- Forest Health
- Watershed Protection
- Wildlife Habitat
- Improved Home Protection from Wildfire
- the area of the Forsythe II project is all above 7600′, in the northern half of Colorado, and falls into the upper montane zone, with a historical fire rotation of 100+ years, fire exclusion has probably had little effect on the forest. [1,2,5,8]
- this fire regime is one of mixed intensity fire, with a predominance towards moderate and high severity fire, primarily dependent on weather and terrain, not on fuel density, thinning will likely have few mitigating effects on fire in this area. [1,2,3,4,5,6,7,8]
- the upper montane zone is not an area that has ever been similar to the pure ponderosa, open stands of the lower montane zone and that this area actually is transitioning to sub-alpine, as evident by the dominance of lodgepole pine over ponderosa or Douglas fir, all attempts to convert it into a lower montane zone should be abandoned. [1,5,8]
- continued chronic disturbances may degrade forest resilience, more recovery time should be allowed for the forest to continue in its return to equilibrium, along with allowing nature to determine resilience, rather than human guesswork. 
- the units proposed for treatment (in original Forsythe2 proposed action) have been clearcut, patch-cut, burned, &/or thinned multiple times in the past 100 years and have not, according to that proposal, been sufficiently mitigated, it could be concluded that this type of treatment doesn’t work. 
- this is a fragmented area of forest WUI, with roads, residences, reservoirs, recreational trails, and small patches of forest, in which reside diverse species of wildlife, further cutting will have a negative impact on overall habitat for current species. 
- as the forest is opened, facilitating human traffic through the forest, including recreational users creating more social trails, which increases human pressure on wildlife, further cutting would have negative impacts on wildlife. 
- the wildlife in the area have not been monitored, catalogued, or studied for current health by the USFS, there is no evidence that changes would have a positive impact.
- this is an important migration corridor and core habitat for the Winiger elk herd, which has already been impacted by cutting and trails, further depredations could have a severe impact on the herd’s ability to utilize traditional wintering and calving grounds. [11,12]
- Douglas firs are an important wildlife resource, providing nesting habitat, hiding & thermal cover, and forage for many species of wildlife, large and small, including American martens, blue grouse, Cooper’s & sharp-shinned hawks, chipmunks, and numerous songbirds, the emphasis on removing these trees from the landscape is misguided. The same is true for dwarf mistletoe. 
- producing more surface fuels, as scattered or piled slash, does not mitigate for fires, or promote forest health, slash should be removed, not increased by more cutting. [3,7,+]
- trees protect the watershed by providing shade to help retain soil moisture and increase soil absorbency, by holding soil on hillsides with their roots, and by providing a natural regulatory effect by taking in and releasing water, they should be retained, not cut, especially as tree removal can increase flood potential. [15,16]
- research has shown that pulsed disturbances from fire may be less deleterious than chronic watershed impacts from repeated treatments, mitigation should not be attempted. [8,15,17,16]
- research has shown that the best defense for homes in the WUI is to have a mitigation zone up to 100′ around the home, emphasis should be placed on this action. [3,9,18,19]
- residents and recreational users place a high value on a sense of wilderness and the biophysical factors that contribute to these natural amenities and that this importance is integral to community well-being, both socially and economically, any forest treatments that degrade this sense of wildness will be detrimental to
the community and county. 
- the “Theme” for the ARF Forest Plan emphasizes providing adequate amounts of quality forage, cover, escape terrain, solitude, breeding habitat, and protection for a wide variety of wildlife species and associated plant communities, as well as limited management, and given the above facts, less intervention is more in line with the Forest Plan.
Units that were treated in the past 20 years should be assessed for conifer regeneration (trees < 18 years old). While dense lodgepole growth is the norm, some thinning of the regeneration at this stage could allow for increased growth and root strength, both of which would be advantageous given the high winds in this area.
The amount of regeneration thinned should be based on slope, aspect, species, and adjacent stands. Regeneration thinning on steeper, north facing slopes should be minimal to provide wildlife cover, moisture & soil retention, and prevent surface fuel growth (800-1400 stems/acre, spacing – irregular). On gentle slopes and south facing slopes, thinning of regeneration can be more aggressive to achieve a somewhat more open forest, although with clumps and heavier patches to provide cover and migration corridors for wildlife. Where ponderosa have regenerated, lodgepole can be thinned away from them. In areas of Douglas fir and
lodgepole, thinning would be consistent with historical variation for those species. (Basal area for sparse to moderate lodgepole would be 80-150 ft2/acre, or 300-700 stems/acre, 6.6′-10′ random spacing betweentrunks). 
Areas that were cut in 2014 will need to be monitored and slated for regeneration thinning in the next 10-15 years.
Surface Fuel Reduction:
As fire still seems to be perceived as a threat to be mitigated, rather than an integral part of ecological restoration, addressing the preponderance of surface fuels in the area would be the best way to mitigate. The 1000’s of slash piles produced by the USFS in the last 20 years should be removed, either by chipping & spreading (no deeper than 1″), incineration (preferably with mobile incinerator), or removed off-site. Burning all of these piles in situ produces high heat (inconsistent with natural fires), especially as many consist of cut boles, that sterilizes the soil, alters the soil chemistry, and kills natural seeds, such that nothing grows for years and/or invasive weeds are most likely to colonize the sites . Many of the piles are barely ten feet apart, meaning that quite large areas will be at risk for invasive weeds, if piles are burned in situ, as well as an increased risk of escaped fire. Piling slash can also facilitate an increase in bark beetles, increasing mortality in residual trees (Six et al. 2002)
There are numerous areas with heavy downfall of small diameter lodgepole pines. Although woody debris is an important component to the ecosystem, providing habitat and nutrients to the forest floor as they decay, it is a slow process and they act as abundant surface fuel. It may not be practical to remove some of this debris, but it would be more effective as fire mitigation to do so, rather than to cut the forest. The natural progression of lodgepole forest is dense growth, followed by self-thinning, leading to undergrowth of other species. 
