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French Fire Recovery and Restoration Project

Wilderness Resource Impact Analysis

This Wilderness Resource Impact Analysis for the French Recovery and Restoration Project

(Project) includes a review of relevant regulatory direction, the existing wilderness on the Sierra

National Forest (NF), a description of the current process underway for the Forest’s Forest Plan

Revision process which may result in recommending additional wilderness to Congress for

designation, and an analysis of the effects of the Project on future potential wilderness areas.

This analysis addresses the impact of the Project on the potential wilderness character of areas

that have been considered as part of the current plan revision process and are affected by the

Project.

Affected Environment - Existing Wilderness

Designated wilderness comprises 44 percent of the total 1,322,913 acres that make up the Sierra

NF. There are five designated wilderness areas, either in whole or part, within the administrative

boundary of the Sierra NF:

Wilderness acres

and permits on

the Sierra NF

Wilderness

Total Acres Acres in Sierra

NF

# of wilderness

permits issued in

2012

Ansel Adams 231,279 151,483 1,020

Dinkey Lakes 30,000 30,000 640

John Muir 581,000 351,957* 1,672

Kaiser Wilderness 22,700 22,700 Not available

Monarch 44,896 21,000 1,672

Total 909,875 577,140

*Approximately 26,000 acres in the northern portion of the Fish Creek watershed are Sierra NF

lands administered by the Inyo NF.

Final Sierra NF Assessment 2014

http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5444580.pdf

The Sierra NF is an “early adopter,” being one of the first seven forests nationwide to implement

the new 2012 Planning Rule. Wilderness inventory and evaluation is required under the Rule

during the plan revision process. The wilderness requirements under the rule occur in four

primary steps: inventory, evaluation, analysis, and recommendation. (FSH 1909.19 Section

70.6). All plan revisions or new plans must complete this process before the Responsible Official

determines, in the plan decision document, whether to recommend lands within the plan area to

Congress for wilderness designation (36 CFR 219.7 (c)(2)(v)).

The primary function of the inventory step is to efficiently, effectively, and transparently identify

all lands in the plan area that may have wilderness characteristics as defined in the Wilderness

Act (emphasis added).

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The inventory is intended to be reasonably broad and inclusive, based on the inventory

criteria set out in this section and additional information provided to the Responsible

Official through the required opportunities for public and government participation (sec.

70.61 of this Handbook). The intent is to identify lands that may be suitable, so that they

can be evaluated and to allow for public input and feedback (sec. 70.61 of this

Handbook). Lands included in the inventory will be carried forward for evaluation.

Inclusion in the inventory is not a designation that conveys or requires a particular kind

of management. (FSH 1909.19 Chap 70 section 71) (emphasis added)

Based on the results of a methodical process, in May 2015, the Sierra NF released final inventory

maps on the R5 website. For an area to be included in the inventory, it had to meet the following

criteria:

1. The area meets the size criteria defined in section 71.21 and has no improvements; or

2. The area meets the size criteria defined in section 71.21 and is consistent with the

improvements criteria defined in sections 71.22a and 71.22b.

The “Size criteria” is defined as the following:

71.21 – Size Criteria

According to the Wilderness Act, a wilderness area “[h]as at least five thousand acres of

land or is of sufficient size as to make practicable its preservation and use in an

unimpaired condition” (16 U.S.C. 1131c).

Areas to be included in the inventory must be federal lands and must meet one of the

following size criteria:

1. The area contains 5,000 acres or more.

2. The area contains less than 5,000 acres but is of sufficient size as to make practicable

its preservation and use in an unimpaired condition, including but not limited to areas

contiguous to an existing wilderness, primitive areas, administratively recommended

wilderness, or wilderness inventory of other Federal ownership. (FSH 1909.19 Chapter

70 Section 71.21)

Sierra NF’s inventoried areas map showed the results of the inventory phase of the wilderness

forest plan revision requirements. See Figures 1 & 2. The purple area indicates the areas that

may have wilderness characteristics based on the criteria in Chapter 70 of the Planning

Handbook, recently updated to reflect the 2012 Planning Rule. The yellow areas reflect the land

that did not meet the established criteria.

