DRAFT ENVIRONMENTAL ASSESSMENT

URBAN FUEL LOAD REDUCTION IN PORTLAND, OR
CITY OF PORTLAND
PDMC-PJ-10-OR-2005-005

FEBRUARY 2006

Prepared for:
U.S. DEPARTMENT OF HOMELAND SECURITY
130 228th Street SW
Bothell, WA  98021-9796

Prepared by:
URS
111 S.W. Columbia, Suite 1500
Portland, Oregon 97201

Section 1	Introduction	1-1
Section 2	Purpose and Need for Action	2-1
Section 3	Alternatives Analysis	3-1
	3.1	Alternative 1 - No Action	3-1
	3.2	Alternative 2 - Proposed Action	3-1
		3.2.1	Alternative Features	3-1
		3.2.2	Years One, Two and Three	3-1
		3.2.3	Year Two	3-2
		3.2.4	Years Two and Three	3-2
		3.2.5	Year Three	3-3
	3.3	Other Alternatives Considered	3-3
Section 4	Affected Environment and Environmental Consequences	4-1
	4.1	Air Quality	4-2
		4.1.1	Environmental Consequences	4-2
	4.2	Climate, Geology and Soils	4-3
		4.2.1	Climate	4-3
		4.2.2	Geology and Soils	4-3
		4.2.3	Environmental Consequences	4-5
	4.3	Floodplains	4-5
		4.3.1	Environmental Consequences	4-5
	4.4	Wetlands and Water Resources	4-6
		4.4.1	Environmental Consequences	4-6
	4.5	Vegetation	4-7
		4.5.1	Forest Park	4-7
		4.5.2	Environmental Consequences (Forest Park)	4-7
		4.5.3	Powell Butte Nature Park	4-8
		4.5.4	Environmental Consequences (Powell Butte Nature Park)	4-9
		4.5.5	Willamette Bluffs Escarpment	4-9
		4.5.6	Environmental Consequences (Willamette Bluffs Escarpment)	4-
10
	4.6	Biological Resources	4-10
		4.6.1	Listed Species and Critical Habitat	4-10
		4.6.2	Environmental Consequences	4-12
	4.7	Essential Fish Habitat	4-12
		4.7.1	Environmental Consequences	4-13
	4.8	Historic, Archaeological and Cultural Resources	4-13
		4.8.1	Historical Resources	4-13
		4.8.2	Environmental Consequences	4-14
		4.8.3	Archaeological and Cultural Resources	4-15
		4.8.4	Environmental Consequences	4-15
	4.9	Hazardous Wastes and Materials	4-16
		4.9.1	Environmental Consequences	4-16
	4.10	Socioeconomic and Environmental Justice (EO 12898)	4-16
Section 5	Cumulative Impacts	5-1
	5.1	Cumulative Effects Analysis	5-1
Section 6	Public Involvement and Response to Comments	6-1
Section 7	Required Permits and Compliance	7-1
Section 8	Conclusion	8-1
Section 9	References	9-1

Appendices
Appendix A	Vicinity Map
Appendix B	Site Maps
Appendix C	Executive Order
Appendix D	Project Conditions and Conservation Measures
Appendix E	Public Notice
Appendix F	Findings of Effect, Section 10 NHPA 

List of Terms and Acronyms Used in This Document
Crown Fire - fire that involves the tops of the canopy trees in the forest; can 
spread rapidly.
Fire Line - a break in fuel made by cutting, scraping, or digging to stop the 
progress of fire; 
needs to be wide enough to prevent smoldering, burning, or spotting across the 
line.
Fire Management Plan - a strategic plan that defines a program to manage 
wildland and 
prescribed fires and provide for fuels reduction as needed.
Fire Regime - the frequency of occurrence, size, and intensity of fires that 
occur within a given 
area.  Includes non-lethal (one fire every 5-25 years), mixed severity (one fire 
every 5-67 years), 
and stand replacement (one fire every 70-120+ years) regimes.
Fuels (Ground/Ladder) - wood, foliage or grass that can burn. Ground fuels are 
grasses, duff, 
herbaceous cover; ladder fuels are under-story branches or shrubs that can allow 
a fire to ascend 
into the canopy.
Fuels Reduction - removal of excess fuels through thinning, limbing, slash pile 
burning, or 
other methods to reduce the potential for severe wildfires.
Jackpot Burning - controlled burning of slash (trees, brush, branches) removed 
during thinning; 
burning of concentrated fuels 
Limbing - removal of large tree limbs to reduce fuel load and the potential for 
crown fires.
Pile Burning - controlled burning of slash (trees, brush, branches) removed 
during thinning 
through the use of hand piling and burning.
Prescribed Fire - any fire ignited by management actions to meet specific 
objectives.  A written 
approved prescribed fire plan must be completed and appropriate NEPA 
requirements followed 
prior to ignition.  This term replaces the term "management ignited prescribed 
fire."
Prescribed Natural Fire - a term previously used; has been replaced by "Wildland 
Fire Use."  
Spot Burning - a modified form of broadcast burning in which only the larger 
accumulations of 
slash are ignited and the fire is confined to these spots; may be used to burn 
small populations of 
plants; can be used in wet conditions to kill unwanted vegetation.
Start - any new fire.
Suppression - a response to wildland fire that results in curtailment of fire 
spread and 
elimination of all identified threats from the fire.
Thinning - removal of trees, branches, or shrubs to reduce fuel loads.
Wildfire - an unwanted wildland fire.
Wildland Fire - any non-structure fire, other than prescribed fire, that occurs 
in the wildland.  
This term encompasses fires previously referred to as both wildfires and 
prescribed natural fires.
Wildland Urban Interface - line, area, or zone where structures and other human 
development 
meet or intermingle with vegetative fuels in wildlands.

Acronyms
BMP	Best Management Practice
CFR	Code of Federal Regulations
CO	Carbon Monoxide
EA	Environmental Assessment
EFH	Essential Fish Habitat
EIS	Environmental Impact Statement
EO	Executive Order
ESU	Evolutionary Significant Units
FEMA	Federal Emergency Management Agency
MSA	Magnuson-Stevens Fishery Conservation and Management Act
NAAQS	National Ambient Air Quality Standard
NEPA	National Environmental Policy Act
NHPA	National Historic Preservation Act
NMFS 	National Marine Fisheries Service
NO2	Nitrogen Dioxide
NWI	National Wetland Inventory
O3	Ozone
ODFW	Oregon Department of Fish and Wildlife
ORNHIC	Oregon Natural Heritage Information Center
PM10	particulate matter less than 10 micrometers in diameter
PAQMD	Portland Air Quality Management District
PPR 	Portland Parks and Recreation 
RCRA 	Resource Conservation and Recovery Act 
SHPO	State Historic Preservation Officer
SO2	Sulfur Dioxide
USEPA	U.S. Environmental Protection Agency
USFWS	U.S. Fish and Wildlife Service
VOC		Volatile Organic Compound

The City of Portland has applied to the U.S. Department of Homeland Security's 
Federal 
Emergency Management Agency (FEMA) for assistance with an urban fuel load 
reduction 
project in Portland, Oregon. The project will utilize and build upon an existing 
volunteer 
program to include fuels reduction education and vegetation management for 
wildfire risk 
reduction. 
The National Environmental Policy Act of 1969 (NEPA) and the Council on 
Environmental 
Quality (CEQ) regulations implementing NEPA (40 Code of Federal Regulations 
[CFRs] Part 
1500 through 1508) direct FEMA and other federal agencies to fully understand 
and take into 
consideration environmental consequences of proposed federally funded projects. 
Under NEPA, 
Congress authorizes and directs federal agencies to carry out their regulations, 
policies, and 
programs as fully as possible in accordance with the statute's policies on 
environmental 
protection.  NEPA requires federal agencies to make a series of evaluations and 
decisions that 
anticipate adverse effects on the environmental resources.  This requirement 
must be fulfilled 
whenever a federal agency proposes an action, grants a permit, or agrees to fund 
or otherwise 
authorize any other entity to undertake an action that could possibly affect the 
human 
environment.   In compliance with NEPA and its implementing regulations, FEMA 
prepared this 
draft environmental assessment (EA) to analyze potential environmental impacts 
of alternatives.
Large areas of Portland (City) are comprised of natural areas, stream corridors, 
and open spaces. 
While this is a community asset, it is also a fire hazard at the wildland-urban 
interface. Large 
areas of highly flammable, non-native vegetation are present on steep slopes 
near homes and 
businesses.  Stands of dead trees and vertical ladder fuels are expanding in 
areas with limited 
fire. For these reasons, the risk for a catastrophic wildfire is increasing. 

The purpose of the FEMA Pre-Disaster Mitigation Program  is to encourage 
communities to 
implement disaster preparation programs and increase the capability of state and 
local 
governments to provide comprehensive disaster preparedness plans and programs. 
Through such 
programs, FEMA provides financial assistance to states, local governments, 
tribal governments, 
and U.S. territories by providing fire suppression assistance grants. 
Fuel loads in three natural areas (project areas) in Portland currently present 
a real danger to 
property and people who live, work, and play in these areas. They include Forest 
Park, 17,331 
acres of natural area that includes a 5,151-acre maintained open space park on 
the west side of 
Portland; Powell Butte Nature Park, a 738-acre natural area on the east side of 
Portland; and 
Willamette Bluffs Escarpment, a linear open space approximately 370 acres in 
total, to the east 
of the Willamette River on the river's east bank (Appendix A, Vicinity Map). 
Highly volatile, 
non-native vegetation and steep slopes combine to increase fire risk in these 
areas. When fire is 
introduced by human and/or natural causes and the flammable vegetation ignites, 
there is the 
potential for risk to human lives, immediate damage to property from the fire, 
and subsequent 
damage due to landslides on slopes where fire has removed soil-holding 
vegetation.
Property values at the wildland-urban interface for the proposed project exceed 
$2.5 billion. 
Over 20,000 Portland residents and hundreds of thousands of park visitors would 
feel the 
devastation resulting from a catastrophic fire.  The need for this action is to 
reduce or eliminate 
the risk to improved property from wild fires in the city of Portland natural 
areas.  

