Forsythe II Multiparty Monitoring Group (MMG) USFS Response to MMG Input on Units – Avenza Points and Discussion Items July 2018 1 The information in this table is a summary of the Avenza points and comments brought forward by the MMG to the US Forest Service in regard to Phases 1 and 2 for the Forsythe II Project. The points that were brought forward by the MMG were very helpful in identifying areas of concern along with points of interest (i.e. springs) that the Forest Service’s GIS and other databases did not have identified. All feedback was considered; however, in order to maintain the integrity of the purpose and need and to achieve the objectives for the Forsythe II Project, some of the feedback was not incorporated into the layout of the units to be implemented in Phases 1 and 2. Minor changes are still being made to the boundaries of units and aggregations, but the majority of the boundary establishment has been completed. Through the process of layout, some significant changes were made to Phases 1 and 2. For example, almost 40% less acres will be treated from what was planned in the final decision. A substantial shift from treating acres mechanically to treating acres manually will also occur, which will result in less basal area being removed in all treatment types. The outcome of these two changes is a significant reduction in the number of trees that will be cut. Commonly Used Acronyms: DN – Decision Notice; DBH – Diameter at Breast Height (4.5’ above ground on the uphill side); BA – Basal Area; PP – ponderosa pine; DF – Douglas-fir; LPP – lodgepole pine; LM – limber pine; AS – Aspen; ES – Engelmann spruce; BS – blue spruce; RMJ – Rocky Mountain juniper Links Associated to Documents Cited: Forsythe II Project Decision Notice: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd549685.pdf 1997 Revision of the Land and Resource Management Plan; Arapaho and Roosevelt National Forests and Pawnee National Grassland Final Environmental Impact Statement FEIC Appendices Appendix B: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fsm91_058054.pdf Terrestrial Wildlife Specialist Report: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd525367.pdf Botanist Findings: https://cfri.colostate.edu/wp-content/uploads/sites/22/2018/07/orchids-botany.pdf Hydrologist and Soils Findings: https://cfri.colostate.edu/wp-content/uploads/sites/22/2018/07/unit1-hydro-soils.pdf Wildlife Findings: https://cfri.colostate.edu/wp-content/uploads/sites/22/2018/07/fnwildlife26june18.pdf
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Areaofobservedhighwinds A groupmember stated that thewindson theslopesthattheForsytheIIprojectwilltreatarefast. The USFS is underestimating the erosive
The effects ofwind are incorporated into the designand layout of the aggregations within the unit.Blowdownisexpectedtooccurinboththeareasthat
potential of thewinds in this area. The Towndoesnotwant toaddress suchdetails,but theUSFSdidnotreceiveinformationabouterosionas a result. The Town should work with theColoradoStateForestService(CSFS)tocreateafuel-break around the town. The USFS is notequipped for this kind of work because it isaccustomedtooperatingonamuchlargerscale.TheUSFSshouldpartnerwithBoulderCountyandtheCSFStoconductfiremitigationaroundNederland.
Inresponse,theUSFSsaidthatitwouldexaminewindthrowandwind-scour.Wind-scourcanbeminimized by shaping units that run north tosouth and making the units smaller.Additionally, the USFS stated that CSFSprescriptions are designed to be implementedaroundhouses.Everypartofthetreatmentareaisatleast300feetawayfromthenearesthouse.Individual homeowners can choose tocollaboratewith the CSFS to create defensiblespacearoundtheirhouses,butnotmanypeoplehavedonethatsofar.
are treated and are not treated.Wind effectswill beminimized to the extent possible with aggregationorientationandlocationplacement.The site was visited by a USFS Hydrologist, SoilScientist,Forester,andSilviculturistonJune4,2018toconduct field observations and discuss Soil Erosionand Runoff. It was determined that the existingeffective ground cover was very high. AHydrologist/Soilsspecialist’ssummarywasdevelopedandwas put on the CFRIwebsite (Hydrologist/SoilsFindings,p.1,2).
Gullyordrainagearea A participant noted that “j-shaped” cuts werediscussed for Unit Two to avoid creating anysquare edges in the treatment areas.TheDATrecommended that all of the polygons beirregular. TheUSFSwill not disturb drainagesandhasleewaytotailorthecutsdependingonconditionsontheground.
