Attachment 4 - Environmental Assessment.pdf

United States Department of Agriculture

Hermits Peak Calf Canyon and Luna Post-Fire Recovery Project Final Environmental Assessment

Forest Service Carson National Forest/Camino Real

Ranger District 10/30/2023

HPCC & Luna Post-Fire Recovery Project 2023-10-30

Table of Contents List of Tables List of Figures Introduction Purpose and Need for Action Proposed Action

Design Elements Project Maps

Alternatives to the Proposed Action No Action Alternative

Alternatives Considered but Eliminated No Treatments within the Pecos Inventoried Roadless Area

Environmental Impacts National Forest Management Act (NFMA) - Land Management Plan Consistency

Cultural / Heritage Engineering (Roads) Hydrology & Soils Noxious and Invasive Plants Recreation & Recreation Opportunity Spectrum Scenery Vegetation Supporting Project Documentation

Other Law, Regulation and Policy Consistency Government to Government Consultation (EO 13175) Relevant Executive Orders

Agencies, Organizations, Tribes, and Persons Consulted Native American Tribal Governments Collaborative Groups Elected Officials Individuals

References Appendix A – Project Design elements Appendix B – Project Area Maps Appendix C – Consideration of Draft EA Comments

List of Tables Table 1. Applicable project file documentation to support NFMA compliance Table 2. Threatened, endangered, proposed or candidate species and critical habitat effect determinations Table 3. Applicable project file documentation to support Endangered Species Act compliance Table 4. Applicable project file documentation to support agency species of conservation concern compliance Table 5. Special management area compliance determinations for the proposed action Table 6. Applicable project file documentation to support special management area compliance Table 7. Applicable project file documentation to support National Historic Preservation Act compliance Table 8. Applicable project file documentation to support Government to Government consultation compliance ... 36

List of Figures Figure 1 Hermits Peak Calf Canyon & Luna Post-Fire Recovery Project Area Vicinity Map Figure 2. Treatment Locations within the Pecos Inventoried Roadless Area Figure 3. Pecos Inventoried Roadless Area and Alamitos Eligible Wild and Scenic River within the Hermits Peak Calf Canyon Project Boundary Figure 4. Proposed Reforestation Treatment Areas within the Hermits Peak Calf Canyon & Luna Post-Fire Recovery Project Boundary Figure 5. Mechanical Treatment Areas within the Hermits Peak Calf Canyon Project Boundary Figure 6. Authorized and Temporary Roads to be used for Implementation within the Hermits Peak Calf Canyon Project Area Figure 7. Authorized and Temporary Roads to be used for Implementation within the Luna Fire Project Area Figure 8. Semi-Primitive Non-Motorized Recreational Opportunity Spectrum Class within the Hermits Peak Calf Canyon Project Area Figure 9. Desired Scenic Integrity Objectives for the Hermits Peak Calf Canyon & Luna Post-Fire Recovery Project Figure 10. Ecological Response Unit (ERU) Classes for the Hermits Peak Calf Canyon Project Area Figure 11 Burn Severity Classes within the Hermits Peak Calf Canyon and Luna Post-Fire Recovery Project Area 54

Introduction In section 40807 of the Infrastructure Investment and Jobs Act of 2021 (Public Law 117-58 Nov.

15, 2021) the Secretary of Agriculture may determine an emergency situation occurs on National Forest System land for which immediate implementation of one or more emergency actions is necessary to achieve relief from hazards threatening human health and safety or mitigation of threats to natural resources on National Forest System land or adjacent land. The actions to address the emergency situation include emergency actions, which include, but are not limited to the salvage of dead or dying trees, the reforestation or replanting of fire-impacted areas, the removal of hazardous trees in close proximity to roads and trails, and the removal of hazardous fuels.

In December 2022 the Forest Service sent a Decision Memorandum to the Department of Agriculture Secretary Tom Vilsack defining an emergency situation for post-fire recovery areas, stating:

“Post-Fire Recovery Areas. An emergency situation as defined in IIJA section 40807 exists in certain areas that experienced high intensity wildfire in Fiscal Year 2022, including National Forest System lands in: (1) New Mexico (Catron, Colfax, Grant, Lincoln, Los Alamos, Mora, San Miguel, Sandoval, Sierra, Socorro, Taos, and Valencia counties), (2) Arizona (Coconino and Yavapai counties), and (3) California (Alpine, Amador, Butte, El Dorado, Humboldt, Kern, Lassen, Madera, Mariposa, Plumas, Shasta, Santa Barbara, Siskiyou, Tehama, Trinity, and Tulare counties).

Immediate implementation of emergency actions is necessary to provide relief from threats to public health and safety and/or to mitigate threats to natural resources on National Forest System land or adjacent land (including Tribal reservation and trust lands). The health and safety of communities, including Tribal communities, in these counties is threatened by falling trees, obstructed emergency evacuation routes, flooding, landslides, reburns, and lost infrastructure caused by wildfire and post-fire floods. The Chief of the Forest Service shall monitor and reassess this situation and recommend to the Secretary the need to include additional areas affected by wildfires or natural disasters or remove areas where this designation is no longer needed.”