The following sections discuss the two alternatives considered: (1) the No 
Action and (2) The 
Proposed Action to which FEMA funding would contribute.

3.1	ALTERNATIVE 1 - NO ACTION
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface. Existing conditions at 
these sites would 
continue to deteriorate.  People and nearby structures would continue to be at 
risk from 
catastrophic fire events. Current and ongoing activities to protect the open 
spaces and urban 
interface will continue including noxious weed abatement, re-vegetation with 
native plant 
species, and general vegetation maintenance, but not to the degree needed and/or 
anticipated if 
funding is appropriated.  This alternative would not meet the project nor the 
City's goals and 
objectives.

3.2	ALTERNATIVE 2 - PROPOSED ACTION
Under the Proposed Action, three natural areas would be targeted for reduction 
and management 
of fuel loads: Forest Park, Powell Butte Nature Park, and two segments of 
Willamette Bluffs 
Escarpment (Appendix B). The following lists the total acreage of Wildfire 
Hazard Target Areas 
within each of the natural areas:
	17,331 acres in Forest Park 
	738 acres in Powell Butte 
	140 acres in South Bluff 
	230 acres in North Bluff 

3.2.1	Alternative Features
The FEMA funding for the project would provide for activities that will span 
three years and 
would include fire break and vegetation management modeling; herbicide, 
mechanical and 
manual reduction in non-native vegetation mass; education and prescribed fire 
training; and 
coordination efforts.  The modeling, education, and training for fire management 
will be 
conducted throughout the three-year period.  Herbicide, mechanical, and manual 
reduction of 
vegetation would occur during those times (spring, summer, fall) that target 
species would be 
most susceptible.  All activities would be confined to existing roads and fire 
lanes in all 
locations.  No new roads would be built, refueling of vehicles/equipment would 
occur in existing 
roads away from concentrations of fuels to be burned, and away from waterways.     

3.2.2	Years One, Two and Three 
	Fire break and vegetation management options (herbicide, mechanical, 
and/or manual 
reduction of non-natives) for highly combustible vegetation would be modeled for 
Forest 
Park and Powell Butte.
	Reduction of vegetation would occur in the three project areas and 
projected activities 
would include the on-going and additional herbicide application and other 
mechanical 
and manual methods to remove targeted fuel loads as well as spot and jackpot 
burning.  
Spot burning involves igniting accumulations of slash in small areas and may 
also 
include burning small populations of plants. It can be used in wet conditions to 
kill 
unwanted vegetation. A jackpot burn will involve hand piling excessive fuels and 
deliberately burning them under environmental conditions that allow the fire to 
be 
confined to the perimeter of the hand pile area. Jackpot burns produce the 
intensity 
required to attain planned fuel reduction objectives. By avoiding the use of 
machinery, 
hand piling has a minimal and temporary impact on vegetation and soils in the 
area of 
activity. Hand constructed fire lines, which are lines of flammable material 
(vegetation) 
removed from surrounding burn piles, will be restored to pre-project conditions. 
Best 
management practices for erosion control, such as the placement of straw bales 
or bio-
filter bags will be employed. Burning would be timed after the first seasonal 
rains when 
the larger of the piled fuels combust but surrounding areas have the lowest 
probability of 
burning.
	Minimal ground disturbance would be required.    Crews would use existing 
roads and 
fire lanes within the park for access and staging of vehicles and equipment.   
	Refueling of vehicles/equipment would occur on existing roads away from 
concentrations of fuels to be burned and away from waterways.
	Erosion control grass seeding would occur in all disturbed areas.
	The effectiveness of vegetation reduction and public education activities 
would be 
monitored.
	Contract labor and volunteers would be utilized to remove vegetation.
	Education of students at the K5-K12 level would occur in Portland public 
schools.

3.2.3	Year Two 
	Curriculum of fire safety and fuel load management would be developed and 
delivered.
	 Education and volunteer stewardship would continue in the field and in 
the classrooms.

3.2.4	Years Two and Three 
	Areas where prescribed burns would occur will be established through the 
fire risk 
modeling.
	Public involved burn plans would be developed for those areas described as 
high risk for 
fire.  These plans will include all the logistics necessary to complete 
prescribed burns 
safely and within the confines of designated areas.  Burn plans would also 
include any 
mitigation required for protection of natural and cultural resources   
	Initial training and preparation of firefighters and the public for urban 
fire training and 
implementation of burn plans would begin. 

3.2.5	Year Three
	Evaluate the work performed thus far, make any corrections in methods 
and/or 
techniques, and plan the implementation of future work in wildfire mitigation in 
the 
greater Portland area.

3.3	OTHER ALTERNATIVES CONSIDERED
A variation of the proposed action was evaluated and dropped from further study 
based on issues 
of safety and fire preparedness.  This alternative would have aggressively used 
fire and other 
vegetation abatement without the assessment of fire modeling and risk 
assessment.  Areas for 
implementing prescribed fire would have been designated solely on their extreme 
fuel loading 
and juxtaposition to the urban areas.  This alternative was dropped from further 
study and no 
other alternatives were evaluated.  

The following sections discuss the existing conditions by resources and the 
potential effects of 
the two alternatives mentioned earlier on the resources.  
For each topic or resource category, the impact analysis follows the same 
general approach. 
First, the existing conditions are established for the affected areas. Then, the 
regulations and 
policies that guide impact assessment are identified, and finally, the specific 
impact thresholds 
for intensity of impacts are developed (see below).  The study area, or area of 
analysis, was 
specific to the three natural areas (Forest Park, Powell Butte, and Willamette 
Bluffs Escarpment).   
Distinct durations were defined (short-term, long-term).  Impacts were assessed 
based on extent 
or intensity of the departure from the existing conditions.  Establishing 
thresholds and degrees of 
impact intensity were based on a review of relevant scientific literature, 
previously prepared 
environmental documents, and the best professional judgment of the EA team 
resource 
specialists.
Impact Intensity Threshold Criteria (Soils used as an example)
Negligible
Effects to soil productivity, fertility, stability, or infiltration capacity 
resource would be below or at the lower levels of detection.  Any effects to 
soil productivity or fertility would be slight and no long-term effects to soils 
would occur.
Minor
The effects to soil productivity, fertility, stability, or infiltration capacity 
would be detectable, but the area is generally of limited and localized.  
Effects to soil productivity or fertility would be small.
Moderate
The effects on soil productivity, fertility, stability, or infiltration capacity 
would be readily apparent and result in a change to the soil character over a 
relatively wide area.
Major
The effect on soil productivity, fertility, stability, or infiltration capacity 
would have a substantial and possibly permanent consequence.  Effects on 
productivity or fertility would be readily apparent, long-term, and 
substantially change the character of the soils over a large area.

Impact Duration Definitions:
Short-term
Recovers in less than three years from fire or other action.
Long-term
Takes more than three years to recover from fire or other action.

Impacts are described in general terms and are qualified as short-term and long-
term, adverse or 
beneficial, as appropriate.  Impacts may also be described as direct or 
indirect.  Direct impacts 
are caused by an action and occur at the same time and place as the action.  
Indirect impacts are 
caused by an action and occur later in time or farther removed from the area, 
but are reasonably 
foreseeable.  Cumulative impacts are also discussed, per NEPA requirements.

4.1	AIR QUALITY
In 1970, the U.S. Environmental Protection Agency (USEPA) established national 
ambient air 
quality standards for six "criteria pollutants": nitrogen dioxide (NO2), ozone 
(O3), carbon
monoxide (CO), sulfur dioxide (SO2), lead, and particulate matter less than 10 
micrometers in 
diameter (PM10). Areas where the monitored concentration of a pollutant exceeds 
the federal 
standard are classified as "non-attainment" for that pollutant. If the monitored 
concentration is 
below the standard, the area is classified as "in attainment."  Maintenance 
areas are those 
geographic areas that had a history of non-attainment, but are now consistently 
meeting the 
National Ambient Air Quality Standard (NAAQS). 
The study area for the proposed project is within the jurisdiction of Portland 
Air Quality 
Management District (PAQMD) and is classified as being in attainment of all 
federal standards 
except for O3 and CO (Oregon Department of Environmental Quality 2005). 

