401 N 3rd Street, Suite 290

Minneapolis, MN 55406

612.332.9630
friends-bwca.org

Douglas Smith, District Ranger

Kawishiwi Ranger Station
1393 Hwy 169
Ely, MN 55731
(Submitted electronically to comments-eastern-superior-kawishiwi@fs.fed.us)
Mr. Smith:
The Friends of the Boundary Waters Wilderness (Friends) appreciates the opportunity to
comment on the Scoping Report for the Hi Lo Project in the Superior National Forest (SNF). The
Friends is a nonprofit organization with nearly 4,000 members who share our mission of
protecting, preserving and restoring the Boundary Waters Canoe Area Wilderness (BWCAW)
and the Quetico-Superior ecosystem. We communicate regularly with over 20,000 people
through mail, electronic mail, and social media. Our members and followers have a profound and
enduring interest in ensuring that actions proposed in and near the BWCAW protect wilderness
character and the biological integrity of the Quetico-Superior ecosystem.
Our comments on the Hi Lo Project are made with the knowledge that the project as described in
the Scoping Report is likely to change, perhaps significantly, due to impacts on the Forest from
the July 21, 2016 windstorm. Since the analysis underlying the proposed action was conducted
before the storm, and since the impact was heavily felt in the proposed project area, it is natural
that there will be changes. However, this has made the work of commenting on the Scoping
Report an exercise in responding to a project that may not be the one proposed. Since there is
little or no guidance provided as to how the project may change, we hope that the SNF will
provide additional opportunities for public involvement and comment through a supplemental
scoping process once these changes are known. However, based on the project described in the
Scoping Report, we believe that the potential environmental impact of thousands of acres of
logging, vegetation management and prescribed fire justify the preparation of an Environmental
Impact Statement (EIS).
We appreciate the Forest Service giving attention to the ecological conditions of the forest and
the BWCAW. The Friends generally supports the goals of re-introducing fire into fire dependent
ecosystems and understands the importance of reducing the risk of uncharacteristic wildfire.
Our comments on the Hi Lo Project Scoping Report raise a number of concerns and needs for
additional analysis.
The logging activities proposed in potential wilderness areas contiguous to the BWCAW
may be inappropriate for these areas.
Additional and specific analysis is required of the impact on wilderness character and
biological integrity from several proposed actions in the BWCAW and within a quarter
mile of the BWCAW border.

The open-ended time period for completion of project activities should be addressed to
ensure (as much as possible) that forest conditions at the time of project activity
implementation reflect the forest conditions at the time of completing environmental
analysis.
Claims that the Hi Lo project would maintain or improve habitat for threatened species
and species of special concern (such as the long-eared bat, goshawk, lynx, and moose)
require specific analysis.
The proposed access to Camp Lake should be analyzed in accordance with the principles
of public access and more details should be provided about how to ensure public access
to the BWCAW.

We address these issues in more detail in our attached comments and hope that they are helpful
as you make decisions about the environmental review required for the Hi Lo Project.
If you have any questions or would like additional information about these comments, feel free
to contact me.
Sincerely,
Aaron Klemz
Advocacy Director
Friends of the Boundary Waters Wilderness

Detailed Comments and Recommendations

Hi Lo Project Scoping Report
Friends of the Boundary Waters Wilderness
I.

The proposed action requires preparation of an Environmental Impact Statement

Forest Service National Environmental Policy Act (NEPA) procedures identify classes of actions
that normally require preparation of an Environmental Impact Statement (EIS). Proposals that
would substantially alter the undeveloped character of inventoried roadless areas or potential
wilderness areas fall into Class 2 of actions normally requiring an EIS.
(2) Class 2: Proposals that would substantially alter the undeveloped character of an
inventoried roadless area or potential wilderness area. Examples include but are not
limited to:
(i) Constructing roads and harvesting timber in an inventoried roadless area where
the proposed road and harvest units impact a substantial part of the inventoried
roadless area (FSH 1909.15 Section 21.2).
The term inventoried roadless areas refers to areas identified under the Roadless Area
Conservation Rule (RACR) (36 CFR 294.11). The Hi Lo project area involves management
activities in two RACR areas (Baldpate Lake and Hegman Lakes), and therefore should be fully
analyzed in an EIS.
The term potential wilderness area applies to areas inventoried as roadless area and considered
for recommendation as wilderness or Wilderness Study Areas in the 2004 Superior National
Forest Plan Revision (referred to in this comment and the Scoping Report as FP IRAs). The
Agassa Lake FP IRA, Baldpate Lake RACR/FP IRA, Big Lake FP IRA, and North Arm
Burntside Lake FP IRA. While none of these area are currently managed as wilderness or as
Wilderness Study Areas, all were inventoried as roadless areas in the 2004 Forest Plan Revision
process, all were evaluated for possible inclusion in the National Wilderness Preservation
System in the 2004 Forest Plan Revision, and all should be evaluated for inclusion in the
National Wilderness Preservation System in future Superior National Forest Plan revisions. The
term potential wilderness area is distinct from recommended wilderness areas, which are
those areas that are recommended for wilderness status as the result of the inventory and
evaluation process in FSH 1909.12 Chapter 70.
The inventory process outlined in chapter 70 of the handbook requires a thorough review
of not only those areas that were identified in previous inventories, but also other areas
that may meet the criteria. This inventory of areas is updated during land management
plan revision, and each area meeting inventory criteria is then evaluated following the
policy in FSM 1923 and the procedural guidance in FSH 1909.12, chapter 70. Based on
the evaluation, some potential wilderness areas may be administratively recommended
for wilderness designation. (Federal Register, Vol. 72, No. 20, p. 4479).
See below for a more thorough discussion of the impact of the Hi Lo project as proposed on
potential wilderness areas and inventoried roadless areas.

