20230552 Ver 1_Twelve Mile Final Decision_signed_20230417

USDA Decision Notice,
aNd
United States inching of No Significant Impact,
Department of
Agriculture And Comment Res ons
Forest Service
Southern Region.
January Twelve Mile Project
2020
Appalachian Ranger District
Pisgah National Forest
Haywood County, North Carolina

Decision Notice,
Finding of No Significant Impact,
And Comment Response
Twelve Mile Project
USDA Forest Service
Appalachian Ranger, District, Pisgah National Forest
Haywood County, North Carolina
Decision and Rationale
Forest Service Decision
Based upon my review of the alternatives, I have selected all actions on Forest Service lands, design
features, and mitigations associated with Alternative B - Action Alternative from the Twelve Mile Project
EA as a phased decision. My decision will have two phases to allow for a Forest Plan amendment to be
completed to assign management area direction on an unassigned parcel in Compartment 0468. My
decision does not include the portion of a prescribed burn unit that is located on Great Smoky Mountains
National Park lands included in the analysis. The National Park Service will issue a separate decision for
the prescribed bum proposed on Park Service lands.
Phased Decision: Alternative B - Action Alternative
It was brought to my attention that actions were proposed on lands recently acquired by the Forest Service
that do not officially have designated land management direction consistent with the current Nantahala
and Pisgah Land and Resource Management Plan (Forest Plan). The Forest Plan (page HI-45) direction is
to "use plan amendments to designate management areas to new land acquisitions." A Forest Plan
amendment has not been completed to designate management area direction to the acquired parcel in
Compartment 0468-Stands 44, 45, 46, 48, and 49. My decision contains two phases. Phase #1 will be
effective upon signing of the final decision and Phase #2 will be contingent upon a Forest Plan
amendment decision that officially applies management area direction to these lands.
• Phase #1: I have decided that Phase #1 will contain all actions on Forest Service lands, design
criteria, and mitigations associated with the Twelve Mile Project EA Alternative B - Action
Alternative with the exception of those actions proposed in the unassigned parcel in Compartment
0468, Stands 44, 45, 46, 48, and 49. Phase #1 of my decision will be effective upon signing the
final Decision Notice.
• Phase #2: I have decided that Phase #2 will contain the woodland management, wildlife field
creation/expansion, and stand improvement actions in compartment 0468, Stands 44, 45, 46, 48,
and 49. Phase #2 of my decision will be contingent upon a Forest Plan amendment decision that
officially assigns management area direction to this acquired land. Actions in this parcel were
fully analyzed in the Twelve Mile EA and are consistent with adjacent Management Area (MA)
direction for MA I and MA 4C.
Alternative B Actions
Together, Phase #1 and Phase #2 of my decision will contain all the actions on Forest Service lands of the
Twelve Mile Project EA Alternative B - Action Alternative. Please refer to the Final EA for a full
description of this Alternative as well as the Twelve Mile Decision Map associated with this Decision

Notice. These can be found on the project website at: htti,);//www.fs.usda.tpov/y Project/?I)rQject=48776
under the decision tab.
The following is a summary of the Alternative B actions:
• Regenerate approximately 1,027 acres by two -aged commercial harvest methods (shelterwood
with reserves, overstory removal, or oak shelterwood). The two -age harvest methods remove
most trees, leaving some overstory trees so that two distinct ages of trees are maintained on the
same site. The leave tree basal area will be designed to meet visual quality objectives outlined in
the EA and/or meet specific stand objectives.
• Commercially harvest approximately 329 acres using uneven -aged harvest methods (group
selection, group selection with thinning, or variable retention).
• Create and maintain approximately 498 acres of woodland habitat conditions using commercial or
non-commercial harvesting, herbicides, prescribed fire, mastication, and/or mowing.
• Commercial thin approximately 327 acres.
• Improve stands using non-commercial methods (stand release and/or vine control). on
approximately 649 acres.
• Designate approximately 1,570 acres of small patch old growth.
• Create approximately 136 acres of permanent wildlife fields, either new or expanding existing
fields. Trees will be removed by commercial or non-commercial harvest, stumps removed,
grasses and shrubs planted, and will be maintained by mowing.
• Prescribe burn approximately 1,180 acres.
• Improve 14 stream crossings.
• Enhance .66 miles of stream.
• Install one informational kiosk.
• A total of approximately 7.95 miles of road construction on existing corridor and a total of
approximately .68 miles of new road construction.
• A total of 28.5 miles of changes to the current transportation system including adding system
roads, changing seasonal closures, and closing roads.
Design Features and Mitigations
My decision will follow all the design features and mitigations contained in the Twelve Mile Project EA.
The design features and mitigations are listed below:
• To provide for future salamander habitat, all existing large coarse woody debris be left on site
when feasible.
• During the northern long-eared bat (NLEB) pup season (June 1—July 31), where possible and not
a safety hazard, leave dead or dying trees standing.
• If discovered during implementation, avoid cutting or destroying known NLEB maternity roost
trees during the pup season (June 1-July 31).
• If discovered during implementation, avoid Shelterwood harvest within 150 feet of known NLEB
maternity roost trees during the pup season (June 1—July 31).
• Herbicides application will follow all label directions.
• Riparian areas (MA 18) will be defined as 100 feet each side of a perennial stream when not
specifically mapped by an interdisciplinary team. During implementation, riparian areas may be
mapped by an interdisciplinary team using a minimum of 30 feet each side of a perennial stream

and /or wider as needed to enhance riparian values. This is not reflected on the proposed action
map.
• Implementation of instream work will be scheduled outside of the trout spawning season
(October 15-April 15).
• Control lines for prescribed burns that are needed within the riparian area will be constructed by
hand perpendicular to the stream flow and only remove brush and duff (no trees). After the burn
is completed these lines will be rehabilitated by seeding and/or mulching.
• Trees accidentally felled across stream channels (that prevent or block stream flow) will be lifted
(when possible) away from the water. If this is not possible, each tree will be pulled away from
the water where it fell and temporary decking will be used to support the weight of the tree as it is
pulled across the channel. These removals will be perpendicular to the stream channel whenever
possible to minimize stream bank disturbance. Bare soil will be seeded and mulched if native
vegetation does not start to recolonize the area by the time timber removal from the unit is
complete.
• Skid roads will avoid stream crossings when feasible and will avoid paralleling perennial
channels within designated riparian areas.
• Landings and skid trails should be vegetated as soon as possible after use to avoid off -site soil
movement.
• Temporary roads (if needed) will be constructed to avoid runoff into area streams. In addition, silt
fence, straw bales, or brush barriers will be placed along the length of the road where it parallels
or crosses a stream as needed to control runoff and stream sedimentation.
• Where feasible, stream crossings will be designed so that they allow for continuity of habitat for
all aquatic organisms.
• The CxA soil occurs once in harvest unit 97 (woodland management unit) and the TuD soil
occurs in units 43 (commercial thinning unit), 42, 45 (regeneration cut unit), 0467/16 (wildlife
opening) and 11 (woodland management unit). Before ground disturbing activities occur in these
units, consult with hydrologist/soil scientist.
• Small spreading pogonia was observed by botanical contractors in Commercial Thinning Unit
104 and in Woodland Creation Units 59 & 85. A 50 foot no -activity buffer will be placed around
the small spreading pogonia population primarily to keep it from being crushed by machinery and
tree felling operations.
• When butternut is encountered during timber marking or timber harvesting operations this species
will be left un-cut in the stand. Consult with botanist to determine the best way to protect
individual trees. Butternut was found in the following proposed units: In Regeneration Harvest
Unit 7, one tree approximately 18" DBH was found in decent condition (though it probably has
early stages of canker). In Regeneration Harvest Unit 21, two trees exhibiting butternut canker
were found (one 7" DBH, the other 13" DBH).
• Ovate catchfly was found in Regeneration Harvest Unit 15.. A 100-foot no -activity buffer will be
placed around populations of ovate catchfly primarily to maintain the desired shade environment.
• A 50-foot no -activity buffer will be placed around the piratebush population in 0462-18 to
preserve a partially shaded environment and protect the parasitic interaction with mycorrhizae
associated with tree roots. One outlying individual will be avoided but will not have a 50' buffer
in an effort to re -use an existing skid trail.
• A 50 foot no -activity buffer will be placed around populations of small yellow lady's-slipper if
discovered (potentially in treatment unit 58).
• Treatment of non-native invasive species will be prioritized to coincide with implementation of
ground disturbing activities when needed to control spread or promote forest regeneration.
Controlling invasive plants is most easily and effectively done by the use of herbicide. It may be
necessary to treat these populations several times to ensure successful control. This action is
covered by the 2009 Decision and Environmental Analysis titled Nantahala and Pisgah National