This inventory of potential wilderness areas under the 2012 Planning rule does not reflect the

inventorying process under the Roadless Rule in 2001. Special Areas; Roadless Area

Conservation, 66 Fed. Reg. 3,244 (Jan. 12, 2001). The two processes have different purposes

and different meanings.

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Figure 2 Close Up of above Map showing the Area in the Vicinity of the French Fire

As the Sierra NF moved into the post-inventory phases, the Forest followed a methodical process

(R5 Early Adopters Forest Plan Revision Summary of the Wilderness Evaluation Step

Documentation of the Process, see Appendix B) and assigned inventoried areas into polygons

that it could evaluate for wilderness character. The French Fire Recovery and Restoration Project

overlaps on the edges of two of these polygons, as shown in Figures 3 & 4 below.

During September through mid-December of 2014, each R5 early adopter forest began a detailed

evaluation of the wilderness characteristics and manageability1 of each area in the inventory. See

1 Manageability is defined as the ability of the Forest Service to manage an area as wilderness considering such factors as size, shape, and juxtaposition to external influences. See http://www.wilderness.net/NWPS/designateFS.

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Appendix A of this analysis for the explanation of the wilderness evaluation process posted on

the R5 Inyo, Sequoia and Sierra Forest Plan Revisions website section addressing Wilderness

Inventory and Evaluation

[http://www.fs.usda.gov/detail/r5/landmanagement/planning/?cid=STELPRD3803608.]

Currently the Sierra NF has also posted on the R5 website above two areas that the Forest will

evaluate as recommended wilderness in at least one alternative for the Sierra Forest Plan. These

two areas total 35,990 acres, and they are both more than approximately 9 miles away from the

Project area. The Sierra NF is currently considering and is likely to add additional wilderness

polygons or portions of those polygons to its recommendation in one or more alternatives in

Forest Plan Revision for the Sierra NF. In analyzing the French Fire Recovery and Restoration

Project, the Forest reviewed the wilderness evaluation it is currently undertaking. The Forest has

concluded that it is not likely to consider for wilderness inclusion in any Forest Plan Revision the

portions of the polygons that overlap with French Project treatment units, because the two

polygons either lack of wilderness character, are not manageable, or both. The Forest does not

reasonably foresee designating those areas as wilderness in the foreseeable future.

Effect of the Project on Wilderness Character

To determine the effects of the French Project on wilderness character, the Forest looked at the

effects on both designated wilderness and potential wilderness.

As the project does not overlap any currently designated wilderness, the French Project does not

affect wilderness character in existing wilderness areas.

Inventoried potential wilderness areas2 identified as part of the forest plan revision process have

no official designation and no special management direction or other requirements apply to these

areas. Nonetheless, the Forest has reviewed the impacts of the Project on the inventoried

polygons in the French Fire area to determine whether they have wilderness character potential

and whether the Forest Service would likely designate them as wilderness in the future.

The Forest has not completed its currently ongoing process for identifying wilderness character

of inventoried polygons. The final inventory map released by the Sierra NF as part of plan

revision does not reflect the polygons, either. To ascertain the potential impact of the Project

most conservatively, our analysis overlaid the Project treatment units onto the final wilderness

inventory maps, and found that 142 acres of inventoried potential wilderness acres overlap

Project treatment units. See Figures 3 & 4. Table 1 identifies the treatments the French Project

contractor will complete on these 142 acres

2 “Inventoried” potential wilderness areas are defined as areas identified as part of the potential wilderness inventory conducted as part of plan revision. They have no correlation to areas that may be designated as “Inventoried Roadless Areas” under the Roadless Rule.