In January 2023, Department of Agriculture Secretary Tom Vilsack announced expanded efforts to reduce wildfire risk and recover areas that experienced high intensity wildfire in 2022, including Taos and Mora Counties.

Using the authorities provided in the IIJA, the Carson NF was approved for the Emergency Authority Determination (EAD) for the Hermits Peak Calf Canyon & Luna Post-Fire Recovery Project under the Bipartisan Infrastructure Act section 40807 (USDA 2023). Under EAD, the project would not be subject to the pre-decisional objection process.

Purpose and Need for Action During the spring/summer of 2022 the Hermits Peak Calf Canyon Fire (HPCC) burned over 340,000 acres between early April and late June in the southern Sangre de Cristo Mountains in San Miguel, Mora, and Taos counties New Mexico. The footprint of the fire is spread across the Pecos/Las Vegas Ranger District of the Santa Fe National Forest and the Camino Real Ranger District of the Carson National Forest (Carson NF) in Northern New Mexico.

The Luna Fire ignited from an abandoned campfire on October 17, 2020, and grew to 10,142 acres before it was fully contained in November 2020. The fire footprint fell within the Sangre de Cristo Mountains in Mora County approximately five miles north of the community of Chacon and on the Camino Real Ranger District of the Carson NF. The Luna Fire is located north of the Hermits Peak Calf Canyon Fire and a portion of the footprint of this fire is within the Enchanted Circle Wildfire Crisis Strategy Landscape.

These fires changed the condition of vegetation on these landscapes, specifically the spruce-fir type. There is an increase in dead and downed, dead and standing, and coarse woody debris, which without treatment will accumulate on the ground leading to fuels build-up beyond desired conditions, an increase in risk to insect and disease outbreaks (Carson National Forest Land Management Plan (Forest Plan) (FW-VEG-DC-1, 2, 3 and FW-SL-DC-2) and increase the risk of safety to forest visitors and local communities, like Angostura. There is a need to remove the accumulation of dead material within the Hermits Peak Calf Canyon and Luna fire boundaries as soon as possible to lessen these risks. There is also an urgency to support recovery efforts for the Hermits Peak Calf Canyon Fire, including economic recovery, which this project would support.

In addition to ecological conditions, the Forest Service is conducting joint operations that facilitate an integrated response and recovery approach to the current disaster and to possible future events associated with FEMA-4652-DR-NM for the Hermits Peak Calf Canyon fire. This work is being conducted as part of the State of New Mexico unified recovery objectives, organized through seven Lines of Effort for Recovery. The defined Lines of Effort are Community Outreach, Drinking Water, Economic Recovery, Health and Social Services, Historical and Cultural Resources, Housing Recovery, and Watershed Mitigation. As part of this operation the Carson NF is working to provide wood to local communities through opening fuelwood gathering areas or supplying fuelwood to fuelwood bank systems. This project would meet the needs of these communities, and Forest Plan desired conditions, for fuelwood FW- RHC-DC-2, 3, 4 and FW-FFP-DC-1).

Additional recovery efforts beyond vegetation thinning which are covered under the FEMA Programmatic Environmental Assessment (PEA) also need to be addressed within the Hermits Peak Calf Canyon portion of the project area. The purpose of including these treatments is to be proactive and match similar treatments occurring on lands outside the National Forest System within the Hermits Peak Calf Canyon Fire boundary. These treatments are intended to mitigate watershed impacts downstream and or accelerate watershed recovery after fire and flooding.

With the changed condition to primarily spruce-fir and pockets of mixed-conifer vegetation in this landscape there is a need for reforestation to occur. Reforestation will allow for more of a mosaic of life stages of conifer species such as spruce, Douglas-fir, and white pine within this early seral condition.

The purpose of this project is to address the ecological conditions of increased fuel accumulation, reduce debris impacts on water flow and downstream communities within the Hermits Peak Calf Canyon and Luna fire footprints by removing dead and downed, dead and standing, and coarse woody debris from these areas, and reforesting areas to improve stand classes. This will also have additional beneficial effects to habitat connectivity and watershed recovery. This project will also provide for economic recovery by providing the removed material to local communities impacted by the Hermits Peak Calf Canyon Fire.

If no action is taken to meet desired conditions and address the ecological and social impacts caused by the Hermits Peak Calf Canyon and Luna fires it is anticipated that there may be an increase in dead and down material, increasing fuel loads and the risk of wildfire, increasing risk to insect and disease, impacting public safety within the burned areas, and reducing habitat connectivity and reforestation due to heavy coarse woody debris.

Spruce-fir stands were also impacted by the HPCC fire within the Pecos Inventoried Roadless Area (IRA) and Alamitos Creek eligible wild and scenic river corridor. If no action occurs there would continue to be impacts to the ecological conditions in these areas as well. There is continued risk for the area to re-burn due to the amount of fuel loads in these areas, which would lead to further impact to the outstanding remarkable value, Rio Grande cutthroat trout, in Alamitos Creek, as well as impact the fish barrier protecting this species habitat. If trees are not removed within the IRA, restoration efforts such as reforestation, would be lessened and there would be an increased risk to public safety in accessing these areas from designated routes.

