HomeMy WebLinkAbout20083219.tiff United States Forest Pawnee 660 "O" Street
USDADepartment of Service National Grassland Greeley,CO 80631
Agriculture Voice: (970)346-5000 TDD: (970)346-5015
Web: www.fs.fed.us/r2/arnf
Fax: (970)346-5014
File Code: 1950
Date: December 2, 2008
Dear Interested Party:
On December 2, 2008, I made a decision to implement Prescribed Fire Management on the
Pawnee National Grassland (PNG). Under this decision the PNG will manage for a 10 to 35 year
fire frequency rate, with a maximum of 6,000 acres burned annually. Treatments will be applied
from late winter through early spring (no later than April 10th). Several areas will be excluded
from prescribed fire. No more than one-third of any one grazing allotment will be burned in any
one year and generally, no pasture will be burned more often than one out of every 10 years.
Mitigation measures and design criteria will be applied to this alternative to address the key
issues. Monitoring for treatment effectiveness is identified in the decision.
I have included a copy of the Decision Notice with the Forest Service Response to Comments
included in Appendix C. The Decision Notice is also available at the Pawnee National Grassland
Office at 660 "O" Street in Greeley, CO, at the Forest Supervisor's Office at 2150 Centre
Avenue in Fort Collins, CO or is available on the web at http://www.fs.fed.us/r2/amf/projects/ea-
projects/png/prescribedfire/index.shtml. To obtain additional hard copies of the Decision Notice,
a copy of the Decision Notice on CD ROM, or to obtain additional information, please contact
Beth Humphrey at (970) 346-5004, or via email at ehumplu-ey@fs.fed.us.
My decision is subject to appeal, under Forest Service Regulation 36 Code of Federal
Regulations Part 215, or under 36 Code of Federal Regulations Part 251, Subpart C. 36 CFR 215
appeals must be filed within 45 days from the publication date of the decision legal notice in the
Greeley Tribune, the newspaper of record. 36 CFR 251 appeals must be filed within 45 days
following the date on the Decision Notice. Appeals received after the 45 day appeal period will
not be considered. The appeal opportunities are described fully in the Decision Notice.
Thank you for providing comments on the Environmental Assessment for Prescribed Fire
Management on the Pawnee National Grassland. If you have questions about the Decision
Notice,please contact us at (970) 346-5000.
Sincerely,
/
`+
LORI A. BELL
District Ranger
Enclosure
(///� l c = / 0yet) 04
�c� 'k(rrnl X4�-S Caring for the Land and Serving People 2008-3219
/-R —e"S—O5"
Prescribed Fire Management on the Pawnee National
Grassland
DECISION NOTICE
FINDING OF NO SIGNIFICANT IMPACT
USDA, Forest Service
Pawnee National Grassland
Weld County, Colorado
Background
The Pawnee National Grassland (PNG) is located in northeast Weld County, approximately 35
miles northeast of Greeley, Colorado. The PNG is approximately 193,000 acres of National
Forest System land intermingled with privately owned farms and ranches, and Colorado State
lands (See Vicinity Map in Appendix A).
Prescribed burning on the Pawnee National Grassland began in 1994 when 90 acres were burned
on the Wildhorse Allotment in the Crow Valley Unit. This bum was designed as a
demonstration project and was evaluated to determine the effect it had on certain aspects related
to the short-grass prairie ecosystem and the role of fire in the short-grass prairie. The project
objectives included the following:
1. Evaluate habitat effectiveness for mountain plover, a Forest Service Sensitive bird
species and a management indicator species for short-grass prairie;
2. Monitor vegetative composition;
3. Evaluate visibility and effects of fire on heritage resources.
The demonstration project was considered to be successful and prescribed fire was further
evaluated as a tool for management of mountain plover through the NEPA process. A Decision
Memo was signed for the "Prescribed Fire Program for Mountain Plover Habitat Effectiveness"
on February 6, 1997 and February 2, 1999. These decisions were also amended on January 30,
2002 and April 12, 2004 to add additional burn acreage. A final amendment dated January 5,
2005, was signed allowing the PNG to use prescribed fire to manage vegetation and fuels to
reduce the risk of wildland fire intensity and rate of spread.
Since the prescribed fire program began in 1994, approximately 35,000 acres have been burned.
Purpose and Need for the Decision
The purpose of this project is to develop and implement prescribed fire management strategies to
achieve the following:
1
• Manage vegetation to provide for wildlife habitat
• Promote diversity in vegetation type, structure, composition and successional stages
• Reintroduce natural disturbance (e.g. natural fire)
• Improve rangeland forage
• Reduce grassland fuel hazards
The following needs were identified for this project:
There is a need to improve and maintain shortgrass prairie wildlife habitat by managing for a
mosaic of grassland vegetation structure and successional stages. The PNG supports a diverse
array of native wildlife, native plant species and important habitats. Many species of wildlife are
dependent upon short-grass steppe habitat that was once maintained or created by fire and
grazing by wild ungulates and other species, such as bison and prairie dogs. In addition, the
interactions on the shortgrass steppe, such as those between wildlife, climate, and plant structure
are complex. Many species co-evolved with, and are dependent on fire and grazing by large
ungulates. Habitat for many PNG wildlife species is provided or maintained by these
interactions within the shortgrass steppe. There are a variety of tools that can be used to provide
a mosaic of plant communities across the PNG representing early to late seral stages and low to
high vegetation structure, to promote short structure in upland areas that provide habitat for
mountain plover and other shortgrass-dependent species, and to provide the mix of vegetative
communities and structures that will meet the needs of low structure dependent species such as
the mountain plover, prairie dog, and swift fox, and also meet the needs of taller structure
dependent species such as the lark bunting.
There is a need to mimic the historic fire regime on the PNG. In contrast to the past, naturally
occurring fires are extremely limited in size and frequency because active suppression begins
immediately and contains them. Historically, natural disturbances such as fire, wind, drought,
and impacts from American bison and black-tailed prairie dogs promoted a "complex pattern of
distinct patches of grasses and forbs" on shortgrass steppe. Of all these natural disturbances, fire
was perhaps the most important ecological process prior to European settlement. Historic fires
occurred every 3 to 35 years, following cycles of moisture, low level to moderate drought, and
patterns of bison grazing. Prescribed fire can be used to mimic the frequency of natural
occurring fires of the past.
There is a need to improve the palatability and nutritional value of forage for livestock and
wildlife. Some crested wheat pastures are becoming decadent, rank, and less palatable for
livestock grazing. Prickly pear cactus is increasing in certain places and is reducing desirable
forage for livestock and wildlife.
There is a need to reduce grassland fuels to minimize the risk of wildfires on and off private and
State lands adjacent to the PNG. Although reduction in grassland fuels is generally considered to
be short lived, it can and has been used in some situations to reduce and modify the vegetative
structures of grassland fuels. This use minimizes the risk of wildfires spreading to or from
adjacent private and state lands and can be used to aid firefighting resources in controlling
wildfires more efficiently.
2
Decision
Based upon my review of the Environmental Assessment (EA), public comments, and
information contained in the project record, I have decided to implement Alternative C —
Modification of Current Management with several minor modifications.
This decision resembles current prescribed fire management on the PNG, with an expansion of
the vegetation structure types where burning is allowed, identification of specific areas where
burning is not allowed, modification of when burning is allowed, and establishment of burn
frequencies and an upper limit of acreage burned.
This decision applies prescribed fire at a frequency rate of approximately every 10 to 35 years,
with a maximum of 6,000 acres burned annually. Treatments will be applied from late winter
through early spring(no later than April 10th). I have made this minor modification to provide
greater flexibility in achieving the purposes of this project. This change is within the scope of
the alternatives and analysis of Alternative B clearly showed that prescribed fire could be
implemented through a greater part of the year without adverse affects on the environment. I do
not expect these changes to greatly change implementation of the prescribed fire projects as the
vast majority of burns have occurred in March. I expect this trend to continue due to limitations
of burn windows. Mitigation measures and design criteria, as described in Appendix B would be
applied to this alternative to address the key issues. I have provided some clarification to the
mitigation measures. No more than one-third of any one grazing allotment will be burned in any
one year and generally, no pasture will be burned more often than one out of every 10 years.
Table 1 summarizes how the decision will be applied.
TABLE I: RANGES OF ACRES BURNED,FIRE FREQUENCY,AND SEASONALITY OF BURNING
APPLICATION MODIFIED ACTION ALTERNATIVE C
Acres Burned Annually 0 to 6,000 acres
Short Structure annual acres burned Up to 6,000 acres
Short Structure burn frequency Generally every 30 years;
For select locations every 20 to 30 years
Mid to Tall Structure annual acres burned Up to 6,000 acres
Mid to Tall Structure burn frequency Generally every 30 years;
For select locations: every 10 to 15 years
Riparian Structure*annual acres burned Up to 80 acres
Riparian Structure burn frequency Every 10 to 35 years
Riparian Buffer*annual acres burned Up to 60 acres
Short, Mid to tall and Riparian structure and Riparian Late winter through early spring (no later than April I Om);
Buffers: avoid burning in mid to tall structure after March I".
Burn Season
*Riparian Structure on the PNG refers to perennial stream corridors,wet meadows,willow bottoms,and perennial potholes.
**Riparian Buffers are 100 ft.on both sides of perennial streams.
Several areas will be excluded from prescribed fire. These locations and the justification for
their exclusion are documented in Table 2 below:
3
Table 2: Locations Excluded From Prescribed Fire.
LOCATION JUSTIFICATION
Chalk Bluffs Unique geological features; raptor nesting, Forest Plan Management Area 3.61;
OHV recreation area
Dave's Draw Rare or unique biological features and species; Forest Plan Management Area 3.61
Indian Caves RNA, Little Owl Forest Plan Management Area 2.2
RNA& Keota RNA
Portions of Pawnee Buttes SIA Forest Plan Management Area 3.1
Crow Valley Recreation Site Forest Plan Management Area 8.21, Developed recreation structures and features
1/4 Mile from Missile Silos Co-jurisdictional military installations managed with a Memorandum of
Understanding.
Within ''/ mile of the town of New I have made this minor modification to respond to comments received that
Raymer identified concerns with the smoke emissions, the risk of escaped fires, and the
potential risk to adjacent property.
Within '/: mile of any occupied I have made this minor modification to respond to comments received that
dwelling identified concerns with smoke emissions, the risk of escaped fires, and the
potential risk to adjacent property.
