Craggy Vegetation Management Project Scoping Outcome Summary

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Craggy Vegetation Management Project

Scoping Outcome Summary

Salmon/Scott River Ranger District

Klamath National Forest

Siskiyou County, California

The Klamath National Forest proposes the Craggy Vegetation Management Project to improve 

fire resiliency on National Forest System lands by reducing fuels and stand density in strategic 

areas and within the wildland-urban interface (WUI). The project would treat about 10,650 acres 

within the 29,500-acre project boundary. WUI amounts to about 50 percent of the project area 

(14,550 acres) and proposed treatments in WUI amount to about 4,120 acres. 

The Craggy Vegetation Management Project is located one mile west of Yreka and ten miles 

north of Fort Jones, California in Siskiyou County. It is within the Clear Creek, Upper Humbug 

Creek, Lower Humbug Creek, Middle Fork Humbug Creek, Greenhorn Creek, Yreka City-Yreka 

Creek, Rocky Gulch-Yreka Creek and Long Gulch 7th field watersheds. The project is located in 

Township (T) 46 North (N), Range (R) 8 West (W), Sections 13, 23-28, and 32-35; T45N R8W 

Sections 1-17 and 21-24; T46N R7W, Sections 16-18, 20, 22, 28, 30, and 32-34; and T45N 

R7W, Sections 4-6, 8, 9, and 17-20 (Mt. Diablo Meridian). See vicinity and treatment maps in 

Appendix A.

Public Involvement and Scoping

Planning for this project was initiated in 2010. The project was first published to the Schedule of 

Proposed Actions and the Forest website on April 1, 2010. 

Public involvement with the Yreka Area Fire Safe Council and Klamath Siskiyou Wildlands 

Center began in 2012. This outreach effort led to public field trips in 2012 and 2013. Comments 

were sought from a number of other organizations and Indian tribes; those providing input during 

this process included the City of Yreka, California Department of Forestry and Fire Protection 

(CAL FIRE), U.S. Fish and Wildlife Service, Shasta Nation, California Deer Association, and 

the Office of State Senator for the area including the project (formerly Douglas LaMalfa). 

Scoping was originally planned for spring 2014 but was delayed due to agency personnel 

changes and the reprioritization of resources in response to large-scale wildfires in 2013 and 

2014. On December 30, 2015, a scoping letter was sent to interested and affected parties, 

including the EPA, Quartz Valley Indian Reservation, Karuk Tribe, Shasta Indian Nation, Shasta 

Nation, adjacent property owners, and interested groups and individuals. The list of addresses of 

landowners was sourced from the Siskiyou County Assessor’s Office tax-payer records. On 

January 4, 2016, a legal notice of scoping was published in the Siskiyou Daily News, the 

newspaper of record for the project; this notice began the formal scoping process that guides the 

development of the environmental impact statement (EIS). A notice of intent to prepare an 

environmental impact statement for the project was published in the Federal Register, and project 

information including the project proposal and maps were made available on the project website 

at: http://www.fs.usda.gov/project/?project=31770 on the same date. See Appendix B for the 

project proposal as originally scoped.

The Forest and Yreka Area Fire Safe Council co-sponsored an open house on January 13, 2016.

This open house was attended by representatives from City of Yreka, CAL FIRE, Northern 

California Resource Center, Siskiyou Gardens, Parks and Greenway Association, and 
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landowners within and adjacent to the project area as well as other private individuals. A total of 

17 participants signed the attendance sheet. CAL FIRE representatives and private individuals 

were especially interested in fuels reduction treatments adjacent to private lands and proposed 

additional areas for treatment. Subsequently on March 1, 2016, the project team leader and 

fire/fuels specialist met with CAL FIRE to further discuss the agency’s interests and potential 

modification of the proposed action. This led to the development of Alternative B, which 

includes additional fuels reduction treatments.