On-the-ground conditions dictated the shape andboundaries of the cut units. Boundary lines wereestablished in an irregular pattern. Design Criteriawereincorporatedaroundthedrainages(DN,pp.36,38).
The USFS responded to these concerns aboutrunoffbynoting that thecurrentpolygonsarejust general locations designed to provide anidea of forest composition. The exact shapeofthecutscanbechanged.Ifthetwolandownersallowtheirbufferstobecutthepolygonwillbeelongated.TheUSFS isopentoputting“turns”into thecuts.Theproposedcutscurrently runnorth to south because the westwardwind isless intense that way. The aspen, ponderosa,andmixed conifer treatments are going to bemore exact, but there is flexibility for thelodgepolecuts,whichwillprobablybemodifiedinsomeways.
these patch-cuts. Grasses and other surfacefuelswillgrowback.
TheUSFSsaidthatitwillpileandburncuttreesusingmanualcrewsbecauseofthesteepnessoftheterrain.TheUSFSwillevaluateeachpatch-cuttodeterminewhetheritneedstoplantotherspeciessuchaslimberorconifertodiversifythelodgepole area. Some conifer will probablyregrownaturallyinthepatch-cutsaswell.
burningwillincurnewvegetativegrowth.Evendoingnothing, vegetative biomass growth and processeswouldcontinuetoincreasebothinliveanddeadforms.Vegetation management is not a one-time entry.Similartodefensiblespacemitigationonprivatelands,treatments have to be maintained in order to meettheirobjectives.Afterthecuttingandpilinghasbeencompletedwithinthepatchcuts,theareawillbeevaluatedforfollow-upartificialregenerationneeds.
Therewasconcern that thesouth-centralareaof Unit 24 is well-spaced and should not bepatch-cut.Thenortheastpartoftheunithasawell-spacedcanopy.MMGmemberswouldnotliketheUSFStopatch-cutthere.
The area northwest of Unit 24 is defensiblespaceand soprobably cannotbe treated.Thisconstrainstreatmentoptions.
TheDecisionidentifiesthattreatmentscanbetreatedeithermechanicallyormanually(DN,p.6)inordertomeettheobjectivesoftheProject.Unit24isaccessiblewith the existing road system and will not requireadditional road improvements to implement the 4.8acres of patchcuts with mechanical equipment. ThetwopatchcutsthatwereidentifiedonthefieldtripwillutilizesomeoftheexistingboundariesofthepatchcutsthatwerenotimplementedduringtheForsytheFuelsReductionProject(2012).TheidentifiedaspenbytheMMGislessthan½acreinsize andwill not be treated as an aspen aggregationandthe“regenerationarea” identifiedonthemaponthesouthenddoesnotfitthecriteriaofaregenerationthinintheDecision(DN,p.6).Defensible space areas at this point will not be cutwithin this unit. Adjacent landowners have notrequestedtocuttotheboundary.
Inputrecommendscutting/thinningatspatialpoint
TheMMGproposedthattheUSFSplaceapatch-cut between the road and powerlines on thisunit. However, the USFS said that doing sowouldcreate largersnowdriftsontheroad.Agroupmember noted that the shade from thetrees currently in the center of the road maycause snow to stay there longer than itotherwise would. Some group members saidthat there havenot beenproblemswith snowfromsimilar clear-cutsonMagnoliaRoad.The
An MMG member suggested scalloping theforest just below the road in the centerof theunit.Feathering or scalloping some cuts on thesouthwesterncorneroftheunitcouldgiveitamore natural look. The USFS could move apatch-cut towards the center of the unit toremovesomedensetreesfromaslope.
Theorientationoftheroad(easttowest)funnelsthewindandwideningthegapbetweenvegetationwouldexacerbatewindeffectstothestretchofroadandareawhereLazyZRoadturnsontheeastendoftheunit.Roadsareconducivetofuelbreaks,butduetotheroadorientation,shortlineardistanceoftheareaproposedtobecut,benefitsfromaroadfuelbreakareminimal.AstripclearcutoneithersideofLazyZ throughNFSlands and private lands would be beneficial to thelandowners who live there because it would offerreduced exposure to convective heat and flamesduring awildfire event topeople evacuating an areawithonlyonewayinandonewayout.All treatment areas will be reviewed by a USFSLandscape Architect prior to final unit layout. Unitboundariesshallbenaturaledgeswheneverpossibleand prevent the appearance of uniform tree spacingandstraightlineboundaries.(DN,p.32).Boundarylinesshallbeestablishedbyfeatheringandscalloping(DN,p.32).