Proposed Action The project area includes the Hermits Peak Calf Canyon and Luna fire burn boundaries (about 24,420 acres) (Figure 1). Treatments would not occur within the Pecos Wilderness and private lands located within the burn areas. Project activities will occur within a small portion (less than 5%) of the Pecos Inventoried Roadless Area (IRA) and the Alamitos Creek, an eligible wild and scenic river (WSR), as compliant with IRA and WSR guidance and consistent with the outstanding remarkable values of these areas (Figure 2 & Figure 3).

Reforestation

• Acreage within the entire burned areas (HPCC and Luna Fire) affected by moderate to high-severity fire on the Carson National Forest will be assessed for artificial regeneration (tree planting activities). Approximately 3,500 acres have currently been identified for potential hand tree planting activities within the HPCC fire footprint and an additional 5,000 acres within the Luna fire footprint (Figure 4). However, if through monitoring, other areas are identified as needing reforestation, those treatments would follow what is outlined below.

• Local stock of conifer species such as Douglas-fir, Engelmann spruce, blue spruce, white pine, ponderosa pine, and aspen may be considered for planting.

• Trees may be planted with tools such as a tree auger or hoe-dad to create planting holes.

Scalping of 2 X 2-foot dimensions may also be considered to remove competing vegetation. Shelters may also be installed to prevent ungulate browsing and to potentially provide shade for seedlings.

• Tree planting will occur at the appropriate time of year when soil moisture is adequate at specific elevational bands and when moisture is best forecasted to improve chances of survival.

• Authorized Forest Service roads would serve as primary access to project areas; however motorized trails, and temporary roads may be used for transportation of hand tools and seedlings to planting units.

• Post-planting survival surveys would be conducted one year, three years, and five years following planting activities to track survival and stocking. Wooden or plastic stakes may be driven into the ground to mark trees falling within line transects for continued monitoring and certification purposes.

Reforestation in the Pecos Inventoried Roadless Area

• Only hand planting methods would be used.

• No motorized use would occur within the IRA.

• No road construction or use of temporary roads would occur within the IRA.

Material Removal Small wood products (e.g., fuelwood, latillas, vigas, etc.) removal treatments would occur where stands meet these conditions:

• Stand has a higher density and/or tonnage of dead and downed, dead and standing, or coarse woody debris that would exceeds accumulations of 40 tons per acre;

• Slopes are less than 40%; and

• Areas can be easily accessed from an authorized or temporary road.

Within the project area, approximately 21,765 acres have currently been identified as meeting requirements for treatment (Figure 5). However, if through monitoring, other areas are identified as meeting the criteria they may also be treated in a like manner. The removal of material would be conducted by ground-based and personal fuelwood gathering methods. Treatment units include:

• Alamitos – 4, 300 acres

• Vigil Canyon – 355 acres

• Picacho-Holman Hill – 4,735 acres

• Angostura – 3, 680 acres

• IRA – 655 acres

• Luna Fire – 8,040 acres

Ground-based material removal

• Material would be mechanically cut, skid, processed, and decked at all landings;

• Incidental removal of individual live trees may be necessary for landings, skid trails, and road clearing;

• Treatments will primarily occur on slopes less than 40%;

• Slash may be treated by lop and scatter or by piling depending on the density of material laid on the ground;

• General road maintenance to allow for ingress/egress as well as proper drainage to maintain road integrity will occur where needed (32.2 miles). Road maintenance includes:

o Curve-widening to allow for larger vehicles to access sites o Clearing vegetation along routes to allow for larger vehicle access

Hardening water crossing, installing culverts, or if needed installing temporary bridges to protect water resources

• Certain non-system routes would be designated as temporary roads (58.1 miles) for only activities related to tree removal and will be decommissioned after the end of the project (within semi-primitive non-motorized areas within two years of project completion; all other areas within five years after project completion. Project completion is defined as completion of treatments within a designated treatment unit) (Figure 6 & Figure 7).

o Decommissioning these routes would include, but would not be limited to, installing gates, removing infrastructure (culverts, etc.), or creating berms, and any other activity that would not allow the public to access the road after treatments have ended. Agency resource specialists will also ensure that other rehabilitation activities will be conducted to enhance and protect resources and ensure the route returns to a natural state.

• A temporary bridge would be re-placed over Alamitos Creek (outside the IRA and eligible WSR corridor) for equipment to access treatment areas. This bridge was removed after the 2013 flood along Alamitos Creek.

• No new road construction would occur.

• No treatments would occur within green islands (pockets of live trees) within the project area.

• Skid trails and landings will be determined on-site, but will not occur in sites that:

o Have sensitive cultural resources o Are sensitive riparian or wetland areas; or o Identified meadows

• Replace a temporary bridge over Alamitos Creek to provide access along Forest Service road 161D to access portions of the Alamitos and IRA treatment units.

Ground-based material removal may use equipment such a Cut-to- Length system. In a Cut-to-Length system the equipment can be tracked or rubber-tired machines.