4.1.1	Environmental Consequences:
Alternative 1: No Action
Under the No Action Alternative, no pollutant emissions would directly impact 
air quality. 
However, in the event of a wildfire, the resulting smoke would cause temporary 
adverse impacts 
to air quality. Smoke from a fire consists of carbon dioxide (CO2), water vapor, 
particulates 
(some of which contain volatile organic compounds [VOCs]), and CO. In addition, 
exhaust from 
support vehicles used in fighting the wildfire would cause a slight, temporary 
increase in PM10, 
CO, NO2, SO2, and O3 precursors. Soils exposed by a wildfire would increase PM10 
levels 
through wind erosion.
Alternative 2: Proposed Action
Under the Proposed Action Alternative, spot and jackpot pile burning would emit 
CO2, water 
vapor, particulates (some with VOCs), CO, PM10, NO2, SO2, and O3 precursors. 
These are the 
only types of burning that would occur under this alternative.  Impacts to air 
quality from spot 
and jackpot pile burning would be negligible, as these activities would be 
conducted in a 
controlled manner and would be timed to coincide with optimum meteorological 
conditions 
conducive to concentrated air-column dispersal of fire-induced smoke. In 
performing the spot 
and jackpot pile burning associated with the proposed project, the City would 
comply with 
requirements regarding permitting and public notification prior to initiating 
burns. 
No impacts to air quality are expected from herbicide use due to the small-
scale, localized, hand-
applied methods and the nonvolatile nature of the herbicide. Also, the particle 
size of the 
herbicide spray would cause it to sink, so it would not affect air quality.
No impacts to air quality are expected from the use of chainsaws, weed cutters 
and other small 
power tools due to the small-scale, localized nature of their proposed use.
Changes in air quality and air quality-related values would be at or below a 
negligible level of 
detection. If detected, effects would be considered slight with no anticipated 
consequences to 
health or visibility.  These impacts are considered short-term and would not add 
incrementally to 
the long-term cumulative effect on air quality.

4.2	CLIMATE, GEOLOGY AND SOILS

4.2.1	Climate
The climate of western Oregon and the City of Portland metropolitan area 
specifically is greatly 
influenced by winds from the Pacific Ocean. The maximum average annual 
temperature for the 
Portland area is 62 degrees and the average minimum annual temperature is 44 
degrees, with 80 
degrees the average maximum for July and August and 34 degrees the average low 
for January 
(National Weather Service, 2004). The average total annual precipitation for the 
Portland area is 
37 inches, most of it occurring as rainfall between the months of October and 
May. While 
rainfall occurs in any month of the year, the region generally endures a summer 
drought season, 
generally in the months of June through September. Hot, dry winds from Eastern 
Oregon 
frequently blow west through the Columbia River Gorge and through the Portland 
area. The dry 
winds significantly reduce fuel moisture levels and can fan sparks into a 
wildland fire. 

4.2.2	Geology and Soils

Forest Park
Forest Park is located on Tualatin Mountain, a ridge running along the southwest 
edge of the 
Willamette River. The portion of the ridge comprising Forest Park ranges in 
elevation from 
approximately 50 feet to 1,150 feet above sea level. The ridge was formed by 
uplift. Quartzite 
pebbles and granite rocks at the 600-foot elevation were deposited during 
flooding events 
associated with ice age thawing periods. Small volcanic vents found along the 
ridge top and 
western slopes of Forest Park area helped deposit flows of platey basalt. 
Finally, wind and water 
influences led to the deposition of clay-like silt over the Tualatin Mountains. 
Silt deposits up to 
45-feet thick occur in the highest portions of Forest Park. The silt overlaying 
basalt is an unstable 
formation when wet. Landslides frequently occur throughout slopes covered by the 
silt when 
altered by excavation or construction.
As mapped by the Multnomah County Soils Survey (NRCS 1983), the soils in the 
Forest Park 
area are dominated by silt loams, including the Cascade silt loam and the Goble 
silt loam soil 
series and the Wauld loam series. The Cascade and Goble silt loams are poorly 
drained soils 
formed in silts with a fragipan (brittle subsurface soil horizon) at about 60 
inches below ground 
surface. Runoff from the Cascade silt loams ranges from slow to medium speed, 
and the erosion 
hazard ranges from slight to high. Runoff from the Goble silt loams ranges from 
medium to rapid 
speed, and the erosion hazard ranges from moderate to high. The Wauld loam 
series is 
characterized as well-drained soils formed from weathered basalt. Runoff from 
the Wauld loam 
series ranges from aslow to medium speed, and the erosion hazard ranges from 
slight to high. 
The Cascade and Goble silt loams and the Wauld loam series are generally suited 
for growing 
Douglas fir.

Powell Butte Nature Park
Powell Butte was formed by basaltic flows and pyroclastic rocks of local origin 
known as Boring 
lava. Boring lava is composed primarily of basaltic flow rocks but locally 
contains cindery 
pyroclastic rocks. Powell Butte itself is a mound-shaped area with moderately 
steep, forested 
sides in its lower half, slightly sloped sides in its upper half, and a nearly 
level, grass-covered 
top. The park ranges in elevation from approximately 250 feet to 612 feet above 
sea level.
The soils in the Powell Butte Nature Park area are primarily loams and silt 
loams including the 
Multnomah silt loam, the Quatama loam, and Latourell loam soil series.  The 
Multnomah silt 
loams are well-drained soils formed in stratified gravelly or cobbly alluvium. 
Runoff from the 
Multnomah silt loams ranges from slow to rapid speed, and the erosion hazard 
ranges from slight 
to high. 
The Quatama loams are characterized as moderately well drained soils formed on 
short 
escarpment fronts of low terraces.  Runoff from the Quatama silt loams ranges 
from slow to 
medium speed and the erosion hazard ranges from slight to high. The Latourell 
loams are 
characterized as well-drained soils formed on broad terraces found in alluvium.  
Runoff from the 
Latourell silt loams ranges from slow to medium speed and the erosion hazard 
ranges from slight 
to high.

Willamette Bluffs Escarpment
The Willamette Bluffs Escarpment is located on the east side of the Willamette 
River and is 
defined by two separate segments, the South Bluff and North Bluff areas. An 
escarpment is 
defined as a long cliff or steep slope separating two comparatively level 
surfaces of differing 
heights resulting from erosion or faulting. The Willamette Bluffs are 
escarpments formed when 
the Troutdale and Missoula flood deposits were incised by the river channel 
during the last 
glacial period. As sea levels dropped during glaciation, the river cut downward 
from its previous 
elevation, which corresponded with the top of the bluffs. The bluffs are steep, 
exceeding 35 
percent slopes and range in elevation from 50 to 100 feet in the south segment 
and 20 to 150 feet 
in the north segment. The area targeted for fuels reduction in the south and the 
north segments 
includes the vegetated escarpment as well as the adjacent plateau on its high 
side. The South 
Bluff Wildfire Hazard Target Area does not include the adjacent Oaks Bottom 
Wildlife Refuge, 
a Portland city park comprised of floodplain, wetlands, and open water. 
The soils in the Willamette Bluffs Escarpment formation are dominated by the 
Haploxerolls-
steep soil series. The Haploxerolls-steep soils range from moderate to well 
drained and are 
formed on long, narrow escarpments including those at the junction of terraces 
with bottomlands 
and flood plains along major streams and rivers.  Runoff from the Haploxerolls-
steep soils 
ranges from medium to rapid speed, and the erosion hazard ranges from moderate 
to high. These 
soils are subject to slumping and sustain drought-tolerant plants. 
Other soils within the South Bluff Wildfire Hazard Target Area include the Urban 
Land-
Latourell complex, 0 to 3 percent slopes. This soil series is found at the top 
and to the east of the 
escarpment. This is a well-drained soil with slight erosion hazard and is often 
disturbed and 
covered by concrete and asphalt.   
Soils adjacent to the North Bluff project area are heavily urbanized. The Urban 
Land-Latourell 
complex, 0 to 3 percent slopes is found at the top and to the east of the North 
Bluff. This is a 
well-drained soil with slight erosion hazard and is often disturbed and covered 
by concrete and 
asphalt. 

4.2.3	Environmental Consequences:
Alternative 1 - No Action  
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel loads 
in target areas of Portland's wildland-urban interface.  No impacts to soil 
resources within the 
three project areas would be expected, except for impacts associated with a 
catastrophic fire. 
These impacts may include de-vegetation caused by uncontrolled fire and 
subsequent soil erosion.  
Alternative 2 - Proposed Action
Fires of varying intensities may alter the physical, chemical, and biological 
properties of the soil 
as a result of vegetation removal, organic consumption, and increased 
temperatures.  In addition, 
the lack of fire may alter the soil properties as a result of limited nutrient 
cycling in fire 
maintained habitat areas.  
No environmental consequences to soils are expected from fuels reduction 
activities in the three 
natural areas because the activities would not require leveling of the soil.  
Mechanical removal 
activities would be limited to the use of chainsaws, weed cutters, and polaskis 
and would not 
include heavy equipment. By avoiding vegetation removal of overly large areas at 
a given time 
and employing best management practices for erosion control, vegetation removal 
activities 
would not result in increased turbidity in streams and increased erosion of 
stream banks. 
Occasional jackpot and spot burns would not occur on steep slopes and would not 
be expected to 
have consequences to soils over the long term.  No soils would be removed.     
Direct, indirect, and cumulative effects to soil productivity, fertility, 
stability, or infiltration 
capacity would be at or below the lower levels of detection.  Any effects to 
soil productivity or 
fertility would be slight, and no long-term effects to soils would occur.

4.3	FLOODPLAINS
Forest Park and the Willamette Bluffs Escarpment are adjacent to the Willamette 
River 
floodplains and Powell Butte is adjacent to the Johnson Creek floodplain. A 
large portion of the 
South Bluff is comprised of the 141-acre Oaks Bottom National Wildlife Refuge 
and is located 
within the Willamette River floodplain. However, the Wildfire Hazard Target 
Areas for each of 
these project areas does not include the adjacent floodplains.  The Oaks Bottom 
area is also not 
included, as part of the South Bluff Wildfire Hazard Target Area because no 
project related 
activities would take place in these areas.  See Appendix C for the Floodplain 
Management 
Checklist for each project area. 

