 

and after a mountain pine beetle epidemic outbreak (2009-2011). Progress report submitted to the 

Helena National Forest Unpublished.

This document provided did not have page numbers. The 4 pages provided included the intro, a methods 

paragraph, preliminary results and a partial paragraph in the discussion section. The intro stated that the 

report summarizes habitat characteristics measured at woodpecker nest locations before and after a 

mountain pine beetle epidemic and compared it to non-nest locations. Results from the study showed a 

reduction in live trees after the beetle epidemic and that woodpeckers before the outbreak selected 

locations with higher snag densities than random. Post-outbreak, snag densities at nests were variable 

compared to random locations. Snag densities at three-toed woodpecker sites were higher than random. 

Ponderosa pine was the dominant tree species in the study and aspen was rare on the landscape but was 

favored before the outbreak. Some species favored aspen as nesting substrate. 

Aspen is targeted for restoration and enhancement in the EDLV analysis area, not removal. The aspen 

units as designed would maintain these clones on the landscape, which would benefit all species that 

utilized aspen, including woodpeckers. The EDLV is consistent with the information in this report as 

snags were analyzed in detail and impacts to woodpeckers were considered. 

34. Sherburne, S., and J. Bissonette. 1994. Marten subnivean access point use: response to 

subnivean prey levels. Journal of Wildlife Management 58:400-405.

Researchers used prey biomass and percent ground cover of coarse woody debris (CWD) to develop a 

predictive model of marten use of subnivean access holes in Yellowstone National Park. Prey biomass 

yielded the best predictive model of marten use. As CWD increased by 5%, the probability of marten 

using the access point increased. The study concluded that marten chose between different access points 

primarily on the basis of prey abundance levels. CWD enables marten to forage effectively in the winter 

so the researchers stated that older growth forests with accumulated CWD provide the forest floor 

structure necessary for marten foraging. 

The literature suggests that cutting old forest and replacing it with newer forest would cause a loss of 

marten habitat. The EDLV project follows Forest Plan standards for woody debris to ensure that this 

material is left in sufficient amounts post-harvest. The literature suggests that cutting old forest and 

54
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

replacing it with newer forest would cause a loss of marten habitat. The EDLV project does not propose 

converting older forests to younger forests and maintains woody debris, which is consistent with the 

information in this document. Additionally, marten are ranked G5 (common, widespread and abundant 

locally) and S4 (populations apparently secure in the state) by the Montana Natural Heritage Program. 

They are not on the State’s Species of Concern list and are not considered to be at risk.

35. Smith, C. and S. Aldous. 1947. The influence of mammals and birds in the retarding artificial 

and natural reseeding of coniferous forests in the United States. Journal of Forestry 45:361-369

Only 2 pages of this document were provided (pp. 362-362). The first page of the document outlines the 

methods used for reforestation on deforested lands and the factors that prevent reforestation (seed source, 

soil type, soil condition, prevalence of disease, moisture, temperature, slope and many others including 

animals. The authors stated the purpose of the paper was to point out the degree and type of pressure 

exerted by birds and mammals on forest seeds, tree species affected and to describe the methods for 

reducing or eliminating the losses. The next page that was provided was a list of birds and mammals by 

common and scientific name title ‘List of Birds and Mammals known to eat the seeds of coniferous trees.’

Impacts to conifer seeds from the EDLV project proposal was analyzed in the DEIS and the FEIS as well 

as species that utilize these seeds. Because the largest trees in the analysis area would remain, and these 

trees are the ones that typically produce consistently and produce the most cones, impacts to conifer seed 

production (and therefore impacts to the wildlife that utilize the seeds) would be minimal.

36. Smith, C., and R. Balda. 1979. Competition among insects, birds and mammals for conifer 

seeds. American Zoologist 19:1065-1083.

Only 4 pages of this document were provided. The first page of text was mostly covered by a sticky note 

that was photocopied making a majority of the first page unreadable. The synopsis (abstract) of the 

document stated that there are multiple species that exploit the cones and seeds of most species of 

conifers with the exception of lodgepole pine in that only squirrels and bugs attack its serotinous cones. 

The 3 other pages provided included a table of tree species and the source of seed units, the number of 

seeds and range. The other pages were a list of species and how they utilize seeds. It is unclear if the tree 

table was a partial or incomplete table. 

