chapter 1 purpose and need for proposed...

Environmental Assessment of 15 August 2011 High Sierra Fuelbreak Maintenance Project USDA Forest Service

Chapter 1

Purpose and Need for Proposed Action

Introduction

The U.S. Department of Agriculture (USDA) Forest Service has prepared this Environmental

Assessment (EA) in compliance with the National Environmental Policy Act (NEPA) and other

relevant federal and state laws and regulations. This EA discloses the direct, indirect, and

cumulative environmental impacts that would result from the proposed action and alternatives. It

also provides the supporting information for a determination to prepare either an Environmental

Impact Statement or a Finding of No Significant Impact.

Additional documentation, including more detailed analyses of project-area resources

referenced in this document, may be found in the project planning record located at the High

Sierra Ranger District (District) Office in Prather, California.

The High Sierra Fuelbreak Maintenance Project area includes 4,613 acres of the Sierra National

Forest (SNF) in the Southern Sierra Nevada Mountains, approximately 19 miles northeast of the

city of Fresno, California (see Figure 1-1). The fuelbreak maintenance project includes

maintenance of six existing fuelbreaks and the creation of one new fuelbreak plus two roadside

clearing projects, one fireline along Powerhouse Road and road maintenance associated with

access to the Beal, Burrough and Powerhouse fuelbreaks.

The intent of this analysis is to provide for the creation and maintenance of the existing

fuelbreaks for the next 10 year period. The use of the term fuelbreak is used loosely in some

instances in the document. The Beal, Vincent, Lerona, Burrough and Powerhouse are to be

considered actual fuelbreaks:

“A fuelbreak is a strategically located wide block or strip, on which a cover of dense,

heavy or flammable vegetation has been permanently changed to one of lower fuel

volume or reduced flammability as an aid to fire control. Though any of piece land

cleared of existing heavy vegetation can be termed a fuelbreak, it is misapplied

unless long-term maintenance of new vegetation cover on the cleared area is

specifically planned” (USDA, 1977) .

The Upper Sycamore and Shaver Springs Project are not true fuelbreaks but fuels modification-

type conversion projects designed to create a mosaic of brush age classes to slow fire spread

below the associated communities. The Jose Basin Road and Powerhouse Road brush

clearing projects are to remove brush directly adjacent to these roads to provide firefighters a

safe place to start fire control actions in the event of a wildfire. All of the above projects are

given the general term fuelbreaks to discuss methods and changes to habitat. The fire control

hand lines (P-lines) are constructed by California Department of Forestry and Fire Protection –

Cal Fire handcrews; this work is proposed within the Fresno County Roads Department Right of


Way and through not required to be analyzed under NEPA they are included in this document to

assist in the cumulative effects analysis.

Large scale ground disturbing activities such as bull dozing brush for fuelbreaks can leave soil

exposed enough to allow for the occurrence of invasive weeds as occurred after the 2001

clearing of the Beal Fuelbreak. In the months after this maintenance activity, the SNF

experienced its first large scale invasion by the highly noxious yellow starthistle (Centaurea

solstitialis); though the forest has diligently worked to eradicate this noxious weed, it still occurs

in limited quantities on this fuelbreak and on private lands adjacent to the SNF. In response to

the possibility of future outbreaks of this plant and other invasive species, a noxious weed risk

assessment has been developed for this analysis and is included in an appendix.

Access to the fuelbreaks is by county and SNF roads. The Burrough, Beal and Powerhouse

fuelbreaks have roads that if not adequately maintained for access by fire fighting vehicles can

jeopardize the efficiency of the use and maintenance of those fuelbreaks. The maintenance of

these roads is a connected action and are analyzed as a part of this document.

Scope of the Analysis

This EA focuses on potential effects to eleven resource areas responding to the issues raised

during scoping, analyzing resources that may be perceived as being significantly affected by the

project as well as demonstrating the Forest‟s compliance with environmental regulations

including the Forest‟s Land and Resource Management Plan (LRMP or Forest Plan). These

resource areas include: air quality, aquatic, health and human risk, botanical, cultural,

economic, fire and fuels, hydrology, soils, and terrestrial wildlife.

