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US DOI Bureau of Indian Affairs Fire Management Plan

Crow Agency October, 2010

APPENDIX B

FONSI

United States Department of the Interior

BUREAU OF INDIAN AFFAIRS

CROW AGENCY

P.O. Box 69

Crow Agency, MT 59022

October 4, 2010

FINDING OF NO SIGNIFICANT IMPACT

This Finding of No Significant Impact (FONSD was completed in accordance with the National

Environmental Policy Act of 1969 (NEPA), Council of Environmental Quality Regulations, Department

of Interior procedures and Bureau of Indian Affairs (BLA) NEPA manual.

Proposed Action:

The Bureau of Indian Affairs proposes to adopt the 2010 revision of the Fire Management Plan for the

Crow Indian Reservation. All activities associated with this plan have been addressed in the

2010Environmental Assessment for the Fire Management Plan for the Crow Indian Reservation. This

FONSI together with the EA constitute a complete record of the conservation planning and

environmental impact analysis process for this proposal. The Fire Management Plan provides the

operational guidance for conducting fire management activities.

Comments were solicited from the public, Crow Tribal members, Crow Tribal Executive, Legislative, and

Natural Resources Staff, and the BIA Rocky Mountain Regional Office. The preferred alternative

supports a range of fire suppression management options based on benefits to the resource, as well as the

use of prescribed fire for the treatment of hazardous fuels buildup, degraded habitat, and forest

management.

There are no major adverse cumulative or secondary environmental effects of the actions proposed in the

preferred alternative; therefore, an EIS is not required. The reasons supporting this finding are as follows:

1. The proposed actions suppert the goals and objectives of the Crow Tribe.

2. All fire management activities will be conducted in accordance with federal, state and

tribal regulations.

tad

By managing planned and unplanned fires for multiple resource objectives, using a

range of suppression alternatives, ecological sustainability, forest productivity, and

forage production for wildlife and domestic stock are expected to increase or not

change negatively, and wildlife habitat should improve.

4, Archeological and cultural advisement requirements will be fulfilled to minimize the

effects on cultural resources of unplanned fire, suppression, and prescribed burning

activity.

5. Mitigating measures will be taken to minimize adverse impact on air quality, public

health or safety, as suppression activities are monitored or increased to meet resource

objectives.

6. The preferred alternative’s quantified improved forest health will benefit water

resources; potential minor adverse impacts to water resources from fire and

suppression will be minimized.

7. Protective measures will be taken for Threatened or Endangered Species which may

inhabit planned or unplanned fire areas.

8. Prior to certain management activities such as prescribed burning, NEPA compliance

will be prepared and assessed for the particular land area of the proposed activity.

Any party affected by this FONSI may request an appeal from administrative actions in accordance with

25 C.F.R. Part 2.7, which requires a 30 day appeal period after the decision to proceed with the action is

made, before the action may be implemented. The Notice of Appeal, including all supporting

documentation, must be filed in the office of the official whose decision is being appealed within 30 days.

A copy shall be filed through the Department of the Interior Board of Indian Appeals. A copy of the

Notice of Appeal shall also be filed with the Chief, Environmental Services Staff, BIA, 1849 C Street

NW, Washington, D.C. 20240-0001.

Leta LL? auethank Lb <0g¢-l0/0

erchant, A¢ting Superintendent Date

eau of Indian Affairs

Crow Agency

US DOI Bureau of Indian Affairs ~ Fire Management Plan

Crow Agency October, 2010

APPENDIX C

Environmental Assessment

5s NTI

eed

niece erin cmmmnanaenpemmmcmanras

Bureau of Indian Affairs, Crow Agency

Fire & Aviation Management

Environmental

Assessment

FOR

Fire Management Plan

2010-2024

Abstract

The Bureau of Indian Affairs, Crow Agency is proposing to implement a new Fire

Management Plan (FMP) for the Crow Indian Reservation located in south central

Montana. This plan will specify a fire management course of action for the Crow Agency,

as described in detail through a set of goals, objectives, and strategies.

This Environmental Assessment (EA) considers the biological, environmental, and socioeconomic effects that implementation of the FMP’s preferred alternative, and other

management alternatives, will have on the most significant issues and concerns identified

during the planning process.

