Environmental Assessment
Monte Cristo Grade Road Bridge

Snohomish County, Washington
FEMA-1499-DR-WA (Public Assistance)
January 2009

U.S. Department of Homeland Security
FEMA Region X
130 - 228th Street SW
Bothell, WA 98021-9796

Environmental Assessment

Monte Cristo Grade Road Bridge

Prepared by Snohomish County Public Works
3000 Rockefeller Place
Everett, WA 98201

for

U.S. Department of Homeland Security
Federal Emergency Management Agency (FEMA)
130 - 228th Street SW
Bothell, WA 98021-9796

January 2009

Table of Contents
1.	Purpose and Need for Action
1.1.	Introduction	3
1.2.	Purpose and Need for Action	6
1.3.	Location and Background	6
1.3.1.	Alternatives Analyzed in the 2005 Draft Environmental Assessment	6
2.	Alternatives
2.1.	Alternatives Analyzed in this EA	7
2.1.1.	Alternative A  Action Alternative: Bridge Option	9
2.1.2.	Alternative B  No Action Alternative	10
3.	Affected Environment and Environmental Consequences
3.1.	Soils, Geomorphology, and Streambank Stability	19
3.1.1.	Affected Environment	19
3.1.2.	Alternative A  Bridge Option	22
3.1.3.	Alternative B  No Action Alternative	23
3.2.	Hydrology and Water Quality (and Executive Order 11988)	24
3.2.1.	Affected Environment	24
3.2.2.	Environmental Consequences	27
3.2.3.	Alternative A  Bridge Option	27
3.2.4.	Alternative B  No Action Alternative	29
3.3.	Vegetation and Wetlands (and Executive Order 11990)	29
3.3.1.	Affected Environment	29
3.3.2.	Environmental Consequences	30
3.3.3.	Alternative A  Bridge Option	30
3.3.4.	Alternative B  No Action Alternative	31
3.4.	Wildlife and Fish	31
3.4.1.	Affected Environment	31
3.4.2.	Environmental Consequences	35
3.4.3.	Alternative A  Bridge Option	35
3.4.4.	Alternative B  No Action Alternative	35
3.5.	Threatened and Endangered Species (including Magnuson-Stevens Act and Essential 
Fish Habitat)	36
3.5.1.	Affected Environment	36
3.5.2.	Environmental Consequences	39
3.5.3.	Alternative A  Bridge Option	39
3.5.4.	Alternative B  No Action Alternative	40
3.6.	Recreational Resources	40
3.6.1.	Affected Environment	40
3.6.2.	Environmental Consequences	41
3.6.3.	Alternative A  Bridge Option	41
3.6.4.	Alternative B  No Action Alternative	41
3.7.	Visual Resources	41
3.7.1.	Affected Environment	41
3.7.2.	Environmental Consequences	42
3.7.3.	Alternative A  Bridge Option	42
3.7.4.	Alternative B  No Action Alternative	42
3.8.	Environmental Justice	42
3.8.1.	Affected Environment	42
3.8.2.	Environmental Consequences	44
3.8.3.	Alternative A  Bridge Option	44
3.8.4.	Alternative B  No Action Alternative	44
3.9.	Cultural Resources	44
3.9.1.	Affected Environment	44
3.9.2.	Environmental Consequences	45
3.9.3.	Alternative A  Bridge Option	45
3.9.4.	Alternative B  No Action Alternative	45
3.10.	Transportation and Access	46
3.10.1.	Affected Environment	46
3.10.2.	Environmental Consequences	46
3.10.3.	Alternative A  Bridge Option	46
3.10.4.	Alternative B  No Action Alternative	47
3.11.	Air Quality and Noise	47
3.11.1.	Affected Environment	47
3.11.2.	Environmental Consequences	47
3.11.3.	Alternative A  Bridge Option	47
3.11.4.	Alternative B  No Action Alternative	47
3.12.	Socioeconomics	48
3.12.1.	Affected Environment	48
3.12.2.	Environmental Consequences	48
3.12.3.	Alternative A  Bridge Option	48
3.12.4.	Alternative B  No Action Alternative	48
4.	Consultation and Coordination
4.1.	Scoping	49
4.2.	Tribal and Agency Coordination	50
4.3.	Other Laws and Regulations	50
5.	Wild and Scenic River (Recommended) 
5.1.1.	Wild and Scenic Rivers Act	50
5.1.2.	Management Area 5: Recommended Wild and Scenic River	51
5.2.	Affected Environment	52
5.3.	Environmental Consequences Recommended Wild and Scenic River	52
5.3.1.	Alternative A  Bridge Option	52
5.3.2.	Alternative B  No Action	52
6.	Cumulative Impacts
6.1.1.	Affected Environment	53
6.1.2.	Environmental Consequences	53
6.1.3.	Alternative A  Bridge Option	53
6.1.4.	Alternative B  No Action	53
7.	BIBLIOGRAPHY
7.1.	Literature Cited	54
7.2.	Internet Sources	56
8.	List of Preparers	58
9.	Appendix A: Best Management Practices	60
10.	Appendix B: Conservation Measures	62
11.	Appendix C: Biological Assessment	64
12.	Appendix D: Technical Memorandums	66
12.1.	Fisheries Resource Report	66
12.2.	Aquatics Conservation Strategy	66
12.3.	Wildlife Resources Report and Biological Evaluation	66
13.	Appendix E: Comment Letters and Responses	68

List of Figures

Figure 1:	Project Location	4
Figure 2:	Project Vicinity	5
Figure 3:	2003 Washout Site	8
Figure 4:	Proposed Bridge Location	11
Figure 5: 	Bridge Site Plan and Profile	13
Figure 6: 	Original Bridge (circa 1970)	21
Figure 7: 	Existing Concrete Pier	25
Figure 8:	General Timing of Salmonid Life Stages	34
Figure 9:	Bridge Design	43

List of Tables

Table 3.2-1	Peak Flows Return Interval at Granite Falls.	24
Table 3.2-2	Mean Monthly Flows (cfs) at Granite Falls Gauge	26
Table 3.3-1 	Plant Species Known to Occur in the Project Area	29
Table 3.4-1 	Anadromous and Resident Fish of the Monte Cristo Grade Road Area	33
Table 3.5-1	Federally Listed Species that Occur in the Monte Cristo Grade Road Area	36
Table 3.5-2	Species of Salmonids and Possible Life Stages with Designated Essential Fish 
Habitat in the Action Area	38
Table 3.8-1 	Race and Ethnicity Profile of Census Tract 536.02, Snohomish County, WA.	44
Table 3.11-1	Estimated Cost of Each Alternative	48
Table 4.1-1	Staff that Attended the February 9, 2005 Monte Cristo Grade Road Site Visit	49
Table 4.1-2	Staff that Attended the March 1, 2005 Monte Cristo Grade Road Site Visit	49

ACRONYMS AND ABBREVIATIONS

BA 		Biological Assessment
BMP 		Best Management Practice
CFR 		Code of Federal Regulations
cfs 		cubic feet per second
Corps 		U.S. Army Corps of Engineers
Cy 		Cubic yards
dbh 		Diameter at breast height
DPS 		Distinct Population Segment
EA 		Environmental Assessment
EIS 		Environmental Impact Statement
EO 		Executive Order
ESA 		Endangered Species Act
ESU 		Evolutionarily Significant Unit
FEMA 	Federal Emergency Management Agency
FONSI 	Finding of No Significant Impact
FR 		Federal Register
Ft		feet
LWD 		Large woody debris
MSE 		mechanically stabilized earth
NEPA 		National Environmental Policy Act
NOAA 	National Oceanic and Atmospheric Administration
OHWM 	Ordinary High Water Mark
PHS 		Priority Habitats and Species
RM 		River Mile
ROW 		right-of-way
SCC 		Snohomish County Code
SCPW 		Snohomish County Public Works
SCS 		Soil Conservation Service
SCSWM 	Snohomish County Surface Water Management
SHPO 		State Historic Preservation Office
SLE 		Stillaguamish Lead Entity
STAG 		Stillaguamish Technical Advisory Group
TMDL 	Total Maximum Daily Load
USFS 		U.S. Forest Service
USFWS 	U.S. Fish and Wildlife Service
USFWS 	U.S. Fish and Wildlife Service
USGS 		U.S. Geological Survey
WAC 		Washington Administrative Code
WAU 		Watershed Assessment Unit
WDF 		Washington Department of Fisheries
WDFW 	Washington Department of Fish and Wildlife
WDNR 	Washington Department of Natural Resources
WDOE 	Washington Department of Ecology
WRIA 		Water Resource Inventory Area
WSCC 	Washington State Conservation Commission

Environmental Assessment

Monte Cristo Grade Road Bridge

1.	PURPOSE AND NEED FOR ACTION
1.1.	Introduction
Record rainfall occurred in Western Washington during October 19 - 21, 2003 causing extensive 
damage throughout the region. Flooding and erosion in the South Fork Stillaguamish River 
watershed caused about 650 feet of the Monte Cristo Grade Road, just outside of Verlot, 
Washington to washout. The Monte Cristo Grade Road is an unpaved gravel road accessing 
twenty four recreational properties and one residence. The river now occupies a section of the old 
road footprint. Additional erosion occurred during the 2006 and 2007 flood seasons. The road 
has been barricaded since 2003 and there is currently no vehicular access to the recreational 
properties and Forest Service land along the road. (See Figure 1: Project Location).

Snohomish County requested funding from the Department of Homeland Securitys Federal 
Emergency Management Agency (FEMA) to repair the road. The event was a presidential 
declared disaster (#1499) and the County prepared Public Worksheet (PW) 205. The original PW 
was prepared March 2004. PW205 Scope of Work was revised October 2007.

Because of the federal nexus with FEMA funding, an Environmental Assessment (EA), is being 
prepared by Snohomish County to comply with the National Environmental Policy Act (NEPA) 
pursuant to FEMAs regulations found in 44 Code of Federal Regulations (CFR) Part 10.

A Draft EA, dated April 2005, was prepared by FEMA to analyze the construction of a new 
segment of road away from the river and around the washout. Three alternative road alignments 
were considered and analyzed. These alignments and potential environmental impacts of each are 
described in the Draft Environmental Assessment: Reconstruction of the Monte Cristo Grade 
Road, 2005. That EA was prepared but not distributed for public comment or review.

Following a review by FEMA and Snohomish County of the draft EA and Draft Biological 
Assessment (BA), another alternative was developed that would have less environmental impact. 
A bridge across the river was proposed to restore access to the Monte Cristo Grade Road. The 
bridge site is approximately 0.5 mile downriver from the washout site. There was a bridge in this 
location up until early 1970s when it was removed due to structural deficiencies. 

A decision was made by Snohomish County Public Works in fall 2007 to pursue the bridge 
option. Further damage to the washout area had occurred from flooding in 2006 and additional 
wetlands and streams had also been identified along the steep slopes of the proposed road 
alignments. Impacting these critical areas would require extensive mitigation. The site of the 
washout is continuing to erode. 

This Environmental Assessment examines the Countys proposal to construct a bridge across the 
South Fork of the Stillaguamish River. It would connect the dead end of 342nd Drive NE to the 
Monte Cristo Grade Road on the same alignment as a previous bridge. Much of the background 
information contained in the April 2005 EA is applicable to this current EA. 

Figure 1:	Project Location

Figure 2:	Project Vicinity

1.2.	Purpose and Need for Action
The purpose of FEMAs Public Assistance Program is to assist local communities requesting 
funding to recover from damages caused by natural disasters. Snohomish County needs this 
proposed action to provide a safe, economical and continuous access to the 24 parcels and 15 
property owners (including one permanent resident) along the road. The proposed bridge would 
restore the original function of the Monte Cristo Grade Road. Without the bridge, the property 
owners have no vehicular access to their properties. The purpose of the Action Alternative 
(Bridge Option) presented in this EA is to restore vehicular access to the road with the least 
environmental impact.
1.3.	Location and Background
The 2003 floods washed out a section of the Monte Cristo Grade Road just outside the 
community of Verlot in Snohomish County, Washington, (Township 30N, Range 8E, Section 15, 
W.M.). Verlot is located on the Mountain Loop Highway, approximately 55 miles northeast of 
Seattle and 11 miles east of the town of Granite Falls. The Mountain Loop Highway is 
designated as a National Forest Scenic Byway and is a popular fifty mile loop road between the 
towns of Granite Falls and Darrington, Washington. This road provides access to an extensive 
network of hiking trails, campgrounds, climbing and picnicking areas. Segments of the road 
typically close due to snow during the winter months.

The section of road that washed out during the 2003 flood is at River Mile (RM) 47.2, along the 
left bank (facing downriver) of the South Fork Stillaguamish River. It is 0.1 mile from the 
intersection of the Mountain Loop Highway and Mount Pilchuck Road (USFS Road #42) just 
east of Snohomish Countys Bridge #538 (commonly known as Blue Bridge). (See Figure 2: 
Project Vicinity). 

During the 2003 flood, it was estimated that the flood flows reached approximately 10-12 feet 
above the low flow river levels at the washout site (Van Wormer 2005). The high flow 
undermined the mostly unconsolidated hillside where the road was located and removed 40 to 
60 feet (horizontal distance) of the riverbank, which amounted to 30,000-40,000 cubic yards (cy) 
of sand, gravel, and cobble (Van Wormer 2005). The river bank has continued to erode and an 
additional section of the road was lost during a 2006 flood event.

Snohomish County has installed concrete barricades and signs on the Mount Pilchuck Road to 
prevent vehicular traffic access to the Monte Cristo Grade Road. Approximately two miles of the 
Monte Cristo Grade Road is isolated by the washout. At present, owners of the properties along 
the road must walk around the eroded area to reach their parcels. There is currently no vehicular 
access to these properties. The U.S. Forest Service (USFS) administers adjacent land in the 
project area as part of the Mount Baker-Snoqualmie National Forest. (See Figure 3: 2003 
Washout Site).
1.3.1.	Alternatives Analyzed in the 2005 Draft Environmental Assessment 
The Draft Environmental Assessment for the Reconstruction of the Monte Cristo Grade Road, 
April 2005, examined three road alignments at the washout area and a No Action Alternative. 
The draft EA also discussed three options that were considered but not carried forward. One of 
these options was to reconstruct the road along its original alignment. However, it quickly 
became apparent that this was not a viable option as the South Fork Stillaguamish River now 
occupies much of the 650-foot washed out roadbed. The bluff would need extensive excavation 
and stabilization to rebuild the road. Another alternative considered but eliminated would have 
required the construction of a new road within several perennial streams, seeps and wetlands. 
This option would require extensive use of a Mechanized Stabilized Earth wall. A third option 
initially considered but rejected was the construction of a 3,500 foot long road from the Mount 
Pilchuck Road directly upslope of the washout. This option was eliminated due to the cost, long 
length and need for numerous switchbacks.

The alternatives carried forward and evaluated in the 2005 Environmental Assessment 
were:
*	Alternative A: 	No Action Alternative;
*	Alternative B: 	Northern alignment 
*	Alternative C: 	Middle alignment immediately upslope 
*	Alternative D:	Southern alignment slightly farther upslope in some locations.
Environmental impacts are associated with all three action alternatives. The bank above the river 
is eroding and geologic evidence indicates that mass wasting of the bluff will continue, especially 
during high flows. A washout of a new road constructed on this bank could potentially occur 
due to this continued mass wasting and landslide activity. Landslides contribute high sediment 
loads to the watershed which can potentially impact fish habitat in the river. The new road 
alignments would also remove riparian habitat which provides shade, terrestrial insects and a 
source of large woody debris. Riparian buffer would need to be replaced with a Mechanized 
Stabilized Earth (MSE) wall to support the new section of road.

Following analysis of these three alignments, another alternative was proposed that would restore 
access to the Monte Cristo Grade Road but would have fewer environmental impacts. A bridge 
was proposed just down stream of the three proposed road alignments. 

The bridge would be in the same location as a previous bridge constructed in the 1930s and 
removed in the 1970s. At that time the bridge was in need of repair and it was decided to 
remove the structure. The Mount Pilchuck Road connected with The Monte Cristo Grade Road 
and provided adequate access to the properties on the south side of the Stillaguamish River. The 
original concrete bridge abutments and center pier remain, but the deck and other structural 
elements were removed in the 1970s. Preliminary analysis indicated that constructing a bridge in 
this location would have fewer environmental impacts than creating a new road on the steep 
slopes around the washout site. The following is an analysis of the bridge alternative.
2.	ALTERNATIVES
2.1.	Alternatives Analyzed in this EA
Evaluation of the potential alternatives to restore vehicle access to the Monte Cristo Grade Road 
resulted in two alternatives carried forward for analysis in this EA:
*	Alternative A  Bridge Option-Construct a bridge on previous bridge site at 342nd 
Drive NE and connect to the Monte Cristo Grade Road
*	Alternative B  No Action Alternative

Figure 3:	2003 Washout Site

2.1.1.	Alternative A  Action Alternative: Bridge Option
Floods in 2003 washed out a portion of the unpaved Monte Cristo Grade Road near the 
Mountain Loop Highway leaving the remaining portion of the Monte Cristo Grade Road 
inaccessible. This project would re-establish access to Monte Cristo Grade Road by constructing 
a bridge across the South Fork of the Stillaguamish River, connecting 342nd Drive NE to the 
Monte Cristo Grade Road on the south side of the river. The Monte Cristo Grade Road dead 
ends at the Stillaguamish River, approximately 1.35 miles west of the bridge site.
 
The proposal is a one-lane vehicular bridge located where an earlier bridge stood. The original 
bridge and piers were constructed in the 1930s. The original steel truss superstructure was 
removed in the 1970s, leaving the center concrete pier on the north side of the river and concrete 
abutments on the north and south banks. The bridge was structurally deficient at that time and 
the Monte Cristo Grade Road was also accessible from the Mount Pilchuck Road.

A geotechnical evaluation of the remaining structures was conducted in 2006. According to this 
study, the existing center pier would need to be removed and replaced due to inadequate scour 
resistance and vertical load capacity. It is anticipated that the concrete abutment on the south 
side of the river would be left in place and modified to accommodate the new superstructure. If 
after more detailed analysis it is determined to be deficient, the abutment would be removed and 
replaced in the same location. A new abutment would also be constructed at the north end of the 
bridge at the end of 342nd Drive NE. 

A prefabricated two-span, steel bow truss is planned for the superstructure. The first span 
between the north abutment and the center pier would be approximately 92 feet long and the 
second span over the main river channel would be approximately 152 feet long. Each span would 
be fabricated and installed as simple-spans. The horizontal alignment is straight with no skew at 
the new pier and abutment. The center pier and north abutment will be supported by pile 
foundations. The piles are planned to be vibrated in place. If it is not possible to vibrate the piles 
they would be driven into place.

The vertical alignment is straight with an upward slope from south to north of about 0.8%. The 
transverse slope on the bridge is flat. The bridge decking is planned to be open steel grate. The 
lane width would be 12 feet wide and the outside width would be approximately 14 feet wide.

Additional work includes grading and paving needed for the roadway approaches, grading to 
match existing driveways and modifying adjacent drainage ditches to provide water flow away 
from the new bridge abutments. Guardrail would be installed at the bridge approaches. It is 
anticipated that stormwater detention would not be required and that low impact development 
techniques would be used to treat the stormwater from the road approaches and possibly from 
the bridge. The new bridge and road approaches would be constructed within Snohomish County 
right-of-way. No additional right-of-way would be required. Temporary construction easements 
would be needed from adjacent properties for equipment access and staging areas. 

The Monte Cristo Grade Road would remain unpaved following construction of the bridge. The 
road would be permanently barricaded in the area of the washout. (See Figure 4: Proposed 
Bridge Location).

Summary of Pier and Abutment Construction: 

North abutment: 	The existing abutment would be removed. The new north abutment is 
proposed to be constructed of five vibrated or driven pipe piles with a pile 
cap. The piles are assumed to be 18 inches in diameter with an estimated 
length of 50 feet each. 

Center pier: 	The existing center pier would be removed. The new center pier is 
proposed to be constructed of seven vibrated or driven steel pipe piles, 
covered with a concrete cap. The piles are assumed to be 24 inches in 
diameter. A reinforced concrete pier wall would extend from the pile cap 
to the bridge structure.

South abutment: 	The existing south abutment would be left in place, cleaned and reused to 
support the south end of the new truss. Some additional concrete may be 
needed to modify the abutment for the new bridge superstructure.

2.1.2.	Alternative B  No Action Alternative
NEPA suggests including analysis of a No Action Alternative, against which the effects of the 
action alternatives can be evaluated and compared. For the purpose of this EA, the No Action 
Alternative would keep the road in its current state of disrepair. No effort would be made to 
provide vehicle access to private residences or the private land farther downstream from the road 
wash-out. 

Snohomish County would continue to maintain barriers at the eastern end of the road near the 
junction with the Pilchuck Road. FEMA funding, while available for a reconstruction of a 
damaged road, is not available for a land purchase program with unwilling sellers. Thus, 
Snohomish County would be responsible for the cost of any private property buy-out program 
that might be proposed to mitigate for the loss of personal use of the lands affected by the 
washout.

Figure 4:	Proposed Bridge Location

Figure 5: 	Bridge Site Plan and Profile

3.	AFFECTED ENVIRONMENT AND ENVIRONMENTAL 
CONSEQUENCES
The following section discusses the existing conditions by resource and the potential effects of 
the proposed bridge. Cumulative impacts are discussed separately for all resources in Section 
3.13. Measures to minimize project impact are also described.
3.1.	Soils, Geomorphology, and Streambank Stability
3.1.1.	Affected Environment
The project area is situated on the lower slopes of a predominantly north-facing slope of Pilchuck 
Mountain. The geologic unit in this area consists of Quaternary glacio-lacustrine silt that typically 
was deposited on either Vashon-age till, recessional outwash or bedrock. The area of the washout 
is composed of thick layers of fluvial and glacial outwash deposits on bedrock (Van Wormer 
2005). The eroded riverbank reveals three layers of outwash: (1) an upper layer dominated by 
gravely sand and cobble, (2) a middle layer composed of fine sand, and (3) and lower gravely 
sand layer. This lower layer is being actively eroded by the river which, in turn, results in the 
upper layers giving way. A summary of geologic observations for the site was provided by 
Findley and Kammereck (2004), which characterized the road location as being on a glaciofluvial 
terrace approximately 30 ft above the river. The general geology is mapped as Pleistocene glacial 
deposits overlying Western Melnge Belt lithologies (Tabor 1988 as cited in Findley and 
Kammereck 2004). There are several small bedrock outcroppings suggesting a rather irregular 
bedrock surface. The steep slopes to the east of the eroded bluff are likely underlain with 
bedrock.

Snohomish County conducted a separate geophysical survey in January 2005 to evaluate the 
depth of bedrock in the area of the different road alignment options (Findley et al. 2005). The 
geophysical survey found that the bedrock surface generally dips to northeast with a slope angle 
of approximately 40 - 60 degrees (Findley et al. 2005). Findley et al. (2005) recommend that, in 
some locations along proposed road alignments, the exact depth to bedrock should be 
investigated further to determine appropriate construction techniques. Granular soils with some 
wet seeps dominate the eastern portion of the road alignments, while shallow bedrock occurs 
along the western portion. Additional geotechnical analysis was conducted by Golder Associates 
and a report submitted to Snohomish County in April 2008. 

The combination of channel morphology and erodible surfaces suggests that the large volume of 
outwash deposits along the bluff at the road washout site is likely to continue to actively erode 
over the long-term (Findley and Kammereck 2004). 

The presence of Bridge #538 on the Mountain Loop Highway (commonly known as Blue Bridge) 
just upstream of the project site, contributes to the river not being able to migrate as it would 
under natural conditions. This likely contributes to the river flows continually eroding the 
riverbank at the site of the 2003 washout. The clay, silt, and sand deposits of glacial and lake 
origin are the main source of the significant sediment production in the watershed (Perkins and 
Collins 1997, as cited in WSSC 1999). In the steeper sloped areas, these deposits are particularly 
prone to landslides. Seventy-five percent of the more than 1,000 landslides documented in the 
entire Stillaguamish watershed were associated with human disturbance, most commonly clear 
cuts or roads (Perkins and Collins 1997 as cited in Stillaguamish Lead Entity, 2004). Major 
sediment contributions on the South Fork Stillaguamish are at Gold Basin (SLE 2004), which is 
just upriver from the project. The Gold Basin landslide is listed as a priority site for sediment 
reduction projects by the SLE (2004).

The Snohomish County Soil Survey characterizes the soil in the vicinity of the bridge site as 
Skykomish gravelly loam, 0 to 30 percent slopes (U.S. Soil Conservation Service 1983). This soil 
is very deep, somewhat excessively drained soil and occurs on terraces, terrace escarpments, and 
outwash plains. The soil formed in glacial outwash and volcanic ash. The substratum to a depth 
of 60 inches or more is extremely gravelly loamy, coarse sand, and extremely gravelly coarse 
sand. Included in this unit are areas of Elwell and Olomount outcropings on mountainsides and 
ridgetops and Rober soils on terraces and terrace escarpments (U.S. Soil Conservation Service 
1983). These soils are seasonally wet. Another soil in the vicinity is Nargar Variant sandy loam 3- 
30 percent which is deep well drained soil on terrace escarpments and mountainsides.

The Geologic Map of the Sauk River (30- by 60 Minute Quadrangle, Washington) shows the 
bridge site lies within an area covered by Holocene-age (less than 10,000 years ago) river 
alluvium, deposited by the South Fork Stillaguamish River. The recent geologic history of the 
project site consists of the incision of the stream into the bedrock creating the original valley, 
subsequent infilling of the valley with Holocene-age alluvium (silts, sand, gravel and boulders) 
followed by river incision through the deposited alluvium resulting in well developed terraces. 
On of these terrace surfaces forms the area of the north bridge abutment. 

Channel bed material consists of approximately eight feet of coarse gravels and cobble deposits 
atop a deep lens of medium sands. (Ambrose 2008). Explorations of the north abutment and 
center pier site encountered exclusively fluvial deposits. These deposits were dominated by fine 
to course sands but also contained some layers and lenses of silt. In additions the borings 
contained gravel and boulder deposits in the upper portions capping each hole.

The south abutment area consists of a cast in place concrete structure that appears to be founded 
on bedrock. Bedrock exposed several tens of feet upstream of the abutment consisted of fresh 
foliated, medium dark gray to dark gray, fine grained granulose, very strong phyllite. Bedding or 
foliation dips to the north-northeast at around 70 degrees.

Figure 6: 	Original Bridge (circa 1970)
Environmental Consequences
3.1.2.	Alternative A  Bridge Option
Under the Bridge Option a prefabricated two-span steel truss is planned. The existing pier would 
be removed and replaced with a new one in approximately the same location. Grading would be 
required to remove and replace the abutment at 342nd Drive NE and match existing road grades. 
Some grading would also be required on the south side of the river to match the existing grade at 
the old abutment which will be reused, if possible. Clearing and grading will occur within the 
County right-of-way. Construction easements may also be required from private landowners 
adjacent to the project site and U.S. Forest Service. Site preparation will include the removal of 
vegetation, unsuitable fill and topsoil from the construction area. In general, the fill appeared to 
be suitable for reuse as structural fill. (Golder 2008).

Impacts to North Side of the River

Construction would occur during the dry season. Ground impacts on the north side of the river 
include excavation for removal of the center pier and construction of a new pier. The proposed 
center pier would be at approximately the same location as the existing pier. The old pier is a cast-
in-place structure with two columns supporting a concrete cap. (See Figure 7: Existing Concrete 
Pier). Impacts would also include excavation and removal of the existing north abutment where 
342nd Drive NE dead ends. The abutment would be replaced with piles.

The new center pier will be supported by seven 24-inch diameter pipe piles driven to refusal. The 
north abutment would be supported by five 18-inch piles driven to refusal. Open-ended pipe 
piles are recommended due to their drivability in the granular soils encountered at the site. The 
depth of excavation for the center pier and north abutment piles is not determined at this time. 
Additional investigation is planned to determine the site design scour depth, the elevation and 
shape of the pile cap and pile depth. 

A geologic site investigation encountered cobbles and boulders from the surface to depths 
between 7-8.5 feet in the area of the proposed pier. It is likely the depth of the obstructions will 
vary across the pile caps. Pre-drilling or excavation and backfilling with structural material may 
be needed prior to pile driving. If the pile cap is constructed below groundwater, a coffer dam 
and/or pumping may be required during construction. (Golder 2008). 

Clearing and grading would also be needed at the dead end of 342nd Drive NE to match the 
existing road grade and for a temporary construction access road down to the beach. There is an 
existing, non-vegetated slope from the dead end of 342nd Drive NE down to the river level where 
the original bridge was located. This bank would be graded for equipment access down the north 
bank to the cobble beach. There is potential for soil erosion on this bank during clearing, grading 
and construction. 

At the river level, approximately 310 cubic yards of temporary fill would be needed for the crane 
pads and construction access. The beach area is sandy, relatively flat with cobbles and boulders. 
The pad areas would be cleared and geo-textile laid down and covered with compacted gravels 
and quarry spalls to provide a base for the crane pads and construction access. Existing cobbles 
and boulders from the crane pad locations would be stockpiled. This material would be 
redistributed to restore the site following construction. The geo-textile and gravel used for the 
crane pads will be removed following construction. 

Impacts to the soil are assumed to include: equipment movement, excavation for permanent and 
temporary bridge supports, access road construction and placement of a crane pad. A temporary 
support may be required for the bridge superstructure during construction. This temporary pier 
would be located just south of the existing pier and north of the wetted channel boundary. An 
area just east of the bridge site may be needed to temporarily stage the bridge sections during 
construction. This area is shown on Figure 4: Proposed Bridge Location and is approximately 
12,340 square feet. Impacted areas would be returned to pre-existing conditions as closely as 
practicable and as required by all permits. Permanently impacted areas are approximately 400 
square feet at the center pier, 100 square feet at the north abutment and 2,200 square feet for 
grading on 342nd Drive NE. 

Liquefaction is assumed to occur in the sand deposits in the area of the bridge. Further 
investigation, including additional borings, is needed to determine depth of piles to minimize 
structural damage during an earthquake.

Impacts to South Side of River

Impacts to soils on the south side of the river consist primarily of grading to match the Monte 
Cristo Grade Road on either side of the existing abutment. The impacted area would be about 
10,000 square feet. There would be no grading work below the OHWM on the south side of the 
river. All work would be on the existing road, rock bluff and existing concrete abutment above 
the river.

This old abutment is assumed to be a cast-in-place structure founded on exposed bedrock. The 
top of the abutment is nearly flush with the surrounding ground. The structure is approximately 
14 feet in height from the road surface to the base. The abutment would be cleaned and reused. 
The abutment would be modified with additional concrete to support the bridge, if necessary.

The Monte Cristo Grade Road dead ends approximately 1.35 miles west of the bridge site. This 
gravel road has not been maintained by the Snohomish County Road Maintenance Division since 
the flood of 2003 washed out the vehicular access. Based on a recent inspection of the road 
(May 2008) sections of this road would need to be cleared to allow vehicle use. Fallen trees and 
branches would be removed and several blocked culverts would be replaced. Some regrading and 
placement of gravel would be needed. The river bank may be stabilized in several areas where 
scalloping and minor bank erosion has occurred. Maintenance of this road would be a separate 
Snohomish County project from the bridge replacement and would occur after vehicular access 
has been restored.
3.1.3.	Alternative B  No Action Alternative
Under the No Action Alternative the soils and geology at the bridge site would remain in its 
current condition. The existing concrete bridge pier would not be removed and the southern 
abutment on top of bedrock would remain. No grading would be done at the bridge site. 
3.2.	Hydrology and Water Quality (and Executive Order 11988)
3.2.1.	Affected Environment
The Stillaguamish River basin has a drainage area of approximately 685 square miles (WSSC 
1999) and consists of two main streams; the North and South Fork Stillaguamish River. The 
confluence of these two forks is near the City of Arlington in northwest Snohomish County. 

The South Fork Stillaguamish River begins in the Barlow Pass area at about 6,200 feet elevation 
and carries snow melt and rainfall from the high and steep slopes of the Cascade Mountains. It 
drains approximately 254 square miles and includes over 4,618 miles of streams and rivers 
(WDOE and SCPW 2003). 

The Monte Cristo Grade Road Bridge project site is located near the upstream boundary of the 
Robe Valley Subbasin in Hydrologic Unit171100080202 (USGS website). This sub-basin 
encompasses over 15,000 acres of land. The 20 miles of the South Fork Stillaguamish River just 
upstream of the project site has a moderate gradient33 ft vertical change/milewhile the river 
upstream of that is steep (100 ft/mile) (WDOE and SCPW 2003). 

South Fork Stillaguamish flows are often subject to extremes in fluctuation. U.S. Geologic 
Survey (USGS) flow data over a 53-year period of record for the USGS gage at Granite Falls 
(gage #12161000) indicate that flows have fluctuated up to a maximum of 32,400 cubic feet per 
second (cfs) (February 1932) (USGS website). This flow approaches the estimated 100-year 
flood flow for this gage (Table 3.2-1). Mean monthly flows range from a low of 299 cfs in 
August to a high of 1,663 cfs in December. Major tributaries in this sub-basin include: Bear, 
Black, Boardman, Gordon, Hemple, and Wiley creeks (WSCC 1999). The Robe Valley receives 
approximately 103 inches of precipitation per year (WDOE and SCPW 2003).

Table 3.2-1	Peak Flows Return Interval at Granite Falls.
Recurrence Interval
Flow (cfs) at Granite Falls
2-year 
16,400

5-year 
21,700

10-year 
25,000

25-year 
28,600

50-year 
31,900

100-year 
34,800

500-year 
41,200

Source: WDOE and SCPW (2003)

Figure 7: 	Existing Concrete Pier

Table 3.2-2	Mean Monthly Flows (cfs) at Granite Falls Gauge 

The Robe Valley sub-basin is one of four in the entire Stillaguamish watershed that meet four 
criteria for being sensitive to forest practices affecting hydrology (SCSWM 2002). These criteria 
include having:
 A Unit Flood Discharge that is greater than 0.25 cfs/acre
 More than 35 percent of the area in the rain-on-snow zone
 Greater than 12 percent of the forestland in scrub-shrub stage
 Greater than 35 percent of forestland being non-federal
In terms of water quality, the South Fork Stillaguamish upriver of Canyon Creek (RM 33.7) is 
considered to be Class AA (extraordinary) as defined by the Water Quality Standards for 
Surface Waters of the State of Washington (Hicks, 2000 as cited in Pelletier and Bilhimer [2001]; 
Chapter 173-201A-030 WAC). Temperatures in Class AA waters are not to exceed 16C due to 
human activities (Pelletier and Bilhimer 2001, Chapter 173-201A-030 WAC). The South Fork 
has a high sediment load (0.5 tons per mi2 per day) but not nearly as high as the North Fork, 
which has 4.9 tons per mi2 per day (Pelletier and Bilhimer 2001).

The Stillaguamish River comprises the Water Resource Inventory Area (WRIA) #5. WRIAs 
define watershed areas monitored by the Washington Department of Ecology (WDOE) for water 
quality impairments, contamination, and degradation. Portions of streams and rivers not meeting 
basic water quality requirements are included on a 303(d) list. No surface waters within the 
South Fork Stillaguamish basin are included on WDOEs 303(d) list, and only small portions of 
streams in the lower mainstem Stillaguamish are 303(d) listed. 

This very limited number of 303(d) listings provides an indication of the general health and 
quality of water existing in the South Fork Stillaguamish River basin. However, the number of 
reported water quality violations in this watershed is increasing as evidenced by Washington 
States growing number of 303(d) listings in the Stillaguamish drainage (WSSC 1999). WDOE 
will eventually implement a Total Maximum Daily Load (TMDL), defined as the sum of all 
pollutant loads to a water body, for each stream or lake on the 303(d) list. The South Fork 
Stillaguamish River is a candidate for 303(d) listing for fecal coliform, pH, dissolved oxygen, 
and temperature (WDOE 1998, as cited in WSSC 1999). 

Lands within the Robe Valley sub-basin are dominated by unmanaged forests and areas managed 
for silviculture. Very few rural communities and developed areas with potential for point-source 
pollutant contributions occur within the South Fork Stillaguamish River sub-basin upstream of 
the town of Granite Falls. Thus, the South Fork Stillaguamish River has a very limited potential 
for water quality impairments. While South Fork Stillaguamish River contaminant risk may be 
minimal, sediment loading within the river can become extreme depending upon precipitation 
and land use alteration. South Fork Stillaguamish River sediment load becomes especially high 
during periods of fall/winter rains and when increased surface flow from snowmelt conveys loose 
surface substrate from surrounding lands. 

Flow characteristics in the river near the washout site are likely affected by the presence of the 
Mountain Loop Highway Bridge 0.1 mile upstream (Bridge #538, Blue Bridge). The bridge 
abutments and the adjacent highway roadbed play a role in directing flows toward the south and 
not allowing the river channel to naturally migrate the west. At low flows, the thalweg (deepest 
part of the channel) is farther to the north, away from the washout site. But as flows increase the 
flow path becomes aimed directly at the landslide area (Van Wormer 2005). However, the reach 
of the channel through the project area appears to be much more stable than reaches upstream 
(Ambrose 2008). This section is considered a transport reach that tends to move large wood and 
sediment through rather than accumulate in large deposition areas. The geometry and alignment 
in this area is less subject to migration and wood accumulation than areas upstream. These are the 
mechanisms by which channels tend to migrate into their banks or avulse into historical channels. 
3.2.2.	Environmental Consequences
3.2.3.	Alternative A  Bridge Option
Standard Best Management Practices would be used control erosion and sedimentation at the 
site during construction. These could include silt fences, check dams in swales, filter strips and 
baker tanks. There are no other stream or wetland crossings at the bridge site.

The proposed bridge would comply with Executive Order No. 11988, Floodplain Management. 
The center pier is above the OHWM but within the rivers flood plain. The pier is designed to 
withstand flooding and would not alter the hydrology of the river. The footing of the pier would 
be below the scour depth of the river. The pier will be designed as a solid wall to minimize debris 
getting caught on the pier. The center pier would not affect the channel migration capacity of the 
river. The 100-year flood elevation is 958 feet according to FEMA Flood Insurance maps. The 
bottom of the bridge is approximately 13 feet above the 100-year flood elevation and the 
ordinary high water (OHW). (See Figure 5: Bridge Site Plan and Profile).

The bridge would be constructed during the dry season to reduce impacts to the river. However, 
depending on the river level during construction, a temporary water diversion could be necessary 
for construction of the center pier, temporary supports and crane pads. Work would be limited to 
the area above the wetted channel boundary (defined by County staff on February 14, 2008). 

If dewatering is needed during construction of the center pier it could be performed with 
cofferdams constructed of sheet piling, precast concrete blocks or median barrier, sand bags and 
plastic sheeting. Once the cofferdam is in place, water would be pumped out.

It is anticipated that the south abutment would be retrofitted with cast in place concrete to meet 
current design standards. The abutment was scraped clean by hand (winter 2008) to remove 
moss, plants and soil and other accumulated debris. Final cleaning to ensure a proper bond of 
new concrete would require pressure washing with water. Silt fence, straw bale barrier and other 
appropriate best management practices (BMPs) would be used to control water runoff. Limits on 
time of continual washing can be in place as well to limit the buildup of water. The contractor 
would be required to meet all applicable water quality and Temporary Erosion and Sediment 
Control (TESC) requirements due to construction activities.