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Table 1 Acreages of French Treatment Units Overlapping in Wilderness Inventory Map Areas of

“Final Inventory >5,000 acres”

Acres What Map_Symbol

4.08 Plantation Purple

0.02 Plantation Purple

0.01 Plantation Purple

16.14 Plantation Purple

3.99 Plantation Purple

13.65 FirstEntryUnit Purple

21.11 FirstEntryUnit Purple

9.69 Outer 150' Road

Haz

Purple

19.77 Outer 150' Road

Haz

Purple

12.26 DFPZ 75ft Buff Purple

27.38 DFPZ 75ft Buff Purple

14.66 DFPZ 75ft Buff Purple

142.75 TOTAL ACRES

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Figure 5 West side of French Fire Project Treatment Units (81 acres)

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Figure 6 Eastside of the French Fire Project Treatment Units – 61 acres

The Forest has determined that it needs to implement the French Project, in part, to treat the

DFPZs in the inventoried area (54.3 acres) because it needs to maintain a strategic line for safely

fighting wildfire. These DFPZs already exist on the landscape, showing human influence on the

landscape and reducing their potential wilderness character. Treating DFPZs manages vegetation

re-growth and fuel loading to provide fire managers the needed anchor points and safe locations

to engage future wildfires. DFPZs have been identified in existing pre-attack planning maps and

were used during the suppression of the 2013 Aspen fire and the 2014 French fire.

The contractor will treat the plantations located in the inventoried areas (24.24 acres) where one

can already see prior human influence in the regular plantation planting patterns. That makes

them unlikely to exhibit wilderness character.

The Project also treats roadside hazard trees within or close to roaded areas. Hazard trees could

fall on the roads and could trap users or even strike them directly. Likely, since these areas are

close to roads with its associated motorized use, the Forest will again screen those areas out of

any future wilderness proposal because they would not exhibit wilderness character. Even if the

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Forest identifies those areas as exhibiting wilderness character, the Forest would want to remove

those hazards along the roadways to mitigate the public safety risk.

Beyond the human manipulation that has occurred in these areas prior to the French fire, other

characteristics compromise their wilderness character. The Forest has identified some of these

characteristics as it has been completing its Forest Plan Revision. Within the French Fire

boundary, the Forest found the following characteristics that compromise their wilderness

character:

• On the west side of the Project treatment area (Fig. 5), the southern portion of the

inventoried polygon was directly impacted by the French Fire itself, with remnants

from fire suppression actions present on the landscape, including direct and indirect

fire line construction, both hand and mechanical.

• Similarly, on the east side of the Project treatment area (Fig. 6), which falls within the

San Joaquin River canyon, the wilderness characteristics of the area are significantly

compromised by surrounding development and extensive fire suppression impacts.

Conclusion The Project is not impacting any existing designated wilderness, or any portions of inventoried

potential wilderness polygons that are currently proposed or likely to be proposed for wilderness

inclusion in an alternative in the Sierra NF’s Forest Plan Revision DEIS. Therefore, it is not

reasonably foreseeable that the Forest would include any areas within the French Fire boundary

as potential wilderness.

Beyond the Wilderness Act, no law, policy, or regulation requires the Forest Service to manage

inventoried potential wilderness areas in any particular way. Even if one did, the Project only

intersects with inventoried potential wilderness areas on 142 acres (0.01% of the Forest). Of

those 142 acres, most (75%) are in areas already that humans have already impacted, and those

impacts have degraded the areas’ wilderness character, or are in areas that require human

intervention for public safety.

The Sierra NF’s preliminary wilderness evaluation indicates that all of the 142 acres of treatment

units are within areas where active fire suppression has recently occurred, showing clear signs of

human manipulation which further degrades their potential wilderness character. The Project will

treat areas that do not have sufficient wilderness character or manageability for the Forest to

recommend as wilderness during the Forest Plan Revision process. Based on the above analysis,

the Project activities would have minimal impact on wilderness character or the potential to

designate new wilderness and it is not reasonably foreseeable that Project areas intersecting with

inventoried potential wilderness will be included in the future as recommended wilderness.