Forest Non-native Invasive Plant Control and is not a part of this decision. However, the actions
may be performed in conjunction with the proposed activities in this document when needed.
• All eligible and unevaluated heritage sites will be flagged and avoided during any ground
disturbing activities.
• Rock shelters archaeological sites were not found in burn units during survey. If any rock shelters
sites are discovered during implementation, those sites will be monitored and protected from
undesirable impacts by: 1) Photographing shelters identified by the Archeologist as sensitive
before any preparation work is completed; 2) Physically removing dead fuels from the area
immediately in front of shelters and scattering those fuels; 3) Blowing leaves and fine fuels from
the shelters and entrances to the shelters; 4) Ensuring bum prescriptions are within parameters
where duff layer is not consumed; 5) Utilizing firing patterns which minimize intensity around
rock shelters; and 6) Photographing documentation of post -bum results.
• If the implementation of project activities results with the discovery of previously unknown
cultural resources, the activity will be immediately stopped pending archeological documentation
and evaluation. This may result with a recommendation to stop, modify, or proceed with the
activity using appropriate mitigation measures.
• Harmon Den Horse Camp will be temporarily closed during the harvest of the units within close
proximity due to noise concerns and to ensure public safety.
• Hauling timber through the Harmon Den Horse Camp will be restricted on the weekends and
holidays during the open season. Do not allow engine compression breaking while hauling
through the Horse Camp and Day Use Area.
• Temporarily close trails and roads adjacent to or within active harvest units. Post temporary
closure signs on gates near trails in the areas where trails will be impacted by timber harvesting.
Provide closure information on the Forest website and office.
• Ensure signs and reassurance markers (blazes) are restored to original location/condition if
damage occurs during operations. To the extent possible, retain trees that hold signs or are
marked with reassurance markers (i.e. diamonds on trails).
• Repair any damage to trails caused by commercial harvest operations.
• When actively hauling, post information and caution signs on roads that are used as Horse Trails.
• In Compartment 0466, regeneration harvest exceeds Forest Plan Standards by 15 acres as
analyzed. During implementation, ensure total acres do not exceed Forest Plan Standards.
• All prescribed burning activities on the Pisgah National Forest, including those proposed in this
action, are conducted in accordance with the Region 8 Smoke Management Guidelines in order to
alleviate the smoke related impacts.
• Natural or artificial regeneration of recently harvested stands may be excluded from prescribed
burning, consult with Silviculturist for appropriate timing.
• Design features to meet Visual Quality Objectives can be found in the Scenery section of the EA.
These tables were not included in this section due to their lengthy size.
Best Available Science
My decision is based on a review of the project -record that shows a thorough review of relevant scientific
information, a consideration of responsible opposing views, and the acknowledgment of incomplete or
unavailable information, scientific uncertainty, and risk pursuant to 40 CFR 1502.9(b), 1502.22, and
1502.

Rationale
My criteria for making a decision on this project was based on how well the management action analyzed
in the EA address the purpose and need of the project and considerations of issues that were raised during
the scoping process and the comment period on the EA. I considered Forest Plan standards and guides for
the project area and took into account competing interests and values of the public.
I have reviewed the alternatives analyzed in detail and have found that they are responsive to the issues
and concerns as well as purpose and need for action. The issues were developed based on public and
internal comments and an interdisciplinary review of existing conditions in the project area. The purpose
and need for action is consistent with the goals and objectives of the Forest Plan.
I reviewed public comments from the scoping period as well as those that were received for the EA
Notice and Comment Period. The interdisciplinary team (IDT) considered all public comments that were
received when developing the EA. I find that the range of alternatives considered was thorough and
complete, and reflects public comments and concerns.
Based on my review, I have selected a modified version Alternative B, the Action Alternative. This
decision will best meet the watershed, wildlife, and vegetation restoration purposes and needs of this
project. This decision minimizes the addition of system roads to those needed to meet wildlife objectives
of this project, continue maintenance of existing wildlife fields, provide management access, provide
public access, and provide access to private properties. This decision meets the purpose and need for
action (EA, Purpose and Need of Action) while being responsive to public comments and other agency
concerns and summarized as follows.
• There is a need to create 0-10 year age class. My decision includes approximately 1,027 acres
of two -aged regeneration harvest which creates new 0 year age class and provides temporary
young forest habitat needs defined in the Forest Plan. My decisions meets mid to upper level
objectives from the Forest Plan for young forest habitat in most compartments. My decision does
not meet Forest Plan standards for young forest in compartment 0457 and 0464 due to limited
access and poor logging feasibility.
• There is a need to commercially thin overstocked units. My decision will commercially thin
approximately 327 acres in stands found to be overstocked but not within rotational age,
culmination of mean annual increment, or other conditions appropriate for regeneration harvest.
• There is a need for non-commercial stand improvement to reduce stocking, improve
growth, and promote desired species. My decision will thin young overstocked stands, favoring
desired species for the site; release favorable trees where necessary to maintain desired species
diversity; and reduce vines when problematic for forest growth.
• There is a need to designate small patch old growth. My decision will designate 1,570 acres of
small patch old growth and meets or exceeds Forest Plan standards in each compartment.
• There is a need to create, maintain, and improve permanent wildlife openings in MA 3B,
4A, 4C, and 4D (MA 1B emphasizes temporary wildlife habitat within the context of timber
management but does not preclude creating permanent wildlife habitat). My decision will
create/expand 131 acres of wildlife fields as well as additional acres created in log landings when
feasible. My decision will also daylight closed roads currently maintained as linear wildlife
openings thereby enhancing the early successional habitat attributes. This decision will also
provide official access for maintaining established wildlife openings by designating roads as
system roads with maintenance levels appropriate for that use.

• There is a need to increase shortleaf pine (Pious echinata) and other yellow pine species
within the shortleaf pine and pine/oak heath ecological zones. My. decision includes 274 acres
of prescribed burning and 80 acres of woodland creation designed specifically to enhance and
maintain species composition and habitat objectives in the limited amount of shortleaf pine and
pine/oak heath ecological zones that exist in the project area.
• There is a need to manage white pine (Pinus strobus) dominated stands towards species that
are more appropriate for the ecological zone. Collaborative engagement highlighted white pine
dominated stands as a high priority for creating young forest while also attempting to diversify
species composition appropriate for the ecological zone. My decision includes 245 acres of two -
aged regeneration harvest in white pine dominated stands. Other white pine dominated stands
were identified but not included in the action alternative due to access and feasibility issues.
Additionally, my decision includes an uneven -aged harvest on 156 acres that has a large
component of white pine which will be managed to diversify the species composition.
• There is a need to promote the regeneration of oak species (Quercus spp.) within the
appropriate ecological zones. My decision includes 1,003 acres of prescribed burning, 388 acres
of two -aged regeneration harvest, 43 acres of commercial thinning, and 333 acres of uneven -aged
harvest that have the opportunity to promote regeneration of oak species.
• There is a need to move the condition classes within ecological zones towards the natural
range of variation (NRV). This project utilized a project area departure analysis to help
determine needs and priorities in this area as it relates to NRV. Although NRV distribution goals
for the geographic area are not met through this one project, my decision includes actions that
move the distribution in the right direction as will future projects. The actions included in my
decision that contribute to this are: 1,288 acres of prescribed burning, 29 acres of commercial
thinning, 1,009 acres of two -aged regeneration harvest, 333 acres of uneven -aged regeneration
harvest, and 497 acres of woodland creation.
• There is a need to create suitable habitat for golden -winged warblers (Vermivora
chrysoptera). My decision includes 167 acres of two -aged regeneration harvest that were
specifically selected for creating golden -winged warbler habitat. Additionally, my decision allows
log landings to be maintained for golden -winged warbler habitat where feasible.
• There is a need to replace undersized or failing culverts and improve fords to protect water
quality. My decision includes replacing or improving 11 culverts or fords that were determined
to be failing or inadequate.
• There is a need to restore aquatic organism passage (AOP) where old culverts or fords limit
the movement of aquatic species. My decision includes restoring the three aquatic organism
passages that were determined to be obstructive.
• There is a need to restore stream conditions in Cold Springs Creek and Fall Branch. My
decision includes stream bank restoration in these areas that were found to be channelized and
eroding.
• There is a need to create a safe and efficient transportation system to provide and improve
access for public and commercial recreation, research, public land management, and
private land use in the most ecological, economic, and socially sustainable manner. I have
completed a transportation analysis for this project and made decisions based on current access
needs and maintenance issues. My decision includes a total of approximately 7.95 miles of road
construction on existing corridor and a total of approximately .68 miles of new road construction
to provide management access now and into the future. My decision also includes a total of 28.5
miles of changes to the current transportation system including adding system roads, changing
seasonal closures, and closing roads which will provide adequate access for recreation and other
forest users, provide public transportation routes, provide private land access, and reduce
maintenance needs as much as possible.