There is no vehicular access to the south side of the river due to the 2003 washout upstream. 
Equipment and materials to construct the bridge would be carried across a temporary work 
bridge and or lifted into place by a crane. 

Concrete needed to restore the south abutment would be lifted across the river by a crane in a 
concrete bucket. It is anticipated that only a few cubic yards of concrete would be needed. 
Depending on the size of the bucket (generally available in 1/3 cubic yard to 4 cubic yard), only a 
couple passes over the river would be needed. Properly functioning buckets that do not leak 
would be specified and the bucket would be wiped clean prior to lifting over the river. If needed, 
plastic sheeting or other material would be draped below the bucket to ensure no drips from the 
gate. It may also be feasible to use a concrete pump truck to place concrete at the south 
abutment. The contractor would be required to have a written, approved plan for carrying 
concrete over the river and protecting it from spills, drips, etc. prior to bringing concrete on site 
for both the bucket and pump truck methods.

The roadway approaches would be graded to match the new bridge elevation. The north 
abutment would be designed to minimize grading on 342nd Drive NE and adjacent driveways. 
Culverts may be needed at the driveways to improve drainage and direct water away from the 
new bridge abutments. At the south abutment it is anticipated that the grade would rise by about 
one foot.

The amount of net impervious surface area is well below 5,000 square feet. Monte Cristo Grade 
Road will remain unpaved. Due to the seasonal use and limited number of residents the average 
daily traffic is expected to be very low on the Monte Cristo Grade Road. The estimated traffic 
volume is less than 20 vehicles per day. Steel grate decking would be used on the bridge. 
Stormwater detention and water quality treatment are not required in accordance with Volume I 
of Washington Department of Ecology Stormwater Management Manual for Western 
Washington. 

3.2.4.	Alternative B  No Action Alternative
Under the No Action Alternative, site hydrology and water quality at the bridge site would not 
be altered. 

It is likely that the South Fork Stillaguamish River channel will continue to migrate to the south 
near the washout site, particularly during high flow events. This area would likely continue to 
erode and contribute sediment to the river. 
3.3.	Vegetation and Wetlands (and Executive Order 11990)
3.3.1.	Affected Environment
Forests in the vicinity of the project site are dominated by western hemlock (Tsuga heterophylla), 
Douglas-fir (Pseudotsuga menziesii), and western red cedar (Thuja plicata). Deciduous species 
found in riparian and upland habitats are predominantly red alder (Alnus rubra), but a small 
number of black cottonwood (Populus trichocarpus) and big-leaf maple (Acer macrophyllum) 
also occur. Within the Robe Valley sub-basin, 21, 9, and 2 percent of federal, state, and private 
forest lands, respectively, are considered to be mature (WDOE and SCPW 2003). The vegetation 
communities near the site have been affected both by stand-replacing fires and logging in the 
Stillaguamish watershed (Peter 1999, SLE 2004). Poor railroad, road, and culvert design and 
maintenance have also led to substantial riparian habitat degradation. Nonetheless, the riparian 
habitat in the Robe Valley sub-basin is considered to be recovering (WSCC 1999). 

At the bridge site, the vegetation is composed primarily of second-growth mixed coniferous and 
deciduous forests dominated by cedar, western hemlock and red alder. There are no federally 
listed plants occurring in the action area. Most of the area to be disturbed for bridge construction 
consists of existing road grade.

The understory consists of sword ferns, vine maple, salmonberry and thimbleberry. The uplands 
have been heavily influenced by logging and previous grading activities. The community of 
Verlot is located on the north side of the river. Vegetation on this side is a mixture of native and 
non-native plant species. 

Narrow shrub-dominated riparian zones occur along streams in the area. The riparian species 
include salmonberry (Rubus spectabilis), vine maple (Acer circinatum), devils club (Oplopanax 
horridus), and ninebark (Physocarpus capitatus). The seeps in the area support a mix of 
hydrophytic and mesophytic vegetation, including: salmonberry, devils club, and vine maple 
(Table 3.3-1). Along the Monte Cristo Grade Road on the south side of the river the slopes are 
forested with large conifers including hemlock and red cedar up to 36 inches diameter at breast 
height (dbh). 

Table 3.3-1 	Plant Species Known to Occur in the Project Area 
Species
Scientific name
Status
Vegetation 
Layer
Notes
Douglas-fir
Pseudotsuga 
menziesii
FACU
Overstory
Limited number.
Western Red Cedar
Thuja plicata
FAC
Overstory
Limited number
Western Hemlock
Tsuga heterophylla
FACU-
Overstory
Common upland species.
Big-leaf Maple
Acer macrophyllum
FACU
Overstory
Very limited in number.
Red Alder
Alnus rubra
FAC
Overstory
Pervasive in disturbed areas 
and along the
unnamed stream
Black Cottonwood
Populus balsamifera
FAC
Overstory 
Small number of saplings
Indian Plum 
Oemleria 
cerasiformis 
FACU
Shrub
Found throughout project 
site
Red Osier Dogwood
Cornus stolonifera
FACW
Shrub
Isolated individuals along 
river near debris chute.
Vine Maple
Acer circinatum
FACU
Shrub
Small number.
Salmonberry 
Rubus spectabilis
FAC+
Shrub
Most common/dense shrub 
species in uplands, riparian 
zone, and wetland
Thimbleberry 
Rubus parviflorus
FACU+
Shrub
Limited densities in shrub 
layer
Ocean Spray 
Holodiscus discolor
FACU
Shrub
Small number along stream
Red Elderberry
Sambucus racemosa
FACU
Shrub
Limited in seeps and along 
stream.
Devils Club
Oplopanax horridus
FAC
Shrub 
Limited densities in seeps.
Sword Fern
Polystichum munitum
FACU
Herb
Common component of 
upland forest community.
Deer Fern 
Blachnum spicant
FAC+
Herb 
Common component of 
riparian zone.
Lady Fern 
Athyrium filix-femina
FAC
Herb
Common component of 
riparian zone.
Bracken Fern 
Pteridium aquilinum
FACU
Herb 
Fern of wet and disturbed 
areas.
Salal 
Gaultheria shallon
FACU
Shrub 
Small number in upland 
zone.
Fringecup 
Tellima grandiflora
FACU
Herb 
Most pervasive ground 
cover along road.
Piggy-back plant
Tolmiea menziesii
FAC
Herb
Common in riparian zone
Foamflower 
Tiarella trifoliata  
FAC
Herb
Common in riparian zone
Common
Horsetail
Equisetum arvense
FAC
Herb
Found along disturbed 
roadside areas
Skunk
Cabbage
Lysichiton
americanum
OBL
Herb
Obligate wetland species 
found in site wetlands

Approximately 78 percent of the historic wetlands in the Stillaguamish River watershed have 
been impacted or lost (Gersib 1997). There are many riverine wetland sites that have been 
disconnected by historic flood control projects, although most of this has occurred well 
downstream of the project site where a large number of wetlands have been degraded by 
agricultural and urban land use.
3.3.2.	Environmental Consequences
3.3.3.	Alternative A  Bridge Option
Impacts to vegetation would occur during the clearing and grading needed to construct the new 
bridge. Some trees and other vegetation would be removed to accommodate the new bridge and 
the swing radius of the crane which would be used during construction. Approximately 32 trees, 
8 inches in diameter or larger, may be removed. Additional smaller trees and shrubs may be 
removed in the work area to accommodate access, equipment movement and other construction 
activities. The trees to be removed are primarily alder and western red cedar. (Figure 4: Proposed 
Bridge Location). All brush and trees removed will be disposed of at an approved site. Some 
trees removed from the County right-of-way may be suitable for use in stream restoration 
projects. These trees would be stockpiled for reuse. Removal of the trees and brush will allow 
more light in the vicinity of the bridge site until the remaining trees grow larger. Mitigation for 
removal of the trees will include planting native tree species on the south side of the river within 
the riparian corridor. 

This project complies with Executive Order No. 11990, Protection of Wetlands. There are no 
wetlands in the immediate vicinity of the proposed bridge and no wetlands will be impacted by 
the proposed bridge construction.
3.3.4.	Alternative B  No Action Alternative
Under the No Action Alternative, vegetation would remain unaltered from current conditions. 
Continued erosion of the riverbank would reduce vegetated land over the long term at a slow 
rate. If no action is taken to construct the Monte Cristo Grade Road Bridge there would be no 
impacts or effects to native vegetation communities.

3.4.	Wildlife and Fish
3.4.1.	Affected Environment
3.4.1.1.	Wildlife
The native riparian corridor and managed forests surrounding the project site provide habitat for 
a broad array of terrestrial wildlife species. Federally listed species under the Endangered Species 
Act (ESA) are discussed in Section 3.5. During the January site reconnaissance for the 2005 
Environmental Assessment conducted by EDAW, biologists only detected chickadee (Poecile 
atricapillus and P. rufescens) and American crow (Corvus brachyrhynchos) at the washout site. 
However, the diversity of upland and riparian habitats and the proximity to the South Fork 
Stillaguamish River likely provide habitat for a variety of wildlife species common to forests of 
the Pacific Northwest including: various species of warblers, belted kingfisher (Ceryle alcyon), 
dark-eyed junco (Junco hyemalis), American robin (Turdus migratorius), brown creeper (Certhia 
americana), spotted towhee (Pipilo maculatus), red-tailed hawk (Buteo jamaicensis), black-tailed 
deer (Odocoileus hemionus), and small furbearers such as mink (Mustela vision) and weasel 
(Mustela frenata). The river is likely used by spotted sandpiper (Actitis macularia) and common 
merganser (Mergus merganser) that preferentially breed along the river and in riparian habitat 
and upland habitats.

The seeps and unnamed streams on the south side of the river appear to have habitat that is 
suitable for several amphibian species, such as coastal tailed frog (Ascaphus truei), Pacific giant 
salamander (Dicamptodon tenebrosus), and Pacific tree frog (Hyla regilla). Species such as 
western red-backed salamander (Plethodon vehiculum), rough-skinned newt (Taricha granulosa), 
red-legged frog (Rana aurora), and ensatina (Ensatina eschscholtzii) could occur in the riparian 
and upland habitats in the area. The tailed frog is a Washington State Monitor species and federal 
Species of Concern that has been documented in the lower section of Twenty-two Mile Creek 
approximately one mile southeast of the bridge site. The larger conifer and deciduous trees on the 
south side of the South Fork Stillaguamish River may be suitable for bald eagles, osprey, and 
other raptors for use as perches as they forage along the river.
3.4.1.2.	Fish
The South Fork Stillaguamish River supports a wide diversity of resident and migratory fish 
species. Most notable is the extensive variety of resident and anadromous salmonid species (i.e., 
salmon and trout) that comprise a recreational sport fishery on the river. The Stillaguamish River 
is managed for wild coho (Oncorhynchus kisutch) and chinook (O. tshawytscha) stocks; however, 
hatcheries have supplemented wild runs of summer chinook, chum (O. keta), and coho on this 
river since 1939 (Corps 1997, as cited in WSSC 1999). Hatchery-raised chinook, coho, and pink 
(O. gorbushcha) salmon were introduced to the upper South Fork above Granite Falls after 1954 
with the construction of the Granite Falls Fishway. Since 1994, fishing for bull trout/Dolly 
Varden (Salvelinus confluentus) in the Stillaguamish has been closed. Hatchery-origin chinook, 
chum, coho, and steelhead (O. mykiss) are released annually into the Stillaguamish basin. 

In recent years, chinook salmon redds have been documented in the South Fork Stillaguamish 
River between RM 49.0 (less than 2 upstream of the project) and 64.5 (unpublished Washington 
Department of Fish and Wildlife [WDFW] data provided by C. Jackson). Approximately 51 
miles (57 percent) of the 90 miles of stream in the Robe Valley subbasin are thought to support 
anadromous fish populations (WSSC 1999). Table 3.4-1 lists the common species that occur in 
the South Fork Stillaguamish River or its tributaries in the vicinity of the project site. The general 
life stage timing of salmonids is illustrated in Figure 8: General Timing of Salmonid Life Stages.

Table 3.4-1 	Anadromous and Resident Fish of the Monte Cristo Grade Road Area

Species
Scientific Name
ESU/DPS
Federal 
Status
Project Area Use
Chinook Salmon
Oncorhynchus 
tshawytscha 
Puget Sound ESU
FT, SC
Rearing and migration

Coho Salmon
Oncorhynchus
kisutch
Puget Sound/Strait of 
Georgia ESU
FC
Rearing and migration

Chum Salmon
Oncorhynchus Keta
Puget Sound/Strait of 
Georgia ESU
--
Spawning and 
rearing; not spawn

Sockeye Salmon
Oncorhynchus nerka
No designated ESU
--
Rearing and migration

Pink Salmon
Oncorhynchus gorbuscha
No designated ESU
--
Rearing and migration

Steelhead
Oncorhynchus
mykiss
Puget Sound ESU
FT
Migration, spawning, 
and rearing

Cutthroat Trout
Oncorhynchus clarki 
clarki
Puget Sound ESU
--
Resident-all life 
stages

Rainbow Trout
Oncorhynchus mykiss
No designated ESU
--
Resident-all life 
stages

Mountain 
whitefish
Prosopium williamsoni
No designated ESU
--
Resident-all life 
stages

Bull Trout
Salvelinus confluentas
Coastal 
Washington/Puget 
Sound DPS

FT, SC
Rearing and migration
Sucker
Catostomus sp. cf, 
catostomus
--
--
Resident all life 
stages

Status: 
FT:	Federal Threatened
SC:	State Candidate
FCo:	Federal Species of Concern
ESU: 	Evolutionarily Significant Unit
DPS:	Distinct Population Segment

Sources: StreamNet website; NOAA Fisheries website; WDFW website.

Figure 8:	General Timing of Salmonid Life Stages
3.4.2.	Environmental Consequences
3.4.3.	Alternative A  Bridge Option
Temporary disturbance to wildlife could occur during construction due to noise and construction 
activity. Piles will be driven or vibrated into place for the center pier and the north abutment. 
Construction would affect a minimal amount of wildlife habitat on the north side of the river as 
this area is primarily the existing 342nd Drive NE and the residential community of Verlot. This 
area consists of homes and seasonal cabins. Much of the construction would occur in the existing 
road right-of-way and on the alignment of the previous bridge. Placing the piles is expected to 
take approximately 4-5 days. This work would occur approximately 70 feet landward from the 
wetted channel and above the OHWM. Some short term, temporary impacts to wildlife could 
occur during the placement of the piles due to noise and vibration.

On the south side of the river, much of the work would occur in the existing Monte Cristo Grade 
Road right-of-way and at the existing concrete abutment from the previous bridge. The south 
side of the river is more heavily vegetated and could potentially provide more wildlife habitat 
than the northern side. No pile driving would occur on the south side of the river. Work in this 
area includes minor grading and modifying the existing abutment with additional concrete.

No in-water work would be required for the Bridge Option but work would occur over the South 
Fork Stillaguamish River and on its banks. Direct impacts to resident fish and aquatic organisms 
during construction could include short-term sedimentation and increased turbidity in the river. 
The magnitude of stress to fish generally increases as turbidity level increases and particle size 
decreases (Bission and Bilby, 1982). Because fish can readily disperse, many species may 
relocate when sediment load is increased. This avoidance can expose fish to increased predation 
and energy expenditure. 

The primary wildlife impact would occur from the removal of trees to construct the bridge. 
Approximately 32 trees 8 inches in diameter or greater would be removed to construct the bridge. 
The trees to be removed are primarily red alder and western red cedar. Some displacement of 
potential bird nesting habitat will occur with the removal of the trees. However, the bridge site is 
adjacent to large tracts of densely forested U.S. Forest Service land which provides alternate 
habitat.

The bridge site is within the Pacific Flyway for migratory birds. Removal of trees needed for the 
bridge construction will not significantly impact bird habitat or migration routes. No impacts are 
expected to migratory birds during or after the construction of the bridge.

3.4.4.	Alternative B  No Action Alternative
The No Action Alternative would avoid potential construction impacts at the project site and 
would not affect fish and wildlife. Human disturbance of fish and wildlife would remain at 
existing low levels because of the lack of vehicle access to the Monte Cristo Grade Road. 
Pedestrian access to the bridge site would be possible from the Pilchuck Mountain Road but 
would remain low due to the narrow, rugged trail to access the area.
3.5.	Threatened and Endangered Species (including Magnuson-
Stevens Act and Essential Fish Habitat)
Threatened and endangered species include all plant and wildlife species designated by the U.S. 
Fish and Wildlife Service (USFWS) and National Oceanic and Atmospheric 
Administration/National Marine Fisheries Service (NMFS) as threatened, endangered, or as 
candidates for listing under the Endangered Species Act (ESA). No listed plant species are 
known to occur in the project area. 

A separate Biological Assessment (BA) has been be prepared and submitted for review by 
USFWS and NMFS. Both Services have determined that No Take of Endangered Species is 
associated with this project. A letter of concurrence was received from USFWS dated November 
13, 2008. A letter of concurrence was received from NMFS dated September 2, 2008. The 
concurrence letters are included in the BA, Appendix C.
3.5.1.	Affected Environment
3.5.1.1.	Fish
The fish species that occur in the South Fork Stillaguamish River in the vicinity of the project site 
include the Puget Sound Evolutionary Significant Unit (ESU) of chinook salmon (Oncorhynchus 
tshawytscha) (summer run), the Puget Sound/Strait of Georgia ESU of coho salmon (O. kisutch), 
and the Coastal Puget Sound DPS of bull trout (Salvelinus confluentus) (Table 3.5-1). The Puget 
Sound/Strait of Georgia ESU of chum salmon (O. keta) and the Puget Sound ESU of steelhead 
(O. mykiss) occur in the South Fork Stillaguamish River but have been determined not to warrant 
protection under ESA, although other distinct population segments of chum salmon and 
steelhead are protected under ESA. The South Fork Stillaguamish River in the project area is not 
included in the proposed Critical Habitat for chinook salmon but is proposed as Critical Habitat 
for bull trout.

Table 3.5-1	Federally Listed Species that Occur in the Monte Cristo Grade Road Area
Species
Scientific Name
ESU/DPS
Status
Project Area Use
Chinook 
Salmon
Oncorhynchus 
tshawytscha
Puget Sound ESU
Federal 
Threatened
Primarily restricted 
to 17 miles of South 
Fork
Coho salmon
O. kisutch
Puget 
Sound/Strait of 
Georgia ESU
Candidate
Rearing and 
migration in South 
Fork Stillaguamish 
near project 
Bull trout
Salvelinus 
confluentus
Coastal 
Washington/Puget 
Sound
Threatened
Rearing and 
migration in South 
Fork Stillaguamish 
River 
Steelhead
O. mykiss
Puget Sound DPS
Threatened
Rearing and 
migration in South 
Fork Stillaguamish
Status: FT=Federal Threatened; SC=State Candidate; FCo=Federal Species of Concern; 
ESU=Evolutionarily Significant Unit; DPS=Distinct Population Segment
Sources: Unpublished WDFW data; StreamNet website; NOAA Fisheries website; WDFW website

Anadromous fish access to the South Fork Stillaguamish River above Granite Falls, which was a 
natural anadromous fish barrier, is limited by poor attraction to the Granite Falls Fishway, poor 
entrance conditions at the fishway, sedimentation and flow problems and by a rock fall in Robe 
Canyon that may be a migration barrier (WDFW 2004b). In addition to fish passing through the 
Granite Falls Fishway, there is a coho trapping and hauling program that transports small numbers 
of bull trout/Dolly Varden around Granite Falls and Robe Canyon.
3.5.1.2.	Essential Fish Habitat (EFH)
Public Law 104-267, the Sustainable Fisheries Act of 1996, amended the Magnuson-Stevens 
Fishery Conservation and Management Act (Magnuson-Stevens Act) to establish new 
requirements for Essential Fish Habitat (EFH) descriptions in Federal fishery management plans 
and to require Federal agencies to consult with National Marine Fisheries Service (NMFS) on 
activities that may adversely affect EFH. EFH means those waters and substrate necessary to 
fish for spawning, breeding, feeding, or growth to maturity. 

The Pacific Fisheries Management Council (PFMC) has recommended an EFH designation for 
the Pacific salmon fishery that would include those waters and 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) (PFMC 1999).

The Magnuson-Stevens Act requires consultation for all actions that may adversely affect EFH, 
and it does not distinguish between actions in EFH and actions outside EFH. Any reasonable 
attempt to encourage the conservation of EFH must take into account actions that occur outside 
EFH, such as upstream and upslope activities that may have an adverse effect on EFH. 
Cumulative impacts are incremental impacts, occurring within a watershed or marine ecosystem 
context that may result from individually minor but collectively significant actions. The 
assessment of cumulative impacts is intended in a generic sense to examine actions occurring 
within the watershed or marine ecosystem that adversely affect the ecological structure or 
function of EFH. The assessment should specifically consider the habitat variables that control or 
limit a managed species use of a habitat. It should also consider the effects of all impacts that 
affect either the quantity or quality of EFH. The consultation requirements of section 305(b) of 
the Magnuson-Stevens Act (16 U.S.C. 1855(b)) provide that:
*	Federal agencies must consult with NMFS on all actions, or proposed actions, authorized, 
funded, or undertaken by the agency, that may adversely affect EFH.
*	NMFS will provide conservation recommendations for any federal or state activity that may 
adversely affect EFH.
*	Federal agencies will, within 30 days after receiving conservation recommendations from 
NMFS, provide a detailed response in writing to NMFS regarding the conservation 
recommendations. The response will include a description of measures proposed by the 
agency for avoiding, mitigating, or offsetting the impact of the activity on EFH. In the case 
of a response that is inconsistent with the conservation recommendations of NMFS, the 
federal agency will explain its reasons for not following the recommendations.
3.5.1.3.	Identification of Essential Fish Habitat
Salmon fishery EFH includes all streams, lakes, ponds, wetlands, and other water bodies 
currently or historically accessible to salmon in Washington, Oregon, Idaho, and California, 
except above the impassable barriers identified by PFMC (PFMC 1999). Salmon EFH excludes 
areas upstream of longstanding naturally impassable barriers (i.e., natural waterfalls in existence 
for several hundred years). During the proposed project, coho, Chinook, and pink salmon may be 
within the project area. 
Table 3.5-2	Species of Salmonids and Possible Life Stages with Designated Essential Fish 
Habitat in the Action Area

Life Stage
Species
Spawning/Egg
Juvenile 
Rearing
Migration 
(Adult/Juvenile)
Fresh/Salt Water 
Acclimatization
Coho Salmon
X
X
X

Pink Salmon
X
X
X

Chinook Salmon
X
X
X

3.5.1.4.	Direct, Indirect and Cumulative Effects
Potential impacts of the Monte Cristo Bridge to ESA listed fish species are discussed in Sections 
6 of this BA. As discussed, strict adherence to BMPs will help protect the SF Stillaguamish 
River from water quality effects and other potential short-term impacts during project 
construction. Although, riparian mitigation, likely will improve in-stream habitat over the long-
term, insignificant short-term impacts may occur to Pacific Coast salmon EFH.  There should be 
no cumulative adverse effects to EFH.
3.5.1.5.	EFH Determination
Based on the EFH requirements of Pacific Coast salmon species, BMPs, and conservation and 
mitigation measures proposed as part of the project, this project will not adversely affect EFH
3.5.1.6.	Wildlife
Bald Eagle
The bald eagle (Haliaeetus leucocephalus) was removed from protection in July 2007 under the 
federal Endangered Species Act. However, two other federal laws still provide protection for the 
bald eagle, the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act. 

There are no known bald eagle nests within two miles of the project site (as of 2001), however, 
there were 32 bald eagle nest territories in Snohomish Countymostly in the western portion of 
the county (Stinson et al. 2001). During the winter months (November-March), bald eagles come 
from as far north as the Yukon and Alaska to forage on spawning salmon in western Washington 
rivers. It is unknown how many eagles actually use the immediate section of the South Fork 
Stillaguamish River, but it is likely that some eagles do use the area periodically. Regional eagle 
migration reaches its peak in late December and early January when the largest numbers of eagles 
are likely to occur in the vicinity of the project site. Bald eagles may make use of the larger trees 
along the South Fork Stillaguamish River near the project site for night roosts and perches. No 
communal roosts have been identified in the WDFW Priority Habitats and Species (PHS) 
database.
Marbled Murrelet and Spotted Owl
The marbled murrelet (Brachyramphus marmoratus), is the only listed wildlife species known to 
occur within two miles of the project. No spotted owls (Strix occidentalis) have been documented 
in the project area. The nearest suitable spotted owl habitat is on the slopes of Mt. Pilchuck. Only 
very small patches of larger trees occur near the proposed bridge location.

The marbled murrelet is a state and federal endangered species in Washington. This species nests 
in forests that have at least remnant old-growth characteristics that enable them to find nesting 
platforms on large horizontal limbs. Adult murrelets nesting in the Stillaguamish River watershed 
make daily flights between their nests and marine foraging areas in Puget Sound. The marbled 
murrelet has been documented within USFS forests within 0.8 mile of the project site (WDFW 
PHS data). The forests at the project site generally lack the structure (e.g., large trees with moss 
covered branches) necessary for nesting murrelets. However, a few trees approximately200 feet 
from the south abutment would be considered suitable habitat. 
3.5.1.7.	Plants
At the bridge site, the vegetation is composed primarily of second-growth mixed coniferous and 
deciduous forests dominated by cedar, western hemlock and red alder. There are no federally 
listed plants occurring in the action area. Most of the area to be disturbed for bridge construction 
consists of existing road grade.

3.5.2.	Environmental Consequences
A detailed effect analysis for federally protected species for the preferred alternative would be 
provided in a separate Biological Assessment (BA). The following narrative summarizes 
information to be included in the BA.
3.5.3.	Alternative A  Bridge Option
There is a potential for increased sediment in the river during construction, but this would be 
minimized by implementation of BMPs. 

Although trees would be removed for construction of the bridge, construction would not directly 
affect any nesting habitat for bald eagles or marbled murrelets, nor would the bridge construction 
remove any bald eagle perch sites. 

The project is 0.8 mile from a known marbled murrelet nesting site. Construction noise, which 
would be significantly higher than normal ambient levels, has the potential to disturb marbled 
murrelets. Construction noise would occur during the breeding season but the bridge site is 
outside the USFS recommended distance (>60 yards for heavy equipment) for not likely to 
adversely affect the species. No blasting would occur on this project. No suitable nesting habitat 
for marbled murrelets would be removed.

Assuming that construction takes place during the summer, there would be no effect on bald 
eagles as there are no bald eagle nests near the project.

The project is not likely to adversely affect listed fish species. There is no in-water water work 
proposed for the bridge. Some construction would take place over the water as the bridge is 
assembled and lifted into place. Construction during the dry period and the implementation of 
BMPs would ensure that there would be insignificant effects to fish in project area. 

For this alternative, the determination is assumed to be May Affect, Not Likely to Adversely 
Affect for marbled murrelet, Chinook, steelhead, and bull trout and May Affect, Not Likely to 
Adversely Affect listed or proposed critical habitat.
3.5.4.	Alternative B  No Action Alternative
There would be no effects to threatened or endangered species under the No Action Alternative. 
Without repair of the Monte Cristo Grade Road, human disturbance in the project area would 
remain at the current low levels. The continued erosion along the river may remove a small 
number of potentially suitable bald eagle perch sites. There is the potential for additional bank 
slides and wash-outs that act as minor sediment sources to the Stillaguamish River.
3.6.	Recreational Resources
3.6.1.	Affected Environment
The two-mile long Monte Cristo Grade Road provides access to twenty four undeveloped 
recreational properties and one residence along the southern bank of the South Fork 
Stillaguamish River. The road also accesses an undeveloped portion of the Mount Baker-
Snoqualmie National Forest on the south flank of Mount Pilchuck. Currently there is no vehicular 
access to the Monte Cristo Grade Road due to the 2003 washout.
The Monte Cristo Grade Road does not provide public access to any developed recreation 
facilities, camping or constructed trails. The road does access three known waterfalls that draw 
recreational visitors (Snohomish County website). These waterfalls include:
*	First Fallsa 30- to 40-foot cataract along an unnamed creek 0.3 mile west of the wash-
out.
*	Heather Creek Fallsa series of cascades accessible by hiking from a small pond located 
0.6 mile west of First Falls.
*	Triple Creek Fallsa 15- to 25-foot lower and 40-foot upper falls accessible by a 200-
yard hike from the western end of the Monte Cristo Grade Road.

The primary recreational activities on the South Fork Stillaguamish River include fishing and 
whitewater boating. Fishing season upstream of the town of Granite Falls occurs between June 1 
and November 30 (WDFW 2004a). Limited whitewater rafting occurs in the upper South Fork 
Stillaguamish River, with the season generally beginning in April and ending in July. Fishing 
could occur on Forest Service property from the Monte Cristo Grade road although there no 
developed boating or fishing access points in the project area.

Within the Verlot area, many visitors hike on the extensive network of USFS trails in the area. 
Closest to the project site is the Mt. Pilchuck Trail (USFS Trail #700). The trailhead for this 
popular route is located 6.9 miles from the Mountain Loop Highway along Forest Service Road 
#42. The Mount Pilchuck Trail receives heavy use during the summer and fall seasons (USFS 
website). A new segment of the Mount Pilchuck Road was constructed in 2007 due to flood 
damage on the Monte Cristo Grade Road at the washout site. The project relocated a section of 
the Mount Pilchuck Road approximately 160 feet east of its original location to bypass the 
damaged section of road. Approximately 780 feet of new road was completed.

The section of the Mountain Loop Highway between Barlow Pass and the town of Darrington 
reopened in 2007 after four years of closure by the Forest Service due to washouts, slides and 
other damage from floods and debris. This is a popular recreation road for picnicking, camping 
and climbing. This segment of the Mountain Loop Highway is only opened during the summer 
season.
3.6.2.	Environmental Consequences
Each of the alternatives is described below in terms of its potential impacts to recreation 
resources.
3.6.3.	Alternative A  Bridge Option
The Mountain Loop Highway is also designated as the Mountain Loop Scenic Byway and is a 
popular destination as a scenic drive. Drivers would likely to turn off the highway to see the 
bridge and explore the south side of the river. 
If the bridge is constructed, the waterfalls, Forest Service land and private recreational properties 
on the south side of the Stillaguamish River would again be accessible by vehicle. However, 
because of the lack of public facilities or designated parking areas on the south side of the river 
the recreational use of this area is likely to be at a similar level as occurred prior to the road 
washout. 
3.6.4.	Alternative B  No Action Alternative
Under Alternative B, the washed-out segment of the Monte Cristo Grade Road would not be 
restored. There are currently no alternate trails or roads directly accessing the Monte Cristo Grade 
Road. Access to the road is only possible by hiking from the Pilchuck Mountain Road on steep 
terrain through heavily timbered Forest Service land around the washout site. A narrow trail 
along the washout site does access the Monte Cristo Grade Road; however, this trail is on private 
property.
3.7.	Visual Resources 
3.7.1.	Affected Environment
The general visual character of the South Fork Stillaguamish River corridor, including the 
washed-out section of the Monte Cristo Grade Road, is mountainous with periodic vistas of 
forested hillsides, river valleys and the river itself.

On the north side of the river, the bridge site includes permanent residences and cabins along 
342nd Drive NE and 102nd Street NE. The vegetation is a mix of native and non-native species 
with some large conifers. Looking south from the road end at 342nd Drive NE is the old concrete 
arched pier which once supported the earlier bridge. The pier and the concrete abutments are all 
that remain of the original bridge structure. 

On the south side of the river the vegetation along the road is typical of the Puget Sound 
foothills. The deciduous-coniferous tree canopy is dominated by western hemlock, red cedar, and 
red alder, while the understory consists primarily of native shrub species. Large conifer trees are 
found on the USFS land to the south of the bridge site. The bluff where the Monte Cristo Road 
washed out is visible from the Mountain Loop Highway near Bridge #538 (commonly referred to 
as Blue Bridge), as well as from the residences along the riverfront on the opposite side of the 
river. The steep, vertical bluff is vegetated on top with alder and other deciduous trees and native 
understory. 
3.7.2.	Environmental Consequences
The following sections discuss the potential effects on visual resources from each alternative.
3.7.3.	Alternative A  Bridge Option
Under the Bridge Option the existing concrete center pier would be removed and replaced with a 
similar structure. The new bridge is planned to be a prefabricated steel truss similar to the one 
pictured in Figure 9: Bridge Design. The bridge would be visible from the end of 342nd Drive 
NE. The bridge would also be visible from the river and the adjacent beach around the bridge 
site. The bridge may be visible from some of the cabins and homes off of 102nd Street NE just 
west of the bridge site. Due do the heavy vegetation and distance it is not likely the bridge 
would be visible from the Mountain Loop Highway.
3.7.4.	Alternative B  No Action Alternative
Under Alternative B, the washed out segment of the Monte Cristo Grade Road would not be 
restored and there would be no effects to visual resources. The existing washout is comparable to 
other slides along the South Fork Stillaguamish River and is not visually inconsistent with natural 
features upstream and downstream of this section. Segments of the damaged road are likely to be 
eroded by future channel migration while other areas would naturally revegetate and would not 
detract from the visual character of the area in the long term.

Under the No Action alternative the existing concrete pier and original abutments would remain. 
The pier and the abutments are visible from 342nd Drive NE and from the river and beach. 
3.8.	Environmental Justice
In the past decade, the concept of Environmental Justice has emerged as an important component 
of federal regulatory programs, initiated by Executive Order (EO) No. 12898 Federal Actions 
to Address Environmental Justice in Minority Populations and Low Income Populations. This 
Executive Order directed each federal agency to make achieving environmental justice by 
avoiding disproportionately high or adverse human health or environmental effects on minority 
and low-income populations a part of its mission. EO 12898 emphasized that federally 
recognized Native tribes or bands are to be included in all efforts to achieve environmental 
justice (Section 6.606).
3.8.1.	Affected Environment
The demographics of the affected area were examined to determine the presence of minority 
populations, low-income populations, or tribal peoples in the area potentially impacted by the 
proposed action. The race and ethnic profile of the local census tract from the 2000 census for the 
heavily rural census tract 536.02 (east of Granite Falls) is presented in Table 3.8-1. These 
percentages were based on a tract population of 4,564 persons. Snohomish County as a whole has 
a smaller percentage of Native Americans (1.4%), and a larger contingent of African Americans 
(1.7%) and Asians (5.8%). As part of the NEPA scoping process for the road alignment options, 
a site meeting was held with Tribal contacts, as detailed in Chapter 4, Consultation and 
Coordination.

Figure 9:	Bridge Design

Table 3.8-1 	Race and Ethnicity Profile of Census Tract 536.02, Snohomish County, WA.
Race or Ethnicity
Percentage of Population*

White 
94.8
Black or African American 
0.5
American Indian or Alaskan Native 
2.3
Asian 
1.0
Native Hawaiian and Other Pacific Islander
0.4
Some other race 
1.0
Source: 2000 Census website.
*Percentage adds to more than 100% because Hispanic and Latino is a category of ethnicity and includes more 
than one race category (black, white, etc.)
3.8.2.	Environmental Consequences
3.8.3.	Alternative A  Bridge Option 
Constructing the bridge would restore access to the Monte Cristo Grade Road and would have 
no effects to low income or minority populations.
3.8.4.	Alternative B  No Action Alternative
Under the No Action Alternative, conditions would remain the same at the site and there would 
be no disproportional impacts to low income or minority populations.
3.9.	Cultural Resources
Cultural resources include resources of historical and/or archaeological significance. For purposes 
of this document; the term historical resources is used to refer to historic structures or districts 
and archaeological resources is used to refer to prehistoric or historical subsurface sites or 
objects.
3.9.1.	Affected Environment
According to the files of the Washington Department of Archaeology and Historic Preservation 
(DAHP), which document the occurrence of National and State Historic Register resources, 
Historic Property Inventories, and Historic/Archaeological Sites and Districts, there are no 
documented historic or archaeological resources in the immediate vicinity of the project site (files 
retrieved electronically, December, 2007). The nearest site identified on the State Historic 
Register is the Hartford and Monte Cristo Railroad District; as described, the district is about 
three miles (at its closest point) from the project area. Correspondence between FEMA and the 
DAHP concluded that the remaining bridge pier at the proposed crossing site is not eligible for 
inclusion in the National Register of Historic Places. A letter was sent by FEMA to DAHP on 
December 19, 2007 requesting a review of the proposed bridge for Section 106 compliance. The 
DAHP responded on January 2, 2008 concurring with FEMAs recommendation and finding of 
No Historic Properties Effected. 

The Stillaguamish River drainage is of cultural importance to the Stillaguamish and Tulalip 
Tribes, whose people have historically made use of its resources and used the river as a travel 
corridor. FEMA requested review of the project from the Stillaguamish Tribe and the Tulalip 
Tribes by letter dated May 3, 2005. No specific references of important features were supplied by 
Stillaguamish or Tulalip Tribal representatives during a site visit in 2004.

The Tribes were contacted again by FEMA regarding the proposed bridge option. No additional 
comments from the Stillaguamish or Tulalip Tribes were received in response to telephone and e-
mail contacts in December, 2007.
3.9.2.	Environmental Consequences
3.9.3.	Alternative A  Bridge Option
Under this alternative a new bridge crossing of the river would be constructed to restore 
vehicular access to Monte Cristo Grade Road. The proposed bridge would be constructed on the 
same alignment that was disturbed for the original bridge in the 1930s. There would be some 
disturbance of the slope and cobble beach during construction. 

The original bridge was constructed in 1930s and removed in the 1970s. According to a historic 
photograph the original bridge appears to be a Double Intersection Warren Through-Truss type of 
structure. The steel trusses were set on a concrete pier and abutments. The bridge connected 
Monte Cristo Grade Road to 342nd Drive NE and the Mountain Loop Highway. The Monte 
Cristo Grade Road was originally part of the railroad corridor for the now abandoned Northern 
Pacific Railroad line (Hartford to Monte Cristo). 

The only evidence of the previous bridge is the concrete pier visible from 342nd Drive NE and a 
concrete abutment on each side of the river. There are barely visible remains of wooden piers on 
the beach which may have been part of temporary scaffolding used for construction of the 
bridge. 

The Washington DAHP has concurred with FEMAs determination of No Historic Properties 
Affected for this Alternative. Correspondence between FEMA and the DAHP concluded that 
the destroyed bridge at the proposed crossing site is not eligible for inclusion in the National 
Register of Historic Places.

