Lower West Fork Project

Record of Decision

Bitterroot National Forest

West Fork Ranger District

Ravalli County, MT

July 2010

Responsible Agency: USDA Forest Service

Responsible Official: Julie K. King

Forest Supervisor

1801 No. First

Hamilton, MT 59840-3114

For Further Information Contact: David M. Campbell

West Fork District Ranger

6735 West Fork Road

Darby, MT 59829

(406) 821-1211

Project Area Location: T2N R21W Sections 27-36, T1N R20W 

Sections 6-8, 17-20, 29-32, T1N R21W 

Sections 1-30, 34-36, T1N R22W 

Sections 1, 12-15, 23-26, and T1S R21W 

Sections 1-4, 10-12, 14-16, 21, 22 PMM, 

Ravalli County, Montana. 
Record of Decision

Lower West Fork Project ROD - 3

TABLE OF CONTENTS

1.1 DECISION OVERVIEW ........................................................................................................................................5

2.1 BACKGROUND...................................................................................................................................................5

3.1 PURPOSE AND NEED .........................................................................................................................................7

4.1 DECISION...........................................................................................................................................................8

5.1 ALTERNATIVES CONSIDERED ...........................................................................................................................17

5.1.1 ALTERNATIVE 1..............................................................................................................................................17

5.1.2 ALTERNATIVE 2..............................................................................................................................................17

5.1.3 ALTERNATIVE 3..............................................................................................................................................18

5.2 ALTERNATIVES CONSIDERED BUT ELIMINATED (FEIS PP. 2-17) .......................................................................18

6.1 RATIONALE FOR MY DECISION.........................................................................................................................20

7.1 PUBLIC INVOLVEMENT .....................................................................................................................................25

8.1 FINDINGS RELATED TO OTHER LAWS AND REGULATIONS ...............................................................................26

9.1 APPEAL PROVISIONS ........................................................................................................................................30

10.1 IMPLEMENTATION ........................................................................................................................................31

11.1 FURTHER INFORMATION AND CONTACT PERSON..........................................................................................31

LIST OF REFERENCES CITED IN THIS DECISION.........................................................................................................32

TABLE 1: UNIT TREATMENTS UNDER ALTERNATIVE 3-MODIFIED.............................................................................9

TABLE 2: STORED OR DECOMMISSIONED ROADS UNDER ALTERNATIVE 3-MODIFIED............................................15

TABLE 3: MANDATORY STEWARDSHIP ROAD TREATMENTS UNDER ALTERNATIVE 3-MODIFIED............................16

TABLE 4: SUMMARY OF ACTIVITIES FOR ALTERNATIVE 3-MODIFIED......................................................................16

TABLE 5: COMPARISON OF ACTIVITIES BY ALTERNATIVE ........................................................................................17

TABLE 6: COMPARISON OF MEASURES TO MEET THE PURPOSE AND NEED OF THE LOWER WEST FORK PROJECT..21

FIGURE 1: LOWER WEST FORK PROJECT AREA AND VICINITY MAP SHOWING THE WILDLAND URBAN INTERFACE 

BOUNDARY...............................................................................................................................................................4

FIGURE 2: LOWER WEST FORK PROJECT SELECTED ALTERNATIVE - TREATMENT AREAS ON THE WEST SIDE OF THE 

WEST FORK RIVER...................................................................................................................................................11

FIGURE 3: LOWER WEST FORK PROJECT SELECTED ALTERNATIVE - TREATMENT AREAS ON THE EAST SIDE OF THE 

WEST FORK RIVER...................................................................................................................................................13

APPENDIX A – MITIGATION MEASURES
Record of Decision 

ROD - 4 Lower West Fork Project

Figure 1: Lower West Fork Project Area and Vicinity Map showing the Wildland Urban Interface 

Boundary
Record of Decision

Lower West Fork Project ROD - 5

RECORD OF DECISION

LOWER WEST FORK PROJECT

USDA Forest Service

West Fork Ranger District, Bitterroot National Forest

Ravalli County, Montana

1.1 DECISION OVERVIEW

After thorough review of the Lower West Fork Project Final Environmental Impact Statement (FEIS) and 

public comments received throughout the analysis process, I have decided to modify and select Alternative

3. I modified Alternative 3 by adding the following features from Alternative 2: 

Ø commercially thin Unit 60 on the west side of the West Fork of the Bitterroot River (West Fork 

River)

Ø retain the option to treat potential noxious weed spread with herbicides 

Ø treat the prescribed fire units in the Wildland Urban Interface (WUI) on the east side of the West

Fork River 

Ø decommission National Forest System Road (NFSR) 13841 from its junction with NFSR 74327

and decommission NFSR 13424 from its junction with NFSR 13425

I believe my decision is the best balance between enhancing forest conditions and reducing the potentially

negative effects of forest management. My decision will reduce the risk of crown fire in the WUI, and 

stream sedimentation, and improve forest resiliency, fish population connectivity, and soil productivity.

The potentially negative effects of the activities required to achieve these objectives will be eliminated or 

reduced through project design and the application of Best Management Practices (BMPs). This Record of 

Decision (ROD) explains the rationale for my decision. 

The ROD is organized as follows:

Ø Background information about the proposal and the purpose and need for the project

Ø Description of the activities approved in the modified Alternative 3

Ø Criteria and rationale I considered in selecting this alternative

Ø Description of the public involvement process

Ø Consistency findings with applicable laws and policies

Ø Project implementation and contact information

This document and my decision are based on and reference the analysis in the Lower West Fork Project 

FEIS and Draft EIS (DEIS), and information in the project file. 

2.1 BACKGROUND 

The Lower West Fork analysis area is located about 15 air miles southwest of Darby, Montana (Fig. 1). 

National Forest System land makes up most of the analysis area though about 3,400 acres of private land 

exist along the West Fork River. The Selway-Bitterroot Wilderness borders the analysis area to the west 

and Shook Mountain and Medicine Point lookout mark the border to the east.

The goal of this project is to expand fire management options beyond suppression in the event of an 

ignition by decreasing stand density and fuel loads. The intent is to re-establish fire as a natural process at 

the intensities and frequencies that shaped this landscape. Managing fuel loads and stand density using 

timber harvest, non-commercial thinning, prescribed fire, and natural ignitions would reduce fire intensity 

at the Bitterroot National Forest boundary.

I have decided to treat this area because:
Record of Decision 

ROD - 6 Lower West Fork Project

Ø The Forest Plan directs the use of prescribed fire to maintain healthy, dynamic ecosystems that 

meet land management objectives and to emphasize fire ecology implications in its application 

(Forest Plan Appendix M).

Ø Management Area direction requires fire planning be designed to 

§ protect and enhance timber investments and values (Forest Plan pg. III-7)

§ protect and enhance winter range habitat (Forest Plan pg. III-13)

§ protect visual quality and minimize fire danger and insect and disease problems, and assure 

establishment and protection of stands (Forest Plan III-20, III-28, III-34, III-60)

§ perpetuate natural ecosystems (Forest Plan III-43)

Ø The Wildland Fire Risk Mitigation Plan identifies fuel reduction as a high priority (Community 

Wildfire Protection Plan; DNRC et al. 2006) (FEIS pg. 1-1).

§ Treating fuels in the WUI adjacent to the West Fork River moderates potential fire intensity 

adjacent to the private land boundary. Lower fire intensities will allow fire protection 

agencies more options to manage the fire, and protect the natural resources and private land 

developments. 

Ø The ponderosa pine/Douglas-fir forests are densely stocked, declining in resilience to 

environmental stressors, and shifting composition from ponderosa pine to Douglas-fir (FEIS 

pgs. 1-6, 3.2-8).

§ The trees left after thinning will be predominantly large ponderosa pine mixed with large 

Douglas-fir. These trees will have adequate growing space to restore their defense 

mechanisms and resist insect and disease infections. The larger trees also have thicker bark 

that is more resistant to fire. The spacing between trees will inhibit fire from transitioning 

to the crown and reduce the potential burning time adjacent to the tree bole. These 

conditions will improve tree survival in a fire. 

Ø High fuel loads and crown fire potential in the low elevation ponderosa pine/Douglas-fir forests 

limit fire management options (FEIS pgs.1-5, 3.3-11, 3.3-12).

§ Reducing fuels will allow more flexibility in the management of natural ignitions and

promote the natural role of fire in the ecosystem.

Ø The fuel treatments augment the area of fuels reduction created by the Frasier Interface project 

and the School Point Ecoburn and improve the management of fire behavior on the landscape 

scale.

Ø The project analysis area provides opportunities to evaluate soil, watershed, and fisheries 

projects that would reduce sedimentation in the West Fork River, which is listed as impaired 

(Montana Department of Environmental Quality (MDEQ 2008)) (FEIS pgs. 1-7, 3.5-6, 3.5-6, 

3.6-8, 3.6-9).

§ Storing and decommissioning roads no longer used for forest management, and 

rehabilitating disturbed soils will improve water infiltration to the soil and reduce runoff 

and sedimentation. Less sediment in the streams and more water stored in the soil will 

improve water quality and fish habitat. 

§ Removing fish barriers will improve the genetic mixing of fish populations and improve 

their resilience to environmental stressors. 

§ Rehabilitating soils in the terrace units and units with legacy soil compaction will augment 

the natural soil recovery process. 
Record of Decision

Lower West Fork Project ROD - 7

3.1 PURPOSE AND NEED

The purpose of the Lower West Fork project is to improve forest resilience to environmental stressors such 

as fire, insects, and disease and reduce fuel loads in and adjacent to the WUI. An additional purpose of this 

project is to reduce soil compaction on terrace units, and reduce sedimentation and fish barriers created by 

roads and road crossings.

The purpose of this project is not to prevent insects, disease, and fire from regulating forest conditions but 

to maintain forest conditions that support endemic populations and historic fire intervals and intensities. 

Forest conditions following treatments would be open stands of large, predominantly ponderosa pine trees 

with fuel loads appropriate to the site and fire interval. These stands would have less competitive stress and 

better resistance to insect and disease occurrences. The lighter fuel loads and wider spacing between trees 

would:

1. Reduce crown fire hazard in low elevation ponderosa pine/Douglas-fir forests

2. Improve forest resilience to natural disturbances, particularly the resilience of large diameter 

ponderosa pine trees 

3. Maintain or increase shade intolerant species, specifically ponderosa pine

Soil compaction would be reduced on terrace units, historic skid trails in Units 3 and 12, and in the portion 

of Unit 1 where detrimental soil disturbance exceeds Regional soil quality standards (FEIS pgs. 3.5-5). 

Sedimentation in tributaries to the West Fork River would be reduced by storing and decommissioning 

roads, and fish passage would be restored by replacing culverts that block fish migration. These projects 

would improve the overall soil, watershed, and fisheries conditions and enhance the biological resilience in 

the Lower West Fork analysis area. 

The differences between current conditions and desired conditions and the effect of those conditions on 

ecosystem processes determined the need for the proposed actions in Lower West Fork analysis area. 

Ø Forest vegetation has shifted from open stands of primarily large ponderosa pine to more 

uniform and dense stands of Douglas-fir, especially in the understory, in the Lower West Fork 

area. These dense stands are more prone to intense wildland fires and insect or disease 

epidemics (Graham et al. 2004; USDA 2004, FEIS pgs.1-6, 3.2-10 to 3.2-17, 3.3-6 to 3.3-12).

Ø Forests in the Lower West Fork analysis area have departed from historic fire frequency 

intervals causing changes in vegetation structures, fuel loads, and fire severity. This means that 

fires could burn at higher intensities than is typical for these types of forests. The potential loss 

of forest ecosystem and private property components is higher because of these conditions 

(FEIS pgs. 3.3-6 to 3.3-12).

Ø The forest around the Lower West Fork WUI is a high priority treatment area based on values at 

risk and potential fire behavior (FEIS pg. 3.3-6). The Lower West Fork project would reduce 

fuel loads and modify areas of high-intensity, crown fire behavior to low or moderate intensity 

surface fire behavior (FEIS pg. 3.3-12).

Ø The Bitterroot Community Wildfire Protection Plan recommends restoration of fire-adapted 

ecosystems by restoring healthy, diverse, and resilient ecological systems to minimize fire 

severity in the priority areas. 

Ø The Rombo Fire burned over 1,400 acres of old growth forest in the Lower West Fork analysis 

area, which reduced old growth habitat by 33 percent (FEIS pg. 3.8-4). Reducing fire intensity 

in the analysis area protects remaining old growth habitat. 

Ø Roads contribute sediment to tributaries of the West Fork River, which is listed as impaired by 

sediment (MDEQ 2005) (FEIS pg. 3.6-2). Reducing sediment by storing and decommissioning 

roads no longer used for forest management would decrease sediment in the West Fork River

and its tributaries (FEIS pgs. 3.6-30 -3.6-32).
Record of Decision 

ROD - 8 Lower West Fork Project

Ø Seven culverts present barriers to westslope cutthroat trout migration (FEIS 3.7-29). Replacing 

or removing these barriers would reconnect westslope cutthroat trout access to about 3.4 miles 

of spawning and rearing habitat. The improved access would allow genetic mixing between 

strains of westslope cutthroat trout and improve their resilience to environmental stressors.

Ø Terrace units developed in the late 1960s created high levels of ground disturbance. The units 

have regenerated and formed dense stands of commercial-sized trees. Thinning these stands 

provides an opportunity to augment soil rehabilitation on the terrace benches by actively 

decompacting the soil and covering them with 10-15 tons/acre of woody debris. Active 

decompaction will only be feasible on units with slopes less than 35 percent. On steeper slopes, 

10 to 15 tons/acre of woody debris will be left on the terrace benches. The high levels of woody 

debris increase soil moisture, moderate soil temperatures, and increase soil microbe populations 

and functions. 