TheUSFSneedstocutalmost5acresinthisunit.MMGmemberssuggestedcuttingnearertotheroad in the south-center of the unit and thesoutheastportionoftheunitbeneaththeroad.Additionally, there are some dense, young,regenerated trees in the south-central portionof theunitsuitable forthinning.TheUSFSwillexaminethesepossibilitiesthenexttimeitvisitstheunit.There are aspens in the northwest of the unitabove the road. Removing conifer there couldmodifyfirebehavior.
The“regenerationthin”areadidnotfitthecriteriaforregenerationthinbecausethetreesaretallerthan15’(DN,p.6).Theunitisbeingtreatedmechanicallyandthematerialwillberemovedfromthesite.Thetreesidentifiedby theMMGare too small to economicallytreatwithmechanicalequipment.TheidentifiedaspenbytheMMGislessthan½acreinsizeandwillnotbetreatedasanaspenaggregation.
Markedtrees Therearesometreesmarkedwithpaintonthenorthernportionof theunit.Agroupmemberwonderedaboutthemeaningoftheribbonsandpaintcolorsontreesinthisunit.TheUSFSsaidthattreesmayhavebeenpaintedpinktotakeaninventory of tree volume. Orange indicates aboundaryanddouble-paintingindicateswhereaturninthetreatmentboundariesoccurs.Thisunithasnotbeenpaintedyet.Theseoldmarksare from two 4-acre clear-cuts from theForsythe I project that were designated for atimbersale.
There are rocky outcrops in the northeasternportionofunit39.Thesemaybeinadefensiblespace zone. The USFS has not receivedpermissionfromlandownerstotreatthisarea,butitmight.
Knolls and rock outcrops will be excluded fromtreatmenttomaintainaestheticvalues.Thesefeaturesareidentifiedasthehighestpointinthelocalvicinitythathaveafewtreesexhibitingcharacteristicssuchasstunted growth, irregular crown shapes, andmaturebark attributes. Treatment exclusions will extenddownfromthepeakofthefeaturetotheareawheremechanical equipment can operate, approximately40%,orthepointwherethevegetationtransitionsintoameadowdominatedbygrassandforbs(DN,p.34).TheUSFShasnotbeencontactedabouttreatingwithinthedefensiblespacezonealongtheboundaryofunit39;thus,thedefensiblespacezonewillnotbetreated.Part of unit 39 will be followed with a prescribedbroadcastburnandinthatarea,cutvegetationwillbeloppedandscattered.Inunit39wheretheslashwillbepiled, piles will not be constructed on the rockoutcrops.
The entire project area, including unit 39, is used inonewayoranotherbylargeungulates,predators,andbirds through migration, foraging, refuge, or asseasonal range.The landscape isdynamicandas thecomponents of the environment change either in anatural (i.e.wildfireor insectepidemic)or inhumancaused (building a house or patch cut) disturbances,speciesofwildlifewilladapttheirpatternsbestsuitedfortheirneeds(TerrestrialWildlifeSpecialistReport,pp.64-67,87,88).
Thereislimberpineintheeast-centralportionof Unit 76 mixed with dense lodgepole. TheUSFSsaidthatitfavorslimberpineintreatmentandwouldleaveit.
Limber pine will only be cut if it is a hazard to theimplementation of the project (DN, pp. 5-7). Bluespruce are generally locatedwithin the stream zoneandmostlikelywouldnotbecutduetotheirsize(DN,pp.4,5).
or patch cut) disturbances, species of wildlife willadapttheirpatternsbestsuitedfortheirneeds.Astheyadjusttothosechangingconditions,findingthepathofleast resistance by cutting across an open field orthroughadenseforestwilleventuallyturntonewtrail.It isnotuncommon tosee largemammals,being themostnoticeable, incorporatehumancreated trailsorroadsintotheirtrailsystem.
Units 42, 75, and 76 are being manually treated,handpiled, and then later burned. The layout andpreparation for these units will be emphasizing thecuttinginthedenser,“dog-hair”areas.
