Objection notice for Breckenridge Forest Health and Fuels Project

							United States        Forest         White River                          Dillon Ranger District
Department of        Service        National Forest                      P.O. Box 620
Agriculture                                                              680 Blue River Parkway
                                                                         Silverthorne, CO 80498
                                                                         (970)468-5400
                                                                         FAX (970)468-7735

                                                            File Code:   1950-1/2410
                                                                 Date:   October 27, 2010




Dear Interested Party,
The Forest Service has completed the Environmental Assessment (EA) for the Breckenridge
Forest Health and Fuels Project located on the Dillon Ranger District, Summit County, Colorado.
This analysis has been completed using the Healthy Forest Restoration Act 2003 (HFRA), Title
I, Sec. 102 (a) (1) and (4) authorities. The purpose of this project is to accelerate forest
regeneration following the mountain pine beetle epidemic, reduce the impacts of hazard trees and
potential wildfire to USFS and community infrastructure and to provide a community protection
zone on National Forest System lands adjacent to communities in the wildland-urban interface.
The EA analyzes three alternatives; a no-action alternative, Alternative 2 which proposes treating
about 5600 acres of lodgepole pine within the wildland/urban interface, and Alternative 3 which
proposes to treat about 5360 acres. At this time, as the deciding official, I am favoring the
selection of Alternative 2. The vast majority of beetle-infested, mature lodgepole pine stands on
the White River National Forest are not available for management due to a variety of factors
including wilderness designation, resource protection requirements, and terrain that is logistically
or economically infeasible to operate in. As such, I find that implementation of Alternative 2 is
an opportunity to actively realize specific resource and social benefits, and mitigate potential
adverse effects that could result from no action, in some of the limited areas where such
activities are a viable option. A strong factor in my preference is the fact that the vast majority
of the timbered lands affected by the mountain pine beetle within the Dillon Ranger District will
continue to be primarily influenced by ecological processes without direct human manipulation.
Alternative 3 was developed in response to several comments expressed by residents around the
Peak 7 neighborhood by proposing fewer acres of treatment, providing a no-treatment buffer
around the Peaks Trail, and changing mechanical felling to hand felling in the Community
Protection Zone (CPZ) around parts of the neighborhood. However, many residents of this
community also expressed concerns regarding the amount of slash left in the forest after
treatment, or were in favor of treatment as long as species other than lodgepole pine were left
standing. I would like to take this opportunity to summarize my rationale for preferring
Alternative 2 over Alternative 3.
   1. The design of Alternative 2 allows for access to equipment that could be used to remove
      fuels from treatment units 124 – 128. Residual fuel loading requirements in mechanical
      treatment units are under 8 tons/acre within the CPZ and 15 tons/acre outside the CPZ.



