Public comment ends for Mud Creek Vegetation Management Project
The chance for public comment on the Bitterroot National Forest’s Draft Environmental Assessment (EA) for the proposed Mud Creek Vegetation Management Project came to a close on Tuesday, April 20. The West Fork Ranger District is proposing the Mud Creek project to address forest health, hazardous fuels, and road network concerns in the entire Mud Creek watershed and portions of the Nelson Lake, Little West Fork, Lloyd Creek, Lower Blue Joint and Painted Rocks watersheds areas of the Bitterroot Mountains. The project area is approximately 48,523 acres, however, most vegetation treatments will focus on the Wildland- Urban Interface (WUI). Even though vegetative treatments will be primarily focused within the WUI and Community Protection, according to the Environmental Assessment the project area boundary was left larger to incorporate other resource opportunities such as fish habitat, recreation and watershed function that are spread out over the project area.
The Mud Creek project EA focuses on three main issues impacting the area, including the departure from historic disturbance regimes and subsequent existing vegetation and fuel conditions, conditions related to the current road network, and some programmatic forest plan amendments related to elk habitat objectives.
To improve landscape resilience to disturbances such as insects, diseases, and large crown fires the Forest Service proposes to use commercial timber harvest, thinning, and planed burns to modify forest structure, composition and fuel loads.
The project area has one of the highest road densities found on the Bitterroot National Forest. Field surveys have identified some road segments in need of maintenance and repair to address resource concerns (e.g. watershed health). Some third order drainages currently exceed Bitterroot Forest Plan road density standards for elk habitat effectiveness. And opportunities exist to designate new motorized and non-motorized trails and make on-the-ground conditions compatible with road travel status in the Bitterroot Travel Management Plan. The project plans include designing and implementing a suitable transportation and trail system for long-term land management “that is responsive to public interests and reduces adverse environmental effects.”
The project EA also proposes to conduct a programmatic Forest Plan amendment related to elk habitat objectives. The 1987 Forest Plan contains several standards pertaining to elk habitat effectiveness, thermal cover, and hiding cover, collectively referred to as Elk Habitat Objectives. The science behind implementing the Elk Habitat Objectives is based on guidance from the 1970’s as well as direction from Lyon et al. (1983). But the Forest Service claims that the guidance provided by Lyon et al was misapplied within the Forest Plan creating a situation where the elk habitat effectiveness standard is not met under the existing condition in most third order drainages and that this has necessitated the need for a project- specific amendment for elk habitat objectives for each project.
“A programmatic forest plan amendment will address the discrepancy between more recent scientific literature related to elk habitat effectiveness and the Forest Plan,” states the EA.
Although silviculturists and foresters reviewed existing data sources and surveyed the project area in summer/fall 2018 to identify potential priority areas for treatment and the project plan sets out certain criteria and guidelines for developing particular projects within the area, no details of any projects are presented.
For instance, in the EA it states in terms of timber management that “within high and medium treatment areas, the existing and desired future conditions of each individual stand will dictate the silvicultural treatment options that will be applied…During surveys for individual treatments, additional opportunities and objectives may be determined to enhance resources with the identified silvicultural treatment. During implementation, design features will be applied to minimize, avoid, or mitigate impacts to existing resources.”
The project is scheduled to last from 15 to 20 years.
Not everyone is happy with the proposal as it stands. Friends of the Bitterroot claim that the open ended aspect of the Forest Service’s “conditions based process” is a violation of the National Environmental Policy Act.
“It is difficult to discern the likely impacts both positive and negative given the lack of site-specific information for the numerous hypothetical proposed management activities over the course of a 20-year project duration,” it states on the group’s website. They claim by not providing specific onsite information to the public the Forest Service is “leaving the public bereft of necessary information to provide meaningful comment.”
The organization also expresses concern about the proposed cutting of old growth and the number and size of proposed clearcuts. They urge retaining the thermal cover standards, the coarse woody debris standards and and the elk habitat standards currently in the Forest Plan. They are also calling for a more thorough study of the soils in the areas impaired due to heavy logging, clearcuts and terracing from past activities.
Friends of the Bitterroot also asked the Forest Service to open a new public comment period on June 1st by which time the public can gain access to the project area. They mention specifically the need for another 60-day comment period to give the public a chance to access the areas proposed for the 22 plus “regeneration” clearcuts from 40 to 200 acres in size, since the areas only recently became accessible due to previously impassible roads.
West Fork District Ranger Seth Carbonari said, “We will be taking a good hard look at all the comments received and see if there is anything we hadn’t considered that we should have, or if we have to consider changing the EA to address some of the comments. We don’t want to take any more time than we need, but we do want to take the time to do a good job.”
Carbonari said they would be thorough in their consideration of the comments and make whatever changes they need to make and hopefully by the end of May come out with a Final EA and Draft Decision and Finding of No Significant Impact.
Once the Final EA has been approved, according to Carbonari, a 45 day “objection period” sets in in which objections can be heard and potential changes made prior to the decision becoming effective.