While there are no documented sites in the area, construction could uncover previously unknown 
artifacts. If this occurs, construction would be stopped in and around the area of discovery and a 
qualified archaeologist would examine the site and consult with the SHPO and the Tribes. If 
human remains are uncovered all construction would stop until all appropriate officials and 
agencies are contacted and consulted. A report would be prepared to document the occurrence 
and the final resolution of the consultation process. Given these provisions and the lack of 
documented resources in the area, there would be no effects to cultural resources from this 
alternative.
3.9.4.	Alternative B  No Action Alternative
Under Alternative B, the access to Monte Cristo Grade Road would not be restored and no new 
river crossing would be constructed. It is possible that some artifacts may be in or near the 
existing road prism that could be affected by continued riverbank erosion. The extent of this 
possibility is unknown. There would be no effect to cultural resources outside of natural 
processes.
3.10.	Transportation and Access
3.10.1.	Affected Environment
The vicinity of the proposed project is served by a limited network of roads that include local 
highways and primitive gravel roads. The community of Verlot is approximately 170 residents 
(2000 census) with one small store, a campground and the Forest Service Ranger Station. 

The Monte Cristo Grade Road is a gravel roadway that originally extended approximately two 
miles westward from its intersection with Pilchuck Road, about 0.1 mile east of Verlot, 
Washington, along the southern bank of the South Fork Stillaguamish River. The road provided 
access to one permanent residence and twenty four unimproved properties. The Monte Cristo 
Grade Road dead ends approximately 1.35 miles west of the bridge site.

After the wash-out occurred in 2003, the Monte Cristo Grade Road was closed to all vehicular 
traffic. Snohomish County has installed concrete barriers and signage near the intersection with 
Pilchuck Road. Private property owners must access their properties by walking around the 
washout. There is a narrow trail along the edge of the washout.
3.10.2.	Environmental Consequences
3.10.3.	Alternative A  Bridge Option
Under this option vehicular access would be restored to the remaining section of Monte Cristo 
Grade Road on the south side of the Stillaguamish River via 342nd Drive NE. Vehicular and 
pedestrian traffic on the new bridge is expected to be minor and similar to what occurred on the 
Monte Cristo Grade Road prior to the washout. This road serves 15 property owners on 24 
undeveloped parcels and one resident. The estimated traffic volume is less than 20 vehicles per 
day and usage is primarily during the summer months. There is one permanent resident on the 
south side of the river that would use road as access. The remaining properties are not developed 
although some seasonal use of the bridge and road would be expected. There are no developed 
recreational or parking areas on the south side of the river. 

Due to the low traffic volumes no improvements are expected at the intersection of the Mountain 
Loop Road and 342nd Drive NE. Following completion of the bridge, the Monte Cristo Grade 
Road would be maintained as a primitive, low volume gravel road.

During construction of the bridge, trucks and other vehicles would access the site via the 
Mountain Loop Highway and 342nd Drive NE. There are several permanent residents and cabins 
that access off of 342nd Drive NE, a low volume road. There is one road, 102nd Street NE that 
intersects 342nd Drive NE. This is also a low volume road that serves approximately twenty 
residents. These appear to be permanent residents and seasonal cabins. 

The construction will occur in the road right-of-way where 342nd Drive NE dead ends. Access to 
one seasonal cabin at the road end and other residences on 342nd Drive NE will be maintained 
during construction. The bridge is expected to be completed in one construction season, 
approximately eight months. Contractors and construction crews are expected to commute daily 
from the town of Granite Falls, Everett and other nearby communities. No supplemental housing 
is anticipated to be needed. The temporary construction office will be located near the dead end 
of 342nd Drive NE. 
3.10.4.	Alternative B  No Action Alternative
Under Alternative B, access to the Monte Cristo Grade Road would not be restored. The private 
properties on Monte Cristo Grade Road would remain inaccessible to vehicular use. 
3.11.	Air Quality and Noise
3.11.1.	Affected Environment
The project site is within the Mount Baker Snoqualmie National Forest. The closest incorporated 
town is Granite Fall, approximately 11 miles west bridge site. The area around the north side of 
the bridge site is the small rural residential community of Verlot. There are no large industries in 
this area. Air quality is considered high in this area of the county. Noise levels are typical of a 
rural residential setting. The primary noise generator is the Mountain Loop Highway which 
typically closes during the winter at Silverton, approximately 12 miles east of the bridge site. 
3.11.2.	Environmental Consequences
3.11.3.	Alternative A  Bridge Option
Under this option vehicular access would be restored to the Monte Cristo Grade Road via 342nd 
Drive NE which is currently a dead end. There are several residential properties that take access 
from this road. 

During construction there would be temporary increase in sound levels due to the use of heavy 
equipment and hauling of materials. The equipment used to construct the bridge includes a large 
crane, trucks, cement mixer and other vehicles. Piles would be constructed for the new bridge. 
The piles for the bridge would be vibrated or pounded in. The increase in sound levels would 
depend on the type of equipment being used and the amount of time it is in use. Noise impacts 
resulting from construction would be short term and temporary. The placement of the pilings is 
expected to take 4-5 days. 

Sounds created from activity at temporary construction sites are exempt from the Countys noise 
ordinance except between the hours of 10:00 p.m. and 7:00 a.m. The majority of construction 
activities related to the project would occur during daytime hours on weekdays which would 
minimize impacts. If nighttime construction is required, then the County would be required to 
comply with the nighttime noise limits as required in the noise ordinance.

Vehicular traffic would increase on 342nd Drive NE following construction of the bridge; 
however, the average daily traffic would remain low. The average daily traffic is expected to be 
less than 20 trips per day. There is only one developed property along the Monte Cristo Grade 
Road. The remaining properties are either undeveloped or Forest Service land. There are no 
developed recreational destinations that are accessed from the Monte Cristo Grade Road. 
Therefore, there would be no significant increase in air quality or noise levels with this 
alternative.
3.11.4.	Alternative B  No Action Alternative
Under this option the washed-out segment of the Monte Cristo Grade Road would not be 
restored and vehicles would not have access to the road. The air quality and noise would remain 
in their present condition. 
3.12.	Socioeconomics
3.12.1.	Affected Environment
The primary industry types in the Granite Falls and Verlot area are light manufacturing, 
education, health, and social services; construction; and agriculture, forestry, fishing and hunting, 
and mining (U.S. Census 2000). The Monte Cristo Grade Road provides access to a small 
number of private residential properties. One of the properties includes a residence.
3.12.2.	Environmental Consequences
3.12.3.	Alternative A  Bridge Option
The estimated cost of each alternative is provided in Table 3.11-1. Though FEMA cannot fund a 
property buy-out that requires condemnation, the assessed value of the affected properties is not 
provided under the No Action Alternative cost.

Table 3.11-1	Estimated Cost of Each Alternative 
Alternative
Cost
Alternative ABridge Option

$ 1,516,170 (includes 20% contingency) 
Alternative BNo Action Alternative

$0
Source: Van Wormer 2005.

The cost of building one of the originally proposed road alignments around the washout is 
substantial because of the difficult terrain and the physical and environmental constraints of the 
site. Extensive mitigation for impacts to streams and wetlands would be required. These costs 
would be borne by federal, state, and county tax-payers. There would be no direct costs applied 
to the affected landowners. Because the area is zoned for one structure per lot, there would be 
minimal further development along the rebuilt road.

The cost of building the bridge option is approximately $1,516,170 and much less damaging to 
the environment than the road alternatives originally proposed. The bridge option would be built 
in the same location as an earlier bridge with minimal new impacts as compared with the three 
road options proposed in the 2005. 

The County does not anticipate the purchase of any right-of-way for this project. The bridge and 
the approach roads are within County right-of-way. The right-of-way on the north side of the 
river is 60 feet wide and 200 feet wide on the south side of the river. Temporary construction 
permits will be required from three property owners adjacent to the project area on 342nd Drive 
NE on the north side of the river. A temporary construction permit will also be required from U. 
S. Forest Service. Figure 4 shows approximate property boundaries.
3.12.4.	Alternative B  No Action Alternative
The No Action Alternative could be implemented without buyout of the properties by simply 
closing the damaged road. There would be no project cost associated with this option, but there 
would be no vehicle access for landowners. While individual property owners would be 
inconvenienced from such action, there would be minimal socioeconomic impacts at the macro 
scale.
4.	CONSULTATION AND COORDINATION
4.1.	Scoping
On February 9, 2005, a site visit was held with FEMA and the representatives of the 
Stillaguamish and Tulalip Tribes to discuss the merits of the road alternatives and the issues of 
concern for the Tribes. FEMA requested review of the project from the Stillaguamish Tribe and 
the Tulalip Tribes by letter dated May 3, 2005. 

Another meeting was held on site on March 1, 2005 with representatives of WDFW, USFWS, 
NOAA Fisheries, and the Washington State Emergency Management Division. Tables 4.1-1 and 
4.1-2 list the attendees of those meetings.

Table 4.1-1	Staff that Attended the February 9, 2005 Monte Cristo Grade Road Site Visit
Tribal/Agency Affiliation
Staff
Tulalip Tribe
Dave Luzi
Stillaguamish Tribe
Pat Stevenson
FEMA 	
Bert Bowen
FEMA/EDAW
Jim Keany

Table 4.1-2	Staff that Attended the March 1, 2005 Monte Cristo Grade Road Site Visit
Agency Affiliation 
Staff
USFWS 	
Suzy Lutey
NOAA Fisheries
Dan Tonnes
WDFW
Phil Jensen
Washington Military Department 
Emergency Management Division
Virginia Haas, Gary Urbas
FEMA/EDAW
Jim Keany

The primary issues raised by the Tribes and agencies included the following:
 Road alignment effects to aquatic systems and listed fish.
 Potential for new road to be affected by channel migration of stream.
 High cost of project for a low benefit providing access for one resident.
 Potential archaeological resource effects.
 Option of landowner buy-out to preclude need for road rebuilding.
 Effects of building close to river.
 Longevity of a new road built close to the river.
4.2.	Tribal and Agency Coordination
FEMA has had continued coordination with Tribal entities and state and federal resource 
agencies throughout the NEPA process. The Tribes and agencies have had an opportunity to 
comment on the Draft EA. No further comments have been received. Several meetings and 
additional phone calls were conducted with Tribal entities in regard to cultural resources. While 
the SHPOs office had no data on the project vicinity, they requested that results of the Tribal 
coordination be sent to their office. Upon completion of the NEPA process, this information will 
be sent to the SHPOs office.

The Tribes were contacted again by FEMA regarding the proposed bridge option by Charles 
Diters, Historic Preservation Specialist (FEMA Region 10). No additional comments from the 
Stillaguamish or Tulalip Tribes were received in response to telephone and e-mail contacts in 
December, 2007.

In addition, a separate Biological Assessment (BA) has been prepared and consultation was 
initiated with U.S. Fish and Wildlife Service (USFWS) and National Oceanic and Atmospheric 
Administration/National Marine Fisheries Service (NMFS) as mandated by the ESA. The 
Services have determined that No Take of Endangered Species is associated with this project. 
The letters of concurrence from both agencies are attached to the BA in Appendix C.
4.3.	Other Laws and Regulations
State, federal, and local laws that apply to the project, under the action alternative, include the 
following:
 Section 313 of the Federal Clean Water Act  Stormwater Management and Erosion 
Sediment Control
 Section 404 of the Clean Water Act
 Section 10 of the Rivers and Harbors Act
 State Water Quality Standards for Construction Projects
 State Hydraulic Project Approval
 State/Snohomish County Shoreline Management Regulations
 Snohomish County Critical Areas Ordinance
5.	WILD AND SCENIC RIVER (RECOMMENDED)
The South Fork Stillaguamish River, from the headwaters to Canyon Creek, has been 
recommended as a Wild and Scenic River in the U.S. Forest Plan. This recommendation is under 
review. However, because this river is a Recommended Wild and Scenic River, the project has 
been reviewed under the Wild and Scenic Rivers Act.
5.1.1.	Wild and Scenic Rivers Act
The Wild and Scenic Rivers Act (Act) was signed into law as Public Law 90-542 on October 2, 
1968. The Act established a National Wild and Scenic Rivers System (National System). To 
qualify, a river or river segment must be in a free-flowing condition and must be deemed to have 
one or more outstandingly remarkable scenic, recreational, geologic, fish and wildlife, historic, 
cultural or other similar values.

Section 5(d)(1)of the Act requires that In all planning for the use and development of water and 
related land resources, consideration shall be given by all Federal agencies involved to potential 
national wild, scenic and recreational river areas, and all river basin and project plan reports 
submitted to the Congress shall consider and discuss any such potentials. 

Rivers found eligible or suitable for the National System through federal agency planning 
processes are not protected by the Act from proposed hydroelectric facilities or other federally 
assisted water resources projects (Section 7(a)). However, the managing agency should, within its 
authorities, protect the values (scenic, recreational, geologic, fish and wildlife, historic, cultural, 
or other similar values) that make the river eligible or suitable.

Section 10(a) of the Act is interpreted as a non-degradation and enhancement policy for all 
designated river areas, regardless of classification. Each component is to be managed to protect 
and enhance the free-flowing condition, water quality and values for which the river was 
designated, while providing for public recreation and resource uses which do not adversely 
impact or degrade those values. Therefore the managing agency should analyze and document: 

a.  The effects of the proposed activity on conditions of free-flow, including 
identification of any proposed measures to minimize those effects;
b.  Any direct and adverse effects on the outstandingly remarkable and other significant 
resource values for which the river was designated or is being studied; and,
c.  Any unreasonable diminishing of scenic, recreational, fish and wildlife values 
associated with project activities above or below the area.

To be consistent, the river management agency should analyze the effects of proposed projects 
with the intent of maintaining the highest standards for all recommended rivers. Relationship to 
Forest Plan
5.1.2.	Management Area 5: Recommended Wild and Scenic River
The South Fork Stillaguamish River, from the headwaters to Canyon Creek, was recommended 
as a Scenic River in the Forest Plan (Management Area 5a). The goal would be to protect from 
degradation the outstandingly remarkable values and the wild, scenic, and recreation 
characteristics of recommended rivers and their environments pending a decision on inclusion 
into the National Wild and Scenic River System. 

The Forest Plan, as amended, stipulates (these) rivers shall be managed to protect those 
characteristics that contribute to the eligibility of these rivers at their highest potential 
classification (Chapter 4, p.4-95 USDA FS 1990). The Forest Plan, as amended, identified the 
Outstandingly Remarkable Values for the South Fork Stillaguamish River to be Scenic, 
Recreation, Fisheries, and Wildlife Historical/Cultural and Ecological (Appendix E, p.E-134, 
USDA FS 1990). 

The desired future condition for recommended recreation rivers is that evidence of a full range of 
management activities may exist. In addition, the river is readily accessible by roads or railroad 
and bridge crossings. High water quality is maintained.

5.2.	Affected Environment
The Outstandingly Remarkable Values for the South Fork Stillaguamish River are: Scenic, 
Recreation, Fisheries, and Wildlife Historical/Cultural and Ecological.
5.3.	Environmental Consequences Recommended Wild and Scenic 
River
This section discusses the No Action Alternative, and Action Alternative and the effects of 
implementation of those alternatives as they pertain to the Recommended Wild and Scenic River. 
As stated previously, rivers found eligible or suitable for the National System through federal 
agency planning processes are not protected by the Act from proposed projects. However, the 
managing agency should, within its authorities, protect the values (scenic, recreational, geologic, 
fish and wildlife, historic, cultural, or other similar values) that make the river eligible or suitable.

The desired future condition for recommended scenic rivers is free flowing with no substantial 
evidence of human activity. A few small community buildings or structures may be present and 
visible from the river. Evidence of timber harvest is not noticeable from this river, and lands 
appear natural when viewed from riverbanks. The river is accessible by roads which may 
occasionally bridge the river area. Short stretches of conspicuous or longer stretches of 
inconspicuous and well screened roads or railroads paralleling the river area may be permitted. 
5.3.1.	Alternative A  Bridge Option
A new Monte Cristo Grade Road Bridge would be constructed where an earlier bridge stood. 
The original bridge and piers were constructed in the 1930s. The original steel truss superstructure 
was removed in the 1970s, leaving the center concrete pier on the north side of the river and 
concrete abutments on the north and south banks. 
The existing center pier would need to be removed and replaced due to inadequate scour 
resistance and vertical load capacity. It is anticipated that the concrete abutment on the south 
side of the river would be left in place and modified to accommodate the new superstructure. If 
after more detailed analysis it is determined to be deficient, the abutment would be removed and 
replaced in the same location. A new abutment would also be constructed at the north end of the 
bridge at the end of 342"d Drive NE.
The new bridge would have an effect on free flow similar to that of the existing piers.  There 
would be additional short-term impacts during construction which would be mitigated by 
standard best management practices. Refer to the Recreation, Fisheries, and Wildlife sections for 
affects on those values.
5.3.2.	Alternative B  No Action
Under No Action Alternative the bridge would not be replaced and there would be no effects to 
the river.
6.	CUMULATIVE IMPACTS
Cumulative impacts are those that result from the incremental impact of a proposed action when 
added to other past, present, and reasonably foreseeable future actions regardless of what agency 
or person undertakes such other action (40 CFR 1508.7). Only those resources associated with 
cumulative effects are discussed below.
6.1.1.	Affected Environment
The project is in rural Snohomish County in an area dominated by federally owned forest, with 
scattered private and state-owned land. Land-disturbing activities in the basin include forestry 
and associated road building, residential housing construction, and minor amounts of mining 
(WSCC 1999). A number of flood repair road projects are being planned in the basin on federal 
and county land including culvert and bridge wash-out repairs on USFS land and a number road 
shoulder repairs in the Stillaguamish River drainage. The landslides at Gold Basin are a high 
priority for stabilization to minimize sediment input to the river. Snohomish County recently 
updated its Critical Areas Ordinance, which provides restrictions for land development near 
sensitive natural resources and requirements for mitigation of impacts.
6.1.2.	Environmental Consequences
6.1.3.	Alternative A  Bridge Option
Under Alternative A, construction of the bridge over the river would cause minor amounts of 
sediment to enter the river from construction. No long term effects to the river are anticipated.

The bridge would re-establish vehicle access for landowners and could lead to future 
development of properties that are currently undeveloped. However, the area is zoned as one 
structure per lot so development would be minimal and would not significantly contribute to 
basin-wide cumulative effects from land clearing. The County does not expect changes in zoning 
that would greatly increase the development along this road. This is a dead end road and there 
are currently no utilities along the Monte Cristo Grade Road. If the properties are developed, the 
county expects it to be primarily for seasonal, recreational use. 

Wild and Scenic River: There would be no effect to the South Fork Stillaguamish River 
Recommended Wild and Scenic River since the project replaces existing piers with similar 
structures in the same location. 

6.1.4.	Alternative B  No Action
For aquatic and terrestrial natural and physical resources, there would be no cumulative impacts 
associated with the No Action Alternative. Natural processes would continue to erode the right 
bank at the washout site, but this is the natural occurrence in a dynamic alluvial river system. 

7.	BIBLIOGRAPHY
7.1.	Literature Cited

Ambrose, J. 2008. Potential Bank Erosion and Maintenance Downstream of the proposed Monte 
Cristo Bridge, Verlot. Email communication to Lisa Wirt, P.E, Snohomish County Public 
Works from GeoEngineers, 600 Stewart Street, Suite 1700, Seattle, WA 98101, April 16, 
2008.

Ambrose, J. 2008. Draft Hydraulics Report, Proposed Monte Cristo Bridge, South Fork 
Stillaguamish River, GeoEngineers, 600 Stewart Street, Suite 1700, Seattle, WA 98101, 
April 25, 2008.

Barton, B. 1977. Short-term effects of highway construction on the limnology of a small stream 
in southern Ontario. Freshwater Biol., 7: 99-108.

Beamer, E. M. and R. A. Henderson. 1998. Juvenile Salmonid Use of Natural and 
Hydromodified Stream Bank Habitat in the Mainstem Skagit River, Northwest 
Washington. Skagit System Cooperative, La Conner, WA.

Bisson, P.A. and R.E. Bilby. 1982. Avoidance of suspended sediment by juvenile coho salmon. 
North American Journal of Fisheries Management 2: 371-374.

Dillon, J., T. Littleton, and J. Laufle. 1998. Literature review of revetment and canalization 
impacts on Pacific Northwest aquatic resources with implications to Skagit River, 
Washington. U.S. Army Corps of Engineers, Seattle District, Seattle, Washington.

FEMA. Draft Environmental Assessment: Reconstruction of the Monte Cristo Grade Road, 
Snohomish County, WA FEMA-1499-DR-WA (Public Assistance) April 2005.

Findley, D.P. and A.Q. Kammereck. 2004. Memorandum of findings related to the Monte Cristo 
flood damage site, Snohomish County, prepared for W&H Pacific, September 29.

Findley, D.P., R.J. Fraser, R.E. Sylwester, and R.L. Plum. 2005. Summary of findings related 
from the geophysical survey for Monte Cristo site road replacement from Stillaguamish 
River flood damage, , prepared for W&H Pacific, January 14.

Fraley, J.J., and B.B. Shepard. 1989. Life history, ecology, and population status of migratory 
bull trout (Salvelinus confluentus) in the Flathead Lake and River system, Montana. 
Northwest Science 63:133-143.

Gersib, R. 1997. Restoring wetlands at a river basin scale, a guide for Washington Puget Sound 
operational draft. Washington State Department of Ecology, Publication No. 97-99, 
Olympia.

Golder Associates Inc. 2008. WHP/Monte Cristo Bridge Road Realignment Geotechnical 
Investigation, Snohomish Washington prepared for W & H Pacific, April 28.

Li, H. W. 1994. Cumulative Effects of Riparian Disturbances along High Desert Trout Streams 
of the John Day Basin, Oregon. Transactions of the American Fisheries Society 123:627-
640.

McShane, C. , T. Hamer, H. Carter, G. Swartzman, V. Friesen, D. Ainley, R. Tressler, K. Nelson, 
A. Burger, L. Spear, T. Mohagen, R. Martin, L. Henkel, K. Prindle, C. Strong, and J. 
Keany. 2004. Evaluation report for the 5-year status review of the marbled murrelet in 
Washington, Oregon, and California. Unpublished report. EDAW, Inc. Seattle, 
Washington. Prepared for the U.S. Fish and Wildlife Service, Region 1. Portland, 
Oregon.

Miller, C. and D. Somers. 1989. TFW Stillaguamish River early action project. Tulalip Tribes 
Natural Resources Department, Marysville, WA.

Pelletier, G. and D. Bilhimer. 2001. Stillaguamish River temperature total maximum daily load. 
Quality assurance project plan. Washington Dept. Ecology. Publ. No. 01-03-066. 21pp.

Peter, D. 1999. Subregional Ecological Assessment (REAP) for Mt. Baker-Snoqualmie National 
Forest. Report from the Subregional Ecological Assessment Team. USDA, Forest Service, 
Mountlake Terrace, WA.

Pratt, K.L. 1992. A review of bull trout life history. Pages 5-9 in: P.J. Howell Buchannan editors, 
Proceedings of the Gearhart Mountain Bull Trout Chapter of the American Fisheries 
Society, Corvallis, Oregon.

Rieman, B.E. and J.D. McIntyre. 1996. Spatial and temporal variability in bull trout redd counts. 
North American Journal of Fisheries Management 16:132-141.

Rieman, B.E., D.C. Lee, and R.F. Thurow. 1997. Distribution, status and likely future trends of 
bull trout within the Columbia River and Klamath River basins. North American Journal 
of Fisheries Management 17:1111-1125.

SCSWM (Snohomish County Surface Water Management). 2002. The effects of selected 
forested practices on flooding in the Stillaguamish River Basin. Final Issue Paper #1. 
Prepared for Planning Advisory Committee for the Stillaguamish River Comprehensive 
Flood Management Plan.

SHPO (State Historic Preservation Office). 2004. Electronic geospatial National and State 
Historic Register, Historic Property Inventory, and Historic/Archaeological Sites and 
Districts data. 

SLE 	(Stillaguamish Lead Entity). 2004. 2004 Stillaguamish Lead Entity Strategy. Prepared for 
Stillaguamish Implementation Review Committee & Washington State Salmon Recovery 
Funding Board.

STAG (Stillaguamish Technical Advisory Group). 2000. Technical Assessment and 
Recommendations for Chinook Recovery in the Stillaguamish Watershed. 

Stinson, D.W., J.W. Watson, and K.R. McAllister. 2001. Washington State Status Report for the 
Bald Eagle. WDFW. Olympia, Washington. USDI (U.S. Department of the Interior). 
2003. Estimates of distances at which incidental take of murrelets and spotted owls due 
to harassment are anticipated from sound-generating, forest-management activities in 
Olympia National Forest. Fish and Wildlife Service, Lacey, WA.

U.S. Soil Conservation Service. 1983. Snohomish County Soil Survey.

Van Wormer, M.S. 2005. Monte Cristo Grade Road 2003 Flood Damage Repair Conceptual 
Design. Prepared by W&H Pacific, Bothell, WA. For Snohomish County Public Works 
Department, Everett, Washington.

WDF (Washington Department of Fisheries). 1975. A Catalog of Washington Streams and 
Salmon Utilization. Vol. 1 Puget Sound.

WDFW (Washington Department of Fish and Wildlife). 1998. Washington state salmonid stock 
inventory: bull trout/Dolly Varden. Olympia.

WDFW. 2003. Design of road culverts for fish passage. Olympia, Washington.

WDFW. 2004a. Fishing in Washington: Sport Fishing Rules. 2004/2005 Pamphlet Edition. 
Washington Department of Fish and Wildlife. Olympia, WA.

WDFW. 2004b. Salmonid Stock Inventory. Updated Bull Trout and Dolly Varden. Appendix.

WDNR (Washington State Department of Natural Resource). 1997. Habitat Conservation Plan.

WDOE (Washington Department of Ecology). 1981. Stillaguamish River Basin Instream 
Resources Protection Program Including Proposed Administrative Rules. Draft. 
W.W.I.R.P.P Series  No. 10. 67pp.

WDOE and SCPW. 2003. Draft Public Review Stillaguamish River Comprehensive Flood m 
Hazard Management Plan. May 19, 2003.  

WSCC (Washington State Conservation Commission). 1999. Salmon Habitat Limiting Factors 
Water Resource Inventory Area 5, the Stillaguamish Watershed.
7.2.	Internet Sources
Snohomish County. 2004. Snohomish County Online Property Information on internet at: 
http://gis.co.snohomish.wa.us/maps/property/index.htm.

Snohomish County. 2004. Interactive Permit and Zoning Map on internet at: 
http://gis.co.snohomish.wa.us/maps/permits/index.htm.

StreamNet Fish Data Website. http://www.streamnet.org/pub-ed/ff/Species/index.html

USFS Pacific Northwest Fisheries Program Website. 
http://www.fs.fed.us/r6/fishing/forests/fishresources/mtbsno_coldwater.html#dollybull

USGS. 2004. website URL = http://nwis.waterdata.usgs.gov/wa/nwis/monthly/ 
?site_no=12161000&agency_cd=USGS

U.S. Census 2000. Website URL =http://www.psrc.org/datapubs/census2000/sf1/index.htm.

8.	LIST OF PREPARERS

2008 Environmental Assessment

Snohomish County Public Works,
	 Mary Auld, Senior Environmental Planner
	 Tony Stigall, Senior Environmental Planner
       Steve Cole, Senior GIS Analyst
       Robert Raynor, Engineering Technician V

FEMA, Region X
 Charles E. Diters, Historic Preservation Specialist

2005 Draft Environmental Assessment 

EDAW, Inc.
 Jim Keany, Project Manager and Lead Ecologist
 Kirk Prindle, Terrestrial and Wetlands Ecologist
 Ron Tressler, Ecologist
 Chris Stoll, GIS Specialist

FEMA Region X
 Mark Eberlein, Region X Environmental Officer
 Bert Bowen, Environmental Specialist

9.	APPENDIX A: BEST MANAGEMENT PRACTICES

Permits and Regulations 

 The project will implement conditions included in any Hydraulic Project Approval (HPA) 
permit provided by WDFW. 

 Mitigation required by Snohomish Countys Critical Areas Ordinance will be developed in 
coordination with Snohomish County staff. 

 No in-water work will be conducted in the mainstem South Fork Stillaguamish River. 

Stormwater Control 

 A site-specific Spill Prevention, Control, and Countermeasures (SPCC) Plan will be 
developed and implemented to ensure that all pollutants are controlled and contained 
(provided by contractor).

 In the event of unexpected rainfall, all concrete, paving, paint, paint remover, or other 
potentially harmful chemicals will be contained and prevented from leaving the construction 
area. 

 Fueling and maintenance of equipment will occur more than 150 feet from surface water or 
wetlands, to the extent practical. 

Sediment Control 

 An Erosion and Sedimentation Control Plan (ESCP) will be prepared and implemented for 
all projects that require earth-moving, vegetation removal, or soil compaction. If the project 
includes excavation below the water table, the turbid water will be de-watered to the 
adjacent vegetated floodplain for infiltration and BMPs will be implemented to eliminate risk 
of runoff. 

 Turbid water generated by excavation below the water table will be pumped from the 
excavation area and discharged to a vegetated area. 

 Exposed soil will be stabilized within 7 days of disturbance. 

 Disturbed areas will be restored and revegetation implemented using plants native to the 
area. 

 Temporary storage piles will not be placed in the 100-year floodplain from October 1 to 
May 1. Storage piles used in the project within 12 hours will not be considered as temporary 
storage. 

 Project-caused unstable slopes will be stabilized as soon as possible. 

Clearing and Disturbance 

 Clearing and grading will be limited to the minimum necessary to complete the project. 
Boundaries of clearing will be clearly marked.

 Removed debris will be disposed of at an appropriate upland location. 

 A temporary access road will be constructed from 342nd Drive NE to the center pier.

 Cobbles and rocks removed from the beach for crane pads and temporary construction 
access will be restored to the extent possible following construction

Implementation 

 The Applicant is responsible for Conservation Measure success to ensure desired outcomes. 
The Applicant will be required to monitor and maintain Conservation Measures to control 
erosion and sediment, reduce spills and pollution, and provide habitat protection. Failure to 
properly implement Conservation Measures may result in loss of all financial assistance 
provided for that project.

10.	APPENDIX B: CONSERVATION MEASURES 
The following Conservation Measures identified during the environmental process will be 
implemented during construction of this project in addition to the Best Management Practices.

Decking material 
The decking material was originally planned to be constructed as a steel grate. The decking 
material has been changed to untreated wood. The wood decking will reduce the amount of 
noise generated.

Signage
Additional signage will be installed on the new bridge as approved by Snohomish County Traffic 
Operations.

Project timing
Work occurring on the gravel bar during the dry season will adhere to the in-water work window 
as specified by Washington Department of Fish and Wildlife (WDFW) in the Hydraulic Permit 
Approval, anticipated to be July 15 to August 15. 

Tree removal
The construction sequencing has been modified during the design process to greatly reduce the 
number of trees to be removed. The original design showed a temporary construction road down 
to the beach as access for the crane. An alternate design has since been developed to use the 
existing, already-cleared right-of-way as the crane access instead of clearing vegetation for a new 
access road. This change minimizes the number of trees to be removed and disturbance to the 
gravel bar.

Riparian restoration
Following construction of the bridge, approximately 8,500 square feet of the existing Monte 
Cristo Grade Road on the south side of the river will be abandoned and decommissioned. 
Approximately 280 linear feet of the old road will be planted with native trees and shrubs. Over 
time, this replanted riparian area will provide habitat and cover for a variety of wildlife species. 
The plantings will be monitored and maintained by the County to ensure successful establishment 
of a native vegetation community.

11.	APPENDIX C: BIOLOGICAL ASSESSMENT

Biological Assessment
Monte Cristo Grade Bridge
PW# 06-00976, RC1513

 

August 2008

Prepared for:
Federal Emergency Management Agency
by

Snohomish County Public Works
3000 Rockefeller Avenue
Everett, WA 98201

TABLE OF CONTENTS
EXECUTIVE SUMMARY	v
1.	INTRODUCTION	1-1
1.1 Purpose	1-3
1.2 Consultation history	1-3
1.3 Methods	1-3
1.3.1 Literature Review and Personal Communications	1-3
1.3.2 Geographic Information Systems Data	1-4
1.3.3 Field Investigations	1-4
1.3.4 Effect Determinations	1-4
1.3.5 Documentation	1-4
2.	ACTION AREA And site  DESCRIPTION	2-1
2.1 ACTION AREA	2-1
2.2 GENERAL SITE CHARACTERISTICS	2-3
2.3 AQUATIC RESOURCES	2-3
2.4 Terrestrial resources	2-6
3.	PROPOSED ACTION	3-1
3.1 PROJECT PURPOSE	3-1
3.2 PROPOSED ACTION and Construction Disturbance	3-1
3.2.1 Bridge Construction	3-1
North Abutment	3-3
Gravel Bar Work Pad	3-3
Center Pier	3-3
South Pier	3-4
Bridge Span Placement and Site Restoration	3-4
3.2.2 Approach Roads	3-4
3.2.3 Impervious Area and Stormwater Treatment Facilities	3-4
3.2.4 Road Decommissioning	3-5
3.3 Indirect and interrelated activities	3-5
3.4 Conservation Measures and Best Management practices	3-6
3.4.1 Conservation Measures	3-6
3.4.2 Best Management Practices	3-6
4.	FISH SPECIES EVALUATIONS	4-1
4.1 CHINOOK SALMON	4-1
4.1.1 ESA and Stock Status	4-1
4.1.2 Chinook Salmon in the Action Area	4-2
4.1.3 Critical Habitat	4-2
4.2 BULL TROUT	4-4
4.2.1 ESA and Stock Status	4-4
4.2.2 Bull Trout in the Action Area	4-4
4.2.3 Critical Habitat	4-4
4.3 STEELHEAD	4-6
4.3.1 ESA and Stock Status	4-6
4.3.2 Steelhead in the Action Area	4-6
4.3.3 Critical Habitat	4-6
5.	WILDLIFE SPECIES EVALUATIONS	5-1
5.1 Marbled Murrelet	5-1
5.1.1 ESA Status and Distribution	5-1
5.1.2 Marbled Murrelets in the Action Area	5-1
5.1.3 Critical Habitat	5-2
6.	EFFECTS to LISTED SPECIES and critical habitat	6-1
6.1 Riparian Vegetaion	6-1
6.2 Water Quality	6-1
6.3 Noise and Sound Pressure	6-3
6.4 channel conditions	6-4
6.5 EFFECT DETERMINATIONS	6-5
6.5.1 Effect Determinations for Chinook, steelhead, and bull trout	6-5
6.5.2 Effect Determination for Marbled Murrelet	6-6
6.5.3 Critical Habitat Determination for Chinook and bull trout	6-6
6.5.4 Critical Habitat Determination for Marbled Murrelet	6-7
7.	REFERENCES	7-1
 APPENDICES
A	Essential Fish Habitat Consultation
B	Project Plans
C	Pathway and Indicators Discussion
D	Listed Species Life Histories
E	Project Area Photos
 

ACRONYMS
BE	Biological Evaluation
BMPs	best management practices
BMU	bear management unit
cfs	cubic feet per second
DDT	dicholo-diphenyl-tricholoroethane
DPS	distinct population segment
DPSs	distinct population segments
EFH	Essential Fish Habitat
ESA	Endangered Species Act
ESU	evolutionarily significant unit
LWD	large woody debris
MBSNF	Mount Baker-Snoqualmie National Forest
MSA	Magnuson-Stevens Act
NMFS	National Marine Fisheries Service
NOAA	National Oceanic and Atmospheric Administration
OHWM	ordinary high water mark
PCE	primary constituent element
PHS	Priority Habitats and Species
RM	river mile
ROS	rain-on-snow event
TESC	temporary erosion and sediment control
USFWS	U.S. Fish and Wildlife Service
USGS	United States Geologic Survey
WDFW	Washington Department of Fish and Wildlife
WDNR	Washington Department of Natural Resources
WRIA	Water Resources Inventory Area
WSDOT	Washington State Department of Transportation

 EXECUTIVE SUMMARY
Snohomish County proposes to construct a single lane, steel truss bridge across the South Fork 
(SF) Stillaguamish River to restore vehicle access to approximately 20 properties. The County 
will receive funding from the Federal Emergency Management Agency (FEMA). A Clean Water 
Act Section 404 permit is required for proposed temporary fill within waters of the United States 
from the U.S. Army Corps of Engineers (USACE).  The federal funding and Corps permit 
constitute federal actions under Section 7 of the Endangered Species Act (ESA). Since the 
project may affect threatened species, consultation with the U.S. Fish and Wildlife Service 
(USFWS) and the National Marine Fisheries Service (NMFS) is required.
Snohomish County has prepared this Biological Assessment (BA) on behalf of FEMA to 
determine the potential effects of the proposed Federal action on threatened and endangered 
species and their critical habitats. 
The County is proposing to construct a bridge across the SF Stillaguamish to reconnect 342nd Dr 
NE to the Monte Cristo Grade Road at the site where a bridge was removed 30 years ago. The 
Monte Cristo Grade Road parallels the SF Stillaguamish and a portion was severely damaged by 
record flooding in October 2003, making it impassable. Replacing the road would cause 
extensive impacts to wetlands, streams and riparian buffers. To avoid those impacts, the County 
is proposing to build the bridge. 342nd  Drive NE is approximately 550 feet long and connects to 
the south side of the Mountain Loop Highway at mile post 11.6, east of the Verlot Ranger 
station. This road currently ends at the SF Stillaguamish River, directly across from the Monte 
Cristo Grade Rd. The half mile of road between the original start of the Monte Cristo Grade 
Road and where the bridge will connect to the Monte Cristo Grade Rd will be decommissioned 
and used as a conservation measure. 
The two abutments and the center pier still remain of the old bridge. The south abutment is 
located on bedrock above the Ordinary High Water Mark (OHWM) and is assumed to be used 
for the new bridge. The existing center pier is not structurally adequate to support the new 
bridge. The center pier will be replaced in approximately the same location, which is above the 
OHWM. The north abutment is located in the road and will be replaced with deeper piles. The 
bridge will cross the SF Stillaguamish River at river mile (RM) 47.
Potential effects of the project on federally listed species include: removal of riparian vegetation; 
work below the OHWM, but outside of the wetted channel; potential sedimentation; and 
construction related noise and vibrations.
Avoidance and minimization measures include: locating the bridge piers above the OHWM of 
the SF Stillaguamish River; scheduling work below the OHWM to occur during summer low 
flows between July15-August15 to avoid in-water work and minimize impacts to ESA-listed 
species; and employing standard sedimentation and erosion control measures. No in-water work 
will occur. All work below the OHWM will be above the wetted channel.
Conservation measures include restoring riparian vegetation, decommissioning part of the old 
road and enhancing it with riparian vegetation.
Analyses of potential impacts were made based on a review of plans for the proposed action, an 
on-site evaluation of existing habitat conditions, data on the current and historical distributions 
of each species, and personal communications with local agency biologists. Based on this review, 
determinations of effects were made for the proposed project, and are summarized in the Table 1.
Essential Fish Habitat (EFH) consultation with NMFS is required and effects to EFH are 
documented in Appendix A of this BA.