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       Alternative 3, however, would treat units 349 and 350 with hand crews (portions of
       Alternative 2 treatment units 126 and 127) because units would no longer be accessible
       from National Forest System Roads (NFSR) 3.1B and 3.1C. As a result, under
       Alternative 3, residents could expect up to 30 tons/acre of fuel left on the forest floor
       after treatments are completed in units 349 and 350.
   2. Under Alternative 3, in units 349 and 350, many of the tree boles could be carried out of
      the forest in the form of firewood or poles. It is not realistic to expect that this method
      would be able to remove enough material to meet the 30 tons/acre requirement.
      Therefore, additional burning of slash would be needed to meet maximum fuel loading
      requirements. This additional burning, although planned around days with favorable
      conditions, would produce more smoke and could impact more soil through heating.
   3. Although Alternative 3 responds to comments made by some members of the Peak 7
      community by reducing the extent of the treatment areas, under Alternative 2 units 124-
      130 and 134 would only be regenerated if mortality rates reach of level of over 60-
      percent (as described under the Adaptive Management section of the Proposed Action).
   4. Much of the Peaks Trail is expected to have hand felling of dead trees along its length for
      hazard tree mitigation. This work would be accomplished under the authority of the
      White River Forestwide Hazardous Tree Removal project (2009). Because this cutting
      would occur within the trail corridor, there will be limited opportunities to remove the
      trees that are felled. Alternative 2 of the Breckenridge Forest Health project would allow
      for mechanical treatment along portions of the trail so that felled trees can be removed
      from the forest, as opposed to felling and leaving on-site.
   5. Alternative 2 would allow equipment into treatment units 124 – 130 and 134, so more
      soil scarification would occur under this alternative than under Alternative 3. The result
      would be to expose mineral soil and provide suitable conditions for seed germination.
      Therefore, Alternative 2 would provide better conditions for forest regeneration; be it
      lodgepole pine or aspen.
These are some of my primary considerations in preferring Alternative 2 to Alternative 3.
Alternative 3 would also have benefits, such as having less of a direct, short-term impact to
recreationists on the Peaks Trail and less of a short-term impact to scenery. After reviewing the
Environmental Analysis, however, I believe the positive effects of Alternative 2 outweigh those
of Alternative 3.
In addition I am also considering dropping unit 416 as well as the portion of unit 338 outside the
CPZ because of the potential impacts to lynx habitat. Fuels analysis indicated that the amount of
fuel removed from salvage treatments would not significantly alter fire behavior in this unit.
Other treatment areas in the Indiana Creek Drainage, such as units 117-119, would be more
effective at lowering fire severity. In addition, the reconstruction of the Indiana Gulch Road
would still have the indirect beneficial effect of providing improved access to fire personnel.
The EA is available online at www.fs.usda.gov/whiteriver (navigate to ‘Land & Resources
Management’ then ‘Projects’) or at the Dillon Ranger District Office. For more information or
to request a hard copy of the EA, contact Peech Keller, PO Box 620, Silverthorne, CO 80498;
phone 970-262-3495 or email: cpkeller@fs.fed.us.
Public comments are no longer being accepted on this project. This authorized hazardous fuel
reduction project is subject to an objection process pursuant to 36 CFR part 218, subpart A.
Objections (including attachments; incorporation of documents by reference shall not be allowed
(§ 218.7(c))) must be in writing and filed (regular mail, fax, e-mail, hand-delivery, express
delivery, or messenger service) with the Reviewing Officer (§ 218.7) within 30 days after the
publication date of the legal notice of the EA in the Summit Daily News (Frisco, Colorado). The
publication date of the legal notice in the newspaper of record is the exclusive means for
calculating the time to file an objection (§ 218.9(a)). Those wishing to object should not rely
upon dates or timeframe information provided by any other source. It is the responsibility of
objectors to ensure that their objection is received in a timely manner.
Pursuant to 36 CFR 218.6, only those individuals or organizations who submitted specific
written comments related to the proposed authorized project during scoping or other opportunity
for public comment during the preparation of the EA may file an objection. It is the objector’s
responsibility to provide sufficient narrative description of those aspects of the proposed
authorized hazardous fuel reduction project addressed by the objection, specific issues related to
the proposed authorized hazardous fuel reduction project, and suggested remedies which would
resolve the objection (§ 218(b)). At a minimum, an objection must include the following (§
218.7(d)): 1) objector’s name and address, with a telephone number, if available; 2) signature or
other verification of authorship upon request (a scanned signature for electronic mail may be
filed with the objection); 3) when multiple names are listed on an objection, identification of the
lead objector, verification of the identity of the lead objector shall be provided upon request; and
4) the name of the proposed authorized hazardous fuel reduction project, the name and title of
the Responsible Official, and the name(s) of the National Forest(s) and/or Ranger District(s) on
which the proposed authorized hazardous fuel reduction project would be implemented.
Objections may be filed with the Reviewing Officer, Scott Fitzwilliams, Forest Supervisor,
USDA Forest Service, White River National Forest/ATTN: Reviewing Officer, PO Box 948,
Glenwood Springs, Colorado 81602 or e-mail in Microsoft Word or an .rtf file format to
comments-rocky-mountain-white-river-so@fs.fed.us. Fax: (970) 945-3211. Objections may
also be hand delivered to White River National Forest Supervisor’s Office, 900 Grand Avenue,
Glenwood Springs, CO during normal business hours, 8 a.m.- 4:30 p.m., Monday through Friday
(excluding holidays).
The Breckenridge Forest Health and Fuels Project, an authorized hazardous fuel reduction
project, is not subject to the notice, comment, and appeal procedures found at 36 CFR part 215.
Pursuant to 36 CFR 218.11(b), if no objection is filed, approval of the project in a Decision
Notice may occur on, but not before, the fifth day from the close of the objection filing period.


Sincerely,


/s/ Paul Semmer (for):
JAN CUTTS
District Ranger


cc: Cynthia P Keller
Jan Cutts
Jan Burke
Brett C Crary
Cary Green
Scott Fitzwilliams