Changing these resource conditions to maintain the ecological parameters under which they developed will 

allow more management flexibility of natural disturbances, specifically fire, when they occur. The 

proposed actions would change the existing resource conditions so they are closer to the desired conditions. 

They would also complement and extend the area of fuels reduction treatments in the Frasier Interface 

project (designed by the Forest Consensus Council), the School Point Ecoburn, and similar actions taken on 

private land. The objective is not to attain a specific desired condition and remain static, rather to create 

conditions where natural processes can occur without severe ecological consequences or large capital 

investments.

Soil, watershed, and fishery resources have residual effects from road system development and past harvest 

practices. This analysis provides an opportunity to evaluate these situations in the context of the planned 

activities and improve these resource conditions. The Water Quality Restoration Plan and Total Maximum 

Daily Loads for the Bitterroot Headwaters Planning Area

4.1 DECISION

(Restoration Plan) (MDEQ 2005) listed the West 

Fork River as impaired by sediment. Though the Restoration Plan did not identify any of the streams in the 

Lower West Fork analysis area as restoration priorities, it recommends that sediment from roads be reduced 

in the West Fork River Watershed (MDEQ 2005 pg. 182). 

I have decided to select Alternative 3-modified to include the following features of Alternative 2: 

Ø Include Unit 60 on the west side of the river as a commercial thin unit

Ø Retain herbicide use as described in Alternative 2 as an option for treating new invasive plant

populations

Ø Treat prescribed fire units in the WUI on the east side of the river as proposed in Alternative 2 

Ø Decommission NFSR 13841 from its junction with NFSR 74327

Ø Decommission NFSR 13424 from its junction with NFSR 13425

Unit 60 was not analyzed for treatment under Alternative 3 because the purpose of the alternative was to 

reduce fuels in the WUI on the west side of the West Fork River and Unit 60 is not within the WUI. 

However, Unit 60 abuts the Trapper-Bunkhouse analysis area and the Trapper-Bunkhouse unit adjacent to 

Unit 60 is scheduled for commercial thin. Thinning the unit in Trapper-Bunkhouse and not Unit 60 in 

Lower West Fork would create an unnatural visual and ecological division in the same vegetation type. 

There are no detrimental effects associated with treating Unit 60 and not treating it would diminish the 

landscape benefits of treatment in both project areas. 

Herbicide use was not analyzed under Alternative 3 to display the difference between vegetation treatments 

with and without herbicide use to control the spread of invasive plants. The same parameters for herbicide 

use as described in Alternative 2 would be applied to Alternative 3. Since less area will be treated than in 

Alternative 2, the potential need to use herbicides will be less and therefore, the effects of herbicide use 

will be less than described in Alternative 2. 
Record of Decision

Lower West Fork Project ROD - 9

Though the headwaters of Piquett Creek and East Piquett Creek have burned in the past 10 years, there is 

still the potential for crown fire in the WUI on the east side of West Fork River. Prescribed fire in Units 

64, 65, 69, 71, 72, and 73 would reduce fuels adjacent to private land and provide options when managing 

fires. 

In Alternative 3, NFSR 13424 and 13841 were proposed for decommission from their junctions with NFSR 

5723 and 5724, respectively. After closer inspection, it is apparent that this action would close access to 

other road systems without removing the drainage structures. Furthermore, closing the other road systems 

was not analyzed in this process. My decision is to decommission NFSRs 13424 and 13841 from their 

junctions as stated above, which would reduce the total road decommission project by about one mile 

(about 0.5 mile less decommissioning on each road). Current management direction would be followed on 

the road sections not decommissioned. 

The above modifications were analyzed under Alternative 2 and their effects would not exceed the degree 

of effects analyzed in that Alternative.

My decision will reduce fuels on approximately 4,131 acres using commercial thinning, non-commercial 

thinning, and prescribed fire (Table 1). Approximately 88% of the treatments will occur in the WUI (Fig. 

1, 2). About 1,741 acres will be commercially thinned using ground-based and skyline yarding systems 

(Table 1). Commercial thins occur on parts of the commercial thin units, however the entire unit 

understory will be thinned (non-commercial thin) and excess slash will be treated using prescribed fire. 

Fuels will be reduced on another 1,658 acres using prescribed fire only. Another 296 acres in existing 

plantations will be non-commercially thinned. Approximately 1.8 miles of temporary road and 1.6 miles of 

tracked line machine (TLM) trail will be constructed to access timber. Individual road lengths vary 

between 1,200 and 2,100 feet. 

My decision includes the application of the design features and mitigation measures described in the FEIS 

and summarized in Chapter 2 (FEIS pgs. 2-18 – 2-25) and Appendix A of this Record of Decision. About 

18 miles of road will be stored and 26 miles decommissioned (Table 2, FEIS pg. 3.6-31, Table 3.6-13). 

Thirty-three culverts will be removed from road-stream crossings, 23 of which contribute sediment to 

streams. Storing or decommissioning 11.3 miles of road are mandatory to off-set potential short-term 

timber sale effects (Table 3, FEIS Table 2-4). This mitigation would remove 18 culverts, 12 of which 

contribute sediment to streams. The remaining roads will be decommissioned or stored using appropriated 

or partnership funds. Table 4 provides a summary of the treatments in Alternative 3, modified.

Table 1: Unit Treatments under Alternative 3-modified

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2 Trail 

(ft2) Ground Skyline TLM

1 Commercial Thin with underburn 239 239 64 26 31 1,246 404

2 Commercial Thin with underburn 197 197 76 104 0 N/A3 N/A

3 Commercial Thin with underburn 163 163 98 58 7 N/A 873

4 Commercial Thin with underburn 142 142 52 0 0 N/A N/A

5 Commercial Thin with underburn 35 35 12 21 0 N/A N/A

6 Commercial Thin with underburn 35 35 35 0 0 N/A N/A

7 Commercial Thin with underburn 25 25 0 19 10 N/A N/A

8 Commercial Thin with underburn 130 130 43 62 25 1,454 1,035

9 Commercial Thin with underburn 109 109 16 62 15 1,284 N/A

10 Commercial Thin with underburn 55 55 11 40 0 N/A N/A

11 Commercial Thin with underburn 33 33 30 3 0 N/A N/A

12 Commercial Thin with underburn 125 125 93 13 19 1,863 598

14 Commercial Thin with underburn 19 0 3 16 0 N/A N/A

21 Commercial Thin with underburn 18 0 0 18 0 N/A N/A

25 Commercial Thin with underburn 7 0 2 5 0 N/A N/A
Record of Decision 

ROD - 10 Lower West Fork Project

Unit 

No. Treatment* Area(acre)

WUI 

Area 

(acre)

Yarding Method (acre) Temp. 

Roads1

(ft)

TLM2 Trail 

(ft2) Ground Skyline TLM

27 Non-commercial Thin 4 0 0 N/A N/A N/A N/A

32 Prescribed Fire 131 131 N/A N/A N/A N/A N/A

33 Prescribed Fire 282 237 NA N/A N/A N/A N/A

34 Commercial Thin with underburn 119 119 43 0 0 N/A N/A

35 Commercial Thin with underburn 35 35 5 0 31 N/A 1,814

60 Commercial Thin with underburn 140 0 102 28 N/A 1,322 N/A

60A Prescribed Fire 31 0 N/A N/A N/A N/A N/A

61 Commercial Thin with underburn 418 418 131 145 8 2,112 1,812

61A Prescribed Fire 414 415 N/A N/A N/A N/A N/A

62 Commercial Thin with underburn 66 66 19 47 0 N/A N/A

63 Prescribed Fire 20 20 N/A N/A N/A N/A N/A

63B Prescribed Fire 32 32 N/A N/A N/A N/A N/A

64 Prescribed Fire 246 246 N/A N/A N/A N/A N/A

65 Prescribed Fire 40 28 N/A N/A N/A N/A N/A

69 Prescribed Fire 27 27 N/A N/A N/A N/A N/A

70 Prescribed Fire 199 199 N/A N/A N/A N/A N/A

71 Prescribed Fire 70 49 N/A N/A N/A N/A N/A

72 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

73 Prescribed Fire 2 2 N/A N/A N/A N/A N/A

74 Prescribed Fire 4 4 N/A N/A N/A N/A N/A

75 Non-commercial thin 20 0 N/A N/A N/A N/A N/A

80 Non-commercial thin 24 0 N/A N/A N/A N/A N/A

81 Commercial Thin with underburn 25 25 0 25 0 N/A N/A

82 Non-commercial thin 11 11 N/A N/A N/A N/A N/A

83 Non-commercial thin 14 14 N/A N/A N/A N/A N/A

84 Non-commercial thin 2 2 N/A N/A N/A N/A N/A

85 Non-commercial thin 15 15 N/A N/A N/A N/A N/A

86 Commercial thin 23 23 0 23 0 N/A N/A

87 Non-commercial thin 38 38 N/A N/A N/A N/A N/A

88 Commercial Thin with underburn 30 29 7 24 0 N/A N/A

89 Commercial Thin with underburn 61 0 0 51 10 N/A 1,046

90 Commercial Thin with underburn 38 0 3 36 0 N/A N/A

91 Non-commercial thin 28 28 N/A N/A N/A N/A N/A

92 Non-commercial thin 27 0 N/A N/A N/A N/A N/A

93 Non-commercial thin 12 0 N/A N/A N/A N/A N/A

94 Non-commercial thin 7 7 N/A N/A N/A N/A N/A

95 Non-commercial thin 43 43 N/A N/A N/A N/A N/A

96 Non-commercial thin 23 23 N/A N/A N/A N/A N/A

97 Non-commercial thin 4 4 N/A N/A N/A N/A N/A

98 Non-commercial thin 11 0 N/A N/A N/A N/A N/A

99 Commercial Thin with underburn 16 16 0 0 16 N/A 927

100 Prescribed Fire 30 30 N/A N/A N/A N/A N/A

101 Non-commercial thin 9 9 N/A N/A N/A N/A N/A

102 Non-commercial thin 4 0 N/A N/A N/A N/A N/A

TOTALS 4,131 3,637 743 826 172 9,281 8,509

Percentage 851 432 49 8 (1.8 mi) (1.6 mi) 1

Percentage of area treated

2

Percentage of harvest area


Record of Decision

Lower West Fork Project ROD - 15

Table 2: Stored or Decommissioned Roads under Alternative 3-modified

Road Number Milepost Description Culverts 

Removed

Contributing 

Culverts Removed

363, Piquet Cr. 5.1-6.8 Storage 0 0

363, West Fork near Baker Cr. 0.0-3.0 BMP Improvements 0 0

5724, Piquett 0.0-3.7 BMP Improvements 0 0

13411, East Piquett1 1.6-2.4 Storage 4 2

13411, East Piquett1 2.4-2.8 Decommission 1 0

13421, Piquett 0.0-0.6 Decommission 0 0

All Haul Routes Entire 

Length

Reshape and maintain drain dips; under 

contract and complete before contract closes

13422, Piquett 0.0-0.2 Decommission 0 0

13423, Piquett 0.0-1.7 Storage 1 0

13423, Piquett 1.7-1.9 Decommission 0 0

13424, Piquett1 0.2-3.1 Decommission 4 2

13430, Piquett 0.0-4.2 Decommission 1 1

13434, Piquett 0.0-2.7 Storage 1 1

13434, Piquett 2.1-2.7 Decommission 1 1

13456, East Piquett 0.4-1.6 Storage 0 0

13457, Near Baker1 0.0-1.8 Storage 0 0

13464, East Piquett 1.7-2.3 Decommission 0 0

13465, East Piquett 0.0-1.6 Decommission 1 1

13466, Pierce1 0.0-0.6 Storage 3 2

13828, Troy, Lavene 0.0-0.9 Storage 1 1

13829, Violet 0.0-3.6 BMP Improvements 0 0

13830, Violet1 0.0-1.6 Storage 2 2

13831, Violet1 0.0-1.3 Decommission 2 2

13832, Piquett 0.6-0.9 Decommission 0 0

13834, Piquett 0.0-0.6 Decommission 1 0

13836, East Piquett1 0.0-2.4 Decommission 2 2

13837 Repair sediment sources

13838, East Piquett 0.0-0.6 Decommission 1 1

13839, Piquett 0.6-0.8 Decommission 0 0

13840, Piquett 0.0-1.8 Decommission 1 0

13841, Piquett 0.0-1.2 Decommission 1 0

13842, Piquett 0.0-1.3 Decommission 1 1

13883, East Piquett 0.0-0.1 Storage 0 0

62416, Lavene 0.0-0.6 Storage 1 1

74006, Ward 0.0-1.2 Decommission 0 0

74023, Barn Draw 1.0-1.8 Decommission 1 1

74313, East Piquett 0.0-0.2 Decommission 1 1

74319, East Piquett 0.0-0.8 Storage 0 0

74320, East Piquett 0.0-0.2 Storage 0 0

74321, Piquett1 0.0-0.7 Decommission 1 1

74339, Castle 0.0-1.7 Storage 0 0

74347, Pierce 0.0-0.2 Decommission 0 0

74357, Christisen 0.0-0.3 Decommission 0 0

74605, Caste 0.0-1.4 Storage 0 0

74606, Castle 0.0-0.8 Storage 0 0

74611, Castle 0.0-0.1 Storage 0 0

Total culverts removed

Estimated Sediment Reduction (1.7tons*23)

33 232

39.1 ton less 1 Included in stewardship contract and completed prior to the contract closure. 2 BMP work assumed neutral
Record of Decision 

ROD - 16 Lower West Fork Project

Table 3: Mandatory Stewardship Road Treatments under Alternative 3-modified. 