The following monitoring and evaluation will be done to help verify that assumptions made in
the planning process are valid. Monitoring and evaluation will help determine if implementation
is achieving desired conditions within the appropriate timeframes.
Table 3: Monitoring For Treatment Effectiveness.
ITEM TO BE RESPONSIBILITY TIMING OF OBJECTIVE FOR MONITORING
MONITORED MONITORING
Effects to Soil, Soil Scientist, Prior to and following To evaluate soil erosion, sedimentation, and
Watershed & Rangeland project implementation long term vegetation change.
Vegetation Management
Specialist, Botanist
and/or Hydrologist
Effects to Rangeland Rangeland Prior to and following To evaluate changes in rangeland forage and
Forage and four- Management project implementation four-wing saltbush.
wing saltbush Specialist
Effects to Mountain Wildlife Biologist Following project To evaluate preference and use of burned
Plover Nest Habitat implementation. areas for nesting habitat.
Effects to Mountain Wildlife Biologist Following project To evaluate reproductive success for
Plover Population implementation. mountain plover and long-term trends.
and Habitat Trends
Effects to Noxious Rangeland Prior to and following To evaluate infestation of burned acreage
Weeds Management Project implementation.
Specialist, Botanist
Decision Rationale
In making my decision I first considered the alternatives in the context of the purpose and need.
I again reviewed the alternatives eliminated from further consideration, including livestock
grazing. I agree that some of the objectives for this project such as maintenance and
4
improvement of shortgrass prairie wildlife habitat, maintenance and improvement in palatability
and nutritional value of forage, and reduced grassland fuels, can be achieved through livestock
grazing. Alternately, I do not believe that livestock grazing fully meets the purpose and need to
mimic the historic fire regime on the PNG. Based on this and the fact that livestock grazing on
the PNG has been analyzed in depth in recent environmental assessments, I agree that livestock
grazing should not be considered further as an alternative to meet the purpose and need for this
project.
I selected Alternative C with modifications because it best meets the purpose and need while
responding to the key issues. I seriously considered the issues raised by the Crow Valley and
Pawnee Grazing Associations, Weld County Commissioners and the public in making my
decision to select Alternative C with modifications. Several of these commenters had serious
concerns raised about the potential economic effects of utilizing prescribed fire on the Pawnee
and especially about increasing the acreage burned annually. The analysis documented in the
Environmental Assessment and project record indicated that the amount of area burned could be
increased with a minimal impact. However, the analysis also indicated that the purpose and need
for the project could be met with Alternative C. Therefore, I determined that the alternative that
best meets the purpose and need for the project and also best addresses the issues raised by the
public (p. 11-12 of EA) is Alternative C with modifications.
Other Alternatives Considered
Three alternatives were considered in detail for this EA including a"no action" alternative and
two action alternatives.
Alternative A - No Action
This Alternative would end the current use of prescribed fire. No prescribed fire activities would
be implemented if Alternative A is chosen. This alternative is used as a baseline against which
to compare the other alternatives. This alternative complies with 40 CFR 1502.14(d), which
requires that a no action alternative be included in the analysis.
Alternative B — Proposed Action
This alternative would apply prescribed fire to 184,000 acres of the PNG every 10 to 35 years.
Achieving this fire interval would require burning 8,000 to 12,000 acres annually, with different
acreages targeted for each of the structure classes: short, mid to tall, and riparian. Mitigation
measures and design criteria, as described in Appendix B would be applied to this alternative to
address the key issues.
Alternatives Considered but Eliminated from Detailed Study
Six other alternatives were considered but eliminated from detailed study. They include 1)
Livestock Grazing, 2) Mowing, 3) Burning Short Structure Only, 4) Burning Short and Mid To
Tall Structure Vegetation Only, 5) Burning Short Structure and Riparian Areas Only, and 6)
5
Burning At Very Short Fire Return Intervals (Every 3 To 10 Years) in Mid to Tall Structure
Vegetation Only
Public Involvement
The public was invited to participate in the project in the following ways:
June 5, 2006: A scoping letter was sent to approximately 246 individuals, organizations, local,
federal and state governments, tribes, and cooperating resource agencies announcing the project
purpose and need, along with an outline of the proposed action. It announced a public open
house scheduled for June 22, 2006 and the scoping period deadline of July 3, 2006. Fifteen
comments to this scoping letter were received.
June 15, 2006: A press release for the public meeting was sent to the Denver television markets
(five stations); Denver, Fort Collins, and Greeley radio stations (seven stations), and northern
Colorado newspapers (seven dailies, nine weekly or monthly papers). It announced the purpose
and need, along with an outline of the proposed action. It announced a public open house
scheduled for June 22, 2006 and the scoping period deadline of July 3, 2006. The Greeley
Tribune,Loveland Reporter-Herald, and the Fort Collins Coloradoan all ran the meeting
announcement. Later, the Greeley Tribune wrote a follow-up story on the project.
June 22, 2006: An open house was held in Ault, Colorado. Several members of the
interdisciplinary team were there to answer questions and describe the purpose, need, and
proposed action. Maps were displayed outlining the proposed action. Handouts and maps
detailing the proposed action were made available to those attending, along with the scoping
letter and comment forms. Nine members of the public attended.
October 15, 2007: A meeting was held with local ranchers to provide an opportunity for the
grazing associations to discuss their concerns with prescribed burning on the PNG. This meeting
was an effort by the PNG to solicit further comments and concerns, and to answer questions
about the use of prescribed fire on the Grassland. Nine members of both the Pawnee and Crow
Valley Grazing Associations attended and comments were recorded in meeting notes which were
made a part of the project record.
July 15, 2008: The environmental assessment was completed and made available for public
review. It was available through the website for the Arapaho and Roosevelt National Forests and
Pawnee National Grassland, by hard copy, or on compact disk. The official comment period
ended on August 15, 2008. A letter was sent out to approximately 260 individuals,
organizations, federal, local and state governments, tribes, and cooperating resource agencies
announcing the availability of the environmental assessment. Two requests for the
environmental assessment were received. Nineteen comments about the environmental
assessment were received, Responses to the comment letters can be found in Appendix C of this
Decision Notice.
6
July 15, 2008: A press release for a public open house was sent to the Denver television markets
(five stations); Denver, Fort Collins, and Greeley radio stations (seven stations), and northern
Colorado newspapers (seven dailies, nine weekly or monthly papers). It announced the
availability of the environmental assessment, invited the public to comment, and the open house
scheduled for July 25, 2008. The Greeley Tribune, Loveland Reporter-Herald, and the Fort
Collins Coloradoan all ran the meeting announcement.
July 25, 2008: An Open House was hosted by the Pawnee National Grassland to provide an
opportunity for the public to ask questions and to provide comments on the environmental
assessment. Forest Service resource specialists were available to answer questions about the
alternatives and analysis in the EA. There were no attendees.
In addition to the above formal comment venues, monthly updates were given at Crow Valley
and Pawnee Grazing Association Board Meetings and annual meetings, and in semi-quarterly
meetings with the Weld County Commissioners.
In addition to the agencies and persons listed on p.104-105 in the EA, Appendix D of this
decision also includes other individuals, organizations, local and state governments, tribes, and
cooperating resource agencies that were consulted during development of this environmental
assessment.
Finding of No Significant Impact
After considering the environmental effects described in the EA, I have determined that these
actions will not have a significant effect on the quality of the human environment considering the
context and intensity of impacts (40 CFR 1508.27). Therefore, an environmental impact
statement will not be prepared. I base my finding on the following points.
Impacts that may be both beneficial and adverse—Impacts associated with Alternative C are
discussed in Chapter 3 of the EA. The actions described in Alternative C will not have a
significant impact on the resources described in Chapter 3 (pp. 22-23, 28-29, 31-34, 35, 38, 43-
44, 46, 50-51, 54-47, 61, 71-72, 76-77, 80, 82-83, 87-88, 92-93, 96-97, 100-103).
Degree of effects to public health and safety - The risk of escaped fire onto private land from
prescribed burning on public land was identified as an issue during the scoping process. Design
criteria for safety are included in Appendix B to address these concerns. I also made minor
modifications to Alternative C that further address public health and safety through the
establishment of buffer zones in which no burning would occur within '// mile of the Town of
New Raymer or any occupied dwellings. In addition, a site specific burn plan will be prepared
for each treatment area prior to treatment. The analysis in the EA indicates that there is a low
risk to public health and safety with implementation of any of the alternatives.
Unique characteristics of the geographic area such as proximity to historic or cultural
resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically
critical areas —The decision will not affect the unique characteristics of park lands, prime
farmlands, wetlands, wild and scenic rivers, or ecologically critical areas. This project is in
7
proximity to historic or cultural resources and has the potential to impact these resources. In
compliance with the National Historic Preservation Act (NHPA), the PNG will not proceed with
ground disturbing activities associated with the decision until a report on these activities and
their potential to affect historic properties is submitted to the Colorado State Historic
Preservation Office (SHPO) in compliance with Section 106 of the NHPA and SHPO concurs
with the determinations of"no historic properties affected." Based upon the identification of
unique or special areas in the Arapaho and Roosevelt National Forest Land and Resource
Management Plan and the application of appropriate mitigation measures and on-site inventories,
I conclude that there will be no significant effects on unique or special resource characteristics.
Degree to which the effects on the quality of the human environment are likely to be highly
controversial—The effects of prescribed fire to the human environment are well documented
and not controversial. However, diverse values and opinions have been expressed. This is a
reflection of diverse values regarding prescribed fire, including the value of native species and
ecosystems in areas where ranching is an important livelihood and opinions as to what actions
should be taken in areas where these values conflict. In a NEPA document, disclosure of
environmental effects is the primary objective. The EA, project record and public comment as a
whole does not indicate a high level of controversy regarding the disclosure of environmental
effects related to prescribed fire.
Degree to which the possible effects on the human environment are highly uncertain or
involve unique or unknown risks —The effects on the human environment due to managing
prescribed fire on the PNG are well known, and do not involve unique or unknown risks. The
PNG has been burning for 14 years with minimal adverse effects as documented in the EA and
project record and the decision calls for continuing with historic levels of prescribed fire.
Degree to which the action may establish a precedent for future actions with significant
effects or represents a decision in principle about a future consideration—The action
adheres to agency regulations and policy for managing and administering prescribed fire on
National Forest System lands. My decision falls within the framework of this regulatory process
and would therefore not establish any new precedents or principles for decisions involving
significant effects.