The interdisciplinary team met and reviewed the scoping responses on March 9, 2016. This 

meeting included representatives from National Marine Fisheries Service and U.S. Fish and

Wildlife Service. Ideas presented at the meeting led to clarification of the proposed action and 

were considered in the development of alternatives. Project design features were also updated 

following scoping (see Appendix C). The comments received as a result of public scoping are 

summarized in Appendix D of this scoping outcome summary.

Issues

The Forest received 122 comments by means of 12 letters or phone calls and one public open 

house. During scoping, 58 issues or concerns were identified, and two were determined to be 

relevant to alternative development or modification. 

Table 1. Relevant issues identified for this project, and associated indicators and alternatives

Relevant Issue #1: There is a debate about the effectiveness of the project for adequately 

protecting private landowners and private property.

Indicators: Potential flame length in wildland-urban interface defense zones; acres treated adjacent to private 

land.

Alternative: Additional hazardous fuel reduction activities adjacent to private lands were added in Alternatives 3 

and B.

Relevant Issue #2: There is a debate about the environmental effects of project activities such 

as temporary road construction, timber haul, landing establishment, and yarding activities on 

soils and aquatic resources. 

Indicators: Cumulative watershed effects results (equivalent roaded acres, landslide potential, and soil erosion); 

miles of temporary roads; miles of road (all types) used for forest product removal; number of low-water stream 

crossings; number of new landings.

Alternative: Alternative 3 has a decreased level of thinning with removal (with a greater thinning without removal 

component), as well as a decreased amount of miles used of open roads, existing temporary roads, new 

temporary roads, and low-water stream crossings. 

Action Alternatives 

1. Alternative 1

The analysis of this alternative reflects the environmental effects of not implementing any 

treatments in this project. The environmental condition described in the analysis of this 

alternative will reflect the result of natural processes and the cumulative environmental effects of 

past and on-going activities.

2. Alternative 2

This alternative is the proposed action as detailed in the project proposal for scoping (see 

Appendix B). This alternative reflects the level of fuel break, underburn, and mastication 
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treatments as recommended by the project fuels specialist. Thinning without removal has been 

proposed for young planted and naturally-regenerated stands with no record of recent treatment. 

Units for thinning with forest product removal were identified and recommended by a logging 

system specialist. Road sediment legacy source sites proposed for treatment are limited to roads 

to be used for access in implementation. An Alternative 2 treatment map is provided in Appendix 

A. 

3. Alternative 3

This alternative was developed in response to concerns related to hazardous fuels reduction 

adjacent to private lands; sediment displacement resulting from log-haul, road construction, and 

yarding activities; and the resulting impact on watershed condition from implementing the 

proposed action (see comments 6-3, 6-21, and 6-37 in Appendix D). Treatments proposed in 

Alternative 3 are identical to Alternative 2 with the exception of the differences as follows:

• Hazardous fuel reduction treatments adjacent to private lands (fuel breaks and 

underburning) have been modified to increase protection in response to comments 

received from private individuals and fire protection agency recommendations.

This includes changing two units from mastication to fuel breaks and increasing 

fuel breaks adjacent to private property to up to 300 feet wide.

• High-risk legacy road sediment source sites would be treated based on 

prioritization for treatment of the sites that may reduce the overall potential 

hazard of sediment delivery from roads to waterways. 

• Change of some units from thinning with forest product removal to thinning 

without removal. This change reduces the number of low-water stream crossings

and miles of road to be used for transportation of forest products.

• Modification of some treatment unit boundaries. This change is in response to 

conversations with Fish and Wildlife Service representatives. Some unit 

boundaries have been modified to decrease impacts to northern spotted owl 

foraging habitat from proposed treatment activities. This affects both proposed 

thinning with forest product removal and mastication units.

An Alternative 3 treatment map is included in Appendix A.