In reaching my decision, I reviewed the purpose and need for the project and the alternatives
considered in detail in the EA. I then carefully weighed the effects analyses of the alternatives and the
public comments received. The Twelve Mile Project IDT conducted field surveys, database queries,
and other localized analyses in order to determine effects the alternatives considered in detail could
have on the area's ecology including threatened, endangered, and sensitive species. During their
analyses, they took a hard look at past, present, and reasonably foreseeable future actions that could
be combined with expected effects from the proposed action. The IDT provided sufficient analyses
and conclusions to make a reasoned decision. This analysis supports that the Selected Alternative
moves resources in the project area towards the desired future conditions and achieves the purpose
and need for the project.
Other Alternatives Considered
There was a focus to develop this project in a collaborative effort with many forest users and interest
groups. Due to this engagement early in the process, many issues and conflicts were identified and
resolved prior to scoping. Therefore, there were few key issues identified in the scoping process.
These key issues led to only minor changes to the proposed action as scoped and did not warrant a
separate alternative as it would provide very little value in terms of comparison. For that reason, the
EA only analyzed two alternatives for this project: Alternative A (No Action Alternative) and
Alternative B (Action Alternative).
Alternative A — No Action
Under Alternative A, current management plans, such as existing wildlife management, wildfire
suppression, general road maintenance, and special use authorization operations would continue to
guide management of the project area. I did not select this alternative because it would not meet any
of the purposes and needs of the project. This alternative was considered as a baseline for effects.
Public Involvement
The Twelve Mile Project was initiated with a public meeting on July 14, 2016. Several meetings and
field trips were held involving a collaborative group representing various interests and user groups.
These collaborative discussions led to the development of the purpose and need and proposed actions.
This project was first published in the Schedule of Proposed Actions on April 1, 2016. The proposed
actions were available on the public website and interested people were contacted to begin an official
scoping period between May 3 and June 6, 2018. Additionally, a public open house meeting was held
on May 9, 2018 in which adjacent and nearby property owners were invited by mail. This meeting
generated several discussions and one written comment was received. During the official scoping
period, eleven comment letters were received electronically and one hand written comment was
received. A follow up meeting was held to further discuss Haynes Road with adjacent land owners
and environmental organizations on October 26, 2018.
The Comment Period for the Environmental Assessment (EA) was open from• 7/24/2019 — 8/23/2019.
Twenty-six individual comment letters were received during this time. There were no edits to the EA
as a result of comments received:, The Cultural Resources Section of the EA was slightly modified to
include more specific conclusions. Issues/concerns raised during comment period can be found in the
attached comment response section.

I carefully reviewed and weighed all comments received during the development of this project and
used them to guide my decision.
Finding of No Significant Impact
After considering the environmental effects described in the EA, I have determined that these actions
will not have a significant effect on the quality of the human environment considering the context and
intensity of impacts (40 CFR 1508.27). Thus, an environmental impact statement will not be
prepared. I base by finding on the following:
Context
The setting of the project is in an intensively managed area. The resources affected by the proposal
are described in the EA. Alternative B is consistent with the management direction, standards, and
guidelines outlined in the Forest Plan. We identified issues through the scoping process and
considered them in alternative development and analysis. The project area is limited in size and the
activities are limited in duration. Effects are local in nature and not likely to significantly affect
regional or national resources.
Intensity
I have determined the following with regard to the intensity of this project as identified in 40 CFR
1508.27: My finding of no significant environmental effects is not biased by the beneficial effects of
the action. All effects, both beneficial and adverse, are disclosed in the EA, and adhere to standards
and guides of the Forest Plan.
1. There will be no significant effects on public health and safety and implementation will be in
accordance with project design features and OSHA regulations.
2. There will be no significant effects on unique characteristics of the area, because there are no prime
farmlands, wetlands, wild and scenic rivers, or ecologically critical areas in the project area, nor
would it violate local law or requirements imposed for the protection of the environment.
3. The effects on the quality of the human environment are not likely to be highly controversial because
there is no known scientific controversy over the impacts of the project. The IDT has reviewed
references from public comments and have determined that there is no controversial determinations
within the most widely accepted, peer reviewed scientific literature.
4. The Forest Service has considerable experience with the types of activities to be implemented. The
effects are not uncertain, and do not involve unique or unknown risk.
5. The action is not likely to establish a precedent for future actions with significant effects, because the
project is site specific and effects are expected to remain localized and short-term.
6. The cumulative impacts of past, present, and reasonably foreseeable future actions do not add any
significant effects as disclosed in the EA.

7. The action will have no adverse effects on districts, sites, highways, structures, or objects listed in or
eligible for listing in the National Register of Historic Places. The action will also not cause loss or
destruction of significant scientific, cultural, or historical resources. A heritage report was completed
for this project.
8. The action will not adversely affect any endangered or threatened species or critical habitat as
discussed in the EA.
9. The action will not violate Federal, State, or local laws or requirements for the protection of the
environment. Applicable laws and regulations were considered in the EA. The action is consistent
with the Nantahala and Pisgah National Forests Land and Resource Management Plan as ammended.
Findings Required by Other Laws and Regulations
My decision to implement the Selected Alternative, with modifications, is consistent with the intent of the
long-term goals and objectives listed on pages III-1 and 1II-2 of Forest Plan Amendment 5. The project
was designed to Forest Plan objectives and incorporates Forest Plan standards and guidelines. To the best
of my knowledge, my decision is consistent with applicable statutory laws, policies, and regulations
including
• National Forest Management Act (NFMA) and implementing regulations in 36 CFR 219, and 16
U.S.C. 1604
• National Environmental Policy Act of 1969 (NEPA) and Council on Environmental Quality
(CEQ) implementing regulations under 40 CFR 1500-1508
• National Historic Preservation Act (NHPA) and implementing regulations under 36 CFR 800
• Clean Water Act (Federal Water Pollution Control Act) together with implementing regulations
under 40 CFR 130
• Endangered Species Act of 1973, as amended (P.L. 96-159 1531 (0) (ESA) and implementing
regulations pursuant to 50 CFR 402.06 and 40 CFR 1502.25
• Clean Air Act (CAA) and implementing regulations in 40 CFR 50
• Environmental Justice (Executive Order 12898)
• Floodplains and Wetlands (Executive Orders 11988 & 11990)
• Travel Management, Designated Routes and Areas for Motor Vehicle Use Rule 2005 (Travel
Rule)
• Roadless Area Conservation 2001 (Roadless Rule) 36 CFR 294

Implementation Date
This project may be implemented upon signing of the final Decision Memo by the responsible official.
For more information on this project, please contact the project leader, Jason Herron, at 828-689-9694.
S 2 e^ 22 -61
Richard Thornburgh, District RAi ger USFS (Responsible Official)