Whether the action is related to other actions with individually insignificant but
cumulatively significant impacts—The EA included analysis of cumulative effects or impacts
from past, present, and reasonably foreseeable future actions in Chapter 3. It was concluded that
the action would not result in any significant impacts to the environment. I find that the analyses
were accurate and based on reasonable consideration of cumulative impacts.
Degree to which the action may adversely affect districts, sites, highways, structures, or
objects listed in or eligible for listing in the National Register of Historic Places or may
cause loss or destruction of significant scientific, cultural, or historical resources—The
proposed action will have no significant adverse effect on districts, sites, highways, structures, or
objects listed in, or eligible for listing, in the National Register of Historic Places. In compliance
with the National Historic Preservation Act (NHPA), the PNG would not proceed with ground
disturbing activites associated with the decision until a report on these activities and their
8
potential to affect historic properties is submitted to the Colorado State Historic Preservation
Office (SHPO) in compliance with Section 106 of the NHPA and SHPO concurs with the
determinations of"no historic properties affected."
Degree to which the action may adversely affect an endangered or threatened species or its
habitat that has been determined to be critical under the Endangered Species Act of 1973 —
The project included full consideration of federally listed threatened and endangered species in
the EA, Botany and Wildlife Specialist Reports. Four threatened and four endangered species
were considered in the analysis. None of the eight species would be affected by the decision,
since they do not occur or they are rare migrants on the PNG.
Whether the action threatens a violation of Federal, State, or local law or requirement
imposed for the protection of the environment—The activities of this project would not
violate federal, state, or local laws enacted for the protection of the environment. The decision
meets the requirements of the Clean Air Act (1990), the Clean Water Act(1972), the Endangered
Species Act (1973, as amended), the National Forest Management Act (1976), the Multiple Use-
Sustained Yield Act of 1960, the National Environmental Policy Act (1969) and the National
Historic Preservation Act (1966 as amended).
Findings Required by Other Laws and Regulations
I have concluded that my decision is in compliance with current laws, regulations, and policies.
I have reviewed the Prescribed Fire EA and Project File and find that documentation and
procedures required for the management of prescribed fire on the PNG satisfy the requirements
of applicable environmental laws.
I have reviewed the Forest Plan and determined that this decision is consistent with the Forest
Plan goals and objectives (Forest Plan, Chapter One). The action in this project complies with
the Forest Plan Chapter One, Management Direction for Management Areas 2.2, 3.1, 3.61, 4.2,
4.3, 6.4, 6.6, and 8.21, and the Forest-wide Operational Goals, Standards, and Guidelines. I have
also reviewed Chapter 4, Environmental Consequences, of the Final Environmental Impact
Statement (FEIS) for the Forest Plan, and conclude that the environmental effects associated with
this project are consistent with those described in the FEIS.
Environmental Justice: In accordance with Executive Order 12898, I have determined this
project will not have a disproportionately adverse health or environmental effect on low income
or minority populations.
Energy Requirements and Conservation Potential of Alternatives: The energy required to
implement this decision in terms of petroleum products will be insignificant when viewed in
light of the production costs and effects of the national and worldwide petroleum reserves.
Invasive Species Executive Order 13112 of February 3, 1999: The analysis indicates that there
is some potential for prescribed fire to increase occurrences of noxious weeds. This will be
9
mitigated by implementing the following design criteria: (1) Spray, physically remove or use
bio-control methods prior to and/or following a prescribed burn to treat noxious plants; (2)
Survey burned areas for several years following the prescribed burn to look for and treat new
infestations. By implementing these design criteria, this decision is in compliance with the
Executive Order.
Implementation
Pursuant to 36 CFR Part 215, if no appeal is filed within the 45 day time period,
implementation of this decision may occur on, but not before, 5 business days from the close of
the apeal filing period. If an appeal is received, implementation may occur on, but not before,
the 15` business day following the date of the last appeal disposition.
Pursuant to 36 CFR Part 251 Subpart C, if no appeal is filed, implementation of this decision
may occur on, but not before, 5 business days from the close of the appeal filing period. If an
appeal is received, implementation may occur during the appeal process, unless the Reviewing
Officer grants a stay(§251.91).
Administrative Review or Appeal Opportunities
This decision is subject to administrative review (appeal) pursuant to 36 Code of Federal
Regulations (CFR) Part 215. This decision is also subject to administrative review under 36
CFR Part 251 Subpart C by term grazing permit holders, grazing agreement holders or applicants
(§251.86). However, term grazing permit holders, grazing agreement holders, or applicants must
choose to appeal under either 36 CFR 251 or 215, but not both (§251.85).
Notices of Appeal that do not meet the content requirements of 36 CFR 215.14 or 36 CFR
251.90 as appropriate will be dismissed.
Appeals filed under 36 CFR Part 215
Appeals filed under 36 CFR, Part 215, must be filed (regular mail, fax, email, hand-delivery, or
express delivery) with the Appeal Deciding Officer at the address shown below.
The office business hours for those submitting hand-delivered appeals are: 8:00 a.m. -4:30 p.m.,
Monday through Friday, excluding holidays. Electronic appeals must be submitted in a format
such as an email message, rich text format (.rtf), or Word (.doc) to the e-mail address shown
below. In cases where no identifiable name is attached to an electronic message, a verification of
identity will be required. A scanned signature is one way to provide verification.
Appeals, including attachments, must be filed within 45 days from the publication date of the
decision legal notice in the Greeley Tribune, the newspaper of record. Appeals received after the
45 day appeal period will not be considered. The publication date in the Greeley Tribune,
newspaper of record, is the exclusive means for calculating the time to file an appeal. Those
10
wishing to appeal this decision should not rely upon dates or timeframe information provided by
any other source.
An appeal may be filed by any person, or any non-federal organization or entity that provided
comments or otherwise expressed interest in this Proposed Action by the close of the 30 day
Environmental Assessment comment period.
Where to File a 36 CFR 215 Appeal
Mail:
USDA Forest Service
Rocky Mountain Region
Attn: Appeal Deciding Officer
PO Box 25127
Lakewood, CO 80225
Fax: (303) 275-5134
Delivery:
USDA Forest Service
Rocky Mountain Region
Attn: Appeal Deciding Officer
740 Simms Street
Golden, CO 80401-4720
Hours: Mon-Fri 7:30 am —4:30 pm
Email: appeals-rocky-mountain-regional-
office@fs.fed.us
Appeals filed under 36 CFR Part 251 Subpart C
Appeals filed under 36 CFR Part 251 Subpart C (including attachments) must be in writing and
filed with the Reviewing Officer within 45 days following the date on the notice of the written
decision (§251.88). Attachments received after the 45 day appeal period will not be considered.
It is an appellant's responsibility to provide sufficient activity-specific evidence and rationale,
focusing on the decision, to show why the Deciding Officer's decision should be reversed
(§251.90). The Deciding Officer is willing to meet with applicants and holders to hear and
discuss any concerns or issues related to the decision (§251.93).
Appeals filed under 36 CFR 251 Subpart C must have a copy of the appeal simultaneously sent
to the Deciding Officer (§251.88). An appellant may also include in the notice of appeal a
request for oral presentation (§251.97) or a request for stay of implementation of the decision
pending decision on the appeal (§251.91).
11
Where to File a 36 CFR 251 Appeal
Mail or Delivery only:
USDA Forest Service
Appeal Reviewing Officer
Arapaho and Roosevelt National Forests and
Pawnee National Grassland
Supervisor's Office
Attention: Forest Supervisor
2150 Centre Ave., Bldg. E
Ft. Collins, CO 80526
Fax: (303) 295-6696
Simultaneously send a copy of the appeal to:
USDA Forest Service
Deciding Officer
Pawnee National Grassland
Attn: Lori Bell, District Ranger
660 O Street
Greeley, CO 80631
Fax: (970) 346-5014
Hours: Mon-Fri 7:30 am —4:30 pm
When an appeal is electronically mailed, the appellant should receive an automated electronic
acknowledgement of agency receipt. If the appellant does not receive electronic confirmation of
receipt, it is the appellant's responsibility to ensure timely receipt of the appeal by other means
[CFR 215.15 (c) (3)].
It is the appellant's responsibility to provide sufficient project or activity specific evidence and
rationale, focusing on the decision, to show why the Responsible Official's decision should be
reversed [CFR 215.14 (a)]. At a minimum, the appeal must include the following:
1. Appellant's name and address. Please include telephone number if available.
2. Signature or other verification of authorship upon request.
3. When multiple names are listed on the appeal, identification of the lead appellant and
verification of the identity of the lead appellant upon request.
4. The name of the project for which this decision is made, the name and title of the
Responsible Official, and the date of this decision.
5. The regulation under which the appeal is being filed.
6. Any specific change(s) in this decision that the appellant seeks and rationale for those
changes.
7. Any portion(s) of this decision with which the appellant disagrees, and explanation for
the disagreement.
8. Why the appellant believes the Responsible Official's decision failed to consider the
substantive comments.
9. How the appellant believes this decision specifically violates law, regulation, or policy.
12
Contact
For additional information concerning this decision or the Forest Service appeal process, contact:
Beth Humphrey
Pawnee National Grassland
660 "O" Street
Greeley, CO 80631
ph. # (970) 346-5004
e-mail: eumphrey@fs.fed.us
Responsible Official
LORI A. BELL Date
District Ranger
Pawnee National Grassland
The U.S. Department of Agriculture (USDA) prohibits discrimination in all its
programs and activities on the basis of race, color, national origin, gender, religion.
age, disability, political beliefs, sexual orientation, or marital or family status. (Not all
prohibited bases apply to all programs.) Persons with disabilities who require
alternative means for communication of program information (Braille, large print,
audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice
and TDD). To file a complaint of discrimination, write USDA, Director, Office of Civil
Rights, Room 326-W, Whitten Building, 14th and Independence Avenue, SW,
Washington, DC 20250-9410 or call (202) 720-5964 (voice and TDD). USDA is an
equal opportunity provider and employer.
13
APPENDIX A
Vicinity Map
Environmental Assessment: Prescribed Fire Management on the
Pawnee National Grassland
14
E _ 111
•
I - O
Y u
v _ I. (2
1.6 • - n
L
o
HP
Or I
O ��
m Z
Lr
1 I � II
V d � zi
N I m - L
O m 3)
CI
i
H
U. ai.
O
Z I --,'
•L C _
0 gm.en CL
0. A+ o
^^,, W O^W
)
�&
a
C �e
a
w
C0m
\V IS
I 1
- -17 -
MI
r
in
m I r
13
13 _
I
L
N { , - s i I
jr _
:12
O
To 03
O Nt73 iz p
z 0
O.