The adaptive management protocol developed for the 65-acre portion of Unit 1 with detrimental soil 

disturbance will be applied. This protocol reduces ladder fuels, provides coarse woody debris, and 

increases crown spacing without the use of heavy equipment. Heavy equipment in this portion of Unit 1 

might increase soil compaction above Region 1 soil standards. Initially, the area will be thinned from 

below and the slash will be lopped and scattered to prevent beetle infestation. The slash will be left on the 

ground at least one year to allow nutrients to leach into the soil. The slash will be burned and the area resurveyed to assess residual coarse woody debris on the site. The coarse woody debris goal is 15-20 tons 

per acre. If residual coarse woody debris is below the required level, larger trees will be felled and left on 

site. The treatment emphasis will be to thin Douglas-fir and retain large ponderosa pine. Douglas-fir logs 

greater than 17 inches diameter and longer than six feet are preferred as coarse woody debris because 

Douglas-fir decays at a slower rate than ponderosa pine and stays on the soil surface longer. 

Thinning larger trees from the overstory increases crown spacing and coarse woody debris in larger 

diameter classes. Limbs and treetops may needed to be piled and burned if the fine fuel load is too high

following the last thinning entry. 

Table 4: Summary of Activities for Alternative 3-modified

Activity Acres (% of total area treated)

Total Number of Treatment Units 60

Treatments Area in WUI (acres) 3,639 (85%)

Proposed Treatments:

 Commercial Thin 2,303 (56%)

 Prescribed Burn 1,532 (37%)

 Small Tree Thin (Plantations) 296 (7%)

 Research 199 (5%)

Total Acres Treated 4,131

Yarding Systems:

 Skyline 998 (57%)

 Tractor 743 (43%)

Total Commercial Treatments 1,741

Temporary Road Construction (miles) 1.8

Tracked Line Machine (TLM) Trail (miles) 1.6

Roads to be decommissioned (miles) 26

Mandatory Roads to be decommissioned 11.3

Estimated Timber Harvest Volume (thousand cubic feet, CCF) 11,700 (5.4 mmbf1) 1 mmbf = million board feet

Road Number Watershed Treatment Length (miles)

13411 East Piquett Storage 0.8

13411 East Piquett Decommission 0.4

13421 Piquett Decommission 0.7

13424 Piquett Decommission 2.4

13457 East Piquett Storage 1.8

13466 Pierce Storage 0.6

13830 Violet Storage 1.6

13831 Violet Decommission 1.3

13836 East Piquett Decommission 2.4

13837 Piquett Repair sediment sources N/A
Record of Decision

Lower West Fork Project ROD - 17

5.1 ALTERNATIVES CONSIDERED 

Three alternatives were analyzed in detail in the FEIS. These are briefly described below. Table 5 shows a 

comparison of activities by alternative, including the chosen alternative.

Table 5: Comparison of Activities by Alternative

5.1.1 ALTERNATIVE 1 – NO ACTION (FEIS PP. 2-5).

Under Alternative 1, current management would continue in the analysis area. No treatments are 

prescribed in Alternative 1 that would reduce potential crown fire, improve forest resiliency, or watershed 

condition. Though no management activities are proposed under this alternative, environmental changes 

will continue in the analysis area. 

5.1.2 ALTERNATIVE 2 - PROPOSED ACTION (FEIS PP. 2-5 TO 2-12).

Alternative 2 was developed to meet the Purpose and Need of the project. It would have treated 

approximately 5,056 acres on National Forest System land. Eighty-five percent of the treatments would 

occur in the WUI. The proposed treatments would have been a combination of commercial thinning, small 

tree thinning, and prescribed burning. Approximately 49% of the treatment area would produce 

commercial timber volume estimated to be about 7.5 million board feet (MMBF). About 2.2 miles of 

temporary roads and 1.7 miles of TLM trail would have been constructed. This alternative would have 

stored almost 19 miles of road and decommissioned another 10 miles. Properly closing these roads would 

have removed 22 culverts of which 16 contribute sediment to streams. About 11.6 miles of road would 

Activity Alt. 1 Alt. 2 Alt. 3 Alt. 3 – modified

Total Number of Treatment Units 0 76 51 60

Acres of Treatments in Wildland Urban Interface (% of 

total acres treated) 0 4,290 (85%) 3,277 (91%) 3,639(85%)

Proposed Treatments in acres (% of total acres treated)

Commercial Thin with underburn 0 3,057 (60%) 2,163 (60%) 2,303 (56%)

Prescribed Burn only 0 1,703 (34%) 1,140 (32%) 1,532 (37%)

Small Tree Thin (Plantations) 0 296 (6%) 296(8%) 296 (7%)

Research (included in Prescribed burn) 0 199 (4%) 199 (6%) 199 (5%)

Total Acres Treated 5,056 3,599 4,131

Yarding Systems (acres) (% of harvest)

Skyline 0 1,083 (43%) 798 (47%) 826 (47%)

TLM 0 366 (15%) 172 (10%) 172 (10%)

Tractor 0 1,044 (42%) 743 (43%) 743 (43%)

Roads Management

Temporary Road Construction (miles) 0 2.2 1.5 1.8

TLM trail (miles) 0 1.7 1.6 1.6

Roads Decommissioned or stored with timber sale(miles) 0 11.6 11.8 11.8

Culvert removed/sediment contributors 0 15/11 18/12 18/12

Road Storage 19 18 18

Total Road decommission (miles) 0 10 27 26

Total Culverts removed/sediment contributors 0 22/16 33/23 33/23

Fish Passage Barriers removed/replaced 0 7 7 7

Fish screens installed 0 2 2 2

Soil Restoration 0 329 382 382

Estimated Timber Harvest Volume (thousand board feet, 

MBF) 0 7,500 5,100 5,500
Record of Decision 

ROD - 18 Lower West Fork Project

have been stored or decommissionied as part of the timber sale. The remaining work would be funded by 

appropriated or partnership funds.

Five culverts that block fish passage would also be replaced or removed. Soil restoration would be initiated 

in harvest units 1, 3, and 12 and on 297 acres of terraced plantations. 

5.1.3 ALTERNATIVE 3 (FEIS PP. 2-12 TO 2-15).

Alternative 3 was designed to respond to the public concern that fires in 2000 and the Rombo fire have 

treated fuels on the east side of the West Fork River and that additional treatment is not necessary for 

community fire protection in the WUI. Alternative 3 would have treated approximately 3,599 acres of

National Forest System land. Ninety one percent of the treatments would occur in the WUI. The proposed 

treatments would have been similar to those described for Alternative 2. Approximately 48% of the 

treatment area would produce commercial timber volume estimated to be about 5.1 MMBF. Approximately 

1.5 miles of temporary roads and 1.6 miles of TLM trail would have been constructed. This alternative 

would have stored about 18 miles of road and decommissioned another 27 miles. Properly closing these 

roads would have removed 33 culverts of which 23 contribute sediment to streams. About 11.8 miles of 

road would have been stored or decommissionied as part of the timber sale. The remaining work would be 

funded by appropriated or partnership funds. 

Treatments to benefit the fisheries would have been the same as in Alternative 2. Soil restoration strategies 

would also have been the same except in Unit 1. The portion of Unit 1 with high amounts of soil 

compaction would not be commercially thinned. Instead, the progressive strategy would achieve the fuel 

load reduction and stand enhancement objectives in the purpose and need. The strategy consists of:

Ø thinning from below

Ø lopping the slash to prevent beetle infestation

Ø letting nutrients leach from the slash for at least a year

Ø burn the slash

Ø assess coarse woody debris level with a goal of 15-20 tons/acre

Ø thin larger trees from the mid-story, if necessary

5.2 ALTERNATIVES CONSIDERED BUT ELIMINATED (FEIS PP. 2-17)

During project development, and in response to comments submitted on the DEIS, six other alternatives 

were considered but not analyzed in detail. These alternatives, and the reasons for not analyzing them in 

detail, are described below.

5.2.1 FOCUS FUEL TREATMENTS IN THE HOME IGNITION ZONE RATHER THAN 

EXTENSIVE WILDLAND FUEL MANAGEMENT 

This alternative was not considered in detail because it would treat fuels on only a tiny fraction of the 

National Forest. The effects of this alternative would be indistinguishable from the No Action alternative. 

This alternative would not meet the purpose and need because it would not:

Ø Reduce fuel loads enough to lower crown fire hazard

Ø Improve ponderosa pine resilience

Ø Promote the representation of shade intolerant trees species in stands. 

5.2.2 REMOVE OR FIX ALL ROADS THAT CAUSE SOIL AND WATER PROBLEMS, OR 

ARE NOT NEEDED FOR FUTURE MANAGEMENT

Alternatives 2 and 3 adequately address this issue. The ID Team used the Roads Analysis process to 

determine the roads not needed for future management. The FEIS discloses the cost of fixing all roads that 

cause soil and water problems. The arterial roads that encroach on streams in the analysis area (Roads 363 
Record of Decision

Lower West Fork Project ROD - 19

and 5630 along Pierce and Lavene creeks, for example) have been graveled to reduce sediment production. 

Little more can be done to reduce sediment production from these roads other than paving or relocation. 

Paving or relocation is infeasible due to topographic constraints and high costs.

5.2.3 DROP ALL UNITS WHERE TREATMENTS ARE PROPOSED FOR FOREST HEALTH 

REASONS, OR FOR GENERATING MONEY TO DO OTHER WORK

None of the treatment units were proposed exclusively for forest health reasons, or for generating money. 

All of the treatment units were designed to improve stand resiliency to fire and insect activity. Therefore, if 

all of the units proposed to improve stand resiliency were dropped, the alternative would be the same as the 

No Action alternative, which is analyzed.

5.2.4 DO NOT INCLUDE ANY COMMERCIAL LOGGING IN ROADLESS AREAS, BUT DO 

INCLUDE THE USE OF PRESCRIBED FIRE

Alternatives 2 and 3 adequately address this alternative. Both alternatives propose the use of prescribed 

fire in inventoried roadless areas, and neither alternative proposes commercial harvest in inventoried 

roadless areas.

5.2.5 DEVELOP A WATERSHED RESTORATION ALTERNATIVE, OR AT LEAST INCLUDE 

WATERSHED RESTORATION ELEMENTS IN ALL OF THE REASONABLE 

ALTERNATIVES.

Alternative 3 was developed in response to this recommendation. Watershed restoration elements are also 

included in Alternative 2. 

5.2.6 REDUCE FUELS THROUGH TIMBER HARVEST AND SLASH DISPOSAL WITHOUT 

THE USE OF PRESCRIBED FIRE OR PILE BURNING.

This alternative would not treat the prescribed fire units or adequately reduce fuel loads. Not treating the 

prescribed fire units would decrease the fuels management effectiveness at the landscape-level (Arno and 

Fiedler 2005, Finney et al. 2005) by maintaining forest conditions that could carry fire and threaten 

resources in and adjacent to the WUI. 

Thinning forests creates slash or woody material with little to no commercial value. Some of this material 

has value for replenishing soil nutrients and other soil characteristics, however too much can increase fuel 

loads and fire hazards. Slash can be ground into chips but this requires whole tree yarding, which is not 

feasible in some units. Also, chip vans typically have a wider turning radius than log trucks and may not be 

able to access some units. The nearest chip market is 100 miles from the analysis area but is not operating 

at this time. Under Alternatives 2, 3, and 3 – modified, chipping is an option if the market is available and 

the units are accessible (FEIS pg. 2-8, 2-14). 

Stephens et al. (2009) found the effectiveness of mechanical thinning to reduce passive and active crown 

fire potential is dependent on the type of harvest system used, and the activity fuels remaining after harvest. 

Whole tree harvest systems cause little increase in 1-, 10-, and 100-hour fuels while cut-to-length systems 

greatly increase surface fuels in these classes. Stephens et al. (2009) found that mechanical treatments 

followed by prescribed burning or pile burning were the most effective treatment for reducing crown fire 

potential and predicted tree mortality. Post-wildfire studies indicate that mechanically treated stands 

without surface fuel treatments burned with higher intensity than those mechanically treated followed by 

prescribed fire (Skinner et al. 2004, Cram et al. 2006, Schmidt et al. 2008). 

For these reasons, this alternative would not meet the purpose of reducing fuel loads and crown fire 

potential. 
Record of Decision 

ROD - 20 Lower West Fork Project

6.1 RATIONALE FOR MY DECISION 

In selecting Alternative 3-modified, I determined that my decision is consistent with all laws, regulations, 

and policies. I considered the potential cumulative effects and reasonably foreseeable activities. I believe 

my decision provides the best balance of management activities to respond to the purpose and need, public 

comments, and environmental and social issues while complying with all applicable laws and regulations. 