Even if the Hi Lo Project did not fall into a class of projects that require an EIS, the project
clearly may have a significant environmental impact and therefore an EIS should be prepared
(36 CFR 220.6(c)). Over 1,000 acres of clearcutting, over 6,000 acres of thinning, and nearly
9,000 acres of prescribed burning are proposed in the Hi Lo project. These project activities are
proposed in federal designated wilderness, potential wilderness areas, inventoried roadless areas,
and unique biological areas in the Superior National Forest.
Recommended Action: Prepare an Environmental Impact Statement to analyze the Hi
Lo project
II.

The Scoping Report reference to a July 2016 windstorm requires revisiting the
Purpose and Need of the proposal and providing avenues for public input on
potential changes through a supplemental scoping process

References to a July 2016 wind event in the Hi Lo project area occur at several points in the
Scoping Package. The cover letter for the Scoping Report states:
There is a large area in the Hi Lo Project that was impacted by a strong windstorm in July
2016. The extent and severity of the blowdown is still being assessed and mapped to
determine the best course of action The Hi Lo Scoping Report does not include
actions based on this blowdown because of incomplete information. We acknowledge
that impacted stands may be added or dropped from the proposed action unit pool and
some treatment types may change (1).
The Scoping Report adds:
Depending on the content of public comments and further analysis by the
interdisciplinary team, the team may look at alternative ways to address the proposed
action and may recommend additional stands for treatments, changes in treatment types,
or stands to drop from treatment. This is likely to happen once the extent of blowdown
from the July 2016 storm is fully assessed and mapped (12).
We recognize that the timing of this wind event poses a challenge to the SNF in scoping this
proposal, but the uncertainty of whether the actions described in the Scoping Package will be the
actual proposal makes it difficult for us to comment meaningfully on the project. We look
forward to the results of the interdisciplinary teams analysis and subsequent changes to the
Project. If significant changes are made to the project (especially any additional locations for
actions,) a supplemental scoping process should be initiated to provide the public with
meaningful opportunities to provide input on the revised plan.
As these modifications are being made, subsequent analysis should include updated analysis of
the desired conditions, purpose and need for the project actions, especially need A4, Create
Young Forest.

The interdisciplinary team identified opportunities to move the area toward desired
conditions by increasing the amount of young (0 to 9 years) age class within the project
area. Currently, this age class makes up less than 5 percent of the project area and Forestwide amounts are below the Forest Plan objective (8).
If the July 2016 wind event substantially changed the proportion of young age class forest in the
project area, the actions needed to achieve this desired condition should change as well.
This is especially true since the Scoping Report argues that wind events are one of the ways in
which the desired conditions of the Forest Plan come about and the conditions in the Hi Lo
project area were identified in 2015. The overall vegetation objective is to move conditions
from the existing condition in Hi Lo (based on data collection and conditions identified in 2015)
toward the long-term desired composition, age, spatial patterns, and within stand diversity
Historically, this was maintained by natural disturbances; such as fire and windstorms (5).
Recommend Actions: Initiate a supplemental scoping process if significant changes in
the Hi Lo Project proposal are made due to the impact of the July 2016 windstorm.
Revise the Purpose and Need to reflect forest composition changes due to the July 2016
windstorm.
III.