A few other resource areas are sometimes also included in forest health related environmental

analyses: transportation, recreation and visual quality. No scoping issues were raised related to

these three resource areas and there are no environmental laws requiring Forest Service (FS)

compliance for these resource areas. There will not be significant effects to these resources

areas for the reasons described below therefore the Forest has elected not to include these

resource areas in this document to focus on the resource areas of interest and concern. Further

explanation for the exclusion of these resource areas from further analysis is presented below.

Transportation: Although there will be some road reconstruction (7.4 miles), this milage is very

small in comparison to the SNF National Forest Transportation System (NFTS) (2500 miles of

roads or less than 1 percent of the NFTS will be affected.) Additionally, engineer approved

design criteria have been included in all the alternatives to comply with Forest Service road

maintenance and construction guidance. Road related impacts to resources such as soils and

hydrology due to road related actions will be addressed in these resource sections.

Recreation: There are no established and maintained recreational facilities in the project area.

Dispersed camping opportunities will still be available on hundreds of locations throughout the

forest. There would be no short or long term effects on the Recreation Opportunity Spectrum

(ROS) classes in the project area because there a few if any recreational opportunities in this


area of the forest due to the elevation, the extreme summer time temperatures and the

intermingle presence of private property throughout the project area.

Project History

The history of the fuelbreaks for wildfire control dates back to the early days of the Forest

Service. Prior to World War I, rangers had built a 110-mile-long firebreak through much of the

brush country of the Sierra and Sequoia National Forests (Rose 1993). During the Great

Depression years prior to World War II, the Sierra National Forest had many Civilian

Conservation Crews (CCC) working on building roads, campgrounds, and many other facilities.

One of the most ambitious CCC projects in California was the construction of the Ponderosa

Way. The project, first proposed by the Regional Forester in 1929, was a plan to construct “a

real fire line with a truck trail along it down the length of the Sierra and the north Coast Range

located near the lower edge of the present timber lands” (Otis et al. 1986). The Ponderosa Way

was a 100-foot-wide firebreak that would cut off the foothill brush fires, which often led to the

most destructive wildfires on the forest. The almost 800-mile-long Ponderosa Way ran from the

Shasta Bear Lookout on the Shasta National Forest on the north to the southern end at the Kern

County line on the Sequoia National Forest, passing through the Sierra National Forest. On the

SNF, the construction of the Ponderosa Way firebreak was a difficult task for the CCC. Besides

the backbreaking manual labor with saws and shovels, one corpsman was killed by the

explosives used to remove brush and trees in the brush fields above Tollhouse. Thousands of

pounds of arsenic were also used “in a futile attempt to prevent the regrowth of vegetation”

(Rose 1993).

SNF files describe the history of construction, maintenance, and use of these existing

fuelbreaks:

The Beal Fuelbreak is originally part of the Ponderosa Way, with reconstruction in 1977, and

maintenance in 1987 and 1995 by dozer and hand piling, and herbicide. The Beal Fuelbreak

has been used in fire suppression activities seventeen times since its initial creation in 1933. All

but one of the treatment units have been burned in past wildfires dating to 1930.

The Burrough Mountain fuelbreak was originally constructed in 1935 as part of the Ponderosa

Way. This fuelbreak was cleared by bulldozers in 1944, 1968, 1977, and 1987 and 2004 by

means of brush rakes, and the ground bears the marks of the heavy equipment. Additional

bulldozer clearance was done for fire suppression in the 1987 Burrough Fire. The fuelbreak

area has a high fire occurrence rate, with eleven major fires since 1911; SNF fire history GIS

data shows the entire fuelbreak as having burned in wildfires since 1929.

The 200 acre Lerona fuelbreak forms a barrier between fires coming out of the San Joaquin

River canyon and the timber stands of Jose Basin. It is on the edge of the Sugarloaf „type

conversion‟, where 2500 acres were converted from brush to grassland by heavy equipment to

benefit cattle grazing. The entire fuelbreak has been previously burned in wildfires dating to

1927.


In the Upper Sycamore/Shaver Springs Fuelbreaks, SNF fire history GIS data shows almost the

entire Shaver Springs fuelbreak has burned in wildfires since 1927, but no fire history is

available for the Upper Sycamore fuelbreak.