Table 2. Comparison of proposed treatment differences between alternatives considered in detail

Treatments Alternative 1 Alternative 2 Alternative 3

Fuel Breaks 0 1,400 acres 2,190 acres

Prescribed Burning 0 4,160 acres 4,390 acres

Mastication 0 860 acres 770 acres

Thinning Without Forest Product 

Removal 0 1,350 acres 1,650 acres

Thinning With Forest Product 

Removal 0 2,880 acres 2,310 acres

Roads Used for Forest Product 

Removal 0 90 miles 80 miles
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Treatments Alternative 1 Alternative 2 Alternative 3

Temporary Roads/Existing 

Roadbed 0 12 miles 11 miles

New Temporary Roads 0 2 miles 1 mile

Existing Low Water Crossings 

Used in Project 0 2 crossings 1 crossing

Legacy Road Sediment Source 

Site Treatment 0

20 high priority sites

48 low priority sites

30 high priority sites

Project design features have been evaluated for their applicability to each alternative. The 

updated project design features table is included in Appendix C.

Alternatives Considered but Eliminated from Detailed Study

Alternative A

This is the project as initially prepared for scoping in 2014. It included fewer acres of hazardous 

fuels reduction activities than what is now proposed in Alternative 2, such as for prescribed fire 

underburn and fuel break treatments. Legacy road sediment site treatment was not included in 

the initial proposal. The level of proposed treatments are listed below:

• Fuel break - 404 acres 

• Prescribed fire underburn - 3,466 acres 

• Mastication - 271 acres 

• Thinning without forest product removal- 431 acres

• Thinning with forest product removal - 2,402 acres 

• Roads used for forest product removal - 85 miles

• Temporary road on existing roadbed - 12.7 miles

• New temporary road - 0.5 miles

Ongoing consultation with Fish and Wildlife Service and CAL FIRE in addition to an internal 

reassessment of the project determined that the lower level of treatments in the wildland-urban 

interface proposed in this alternative would not have been sufficient to meet the desired 

condition for hazardous fuel reduction and forest health. Because it does not meet the purpose 

and need of the project, it has therefore been excluded from more detailed study (see map, 

Appendix A).

Alternative B

This alternative was developed in response to Relevant Issue 1 to address the debate about 

effectiveness of the project for protecting private landowners and private property. Treatments 

proposed in Alternative B are identical to Alternative 2 except fuel break treatment is increased

to 3,223 acres. This change resulted from interaction with CAL FIRE representatives at the 

scoping period open house and a follow-up meeting in which they recommended additional 

treatment of a 300-foot buffer adjacent to all private land in the project area. This area would be 

treated as a fuel break to reduce hazardous fuels. Including all of this adjacent private land buffer

was determined to be unfeasible because of the location of proposed fuel breaks in riparian 
Craggy Vegetation Management Project Scoping Outcome Summary 

reserves and/or mid-slope positions unconducive to wildfire suppression. Many private parcels of 

land within the project area also do not have occupied structures or residences. Fuel break 

treatment adjacent to these non-occupied parcels would not contribute to the safety of private 

landowners who do not reside on their property. For these reasons, this alternative has been 

eliminated from more detailed study although additional fuels treatment adjacent to private 

property in appropriate areas has been added to Alternative 3 (see map, Appendix A). 

Alternative C 

This alternative was proposed by comment letter 11. In that letter, the commenter stated that the 

project should treat all ponderosa pine plantations because they are "at risk to bark beetle caused 

mortality which will add to fuel loading over time" (Comment 11-5). In response to the 

comment, we developed an alternative consisting of treatment of all planted areas within the 

project boundary; this would total about 6,311 acres of treatments. Spatial records are incomplete 

as to the original species or range of species planted and field survey has determined that most 

planted areas are stocked with ponderosa pine, so all areas recorded as planted were included in 

this alternative (see map, Appendix A). 

Records indicate some of these planted areas have been treated within the past 15 years and are 

not likely susceptible to insect-caused mortality. Other planted areas have been determined to be 

unfeasible for treatment because of closure of roads formerly used to access these plantations. 

Finally, some planted areas are located on lower slope positions on the landscape; hazardous 

fuels reduction treatment in lower slope positions would not significantly contribute to 

improving fire resiliency since they are not expected to bum at high severity nor would treatment 

contribute to firefighter safety. For these reasons, the project interdisciplinary team has 

determined that Alternative C does not meet the purpose and need for the project, and so will not 

be analyzed further. 