A benefit of this harvester/forwarder system is the harvester places tops and limbs in the forwarding trail that provides a "slash cushion" for the forwarder. This cushion reduces the soil displacement, compaction, and erosion potential that is usually associated with traditional ground-based systems while the forwarder carries logs completely free of the ground. Since the logs are not dragged, the load is evenly distributed on the axles of the forwarder. This contrasts with the loaded ground pressure on the rear wheels of rubber-tired skidders and the back 1/3rd of the tracks on tractors. The even load distribution on the forwarder results in greater traction and less wheel slip, which reduces soil displacement and compaction. In the same manner, since the logs are being carried by the forwarder rather than skidded, unit and road damage as well as surfacing loss/contamination is minimized. The forwarder can take the place of 2 or 3 skidders.

In many cases the forwarder can off-load directly onto trucks/landings, thereby eliminating the need for a separate log loader and operator at the landing.

Ground-based Material Removal within the Pecos Inventoried Roadless Area and Alamitos Creek Eligible Wild and Scenic River

The above project activities will be implemented with the following adjustments in the Pecos Inventoried Roadless Area and Alamitos Creek Eligible Wild and Scenic River:

• A cut-to-length system (see Photo 1) will be used for mechanical treatment to remove trees.

• No new roads or temporary roads will be constructed.

• Material will be hauled to a location outside the Inventoried Roadless Area and eligible wild and scenic river corridor for distribution to the public.

• Within the Inventoried Roadless Area, trees will be cut as low to the ground as possible

(maximum 6 inches).

• Treatments within these areas will be completed within two years from the start of treatment.

• Small material (less than 5 inches dbh) will not be removed.

• No mechanized equipment or tree removal would occur within the riparian management zone (100 feet), except where treatment is identified to protect the fish barrier structure.

Personal Fuelwood

• General road maintenance to allow for ingress/egress as well as proper drainage to maintain road integrity.

o Road maintenance will include:

Photo 1 Photograph of a Cut-to-Length system used for ground-based material removal

Curve-widening to allow for larger vehicles to access sites Clearing vegetation along routes to allow for larger vehicle access Hardening water crossing, installing culverts

• No treatments would occur within green islands within the project area.

• Treatments would most likely occur on slopes less than 40%, with the majority on slopes less than 30%.

• A permit will be issued to the public for gathering fuelwood within the project area, authorizing them to use temporary roads to access dead trees. The permit will state that no green trees are to be cut.

Slash Management

• Slash at landings would be redistributed in areas where down wood debris would facilitate recovery such as covering bare soil. Minimal pile burning is anticipated to occur (due to the need for biomass in the form of fuelwood) and as previously stated for watershed recovery. Pile burning would follow the National Prescribed Fire Resource Mobilization Strategy (June 2023) and only when proper conditions allow.

• Slash may also be left on site and may be lopped and scattered or used as slash mats on steeper ground where ground-based equipment may be operating.

Stabilization of Recreation Sites or Uses

Vehicle access is needed at the Serpent Lake Trailhead and along 0.10 mile at the beginning of the trail which will require stabilization of a large head-cut to allow for temporary vehicle access.

This work will include:

• Armoring the area to reduce the expansion of the head-cut

• Placing boulders around the parking lot to reduce vehicle trespass

• As part of decommissioning the use of the temporary road, place a walk-through gate at the trailhead

Additional Recovery Efforts

Additional recovery efforts beyond vegetation thinning which are covered under the FEMA Programmatic Environmental Assessment (PEA) will occur within the Hermits Peak Calf Canyon Fire portion of the project area. These activities include noxious weed abatement;

restoration and reforestation of fire-adapted vegetation types; restoration of riparian areas; post-wildfire hillslope stabilization treatments, including aerial seeding; post-wildfire channel treatments; post-wildfire road, culvert, and trail flow diversion treatments; post-wildfire ash, sediment, and debris removal and infrastructure repairs; structure demolition, relocation, or alteration; and hydraulic capacity improvements and protection of water infrastructure. The specific areas for these treatments will be determined after assessments have been completed.

Design Elements

For a list of design elements incorporated into the proposed action to ensure land management plan compliance see Appendix A.

Project Maps

All project maps can be found in Appendix B.

Figure 1 Hermits Peak Calf Canyon & Luna Post-Fire Recovery Project Area Vicinity Map

Alternatives to the Proposed Action No Action Alternative

A no action alternative must be analyzed if a project has been identified as an emergency action responding to an emergency situation as defined in the Bipartisan Infrastructure Investment and Jobs Act, section 40807(b)(3)(c)(B).

Within the Hermits Peak Calf Canyon and Luna fire boundaries the current condition of dead and standing, dead and down, and other coarse woody debris would remain, with increases in the amount of dead and down and coarse woody debris overtime as dead and standing trees fall.

Personnel fuelwood permits would authorize removal of dead and down material where it is accessible along authorized Forest System routes. Any slash left from wood cutting would remain in place. No reforestation treatments would occur. Additional watershed restoration work, such as aerial seeding, would not occur. No treatments would occur in the Pecos Inventoried Roadless Area or within the Alamitos Creek eligible wild and scenic river corridor.

