November 11, 2013 Scott itzwilliams, Forest Supervisor White River National Forest 802 Grand Avenue Glenwood Springs, CO 81601 Hand Delivered Re: Hunter Creel<~Smuggler Mountain Cooperative Plan EA, Draft DN, and FONSI Objection Dear Supervisor Fitzwilliams, On October 31, 2013 representatives from Aspen Center for Environmental Studies (ACES), the City of Aspen, Pitkin County, and Wilderness Workshop 1net to discuss the objection filed by Wilderness Workshop to the Hunter--Smuggler Cooperative Plan Environmental Assessment (EA), Draft Decision Notice (DN), and Finding of No Significant Impact (F ONSI). As a result of that meeting all four organizations agreed on a i set of recommendations for changes to the EA, DN and FONSI. This letter lists those for changes. We encourage the Forest Service to adopt these changes both as a way to improve the overall project and as a way to satisfy Wilderness Workshop"s most significant objections. Recommendation 1). - The EA and final Decision must clarify whether the Forest Service is authorizing a planning team and an implementation team or just one team. Our recommendation is to authorize a team (called an Implementation Team) that will be open to additional members and will be responsible for determining the annual implementation strategy} The planning team described exclusive group made up of only four organizations (ACES, USFS, City of Aspen and Pitkin County). The success of this project will depend on broader participation and representation on the Implementation Team that designs and implements projects. We recommend that the Plan, EA, DN,and FONSI be amended to ensure amore inclusive implementation 1 The EA and DN alternatively reference a "planning team" (EA at 2-2; 2-3; 2-5; 3-8; A- 2; DN--8) and an "implementation team" DN-10) but it is not clear if these two terms reference the same body. We recommend the Plan, EA, DN, and FONSI clarify what this group is called for consistency. - strategy. Specifically, there should only be one team (called the Implementation Team) with the responsibility and authority to annually design and recommend projects to the Forest Service. All references within the EA, DN, and FONSI to a Planning Team should be changed to "Implementation Team," except when referring to the previous Planning Team, which developed the Hunter Smuggler Cooperative Plan and EA.. Specifically, page ofAppendiX A ofthe EA should be amended as follows. Delete the following sentence: "The Planning Team would meet at least semiannualbz and coordinate with relevant stakeholders to specijj/ projects to be implemented. Replace it with this sentence: "The Implementation Team will be open to all members of the previous Planning Team and Focus Group as well as other individuals representing relevant stakeholder interests. The Implementation Team will recommend projects using a consensus-based decision making process. For those projects where consensus cannot be achieved, following a thorough and reasonable efifort, the various opinions of members of the Implementation Team will be acknowledged and shared with the Forest Service. A project that includes a disagreement may still be advanced with acknowledgement of the disagreement. The Implementation Team will meet at least semiannually to discuss and specijjr projects to be implemented. Similarly, the sentence on page 8 ofthe DN, which reads: "The Planning Team will meet at least semiannually and coordinate with relevant stakeholders to specijjz projects to be implemented. Should be replaced with this sentence: he Implementation Team will be open to all members of the previous Planning Team and Focus Group as well as other individuals representing relevantstakeholder interests. The Implementation Team will recommend projects usinga consensus-based decision making process. For those projects where consensus cannot be achieved, following a thorough and reasonable efifort, the various opinions of members of the Implementation Team will be acknowledged and shared with the Forest Service. A project that includes a disagreement may still be advanced with acknowledgement of the disagreement. Recommendation 2. - Add a paragraph to the DN describing the intent to create a signed Memorandum of Understanding between the City of Aspen, Pitkin County, and the F.S. that grants City and County staff enforcement authority on .S. lands as part of this Decision. Throughout this process staff from both Pitkin County and the City of Aspen have confirmed that as a result of the HSCP each of their jurisdictions would be able to commit resources to enforcement of recreational regulations in the project area. Specifically, Forest Service, County and City staff described how through an MOU with the F.S., County and City staff would be given the ability to enforce travel and recreational regulations on Forest Service land. We recommend the following paragraph be added to the DN: "Enforcement of travel management regulations is key to protecting and enhancing the recreational quality and values in the project area. The City of/lspen, Pitkin County and the U.S. Forest Service will work to sign an agreement authorizing City and County stafi' to enforce travel management regulations on U.S. Forest Service land. Recommendation 3. - Delineate a specific area for analysis of a trail