Responsible Agency and Official:

Edward Parisian, Regional Director

Bureau of Indian Affairs, James Battin Federal Building, 316 North 26" Street, Billings, MT

59101

Additional Contacts for information regarding this Fire Management Plan and

Environmental Assessment are:

Judy Gray, Superintendent

Bureau of Indian Affairs, Crow Agency, P.O. Box 69, Crow Agency, MT 59022

Debbie Scott, Deputy Superintendent of Trust Services

Bureau of Indian Affairs, Crow Agency, P.O. Box 69, Crow Agency, MT 59022

Dale Glenmore, Fire Management Officer

Bureau of Indian Affairs, Crow Agency, P.O. Box 69, Crow Agency, MT 59022

Randy Pretty On Top, Prescribed Fire Specialist

Bureau of Indian Affairs, Crow Agency, P.O. Box 69, Crow Agency, MT 59022

Environmental Assessment -l-

August 2010

Table of Contents

Topic Page

L Purpose’and Need for Action «.ccssessissscssssisscenvs eri ssanmnnnmncnnncesS

i. Management Alternatives

Alternative A: (Full Suppression Only) — Full suppression of all

wildland fires.

Alternative B: (Preferred Alternative) — Prescribed burning would

be utilized as a management tool. All wildland fires will be

suppressed utilizing an appropriate reSPONSE oo... sec ces seccstesssseeessesseseesereee 4

Alternative C: (Suppression without use of planned fire) -- No prescribed

burning will be used. All wildland fires will be

suppressed utilizing an appropriate response

Alternatives Considered but eliminated from detailed analysi.

Summary Comparison of the Alternatives / Issues... é ws

Table 1: General effects of alternatives upon —_* en en concerns.....

Hara"

Hl. Affected Environment

3.1 Introduction... .

3.2 Status of. ‘Adjacent Lands,

3.3 Air R@SOUurces.......0045

3.4 Water Resources.

3.5

3.6 Vegetation

3.7 Fauna oss

3.8 CUTTUTET RESGUPCES .. osneenesearnanmnnnanenseinaiiesiiiact esis siGealls dives dase 15

3.9 Sotial dnd Economie VAMOS ccccmeswsapararccensecanasiisiconsnnnnsnnvawerssess 18

IV. Environmental Consequences

ae

Environmental Assessment

August 2010

List of Preparers

Bibliography

4] Introduction... Js RE EERO ESI REE RRO eer were

4.2 Status of Adjacent Lands.

43 Air Quality

44 Water Resources

4.5

4.6

4.7

4.8 Cultural RESOUr G28. ccxesessicxonswasessecseeieevemewes evans

4.9 Social and Economic Values... .ccccecce scence ne eee eee ee nn eee snes eneenessnanees

I. Purpose and Need for Action

This Environmental Assessment analyzes and

considers the impacts of implementing

short/long term alternatives for managing

prescribed and unplanned wildland fire on the

- Crow Indian Reservation. The proposed

appropriate management courses of action are

described in goals, objectives, and strategies of

the agency’s Fire Management Plan (FMP) for

fiscal years 2010-2024. The revision of

management direction is needed to address

current management issues, and to establish

alternatives that may be taken in the use of fire

as a management tool and appropriate responses

to fire suppression efforts.

This Environmental Assessment (EA) was

prepared using the guidelines of the National

Environmental Policy Act (NEPA) of 1969.

The Act requires examination of the effects on

proposed actions on the natural and human

environment. In the following sections,

alternatives for future Agency fire management

direction, the environmental consequences of

each alternative, and the preferred management

course of action are described.

In accordance with the Bureau of Indian Affairs

(BIA), Indian Affairs Manual (IAM), Part 90,

Chapter 1, every area of burnable vegetation

must have an approved Fire Management Plan

(FMP). Through implementing fire

management principles and using the best

available science, it is the agency’s intent to

implement a full range of fire management

activities to achieve ecosystem sustainability,

including its interrelated ecological, economic,

and social components, to accomplish resource

management objectives.

The 1995 Final Report of the Federal Wildland

Fire Managernent Policy and Program Review

provides guiding principles that are fundamental!

to the success of the Federal wildland fire

management program and implementation of

Environmental Assessment

August 201)

review recommendations. These

recommendations include Federal wildland fire

policies in the areas of; safety, planning,

wildland fire, prescribed fire, preparedness,

suppression, prevention, protection priorities,

interagency cooperation, standardization,

economic efficiency, wildland/urban interface,

and administration and employee roles.