I base my conclusion on a review of the record that shows a thorough review of relevant scientific 

information, consideration of responsible opposing views, and the acknowledgement of incomplete or 

unavailable information, scientific uncertainty, and risk. For example, soil surveys in Unit 1 indicate that 

42 acres of the Unit has 19% detrimental soil disturbance (DSD). The soil scientist recommended winter 

logging for the highly compacted soils in Unit 1. Forest monitoring supported by scientific literature 

indicates that winter ground-based harvest causes about 1% DSD (FEIS 3.5-18). Though mitigation 

measures require re-using skid trails and leaving 15-20 tons of coarse woody debris on the site, there is a 

risk that soil compaction would increase in the short-term. In response to a comment on the DEIS, I 

directed the ID Team to develop an alternative treatment that would meet the purpose and need for the 

project without increasing DSD. The alternative treatment analyzed in Alternative 3 of the FEIS does not 

increase DSD because heavy equipment is not used (FEIS 3.5-20). It achieves the purpose and need by 

thinning the understory and possibly the overstory, treating the smaller fuels after nutrients leach into the 

soil, and leaving the larger woody debris for long-term soil productivity. Throughout the FEIS, the 

scientific basis is referenced as it supports the purpose and need, the actions developed to respond to the 

purpose and need, and the effects analysis of the actions included in my decision. 

The criteria I relied upon to make my decision on this project include:

Ø Achievement of the project purpose and need

Ø Relationship to environmental and social issues and public comments

My decision reduces the severity of fire on National Forest System lands adjacent to private property, and 

supports the Bitterroot Community Wildfire Protection Plan. 

6.1.1 MEETING THE PURPOSE AND NEED

As noted in Section 3.1 of this document, the purposes for undertaking the Lower West Fork project are: 

Ø Reduce fuel loads and lower crown fire hazard in low elevation ponderosa pine/Douglas-fir 

forests

Ø Improve forest resilience to natural disturbances (fire, insects, disease); particularly the 

resilience of large diameter ponderosa pine trees 

Ø Maintain or increase shade intolerant species, specifically ponderosa pine

Ø Improve overall soil, watershed, and fisheries conditions by reducing road effects and 

rehabilitating degraded soils in historic harvest units and terraced lands.

Measurement indicators (Table 6) were developed for each of the purpose and need statements to indicate 

how each alternative responds to the statements (FEIS pg. 2-4, 2-16). The following section describes the 

purpose and need statements, lists the measurement indicators, and presents the results for each of the 

alternatives considered in detail. I believe the long-term benefits of improving forest conditions, reducing 

crown fire potential, and restoring the natural fire regime override the poor economics of this project. The 

currently poor market conditions may improve by the time the project is prepared for sale or the project 

may be delayed until market conditions improve. The analysis includes soil and watershed rehabilitation 

projects for which funds are available or that can better compete for funds since they are analyzed through 

the NEPA process. These projects will augment the natural soil rehabilitation and improve watershed 

conditions.
Record of Decision

Lower West Fork Project ROD - 21

Table 6: Comparison of Measures to Meet the Purpose and Need of the Lower West Fork Project

1 Represents area of commercial thin treatments. Though non-commercial thin treatments reduce stocking, they do not change the 

structure of the unit.

REDUCE FUEL LOADS AND LOWER CROWN FIRE HAZARD IN LOW ELEVATION 

PONDEROSA PINE/DOUGLAS-FIR FORESTS

The Bitterroot National Forest has been altered by 100 years of fire suppression, insect and disease 

outbreaks, and logging (Hessburg et al. 1994). The vegetation structure in most of the project area has 

shifted to dense, overstocked stands that are at increasing risk of stand-replacing fires. Large areas of 

unburned fuel exist in the project area that, in the event of a wildfire, could pose a considerable risk to 

firefighters, the public, and natural resources. 

The fires of 2000 burned over 307,000 acres on the Bitterroot NF causing the loss of residences and 

property and the evacuation of over 1,000 homes. The fires of 2000 burned a portion of the Piquett Creek 

drainage, but most of the Lower West Fork analysis area did not burn in 2000. In 2007, the Rombo fire 

covered about 29,000 acres and burned 24,700 acres, including much of the upper half of the Piquett Creek 

drainage. The Rombo fire did not pose as great a threat to life and property as the fires in 2000 because it 

started in the higher elevations. However, the suppression cost of this fire was 7.2 million dollars. The 

Lower West Fork analysis area surrounds private land along the West Fork River. A large fire, or multiple 

ignitions in one day on the West Fork face has the potential to overwhelm suppression forces and travel 

unimpeded to the Forest Service/private property boundary.

Addressing this situation is a primary purpose of this project. Taking actions to reduce fuels in the project 

area would set the stage for fire to play a more natural role, which historically was non-stand replacing with 

short-to-moderately short fire free interval. To achieve this purpose, there is a need to reduce existing fuel 

loads, including live trees and dead and down woody material. Fire type was the measure chosen to 

evaluate the effects of the proposed treatments on fuels and fire behavior. 

Purpose and Need Measure Alt. 1 Alt. 2 Alt.3 Alt.3 - modified

Area of reduced crown fire behavior (acres) 0 1,330 886 978

Area of reduced stocking (acres) 0 2,789 2,009 2,037

Area of reduced forest structure change1 (acres) 0 2,493 1,713 1,741

Area of ponderosa pine treated 0 2,614 1,829 1,870

Area treated in the WUI 0 4,290 3,277 3,637

Part- and Full-time job contribution over the life of the 

project 0 170 121 121

Income contribution over life of the project) ($) 0 5.6 million 4.0 million 4.0 million

Revenue available for resource improvement ($) 0 140,000 100,400 100,400

Expected funding needed for implementation of 

mandatory activities ($) 0 581,100 492,800 492,800

Expected funding needed for implementation of 

mandatory activities and all optional stewardship 

activities ($)

0 1,656,600 1,441,900 1,441,900

Reduced long-term sedimentation (tons/year) 0 27 39 39

Decommissioned roads (miles) 0 10 27 26

Stored roads (miles) 0 19 18 18

Stream crossings removed 0 23 33 33

Fish barriers eliminated 0 7 7 7

Soil rehabilitation in terraced plantations (acres) 0 297 297 297

Soil rehabilitation in units with historic disturbance 

(acres) 0 32 85 85
Record of Decision 

ROD - 22 Lower West Fork Project

Alternative 2 reduces potential crown fire behavior the most (1,330 acres) followed by Alternatives 3 –

modified (978 acres) and 3 (886 acres) (Table 6). The potential for crown fire to occur would continue to 

increase in Alternative 1.

The west side of the West Fork River is the highest priority for treatment because the terrain and vegetation 

are fairly uniform. Only one fire has occurred in the area since 1979. All of the action alternatives treat 

this area similarly. The difference between alternatives is the treatments on the east side of the West Fork 

River. The east side of the river has more broken terrain and more area previously harvested using the 

clearcut silvicultural system. The less uniform stands and topography create more barriers to fire spread. 

In addition the Rombo Fire and fires in 2000 burned most of the analysis area up to the WUI. Alternative 2 

treats the most area using a combination of prescribed fire and commercial thin followed by an underburn. 

Alternative 3 treats only the terrace units. This treatment may interupt fire behavior but it but would not be 

as effective as Alternative 2. Alternative 3-modified allows for prescribed burning that would augment the 

treatment in the terrace units. The ID Team discovered through the analysis process that the Piquett 

drainage is vulnerable to channel changing events because of the amount of forest canopy lost during the 

Rombo Fire. In addition, the recent fires have reduced thermal cover and old growth habitat. Not 

harvesting timber in these units would offset the effects of the fires. Under these circumstances, I believe 

that Alternative 3-modified provides appropriate reductions in potential crown fire that will provide 

adequate fire management options in response to ignitions and protect vulnerable resource conditions and 

habitat components. 

IMPROVE PONDEROSA PINE FOREST RESILIENCY TO NATURAL DISTURBANCE,

Stands in the Lower West Fork project area are a product of succession in the absence of disturbance. 

Stand densities have increased which has decreased tree vigor and increased fuel continuity. Declining tree 

vigor increases forest susceptibility to insects and disease, and higher tree mortality. Increasing stand 

density also increases the fuel continuity and provides structure for the development of crown fires. 

Ponderosa pine and ponderosa pine/Douglas-fir stands historically experienced frequent low-to-mixed 

intensity fires. This fire regime created landscapes resilient to fire, insects, and disease pathogens. Not only 

does the increase in tree density increase the flammability of the forest, but it increases water and nutrient 

competition among trees, shrubs, and other forest plants and predisposes the forest to disease and insect

attacks. The area of reduced stand density, especially in the ponderosa pine and ponderosa pine/Douglasfir forests was the indicator used to determine resiliency. Commercial thinning reduces stocking and 

favors disease-resistant trees, which improve tree vigor and resiliency. Alternative 2 reduces stocking the 

most (Table 6) followed by Alternative 3-modified and Alternative 3. Stocking is not reduced under 

Alternative 1 and stand density will continue to increase in the analysis area. 

Again, the Alternatives treat the same units on the west side of the West Fork River, except Alternative 3 

does not treat Unit 60. On the east side of the River, the terrace units are the only units commercially 

thinned in Alternative 3 or Alternative 3-modified. Not thinning the stands commercially thinned under 

Alternative 2 on this side of the river may off-set recent losses in thermal cover in the adjacent burned 

areas. The stands will become increasingly at risk for disease and insect attacks but treatments in the 

terrace units and prescribed fire units may buffer this risk. 

As described in the Economics and Social Analysis section of the FEIS, the timber program on the 

Bitterroot National Forest has declined substantially over the last twenty years. However, even at the 

current level, timber from the Forest plays an important role in the wood products economy of Missoula 

and Ravalli Counties. The trees harvested to reduce stocking levels and, consequently, reduce the risk of 

stand-replacing wildfires, have commercial value, which will contribute to the local economy. 

The ID Team selected two measurement indicators to compare the alternatives in terms of their effect on 

economic opportunities. They are total employment, expressed as jobs, and total labor income. It is 

important to note that these are not new jobs or income, but rather jobs and labor income attributed to the 

project. 
Record of Decision

Lower West Fork Project ROD - 23

With respect to total employment, Alternative 2 would contribute 170 part- and full-time jobs over the life 

of the project, followed by Alternative 3 with 121 jobs over the life of the project. Alternative 3-modified

would be similar to Alternative 3 because timber harvest on the east side of the river is similar to 

Alternative 3 and the road decommissioning and storage is essentially the same.

With respect to total labor income, Alternative 2 would result in $5.6 million dollars spread over the life of 

the project, followed by Alternative 3 with $4.0 million dollars spread over the life of the project. Again, 

Alternative 3-modified would be similar to Alternative 3 because the treated areas are similar and the 

watershed, soils and fisheries projects are the same. Alternative 1 would not result in any total labor 

income. Under current market conditions, this project is unlikely to generate adequate funds to cover all 

the stewardship costs. However, allocated and partnership funds are available to pay for most watershed, 

soil, and fisheries projects not associated with the timber sale and having these projects analyzed in a 

NEPA document improves their potential to be funded. 

MAINTAIN OR INCREASE SHADE INTOLERANT SPECIES

The dry, lower elevations are composed of mixed Douglas-fir and ponderosa pine in well-stocked or overstocked stands with increasing levels of Douglas-fir regeneration in the understory. Fire was an important 

agent that controlled forest density and species composition. These moderately warm, dry grasslands and 

cool upland sites had high fire frequencies and low to mixed intensity fire regimes. Fire suppression 

initiated the species composition shift in most of the ponderosa pine forest type to forest dominated by 

more shade tolerant species such as Douglas-fir and grand fir. Fire suppression reduced fire frequency and 

created conditions for shade tolerant species to encroach and out-compete less shade tolerant species. 

Reducing the stand density to favor retention of the large ponderosa pine and to a lesser extent, the large 

Douglas-fir will allow fire to function at an intensity that will not damage the forest components. The 

measurement indicators selected to compare the alternatives are area of ponderosa pine habitat treated and

area of reduced stand density. As with the previous measures, Alternative 2 treats the most area and 

reduces the density of the most stands. Alternative 3 treats the least area and the fewest stands. Alternative 

3-modified is similar to Alternative 3, though this alternative treats slightly more area. Again, Alternative 1 

does not treat any stands so ponderosa pine representation in stands would continue to decline. 

The main difference between the action alternatives is the treatment of areas on the east side of the West 

Fork River. Only the terrace units are thinned on the east side of the River in Alternatives 3 and 3–

modified though ponderosa pine stands will be maintained in the prescribed fire units under Alternative 3–

modified. 

IMPROVE OVERALL SOIL, WATERSHED, AND FISHERIES CONDITIONS BY REDUCING 

ROAD IMPACTS AND REHABILITATING SOILS ON TERRACED LANDS IN THE AREA.

Road sediments reduce water quality and channel conditions by increasing the amount of fine sediments in 

the stream, which settles into the stream substrate, reduces the volume of pools, and increases bank erosion. 

The Restoration Plan lists the West Fork River as impaired (MDEQ 2005) by sediment and thermal 

modification. The Restoration Plan recommends reductions in road sediment sources. The number of 

stream crossings removed and the miles of road decommissioned or stored are the two measurement 

indicators. 

Streams and Fish

Alternatives 3 and 3 – modified decommission and store the most miles of road and remove the most 

culverts. Alternative 2 is similar to Alternatives 3 and 3–modified in the miles of road stored but 

decommissions 10 miles of road in contrast to the 27 and 26 miles of road decommissioned in Alternatives 

3 and 3–modified, respectively. Similar amounts of road are stored or decommissioned as part of the 

timber sale (Table 6). Appropriations or partnerships will fund the roadwork not associated with the timber 

sale. 
Record of Decision 

ROD - 24 Lower West Fork Project

Soil conditions in three proposed commercial thinning units are near or exceed Region 1 Soil Quality 

Standards. Rehabilitation by increasing the amount of fine and coarse wood on the soil for future soil 

development, decompacting soils degraded by past ground-based logging operations, or a combination of 

these treatments would improve soil quality. 