4.3.1	Environmental Consequences:
Alternative 1 - No Action 
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel loads 
in target areas of Portland's wildland-urban interface.  No impacts to 
floodplains adjacent to the 
three natural areas would be expected with the No Action Alternative. 
Alternative 2 - Proposed Action
No environmental consequences related to floodplains are expected from fuels 
reduction 
activities in the three natural areas because the activities do not require 
soil-leveling or large-
scale removal of vegetation that would result in changes to the adjacent 
floodplain contours or 
elevations.  No direct, indirect, or cumulative impacts to floodplains are 
anticipated. 

4.4	WETLANDS AND WATER RESOURCES
Forest Park
The National Wetland Inventory (NWI) shows mapped streams but no wetlands for 
Forest Park 
(NWI 2004). This is likely due to the steep slope of the Forest Park landscape 
and the well-
drained characteristics of many of its soils. The mapped streams are generally 
intermittent except 
for a few perennial streams, including Balch Creek. Although Forest Park streams 
drain to the 
Willamette River, existing culverts prohibit fish passage. 
Powell Butte Nature Park
Although a forested wetland area is mapped by the NWI to the east of Powell 
Butte, no wetlands 
or other waters are mapped on Powell Butte itself. There are few perennial 
streams, likely a 
result of the sloped landscape and the well-drained soils on-site. An 
intermittent stream flanks 
the southwest side of Powell Butte, draining to the ground at the base of the 
butte. No 
hydrological connection exists between Powell Butte and Johnson Creek, which is 
situated in the 
lowlands to the southeast and south of the butte.   
Willamette Bluffs Escarpment
The escarpment portion of the Willamette Bluffs project area for both the north 
and south 
segments are too steep and well drained to form wetlands and streams. A 
seasonally flooded, 
scrub-shrub wetland is mapped by the NWI to the southwest of Mocks Crest in the 
North Bluff 
segment; however, this area is not within the Wildfire Hazard Target Area. The 
Oaks Bottom 
Wildlife Refuge to the east of the escarpment in the southernmost portion of the 
South Bluff 
includes wetlands and a deepwater pond; however, the Oaks Bottom area including 
the wetlands 
and pond is outside of the Wildfire Hazard Target Area.  

4.4.1	Environmental Consequences: 
Alternative 1 - No Action 
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.  No impacts to water 
resources within the 
Willamette Bluffs Escarpment would be expected, except those impacts associated 
with a 
catastrophic fire. These impacts may include a loss of vegetation due to 
uncontrolled fire and 
subsequent soil erosion, both of which would impact the water quality of streams 
in Forest Park 
and the wetlands and pond within the Oaks Bottom Wildlife Refuge adjacent to the 
South Bluff 
area. 
Alternative 2 - Proposed Action
No environmental consequences are expected to occur in the wetlands and 
waterways within and 
contiguous with the three natural areas. Manual, mechanical, and chemical 
vegetation removal 
would be avoided in wetlands and would be conducted to avoid increased turbidity 
in streams. In 
steep areas requiring vegetation management, soil disturbance would not be  
expected from 
vegetation control activities; however, best management practices (BMPs) for 
erosion control 
would be used if necessary. These BMPs would include the use of straw bales and 
silt fences to 
prevent sediment transport and the seeding of disturbed areas with native 
erosion control seed 
mixes until native plants can be installed. Environmental consequences from 
occasional jackpot 
burns would not be expected because they would occur away from wetlands and 
drainages. 
Changes in water quality would be either non-detectable or, if detected, would 
be considered 
slight and localized.  Therefore, impacts should be considered negligible for 
water quality and 
quantity.  

4.5	VEGETATION

4.5.1	Forest Park
Forest Park is comprised of a varied and evolving forest ecosystem. In the mid-
1800s, vegetation 
in Forest Park consisted of mixed-conifer forest (Darling 2005) with 
approximately 48% of the 
forest burned and containing scattered trees that survived the various fires. 
Dominant tree species 
included Douglas fir, western hemlock, western red cedar, grand fir, big leaf 
maple, Pacific yew, 
dogwood, Oregon white oak, and red alder. Forest Park had an under-story 
dominated by 
deciduous species including hazel and vine maple, young conifers, and herbaceous 
species such 
as bracken fern. Currently, the same over-story species can be found in the park 
but in different 
distributions. Generally, conifer forest dominates the northern segment, and 
deciduous forest is 
more common in the southern portion. A mixed conifer-hardwood forest dominates 
the central 
portion. Many areas have under-story vegetation that includes native species 
such as sword fern, 
salmonberry, and Oregon grape, but invasive species such as English ivy and 
English holly 
currently dominate the under-story, especially the south portion of the park. 
Other areas, 
particularly those cleared around power lines are dominated by Himalayan 
blackberry. Many of 
the most common invasive species in Forest Park are highly flammable and include 
such species 
as the Himalayan blackberry, Scotch broom, and English hawthorn. In addition, 
decades of fire 
suppression in the park have resulted in congested under-stories ("dog hair" 
thickets) and ladder 
fuels, which are combustible fuels that provide vertical continuity between the 
ground fuels and 
the tree canopy fuels. Portland's largest wildland interface fire in the last 
century occurred in 
1951, charring 2,500 acres in and around Forest Park. Several other small fires 
have occurred in 
Forest Park in recent years. 

4.5.2	Environmental Consequences (Forest Park):
Alternative 1 - No Action 
As new development occurs within the wildland urban interface (fire-prone 
areas), the risk of 
wildfire and Portland's associated loss rate would likely multiply unless the 
City increases its 
mitigation efforts (City of Portland 2005). Factors contributing to the highest 
fire risk include 
combinations of steep topography, narrow roads with few connecting streets, 
inadequate water 
supply in older neighborhoods, dense development, fuel loads, and buildings 
lacking defensible 
space (clearings between wildland vegetation and structures). Under the No 
Action Alternative, 
FEMA would not provide funding to reduce urban fuel load in target areas of 
Portland's 
wildland-urban interface.  Increased invasive species creating an increased fuel 
load, resulting in 
an increased fire risk, would be expected. 
Alternative 2 - Proposed Action
The integration of prescribed fire and manual/mechanical vegetative treatment 
would result in a 
minor loss of individual native plants. Various disturbances, as a result of the 
work crews, 
jackpot burning, removal of individual trees, and hard thinning/limbing would 
result in localized, 
direct, minor effects to native plant communities.  However, thinning is 
generally desirable and 
promotes reduction of overstocked under-story trees and shrubs.  Spot and 
jackpot burning would 
result in some beneficial effects as nutrients are released into the soil.  
Most native plant species have adapted to the effects of periodic surface fires; 
thus, prescribed 
fires would produce similar beneficial impacts to these plant communities while 
reducing the 
invasive species. 
Changes in vegetative community or species population would be measurable, with 
small and 
localized effects to a relatively minor proportion of any native species 
population.  These effects 
would be considered short term. 
The City of Portland has graphically depicted demographic information and 
building stock data 
over hazardous and forested areas to calculate potential loss using FEMA's loss 
estimation 
software, HAZUS-MH. The City has developed Wildfire Hazard Target Areas as 
determined by 
weather, topography, natural vegetative fuels, and fuel distribution. Analysis 
of the information 
could lead to a greater success in targeting mitigation efforts and reducing the 
risk of urban fire 
scenarios.  Education as part of mitigation efforts would increase home and 
business owners' 
awareness of the risks and would provide them with alternatives for reducing 
those risks. 
Using prescribed fires, in combination with the use of manual/mechanical 
vegetative treatments, 
would benefit natural resources and the ecological system as a whole.    

4.5.3	Powell Butte Nature Park 
The vegetation in Powell Butte Nature Park includes a mixed conifer-deciduous 
forest 
community on the lower slopes with an over-story dominated by red alder, big 
leaf maple, 
western red cedar, and Douglas fir. Most of the under-story on Powell Butte 
contains non-native 
invasive species, and in some areas, a very high percentage of the under-story 
is comprised of 
invasive species, especially Himalayan blackberry, English hawthorn, and English 
holly. The 
midslope vegetation is comprised of a shrub community dominated by native red 
alder and non-
native invasive Himalayan blackberry, Scotch broom, and English hawthorn. 
Various grasses 
including native red top grass and non-native tall fescue and velvet grass 
dominate the 
herbaceous layer in this community. The upper slopes of Powell Butte are 
comprised of 
grasslands dominated by red top, tall fescue, and velvet grass with occasional 
shrubs including 
non-native invasive Himalayan blackberry and English hawthorn.  In part due to a 
build-up of 
highly flammable invasive species, Powell Butte Nature Park has experienced 
several small fires 
since 1998. Two 3-alarm fires, affecting 35 acres of parkland required more than 
70 firefighters 
and two-dozen pieces of firefighting equipment.