N w a _I
TD o t 7' a co 465 o z W
E = ll1i"JjI
bill
mCe o0tdg6
a a N N CO Q ,��I— WI c a i t III-
LL o v a v �'�' y 6 � g g
Oco et W I — N m , �°
I Tr, Jts) o
1;11111
l
r mill,
APPENDIX B
Mitigation Measures, Design Criteria and Best Management Practices
Environmental Assessment: Prescribed Fire Management on the
Pawnee National Grassland
The following mitigation measures and design criteria are an important part of the
environmental effects analysis. These elements are necessary to ensure that implementation of
the Pawnee Prescribed Fire Project complies with the Best Management Practices, Forest
Service Handbook and Manual, laws, policies and the Forest Plan standards and guidelines.
Specific Best Management Practices directly applicable to the action alternatives are found in
the respective Specialist Reports as part of the Project File.
The intent of mitigation measures and design criteria are to reduce or eliminate the
environmental impacts related to project actions. These measures and criteria may be
incorporated into implementation phases for the various activities. They are applicable to any
action alternative selected. The officials responsible for ensuring that all mitigation measures
and design criteria are met during project implementation are noted in parentheses following
the individual mitigating actions.
General
o Use wet-line or other control techniques to control fire spread and protect excluded features
(Burn Boss)
Cultural Resources
o Inventory all proposed burn areas, hand and machine constructed control lines for cultural
resources prior to project implementation, in consultation with the Colorado State Historic
Preservation Office and Native American Tribes, and in compliance with the National
Historic Preservation Act. (Archaeologist)
o Flag, map and avoid all historic properties within or near burn units prior to
implementation.
Invasive Plants
o Spray, physically remove or use bio-control methods prior to and/or following a prescribed
burn to treat noxious plants. (Rangeland Management Specialist)
o Survey burned areas for several years following the prescribed burn to look for and treat
new infestations.
o Selection of burned areas will take into consideration cheatgrass infestations.
15
Range
o Notify both grazing associations, no later than their annual meeting dates, of the specific
locations planned to be burned during the subsequent year, to facilitate the preparation of
grazing rotations and determine permitted livestock numbers for each allotment. (Rangeland
Management Specialist)
Watershed Resources
o Burn up to 15% of riparian buffer or stream length to revitalize riparian shrubs, while
reducing the impacts to riparian features and fish species. (Hydrologist and Burn Boss).
Riparian features are riparian vegetation, soils, and filtering capability of the riparian buffer
to protect water quality from sedimentation.
o Wet line or black line around gullies and rill erosion areas to protect them from
exacerbation of water and wind erosion. (Burn Boss) Prior to implementation of the annual
fire plan a field review would be conducted by the Soils Scientist or Hydrologist or their
representative to determine if there are any gullies or rill erosion areas of concern in the area
that need a buffer. (Hydrologist or Soils Scientist)
o Wet line or black line around any riparian vegetation structure areas if the areas are deemed
too sensitive to be burned that year. (Burn Boss and Soils Scientist or Hydrologist)
o Avoid prescribed burning when the Palmer Drought Severity Index is -2.00 or lower
(moderate to extreme drought conditions) or when the U.S. Drought Monitor is rated at D1
(Drought-moderate) or higher. These indices need to be checked within a week of the
prescribed burn operations. (Hydrologist, Soil Scientist, Burn Boss, and Fuels Specialist)
o Do not conduct prescribed burning when soil moisture within the upper root horizon is
approaching permanent wilting point. Soil in the upper horizons should be at or
approaching field capacity; i.e. damp (moist to touch without free water), but not wet
(excess water is voided when soil is squeezed in hand). Soil moisture tests, field capacity
tests, or other measuring techniques and equipment may be used to determine soil moisture
content. (Soil Scientist and Burn Boss)
o Utilize forward and flanking fire spread, but limit the amount of backing fire spread, to
retain cottonwoods, limit the exposure of riparian features to fire, limit wind and water
erosion, while revitalizing riparian shrubs along perennial and intermittent stream corridors,
wet meadows, willow bottoms, perennial potholes, and playas. (Burn Boss)
o Establish a 100 foot wide riparian buffer along perennial streams, and utilize forward and
flanking fire spread, but limit the amount of backing fire spread, to retain cottonwoods,
limit the exposure of riparian features to fire, limit wind and water erosion, while
revitalizing riparian shrubs. (Burn Boss)
o Following the annual prescribed burn, field review burn units to determine watershed
impacts. The Soil Scientist or Hydrologist or their representative would conduct this
monitoring. If impacts are unacceptable, determine if further design criteria or mitigation
measures are in order.
16
Wildlife, Fish and Rare Plants
Ground-Nesting Birds
o If prescribed burning is done during the breeding season of ground-nesting birds
(between March 1 and July 10 each year), then a wildlife biologist will confirm that
birds have not started to nest in areas to be burned.
Raptors
o A pre-burn check will be completed to determine whether raptors are present at nest-
sites within and adjacent to the burn blocks. If hawks are present at nest sites, a 250-
foot buffer will be placed around the trees and no burning or other disturbance would
occur within the buffer zone.
o If burning occurs between March 1 and June 30, a biologist must confirm that birds
have not started to nest in areas proposed for burning. If nesting activity has started, a
mile buffer will be placed around the nest site and no burning or other disturbance
related to prescribed burning would occur within the buffer zone.
o Known raptor nest sites within and adjacent to proposed burn blocks will be protected
from burning using a wetline or other fireline construction around the nest site.
Loggerhead Shrike
o Protect known nest trees and shrubs from destruction by fire.
o Preserve tall grasses, shrubs, and other vegetation along fencelines and other areas
within 200 yards of known nest trees.
o Preserve hedgerows and windbreaks.
Northern Leopard Frog
o A buffer zone a minimum of 200 meters wide will be established around ponds where
northern leopard frogs are known to occur. No activities associated with prescribed
burning would be allowed to occur within this buffer zone.
o Water quality will be protected wherever open water occurs. No release of water from
engines or other sources will occur into existing water sources. Where engines or water
tanks need to be drained, it will occur away from existing water sources in areas with no
potential to reach above-ground water sources.
Fringed Myotis
o Any large tree greater than or equal to 30 cm DBH (on the PNG, these are usually
cottonwood or willow trees, but there are a few ponderosa pine, limber pine,juniper,
and spruce trees and snags that provide potential roost sites for bats), including dead
and dying trees, would be protected from burning by using a wet line or other control
technique to protect the roost site.
o If a roost is identified on the PNG, prescribed burning should not occur within a 0.25
mile radius of the roost. If the roost is not occupied, a buffer zone of 500 feet around
the roost entrances will be applied (Keinath 2004).
o If a roost site is found on the PNG, wetland habitats within a 2.0 mile radius of the roost
will not be burned while the roost site is occupied.
Rare Plants
o Selection of burned areas will take into consideration rare plant communities.
17
Global Warming Comment
APPENDIX C
Response to Comments
Environmental Assessment: Prescribed Fire Management on the
Pawnee National Grassland
Nineteen comment letters about the environmental assessment were received. Each of these letters
was analyzed in depth and divided to address individual points made by the commenter. The
following table lists the commenter,who they are representing, and their commenter number.
COMMENTOR# COMPANY NAME
1 Wendell Funk
2 John Leone
Northern Cheyenne Tribe
Tribal Historic Preservation
3 Office Conrad Fisher
Pawnee Pioneer Trails Scenic
4 By-way Barbara Malaby
5 Frank Burnett, Sherry Burnett
6 Eugene and Sharon Hahn
Audubon Society of Greater
7 Denver Polly Reetz
8 Roger and Peggy Blake
9 Judy May
Colorado Historical Society,
Office of Archaeology and Edward C. Nichols, State Historic
10 historic Preservation Preservation Officer
Allen Diehl, Elmer Diehl, and Mildred
11 Diehl
William H. Jerke, Robert D. Masden,
Weld County, Office of Board David E. Long, William F. Garcia, and
12 of County Commissioner Douglas Rademacher
13 Robert E. Hill
Pawnee Cooperative Grazing
14 Association Gary Dollerschell, Secretary
15 Lazy J Quarter Circle Ranch Doris W. Williams
Congress, 4th District of
16 Colorado Marilyn Musgrave
Crow Valley Livestock
Cooperative, Inc Board of
17 Directors Tom Baur
18 Robert Rohn
19 Ft. Collins Audubon Society Bill Miller
The following is the Forest Service's response to each of the points made in these letters. Many of the
comments were similar and were answered in combination with other commenter's points. Most of
the comments received could be addressed under one of the following categories.
A. LAW,REGULATION AND POLICY
B. KEY ISSUE#1: LOSS OF RANGELAND FORAGE AND VEGETATION DUE TO
COMBINED EFFECTS OF HUMAN AND NATURAL CAUSES.
C. KEY ISSUE#2: LOSS OF SOIL DUE TO THE COMBINED EFFECTS OF HUMAN AND
NATURAL CAUSES
D. KEY ISSUE#3: RISK OF ESCAPED FIRE ONTO PRIVATE LAND FROM PRESCRIBED
BURNING ON PUBLIC LAND.
E. ECONOMIC COSTS/BENEFITS
F. FIRE/FUELS MANAGEMENT
G. WILDLIFE
H. MISCELLANEOUS COMMENTS
19
A. LAW, REGULATION,AND POLICY
COMMENT 17-7: On page 103 it is stated that "No alternative would result in a
disproportionate adverse impact on.....low income individuals." This is offered with no backup
data and we believe it to be false. It is well known that many ranchers are low income
individuals and there may be some forage loss due to burning when it is followed by a low
rainfall period. Surely the possibility of adverse impact warrants at least some discussion.
RESPONSE: There appear to be two concerns voiced in this comment, 1) the impact on
low income individuals, and 2) the loss of forage to burning. According to the economic
effects analysis (pp. 27-29 in the EA), implementation of Alternative C could result in a
loss of range forage up to 100 AUM's, with a benefit to range forage totaling up to 50
AUM's. Thus, the prediction is that no more than 50 AUM's would be lost across the
Grassland as a result of prescribed fire. This loss would be averaged across the Grassland
and would not impact any one individual disproportionately due to the inclusion of the
following decision elements. First, no more than 1/3`d of any single allotment would be
burned in any one year. Second, generally most pastures would not be burned more than
once every 10 years. Further, the rangeland forage and grazing effects analysis (pp. 38-
44 in the EA) states that Alternative C would provide for a long-term gain in forage
production with moderate benefits found for all important rangeland forage species.