RESPONSE TO COMMENTS
FOR THE
MILE PROJECT
30-DAY NOTICE & COMMENT PERIOD
Associated Comments: [Seq#2]
We also believe that at least one of the fords in the project area should be updated to a bridge. We strongly
support that idea of a new bridge constructed across Laurel Creek. [24-11]
Response:[Seq#2]
An improved crossing on Laurel Creek is proposed in the action alternative. This will either be in the form of a
bridge or an open bottom culvert that will do away with the ford on an open road and still provide aquatic
organism passage. This action has been proposed but may not have been easy to identify in the EA and may have
been overlooked by the commenter. [ID#2]
Associated Comments: [Seq#3]
While the EA's action alternative will provide an increase in habitat and diversity well above what is currently
within the project area, many of the project actions in the EA were reduced from that proposed in the Scoping
Record. We ask the USFS to reconsider expanding proposed actions, particularly those that relate to fire, field and
meadow creation, and woodland management in order to maximize effort of entry into this rugged area as well as
to further expand more immediate habitat benefits to elk and golden -winged warbler. [20-3]
Response: [Seq#3]
The proposed actions that were removed between scoping and the final action alternative were dropped from
consideration because of key issues. These issues were largely problems of feasibility and implementation and
therefore should not be added back into the project proposal since they cannot be accomplished. To a lesser
degree, a couple of units were dropped from consideration due to a conflict in desired objectives. In this case, field
trips were scheduled to discuss as a collaborative group. This resulted in reaching a compromise that was generally
acceptable to all those chose to be a part of those discussions. [ID#3]
Associated Comments: [Seq#4]
We want to emphasize that we consider the woodland site on the northern 2/3rds of Brushy Ridge in
Compartments 476 and 477 to be existing old -growth. This section of the ridge is very remote. We request that no
road or skid trail be built into this section of the woodland and that only midstory and understory trees be cut, and
that the treatment be completed by slashing and leaving the trees, rather than removing them. [24-7]
Response: [Seq#4]
This issue was brought up during scoping and this unit was completely dropped from consideration in the Action
Alternative. It was determined after a few field trips with collaborative partners that the benefit of doing any work
in that stand was likely not worth the potential undesirable effects. The commenter may have not recognized that
this unit had been dropped in the action alternative. [ID#4]
Associated Comments: [Seq#S]
The low water bridge on Forest Service Road 288 across the Pigeon River needs improving. There either needs to
be a bridge constructed that is out of the flood zone of the river, or an emergency foot bridge above the flood
zone. Floods on the Pigeon River have stranded residents and visitors along Forest Service Road 288 over the
years. Some deaths have even occurred when people have attempted to drive across the flood waters there. A

new bridge or an emergency foot bridge could go a long way towards enhancing public safety in this area. Even if
there are no current funds for improving the river crossing, these actions should be analyzed and improved in the
event that the Forest Service, NC DOT, or another entity could provide funding for a new bridge. [24-10]
Response:[Seq#S]
A transportation improvements of this magnitude are outside the scope of this project. [ID#5]
Associated Comments: [Seq#6]
Creating the young forest habitat, characterized by high woody stem density, identified as a need is more difficult
to maintain on the landscape due to the dynamic nature of succession. The first few years following harvest they
fill a much different habitat niche than that of the next 15 years. Allowing for the adaptive'management approach
throughout the life of this project enables periodic evaluation of the development of these stands and their
contribution to overall biodiversity. Based on the monitoring, decisions could then be made to advance the stand
to maturity with tending or reinitiate the regeneration process for greater wildlife benefit. [21-6]
Response:[Seq#6]
While an adaptive management approach is an intriguing idea, and one that the Forest Service pondered to some
degree for this project, the approach to enter the area on a rotational basis to re -analyze the landscape and make
future decisions at that time remains the least complicated method for several reasons. Some of those reasons
are: 1) After 15 years, NEPA decisions would likely need to be reviewed and likely altered due to law/policy
changes, additional listed Threatened/Endangered/Sensitive species, updated master agreements for preservation
of historic places, tribal relations, and so on which makes adaptive management decisions that are expected
beyond 15 years quite problematic, 2) new surveys may be needed or required, 3) ecological and social priorities
can shift within that time period, 4) it very well may take 10 or more years to implement all the action items in this
decision, and 5) it is difficult to make stand level decisions such as those discussed in the comment without looking
at a larger landscape anyway and therefore does not present a savings of time and effort.
For these reasons we did not approach this project with an adaptive management decision in mind. As future
project are developed, the Forest Service would like to discuss this as a possibility if it will result in more efficient
management that meets project objectives. [ID#6]
Associated Comments: [Seq#7]
Rare bigtoothed aspen are found in the area and the bigtoothed aspen population should be increased and
expanded. Bigtoothed aspen is a great wildlife tree and needs open areas to reproduce and survive. [9-2]
Response:[Seq#7]
The Forest Service is aware of the presence of big -tooth aspen (Populus grandidentata) within some stands in the
project area. This is the southernmost part of the natural range for this species and it only occurs in small pockets
in this area. The Forest Service recognizes this as an important species component within the stand and intends to
maintain and possibly expand the presence of big -tooth aspen where feasible. This would be incorporated into the
detailed long term silviculture prescriptions prior to implementation of proposed treatments.
Associated Comments: [Seq#8]
A project- and forest -wide concern noted is the potential and real threat that invasive exotic plants pose to forest
health and diversity. The Empress Tree, Paulownia tomentosa, is one example of exotics that proliferate rapidly in
sunny conditions. Since these and other exotics are extremely abundant along the Interstate 40 corridor, it is
critical that the USFS have proper resources available to deal with invasive species. [23-4]
Response: [Seq#8]
The Forest Service is aware of the current and potential issues associated with non-native invasive plant species

(NNIS). In some cases, special attention will be given to NNIS such as Paulownia tomentosa, which has been
mapped and intended to be treated. Priority will be given to the project area prior to implementation for
treatment of NNIS of concern to reduce the threat of spread using funding available for NNIS reduction. Stands
with commercial harvest treatments will be treated before and/or after harvest and monitored/treated for three
to five years using money generated by the commercial harvest. If woody NNIS are still present within the stand
10-15 years post -harvest, they will be treated again when the stand is released or weeded. [ID#8]
Associated Comments: [Seq#9]
Utilizing NRV as a guide is acceptable but do not negate the need for ground truthing and the knowledge of USFS
silviculturists, wildlife biologists and ecologists in determining where and what disturbance activities are logistically
feasible. NRV documentation does not permit the evaluation of new environmental roadblocks to management
including but not limited to non-native and invasive vegetation and, integrated pest management concerns having
negative impacts on stand response and forest resiliency. [21-1]
We would like to commend the Appalachian Ranger District on being the first district in North Carolina to use
ecozones and ecological departure analysis to inform project goals. We believe that vegetative management can
be greatly improved by tailoring prescriptions to specific site conditions and the ecosystems in which they occur.
We likewise support prioritizing management activities in the most departed ecozones, which is why we have
some concerns with the approach taken in this project. We caution that the biophysical setting models that the
departure analysis is based on are little more than a bundle of assumptions - albeit assumptions by knowledgeable
experts - run through a complex model. It is also critical to acknowledge that ecozones are also models that, at
best, approximate reality. We believe that these models are valuable in providing a direction for the emphasis of
management, but not accurate or precise enough to be prescriptive. Caveat emptor. The scoping has analyzed the
age class and structure distributions of all ecozones, but the only source of age class information is the FS VEG
database, which only counts timber harvest as a source of young forest, or the early s-class. This leads to a
complete lack of accounting of the contributions of natural disturbances or disturbances on private land to
creating early s-class or open conditions in the project area. A similar issue is in the seeming interpretation that
only large disturbancesgreater than several acres in size qualify as part of the early s-class. This is despite
abundant scientific information that the most common type of disturbance that leads to tree regeneration in cove
forests is single or multiple tree -fall gaps less than an acre in size (Lorimer 1980, Runkle 1982). We therefore
question how great the need is for creating the early s-class in cove forest ecozones really is, and whether the
uneven age management techniques might also be producing acreage of early s-class. These are important
questions to address as the use of Ecozones and departure analysis are refined in forming project goals. All of that
being said, we acknowledge that advances in knowledge and management come incrementally, and we see the
use of complex analysis done in this project, and for the entire forest during plan revision, as a step forward for
ecosystem management. [24-3]
Response:[Seq#9]
Natural Range of Variation (NRV) modeling and departure analysis was used in the assessment of the project area.
The Forest Service does not consider this modeling and departure analysis to be prescriptive and it was not used to
make site specific proposed actions. Rather, this assessment was used to provide higher level understanding of the
project area to determine needs and priorities. Forest Service employees, contractors, and partner groups
conducted extensive surveys and data collection used to develop the Action Alternative. Furthermore, site specific
silviculture prescriptions are required for all forest management actions and can only be approved/signed by a
certified agency silviculurist. These prescriptions will be developed based on actual conditions on the ground.
For this project, a project level departure analysis was completed to assess the needs and priorities specific to the
project area. The current conditions were based on actual vegetation data collected at the stand level in 2016
(approximately 75% of the project area) or data imputed from the collected data to cover the remaining —25% of
the project area. This is actual data of the current conditions and does not have any connection to whether or not
it is the result of timber harvesting or natural disturbance. Private lands do not contribute to the desired
conditions or objectives of the National Forests Lands and therefore were not included in the analysis.