Alternatives Considered but Eliminated No Treatments within the Pecos Inventoried Roadless Area

The interdisciplinary team considered an alternative that would not include restoration treatments within the Pecos Inventoried Roadless Area (IRA). Conditions within this IRA are similar to those in adjacent landscapes, with large quantities of dead and standing, dead and down, and coarse woody debris outside of desired conditions and leading to threats to human health and safety, increased fuel loading, and impacts to wildlife habitat connectivity. Access into the IRA is from Forest Service roads 161 and 161D and the presence of dead and standing trees poses a threat to safety of forest visitors accessing the IRA from these roads. Reforestation treatments occurring within the IRA would not occur due to the risk to planting crews from dead and standing trees in the area. Success of planting would also be minimized with the amount of dead and standing and dead and down trees in the area which would limit the amount of sunlight needed for seedlings to grow and the risk of dead and standing trees falling into planted areas.

Natural recovery within the IRA would be slower than if restoration treatments occurred because natural re-seeding of conifer species would be hindered by the presence of dead and standing and dead and down trees. There would be detrimental impacts to wildlife habitat connectivity for big game species if dead material is not removed, leading to negative effects to the diversity of plant and animal communities. The risk to public safety in areas accessing the IRA would have a negative impact on the semi-primitive non-motorized recreation opportunities within the area.

Although in the long-term there would be benefits to the high scenic quality through natural recovery, this would not occur at the same pace as the proposed action.

This alternative was not considered in detail because it would not meet the purpose and need of increasing the pace of restoration efforts and addressing the risk to health and safety to forest visitors.

Environmental Impacts This section summarizes the analysis and disclosure of effects of the proposed action conducted to support the Finding of No Significant Impact and compliance with applicable law, regulation, and policy.

Where applicable, specialists tiered to the Federal Emergency Management Agency (FEMA) Programmatic Environmental Assessment (PEA) for the State of New Mexico Watershed Resiliency and Post-Fire Wildfire Treatments (October 2022). This document provides an analysis of the following recovery actions: vegetative thinning, hazardous tree removal, and noxious weed abatement; restoration and reforestation of fire-adapted vegetation types;

restoration of riparian areas; post-wildfire hillslope stabilization treatments, including aerial seeding; post-wildfire channel treatments; post-wildfire road, culvert, and trail flow diversion treatments; post-wildfire ash, sediment, and debris removal and infrastructure repairs; structure demolition, relocation, or alteration; and hydraulic capacity improvements and protection of water infrastructure. This analysis covers the Hermits Peak Calf Canyon fire boundary.

Ground disturbance and construction work analyzed under the FEMA PEA and will also occur under the proposed action includes:

• Site clearing, tree and vegetation cutting, clearing, and removal,

• Loosening of hydrophobic topsoil by mechanical means or hand tools,

• Initial and post treatment grading,

• Temporary stream crossings,

• Installation of erosion and sediment control measures,

• Use of staging areas for equipment, equipment fuel, and post-wildfire treatment materials,

• Temporary site access routes,

• Use of heavy equipment, such as industrial woodchippers, backhoes, augers, front-end loaders, compactors, trenchers, and trucks,

• Use of hand-operated mechanized equipment such as chain saws, hydro axes, or jack hammers,

• Use of worker vehicles to and from the project site,

• Traffic disruptions, lane closures, possible detours for projects in sites adjacent to roadways, and

• Aerial re-seeding

The environmental effects outlined below supplement the effects analyzed under the FEMA PEA and the proposed action that are more site-specific to NFS lands and compliance requirements.

The resource areas analyzed in detail include cultural/heritage, engineering (roads), fuels, hydrology and soils, noxious and invasive plants, recreation, scenery, vegetation, and special management areas (IRA and eligible wild and scenic river).

The interdisciplinary team identified issues to include in the analysis:

• Use of temporary roads and temporary road decommissioning;

• Presence of invasive or noxious plant species;

• Impacts within the Pecos Inventoried Roadless Area; and

• Impacts within the Alamitos Creek eligible Wild and Scenic River

National Forest Management Act (NFMA) - Land Management Plan Consistency

The pertinent specialists have reviewed the proposal and incorporated specific design elements or mitigation measures listed under the “Proposed Action” section above to ensure consistency with applicable land management plan direction. The following summarizes the analysis and conclusions supporting plan consistency for both the proposed action and no action alternatives.

Cultural / Heritage

Proposed Action Alternative

A preliminary review of site and survey records was conducted by the Forest Service in June of 2023. An Area of Potential Effects (APE) was defined based on the project area. Detailed confidential data was reviewed and compiled to determine the extent of past projects and site identification efforts and results. These data will provide the basis for determining the appropriate pre-implementation Section 106 compliance needs.

A cursory analysis of this data reveals a total of 69 surveys (~13,900 acres) that have been conducted within the HPCC and Luna Recovery project APE. Approximately 45 sites have been previously recorded on the forest, within that same boundary.

Cultural resource baseline information was compiled by the Forest Service for areas that are under consideration for future restoration projects as part of the HPCC and Luna Wildfire Recovery Project. This baseline information provides a greater understanding of the presence and condition of known resources, the extent and validity of cultural resource identification efforts, and site-specific resource information in the project areas. These data will provide the basis for developing a strategy for completing the Section 106 process pursuant to the Region 3 Programmatic Agreement.