The 2001 Federal Fire Management Policy

update addresses 17 distinct items, the foremost

being safety; all FMPs and fire management

activities reflect this commitment. The Federal

Wildland Fire Management Policy that now

governs wildland fire management provides for

a full range of responses, and the opportunity

for wildland fires to be managed for multiple

objectives including resource benefits. This

policy represents a significant departure from

past fire management practices. All ignitions

occurring in wildland areas are now classified

either as planned and unplanned fires.

Unplanned wildland fires include most nonstructure fires that occur in the wildland.

Regardless of whether the origin is natural

(generally lightning) or human (accident or

arson), unplanned fires will receive a

suppression response, in the absence of other

specific management direction. Planned fires

include any fire ignited by management actions

to meet specific objectives, such as prescribed

burns. Prior to the ignition of planned fires, a

written, approved prescribed fire plan must exist

and must fulfill NEPA requirements.

This EA constitutes the requisite NEPA

documentation and compliance for the FMP.

Specific needs of the FMP include:

* Wildland fires are managed with the

analysis and appropriate response as

directed by the FMP.

bs Minimize bummed area due to high values

to be protected, threats to life or

property, or other social, political, and

economic considerations that outweigh

potential environmental benefits.

* Implement a wildland fire suppression

decision-making process that evaluates

and compares alternative strategies

regarding safety, environmental, social,

economic, political, and resource

management objectives.

* Meet current Congressional,

Departmental and Bureau policy and

direction for the requirement of a FMP.

. Plan for use of prescribed fire to restore

the historic role of fire to fire-dependent

or fire-adapted habitats.

* Use prescribed fire or other appropriate

management tools (mechanical) to

reduce hazardous fuels to protect

improvements, and reduce risk of fire

escape to adjacent land ownerships.

II. Management Alternatives

This section describes the alternatives to be

considered, including the proposed action and

three alternatives. This section also summarizes

the environmental consequences of the

alternatives and defines the differences between

the alternatives.

Alternative A: (No Action) — Full suppression

of all wildland fires.

This alternative would reflect aggressive

suppression of all wildland fires regardless of

the potential benefits of fire to natural resources.

This alternative would also preclude the use of

prescribed fire to benefit resources or reduce

hazard fuels. A Fire Management Plan

describing this policy would be prepared,

approved and implemented.

Alternative B: (Preferred) — Prescribed

burning would be utilized as a management

tool. All wildland fires will be suppressed

utilizing an appropriate response.

Eavironmental Assessment

August 2010

This alternative would allow for flexibility when

considering management options. There are

many benefits to the use of prescribed burning

which, when combined with other management

techniques such as mechanical treatments,

allows for superior habitat management results.

A considerable amount of effort will be

expended in restoring ponderosa pine (Pinus

ponderosa) timber stands to their historic fire

regime. The use of prescribed fire allows for

the successful re-establishment and restoration

of these timber stands. Not only can time and

money be saved, but the effects of fire

management will meet habitat objectives in this

fire dependent ecosystem better than any other

method. Without the proper site preparation and

pre-ignition controls involved in prescribed

burming, wildland fires will have a greater

likelihood of adversely affecting life, personal

property, facilities, infrastructure and/or

endangered species.

With this alternative, all wildland fires will be

suppressed utilizing an appropriate response as

fire behavior and environmental conditions

dictate. An appropriate response includes the

full range of suppression options, chosen based

on qualitative and quantitative progress toward

multiple management objectives specified in the

Fire Management Plan. Responses are dictated

by the range of potential objectives, combined

with the program’s capabilities to safely

suppress a fire. Suppression action decisions

will be aided by the 2009 introduction of the

online interagency Wildland Fire Decision

Support System, (WFDSS), which offers tools

in decision analysis and reporting, and a range

of documented response options.

Wildland fires not in urban interface zones will

be suppressed utilizing Minimum Impact

Suppression Techniques (MIST).

Criteria that would assist in choosing strategies

of less than full suppression would include:

e No danger to human life or health.

Not danger to private or governmentowned property.

e Benefits must outweigh damage to

natural resources.

« Must not have any negative impact on

endangered, threatened or rare species.

e Must be capable of containment with

resources immediately available.

Alternative C: No prescribed burning will be

used. All wildland fires will be suppressed

utilizing an appropriate management response.