While this project level departure analysis was beneficial in determining needs and priorities for this project, it was
also discovered that project area departure analysis has problems of scale and may not necessarily be the method
used for future projects. For example, this project area contains a large portions of Management Areas that are
suitable for timber harvest and that is largely what was included in the departure analysis. Adjacent Management
Areas that are largely not suitable for timber harvest, such as back country, were not included in the analysis area
and this can skew the outputs of the existing condition as compared to the desired condition. Future projects may
utilize departure analysis at the Geographic Area scale to help determine project area goals and priorities.
The Forest Service agrees that small openings such as single/multiple tree fall gaps are disturbance patterns that
lead to gap phase stand dynamics. However, it is difficult to impossible to analyze and manage a large landscape at
less than an acre scale. The National Forests of North Carolina defines a stand as a minimum of five acres and that
was used in the analysis of this project area. Small gap openings were not incorporated into the overall acreage of
existing young forests and therefore were not represented in the analysis. That being said, stands can still be
managed, or not managed, in many different ways to meet many different objectives, including uneven -aged
management. Recognizing the importance of the gap phase disturbance pattern, opportunities for uneven -aged
management were identified where possible. Uneven -aged management was somewhat limited in this project
area due to topography and access issues. In the Environmental Analysis, stands proposed for uneven -aged
management were considered to continue to be_in their current s-class after treatment in terms of NRV departure.
Specifically, these stands were not considered to be changed to young forest (early s-class) after treatment nor did
the small openings contribute to overall young forest acres. These were also not considered to be changed to open
forest conditions because the overall canopy closure would still be greater than 60%. Since there is not an uneven -
aged s-class in the NRV model, it is difficult to show a condition change associated with uneven -aged harvest
methods within the departure analysis at the stand scale. However, the condition class change associated with the
proposed uneven -aged harvest method is disclosed in other ways in the Environmental Analysis.
The proposed action is consistent with the goals and objectives of the current Nantahala and Pisgah Land and
Resource Management Plan that aims to create young forest habitat that is not realized at scales less than the
minimum stands size of 5 acres. While this project did attempt to incorporate ecological departure concepts being
developed for Forest Plan Revision, comments targeted specifically towards Forest Plan Revision efforts are
outside the scope of this project.
Associated Comments: [Seq#10]
The above concept becomes more important in the described emphasis on establishing oak regeneration. Getting
advanced oak regeneration established can be difficult and a resource suck. Having multiple tools available to the
silviculturist and giving them the ability to determine the best sites to invest for the greatest return on the desired
outcome is essential, and again adaptive management. Treating off -site white pine stands for most likely
conversion back to oak dominated through the introduction of fire and canopy manipulation meets 2 of the
identified needs. The need to promote oak species and the need to manage white pine dominated stands towards
more appropriate dominant species are both addressed in the use of prescribed fire included in a deferment or
traditional shelterwood system. [21-7]
Response:[Seq#10]
While this is not necessarily an adaptive management decision, it was intended to give silviculturists as much ---
flexibility as possible to fine tune prescriptions while also being specific enough for detailed environmental analysis
and biological evaluation/assessment.
The built in flexibility should allow for the needed tools to support oak regeneration when needed in both the two -
aged and uneven -aged regeneration proposals. See pages 31-33 of the Environmental Analysis for full descriptions
of these proposed actions. Both allow for multi -entry oak shelterwood treatments and follow up stand
improvement such as herbicide release treatments and non-commercial thinning. [ID#10]

Associated Comments: [Seq#11]
I bought a Jeep and did a couple of modifications to it so I could get off road and explore some of the trails here in
Western NC, but it seems that a lot of the trails are closing for one reason or another and not opening back up. I
am not able to walk long distances not able to ride bicycles like I use to. Please don't take away a Hurricane Creek
Trail (Haynes Rd) from us that are not otherwise able to access the area. It is about the only way that I can show
my kids and grandkids the beauty that is our home. [16-1]
Response: [Seq#11]
The proposed action for Haynes road includes a seasonal closure between the end of December and early April to
prevent the damage to the road and erosion and sedimentation into Hurricane creek that occurs at a greater
extent during those months of freeze -thaw cycles. This proposed seasonal closure will not interfere with hunting
and fishing seasons and will still allow for public access the majority of the year while significantly reducing
damage and maintenance needs. [ID#11]
Associated Comments: [Seq#12]
1. Generally concerned on all roads that the proposed seasonal closures would result in gates being closed longer
than the proposed season and may ultimately lead to permanent closure of the roads. 2. Comment to be sure that
proposed seasonal closure on Long Arm Road (FSR 287) does not affect primary access to her private property
inholding. 3. Generally opposed to the closure of Sutton Road (FSR 3537) between Sutton Tower and her private
property inholding. Emphasizes the need for secondary access for emergencies (fire, down trees, medical
emergencies, etc.). 4. Comment to make sure that proposed season closure on the Goat Road (FSR 289) does not
affect access for private land owners. 5. Generally opposed to the proposed seasonal closure on the Goat Road
(FSR 289). 6. Comment to maintain public access on Long Arm Road (FSR 287) through Mount Sterling Gap. 7.
Comment that the low water crossing of the Pigeon River Needs on FSR 288 needs to be replaced to improve
safety. [27-1]
Response: [Seq#12]
1. Gates would only be closed seasonally as specified in the action alternative.
2. Seasonal closure on Long Arm Road would not affect primary access to private property.
3. The Forest Service does not provide secondary access to private land and only provides primary access when no
other option is available.
4. Seasonal closure on the Goat Road will not affect primary access to private land
5. Position statement, no response needed
6.On Forest Service Lands, the forest Service is only proposing a seasonal closure on the upper portion of Long
Arm Road between the end of December and early April to reduce damage to the road during freeze -thaw cycles.
Connection to state road 1397at Mount Sterling Gap crosses Great Smoky Mountains National Park and would be
under their authority to open or close.
7. The issues associated with this low water bridge have been voiced from several partner groups and individual
forest users, as well as internally from within the agency. The Forest Service considered the idea of replacing the
low water crossing with a bridge and Forest Engineers looked into the possibility. The unfortunate conclusion is
that a bridge cannot be constructed in that location without a considerable undertaking and budget. The design
work alone could not be funded within this project and therefore was not considered as a proposed action at this
time.
Associated Comments: [Seq#13]
The disturbed trails being returned to their current status [18-6]