The timeframe for the proposed action should be more clearly defined, a time limit
established for actions proposed, and more detail should be provided on the
duration of each phase of the project

The Scoping Report states that if approved, proposed actions would be implemented beginning
in 2017. Implementation of primary treatments would be expected to occur over ten to fifteen
years (3). While the expansive nature of the proposed project justifies a longer period of
implementation, the history of vegetation management projects on the Superior National Forest
and the dynamic nature of the area show a need for a tighter implementation timeline. In 2016, a
Supplemental Information Report was completed for the 2001 Boundary Waters Canoe Area
Wilderness Fuel Treatment EIS. In that case, project activities that were fully analyzed in 2001
will be carried out fifteen years or more after that analysis. Much can change in fifteen years,
since the forest is a dynamic system. The Scoping Reports reference to the need to modify the
Hi Lo project in response to the July 2016 windstorm provides one example of this.
According to the Scoping Report, depending on the timeline for implementation, it is possible
that logging, vegetation management, and other activities that were analyzed 15 years earlier (or
more) could occur in the Hi Lo Project area. Given the emphasis on stand age and moving the
forest toward desired conditions in the Hi Lo project Purpose and Need, it is especially important
that proposed actions are implemented as close as possible to the time of the analysis used to
justify them.
Forest Service guidance on environmental review emphasizes that in multi-phase and complex
projects, more detail should be provided at the scoping phase regarding the timeframe of the
project. The when refers to the timeframe in which the project will be implemented and

completed. If a project has several identified phases, the duration of each phase should be
documented (FSH 1909.15, Section 11.2). The Scoping Report does not document the duration
of each phase of the project, providing only a general and broad statement of ten to fifteen
years. Since the Hi Lo Project involves vegetation management, road construction, trail
construction, and gravel pit management changes, the timeframe for each should be specified.
Recommended Actions: Provide a clear and specific statement of the duration of the
project, including the duration of each phase of the project.
Create a clear deadline for completion of project actions and trigger events in the
project area that would require revisiting the analysis conducted for vegetation
management (such as unforeseen fire and/or wind events.)
IV.

The impact on the status of potential wilderness areas and inventoried roadless
areas in the project area should be analyzed and an alternative included in
environmental review that excludes logging and road construction in these areas

The Hi Lo Project proposes timber harvest, vegetation management, and special use road
authorizations in a number of 2004 Forest Plan Inventoried Roadless Areas (FP IRAs).
Specifically, four FP IRAs are contained in the Hi Lo Project Area, Agassa Lake, Baldpate Lake,
Big Lake, and North Arm Burntside Lake. Baldpate Lake is also listed under the Roadless Area
Conservation Rule (RACR). A fifth area, Hegman Lakes, was identified under RACR but
excluded from analysis under the 2004 Forest Plan Revision (Scoping Report, 23).
Note: The term inventoried roadless areas is a term of art that refers to areas listed
under the RACR. We refer to 2004 Forest Plan Inventoried Roadless Areas as FP
IRAs and potential wilderness areas and to areas listed under the RACR as RACR
and inventoried roadless areas. In one case (Baldpate Lake) there is overlap between
these two categories, it is listed both under RACR and in the 2004 Forest Plan.
As noted above, Agassa Lake FP IRA, Baldpate Lake FP IRA/RACR, Big Lake FP IRA, and
North Arm Burntside Lake FP IRA are potential wilderness areas due to their inclusion in the
inventory of roadless areas for evaluation as potential wilderness in the 2004 Forest Plan
Revision. The characteristics that justified their inclusion in 2004 will also justify their inclusion
in a similar inventory when the next Superior National Forest Plan Revision is conducted.
While the terms used for these areas are different, the principles underlying the designation of all
these areas are similar. The goal of rules and Forest Service policies on inventoried roadless
areas and potential wilderness areas is to protect and preserve the undeveloped character of these
areas and to periodically analyze them for possible inclusion in the National Wilderness
Preservation System.
Previous vegetation management projects in this area of the SNF have avoided impacts to
potential wilderness areas and inventoried roadless areas. For example, the 2004 Echo Trail Area
Forest Management Project FEIS discusses at length the impact to roadless areas from a similar
proposal for timber harvest and vegetation management. In fact, the Echo Trail FEIS considered

