Wildland-Urban Interface Fuels Management FONSI

The purpose of wildland-urban interface fuels management at Yellowstone National Park is to protect and preserve developments, park infrastructure, and cultural resources of the park for the enjoyment of present and future generations. Wildland-urban interface fuels management also is intended to protect human life and property, both public and private, within and adjacent to National Park Service (NPS) lands.
To help in achieving these long-term goals, the National Park Service has implemented a comprehensive fuels management program. Actions within this nation-wide program include, but are not limited to, mechanical thinning and prescribed burning, although only mechanical thinning is proposed for the Yellowstone National Park wildland-urban interface projects.
This wildland-urban interface fuels management project would be consistent with the Yellowstone National Park fire management plan (NPS 1992).
Yellowstone National Park has a long association with free-burning fire and its present forests have grown up in the wake of large fires. The historic record demonstrates the capability of the region to support large, occasional fires and that fire in some form has had a continual presence in the park. Organized fire suppression in the park began about 1929, which reduced the frequency and size of fires. Large fires have burned at average intervals of 25-60 years on the low elevation grasslands of the northern range (Houston 1982), at intervals of 250-400 years in the conifer forests (Romme 1982), and less frequently in the alpine areas.
Yellowstone National Park has experienced 1,900 fires in the last 60 years (NPS 1992). These fires burned 908,052 acres. Fifty fires burned 793,800 acres in Yellowstone National Park in 1988, the most active fire season in recorded history (NPS 1992). Activities occurring under the current fire management plan protect structures in the park using suppression. However, hazardous fuels continue to accumulate around structures and developed areas. The proposed management activities would reduce fuels in areas of the wildland-urban interface in a manner that is not addressed in the current fire management plan.
A contributing factor to the amount of damage resulting from wildland fires has been proximity of development adjacent to public lands. Such development puts human life, structures, and other property at risk. Wildland-urban interface projects are intended to reduce the fire hazard in areas where developed areas join wildlands.
During much of the 20th century, total fire suppression on public lands was viewed as the most appropriate method to prevent widespread wildland fires. However, after decades of fire suppression, it became obvious that complete exclusion of fire did not promote ecosystem health. In fire-evolved systems, fuels accumulated that increased fire risk and had detrimental impacts on native flora and fauna. Increased combustible fuels near archeological and other cultural sites posed a high risk to cultural resources on public lands. Following intense fire seasons in 1988 and 1994, fire management policies for public lands were reviewed and updated. In 1995, the role of fire was reconsidered, and prescribed burns were re-introduced as a management tool on National Park Service lands. Reductions of fuel loads were planned to facilitate the control of wildfire. Current federal policy reinforces the protection of human life and property as an overriding principle in wildland fire management. Other guiding principles include protecting natural ecological systems and safeguarding cultural and natural resources.

Alternative B

The preferred alternative (Alternative B) would thin the forest so that the edges of all remaining tree crowns would be generally 20 feet apart in 3 developed frontcountry areas and around 31 backcountry sites within the park. The three frontcountry treatment areas, the Lake Utility area, East Entrance, and Northeast Entrance areas, cover approximately 119.4 acres. The backcountry sites (30 patrol cabins) would each be treated over an area ranging from 4 to 15 acres, plus an 18.5-acre treatment around the Bechler developed area. The preferred alternative would thin areas bounded by a 400-foot perimeter from the edge of the outside buildings in each development. The treatments would lessen the likelihood of a crown fire and would increase firefighters' ability to provide increased protection to human life and property.
Hazardous fuels reduction would occur in treatment areas adjacent to structures that are at risk from wildland fire. Park personnel and contractors would perform fuels reduction with non- motorized, traditional or primitive tools in proposed wilderness areas. Motorized tools, such as chainsaws will not be used as originally proposed in the EA, unless required in an emergency involving the health and safety of persons within the area. In addition, there will be no helicopter landings. Prescribed fire will not be used. A minimum requirement analysis and a minimum tool analysis will be completed for each proposed activity.
The method of disposal/removal of mechanically thinned vegetation in the treatment areas would vary according to the amount of live canopy and woody material present prior to treatment. Possible disposal methods include salvaging cuttings for firewood, and hand piling and burning of slash. In addition, chipping would be considered at the three frontcountry treatment areas in order to alleviate possible impacts created by burn circles.

In addition to the preferred alternative described above, the environmental assessment also analyzed a no action alternative, Alternative A.
Alternative A would continue the park's current fire management practices. This alternative assumes that fuels in the treatment area would continue to build up. At some future time, an ignition from a natural or human-caused source could result in an uncontrolled wildland fire. Under most conditions, surface fires that consume surface plant cover and portions of the understory and midstory would be expected. However, under drought conditions and/or high winds, a running crown fire could destroy the overstory vegetation.
Mitigation measures and best management practices to be employed during implementation of any of the alternatives are described in the environmental assessment.
The environmentally preferred alternative is determined by applying the criteria in the National Environmental Policy Act of 1969 (NEPA), which is guided by the Council on Environmental Quality (CEQ). The CEQ provides direction that "the environmentally preferable alternative is the alternative that will promote the national environmental policy as expressed in NEPA's Section 101:
· Fulfill the responsibilities of each generation as trustee of the environment for succeeding generations.
· Ensure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings.
· Attain the widest range of beneficial uses of the environment without degradation, risk of health or safety, or other undesirable and unintended consequences.
· Preserve important historic, cultural, and natural aspects of our national heritage and maintain, wherever possible, an environment that supports diversity and variety of individual choice.
· Achieve a balance between population and resource use that will permit high standards of living and a wide sharing of life's amenities.
· Enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.

