Status
On January 14th, 2020, Y2U submitted scoping comments on the Middle Fork Henry’s Aspen Enhancement Project was proposed by the Ashton/Island Park Ranger District of the Caribou-Targhee National Forest to increase aspen regeneration across the Middle Henry's Fork watershed by decreasing their competition with conifer trees. The Middle Henry's Fork watershed is the largest watershed on the Caribou-Targhee National Forest covering 120,000 acres (see map). It is located within the Henry's Fork caldera and includes the Big Bend Ridge to the south, Last Chance and Box Canyon to the north, Thurman Ridge and Bishop Mountain to the west, and Hatchery Butte and Elk Butte to the east. This watershed was chosen for treatment due to the abundance of aspen mixed with conifers scattered throughout. This project proposes to treat approximately 49,000 acres with a combination vegetation management activity throughout the project area to improve the condition of the forest ecosystem. This project is proposed as a Categorical Exclusion (CE) and should be analyzed with an Environmental Impact Statement (EIS) not an Environmental Assessment (EA) to assess the umulative impacts of the proposal along with all other existing and reasonably foreseeable future project impacts in the region, specifically in the Corridor. This project should be analyzed with an Environmental Impact Statement (EIS) to assess the cumulative impacts of the proposal along with all other existing and reasonably foreseeable future project impacts in the region, specifically in the Corridor. Reasons why an EIS is needed for this project:
- The use of CE lack of programmatic or site-specific project NEPA without addressing the circumstances prevailing in this project area.
- The lack of site-specific analysis and comparison to ecological criteria, best available science or Forest Plan intent.
- There was no designation of a cumulative effects area (CEA) and no analysis of cumulative effects.
- Reliance is placed on Best Management Practices (BMPs) instead of science-based criteria under which to manage the project and overlapping uses such as livestock grazing and recreation.
- Climate change was not addressed.
- There was no analysis included in the Scoping Document of the Regionally Significant Wildlife Corridor, ESA, special status species such as Grizzly bear, goshawk, Canada lynx or wolverine, or for that matter native plants. No data is presented to show current state of each special status species nor of the impact the project will have on these species in the project area.
- The Scoping Document does not include the results of a formal consultation with the US Fish and Wildlife Service (USFWS) regarding the impact of the project on lynx, grizzly bears and wolverines.
- There was no analysis of NFMA viability requirements for special status species.
- Old growth and the impact that removal of old growth forest has on wildlife was not addressed.
- The Scoping Document lacks data to support the projected outcome of the project – shifting species composition from conifer to aspen where aspen is present and reducing conifer where aspen is absent.
- The Scoping Document lacks analysis of the impact that domestic livestock grazing has on aspen regeneration and the lack of seedling and sapling age class.
- The Scoping Document lacks detail as to how temporary roads, landings and skid trails will be effectively closed and rehabilitated.
- The Scoping Document lacks defined monitoring protocol and timing for tree regeneration, tree condition, survival and mortality, herbivory by ungulates, motorized violations on closed routes within the project area, noxious weed invasion of the project area and domestic livestock movement and utilization impacts on the project area.
The full set of comments can be found below.
Work Plan
- Y2U will continue to monitor the impact of this project on wildlife and habitat.
- Y2U is considering seeking legal representation to challenge the Categorical Exclusion of the NEPA process for this and several other “vegetation treatment” or “fuels treatment” projects.
Expected Outcome
Unknown at this time.