alternatives that included timber harvest in some of the same areas as the Hi Lo Project scoping
package.
The discussion in the Echo Trail FEIS is instructive about the level of analysis that is required.
Since the [Record of Decision] for the Forest Plan was signed in July 2004, any proposed sitespecific project within a forest plan inventoried area requires an environmental analysis that
considers effects of the project proposal on the roadless characteristics in the area. The effects
analysis considers the entire inventoried area, not just the project area (Echo Trail FEIS, 3-124).
The issue is that harvest and road management activities would affect Forest Plan inventoried
roadless areas, which could adversely affect the long-term roadless characteristics of the areas,
effects that would be evident beyond the times when the actions are taking place (Echo Trail
FEIS, 3-125).
Ultimately, the Record of Decision (ROD) for the Echo Trail Project selected an alternative that
did not include timber harvest in inventoried roadless areas. We suggest a similar alternative that
excludes or modifies proposed actions within potential wilderness areas and inventoried roadless
areas should be included in the environmental review of the Hi Lo Project because a number of
proposed activities would change the undeveloped character of these areas adjacent to federal
designated wilderness and could potentially threaten their inclusion in a future inventory of
potential wilderness areas under FSH 1909.12 Chapter 70.
The Final EIS for the 2004 Forest Plan Revision analyzed a number of alternatives in detail that
prioritized different themes in the revised Plan. The alternative selected in the ROD (Modified
Alternative E) emphasizes a diverse economic base in local communities, emphasizes timber
harvest more than most of the other alternatives, and recommended none of the thirty inventoried
roadless areas in the SNF for wilderness study or inclusion (pp. 28-9). However, this
determination in 2004 does not preclude a future recommendation that any or all of these areas
(or any areas that meet the criteria under FSH 1909.12 Chapter 70) be included in the National
Wilderness Preservation System in the future.
It is the Friends position that no actions should be taken that could potentially threaten the status
of potential wilderness areas and/or inventoried roadless areas in the project area for inclusion in
a future inventory for wilderness study or possible inclusion in the BWCAW.
The Superior National Forest Plan is now twelve years old and the Plan will be revised at least
every fifteen years (SNF Forest Plan, 1-4). If approved, Hi Lo Project activities would be
carried out over the next ten to fifteen years (Scoping Report, 3). Therefore, the status of these
areas and evaluation as potential wilderness will be considered within the project timeline of the
Hi Lo Project, if approved.
As the SNF revises the Forest Plan, it will be governed by the Land Management Planning
Handbook. Specifically, FSH 1909.12 Chapter 70 will guide evaluation of current roadless areas
as potential wilderness areas. Section 70.1 will require the SNF to [i]dentify and evaluate lands
that may be suitable for inclusion in the National Wilderness Preservation System and determine
whether to recommend any such lands for wilderness designation. (36 CFR 219.7(c)(2)). This

process will begin by inventorying lands considered for inclusion in the National Wilderness
Preservation System using two overarching criteria, size and improvements.
While none of the FP IRAs are larger than 5,000 acres, since all of them are contiguous to the
BWCAW, all of them are likely to meet the size criteria contained in FSH 1909.12 71.21.
Specifically, [t]he 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
Therefore, in a future Forest Plan Revision, all of the FP IRAs will likely be evaluated under the
Improvements Criteria (FSH 1909.12 71.22) to determine if they will be included in the
inventory of areas to be evaluated for inclusion in the National Wilderness Preservation System.
The Improvements Criteria in the Forest Service Handbook is used to evaluate areas for
recommendation as Wilderness or Wilderness Study Areas include attributes that may be
affected by the Hi Lo Project as proposed. We discuss these below with specific reference to two
specific potential wilderness areas and the proposed actions inside of each.
Road Building and Special Use Road Authorization
Generally, new road construction is prohibited in roadless areas on National Forest System land
under the RACR, with defined exceptions (Forest Plan Revision Final EIS, C-3). While the
RACR does not apply to the potential wilderness areas in the project area, evaluation of the
wilderness suitability of roadless areas includes extensive guidance about the quantity and
quality of roads in an area. The Scoping Reports discussion of the Forest Plan Criteria for
Inventoried Roadless Areas (Table 13, p. 26) states that to meet the criteria an area must contain
[n]o more than mile of improved roads per 1,000 acres and [n]o roads not under Forest
Service jurisdiction.
The Scoping Report also states [i]n general the existence of OML 1 roads and decommissioned
routes, or temporary roads does not preclude an area from wilderness consideration (see
footnote 11 at 26). However, even if OML 1 roads or temporary roads do not preclude an area
from consideration for wilderness study, the quantity and quality of unimproved roads and
presence of temporary access needs are criteria used to justify planning decisions regarding
wilderness status.
Analysis of FP IRAs under Availability for Wilderness in the Forest Plan Final EIS includes
existence of unimproved roads in the area and special use authorizations. For example, Agassa
Lake IRA has 1.3 miles of unimproved road in the area and no known existing special use
permits. The State of Minnesota had a permit for access, which expired in May of 1999 (C25). The Big Lake FP IRA contains 1.6 miles of improved roads within the area (C-33).
There was a road access special use permit issued to the State of Minnesota to access their land
adjacent to the evaluated area, which expired in June of 2000 (C-35).
In the Hi Lo Project Scoping Report, special use authorizations for roads are proposed in two
potential wilderness areas, Agassa Lake FP IRA (SU-3, SU-4 and SU-5) and Big Lake FP IRA