4.5.4	Environmental Consequences (Powell Butte Nature Park):
Alternative 1 - No Action 
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.  Increased invasive plant 
species creating an 
increased fuel load, resulting in an increased fire risk, would be expected.
Alternative 2 - Proposed Action
Minimal environmental consequences to native vegetation would be expected from 
fuels 
reduction activities in the Powell Butte Nature Park. Continued manual, 
mechanical, and 
chemical vegetation removal would be expected to decrease the presence of highly 
flammable, 
non-native, invasive species, and therefore, would reduce the risk of wildfire. 
Occasional jackpot 
burns would not be expected to have negative consequences for native vegetation 
communities.
Changes in native vegetative or species population would be measurable, with 
small and 
localized effects to a relatively minor proportion of any species population.  A 
reduction in 
invasive species could be considered a beneficial effect to the native 
populations.

4.5.5	Willamette Bluffs Escarpment
Approximately half of the South Bluff area of the Willamette Bluff Escarpment 
was historic 
floodplain, and vegetation was comprised of a mixed deciduous riparian forest 
dominated by 
Oregon ash, red alder, black cottonwood, white oak, and small quantities of 
conifers. Savanna 
and Douglas fir and a white oak woodland community dominated the steep bluff 
portion.   
Currently, the vegetation in historic floodplain areas includes mixed forb-
grassland and shrub 
community dominated by Himalayan blackberry. Wetlands are dominated by non-
native reed 
canary grass. The escarpment is vegetated in some areas with deciduous forest 
containing an 
under-story dominated by English ivy. The South Bluff Escarpment slopes are 
currently 
dominated by non-native invasive species including Himalayan blackberry, big 
leaf periwinkle, 
English ivy, Scotch broom, and evergreen clematis.  
The steep bluff portion of the North Bluff Escarpment was historically described 
as mixed 
conifer forest with mostly deciduous under-story (Darling 2005). The dominant 
communities 
included Douglas fir, western hemlock, western red cedar, grand fir, big leaf 
maple, Pacific yew, 
white oak, and red alder. Portions were described as burned Douglas fir forest.  
Currently, the 
under-story and non-forested areas of the North Bluff are dominated by non-
native invasive plant 
species.  A typical plot in the Mocks Crest area of the North Bluffs is 
currently comprised of a 
severely degraded, deciduous woodland community with approximately 35% over-
story of big 
leaf maple and an under-story comprised of 50% Himalayan blackberry and 50% 
clematis. The 
North Bluffs include a forty-acre area burned in 2001 and replanted with native 
grasses, with 
native oak savannah being the desired plant community. Other areas lack tree 
canopy and are 
dominated by Himalayan blackberry and other invasive species including English 
ivy and 
Japanese knotweed.
Portland's largest, recent, wildland-urban interface fire occurred in August 
2001 in the north 
portion of the Willamette Bluffs known as Mocks Crest. The Mocks Crest fire 
started when grass 
ignited along the railroad tracks situated in the floodplain between the bluffs 
and the Willamette 
River. It ignited the brushy fuels of the bluffs, aided by the steep topography 
and solar heating of 
the southwest facing slopes of the bluffs. The 5-alarm fire resulted in very 
little structural 
damage, but the City was faced with numerous expenses related to fire 
suppression, erosion 
control, and re-vegetation.  The following year, a 2-alarm fire ignited in the 
vegetative fuels of the 
Willamette Bluffs, in close proximity to the location of the 2001 fire.   

4.5.6	Environmental Consequences (Willamette Bluffs Escarpment):
Alternative 1 - No Action 
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.  Increased invasive plant 
species creating an 
increased fuel load, resulting in an increased fire risk, would be expected. 
Alternative 2 - Proposed Action 
No environmental consequences to native vegetation are expected from fuels 
reduction activities 
in the Willamette Bluffs Escarpment.  Continued manual, mechanical, and chemical 
vegetation 
removal in select areas would be expected to decrease the presence of highly 
flammable, non-
native, invasive species; therefore, would reduce the risk of wildfire. Changes 
in native 
vegetative communities or species population would be measurable, with small and 
localized 
effects to a relatively minor proportion of any species population.

4.6	BIOLOGICAL RESOURCES
A comprehensive list of the wildlife species found in Portland includes 797 
species of birds, 
mammals, reptiles, and amphibians. In particular, because of its large size and 
forest habitat, 
species found in Forest Park include large mammals such as Roosevelt elk, black-
tailed deer, 
mountain lion, and bobcat.  Species specific to each geographic area are 
described in further 
detail in the sections following. 

4.6.1	Federally Listed Species and Critical Habitat
A list of federally endangered and threatened species (and species proposed for 
threatened or 
endangered status) with the potential to occur in the Wildfire Hazard Target 
Areas  was obtained 
from the USFWS on October 28, 2005. In addition, an Oregon Natural Heritage 
Information 
Center (ORNHIC) data system search of occurrence records was prepared that 
included federally 
listed species and other special-status species (September 7, 2005). Fisheries 
biologists with 
National Marine Fisheries Service (NMFS) and the Oregon Department of Fish and 
Wildlife 
(ODFW) were contacted to verify salmonid and critical habitat presence in the 
Wildfire Hazard 
Target Areas.  Isaacs and Anthony's "Bald eagle nest locations and history of 
use in Oregon and 
the Washington portion of the Columbia River Recovery Zone, 1972 through 2001" 
was also 
referenced.  According to these inventories, the only federally listed species 
that may be found 
within the proposed project areas were bald eagles and salmonids. 

4.6.1.1	Bald Eagle

Willamette Bluffs Escarpment
The bald eagle (Haliaeetus leucocephalus) is protected as both a state and 
federal threatened 
species in Oregon, although as a result of successful recovery efforts, USFWS 
has proposed 
delisting it (64 FR 36454-36464 in Federal Register). Prey availability, 
suitable nesting habitat, 
and disturbances from human activities including construction are considered 
important factors 
affecting bald eagle productivity and survival. Human activities near nest sites 
during the nesting 
season can disturb eagles and lead to nest abandonment or reduced reproductive 
success. 
Potentially suitable nesting, roosting, and foraging habitats are abundant 
within the Willamette 
River and Columbia River corridors. The nearest active nest is approximately 
0.25 mile from the 
South Bluff Fire Management Zone on Ross Island, which is located just west of 
the South Bluff 
area. This alternative nest site, which was first documented in 2004, is 
associated with a pair that 
has been nesting on the island since 1996 at two other nest sites. In 2005, the 
Ross Island pair 
successfully fledged two eaglets (Isaacs 2006). USFWS management guidelines 
recommend a 
minimum 0.5-mile buffer from active bald eagle nests if the nest is visible from 
the project limits 
or a 0.25-mile buffer if the nest is not visible from the project. The Ross 
Island nest is not within 
the project line-of-sight as it is visually buffered from the project limits by 
a stand of mature 
cottonwoods.  

4.6.1.2	Salmonids

Powell Butte Nature Park
While there are no federally listed fish species in the Powell Butte Wildfire 
Hazard Target Area, 
Johnson Creek, situated in the lowlands to the southeast and south of the butte, 
supports a 
number of anadromous fish stocks.  Johnson Creek is listed for spawning/rearing 
for Lower 
Columbia River (LCR) Coho salmon (Oncorhynchus kisutch), rearing/migration for 
LCR 
Chinook (O. tshawytscha), and spawning/rearing/migration for LCR steelhead (O. 
mykiss) 
populations (Fellas 2005).  NOAA Fisheries also announced its final critical 
habitat designations 
for 19 evolutionarily significant units (ESU) on August 12, 2005 that included 
Johnson Creek. 
Critical habitat will become effective January 2, 2006. While the Powell Butte 
Wildfire Hazard 
Target Area is adjacent to the floodplain of Johnson Creek, it is not within the 
Johnson Creek 
floodplain and no hydrological connection exists between Powell Butte and 
Johnson Creek. 
Forest Park
Balch Creek, McCarthy Creek, and Saltzman Creek flow through Forest Park in 
Portland and 
enter the Willamette River on the west bank. Miller Creek also flows through 
Forest Park but 
enters Multnomah Channel, which flows from the Willamette River into the 
Columbia River.  
Balch Creek supports a population of cutthroat trout that has been isolated in 
the stream by a 
culvert installed at Lower Macleay Park in the early 1920s, but anadromous fish 
presence is 
limited due to the stream being piped underground beneath a major industrial 
area. McCarthy 
Creek is listed as spawning/rearing/migration for LCR Coho.  Saltzman Creek also 
supports a 
population of cutthroat trout, but a cement canal on Saltzman Creek below 
Highway 30 acts as 
an impassable barrier to fish movement.   Coho salmon, steelhead, Chinook, 
cutthroat trout, and 
lamprey have been identified in Miller Creek below the culvert at Marina Way, 
but cutthroat is 
the only species found above the culvert. 

4.6.1.3	Migratory Birds

The Wildlife Hazard Target areas provide habitat for a variety of migratory 
birds including 
songbirds and birds of prey. The USFWS Office of Migratory Bird Management 
maintains a list 
of migratory birds (50 CFR 10.13). The Migratory Bird Treaty Act (MBTA) of 1918, 
as 
amended, provides federal protections for migratory birds, their active nests, 
eggs, and parts 
from harm, sale, or other injurious actions; the MBTA has no take provision. 
Fuels reduction 
activities such as vegetation removal and selective burning have the potential 
to directly and 
indirectly affect migratory birds. However, potentially negative impacts to 
migratory birds can 
be eliminated or greatly reduced by avoiding fuels reduction activities during 
the most sensitive 
portion of the breeding season (early March through July). If seasonal 
restrictions are not 
practicable, a pre-construction survey to identify active nests should be 
conducted by a qualified 
biologist prior to any disturbing activities.