Moreover, while I have concluded that the two affected portions of the inventoried polygons are

unlikely to be included in a wilderness recommendation at this time because they lack wilderness

character, even if the larger areas were subsequently found to have the requisite wilderness

characteristics in the future, any resulting wilderness recommendation could redraw the proposed

wilderness boundaries to excise the 142 acres treated with no loss to the remaining area’s

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Appendix A

Wilderness Inventory and Evaluation Process for Forest Plan Revision

(Forest Service Pacific Southwest Regional Office Wilderness Inventory and Evaluation website http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprd3803609.pdf The following outline describes the steps and criteria we will use to identify and evaluate lands on the Inyo, Sequoia, and Sierra National Forests that may be suitable for inclusion in the NWPS and determine whether to recommend any such lands for wilderness designation. The process is based on the direction found in the draft, FACA-edited version of the revised Forest Service Handbook (FSH) 1909.12, Chapter 70. There are four primary steps in the process: Inventory, Evaluation, Analysis and Decision.

Inventory During inventory, National Forest System (NFS) lands that meet the size and improvements criteria outlined in Section 71 of Chapter 70 will be identified. We will use the following process to develop the inventory: 1. Identify all lands that meet the Roads Improvements criteria, as outlined in Ch. 70, 71.22(a). 2. Exclude lands that meet the Roads Improvements criteria but have less than half a mile across between roads, because they are not of sufficient size as to make practicable their preservation and use in unimpaired condition. 3. Identify and exclude lands that meet the Roads improvements criteria but have “power lines with cleared right-of-ways, pipelines, and other permanently installed linear right-of-way structures.” This step is based on Ch. 70, 71.22 (b) (9). 4. Create a draft preliminary inventory map based on the above steps, identifying polygons in the following categories: a. Areas that are 5000 acres or greater. b. Areas less than 5000 acres and non-contiguous to existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other Federal ownership. c. Areas between 1000 and 4999 acres and contiguous to existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other Federal ownership. d. Areas less than 1000 acres and contiguous to existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other Federal ownership. 5. Include areas greater than 5000 acres, both contiguous and non-contiguous. This step is based on the size criteria described in Ch. 70, 71.21 (1). 6. Include areas that are between 1000 and 4999 acres and contiguous with existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other Federal ownership. This step is based on the size criteria described in Ch. 70, 71.21 (3). 7. Review areas less than 5000 acres that are not contiguous to existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other federal ownership. Unless the Forest determines that these areas are of sufficient size as to make practicable their preservation and use in an unimpaired condition and are able to be managed as a separate unit of the NWPS, Last updated: 6/6/2014 2

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they will be excluded. This step is based on the criteria described in Ch. 70, 71.21 (3). 8. Review areas that are less than 1000 acres and contiguous to existing designated wilderness, primitive areas, and recommended wilderness on both NFS lands and adjacent lands of other Federal ownership. Unless it is determined that these areas are practicable additions in shape and size, they will be excluded. 9. Identify and exclude any improvements in the polygons that clearly do not meet the criteria in Ch. 70, 71.22(b). 10. Create an updated preliminary inventory map based on the above steps. 11. Share the preliminary inventory map and a description of the inventory process with the public and tribes. 12. Collect feedback from the public and tribes on the preliminary inventory and any citizen inventory proposals. At the discretion of the responsible official (Forest Supervisor), the preliminary inventory may be modified based on feedback received. Modifications may include: a. Eliminating areas based on new information. b. Adding areas based on new information. c. Reshaping areas based on new information. 13. Create a final inventory map and share with the public and tribes.