Rehabilitating Detrimental Soil Disturbance

The project area contains approximately 297 acres of terrace plantations created in the late 1960s to 

improve tree survival and growth. The construction of terraces created high levels of soil disturbance as 

dozers cut benches across the recently clearcut slopes. The soils cut from the benches were side cast down 

slope on risers between benches. Dozer operations created highly compacted soil conditions on the terrace 

benches. Soil monitoring of the terraces indicate these units have 50 to 60 percent detrimental soil 

disturbance, which exceeds Region 1 Soil Quality Standards. The two measures indicating differences 

between alternatives are the area of soil improvement in past harvest units and the area of soil improvement 

on terrace plantations. All the alternatives treat the same area of terrace plantations and Alternative 2 treats 

32 acres of past harvest units while Alternatives 3 and 3–modified treat 85 acres. The difference between 

alternatives is not the absolute area treated but the method of treatment. My preference is in the methods 

used to treat the compacted soils in Unit 1 as described in Alternatives 3 and 3–modified. I believe this 

treatment would augment soil rehabilitation without the risk of incurring more compaction. 

IMPROVE AQUATIC CONNECTIVITY

The fishery in the Lower West Fork analysis area does not meet desired conditions, primarily because 

several culvert barriers fragment bull trout and westslope cutthroat trout populations; and non-native trout 

competitors are present throughout the West Fork River and much of Piquett and East Piquett creeks. 

The number of fish barriers replaced or removed is the measurement indicator selected to address this 

Purpose and Need item. Alternatives 2, 3, and 3–modified all remove or replace the same culvert on the 

same streams. No culverts are removed or replaced under Alternative 1.

6.1.2 ADDRESSING ISSUES AND PUBLIC CONCERNS

I considered the comments received on the DEIS, and directed the ID Team to incorporate changes to the 

FEIS as appropriate. Refer to the Summary of Changes between Draft and Final EIS in the FEIS. Chapter 

4 of the FEIS provides more thorough responses to the comments on the DEIS and the comment letters are 

provided in Appendix G of the FEIS.

The following are the major concerns raised by the public in their responses to scoping the DEIS, and 

during public field trips and public meetings. I have summarized how the ID Team addressed them

through the analysis process.

FISHERIES AND WATERSHED 

The primary concerns raised by the public focused on the funding of proposed watershed improvement 

mitigations and opportunities. 

The funding of watershed and fisheries improvements are discussed in alternative descriptions and the 

Chapter 3 watershed and fisheries sections of the FEIS. They are also considered in the Economics 

analysis (Section 3.13). Table 3.13-5 shows the revenues associated with the project and the mitigation 

activities, while Table 3.13-6 shows the improvement opportunities and possible funding sources. 

SOILS

Commenters raised concerns about the effectiveness of subsoiling, the Region 1 soil quality guidelines; 

failure to conduct field reviews; and guidelines pertaining to coarse woody debris. 

Information concerning subsoiling is included in Chapter 4, Response to Comments of the FEIS and

disclosed in the soils analysis, Section 3.5, as are the Region 1 soil quality guidelines and field reviews.
Record of Decision

Lower West Fork Project ROD - 25

Concerns raised about the effectiveness of soil mitigations in the compacted portion of Unit 1 prompted 

additional ID Team discussions and an alternative method for treating the area. The alternative method was 

incorporated into Alternatives 3 and 3–modified and will be implemented as part of my decision. 

WILDLIFE – ELK HABITAT EFFECTIVENESS AND THERMAL COVER

Concerns were raised about road management and how they were considered in the determination of elk 

habitat effectiveness. Also, concerns were raised about the proposed Bitterroot National Forest Plan 

(Forest Plan) amendments for elk habitat effectiveness and thermal cover. 

Both amendments were modified to clarify the intent and their application in the Lower West Fork 

Analysis Area. The elk habitat effectiveness and thermal cover analyses are also expanded and clarified in 

the FEIS. 

RECREATION AND ROADLESS

Concerns raised by commenters pertaining to unroaded and roadless areas dealt with the effects of the 

proposed treatments on unroaded areas. 

The effects of the proposed activities on roadless and unroaded areas are clarified and disclosed in Section 

3.12 of the FEIS. 

7.1 PUBLIC INVOLVEMENT

The concept for the Lower West Fork Project was introduced on a public field trip to review the similar 

Frasier Interface project in October of 2006. The feedback from this field trip was used to refine the 

proposed action for the Lower West Fork Project. Two additional field trips were held as the project 

developed in May 2007 and January 2008. 

A legal notice was published in the Ravalli Republic newspaper on March 7, 2007 (PF-Scoping-07-002). 

This notice provided details on the project and invited people to comment during the 30-day scoping 

period. News releases on the project proposal appeared in the Ravalli Republic on March 8, 2007. The 

Forest Service mailed a scoping letter, with four maps describing the proposed project and its background, 

to about 148 people, organizations, and agencies on March 7, 2007. They were invited to submit comments 

and questions on the project proposal by April 7, 2007. The Forest Service received 12 responses (PFScoping-001-009, 021, 023, 031). On March 10, 2007, the Forest Service established a Lower West Fork 

Project webpage providing public access to scoping letters, maps, and treatment examples used in the 

proposed action and alternatives. This website was updated as new information became available

(www.fs.fed.us/r1/bitterroot).

Preliminary ID Team analysis indicated that larger areas needed treatment to better apply current research 

and meet the project’s purpose and need of reducing crown fire risk on a landscape scale. In addition, the 

Rombo fire burned through several previously proposed units. Three of these units were proposed for 

prescribed fire, two for commercial harvest, and two for non-commercial thins. Only one of these units, a 

non-commercial thin unit would still benefit from treatment. The proposed action was expanded to treat 

additional areas within the analysis area boundary and a Notice of Intent was published on December 12, 

2007. The Notice of Intent opened another comment period that closed January 22, 2008. The Forest 

Service received 10 comments during this period. These comments in addition to the comments received in 

the initial comment period were used to identify issues and develop alternatives to the proposed action. 

The DEIS was completed and a Notice of Availability was published in the Federal Register on April 10, 

2009. The Notice of Availability opened the 45-day comment period that ended May 26, 2009. The Forest 

Service sent letters to 154 individuals, organizations, and agencies informing them that the DEIS was 

available as a document, compact disc, or on the Bitterroot National Forest web site. They also placed a 

legal advertisement in the Ravalli Republic, the newspaper of record, and distributed articles to the 

Missoulian, Missoulian on line, the Ravalli Republic, and the Bitterroot Star. The Forest Service received 
Record of Decision 

ROD - 26 Lower West Fork Project

six letters in response to these notifications and the comments in the letters were used to correct mistakes or 

clarify or amend the analysis. The ID Team added another alternative to evaluate the effects of stand 

treatments without the use of fire but did not carry that alternative through the analysis. The responses to 

all comments the Forest Service received are in Chapter 4. 

Public Meetings

Prior to the January 16, 2008 field trip, District Ranger Campbell briefed the Bitterroot Restoration 

Committee (BRC) on the project at a regularly scheduled meeting on December 18, 2007. The purpose and 

need for management and the BRC restoration principles were compared as part of the briefing. The BRC 

was also briefed on the project status at the regularly scheduled meeting on October 27, 2008.

7.1.1 HOW I CONSIDERED PUBLIC COMMENTS

Regardless of the source or form of the correspondence, or whether the comment was received during the 

official comment periods or afterwards, I considered each piece of correspondence. The public comment 

process provided many issues and concerns related to the project that were considered in the analysis (FEIS 

Chapter 4). I have reviewed these issues and concerns and I believe Alternative 3-Modified provides the 

best balance addressing public concerns and achieving the project purpose and need. 

8.1 FINDINGS RELATED TO OTHER LAWS AND REGULATIONS

To the best of my knowledge, my decision is consistent with all laws, regulations, and agency policy 

relevant to this project. The following discussion is not an all-inclusive listing, but provides information on 

topics raised by the public or other agencies.

8.1.1 NATIONAL FOREST MANAGEMENT ACT

The selected alternative is consistent with the National Forest Management Act (NFMA) requirements 

under 16 USC 1604 (g) (3) (E), which concerns even-aged management and clearcutting. The cutting of 

live trees to create an even-aged system is not proposed. 

1) No soil, slope, or other watershed conditions will be irreversibly damaged (FEIS pgs. 3.5-44, Appendix 

A). No system roads will be built during this project, so the project will not create any permanent 

impairment. Alternative 3-modified maintains organic matter, soil porosity, and topsoil through the use of 

Best Management Practices (BMPs), Soil and Water Conservation Practices (SWCPs), and mitigation

measures (FEIS pg. 3.5-44). Localized and limited detrimental soil disturbance will occur on landings, skid 

trails, temporary roads, or where soils are intensely heated, for example under logs or around roots. 

Detrimental soil disturbances will be managed according to Region 1 Soil Quality Guidelines to ensure soil 

productivity is maintained in activity areas. Compacted soils from terracing, historic logging activities, and 

re-used skid trails will be rehabilitated and trend soil productivity towards a net improvement (FEIS pgs. 

3.5-26 – 3.5-31)

2) The units will be fully stocked following the commercial thin and prescribed fire treatments. No 

regeneration harvest would occur therefore, there would is no need to restock stands withing 5 years (FEIS 

pg. 3.2-3).

3) Alternative 3-modified protects streams, stream banks, shorelines, lakes, wetlands, and other bodies of 

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

sediment through implementation of the Inland Native Fish Strategy standards and guidelines, 

programmatic agreements made with the U.S. Fish and Wildlife Service, BMPs, project design, and 

mitigations (FEIS pp. 3.7-8, 3.7-28, 3.7-34,2-20 – 2-21, Appendix A).

4) In Alternative 3-modified, the harvesting systems were selected based on site-specific resource 

requirements and not primarily to generate the greatest dollar return or the greatest unit output of timber 

(FEIS pg. 3.2-3). 
Record of Decision

Lower West Fork Project ROD - 27

SITE-SPECIFIC BITTERROOT NATIONAL FOREST PLAN AMENDMENT 

Implementation of Alternative 3-modified will require a site-specific amendment to the Bitterroot Forest 

Plan (1987) (FEIS p. 1-11 to 1-13) Appendix F. Therefore, my decision includes an amendment that will

modify the following Forest Plan standards specifically as they relate to the Lower West Fork decision:

Ø Elk habitat effectiveness

Ø Forest-wide thermal cover

Ø Coarse woody debris

Please see Appendix F of the FEIS for more detailed information pertaining to this amendment. Section 

1926.51 of the Forest Service Directives (www.fs.fed.us/emc/nfma/index5.html) gives guidance for 

determining what constitutes a “significant amendment” under NFMA. I have determined, based on this 

guidance, that this site-specific forest plan amendment is not significant because it will not significantly 

alter the long-term relationship between levels of multiple-use goods and services originally projected; and, 

it will not have an important effect on the entire land management plan or affect land and resources 

throughout a large portion of the planning area during the planning period. The amendment modifies 

standards and guidelines in the analysis area for the Lower West Fork project. Therefore, it is not a long 

term change in the plan. The public has been notified of this amendment throughout the NEPA process. 

FOREST PLAN CONSISTENCY

The Bitterroot National Forest Plan (Forest Plan) provides general management direction for the Forest, 

and establishes Forest-wide and management area standards and guidelines (USDA Forest Service 1987,

Chapter II). Management activities are to be consistent with the Forest Plan (16 USC 1604 (i)). 

I have evaluated the consistency of the alternatives with Forest Plan standards. Alternative 3-modified is 

consistent with the Forest Plan, meets Forest Plan standards, as amended, and will contribute toward 

reaching Forest Plan goals and objectives. Consistency with these standards can be found throughout the 

FEIS (pgs. 3.2-3 to 3.2-5 3.3-3 – 3.3-5, 3.3-22, 3.4-13, 3.5-45 – 3.5-46, 3.6-41 - 3.6-45, 3.7-34, 3.8-65 –

3.8-67, 3.9-11, 3.10-14 to 3.10-15, 3.11-5, 3.12-19). The Biological Evaluations and Biological 

Assessments confirm that this project will not impact the viability of sensitive, or threatened and 

endangered species. (FEIS pgs. 3.7-32 – 3.7-33, 3.8-68, 3.10-13 - 3.10-14.

8.1.2 NATIONAL ENVIRONMENTAL POLICY ACT 

NEPA requires Federal agencies to: (a) use a systematic interdisciplinary approach in planning and 

decision making; (b) consider the environmental impact of proposed actions; (c) identify adverse 

environmental effects which cannot be avoided should the proposal be implemented; (d) consider 

alternatives to the proposed action; (e) consider relationship between local short-term uses of the human 

environment and the maintenance and enhancement of long-term productivity; and (f) identify any 

irreversible and irretrievable commitments of resources which would be involved in the proposed action 

should it be implemented.

I find that the Lower West Fork analysis process and documentation is consistent with NEPA. The CEQ

provides NEPA guidance for government agencies, and interprets regulations on cumulative effects as; 

requiring analysis and a concise description of the identifiable present effects of past actions to the extent 

that they are relevant and useful in analyzing whether the reasonable foreseeable effects of agency proposal 

for action and its alternatives may have a continuing additive and significant relationship to those effects. 