Impacts to conifer seeds from the EDLV project proposal was analyzed in the DEIS and the FEIS as well 

as species that utilize these seeds. Because the largest trees in the analysis area would remain, and these 

trees are the ones that typically produce consistently and produce the most cones, impacts to conifer seed 

production (and therefore impacts to the wildlife that utilize the seeds) would be minimal.

37. Squires, J., N. DeCesare, J. Kolbe, and L. Ruggerio. 2010. Seasonal resource selection of 

Canada lynx in managed forests of the Northern Rocky Mountains. Journal of Wildlife 

Management 74:1648-1660

Researchers investigated seasonal patterns in resource selection of Canada lynx from 1998-2002. During 

the winter, lynx foraged in mature, multilayer forests with Engelmann spruce and subalpine fir in the 

overstory and understory, with larger diameter trees with higher horizontal cover, more abundant 

snowshoe hares and deeper snow than random locations. During the summer, lynx broadened their 

selection to use younger forests with high horizontal cover, abundant shrubs, and abundant small diameter 

trees. Lynx avoided recent clear cuts and other open patches. Management recommendations were that 

managers should retain a habitat mosaic of patches of mature, multilayer spruce-fir forests and younger 

forest stands as reducing horizontal cover (as with precommercial thinning) degrades lynx habitat.

55
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

This article was utilized and considered in the EDLV analysis and the analysis is consistent with the 

information presented in this study. 

38. Thomas, J. 1979. Wildlife habitats in managed forests of the Blue Mountains of Oregon and 

Washington. U.S. Department of Agriculture Forest Service Handbook No. 553. September 1979.

Only pages 150 and 155 of this document were provided. Page 150 included Table 33: Hard snag 

requirements for woodpeckers in the ponderosa pine community and Table 34: Snags required per hectare 

by dbh class to meet the needs of woodpeckers at various population levels in the ponderosa pine 

community. Page 155 gives an example and titled ‘Providing Old-growth Habitat.’ It is unclear the 

context of the example or the conclusion as the example is not provided. A list of items considered that 

‘must be provided’ were 1) plant community or timber type 3)definition of old growth 4) percent of 

commercial forest maintain in old growth 5) size of planning area and 5) availability of areas reserved 

from cutting. 

It is unclear the how this information is applicable to the EDLV analysis. Ponderosa pine forest 

communities are not present in the EDLV project area and the information on snag habitat for 

woodpeckers in Region 1 was used as best available science (not woodpecker needs in Oregon). The old 

growth definition in EDLV is based on the site specific habitats present on the BDNF and specific to 

Montana which is more applicable than the information presented in this document on Oregon forest 

types. 

39. Tomback, D. and K. Kramer. 1980. Limber pine seed harvest by Clark’s nutcracker in the 

Sierra Nevada: timing and foraging behavior. The Condor 82:467-468

This article documented three days in September 1979 where Clark’s nutcrackers were observed. The 

birds foraged on whitebark pine and limber pine in the Sierra Nevada Mountains. As whitebark pine 

cones were depleted of their seeds and limber pine cones start to open, the bird shifted to limber pine 

seeds as they were easier to obtain at this time during this year. It was not clear if this is a typical pattern 

for this bird or a result of a good limber pine cone crop year. 

The EDLV DEIS and FEIS both acknowledged the Clarks nutcrackers preferred foraging species in 

Montana is whitebark pine. There are no limber pine present in the EDLV analysis area and the habitat 

available in the EDLV analysis area is not similar to the Sierra Nevada Mountains. Impacts to whitebark 

pine would be minimized in the design features of both action alternatives and is not targeted for 

treatment. 

40. USDA. 2002. Science Findings: sex and the single squirrel: a genetic view of forest management 

in the Pacific Northwest. Author S. Duncan. Pacific Northwest Research Station, February 2003.

This article documents the northern flying squirrel in the Pacific Northwest and how in highly fragmented 

forests in the Pacific Northwest had lower genetic variation than populations with relatively continuous 

forests with fewer barriers to movement (large open spaces). Sharp population declines were noted after 

variable density thinning however high landscape permeability produced rapid gene flow and quick 

recovery after management disturbance. Flying squirrels are dependent on trees for major travel and 

dispersal and large clear cuts in the Pacific Northwest produce barriers to movement however small, 

unpaved roads do not inhibit flying squirrel movement. 