Inputdiscouragescutting/thinningatspatialpoint
The western arm of unit 75 includes well-spaced,largertreesthatMMGmemberswouldliketheUSFStoleave.
Units 42, 75, and 76 are being manually treated,handpiled,andthenlaterburned.Thelayoutandprepemphasized cutting the denser, “dog-hair” areas andavoidedthewesternarm.
There is a cluster of large lodgepole in thenortheasternportionofUnit43.ThelodgepoleisdenseandincludesyoungDouglasfir.Thereare large ponderosa and spruce trees to thenortheastofthisarea.TheUSFSwillchecktoseeifthereisadrainageinthearea.
Thisunitwillbe treatedmanuallyso large lodgepolepinemost likelywouldnotbecut.TheDouglas-fir intheunderstorymostlikelywouldbecut.Ifadrainageisencountered,appropriateDesignCriteriawouldbeimplemented(DN,pp.35,36,38).
Inputrecommendscutting/thinningatspatialpoint
There are some well-spaced, average-sizedponderosapineinthesouthwesternportionofunit 43. The USFS could thin some of theregenerated vegetation there, which couldfunctionasladderfuel.TheUSFScouldthinlodgepoleinthenortheastofunit68.Thatarea is steep, so theUSFSwill
The area will be evaluated to determine if the areacouldbesteeredtowardsanunevensizedaggregation(retaining trees of all size classes) and not just cutladderfuels.Theunitwillbetreatedmanually.Becausetheunitisidentified as Mixed Conifer unit, an aggregation oflodgepole pine treatment (patchcut) could be
Knolls and rock outcrops will be excluded fromtreatmenttomaintainaestheticvalues.Thesefeaturesareidentifiedasthehighestpointinthelocalvicinitythathaveafewtreesexhibitingcharacteristicssuchasstunted growth, irregular crown shapes, andmaturebark attributes. Treatment exclusions will extenddownfromthepeakofthefeaturetotheareawheremechanical equipment can operate, approximately40%,orthepointwherethevegetationtransitionsintoameadowdominatedbygrassandforbs(DN,p34).
There is spruce along the drainage in thesouthwestern part ofUnit 43. TheUSFS couldpromoteaspeninthatareaaswell.
Duetothesizeofspruceindrainages,thediametercaplimitwillmostlikelybeexceeded;thus,theywouldnotbe cut (DN, p. 5). Design Criteria for diameter caps,stream,andriparianvegetationwillbefollowed.(DN,pp.5,6,35,36,38)
Suggestionformovingtheunitboundary
There was some confusion because thenorthern curve in the boundary of Unit 43appearedtobefartooclosetoahouse.TheUSFSexplained that itsmappingprogrammayhavemissedthebufferzone.TheUSFSwillshifttheboundary down to provide the home with itsstandardbuffer.
Thereare severalmountain lionkillson theseUnits.MountainlionsarenotmentionedintheEnvironmental Assessment (EA) or the DN.Group members would like more informationaboutthehistoricalresponseofmountainlionstothesetypesoftreatments.
Units73and48haveareasofskinnyponderosapinethatseemssuitableforthinning.However,theUSFSnotedthatifthoseareasarethinneditwillbeeasy for snow loads toknock the treesover.Itmightmakemoresensetocleartheareatolettreesregrowaltogether.
The area will be evaluated to determine the bestprescriptionforthislocation.
MMGmembersmarkedwildlife trailsontheseunits; scat can provide a general picture ofwhereanimalpopulationscanbefound.
Refer to theTerrestrialWildlifeSpecialistReport forinformation regarding migratory birds (TerrestrialWildlife Specialist Report, pp. 87, 88). Refer to theDesign Criteria in the Decision regarding the
Ingeneral, thespacebetweensouthandnorthslopes on these units is flatter, cooler, andwetter. MMGmembers found a lot of elk scatthereanditseemsthatelklikethishabitat.MMGmembers recommended that the USFS thinthoseareaslessandinsteadthinmoreonsouthslopes to meet basal percentage targets.Similarly, there are shady, wet areas in thenortheastern part of unit 73 that should bethinnedlesssothatthereissufficientcoverforelk.AUSFSbiologistnotedthattheareaswithscatareprobablytheeasiestplacesforelktotravel.