The CEQ regulations do not require agencies to catalog and analyze all individual past actions. 

Information about past actions that may be available or obtained with reasonable effort does not mean that 

it is relevant and necessary to inform decisionmaking (CEQ 2005). However, I directed the Lower West 

Fork ID Team to catalog past harvest, road construction, and grazing activities and their effects, which is 

documented in Appendix B of the FEIS.
Record of Decision 

ROD - 28 Lower West Fork Project

8.1.3 CLEAN WATER ACT

The Lower West Fork project complies with the Clean Water Act (FEIS pgs. 3.6-42 to 3.6-43). Soil and 

water resources are protected through the application of design features and mitigation measures (FEIS pgs. 

2-17 to 2-24) and soil and water conservation practices listed in Appendix A of the FEIS. Though the West 

Fork of the Bitterroot River (West Fork River) is listed on the Montana 2008 impaired waters list, none of 

the tributaries in the Lower West Fork analysis area are listed. However, reducing sediment levels in these 

tributaries will decrease sediment levels in the West Fork River. The soil and water rehabilitation projects 

will reduce potential long-term sediment contributions to streams and contribute to the overall reduction of 

sediment in the West Fork River.

8.1.4 CLEAN AIR ACT

The basic framework for controlling air pollutants in the United States is the 1970 Clean Air Act, as 

amended in 1990 and 1999 (42 USC 7401 et seq.). The main air quality concern associated with this 

project is the amount and duration of particulate matter produced by prescribed burning. All prescribed 

burning will be implemented in full compliance with Montana Department of Environmental Quality air 

programs through cooperation with the Montana Idaho Airshed Group (FEIS p. 3.4-13). I have concluded 

that Alternative 3-modified meets the Clean Air Act and the Montana Clean Air Act (FEIS p. 3.4-8 to 3.4-

10).

8.1.5 ENDANGERED SPECIES ACT

The Bitterroot National Forest Fisheries Biologist, Wildlife Biologist, and Botanist evaluated the effects of 

the alternatives on threatened and endangered fish, wildlife, and plant, species, respectively (FEIS pgs. 3.7-

1 to 3.7-5, 3.7-10 to 3.7-15, 3.7-19 to 3.7-32, 3.8-42 to 3.8-44, 3.8-67, 3.10-1). The Fisheries Biologist 

prepared a Biological Assessment of bull trout (PF-FISH-002) and the U.S. Fish and Wildlife Service 

(USFWS) concurred with the Forest Service determination “that the proposed project is not likely to 

adversely affect bull trout, bull trout critical habitat, and proposed bull trout critical habitat.” (PF-FISH003). As there are no Threatened and Endangered wildlife or plant species known to occur on the 

Bitterroot National Forest, consultation with the USFWS was not required, and Biological Assessments

were not prepared (FEIS pgs. 3.8-1, 3.10-1). 

The USFWS no longer lists the Canada lynx as threatened or endangered on the Bitterroot NF (FEIS pgs. 

3.8-42). However, the project effects on Canada lynx habitat were evaluated as described in the NRLMD 

ROD (FEIS pg. 3.8-42) and the analysis showed there would be “No Effect” (FEIS pg. 3.8-44). 

Consultation with the USFWS is not required because Canada lynx are not listed as threatened on the 

Bitterroot NF and the determination was “No Effect.”

Forest Service resource specialists prepared Biological Evaluations or Biological Assessments for sensitive 

fish, wildlife, and plants and summarized the conclusions in the FEIS (FEIS pgs. 3.7-33, 3.8-67, 3.10-14, 

respectively). The conclusions were either “No Impact” or “May Impact Individuals or Habitat but not 

likely to contribute to a trend towards Federal listing or loss of viability to the population or species.” 

Alternative 3-modified would have effects similar to Alternative 3 because the soil and water rehabilitation 

projects would be the same and the timber harvest would be similar. The determinations of effect for 

threatened, endangered, and sensitive species were the same for Alternatives 2 and 3. Therefore, the 

determinations would be the same for Alternative 3-modified. 

8.1.6 ENVIRONMENTAL JUSTICE ACT

Executive Order 12898, issued in 1994, orders federal agencies to identify and address any adverse human 

health and environmental effects that disproportionately impact minority and low-income populations. 

Based on the composition of the affected communities and the cultural and economic factors, Alternative 3-
Record of Decision

Lower West Fork Project ROD - 29

modified will have no adverse effects on human health and safety or environmental effects on minority, 

low-income, or any other segments of the population (FEIS pg. 3.13-10).

Alternative 3-modified provides the option to treat potential new invasive plant populations with 

herbicides. The criteria for determining whether to use herbicides, which herbicides to use, and how to 

apply them will be the same as described in Alternative 2. The potential exposure to herbicides under 

Alternative 2 were determined to be very low (FEIS pg. 3.15-5) and would not disproportionately affect 

minorities or low income populations. Herbicide exposure would be less likely under Alternative 3-

modified because soil disturbance would occur on 758 fewer acres. Though more roads would be 

decommissioned and stored under Alternative 3-modified, it would increase the area of potential 

disturbance to 1,791 acres, which is less than the 2,549 acres of potential disturbance in Alternative 2.

8.1.7 MIGRATORY BIRD TREATY ACT

The design features and mitigation measures in Alternative 3-modified provide adequate conservation 

measures for migratory birds. Overall, impacts on forest land birds are expected to be minimal and are not 

expected to affect species viability (FEIS pg. 3.8-66).

8.1.8 NATIONAL HISTORIC PRESERVATION ACT

Alternative 3-modified would not affect any cultural resources. Recognizing the potential exists to 

encounter and disturb unidentified sites during project activity, mitigation practices require halting 

activities and notifying the Forest Archaeologist, if cultural resources are encountered during project 

implementation. Formal consultation has been completed with the Confederated Salish and Kootenai

Tribes and the State Historic Preservation Office in accordance with the Memorandum of Understanding

(PF-HERT-002). Heritage and Tribal interests are regulated by federal laws that direct and guide the Forest 

Service in identifying, evaluating and protecting cultural resources. Alternative 3-modified will comply 

with these federal laws because both Alternative 2 and Alternative 3 comply (FEIS pg. 3.11-5) and 

Alternative 3-modified is within the parameters of these two alternatives.

8.1.9 ENVIRONMENTALLY PREFERRED ALTERNATIVE

The Council on Environmental Quality defines the environmentally preferred alternative as “the alternative 

that will promote the national environmental policy as expressed in NEPA’s Section 101. Ordinarily, this 

means the alternative that causes the least damage to the biological and physical environment; it also means 

the alternative which best protects, preserves, and enhances historic, cultural, and natural resources.” This 

definition could be generalized to mean the alternative that best balances negative impacts with benefits.

Alternative 1 (No Action) would impact the biological and physical environment the least in the short-term 

because no ground-disturbing activities would occur. However this alternative does little to improve stand 

growing conditions and forest density will increase. Over time, stand resilience to environmental stressors 

would decline and the forest will increasingly become susceptible insects, disease, and fire. In addition, no 

road decommissioning or storage and associated culvert removal would occur and current trends in 

sediment contributions to associated streams would continue. This alternative would not contribute to the 

sediment reduction target identified in the Water Quality Restoration Plan and Total Maximum Daily 

Loads for the Bitterroot Headwaters Planning Area

Alternative 3-modified offers the best balance between meeting the purpose and need for the project and 

minimizing long-term environmental effects. The units on the west side of the West Fork River are treated 

under Alternative 3-modified, which links fuel treatments in three previous decisions. These treatments

provide a buffer across the landscape between the Selway-Bitterroot Wilderness and private land 

boundaries, which would likely increase fire management options. Alternative 3-modified retains the 

prescribed fire units on the east side of the River, which combined with past treatments and fires, will 

(DEQ 2005). Fish habitat would continue to be 

fragmented at the seven fish barrier culverts. Soil rehabilitation would continue at the normal rate and 

would not be expedited through subsoiling or slash decomposition. 
Record of Decision 

ROD - 30 Lower West Fork Project

provide some fire management options while not creating additional disturbance in drainages recovering 

from the effects of the Rombo fire. By not commercially thinning the units on the east side of the river at 

this time, log truck traffic will not be on roads next to streams that are prone to increased sedimentation 

from the Rombo fire. I conclude that the commercial thin treatments on the east side of the West Fork 

River are not as critical to enhancing fire management options. Past fire activity and harvest treatments and 

the proposed prescribed fire and terrace treatments provide adequate opportunities to manage fire and 

protect resources in the WUI. 

Retaining the option to combat new weed infestations using herbicides is an important feature analyzed in 

Alternative 2 that needs to be retained in Alternative 3-modified. These drier ecotypes are prone to weed 

infestations and weed seed sources typically are adjacent to treatment areas. Though preventive and 

mechanical methods of eradication are preferable, not all weed species can be treated in this manner.

Alternative 3-modified also restores the most soil and watershed conditions. The treatment of the portion 

of Unit 1 with high levels of soil disturbance has the potential to accelerate the recovery of soil conditions. 

Terrace units will be treated to improve stand growing conditions and enhance soil rehabilitation rates. 

This Alternative also decommissions or stores the most roads and removes the most culverts from roads not 

needed for forest management, which in turn reduces the most sedimentation and restores fish habitat 

connectivity. 

Considering these factors, I conclude that Alternative 3-modified is the environmentally preferred 

alternative. 

8.1.10 PERMITS REQUIRED

Removing or replacing culverts within an active stream channel requires a 124 permit from the Montana 

Department of Fish, Wildlife, and Parks. In certain instances, a 404 permit from the Army Corps of 

Engineers or 318 permit from Montana Department of Environmental Quality, may also be required. The 

applicable permits must be obtained prior to conducting the work. The permits sometimes contain 

additional site-specific mitigations to minimize damage to the aquatic ecosystem. Appropriated dollars 

from the Forest Services annual budget is also required for implementation of the culvert work. No other 

permits, licenses, grants, or authorizations are needed to implement the decision. 

9.1 APPEAL PROVISIONS

This decision is subject to appeal pursuant to 36 CFR 215.11. A written appeal must be submitted within 

45 days following the publication date of the legal notice of this decision in the Ravalli Republic, the 

newspaper of record in Hamilton, Montana. It is the responsibility of the appellant to ensure their appeal is 

received in a timely manner. The publication date of the legal notice of the decision in the newspaper of 

record is the exclusive means for calculating the time to file an appeal. Appellants should not rely on date 

or timeframe information provided by any other source. Appeals must be submitted to:

USDA Forest Service, Northern Region 

ATTN: Appeal Deciding Officer 

P.O. Box 7669 

Missoula, MT 59807

Or USDA Forest Service, Northern Region

ATTN: Appeal Deciding Officer 

200 East Broadway 

Missoula, MT 59802

(Office hours are Monday through Friday from 7:30 a.m. to 4:00 p.m., except holidays.)

Electronic appeals must be submitted to: appeals-northern-regional-office@fs.fed.us

Faxed appeals must be submitted to: Fax: (406) 329-3411

In electronic appeals, the subject line should contain the name of the project being appealed. An automated 

response will confirm your electronic appeal has been received. Electronic appeals must be submitted in 

MS Word, Word Perfect, or Rich Text Format (RTF).

Record of Decision 

ROD - 32 Lower West Fork Project

LIST OF REFERENCES CITED IN THIS DECISION

The following references were cited in this Record of Decision. Additional literature is cited in the Final 

Environmental Impact Statement.

Arno, S.F., Carl Fiedler. 2005. Mimicking Nature’s Fire: Restoring Fire-Prone Forests in the West. pp 154-

159. Island Press, Washington, D.C., USA [0412]

Cram, D.S., T.T. Baker, and J.C. Boren. 2006. Wildland Fire Effects in Silviculturally Treated vs. 

Untreated Stands of New Mexico and Arizona. Paper RMRS-RP-55. USDA Forest Service, Rocky 

Mountain Research Station, Fort Collins, Colorado, USA. [1182]

Dept. of Natural Resource Conservation, Bitter Root Resource Conservation & Development Area, Inc., 

USDA Forest Service, et al. 2006, updated 2010.

http://www.bitterrootfireplan.info/pdf/CWPP_20091215.pdf

Finney, M. A., C.W. McHugh, and I.C. Grenfell. 2005. Stand and landscape level effects of prescribed 

burning on two Arizona wildfires. Canadian Journal of Forest Research 35: 1714-1722 [0427]

Graham, Russell T.; McCaffrey, S.; Jain, T. B. (tech. eds.) 2004. Science basis for changing forest structure 

to modify wildfire behavior and severity. Gen. Tech. Rep. RMRS-GTR-120. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research Station. 43 p. [0130]

Hessburg, P. F., Mitchell, R. G., Filip, G. M. 1994. Historical and current roles of insects and pathogens in 

eastern Oregon and Washington forested landscapes. Gen. Tech. Rep. PNW-GTR-327. Portland, OR: 

USDA Forest Service, Pacific Northwest Research Station. 72 p. [0185]

Montana Department of Environmental Quality (MDEQ). 2008. Montana Numeric Water Quality 

Standards http://www.deq.state.mt.us/wqinfo/standards/pdf/CompiledDEQ7.pdf [1191]

Schmidt, D.A., A.H. Taylor, and C.N. Skinner. 2008. The Influence of Fuels Treatment and Landscape 

Arrangement on Simulated Fire Behavior, Southern Cascade Range, California. Forest Ecology and 

Management 255:3170-3184 [1183]

Skinner, Carl N., Martin W. Ritchie, Todd Hamilton, and Julie Symons. 2004. Effects of Thinning and 

Prescribed Fire on Wildlife Severity. pp 80-91. IN S. Cooper, editor. Proceedings 25th Annual Forest 

Vegetation Management Conference, January 20-22, 2004, Redding, CA. University of California 

Cooperative Forestry Extension, Redding, CA USA [0372]

Stephens, Scott L., Jason J. Moghaddas, carl Edminster, Carl E. Fiedler, Sally Haase, Michael Harrington, 

Jon E. Keeley, Eric E. Knapp, James D. McIver, Kerry Metlen, Carl N. Skinner, and Andrew 

Youngblood. 2009. Fire Treatment Effects on vegetation structure, Fuels, and Potential fire Severity in 

Western U.S. Forests. Ecological Applications 19(2):305-320 [1184]

USDA, Forest Service. 1987. Forest Plan, Bitterroot National Forest. USDA Forest Service, Northern 

Region. Hamilton MT, September, 1987. [0120]

USDA Forest Service. 2004. Forest Plan Monitoring and Evaluation Report, Fiscal Year 2004, Bitterroot 

National Forest, Hamilton, MT. [0325]
Appendix A – Best Management Practices

Lower West Fork Project ROD A-1

APPENDIX A

BEST MANAGEMENT PRACTICES

BITTERROOT NATIONAL FOREST

2.3 MITIGATION MEASURES AND PROJECT DESIGN

The Forest Service designs projects and specifies practices that prevent or mitigate adverse effects of 

project activities. These design features and management practices come from direction in the Forest Plan, 

and Forest Service manuals and handbooks. The design features and mitigation practices specified in the 

alternatives are outlined in Tables A-1 and A-2.