Evaluation The primary function of the evaluation process is to evaluate the wilderness characteristics of each area identified during inventory. We will use the following process: 1. Identify authorized motorized trails and prepare maps that overlay authorized motorized trails on the final inventory maps. 2. For each area in the inventory, examine the extent of authorized and maintained motorized trails. Make recommendations on whether to eliminate the area from further consideration, to eliminate a portion of the area and reshape it to exclude authorized motorized trails, or continue to evaluate the whole area. These recommendations will be presented to the responsible official who will make the final decision on what to carry forward for evaluation. This early evaluation step is based on the criteria found in Ch. 70, 72.1 (5). 3. Create new maps of areas to carry forward in the evaluation, reflecting any changes resulting from the above steps, and make these maps available to the public and tribes. 4. Using forest interdisciplinary teams (IDTs), evaluate each area for its wilderness potential based on the wilderness evaluation criteria found in Ch. 70, 72.1. These criteria will be addressed in narrative format using a wilderness evaluation template. 5. Use the wilderness evaluation criteria narratives to write a summary of wilderness character for each area evaluated. 6. Prepare a document of the evaluation of areas that may be suitable for inclusion in the NWPS, and include the following: a. A description of the identification, inventory and evaluation process. b. Narrative descriptions of each area evaluated. Last updated: 6/6/2014 3

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c. A summary of the wilderness character for each area evaluated. d. Large scape maps of the evaluated areas. 7. Include this information as an appendix to the Draft Environmental Impact Statement (DEIS). The appendix will be available for public review during the DEIS comment period.

Analysis We will use the following process for the analysis: 1. Present the evaluation document, public input, and staff recommendations to the responsible officials for their review. Responsible officials will identify which specific areas, or portions thereof, to carry forward into the National Environmental Policy Act (NEPA) analysis in one or more alternatives. Not all lands included in the inventory and subsequent evaluations are required to be carried forward in an alternative. 2. For areas that will be carried forward into the NEPA document, include the minimum documentation described in Ch. 70, 73. This includes cleaning up boundaries using the guidelines contained in Ch. 70. Produce updated maps reflecting the boundary updates, as well as overview maps. 3. Develop plan components for areas recommended for wilderness designation that protect and maintain the ecological and social characteristics that provide the basis for their suitability for wilderness designation. 4. The responsible official will document his/her rationale for why areas were not carried forward into the NEPA process as part of one or more alternatives. 5. Adjustments may be made to alternatives between the DEIS and FEIS in response to public comments.

Decision

Based on the NEPA analysis, the responsible official will make a decision on specific areas to

recommend for inclusion in the NWPS. The decision will be included in the final decision

document as a “preliminary administrative recommendation."

Wilderness Evaluation Process – Also from the R5 website listed above

clicking on “Evaluation”

As a first step in the evaluation process, we identified authorized motorized trails on the final

inventory maps. Areas with authorized motorized trails were examined and determined to lack

wilderness character due to the prevalence of authorized motorized activity and its impacts to the

surrounding area. Additionally, there is a high level of commitment to maintaining these

authorized motorized trails. As a result, each forest identified areas within the inventory where

wilderness characteristics are impacted by the authorized motorized trail system and highlighted

these portions of the inventory (about 19%). Each area was evaluated as a whole, but the focus

for the detailed evaluation was on the portions of the inventory that do not contain authorized

motorized trails (remaining 81%).

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The Forest Service posted the map of areas to be evaluated in detail on a collaborative mapping

website, called Talking Points and invited participation in the evaluation process by asking the

public to provide any information that would be helpful as we evaluated the factors that

contribute to the wilderness characteristics of each area

As described in the 2005 USDA Forest Service Rocky Mountain Research Station publication

Monitoring Selected Conditions Related to Wilderness Character: A National Framework,

wilderness character includes the following five qualities:

• Untrammeled—wilderness is essentially unhindered and free from modern human control

or manipulation.

• Natural—wilderness ecological systems are substantially free from the effects of modern

civilization.

• Undeveloped—wilderness is essentially without permanent improvements or evidence of

modern human occupation.