on the south side of Smuggler Mountain that eliminates important habitat from the analysis area. The Final Decision should define a spatially explicit area exclusive of important habitat in which the analysis for an alignment of a single-track mountain bike trail will occur on the south side of Smuggler Mountain. The defined area should be based upon previous mapping of wildlife habitat in the HSCP and Visioning Documents. More specifically defining the analysis area for this particular trail will provide transparency, reduce opposition, increase public understanding, and ensure that impacts to important wildlife habitat do not occur. Figure 2 of the EA and Figure 1 ofthe DN would be amended accordingly. Additionally, the EA on page 2-4 should also be amended as follows (new text is underlined): "Design areieleal a sustainable alignment for a mountain biking trail on the south side of Sm uggler Mountain, regardless of its current route refer to Figure 2 fI9r--t--he e++Lt--Fail for the specific area in which a new trail alianment can occur); considerations must include avoidance, to the level comfortable by the implementation team of important wildlife habitat (such as elk winter range and transition habitat and bear fall concentration and denning habitat], rideability, and visual experience." All similar references and figuresin the Plan, EA, DN, or FONSI to a trail on the south side of Smuggler Mountain should identify the specific area for analysis outside of mapped wildlife habitat and make it clear that the possible trail alignment will avoid, to a level comfortable by the implementation team, important mapped wildlife habitat. Recommendation 4. -- Identify a specific trail corridor in which alignment for the Hunter Ditch Loop trail may be built. The Plan, EA, DN, and FONSI should define a' spatially explicit trail corridor for the Hunter Ditch Loop. While the EA is vague on the location ofwhere the Hunter Ditch Loop might occur, in previous conversations the planning team and focus group members agreed that the Hunter Ditch Loop would be placed within approximately 100' of the existing Hunter Valley Trail. To help facilitate this, City and County staff will provide a map of the trail corridor within which the newly constituted Implementation Team will determine a precise alignment in the 2014- field season. Recommendation 5. -- Identify a specific trail corridor within which the alignment for the Hummingbird Traverse trail may bebuilt. A The Plan, EA, DN, and FONSI should define a spatially explicit trail corridor for the Hummingbird Traverse that recognizes previous conversations among the planning team and focus group to site the trail in such a way as to minimize impacts to important sage and shrubland habitat on the south facing slope east ofthe existing Plunge Trail and locates the trail as far to the west as is practicable. To help facilitate this, City and County staff will provide a map of the proposed Hummingbird Trail corridor within which the newly constituted Implementation Team will determine a precise alignment in the 2014 field season. Recommendation 6. - Adaptive management should be defined in the EA and incorporated into any final Decision. The Forest Service should commit to incorporating adaptive management into the HSCP. The following paragraph defining adaptive management and committing to implementation of adaptive management should be added to the EA and incorporated into any final Decision. "Adaptive management is a crucial tool to ensure that the design and implementation of ecological management projects use the most up to date information, data and scientific research possible. Projects designed and implemented as part of the Hunter Smuggler Cooperative Plan will utilize adaptive management principles. Each project will not only have a clear set of objectives but will also include an evaluation component to assess whether those objectives were met and will identify a feedback loop to determine how similar projects should be modified in the future to better achieve project objectives." Recommendation 7. - The EA and final Decision should clarify that no roads will be built as part of this project. The EA should provide clarity on road construction by explicitly stating that no new temporary or permanent roads or road reconstruction will be authorized. Any reference to road approval or construction should be removed from the Plan, EA, DN, or FONSI. Specifically, the PDC describing mitigation from permanent and temporary road construction is therefore not applicable to the project and should be removed. Additionally, selection Criteria #3 and #4 (A-3) in Appendix A should be removed and modified so that it is clear road construction will not occur as part of this project. Recommendation 8. - Add a research and monitoring summary as provided by ACES and Wilderness Workshop. The research and monitoring summary submitted by ACES and Wilderness Workshop and attached to this letter should be added to the EA and incorporated into any final Decision. - Recommendation 9. - The following PDC in the EA and final Decision should be mandatory rather than discretionary, as amended below (new text is underlined). Watershed Conservation Handbook/ Best Management Practices. Monitor as needed compliance of the proposed action with