Alternatives 2 and 3 include planted areas in need of silvicultural treatment and that are 

strategically located on ridgelines, upper slope positions, and near ingress and egress routes 

where treatment would contribute to landscape resilience to fire. In total, Alternative 2 would 

treat 4, 168 acres, or 66 percent of the planted area within the project boundary; Alternative 3 

would treat 5,033 acres or 80 percent of the planted area. 

Summary 

I considered all comments received and the associated issues. I concur with the interdisciplinary 

team's recommendation of the relevant issues for this project and that the action Alternatives 2 

and 3, as well as the three alternatives considered but eliminated from detailed study, represent 

an adequat ange of alternatives. The action alternatives merit detailed analysis and will be 

compared o e no action altem Ye to determine how well they meet the purpose and need of 

the 

C. CHRISTINE FRISBEE Date 

Acting Forest Supervisor, Klamath National Forest 

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Appendix A: Vicinity and Treatment Maps For All Action 

Alternatives
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Appendix B

The Proposed Action as Scoped

Proposed Action:

The Craggy project interdisciplinary team has come up with the following proposed treatments 

to meet the purpose and need for the project. These treatments are subject to project design 

features (project design features) developed to address overall project objectives, to minimize 

resource impacts, and ensure Forest Plan compliance (see following appendix). A total of 10,700 

acres is being proposed for treatment out of the total project area of 29,500 acres. Strategic 

actions within project boundary will treat about 250 acres of the 1,190-acre defense zone and 

3,870 acres within the 12,350-acre threat zone around the community of Yreka. 

Proposed treatments in the project area:

• Fuel Breaks (1,450 acres) along strategic road systems and ridges. 

• Prescribed Burning (4,160 acres)

• Mastication (860 acres) to enhance wildlife habitat while reducing hazardous fuels.

• Thinning without Removal of Forest Products (1,350 acres)

• Thinning with Removal of Forest Products (2,880 acres)

Treatments are described in greater detail below.

Fuel Breaks (1,450 acres)

Fuel breaks (300 feet in width) will be placed along key ridges in the project area. Within these 

fuel breaks, conifers less than 10 inches diameter at breast height (DBH), will be thinned 

manually, hand-piled and burned. Areas dominated by brush will be hand-cut, piled and burned. 

Actual treatment will vary in size according to field conditions. In roadside fuel treatments, brush 

and small diameter trees (less than 10 inches DBH) within buffers (about 150 feet wide on either 

side of the road) will be manually cut, hand-piled and burned. Where equipment can remove 

trees without leaving established roadbed, some trees may be removed as biomass. Actual 

treatment may vary in size and width depending on fuel conditions. Trees less than 10 inches 

DBH will be variable density thinned to an average spacing. Areas dominated by brush will be 

hand cut, piled and burned. Hand-cut and pile fuels reduction/brush encroachment removal work

may occur through two subpopulations of Calochortus persistens as described in the project 

design features. 

Prescribed Burning (4,160 acres)

In the project area, strategic areas will be underburned in blocks according to an approved burn 

plan. Prescribed fire may be used in the MA 5 Special Habitat, Plant Management Area in 

accordance with the project design features. All implementation will be done in coordination 

with the project botanist and timed during the dormant growing season.
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Mastication (860 acres)

In the project area, about 860 acres will be masticated. Mastication will be used in areas that are 

dominated by decadent brush. Operation of mastication equipment will be subject to the project 

design features.

Thinning without Removal of Forest Products (1,350 acres)

Thin sub-merchantable trees, (conifers less than 10- inch DBH), using a variable density 

approach. Density may vary to select for the more desirable tree. Leave trees should be disease 

and damage free, have constant or increasing height growth, have a strong live crown-ratio, good 

form, color, needle complement and needle retention. To enhance species diversity there will be 

species-specific preferences for thinning in all units based on topographic location, amount of 

disease present, and desired species composition. Cut trees will be limbed and bucked with 

resulting slash scattered or hand-piled for burning.