4.6.2	Environmental Consequences:
Alternative 1: No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.  The No Action Alternative 
would not 
conduct vegetation management activities, and therefore, would not directly 
impact proposed or 
listed threatened and endangered species and their habitat in the Wildfire 
Hazard Target Areas. 
However, the potential for losses of listed species due to wildfire would 
remain. Native plant and 
wildlife species would not benefit from the selective reduction of non-native 
vegetation.  Also, 
uncontrolled wildfires have the potential to burn at a greater intensity than a 
prescribed fire. 
Therefore, future uncontrolled wildfires could result in adverse impacts to 
wildlife through the 
loss of habitat and/or the mortality of individuals. 
Alternative 2: Proposed Action
While some habitat would be affected by the Proposed Action Alternative 
activities, the 
activities are not anticipated to have long-term, adverse effects for listed 
species. Impacts to 
native fish and wildlife would be detectable, but would not be expected to 
exceed the natural 
range of variability, and long-term effects to native species, their habitats, 
or the natural 
processes sustaining them would not be expected.   Ecosystem processes and 
species habitat 
could have minor disruptions but no long-term impacts that would be considered 
outside natural 
variations. 
An analysis of effects of the proposed action a "Letter of No Effect" determined 
that the 
Proposed Action Alternative would have no detectable effect on bald eagles.

4.7	ESSENTIAL FISH HABITAT
Essential Fish Habitat (EFH), established under the Magnuson-Stevens Fishery 
Conservation and 
Management Act (MSA), includes those waters with substrate necessary to ensure 
the production 
needed to support a long-term sustainable fishery (i.e., properly functioning 
habitat conditions 
necessary for the long-term survival of the species through the full range of 
environmental 
variation). EFH includes all streams, lakes, ponds, wetlands, and other water 
bodies currently, or 
historically, accessible to salmon in Washington, Oregon, Idaho, and California. 
Three salmonid 
species are identified under the MSA: Chinook salmon, Coho salmon, and Puget 
Sound pink 
salmon. Johnson Creek (Powell Butte Nature Park) is listed as spawning/rearing 
ground for 
Lower Columbia River (LCR) Coho salmon (Oncorhynchus kisutch) and 
rearing/migration 
ground for LCR Chinook (O. tshawytscha) populations.  McCarthy Creek (Forest 
Park) is listed 
as spawning/rearing/migration ground for LCR Coho. 

4.7.1	Environmental Consequences:
Alternative 1: No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface, and therefore, this 
alternative would not 
adversely affect essential fish habitat.  
Alternative 2: Proposed Action
Implementation of the projects covered in this EA would not adversely affect 
essential fish 
habitat. These projects would not have any negative, long-term effect on water 
or the substrate 
essential for Coho or Chinook salmon that inhabit the watersheds where the 
proposed projects 
would take place.

4.8	HISTORIC, ARCHAEOLOGICAL AND CULTURAL RESOURCES

4.8.1	Historic Resources
A search for historic resources within the three Wildfire Hazard Target Areas 
identified only those 
associated with Forest Park.  No historic resources were found within the 
Willamette Bluffs 
Escarpment, or Powell Butte.  The Pittock Mansion and associated Gate Lodge, are 
located in the 
southeast portion of Forest Park within the Wildfire Hazard Target Area; 
however, these structures 
are situated within a large designated buffer ("no burn area") surrounding the 
site (see Appendix B, 
Site Map). Pittock Mansion and Gate Lodge are listed in the National Register of 
Historic Places for 
their association with Henry and Georgiana Pittock, prominent Oregon pioneers.  
Henry Pittock 
became the owner of The Oregonian Newspaper in 1860 and, over 30 years, built 
the business into 
the principal regional newspaper.  Henry Pittock married Georgiana Martin Burton 
in 1860.  An 
Oregon Trail pioneer in 1852, Georgiana became a leader in social affairs and 
worked towards 
improving the lives of women in Portland by establishing the Ladies Relief 
Society.
The Pittocks moved into the mansion in 1914.  The well-known architect Edward T. 
Foulkes 
designed the house in the French Renaissance style.  Foulkes incorporated the 
latest state-of-the-arts 
technologies in the house, using concrete with a sandstone veneer for the walls, 
and stone, plaster, 
and wood paneling throughout the interior.  Other innovations included electric 
service and wiring in 
steel conduit, a forced air heating system, private elevator, kitchen 
refrigeration system, a telephone 
and intercom system, and a central vacuum-cleaning system.  
Foulkes also designed the gatehouse, which was finished in 1914.  The four-story 
house was 
carefully designed to utilize the steep hill where it was located and was 
designed so that the 
caretakers could control access to the grounds.  After the City purchased the 
property in 1977, 
restoration of the Gate Lodge began, and a Tea Room was opened in the building 
in 1984.
The Pittocks only enjoyed their mansion for a few years before their deaths in 
1918 and 1919 
respectively.  The Pittock's children remained in the residence until 1958 when 
they put the estate on 
the market.  The threat of demolition caused local citizens to raise funds in 
order to save the site; in 
1964, the City purchased the estate, and the house and grounds were opened to 
the public as a 
museum in 1965.  The Pittock Mansion Society was formed to aid in the 
preservation, operation, and 
restoration of the estate. 

4.8.2	Environmental Consequences:
Alternative 1 - No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.   Protection action and 
activities would 
continue for Pittock Mansion, regardless of FEMA funding.  The City has already 
identified 
evasion actions and has implemented these actions to protect and maintain the 
cultural and 
historical integrity of Pittock Mansion. Without these actions, the 
vulnerability of the Mansion to 
catastrophic wildfire also increases.    
Alternative 2 - Proposed Action
Based on the information provided, it is the finding of FEMA that the project 
will have a no effect on 
the property.  Concurrence with this finding is being requested from the Oregon 
State Historic 
Preservation Office (SHPO).  This "Finding of Effect" is made pursuant to the 
requirements of 
Section 106 the National Historic Preservation Act (NHPA) of 1966 (36 CFR 800), 
Executive Order 
11593, and NEPA.  The Portland Urban Fuels Reduction project would minimally 
affects the Pittock 
Mansion because of its location in the southeast corner of Forest Park and the 
type of fuel reduction 
tasks proposed as part of the project.  
The City is very aware of the significance of the Pittock Mansion and has 
outlined mitigation 
measures that will assure that the mansion and grounds will not be affected by 
the proposed fuel 
reduction project.  The City has:
	Delineated a no burn area around the Pittock Mansion that measures 
approximately 1/2 mile 
North South and 3/4-mile East West (Figure 2).  There will be no controlled 
burns in this area. 
	Isolated controlled burns to small areas (purple hexagons on Figure 1); 
the nearest one is about 
3/4-mile away from the mansion.  These areas would have spot or jackpot burns in 
degraded oak 
habitats and be heavily monitored.  These controlled burns would be planned for 
the third year of 
the project, and may change as the planning and modeling phases are developed in 
the first two 
years of the project.  
	Other areas outlined on the Wildfire Mitigation Tasks are over 1 1/2 -
miles away and would not 
affect the mansion.  The fuels reduction projects would be located in small 
isolated areas; the 
remaining fuel reduction tasks would not affect the mansion since the projects 
utilize non-burn 
removal techniques.  
Pursuant to 36 800.5(a)(2), application of the Criteria of Adverse Effect 
resulted in a finding of "No 
Historic Properties Adversely Affected."  Therefore, it is FEMA's determination 
that the proposed 
Portland Urban Fuels Reduction Project as it relates to the area in Forest Park 
would not adversely 
affect the Pittock Mansion and grounds, a National Register of Historic Places 
listed property 
(1974).    

4.8.3	Archaeological and Cultural Resources
A search of archeological records was recently conducted at the SHPO in Salem 
for the area of 
potential effect, which consists of the Wildfire Hazard Target Areas for the 
three project areas 
(see Appendix B). The search provided information related to the amount of 
previous survey 
coverage and/or previously recorded archaeological sites in the Wildfire Hazard 
Target Areas.  
Results of the search provide a basis for recommendations regarding the level of 
effort that will 
be required for the proposed project.  
The current archaeological database shows that no previous archaeological 
inventories have been 
conducted within the Willamette Bluffs or Powell Butte areas of the Urban Fuel 
Load Reduction 
Project.  A small linear survey had been conducted along the southern portion of 
the Forest Park 
area, as related to a survey of the Balch Creek watershed (Ricks and White 
1996).  No cultural 
resources were recorded as a result of this effort; however, the survey only 
overlaps a small 
portion of the Forest Park project area.
One archaeologically sensitive area was identified during a review of maps on 
file at the SHPO. 
An "Indian Camp" is currently identified on the east side of the Willamette 
River near Ross 
Island and falls within the northernmost portion of the South Bluff area of the 
Willamette Bluffs 
project component.  The site has not been formally recorded, and record of its 
existence is based 
entirely upon notes taken by the previous SHPO archaeologist.  However, this 
area should be 
considered to have a high probability to contain archaeological deposits.
No Tribal consultation has taken place other than involvement with the ongoing 
projects.  The 
City is not aware of any local Tribal entities with treaty and/or jurisdictional 
interests in the 
projects.  The EA will be sent to the Columbia Intertribal Council for their 
review and comment 
prior to finalizing.  