standards and design criteria in Chapter 10 of Forest Service Handbook 2509.Z5--Watershed Conservation Practices Handbook (F SH 2509.25). The standards and design criteria meet the requirements of the Best Management Practices in Colorado and if unexpected adverse effects become evident through monitoring, treatment activities may mm be reduced, revised, or halted completely for watershed resource protection. Mines and homesteads sheulel will be examined for the presence of cave bat (incl. Townsend's big-eared bat and fringed myotis) hibernacula or maternity roosts prior to being included within the Heritage Trail network and or vegetation treatment units. . No spring burning sheulel will be conducted within 0.5 miles of any known or suspected occupied denning area unless approved by a Line Officer in coordination with a Forest Service wildlife biologist, unless the denning area is above the snowline at the time of ignition. Sagebrush vegetation treatments sheulel _vy_il_l be designed to maintain or improve sagebrush stand conditions without degrading existing sagebrush attributes of shrub structure, complexity, diversity, or overall age of the stand. All equipment surfaces should be cleaned especially drive systems, tracks and "pinch points" to ensure removal of potentially invasive debris. For three years after treatment completion, treatment units should will be monitored for newly invading exotic species. Post--burn treatments should will obliterate lines, address erosion concerns, and ehoouhage manage humans and wildlife so as not to impede Vegetation re-growth. Any skid trails should _w_i_l_l be rehabilitated to reduce the color contrast of the exposed soil by randomly scattering and spreading slash to replace scraped material. Cover exposed bare soil with adjacent organic material when/where possible. Where feasible, construction of skid trails should avoid creating straight line corridors when the skid trails connect with open system roads and 'trails. Skid trails will be held to the minimum number, width, and length necessary to complete the project. Projects will be designed with the goal of minimizing skid trail length. Treatment units that already have off--road impacts and or the potential for new and increased off--road vehicular use should be protected by creating a buffer zone between the road and the treatment area where practical. Buffer zones should be deep enough, where practical, to discourage attempts at creating new routes. Possible ORV travel corridors will be physically blocked to prevent exploratory use. In roadless areas where mechanical treatment or mechanical preparation is required, use the minimal amount and type of equipment necessary;-as feasible, to accomplish the treatment goals. If and where wheeled or tracked equipment is used, measures should will be taken to rehabilitate any ground disturbance from such use. Vegetative buffers will be maintained adjacent to intermittent or perennial drainages and wetlands . and any impacts to intermittent or perennial drainages and wetlands will be avoided. Recommendation 10. - Add the following PDC tothe EA and any final Decision to ensure mapping of recreational impacts on wildlife and wildlife habitat occurs and consideration of wildlife habitat in the construction of any trails on the south side of Smuggler Mountain. The following PDC should be added to the EA: "Impacts (including mapping of edge effects, habitat fragmentation, the zone ofdisturbance and wildlife displacement) of proposed and existing roads and trails will be mapped and quantified to determine impacts to wildlife and wildlife habitat and inform projects proposed under this EA and Decision." "Prior to and following any new trail approval on the south side of Smuggler Mountain, the Forest Service shall evaluate the impacts of that trail on wildlife populations and habitat and in consultation with Colorado Parks and Wildlife will consider modifications of trail location and management up to and including closure ifimpacts are shown to be significant." Recommendation 11. -- Add the following PDC to the EA and any final Decision to ensure complete projects are evaluated based on whether they achieved stated goals. "Each project will include an evaluation component to assess whether project implementation was conducted as specified and if project objectives are met" "At the conclusion of each project, the assessment of project goals will be shared with the planning team along with recommendations concerning modifications .to and the utility of future projects" "The design and selection of projects will be based in part upon the assessment of the success of previous similar projects" Recommendation 12. - Amend the EA and any final Decision to better specify and prioritize the location of aspen treatments. On page 2-7 ofthe EA following the sentence: "Within the study area, approximately 1,400 acres of aspen stands exist, and the Proposed Action would mechanically treat up to 280 acres of this vegetation type through implementation of patch cuts refer to Figure Add the following text: "The location of aspen projects will be determined based on evaluation and mapping of stand conditions as described below. This evaluation and mapping will occur annually both through consultations with USFS City and County