Recent research conducted on the Pawnee NG further supports that any loss of forage
resulting from prescribed burning in the late winter would be minimal and may have
neutral or positive consequences for livestock. The exception to this would be burning
following severe drought (Augustine and Milchunas 2008). In the case of severe
drought, mitigation measures included in the decision would be implemented that would
avoid or limit prescribed burning under drought conditions.
COMMENT 10-3: On page 24, Section 3.3, under"Cumulative Effects for all Alternatives,"
we recommend that the EA provide more specific information about the reasonable and
foreseeable cumulative effects of this proposed action. While this statement is accurate, its
generalized nature precludes it from contributing anything meaningful to the understanding of
the cumulative effects of prescribed fires to the cultural resources of the PNG.
RESPONSE: We acknowledge that information provided about reasonable and
foreseeable cumulative effects of this proposed action is generalized in nature. While it
is fairly simple to describe past and current actions in detail, it is much more difficult to
predict what will happen in the future unless a proposal has been received. As a result,
cumulative effects analysis is based on the best information available at the time the
environmental analysis is written. This was the case for this EA. A complete list of
cumulative effects for the project was developed by the interdisciplinary team and was
used for this analysis. This list is included in the project record and is available upon
request.
20
COMMENT 17-6: Page 102 has a statement that there is no "irretrievable commitment of
resources". There is plenty of evidence that there is at least a short term loss of forage when
there is drought following the burn. Thus the statement is not correct.
RESPONSE: "Irretrievable" as applied in the EA relates to "losses of production or use
of renewable resources for a period of time." Irretrievable in this context relates to a land
use decision that, once executed, cannot be changed. Although there may be a short term
irretrievable reduction or loss of forage immediately following prescribed burning, and
conversely, the effects analysis for Alternative C for rangeland forage and livestock (pp.
38-44 in the EA) indicates that over time, forage production would show long-term gains.
COMMENT 16-4: Finally, it has come to my attention that local ranchers would like
additional time to study the EA and prepare an appropriate response. I request that the Forest
Service allow additional time for stakeholders to better understand the issues involved.
RESPONSE: Extending the 30-day comment period for this environmental assessment
was not necessary. We received comment letters from both grazing associations and
numerous individual ranchers by the comment deadline. In addition there have been
several opportunities for stakeholders to provide us their concerns. As described in the
EA, Section 1.8 Scoping and Public Involvement, pp. 10 -11, and in the Decision Notice,
we have provided stakeholders multiple opportunities to ask questions and to voice their
concerns. Based on these efforts and responses from our stakeholders, there did not
appear to be a need to extend the comment period.
COMMENT 7-11: If burning is instituted on the scale described in Alternative B, Forest
Service staff will need to monitor the impacts closely, especially for riparian areas and playas.
Including a proposed schedule for the monitoring work would allay some concerns about the
condition of riparian areas after burning.
RESPONSE: Monitoring will be required for any action alternative. Section 2.4
Monitoring and Evaluation of the EA, p. 16, illustrates how monitoring and evaluation
will be used to determine whether implementation of Alternative C is achieving desired
conditions within the appropriate timeframes, including areas characterized as riparian
and playas.
B. KEY ISSUE#1: LOSS OF RANGELAND FORAGE AND VEGETATION DUE TO
COMBINED EFFECTS OF HUMAN AND NATURAL CAUSES.
COMMENT 9-4, 9-5, 13-6, 14-2,: We feel that more damage than good takes place when
burning occurs during these dry times.
RESPONSE: The EA recognizes that the impacts on vegetation and soils are variable
depending on amount of moisture, season burned, and fire intensity (pp. 39-44).
Mitigation measures designed to reduce or eliminate the environmental impacts related to
project actions are included on pp. 107-109 of the EA and in the Decision Notice. These
21
include measures that would avoid or limit prescribed burning during moderate to
extreme drought conditions or when soil moisture is approaching the permanent wilting
point. We expect these criteria to reduce impacts such as soil erosion and slow plant
recovery that would otherwise occur during drought periods.
COMMENT 6-3: The Wharton-Fuss pasture was burned around six years ago and it is still
having a hard time recovering from it. Some of the Four Wing Salt Bush was killed and the
other was badly damaged.
RESPONSE: We recognize that some plants will be killed or damaged as a result of
prescribed fire. The EA addresses your comment in Chapter 3, Section 3.8, pp. 38-44,
and Section 3.16, pp. 88-93. Wright and Bailey(1982) state that southern Great Plains
four-wing saltbush plants are capable of re-sprouting after fire. However, recognizing the
potential sensitivity of four wing saltbush to burning, an effort will be made to exclude
fire in areas managed for this species. The potential for a drastic loss of individual plants
on the PNG is greatly reduced because the genetics of the Great Plains variety of four-
wing saltbush allow for re-sprouting. If experience under this EA shows that the four-
wing saltbush of the PNG is vulnerable to significant loss of individual plants to the point
of eliminating stands, mitigation would be applied to protect it (p. 92) where necessary.
COMMENT 6-4, 11-2: This area of the Pawnee National Grassland is short grass so should
not need to be burned off.
RESPONSE: As described in Chapter 1, Section 1.4 of the EA (p. 8), historic fires
occurred on the short grass steppe every 3 to 35 years prior to European settlement. Fire
is considered to be an important ecological process, but has been extremely limited in
size and frequency in modern times due to active suppression efforts. In combination
with wind, drought, fire, and impacts from native grazers, the short grass steppe,
including the vegetation, soils and wildlife in it have evolved over tens of thousands of
years. Many researchers and scientists believe that the loss or modification of any one of
the processes that influence the short grass steppe can be detrimental to the vegetation,
soils and wildlife that occur here. For this reason, prescribed burning of short grass is
being considered to meet the purpose and need for this project (p. 8-9 of the EA).
COMMENT 7-4: On page 29, under "Fuels" the weight of clippings is given as 392 pounds of
air-dried forage per acre. We assume the clippings were taken from grazed rangeland, but the
EA doesn't specifically say so. Is this an example of fuel loading on grazed or ungrazed
pastures?
RESPONSE: On that year, at that time of the season, the clippings represent average
utilization on grazed pastures, though a small percentage of the samples may have been
clipped on sites that hadn't received any grazing.
COMMENT 18-3: Old grass holds moisture and soil temperatures so we can grow more grass
for livestock and wildlife.
22
RESPONSE: As understood by this reviewer/responder, Comment 18-3 refers to four
main concepts: vegetation age; the relationship of existing vegetation (i.e. grass)to soil
moisture; the relationship of existing vegetation to soil temperature; and increasing
forage production for livestock and wildlife.
The resource specialists report for soils (p. 7) notes that soil moisture and temperature, in
conjunction with other parameters, control soil biological activities and plant growth on a
seasonal basis. Other parameters include soil types in the area, which are explained on
page 3 of the soils specialists report. Also see the response to Comment 17-7 in the Law,
Regulation, and Policy section.
COMMENT 14-7: Some of the taller structure grasses are needed to catch the winter snows,
so we object to the Forest Service always managing for shorter structure grasses by burning and
mowing.
RESPONSE: Goals and desired conditions stated in the Forest Plan (p. 193)
state that we will "provide for low vegetative structure on the majority of the
Grassland." However, the PNG win not be managed only for shorter structure
grasses. A Forest Plan amendment would be necessary to change this. As stated
in the EA, the desired future structural categories, including short grass structure;
mid to tall grass structure; riparian vegetation structure and riparian buffers; and
chalk bluff structure would be managed to meet wildlife, rangeland, fire, fuels,
botany, soils and hydrology concerns within the range of natural variability.
The combination of the above predictions could result in a change in species
composition.
C. KEY ISSUE #2: LOSS OF SOIL DUE TO THE COMBINED EFFECTS OF HUMAN
AND NATURAL CAUSES
COMMENT 9-7: If you are trying to develop specific fertilizer from the ash, most of the ash
blows away. Dry years tend to be windier than wet years.
RESPONSE: Comment 9-7 refers to three different factors, all of which are addressed in
the Soil Specialist's report and the final EA: 1) nutrient cycling, 2) wind erosion, and 3)
drought. A benefit of the low intensity prescribed fire recommended for the PNG landscape
is that it promotes nutrient cycling after organic matter is reduced to ash and nutrients from
the ash are released and made more readily available for uptake by plants (Soil Scientists
Specialist Report, pg. 10). For the concern of wind erosion, recommendations were made by
the ID Team to implement prescribed burning in spring, outside of the historical windy
season, and just before a rapid green-up is expected (EA, pg 48; and Soil Scientists Specialist
Report, pg. 7). For concerns about drought, mitigation measures include determining soil
moisture content before actually implementing a prescribed burn (EA, pg 105, and Soil
Scientists Specialist Report, pg. 8 and 9).
23
COMMENT 11-4: The original intent of re-establishing grasslands after the homesteaders
plowed the land was wind erosion control. Why would we want to even risk that again
especially during the low precipitation period we have experienced now for eight years?
RESPONSE: As stated in the EA, the purpose for recommending prescribed fire on the
PNG is to manage vegetation to provide for wildlife habitat; promote diversity in vegetation
type, structure, composition and successional stages; reintroduce natural disturbance (e.g.
natural fire); and improve rangeland forage. Impacts by wind erosion and drought, and
mitigation measures to address these concerns are addressed throughout the Soil Specialists
report, and in the EA.
For the concern of wind erosion, recommendations were made by the ID Team to implement
prescribed burning in spring, outside of the historical windy season, and before a rapid green-
up is expected (EA, pg 48; and Soil Scientists Specialist Report, pg. 7). For concerns about
drought, mitigation measures include determining soil moisture content before actually
implementing a prescribed burn (EA, pg 105, and Soil Scientists Specialist Report, pg. 8 and
9).
COMMENT 11-5: When it does rain these burned areas are much more prone to water erosion
because of the depleted ground cover.
RESPONSE: The Soil Specialist's report addresses concerns for wind and water erosion
on bare ground and the EA includes mitigation measures recommended to minimize
erosion impacts. See response to comment 11-4 above.
D. KEY ISSUE #3: RISK OF ESCAPED FIRE ONTO PRIVATE LAND FROM PRESCRIBED
BURNING ON PUBLIC LAND.
COMMENT 11-3, 11-6, 12-10: We believe that the Forest Service has huge risks involved in
the continuation of prescribed burns.