Thinning with Removal of Forest Products (2,880 acres)

Both ground-based and skyline cable-yarding systems will be used to yard thinned trees. Trees 

will be thinned by a combination of hand- and mechanical falling using a variable-density 

thinning approach. Species preference and leave trees will vary by unit and is driven by 

topographic location, amount of disease present, current species composition, and future desired 

characteristics of the stand. Ground-based yarding is proposed for 1,730 acres of which 1,260 are 

in plantations. Skyline cable yarding is planned for 1,150 acres, of which 510 are in plantations. 

Access/Roads

No roads will be added to, or removed from, the National Forest Transportation System as part 

of this project. To reduce log skidding distances and associated impacts to soils and other 

resources, twelve miles of existing roadbeds will be used as temporary roads for short-term 

access. Two miles of new temporary road construction is proposed. All temporary roads on 

existing roadbeds and new temporary roads will be hydrologically stabilized as described in the 

project design features. Existing landings will be used to the extent possible. 

Legacy Site Restoration

Road-related sediment legacy sites in treatment units and along potential haul routes will be treated to 

minimize the risk to water quality. Based on funding and prioritization from water quality risk 

assessment, any or all of the following legacy site restoration activities may be carried out:

• Remove fill from streambanks and unstable areas.

• Construct dips at stream crossings to eliminate diversion potential

• Outslope road surface and eliminate in-board ditch or outside berms

• Seed, mulch or plant disturbed areas to control surface erosion

• Stabilize landslides. May include construction of retaining walls

• Upgrade culverts to pass 100-year peak flows

• Reduce road fill volumes at stream crossings to withstand 100-year peak flows and debris flows

• Apply rock aggregate to the road surface
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Appendix C

Updated Project Design Features

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Air Quality-1 Native surface roads will be watered to suppress dust when needed.

All Alternatives:

All thinning with 

forest product 

removal units 

Air Quality -

2

Burning will be implemented when smoke is likely to be transported away from 

sensitive locations, when possible. Forecasts of weather in the project area will 

be used to ensure favorable “within prescription” weather conditions for the 

burn and smoke transport. Contingency plans will be developed to minimize 

smoke impacts if meteorological conditions change. 

All Alternatives:

All Pile Burning 

and Underburn 

Units

Air Quality -

3 Local residents and landowners will be notified, as appropriate, prior to ignition.

All Alternatives:

All Pile Burning 

and Underburn 

Units

Air Quality -

4

Ignition will only take place on permissive burn days as determined by the 

Siskiyou County Air Pollution Control District. 

All Alternatives:

All Pile Burning 

and Underburn 

Units

Air Quality -

5

When possible, schedule burning to minimize impacts to those recreating. This 

may involve burning on low visitor use days in the spring and avoiding burning 

on high use weekends. 

All Alternatives:

All Pile Burning 

and Underburn 

Units

Botany-1

Calochortus persistens (general habitat within the management area): Within the

plant management area (MA5) ground disturbance will only occur within 

designated unit boundaries; all equipment and project related disturbance will 

not operate or occur outside those boundaries except on designated road 

systems. No new landings will be constructed within this management area.

Existing landings may need some work to be operational, and this work will be 

coordinated with the district botanist. If a landing location is infested with nonnative invasive species, the district botanist will be consulted to determine 

appropriate methods for containing and/or managing the infestation. 

All Alternatives:

All Units in MA 5

Botany-2

Calochortus persistens (actual populations within the management area): All subpopulations within the project area will be flagged with yellow and black striped 

flagging. No equipment/vehicle activity, tree skidding, or any other form of 

ground disturbance will occur within these flagged boundaries. Burn piles will 

not be constructed within flagged areas. 