SNF records indicate that the Vincent Fuelbreak was originally constructed during the 1918

Sycamore Creek Fire, used again in the 1932 Davis Mountain Fire, reconstructed in the 1960s,

and again in 1995 and 2002 with dozer piling along the 4.5 mile length to a width of 100-300‟.

The fuelbreak was last maintained in 2007- present using hand piling, underburning and

herbicides. Over half of the fuelbreak was burned in the 1918 wildfire.

The newly proposed Powerhouse Fuelbreak is a prominent ridge used in three recent fire

control actions (1989, 2002 and 2007 Powerhouse Fires). The entire ridge was plowed as a

firebreak for the wildfire in 1921 and most recently in the 1989 Powerhouse Fire.

SNF NEPA decisions for construction and maintenance actions to this fuelbreak system date to

the mid-1970s:

The Burrough and Beal Fuelbreak EA, signed by the District Ranger in December, 1977

approved reconstruction of Burrough Fuelbreak and two miles of Beal Fuelbreak with hand and

dozer piling and burning.

The Front Country Fuelbreaks EA, signed in 1977, included the Backbone/Auberry

(Powerhouse), Beal, Lerona, and Mountain Rest (Shaver Springs, Sycamore and Vincent)

Fuelbreaks, for a total treatment of 912 acres of federal land at 300‟ wide.

Twenty years later, in the mid-1990s, the fuelbreaks again became a focus of SNF management

decisions:

The Vincent, Shaver Springs, and Upper Sycamore Fuelbreaks were addressed in the

Sycamore Basin Brush Piling Project, Decision Memo signed by District Ranger Ray Porter in

May 1996, which approved 703 acres of dozer and hand piling and burning.

The Lerona Fuelbreak Reconstruction Project, Decision Memo signed by Ranger Porter in

September 1999 approved reconstruction of the fuelbreak north of Jose Basin Road with dozer

piling and burning.

The Vincent and Beal Fuelbreak Maintenance Project, Decision Notice signed in February 1999 approved herbicide applications, piling and burning with follow-up treatments on these fuelbreaks.

The Burrough Fuelbreak Maintenance Project, Decision Memo signed by Ranger Porter in July 2000 approved 300 acres of dozer piling and burning to reconstruct and maintain the fuelbreak.

The legal description of each fuelbreak is:

Powerhouse Fuelbreak–T 9 S. R23 E. Sections 19, 30, 31 and 32. 153 acres Powerhouse Road Brushing and P-line. T.9 S. R.22 E. Sec. 24, and T. 9 S. R. 23 E. Sec 19 and 30. Road Brushing – 48 acres, Cal-Fire P-Line –The total length is 2.22 miles, the acres


of area cleared is 0.8. This hand line will be within the county right-of-way on Powerhouse Road. Jose Basin Road Brushing - T.10 S. R.23 E. Sec. 4, T.9 S. R.23 E. Sec. 23, 24, 35, T.9S. R.24 E. Sec.19, - 31 acres Beal Fuelbreak – T. 10 S. R. 23 E. Sections 13-15, and 24, T. 10S. R. 24 E. Sections 19, 20 and 30. 441 acres.

Vincent Fuelbreak – T. 10 S. R 24 E. Sections 23-27, 34 and 35. 1279 acres.

Burrough Mountain Fuelbreak –T. 10 S. R. 24 E. Sections 19, 29, 30, 32 and 33. T. 11 S. R 24 E. Sections 3, 4 and 10. 1666 acres

Lerona Fuelbreak –T. 9 S. R. 23 E. Sections 24, 25, and 26. 200 acres.

Shaver Springs/Upper Sycamore - T. 10 S. R. 24 E. Sections 20, 21, 28 and 29. 673 acres.

Mount Diablo Baseline & Meridian Township. The actions range in elevation from 1,400 to 4,800

feet.

Organization of this Document

The document is organized into the following parts:

Chapter 1, Introduction: This chapter provides information on the history of the project proposal,

the purpose and need for the project, and the agency‟s proposal for achieving that purpose and

need. This section also details how the Forest Service informed the public of the proposal and

how the public responded.

Chapter 2, Alternatives, including the Proposed Action: This chapter provides a description of

the agency‟s proposed action and any alternatives.