protectionofraptornestsandactivity(DN,pp.32,33,40).Units 49& 73were surveyed during the summer of2018 foractiveNorthernGoshawkandFlammulatedOwl nests/territories. Male Flammulated Owls weredetected in both units, but nests were not located.TherewerenodetectionsofNorthernGoshawksandnootherraptornestswerelocated.Population trends on a landscape scale have beencaptured with CPW’s and Boulder County’s elkmigration mapping of the elk corridor that passesthrough the Forsythe II Project area. Past fuelstreatmentshaveincreasedavailableforageforelkandproposed fuels treatments with Forsythe II wouldfurtherincreaseforageinportionsoftheprojectarea.In addition to the Avenza points that the group hasprovided,visualsightingsandevidenceofelkusehavebeenmadethroughouttheprojectandadjacentareas.TheseunitswillbetreatedmanuallywithchainsawsinPhase3whichwillresult in lessbasalareabeingcutthroughout the entire area of both units. Commentswill be considered in unit layout and prescriptiondevelopment.
However, these units are quite large and it ishard to capture population trends on thelandscape level using Avenza points. If atreatmentoccurredinoneplace,theelkwouldprobablymove somewhere else. The biologistnoted that it isdifficult forUSFSstaff tocovertheentiretyof theseunits, sostaffwill takeofthis input on elk activity into consideration.MMGmembersshouldconsiderelkpopulationsat the landscape scale when providing thisinput, but the more information that MMGmembersprovide toUSFSbiologists, themorethey can say about elk concentrations in thearea.A group member requested that the USFSpreservelargeswathesofcoverinareaswhereelkandmountain lionsarepresent.Thegroupmember stated that 100 feet of buffer forcoverage is insufficient. In response, a USFSbiologiststatedthat thetreatmentswouldstillleave cover for predators and ungulates. TheUSFS’wildlifebiologistwillbeconsultedbythetreatment team about what needs to beconsideredbefore treatment.Accordingly, thisinput is helpful for theUSFS’ biologists. It caninformmodifications to treatmentboundaries.The USFSwill not just ignore the presence ofmountainlions.ThatisthepurposeoftheMMG.
TheUSFS said that it couldmaintain cover onnorth slopes, but there are toomany trees onsouth slopes and they need to be thinned.
Thelandscapeisdynamicandasthecomponentsoftheenvironmentchange,elkwilladapttheirpatternsbestsuitedfortheirneeds.Astheyadjusttothosechangingconditions, finding the path of least resistance bycuttingacrossanopenfieldorthroughadenseforestwilleventuallyturntonewtrail.Population trends on a landscape scale have beencaptured with CPW’s and Boulder County’s elkmigration mapping of the elk corridor that passesthroughtheForsytheIIProjectarea.Buffers between pathcuts/clearcuts are in place toprovidewildlifecorridorsinlodgepolepinetreatmentunits. These units are identified as Ponderosa PineMixedConiferwhichwillbethinneduptoa50%BAreduction.TheresidualBAwillstillprovidecoverforpredators and large ungulates. The design of theprojectreducesstanddensitiestovaryinglevels.Standdensities on north aspects are higher than on southaspects.Forexampleanorthaspectmayhaveabasalareaof120sq.ft.peracreandasouthaspectmayhaveabasalareaof70sq.ft.peracre.Afterthinningupto50%,thebasalareasoneachaspectcouldbe60and35sq. ft. per acre. Adjacent areas to the treated unitswouldmaintaintheirexistingbasalareas,120and70sq.ft.peracrerespectivelyuntilanaturaldisturbancemodifies and impacts the surrounding landscape.Stand structural vegetation heterogeneity across the
Mountainlionkillswillbefoundinthearea,butthe habitat is expansive. The USFS said thatMMGmembershaveprovidedinformationthattheirobservationsindicatearediminished,butthereareprobablynewspeciesandvegetationpresentintreatedareasaswell.WestMagnoliaand other past treatment areas probably nowhostspeciesthatwerenotpreviouslypresent.
landscapeprovideshabitatforawiderangeofwildlifespecies.Therearethreegoldeneagleterritoriesthathavebeenmonitored over the past few years in the GrossReservoirvicinity.Theseareaswillbecontinuedtobemonitoredannually.AppropriateDesignCriteria andoperatingperiodswillbeappliedpertheDecision(DN,pp.32,40).