The preferred alternative, Alternative B, was identified as the environmentally preferred alternative because it would:

· Reduce fuel loads to a level that would enhance the protection of resources for succeeding generations.
· Improve the safety of the surroundings (frontcountry and backcountry sites) for employees, visitors, and firefighters.
· Reduce the risk to health and safety and other undesirable consequences of a catastrophic wildfire.
· Provide better protection of historic, cultural, and natural resources.

Therefore, the preferred alternative (Alternative B) would be environmentally preferable over the continue current management/no action alternative (Alternative A).

As defined in 40 CFR §1508.27, significance is determined by examining the following criteria:
Impacts that may be both beneficial and adverse: The impact topics that would experience negligible adverse effects as a result of mechanical thinning treatments would include water quality and hydrology, wilderness, wildlife, economics, park operations, public health and safety, and visitor use and experience. Minor adverse effects would occur to air quality, soils, vegetation, and cultural resources, primarily in the short-term. Long-term beneficial effects would accrue to air quality, soils, wilderness, cultural resources, and public health and safety. There would be no adverse effects to endangered and threatened species or their critical habitats. There would be no effect on geothermal, wetland, or floodplain resources as a result of the fuels reductions.

Degree of effect on public health or safety: Public health and safety is an important issue for the wildland-urban interface fuels reduction project. By reducing the potential for migrating wildfire, protection of life and property would be enhanced. The treatment activities would pose no threat to visitors, adjacent residents, or staff, though there would be a negligible, short-term, direct adverse effect to the health and safety of workers using hazardous equipment. The long-term effect of the preferred alternative would be beneficial and range from minor to moderate by reducing the potential for smoke and particulate emission and by enhancing firefighter safety and their abilities to suppress a fire when necessary. A safety zone would be created in the wildland-urban interface.
Unique characteristics of the geographic area such as proximity to historic or cultural resources, park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas: As described in the environmental assessment, negligible to minor adverse effects to cultural or ethnographic resources were identified for the preferred alternative. The possibility of disturbing currently unmapped and unsurveyed sites exists, although this would be unlikely, as there would be no ground disturbing activities. Mitigation measures to protect cultural resources would be employed during project implementation and are described in the environmental assessment.
Wetlands would be avoided during treatment and are protected under current management direction. There are no prime farmlands, wild and scenic rivers, or ecologically critical areas within the treatment areas, and these resources would not be affected.
Degree to which effects on the quality of the human environment are likely to be highly controversial: The preferred alternative's overall effects on the human environment would be beneficial as a result of the reduction in wildfire risk in the wildland-urban interface. The methods originally proposed to achieve the project's objectives caused some controversy, particularly with regard to the backcountry cabins and wilderness resources. Originally the EA mentioned a variety of methods to implement the fuels reduction projects. There will be a change in emphasis from power tools and hand tools to an increased emphasis on hand tools. In the implementation of this plan for the designated backcountry cabins, no motorized equipment, vehicles, or helicopter landings would be used for the project in proposed wilderness. Access to the backcountry sites would be accomplished by non-motorized means. Similarly, primitive tools like crosscut saws and axes would be used to carry out this plan within proposed wilderness. The preferred alternative would not change, only the emphasis on the tools used for its implementation. The proposed treatment would not have a significant adverse affect on key resources or values at Yellowstone National Park.
As part of the initial scoping process, the National Park Service sent letters regarding the wildland-urban interface project to the public; local, state, and national organizations; and to government agencies. After initial public scoping, discussions about fuels treatment around the backcountry cabins occurred with an interdisciplinary team of National Park Service staff. Thus, the scope of the project changed. The issues and concerns identified as a result of scoping and public review of the environmental assessment are addressed in the responses to comments attached to this FONSI. People may be opposed to the implementation of the preferred alternative because of differing values concerning wilderness character and the backcountry cabins. The park considers the cabins as important historic structures, as well as administrative sites to protect and monitor natural and cultural resources and to facilitate the management and protection of wilderness resources.
Degree to which the possible effects on the quality of the human environment are highly uncertain or involve unique or unknown risks: The risks to the quality of the human environment associated with the preferred alternative would be negligible to minor. There were no highly uncertain, unique, or unknown risks identified.
Degree to which the action may establish a precedent for future actions with significant effects or represents a decision in principle about a future consideration: The preferred alternative neither establishes a National Park Service precedent for future actions with significant effects nor represents a decision in principle about a future consideration.
Whether the action is related to other actions with individually insignificant but cumulatively significant impacts: Implementation of fuels reduction at the wildland-urban interface would not have a significant cumulative impact on the resources or values of Yellowstone National Park. The negligible to minor adverse effects related to the preferred alternative, in conjunction with the adverse impacts of any other past, present, or reasonably foreseeable future actions would result in negligible or minor impacts to air quality, water quality, wilderness, and cultural resources.
Degree to which the action may adversely affect districts, sites, highways, structures, or objects listed on National Register of Historic Places or may cause loss or destruction of significant scientific, cultural, or historical resources: No known district, site, structure, or object listed on the National Register of Historic Places would be adversely affected, as defined in 36 CFR 800, by the proposed action. As described in the environmental assessment, compliance with Section 106 of the National Historic Preservation Act has been initiated. Section 106 compliance is project specific and would be completed prior to project implementation. Prior to implementation of the preferred alternative, survey information and an evaluation of potential National Register of Historic Places eligibility for previously unevaluated sites within the area of potential effect will be sent to the appropriate State Historic Preservation Office to complete Section 106 compliance. If necessary, additional mitigation measures would be developed in consultation with the State Historic Preservation Officer and, as appropriate, with concerned American Indian tribes. Many of the backcountry project areas contain both National Register-eligible and non-eligible buildings and sites. All these resources would be protected and avoided during project implementation, regardless of their National Register status. No adverse effects would occur to properties currently listed in or eligible for the National Register of Historic Places with mitigating measures (including avoidance) as described in the environmental assessment and developed in consultation with the appropriate State Historic Preservation Office and concerned American Indian tribes. In addition, implementation of the preferred alternative would yield long-term beneficial effects to cultural and ethnographic resources as the potential for destructive wildfire is reduced. A full description of the potential effects on cultural and ethnographic resources is included in the environmental assessment.
Degree to which the action may adversely affect an endangered or threatened species or its critical habitat: The proposed action "may affect, but is not likely to adversely affect" any federal or state-listed endangered, threatened, proposed, or candidate species, or any state species of special concern, or any designated critical habitats. The U. S. Fish and Wildlife Service concurred with this determination on May 31, 2002. Refer to Appendix C of the environmental assessment for the biological assessment associated with the wildland-urban interface project.
Whether the action threatens a violation of federal, state, or local environmental protection law: The preferred alternative would not violate federal, state, or local environmental protection laws.
Impairment: In addition to reviewing the list of significance criteria, the National Park Service has determined that implementation of the proposed action would not constitute an impairment to Yellowstone National Park's resources and values. This conclusion is based on a thorough analysis of the environmental impacts described in the Wildland-Urban Interface Fuels Management Environmental Assessment, the public comments received, relevant scientific studies, and the professional judgment of the decision-maker guided by the direction in NPS Management Policies 2001 (NPS 2000). Although the plan/project would have some adverse impacts, in all cases these adverse impacts are the result of actions taken to preserve and restore other park resources and values. Overall, the proposed action would result in benefits to park resources and values, opportunities for their enjoyment, and it would not result in their impairment.