• Outstanding opportunities for solitude or a primitive and unconfined type of recreation—

wilderness provides outstanding opportunities for people to experience solitude or primitive and

unconfined recreation, including the values of inspiration and physical and mental challenge.

• Unique qualities of a particular wilderness area—other features of value such as

ecological, geological or other features of scientific, educational, or scenic value that are unique

to a particular wilderness area.

During the wilderness evaluation, the Inyo, Sequoia and Sierra National Forests also held a

formal 30-day scoping period on the proposed action to revise the existing forest plans for each

of these forests. Scoping guides the development of the environmental impact statement (EIS).

All comments received, through both the Talking Points website and during scoping that had

information regarding the relative wilderness characteristics of each area were considered by

each forest.

Using the criteria in Forest Service Handbook 1909.12 Chapter 70, 72.1,each forest evaluated all

lands identified in the inventory to determine potential suitability for inclusion in the National

Wilderness Preservation System. In addition to the information provided by the public and the

tribes, the Forests gathered and documented the existing condition of all of the factors that

contribute to each of the criteria. Next, this information was summarized into a narrative

evaluation for each area. Each wilderness evaluation narrative includes:

• A general description of the area;

• A description of the area’s wilderness characteristics including;

o The degree to which the area generally appears to be affected primarily by the forces of

nature including the current condition of the natural and undeveloped characteristics of the area.

o Opportunities for solitude of primitive and unconfined recreation

o Other features of value including any high value, special, rare, or unique resources

identified by the specialists that contributes to the wilderness character of the particular area (i.e.

SN Bighorn Sheep, unique geology, rare or unique heritage resources.

• A description of factors that affect the manageability of the area (i.e. adjacent land uses,

non-conforming established rights and uses, inholdings, incompatible recreation activities (i.e.

mtn. biking), overlapping designations, shape, etc.

• A summary of the factors that affect the area’s potential suitability for inclusion in the

NWPS based on the wilderness characteristics and potential manageability of the area as

wilderness, including any other key factors that will assist the decision maker in understanding

the suitability of the area for recommendation as wilderness (i.e. provides critical connectivity, is

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an ecosystem type that is not yet or is underrepresented in the NWPS, provides opportunities for

restoration, etc.)

The Forest Service is compiling the results of the wilderness inventory and evaluation into one

document that will be included as an appendix in the draft EIS and will be available for public

review during the draft EIS comment period.

Forest Supervisors will use the wilderness evaluation narratives and public input to identify

which specific areas, or portions thereof, to carry forward into the draft EIS analysis in one or

more alternatives as recommended wilderness. Not all lands included in the inventory and

subsequent evaluations are required to be carried forward in an alternative. A detailed boundary

map and a narrative description has been prepared for each recommended area that will be

analyzed in the DEIS.

R5 website

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Appendix B – Need for DFPZs and their Interrelationship with the Project

1.1.3.7. Manage Fuel Loadings within Defensive Fuel Profile Zones (DFPZ’s) in Strategic Topographic Locations

There is a need to manage vegetation re-growth and fuel loading in identified DFPZ’s to provide fire

managers the needed anchor points and safe locations to engage future wildfires. DFPZ’s have been

identified in existing pre-attack planning maps and used during the suppression of the 2013 Aspen fire and the French fire.

In these areas, fire-affected trees fall to the ground and become down woody material and vegetation re-

growth of shrubs would create hazardous live and dead surface fuel conditions inhibiting effective fire

management in the future. Managed DFPZ’s are also needed to help protect the established reforested

areas in the event of another fire, while the planted trees are more vulnerable at a younger age. (EA

Section 1.1.3.7)

2.1.2.6. Create and Maintain DFPZ’s in Strategic Locations to Help Manage Future

Wildfires.

Fuels treatment and maintenance would occur on approximately 221 acres within existing and proposed

DFPZ’s, 126 acres overlap with other treatments. These areas are 150 feet wide and are located along dominant ridges and terrain features. (EA Section 2.1.2.6)