Table 1. Summary of Effects for Listed Endangered and Threatened Species, Critical Habitat and EFH
Common 
Scientific
ESA Status
Life Stages 
Considered
Effect Determination
Chinook salmon  
Oncorhynchus tshawytscha
Threatened
All freshwater 
phases
May affect, not likely to adversely affect
Chinook salmon critical habitat
N/A
N/A
May affect, not likely to adversely affect
Bull trout 
Salvelinus confluentus
Threatened
All freshwater 
phases
May affect, not likely to adversely affect
Bull trout critical habitat
N/A
N/A
May affect, not likely to adversely affect
Steelhead
O. mykiss
Threatened
All freshwater 
phases
May affect, not likely to adversely affect 
Marbled Murrelet
Brachyramphus marmoratus
Threatened
Nesting
May affect, not likely to adversely affect
Marbled Murrelet Critical 
Habitat
N/A
N/A
May affect, not likely to adversely affect
Essential Fish Habitat
N/A
N/A
May adversely  affect

12.	INTRODUCTION

Severe flooding of the SF Stillaguamish River in October 2003 resulted in the destruction of the 
east end of the Monte Cristo Grade Road in central Snohomish County, cutting off access to 
approximately 20 properties. The river migrated approximately 60 feet to the east, eroding a high 
bank and approximately 200 linear feet of the Monte Cristo Grade Road. 

In response to widespread flooding in October and November 2003, a federal disaster was 
declared for Snohomish County. The County requested federal financial assistance from the 
Federal Emergency Management Agency (FEMA) for the repair of damaged public facilities, 
including the Monte Cristo Grade Road. The purpose of this project is to restore vehicular access 
to the property owners along the Monte Cristo Grade Road.  FEMA is funding construction of a 
bridge over the SF Stillaguamish River as an alternative to replacing the portion of Monte Cristo 
Grade Road that was damaged by the flood.  Snohomish County has proposed the bridge 
alternative because rebuilding the Monte Cristo Grade Road would have far greater impacts to 
wetlands, riparian areas, and habitat for listed species.  

The project will be constructed in summer 2009 and is located east of Verlot on 342nd Drive NE 
in Section 15, Township 30N, Range 8E (Figure 1) at river mile (RM) 47 of the SF Stillaguamish 
River.

 
12.1.	Purpose
Section 7 of the Endangered Species Act (ESA) requires that federal agencies consult with the 
US Fish and Wildlife Service (USFWS) and/or the National Marine Fisheries Service (NMFS) if 
their actions may affect listed species or critical habitat to ensure that they are not funding, 
permitting, or authorizing actions likely to jeopardize the continued existence of listed species or 
destroy or adversely modify designated critical habitat. This project involves two federal actions: 
FEMA funding of the repair and the Corps issuance of a Section 404 permit under the Clean 
Water Act. The County prepared this biological assessment (BA) for FEMA for consultation on 
the federal actions with the NMFS and USFWS.  This BA addresses the direct and indirect 
effects of the funding and Section 404 permitting actions, as well as effects associated with any 
interdependent and interrelated activities on ESA-listed species, designated or proposed critical 
habitat.  Because the project may adversely affect Essential Fish Habitat (EFH) designated per 
the Magnuson-Stevens Fishery Conservation and Management Act, consultation with NMFS 
regarding effects to EFH is also required. Effects to EFH will be similar to effects to critical 
habitat and the analysis of effects to EFH is included in Appendix A.
The County obtained listed species likely to occur in the project vicinity from the most recent 
USFWS and NMFS websites. From these sources, communications with local biologists, and 
evaluation of suitable habitat, we have determined that Chinook salmon, steelhead, bull trout and 
marbled murrelet may occur in the project vicinity (Table 1). Designated critical habitat for 
Chinook salmon, bull trout, and marbled murrelet also occurs in the project vicinity. No federally 
listed plant species were identified in the action area.  
Suitable habitat for northern spotted owl is not present in the action area and the action area is 
not located within an established territory management circle (WDFW PHS 2006). The nearest 
spotted owl site center is over 2 miles outside of the action area.
Based on current land uses, level of human presence in the vicinity of the project, and lack of 
suitable habitat and critical habitat in the action area, the project will have no effect on northern 
spotted owl, Canada lynx, gray wolf, grizzly bear, or Southern Resident Killer Whale; these 
species will not be discussed further.
12.2.	Consultation history
FEMA issued an Environmental Assessment addressing rebuilding the road. The bridge is a new 
proposal and is considered a new project by FEMA.
Pre-consultation meetings and site visits were held with Suzy Lutey and Jim Muck (USFWS) 
and with Tom Sibley, Sean Gross, Brett Farman, and Dan Tonnes (NMFS) between early 2004 
and 2008. The Stillaguamish and Tulalip tribes were also notified. Representatives of the Services 
responded and consistently conveyed that rebuilding or realigning the damaged section of the 
Monte Cristo Grade Road would have impacts to listed species and strongly encouraged the 
County and FEMA to propose a lower impact alternative.  Neither agency concurred with the 
effects call in the BA submitted June 9, 2005. This input was used to develop this proposal to 
build a bridge over the SF Stillaguamish to access the intact portion of the Monte Cristo Grade 
Road and associated properties, greatly reducing potential impacts to riparian habitat.  
12.3.	Methods
12.3.1.	Literature Review and Personal Communications 
Existing literature and scientific data were reviewed to determine species distribution, habitat 
requirements, and other pertinent biological requirements.  Federal, state and county biologists 
were also consulted to provide local information about listed species in the project vicinity. 
Literature and data sources are summarized in References (Chapter 7).
12.3.2.	Geographic Information Systems Data
Using geographic information systems (GIS), natural resource related data was reviewed to 
thoroughly document all sensitive species and habitats associated with the proposed project. This 
included the Washington Department of Fish and Wildlife (WDFW) Priority Habitat and Species 
(PHS) and Salmonscape database, National Wetlands Inventory (NWI), Department of Natural 
Resources (DNR) soils and hydrography information, and Snohomish Countys Chinook salmon 
and bull trout distribution GIS coverages.
12.3.3.	Field Investigations
On-site investigations of the project site were conducted by County environmental staff to 
evaluate the environmental baseline, probability of species presence, and existing habitat 
conditions.  Site investigations were conducted between 2003-2008 during all seasons of the 
year.  General habitat suitability for each of the subject species was assessed. The extent of 
potential project impacts to potential species habitat was also evaluated in the field. 
12.3.4.	Effect Determinations
Direct and indirect effects of the action were analyzed using the information compiled from the 
literature review and site visits, review of engineered drawings, and consultation with project 
engineers and agency staff.  Direct effects considered include physical impacts to the species as 
well as critical habitat (where designated) that could potentially result from construction 
activities.  Indirect effects include effects that are caused by the proposed action and occur later 
in time.  Indirect effects evaluated include potential changes to habitat that could evolve 
following project construction and future disturbance related to project operation and 
maintenance.
Potential interrelated, interdependent activities and beneficial effects were also evaluated. 
Interrelated activities include activities that are part of the proposed action and depend on the 
proposed action for its justification. Interdependent activities include those activities that have 
no independent utility apart from the action under consultation.
Proposed conservation measures are intended to reduce or minimize project impacts, thus 
avoiding the take of listed species. Appropriate conservation measures have been developed 
through coordination between County biologists, the federal services, state and Tribal biologists, 
and project managers, and are considered when making the final effect determinations. 
12.3.5.	Documentation
The findings from the above tasks are documented in this BA. The presumed, historical and/or 
documented presence of these species and the level of known use within the project site are 
presented herein. General requirements and habits such as timing of spawning and vulnerability 
to the proposed construction activities are addressed for species that are threatened or 
endangered. Proposed conservation measures that will avoid, minimize, or mitigate the impacts 
of the proposed construction activities on listed species and their critical habitat are also 
presented. All of this information has been considered to make effect determinations for each 
species.

13.	ACTION AREA AND SITE  DESCRIPTION 
13.1.	ACTION AREA
The action area includes all areas to be affected directly or indirectly by the project.  Potential 
direct and indirect effects include: 1) clearing of riparian vegetation; 2) water quality; 3) 
construction noise; and 4) altered channel conditions.  The project will not increase the pre-
disaster traffic capacity of Monte Cristo Grade Road and will not result in increased traffic.  
Although Best Management Practices (BMPs) will be used to minimize or eliminate in-stream 
effects of the project, there is some potential for sediment or debris to enter the river at the 
project site.
Sediment and erosion control, as well as spill control and containment BMPs, will minimize the 
potential for the project to degrade water quality.  Due to the large volume of the receiving water 
body, any sediment introduced into the river should not be detectable beyond 300 feet 
downstream (using criteria of the 1998 Surface Water Quality Standards Agreement between the 
Washington State Department of Transportation and Ecology, which specifies a downstream 
point of compliance for turbidity standards based on flow rates during construction). 
Due to proximity of the project to the Mt. Loop Highway and the river, construction noise (e.g. 
heavy equipment operation, gravel dumping, and trucks) will not generate noise in excess of 
ambient noise levels beyond 0.5 miles from the site.  
Minor road maintenance of the Monte Cristo Grade Road downstream of the bridge site will be 
required after the bridge is constructed. The road profile will be raised to prevent water from an 
adjacent wetland from overtopping and eroding the road. This work will not be funded by 
FEMA and may not have any federal nexus; at this time, the County has not determined if the 
work will require a Section 404 permit.  However, because the road maintenance cannot be 
completed until the bridge is constructed, the maintenance is considered an interdependent and 
interrelated activity and potential effects of the maintenance is accounted for in the delineation 
of the action area and subsequent analysis of effects.
Conservation measures, including decommissioning of the Monte Cristo Grade Road segment 
upstream of the bridge site, will extend approximately 0.5 miles upstream on the south bank of 
the river. Conservation measures will take place on the portion of road, between the road 
washout and the proposed bridge.  
With these factors in mind, the action area for the project (Figure 2) includes: 1) the entire project 
limits; 2) the SF Stillaguamish River 300 feet downstream of the bridge site and adjacent to the 
conservation sites upstream of the bridge; and, 3) 1 mile west along the Monte Cristo road and 
the adjacent terrestrial habitat within 0.5 miles of the project limits. 
The actions area outlined above is a conservative estimate of the extent to which water quality 
impacts could result from the proposed project should best management practices (BMPs) fail, 
and in which noise disturbance from construction activities has the potential to affect wildlife 
species. 

13.2.	GENERAL SITE CHARACTERISTICS
The project is located near Verlot within Township 30, Range 8E, Section 15 in eastern 
Snohomish County (Figure 1). Topography in the project area is gentle along the Mountain Loop 
Highway. Second growth conifer forest is the dominant vegetation type surrounding the project 
area. Forested plant associations identified in the area include the western hemlock/swordfern 
(Polystichum munitum), foamflower (Tiarella trifoliata), and western hemlock/Alaska huckleberry 
(Vaccinium alaskaense) associations (Henderson et al. 1992). 
The project is located off of the Mt. Loop Hwy on 342nd Drive NE, a short road which currently 
ends at the river, but crossed the SF Stillaguamish via a bridge, approximately 30 years ago.  The 
concrete abutments and central pier of the original bridge are still standing at the site. The north 
side of the bridge site is adjacent to a community of several residences. The south side of the 
bridge will connect to the Monte Cristo Grade Road providing access to approximatlely 20 
private parcels and US Forest Service land. Approximately 20 parcels of private property 
including one cabin are located near the western terminus of the Monte Cristo Grade Road. 
The north abutment of the original bridge is located in the existing road of 342nd Dr NE. There 
are driveways on both sides of 342nd near the abutment. In the northwest quadrant of the bridge 
site, the front yard and carport of the adjacent home extends into the right-of way and 
Snohomish County is addressing this with the property owner. In the northeast quadrant the 
adjacent yard is forested along the road.
The center pier of the original bridge is located approximately 4 feet landward of the Ordinary 
High Water Mark (OHWM) of the SF Stillaguamish River (Appendix E photos). The 2003 flood 
was considered a 300-year event and much of the vegetation around the pier was removed by the 
flood waters. Water rose 10 feet above the OHWM (Van Wormer 2005). Trees were removed by 
the flood, on all sides of the pier and sand was deposited along the east and north side of the 
pier. A large gravel bar is located waterward of the pier. The bar consists of small boulders, 
cobbles and sand. 
The south abutment of the original bridge is located on bedrock on the near vertical wall of the 
left river bank (Appendix E photos). The abutment is approximately 15 feet above the river. The 
terrain on the south side of the river is very steep with the Monte Cristo Grade Road bed 
benched into the hill side. The area landward (south) of the Monte Cristo Grade Road is 
forested. 
13.3.	AQUATIC RESOURCES
The SF Stillaguamish River flows from east to west through the action area (6th field HUC 
17110080206).  The Stillaguamish River is the fifth largest tributary to the Puget Sound and is 
one of its most important salmon-bearing streams.  The Stillaguamish River has two primary 
tributaries, the North Fork (NF) Stillaguamish River and SF Stillaguamish River. The SF 
Stillaguamish River drains 255 square miles, 37 percent of the Stillaguamish River watershed 
(USFS 1995), and is divided into eight sub-basins.
The project lies in the middle of the Robe Valley sub-basin (24 mi2), which is bounded at its 
downstream end by the mouth of Cranberry Creek and at the upstream end by the mouth of 
Twenty-two Creek. The Robe Valley sub-basin contains about 4 miles of river channel and 10 
tributary streams, including Turlo Creek.  About 60% of the Robe Valley sub-basin is in the 
national forest. There are approximately 15 miles of river and 309 miles of tributary streams that 
drain to the site (NMFS and USFWS 2005).
About 1/3 of the Robe Valley sub-basin is privately owned; over 90% of the sub-basin has been 
logged in the past.  Most of the tributaries are steep, with very little floodplain. Within this sub-
basin, the river is confined between the Mountain Loop Highway and alternating bedrock 
outcrops, bluffs, and narrow bands of floodplain along the left (south) bank. Much of the left 
bank is composed of bedrock; much of the non-bedrock banks are covered with rock riprap to 
protect an abandoned railroad grade. Most of the riparian areas along the river are composed of 
maturing second growth, much of it deciduous tree species. Tributary streams in the upper two 
sub-basins have good riparian canopy cover.
The streambed at the project site consists primarily of cobbles, gravel, sand, and silt. A large 
gravel bar is present along the right (north) bank.  The gravel bar is largely exposed during typical 
and low flows, but is wet during freshets and flood events.  The riverbed contains a tremendous 
amount of silt and fines from upstream landslides, bank sloughing, erosion, and logging practices.
Habitat condition in the SF Stillaguamish have been degraded by logging practices, resulting in 
higher stream temperatures, flooding, sedimentation and loss of large woody debris (WDFW 
1998).
Chinook salmon use the habitat in the action area for rearing, holding for adults, and migration. 
Steelhead use the habitat in the action area for spawning, rearing, and migration. Bull trout use 
the habitat in the action area for foraging, migration, and overwintering of subadults and adults. 
Conditions in the action area likely contribute less to the conservation of bull trout, steelhead and 
Chinook than historically because upstream actions have altered water and sediment dynamics 
such that habitat conditions expressed at this time are not fully functional. 
The Checklist for Documenting Environmental Baseline and Effects of Proposed Actions(s) on 
Relevant Indicators (NMFS 1996) is included as Table 2 and was used to assess current baseline 
parameters as well as to guide the determination of effect for the proposed action on Chinook 
salmon, bull trout, and steelhead. Descriptions of the individual parameters are presented in 
Appendix C. The evaluation is based on site visits, review of available information, and best 
professional judgment.
 

Table 2. Checklist for Documenting Environmental Baseline and  
Effects of Proposed Action(s) on Relevant Indicators
PATHWAYS:
	INDICATORS
ENVIRONMENTAL BASELINE
EFFECTS OF THE ACTION(S)

Properly1 
Functioning
At Risk1
Not Properly1 
Functioning
Restore2
Maintain3
Degrade4
Water Quality:
	Temperature

X 

X

	Sediment/Turbidity

X

X

	Chemical Contaminants/Nutrients

X

X

Habitat Access:
	Physical Barriers
X

X

Habitat Elements:
	Substrate

X

X

	Large Woody Debris

X

X

	Pool Frequency 
 

X

X 

	Pool Quality
 

X

X 

	Off-channel Habitat

X

X

	Refugia
X 

X 

Channel Conditions and Dynamics:
	Width/Depth Ratio

X

X

	Streambank Condition
X

X

	Floodplain Connectivity

X

X

Flow/Hydrology:
	Peak/Base Flows

X

X

	Drainage Network Increase

X

X

Watershed Conditions:
	Road Density and Location

X

X

	Disturbance History

X

X

	Riparian Reserves

X

X

Watershed Names: SF Stillaguamish River	Location: T30N, R8E, Sec15
1	These three categories of function (properly functioning, at risk, and not properly functioning) are defined for each indicator in 
the Matrix of Pathways and Indicators.
2	For the purposes of this checklist, restore means to change the function of an at risk indicator to properly functioning  
(i.e., it does not apply to properly functioning indicators).
3	For the purposes of this checklist, maintain means that the function of an indicator does not change (i.e., it applies to all indicators 
regardless of functional level).
4	For the purposes of this checklist, degrade means to change the function of an indicator for the worse (i.e., it applies to all 
indicators regardless of functional level). In some cases, a not properly functioning indicator may be further worsened, and this 
should be noted.
13.4.	Terrestrial resources
Terrestrial habitats within the action area consist of upland and riparian forests. The forest 
overstory within the action area is composed primarily of mature, second growth western 
hemlock, Douglas-fir (Pseudotsuga menziesii), and red alder (Alnus rubra) with occasional 
western red cedar (Thuja plicata), Sitka spruce (Picea sitchensis), or big-leaf maple (Acer 
macrophyllum). Vine maple (Acer circinatum), huckleberries (Vaccinium spp.), and salmonberry 
(Rubus spectabilis) are common shrubs. 
Suitable habitat for marbled murrelets to nest is defined as mature and old-growth forest with 
limbs greater than 4 inches in diameter and a height of 33 feet or greater from the ground to 
provide a platform for a nesting adult. It is important for the platform to have vertical and 
horizontal cover (branches that provide protection to the side and from above). Murrelets appear 
to select limbs and platforms that provide protection from predation (USFWS 2006).
The action area includes potential nesting habitat for marbled murrelets, and is designated 
marbled murrelet critical habitat. Primary constituent elements (PCEs) for marbled murrelet 
critical habitat that may be present within the action area include: 1) individual trees with 
potential nesting platforms; and 2) forested areas within 0.8 kilometers (0.5 miles) of individual 
trees with potential nesting platforms, and with a canopy height of at least one-half the site-
potential tree height.
The Monte Cristo Grade road runs parallel to the south side (left bank) of the river. The road is 
bordered on the south by second growth forest. The forested area is exposed on one side due to 
the road cut and the adjacent river. The area has been logged in the past; however there are 
individual trees that have potential nesting platforms within the action area. These trees appear to 
be marginal habitat due to the lack of cover and the small diameters of the platform. These trees 
meet the 4 inch minimum criteria; however nesting success is thought to be rare at less than 7 
inches (USFWS pers. comm., 2007).

14.	PROPOSED ACTION
14.1.	PROJECT PURPOSE
The purpose of the project is to construct a bridge to restore vehicular access to the property 
owners along the Monte Cristo Grade Rd. Access was cut off during the 2003 flood when 
approximately 200 linear feet of road and 40,000 cubic yards of high bank and bluff eroded into 
the river. Originally, the County planned to restore the road upslope of the washout. However, 
that proposal would have adversely affected several streams, a large wetland system, and riparian 
resources. During the previous consultation, both NOAA and USFWS supported a no action 
alternative. The new road would have been in the channel migration zone and may have 
continued to erode. The alternative of constructing a bridge where a bridge was previously 
located minimizes the impacts to the environment.
14.2.	PROPOSED ACTION and Construction Disturbance
14.2.1.	Bridge Construction
The new bridge will be constructed on the same alignment as the existing bridge abutments on 
342nd Dr., in order to minimize short- and long-term effects to natural resources. The bridge will 
utilize the existing south abutment.  The existing center pier and north abutment are insufficient 
to support the new bridge and will be removed and reconstructed in their same approximate 
footprint (see Figure 3 and plans in Appendix B). The bridge will be a two-span, single lane, 
prefabricated steel truss bridge with steel grate or untreated timber decking. 
The bridge will provide over 10 feet of clearance to the ordinary high flow in the river; it will also 
provide about 12 feet of clearance to the 100-year flow. 
Construction is anticipated to commence in June 2009 and last until October 2009. 

 

No in-water work will take place. All work below the OHWM will be above the wetted channel. 
Staging may take place on the gravel bar in the dry. This work will adhere to the in-water work 
window, as specified by WDFW in the HPA (anticipated to be July 15 to August 15). 
Equipment that will be used for the proposed project includes a crane, dump trucks, bulldozers, 
excavators, pile drivers, hoe rams, chainsaws, generators, compactors, and concrete saws. The 
contractor will be required to provide designated mobilization and refueling sites located at least 
150 feet from the river and to prepare a spill response plan to minimize the likelihood and 
severity of potential fuel spills.
North Abutment
The existing north abutment does not meet modern engineering safety standards for supporting 
the bridge and thus will be replaced.  The existing concrete abutment will be dug out of the 
existing approach road, broken up with heavy equipment, and hauled off-site before a new 
abutment is constructed.  
A new abutment constructed of four driven steel piles will replace the existing abutment in the 
same location. The piles will be 18 inches in diameter and 80 feet long. This abutment is located 
in the existing road. No vegetation will be removed for this activity. Pile driving will occur 
within the murrelet breeding season approximately 150 yards away on the opposite side of the 
river from potential murrelet habitat.  Pile driving will occur approximately 165 feet from the 
wetted channel.
Gravel Bar Work Pad
Grading will be required to create a work pad for a crane that will place the south span of the 
bridge.  The work pad will be constructed on the exposed gravel bar, minimizing disturbance of 
riparian vegetation.  To construct the work pad, large boulders on the gravel bar will be removed 
(by heavy machinery) and stockpiled, and a level work surface will be created on the bar by 
spreading rounded fish mix gravel on the bar and placing timber mats on top of the fish mix. 
The work pad is anticipated to be no larger than 50x 50 (2,500 square feet). 
Approximately 15,000 square feet of the bar may be used for construction and staging.  At the 
time of construction the bar will be above the elevation of the wetted channel but below the 
OHWM. No in-water work will occur. The portion of the bar above the wetted channel and 
outside of the work pad (12,500 square feet) may be used to assemble the trusses but no fill, 
grading, or removal of boulders will be required.
Center Pier
The existing center pier does not meet modern engineering safety standards for supporting the 
bridge and thus will be replaced.  The existing concrete pier will be pushed over and broken up 
with heavy equipment and hauled off-site before a new, deeper, pier is constructed.  
Seven 24-inch diameter steel piles will be driven above the OHWM and approximately 70 feet 
deep, to construct the center pier. The piles will be in a single row. The new abutment will be 
narrower (perpendicular to the river), but longer (parallel to the river) than the existing abutment. 
The piles will have a concrete pile cap on top. The boulders will be excavated from the pile 
locations to approximately 1 foot and then the piles will be pre-drilled with an auger to avoid a 
messy excavation. The auger will pre-drill through the cobble layer (approx. 8 feet) to allow the 
piles to be placed without obstructions. Spoils from the auger will be contained and any water 
from dewatering will be pumped to baker tanks or dirt bags to remove fine sediments before 
being discharged in riparian areas. 
Pile driving will occur within the murrelet breeding season approximately 116 yards away on the 
opposite side of the river from potential murrelet habitat.  Pile driving will occur approximately 
65 feet from the wetted channel.
South Pier
The crane will be used to transport materials over the river to the south side. The existing 
concrete abutment is founded on bedrock and will be expanded for the proposed bridge. It will 
be cleaned off with a power washer. The abutment is approximately 10 feet above and 10 feet 
landward of the OHWM. Measures will be taken to prevent debris from entering the river. The 
area around the abutment has revegetated and approximately 900 square feet of riparian 
vegetation will be cleared. 
Approximately 6.5 cubic yards of concrete will be required for expansion of the abutment.  Once 
the concrete forms are constructed around the existing abutment, the crane will transfer wet 
concrete over the river from the gravel bar (approximately 80 feet) to the south abutment. A tarp 
will be hung under the bucket and the outside of the bucket will be cleaned off prior to each 
load, to prevent any concrete from dropping into the river. It is anticipated that only a few loads 
will be required.
Concrete forms will be removed after and disposed after concrete has cured.
Bridge Span Placement and Site Restoration
The bridge spans will be placed by the crane and attached to the pier and abutments.
After the work is completed, the work pad on the gravel bar will be deconstructed.  The timber 
mats will be removed and the native boulders will be redistributed on the bar.  The gravel fish 
mix will be left on the bar to be redistributed by high flows and contribute to spawning gravel 
recruitment.  Constructing the work pad with gravel fish mix will minimize the need to grade the 
gravel bar and disrupt the substrate.
Vegetated areas that were temporarily impacted by clearing and grading (Appendix B, Sheet 1) 
will be mulched and replanted with native vegetation.  Plantings will be monitored and 
maintained by the County to ensure successful establishment of a native vegetation community.  
Vegetated areas that are permanently impacted by the project (i.e. paved over or shaded by the 
bridge) will be compensated for through conservation measures on the decommissioned road 
segment (see 3.2.4 Road Decommissioning).
14.2.2.	Approach Roads 
The existing approach roads to the bridge will be utilized as the permanent approach roads. No 
clearing will be required. The south approach will be paved for approximately 50 feet. 
The north approach to the bridge will be rebuilt and repaved once the center pier is constructed. 
The north approach will be narrower than the existing approach since the bridge will be 12 wide 
with a single lane. The finished approach road will consist of two 10 wide travel lanes.
14.2.3.	Impervious Area and Stormwater Treatment Facilities
Existing asphalt will be removed in some areas, though new asphalt and gravel will be installed in 
other areas. It is anticipated that there will be a small net increase of approximately 500 sq. feet 
of impervious area at the approaches. Pavement will be removed from the width of the north 
approach but the pavement will extend toward the bridge beyond the existing pavement. 
Stormwater detention and water quality treatment are not required for this project, in accordance 
with Volume I of the Stormwater Management Manual for Western Washington (WSDOE 
2005). The bridge deck will be an open grate or untreated timber which will not collect 
stormwater. The traffic volume on the bridge is expected to be very low (less than 20 average 
daily trips).
On the north side of the bridge, the existing road drainage consists of sheet flow off the road. 
The project will establish ditches that will outlet to rock pads at the top of the slope and then 
sheet flow through the vegetated slope. There is approximately 60 feet of gravel bar before the 
water reaches the SF Stillaguamish, which will provide some interception and infiltration.
On the south side of the bridge the existing road drainage goes to a ditch on the south side of the 
road or sheet flows off the road into the vegetation on the north side of the road. There will be 
no changes to the drainage on the south side.
14.2.4.	Road Decommissioning  
Approximately 2,000 linear feet of the Monte Cristo Grade Road between the bridge and the site 
of the 2003 flood damage will be decommissioned once the bridge is in place. The 
decommissioned portion will be used as conservation measures for several County projects, 
including this project and additional future projects. The total amount of forested riparian area 
that could be created on the road is approximately 60,000 square feet. This project will utilize 
10,000 square feet of that area to compensate for impacts per Snohomish Countys Critical Areas 
Ordinance. The gravel and road base material be removed.  Topsoil and mulch will be applied 
and the area will be planted with native trees and shrubs.  Plantings will be monitored and 
maintained by the County to ensure successful establishment of a native vegetation community.
Additional conservation measures will consist of restoring a non fish-bearing tributary that 
crosses the Monte Cristo Grade Road in a culvert. The culvert is perched approximately 10 above 
the OHWM of the SF Stillaguamish. This culvert will be removed and a natural stream reach will 
be reestablished by grading the streambanks of the tributary back to a 1:1 and using stream bed 
gravels and cobbles to create a natural channel configuration and bed. The natural stream channel 
will allow fish passage from the SF Stillaguamish into the tributary.  This conservation measure 
element will occur during the in-water work window in 2010 and will require a temporary stream 
bypass to reduce the potential for downstream sedimentation.  Standard worksite isolation and 
sediment containment BMPs will be implemented.
14.3.	Indirect and interrelated activities
Interrelated activities are actions that are part of a larger action and depend upon that action for 
their justification. Interdependent activities have no independent utility apart from the proposed 
action. Interrelated and interdependent activities that could result in direct or indirect effects are 
those that would not occur but for the proposed action. Since vehicle access was cut off 5 
years ago, there has been no maintenance done on the Monte Cristo Grade Road, resulting in 
minor damage to the road. Road maintenance of the currently inaccessible segment of the Monte 
Cristo Grade Road is interrelated and interdependent to the federal actions of funding and 
permitting construction of the bridge because the road cannot be maintained until vehicular 
access is restored.  Further, there would be no independent utility to maintaining the inaccessible 
road segment without the bridge, which will connect the road segment to the larger road 
network. 
The Monte Cristo Grade Road has sustained minor flood damage approximately 1 mile west of 
the bridge. The road is approximately 1,000 feet from the SF Stillaguamish at this location. The 
water appears to be coming from a wetland on the south side of the road. At this time, it is 
unclear if the drainage failure was caused by a culvert being plugged or by sediment filling in a 
pre-existing roadside ditch. In order to make this road passable, a culvert will need to be placed 
or a ditch established to convey the drainage into existing ditches. Some portion of the work will 
occur at the margin of wetlands.  Impacts to wetlands and vegetation will be avoided to the 
degree feasible and unavoidable impacts will be mitigated per Snohomish Countys Critical 
Areas Ordinance and all other applicable regulations. County road crews will perform the work 
with County funds. Work will take place in 2009. It is unclear at this time if the road 
maintenance activity will require a Section 404 permit.
14.4.	Conservation Measures and Best Management practices
Conservation Measures that have been incorporated into the proposed project include avoidance 
and minimization measures, in addition to prescriptive compensatory mitigation requirements that 
comply with Snohomish County Critical Areas Regulations (Snohomish County Code 30.62A). 
Best management practices include methods and techniques implemented during construction to 
reduce short- and long-term project impacts. These measures will be implemented for the purpose 
of avoiding and minimizing the likelihood of adverse effects to listed fish and wildlife species 
and their habitats. 
14.4.1.	Conservation Measures
Impacts to the river and riparian buffer will be avoided or minimized to the extent practicable. 
Specific conservation measures for the project include:
*	The project design minimizes the footprint of the bridge and approach road by constructing 
a single lane bridge.
*	Riparian impacts will be mitigated by replacing affected functions and values at an equal or 
greater rate than provided for by existing conditions.
*	No suitable habitat for marbled murrelet will be removed.
*	Construction between April 1 and September 15 will take place no earlier than 2 hours after 
sunrise and end 2 hours before sunset.
*	Minimize impacts to riparian vegetation to the minimum necessary for the bridge 
construction and crane access;
*	Avoid in-water construction;
*	Leave tree stumps as habitat snags;
*	Disturbed riparian vegetation will be restored at greater than a 2:1 ratio;
The goal of the design is to compensate for functions lost through project impacts. Enhancement 
of riparian areas with native vegetation will occur at greater than a 2:1 ratio on an aerial basis. The 
County will enhance riparian buffers to provide functions that are distinctly greater than those 
functions affected by the project. 
14.4.2.	Best Management Practices
BMPs will be applied for all aspects of project implementation.  Erosion and sediment control 
measures may include mulching, matting, and netting; filter fabric fencing; sediment traps and 
ponds. Long-term water quality impacts are not expected.  Significant short-term effects to water 
quality are not expected if erosion control BMPs, stormwater treatment measures, and spill 
containment measures are properly implemented, monitored, and maintained during construction. 
A temporary erosion and sediment control (TESC) plan will be prepared and implemented to 
minimize and control pollution and erosion from stormwater. The use of BMPs should eliminate 
adverse effects to listed species.
General BMPs that will be implemented are as follows:
*	No work will occur within the wetted channel of the SF Stillaguamish or other fish-bearing 
waters.
*	All work will be performed in accordance with the conditions of the Hydraulic Project 
Approval (HPA) and other permits obtained for the project.  This includes complying with 
the in-water work window specified in the HPA.  Note that the in-water work window 
applies to activities below the OHWM of the SF Stillaguamish; the bridge construction will 
not require any work within the wetted channel.
*	In-water work required for the decommissioning of the abandoned road segment and 
restoration of the tributary to the SF Stillaguamish will be performed within the in-water 
work window specified by WDFW and employ a stream bypass and other worksite isolation 
and sediment stabilization techniques.
*	Clearly define construction limits with stakes prior to the beginning of ground disturbing 
activities.  No disturbance would occur beyond these limits.  Temporary construction 
fencing will be installed where determined to be necessary.  
*	Install site specific erosion control measures along the down-gradient edge of grading.  (This 
BMP will not apply to removal of the boulders on the gravel bar because the BMP would 
cause more disturbance than removal of the boulders.)
*	Staging areas will be located in areas that will prevent the potential of contamination of any 
wetland or water body. Servicing and refueling of vehicles will not occur within 150 feet of 
the river to reduce potential spills of petroleum and hydraulic fluids in sensitive areas. 
Additionally, drip pans will be fitted with absorbent pads and placed under all equipment 
being fueled.
*	Spill control and emergency response plans will be implemented for fueling, concrete 
activity, and staging areas.  The spill control/prevention plan will include the following 
items: notification procedures; specific cleanup and disposal instructions for different 
products; quick response containment and cleanup measures that will be available on site; 
and employee training for spill containment. These plans will satisfy all pertinent 
requirements set forth by federal, state, and local laws and regulations.
*	No wet or curing concrete, including washwater from equipment, will enter the river or 
other natural water resources. A containment tarp will be used to isolate any runoff from 
activities involving wet or curing concrete activities.
*	When heavy equipment is required, the project contractor will use equipment having the 
least impact necessary to accomplish the authorized work (e.g., low ground pressure, 
minimally sized, rubber tired).  
*	Prior to operating within the OHWM, all equipment will be cleaned of external oil, grease, 
dirt, or caked mud. Hydraulic fluids will be replaced by vegetable based oil. Any washing 
of equipment will be conducted in a location that will not contribute untreated wastewater to 
a stream or wetland.
*	BMPs will be regularly monitored and maintained during construction.
*	Implement measures to minimize noise impacts during 
construction, including the following:
>	Limit construction to daylight work hours;
>	Turn off equipment when not in use;
>	Use only well-maintained and properly functioning 
equipment and vehicles. 
*	Implement stormwater runoff control BMPs, including the 
following:
>	Install temporary sediment control devices, such as 
such as sediment mats, filter bags, erosion blankets, sediment traps, staked sediment 
barriers, water bladder dams, and/or "dirt bags".
>	Use swales, trenches, or drains to divert stormwater 
runoff away from disturbed areas.
>	Monitoring of erosion and sediment control measures will take place weekly and 
during major storm events (during active construction periods only) if they should 
occur.
*	All vehicles operated within 100 feet of any stream or water body will be inspected daily 
for fluid leaks before leaving the vehicle staging area. Any leaks detected will be repaired 
before the vehicle resumes operation. When not in use, all vehicles will be stored in the 
vehicle staging area as practicable. Other vehicles that may be stored in place, such as 
cranes, will be inspected daily for fluid leaks.
*	An oil absorbing, floating containment boom shall be available on-site during all phases of 
work.

15.	FISH SPECIES EVALUATIONS
This section outlines the distribution, listing and stock status, and critical habitat designations for 
listed fish species. Additionally, Table 3 outlines timing of use among these species in the SF 
Stillaguamish River. A discussion of applicable life histories is included as Appendix D.