Prior to preparation of the environmental assessment, the National Park Service sent a scoping letter regarding the wildland-urban interface project to the general public, local, state, and national organizations, and government agencies, including the Wyoming, Montana, and Idaho State Historic Preservation Offices, the U.S. Fish and Wildlife Service, U.S. Forest Service, and to representatives of the park's 25 affiliated American Indian tribes.
Copies of consultation letters are included in the environmental assessment and the Consultation and Coordination section includes a list of recipients and the agencies contacted. Changes to the environmental assessment as a result of consultation with agencies are addressed in errata sheets attached to this Finding of No Significant Impact (FONSI). A copy of this document and the errata sheets will be sent to all respondents.
The environmental assessment was made available for public review and comment during a 30-day period ending November 8, 2002. Fifteen written comments were received, plus 30 e-mail comments were sent through an organization. Refer to the attached summary of responses to substantive comments. The comments included:

· Objections to the use of mechanized tools (e.g., chainsaws and helicopters) in proposed wilderness,
· Concerns that not enough alternatives were evaluated
· Effectiveness of the preferred alternative,
· Lack of scoping for the backcountry cabins,
· Whether backcountry cabins should be protected,
· Minimum requirement/tool analysis was flawed,
· Impacts on wilderness character and values, and
· A cost benefit analysis should have been completed.

The preferred alternative would not constitute an action that normally requires preparation of an environmental impact statement (EIS). The preferred alternative would not have a significant effect on the human environment. Adverse environmental effects that could occur are negligible to minor in intensity. There would be no significant adverse effects on public health, public safety, threatened or endangered species, sites or districts listed in or eligible for listing in the National Register of Historic Places, or other unique characteristics of the region. No highly uncertain or controversial impacts, unique or unknown risks, significant cumulative adverse effects, or elements of precedence were identified. Implementation of the action would not violate any federal, state, or local environmental protection law.
Based on the foregoing, it has been determined that the preparation of an EIS is not required for this project and thus will not be prepared.

Recommended: _____________________________________ _______________
Superintendent Date

Approved: _____________________________________ _______________
Intermountain Regional Director Date

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