Chapter 3, Environmental Consequences: This chapter presents the environmental effects of

implementing the proposed action and other alternatives. The effects of the no-action

alternative are described to provide a baseline for evaluation and the comparison of the

alternatives that follow.

Chapter 4, Consultation and Coordination: This chapter provides a list of preparers and

agencies that consulted during the development of this document.

Chapter 5, References: This chapter lists bibliographical information of any literature cited and

personal communication used to write this report.

Appendices: The appendices provide more detailed information to support the analysis

presented in this report.

A. Map Packet

B. Design Criteria


C. Noxious Weed Risk Assessment

Resource Areas addressed in this document include:

Fire and Fuels Air Quality Herbicide - Health and Human Risk Herbicide with R11 – Resources Economics Cultural Resources Botanical Resources Watershed and Soils Terrestrial resources Management Indicator Species Migratory Landbirds Aquatics

Areas not addressed in this document because these resource areas to not apply or do not

occur in this part of the forest: – Visual Quality Objectives, Recreation.


Figure 1-1. Project Vicinity Map – High Sierra Fuelbreak Maintenance Project


COLLABORATION

A collaborative group of state, federal and local fire agencies and the Highway 168 Fire Safe

Council assembled to direct the planning approach for the protection of the communities that

exist in the Wildland Urban Interface (WUI) of SNF and eastern Fresno County. Participants

represented the interests of themselves and their interest groups.

These fire agencies addressed the current hazard and risk of the communities, local fire history,

the growth of the WUI, the desired conditions, purpose and need and the proposed action. The

proposed action is a collaborative outcome incorporating the desired future conditions that

would best provide firefighter and public safety, reduce firefighting costs and minimize impacts

to resources. The collaborative group met five times including two site visits, either as a full

group or as a smaller group to discuss detailed conditions of the current fuelbreaks and

community efforts. The second site visit included both Cal-Fire state and regional

representatives, US Forest Service regional and Washington office employees, the local fire

safe council as well as the local landowners..

MANAGEMENT DIRECTION

Regulatory Setting

The fuelbreaks on the District are situated entirely within the WUI land allocation. WUI zones

are where human habitation is mixed with areas of flammable wildland vegetation; this land

allocation extends out from the edge of developed land (urban core) into Federal, private and

State jurisdictions. The first ¼ mile of federal land outside of the urban core is considered the

defense zone and the 1 ¼ mile past the defense zone is termed the threat zone. The

designation of the Wildland Urban Intermix (WUI) Zones in the this analysis were prepared in

accordance with Title IV of the Fiscal Year 2001 Appropriations Act for the Department of the

Interior and Related Agencies (Public Law 106-291, 106th Congress) and as defined on page

43384 of the Federal Register Vol. 66 No. 106 dated Friday August 17, 2001. The public law

(http://bulk.resource.org/gpo.gov/laws/106/publ291.106.txt) states:

Prior to May 1, 2001, the Secretary of Agriculture and the Secretary of the Interior shall jointly publish in the Federal Register a list of all urban wildland interface communities, as defined by the Secretaries, within the vicinity of Federal lands and at high risk from wildfire”.

These zones are mapped land allocations on SNF. These fuelbreaks are priority management areas for treatment as identified in the Healthy Forest Initiative (HFI) and Healthy Forest Restoration Act of 2003 (HFRA).

HFI for Wildfire Prevention and Stronger Communities was signed into law by President

Bush on August 22, 2002. The HFI implements core components of the National Fire

Plan and the 10-year Comprehensive Strategy, which were developed after the

devastating 2000 fire season and agreed to by states, tribes, and stakeholders. Both

provide direction for prioritizing treatment in areas that are at risk of severe wildland

fires, especially communities in the WUI, in order to protect communities, firefighters,

http://bulk.resource.org/gpo.gov/laws/106/publ291.106.txt


wildlife, and forest health. The proposed treatments for the High Sierra Fuelbreaks would

further the goals of the HFI as outline in the Cohesive Wildfire Management Strategy as

directed by the Wildland Fire Leadership Council.

HFRA authorizes projects on federal lands to reduce fuel loads and increase or maintain

healthy forest conditions. It provides a foundation to work collaboratively with at-risk

communities to reduce wildfire hazards caused by fuel loads within the WUI that exceed

desired conditions as defined by the Forest Plan (16 USC 6612 Sec.102 (b)).