Response: [Seq#13]
As disclosed in the Environmental Assessment, system trails disturbed by commercial timber harvest would be
returned to their current condition prior to timber harvest and will be a requirement in -timber sale contracts.
[ID#13]
Associated Comments: [Seq#14]
The time frame for the project completion as it relates to recreational opportunities [18-7]
Response: [Seq#14]
It is disclosed in the Environmental Assessment that it is likely that commercial timber harvest will disrupt
recreational opportunities at the Harmon Den Horse Camp and nearby trails. It was considered to restrict timber
harvest to the winter months to decrease the effects to recreational opportunities. However, impacts to soils from
logging during winter months are greater and often prohibitive of operating during these times. Therefore, logging
was not restricted to the recreational off-season and effects to recreational opportunities were disclosed. It is
likely that the camping area and trails will need to be closed during the recreational seasons to complete a couple
of the commercial logging units. This effect to recreation will be limited as much as possible. [ID#14]
Associated Comments: [Seq#15]
Woodlands, wildlife fields, and stand improvements are all planned for a tract purchased since the 1994
Amendment was signed in stands 44, 45, 46, 48, & 49. While we support these activities, the processes and laws
that govern National Forests should be followed, even for broadly supported actions. The National Forest
Management Act requires that all National Forests and Grasslands have a Management Plan that assigns
management direction to Forest Service land. No management area has been assigned to these tracts, so these
actions are out of compliance with the National Forest Management Act. We suggest this oversight be remedied.
[24-2]
Response: [Seq#15]
Comment is correct that a Management Area direction was not assigned to this acquired land through a Forest
Plan Amendment. To remedy this situation, a phased decision will remove the actions associated with the acquired
land until management area direction has been applied through a Forest Plan amendment. [ID#15]
Associated Comments: [Seq#16]
Identifying isolated pockets of OG should be part of the landscape configuration of an un-even aged silviculture
system. The goal of the project should be to achieve an un-even aged structure not simply within stands but across
the project area comprised of individual stands of multiple age and structural variation. The proposed
management should provide this landscape complexity and connectivity contributing to the benefit of the native
flora and fauna. [21-2]
Connectivity of older tracts of forest is equally important as connectivity of the younger aged forested habitat.
Keeping this in mind during the implementation stages and being creative in road daylighting, staging area location
and the decommissioning of roads may provide the desired travel corridors. [21-3]
Response: [Seq#16]
Small patch Old Growth was designated in compliance with current Forest Plan Standards which was intended to
provide connectivity between medium and large patch Old Growth designations. Furthermore, at the stand level,
detailed silvicultural prescriptions can identify, protect and enhance old growth characteristics and promote
structural complexity within stands proposed for uneven -aged management, thinning, woodland management
and, to a more limited degree, two -aged regeneration harvest. [ID#16]

Associated Comments: [Seq#17]
The resulting project, if implemented, will not nearly produce the mosaic of ESH that science tells us produces a
healthy forest landscape for wildlife and a healthy forest age mixture. [8-2]
We are deeply concerned that we are not meeting anything close to forest plan requirements for early
successional habitat. [17-2]
Response:[Seq#17]
The action alternative meets Forest Plan Objectives for creating 0-10 year age classes in all compartments except
two. Compartments 0457 and 0464 are not meeting minimum 0-10 objectives due to access and feasibility issues.
Several compartments are planned more toward the upper end of the desired range, see Table 50 in the
Environmental Analysis.
There is no referenced "science" in this comment in which to respond to specifically. [ID#17]
Associated Comments: [Seq#18]
What is most lacking within the project area and most difficult to maintain is the young regenerating forest
structure and early successional habitat structure. Determining where and how these deficits are addressed should
be based on current health and composition of existing mature stands. The lesser quality stands in terms of timber
should be the focus of creating habitat diversity through mechanical harvest in stand initiation. This provides the
structure for some species but a more shrubby static habitat is recommended for GWWAs. If this type of structure
is not currently present within the project area, supplemental plantings and vegetative treatments may be
required. The proposed wildlife openings and staging areas would be logical areas to promote native shrub growth
to provide the necessary structure for GWWAs. These areas could also be an emphasis for pollinators. [21-4]
Response: [Seq#18]
The creation of young forest structure and early successional habitat structure are both proposed in this project.
Stands were proposed for regeneration harvest for a variety of reasons not concerned with the quality of timber.
The stands that were proposed specifically for golden -winged warbler (GWW) will be designed to have the
open/brushy habitat suitable for this species. Also contained within this action alternative is the ability to create
GWW habitat structure at log landings and around proposed fields within the GWW focal areas. This comment is a
general statement and does not appear to contain issues specific to the action alternative or assessment. [ID#18]
Associated Comments: [Seq#19]
In managing for a target species of songbird the concept of patch swapping needs to be incorporated in the layout
and location of disturbance. Some species nest in younger stands and post -fledging travel in older stands while the
reverse is true for some nesting in mature forest stands. [21-5]
Response: [Seq#19]
The Action Alternative creates a mosaic of habitat types across the landscape. This comment is a general
statement and does not display a specific issue or concern related to the design or locations of the current Action
Alternative. [ID#19]
Associated Comments: [Seq#20]
My only suggestion is that the insect populations which are so important for soil health are considered. When the
downed trees are removed and no logs are left to decompose many beneficial insects will be affected. In nature
when trees fall the remains are populated by hundreds if not thousands of insect species who rely on downed tree
parts for habitat and food. As they break down the tree parts they enrich the soil for future growth. Without this
process, the insects and soil health is affected, and this is something that affects the health of the forest as a
whole. Please consider this fact when clearing the forest floor and downed trees. [13-2]

Response: [Seq#20]
A biological evaluation of how a project may affect any species federally listed as threatened, endangered, or
proposed, or identified by the Forest Service as sensitive is done as part of the site -specific environmental analysis.
This evaluation considers available information on threatened, endangered, proposed, and sensitive species
populations and their habitat for the proposed treatment areas as necessary to comply with the Endangered
Species Act and Forest Service Manual 2670.
In addition, the North Carolina Natural Heritage Program tracks occurrences of rare species across the state,
including those that are not federally or regionally listed, but may be of some conservation concern. Many of these
are addressed as forest concern species during project planning. While there is no legal requirement to address
forest concern species, they are part of the relevant ecosystems and disclosing potential effects strengthens the
credibility of the analysis.
Consistent with the Forest Plan and its associated FEIS (Volumes I and II), the effects analysis also focuses on
changes to management indicator species (MIH) and their habitats to help indicate project effects on fish and
wildlife resources. Each MIH represents a biological community or habitat component. Thus, project effects to MIH
represent effects to a wide array of populations and habitats.
For hardwood sawtimber trees the tops or "laps" are usually bucked off at 9" but often larger than that due to
forks, etc. This material is left on -site, most often where the tree falls. White pine plantations tend to have less
debris left on site because more of the stem is utilized. Hardwood stands have a significant amount of debris left
behind. Existing dead and down logs are usually left on site, and most of these stands have plenty of that since
they are about 100 years old and have been hit by numerous insects and diseases over the years. Standing dead
trees are often left on site when they don't pose a safety hazard. This provides an increase in available debris for
insects for the following decade or so then diminish back to near pre -harvest levels where leaf fall would be the
biggest contributor of organic matter. [ID#20]
Associated Comments: [Seq#21]
While I'm generally in support of this project, I have a specific concern relating to the area immediately adjacent to
the waterfall on Little Fall Creek near the horse camp: The maps seem to suggest Regeneration Harvest logging will
occur around or just north of the waterfall, along the path people are using to access the falls. Please reconsider
this, as this little waterfall is a beautiful gem in a part of the mountains where not many of them are found. Please
at least consider leaving the forest immediately adjacent to the falls intact, perhaps a bit more than the usual
streamside buffer, if the area to be cut is to include the falls. While a clearcut may prove ideal for wildlife, it's not
easy for people to traverse them with the resulting weeds, briars, small trees, and slash blocking the forest floor
after a clearcut occurs. Please consider adding an official trail up to the falls whether or not the logging occurs, or
at the very least leaving a route to the falls semi -clear of slash and debris after operations are complete, and
paying special attention to invasive species in this area. Again, I'm generally in support of this project. I know this
seems like a small concern, but this is a special, scenic spot in the Pisgah National Forest and I know many would
agree with me. I've included a map assembled from the ones on the project site with the approximate location of
the waterfall marked. [19-1]
Response: [Seq#21]
At this level of planning, the size/shape of proposed treatments are often much larger than they will be when
implemented. This is to ensure that we have thoroughly surveyed and analyzed the area in an attempt to not
restrict the options for implementation layout. Also on this project, the required riparian buffers (generally 100
feet each side of a perennial stream when not specifically mapped by an interdisciplinary team) were not displayed
in the shape of the unit polygon either.
The proposed harvest unit in this comment (stand 0452-12) will be significantly reduced on the eastern portion of
the unit due to the required riparian buffers. The actual harvest will not extend past Little Fall Branch and there
will be a buffer along that stream as well. In addition to the required riparian buffer, pre -harvest foresters have