Table 3. Timing of Use Among ESA listed Salmonids in SF Stillaguamish River (from Parametrix 2007)

Jan
Feb
Mar
Apr
May
Jun
Jul
Aug
Sep
Oct
Nov
Dec
Species/Life Stage

Spawning
Bull Trout

Chinook Salmon

Steelhead

Incubation
Bull Trout

Chinook Salmon

Steelhead

Rearing
Bull Trout

Chinook Salmon

Steelhead/Rainbow

Shaded areas indicate life stage timing.  Black shaded areas indicate peak of life stage timing.
15.1.	CHINOOK SALMON
15.1.1.	ESA and Stock Status
NMFS completed an ESA status review of Chinook salmon populations from Washington, 
Oregon, Idaho, and California and defined 15 evolutionarily significant units (ESUs) within the 
region. Naturally spawned spring, summer/fall, and fall Chinook salmon runs from the Puget 
Sound ESU were considered likely to become endangered in the foreseeable future (Myers et al. 
1998). The abundance of Chinook salmon in the Puget Sound ESU has declined substantially 
from historic levels, and there is concern over the effects of hatchery supplementation on genetic 
fitness of stocks, as well as severely degraded spawning and rearing habitats throughout the area 
(Myers et al. 1998). In addition, harvest exploitation rates in excess of 90 percent were estimated 
to occur on some Puget Sound Chinook salmon stocks. Subsequent to this status review, NMFS 
issued a ruling in May 1999 listing the Puget Sound ESU as threatened (NMFS 1999b). Primary 
factors contributing to declines in Chinook salmon in the Puget Sound ESU include habitat 
blockages, hatchery introgression, urbanization, logging, hydropower development, harvests, and 
flood control (NMFS 1998).
WDF et al. (1993) originally listed two stocks of Chinook salmon in the Stillaguamish watershed; 
the North Fork summer Chinook stock and the South Fork fall Chinook stock; however, in 2002, 
run timing designations were dropped from most Puget Sound Chinook stock names because 
they had been inconsistently applied.  When this occurred, the Stillaguamish River stocks were 
renamed the North Fork and SF Stillaguamish River Chinook stocks.
The proposed project is located within the geographic range of the SF Stillaguamish population 
(PSTRT 2003). The most recent estimate of the 5-year geometric mean of natural spawners for 
SF Chinook salmon is 270, whereas the estimate of historical capacity is 20,000 (BRT 2005).  
The number of Chinook above Granite Falls is between 50 and 100 adult spawners. (The action 
area is located above the falls. The long-term trend for the population is 1.02, indicating likely 
minimal growth of the population from 1974-2002. Long-term median population growth rate 
estimates are approximately 1.0, indicating uncertainty as to whether the rate is slightly positive 
or slightly negative.
15.1.2.	Chinook Salmon in the Action Area
Within the SF Stillaguamish basin, spawning occurs in the mainstem SF Stillaguamish River and 
in Canyon and Jim Creeks (StreamNet 2007, WSCC 2002, WDFW 2007).  Other tributaries in 
the subbasin experience moderate to severe low flows during the usual Chinook migration and 
spawning period (Williams et al. 1975).
In the South Fork, the waterfall near the town of Granite Falls (RM34.5) was impassable to 
anadromous fish, including Chinook, until a fishway was constructed in the 1950s (WDFW 
1998). The population is likely fewer than 100 adults in the SF Stillaguamish. Above the falls, the 
SF Stillaguamish gets very little Chinook use.
Although StreamNet (2007) does not report Chinook distribution in the SF Stillaguamish River 
upstream of Canyon Creek (RM33.7), Williams et al. (1975) reports moderate numbers of fall 
Chinook spawners in the SF Stillaguamish River between RM 44 near Robe and RM 62 near the 
town of Silverton. 
Spawning has not been recorded in the action area (RM 47) recently. In the last two years there 
have been no redds recorded between Robe Canyon and Big Four, a reach that is surveyed 1-3 
times each summer (WDFW 2008 pers. comm.). In years where redds were found in the reach, 
generally they were located at least 6 miles upstream of the action area. 
It is expected that small numbers of Chinook adults may migrate upstream through the action 
area to upstream spawning areas in the latter half of construction in September and October.  Due 
to their very low density in the upper SF Stillaguamish and data demonstrating that most 
spawning occurs farther upstream, it is very unlikely that Chinook will use the action area for 
spawning during or immediately following construction.
Chinook juveniles are unlikely to be encountered in the project area during construction.  There 
are typically few spawners in the action area or further upstream.  More importantly, the vast 
majority (about 97 percent) of Chinook salmon juveniles in the Stillaguamish River basin are 
reported to outmigrate from March through June as age 0 juveniles (Myers et al. 1998).  
Consequently, very few juveniles likely will be present during construction, which will occur 
from July to October.
15.1.3.	Critical Habitat
On September 2, 2005, NMFS (2005) designated critical habitat for 19 salmon and steelhead 
ESUs in California and the Northwest.  Critical habitat for Puget Sound Chinook salmon is 
located throughout the entirety of the Stillaguamish River and in the SF Stillaguamish River from 
its confluence with the NF Stillaguamish River upstream approximately 50 miles to the accessible 
headwaters (approximately RM 69), a reach that includes the action area (RM 47).
Specific primary constituent elements (PCEs) for Chinook salmon in freshwater areas, as defined 
by NMFS (2005), are: 
*	Freshwater spawning sites with water quantity and quality conditions and substrate 
supporting spawning, incubation and larval development.
*	Freshwater rearing sites with water quantity and floodplain connectivity to form and 
maintain physical habitat conditions, and support juvenile growth and mobility; water 
quality and forage supporting juvenile development; and natural cover such as shade, 
submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, 
large rocks and boulders, side channels, and undercut banks.
*	Freshwater migration corridors free of obstruction with water quantity and quality 
conditions and natural cover such as submerged and overhanging large wood, aquatic 
vegetation, large rocks and boulders, side channels, and undercut banks supporting 
juvenile and adult mobility and survival. 
The action area lacks high water quality to support productive spawning due to the large amount 
of sediment in the SF Stillaguamish. Sediment intrusion is the primary limiting factor to SF 
Stillaguamish Chinook above Granite Falls. Rearing and migration conditions have been similarly 
degraded. 
The PCEs in the action area have generally been degraded by upstream factors influencing 
watershed processes including logging, landslides, and the presence of the Mountain Loop 
Highway.  The substrate, habitat complexity, large woody material, water temperatures and water 
quality and quantity have been impacted.  Logging and forest roads are associated with many 
landslides and the resultant introduction of large quantities of fine sediment into the river.  
However, some major landslides in the basin are naturally occurring. The presence of the 
Mountain Loop Highway and associated development, including campgrounds, has impacted 
riparian vegetation, reducing shading and LWD recruitment.  The presence of the highway and 
associated riprap bank protection also limits channel migration, thereby reducing channel length 
and increasing the gradient and bedload transport capacity of the river.
The quality of PCEs in the action area are further impacted by infrastructure located in the action 
area, though this has affected the PCEs to a much smaller degree than upstream factors.  The 
most significant infrastructure within the action area influencing PCEs is the presence of the 
Monte Cristo Grade Road.  The road roughly parallels the SF Stillaguamish, and is within 50 feet 
of the river in approximately the upstream half of the action area.  The presence of the road 
reduces the potential for development of a fully functional, uninterrupted riparian vegetation 
community, somewhat reducing the potential for shading and LWD recruitment.  However, 
given the topography, surrounding trees, and aspect of the site, the presence of the road has a 
very small effect on shading of the river.  The presence of the road is also likely to result in a 
small increase in the transport of fine sediment from the riparian area to the river, though this is 
inconsequential relative to the huge quantities of fine sediment in the river due to natural and 
logging-influenced landslides in the watershed.
The Mountain Loop Highway bisects the northern part of the action area.  However, the highway 
is unlikely to affect PCEs because it is several hundred feet or greater from the river throughout 
most of the action area.  Although the Mountain Loop Highway and the Monte Cristo Grade 
Road both parallel the River throughout the action area, they do not currently limit channel 
migration and appear to have little likelihood of significantly limiting it in the future.  Much of 
the Monte Cristo Grade Road is founded on bedrock and both roads are located well above the 
river. 
The PCEs are also influenced by the presence of rural residences near the river at the upstream 
end of the action area, primarily on 342nd Drive NE and 102nd Street NE (Figure 1) and by the 
presence of two Forest Service campgrounds at the downstream end of the action area.  Rural 
development has reduced riparian cover in localized areas and may be a source of low levels of 
water quality contamination from septic systems.
15.2.	BULL TROUT
15.2.1.	ESA and Stock Status
In 1998, USFWS completed a status review of bull trout, identifying five distinct population 
segments (DPSs) in the continental U.S. (USFWS 1998a).  The Coastal-Puget Sound bull trout 
DPS is composed of 34 subpopulations (USFWS 1998b, 1999a).  USFWS listed bull trout in the 
Coastal-Puget Sound DPS as threatened under the ESA on November 1, 1999 (USFWS 1999a). 
The Coastal-Puget Sound DPS of bull trout, which includes the Stillaguamish subpopulation, is 
unique because it is thought to contain the only anadromous forms of bull trout within the 
continental U.S. (USFWS 1998a). The status of the migratory (fluvial, adfluvial, and 
anadromous) forms is of greatest concern throughout most of their range. The majority of the 
remaining populations in some areas may be largely composed of resident bull trout (Leary et al. 
1991; Williams and Mullan 1992). 
Stillaguamish River bull trout have been identified as a distinct stock based on their geographic 
distribution. Anadromous, fluvial and resident fish all exist in the watershed and, in many cases, 
overlap geographically. Because of this overlap and the lack of detailed information on fish 
movement within the basin, all bull trout in the Stillaguamish basin are currently considered to be 
a single stock. This determination may change as more information becomes available.  Exact 
spawn timing is unknown, although bull trout typically are fall spawners. 
In the South Fork, the waterfall near the town of Granite Falls was impassable to anadromous 
fish, including bull trout, until a fishway was constructed in the 1950s (WDFW 1998). However, 
anecdotal information from fish surveys in the 1920s and 1930s suggests a char population 
existed in the South Fork at that time. Since construction of the fishway, large adult bull 
trout/Dolly Varden are seen in the upper SF Stillaguamish River. The fishway allowed more 
anadromous fish to enter the watershed, increased competition, and likely pushed resident bull 
trout populations into the upper reaches of the watershed where competition was lower (USFS 
1995). 
15.2.2.	Bull Trout in the Action Area
Bull trout are found throughout the Stillaguamish River basin (WDFW 1998; Snohomish County 
2000; Snohomish County 2004; USFS 2006a; WDFW 2006).  Spawning occurs in parts of the 
SF Stillaguamish Bull trout do not spawn in the action area or within the Robe Valley (WDFW 
2008 pers. comm.). There is very small population of fluvial fish in the South fork, at critical 
levels (< 50 spawners a year) (WDFW 2008 pers. comm.). Although bull trout use the action area 
primarily for a migratory corridor, larger juveniles and subadults could use the action area for 
foraging and rearing. 
Adult bull trout are likely to migrate through the action area during construction (July to 
October) to spawning grounds upstream.  Rearing or subadult bull trout could be encountered in 
the project area during construction. However since the population is very small for the entire SF 
Stillaguamish, the likelihood of juvenile or subadult occurrence in this 0.5 mile stretch of river 
during construction is relatively small.  A 0.25 mile-long reach of the SF Stillaguamish just 
downstream of the action area was completely de-fished in summer 2005 and no bull trout were 
encountered (Snohomish County, unpublished data).
15.2.3.	Critical Habitat
Critical habitat for the Coastal-Puget Sound bull trout distinct population segment (DPS) was 
recently designated (USFWS 2005a).  USFWS has designated bull trout critical habitat in the SF 
Stillaguamish River from its confluence with the NF Stillaguamish River (RM 18) upstream 
approximately 50 miles to the accessible headwaters (approximately RM 69), an area which 
includes the action area.
Specific PCEs for bull trout in freshwaters areas, as defined by USFWS (2005a), are:
1.	Permanent water having low levels of contaminants such that normal reproduction, 
growth, and survival are not inhibited.
2.	Water temperatures ranging from 2 to 15C (36 to 59F), with adequate thermal refugia 
available for temperatures at the upper end of this range. Specific temperatures within this 
range will vary depending on bull trout life history stage and form, geography, elevation, 
diurnal and seasonal variation, shade, such as that provided by riparian habitat, and local 
groundwater influence.
3.	Complex stream channels with features such as woody debris, side channels, pools, and 
undercut banks to provide a variety of depths, velocities, and in-stream structures.
4.	Substrates of sufficient amount, size, and composition to ensure success of egg and 
embryo overwinter survival, fry emergence, and young-of-the-year and juvenile survival. 
A minimal amount of fine substrate less than 0.63 cm (0.25 in) in diameter and minimal 
substrate embeddedness are characteristic of these conditions.
5.	A natural hydrograph, including peak, high, low, and base flows within historic ranges or, 
if regulated, a hydrograph that demonstrates the ability to support bull trout populations.
6.	Springs, seeps, groundwater sources, and subsurface water connectivity to contribute to 
water quality and quantity.
7.	Migratory corridors with minimal physical, biological, or chemical barriers between 
spawning, rearing, overwintering, and foraging habitats, including intermittent or seasonal 
barriers induced by high water temperatures or low flows.
8.	An abundant food base including terrestrial organisms of riparian origin, aquatic 
macroinvertebrates, and forage fish.
9.	Few or no predatory, interbreeding, or competitive nonnative species present.
The PCEs in the action area have generally been degraded by upstream factors influencing 
watershed processes including logging, landslides, and the presence of the Mountain Loop 
Highway.  The substrate, habitat complexity, large woody material, water temperatures and water 
quality and quantity have been degraded.  Logging and forest roads are associated with many 
landslides and the resultant introduction of large quantities of fine sediment into the river.  
However, some major landslides in the basin are naturally occurring. The presence of the 
Mountain Loop Highway and associated development, including campgrounds, has impacted 
riparian vegetation, reducing shading and LWD recruitment.  The presence of the highway and 
associated riprap bank protection also limits channel migration, thereby reducing channel length 
and increasing the gradient and bedload transport capacity of the river.
The quality of PCEs in the action area are further impacted by infrastructure located in the action 
area, though this has affected the PCEs to a much smaller degree than upstream factors.  The 
most significant infrastructure within the action area influencing PCEs is the presence of the 
Monte Cristo Grade Road.  The road roughly parallels the SF Stillaguamish, and is within 50 feet 
of the river in approximately the upstream half of the action area.  The presence of the road 
reduces the potential for development of a fully functional, uninterrupted riparian vegetation 
community, somewhat reducing the potential for shading and LWD recruitment.  However, 
given the topography, surrounding trees, and aspect of the site, the presence of the road has a 
very small effect on shading of the river.  The presence of the road is also likely to result in a 
small increase in the transport of fine sediment from the riparian area to the river, though this is 
inconsequential relative to the huge quantities of fine sediment in the river due to natural and 
logging-influenced landslides in the watershed.
The Mountain Loop Highway bisects the northern part of the action area.  However, the highway 
is unlikely to affect PCEs because it is several hundred feet or greater from the river throughout 
most of the action area.  Although the Mountain Loop Highway and the Monte Cristo Grade 
Road both parallel the River throughout the action area, they do not currently limit channel 
migration and appear to have little likelihood of significantly limiting it in the future.  Much of 
the Monte Cristo Grade Road is founded on bedrock and both roads are located well above the 
river. 
The PCEs are also influenced by the presence of rural residences near the river at the upstream 
end of the action area, primarily on 342nd Drive NE and 102nd Street NE (Figure 1).  Rural 
development has reduced riparian cover in localized areas and may be a source of low levels of 
water quality contamination from septic systems.
15.3.	STEELHEAD
15.3.1.	ESA and Stock Status
On May 7, 2007, the National Marine Fisheries Service (NMFS) announced the listing of the 
Puget Sound distinct population segment (DPS) of steelhead as a threatened species under the 
Endangered Species Act. The listing was published in the Federal Register on May 11, 2007 and 
took effect on June 11, 2007. 
Four steelhead populations have been identified in the Stillaguamish watershed, including one 
winter run and three summer runs (Snohomish County 2005). Both summer and winter steelhead 
are found in the South Fork Stillaguamish River. 
Adult summer run steelhead generally spawn from mid-February to the end of May. The smolts 
outmigrate between April and July. Adult winter run steelhead generally spawn in the river from 
March to mid-June. Both summer- and winter-run juveniles rear in the river year-round.
15.3.2.	Steelhead in the Action Area
Both summer and winter steelhead utilize the SF Stillaguamish River and many of its tributaries 
(StreamNet 2007; USFS 2006a; WDFW 2006).  Steelhead did not historically access areas above 
the falls before the WDFW fish ladder was built in the 1950s. StreamNet (2007) reports 
spawning and rearing of summer steelhead and migration of winter steelhead in the action area.  
Construction will not occur during spawning and adults are not expected to migrate through the 
action area during construction.
Juvenile steelhead are expected to be rearing in the action area during construction.  A 0.25 mile-
long reach of the SF Stillaguamish just downstream of the action area was completely de-fished 
in summer 2005 and juvenile steelhead were encountered frequently (Snohomish County, 
unpublished data).
15.3.3.	Critical Habitat
Critical habitat has not yet been designated or proposed for this species.

16.	WILDLIFE SPECIES EVALUATIONS
This section outlines the distribution, ESA and stock status, and critical habitat for ESA listed 
wildlife species. A discussion of applicable life histories is included as Appendix F.
16.1.	Marbled Murrelet
16.1.1.	ESA Status and Distribution
Marbled murrelets are marine birds that forage in nearshore environments from northern 
California through Alaska. They nest in mature coniferous forests west of the Cascade crest at 
low to moderate elevations (Smith et al. 1997). Marbled murrelets are resident year-round on 
coastal waters. USFWS listed marbled murrelets as threatened under the ESA in 1992 due to a 
decline in abundance and habitat degradation in the southern portion of their range. Exact 
numbers are unknown. Historical data are limited, but murrelets are currently rare and uncommon 
in areas where they were common or abundant in the early 1900s, especially along the southern 
coast of Washington, northern coast of Oregon, and coast of California south of Humboldt 
County (Sealy and Carter 1984; Marshall 1988; Carter and Erickson 1992; Nelson et al. 1992; 
Ralph 1994). An estimate for the number of individuals in Washington is 5,000 to 6,000 birds 
(Speich et al. 1992; Speich and Wahl 1995). The breeding population in Washington is estimated 
to be 1,900 to 3,500 pairs (Speich et al. 1992). 
Marbled murrelet population decline has been attributed primarily to the loss and fragmentation 
of old-growth nesting habitat caused by logging and development (Ralph and Miller 1995). It is 
believed that forest fragmentation may be making nests near forest edges vulnerable to predation 
by other birds, such as jays, crows, ravens, and great-horned owls. In addition, this species is 
vulnerable to fishing nets and oil spills (Marshall 1988).
The USFWS conducted a 5-year review of marbled murrelet status in 2003 (USFWS 2004b). 
Based on available information in the Washington, Oregon, and California, the status review 
estimated there are currently 2,223,048 acres of suitable murrelet nesting habitat. The status 
review found that the marbled murrelet population is not stable through reproduction due to low 
fecundity levels across the 3-state area, as determined through nest success values (i.e., the 
number of fledglings per breeding pair of murrelets per year). In general, both radio telemetry 
and at-sea survey methods indicate that murrelet breeding success appears to decline from north 
to south. Predation has consistently been the most significant cause of nest failure. Murrelets 
appear to select platforms that provide protection from predation (USFW 2006). The factors 
affecting rates of predation on murrelet nests are not fully clear, yet key elements seem to be 
proximity to humans, abundance of avian predators, and proximity and type of forest edge to the 
nest. The status review did not find that a change in classification from threatened was 
warranted.
16.1.2.	Marbled Murrelets in the Action Area
PHS data (WDFW 2006) indicates that the nearest marbled murrelet occupancy sites are over 0.3 
mile outside the action area, although recent surveys have not detected marbled murrelet nesting 
in the project vicinity (USFS 2006b).
Patches of suitable habitat for marbled murrelet is present in the action area south of the Monte 
Cristo Grade Road. Suitable habitat was determined based on the presence of trees with 
platforms greater than or equal to 4 inches in diameter and greater than 33 feet above ground 
(USFWS 2006).  The nearest suitable habitat tree is approximately 67 yards south of the south 
bridge abutment.  Although the habitat in the action area is considered suitable per the criteria, it 
is marginal and inferior to older and more intact habitat available elsewhere in the SF 
Stillaguamish basin.  The suitable habitat in the action area is expected to have high rates of avian 
(corvid) predation associated with human occupation and disturbed areas in the action area 
including the Mountain Loop Highway and local roads, residential development, and young 
secondary forest.  Further, observed nest platforms that are considered suitable are fairly small 
(i.e. less than 7 inches).  
The early nesting season for murrelets is between April 1 and August 5 and the late season 
continues until although it is unlikely.  Given the relatively small number of murrelets present in 
Washington relative to available suitable habitat, it is far more likely that murrelets will select 
higher quality nesting habitat (with larger nest platforms and fewer predators) in adjacent areas 
than exists in the action area.  It is reasonably likely that murrelets nesting outside the action area 
will regularly migrate through the action area while flying to and from their nests.
16.1.3.	Critical Habitat
The critical habitat designation includes 11 units in Washington State, including 1.2 million acres 
of federal land, 421,500 acres of state forest land, and 2,500 acres of private land. Not all 
suitable habitat is included in this designation, as only areas designated as most essential to 
murrelet survival in terms of quality, distribution, and ownership are included. The USFWS is 
currently proposing to revise the 1996 critical habitat designation for marbled murrelets. 
Critical habitat for marbled murrelets is designated within the project action area. (USFW ECOS 
Critical Habitat Mapper website) The suitability of nesting habitat is marginal due to the small 
platform size and unprotected location of the trees. The trees that have potential platforms are 
along the edge of the forest  with a steep slope on one side and the clearing for the road and river 
on the other side, leaving the trees fairly exposed to predation. The work will occur 
approximately 150 yards from suitable habitat during the nesting season.

17.	EFFECTS TO LISTED SPECIES AND CRITICAL HABITAT
17.1.	Riparian Vegetaion
Approximately 4,500 square feet of riparian vegetation along the SF Stillaguamish River will be 
temporarily impacted by the temporary access road. All of the temporary impact is to scrub shrub 
or non-mature forest vegetation.  Temporary impact includes clearing vegetation and/or grading 
and replanting with native woody species after construction.  Approximately 900 square feet of 
non-mature forest will be permanently impacted by the south abutment and 1,300 square feet of 
scrub shrub riparian vegetation will be permanently impacted at the north abutment. No potential 
suitable nesting habitat for marbled murrelets will be removed.
In addition to the 4,500 square feet of temporarily impacted area that will be replanted, 
approximately 10,000 square feet of the decommissioned segment of the Monte Cristo Grade 
Road will be planted, restoring approximately 350 linear feet of riparian buffer adjacent to the 
river. The road base material will be removed, the area re-graded and replaced with soil and 
planted. The proposed mitigation, required per Snohomish Countys Critical Areas Ordinance, 
includes replanting with native tree and shrub species to increase plant diversity and create a 
more complex vegetative structure.  
The clearing impacts will not have a measurable effect on riparian functions such as LWD 
recruitment; temperature and stream shading due to the small area of clearing, surrounding 
topography, size of trees to be cleared, amount of adjacent mature forest, and north/south 
orientation of the clearing. Therefore, effects to listed species from clearing of this vegetation are 
expected to be insignificant.  
Over the long term, the proposed action including conservation measures will result in a net 
increase of 7,800 square feet of riparian vegetation in the action area.  The shape and location of 
the conservation area (in the footprint of the existing Monte Cristo Grade Road adjacent to the 
river) will contribute to a locally improved riparian buffer for fish species that will lead to minor 
increases in shading, allochthonous input, LWD recruitment, and sediment retention functions 
associated with riparian cover.  Decommissioning of the road and establishment of mature 
vegetation may also slightly reduce the exposure of suitable murrelet nesting habitat to avian 
predators over the long-term.
17.2.	Water Quality 
Fine Sediment
Fine sediment suspension has the potential to affect the behavior or feeding success of juvenile 
salmonids if it is of sufficient duration and intensity (Spence et. al 1996). 
Work below the OHWM will be limited to the gravel bar that will be dry (out of the wetted 
channel) at the time of construction. Construction of the work pad will require the boulders from 
the bar to be set aside.  Fish mix gravel and timber mats will be used to create a stable work 
surface. The mats will be removed after construction and the boulders will be redistributed on the 
bar with the fish mix gravel.
Grading for bridge construction has the potential to introduce fine sediment into the river during 
the construction season.  However, sediment introduction will be insignificant because most 
heavy grading and excavation will occur near the central pier and north abutment, at least 60 feet 
from the wetted channel and standard erosion control BMPs will be employed to stabilize 
disturbed areas.  Further, construction will occur in the dry season, when the likelihood of 
significant rain events is relatively low.  The project will meet all water quality standards imposed 
by state and federal laws (e.g., Clean Water Act 404/401).
After construction ceases, there is potential for temporarily elevated turbidity in the first storm 
event of the season when the river rises enough to submerge the gravel bar.  Disturbance of the 
gravel bar during construction, including removal and replacement of boulders, could cause 
minor localized disruption of natural bed armoring.  The potential for this disturbance to result in 
a significant sediment plume is low.  Additionally, the fish mix gravel that will be left on site will 
cover the disturbed area, further reducing the potential for fine sediment mobilization.  
The location of the construction pad and access  (below OHWM but outside of the wetted 
channel), the use of BMPs, e.g., erosion and sediment control measures, and prohibiting 
machinery from operating in the wetted channel all combine to make the probability of 
significant sedimentation discountable. The background levels of turbidity in the SF 
Stillaguamish are very high. Even if a minor sediment plume occurred, it would be relatively 
small in magnitude and duration, and listed fish would likely avoid the plume in preference of 
less turbid portions of the river. 
The creation of riparian buffer as a conservation measure on the decommissioned road is not 
likely to effect water quality. BMP measures will be used to prevent sediment from enter the 
stream during restoration of the decommissioned road and the site will be mulched, further 
reducing the potential for sediment mobilization.  The proposed riparian buffer will provide a 
long-term improvement in water quality and quantity to the river by removing impervious 
surfaces adjacent to the river, and replacing them with a vegetated riparian buffer.
The removal of the tributary culvert as a conservation measure in the decommissioned road in 
2010 could potentially introduce sediment into the river. However, the work site will be isolated 
from flow, the work will occur under low flow conditions, and BMPs will be in place to prevent 
sediment from entering the stream.  Listed fish are not present in the tributary. 
The interrelated and interdependent road maintenance work to fix the road at the west end could 
occur in wetlands. There is approximately 1000 feet of forested and scrub shrub vegetation 
between the road and the SF Stillaguamish. Erosion control measures will be used to prevent 
sediment from entering the wetland. If any sediment was introduced to the wetland, it would 
settle out in the wetland prior to reaching the SF Stillaguamish.
Stormwater
There is very low potential for the addition of 500 square feet of impervious surface to indirectly 
affect listed fish.  No stormwater treatment currently exists at the project site. The project 
proposes to maintain the existing ditches on the south side and establish ditches on the north side 
that will disperse over the bank on to rock pads. The water will then sheet flow over vegetated 
areas and/or infiltration. The bridge deck will be untreated timber or open steel grate that will not 
collect or concentrate stormwater.  Pollutants from vehicles traveling over the bridge will enter 
the river in very small quantities.  Average traffic over the bridge is expected to be less than 20 
vehicles.  Because the bridge will not have a solid deck, pollutants from vehicles will not collect 
and concentrate.  Any pollutants entering the river will dilute quickly.  Indirect effects to water 
quality will be insignificant.
Wet Concrete
Concrete will be poured to construct piling caps on the north abutment and central pier and to 
expand the south abutment.  Most concrete work will occur at the north abutment and central 
pier, over 60 feet from the wetted channel.  Standard construction BMPs will be employed to 
ensure that uncured concrete and washwater are isolated from the river (see 3.4.2 for details).
Approximately 6.5 yards of wet concrete will be delivered to the south abutment by the crane 
stationed on the north side of the river.  To reduce the potential for wet concrete to enter the 
river, the outside of the bucket will be cleaned between loads and a tarp will be hung under the 
bucket as it is delivered over the river.  A large bucket will be used such that only a few loads 
will be needed.
Given the distance of most concrete work to the wetted channel, the implementation of standard 
BMPs, and the implementation of additional BMPs for the delivery of concrete over the river, it 
is unlikely that any uncured concrete will enter the river.  However, if a small amount of concrete 
is introduced to the river from the bucket or work on the south abutment, it will be diluted 
rapidly. 
17.3.	Noise and Sound Pressure
Potential direct effects on listed fish could include disturbance to individuals due to pile driving 
above the OHWM.  Pile driving will occur out of the water and cause minimal disturbance of a 
short-term duration. The north abutment will be driven approximately 150 feet from the water; a 
high bank and a gravel bar with boulders, cobbles, and sand separate the water from the 
abutment location. The piles of the center pier will be approximately 60 feet from the water and 
the gravel bar separates the water from pier. The stream channel is approximately 80-100 feet 
wide with a depth of less than 6 feet. Sound waves from the pile driving will have been largely 
attenuated and disrupted by the gravel bar.  Further, the relatively shallow river further reduces 
the potential for harmful pressure waves to propagate through the water. Therefore the effect of 
pile driving on listed fish will be discountable.
Listed birds can be negatively affected by increases in noise disturbance, particularly while 
nesting or roosting (USFWS 2006). The project is located within critical habitat for marbled 
murrelets. All work will take place in the existing road right-of-way. The closest potential suitable 
habitat tree is located approximately 200 feet southwest of the south abutment.  
Pile driving between April 1 and August 5 generally requires a distance of greater than 60 yards 
from suitable habitat in order avoid adverse affects to marbled murrelets (USFWS 2003), (Table 
4). Pile driving will take place on the north side of the river at almost twice the prescribed 
distance from potential suitable habitat (approximately 116 yards). Project activities using heavy 
equipment and motorized tools require a distance of greater than 35 yards. Work on the south 
side of the river will not take place until the bridge is in place; this will likely occur after August 
15th, which will be outside of the murrelet early  breeding season. Any work on the south side 
will be approximately 67 yards from potential suitable habitat. Work occurring during the 
breeding season will be 116 yard away. The effects of noise will be discountable due to the low 
probability of murrelet nesting in the action area during construction (see 5.1.2).  If murrelet 
nesting does occur within the action area during construction, effects from noise would be 
insignificant due to the combination of distance and timing.
Compared to pre-flood traffic volumes, there will be no substantial increase to traffic volumes 
resulting from the bridge replacement; therefore a long-term increase in disturbance to marbled 
murrelets is not expected.  

Table 4.  Effects Determinations by Type of Disturbance and Operating Period for Marbled Murrelets when 
Occupied Sites and/or Unsurveyed Suitable Habitat Occurs in the Vicinity of the Proposed Work.  

Type of Disturbance

 Operating Period for Project Activities and 
Associated Effects Determinations for Marbled Murrelet

No Effect
Not Likely to Adversely Affect 
Likely to Adversely Affect

Date
Distance from Suitable 
Habitat
Date
Distance from 
Suitable Habitat
Date
Distance from Suitable 
Habitat
Blasts
9/16-3/30
any
4/1-8/5a
> 1 mile
4/1-8/5
< 1 mile

8/6-9/15 
> 1 mile b
8/6-9/15 c
< 1 mile

Impact pile drivers, 
jackhammers, or rock 
drills
9/16-3/30
any
4/1-8/5
> 60 yards
4/1-8/5
< 60 yards

 8/6-9/15
> 60 yards
 8/6-9/15
< 60 yards

Large-size helicopter 
(Sikorsky type) or large 
airplane
9/16-3/30
any
4/1-8/25
> 1 mile 
4/1-8/5
< 1 mile 

 8/6-9/15
> 1 mile
 8/6-9/15
< 1 mile

Helicopters (Bell Jet 
Ranger type) or single-
engine airplane
9/16-3/30
any
4/1-8/5
> 120 yards 
4/1-8/5
< 120 yards 

 8/6-9/15
> 120 yards
 8/6-9/15
< 120 yards

Heavy equipment, 
motorized tools
9/16-
3/30
any
4/1-8/5a
> 35 yards 
4/1-8/5
< 35 yards 

 8/6-
9/15
> 35 yards
 8/6-9/15b
< 35 yards
 
 
Chainsaws falling trees 
and cutting downed 
wood
9/16-
3/30
any
4/1-8/5
> 45 yards 
4/1-8/5
< 45 yards 

 8/6-
9/15
> 45 yards
 8/6-9/15
< 45 yards
 
 
Prescribed burning
9/16-
3/30
any
4/1-8/5 
> 0.25 mile
4/1-8/5
< 0.25-mile

 
 8/6- 3/30
< 0.25 mile
 
 
a April 1 to August 5 (early breeding season); b Site-, equipment-, and method-specific information can be used to shorten or lengthen 
the 1-mile distance for these activities; c August 6 to September 15 (late breeding season).   
Source:  Programmatic biological opinion for selected forest-management activities, USFWS, 2003
17.4.	 channel conditions
Construction of road crossings across rivers can change conditions at the site or reach scale by 
altering geomorphic processes including channel migration and the transport of coarse substrate 
and large woody debris.  However, construction of the Monte Cristo bridge will not substantially 
or negatively alter geomorphic processes for several reasons.  Construction of the bridge will rely 
on reconstructing and augmenting two existing abutments and the center pier within several feet 
of their existing footprints.  Therefore, the post-construction condition will be very similar to the 
baseline.  Further, the existing abutments do not significantly affect geomorphic processes.  The 
river is naturally constrained by a bedrock outcrop on the south bank, and the south abutment is 
founded atop the outcrop.  The north abutment is buried within 342nd Drive NE and is not 
exposed to flows.  The center pier is just within the OHWM and is wetted only during high 
flows.  Because the bedrock along the south bank is hydraulically smoother than the rough 
gravel/cobble bar on the right bank, the river is unlikely to migrate northward in the foreseeable 
future.  However, the two spans of the bridge are long enough to accommodate northward 
migration of the channel, should it occur.
The other activity with potential to affect geomorphic processes is the construction of the work 
pad on the bar below OHWM.  Coarse bed substrate in a 50 x 50 area will be disturbed by 
construction.  The largest boulders will be removed and stockpiled and fish mix spawning gravel 
will be imported and spread out to construct a level base for the timber mat work pad.  After the 
bridge is constructed, the timber mats will be removed and the native boulders will be 
redistributed on the bar atop the fish mix spawning gravel.  The gravel will be left in place to 
avoid extensive disruption of the bar that would be required to remove the gravel. The bed 
elevation in this area will be slightly higher than the pre-project profile.  However, most of the 
gravel will be redistributed in the first bankfull event and may contribute to spawning sites 
downstream.
17.5.	EFFECT DETERMINATIONS
The Checklist for Documenting Environmental Baseline and Effects of Proposed Actions(s) on 
Relevant Indicators is included in Section 2.4 and was used to guide the determination of effect 
for the proposed action on each fish species. An extensive field survey of the habitat parameters 
identified in the checklist was not performed in the action area. Rather, the checklist was 
completed using the best available scientific information for the area and through visual 
observation of the project vicinity and best professional judgment.
Based on field work by natural resource specialists, evaluation of the proposed design, review of 
pertinent literature, and interviews with fish and wildlife authorities, we conclude the following
17.5.1.	Effect Determinations for Chinook, steelhead, and bull trout
Individuals of all listed fish species may be in the action area during construction, including 
rearing juvenile steelhead, migrating adult Chinook, and foraging and migrating subadult and 
adult bull trout.  Based on the information and analysis presented in the biological assessment, 
the project may affect, but is not likely to adversely affect Chinook salmon, steelhead and bull 
trout. 

*	Minor riparian clearing will occur.  Most cleared areas will be re-planted and an additional 
10,000 square feet of riparian vegetation will be planted on the decommissioned road.  
Effects to all listed fish species will be insignificant.  Over the long term, decommissioning 
and revegetation of a segment of the Monte Cristo Grade Road will likely reduce sediment 
input to the river.
*	Minor increases in fine sediment suspension and pollutants associated with driving surfaces 
will be localized and dilute rapidly, resulting in insignificant effects to listed fish.  Effects 
from introduction of wet concrete to the river are discountable; however, if a small amount 
of concrete is introduced into the river, it would dilute rapidly resulting in insignificant 
effects to all listed fish species. 
*	Pressure waves from pile driving will result in insignificant effects to listed fish.  Pile 
driving will occur in the dry at least 65 feet from the wetted channel.  Resultant pressure 
waves will be disrupted and attenuated in the mixed-substrate matrix of the intervening 
gravel bar to such an extent that they will not have the potential to harm fish in the river.
*	Alteration of channel conditions will be minor and temporary.  Fish mix spawning gravel 
will be left on-site and redistributed by the river, resulting in insignificant, and possibly 
beneficial, effects. 
17.5.2.	Effect Determination for Marbled Murrelet
It is unlikely that marbled murrelets will nest in the action area during construction (see Chapter 
5.1.2).  Based on the information and analysis presented in the biological assessment, the project 
may affect, but is not likely to adversely affect  marbled murrelets.
*	Minor riparian clearing will occur to locally widen the road at the existing bridge abutments 
and will not fragment cover or create new travel corridors into suitable habitat for avian 
predators.  Therefore, clearing will have insignificant effects on marbled murrelet.  Over 
the long-term, decommissioning and revegetation of a segment of the Monte Cristo Grade 
Road may have minor beneficial effects by reducing exposure of suitable habitat to avian 
predation.  Alteration in geomorphic 
*	The effects of noise disturbance will be discountable due to the low probability of murrelet 
nesting in the action area during construction (see 5.1.2).  However, if murrelet nesting does 
occur within the action area during construction, effects from noise would be insignificant 
due to the combination of distance and timing.
17.5.3.	Critical Habitat Determination for Chinook and bull trout
Chinook Critical Habitat
The project may affect, but is not likely to adversely affect Chinook salmon critical habitat 
because: 
*	Minor changes in water quality, including a slight increase in impervious surface and a 
minor temporary increase in fine sediment, will have insignificant effects to the freshwater 
spawning PCE. Over the long term, decommissioning and revegetation of a segment of the 
Monte Cristo Grade Road will likely reduce sediment input to the river.  Short-term changes 
in channel conditions from disturbance of the gravel bar will have insignificant effects to 
the freshwater spawning PCE.  There will be a small change in cover due to minor riparian 
clearing, resulting in insignificant effects to the freshwater spawning PCE.
*	Minor changes in water quality, including a slight increase in impervious surface and a 
minor temporary increase in fine sediment, will have insignificant effects to the freshwater 
rearing PCE. Over the long term, decommissioning and revegetation of a segment of the 
Monte Cristo Grade Road will likely reduce sediment input to the river.  Short-term changes 
in channel conditions from disturbance of the gravel bar will have insignificant effects to 
the freshwater rearing PCE.  There will be a small change in cover due to minor riparian 
clearing, resulting in insignificant effects to the freshwater rearing PCE.
*	Minor changes in water quality, including a slight increase in impervious surface and a 
minor temporary increase in fine sediment, will have insignificant effects to the freshwater 
migration corridor PCE. Over the long term, decommissioning and revegetation of a 
segment of the Monte Cristo Grade Road will likely reduce sediment input to the river.  
Short-term changes in channel conditions from disturbance of the gravel bar will have 
insignificant effects to the freshwater migration corridor PCE.  There will be a small change 
in cover due to minor riparian clearing, resulting in insignificant effects to the freshwater 
migration corridor PCE.
Bull trout
The project may affect, but is not likely to adversely affect bull trout critical habitat because: 
*	PCE #1 (Contaminants) - Contamination from uncured concrete is discountable.  However, 
if a small amount of concrete is dripped into the river from the bucket transferring it to the 
south abutment, the concrete would dilute quickly, resulting in insignificant effects to PCE 
#1.  Effects to PCE #1 from spills of petroleum products associated with heavy equipment 
are discountable.
*	PCE #4 (substrate) - The project will not degrade substrate conditions or potential spawning 
sites or result in increased embeddedness of gravels.  Effects to PCE#4 will be insignificant.
*	There will be no effect to other PCEs for bull trout critical habitat.
17.5.4.	Critical Habitat Determination for Marbled Murrelet
The project may affect, but is not likely to adversely affect marbled murrelet critical habitat 
because: 
*	Clearing of riparian vegetation is insignificant because suitable nesting trees (trees with 
old growth characteristics or with potential nest platforms) will not be removed or 
increase exposure of suitable habitat to avian predation
*	No primary constituent elements will be affected by the proposed project due to the small 
number of trees being removed and their location alongside an existing road.

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Essential Fish Habitat Consultation

Essential Fish Habitat Consultation
ESSENTIAL FISH HABITAT
The Sustainable Fisheries Act of 1996, amended the Magnuson-Stevens Fishery Conservation 
and Management Act (Magnuson-Stevens Act) to establish new requirements for Essential Fish 
Habitat (EFH) descriptions in Federal fishery management plans and to require Federal agencies 
to consult with NMFS on activities that may adversely affect EFH. EFH means those waters and 
substrate necessary to fish for spawning, breeding, feeding, or growth to maturity. The Pacific 
Fisheries Management Council (PFMC) has recommended an EFH designation for the Pacific 
salmon fishery that would include those waters and 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) (PFMC 1999).
The Magnuson-Stevens Act requires consultation for all federal actions that may adversely affect 
EFH, and it does not distinguish between actions in EFH and actions outside EFH. Any 
reasonable attempt to encourage the conservation of EFH must take into account actions that 
occur outside EFH, such as upstream and upslope activities that may have an adverse effect on 
EFH. Cumulative impacts are incremental impacts, occurring within a watershed or marine 
ecosystem context that may result from individually minor but collectively significant actions. 
The assessment of cumulative impacts is intended in a generic sense to examine actions occurring 
within the watershed or marine ecosystem that adversely affect the ecological structure or 
function of EFH. The assessment should specifically consider the habitat variables that control or 
limit a managed species use of a habitat. It should also consider the effects of all impacts that 
affect either the quantity or quality of EFH.
The consultation requirements of section 305(b) of the Magnuson-Stevens Act (16 U.S.C. 
1855(b)) provide that:
*	Federal agencies must consult with NMFS on all actions, or proposed actions, authorized, 
funded, or undertaken by the agency, that may adversely affect EFH.
*	NMFS will provide conservation recommendations for any federal or state activity that may 
adversely affect EFH.
*	Federal agencies will, within 30 days after receiving conservation recommendations from 
NMFS, provide a detailed response in writing to NMFS regarding the conservation 
recommendations. The response will include a description of measures proposed by the 
agency for avoiding, mitigating, or offsetting the impact of the activity on EFH. In the case 
of a response that is inconsistent with the conservation recommendations of NMFS, the 
federal agency will explain its reasons for not following the recommendations.
IDENTIFICATION OF ESSENTIAL FISH HABITAT
Salmon fishery EFH includes all streams, lakes, ponds, wetlands, and other water bodies 
currently or historically accessible to salmon in Washington, Oregon, Idaho, and California, 
except above the impassable barriers identified by PFMC (PFMC 1999). Chief Joseph Dam, 
Dworshak Dam, and the Hells Canyon Complex (Hells Canyon, Oxbow, and Brownlee dams) 
are among the listed man-made barriers that represent the upstream extent of the Pacific salmon 
fishery EFH. Salmon EFH excludes areas upstream of longstanding naturally impassable barriers 
(i.e., natural waterfalls in existence for several hundred years). In the estuarine and marine areas, 
proposed designated salmon EFH extends from the nearshore and tidal submerged environments 
within state territorial waters out to the full extent of the exclusive economic zone (EEZ), 370.4 
kilometers (230.2 miles) offshore of Washington, Oregon, and California north of Point 
Conception (PFMC, 1999).
During the proposed project, coho, Chinook, and pink salmon may use EFH within the project 
area.