(SU-2). The Scoping Report indicates that [m]ost of these requests [for special use road
authorizations from St. Louis County and Minnesota Department of Natural Resources] would
be short-term access, five years or less, and not become a permanent forest transportation system
road. This statement requires greater specificity. Regardless of whether special use
authorization roads are temporary, their presence on the land is one of the pieces of information
used for future decisions recommending inclusion in the National Wilderness Preservation
System.
Lastly, proposed special use authorization road SU-5 appears to overlap a road that is currently
in the Travel Management Plan (designated U5PVT58C11601 on the Superior National Forest,
Forest-Wide Travel Management Plan, Map 1-Disposition of Unclassified Roads). Table 5 lists
SU-5 under both new construction and existing unclassified. Future analysis should clarify
whether SU-5 is currently a classified road and what portions of SU-5 require new construction.
Recommendations: Alternatives to building additional special use authorization roads
in potential wilderness areas should be analyzed as part of the environmental review
process
The length of time that special use road authorizations would allow temporary roads to
exist should be specified. This is particularly important for roads SU-2, SU-3, SU-4,
and SU-5, which are proposed in potential wilderness areas.
Clarify that special use road authorizations are not permanent or improved roads (as
defined by the Forest Service) that could negatively future recommendation of
potential wilderness areas as wilderness or Wilderness Study Areas.
Clarify whether SU-5 is currently a classified road and what portions of SU-5 requires
new construction
Vegetation Management and Timber Harvest
Extensive timber harvest and vegetation management in the Agassa Lake and Big Lake FP IRAs
is proposed in the Hi Lo Project Scoping Package. In the Agassa Lake IRA, 1,277 acres of
Harvest Uneven Age is proposed, comprising nearly half of the Forest Service acres in the
area. In the Big Lake FP IRA, 530 acres of Harvest Uneven Age and 26 acres of Harvest
Even Age is proposed, comprising over half of the Forest Service acreage in the area. Other
potential wilderness areas in the project area are subject to a combination of non-harvest control
of understory vegetation and prescribed burning.
Scoping Report Table 13 describes criteria used during Forest Plan revision for inventorying
roadless areas, and consequently must be met in order for areas to maintain roadless
designation. The criteria description under Vegetation is No more than 20 percent of the
roadless area harvested with an even-age, regeneration cut in the past 10 years. These criteria
appear to come from a Regional Forester memo of August 13, 1997 titled Roadless Area
Inventory for Forest Plan Revision (see Forest Plan Revision Final EIS, C-6).

However, the continued maintenance of roadless designation using this criterion is not the real
issue potentially threatened by Hi Lo Project proposed actions. Ultimately, the value of
identifying roadless areas is to make sound land management decisions, including full
consideration of designating an area for possible inclusion in the National Wilderness
Preservation System. Both the Agassa Lake FP IRA and Big Lake FP IRA are currently likely to
be included in a future inventory of potential wilderness areas using criteria in FSH 1909.12
Chapter 70 and were included in the 2004 inventory. However, if the Hi Lo Project is approved
as proposed in the scoping package, they may be excluded.
Criteria used in future SNF Forest Plan revisions to evaluate potential wilderness areas are more
extensive than the 1997 Regional Foresters guidance on roadless areas. FSH 1909.12 71.22b
states include such lands in the inventory where the other improvements or evidence of past
human activities are not substantially noticeable in the area as a whole and specifies
[t]imber harvest areas where logging and prior road construction are not substantially
noticeable. Since Hi Lo timber harvest activities would affect approximately half of the Agassa
Lake FP IRA and Big Lake FP IRA, there is a possibility that when the next potential wilderness
area inventory is conducted, these areas could be excluded based on substantially noticeable
logging activities, even if they are not even-age regeneration cuts.
Even if included in a future inventory, the project activities may affect evaluation of the
suitability of these areas for inclusion in the National Wilderness Preservation System under a
number of criteria in FSH 1909.12 72.1. Specifically, [e]valuate the degree to which the area
generally appears to be affected primarily by the forces of nature, with the imprints of mans
work substantially unnoticeable (apparent naturalness). Consider such factors as: [t]he extent
to which improvements included in the area (sec. 71.22 of this Handbook) represent a departure
from apparent naturalness.
Each area is currently a good candidate for inclusion in the National Wilderness Preservation
System. Both are contiguous with the BWCAW and include water resources that are of value for
wilderness camping. Big Lake FP IRA is a particularly appealing area for potential future
inclusion in the BWCAW, since Big Lake could provide additional wilderness use capacity
because the Portage River is a good travel route, campsites could be constructed along the river,
and it connects with existing BWCAW canoe routes. The evaluated area also has a very
manageable boundary with the Portage River and state land (C-35).
Currently, both areas would meet the naturalness criterion in FSH 1909.12 72.1. The 2004
Forest Plan Revision Final EIS describes Agassa Lake FP IRA: [t]he area has been modified
over time, but is essentially natural appearing. It is in scenic class 2, which has high public
value (C-24). The Big Lake FP IRA is basically natural appearing. It is in scenic class 1 which
has high public value. After approximately half of each area is modified by uneven age logging
and thinning, it seems unlikely that either would meet the naturalness criterion in the next Forest
Plan revision.