RESPONSE: The Forest Service recognizes that there is inherent risk in implementing
prescribed fire and takes every precaution necessary to reduce this risk. Risk of escaped
fire onto private land is identified as a key issue in the EA, Chapter 1, Section 1.9, pp. 11-
13. Table 2.5 on pp. 17-18 of the EA compares each alternative on a relative scale in
regards to risk of escaped fire. The potential for risk is rated as "no risk", "moderate risk,
and "highest risk" depending on the alternative.
The area specific burn plan addresses and is designed to reduce the likelihood of escape.
A Complexity Analysis is completed and reviewed throughout the burn plan process.
There are 14 elements that must be considered within this analysis, all of which require a
risk assessment. This process identifies areas of concern that may need mitigation to
reduce the identified risk. In addition, an in depth fire behavior analysis generates both
fire and weather prescriptions that specify the conditions that will allow for the successful
completion of the project and reduce the potential for escape. The prescription is used to
24
determine staffing and equipment required to accomplish the burn. Additionally, spot
weather forecasts are done continuously during prescribed burning. If conditions are
outside of prescription, we do not burn.
COMMENTS 15-1, 15-2, 15-8, 12-1, and 17-9: As a property owner I have been concerned
that the Department of Agriculture, US Forest Service or the Pawnee National Grassland does
not have a compensation system in place to cover damages that may occur if a controlled burn
gets out of control.
RESPONSE: The Forest Service does have a process for claims from landowners to
cover damages that may occur if a prescribed fire escapes and crosses onto private land.
Claims Management is the process through which the Forest Service ensures that claims
filed against the Forest Service are managed and processed. The Forest Service begins
processing a claim for monetary damages and ends when the claim is adjudicated
administratively or judicially, and payment is made, when applicable.
COMMENT 12-3: The risk of loss to adjacent landowners is not "moderate," as described in
the EA. It is "moderate" only to the USFS, because the risks of soil erosion and wildfire
escapes are being compared with two extremes (Alternative A's no prescribed burns v.
Alternative B's prescribed burns of 8,000 to 12,000 acres). To the adjacent landowners, the risk
of loss is major, but variable, depending upon many different factors, including soil moisture,
prevailing wind patterns, and the proximity of the planned prescribed burns.
RESPONSE: The risk comparison of the alternatives is based upon the complexity
analysis process. The purpose of the complexity analysis is to indicate degree of risk,
consequences of escape, and technical difficulty. A specific burn plan is then developed
to minimize these factors. Typical mitigations include modifications to the prescription,
increased staffing, and an increase in the number and type of control features required
prior to initiation of the burn. Also, see responses to comments 9-7, 11-3, 11-6, and 12-
10 above.
E. ECONOMIC.COSTS/BENEFITS
COMMENT 11-8: What is the cost benefit ratio?
RESPONSE: Many of the benefits of a prescribed fire are difficult to place a monetary
value on. As discussed in Chapter 3, Section 3.4, page 29 of the EA, the cost benefit
ratio for Alternative C is estimated to be 0.23. In other words, for every dollar spent on
this alternative, the project will return $0.23 in benefits to recreation, wildlife and range.
COMMENT 117-4: Page 29 gives a cost for burning of approximately $10.00 per acre and we
have been told several times by Forest Service personnel that the cost is over$20.00 per acre.
Which is correct?
RESPONSE: The cost of prescribed burning varies by site, topography, vegetation type,
adjacent fuel types, and risk of escape. At the time the Quicksilver Economic model was
25
run for this project, it was determined that the cost of prescribed burning on the PNG
ranged between $9.29 and $10.25 per acre. Since the economic analysis was completed,
costs have risen due to several factors. Increased costs associated with having additional
resources (e.g. firefighters, engines, weather stations) available and standing by to reduce
the risk of escape, increased salaries and costs for materials and transportation, and
increased costs for specialist support (e.g. soil scientists, wildlife biologists,
archaeologists). In combination, these additional costs may result in a cost of more than
$30.00 an acre for prescribed burning on the PNG. Other Grasslands have estimated a
cost of approximately$23.00 to $32.00 per acre for prescribed burning in similar
vegetation types.
COMMENT 11-9, 113-7: If the FS has a budget shortfall it appears this should be one of the
projects to be dropped. If there is no shortage of funds then why not put these monies to
greater use in other areas on the PNG. There are several projects that come to mind for ranchers
that deserve higher priority.
RESPONSE: Congress directs how the Forest Service expends funds appropriated to it.
The Forest Service can not expend funds appropriated for wildlife habitat improvement
or hazardous fuels reduction to accomplish other objectives.
COMMENT 16-3: I am also concerned at the costs associated with prescribed fire,
particularly in light of constrained Forest Service budgets nationwide and the increased costs
associated with fighting wildfire.
RESPONSE: See response to Comment 11-9 above.
F. FIRE/FUELS MANAGEMENT
COMMENT 9-2: First of all, I do not know who prescribed this burning as a "management
tool."
RESPONSE: As stated in Chapter 1, Sections 1.2 (p.7) and 1.5 (p. 9) of the EA, the
USDA Forest Service, Arapaho and Roosevelt National Forests and Pawnee National
Grassland propose to continue using prescribed fire on the Pawnee National Grassland in
response to the purpose and need for action.
COMMENT 12-8 and 12-9: One of the stated needs set forth in Section 1.4 is to "mimic the
historic fire regime on the PNG." That Section states that "historic fires" typically occurred in
the past about once every 3 to 35 years. Obviously these statements reveal that there is belief
among the authors of the EA that it is not only necessary to recreate "historic fires" on the PNG,
but also is preferable. However, this type of thinking ignores the fact that the PNG has
disparate land ownership.
26
RESPONSE: The EA recognizes the fact of disparate land ownership within the
boundaries of the PNG. In Chapter 1, Section 1.2, p. 7 it states "The PNG is
approximately 193,000 acres of Forest Service land intermingled with privately owned
farms, ranches, and Colorado State lands."
The Forest Service recognizes that it is not feasible to burn thousands of acres across the
landscape without regard to property ownership. It also recognizes that on lands
managed by the PNG, there is potential to mimic the historic fire regime and retain the
benefits of fire on the vegetation and wildlife of the short grass steppe at a much smaller
scale.
COMMENT 13-8: The smoke emissions from prescribed burns yearly are increased more than
letting nature do the burning.
RESPONSE: Emissions are addressed in Chapter 3, Section 3.2, p. 21-23 of the EA.
The Forest Service is required to obtain a smoke permit from the Air Pollution Control
Division (APCD) for the State of Colorado prior to beginning any prescribed burn. If the
parameters for ambient air quality and visibility quality are expected to be exceeded
during a prescribed fire, APCD will not grant a smoke permit unless mitigation measures
are implemented to reduce potential impacts.
Further, smoke emissions from wildfires are greater than from prescribed burning as
found in Chapter 3, Section 3.2, p. 21-23 of the EA.
COMMENT 14-5: Some of the needs for burning stated in the document, we disagree with, as
to mimic historic fire regimes, (why?)...
RESPONSE: We appreciate your response and recognize that there is disagreement
with the stated purpose and need for the project among some of our stakeholders. The
need for burning on the PNG is stated throughout the EA (pp. 8-9, 31-34, 38-44, 46-51,
56-57, 58-61, and 66-100) and includes the following:
• Manage vegetation to provide for wildlife habitat.
• Promote diversity in vegetation type, structure, composition and successional
stages.
• Reintroduce natural disturbance.
• Improve rangeland forage.
• Reduce grassland fuel hazards.
COMMENT 15-7: Please keep in mind the ash that is developed by a burn is not pleasant to
deal with. After a year, when we had the 12,000 acre fire here ash was still in the air at the
slightest breeze. I would not like visitors to the grassland be subjected to that.
RESPONSE: We appreciate your concern and recognize that ash can be a hazard and an
inconvenience. It is important to recognize the difference between the levels of ash that
27
would occur from a 12,000 acre wildfire compared to the much smaller acreage that
would be burned in small blocks distributed throughout the Grassland using prescribed
burning. The EA addresses your concern in Chapter 3, Section 3.2, p. 21-23, and Section
3.10, pp. 46-51.
Additionally, see the response to Comment 13-8 above.
COMMENT 6-2: The prescribed fires do more damage than good.
RESPONSE: We appreciate your comment and recognize that there is a difference of
opinion about the benefits of prescribed fire by some of our stakeholders. Your comment
is addressed throughout the EA and specifically in Chapter 3, Affected Environment and
Environmental Effects, pp. 20-103.
COMMENT 9-3: Secondly, what is being managed?
RESPONSE: As stated in section 1.4 Purpose and Need, "The following needs were
identified to achieve the goals and objectives stated for this project:
• Manage vegetation to provide for wildlife habitat.
• Promote diversity in vegetation type, structure, composition and successional
stages.
• Reintroduce natural disturbance.
• Improve rangeland forage.
• Reduce grassland fuel hazards.
COMMENT 12-2, 12-4, and 12-5: The EA fails to identify the need for coordination of
prescribed burns with local agencies and adjacent landowners.
RESPONSE: We recognize the need to coordinate with local agencies and adjacent
landowners, as well as many other stakeholders when planning for prescribed burning.
Chapter 1, Section 1.8, pp. 10-11 illustrates that not only were local agencies invited to
participate in "determining the scope of issues to be addressed and for identifying the
significant issues" related to this project, but multiple opportunities for comment were
provided through a combination of letters, public open houses, press releases, and
stakeholder meetings. Approximately 246 letters were sent out to request comments
about the proposed action in June 2006, and 260 letters were sent out in July 2008 to
request comments on the EA. A complete list of the individuals, organizations, local and
state governments, tribes, and Federal and State agencies invited to participate in this
process is included in Appendix D.
In addition to the requirement for public involvement in the NEPA decision making
process, additional coordination takes place during development of the prescribed burn
plan. Coordination with grazing associations, adjacent landowners, research
organizations, Colorado Division of Wildlife, and other stakeholders are made several
28
months in advance of planned ignition. The burn plan requires that at least the following
notifications be made the day of planned ignition:
Weld County Regional Warren Air Force Base PIO'
Communications Notifications to the public (letters,
Local Fire Departments road signs, local flyers, and webpage
Fort Collins Interagency Dispatch entries)
Unit specific Volunteer Fire
Departments ' Public Information Officer
Weld County Health Department
COMMENT 12-6: Curiously, the EA does not refer to the Annual Wildfire Operating Plan,
which has been formally agreed to by the Weld County Office of Emergency Management, the
Weld County Fire Chiefs' Association, the Colorado State Forest Service, Fort Collins District,
and the Pawnee National Grassland, Arapahoe-Roosevelt National Forest. The stated purpose
of the Plan "...is to set forth the standard operating procedure, agreed procedures, and
responsibilities to implement cooperative wildfire protection on all lands within Weld County."