already flagged an additional buffer (Approximately 400 feet) to protect the aesthetic quality of the waterfall.
[I D#21]
The following comments do not require response as they are position statements, already addressed in the EA,
or beyond the scope of the project:
Associated Comments: [Seq#1]
Thank you for this opportunity to comment on this project. The FWCC fully supports this project for the much
needed benefits for wildlife and forest health. We fully support the need for young forest growth please keep the
total acreage as close to project plan as final will be. We are at critical times in this project area for elk, grouse and
a few other animals. We would support any in all efforts to move forward as quickly as possible. Please let us know
if we can be of further help. [1-1]
I fully support the measures suggested in the Twelve Mile Project letter. Such measures will provide critically
needed habitat for our still fragile but expanding elk herd as well as other game species such as ruffed grouse that
are disappearing from our forests due to absence of its needed habitat of young forest. Many non -game species
will also be benefited including the golden wing warbler. For far too long now forest management has been
essentially nonexistent and our wildlife has been negatively impacted. Results will prove beneficial to wildlife,
forest health and stream health. [2-1]
This project appears to be well thought out with input from many sources and I think it should go forward and be
approved. [3-1]
I believe the Twelve Mile Project is a very worthwhile and necessary project. The growth of the transplanted elk
herd in the Great Smoky Mountains NP is quite remarkable, but has plateaued due to lack of habitat outside the
park boundaries. The forests have become so dense, that there is very little grazing areas, and deer populations in
the mountains are extremely low as compared to the Piedmont and coastal areas. Balds used to exist all over the
Southern Appalachians and were kept free of trees and dense shrubs by the grazing deer, elk, and bison. When
these herds were extirpated hundreds of years ago by over hunting, the balds closed up making a natural
comeback of these grazing species impossible. A project like the Twelve Mile Project is not creating new
experimental habitat, but rather replacing an invasive habitat that is, for all intents and purposes, sterile with
regard to native wildlife, and returning it to the way it originally was over 200 years ago. Restoration of this original
forest habitat will allow the elk and deer to expand their herds outside of their current area of GSMNP. If this
project is successful, this concept could be expanded throughout the Pisgah and Nantahala forests and return elk
to the western NC mountains. Who knows, once the habitat is re-established, will the bison be the next to return?
[4-1]
It's about time that the forests are managed! We are losing grouse, songs birds deer etc. The canopy of the trees
is so thick that there is not much growing below to sustain much life. Where I live in Haywood County there were
tons of deer etc. now it's a rarity to see one. I love trees but we have to manage our forests. We need to use our
brains not our hearts to improve our forests. [5-1]
Please proceed as planned. You are charged with managing the nation's forests not political opinion. [6-1]
fully support the plan to harvest timber AND implement prescribed fire in Pisgah National Forest. This would be a
benefit to the ecology of the region, to the flora and fauna, and to those of us who love and use these lands.
Please press forward with the plan as it is currently, and please continue with your other programs that help
educate people on the benefits of disturbing and resetting successional forest growth. I support this plan
because of my desire to see increased numbers of ruffed grouse for hunting, my desire to see a larger elk heard in
the Appalachians, my support of clean native trout habitat in our creeks and rivers, and my support of public
access to public lands by ALL of the public. Thank you for the opportunity to comment and support. [7-1]

while I support the project, I am disappointed that more early succession (young regenerating forests) habitat
(ESH) wasn't proposed given the size of the analysis area. [8-1]
Having said that, SOMETHING IS BETTER THAN NOTHING! DO IT! 11 [8-3]
1 support the 12 Mile Project. It would create warbler habitat, elk habitat and grouse habitat [9-1]
Please go forward with the planned project burning and logging. [9-4]
This area needs to be logged. I grew up in the area and there were plenty of deer, grouse, and turkey. in the last
years numbers of all have dropped off due to not having sufficient plant life and forest of all ages. [10-1]
I strongly oppose any timber management for the sole purpose of revenue generation. Any land management
should be performed to maintain a healthy and productive forest. [11-1]
I support the proposed actions for the Twelve Mile Project #48776. 1 support creating early successional habIta5
for elk and songbirds. Please go ahead with the proposed actions. [12-1]
1 truly appreciate that this project allows for public input. While the scope of this project sounds large, I feel like
the obvious attention to sustainability and the needs of the species living within the area have been well
considered.
1 am in favor of this project. As an outdoorsman in Haywood this would be very beneficial. [14-1]
1 am writing in support of the Action Altern ' ative proposed in the Twelve Mile EA. This project is an excellent
example of the Forest Service engaging partners to seek collaborative solutions for resource problems and
habitat for multiple priority wildlife species across a range of forest conditions and elevations. The analysis of
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We support this project and would recommend that the final action selected would be the one that creates the
most 0 - 10 year age class, using environmentally sound timber management practices. [17-1]
We feel that for sustained health, our forests need much more diversity in age class and would recommend the
preferred alternative be selected that would create the most age class diversity in a mosaic across the analysis
area.[17-3]
We feel this diversity of forest age class and structure will help maintain healthy forests that are more resilient to
forest pests and changing climate. [17-4]
The lack of law enforcement in the Harmon Den/Twelve Mile area [18-1]
The safety of the people and their personal property [18-21
Vehicle speed [18-3]
The lack of sanitation facilities [18-4]

The amount of trash that will be thrown out [18-5]
Over the past several years our organization has worked closely with the Forest Service to maintain the
recreational facilities in the Harmon Den area. We look forward to maintaining that positive relationship in the
future.[18-8]
NCWRC supports the EA's action alternative, which proposes to improve 14 stream crossings, enhance 0.7 mile of
stream, install a kiosk, create 136 acres of permanent wildlife fields, treat 1,342 acres with prescribed burning,
designate 1,570 acres as small patch old growth, perform stand improvements on 649 acres, thin 327 acres,
manage 1,027 acres with two -aged regeneration harvest, treat 329 acres with uneven -aged management, and
perform woodland management on 498 acres. New road will be constructed, with 8 mi of road on existing
corridors and 0.7 mi of road on a new template; almost all of these new roads will be closed to the public.
Numerous existing roads will be changed from open year-round to open seasonally to reduce road damage and
stream sedimentation, and daylighting will be performed on some roads to reduce road damage and/or create
wildlife habitat. [20-1]
The action alternative will create habitat and establish connectivity among suitable habitats for North Carolina's
elk herd. The creation of early successional habitat (ESH), wildlife openings, and woodland are essential elements
of this project that will benefit elk, golden -winged warbler, and other wildlife species. In our June 2018 scoping
comments, NCWRC provided specific recommendations to expand proposed woodland, ESH, and wildlife opening
prescriptions in order to maximize benefits to elk. [20-2]
We support the emphasis on watershed improvements, particularly the replacement of problematic culverts,
including those that will allow for aquatic organism passage, stream enhancement on Cold Springs Creek and Fall
Branch, riparian restoration and large woody debris enhancement, and changes to the transportation network that
will address erosion within the road system. [20-4]
This proposed project is supported by RGS. We look forward to future involvement and hope that the freedom to
alter treatments based on vegetative response or within stand limiting factors remains open to the USFS
personnel. Feel free to contact me for further discussion on the above comments. [21-8]
I am extremely concerned about the proposed rule amending the Forest Service's National Environmental Policy
Act. It is my understanding that this rule would eliminate the public review process for most timber projects in our
national forests. The information that I have read states that this would be done in order to allow for speeding up
the "pace and scale of work accomplished on the ground". It is also my understanding that -- if the new rule goes
into effect -- up to 75% of decisions that now require public input could proceed under categorical exclusions --
meaning that they will not require environmental assessments and will not solicit public comment -- on
commercial logging of up to 4200 acres. Our National Forests belong to the public. Furthermore, they are a
national treasure and a "buffer" against the increased levels of CO2 in our atmosphere that are contributing to
excess global warming. They should never be compromised for the sake of monetary gain. Any decisions made to
do logging on these public lands must be done with full public knowledge and must include studies to determine
the environmental impacts of any proposed cutting of timber. The Forest Service needs to reject this proposed
rule and focus on standardizing the best practices they have learned through processes like the ones used for the
Twelve Mile Project in Western North Carolina. Following these best practices would mean including MORE front-
end public involvement, not LESS!!! As an informed citizen who cares deeply about our natural environment -- a
gift to us that no amount of money will repair should our society destroy it in pursuit of financial gain -- to protect
this national treasure entrusted to your stewardship so that our children and grandchildren will be able to benefit
from it for many decades to come!! Sincerely, [22-1]
NCWF believes the proposed plan is an exemplary example of what a collaborative approach to forest
management planning can achieve. If selected, Alternative B would provide a wide range of benefits to wildlife
species including elk, ruffed grouse, and golden -winged warbler among others. Early successional species will