Table A-1: Mitigation Practices and Design Features in Alternatives 2 and 3 of the Lower West Fork 

Project 

Objective Mitigation Practice or Design Feature

Soils

Minimize soil erosion and 

compaction

Activities will comply with Best Management Practices (BMPs) to minimize 

effects to soil resources. BMPs are listed in Appendix A. Complete descriptions 

are available in the Project File.

Reduce soil erosion, prevent 

sedimentation into streams, and 

prevent the spread of noxious 

weeds

Disturbed sites will be evaluated by timber sale administrators (TSAs) and/or 

resource specialists to determine erosion control and revegetation needs. Soil 

disturbances associated with landings, roadside ditches, temporary roads, or other 

areas would be rehabilitated as soon as possible by re-contouring, shallow 

ripping (6-12 inches) as needed, seeding, fertilizing, planting of shrubs, and 

covering with mulch or slash.

Minimize soil compaction Skid trails will be designated and historic skid trails will be used to the extent 

feasible in units yarded by ground-based systems.

Winter ground-based yarding is required in Unit 1 below FS road 363 

(approximately 65 acres) under Alternative 2. The winter yarding will be 

required to follow standard winter timber operating procedures. Commercial 

thinning operations will be required to limb and leave tops in this area. Woody 

debris levels should range from 15 to 20 tons/acre on the ground following 

thinning to enhance natural soil rehabilitation The woody debris will be a mix of 

fine and coarse wood.

Summer ground-based yarding will occur when soils are dry (soil moisture is 

near or below the permanent wilting point).

Winter ground-based yarding:

The snow depth, distribution, and air temperature conditions must be such that 

ground-based operations maintain the following combination of snow depth and 

frozen soil conditions under

Depth of compacted (by equipment) 

snow under wheels or track/tread

the wheels or tracks/treads of equipment at all 

times. (* see below).

Minimum thickness of solidly frozen 

soil needed below compacted snow 

layer

10 or more inches 0 inches

7 to 10 inches 1 inch

4 to 7 inches 2 inches

less than 4 inches 4 inches

*Pre-trailing. Pre-trailing selected skid trails a day or so prior to skidding or 

other heavy trail use is a way to achieve this objective. If average, pre-compacted 
Appendix A – Best Management Practices

A-2 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

snow depth along the proposed trail is more than 15 inches, pre-trailing can be 

done whether or not the soil is frozen. If pre-compacted snow depth is 8 to15 

inches, pre-trailing should be done only if the soil is solidly frozen in the top one 

inch or more. Otherwise, pre-trailing should be delayed until more snow falls to 

accumulate another 8 inches or more. To further aid soil protection, pre-trailing 

should be done using an “easy-does-it” approach, including slow ground speeds 

and steady movements. Avoid spinning tires and bouncing equipment on trails as 

much as possible. Adequate pre-trailing air temperatures are generally in the low 

20s  ̊Fahrenheit or lower. For more information about pre-trailing conditions, 

consult with the Forest soil scientist.

Subsoiling will occur on all skid trails used for yarding in the proposed summer 

ground-based units. If winter ground-based yarding is used in units 3 and 12, 

subsoiling of historic skid trails will be required in order to create a net 

improvement in soil productivity in these units. A SGR or excavator subsoiling 

implement that achieves desired results will be used; proper application of 

subsoiling does not mix soil horizons and will cause minimal disturbance to 

surface soil/litter layers. Subsoiling will also occur on all skid trails in skyline 

units where summer, tractor swing is required. When available, slash will be 

placed on the decompacted skid trails by the SGR.

Reduce detrimental soil 

disturbance (DSD) 

Feller/buncher equipment may be used on skyline units pending the results of 

studies conducted in the Trapper Bunkhouse project area. If DSD exceeds 2%, 

then feller/bunchers will NOT be used on skyline units in the Lower West Fork 

Project area. These units will be harvested using conventional felling and skyline 

yarding methods.

Rehabilitation activities on new temporary roads and Tracked line machine trails 

will include recontouring, slashing, and seeding. 

Historic roads used for hauling will be stabilized by removing drainage 

structures; ripping, seeding, and fertilizing the road bed; and closing the entrance 

to these roads. 

Reduce DSD and prevent the 

spread of noxious weeds

Hand pile sizes inside units will average 6-8 feet in diameter so localized areas of 

soil disturbance will be less than about 50 square feet. This does not pertain to 

slash created on landings during yarding operations.

Burning of piles should occur during wet conditions when the duff is moist. The 

entire duff profile should be moist to the touch in the pile locations.

Prevent the creation of new areas 

of DSD 

Where feasible, pile and burn slash where detrimental soil disturbance already 

exists, such as on old log landings, skid trails, and roads associated with the past 

harvest units. This practice will prevent the creation of new areas of detrimental 

soil disturbance.

Maintain 70% ground cover

The soil scientist will be consulted prior to burning to ensure soil conditions are 

acceptable for burning. Prescribed burning in terrace and non-terraced noncommercial thin units will only be completed through piling and burning on a 

case by case basis, pending field review by the soil scientist. 

At least 70 percent ground cover is necessary to prevent detrimental accelerated 

erosion and loss in soil productivity after treatments are completed. Ground 

cover includes duff, organic soil horizons, vegetation basal area, fine woody 

debris, coarse woody debris (CWD), and surface coarse fragments. In those 

cases where ground cover is less than 70 percent prior to burning, fuel 

consumption and ground cover loss should not exceed 15 percent. Prescribe fire 

prescriptions will be designed to meet these soil protection requirements.
Appendix A – Best Management Practices

Lower West Fork Project ROD A-3

Objective Mitigation Practice or Design Feature

Maintain soil productivity

CWD (material greater than 3 inches in diameter) left on site will include leave 

trees both standing and down, and broken limbs and tops created by timber 

harvest. Amounts will be within ranges identified in Section 1.7 D, with the 

exception of unit 1 and terraced units. 

In unit 1, fine and coarse woody debris from logging slash will be spread 

uniformly across the compacted portions of the ground-based unit (below FS 

road 363) at a rate of 15 to 20 tons/acre to increase organic matter for soil 

rehabilitation. Under burning will not be completed in this 65 acre area of unit 1. 

Mechanical thinning operations in terrace units will ensure adequate woody 

debris (fine and coarse wood) is left for soil rehabilitation on the terrace benches. 

This may require some limbing and leaving tops to ensure an adequate amount of 

woody debris is available for soil rehabilitation on the benches. An organic 

fertilizer, woody debris (rate of 10 to 15 tons/acre), or combination of both will 

be applied following subsoiling or ripping on the terrace benches to improve soil 

organic concentrations, nutrient cycling, and microbial populations. Risers in 

between benches should meet CWD standards described in Section 1.7 D. Under 

burning will not be completed on the terrace units. If fuel reduction is required 

after mechanical harvest and soil rehabilitation activities, piling and burning will 

be completed on a case by case basis pending field review by the soil scientist. 

Woody debris levels should be 10 to 15 tons/acre throughout the non-terraced 

plantations following all treatments including potential piling and burning.

The silvicultural prescriptions will be designed to account for future large CWD 

(>15 inches diameter) recruitment that will meet acceptable levels in stands 

where CWD is less than minimum levels before treatment. CWD will be left in 

these stands to the extent feasible to meet minimum requirements that do not 

pose a fuels hazard. High amounts of small CWD (3-15 inches diameter) may 

present wildfire risks. 

CWD will generally be evenly distributed on each acre, unless otherwise agreed 

to by the Contracting Officer or their designee. 

Prescribed burning operations will maintain CWD levels where existing CWD is 

less than required minimum levels. Burning should attempt to increase CWD 

recruitment where possible. 

Wood larger than 15 inches in diameter will not be intentionally ignited during 

hand lighting. It is understood that once hand crews light the fire, fire may burn 

into and combust some large CWD. Coarse woody debris will meet standards 

stated in Section 1.7 D, with the exception of terrace units and unit 1.

Allow time for nutrients to leach 

from slash prior to burning

The slash will be left in all commercial thin units through one winter after cutting 

to allow for initial decomposition and nutrient leaching.

Watershed and Fisheries

Ensure that water-related 

beneficial uses are protected and 

that State water quality standards 

are met

Trees will not be harvested from Riparian Habitat Conservation Areas (RHCAs). 

If trees felled outside of the RHCAs land or roll into the RHCAs, their boles may 

be removed, but the tops and limbs will be left behind. The RHCAs are:

within 300 feet of fish-bearing streams

within 150 feet of permanently flowing, non-fish bearing streams

within 100 feet of seasonally flowing or intermittent streams

within 150 feet of ponds, lakes or wetlands > 1 acre in area

within 50 feet of ponds, lakes or wetlands < 1 acre in area

within 50 feet of landslide prone areas (USDA Forest Service 1995).

RHCA boundaries will be designated and marked on the ground in consultation 

with the Fisheries Biologist. 
Appendix A – Best Management Practices

A-4 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Ensure that water-related 

beneficial uses are protected cont.

In RHCAs, trees can be felled when they pose a safety risk. Felled hazard trees 

will be left on-site (INFISH standard RA-2), unless their removal is deemed 

necessary for safety reasons by the TSA. 

Log landings, temporary roads, and tracked line machine trails will not be located 

in the RHCAs.

Generally, no fuel storage, mixing of fuels, or refueling equipment will occur in 

the RHCAs. If there are no other alternative areas, refueling sites in RHCAs may 

be used, but they must be approved by the Fisheries Biologist and have an 

approved spill containment plan prior to their use. Small pumps (for example, 

Mark III) and chainsaws can be refueled within the RHCA as long as proper spill 

containment actions are implemented (USDA Forest Service1995).

Protect the streamside 

management zone (SMZ) All activities will comply with the Montana Streamside Management Zone Act.

Ground-based equipment will be prohibited from entering SMZs without the 

appropriate variance from Montana DNRC. Boundaries of RHCAs will be 

marked to exclude equipment operation.

Best Management Practices will be applied and monitored during the 

administration of the contract. Applicable BMPs are in the Project File and 

summarized in Appendix A.

Protect Forest roads used during 

log hauling operations

The TSA and/or resource specialists will monitor road conditions to ensure they 

do not contribute sediment to streams. Road maintenance activities (including 

snowplowing and dust abatement) will follow the requirements specified in the 

USFSW1 Programmatic Biological Assessment for road maintenance (1999). 

Prevent sediment entering streams 

from encroached segments of haul 

roads

On the encroached haul road segments (Pierce Creek #363, Lavene Creek #5630, 

and Piquett Creek #49 Roads) –

Straw bale check dams will be installed below the outlets of all ditch relief 

culverts, in the road ditches that empty into streams, and below road drainage 

features such as drive-thru dips that lack adequate riparian filter distance. The 

check dams will be installed prior to winter hauling, and maintained during all 

periods of winter hauling. 

Outlets of all ditch relief pipes will be kept free of snow blockage during winter 

haul.

Snow berm drainage holes will be designated prior to winter haul, and kept open 

throughout the duration of winter hauling.

Roads proposed for long-term 

storage or culvert 

removal/restoration

Seed, fertilize and slash roads after decompaction and/or recontouring, mulch to 

the extent feasible. Seed mix will be as prescribed by the Forest Botanist. Mulch 

is required on sites located within sediment contributing distance of streams 

(about 300 feet). Where culverts with flowing water are removed, a strawbale 

check dam will be installed below the outlet prior to removing the culvert. 

All units with manual thinning Trees will not be manually thinned and slash piles will not be created within 50 

feet of streams and wetlands. 

Protect RHCAs during prescribed 

burning

Helicopter ignition will not occur in the RHCAs. Hand ignition can occur in all 

of the RHCAs except wetlands. Fire will be allowed to back into or burn through 

the RHCAs. 

In Units 32, 33, and 60A, no ignition (hand or helicopter) will occur within 300 

feet of Pierce Creek and Lavene Creek.