All Alternatives:

All Units in MA 5

Botany-3

Two sub-populations of Calochortus persistens will be included for fuels removal 

treatment and underburn prescriptions. This work will be implemented with the 

district botanist and the following design features will be implemented: 1) 

Prescribed fire, and removal of brush and small diameter conifers within the subpopulation boundary will only occur outside of the active growing season; 2) 

Burn piles will not be constructed within the flagged population boundaries 

(delineated with yellow and black striped flagging); 3) Monitoring will occur after 

implementation and will include monitoring non-native invasive plant species. 

All Alternatives:

Selected Units in 

MA 5
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Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Botany-4

Eriogonum ursinum var. erubescens: All populations within the project area will 

be excluded from all project activities. These locations will be flagged with yellow 

and black flagging prior to project implementation.

All Alternatives:

Where applicable

Fuels-1 

A fuels assessment will be conducted on fuel breaks five to ten years after 

implementation to determine if maintenance treatments are needed to maintain 

desired conditions (flame lengths less than 4 feet). If conditions do not meet 

desired conditions, apply a fuels treatment similar to the selected alternative to 

bring fuel breaks within desired conditions.

All Alternatives:

All Fuel Break 

Units

Fuels-2

In fuel break and thinning without removal units where pile burning will occur, 

allow fire to underburn within the designated unit at low intensity if there is low 

risk of burning onto private property. Include measures in the prescribed burn 

plan to minimize the risk of fire escaping designated units.

All Alternatives:

All Thinning and 

Fuel Break Units

Fuels-3

Whole-tree yarding will be required in thinning with removal units to minimize 

activity-generated fuels within the stand. Trees will be limbed at the landings. 

Slash and tops will be piled at the landing to reduce to amount of slash left in the 

stand. Slash and top piles will either be removed for biomass or burned within 

landing areas. 

All Alternatives:

All Thinning Units

Fuels-4

All prescribed fire operations will be conducted subject to an administratively 

approved burn plan which includes the objectives of the burn, desired fire behavior 

and intensity, an emergency contingency plan and specified level of response to a fire 

escape. 

All Alternatives:

All Underburn, 

Fuel Break, and 

Thinning Units

Heritage-1 Conduct heritage resource surveys to determine presence of resources within the 

area of potential effects.

All Alternatives:

All Units

Heritage-2 All sites within the area of potential effects will be clearly delineated prior to 

implementation. This includes but is not limited to flagging site boundaries.

All Alternatives:

All Units

Heritage-3

In the event that new heritage resources are discovered during project 

implementation, the district archaeologist and/or heritage program manager 

must be notified and all activities in the vicinity (150 feet) of the resource shall 

cease until consultations are completed.

All Alternatives:

All Units

Invasive 

Species -1

Equipment and vehicles that leave established road surfaces will be cleaned of 

soil, seeds, vegetative matter, and other debris that could contain noxious weeds 

seeds or propagative material prior to entering and before leaving the project 

area. Areas appropriate for cleaning equipment prior to leaving the project area 

will be designated as appropriate. 

All Alternatives:

All Thinning with 

Removal and 

Mastication Units

Invasive 

Species -2

High priority NNIS sites will be flagged prior to project implementation with 

orange/black flagging labeled with INVASIVE SPECIES. Equipment, vehicles, and 

personnel will avoid working within these flagged high priority areas. 

Mastication, equipment piling, and burn piling will not occur within these high 

priority areas. 

All Alternatives:

All Units

Invasive 

Species -3

If potential landing sites are infested with noxious weeds, consult with the 

district botanist to determine appropriate methods for containing and/or 

managing the infestation. Methods may include blading infested soil away from 

activity zones and covering this soil; or adding a barrier to the landing so seed 

banks cannot be transported.

All Alternatives:

All Thinning with 

Removal Units

Invasive 

Species -4

Any straw or seed placed within the project area must be documented as 

California certified weed free. Other materials where State inspection protocol 

does not exist (gravel, wood chips) used as mulch in the project area should be 

inspected by a Forest Service representative to determine the potential for 

spread of noxious weeds.