benefit from increased forest openings and aquatic organisms will benefit from improved passage due to
replacement of inadequate culverts and improvements to stream fords. [23-1]
Elk have long been a conservation priority for NCWF as an iconic species and positive reintroduction story in North
Carolina. Growth of the state's elk population began in 2001-2002 when 52 elk were reintroduced to western
North Carolina. Despite slow expansion of the original herd to its current numbers, habitat improvements such as
those outlined in the 12 Mile Project plan could positively impact elk population numbers, specifically increased
forest openings, burning, and forest thinning practices. We commend USFS for taking steps to manage forest areas
that may benefit wildlife species such as elk. As chronic wasting disease (CWD) continues to pose a risk to cervids
across the U.S. and due to the fact elk are no longer able to be moved to support restoration efforts, it's prudent
we work to enhance and expand elk habitat in our state to maximize population numbers and the health of this
species. [23-2]
Implementation of the plan across portions of the 18,000-acre analysis area will increase the amount of young
forests in the 0 to 10 year age class. It will thin overstocked forest, designate small patch old growth areas, create
wildlife openings, promote shortleaf pine on appropriate sites, replace planted white pine stands with more site -
appropriate tree species, promote oak regeneration, create golden -winged warbler habitat, initiate increased fire
management, remove inadequate culverts and replace them with better designed culverts that allow for passage
of aquatic organisms up and down streams. Further, the plan calls for active stream restoration in Cold Springs
Creek and Falls Branch that will improve water quality as well as aquatic and riparian habitat. The Twelve Mile
Project calls for the designation of 1,570 acres of small patch old growth to provide connectivity between medium
and large patch old growth forest stands. Timber harvests will promote young tree stands on 1,356 acres
promoting increased forest structural diversity, improving wildlife habitat and fostering oak regeneration .The
project will employ prescribed fire across 1,342 acres to promote fire -adapted plant communities and open forest
conditions. In younger forest stands, competing vegetation will be removed from 649 acres to promote forest
stand health. Forest canopies will be opened on 498 acres to provide for grassy understory and an additional 327
acres of forest will be thinned to improve growth. Openings will be created or maintained on 136 acres to provide
wildlife feeding areas. Fourteen stream crossings will be improved to restore passage for aquatic organisms where
roads cross streams. Aquatic habitat diversity will be improved by enhancing more than a half mile of streams and
stabilizing stream banks to prevent erosion. In addition, inadequate culverts will be replaced and in areas where
aquatic organism movement is prevented, new habitat friendly designs will be employed. NCWF supports all of
these planned actions described in Alternative B of the Twelve Mile Project. [23-3]
We believe the Twelve Mile Project sets the standard for collaborative project design. Because of this, the
Appalachian Ranger District deserves praise. If all projects listened and responded to the information that was
gathered from stakeholders to the extent that the Twelve Mile Project has, the Forest Service would be much
more successful in meeting its mission. That said, nothing in this world is perfect, and there are still a couple of
areas this project could be improved. We offer the following comments with the hope they are constructive. Some
comments are identical to those in our scoping comments and are restated here for emphasis. [24-1]
The Haynes Road, which follows Hurricane Creek for over seven miles and includes at least 5 fords of the main
stem and tributaries, is a significant and chronic source of sediment pollution that is harming the ecology and
fishery of Hurricane Creek. We strongly support the plan for increased maintenance and seasonal closure of the
worst parts of the road. If those measures are not enough to improve the water quality of Hurricane Creek,
alternatives strategies should also be on the table. [24-4] -
We strongly support the proposed stream stabilization measures and aquatic connectivity restoration. We are also
in favor of continued native brook trout reintroduction in the project area [24-5]
A decrease in the frequency and magnitude of fires has been one of the biggest changes our ecosystems have
endured in the past century. The best available science indicates that many of our ecosystems depend on periodic
fire for their maintenance. Additionally, a reduction or exclusion or fire from our forests has decreased the amount

of open canopy woodlands. For those reasons, we generally support the proposals to create and maintain
woodlands through tree cutting and prescribed fire. [24-6]
The designation of small, medium, and large old -growth patches was one of the key innovations of the 1994 Forest
Plan Amendment. During many projects, these designations are made out of convenience, or rather, the
inconvenience of access to stands, and little thought is given to the current condition of the stands. The Twelve
Mile Project proposal does a better job of identifying and designating stands that are existing old -growth than any
other project we have seen. We commend the Appalachian Ranger District on this approach, which goes a long
way towards giving us a favorable impression of the project. [24-8]
One of the major drivers of the Twelve Mile Project is the presence of elk in the project area. We are enthusiastic
about the restoration of elk to Western North Carolina. We believe that elk could play a beneficial role in
maintaining grassy balds, bogs, woodlands, and other open areas in the region. We are also supportive of the
management of habitat for golden winged warbler in this project area. As long as habitat creation and
maintenance for these species does not negatively impact other rare species, water quality, or introduce non-
native invasives, we are generally supportive. [24-9]
The Twelve Mile Project is the largest single timber management project we are aware of in the history of Pisgah
National Forest. In our opinion, the Twelve Mile Project is proof of the concept that timber harvest above the
current level is compatible with old -growth forests, special biological areas, and backcountry management in the
new forest plan. The special character of Pisgah National Forest can be maintained without sacrificing it on the .
altar of early successional habitat. There is room on the Nantahala-Pisgah for young forest and old forest, timber
harvest and nature preserves, mountain bikes and equestrians. We sincerely hope that the Twelve Mile Project is a
sign of more collaborative forest management across Nantahala and Pisgah National Forest, and we will continue
to offer the support and expertise of MountainTrue to make that a reality. [24-12]
Just finished reading in the'Citizen Times' Asheville "Pisgah Timber Sale" "Twelve Mile Project" landscape
improvement. "Bloomberg News" reported big time on California fires. If my memory serves me, it stated that the
great western state has been doing the same type project that is now propOosed for here. This sounds more like a
project to give a lot of people that are already over paid and underworked something to do. If "GOD" wanted all of
his property destroyed HE would have already done it. Nobody benefits except all of the people involved Leave
Everything Alone. IT will be just fine as is! I'm sure you will be run over with comments very similar to mine. [25-1]
Twelve Mile, like all other USFS lands, should be managed for the "greatest good" - both for man and beast.
Harmon Den has tons of existing road infrastructure in place, with a high need for creature habitat that encourages
large ungulates to stay in the forest, rather than cross 1-40. With the Great Smoky National Park so close by, those
500,000 acres are limited in terms of habitat creation. However, the USFS is poised to create open meadows to
support the growing herds, and establish younger forest stands to balance the scales against an aging forest. Many
USFS models project the Pisgah and Nantahala Forests to be 80% standing at 71 years and older at the present
time -- these forests need a more diverse age class distribution, with better structure, composition and overall
forest health and FAST! Our renewable resources, in terms of timber, can shift from the "asset column" to a
"liability" quite quickly and we need pro -active, productive and preventative measures to ensure healthy forests
now and for the long term. [26-1]
Our forests are dying far faster than removals and are becoming more susceptible to the many issues facing us:
locust Ieafminer, hemlock wooly adelgid, emerald ash borer, pine beetle, oak decline and possibly the worst yet:
the lantern fly. Keeping all management tools open to mitigate some of these challenges makes good sense. With
the rise of invasive species, access to treat these forests is critical. Our federal forests were meant to be working
forests and shall be managed for multiple uses: timber, water, wildlife, recreation and range. [26-2]
Through well planned timber harvest projects, such as Twelve Mile, the other uses benefit: the wildlife populations
have better openings for food and habitat creation, water tables are improved with a younger, more vigorous,
green and growing forest, the recreation users will gain better access through roads and loop trails enhanced by

the harvest, and range will benefit, particularly, with the elk project and predictions for herd expansion. Twelve
Mile needs to move forward to illustrate the mission of the USFS in action and on the ground - in the birthplace of
forestry - please. It is time to work. [26-3]