10

Recommendations: Ensure that environmental analysis of the Hi Lo Project considers

effects of the project proposal on the roadless characteristics in potential wilderness
areas and inventoried roadless areas. The effects analysis should consider the entire
inventoried area, not just the project area.
Remove timber harvest in the Agassa Lake and Big Lake IRAs from the Hi Lo Project
or at a minimum, analyze an alternative that excludes or modifies these activities in
potential wilderness areas to preserve their undeveloped and natural character.
Include analysis of the impact of Hi Lo Project proposed actions on the wilderness
recommendation criteria described in FSH 1909.12 Chapter 70 and the impact on the
status of each potential wilderness area.
V.

Activities proposed in RACR areas require analysis under 36 CFR 294.13(b)(1) that
they maintain or improve roadless area characteristics

Since the roadless areas discussed in the Scoping Report include areas that were designated
under different processes and under different statutes and rules, this comment addresses the
Roadless Area Conservation Rule (RACR) areas (Hegman Lakes and Baldpate Lake) separately.
The Hi Lo Project Scoping Report references 36 CFR 294.13(b)(1) in regard to the RACR areas
in the project area. While 36 CFR 294.13(b)(1)(ii) does include restoring ecosystem composition
and reducing the risk of uncharacteristic wildfire as exceptions to the general prohibition against
timber harvest, it subordinates this purpose to protecting the roadless character of the area. See
36 CFR 294.13(b)(1), whereby Responsible Official can authorize the cutting, sale or removal of
timber in inventoried roadless (RACR) areas when [t]he cutting, sale, or removal of generally
small diameter timber is needed for one of the following purposes and will maintain or improve
one or more of the roadless area characteristics as defined in 294.11.
These characteristics (36 CFR 294.11) are:
(1) High quality or undisturbed soil, water, and air; (2) Sources of public drinking water;
(3) Diversity of plant and animal communities; (4) Habitat for threatened, endangered,
proposed, candidate, and sensitive species and for those species dependent on large,
undisturbed areas of land; (5) Primitive, semi-primitive non-motorized and semiprimitive motorized classes of dispersed recreation; (6) Reference landscapes; (7) Natural
appearing landscapes with high scenic quality; (8) Traditional cultural properties and
sacred sites; and (9) Other locally identified unique characteristics.
Therefore, analysis of the proposed actions inside of RACR areas should not end at the
declaration that the intent of the action is to reduce the risk of uncharacteristic wildfire. It must
also include analysis of whether the proposed actions maintain or improve roadless area
characteristics.
Additionally, activities in the Baldpate Lake FP IRA/RACR (specifically, Stand Unit 031-026)
could involve the use of herbicides glyphosate and triclopyr on the border of the BWCAW. This

11

Stand Units primary treatment is listed as CNTLVEG-NONFIRE in Attachment 1 of the

scoping package. Attachment 2 of the scoping package states that CNTLVEG-NONFIRE
[w]ork can be accomplished using motor hand tools such as brush saws or chainsaws or by hand
with herbicide. The SNF Forest Plan has specific guidance about the risk of chemical use on
wilderness values. Special care must be taken with the use of chemicals inside wilderness
because of possible effects on the total biological complex. Consider other alternatives to
chemical use in the environmental analysis (3-63). While the Forest Plan is referring to planned
chemical use in the BWCAW, the risk to riparian environments and from overspray suggest
mechanical, rather than chemical, means of vegetation control should be employed adjacent to
the BWCAW boundary.
Lastly, the Scoping Report references the memorandum of May 31, 2012 titled Chiefs Review
Process for Activities in Roadless Areas. Section 2 of the memorandum indicates that the
Regional Forester approval of activities in the RACR areas of the Hi Lo Project would be
required. However, there is no information about the review process that would be conducted.
Further information about the Regional Foresters review process should be included in further
environmental analysis of the Hi Lo Project.
Recommendations: Analyze vegetation management activities in Stand Unit 031-026 in
the Baldpate Lake RACR, including whether these activities maintain or improve the
roadless area characteristics.
Consider specifying that the primary treatment in Stand Unit 031-026 will be
accomplished with motor hand tools and exclude the use of herbicide due to proximity
to the wilderness boundary.
Provide further information about the Regional Foresters review process for
management activities in RACR areas.
VI.