Thus, the EA should, at a minimum, refer to the Plan and recommend coordination between the
USFS and the agencies which are parties to the Plan whenever prescribed burns are being
planned on the PNG. The parties to the Plan should have been consulted with about the EA and
their names listed in Section 4.1.
RESPONSE: As discussed in the response to comments 12-2, 12-4, and 12-5, the need
for coordination is recognized. The Annual Wildfire Operating Plan specifically deals
with cost reimbursement for wildfires and cost sharing if parties conduct a cooperative
prescribed fire across jurisdictional boundaries.
COMMENT 12-14, 12-15, 12-16: The Board of County Commissioners demands that the
USFS collaborate with Weld County, the various applicable fire districts in which the PNG sits,
and the Colorado State Forest Service, in planning for prescribed bums on the PNG. Such
coordination is required by 36 CFR 219.9(a)(2). That Federal Regulation states that the
"responsible official must provide opportunities for the coordination of Forest Service planning
efforts undertaken in accord with [36CFR 219] with those of other resource agencies. The
responsible official also must meet with and provide early opportunities for other government
agencies to be involved, to collaborate, and to participate in planning for NFS lands." The EA
admits in Section 4.1 that no such collaboration has taken place. The board demands that such
collaboration take place prior to any management decision being made by the USFS based upon
the EA.
RESPONSE: We appreciate your comment. See our response to Comment 12-5 above.
COMMENT 17-3: On page 22 there is the statement that Alternative A has "increased
potential for larger wildfires". Elsewhere in the EA there are the statements that the possibility
for large fires is small because they are actively extinguished and because the landscape is
fragmented. The latter statement does not support the first.
29
RESPONSE: These two statements do not contradict each other. Grazing and fire
suppression have generally kept wildfires small; however, there have been larger
wildfires in the recent past that have escaped initial attack. The prescribed fire program
provided for with Alternative B and C will further reduce the potential for a wildfire to
escape initial attack and become large.
COMMENT 12-7: The EA incorrectly emphasizes the need to "mimic the historic fire regime
on the PNG," and then de-emphasizes the benefits of livestock grazing as a means to reduce
grassland fuels and minimize the risk of wildfires.
RESPONSE: The EA did not de-emphasize the benefits of livestock grazing as a means
to reduce grassland fuels and minimize the risk of wildfires and in fact, addressed
livestock grazing several times (pp. 8, 18, 29, 31, and 34).
We recognize there is a difference of opinion about the need to mimic the historic fire
regime on the PNG and are aware of your concern. We also recognize that livestock
grazing can be used to reduce grassland fuels to minimize the risk of wildfires, to
improve and maintain shortgrass prairie, and to improve the palatability and nutritional
value of forage. In addition, livestock grazing management was analyzed in depth in two
earlier EA's (2004 and 2005) so there was not a need to reconsider livestock grazing in
depth in this EA.
G. WILDLIFE
COMMENT 5-1: Up until the time of 13 years ago when you started the prescribed burns on
the grasslands, the buffalo grass grew according to what the season allowed by Mother Nature.
Some years shorter and others more plentiful according to the amount of rainfall received. In
all that time the wildlife was allowed to maintain their own circle of life without any outside
interference. The plover bird survived while nesting not only in the buffalo grass, but, as well
as, summer fallow.
RESPONSE: According to research done on this species between 1985 and 2007
(Knopf 2008) mountain plovers use the PNG and contiguous fields similarly during
courtship and nest initiation. This same author monitored mountain plover responses to
prescribed burning from 1998 through 2006. His results were variable, but mountain
plover were found to use the burn areas for nesting in most years and for migration in all
years.
COMMENT 5-2: Since about 1989 until 2002, we received just enough moisture to survive
from year to year. Cattlemen who ran on the grasslands were asked to cut the permit numbers
because of the lack of grass, which was done willingly. In 2002, the true drought hit and is still
very much present, yet, you have continually burned precious acres of grass so the plover bird
can nest. How did these birds survive over the past hundreds of years without your interference
of burning?
30
RESPONSE: Mountain plover have declined over the last century primarily as a result
of threats occurring on their breeding grounds, but combined threats to breeding,
migration and wintering habitat are thought to have contributed to this species decline.
Specific threats include loss of native habitats and loss of native herbivores. Much has
changed within the historical range of this species which evolved on the Great Plains with
natural disturbance regimes including wildfires; grazing by native bison, pronghorn
antelope and prairie dogs; and drought and wind.
COMMENT 7-1: My first comment is that there is some disagreement between Chapter 2, the
Comparison of Alternatives, and statements made later in the EA. Table 2.5 on page 17 shows
prescribed burning under Alternative B as "Year-round, except for 4/1 through 7/10." In
Appendix B, page 109, under "Raptors" we find a measure to mitigate burning between March 1
and June 30, part of which time is during the period shown on page 17. On page 79 under
Northern Harrier the EA says that fire is proposed year-round in mid to tall structure vegetation
and in riparian structure vegetation and doesn't mention the breeding season exemption. It's not
clear if burning is to occur absolutely all year or really only from 7/11 to 3/31 of the next year.
RESPONSE: We agree. This is confusing. To clarify, there is overlap between Table
2.4 and the mitigation measures for raptors stated on p. 109 of the EA, which includes
northern harriers. In general, burning can occur anytime between July 11 and March 31
if Alternative B was implemented. The exception to this is in areas where raptor nest
sites occur. Where raptor nest sites occur, a biologist must confirm that birds have not
started to nest prior to burning. If nesting has started, a YA mile buffer would be placed
around the nest site and no burning or other disturbance related to burning would occur
within this buffer zone between March 1 and June 30, so in these areas no burning would
occur between March 1 and July 10 if this alternative was chosen.
COMMENT 7-2 and 15-4: Second, the statements in the EA about the status of the mountain
plover contradict each other to some extent. On page 66 mountain plovers are characterized as
"fairly common summer residents," while in the next paragraph Fritz Knopfs surveys are cited
as showing "severe declines for the Grassland following 1994." Our experience is that the
plover has now become a fairly RARE summer resident on the PNG, compared to its abundance
25 years ago. Then, it was easy to find mountain plovers, including females with young. Now
it has become difficult and in some years our field trips see very few or none. I suggest you
change the wording in that first paragraph to reflect the relative scarcity of this species on the
PNG at this time.
RESPONSE: Mountain plover are still considered to be fairly common summer
residents on the Pawnee NG with widespread use still evident after 1994. The trend
survey referred to on p. 66 of the EA shows severe declines in nest success in mountain
plovers on the PNG. Knopf(2008) states that mountain plover population on the PNG
probably began declining in the late 1940's and early 1950's. Although there appears to
be a shift in nest site use, mountain plover continue to use the PNG for foraging and
migration. Although it is uncommon to see large flocks of mountain plover in this area, it
is not uncommon to see several birds on prairie dog colonies, along roads, and in other
disturbed sites on the Grassland during the summer.
31
COMMENT 7-5: On page 67 the EA says that prairie dogs rely on forbs for a percentage of
their diet. If there are figures for this percentage (20%, 30%, etc.) it would be helpful to include
them.
RESPONSE: Hoogland (2006) estimates that approximately 15% of the diet of prairie
dogs comes from forb species. He further qualifies this by stating that forbs, dwarf
shrubs and cacti are more important food items during the winter.
COMMENT 7-6: The discussion of the northern harrier, p. 79, refers the reader to the
mitigation measures on p. 109, Appendix B. These measures are said to minimize impacts on
breeding members of this species. However, the mitigation measures merely call for a survey
by the wildlife biologist to confirm that birds have not started to nest in areas to be burned. This
begs the question of what happens if they HAVE started to nest. Do the mitigation measures for
raptors then come into play? This should be clarified.
RESPONSE: You are correct. If a northern harrier nest site is found on or within '//
mile of an area proposed for burning, the mitigation measures for raptors would be used
to protect the nest site.
COMMENT 7-7: The discussion of environmental impacts on fringed myotis gives, as
mitigation, that prescribed burning should only occur within a 0.25 mile radius of the
[identified] roost, or when the roost is not occupied. Since the sense of this measure seems to
be avoidance of the roost site, shouldn't "within" be changed to "outside" so that the statement
calls for burning outside a 0.25 mile radius?
RESPONSE: You arc correct. The wording has been corrected in the Decision Notice
to read "prescribed burning should only occur outside of a 0.25 mile radius of the roost".
COMMENT 13-5 and 14-3: The wildlife department has stated there is no need to burn for
the mountain plover during drought as there is not that much tall structure.
RESPONSE: The Conservation Plan for Grassland Species in Colorado (CDOW 2003)
identifies objectives and actions to meet those objectives for five grassland species
including the mountain plover. Objective 8 states that "the CDOW will encourage
significant contributions from publicly owned lands, particularly the National Grasslands,
toward grassland species conservation and work with federal, state, county and municipal
partners to support these efforts. Action 8.6 under Pawnee and Comanche National
Grasslands recommends "maintaining low structure vegetation on suitable shortgrass
prairie habitats by increasing range allotment carrying capacity and grazing intensity,
encouraging expansion of black-tailed prairie dog colonies, or through prescribed burning
as appropriate." Based on this recommendation and others, prescribed burning is
considered to be an appropriate tool for management of mountain plover nest habitat.
Due to the need for bare ground to facilitate successful nesting by mountain plover, it is
likely that drought years enhance the quality of nesting habitat for this species.
32
COMMENT 15-5: Our bird watchers will not appreciate a burned off prairie.
RESPONSE: The PNG is considered to be an international destination for birders
worldwide, many looking to find mountain plover. Each Spring, birders and
outfitter/guides conducting bird tours contact this office to find out where the burns were
conducted so they can see mountain plover. Due to this interest, it has been the policy of
the PNG to include a burn block in mountain plover habitat along the Pawnee Bird Tour,
so that birders searching for mountain plover will have a good chance at seeing this
species. There have not been any complaints from birders related to "burned off prairie"
in the last 13 years. Alternately, birders ask that we burn more acreage for mountain
plover on the PNG.
COMMENT 18-5: I have not seen "any" plover the last two years in the East Keota pasture. I
think burning has been a failure.
RESPONSE: No data has been gathered by the PNG about mountain plover numbers
specific to the East Keota pasture. This pasture is not included in our annual monitoring
efforts, so no long term assumptions about mountain plover in this area can be made by
the PNG. However, research has indicated that mountain plovers utilize burned areas.