The communities of Auberry, Tollhouse, and Meadow Lakes, California have been

identified on pages 43387, 43389 and 43390 of the Federal Register, Volume 66,

Number 160, Friday, August 17, 2001. Part III, Department of Agriculture: Forest

Service; Department of the Interior: Bureau of Indian Affairs, Bureau of Land

Management, Fish and Wildlife Service, National Park Service, Urban Wildland Interface

Communities Within The Vicinity of Federal Lands That Are High Risk From Wildfires;

Notice. State and Local Governments and Native American Tribes developed this list.

The factors that were used to identify "at risk" communities correlate with the residential

communities, businesses, administrative sites, and recreation developments of eastern

Fresno County and the Sierra National Forest.

The SNF Land and Resource Management Plan (LRMP) as amended by the Sierra

Nevada Forest Plan Amendment (2004), and by the SNF Management Indicator Species

(MIS) Amendment Record of Decision (2007) provides the guidance for implementing

National Forest Management Act (NFMA) (P.L. 94-588, sec 6 (g) (3) (B)), on SNF. Specific

guidance has been incorporated into design measures for the project; see Appendix B –

Design Criteria.

The proposed project is responsive to and is consistent with the following:

Land Allocations

1. WUI core defense, defense and threat zones - 2. California Spotted Owl Protected Activity Centers (PACs) 3. Northern Goshawk PACs 4. Riparian Conservation Areas

Land Management Plan Direction 5. First Amended Regional Programmatic Agreement (Regional PA) Among the

USDA Forest Service, Pacific Southwest Region, California State Historic Preservation Officer, and Advisory Council on Historic Preservation Regarding the Process for Compliance with Section 106 of the National Historic Preservation Act for Undertakings on the National Forests of the Pacific Southwest Region dated 2001, or successor PAs.

6. Stream Management Zones – Forest Service Handbook(FSH) 2509.22 Sierra Supplement #1

7. Applicable SNF LRMP Standards and Guidelines 8. Forest Service Landbird Conservation Strategic Plan (2000), Executive Order

13186 (2001), Partners in Flight North American Landbird Conservation Plan


2004 and Memorandum of Understanding between USDA Forest Service and the US Fish and Wildlife Service to Promote Conservation of Migratory Birds (2008).

PURPOSE AND NEED

Purpose

Fuelbreaks provide a permanent defensible space for firefighting forces to stop wildfires that

threaten the WUI communities of Auberry, Tollhouse, Alder Springs and Pineridge. The

proposed treatments are necessary to reduce the risk and intensity of wildfires that threatening

the adjacent wildland urban intermix communities, which are situated along the front range of

the District

The underlying purpose is to: provide a system of well maintained fuelbreaks of low growing

vegetation, maintain the roads that access the fuelbreaks and treat invasive species.

The objectives for the project would focus on:

a. To maintain the defensible space that exists on the Beal, Vincent, Burrough, Lerona, Powerhouse and Shaver Springs/Upper Sycamore fuelbreaks that allows land management agencies to deploy firefighting resources and personnel in a safe and effective manner during fire suppression efforts. b. To remove the encroaching brush that has started to reinvade the fuelbreaks prior to it growing so dense that the fuelbreaks would lose their effectiveness for fire management. c. To minimize the level of work and the costs necessary to recreate the fuelbreaks if they were to be left un-maintained. d. To minimize the impacts of mechanical methods in maintaining fuelbreaks and vegetation modification projects in favor of spraying brush with herbicide application(s).

1. Treat fuelbreaks that are essential in slowing fire spread during fire control actions, reduce fire intensity and spotting potential, while allowing fire fighting forces to make a direct attack on fire, allowing for a safe anchor point.

2: Create and annually maintain a hand line along the east side of Powerhouse Road that will

act as the first line of defense to slow or stop a wildfire that ignites above the road.

3: Maintain access to forest roads that support fuelbreaks. Repair access roads to Burrough,

Beal and Powerhouse fuelbreaks.

4: Use the herbicide glyphosate to treat occurrence of yellow star thistle on the fuelbreaks.