Generally, hand fireline will not be dug in the RHCAs. If needed, hand fireline 

can be dug in the RHCAs, but it must 1) avoid wetlands, 2) be constructed with 

proper drainage structures, and 3) be recontoured and covered with slash upon 

completion of the burn. Machine fireline is prohibited in all RHCAs. 

If drafting from streams occurs, intake hoses will be fitted with a screen mesh 

equal to or smaller than 3/32 inches. Intake hoses will be placed in low velocity 

portions of the stream channel (< 0.4 feet/second of flow).
Appendix A – Best Management Practices

Lower West Fork Project ROD A-5

Objective Mitigation Practice or Design Feature

Protect aquatic resources and 

ground water during herbicide 

application

High effectiveness

Application standards.

(W1) Mixing and loading of tanks will occur more than 300 feet from live water 

where possible. No mixing will occur within 100 feet of live water.

(A1) Herbicides will not be used to control weeds within a 100-foot radius of any 

potable water spring development or diversion within the project area.

Protect aquatic resources during 

herbicide applications

High effectiveness.

Avoids potentially harmful 

exposure

(A2) No ester formulations of herbicides will be used (i.e., 2,4-D ester, triclopyrBEE), due to relatively high fish toxicity.

Protect aquatic resources and 

ground water during herbicide 

applications

High effectiveness.

Practical experience.

(A3) Use of herbicides and surfactants within 100 feet of surface water will 

adhere to distances and conditions outlined in Table 3.7-4, Herbicide Use 

Restrictions in RHCAs (Chapter 3 section 3.7 Fisheries) 

(A4) In areas adjacent to known stream reaches where bull trout spawn (Boulder 

Creek and Piquett Creek), no herbicides would be used within 15 feet of the 

stream, no picloram within 100 feet, and no application after July 15.

Timber Management

Prevent pine engraver (Ips spp.) 

population increases

All thinning in units with ponderosa pine and lodgepole pine must be performed 

between the months of July 1 thru December 31. Slash must be properly disposed 

of, i.e., piled and burned or lopped and scattered. Where limbs and tops exceed 

three inches in diameter, they need to be bucked in four-foot lengths and 

scattered to allow time for larger boles to dry out and not become Ips beetle host 

sites the following year. 

Prevent the spread of annosus root 

disease

Apply borate to freshly cut ponderosa pine stumps greater than 12 inches in 

diameter inside bark.

Protect TES Plant Populations and their Habitat/Promote Healthy Native Plant Communities

Avoid dwarf onion populations 

during harvest operations in units 

3, 18, 41, 64, 68, 69, 70, 73, 74

Dwarf onion (Allium parvum) populations will be located by GPS and marked on 

sale area maps for avoidance during skidding and slash piling.

Avoid Rocky Mountain paintbrush 

populations during harvest 

operations in units 6 and 70

Rocky Mountain paintbrush (Castilleja covilleana) populations will be located 

by GPS and marked on sale area maps for avoidance during skidding and slash 

piling.

Avoid Lemhi penstemon 

populations in units 22 and 66

Lemhi penstemon (Penstemon lemhiensis) populations will be located by GPS 

and marked on sale area maps for avoidance during skidding and slash piling.

To reduce the risk of weed spread 

All Units

Clean equipment prior to moving into the project area, minimize soil disturbance, 

and revegetate disturbed soil where native plant recovery may be delayed 

(consult Forest Botanist for specific recommendations) as outlined in FSM 2000, 

Zero Code 2080 – Noxious Weed Management (R1 Supplement No. 2000-2001-

1). 

Landings, Temp Roads, TLM 

paths

Botanist will evaluate temporary roads, TLM paths, and landing locations that 

have not previously been surveyed for sensitive plants. Sensitive plant locations 

would be avoided or an alternate site would be used.

Herbicide Treatments

(Alternative 2)

Lemhi penstemon plants along NFS roads 13423 and 5723 will be avoided 

during roadside spraying. The Forest Botanist will be contacted prior to off-road 

herbicide applications to ensure that sensitive plants will be avoided. Sensitive 

plants are known to occur in units 3, 18, 22, 41, 64, 66, 68, 69, 70, 73, and 74. 

GPS locations will be made available to applicators so plants can be avoided. 

Prevent weed spread along road 

corridors

Treat haul roads and access roads with herbicides prior to implementing harvest 

and/or burning activities. 

Promote successful revegetation Treat temporary roads, TLM trails and landings with herbicides after harvest 

activities are completed and prior to revegetating. 
Appendix A – Best Management Practices

A-6 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Protect sensitive plants from 

herbicides

Protect sensitive plants from 

herbicides (cont.)

Moderate to High Effectiveness

(SP1) Consult with district/forest botanist each year for updates to speciesspecific protection measures, before any site applications begin.

(SP2) All treatment sites will be evaluated for sensitive plant habitat suitability. 

Highly suitable habitat will be surveyed as necessary prior to treatment.

(SP3) Provide the weed crew with maps of all known sensitive plant locations so 

that these sites can be identified and protected.

(SP4) Train the weed crew to identify sensitive plants so that new sites can be 

identified and protected.

(SP5) The Forest Botanist will provide site-specific treatment guidelines for 

weed infestations within or adjacent to known sensitive plant populations.

(SP6) No spraying with vehicle-based spraying devices will be done within 50 

feet of any known sensitive plant occurrence.

(SP7) No chemical spraying will be done within 25 feet of any known sensitive 

plant occurrence, only mechanical treatment would be used.

Herbicide Use (Alternative 2)

Control Application Rates; 

Moderate effectiveness

Monitor –equipment for wear

(H1) Operators shall calibrate spray equipment at regular intervals 

(approximately after every 80 to 160 hours of use) to ensure proper rates of 

herbicide applications using standard methods.

Ensure responsible application of 

herbicide; Moderate effectiveness 

Monitor –Daily Pesticide 

Application Record or similar 

database.

(H2) Herbicides will be used in accordance with label instructions and 

restrictions. Application will be done or supervised by licensed applicators.

High effectiveness (Professional 

experience)

(H3) Herbicide applicators shall carry spill containment equipment, as described 

and in the Herbicide Emergency Spill Plan, and be familiar with and carry an 

Herbicide Emergency Spill Plan. A spill cleanup kit will be available at 

temporary storage sites and with all transportations (vehicles, raft, plane, mules) 

carrying herbicides.

Prevent spillage in rafts that may 

come into contact with humans or 

may directly enter surface waters.

High Effectiveness, Practical 

experience.

(H4) Equipment used for transportation, storage, or application of herbicides 

shall be maintained in leak proof condition. 

Prevent contact with open water. 

High effectiveness. Logic.

(H5) Chemicals will not be used over live water (streams, ponds, springs, etc.), 

including water standing or running in ditch lines.

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Avoid impact to sensitive plants 

and non-target aquatic species.

High effectiveness Professional 

experience.

(H6) Procedures for mixing, loading, and disposal of herbicides and a spill plan 

will be followed. All herbicide storage, mixing, and post-application equipment 

cleaning will be completed outside of RHCAs. If no other alternative is 

available, mixing and loading operations must take place in an area where an 

accidental spill would not contaminate a stream or body of water before it could 

be contained. Particular attention will be given to avoiding mixing, loading, or 

cleaning within 100 feet of live water. These procedures are referenced in 

Appendix A and B of the Draft Selway-Bitterroot Invasives EIS (2008). Drafting 

equipment used for filling herbicide spray tanks will be equipped with 

appropriate back-siphoning prevention devices.

Assure product safety.

High effectiveness.

EPA Studies.

(H8) Additional herbicides may be considered for use within the project area in 

the future. Only EPA registered herbicides having a completed Human Health 

and Ecological Risk Assessment Final Report will be considered for use. 

Additional consultation regarding ESA-listed species will occur for the use of 

any new herbicide not included in this Record of Decision.
Appendix A – Best Management Practices

Lower West Fork Project ROD A-7

Objective Mitigation Practice or Design Feature

Inform public and reduce 

exposure; High effectiveness 

(Logical – prevent exposure)

(H9) Roads receiving treatment will be posted with the date of treatment and 

chemical applied. 

Provide for annual, pre-application 

oversight.

High effectiveness.

Coordination.

(H10) The Annual Plan of Operations for herbicide application will be reviewed 

by an interdisciplinary team that includes, at a minimum, hydrology and or 

fisheries biology, botany, and wildlife biology skills. The review will take place 

prior to implementation to ensure the protection of native flora and fauna and to 

ensure that herbicide thresholds, as described in the Fisheries section of Chapter 

3, are not exceeded

Prevent contact with open water. 

High effectiveness. Logic.

(H11) No herbicide spraying will occur during rain or when rain is imminent. 

Dry roadside ditches that lead to intermittent and perennial streams will not be 

sprayed with any herbicide containing picloram.

Protect Aquatic Resources; High 

effectiveness

Prior testing.

(H12) Use of surfactants will occur as previously described, using only the 

surfactants listed and according to the allowable distances to live water displayed 

in Table 2-9 below.

Safe handling of herbicide; High 

effectiveness (Logical – visible)

(H13) Water-soluble colorants, such as Hi-Light® blue dye, will be used within 

100 feet of water and in other situations as needed to enable applicators and 

inspectors to better see where herbicides have been applied.

General Safety; High 

Effectiveness; Logical – high 

visibility

Traffic control and signing during weed-treatment operations will be used as 

necessary to ensure safety of the public and workers.

Protect Cultural Resource sites; 

High effectiveness (Logical –

avoids impact to area)

(C1) Mechanical/cultural treatments that disturb soil, will not be used on any 

known historical or archaeological site without proper clearances by a Forest 

Heritage Resource Specialist.

Wildlife

Retain old growth habitat 

characteristics in units that contain 

old growth habitat (units 4, 8, 9, 

15, 33, 60A, 61A, 70, 71)

The Silviculturist and Wildlife Biologist will monitor stand marking and timber 

harvest to ensure the stands meet Green et al. (1995, addednum 2005) old growth 

criteria. 

Snags Retain all snags unless designated “danger” trees (29CFR 1910.266(h)(1)(vi,vii).

Retain downed, woody debris

Fire Type Group Coarse Woody Debris

 2, 4 5-10 tons/acre

 6 10-20 tons/acre

 7, 8, 9 8-24 tons/acre

Protect amphibians and herptiles

High effectiveness with training 

and diligence of applicator.

Avoids potentially harmful 

exposure.

(W1) When ground application of authorized herbicides is necessary within 50 

feet of a water body, wetland, or river beach, applicators will survey the 

treatment area at time of application to determine potential presence of 

amphibians and aquatic associated herptiles.

The broadcast spray application method will not be used if adult amphibians or 

aquatic associated herptiles are identified.

The extent of species population distribution in the treatment area will be 

reported to the district amphibian specialist (Fisheries or Wildlife Biologist) as 

soon as possible. Hand pulling or wick application will be used or treatment will 

be deferred on advice of the amphibian specialist if treatment is not possible 

without directly spraying individuals.

If tadpoles or amphibian metamorphs are identified, the location will be reported 

to the amphibian specialist and weed coordinator as soon as possible, and 

application of herbicides will be delayed until metamorphs disperse.

Reduce potential for incidental 

contact of spray compounds with 

non-target species of concern.

(W2) Avoid directly spraying any terrestrial organism other than invasive plant 

species, including snakes, lizards, salamanders, small mammals, ground nesting 

birds, and insect concentrations such as ladybug swarms.
Appendix A – Best Management Practices

A-8 Lower West Fork Project ROD 

Objective Mitigation Practice or Design Feature

Moderate effectiveness due to 

tendency for some species to hide 

under rocks and debris. 

Practical experience.

If treatment is not possible without directly spraying individuals, then hand 

pulling or wick application will be employed.

Minimize impact to nesting 

eagles; High effectiveness (MT 

Bald Eagle Working Group. 1994. 

page 24)

(W3) Activities associated with weed control will avoid areas within 400 meters 

of active bald eagle or peregrine falcon nest sites unless the Wildlife Biologist 

provides further direction.

Minimize human effects on 

wildlife.

High effectiveness.

Practical experience.

(W4) Food, garbage, and human waste associated with project implementation 

work crews will be properly managed so as not to attract or habituate wildlife.

Crew camps will be located to avoid disturbance to wildlife in reproductive sites 

during active reproductive periods, including calving and lambing areas, raptor 

nesting and carnivore den sites.

Protect Bog Lemmings.

Avoids potentially harmful 

exposure.

High Effectiveness based on 

research

W5) Chemical application is prohibited within 300 feet of all sites where 

northern bog lemmings are known to occur, as well as peatland sites not yet 

surveyed for northern bog lemmings, pending review and approval by the Forest 

Wildlife Biologist.

Table A-2: Adjuvants (Surfactants) Proposed for Use and Allowable Distance to Live Water 

Surfactant

Distance to Live Water Use Allowed

0 – 15’ >15 – 50’ >50 –

100’ > 100’

Agri-Dex, and Super Spread MSO Yes Yes Yes Yes

Cide Kick II No Yes Yes Yes

R-11, Activator 90, X-77, Latron AG-98, Pro-Spreader Activator, 

Cide-Kick, LI-700, Spreader 90, Syl-tac, Cygnet Plus, Sylgard 

309, Freeway, Silwet L-77, Kinectic, and Inlet

No No Yes Yes

R-900, R-56, Cohere, Dyne-Amic, Bond, Tacktic, and Latron Ag98 (N) No No No Yes