Specific analysis examining impact on wilderness character of the BWCAW is

needed from a variety of proposed activities in the Hi Lo project

Chemical Usage
The Hi Lo Project proposes 591 acres of Control Understory Vegetation (Other than Burning)
in the project area. An unspecified amount of this activity may involve the use of herbicides
glyphosate and triclopyr (Attachment 4, 3). Attachment 2 of the scoping package states that
Work can be accomplished using motor hand tools such as brush saws or chainsaws or by hand
with herbicide. The Superior National Forest plan recognizes the higher standard for chemical
use that could affect the BWCAW: [s]pecial care must be taken with the use of chemicals inside
wilderness because of possible effects on the total biological complex. Consider other
alternatives to chemical use in the environmental analysis (Forest Plan, 3-63). While the Forest
Plan is specifically referring to planned chemical use in the BWCAW, risk to riparian
environments and from overspray suggests that mechanical, rather than chemical, means of
vegetation control should be employed adjacent to the BWCAW boundary.

12

Recommended Actions: Mechanical, rather than chemical, means of vegetation control

should be employed adjacent to the BWCAW boundary and in areas where chemicals
could enter the wilderness.
Environmental analysis of the Hi Lo project should include analysis of the potential
impact of chemical use on the BWCAW.
Noise
The Spring Creek gravel pit is located approximately one quarter mile from the BWCAW
boundary. This gravel pit currently has no designation and is proposed for Continuous Use as
one of the Hi Lo Projects proposed actions. Gravel pit operations create a good deal of noise,
and depending on the level of operation, the Spring Creek gravel pit could impact the wilderness
character of the BWCAW. Previous projects in the SNF have analyzed the impact of noise on
wilderness character, for example, the Forest-Wide Travel Management EA and South Fowl EIS
analyzed the impact of noise from OHVs up to one mile from the wilderness boundary. While
the Spring Creek gravel pit is located along the Echo Trail, noise from gravel operations could be
louder than vehicle traffic and could carry much further.
The Spring Creek gravel pit is located between the Agassa Lake FP IRA and the Hegman Lakes
RACR, and within one-quarter mile of the BWCAW. This portion of the BWCAW is designated
primitive wilderness, which provides an excellent opportunity for solitude, relatively free from
the sights and sounds of humans (Forest Plan, 3-44). Previous Forest Service projects have
analyzed the potential impact of noise on solitude, naturalness, and the untrammelled nature of
wilderness. Given that the Spring Creek gravel pit would potentially triple in size from its
current acreage and that use would continue indefinitely, the noise impacts on wilderness should
be analyzed.
In addition, while logging and vegetation control activities contemplated under the Hi Lo project
would occur on the edge of the wilderness. These activities can create significant noise impact
that can impact the wilderness character of the BWCAW and should also be included in
environmental analysis of the Hi Lo project.
Recommended Actions: Analyze the noise impact on the wilderness character of the
BWCAW from designating the Spring Creek gravel pit for continuous use.
Analyze the noise impact on the wilderness characters of the BWCAW from logging
and vegetation management actions conducted near the wilderness boundary.
Prescribed Fire
The Friends generally supports the goal of restoring the role of fire in fire-dependent landscapes
in the Superior National Forest. Use of prescribed burns in wilderness areas may be an
appropriate way to restore ecologically-balanced forests and reduce unnatural fuel loads in
wilderness areas, but human intervention in wilderness is generally to be avoided. Previous
management decisions over the past century to suppress naturally ignited fires have modified the