Table A-1. Species of Salmonids and Possible Life Stages with Designated Essential Fish Habitat 
in the Action Area.

Life Stage
Species
Spawning/Egg
Juvenile 
Rearing
Migration 
(Adult/Juvenile)
Fresh/Salt Water 
Acclimatization
Coho Salmon
X
X
X

Pink Salmon
X
X
X

Chinook Salmon
X
X
X

DIRECT, INDIRECT, AND CUMULATIVE EFFECTS
Potential impacts of the Monte Cristo Bridge to ESA listed fish species are discussed in Chapter 
6 of this BA. As discussed, strict adherence to BMPs will help protect the SF Stillaguamish 
River from water quality effects and other potential short-term impacts during project 
construction. Although riparian buffer creation likely will improve in-stream habitat over the 
long-term, insignificant short-term impacts may occur to Pacific Coast salmon EFH.  There 
should be no cumulative adverse effects to EFH.
DETERMINATION
Based on the EFH requirements of Pacific Coast salmon species, BMPs, and conservation 
measures proposed as part of the project, this project may adversely effect EFH.  However, 
effects will be insignificant and will be avoided to the degree possible through implementation of 
BMPs and riparian buffer creation. 

Project Plans

APPENDIX C
Pathway and Indicators Discussion

Pathway and Indicators Discussion
TEMPERATURE
According to NMFS criteria, temperatures in the SF Stillaguamish River should not exceed 57F 
(14C) to be considered properly functioning or 57 to 60F during spawning and 64F (18C) 
during the remainder of the year to be considered at risk. The portion of the SF Stillaguamish 
River in which the action area is located is 303(d)-listed for temperature, therefore its baseline 
condition is at risk.  
The total quantity of impervious surfaces generated by the project will not increase significantly 
over baseline conditions, and all stormwater runoff will flow through vegetation prior to entering 
the river.  Therefore, added impervious surfaces and associated stormwater runoff are unlikely to 
affect in-stream temperatures.  The project requires the removal of 4,000 square feet of riparian 
buffer but shading will not be affected due to the adjacent dense forest and north, south 
orientation of the removed trees. Cleared areas will be mitigated at a greater than 2:1 ratio.  The 
SF Stillaguamish Rivers riparian zone will not be significantly impacted by the project.  For 
these reasons, significant impacts to stream temperature are not anticipated, and the project will 
maintain baseline conditions.
SEDIMENT/TURBIDITY
Logging and development in the sub-basin has increased fine sediment input to the Stillaguamish 
River. According to the DNR (2002), the Robe Valley sub-basin, with over 100 miles of logging 
roads, has the highest road density (3.98 mi/mi2) of the three uppermost sub-basins of the South 
Fork and the third highest in the entire Stillaguamish watershed. At least 11% of these road miles 
cross areas of unstable geology with slopes greater than 30%.  The upper two sub-basins contain 
134 miles of logging road, of which 20% are potentially unstable.  
In addition, a huge, chronic landslide has been very active since 1952 at Gold Basin, 
approximately three miles upstream from the project site.  It erodes a large amount of silt, clay 
and gravel per year into the river.  This is over 75% of the sediment that enters the entire South 
Fork (DNR 2002).
Based on NMFS criteria, baseline conditions for sediment are at risk due to the high number of 
documented landslides in the SF Stillaguamish River basin. Since the project will include the 
application of appropriate BMPs and sediment control measures, the project is anticipated to 
maintain baseline conditions.
CHEMICAL CONTAMINANTS/NUTRIENTS
The SF Stillaguamish River, from Canyon Creek (RM 33.7) upstream to its headwaters, is not 
303(d) listed for any contaminant/nutrient parameters; however, a TMDL has been completed for 
fecal coliform (USFS 1995).  This reach also had a TMDL completed for dissolved oxygen and 
currently is 303(d) listed for temperature (USFS 1995).  Based on the matrix of pathways and 
indicators criteria, baseline conditions for chemical contaminants and nutrients are at risk. 
Because the project includes the application of appropriate BMPs, new impervious surfaces are 
insignificant, and all stormwater from new impervious surfaces will flow through or infiltrate into 
a vegetated swale, any water quality impacts to action area streams will be insignificant. For 
these reasons, the project is anticipated to maintain baseline conditions.
PHYSICAL BARRIERS
No man-made fish passage barriers exist in the SF Stillaguamish River.  Based on the matrix of 
pathways and indicators criteria, the baseline conditions are properly functioning.  The proposed 
project will not affect fish passage and therefore will maintain baseline conditions at both the 
action area and watershed scales.
SUBSTRATE
No specific studies were found to document the quality of the spawning substrate in the upper 
three basins.  Cobbles and gravel in most bars along the upper South Fork appear to be 
moderately to highly embedded with silt and other fine sediments.  The Stillaguamish Lead 
Entity Strategy (2004) lists the Gold Basin and Robe Valley sub-basins as the highest priority for 
control of fine sediments.  WDFW has found it generally impossible to obtain good spawning 
counts of South Fork chum salmon because the water is too turbid to see fish during the late fall 
and winter months in downstream areas (WDFW pers. Comm.).  Chinook, pink and chum salmon 
prefer to spawn in the main river channel and larger tributaries.  Populations of these species are 
very low in the upper three sub-basins, which may be due, in part, to the heavy silt loads from the 
Robe Valley and Gold Basin areas.  Also, there are few large woody debris jams in the Robe 
Valley sub-basin.  Without these structures, there is very little scouring action to maintain pool 
depth and adequate sorting of the gravel in the tail-out spawning area of the pools. Baseline 
substrate conditions are at risk. The proposed project includes the application of appropriate 
BMPs and sediment control measures and is not expected to increase sedimentation rates. 
Therefore, the proposed project will maintain current levels of substrate embeddedness.
LARGE WOODY DEBRIS
NMFS (1996) defines LWD as pieces of wood greater than 24 inches in diameter and 50 feet in 
length. A wood count of 80 pieces per mile is considered properly functioning. Historic removal 
of riparian vegetation has reduced the supply of wood to the river. Current counts average 
approximately 1 piece per mile (Haas et al. 2003). Therefore the process of LWD recruitment is 
considered at risk. The project will remove a small areas of trees in the riparian buffer, tree 
removal will be mitigated, and the scale of tree removal is insignificant at the action area and 
watershed scales.  Consequently, the project is anticipated to maintain LWD functions.
POOL FREQUENCY
The SF Stillaguamish Rivers pool frequency is assumed to be at risk.  Pool frequency depends 
mostly on the number of pieces of LWD, the number of stream meanders, channel gradient and 
sediment supply.  The Robe Valley sub-basin receives a huge amount of sediment from the Gold 
Basin slide and nearby logging roads, so the tendency for pools to fill in is high.  Without the 
necessary LWD, not many pools would be expected to form. Construction of the bridge does not 
involve in-water work and project effects are not expected to cause downstream pool filling. 
Therefore, the project is expected to maintain current pool functions within the action area.
POOL QUALITY
Pool quality is assumed to be at risk.  As already noted, the lack of LWD in this reach and the 
tremendous amount of siltation from the Gold Basin slide contributes to the poor quality of 
pools. Construction of the bridge does not involve in-water work and project effects are not 
expected to cause downstream pool filling. Therefore, the project is expected to maintain current 
pool quality within the action area

OFF-CHANNEL HABITAT
Within the action area, and throughout much of the watershed, the SF Stillaguamish River has 
moderate to high gradient, confined channels that do not have accessible off-channel areas, e.g., 
backwaters and low energy off-channel areas. The USFS surmises that lack of backwater, low 
energy off-channel areas may be natural for some of the upper watershed sub-basins due to the 
steepness and confinement of the river valley (EBA 1999). However there are several tributaries 
within the action area that are perched or armored with rip-rap. There are no off-channel habitats, 
although there may be potential for off-channel habitat formation. Off-channel habitat in the 
action area is considered at risk. The proposed project will not create off-channel habitat and 
therefore will maintain existing conditions.
REFUGIA
Some amount of refugia habitat capable of supporting and maintaining all life stages of 
salmonids exists within the action area in the SF Stillaguamish River. The river is adequately 
buffered, and this habitat element is properly functioning. The proposed project will not impact 
in-stream habitat and therefore will maintain baseline conditions.
WIDTH/DEPTH RATIO 
Although quantitative channel measurements were not taken during the site visit, the width to 
depth ratio appears to be at risk based on observations of landslides and channel incising in the 
SF Stillaguamish basin. The project will maintain current width-to-depth ratios as it will not alter 
stream channel morphology or increase sedimentation. 
STREAMBANK CONDITION
Within the action area, parts of the SF Stillaguamish Rivers streambank is not stable. The Monte 
Cristo Grade Rd has been armored w/rip-rap in places and a large scale landslide is continuing 
within the upstream end of the action area.  The bank in other areas is stable and composed of 
naturally stable bedrock or gravel bars.  Overall, the streambank condition is at risk. The project 
will maintain existing conditions.
FLOODPLAIN CONNECTIVITY
The hydrologic linkage between off-channel areas and the SF Stillaguamish River is naturally low 
due to steep topography and high gradient channels that typically do not interact with floodplain 
areas.  In these types of systems, overbank flow typically occurs only during extreme flood 
events.  Although natural, this likely would be classified as at risk based on NMFS criteria. 
Project effects are anticipated to maintain floodplain connectivity baseline conditions.
CHANGES IN PEAK/BASE FLOWS
Clearing of mature forest vegetation over large areas of the watershed and construction of roads 
in upland forest areas has reduced natural infiltration, thereby increasing runoff rates and peak 
flows. Therefore, the baseline condition is at risk. The bridge includes a minimal increase in 
impervious surface, and all stormwater from the new bridge will be routed to dissipation pad and 
vegetated slope for treatment.  Consequently, base and peak flows in action area streams are 
unlikely to change and therefore will maintain the current baseline conditions.
INCREASES IN DRAINAGE NETWORK
According to DNR (2002), the Robe Valley sub-basin, with over 100 miles of logging road, has 
the highest road density (3.98 mi/mi2) of the three uppermost sub-basins of the South Fork and 
the third highest in the entire Stillaguamish watershed. The baseline condition is at risk. 
Decommissioning a segment of the Monte Cristo Grade Road will lead to a minor decrease in the 
drainage network.  On a watershed scale, this decrease will not be significant; therefore, the 
project will maintain the current baseline condition.
ROAD DENSITY AND LOCATION
The Monte Cristo Grade Road is parallel  to the SF Stillaguamish, which reduces the riparian 
buffer functions. The baseline conditions are at risk. The project will add 250 feet of road across 
the river. However, approximately 1,800 feet of the Monte Cristo Road will be decommissioned 
within the action area, therefore, the project will maintain baseline conditions at the watershed 
scale.
DISTURBANCE HISTORY
The predominant land use disturbance in the sub-basin is logging (present and historic). The 
geology in the area has resulted in highly unstable slopes which have caused several landslides 
within the major tributary drainages. The Robe Valley sub-basin has the highest percent (11%) of 
unstable roads in the SF Stillaguamish River. Due to the location of the action area and its 
watershed, disturbances exist in unstable or potentially unstable areas. Natural processes 
(sediment, LWD, and hydrology regimes) are mostly at risk. Therefore, based on the matrix of 
pathways and indicators criteria, the existing baseline conditions are at risk. The project includes 
minor clearing and paving, which will be far exceeded by the road area that will be 
decommissioned. Consequently, the project will maintain baseline conditions.
RIPARIAN RESERVES
The Monte Cristo Grade Road is parallel to the river and a relatively large percentage of the 
banks have been armored with rock and the riparian trees are not accessible by the river.  In 
places, there are high banks where floodwaters cannot reach trees. The baseline condition is at 
risk. Minor tree removal will be mitigated and the scale of tree removal will not substantially 
affect the riparian reserves within the lower reach of the SF Stillaguamish.  Including the 
decommissioning and planting of a segment of the Monte Cristo Grade Road, the project will 
result in long-term minor improvement to Riparian Reserves.  Consequently, the project is 
anticipated to maintain this function at the watershed scale.

APPENDIX D
Listed Species Life Histories

Life Histories of Species Listed 
CHINOOK SALMON PERTINENT LIFE HISTORY
In general, summer/fall Chinook salmon migrate into freshwater in August and September 
(Wydoski and Whitney 1979). Spawn timing begins in late September and peaks in October, 
similar to other Chinook salmon stocks in south Puget Sound (WDF et al. 1993). Adult Chinook 
would be migrating in the SF Stillaguamish River from late August through early October, but 
likely would not reach the action area until early September at the earliest.
After emergence, juvenile Chinook salmon rear in freshwater from a few days to 3 years 
(Wydoski and Whitney 1979); however, most juvenile Chinook salmon in Puget Sound streams 
migrate to the marine environment during their first year (Myers et al. 1998). Chinook that 
outmigrate in their first year are called ocean type due to their short freshwater residence and 
because they make extensive use of the nearshore marine environment for rearing. Ocean type 
Chinook salmon generally migrate downstream in the spring, just months after emerging from the 
gravel, or during the summer and autumn after a brief period of rearing in freshwater (Healey 
1991; Myers et al. 1998). 
Migrant juvenile Chinook salmon timing usually peaks in April and May and ends in June.  
Consequently, there is insignificant potential for outmigrating smolts to be present in the SF 
Stillaguamish River during project construction as the vast majority (if not all) outmigrating 
juveniles would have moved into the lower estuarine areas by July (Hayman et al. 1996).  
Additionally, 97% of Chinook salmon juveniles in the Stillaguamish River basin outmigrate as 
age 0 juveniles (Myers et al. 1998), therefore the vast majority of Chinook salmon in the basin 
will have outmigrated by the time the project begins, with only the stream-type juveniles 
(approximately 3% of the total SF Stillaguamish population) remaining to spend a year in 
freshwater.
Juvenile Chinook salmon that remain in freshwater after emergence may migrate to the ocean any 
time of year, though most Chinook salmon within a population tend to migrate at similar times 
and ages (Healey 1991). Migration commonly occurs during the night under the cover of 
darkness, although some fish may migrate during the day (Healey 1991). Chinook salmon fry 
tend to migrate along the banks and avoid the high velocity water near the center (thalweg) of 
the channel (Healey 1991).
BULL TROUT PERTINENT LIFE HISTORY
The amphidromous life-history form of bull trout is poorly studied (USFWS 1999a). Unlike strict 
anadromy, as exhibited by Pacific salmon, amphidromous individuals often return seasonally to 
freshwater as subadults, sometimes for several years, before returning to spawn (Wilson 1997). 
For bull trout, the amphidromous life history form is unique to the Coastal-Puget Sound 
population. For many years it was thought that amphidromous char  in Washington were Dolly 
Varden (Salvelinus malma), and that freshwater char were bull trout. There is conclusive 
evidence that amphidromous bull trout populate Puget Sound (Kraemer 1994), and anecdotal 
evidence suggests these native char were once much more abundant (USFWS 1999a). In 
Washington State, bull trout and Dolly Varden, two closely related char species, coexist and are 
managed as a single species. Separate inventories are not maintained by the WDFW due to the 
considerable biological similarities in life history and habitat requirements that exist between the 
two species. Although historic reports of char may have specified either bull trout or Dolly 
Varden, methodologies for reliably distinguishing between the two have only recently been 
developed and have not yet been widely applied (WDFW 1998). 
Bull trout are considered to be optionally amphidromous, (i.e., the survival of individuals is not 
dependent upon whether they can migrate to sea), in contrast to obligate anadromous species like 
pink (Oncorhynchus gorbuscha) and chum salmon (O. keta) (Pauley 1991). Nonetheless, the 
amphidromous life history form is important to the long-term persistence of bull trout and their 
meta-population structure. Amphidromous fish are generally larger and more fecund than their 
freshwater counterparts, and migratory forms play an important role in facilitating gene flow 
among sub-populations.
Bull trout, which spawn in late summer and early fall, are believed to be restricted in their 
spawning distribution by water temperature (Bjornn 1991). Locally, amphidromous forms 
typically return to freshwater in late summer and fall to spawn in upper tributaries and headwater 
areas. Puget Sound stocks typically initiate spawning in late October or early November as water 
temperature falls below 7 to 8 C. Spawning habitat almost invariably consists of very clean 
gravel, often in areas of groundwater upwelling or cold spring inflow (Goetz 1994). Egg 
incubation temperatures needed for survival have been shown to range from 2 to 4 C 
(Willamette National Forest 1989). Bull trout eggs require approximately 100 to 145 days to 
hatch, followed by an additional 65 to 90 days of yolk sac absorption during alevin incubation. 
Thus, in-gravel incubation spans more than 6 months. Hatching occurs in winter or late spring and 
fry emergence occurs from early April through May (Rieman and McIntyre 1993).
Generally, for their first 1 to 2 years, bull trout juveniles rear near their natal tributary and exhibit 
a preference for cool water temperatures (Bjornn 1991), although they appear less restricted by 
temperature than are spawners. Newly emerged bull trout fry are often found in shallow, 
backwater areas of streams that contain woody debris. Later, or in other habitats lacking woody 
debris for refugia, fry are bottom dwellers, and may occupy interstitial spaces in the streambed 
(Brown 1992).
Resident forms of bull trout spend their entire lives in small streams, while migratory forms live 
in tributary streams for several years before migrating to larger rivers (fluvial form) or lakes 
(adfluvial form). Migratory individuals typically move downstream in the summer and often 
congregate in large, low-velocity pools to feed (Bjornn 1991). Anadromous bull trout usually 
remain in freshwater 2 or 3 years before migrating to saltwater in spring (Wydoski and Whitney 
1979).
Bull trout life histories are plastic (i.e., variable and changeable between generations), and 
juveniles may develop a life history strategy that differs from their parents. The shift between 
resident and migratory life forms may depend on environmental conditions. For example, 
resident forms may increase within a population when survival of migratory forms is low (Rieman 
and McIntyre 1993). Char are generally longer-lived than salmon, and bull trout up to 12 years 
old have been identified in Washington (Brown 1992).
STEELHEAD PERTINENT LIFE HISTORY
Steelhead are the anadromous form of freshwater resident rainbow or redband O. mykiss trout 
species. The present distribution of steelhead extends from Asia, to Alaska, and south to the U.S. 
Mexico border (Busby et al 1996; 67 FR 21586, May 1, 2002). Unlike many salmonid species, 
the O. mykiss exhibit extremely complex and plastic life-history characteristics, such that their 
offspring can exhibit different life-history forms from the parental generation. For example, 
offspring of resident fish may migrate to sea, and offspring of anadromous steelhead may remain 
in streams as resident fish (Burgner et al. 1992). 
Those that are anadromous can spend up to 7 years in freshwater prior to smoltification (the 
physiological and behavioral changes required for the transition to salt water), and then spend up 
to 3 years in salt water before returning to freshwater to spawn. However, they typically return to 
their natal stream to spawn as 4- or 5-year-old fish. Unlike Pacific salmon, steelhead trout are 
iteroparous or capable of spawning more than once before they die. However, it is rare for 
steelhead to spawn more than twice before dying, and those that do are usually females (Busby 
et al. 1996). 
Over their entire range, West Coast steelhead spawning migrations occur throughout the year, 
with seasonal peaks of migration activity varying by location. However, even in a given river 
basin there might be more than one seasonal migration peak, typically referred to as winter, 
spring, summer, or fall steelhead runs. Although there are generally four migration seasons, 
steelhead are typically divided into two basic reproductive ecotypes (summer and winter), based 
on the state of sexual maturity at the time they enter freshwater and the duration of spawning 
migration (Burgner et al. 1992). The summer or stream-maturing type enters fresh water in a 
sexually immature condition between May and October, and sexually matures in freshwater over 
several months. In contrast, the winter or ocean-maturing type enters fresh water in a sexually 
mature condition between November and April, and spawns shortly thereafter. In basins with 
ecotypes, the summer run generally spawns farther upstream than winter run fish. However, the 
winter run of steelhead is the predominant run in Puget Sound.
Depending on water temperature, fertilized steelhead eggs may incubate in redds for 1.5 to 4 
months before hatching as alevins. Following yolk sac absorption, young juveniles or fry 
emerge from the gravel and begin active feeding. As they grow, steelhead move to deeper parts 
of the stream, establish territories and diet changes from microscopic aquatic organisms to larger 
organisms such as isopods, amphipods and aquatic and terrestrial insects, primarily associated 
with the stream bottom (Wydoski and Whitney 1979). Riparian vegetation and submerged cover 
(logs, rocks and aquatic vegetation) are important, for providing cover, food, temperature 
stability, protection from predators. As a result, densities of juvenile steelhead are highest in areas 
containing in-stream cover (Reiser and Bjornn 1979; Johnson and Kucera 1985).
MARBLED MURRELET PERTINENT LIFE HISTORY
Marbled murrelets typically nest high in the canopy of old-growth forests or stands of large trees 
infected with mistletoe (mistletoe brooms of greater than 1 square foot of surface area are 
occasionally used by nesting murrelets; Ralph and Miller 1995). They do not nest in island 
colonies. Murrelets have been detected up to 68 km (43 miles) inland, but they are most abundant 
in old-growth/mature forest, particularly along the North Fork of the Stillaguamish River (Hamer 
1990). Washington State surveys up to 1990 indicate that most murrelet nests have been located 
in conifers that were 150 or more years in age and located in mature or old-growth forests or 
residual old-growth trees greater than 35 inches diameter at breast height (Binford et al. 1975; 
Carter and Sealy 1986, 1987; Marshall 1988; Hamer 1990). The nesting period for murrelets 
extends from April 1 to September 15.
Marbled murrelets generally forage in nearshore and protected coastal waters throughout the 
year, including bays, inlets, fjords, lagoons, coves, and exposed outer coasts (Nelson 1997). 
Murrelets are generally found near the shore, usually within 5 km, and in-water that is less than 
60 meters deep (Sealy 1975). In Washington State, most observed occurrences are on marine 
coasts (Strachan et al. 1995). Murrelets are opportunistic feeders that will consume the most 
available prey species, which may include Pacific sand lance (Ammodytes hexapterus), Pacific 
herring (Clupea pallasi), and surf-smelt (Hypomesus pretiosus) (Burkett 1995; Strachan et al. 
1995). Movement pathways between marine foraging areas and inland areas are unknown, 
although murrelets are suspected to follow river valleys and other areas of least resistance. 

APPENDIX E
Project Area Photos

 

 

19.	APPENDIX D: TECHNICAL MEMORANDUMS
19.1.	Fisheries Resource Report
19.2.	Aquatics Conservation Strategy
19.3.	Wildlife Resources Report and Biological Evaluation

 TECHNICAL 
MEMORANDUM 
Date: October 8, 2008 To: Sean Gross, Snohomish County Public Works From: Pete Lawson Subject: Monte 
Cristo Grade Road Bridge (#RC1520) Fisheries Resource Report - Work 
Authorization #20  
cc: File 
Project Number: 553-1513-085, Phase 20 Project Name: Monte Cristo Grade Road Bridge Environmental Support 
Snohomish County Public Works (County) is proposing to construct a single-lane, steel-truss bridge 
across the South Fork Stillaguamish River (South Fork) to restore vehicle access to approximately 20 
properties. The project limits include a small portion of United States Forest Service (USFS) land, and 
will require an easement from the USFS. The following technical memorandum summarizes the fisheries 
resources in the project area and analyzes the potential impacts associated with the project.  

APPLICABLE LAWS, RULES, REGULATIONS, AND POLICIES  
1	Mt. Baker-Snoqualmie National Forest Land and Resource Management Plan (Forest Plan, as 
amended). 
2	Standards and Guidelines for Management of Habitat for Late-Successional and Old-Growth 
Forest Related Species within the Range of the Northern Spotted Owl, including the Aquatic 
Conservation Strategy (ACS). 
3	Washington State Hydraulic Code, including all provisions of the Hydraulic Project Approval for 
this project issued to Snohomish County by the Washington Department of Fish and Wildlife (WDFW). 
4	Endangered Species Act of 1973, as amended (ESA) (16 U.S.C. 1531 et seq.) and its 
implementing regulations (50 Code of Regulations [CFR] Part 402). Section 7(a)(2) requires federal 
agencies to review actions authorized, funded, or carried out by them, to ensure such actions do not 
jeopardize the continued existence of federally listed species, or result in the destruction or adverse 
modification of designated critical habitat. 
5	Magnuson-Stevens Fishery Conservation and Management Act (16 U.S.C. 1801 et seq.), as 
amended by the Sustainable Fisheries Act of 1996, and its implementing regulations (50 CFR Part 600). 
6	Forest Service Manual 2672.4 states: A biological evaluation must be completed for sensitive 
species for all programs and activities planned, funded, executed, or permitted by the U.S. Forest Service 
(Forest Service). 
7	The National Forest Management Act of 1976 mandates the Use of Management Indicator 
Species (MIS) (Forest Service Manual 2621.1). Fish MIS are identified in the 1990 Forest Plan, p. 4-46. 

(Rev. 06/04) 

RELEVANT MANAGEMENT OBJECTIVES/STANDARDS AND GUIDELINES  
1990 Forest Plan, Threatened, Endangered, and Sensitive Species, Forest-wide 
Standards and Guidelines, p. 4-127 
All proposed management actions which have the potential to affect habitat of endangered, threatened, 
or sensitive species will be evaluated to determine if any of those species are present. Habitat for 
sensitive plants and animals shall be managed to ensure that management activities do not contribute to 
these species becoming threatened or endangered. 

1994 Forest Plan, Record of Decision Standards and Guidelines, p. C-32 
Roads Management Standards and Guideline RF-1. Federal, state, and county agencies should cooperate 
to achieve consistency in road design, operation, and maintenance necessary to attain Aquatic 
Conservation Strategy objectives. 

1994 Forest Plan, Record of Decision Standards and Guidelines, p. C-37 
General Riparian Area Management Standards and Guideline RA-2. Fell trees in Riparian Reserves when 
they pose a safety risk. Keep felled trees on-site when needed to meet coarse woody debris objectives. 
DEFINITIONS OF TECHNICAL TERMS 
Anadromousmigrating from the sea to freshwater to spawn 
Depressed Stocka stock of fish whose production is below expected levels based on available habitat 
and natural variations in survival rates, but above the level where permanent damage to the stock is likely 
(Williams et al. 1975). 
Critical Habitat (for threatened or endangered species; from the ESA, p. 2)(i) the specific areas 
within the geographical area occupied by the species, at the time it is listed in accordance with the 
provisions of section 4 of the ESA, on which are found those physical or biological features (I) essential 
to the conservation of the species and (II) which may require special management considerations or 
protection; and (ii) specific areas outside the geographical area occupied by the species at the time it is 
listed in accordance with the provisions of section 4 of this Act, upon a determination by the Secretary 
that such areas are essential for the conservation of the species. (The USFWS and the NMFS formally 
designate what is critical habitat for their respective species. Critical habitat includes the stream 
channels with a lateral extent defined by the ordinary high-water line [33 CFR 319.11]). 
Essential Fish Habitat (from http://www.nmfs.noaa.gov/sfa/sfaguide/102.htm)those waters and 
substrate necessary to fish for spawning, breeding, feeding, or growth to maturity. 
Healthy Stocka stock of fish experiencing production levels consistent with its available habitat and 
within the natural variations in survival for the stock (Williams et al. 1975). 
Ordinary High Water Mark (OHWM) (33 CFR 328.3(e))that line on the shore established by the 
fluctuations of water and indicated by physical characteristics such as a clear, natural line impressed on 
the bank, shelving, changes in the character of soil, destruction of terrestrial vegetation, the presence of 
litter and debris, or other appropriate means that consider the characteristics of the surrounding areas. 
Redda spawning nest made by a fish, especially a salmon or trout 
Sensitive Species (from http://www.fs.fed.us/r6/sfpnw/issssp/agency-policy)those plant and 
animal species identified by the Regional Forester for which population viability is a concern, as 
evidenced by significant current or predicted downward trends in population numbers or density and 
habitat capability that would reduce a species existing distribution (Forest Service Manual 2670.5). 
Spawnto deposit eggs or sperm directly into the water, as fishes 
Stockthe fish spawning in a particular lake or stream(s) at a particular season, which fish to a 
substantial degree do not interbreed with any group spawning in a different place, or in the same place at 
a different season (Williams et al. 1975). 
MANAGEMENT REQUIREMENTS AND MITIGATION MEASURES 
Management requirements and mitigation measures for the project are outlined below. 
 	In-water work conducted below the OHWM of the South Fork or its tributaries will occur during 
the approved WDFW in-water work window. 
 	There shall be no fill materials discharged below the OHWM and no wet or curing concrete will 
enter the river or other natural water resources.   
 	Erosion control best management practices (BMPs), such as silt fences, will be installed and 
maintained to reduce runoff and sedimentation. 
 	Clearing shall be restricted to areas needed for bridge and bridge approach construction activities 
and hazard tree management. 
 	Temporarily cleared areas shall be replanted with native vegetation and monitored to ensure 
adequate survival.  Plantings will be maintained and replaced as necessary. 

Analysis Methodology 
Fish distribution was determined using the Mt. Baker-Snoqualmie National Forest (MBS) fish 
distribution database, WDFW reports and databases, the Washington State Conservation Commission 
limiting factors analysis report (WSCC 1999), and communications with local biologists. 
Fisheries Affected Environment 
The analysis area for fisheries effects is the South Fork, specifically the Robe Valley sub-basin (6th field 
HUC 17110080206), in Water Resources Inventory Area (WRIA) 5.  The project site is located east of 
Verlot on 342nd Drive NE in Section 15, Township 30N, Range 8E at about river mile (RM) 47 of the 
South Fork. The river flows from east to west through the project area. The streambed in the project area 
consists primarily of cobble, gravel, sand, and silt.  High levels of silt and fines result from upstream 
landslides, bank sloughing, erosion, and logging practices. A large gravel bar occurs along the right 
(north) bank of the project site, which is largely exposed during typical low flows. 
The Stillaguamish River basin is a Tier 1, Key Watershed and contributes directly to the conservation of 
resident and anadromous salmonids. Table 1 displays the fish species of interest and the special habitat 
designations addressed in this analysis. 
Most native Puget Sound salmonid species occur in the project area.  Coho salmon, steelhead, and 
cutthroat trout occur in the South Fork mainstem. Chinook salmon, bull trout, and pink salmon also occur 
in the mainstem, although typically in greater numbers downstream of Granite Falls (about 13 miles 
downstream).  Chum and sockeye salmon occur primarily downstream of Granite Falls. For the small 
population of river sockeye salmon spawners known to inhabit the Stillaguamish River, it is currently 
unknown whether these fish are strays from other watersheds or a genetically distinct stock. However, 
preliminary information from other watersheds with river-spawning sockeye suggests that the populations 
have no genetic relationship to lake-spawning populations, such as the Baker Lake stock (Hendrick in 
WSCC 2002). The spawning that does occur in the South Fork is limited to the lower reaches (about RM 
22), 25 miles downstream of the project area. 
Occurrence of anadromous species in the project area is significantly influenced by fish passage 
conditions at Granite Falls. The falls was historically a natural migration barrier and likely restricted the 
upper watershed to resident forms of native salmonids (WDFW 1998).  The WDFW constructed a 
fishway at the falls in the 1950s to allow upstream passage for anadromous species.  However, sockeye 
and chum do not generally use the fishway and are therefore restricted to the lower river. Depending on 
flow conditions, passage through the fishway may also be difficult for other salmonids, such as Chinook 
and pink salmon.  
Although it is expected that small numbers of adult Chinook salmon may migrate upstream through the 
project area, to upstream spawning areas late in the construction period (September and October), no 
recent spawning has been recorded near the action area. In the last 2 years there have been no redds 
recorded between Robe Canyon and Big Four, a reach that is surveyed 1 to 3 times each summer 
(Snohomish County 2008). In years where spawning has occurred in the area, the closest redds were 
about 2 miles upstream of the project site, and more typically at least 6 miles upstream. 
Although some Chinook salmon could occur in the area during the overall construction period, no in-
water work would occur during this period.  Furthermore, the vast majority (about 97 percent) of 
Chinook salmon juveniles in the Stillaguamish River basin are reported to outmigrate from March through 
June as age-0 juveniles (Myers et al. 1998). Therefore, very few juveniles would likely be present during 
the construction period, which will occur from July to October. 
Table 1. Fish Species of Interest and Special Habitat Designations in the South Fork 
Stillaguamish River Sub-watershed. 
Utilization Associated with Project Species (Stock) Status1 Analysis Area 
Chinook salmon 
Oncorhynchus 
tshawytscha 
(Stillaguamish Fall) 
NMFSESA listed Threatened (3/99);  ESA 
designated critical habitat (9/05); Essential Fish 
Habitat Forest ServiceMIS SaSI 2002
Depressed 
South Fork Stillaguamish River 
Bull trout Salvelinus 
confluentus 
(Stillaguamish) 
USFWSESA listed Threatened (11/99);  ESA 
designated critical habitat (9/05) Forest Service
MIS SaSI 1998Unknown 
South Fork Stillaguamish River  
Steelhead O. mykiss 
(SF Stillaguamish 
Winter-run) 
NMFSESA listed Threatened (5/07);  ESA 
critical habitat not yet designated Forest 
ServiceMIS (anadromous and resident 
rainbow) SaSI 2002Depressed 
Upper South Fork Stillaguamish River   
Steelhead O. mykiss 
(SF Stillaguamish 
Summer-run) 
NMFSESA listed Threatened (5/07);  ESA 
critical habitat not yet designated Forest 
ServiceMIS (anadromous and resident 
rainbow) SaSI 2002Unknown 
Upper South Fork Stillaguamish River  
Coho salmon O. 
kisutch (Stillaguamish) 
NMFSESA Candidate; Species of Concern 
(7/95); Essential Fish Habitat Forest Service
Sensitive; MIS SaSI 2003Healthy 
Upper South Fork Stillaguamish River; 
Marten Creek 
Pink salmon O. 
gorbuscha (SF 
Stillaguamish) 
NMFSESA, Not Warranted (10/95);  Essential 
Fish Habitat Forest ServiceMIS SaSI 2002
Healthy 
Upper South Fork Stillaguamish River 
Chum salmon O. keta 
(SF Stillaguamish) 
NMFSESA, Not Warranted (3/98) Forest 
ServiceMIS SaSI 2002Healthy 
South Fork Stillaguamish River to Granite 
Falls (13 miles downstream of project 
area) 
Coastal cutthroat O. 
clarki clarki 
(Stillaguamish) 
NMFSESA, Not Warranted (4/99) Forest 
ServiceSensitive, MIS (anadromous and 
resident) SaSI 2000Healthy 
South Fork Stillaguamish River 
Sockeye salmon O. 
nerka (Baker River) 
NMFSESA, Not Warranted (4/99) Forest 
ServiceSensitive, MIS  SaSI 2002Healthy 
River spawning strays in the South Fork 
Stillaguamish River to RM 22 (25 miles 
downstream of project area). No known 
distribution of Baker Lake stock. 

  NMFSNational Marine Fisheries Service; USDA Forest Service (Forest Service 1990 and 2004); USFWSUnited States Fish and Wildlife Service; 
SASSIWashington State Salmon & Steelhead Stock Inventory (WDF et al. 1993; WDFW and WWTT 1994); SaSIWashington Salmonid Stock Inventory 
(WDFW 1998, 2000, 2002); MISManagement Indicator Species (from USDA Forest Service 1990). 
The project site is located within a generally confined reach, bounded by the Mountain Loop Highway 
on the right (north) river bank, and alternating bedrock outcrops, bluffs, and narrow bands of floodplain 
along the left bank. Much of the left bank consists of bedrock, with areas of rock riprap protecting an 
abandoned railroad grade.  
Despite the bedrock and armored stream bank, some unstable slopes occur in the project vicinity. The 
Monte Cristo Grade Road is armored with riprap in places, although a large-scale landslide exists near the 
upstream end of the project site.  The bank in other areas is stable and consists of naturally stable bedrock 
or gravel bars.  The presence of Bridge #538 on the Mountain Loop Highway (commonly known as Blue 
Bridge) just upstream of the project site prevents the river from migrating as it would under natural 
conditions. This likely contributes to the chronic riverbank erosion at the site of the 2003 washout. 
Most of the riparian areas along the river are composed of maturing second-growth deciduous species, 
although tributary streams in the area typically have good riparian canopy cover, including some areas of 
old-growth forest. There are few large woody debris jams in the Robe Valley sub-basin, resulting in 
limited scouring forces to maintain pool depths or adequate gravel sorting processes to maintain pool tail-
out spawning areas. 
The South Fork flows are often subject to extreme fluctuations. United States Geologic Survey (USGS) 
flow data over a 53-year period of record at Granite Falls (gage #12161000) indicated a maximum flow 
of 32,400 cubic feet per second (cfs) in February 1932 (USGS 2008). This flow approaches the estimated 
100-year flood flow of 34,800 cfs. Mean monthly flows range from a low of 299 cfs in August to a high 
of 1,663 cfs in December. 
Fisheries Environmental Consequences 
The analysis area for direct and indirect effects to fisheries is the Robe Valley sub-basin, which includes 
a portion of the South Fork. The expected effects of the project are related to actions that could affect 
riparian cover, large wood recruitment, and sedimentation of spawning and rearing habitats. Healthy 
riparian areas provide many functions, including shade, as well as a source of large wood and other 
organic matter for the aquatic ecosystem. Large wood is important in creating and maintaining spawning 
and rearing habitats for fish, and providing cover from predators.  Excessive sedimentation can bury 
redds and suffocate eggs, fill rearing pools, and irritate gills, which can kill or affect fish health.   

Alternative A  Bridge Option 
No in-water work would be required for the Bridge Option alternative, but work would occur over the 
South Fork and on its banks. Potential direct impacts to resident fish and aquatic organisms could include 
short-term sedimentation and increased turbidity in the river during construction, temporary and 
permanent impacts to riparian vegetation, impacts from altered hydrology or water quality from 
additional impervious surfaces, and water quality impacts from wet or curing concrete. No short-term or 
long-term direct impacts to aquatic habitat are anticipated under Alternative A, because no work in the 
wetted portions of the river will occur and all permanent structures (bridge abutments and bridge deck) 
would be placed outside of the OHWM of the river.  If they occur, short-term impacts to fish species 
would be minor, and limited to small-scale, localized sedimentation.  Long-term effects would be 
potential improvements in riparian habitat and a reduction of the overall sediment input potential. 