Known and unknown cultural resources within the project footprint have undoubtedly incurred effects from the wildfire itself. Previous reports have documented in detail the challenges in conducting pedestrian surveys in this area due to the dense and overgrown forest conditions prior to the HPCC and Luna fires. Limited access and poor ground visibility has certainly affected the site types available for discovery during previous surveys. At this level of analysis, it is conservative to assume that there is a potential for impacts resulting from each of the project categories to occur on cultural resources.

Known resources and an informed estimate of cultural resource sensitivity and condition in un-surveyed areas are assessed based on site density, landform, and vegetation against the post-wildfire recovery actions of vegetative thinning, hazardous tree removal, restoration of riparian areas, hillslope stabilization, and road maintenance and construction access found in the project design elements in Appendix A and in the ‘Roads and Access’ section of this report. Conclusions were drawn, based on an understanding of how these types of actions may affect known and potentially discoverable resources.

Direct and indirect effects from project activities can be found in the FEMA PEA (October 2022) and are incorporated into this analysis. Project design elements would reduce the potential for erosion and direct disturbance of cultural sites, potentially maintain historic settings, and protect water resources for traditional uses. Adding in the benefits of erosion control, riparian and hillslope stabilization, vegetation restoration, currently present cultural resources would be better protected in a stable and healthy forest environment. Landscape restoration work to be implemented under this project may enhance traditional plant and animal resources valued by Native American tribes and other Rural Traditional Communities in the area. No contribution to adverse cumulative effects from the proposed undertaking is anticipated. Alternatively, the proposed undertakings would intercede the cumulative effects occurring from a post-wildfire environment. The individual projects would be designed to avoid impacts on cultural resources as much as possible and may reduce damage or loss due to erosion and enhance resources and areas valued for traditional uses.

Without the implementation of the proposed recovery and restoration activities, present cultural resources are as risk of incurring further adverse effects from increased erosion, debris flows, uprooting of hazard trees, and other related environmental effects following a severe wildfire. All of which can disturb, damage, or destroy surface and subsurface cultural deposits.

No Action Alternative

Under the No Action Alternative, existing cultural resources will be placed at greater risk of incurring further adverse effects from a post-wildfire environment; increased erosion, debris flows, uprooting of hazard trees, and other related environmental effects following a catastrophic wildfire. All such events have the capability to disturb, damage, or destroy surface and subsurface cultural deposits. This area remains a culturally important landscape to indigenous and local communities who relied on its natural resources for hundreds of years. No action in the proposed project area would inhibit the rehabilitation of the cultural ecology that is vital to communities continued traditional and cultural uses in the area.

Engineering (Roads)

Proposed Action Alternative

The project area includes a total of 32.2 miles of authorized roads and 58.1 miles of temporary roads. All miles of temporary roads refer to roads that are currently exist on the ground as non-system routes; there will be no new road construction. The HPCC project area accounts for 16.6 miles of the authorized roads and 25.8 miles of the temporary roads. The Luna project area accounts for 15.6 miles of authorized roads and 32.3 miles of temporary roads.

The maintenance and repair of the transportation network within the project boundary to pre-disaster geometric design standards and conditions will improve the hydrology of the roads with an effect of reducing sediment transport and stabilizing the road system. Curve widening will allow passage of larger vehicles for restoration activities to be accomplished while meeting the geometric design standards providing for user safety. Non-system routes identified on the ground as temporary roads will be decommissioned reducing the drainage and erosion impacts associated with these routes. Stream crossings will be addressed with either a temporary bridge, culvert installation, or hardened crossing to minimize sedimentation and potential for soil transport. Any non-native materials used will come from an approved source, certified weed-free. Associated ground disturbance will be limited to existing roads and conforming to the existing footprint unless road widening is needed to allow for equipment to maneuver safely.

Road widening is anticipated on less than two miles of road segments. Installation of the temporary bridge will occur at the previously disturbed location. Stream channel armoring and treatment of head cuts will limit disturbance to surface soils and will not impact the free-flowing nature of Alamitos Creek. It is possible that one or more of these actions would require a section 404 permit from the Army Corps of Engineers. All permits required would be acquired before implementation.

All temporary routes will be decommissioned within five years of when project activities are completed (two years within the semi-primitive non-motorized recreation opportunity spectrum class). Decommissioning of all temporary routes would include, but not be limited to, installing gates, removing infrastructure (culverts, etc.), or creating berms, and any other activity that would discourage public access to the road and provide for full recovery to native conditions after treatments have ended. These actions are consistent with the Carson Land Management Plan (FW-TFA-DC-5; FW-TFA-S-3; FW-TFA-G-1).

Additional effects analysis of project activities can be found in the FEMA Programmatic Environmental Assessment (October 2022).

The spatial boundaries for analyzing the cumulative effects to transportation are any road that insects the project area; the transportation system acts together as an entire network. The cumulative analysis considers other past, present, and reasonably-foreseeable future projects in or near the project area that will take place concurrently with the proposed action and therefore may also contribute to these impacts, resulting in cumulative effects. Similar activities will take place within the Hermits Peak Calf Canyon Fire Perimeter outside of the defined project area for this analysis; however, all proposed activities are following established BMPs and focused on improving watershed and forest health in a similar fashion and for a similar transportation system. Such actions related to the transportation system focus on reducing negative impacts from road-stream interactions and stabilizing the landscape in the current post-fire condition.