Need for Action

The fuelbreaks proposed for maintenance are currently regrowing large brush to such an extent

that they are becoming indefensible and will become ineffective for fire control actions. The

newly proposed Powerhouse Fuelbreak is a prominent ridge used in three recent fire control

actions (1989, 2002 and 2007 Powerhouse Fires). The Forest Service‟s proposal to reconstruct

and permanently maintain this fuelbreak would provide a defensible space for fire crews to stop

future fires that are advancing toward the town of Auberry. Construction and maintenance of a

more permanent fuelbreak would require less heavy equipment use and provide for more

resource protection then the continual re-bulldozing of the fire line during a wildfire, as has

occurred in the past decade. Road brushing projects proposed for Powerhouse and Jose Basin

Roads provide for firefighter safety by giving firefighters an advantageous location in which to

start constructing fire line without high intensity fire and spotting issues; thus giving the

suppression forces an opportunity to suppress fire before it grows into an extended attack.

If the brush on existing fuelbreaks is left untreated, the fuelbreaks would return to the typical

combination of dense oak and large brush common in the Sierra Nevada foothills. This would

cause them to lose effectiveness for fire management. The fuelbreak system on the District is a

key component in the fire management strategy for the urban/forest intermixes along the

foothills of eastern Fresno County. As an example; The Beal Fuelbreak has been used in fire

suppression activities 17 times since its initial creation in 1933. The construction of the new

fuelbreak (Powerhouse Fuelbreak) is necessary to have in place a strategic line of defense that

firefighters can use to make a stand against fire in an area that has seen three large wildfires in

less than a decade.

Access to the Burrough and Beal fuelbreaks has been compromised due to the condition of the

access roads. These roads are currently heavily rutted and nearly impassable to four wheel-

drive vehicles or have overgrown to the extent that large fire vehicles cannot use the road. The

access road to the proposed Powerhouse Fuelbreak is in good condition at this time, but work

needs for future access should to be analyzed at this time.

Summary of Proposed Action

This project would involve a combination of mechanical and chemical methods to reduce the

proportion of certain fast growing shrubs to a level where these fuelbreaks can be maintained as

a pre-established strategic control system in the event of a wildfire. The project also includes the

brushing of Powerhouse and Jose Basin roads and the creation of a hand cut fire line (P-Line)

on the uphill portions of the Powerhouse using handtools.

Refer to Project Maps – Figure 1-2 and 1-3, pgs 8 and 9.


Decision to be Made

The decision to be made by the District Ranger (responsible official) on NFS lands is two-

fold:

1. Whether to implement the proposed action, take action through an alternative

combination of activities, or take no action at this time, and

2. Determine whether to prepare an environmental impact statement or a finding of no

significant impact (FSH 1909.15, Chapter 41.1).

The decision does not include or incorporate specific project activities found in other NEPA

documents that have had project areas that either overlapped or were immediately adjacent

to the Fuelbreak Maintenance Project.

The proposed action is consistent with the Sierra National Forest Land and Resource

Management Plan as amended. The action alternatives are consistent with the strategy of

the National Fire Plan (May 2001)


Figure 1-2. High Sierra Fuelbreak Maintenance Proposed Project (north)


Figure 1-3. High Sierra Fuelbreak Maintenance Proposed Project (south)


PUBLIC INVOLVEMENT

Public involvement for the Fuelbreak Maintenance Project included the collaboration described

in Collaboration above publication in the SNF Schedule of Proposed actions since April 2008,

as well as the formal public scoping approach, which included the mailing of a scoping letter.

On June 18, 2008 a letter was mailed to 134 members of the potentially interested public, local

Native American Tribes, adjoining property owners and public agencies describing the scope of

the High Sierra Fuelbreak Maintenance Project and requesting input. Two letters and three

emails were received and well as numerous phone calls from adjoining landowners.

RESULTS OF SCOPING AND ISSUES

Issues: Public scoping identified one significant issue with this proposal and no non-significant

issues. The one significant issue is that the use of herbicides is controversial and a new action

for control of vegetation on fuelbreaks; a request was made to explore the feasibility of

maintaining fuelbreaks using every method available excluding herbicides. Based upon this

issue being raised, a no herbicide use alternative (Alternative 3) is included in this

environmental assessment.

chapter 1 purpose and need for proposed...

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