Fragmentation impacts were analyzed in the EDLV and large clear cuts like in the Pacific Northwest are 

not similar to the activities proposed in the EDLV project. The article does not define the size of an 

opening or clear cut that creates barriers to flying squirrels and the EDLV project is not proposing clear 

56
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

cuts. Openings from dead and dying lodgepole pine are already present from existing beetle kill and 

snags and live trees would be left in treatment units to meet Forest Plan snag standards. Because there

are no specific criteria to apply to EDLV, there is no information presented in this document that 

conflicts with the information in the EDLV analysis. Additionally, the northern flying squirrel in Montana 

is considered secure at the state level and is not a species of concern.

41. USDA. 2014. Martens, sables and fishers: new synthesis informs management and conservation. 

Science Findings: Pacific Northwest Research Station, April 2014.

Pages 1, 4 and 5 of this document were provided. Page 1 includes the summary which discusses a new 

synthesis that includes 20 chapters from 63 scientists on the evolution, population biology, management 

habitat ecology, research techniques and conservation of these species. Page 4 documents the 

differentiation between the American Marten and the Pacific Marten and the fisher translocation effort 

that was conducted throughout the years. The two variables for successful reintroductions were the 

number of females release and the number of release sites used. Page 5 included 2 paragraphs on climate 

change noting that martens and fishers are highly sensitive to climate change and because fishers prefer 

lower elevations with low or no snowfall, their habitat will likely increase. Martens on the other hand will 

see their range shrink if current trends in global warming continue. 

Climate change was discussed in EDLV. There are numerous sources of uncertainty when trying to 

predict the effect of climate change. The environmental analysis did not attempt to predict the effects of 

climate change on wildlife habitat or species. The fisher was analyzed in detail in the EDLV analysis and 

the information presented in the analysis is consistent with the fisher information in this document. 

Marten are ranked G5 (common, widespread and abundant locally) and S4 (populations apparently 

secure in the state) by the Montana Natural Heritage Program. They are not on the State’s Species of 

Concern list and are not considered to be at risk. The Forest Plan ensures viability for wildlife, including 

marten, through application of the Forest-wide goals, objectives and standards. Forest Plan direction 

ensures management of a variety of habitats in various successional stages so as to ensure the viability of 

a variety of species associated with those different habitats. There is no addition specific information on 

the marten in this document that is inconsistent with the EDLV analysis. 

42. Vander Wall, S. B., S. Hoffman and W. K. Potts. 1981. Emigration Behavior of Clark’s 

Nutcracker. Condor 83:162-170

Only pages 162, 167 and 169 were provided. Page 162 contained the abstract which stated that 

movements of the Clark’s nutcracker were observed in northern Utah in 1977-1979. Eruptive movements 

began in mid to late August and continued until October. Page 167 describes the breeding of nutcrackers 

in pinyon-juniper woodlands in Utah and that this species may breed in its wintering grounds. 

Furthermore page 167 discussed nutcracker use on a limber pine/Douglas-fir habitat in Utah and a pinyon 

pine/limber pine/Douglas-fir forest. Nutcrackers were more efficient at foraging on pinyon pine than 

Douglas-fir. This may attract nutcrackers to settle in pinyon-juniper woodlands and not Douglas-fir 

forests. The last page details that nutcrackers will move in the winter in Utah depending on access to food 

sources. 

Impacts to Clark’s nutcracker as it relates to whitebark pine and availability of conifer seeds were 

discussed in the EDLV analysis. Pinyon-juniper woodlands similar to this research are not present in the 

analysis area and are not the preferred foraging species for Clark’s nutcracker in Montana. 

57
East Deerlodge Valley Landscape Restoration Management Project March 2015 Record of Decision

43. Wright, V. 1996. Multi-scale analysis of flammulated owl habitat use: owl distribution, habitat 

management and conservation. MS Thesis, University of Montana. 

One page of text was provided. The page provided discussed that densities of prey in grasslands are great 

than in forests and forests with open canopies have greater availability than continuous forests. Forests 

with dense understories probably contain less prey. AS food availability decreases, flammulated owls 

may increase territory size. Management activities that eliminate all understory Douglas-fir may remove 

thickets important for roosting and singing, drop-pouncing foraging perches and predator cover.

Flammulated owls in eastern Oregon predominantly roosted in dense stands with over 50% canopy cover. 

Information provided in this document was very limited and difficult to understand context. The 

information referenced above is consistent with the EDLV analysis on flammulated owls. The EDLV 

project does not include any activities that would eliminate all understory Douglas-fir. Related research 

from Wright (1996) that was published and peer reviewed was also referenced and utilized in the EDLV 

analysis.

58