No Action Alternative

Under a no action alternative, current road management practices would continue, and the existing road system within the project area would not be modified. Routine road maintenance activities would continue primarily on National Forest System (NFS) roads, maintenance-levels (ML) 3-5, with limited maintenance performed on ML-2 NFSRs and no maintenance performed on ML-1 NFSRs. No NFSRs, existing routes or unauthorized routes would be decommissioned, closed, or obliterated. The drainage and erosion impacts associated with these routes would continue. Impacts from standing and fallen dead trees to the roads and drainage structures could include damage to ditches and drainage structures including culverts and bridges. Effects of this damage could impact significant road segments if drainage were to be redirected on to the road with loss of aggregate surfacing, native surfacing, and increased sediment into drainages adjacent to the road infrastructure. Road traffic would remain with an increased risk of hazard trees impacting the user and the road infrastructure.

Hydrology & Soils

Proposed Action Alternative

The Burned Area Report (USDA 2022c) and supporting documentation (USDA 2022d and 2022e. Hydrology Resource Report and Soil Resource Assessment) for the 2022 Hermit’s Peak Calf Canyon Fire summarize impacts to soil and water resources, describe expected short and long-term impacts to soil condition and hydrologic function and recommend treatments needed to substantially reduce the probability of damage to identified BAER critical values. The proposed action includes treatments that support the recovery process for soil and hydrologic functions.

The Burned Area Report for the 2021 Luna Fire summarize impacts to soil and water resources, describe expected short and long-term impacts to soil condition and hydrologic function and recommend treatments needed to substantially reduce the probability of damage to identified BAER critical values (USDA 2021). Due to the timing of the fire in the late fall and lack of access, reconnaissance was delayed until the following year, when several heavy rainfall events resulted in numerous damaging floods from May through August 2021.

The project area occurs in 9 sub-watersheds, seven will have less than 10% of each sub watershed affected. These areas are a very small portion of the entire watershed and will have little to no effect to the total watershed. The Luna Creek watershed has 54% of its watershed affected by this project, however it has been three growing seasons since the Luna fire and the undergrowth is showing vigorous regrowth of the understory. Mechanical treatments will occur mostly on slopes less than 40%. Given the amount of regrowth and new aspen regeneration the ground disturbance will be kept to a minimum. This reduces the risk of sedimentation reaching the nearby streams. In addition, the 100 feet buffer along all perennial and intermittent streams reduces the amount of eroded soil that can reach the streams.

The Rito Angostura/Rio Pueblo watershed has 40% of its watershed affected. Within this watershed 8,510 acres have been identified as eligible for treatment. Treatments would not occur within 100 feet of perennial and intermittent streams reducing the amount of sedimentation that will occur. Creek crossings will be designated and may have culverts or hardened crossings installed to reduce the amount of sedimentation. All temporary routes will be decommissioned within five years of when project activities are completed (two years within the semi-primitive non-motorized recreation opportunity spectrum class). Decommissioning of all temporary routes would include, but not be limited to, installing gates, removing infrastructure (culverts, etc.), or creating berms, and any other activity that would discourage public access to the road and provide for full recovery to native conditions after treatments have ended. Near the trailhead to Serpent Lake there is need for a large diameter culvert. This would replace one that had been removed. Given the shape of the channel and the existing roadbed there would not be a large amount of fill required to reinstall this culvert. This reduces the amount of sediment generated by the installation. A large head cut was identified in the Rito Angostura/Pueblo River watershed, along the La Sierra Ditch. This head cut would be armored to arrest the head cut. It is possible that this action would require a section 404 permit from the Army Corps of Engineers. All permits required would be acquired before implementation.

All project activities follow National Best Management Practices (BMPs) for Water Quality Management on National Forest System Lands for mechanical vegetation management activities, aquatic ecosystem improvement and restoration, and road management activities (USDA April 2012). As example, some of these BMPs include, but are not limited to, designing mechanical vegetation treatment prescriptions to limit site disturbance, soil exposure, and displacement to acceptable levels as determined by the Carson NF Land Management Plan; and local direction or requirements for slope, erosion potential, and other soil or site properties to determine areas suitable for ground-based systems. The proposed action includes design elements that comply with these BMPs because the majority of activities will occur on slopes less than 40%, and where work occurs on slopes greater than 40%, slash will be laid on the ground where mechanical equipment is needed to reduce soil erosion. Additional effects analysis of project activities can be found in the FEMA Programmatic Environmental Assessment (October 2022).

The proposed action is consistent with the Forest Plan (FW-FFP-S-2; FW-WSW-RMZ-G-3, 4;

FW-FFP-S-2; FW-WSW-RMZ-G-1; FW-FFP-S-2; FW-WSW-G-1; FW-WSW-RMZ-WR-S-1,

3; and FW-FFP-S-2).

No Action Alternative

Low soil burn severity across all vegetation types will see rapid vegetative recovery within 1-3 years post-fire. Moderate and high soil burn severity within drier forest types like ponderosa pine and dry mixed conifer will respond much differently. Vegetative recovery in these forest types that experienced higher levels of soil burn severity will likely be within a 10–12-year timeframe.