4.8.4	Environmental Consequences:
Alternative 1: No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface. Under this alternative, 
there would be a 
continued increase in fuel loading and invasive plants over time.  The effects 
of an unplanned, 
higher intensity ignition could be extensive because of the increased and 
elevated level of heat 
that would penetrate into subsurface sites and the extensive suppression 
activities that have been 
conducted.  Archaeological resources would be at risk from fire, suppression 
activities, and the 
buildup of fuels.  
There is the possibility that fire or use of equipment could expose previously 
unknown sites or 
artifacts that have been obscured by vegetation or forest litter, which could be 
viewed as a 
benefit.  However, runoff and erosion after the fire could displace these 
artifacts from their 
historic or prehistoric context, causing loss of site integrity.  Adverse, 
indirect impacts could also 
occur if unauthorized collecting occurred following a fire.  Rehabilitation of 
burned areas could 
also disturb the site or cause loss of site integrity.
Alternative 2 - Proposed Action
The implementation of the proposed activities does not include any substantial 
ground disturbing 
activities or large scale burning.  Archaeological surveys would need to be 
conducted to protect 
undiscovered cultural or archeological resources and mitigation measures would 
need to be 
implemented for tree removal, round disturbing and burn activity sites within 
the Wildfire 
Hazard Target Areas. Monitoring would only need to be conducted in any high 
probability areas 
identified in the archaeological surveys. Based on the maintenance and planning 
nature of the 
activities planned for the next three years, impacts would be expected at the 
lowest levels of 
detection - barely measurable with no perceptible consequences, either adverse 
or beneficial, to 
archaeological resources.  For purposes of Section 106, the determination of 
effect would be no 
adverse effect. 

4.9	HAZARDOUS WASTES AND MATERIALS
Hazardous materials and toxic wastes are managed under state and federal 
permitting 
requirements for staging, handling, storage, treatment, and disposal. The 
Resource Conservation 
and Recovery Act (RCRA) would regulate any hazardous wastes encountered. The 
objective of 
RCRA is to prevent release and impacts from hazardous materials to human health 
and the 
environment.

4.9.1	Environmental Consequences:
Alternative 1: No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface. The No Action alternative 
would not disturb 
any hazardous materials or create any potential hazard to human health. 
Alternative 2 - Proposed Action
The implementation of the proposed activities would not include any ground 
disturbing activities 
and would not disturb any hazardous materials or create any long-term potential 
hazard to human 
health. If hazardous constituents are unexpectedly encountered in the project 
area during 
construction operations, appropriate measures for the proper assessment, 
remediation, and 
management of the contamination would be initiated in accordance with applicable 
federal, state, 
and local regulations. The contractor would take appropriate measures to 
prevent, minimize, and 
control the spill of hazardous materials in the construction staging area, 
according to the 
specifications of applicable permits required for the project.

4.10	SOCIOECONOMIC AND ENVIRONMENTAL JUSTICE (EO 12898)
Executive Order (EO) 12898, Environmental Justice, directs federal agencies to 
identify and 
address, as appropriate, disproportionately high and adverse human health or 
environmental 
effects on minority and low-income populations in the United States resulting 
from federal 
programs, policies, and activities. The No Action Alternative and Proposed 
Action Alternative 
are both located within the town limits of Portland. Socioeconomic and 
demographic data for 
residents in the project vicinity was studied to determine if a disproportionate 
number (defined as 
greater than 50 percent) of minority or low-income persons have the potential to 
be affected by 
the alternatives. 
PPR is committed to maintaining the highest standards of respect for the dignity 
of every 
individual.  Everyone is welcome in parks, including the homeless.  Regardless 
of circumstance, 
everyone may use the park and recreation facilities as long as they conduct 
themselves lawfully 
and according to the established Recreation Code of Conduct.  
Pursuant to City Code 14A.50.020 - Camping on Public Property, and 20.12.210 - 
Park Closure 
Hours, PPR does not allow camping or overnight sleeping in city parks, natural 
areas, or PPR 
recreational facilities.  Despite these prohibitions, and while PPR supports 
enforcement of these 
laws as a matter of health and safety for everyone in the community, on any 
given night, many 
people sleep overnight or camp on PPR property.   For this reason, PPR works 
with the City of 
Portland to provide skilled homeless outreach workers, addiction services, 
mental health 
outreach workers, and other social service providers. In addition, PPR provides 
information 
about temporary shelter and other resources. Park maintenance employees often 
have contact 
with homeless persons in parks providing help by reporting problems and calling 
for assistance 
as needed. Field-going employees work with Park Rangers, Police and others to 
provide 
information to individuals and help them find services that can help end their 
homelessness.
It can be expected that park maintenance activities of any sort and the 
associated enforcement of 
the "no camping" rule has the potential to compel illegal campers to move out of 
a park or into 
another part of the park.
Alternative 1 - No Action
Under the No Action Alternative, FEMA would not provide funding to reduce urban 
fuel load in 
target areas of Portland's wildland-urban interface.  Because no federal 
activity would occur, no 
requirement for compliance with EO 12898 exists.
Alternative 2 - Proposed Action
While maintenance activities of any sort within the project areas may 
inconvenience a homeless 
person or other illegal camper, a disproportionate number of minority or low-
income persons 
would not have the potential to be affected by the Proposed Action. The Proposed 
Action would 
not cause adverse economic impacts, and would be compliant with EO 12898.

Cumulative impacts are those effects on the environment resulting from the 
incremental effect of 
an action when added to past, present and reasonably foreseeable future actions, 
regardless of the 
agency (federal or nonfederal) or person that would undertake such actions. 
Cumulative effects 
can result from minor but collectively significant impacts on the human 
environment.

5.1	CUMULATIVE EFFECTS ANALYSIS 
The Council on Environmental Quality (CEQ) regulations for implementing NEPA 
requires an 
assessment of cumulative effects during the decision-making process for federal 
projects.  
Cumulative effects are defined as "the impact on the environment which results 
from the 
incremental impact of the action when added to other past, present, and 
reasonably foreseeable 
future actions regardless of what agency (federal or non-federal) or person 
undertakes such other 
actions" (40 CFR 1508.7).  Cumulative effects are considered for both the No 
Action and 
Proposed Action.  Cumulative effects were determined by combining the effects of 
the 
alternative with other past, present, and reasonably foreseeable future actions.  
The cumulative impacts associated with implementation of the proposed projects 
within the time 
frame of the Proposed Action Alternative would have no significant cumulative 
impacts because 
of their disparate locations, the limited scope of the work, and the proposed 
mitigation. Nor are 
other actions by the City at these locations expected to have any significant 
cumulative impacts 
with the vegetation management projects. Finally, the totality of the City's 
vegetation 
management projects and the other proposed actions would not have any 
significant cumulative 
impacts through the loss of any sensitive species or habitat.  There are no 
other known projects 
that, when added to the Proposed Action, would have a cumulative impact on the 
human 
environment.

FEMA is the lead federal agency for conducting the NEPA compliance process for 
the 
vegetation management project. As the lead agency, FEMA expedites the 
preparation and review 
of NEPA documents, responds to the needs of residents surrounding the park 
lands, meets the 
spirit and intent of NEPA, and complies with all NEPA provisions.
A public notice is required for this draft EA. The public will be provided an 
opportunity to 
comment on the EA for 30 days after the publication of the public notice. The 
notice identifies 
the action, location of the proposed site, participants, location of the draft 
EA, and who to write 
to provide comments. 
FEMA will review all written comments submitted for identification of any 
significant issues 
that need to be addressed and will incorporate them into the Final EA, as 
appropriate.  Public and 
agency involvement has been ongoing and City Staff have conducted several public 
meetings in 
the North Portland neighborhoods.  Educations of homeowners within the three 
geographic areas 
regarding defensible space have been ongoing.  Multiple City programs such as 
Portland Parks 
Ecosystem Management and Bureau of Environmental Services Watershed Re-
vegetation 
Program are now incorporating goals related to reducing fuel loads for fire 
hazard into 
landowner education and citizen outreach programs.  The City plans to launch a 
much larger 
public involvement effort with this program.   
Public Involvement and input into this process has been extensive and ongoing.   
A list of those 
interested parties and participants follows. 
Citywide
	Neighborhood Emergency Teams (NET)
	Forest Park vicinity (all Multnomah County unless noted)
	Arlington Heights Neighborhood Association
	Clean Water Services (Washington County)
	Friends of Forest Park
	Forest Park No Ivy League (PP&R/Friends of Forest Park)
	Forest Park Neighborhood Assoc
	Linnton Neighborhood Association
	Northwest District Association
	Northwest Heights Neighborhood Association
	Northwest Industrial Neighborhood Association
	Portland Public Schools
	Portland State University
	Skyline Ridge Neighbors (Washington County)
Powell Butte vicinity
	Centennial Neighborhood Association
	Johnson Creek Watershed Council
	Pleasant Valley Grange
	Pleasant Valley Neighborhood Association
	Friends of Powell Butte
	Portland Public Schools
	Portland State University
	Powellhurst Gilbert Neighborhood association 
Willamette Bluffs Escarpment vicinity (Oaks Bottom, Waud's Bluff & Mocks Crest)
	Arbor Lodge Neighborhood Association
	Brooklyn Action Corps (neighborhood association)
	Corbett, Terwilliger, Lair Hill Neighborhood Association
	Friends of Oaks Bottom
	Hosford-Abernathy Neighbors
	Overlook Neighborhood Association
	Portland Public Schools
	Portland State University
	Reed College
	Sellwood-Moreland Improvement League (SMILE Neighborhood Association)
	Swan Island Business Association
	Swan Island Transportation Management Alliance (TMA)
	University of Portland 
	University Park Neighborhood Association

Response to Comments: (respond to the draft environmental assessment)  

The City is required to obtain and comply with all required local, state, and 
federal permits and 
approvals prior to implementing the Proposed Action Alternative. Development at 
the Proposed 
Action Alternative sites shall be in compliance with the approved site plan. Any 
expansion or 
alteration of this use, beyond that initially approved would require a new or 
amended permit. In 
the event that historically or archaeologically significant materials or sites 
(or evidence thereof) 
are discovered during the implementation of the project, the project shall be 
halted immediately 
and all reasonable measures taken to avoid or minimize harm to property. The 
City would then 
be required to consult with FEMA and OAHP for further guidance.