Observationsabouttreesorforeststructure
MMG members marked an aspen stand forenhancement.
There is mistletoe among the ponderosa andsomeDouglasfiratthesouthernendofunit49.
Aspenisanaggregationthatcanbetreatedwithintheidentifiedtreatmentunit.Aspentreatmentunitsandaggregationshavediametercaplimitsof14”DBHforPPandDFand12”DBHforLPP.Aminimumof5ofthelargestavailabledeadtreeswillberetained(PP/DF-min.10”DBH,LPP-min.8”DBH);PPsnagspreferredtoretain.Ifmin.numberofsnagsisnotavailable,thenthelargestavailablelive,greenreplacementtreeswillberetainedforfuturesnags(DN,pp.4,5,6,33).OneoftheobjectivesfortheForsytheIIProjectistorestoreponderosapine/mixedconiferstandstowardtheir characteristic species composition, structure,and spatial patterns in order to increase resistanceand resiliency to future natural disturbances. Eventhough dwarf mistletoe is a component in thislandscape,itisathigherlevelsandraisesconcerninregards to forest health. Emphasis, where possible,
DownedMaterial There is a lotofdownedmaterial in this area.MMGmemberswouldprefer that thisdownedmaterialbepiledandburned.TheUSFSwouldliketoremovethedownedmaterialbutdoingsois expensive and the USFS cannot broadcastburnthearea.A group member asked if the USFS wouldremove downed material from unit 74. TheUSFSsaidthatthiswouldnotnecessarilybethecase. The treatment of unit 74 was originallyintendedtobecarriedoutintwostages,buttheUSFS isnowconsidering treating it all atonceinsteadofburningtheslashpiles,whichcouldscorch the overstory. Units designated formechanicaltreatmentwillutilizeequipmenttobring downed material to a landing site. Formanually-treated units, the USFSwill work tominimizethepotentialforerosion.
Duringlayoutandastheprescriptionisdeveloped,thearea will be evaluated to address the amount andarrangementofthedownedmaterialandifsomecanbeincorporatedintoacontract.Unit74willbetreatedmanuallysomaterialwillnotbephysically removed from the unit. Unit 74 is a two-stagedtreatmentunit:thefirstistopileexistingslashand burn; second entry is to thin, pile and burn theactivityslash.
Inputdiscouragescutting/thinningataspatialpoint
The north-central portion of unit 73 could bethinnedless.
ThisunitwillbetreatedmanuallyduringPhase3.Thelocationwillbeevaluated todeterminewhat levelofthinningisneededtomeettheobjectivesoftheProjectandconcernsbroughtforward.Overall,forageavailabilityappearstobedecreasinginsome areas, as mixed conifer stands become denserand canopy openings become smaller. However,within and surrounding the project area, fuelstreatments onNFS andCounty lands in recent years
Thesouthwesternarmofunit73issteep,andagroupmembersaid that itdidnot leavemuchareatocut.TheUSFSsaidthatthatareawillbetreatedmanually,eventhough it is inPhase2,which largely consists of mechanicaltreatments. The USFS will transfer some sub-aggregations to manual treatment. The USFSwill walk the units to identify the need formanual treatment. Portions of unit 49maybetreatedmechanically.
havecreatedrelativelylargeopenings,resultinginanincrease in the grass-forb stage of lodgepole pineforests in the project area. Elk have been observedforagingintheseopeningsUnit73willbetreatedmanuallyinPhase3.
Rockyknollsorrockyoutcrops
MMGmembersmarkedsomeknolls,butnotallof the ones that they could havemarked. TheUSFSnotedthattheDesignCriteriaforknollsisintendedtoprotectlargerknolls.
Knolls and rock outcrops will be excluded fromtreatmenttomaintainaestheticvalues.Thesefeaturesareidentifiedasthehighestpointinthelocalvicinitythathaveafewtreesexhibitingcharacteristicssuchasstunted growth, irregular crown shapes, andmaturebark attributes. Treatment exclusions will extenddownfromthepeakofthefeaturetotheareawheremechanical equipment can operate, approximately40%,orthepointwherethevegetationtransitionsintoameadowdominatedbygrassandforbs(DN,p.34).