This is due to stand replacing fire and complete loss of soil cover. Lastly, vegetative recovery in moderate and high soil burn severity within wet forest types like wet mixed conifer and spruce-fir forests may recover more quickly that drier forest types, but recovery is dependent upon pre-fire vegetation components (e.g., aspen). This timeframe will likely be within 5-10 years due to higher levels of precipitation and soil moisture in these areas.

Threats to the magnitude, timing, and volume of storm water runoff and changes in the condition of stream channels from significant post‐ fire runoff and sediment are expected to continue.

Increased runoff, accelerated sheet and rill erosion throughout the fire areas, as well as the potential for rock fall and debris slides have the potential to alter the hydrologic function and water quality of streams within the burned area resulting in a high potential for geomorphic alteration of stream channels and departures from the watershed natural hydrograph. These impacts will have a considerable and long‐term effects. Threats to NFS property from post fire conditions (increased peak flows, potential hyper‐concentrated flows, and debris flows) would continue to exist and areas of particular concern include roads, bridges, and recreation sites downstream of burned areas within the Rio la Casa, Headwaters Manualitas Creek, Rito San Jose, and Angostura – Pueblo Creek sub watersheds.

Under the no action alternative, treatments that would reduce the potential for future high severity fire would not occur, the landscape would remain at elevated risk of producing damaging runoff events that would continue to affect beneficial uses and downstream users, and the rate of hydrologic recovery (attenuation of damaging runoff), soil recovery (improved infiltration, water holding capacity and site stability) and water quality improvement (sediment reduction) within the project area would be reduced or delayed because of high severity fire. The head cut identified in the Rito Angostura/Pueblo River watershed would continue to degrade the stream channel with reduction of floodplain and riparian function. The impact from sedimentation and potentially damaging flows to beneficial uses and downstream users because of reduced natural recovery within the project area would remain elevated.

Noxious and Invasive Plants

Proposed Action Alternative

Noxious and invasive plant species such as musk thistle, Canada thistle, hoary cress, perennial pepper weed, and Russian knapweed have been identified within the project area. Control efforts will be implemented to reduce the risk of spreading these species, these efforts include washing vehicles and equipment that enter and exit the project area. Any re-seeding activities will be done with a weed-free, native plant seed mix, also reducing the spread of noxious or invasive weeds within the project area. These additional design elements are consistent with the Carson NF Land Management Plan (FW-NIS-S-1, 2; FW-NIS-G-5, 6; FW-FWP-G-5). Reducing the tree density will also open up canopy which will promote native grasses and forbs, helping to reduce noxious and invasive species from becoming common in the project area. Additional effects analysis of project activities can be found in the FEMA Programmatic Environmental Assessment (October 2022).

The defined cumulative effects area for noxious or invasive plants includes the HUC 10 watersheds where the Hermits Peak Calf Canyon and Luna Fires occurred, Embudo Creek and Upper Mora River respectively. Current activities within these areas primarily been related to cattle grazing, recreational activities, fuelwood and other personal use forest product harvesting.

The Rio Trampas project, 2015 Green Fuelwood Areas, and 2016 Green Fuelwood Areas projects have been planned and implemented within the Embudo Creek watershed, primarily in piñon/juniper and ponderosa pine forest types. Treatments have primarily been focused on small-scale personal-use and free use fuelwood projects with some thinning and piling and thinning and lopping contracts, and some pile-burning and broadcast prescribed fire to reduce hazardous fuels. Reasonable, foreseeable future projects include the Vallecitos restoration project, which falls within the Enchanted Circle Landscape and includes the HPCC and Luna fire boundaries.

All these activities follow BMPs, project design features, and are consistent with the Forest Plan and are designed to limit the spread of noxious or invasive plant species. Although the spread of noxious or invasive plant species may continue to occur within the project area, it is not anticipated that this spread will lead to a cumulative effect within these watersheds.

Treatment of any noxious or invasive plant species would be authorized under the Final Environmental Impact Statement for the Invasive Plant Control Project. Carson National Forest and Santa Fe National Forest (USDA 2005).

No Action Alternative Noxious and invasive plant species are present within the burned area and are highly adapted to take advantage of early seral conditions created after fire and can out compete native plants for resources. There would continue to be a high risk of spread to previously un-infested areas that have been burned at a moderate to high intensity and would have considerable long-term effects on site productivity and altered soil function, with eventual displacement of native plants in these areas, with resultant degradation of soil quality. Treatment of any noxious or invasive plant species would be authorized under the Final Environmental Impact Statement for the Invasive Plant Control Project. Carson National Forest and Santa Fe National Forest (USDA 2005).

Recreation & Recreation Opportunity Spectrum The Hermits Peak Calf Canyon fire impacted several motorized and on-motorized trails, changing the recreational experience for Forest visitors from pre-fire conditions. The 11.54 miles Trails effected by HP/CC include Serpent Lake Trail (No. 19), Agua Piedra Trail (No. 19A), Comales Cutoff Trail (No. 22A), Angostura Trail (No. 493), Knob Spur Trail (No. 19D) and Rito Angostura Trail (No. 9A). The current conditions of these trails vary on the ground based on aspect, elevation and burn severity. There is currently a 0.75 mi.