The draft EA evaluated potentially significant resources that could be impacted.  
The evaluation 
resulted in identification of no significant impacts associated with the 
resources of Air Quality; 
Climate, Geology and Soils; Floodplains; Wetland and Waters; Vegetation; 
Biological (ESA), 
Essential Fish Habitat; Historic, Archaeological, Cultural; Hazardous Waste; and 
Socioeconomic 
and Environmental Justice.  Obtaining and implementing permit requirements along 
with 
appropriate BMPs will avoid or minimize any effects associated with the action.  
It is 
recommended that a finding of no significant environmental impact to the human 
or natural 
environment be issued for the Proposed Action Alternative.

City of Portland. 2000. Erosion Control Manual. Office of Planning and 
Development Review in 
Conjunction with Bureau of Environmental Services, Office of Transportation and 
Bureau of Water Works. Portland, Oregon.
City of Portland. 2005. City of Portland Pre-disaster Mitigation Grant 
Application. 
City of Portland. 2005. City of Portland Natural Hazard Mitigation Plan. Section 
11: Wildfire 
Hazards.
Darling, Joshua. 2005. Historic Vegetation Summary based on mapping of 1981 GLO 
Survey 
notes (from Oregon Natural Heritage Project 1851 vegetation data layer).
Fellas, Christina. 2005. National Marine Fisheries Service. Personal 
Communication via e-mail 
with Laura Miller, URS. September 2005.
Isaacs, F.B. Personal communication with Bridget Canty on January 5, 2006.
Isaacs, F.B. and R.G. Anthony. 2004. Bald eagle nest locations and history of 
use in Oregon and 
the Washington portion of the Columbia River Recovery Zone, 1972 through 2004. 
Oregon Cooperative Fish and Wildlife Research Unit, Oregon State University, 
Corvallis. 
31pp.
Oregon Department of Environmental Quality. 2005. Portland, Oregon, available 
online: 
http://www.deq.state.or.us/aq/aqplanning/controlareas.htm.
Portland Parks and Recreation. 2005, Portland, Oregon, available online: 
http://www.portlandonline.com/parks/
NRCS (Natural Resources Conservation Service). 1983. Soil Survey of Multnomah 
County, 
Oregon. United States Department of Agriculture.
NWS (National Weather Service). 2004, Portland, Oregon, available online: 
http://www.wrh.noaa.gov/climate/index.php?wfo=pqr.
Oregon Natural Heritage Information Center. 2005. Rare, Threatened and 
Endangered Plants and 
Animals for FEMA Pre-disaster Project. Oregon Natural Heritage Program. 
Portland, 
Oregon. 30 pp. PDF.
Ricks and White. 1996.  (To be added later)
U.S. Fish and Wildlife Service (USFWS). 1986. Recovery Plan for the Pacific Bald 
Eagle. U.S. 
Fish and Wildlife Service, Portland, Oregon.

U.S. Fish and Wildlife Service (USFWS). 1999. Proposed Delisting; Proposed Rule 
to Remove 
the Bald Eagle in the Lower 48 States from the List of Endangered and Threatened 
Wildlife. Federal Register, Vol. 64, No. 128, p. 36454.

U.S. Fish and Wildlife Service (USFWS). 2004. National Wetlands Inventory Map 
source: 
USFWS Online Data Website: http://wetlands.fws.gov/downloads.htm, Aerial Photo 
Source: Oregon Geospatial Data Clearinghouse. 
U.S. Fish and Wildlife Service (USFWS). 2005. Federally Listed and Proposed 
Endangered and 
Threatened Species, Candidate Species, and Species of Concern That May Occur in 
Multnomah County.

EXECUTIVE ORDER 11988
FLOODPLAIN MANAGEMENT - CHECKLIST (44 CFR Part 9)
                           TITLE: Urban Fuel Load Reduction in Portland, Oregon 
PROPOSED ACTION: The Scope of Work for this project includes: 
fire break and vegetation management modeling, herbicide, 
mechanical, and manual reduction in non-native vegetation 
mass, education, and prescribed fire training, and coordination.
 
APPLICABLILITY: Actions which have the potential to affect floodplains or their
occupants, or which are subject to potential harm by location 
in floodplains.

Project Conditions and Conservation Measures
General:
The applicants shall obtain all required local, state, and federal permits and 
approvals prior to implementing the Proposed Alternative and comply with any and 
all conditions imposed. The applicant is responsible for selecting, 
implementing, 
monitoring, and maintaining Best Management Practices (BMPs) to control erosion 
and sediment, reduce spills and pollution, and provide habitat protection.
Additional Conservation Measures:
Use water bars to prevent erosion of disturbed soils, as appropriate.
Whenever possible, use natural barriers to avoid unnecessary fire line 
construction.
Prior to project implementation of activities involving tree removal or ground 
disturbance, conduct an inventory of unsurveyed areas using a professional 
archaeologist 
and monitor project activities at any high probability sites discovered during 
inventory.  
Prior to removal of vegetation or other fuels reduction activities, a qualified 
biologist 
should conduct a survey to identify migratory birds and their nests OR limit 
fuels 
reduction activities to the non-breeding season.
Consider safety of personnel and the public as the highest priority for all fire 
management 
activities.
Do not initiate any fire management operations until all personnel involved 
receive a 
safety briefing describing known hazards and mitigating actions, current fire 
season 
conditions, and current and predicted fire weather and behavior.
Notify neighbors, park visitors, and local residents of all planned and 
unplanned fire 
management activities that have the potential to impact them.

PUBLIC NOTICE
PUBLIC NOTICE
Federal Emergency Management Agency (FEMA)
Draft Environmental Assessment (EA)
Urban Fuel Load Reduction in Portland, Oregon

Notice is hereby given that the U.S. Department of Homeland Security's Federal 
Emergency Management Agency (FEMA) proposes to provide funding to the city of 
Portland for an urban fuel load reduction project in Portland, Oregon.  Funding 
would be provided as  authorized by 203 of the Robert T. Stafford Disaster 
Assistance and 
Emergency Relief Act (Stafford Act), 42 USC.  

FEMA prepared a draft environmental assessment (EA) for the proposed project 
pursuant to the National Environmental Policy Act (NEPA) of 1969 and FEMA's 
implementing regulations found in 44 Code of Federal Regulations Part 10. The EA 
evaluates alternatives for compliance with applicable environmental laws, 
including 
Executive Orders #11990 (Protection of Wetlands), #11988 (Floodplain 
Management), and #12898 (Environmental Justice). The alternatives evaluated 
include (1) no action; and (2) targeting three natural areas (Forest Park, 
Powell Butte 
Nature Park, and two segments of Willamette Bluffs Escarpment) for reduction and 
management 
of fuel loads including fire break and vegetation management modeling; 
herbicide, mechanical, 
and manual reduction in non-native vegetation mass; education and prescribed 
fire training; and 
coordination efforts. 

This notice will constitute the final notice as required by Executive Order 
11988, 
Floodplain Management and Executive Order 11990, Protection of Wetlands. If no 
significant issues are identified during the comment period, FEMA will finalize 
the 
EA, issue a Finding of No Significant Impact (FONSI) and fund the project.

The draft EA is available for review on February 13, 2006 the City of Portland 
Bureau 
of Environmental Services at 1120 SW 5th Avenue, 10th Floor, Portland, Oregon.

The EA is also available for review online at the FEMA environmental website at 
FEMA's website at: http://www.fema.gov/ehp/docs.shtm.  Written comments on the 
draft 
EA should directed no later than 5 p.m. on March 14, 2006 to Mark G. Eberlein, 
Regional Environmental Officer, FEMA Region 10, 130 228th Street SW, Bothell 
Washington 98021 or by e-mail at mark.eberlein@dhs.gov.  Comments can also be 
faxed to 425-487-4622. 

TABLE OF CONTENTS
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LIST OF TERMS AND ACRONYMS
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SECTION ONE	Introduction
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SECTION TWO	Purpose and Need for Action
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SECTION THREE	Alternatives Analysis
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SECTION FOUR	Affected Environment and Environmental Consequences
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SECTION FIVE	Cumulative Impacts
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SECTION SIX	Public Involvement and Response to Comments
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SECTION SEVEN	Required Permits and Compliance
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SECTION EIGHT	Conclusion
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SECTION NINE	References
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Appendices A, B and F are not available in txt format.  Please view the HTML 
file at:  http://www.fema.gov/ehp/docs.shtm

APPENDIX A	Vicinity Map
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APPENDIX B	Site Maps
APPENDIX C	Executive Order
APPENDIX D	Project Conditions and Conservation Measures
APPENDIX E	Public Notice
APPENDIX F	Finding of Effect Section 10 NHPA