Riparian Buffer Impacts 
Approximately 900 square feet of non-mature forest vegetation will be permanently impacted by the 
south abutment and 1,300 square feet of scrub-shrub riparian vegetation will be permanently impacted at 
the north abutment.  Less than 4,500 square feet of scrub shrub/non-mature forest riparian vegetation 
along the South Fork will also be temporarily impacted by a temporary access road. The removal of 
riparian vegetation has the potential to affect aquatic systems by reducing shade, overhead cover, and 
recruitment of woody debris and other organic matter.  Immediate riparian impacts would occur under 
Alternative A and would be of low to moderate severity at the project scale level and minor at the reach 
scale.  However, the project will replant all temporarily disturbed riparian areas with native tree and shrub 
species. In addition, approximately 8,500 square feet of the decommissioned segment of the Monte Cristo 
Grade Road will be planted, restoring approximately 350 linear feet of riparian buffer adjacent to the 
South Fork. This includes removal of road base material, re-grading, and replacement of soil prior to 
planting. 
The short-term impact from the limited riparian clearing activities is not expected to measurably affect 
riparian functions such as large woody debris (LWD) recruitment or temperature and stream shading, 
because of the surrounding topography, relatively small size of trees cleared, amount of adjacent mature 
forest, and the north/south orientation of the clearing. Therefore, effects to fish species from vegetation 
clearing are expected to be insignificant.  Furthermore, the proposed action and associated conservation 
measures will result in a net increase of about 7,800 square feet of riparian vegetation over the long term.  
The increased riparian buffer area is expected to improve fish habitat by providing minor increases in 
shading, terrestrial organic input, LWD recruitment, and sediment retention functions.    

Sediment Impacts 
Grading for bridge construction has the potential to introduce fine sediment into the river during 
construction, but this will be minimized or eliminated by limiting construction to the dry season, when the 
likelihood of significant rain events is relatively low. In addition, the project will meet all water quality 
standards imposed by state and federal laws (e.g., Clean Water Act 404/401). Sediment introduction will 
be substantially limited because most heavy grading and excavation will occur near the central pier and 
north abutment, at least 60 feet from the typical wetted channel, and standard erosion control BMPs will 
be employed to stabilize disturbed areas.   
After construction ceases, potential sedimentation could occur during the first large fall/winter freshet, 
when the river rises to inundate the gravel bar used for equipment access.  Disturbance of the gravel bar 
during construction, including removal and replacement of boulders, could cause minor localized 
disruption of natural bed armoring.  However, such disturbances are expected to be limited and fish mix 
gravel will be spread over any disturbed bar area. Therefore, the potential for temporarily elevated 
turbidity is low during the first storm event of the season.  
Likewise, establishing additional riparian buffer as a conservation measure on the decommissioned road is 
not likely to affect water quality in the South Fork or its tributary streams.  BMP measures will be used to 
prevent sediment from entering the river during restoration of the decommissioned road and any exposed 
soil at the site will be mulched, further reducing the potential for sediment mobilization.  The proposed 
riparian buffer will provide a long-term improvement in water quality and quantity to the river by 
removing impervious surfaces adjacent to the river, and replacing them with a vegetated riparian buffer. 
The removal of the tributary culvert as a conservation measure in 2010 could also potentially introduce 
sediment into the river. However, the work site will be isolated from the flow; the work will occur under 
low flow conditions; and BMPs will be in place to prevent sediment from entering the river. In addition, 
no fish are known to occur in the tributary.  
Water Quality Impacts 
Although a small amount of new impervious surface area (500 square feet) would be added under 
Alternative A, there is a very low potential for negative impacts to fish from contaminants in the 
stormwater runoff from this surface.  All stormwater runoff will be routed through new or existing 
ditches and dispersed over the river bank and rock pads before sheet flowing through vegetated areas to 
be filtered and partially infiltrated.  Overall, the project will result in a net decrease in impervious surface 
area of about 8,000 square feet, due to the restoration of 8,500 square feet of existing roadway located 
immediately adjacent to the river. Furthermore, the average daily traffic on the road would be very low 
(less than 20 vehicles). Thus, no measurable increases in the concentration or loading of stormwater 
contaminants would be expected to enter the South Fork Stillaguamish River, and indirect effects to 
aquatic species would be nonexistent or insignificant.  
Alternative A would require pouring concrete to construct piling caps on the north abutment and central 
pier and to expand the existing south abutment, which has the potential to enter the river. However, the 
majority of concrete work will occur at the north abutment and central pier, over 60 feet from the wetted 
channel, and BMPs will be employed to minimize or eliminate any of the 
6.5 yards of wet concrete used for the south abutment from entering the river.  This concrete will be 
delivered to the south abutment with a crane and concrete bucket.  BMPs would include cleaning the 
bucket between loads and installing a tarp under the bucket prior to transporting any concrete across the 
river.  Additionally, a large bucket will be used such that only a few loads will be needed. With the 
implementation of these BMPs, the potential for uncured concrete to enter the river is small. However, 
even if a small amount of concrete is introduced to the river from the bucket or work on the south 
abutment, it will be diluted rapidly and would not be at a concentration to cause harm to fish species.  
Water Quantity Impacts 
Undetained stormwater from additional impervious surface areas could affect the hydrology of adjacent 
streams, including alterations to the hydrologic cycle which can affect both low- and peak-flows within 
the stream.  Altered stream hydrology can affect fish access (low flows), scour patterns, and other habitat-
related factors. 
Although a small amount of additional impervious surface area (500 square feet) would be added under 
Alternative A, the additional stormwater would be at least partially intercepted and filtered by the native 
vegetation present at the discharge point.  In addition, the project will result in a net decrease in 
impervious surface area of about 8,000 square feet, due to the restoration of 8,500 square feet of existing 
roadway located immediately adjacent to the river.  Based on the large size of the Robe Valley sub-basin 
and the net loss of imperious surface area in the project area, no measurable effects to the flow regime of 
the South Fork would occur and processes affecting fish resources (scour, deposition, water depth) would 
not be affected. 
Summary of Alternative A Impacts 
The fish species and special habitats of management interest in the Robe Valley sub-basin are shown in 
Table 1. Species that rear in the project area would have the most potential to be affected by Alternative 
A, although this potential is quite small.  These include steelhead, cutthroat trout, bull trout, and coho 
salmon.  Chinook and pink salmon may be present at the site in low numbers, but spend little time rearing 
in freshwater relative to other species and would therefore experience fewer effects.  Species that only 
occur in downstream waters, including chum and sockeye salmon, would also experience negligible 
effects, because of further dilution of the minor on-site effects. Human disturbance to fish, including 
fishing pressure, are not expected to substantially change, because average daily traffic for the road is 
about 20 vehicles.  
For federally listed fish and special habitats, the effect determinations are: Not Likely to Adversely Affect 
federally listed Chinook salmon, steelhead, and bull trout; Not Likely to Adversely Affect designated 
Chinook or bull trout critical habitats.  The project May Adversely Affect Pacific Coast salmon essential 
fish habitat for Chinook, coho, or pink salmon, although these effects would be insignificant and short 
term, and avoided to the extent possible through implementation of BMPs and riparian buffer creation. 
For the Forest Service Sensitive and MBS management indicator species of sockeye and chum salmon, 
project activities would have No Impact; the appropriate effect determination from project activities for 
coho, sockeye, and pink salmon and coastal cutthroat and rainbow trout is 
Impact Individuals, Not Likely to Trend toward Listing. 

Alternative B  No Action 
The No Action Alternative would avoid potential construction impacts at the project site and would not 
affect fish species. Human disturbance of fish would remain at existing low levels because of the lack of 
vehicle access to the Monte Cristo Grade Road. Pedestrian access to the bridge site would be possible 
from the Pilchuck Mountain Road but would remain low due to the narrow, rugged trail to access the 
area.  Local, long-term riparian function would be somewhat less than for Alternative A, because no 
decommissioning of a segment of the Monte Cristo Grade Road would occur. 
The No Action Alternative does not require consultation under Section 7 of the ESA or under the 
Magnuson-Stevens Act.  However, the effects of the No Action Alternative would be consistent with 
the following determinations typically used for interagency consultation.  For federally listed fish and 
special habitats, the effect determinations would be: No Effect for federally listed Chinook salmon, 
steelhead, and bull trout, and designated Chinook salmon and bull trout critical habitat, and No Effect for 
Chinook, coho, or pink salmon essential fish habitat.  
Project activities would have No Impact on the Forest Services Sensitive and MBS management 
indicator species sockeye, chum, pink, and coho salmon; coastal cutthroat trout; and rainbow trout. 
Fisheries Cumulative Effects 
A cumulative effect is the effect on the environment that results from the incremental effect of the 
action, when added to the effects of other past, present, and reasonably foreseeable future actions, 
regardless of what agency or person undertakes the other actions and regardless of land ownership on 
which the other actions occur. An individual action when considered alone may not have a significant 
effect, but when its effects are considered in sum with the effects of other past, present, and reasonably 
foreseeable future actions, the effects may be significant. They can occur when small, incremental 
amounts of habitat are lost (or gained) over time through a variety of management activities across a 
landscape (40 CFR 1508.7). 
The cumulative effects area consists of the South Fork, upstream of RM 47, and its tributaries. The 
downstream extent of the cumulative effects area is approximately 1 mile downstream from the project 
site. This extent represents a conservative estimate of the potential area of the downstream sediment 
effects and the restored public access to the Monte Cristo Grade Road. Identifying the downstream 
extent of effects related to fine sediment is imprecise; the 1 mile extent is based upon best professional 
judgment and experience of staff biologists.  It is highly probable that measurable effects would not even 
extend as far as 1 mile downstream, and negligible beyond that point.  The effect of the project will be a 
small-scale, short-term increase in localized fine sediment input into the river, and increased public access 
to the Monte Cristo Grade Road, as compared to the No Action Alternative. 

Past Actions 
The types of past projects that still have indirect lingering effects to fishery resources in the area include 
in-stream habitat restoration, bank stabilization, and transportation infrastructure projects (Table 2). 
Several past County projects are identified as having lingering effects that overlap in both time and space 
with the proposed project.  The past projects include Phases 1 and 2 of the Mountain Loop Highway 
Bank Protection project and repairs at three sites along the Mountain Loop Highway from 2006 to 2008.  
The 2006 repairs were necessitated by erosion of the highway prism during flooding in November 2006.  
In order to maintain access to Silverton and protect the highway, County crews placed riprap along 
several hundred feet of shoreline in locations where the river was directly adjacent to the highway and 
eroding the existing riprap armoring. These repair actions maintained the integrity of riprap revetments. 
County crews constructed Phase 1 of the Mountain Loop Highway Bank Protection project, immediately 
adjacent to the proposed project, early in 2008.  Phase 1 was constructed in response to rapid erosion of 
the right bank during winter flows and the recognition that the highway was likely to be damaged during 
late winter or spring freshets in 2008.  In January 2008, the river eroded over 10 feet at one location, 
reaching to within 30 inches of the edge of the pavement.  The Phase 1 project consisted of armoring 
about 150 feet of river bank with riprap. The project also incorporated several root wads into the bank 
protection. 
These two previous bank protection activities were implemented under emergency conditions during a 
period of imminent threat to the road.  Winter flows and the speed required to respond to the threat of 
erosion drastically reduced the range of options for repair.  The intent of the Phase 2 (non-emergency) 
project was to avoid effects similar to those that have resulted from past road protection actions in the 
analysis area, particularly negative effects on cover and rearing areas for juvenile salmonids and limiting 
riparian processes for the foreseeable future. This was achieved by continuing 250 linear feet of bank 
protection upstream of the Phase 1 site, 
Table 2. Selected Projects Considered For Fisheries Cumulative Effects 
Past County Projects 
Influence 
Overlap with 
Proposed Project 
Activities in Time, 
Type, or Space 
Time/Type Space 
Comments Resulting 
Cumulative Effects 
Rivershore Lane bank 
stabilization and flood 
repair  2005/2006 
Improve in-stream habitat 
complexity, riparian habitat 
quality, and fine sediment 
levels. Decrease channel 
No/No 
No 

migration and increase 
turbidity during construction. 

Little Beaver culvert 
replacement- 2007 
Increase/improve access to 
spawning and rearing 
habitats. 
No/No 
No 

Waldheim Slide upper 
slope stabilization- 
2005 
Reduce sedimentation. 
No/No 
No 
Benefits of bank 
stabilization extend into the 
future as sediment is 
prevented from entering 
the river.  
Mountain Loop 
emergency flood 
repairs- 2006 
Degrade rearing habitat.   
No/No 
No/No 
Repair riprap eroded from 
shoulder of Mountain Loop 
Highway during flood. 
Perry Creek bridge 
flood damage repair- 
2006 
Degrade rearing habitat.   
No/No 
No 
Repair bridge abutment 
damaged during flood. 
Mountain Loop Bank 
Stabilization Project 
Phase 1 - 2007 
Degrade rearing habit. 
Yes/No 
Yes 
Project complete in early 
2008 adjacent to Phase 2. 
Big Four culvert 
replacement- 2009 
Improve access to spawning 
and rearing habitat. 
Yes/No 
No 

Buck Creek Bridge 
replacement- 2013 
Expected to improve rearing 
habitat and floodway capacity 
and locally degrade riparian 
habitat quality. 
Yes/Yes 
No 
Magnitude of effects will 
depend on final design. 
Marten Creek Bridge 
replacement- 2009 
Improve rearing habitat and 
floodway capacity and locally 
degraded riparian habitat 
quality. 
Yes/No 
Yes 
Improved habitat 
conditions. 
Blue Bridge bank 
stabilization- 2009 
Reduce channel widening 
and sediment input.  
Moderate increase in in-
stream habitat complexity.  
Short-term increase in 
turbidity and possible harm to 
fish from worksite isolation 
and fish 
Yes/Yes 
Yes 
Install wooden cribwall and 
rootwads to stabilize left 
bank of South Fork 
Stillaguamish upstream of 
Blue Bridge. 

salvage activities. 

which incorporated soft bank protection elements (tree tops) within the harder bank protection measures 
(riprap).  The tree tops provide rearing habitat and cover for fish, as well as providing nutrient input and 
habitat for aquatic macroinvertebrates.   
The effects of the proposed action would be beneficial, resulting in a long-term improvement of riparian 
buffer along the South Fort, and mitigating the effects of past actions in the analysis area to some degree.   

Present (Ongoing) and Future Actions 
The agencies mentioned above continue to conduct these regular and planned activities in the upper 
South Fork watershed, although the precise locations and timing of some actions are not known. 
Known ongoing projects or those scheduled for future completion include repair of transportation 
infrastructure projects, restoration projects, trail development, and routine maintenance of roads, trails, 
and campgrounds (Table 3). None of the effects of the specifically identified projects are anticipated 
to overlap in both time and space with the proposed project, although some routine activities could 
overlap in time and/or space.  However, the effects of the maintenance activities are typically 
temporary and immeasurable or beneficial to aquatic resources. Effects from these routine 
maintenance activities are immeasurable and therefore negligible, even if they do overlap in both space 
and time.  
Summary 
The contribution of the Monte Cristo Grade Bridge project alternatives would be negligible to the 
total cumulative effects to fish and fish habitats in the South Fork and its tributaries. 
Forest Plan Consistency 
All alternatives are consistent with the Forest Plan, as amended, Standards and Guidelines for fishery 
resources. 
Table 3. Selected Present and Future Projects Considered For Fisheries Cumulative Effects 
Present (Ongoing) and Future Overlap Comments Resulting Forest Service Projects Influence Time/Type Space 
Cumulative Effects 
Routine annual road maintenance 
Flood repairs of roads & bridges: Mallardy Creek Bridge (FS Road 4032), Coal Lake Road (FS Road 4060), Bear Lake 
Road & Black Creek Bridge (FS Road 4021) 
Routine trail maintenance 
Campground maintenance 
Trail construction at Perry Creek 
Trailhead parking lot enlargement at Dickerman Trailhead and Lake 22 Trailhead 
Decommissioning of the Perry Creek Road (FS Road 4063) 
Replacement of the Big Four Trail Bridge and trail repair Decrease in chronic sedimentation and prevention of mass 
wasting 
Degrade rearing habitat and temporary increase in sedimentation 
Minor clearing of vegetation and reduction in sedimentation 
Clearing vegetation and possible disturbance of fish from recreational use 
Increase in sedimentation and disturbance from recreational use 
Possible minor increase in sedimentation 
Reduction in sediment and improvement in riparian function 
Temporary sedimentation Yes/No Yes 
No/Yes No 
Yes/No Yes 
Yes/No No Includes clearing hazard trees 
Yes/No No 
Yes/No No 
Yes/No Yes 
Yes/No No 
REFERENCES 
Myers, J.M., R.G. Kope, G.J. Bryant, D. Teel, L.J. Lierheimer, T.C. Wainwright, W.S. Grant, 
F.K. Waknitz, K. Neely, S.T. Lindley, and R.S. Waples. 1998. Status review of Chinook salmon 
from Washington, Idaho, Oregon, and California. U.S. Department of Commerce, NOAA Tech. 
Memo. NMFS-NWFSC-35. 443 pp. 
Snohomish County. 2008. Draft Biological Assessment - Monte Cristo Grade Bridge (PW# 06-00976, 
RC1513). August 2008. Everett, WA.  
USDA Forest Service. 1990. Land and Resource Management Plan. Mt. Baker-Snoqualmie National 
Forest. USDA Forest Service, Pacific Northwest Region. 
USDA Forest Service. 2004. Regional Foresters Sensitive Animal Species List, July 2004. Pacific 
Northwest Region, Portland, OR. 
USGS (United States Geologic Survey). Historical flow data for Stillaguamish Watershed. Accessed 
online at: http://wa.water.usgs.gov/cgi/adr.cgi?12167000  
WDF (Washington Department of Fisheries), Washington Department of Wildlife, and Western 
Washington Treaty Indian Tribes. 1993. 1992 Washington State Salmon and Steelhead Stock 
Inventory. Olympia, WA. 
WDFW (Washington Department of Fish), and Wildlife. 1998. Washington Salmonid Stock 
Inventory, Bull Trout/Dolly Varden Appendix. Olympia, WA. 
WDFW (Washington Department of Fish and Wildlife). 2000. Washington State Salmonid Stock 
Inventory, Coastal Cutthroat Trout Appendix. Olympia, WA. 
WDFW (Washington Department of Fish and Wildlife). 2002 (draft). Washington State Salmon and 
Steelhead Stock Inventory. Olympia, WA. 
WDFW (Washington Department of Fish and Wildlife) and WWTT (Western Washington Treaty 
Indian Tribes). 1994. 1992 Washington State Salmon and Steelhead Stock Inventory. Appendix 
One, Puget Sound Stocks. North Puget Sound Volume. Olympia, WA. 418pp. 
WDFW (Washington State Conservation Commission). 2002. Salmonid habitat limiting factory 
analysis. Stillaguamish River watershed (WRIA 5) Final Report. 
Williams, R.W., R.M. Laramie, and J.J. Ames. 1975. A Catalog of Washington Streams and Salmon 
Utilization. Puget Sound Region. Olympia, WA: Washington Department of Fisheries. Vol. 1. 
WSCC (Washington State Conservation Commission). 1999. Salmon limiting factors final report: 
Water resource inventory area 5  Stillaguamish Watershed.  July 1999. Olympia, WA. 

 TECHNICAL 
MEMORANDUM 
Date: October 8, 2008 To: Sean Gross, Snohomish County Public Works From: Pete Lawson Subject: Monte 
Cristo Grade Road Bridge (#RC1520) Aquatic Conservation Strategy (ACS) 
Review - Work Authorization #20  
cc: File 
Project Number: 553-1513-085, Phase 20 Project Name: Monte Cristo Grade Road Bridge Environmental 
Support 
Snohomish County Public Works (County) is proposing to construct a single-lane, steel-truss bridge 
across the South Fork Stillaguamish River (South Fork) to restore vehicle access to approximately 20 
properties. The following is an Aquatic Conservation Strategy (ACS) review, required by the Forest 
Plan, as amended (USDA Forest Service 1990), to assess the potential effects of the project on the 
ecological health of aquatic resources associated with construction of the Monte Cristo Bridge on the 
South Fork. 

AQUATIC CONSERVATION STRATEGY REVIEW 
The ACS was developed to maintain and enhance the ecological health of watersheds and aquatic 
ecosystems occurring on federal public lands. The four primary components of the ACS identified by 
the Forest Plan are intended to protect aquatic and riparian-dependent species and to maintain and 
restore the productivity and resiliency of aquatic and riparian ecosystems. These four components of 
the ACS are: 
	Riparian Reserves 
	Key Watersheds 
	Watershed Analysis 
	Watershed Restoration 

Riparian Reserves 
Riparian Reserves for the project area do not include cut areas around the streams and inner gorges 
and harvest prescriptions that acknowledge and maintain the functions of the Riparian Reserves. 
(Rev. 06/04) 
Key Watershed 
The project area is located within the South Fork, which is identified as a Tier 1 Key Watershed. 
Therefore, the Forest Plan would require a complete watershed analysis prior to timber harvest and 
reducing the amount of system and non-system roads through decommissioning. While the project 
does not include any timber harvest activities or any new permanent roads, about a half mile of 
existing Monte Cristo Grade Road would be decommissioned as part of the proposed project to 
enhance riparian buffer habitat along the South Fork. 
Watershed Analysis 
A watershed analysis was completed in 1996 (USDA Forest Service 1996) for the Lower South 
Fork/Canyon Creek watershed, in which the proposed project is located.  In addition, a watershed 
analysis was completed in 1994 (USDA Forest Service 1994) for the Upper South Fork watershed, 
located 2 miles upstream of the project site.  
Watershed Restoration 
Restoration activities have occurred in several locations in the South Fork watershed area, which 
include road reconstruction and drainage upgrades, road decommissioning, noxious weed treatments, 
and in-stream treatments and off-channel aquatic habitat creation or enhancement.  In addition to 
Forest Service-sponsored projects, the County  has undertaken several restoration actions including 
fish passage improvement and restoration at the Shady Side dispersed recreation area, which restored 
a cleared area with riparian and conifer vegetation and blocked vehicle access to existing riparian and 
aquatic habitats. 
In addition to the four primary components of the ACS, there are nine objectives that collectively 
ensure that the natural processes that the Riparian Reserves are intended to protect would continue to 
function appropriately.  The requirements of the National Forest Management Act include a 
determination of consistency with these nine objectives as described in the Record of Decision for 
amendments to Forest Service and Bureau of Land Management planning documents within the range 
of the northern spotted owl (USDA and BLM 1994 page B-10). In addition, the Pacific Coast Fed. of 
Fishermans Assn. et al. v. Natl. Marine Fisheries Service, et al. and American Forest Resource 
Council, Civ. No. 04-1299RSM(W.D. Wash)(PCFFA IV) decision ruled that project consistency 
reviews must evaluate the project at both the site scale and the watershed scale. The following is an 
assessment of the Monte Cristo Grade Road Bridge project against the nine ACS objectives. 
Objective 1: 
Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale 
features to ensure protection of the aquatic systems to which species, populations and communities are 
uniquely adapted. 
The Monte Cristo Grade Bridge project would have a restorative effect, relative to Objective 1, by 
enhancing the South Fork riparian buffer to provide long-term improvement.  Although some 
permanent riparian clearing of shrub and non-mature forest would occur (1,300 and 900 square feet of 
clearing, respectively) during project construction activities, about 8,500 feet of riparian buffer would 
be enhanced by abandoning and replanting a portion of the Monte Cristo Grade Road with native 
shrubs and trees. Furthermore, all temporarily disturbed areas would be replanted with native trees 
and shrubs. 
Because the bridge deck and piers will be placed outside of the South Fork ordinary high water mark 
(OHWM), natural river processes that provide in-stream cover, hydraulic refuge to aquatic species, 
and large woody debris (LWD)recruitment will not be affected by the proposed project.   
Objective 2: 
Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, 
longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, 
headwater tributaries, and intact refugia. These network connections must provide chemically and 
physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and 
riparian-dependent species. 
The Monte Cristo Grade Bridge project would maintain and improve connectivity functions along the 
South Fork. The proposed action would maintain the integrity of the riparian buffer over the long 
term, although clearing of some vegetation would be necessary during construction.  Because the 
existing bridge approaches are already in place, and because the bridge will be placed outside of the 
South Fork OHWM, the bridge itself would not affect aquatic refugia, and would have only a 
negligible effect on riparian connectivity. Similarly, the project is not expected to obstruct the 
movement of terrestrial species, dependent upon riparian corridors for their habitat needs or 
movement between habitat areas.    
The long-term improvement in the riparian buffer would ultimately result in increased LWD 
recruitment, which could contribute to an increase of complex in-stream wood features that, in turn, 
would enhance the connectivity of productive rearing and foraging habitats for native fish and aquatic 
macroinvertebrates. 
Objective 3: 
Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and 
bottom configurations.  
The Monte Cristo Grade Bridge project would maintain the physical integrity of the aquatic system 
because all work associated with the project would occur in the dry season and all structures 
associated with the bridge will be located outside of the OWHM. Also, the restoration of 8,500 
square feet of existing roadway located immediately adjacent to the river will aid in restoring the 
overall integrity of the aquatic system.     
The project would maintain the physical integrity of the streambed configuration and would not 
affect sediment transport or deposition processes within the South Fork.  The project is designed to be 
consistent with the Stillaguamish Basin Chinook Salmon Recovery Plan by maintaining or improving 
long-term LWD recruitment potential.   
Objective 4: 
Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland 
ecosystems. Water quality must remain within the range that maintains the biological, physical, and 
chemical integrity of the system and benefits survival, growth, reproduction, and migration of 
individuals composing aquatic and riparian communities. 
The Monte Cristo Grade Bridge project would not adversely affect water quality in the South Fork. 
Although a small amount of impervious surface area (500 square feet) would be added under 
Alternative A, there is a very low potential for negative impacts to fish species from stormwater 
contaminants generated by this surface.  All stormwater runoff will be routed through new or existing 
ditches, and dispersed over the river bank and rock pads, before sheet flowing through the vegetated 
buffer area.  This process will filter and partially infiltrate the runoff.  In addition to the small amount 
of additional impervious surface constructed under Alternative A, the average daily traffic on the 
road would be very low (less than 20 vehicles).  Furthermore, the project will result in a net decrease 
in impervious surface area of about 8,000 square feet, due to the restoration of 8,500 square feet of 
existing roadway located immediately adjacent to the river. Thus, no measurable increases in the 
concentration or loading of stormwater contaminants would be expected to enter the South Fork 
Stillaguamish River, and indirect effects to aquatic species would be nonexistent or insignificant. 
Although water quality would be maintained over the long term, construction and grading activities 
for the bridge and road decommissioning may cause minor, short-term increases in sedimentation and 
turbidity in the river. However, sediment will be minimized or eliminated because the majority of 
grading will occur at least 60 feet from the river; construction will be limited to the dry season; 
appropriate sediment and erosion control construction best management practices (BMPs) will be 
employed; and all water quality standards imposed by state and federal laws (e.g., Clean Water Act 
404/401) will be met.  Temporarily disturbed areas will be mulched and planted to reduce sediment 
mobilization after construction.   
No substantial sedimentation from the gravel bar used for equipment access is expected during bridge 
construction or after the first high flows of fall/winter.  Any disturbance of the bar will occur at low 
water and short term because fish mix gravel will be spread on site to cover the disturbed bar area, 
appropriate sediment and erosion control BMPs will be applied, and any boulders moved to deploy 
equipment will be re-dispersed subsequent to equipment removal.   
Likewise, the proposed riparian buffer enhancement along Monte Cristo Grade Road would provide 
some potential improvement in long-term water quality in the river by removing some existing 
impervious surfaces adjacent to the river, and replacing them with a vegetated riparian buffer. Short-
term effects from culvert removal along the road could occur, but the work site will be isolated from 
the river during low flow conditions, and BMPs will be in place to prevent sediment from entering the 
stream. Therefore, no measurable effects to water quality are expected. 
Objective 5: 
Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the 
sediment regime include the timing, volume, rate, and character of sediment input, storage, and 
transport. 
The Monte Cristo Grade Bridge project would likely meet Objective 5 at the project and reach scale, 
and promote restoration at the watershed scale by improving the long-term sediment filtration process, 
and by converting a portion of the existing roadway into native riparian vegetated buffer habitat. Use 
of appropriate BMPs, management requirements, and mitigation measures would minimize and 
mitigate potential short-term increases in sediment mobility associated with any soil disturbance from 
construction activities. At both the reach and watershed scale, changes in the overall sedimentation 
rates attributable to the project would likely be non-detectable given the high variability in natural 
rates of sediment input along the river. 

Objective 6: 
Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland 
habitats and retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, 
and spatial distribution of peak, high, and low flows must be protected. 
The project would contribute to maintaining stream flows. Stormwater associated with the project at 
the bridge approaches is not expected to alter the hydrologic cycle, including low or peak river flows.  
The additional stormwater would be at least partially intercepted and filtered by the existing native 
vegetation at the discharge point and the area of additional impervious surface is small.  In addition, 
8,500 square feet of impervious surface will be removed along the Monte Cristo Road as project 
mitigation.  Therefore, any changes would be negligible and immeasurable.  
Likewise, minor clearing and grading would remove vegetation and increase soil compaction in the 
work area, causing a negligible increase in runoff from the site in the short term.  This negligible 
increase in runoff from the relatively small site would have no measurable effect on the flow 
characteristics of the South Fork. 

Objective 7: 
Maintain and restore the timing, variability, and duration of floodplain inundation and water table 
elevation in meadows and wetlands. 
The project would maintain the current floodplain inundation and water table conditions at both the 
project and the watershed scales. Most of the work area is outside of the South Fork floodplain, and 
only a small increase would occur from installation of the center bridge pier to replace the existing 
pier. The majority of the work will occur outside of the OHWM, atop the high right and left banks of 
the river.   
Objective 8: 
Maintain and restore the species composition and structural diversity of plant communities in riparian 
areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, 
appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and 
distributions of coarse woody debris sufficient to sustain physical complexity and stability. 
The project would contribute to the restoration of Objective 8 over the long term at both the project 
and watershed scales. The project will preserve as many riparian trees as possible and rehabilitate a 
left-bank portion of the riparian zone upstream of the bridge site, which currently serves as roadway. 
This would contribute to a long-term improvement of riparian vegetation that will provide shade, 
nutrient and sediment filtering, and a source of woody debris and other organic matter. 
Objective 9: 
Maintain and restore habitat to support well-distributed populations of native plants, invertebrates, 
and vertebrate riparian-dependent species. 
The project would contribute to restoration of this objective by enhancing the integrity of the riparian 
area upstream of the bridge site.  Maintaining a vegetated riparian zone directly adjacent to the river is 
necessary to support native plant, invertebrate, and vertebrate riparian-dependent species at the site 
scale.  Preservation will contribute to supporting populations of native plant, invertebrate, and 
vertebrate riparian-dependent species at the watershed scale. 
SUMMARY 
Overall, the Monte Cristo Grade Bridge project would help preserve key ecological functions of the 
Riparian Reserves.  The project, designed to allow access to the existing Monte Cristo Road, while 
not directly impacting the South Fork, is consistent with all nine ACS objectives at the site and 
watershed scales. 
Because riparian planting of an existing road section will be conducted as a conservation measure, the 
project will preserve the physical integrity of the soils in the buffer, allowing the re-establishment of 
woody vegetation after construction.  Long-term preservation of buffer soils and protection of 
riparian vegetation and soils will maintain connectivity of riparian habitats and watershed functions. 
REFERENCES 
USDA Forest Service 1990. Land and Resource Management Plan. Mt. Baker-Snoqualmie National 
Forest. U.S. Department of Agriculture, Forest Service, Pacific Northwest Region. 
USDA Forest Service. 1994. South Fork Upper Stillaguamish Watershed analysis, Darrington Ranger 
District. Mt. Baker-Snoqualmie National Forest, WA.  
USDA Forest Service. August 1996. Watershed Analysis South Fork Lower Stillaguamish River, Canyon 
Creek. Darrington Ranger District. Mt. Baker Snoqualmie National Forest, Pacific Northwest Region.  
USDA Forest Service and BLM (Bureau of Land Management). 1994. Record of decision for 
amendments to Forest Service and Bureau of Land Management planning documents within the 
range 
of the Northern Spotted Owl. Portland, OR. 

 TECHNICAL 
M EM ORANDUM 
Date: October 8, 2008 To: Sean Gross, Snohomish County Public Works From: Pete Lawson Subject: Monte 
Cristo Grade Road Bridge Replacement 
Wildlife Resource Report and Biological Evaluation-Work Authorization #20 
cc: File 
Project Number: 553-1513-085, Phase 20 Project Name: Monte Cristo Grade Road Bridge Environmental Support 
INTRODUCTION 
Record rainfall occurred in Western Washington during October 19 to 21, 2003, causing extensive 
damage throughout the region. Flooding and erosion in the South Fork Stillaguamish River (South 
Fork) watershed caused about 200 feet of the Monte Cristo Grade Road, just outside of Verlot, 
Washington, to wash out. Additional erosion also occurred during the 2006 and 2007 flood seasons. 
The Monte Cristo Grade Road is an unpaved gravel road that used to provide access to about 20 
recreational properties and one residence. However, the road has been barricaded since 2003 and there 
is currently no vehicular access to these properties or to National Forest land along the road. 
This biological evaluation examines the effects on wildlife of the Snohomish County (County) 
proposal to reconstruct a bridge across the South Fork and abandon about a half-mile of the Monte 
Cristo Grade Road. The bridge would connect the current dead end of 342nd Drive NE to the Monte 
Cristo Grade Road, on the same alignment as a previous bridge, to provide public access to properties 
along Monte Cristo Grade Road. The Forest Service proposes to issue a special use permit to the 
County to construct the project. 
ExistingCondition 
The Monte Cristo Grade Road project occurs near an eroded bank of the South Fork. The area 
consists of scattered pockets of mixed deciduous and second-growth and old-growth mixed conifer 
forested habitat near the bridge location and upslope (south) areas, as well as along the road. There is 
abundant understory vegetation of primarily low-growing herbs and shrubs, including huckleberry, 
salmonberry, twinflower, horsetail, alder, and cottonwood. There are some large pockets of old-
growth habitat with abundant and diverse riparian vegetation, as well 
(Rev. 06/04) 
as several streams with side channels and adjacent ponds. These streams flow alongside the Monte 
Cristo Grade Road, and downslope (north) into the South Fork. 
Methods 
Analyses of potential impacts were made based on a review of plans for the proposed action, an on-
site evaluation of existing habitat conditions, data on the current and historical distributions of each 
species from The Priority Habitat and Species (PHS) database maintained by Washington Department 
of Fish and Wildlife (WDFW 2008), and personal communications with local agency biologists 
(Brown, personal communication). 
FEDERALLY LISTED THREATENED AND ENDANGERED SPECIES 
A biological assessment was completed and approved in September 2008 by the County, which was 
the source of much of the information on threatened or endangered species, and their habitat, 
occurring in the area. 

Spotted Owl 
No surveys for spotted owls have been completed within the project area and no spotted owl 
territories have been documented within 1 mile of the bridge or along the road. Old growth forest 
with some of the characteristics of spotted owl nesting, roosting, and foraging habitat, is present 
along the south side of the South Fork Stillaguamish, both on National Forest and private land, in the 
general project vicinity. However, large blocks of habitat meeting United States Fish and Wildlife 
Service (USFWS) requirements for spotted owl home range territories are not available because the 
existing forest stands are surrounded on three sides by private land that is managed for timber 
production and the areas supporting mature forest are not large enough to meet the needs of nesting 
spotted owls. 
Although mature forest in the project area may provide foraging or dispersal habitat for spotted owls, 
neither spotted owl nesting or roosting habitat is present within the immediate project area (100 yards 
of project site). In addition, the project site has high levels of ambient noise due to its location 
immediately adjacent to South Fork Stillaguamish River. Ambient noise levels at this location could 
interfere with hunting success or alert response, both of which depend primarily on the hearing ability 
of owls. For this reason it is possible that spotted owls are less likely to nest, roost, or forage at this 
location, compared to other locations farther away from the river. 
Noise from most bridge construction activities will be limited to a small area and is expected to be 
within ambient noise levels of the river. However, pile driving noise may extend into the old-growth 
forest along the south side of the river, potentially disturbing any spotted owls that may be using the 
area for roosting, foraging, or dispersal. Any such disturbance would be short term and temporary; 
additional suitable habitat is available in adjacent areas. It is expected that resumption of the limited 
amount of road use will not alter any uses of the habitat in the area by spotted owls; therefore, 
continued use of the road will have no effect on spotted owls. The project is also outside of 
designated critical habitat for the northern spotted owl. Therefore, the project is not likely to adversely 
affect northern spotted owls, and will have no effect on critical habitat for spotted owls. 

Marbled Murrelet 
The PHS database maintained by WDFW documents two occurrences of marbled murrelet in the 
area. One is upslope and southeast of the bridge replacement site, approximately 0.3 mile from the 
construction area. This occurrence is far enough away such that construction noise from the bridge 
replacement work will not affect murrelet nesting at this location. The other occurrence is adjacent to 
the road and river, just over 0.25 mile from the bridge replacement site. This occurrence was from 
1988 when the road was in use. It is expected that ambient noise levels from the river will mask noise 
expected from the bridge replacement location such that any occurrence of murrelets down the road 
are not likely to be affected by noise at the bridge site. 
It is expected that the resumption of traffic along this road would not affect the use of suitable 
habitat by marbled murrelets. Right-of-way clearing will occur after the nesting season is completed 
(after August 15); so right-of-way clearing is unlikely to affect use of nesting habitat by marbled 
murrelets. Overall, no effect on marbled murrelets from continued use of the road and clearing of 
ROW vegetation is expected. 
The project area is within designated marbled murrelet critical habitat, although no components of 
suitable habitat will be removed as part of the bridge replacement or right-of-way clearing. A few 
small firs are scheduled to be removed at the location of the new bridge, but would result in no 
change to suitable habitat; therefore, it is expected that this project is not likely to have an adverse 
effect on marbled murrelet critical habitat. 
The effects of noise disturbance will be discountable due to the low probability of murrelet nesting in 
the action area during construction. However, if murrelet nesting does occur within the action area 
during construction, effects from noise would be insignificant due to the combination of distance 
and timing. The project is not likely to adversely affect marbled murrelets or their critical habitat. 

Canada Lynx 
The nearest potential habitat for lynx is located approximately 30 miles east of the project area along 
the Cascade Crest. Movement from occupied habitat to the project area is limited by lack of suitable 
foraging habitat. As a result, the project is expected to have no effect on Canada lynx. 

Gray Wolf 
Currently, only dispersing animals would be expected to occur in the project area because an 
adequate prey base to support resident wolves is not present. Because this area is already heavily 
influenced by human activity due to access to private parcels, developed and dispersed campgrounds 
along the South Fork, and residential uses, this project is not expected to affect dispersal patterns. As 
a result, the project is expected to have no effect on gray wolf. 