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forest in the BWCAW. Wide-scale wind events, such as the July 4, 1999 blowdown and the July
21, 2016 windstorm, can also create conditions that can cause hazards outside of the wilderness
from uncharacteristic wildfire.
That said, the burden of analysis for prescribed fires in the wilderness is high, and environmental
review of the Hi Lo Project should be correspondingly rigorous. The 2001 Boundary Waters
Canoe Area Wilderness Fuel Treatment Final EIS analyzed impacts on natural integrity, apparent
naturalness, outstanding opportunities for solitude, outstanding opportunities for primitive
recreation, and scenery. It also analyzed the cumulative effects of the alternatives for the
proposed actions, which are similar in type to those proposed in the Hi Lo project.
The Wilderness Act of 1964 defines wilderness:
A wilderness, in contrast with those areas where man and his own works dominate the
landscape, is hereby recognized as an area where the earth and its community of life are
untrammeled by man, where man himself is a visitor who does not remain (Public Law
88-577, 2(c)).
There is an inherent tension between the definition of wilderness as untrammeled by man and
these proposed management activities. Further environmental review of the Hi Lo Projects
proposed actions within the BWCAW should include analysis of whether these actions enhance
and protect wilderness character.
Recommended action: Analyze the impact on all relevant dimensions of the wilderness
character of the BWCAW from proposed human ignited prescribed fire in the
wilderness.
VII.

Analyze the impact of proposed actions in Birch Bay Unique Biological (UB) Area to
determine if actions are consistent with the Forest Plan

Only 2,578 acres in the Superior National Forest are designated as UB management areas in the
2004 Forest Plan. One of the larger UB areas in the SNF is the Birch Bay UB in the North Arm
Burntside IRA, comprising 757 acres adjacent to the BWCAW (Forest Plan, 3-28). In the
scoping package, two types of prescribed burns are proposed in and adjacent to Birch Bay UB
area.
UB management areas have outstanding biological and other special values and are primarily
managed for interpretive purposes (Forest Plan, 3-28). In the 2004 Forest Plan Revision, Birch
Bay was considered for candidate Research and Natural Area Status. Modified Alternative E,
which was selected, protected Birch Bay as a UB area because of unique ecological attributes
not found elsewhere on the forest (Forest Plan Record of Decision, 18).
Prescribed burning is not necessarily inappropriate for management of a UB area. Forest Plan
Standards and Guidelines S-UB-1 states: [e]xisting old-growth or old forest will be managed in
order to protect and maintain existing conditions. In some forest community types, this may
require the periodic use of prescribed fire (3-28).

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However, [m]anagement emphasis is on conserving or enhancing areas of unique biological

interest. Management practices that would alter important values associated with the UB
management areas are not appropriate (3-28).
Recommended Action: Analyze the prescribed fire actions proposed in the Birch Bay
UB area to determine if they would alter important values and unique ecological
attributes of the area.
VIII. Analyze the impact of proposed actions in the Hi Lo Project on threatened species
and species of special concern (lynx, moose, long-eared bats and goshawks)
The Scoping Report says [h]abitat would be maintained and improved for a variety of species,
including but not limited to, lynx, northern long-eared bat, goshawk, moose, and other species
where opportunities and needs are present (9). This statement needs significant analysis in the
environmental review of the Hi Lo project. The project area contains federally threatened lynx
and northern long-eared bat, as well as Minnesota species of special concern moose and northern
goshawk. All of the Hi Lo Project Area is designated critical habitat for lynx.
It does not suffice to say that implementing actions that meet landscape ecosystem objectives
necessarily maintain and improve habitat for each of these species. The Forest Service should be
specific in stating which species habitat is maintained and for which species habitat would be
improved. Environmental analysis of the Hi Lo project would then need to specifically
demonstrate why these predictions are supported by evidence.
In some cases, actions that improve habitat for one species may degrade habitat for another. In
addition, there are specific issues related to incidental take and known territories for species of
concern that would need to be addressed in further environmental review. The Scoping Report
provides one example in the description of a newly discovered goashawk (sp) territory (9).
Recommended action: Specify the predicted impact on habitat for each threatened
species and species of concern and provide evidence for each predicted impact.
Analyze the risk of incidental take and disruption of known lynx denning sites,
goshawk territories, and long-eared bat hibernacula or maternity roosting sites from
the proposed action.
IX.

Protect the ability of the public to access Camp Lake and consider the BWCAW
management impacts of expanded access

The Scoping Report includes a proposed trail across a permanent easement on land near Camp
Lake. Camp Lake straddles the BWCAW boundary and there is currently little public access. If
public access is created through trail construction, this may open an additional access to the
BWCAW, and will require decisions about how to manage this access. For example, would an
additional permitted entry point into the BWCAW be established with quotas? Would a
BWCAW campsite be appropriately constructed on Camp Lake? Does Camp Lake currently

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connect to existing canoe routes in the BWCAW, or could it connect through the construction of
a portage (or portages)?
The Friends believes that public access to the BWCAW should be preserved. We support the
acquisition of a permanent easement before the sale of Lake County public land to a private
owner.
Recommended Action: Analyze the BWCAW management implications of the trail
providing public access to Camp Lake.

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