All Alternatives:

All Units
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Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Invasive 

Species -5

Any facility that provides material such as rock, gravel, or boulders to be used in 

the project area should be inspected and determined to have limited potential for 

the spread of noxious weeds from stored material. Material stockpiles must be 

noxious weed free.

All Alternatives:

All Units

Recreation 

and Scenery1

Protect and maintain recreational features and recreational settings along roads, 

trails, and trailheads identified as visually sensitive.

All Alternatives:

All Units Where 

Applicable

Recreation 

and Scenery2

Repair or replace recreational signing or other facilities and trail settings if 

damaged during project implementation.

All Alternatives:

All Units Where 

Applicable

Recreation 

and Scenery3

Provide visitor information about area/road/trail closures, or other recreation 

setting changes, in news releases, on-site, and on the Forest website.

All Alternatives:

All Units Where 

Applicable

Recreation 

and Scenery4

Provide safety signing along trails, rivers, or roads or temporary road or trail 

closures in active project areas to provide for public safety.

All Alternatives:

All Units Where 

Applicable

Silviculture1Thinning treatments will be implemented according to site-specific silviculture 

prescriptions prepared by a certified silviculturist.

All Alternatives:

All Thinning Units

Silviculture2

Silvicultural prescriptions will reflect the resource and vegetation management 

objectives of the area including biological diversity, long-term site productivity, 

and forest health.

All Alternatives:

All Thinning Units

Watershed-1 Operate according to the Forest’s wet weather operation standards (USDA Forest 

Service 2002). 

All Alternatives:

All Thinning with 

Removal and 

Mastication Units

Watershed-2

When working in hydrologic riparian reserves: When there is a 30 percent 

chance of rain in the next 24 hours, a Forest Service representative will be on site 

to insure that winterization or erosion control procedures are implemented in a 

timely fashion and to initiate shutdown or resume operations. Operations will not 

resume until suitable weather, soil, and forecast conditions exist.

All Alternatives:

All Thinning with 

Removal and 

Mastication Units

Watershed-3

The project is proposed to take place during the normal operating season (NOS) 

that is defined as May 1 to October 31 and in dry periods outside the NOS with 

line officer approval. Actions will be restricted during any periods of wet weather 

during the NOS. 

All Alternatives:

All Thinning with 

Removal and 

Mastication Units

Watershed-4

To minimize effects to anadromous fish, including spawning, egg incubation, and 

just-hatched fry, no in-stream project activities, including water drafting or use of 

low water crossings by heavy equipment, will occur in anadromous stream 

segments between October 15th and June 15th.

All Alternatives:

All Units

Watershed-5

Cable corridors will be placed on the landscape as to minimize disturbance to 

unstable lands (such as inner gorges, active landslides and toe zones). The layout 

will avoid yarding logs up the axis of the features. 

All Alternatives:

All Thinning with 

Removal Units

Watershed-6 Tractors and mechanical harvesters will be excluded from active landslides, toe 

zones of dormant landslides and inner gorges. 

All Alternatives:

All Thinning with 

Removal Units

Watershed-7

Thinning will be limited in granitic inner gorges of ephemeral or intermittent

stream channels to those reviewed and recommended for treatment by 

watershed specialists. 

All Alternatives:

All Thinning Units
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Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Watershed-8

Hazard trees that have fallen or are felled within riparian reserves will generally 

be left on site. Fallen or felled hazard trees may be removed from riparian 

reserves if 

i. Trees must be removed to provide safe road passage or campground access and 

function; OR

ii. Those trees would pose a substantial risk to the forest road drainage system 

integrity; AND 

iii. A fisheries biologist determines through site inspection and written document 

that removal of individual hazard trees within riparian reserves is consistent 

with the Aquatic Conservation Strategy objectives.

All Alternatives:

All Units

Watershed-9

Proposed activities will not reduce site potential effective shade conditions in 

riparian reserves. The interdisciplinary team will provide justification and 

identify the proposed canopy reduction and expected recovery time, provide an 

estimate of the pre‐ and post‐ project shade or solar impacts, and explain how 

such an exception will result in a net long‐term benefit to water quality and 

stream temperatures.