This alternative prevents the use of prescribed

burning as a management tool, but is otherwise

identical to Alternative B. A Fire Management

Plan describing this policy would be prepared,

approved and implemented.

Alternatives considered but eliminated from

detailed analysis: No suppression.

A fourth potential management alternative, of

no suppression of wildland fires, is not

considered further in this document, due to the

overwhelming impact upon public safety of

dealing with wildfires without options for active

management including suppression activity.

Comparison of the Alternatives/ Issues

A comparison of the three alternatives, based on

the objectives of the Fire Management Plan, is

difficult to quantify since the results depend

Environmenial Assessment

August 2010

upon when and where unplanned fires occur.

Wildfires will occur and will burn lands within

the Reservation regardless of which alternative

is applied.

Fire effects such as the amount of area burned,

the severity of the fire on the landscape, and

other effects described in this document do not

necessarily depend on the alternative chosen,

nor on the length of time a fire burns; rather,

they depend on the available fuels, short- and

long-term weather patterns, and topography for

each fire event.

In other words, a quantitative analysis of the

effects of each alternative would have to discuss

the data for fire effects at all different fuels,

weather, and topographic variations on the

Reservation. These factors at a minimum might

include the 13 fuel models and myriad

ecological communities and human land use

patterns present on the Reservation; weather

factors affecting fire behavior such as seasons,

climate patterns, current and expected weather,

and physiographic factors such as localized fire

effects histories, and local patterns of weather

observations based on topography.

Past Reservation fires have varied greatly in

their environmental effects based on

confluences of these factors. This document

attempts to make the best possible predictions of

each alternative’s fire effects in a mostly

qualitative way.

Table 1: General effects of each alternative upon general environmental concerns

Concerns

Firefighter

Safety

Alternative A (Full

suppression of all fires)

Risks to firefighters would

remain high during fire

suppression operations in

remote and difficult to

access parts of the

Reservation.

Alternative B (Range of

suppression options, use

| of prescribed fire:

| Proposed Action)

Risks to firefighters would

be reduced when using

modified suppression

tactics, or when limiting

response in remote areas

when a fire poses limited

risk to natural resources or

property, and is managed

for multiple objectives with

minimal suppression.

Alternative C (Range

| of suppression options,

| no prescribed fire)

Risks to firefighters

would be reduced when

using modified

suppression tactics.

However, lack of

prescribed fires would

allow continued fuels

buildup leading to

greater fire intensities in

unplanned fires, with

greater risks to

firefighters.

me

Restoration of

Role of Fire

in Native

Plant

Communities

Fire as a natural process

would be limited by active

suppression to limit burned

areas.

The role of fire as a natural

process would be resumed.

Fire would have a role

as a natural process.

Lack of prescribed

controlled buming

would intensify fire’s

effects in areas where it

had been excluded.

Introduction

and Spread of

Noxious

Weeds

The potential for weeds to

colonize areas disturbed by

fire could be reduced if the

total burned area were

minimized by active

suppression actions. On the

other hand, suppression

operations can

inadvertently bring in weed

seeds on firefighting

equipment, and disturb soil

to provide weed seedbeds.

The total area of short-term

| disturbance following fire

will be greater in some fuel

types and burn severities, if

fires are not immediately

suppressed. On the other

hand, fire does not

necessarily increase

noxious weed cover,

| depending on species and

season. Spring burning, as

invasive weeds have begun

to set seed, can reduce

invasive populations.

The total area of shortterm disturbance

following fire will be

greater in some fuel

types and bum

severities, if fires are not

immediately suppressed.

On the other hand, fire

does not necessarily

increase noxious weed

cover, depending on

species and season.

Eavironmental Assessmeat

August 2010

Concerns

Cultural

Properties

Alternative A (Full

| suppression of all fires)

|

|

Suppression operations

create short term intensive

land use (aircraft, activity,

line and camp construction)

and leave long term

physical scars (firelines,

retardant drops, road ruts

leading to further motorized

intrusion). Land use

mitigations include use of a

resource advisor and of

MIST tactics. Increased

fire’s negative effects might

include exposure of and

chemical or physical

changes to artifacts.

Alternative B (Range of

suppression options, use

of prescribed fire:

Proposed Action)

The short and long term

impacts of suppression

operations would be

minimized in culturally

significant areas

Prescribed burns receive a

cultural inventory to

identify and locate cultural

properties before potential

burning, which mitigates

most negative effects of

prescribed fire.