See response to comment 5-1.
COMMENT 15-6: According to the maps I have not noticed any burns in the area of the
Pawnee Buttes.
RESPONSE: The area adjacent to the Pawnee Buttes is not suitable for mountain
plover, so no prescribed burns were conducted there. Under this EA, the chalk bluffs,
including the Pawnee Buttes are excluded from the action alternatives and will not be
burned due to unique geological features, their value for raptor nesting, and their
inclusion in the Forest Plan as prairie woodland management areas and special interest
areas.
COMMENT 9-6: If you are trying to provide better nesting habitat for mountain plover,
burning is not necessary in dry years. There are abundant short grass areas for nesting. I have
found plover nests in my own pastures that were not burned.
RESPONSE: See response to Comments 5-1, 13-5, and 14-3.
H. MISCELLANEOUS COMMENTS
COMMENT 1-1, 1-2, 2-1, 3-1, 4-1, 5-3, 5-4, 6-1, 6-6, 7-3, 7-8, 7-10, 7-12, 8-1, 9-1, 9-9, 9-10,
10-2, 11-1, 12-12, 13-1, 13-4, 13-9, 13-10, 14-1, 14-6, 17-1, 19-1,: Many comments were
received in support of one alternative over the others, or in general support of or opposition to
prescribed fire. Other comments were received that did not address specific issues or concerns
with the project.
33
RESPONSE: Specific responses to these general comments are not possible, but public
participation is appreciated.
COMMENT 1-3, 2-3, 2-4, 2-5, 2-7, 7-8, 7-9, 7-10, 7-13, 7-14, 8-2, 10-1, 12-2, 13-2, 13-3, 14-8,
15-3: Several comments were received that were related to topics outside of the scope of this
analysis including allotment management planning, forest management, land ownership
consolidation, reintroduction of bison, research needs, cultural resources, mountain plover
management, and prairie dog management.
RESPONSE: Specific responses to these general comments are outside the scope of this
analysis, but public participation is appreciated.
COMMENT 3-2: If archaeological materials or human remains are encountered during
construction, the State Historic Preservation Office and applicable Native American Tribes will
be notified.
RESPONSE: As described on p. 100, in Section 3.18, the PNG will conduct cultural
resource inventories of the area of potential effect prior to project implementation.
Additional we will comply with the provisions of the National Historic Preservation Act
if archaeological materials or human remains are encountered during project
implementation including notification of the State Historic Preservation Office and
applicable Native American Tribes.
COMMENT 11-7: A concern for global warming is a key issue that we do not see addressed
in the EA. The possibility of continued warm temperatures and low rainfall is real. Just
consider the fires we have had across the nation in the recent years.
RESPONSE: Global warming was not identified as a key issue for this analysis. Some
predict that global warming will cause increases in temperature and drier conditions.
These changes could increase drought events. The effects of drought are considered in
the EA (page 53) and mitigation measures will be implemented to reduce the risk of
prescribed fires increasing the adverse effects of drought.
Citations:
Augustine, D.J. and D.G. Milchunas. 2008. Vegetation responses to prescribed burning
of grazed shortgrass steppe. Rangeland Ecology and Management (In Press). 26
pp.
Knopf, F.L. 2008. Mountain Plover Studies, Pawnee National Grassland 1985-2007
(Unpublished Report). 74 pp.
National Assessment Synthesis Team. 2000. Climate Change Impacts on the United
States: The Potential Consequences of Climate Variability and Change
Overview. US Global Change Research Program. Website source (accessed
34
April 29, 2008):
http://www.nacc.usgcrp.gov/usgcrp/Library/nationalassessment/overviewwest.ht
m
Wright, Henry A.; Bailey, Arthur W. 1982. Fire ecology: United States and southern
Canada. New York: John Wiley& Sons. 501 p.
35
APPENDIX D
Consultation and Coordination
Environmental Assessment: Prescribed Fire Management on the
Pawnee National Grassland
The Forest Service consulted the following individuals, organizations, local and state
governments, tribes, and Federal and State agencies during the development of the
environmental assessment.
Local, State and Federal Agencies
CONTACT AGENCY
Jerry Craig, Raptor Biologist Colorado Division of Wildlife
Larimer county emergency services
Weld county road department
Weld county district attorney
Weld county sheriff
Weld county public works, weeds division
Sandy Vanna-Miller USD1 Fish and Wildlife Service, Denver
Federal Center
Dalin Tidwell USDA APHIS
Susan Linnear USDI Fish and Wildlife Service
Justin Derner ARS/High Plains Grassland Research Station
John Wicke NRCS
Steve Freemyer Briggsdale Fire Protection District
Alvan and Debbie Shipps Nunn Fire Protection District
Sherry Burnett Grover/Pawnee Fire Department
Steve Pixley Grover/Pawnee Fire Department
Larry Sheets Ault/Pierce Fire Department
Kyle Lambert New Raymer/Stoneham Fire Protection
District
Robert Sleesman U.S. Air Force
Dave Clarkson Colorado Division of Wildlife
Dave Hessel Colorado Division of Wildlife
Russell George Colorado Division of Wildlife
Walt Graul Colorado Division of Wildlife
Larry Nelson Colorado Division of Wildlife
Francie Pusateri Colorado Division of Wildlife
Mike Sherman Colorado Division of Wildlife
Troy Florian Colorado Division of Wildlife
BLM, Royal Gorge Resource Area
John Sidle Great Plains National Grassland
Dave Hessel Colorado State Forest Service
Colorado State Land Board
Greg Watcher Colorado Department of Natural Resources
Colorado Geological Survey
Mike Yeary Colorado State Wildlife Services
36
CONTACT AGENCY
State Historical Society, Historical
Preservation Office
Damon Lange Colorado State Forest Service
Local, State and Federal Governments
NAME ORGANIZATION
Town of New Raymer
David Long, Office of Board of County Weld County
Commissioners
Wayne Allard U.S. Senate
Ken Salazar U.S. Senate
Marilyn Musgrave U.S. House of Representatives
Dianne Hoppe Colorado State House of Representatives
David Owens Colorado State Senate
Tribes
Cheyenne and Arapaho Tribes of Oklahoma
Northern Arapaho Tribe
Northern Arapaho Culture commission
Northern Cheyenne Tribe
Oglala Sioux Tribal Council
Rosebud Sioux Tribe
Kiowa Tribe
Organizations
Crow Valley Livestock Cooperative, Inc.
Pawnee Cooperative Grazing Association
Colorado Cattleman's Association
Forest Guardians (Wild Earth Guardians)
Colorado Wild
Fort Collins Audubon
The Nature Conservancy
Southern Rockies Conservation Alliance
The Wilderness Society
American Lands Alliance, Colorado Field Office
SINAPU
Colorado Environmental Coalition
Sierra Club/Rocky Mountain Chapter
Audubon Society of Greater Denver
Audubon Society of Colorado
37
Sierra Club
CFAR
Colorado Association of 4-wheel Drive Clubs Inc.
The Nature Conservancy
Defenders of Wildlife
Public Lands Advocacy
Rocky Mountain Bird Observatory
Rocky Mountain Bird Observatory
Western Lands Project
National Wildlife Federation
Biodiversity Conservation Alliance
Southern Rockies Conservation Alliance
Greeley Tribune
Southern Star Central Gas Pipeline Co.
Cheyenne Plains Gas Pipeline Co.
Walsh Production, Inc.
Diversified Operations Corp.
HRM Resources, LLC
Wanblisina
High West Energy, Inc.
Worldcom Network Services, Inc.
Spring Communications Co., LP
Nunn Telephone Co.
Colorado Energy Minerals, Inc.
Fortitude Exploration Co.
Wiggins Telephone Association
Tri-State Generation and Transmissions, Inc.
Sterling Energy Co.
ConocoPhillips
Duke Energy
Morgan County REA
Williams Field Services Co.
Pawnee Wagon Train Vacations
Mile High Jeep Club of Colorado
Land Use of Northern Colorado, Assoc. of 4 Wheel Drive Clubs, Inc.
Northern Colorado Trail Riders
Happy Bottoms Wheeling Club
Wagonmasters 4wd Club
Bicycle Colorado
Back Country Horsemen of Colorado
Colorado Outfitters Association
NRA/Friends of the NRA
Colorado State Shooting Association
Colorado Archeological Society
Colorado Oil and Gas Conservation
Pacific Legal Foundation
Mertens Bros. Inc.
L & J Lousberg Co.
38
Colleges and Universities
Colorado State University
University of Colorado, Wilderness Study Group
Colorado State University
Individuals
Wade Castor Jon & Mark Pauling
Keith Nelson Elaine Raffelson
William Shable Barbara Harless
Clayton Stanley Leora Roberts
Ronald Timmerman Dewain Shapley
Barbara & John Toedtli Wayne Shoemaker
Penny Persson Myron Showers
Roland Ball Peggy & Mike Shull
Thomas Baur Jim Sturrock
James Curtis Colby Vaneleave
Leonard Ball Bonnie Voltz
Arvid Deporter David Willich
Jewell Artzer Terry Kugler
Roger Blake Clint Bashor
Marilyn Samber Helen Budin
Dennis Bringelson Charles Craig
Freeman Clyncke George Kindvall
George Ehmke Skip Johnson
Herman Enderson Ladonna Lee
Kenneth Everitt George & Benny Lindsey
Linda & Fredrick Fangmeier Shane Miller
Vera Fiscus Delwyn Northup
Eugene Hahn Marjorie Rosin
Orvil Harms Donna Shablc
Naomi McEndaffer Colby Walker
Geraldine & Larry Highland Robert Rohn
William Hoffman Leonard Harms
Ken Holzworth Gary Dollerschell
John Leone Robert Hill
Virgil Johnson L. James Walker
Tony Joska Fritz Knopf
Paul Kaiser John Benshoof
Glen Klawonn Leroy Carlson
David Klinginsmith Wendell Funk
Janet Konig Karen Hollweg
Jay Littlefield Kelen &Gary Skiba
Donald Mais Curtis Talley, Jr.
Kenneth McEndaffer Grant Stevinson
Virginia Ohare Walter & Ida Slagell
39
•
Lendyl Walker Sandy & Bob Kyle
Charlotte Norgren Deb Jones
Lindsay Sterling 'Crank Katie Kinney
Dean & Doris Suposs Pam Wanek
Ken Klensorge Linn Barrett
Bill Miller
40
Hello