Past treatment efforts have caused a proliferation of invasive weeds, particularly in sites that were treated by machine. Many of these weeds are highly flammable (e.g., wooly mullein, cheat grass) and should be removed. Canadian and Musk thistle spread rapidly and affect neighboring properties. These also need to be removed from FS lands. More personnel and funds are required to address this problem, which will only expand if not addressed now.
Private Home Defensible Space:
Property owners in cooperation with the Colorado State Forest Service and Boulder County are continuing to create areas of defensible space around homes and other improvements on private lands. In order to comply with home insurance companies, some private landowners have been required to complete defensible space mitigation around their homes. Defensible space is the area around a home or other structure that has been modified to reduce fire hazard. In this area, natural and manmade fuels are treated, cleared or reduced to slow the spread of wildfire. Creating an effective defensible space involves a series of management zones in which different treatment techniques are used. The materials the home is built out of, what you store on and around your home, and vegetation present within 30 feet of your home have the greatest influence over whether your home will survive a wildfire. 
Some of these private homes are in close proximity or adjacent to Forest Service lands. One of the purposes of this project is to provide homeowners the ability to complete the required defensible space across their property boundaries onto National Forest System lands.
In areas where there are private homes located within 100 feet of the Forest Service boundary, within the project boundary, private property owners would be permitted to complete defensible space treatments on Forest Service lands in accord with the USFS. Treatment would follow the guidelines outlined by the QUICK GUIDE SERIES FIRE 2012-1. Protecting Your Home from Wildfire: Creating Wildfire-Defensible Zones. http://static.colostate.edu/client-files/csfs/pdfs/FIRE2012_1_DspaceQuickGuide.pdf
There are three zones that characterize defensible space and are defined as the following:
- Zone 1 is the area nearest to the structures that requires maximum hazard reduction. This zone extends up to 30 feet outward from a structure where the most flammable vegetation would be removed including most trees. Remaining trees would be pruned to a height of 10 feet from the ground and be spaced at least 30 feet between crowns.
- Zone 2 is a transitional area of fuels reduction between Zones 1 and Zone 3 or the forest. Typically this zone should extend at least 100 feet from structures. Stressed, diseased, dead or dying trees would be removed along with ladder fuels. Trees would be thinned to a crown spacing of at least 10 feet. Retained trees would be pruned to a height of 10 feet from the ground. Groups of trees may be left in areas however these groups would have at least 30 feet spacing between the crowns of the group and any surrounding trees.
- Zone 2 could be extended to 200′ from the structure, where it slopes steeply down from the house. Thinning between tree crowns would occur to an average spacing of 10 feet. Ladder fuels may be removed from underneath retained trees.
- Zone 3 does not apply in this case, as it is has no defined distance and is only to extend to the homeowners property boundaries. Studies have shown that a distance of 30-100’ is sufficient to protect homes from crown fires. [18,19]
Patrols and Enforcement:
Although the danger of lightning strike caused fire is ever present in this area, human caused fires are the most prevalent. The best form of mitigation is to reduce fire starts. Longer fire bans, bans on dispersed shooting, along with increased patrols and enforcement to ensure compliance, will do more to reduce the threat of catastrophic fire than any amount of thinning or patch cutting. Funding is required for these activities.
To improve wildlife habitat, one must first know what wildlife species are present and the types of habitat preferred by those species. The most recent study on the migration corridor for the Winiger Elk Herd was conducted in 1980’s. Large patches of forest have been cut and thinned since that time. Many residences have been built since that time, as well. Both of these may have had an undocumented impact on the elk herd. The Forsythe Project area falls directly in the path of the historical migration corridor. While elk do like open areas for browse, they need the shelter of denser forest to protect them from winter winds and to provide cover during migration (which can coincide with hunting season or calving).
Northern Goshawks, Ferruginous and Rough Legged Hawks, Golden Eagles, Lewis’ Woodpeckers, Chorus Frogs, American Marten, American Mink, North American Porcupine, and River Otters are among a number of animals that have been sighted in this area and which are listed on Boulder County’s list of “Wildlife Species of Special Concern”, as well as on other lists. Many of these species require special habitats, including retaining wetland and dense forest, as well as protection from human contact. “Some wildlife species have adapted to limitations of suitable patches and tolerate habitat fragmentation, others may take advantage of changes and colonize new openings, however, with human habitation have come more openings and fragmentation, so those species that do not tolerate fragmentation and loss of denser habitat may suffer decline.” Without a study to determine which species are present, where they are, and what habitat is essential for them, we can have no idea of how to improve habitat. Their presence would indicate that they are finding appropriate habitat, so to make changes, without knowledge, is to risk destroying essential habitat.
While it can be said that there is more habitat for these animal species in other parts of the forest, over time more and more habitat is removed from the landscape, with poor results for many species. The USFS needs to look at the mosaic of both public and private lands to determine available types of habitat. Personnel and funding should be provided to perform wildlife studies before any major changes to the forest structure are proposed.
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