specialists and from relevant and available scientific research seeking to map and evaluate aspen stand conditions with an towards informing management. The 2013 aspen projects that have already been found to have value should be immediately undertaken." Stand conditions used to guide aspen treatment locations: Whether aspen stand age structure is Seral aspen is dependent on fire for regeneration] or Stable aspen is not dependent on fire for regeneration]. Whether aspen stands are converting to con1'fer stands or not. Whether saplings and seedlings are limited or abundant within aspen stands. Whether aspen stands are susceptible to or bujfered from drought stress." Recommendation 13. - Amend the EA and any final Decision to better describe new goals and management prescriptions for vegetation treatments in Lodgepole Pine (LPP). According to the EA, LPP treatments in the project area are intended prevent the spread of the MPB epidemic and increase age class diversity (EA at 1-6). Further, the type and location of LPP treatments (with the exception of prescribed fire) are described only in the context of treating stands that are at--risk to the MPB epidemic (EA at 2-6). Both Forest Service and local studies have concluded that the MPB epidemic is over across the State and that MPB is present at only low endemic levels in the project area. As a result, the goals, criteria for selecting and locating LPP projects, and management prescriptions for LPP projects should be significantly changed. The EA should be amended to address specific goals for LPP treatment eliminating hazard trees, encouraging type replacement to aspen or reducing fuel loads to reduce fire risk to values at risk such as lives, homes, water supplies and important infrastructure) and while treatment methods may remain similar, the criteria for locating and designing treatments need to be more precise and directly related to a specific and demonstrated need within the project area rather than preventing a no longer occurring MPB epidemic. In future projects (not proposed for 2013), additional mapping needs to be undertaken to determine where LPP treatments should occur since the previous goals and criteria lack the relevance they once had. General goals like increasing age-class or overall forest diversity, and.improving wildlife habitat need to be evaluated and ground--truthed to demonstrate whether there is a need for them specifically related to the project area as opposed to a general need across the entire forest. Developing such projects should start with specific problems derived from research and data (eg. are likely to use this area but aren't because there is no suitable snowshoe hare habitat; a lack of fire has created an uncharacteristic LPP age structure throughout the project area) and thoroughly demonstrate how treatments can remedy the issue cutting mature LPP in a location adjacent to suitable habitat will increase snowshoe hare forage; these areas are suitable . for prescribed burns while these areas require mechanical treatment to bring them back into their HRV). To the extent possible in a short time frame the EA, DN, and FONSI should be amended to accurately reflect new information that concludes the MPB epidemic is no longer occurring in Colorado. Some relevant project goals, treatments and management prescriptions that reference the MPB should be removed. At a minimum on page 9 of the DN, following the sentence: "Additionally, the way the analysis was conducted and the PDC developed for implementation addressed some of issues. raised. the following text should be added: "Recent Forest Service research has shown that the MPB epidemic is no longer occurring in some Colorado areas. Due to the shift in MPB populationsfrom epidemic to endemic levels across some of the State and within the project area, some of the goals, criteria for selecting and locating LPP projects, and management prescriptions for LPP projects in the EA need to be revised. As a result of this new research, my decision allows the criteria for locating and designing treatments described in the EA to be changed to more precisely and directly relate to specific and demonstrated needs within the project area rather than management actionsfocused on a no longer occurring MPB epidemic. My decision approves additional mapping and a re- evaluation of goals to determine where LPP treatments should occur since the previous goals and criteria focused on the MPB epidemic lack the relevance they once had. These goals should be re--evaluated and ground-truthed to demonstrate whether there is a need for them specifically related to the project area as opposed to a general need across the entire forest. Projects that result from this re-evaluation should stem from the identification of problems derived from research and data and thoroughly demonstrate how treatments can remedy the issue." Thank you for considering these recommendations. It is our strong belief that incorporation of them into the EA, DN and FONSI will both improve the project and largely resolve Wilderness Workshop's objection letter. I 3 Chris Lane CEO, ACES Gary' Tennenbaum Assistant Director, Pitkin County Open Space and Trails - Stephen Ellsperman Director, City of Aspen Parks Open Space Sloan Shoemaker Executive Director, Wilderness Workshop