Alternative C (Range

| of suppression options,

no prescribed fire)

The role of fire as a

natural process would

be resumed. However,

species composition

changes resulting from

past fire exclusion have

created less diverse

landscapes which are

less resilient to further

environmental change.

Erosion increases which

may increase looting of

artifacts.

Effects on

Fauna

Fire effects would not

approach prehistoric norms,

due to a combination of fuel

buildups and resulting fire

severity, yet less acreage

burned overall at moderate

intensities.

Also, suppression.

operations may impact

animal species that show

stress in response to human.

activity in their habitat.

Fire would occur

Reservation-wide at nearprehistoric frequencies and

intensities, allowing fauna

io interact with fire effects

with species encountering

less necessity for rapid

adaptation to changes in

habitat due to bumancaused alterations of natural

fire regimes..

The role of fire as a

natural process would

be resumed. However,

changes in vegetation

resulting from past fre

exclusion have created

less diverse landscapes

which may be

welcoming to fauna, due

to lack of diversity of

food types, shelter, and

the resulting

diminishment of

available resources.

Air Quality

Smoke and the resulting

impairment of visibility

would be minimized by

extinguishing fires as soon

as possible.

Smoke and the resulting

impairment of visibility

could increase or be spread

over a longer period of time

as some fires are not

immediately suppressed.

Prescribed burn plans

mitigate smoke impacts by

allowing burning only when

| smoke will be diffused by

transport winds.

| burn more intensely in

Smoke and the resulting

impairment of visibility

could increase.

Unplanned fires will

areas not pretreated with

prescribed burns,

causing worse sh

term effects on air

and viewsheds.

sheds

Environmental Assessment

August 2010

Concerns

Soils Effeets

Alternative A (Full

suppression of all fires)

|

Fire-caused erosion would

be minimized for a

particular incident.

Conversely, impacts of

firefighting activities on the

ground would be

maximized. Use of aerial

retardant follows federal

guidelines to safeguard

riparian and aquatic

species. MIST tactics are

suggested for each

alternative. Other

Alternative B (Range of

suppression options, use

of prescribed fire:

Proposed Action)

Prescribed fires minimize

disturbance of surface

layers compared to

unplanned fires, and

actively plan to prevent

creation of hydrophobic or

sterilized soils. Lessened

suppression provokes less

physical disturbance than

Alternative A, but more

than Alternative C, due to

human operations on

prescribed burns.

| Alternative C (Range

| of suppression options,

no prescribed fire)

Unplanned fires

typically burn with

greater intensity than do

prescribed fires, with

greater effects on soils.

mitigation includes BAER

and other rehabilitation |

work following a fire.

IW. Affected Environment

This section of the environmental assessment

describes the existing environment potentially

affected by the proposed action.

3.1 Introduction

The Crow Indian Reservation covers over

2,226,000 acres or about 3,600 square miles, of

which almost two-thirds are trust lands: lands

for which the Bureau of Indian Affairs has a

trust management responsibility, usually for

multiple individual owners. About 137,300

acres are forested timberland in ponderosa pine,

limber pine, lodgepole pine, and dense

spruce/fir. Another 21,000 acres are juniper,

aspen and cottonwood/hardwood woodlands.

Forestlands are mainly on one of three mountain

ranges rising from the prairie. The Wolf

Mountains (and Sarpy hills) host mostly

Environmental Assessment

August 2010

ponderosa pine growing on sandstone. The

Pryor Mountains are mostly overmature stands

of lodgepole pine mixed with fir at higher

elevations; both areas are roaded and have

hosted timber sales. The Reservation’s portion

of the Big Horn Mountains rises above 9,000

feet, and access is protected for cultural uses.

Remaining trust lands are mainly open

grasslands devoted to range, wheat farming, or

other agricultural uses. Habitation by a

population of about 7,200 is concentrated in the

Little Big Horn River, Bighorn River, and Pryor

Creek valleys, mostly at a distance from

forested lands. Most wildfires are humancaused in the valleys and are near structures.

Away from population corridors of river

valleys, unplanned fires are mainly lightningcaused, and rarely threaten homes.

Patterns of land ownership and responsibility on

the Reservation are exceedingly complicated.