Grizzly Bear 
The project area is not within any Bear Management Unit that is known to have recent detection or 
sightings (within last 10 years). No habitat would be affected and there would be no change to 
vehicle access compared with past use. Because the project occurs on a low-use road, this project is 
not expected to affect grizzly bear movement patterns or habitat use. Therefore, the project is 
expected to have no effect on grizzly bear. 
REGIONAL FORESTERS SPECIAL-STATUS SPECIES 
The following discussions address the potential impacts of the project on vertebrate and invertebrate 
species on the Regional Foresters list of special-status species potentially occurring in the project 
area. There is no potential habitat for common loon (large lakes); Larch Mountain, and Van Dykes 
salamander (range is south of US 2); peregrine falcons (cliff habitat within 1 mile); wolverine (large 
undisturbed expanses of high elevation habitat) or great gray owls (open forest forage areas). 
Because of the lack of suitable habitat within the project area, this project will have no impact on 
these species. 
On July 24, 2007, the Undersecretary of the Department of Agriculture signed a Record of Decision 
(ROD) (complete title: Record of Decision to Remove the Survey and Manage Mitigation Measure 
Standards and Guidelines from Forest Service Land and Resource Management Plans Within the 
Range of the Northern Spotted Owl), which removed certain requirements from all of the National 
Forest land and resource management plans (LRMPs) within the range of the northern spotted owl. 
However, because the court in Northwest Ecosystem Alliance et al. v. Mark Rey et al., Civ. No. 04-
844, Western District of Washington has not yet granted the governments motion to lift the 
modified October 11, 2006 injunction, this project is designed to be consistent with the 2001 Survey 
and Manage ROD, as modified by subsequent annual species reviews. Implementation of this project 
will have no adverse impacts on any of the terrestrial rare and uncommon mollusk species addressed 
in that ROD. 

Bald Eagle 
The USFWS removed the bald eagle from the federal list of endangered and threatened wildlife, 
effective August 8, 2007 (72 Federal Register [FR] 37346-37372). Bald eagles are protected by the 
Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act, and are on the Regional 
Foresters Sensitive Species List. Suitable nesting and roosting habitat for bald eagles occurs along 
the river in the project area, but no known records of bald eagle use are noted in the PHS database 
and there are no records of bald eagle nests or winter roost sites. This stretch of the river is not 
usually occupied in the winter months, likely due to lack of forage items. Even with a fish ladder at 
Granite Falls, the falls limits the extent of anadromous fish movement up the South Fork, reducing 
the amount of prey for eagles. The project will not remove any large potential nesting trees along the 
river and would occur after fledging of bald eagles is expected to be constructed (July 15 to August 
15), and prior to any winter time use of eagles; therefore, the project is expected to have no impact on 
bald eagles. 

Harlequin Duck 
This species is found along large fast-flowing rivers and streams, and because this project occurs 
alongside the river, it is expected that harlequin ducks may nest or forage near the project site. 
However, activities associated with the bridge replacement will occur at the end of the breeding 
season when chicks can easily move away from any project activities that may disturb their foraging. 
No suitable habitat will be affected by this project and disturbance to any ducks while foraging is 
expected to be minimal. Therefore, the project is expected to have no impact on harlequin ducks. 

Townsends Big-Eared Bat 
Potential foraging habitat for this species occurs in the project area. Roosting habitat in the form of 
mines, buildings, or caves is not known to occur in the area. The species has not been detected in the 
South Fork drainage. This project would not affect any roosting habitat and would not significantly 
alter vegetation. Because the project would occur during the day, there is no potential to alter 
foraging or roosting behavior. As a result, this project is expected to have no impact on Townsends 
big-eared bats. 

Johnson's hairstreak 
This butterfly depends on lowland coniferous forests that contain dwarf mistletoes of the genus 
Arceuthobium. The nearest documented sighting was an adult butterfly found near Verlot in 1953. In 
addition, one larva was found in Snohomish in 1960, and one adult and one larva were found at 
Garland Mineral Springs near Index in 1961. Since 1960 there have been only 12 documented 
occurrences in Pierce, King, and Snohomish counties. No trees with dwarf mistletoe infestations 
would be affected by the proposed project; therefore, no impact to the Johnsons hairstreak is 
expected. 

Puget Oregonian 
This snail species is reported to use old forest habitat at elevations less than about 1,500 feet above 
sea level. This habitat type occurs adjacent to the project site, although the nearest occupied habitat 
for this species is 160 miles south of the project area. Numerous surveys in suitable habitat between 
the occupied location and the project area failed to detect the species. Because repeated surveys in 
apparently suitable habitat have failed to detect Cryptomastix devia within proximity of the project 
area, it is not expected to occur. In addition, no removal or disturbance of suitable habitat is expected 
as well. Therefore, the project is expected to have no impact on the Puget Oregonian. 

Evening fieldslug 
Occupied range for this species is from Hood River to the Klamath River basin, Oregon. After 10 
years of surveying in suitable habitat, the species has not been detected in Washington, and 
therefore there is no reason to suspect the species to occur in the Mount Baker-Snoqualmie 
National Forest. Although there is suitable habitat in the overall project area, the proposed action 
does not affect suitable habitat. Because the species is not known or expected to occur and there 
would be no impacts to potential suitable habitat, the project is expected to have no impact on 
evening fieldslugs. 

Warty jumping-slug 
The nearest occupied site of this species is approximately 80 miles south of the project area. 
Numerous surveys in suitable habitat between the occupied location and the project area failed to 
detect the species. Although there is suitable habitat in the overall project area, the proposed 
action does not affect suitable habitat. Because this species is not known or expected to occur in 
the project area, and there would be no impacts to potential suitable habitat, the project is 
expected to have no impact on warty jumping-slugs. 

Oregon megomphix 
For Washington, records indicate this species has a low-elevation distribution from Olympia to 
the Columbia River, which does not include any National Forest lands. Numerous surveys in 
suitable habitat between the known locations and the project area failed to detect the species. 
This species appears to be found at elevations lower than those found in the project area. 
Therefore, this project is outside the range of potential suitable habitat. Because repeated surveys 
in apparently suitable habitat have failed to detect Megomphix hemphilli and this project is 
outside the range of this species, the project is expected to have no impact on Oregon 
megomphix. 

Shiny tightcoil 
This species is only known to occur east of the Cascade Mountains. A tentative identification of 
this species occurring on the Olympic Peninsula remains unconfirmed 10 years after its reporting. 
Because the species has not been confirmed to occur west of the Cascade Mountains, it is not 
expected to occur in the project area. The project is expected to have no impact on shiny 
tightcoils. 
MANAGEMENT INDICATOR SPECIES 
No impacts are expected to Management Indicator Species. The project would not affect 
mountain goat due to a lack of suitable habitat in the project area. There would be no change in 
habitat conditions for pine marten and therefore no impacts to the species. Although the project 
may occur in black-tailed deer winter range, construction activities would not occur during the 
winter and would avoid having any impact on wintering deer or forage for deer. Habitat for 
woodpeckers, including pileated woodpecker, would not be impacted by the removal of alder 
trees less than 6 to 20 inches in diameter. The removal of a limited number of second-growth 
trees is not expected to affect populations of woodpeckers in the area. 
NEOTROPICAL MIGRATORY BIRDS 
This project would not affect more than a few small-diameter alder and fir trees where 
neotropical birds may nest and forage. All project impacts will be limited to a small area and are 
expected to occur late in the nesting season, when all young are likely to have fledged. Therefore, 
the project is expected to have no impact on neotropical migratory birds. 
CUMULATIVE EFFECTS 
The project is in rural Snohomish County in an area dominated by federally owned forest land, 
with scattered private and state-owned land. Land-disturbing activities in the basin include 
forestry and associated road building, residential housing construction, and minor amounts of 
mining. Several flood repair road projects are being planned in the basin on federal and county 
land, including culvert and bridge wash-out repairs on Forest Service land and a number of road 
shoulder repairs in the Stillaguamish River drainage. The landslides at Gold Basin are a high 
priority for stabilization to minimize sediment input to the river. The County recently updated its 
Critical Areas Ordinance, which provides restrictions for land development near sensitive natural 
resources and requirements for mitigation of impacts. 
Construction of the bridge over the river could cause minor amounts of sediment to enter the 
river. However, the construction timing (dry season), limited area potentially disturbed, and the 
relatively short construction period indicate no long-term effects to wildlife species or habitat are 
anticipated. 
The bridge would re-establish vehicle access for landowners and could lead to future 
development of properties that are currently undeveloped. However, the area is zoned as one 
structure per lot so development would be minimal and would not significantly contribute to 
basin-wide cumulative effects from land clearing. The County does not expect changes in zoning 
that would greatly increase the development along this road. This is a dead end road and there 
are currently no utilities along the Monte Cristo Grade Road. If the properties are developed, the 
County expects it to be primarily for seasonal, recreational use. 
REFERENCES 
Brown, Marianne. Personal email communication with Phyllis Reed, Wildlife 
Biologist/Environmental Coordinator of the Darrington Ranger District in the Mount Baker-
Snoqualmie National Forest on September 9, 2008. 
WDFW (Washington Department of Fish and Wildlife). 2008. Priority Habitats and Species 
Data. Olympia, Washington. 

20.	APPENDIX E: COMMENT LETTERS AND RESPONSES

July 7, 2008

Mark Eberlein
FEMA Region X Environmental Officer
130th 228th Street SW
Bothell, WA 98021

Re: Bridge Construction to Provide Access to a Portion of the Monte Cristo Grade
Road

Dear Mr. Eberlein:

Thank you for the opportunity to comment on the Draft EA for the Monte Cristo Grade Road 
Bridge. The mission of Pilchuck Audubon Society is to conserve and restore natural 
ecosystems, focusing on birds and other wildlife, for the benefit of the earth's biological diversity. 
It is with this statement in mind that we share our concerns below.

Has any research been done to determine whether there are wildlife corridors in the path of the 
proposed bridge? We are concerned that the bridge could be a barrier for wildlife movement.

The proposed open steel grate bridge design will increase the runoff of pollutants into the river. 
How will this be mitigated? What type of low impact stormwater treatment will be constructed for 
the new paved bridge approaches? It is imperative to protect the water quality of the river for 
wildlife, particularly ESA listed fish species.

The EA states that work will be completed during "the dry season" (p. 24). But according to the 
table on p. 36, ESA listed fish will be spawning in the river during the dry months of August and 
September! These conflicting timetables may make it impossible to complete the construction.

We have two concerns regarding the tree removal, as described on p. 29, section 3.4.3, which 
states, "The primary wildlife impact would occur from the removal of trees to construct the 
bridge." First, in terms of displacing potential bird nesting habitat, the EA notes "the bridge site is 
adjacent to large tracts of densely forested USFS which provides alternative habitat." The 
problem with this reasoning is that those adjacent habitats are already occupied. Any displaced 
nesting, migratory and resident birds have nowhere to 
go.

Second, we are concerned about the tree removal proposed in Figure 4 (Proposed Bridge 
Location) on pg 11. This will likely result in what is known as an "edge effect" in the landscape, 
which can result in predation of eggs and young in the trees left standing. The proposed removal 
will tend to increase the edge effect, with subsequent adverse impacts to wildlife.

Does the project conform to all Migratory Bird Treaty Act protections? Will trees be removed 
during nesting season? If so, this would obviously destroy nests as the trees are removed. 
Contrary to the assertion on p.19 of the EA, this would indeed harm migratory birds.

Furthermore, marbled murrelet nesting would be disturbed by the proposed action, and must be 
protected by appropriate work windows. If the trees to be removed are suitable marbled murrelet 
nest trees, their removal would be prohibited. The EA states (p. 41) that suitable marbled 
murrelet nesting habitat does exist within 200 feet of the proposed project area. Any birds using 
these trees would definitely be disturbed by the noise of construction. Bald eagles would also be 
disturbed by the noise.

We are concerned about the possibility of fresh concrete spills into the river during construction, 
especially given the plan to hoist buckets of it across the river. The 
pressure washing of the old bridge abutments proposed could result in concrete dust polluting the 
river as well.

We wish to correct the statement on p. 18 that "NEPA suggests [emphasis added] including 
analysis of a 'No Action Alternative'..." In fact, this analysis is required by NEPA, and must be 
rigorous and thorough. Furthermore, NEPA also requires that a full range of alternatives be 
examined. The EA evaluates only a single action alternative and the requisite 'No Action" 
alternative. At the least, an alternative to purchase the affected
properties should also be evaluated.

In light of the Midwest's recent floods and, in some cases, entire towns of displaced Americans, 
we consider the construction of a bridge for 24 recreational properties and 1 residence an unwise 
use of taxpayer money. Specifically, the proposed action would provide access for 15 property 
owners, with only one being a year-round resident; clearly the money intended for this project 
could be put to better use helping those not merely being inconvenienced.

The EA points out (p. 17) that Snohomish County would be required to fund maintenance of the 
road once access is restored. The economic implications of this must be considered, including 
the high likelihood that this road will wash out again in the future.

In summary, we urge you to consider at least one other action alternative: Purchasing
properties accessed by the Monte Cristo Grade Rd. The economic impacts of this option must 
be examined, in light of the probable future washouts necessitating further maintenance costs. 
The final EA must also include a thorough evaluation of the project's effects on endangered 
species including marbled murrelets, northern spotted owls, and salmon. It must also describe 
how these effects would be effectively mitigated, if in fact they can be.

Sincerely,

Katherine Johnson and Kathryn Piland
Forest Committee

Please address correspondence to:
Kathryn Piland
21431 62nd St NE
Granite Falls, WA 98252

Response to comment letter from Pilchuck Audubon Society
Monte Cristo Grade Road Bridge Replacement

Number
Issue
Response
# 1
Has any research been done to 
determine whether there are wildlife 
corridors in the path of the bridge? Will 
the bridge be a barrier for wildlife?
Yes, a Technical Memorandum was prepared to 
evaluate the effects of the project on the wildlife 
resources. This memorandum is attached as 
Appendix D to the Environmental Assessment.

Deer and other mammals likely move up and down 
the river banks while foraging or accessing water. 
Construction of the bridge will not change the 
contours or obstruct the existing bank. The replaced 
piers will be in the same location and approximately 
the same size as the existing piers. The existing piers 
are outside of the Ordinary High Water Mark 
(OHWM). The proposed bridge deck will be more 
than 21 feet above the beach and is not likely to 
impede use of the beach or bank by wildlife.

# 2
The proposed open steel grate bridge 
design will increase the runoff of 
pollutants into the river. How will this 
be mitigated? 

What type of low impact stormwater 
treatment will be constructed for the 
new paved bridge approaches? It is 
imperative to protect the water quality 
of the river wildlife, particularly ESA 
listed fish species.
The bridge design has been changed from a steel 
grate to wood decking. The wood decking will be 
untreated cedar. Runoff on the bridge would not be 
collected and concentrated. Because of the low 
traffic volume, the runoff would be minor and there 
not be a significant increase in pollutants. 
Stormwater is addressed in more detail in the 
Biological Assessment.

Low impact stormwater treatment will be used on 
the north and south approaches to the bridge. The 
north approach drainage consists of sheet flow off 
the road. The project will establish ditches that will 
outlet to rock pads at the top of the slope and then 
sheet flow through the vegetated slope. 

On the south side of the river the existing road 
drainage goes to a ditch on the south side of the 
road or sheet flows off the road into the vegetation 
on the north side of the road. There will be no 
changes to the drainage pattern on the south side of 
the river

There will be a net decrease of 8,000 square feet of 
impervious surface as part of the mitigation for this 
project. Approximately 8,500 square feet of the 
decommissioned portion of Monte Cristo Grade 
Road will be removed and planted with riparian 
vegetation. The riparian buffer created will result in 
greater surface water infiltration, buffer, and 
maintenance of base flow 
#3
The EA states that work will be 
completed during "the dry season" (p. 
24). But according to the table on p.36, 
ESA listed fish will be spawning in the 
river during the dry months of August 
and September! These conflicting 
timetables may make it impossible to 
complete the construction. There is not 
enough time to construct the bridge 
during the dry season.
Although it is expected that small numbers of adult 
Chinook salmon may migrate upstream through the 
project area to upstream spawning areas late in the 
construction period (September and October), no 
recent spawning has been recorded near the action 
area. In the last 2 years there have been no redds 
recorded between Robe Canyon and Big Four, a 
reach that is surveyed 1 to 3 times each summer. In 
years where spawning has occurred in the area, the 
closest redds were about 2 miles upstream of the 
project site, and more typically at least 6 miles 
upstream.
Although some Chinook salmon could occur in the 
area during the overall construction period, no in-
water work would occur during this period.  
Furthermore, the vast majority (about 97 percent) of 
Chinook salmon juveniles in the Stillaguamish River 
basin are reported to out migrate from March 
through June as age-0 juveniles. Therefore, very few 
juveniles would likely be present during the 
construction period, which will occur from July to 
October.
Work occurring on the gravel bar during the dry 
season will adhere to the in-water work window as 
specified by Washington Department of Fish and 
Wildlife (WDFW) in the Hydraulic Permit 
Approval (HPA) (anticipated to be July 15 to 
August 15). 
#4
We have two concerns regarding the tree 
removal, as described on p. 29, section 
3.4.3, which states, "The primary 
wildlife impact would occur from the 
removal of trees to construct the bridge." 
First, in terms of displacing potential 
bird nesting habitat, the EA notes "the 
bridge site is adjacent to large tracts of 
densely forested USFS which provides 
alternative habitat." The problem with 
this reasoning is that those adjacent 
habitats are already occupied. Any 
displaced nesting, migratory and 
resident birds have nowhere to go.

The bridge replacement has been designed to 
minimize the removal of trees. Construction 
sequencing has been modified during the design 
process to greatly reduce the number of trees to be 
removed. The design presented in the EA showed a 
temporary construction road down to the beach for 
the crane. An alternate design has since been 
developed to use the existing, already-cleared right-
of-way as the crane access instead of clearing 
vegetation for a new access road. 

On the south side of the bridge the trees to be 
removed are primarily young alders and conifers 
that have self-seeded in the unused road right-of-
way and in and around the old concrete abutments. 
There will be minor loss of habitat with the removal 
of these trees. Mitigation will be provided for these 
impacts (See answer #2 above). 
#5
Second, we are concerned about the tree 
removal proposed in Figure 4 (Proposed 
Bridge Location) on pg 11. This will 
likely result in what is known as an 
"edge effect" in the landscape, which 
can result in predation of eggs and 
young in the trees left standing. The 
proposed removal will tend to increase 
the edge effect, with subsequent adverse 
impacts to wildlife.

Smaller trees will be taken along the already 
existing edge created by the road. Over the long 
term, the project will reduce edge effect compared 
to the baseline because of the size, shape, and 
location of the mitigation area compared to the 
proposed clearing area. 

The mitigation proposed will decommission 8,500 
square feet of the Monte Cristo Grade Road. 
Approximately 280 linear feet of existing edge will 
be planted with native trees and shrubs. Over time 
this mitigation will provide cover for a variety of 
species.

Plantings will be monitored and maintained by the 
County to ensure successful establishment of a 
native vegetation community.

#6
Does the project conform to all 
Migratory Bird Treaty Act protections? 
Will trees be removed during nesting 
season? If so, this would obviously 
destroy nests as the trees are removed. 
Contrary to the assertion on p.19 of the 
EA, this would indeed harm migratory 
birds.

A biological evaluation was conducted to examine 
the effects on wildlife of this project including 
Migratory Birds (see Appendix D: Technical 
Memorandum). Some small diameter alders and firs 
trees will be removed where neotropical birds may 
nest and forage. All project impacts will be limited 
to a small area and are expected to occur late in the 
nesting season, when the young are likely to have 
fledged. Therefore, the project is expected to have 
no impact on neotropical migratory birds.
The construction sequencing has been modified to 
minimize the number of trees to be removed. 
Mitigation for removal of the trees includes 
replanting approximately 8,500 square feet of the 
Monte Cristo Grade Road. 
#7

Furthermore, marbled murrelet nesting 
would be disturbed by the proposed 
action, and must be protected by 
appropriate work windows. 

If the trees to be removed are suitable 
marbled murrelet nest trees, their 
removal would be prohibited. The EA 
states (p. 41) that suitable marbled 
murrelet nesting habitat does exist 
within 200 feet of the proposed project 
area. Any birds using these trees would 
definitely be disturbed by the noise of 
construction. Bald eagles would also be 
disturbed by the noise.

None of the trees to be removed are suitable 
marbled murrelet nest trees. The nearest suitable 
habitat tree is approximately 200 feet south of the 
south bridge abutment. Construction will take place 
at a distance which noise will not disturb murrelets. 
When construction is scheduled to be closer, work 
will adhere to the work window. 

The early nesting season for murrelets is between 
April 1 and August 5. Given the relatively small 
number of murrelets present in Washington relative 
to available suitable habitat, it is far more likely that 
murrelets will select higher quality nesting habitat 
(with larger nest platforms and fewer predators) in 
adjacent areas than exists in the action area.  

It is reasonably likely that murrelets nesting outside 
the action area will regularly migrate through the 
action area while flying to and from their nests.
Pile driving between April 1 and August 5 generally 
requires a distance of greater than 180 feet from 
suitable habitat in order avoid adverse affects to 
marbled murrelets (USFWS 2003), (Table 4). Pile 
driving will take place on the north side of the river 
at almost twice the prescribed distance from 
potential suitable habitat (approximately 350 feet). 

Project activities using heavy equipment and 
motorized tools require a distance of greater than 
105 feet. Work on the south side of the river will 
not take place until the bridge is in place; this will 
likely occur after August 15th, which will be outside 
of the murrelet early breeding season. Any work on 
the south side will be approximately 200 feet from 
potential suitable habitat. Work occurring during 
the breeding season will be 350 feet away. The 
effects of noise will be discountable due to the low 
probability of murrelet nesting in the action area 
during construction (see 5.1.2).  If murrelet nesting 
does occur within the action area during 
construction, effects from noise would be 
insignificant due to the combination of distance and 
timing.

Compared to pre-flood traffic volumes, there will 
be no substantial increase to traffic volumes 
resulting from the bridge replacement; therefore a 
long-term increase in disturbance to marbled 
murrelets is not expected.  

#8
We are concerned about the possibility 
of fresh concrete spills into the river 
during construction, especially given the 
plan to hoist buckets of it across the 
river. The pressure washing of the old 
bridge abutments proposed could result 
in concrete dust polluting the river as 
well.

Approximately 6.5 cubic yards of concrete will be 
required for expansion of the south abutment. Once 
the concrete forms are constructed around the 
existing abutment, the crane will transfer wet 
concrete over the river from the gravel bar 
(approximately 80 feet) to the south abutment. A 
tarp will be hung under the bucket and the outside 
of the bucket will be cleaned off prior to each load, 
to prevent any concrete from dropping into the 
river. It is anticipated that only a few loads will be 
required. Concrete forms will be removed after and 
disposed after concrete has cured.

The south abutment has been scraped by hand to 
remove most of the dirt and moss. The concrete 
appears to be sound. The abutment is approximately 
10 feet above and 10 feet landward of the OHWM. 
Measures will be taken to prevent debris from 
entering the river if additional cleaning is required.

#9
We wish to correct the statement on p. 
18 that "NEPA suggests [emphasis 
added] including analysis of a 'No 
Action Alternative'..." In fact, this 
analysis is required by NEPA, and must 
be rigorous and thorough. 

Furthermore, NEPA also requires that a 
full range of alternatives be examined. 
The EA evaluates only a single action 
alternative and the requisite 'No Action" 
alternative. At the least, an alternative to 
purchase the affected properties should 
also be evaluated.

Thank you for the correction.

The draft EA completed in 2005 examined three 
options plus a no-action alternative for restoring 
access to the road. Three additional options were 
also considered but eliminated prior to writing the 
draft EA. The bridge option is in addition to these 
earlier analyzed options.

In 2007 all of the affected property owners were 
presented with the option of forming of a Road 
Improvement District or closing the road 
permanently. Sixty seven percent of the affected 
property owners have opted to form an RID to 
contribute a share of the replacement bridge costs 
based on the assessed value of their property and 
cost of the project.

#10
In light of the Midwest's recent floods 
and, in some cases, entire towns of 
displaced Americans, we consider the 
construction of a bridge for 24 
recreational properties and 1 residence 
an unwise use of taxpayer money. 
Specifically, the proposed action would 
provide access for 15 property owners, 
with only one being a year-round 
resident; clearly the money intended for 
this project could be put to better use 
helping those not merely being 
inconvenienced.

Your comment is noted. Snohomish County has 
spent several years evaluating a number of different 
alternatives to reestablish access to this area. Due to 
the terrain and location of the river, the options are 
limited. The bridge is being proposed as the best 
option with the least environmental impacts and 
cost. All potential alternatives have been discussed 
with the County Council and County Executive, 
including the alternative of closing the road, and it 
was agreed to re-establish access to this area.

#11
The EA points out (p. 17) that 
Snohomish County would be required to 
fund maintenance of the road once 
access is restored. The economic 
implications of this must be considered, 
including the high likelihood that this 
road will wash out again in the future.
Your comment is noted. The road will remain an 
unpaved County road which requires minimal 
annual maintenance. 

A hydraulic analysis of the river was conducted as 
part of the studies for this project. The bridge 
option was selected because this site has been 
relatively stable compared with the area upstream 
that washed out in 2003. 

File Code:
1950, 2730
Date:
July 24, 2008

Mary Auld
Snohomish County Public Works
3000 Rockefeller, M/S 607
Everett, WA 98201

Re: Draft Environmental Assessment for proposed Monte Cristo Grade Road Bridge 
Dear Ms. Auld,
Thank you for the opportunity to comment on the draft Environmental Assessment (EA) for this 
proposed County project.  Constructing a bridge to restore public access to the recreational lots in 
the Verlot vicinity on the south side of the South Fork Stillaguamish River appears to be the least 
impacting and more lasting solution than attempting to rebuild or relocate the washed-out section 
of the Monte Cristo Grade road.  
Judging from the map provided on page 11 of the EA, it appears that the middle section of the 
bridge would be constructed on and over National Forest System land outside of existing rights 
of way to Snohomish County for the Monte Cristo Grade Road and 342nd Drive NE.  Unless 
Snohomish County has an easement to the area once occupied by the former 1970s bridge 
(referenced on page 15 of the EA), I am requesting that Snohomish County obtain an easement 
for the bridge section outside of the rights-of-way.  The county should also enter into a Consent 
Agreement with the Forest Service for the sections of bridge that would occupy NFS land within 
existing rights-of-way, as it involves new construction.  As a result, the EA should address 
project effects to resources pertinent to NFS land management as directed by the Mt. Baker-
Snoqualmie National Forest Land and Resource management Plan, as Amended. Our staff and I 
have reviewed the EA and bridge plans, and our comments follow.
The Biological Assessment (BA) that Snohomish County prepared to address project effects to 
federally-listed threatened and endangered species under Section 7 of the Endangered Species 
Act (ESA) should include a cumulative effects analysis of other past, present and proposed 
bridge and bank stabilization projects along the South Fork Stillaguamish River.
The EA should address project effects on species of interest that include Forest Plan 
Management Indicator species and neotropical migratory birds, as well as Forest Service 
Regional Forester Sensitive species (fish, and wildlife) and Special Status Species.  A complete 
list is posted on Region Sixs website, (www.fs.fed.us/r6/sfpnw/issssp/agency-policy) but 
includes:
Sensitive fish: Puget Sound/Straight of Georgia coho salmon, native Puget Sound Lake and 
Sensitive wildlife: such as peregrine falcon, wolverine, and Johnsons hairsteak.
Management Indicator wildlife species (Forest Plan): such as pine marten, and woodpeckers 
(including pileated woodpecker).
Special Status Species: http://www.fs.fed.us/r6/sfpnw/issssp/agency-policy.
The EA should include a discussion of Forest Plan management direction for the South Fork 
Stillaguamish Recommended Scenic River, and project effects on the Rivers free-flowing 
characteristics and Outstandingly Remarkable Values (see attached documentation provided 
by our Wild & Scenic River Specialist).  
To address aesthetic values and meet visual quality objectives along this river, we suggest that 
the County use a weathering steel for the trusses, as appears to be implied by the photograph 
on page 37 of the EA.
Our botanist determined that a survey for Forest Service Sensitive and Other Rare and 
Uncommon plant species would not be required, as the north bank of the river is an active flood 
plain, the forested south bank has been occupied by the road, and there was once a bridge in that 
location before.
In addition to needing an easement for portions of the proposed Verlot bridge, I am aware of 
two other locations where the County should establish legal occupancy (easements) for existing 
facilities on NFS land: for a portion of the Whitton Avenue bridge in Silverton, and a portion of 
a public road that leads into the Verlot Riverfront Tracts (VRT) subdivision from the Monte 
Cristo Grade Road.  Eric Ozog provided Susan Fenner of County staff an encroachment survey, 
drawings and past correspondence regarding the Silverton bridge and VRT access road.  As 
easements are needed for all three facilities, this presents an opportunity to combine the grant 
process into one effort, for efficiency and cost savings.  Under our NEPA regulations, we have 
authority to Categorically Exclude from EA documentation the granting of these easements by 
using a NEPA Checklist, because the Silverton bridge and VRT access road are existing 
facilities, and we would concur with your EA for the Verlot bridge if it addresses Forest Service 
resource issues.  Also, Our Forest surveyor and crew has surveyed the portion of the Silverton 
bridge and Verlot access road that occupies NFS land, and would be happy to provide that data 
for the County to prepare plats.  The construction plans for the Verlot bridge which Susan Fenner 
provided would be adequate for that easement plat, if the National Forest boundary and existing 
rights-of-way lines for 342nd Drive NE and Monte Cristo Grade Road are shown.  
A preliminary estimate of the cost to process the three easements would be in the range of $6,000 
to $7,000, including resource staff time for the NEPA Checklist, public scoping, plat review, and 
preparation of the easement documents.  If Snohomish County is agreeable to covering this cost, 
I will determine if we can schedule this project for our Fiscal Year 2009, and send you a 
proposed Cost Recovery Agreement and cost estimate to complete this work.  
Sincerely,

/S/  PHYLLIS REED (ACTING FOR )

PETER R. FORBES
District Ranger

Ccs: 	Susan Fenner, Snohomish County
      Deanna Clark-Willingham, Snohomish County
Attch.

Response to comment letter from U. S. Forest Service
Monte Cristo Grade Road Bridge Replacement
Number
Issue
Response
#1
Judging from the map provided on page 
11 of the EA, it appears that the middle 
section of the bridge would be 
constructed on and over National Forest 
System land outside of existing rights of 
way to Snohomish County for the 
Monte Cristo Grade Road and 342nd 
Drive NE. Unless Snohomish County 
has an easement to the area once 
occupied by the former 1970s bridge 
(referenced on page 15 of the EA), I am 
requesting that Snohomish County 
obtain an easement for the bridge 
section outside of the rights-of-way.
The County will obtain the necessary easements 
from the Forest Service for this project.

#2
The county should also enter into a 
Consent Agreement with the Forest 
Service for the sections of bridge that 
would occupy NFS land within existing 
rights-of-way, as it involves new 
construction.  
The County will enter into a Consent Agreement 
with the Forest Service for this project.

#3
The Biological Assessment (BA) that 
Snohomish County prepared to address 
project effects to federally-listed 
threatened and endangered species 
under Section 7 of the Endangered 
Species Act (ESA) should include a 
cumulative effects analysis of other past, 
present and proposed bridge and bank 
stabilization projects along the South 
Fork Stillaguamish River.
Cumulative Effects of the project were considered 
in Appendix C of the Biological Assessment (BA) 
and is available on request. 

Snohomish County is planning another project 
within the vicinity of the proposed Monte Cristo 
Grade Road Bridge. Bridge #538 (commonly called 
Blue Bridge) is approximately  mile upstream on 
the Mountain Loop Highway and crosses over the 
South Fork Stillaguamish River. Snohomish County 
proposes to complete a bank stabilization project to 
protect Blue Bridge. This project is proposed for 
2009 or 2010.

The left bank of the Stillaguamish River, 
immediately upstream from the Blue Bridge is 
comprised of fine sand and silt that eroded during a 
2006 flood. Continuing erosion threatens the piers 
and road approach on the eastern end of the bridge. 
Snohomish County proposes to construct a log crib 
wall combined with bioengineering and limited rock 
riprap to prevent additional loss of the riverbank.  

A Biological Assessment for the Blue Bridge 
project is being prepared and is expected to be 
issued Fall/Winter 2008-2009. This project is not 
expected to affect the proposed Monte Cristo 
Grade Road Bridge.

#4
The EA should address project effects 
on species of interest that include Forest 
Plan Management Indicator species and 
neotropical migratory birds, as well as 
Forest Service Regional Forester 
Sensitive species (fish, and wildlife) and 
Special Status Species.
Additional studies were conducted to analyze 
impacts to wildlife species included in the Mt. 
Baker-Snoqualmie National Forest Land and 
Resource Management Plan. A Biological 
Assessment was also completed to address species 
protected by the Endangered Species Act. See 
Appendix D.

#5
The EA should include a discussion of 
Forest Plan management direction for 
the South Fork Stillaguamish 
Recommended Scenic River, and project 
effects on the Rivers free-flowing 
characteristics and Outstandingly 
Remarkable Values (see attached 
documentation provided by our Wild & 
Scenic River Specialist).  
Information concerning the South Fork 
Stillaguamish Recommended Scenic River has been 
incorporated into the final EA.

#6
To address aesthetic values and meet 
visual quality objectives along this river, 
we suggest that the County use a 
weathering steel for the trusses, as 
appears to be implied by the photograph 
on page 37 of the EA.
A weathering steel truss is planned for the bridge.

# 7
Our botanist determined that a survey 
for Forest Service Sensitive and Other 
Rare and Uncommon plant species 
would not be required, as the north bank 
of the river is an active flood plain, the 
forested south bank has been occupied 
by the road, and there was once a bridge 
in that location before.
Thank you for your determination.

#8
In addition to needing an easement for 
portions of the proposed Verlot bridge, I 
am aware of two other locations where 
the County should establish legal 
occupancy (easements) for existing 
facilities on NFS land.
Easements for these two other location will be 
prepared separately from the easements needed for 
the Monte Cristo Grade Road Bridge.

Sir,  thank you for your comments; I will note them for the record and take them under consideration.  

Mark
 
From: Mike McGivern [mailto:mariners.fan2@comcast.net]  
Sent: Sunday, June 29, 2008 11:37 AM 
To: Eberlein, Mark 
Subject: Monte Cristo Grade Road Bridge

Dear Mark,

We would like to formally make a recommendation to consider Alternative B  No Action Alternative as 
noted in section 2.1.2 of the Monte Cristo Grade Road Bridge Draft Environmental Assessment, FEMA -
1499-DR-WA (Public Assistance) June 2008.

Our family owns a cabin on 102nd St NE, 5 properties west of the proposed bridge on 342nd Dr NE. We 
do not think the 1.5 to 2 million dollars use of taxpayer funds is justified to provide access to 1.35 miles 
of dead end gravel road access to 24 recreational properties and 1 residence. 

Monte Cristo Grade Road is visible directly across the South Fork of the Stillaguamish River from our 
property. Most of the usage of the road, in our opinion, comes from people looking for camping spots, 
of which there are none, from partying teenagers in caravans, and from people driving around exploring. 
There is a considerable amount of traffic in the summer months, much more than you would expect for 
24 recreational properties and 1 residence. Because this is a gravel road with no signage, its not 
uncommon to have vehicles traveling at higher than safe rates of speed kicking up dust that migrates 
across the river to our property and others around us. The bridge will be within direct sight view of our 
cabin and property. There will be a considerable noise generated whenever the bridge is crossed by a 
vehicle because of the planned decking design of open steel grate. The noise generated by a vehicle 
crossing would be substantial, and in our opinion, degrade the serenity or our mountain retreat. The 
gravel road is another noise generator. We have thoroughly enjoyed having only the residents truck as 
the sole vehicle on the road since the washout.

As you can tell, we are biased against the bridge because it directly affects the enjoyment of our 
mountain retreat for many reasons. We also fear a decrease in our property value because of the 
disturbance and visibility issues.

Thank you for consideration of our recommendation for Alternative B  No Action.

Mike and Cynthia McGivern
11001 NE 65th St 
Kirkland Wa. 98033
 
CC: Maria Cantwell, Patty Murray

Response to comment letter from Mike and Cynthia McGirvin
Monte Cristo Grade Road Bridge Replacement

Number
Issue
Response
#1
We would like to formally make a 
recommendation to consider Alternative 
B  No Action Alternative as noted in 
section 2.1.2 of the Monte Cristo Grade 
Road Bridge Draft Environmental 
Assessment, FEMA -1499-DR-WA 
(Public Assistance) June 2008.

Our family owns a cabin on 102nd St 
NE, 5 properties west of the proposed 
bridge on 342 nd Dr NE. We do not think 
the 1.5 to 2 million dollars use of 
taxpayer funds is justified to provide 
access to 1.35 miles of dead end gravel 
road access to 24 recreational properties 
and 1 residence. 

Thank you for your letter and your comments. 

In 2007 all of the affected property owners were 
presented with the option of forming of a Road 
Improvement District (RID) or closing the road 
permanently.  67% of the affected property owners 
have opted to form an RID to contribute a share of 
the replacement bridge costs based on the assessed 
value of their property and cost of the project. 
Snohomish County and Federal Emergency 
Management Agency (FEMA) will share the 
remaining costs.

#2
Because this is a gravel road with no 
signage, its not uncommon to have 
vehicles traveling at higher than safe 
rates of speed kicking up dust that 
migrates across the river to our property 
and others around us. 

Signage will be installed when the bridge is 
complete. 
#3
There will be a considerable noise 
generated whenever the bridge is 
crossed by a vehicle because of the 
planned decking design of open steel 
grate. The noise generated by a vehicle 
crossing would be substantial, and in our 
opinion, degrade the serenity or our 
mountain retreat. 

The bridge design has been modified from the 
originally proposed open steel grate to a wood deck 
which may help to reduce the noise levels. 

  The biological similarities of bull trout and Dolly Varden make them virtually indistinguishable in the field. As a 
result, they are often referred to collectively as native char. In fact, WDFW has combined information on their 
status and distribution into a common inventory (WDFW 1998).
What table is this? I couldnt find a table
 
 
 
 
75
Monte Cristo Grade Road Bridge Environmental Assessment 	                                                                     January 2008
Page 41
TABLE OF CONTENTS (CONTINUED)

TABLE OF CONTENTS (CONTINUED)

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
ii
Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
iii

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	

i
Biological Evaluation 
Marten Creek Bridge Replacement
Snohomish County Public Works
ACRONYMS (CONTINUED)
Biological Evaluation 
Marten Creek Bridge Replacement 
Snohomish County Public Works
ACRONYMS (CONTINUED)

1-4	April 2007 ? 553-1513-085 (09/02)
April 2007 | 553-1513-085 (09/02)	ix

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
iv

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
1-4
Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
14-4

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
15-1
Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
16-1

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
17-1

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
18-1

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
A-2

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
	C-4
Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
C-4

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
D-2
Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
D-4

Monte Cristo Grade Bridge
Biological Assessment	May 14, 2008	
D-1
Biological Evaluation 
Marten Creek Bridge Replacement
Snohomish County Public Works

8174	April 2007? 553-1513-085 (09/02)