All Alternatives:

All Units

Watershed10

Skidding equipment will be generally restricted to slopes less than 35 percent 

(unless designated otherwise). Skid trails that connect benches separated by 

short steep slopes (broken ground) can have minor portions (100 feet or less) of 

the skid trails on slopes greater than 35 percent. 

All Alternatives:

All Thinning with 

Removal Units

Watershed11

Mechanized harvesting equipment will be restricted to slopes less than 45 

percent in stands where tractor skidding is used, and where practical, logs should 

be placed in bundles on slopes less than 35 percent (unless designated 

otherwise). Mechanized harvesting equipment will be restricted to travelling in 

straight up and down patterns on slopes above 35 percent. 

All Alternatives:

All Thinning with 

Removal Units

Watershed12

Existing skid trails will be reused whenever possible. Use existing skid and swing 

trails instead of building new skid trails unless using existing skid trails will have 

greater negative effects than building new. Do not use existing or construct new 

skid trails in areas (1) in which ground-based mechanical equipment is excluded; 

or (2) on highly erosive soils, active landslides, wetlands or meadows (excluding 

small springs and seeps). Designation of new skid trails will be approved by 

timber sale administrator. 

All Alternatives:

All Thinning with 

Removal Units

Watershed13Take offs of skid trails that intersect roads will be obliterated or effectively 

blocked to vehicle access.

All Alternatives:

All Thinning with 

Removal Units

Watershed14

Skidding equipment can operate in terraced plantations with slopes greater than 

35 percent with the following restrictions: terraces will be used that are generally 

wide enough to accommodate harvesting and skidding equipment to limit 

increasing the cut and fill slopes on terraces. Skidding between terraces will be 

limited and locations of these skid trails will be flagged by the timber sale 

administrator with input from the project earth scientist. 

All Alternatives:

All Thinning with 

Removal Units

Watershed15

No full bench skid trails will be constructed except in terraced plantations and 

then only on existing terraces. (Full bench skid trails have the entire skid trail cut 

into the hill slope).

All Alternatives:

All Thinning with 

Removal Units

Watershed16 Ground-based skidding will require front-end suspension of logs on skid trails.

All Alternatives:

All Thinning with 

Removal Units

Watershed17

Skid and swing trails will be waterbarred and/or covered in slash to prevent 

concentration of surface runoff and prevent runoff from the road from entering 

the swing trails. At project completion, permanent operating water bars will be 

All Alternatives:

All Thinning with 

Removal Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 19 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

installed and/or repaired as necessary on all skid trails, and slash scattered on all 

skid trails if necessary.

Watershed18

Place corridors for skyline-yarding outside hydrologic riparian reserves parallel 

to the stream channel unless field assessment by earth/soil specialist and sale 

administrator determines that placing them within the riparian reserve will not 

substantially damage residual trees, soil, or fish.

All Alternatives:

All Thinning with 

Removal Units

Watershed19

All skyline yarding stands will require one end suspension. Full suspension will 

be required for any yarding across or over perennial and intermittent streams to 

avoid damage to stream banks.

All Alternatives:

All Thinning with 

Removal Units

Watershed20

Construct new landings outside both hydrologic and unstable-land riparian 

reserves and away from locations where sediment is likely to enter streams 

(areas that have a hydrologic connection to streams).

All Alternatives:

All Thinning with 

Removal Units

Watershed21

Existing landings will be used to the extent possible. If the existing landings are 

within 50 feet of the slope break to a stream channel or inner gorge they will not 

be used. 

All Alternatives:

All Thinning with 

Removal Units

Watershed22

Where yarding or end lining occurs to retrieve logs from unstable lands

components and hydrologic riparian reserve equipment exclusion zones, ensure 

material does not cause gouging that creates a trough for overland flow to enter 

the channel. If gouging occurs, waterbars will be installed or slash applied to the 

area.

All Alternatives:

All Thinning with 

Removal Units

Watershed23

Once project activities are completed, re-establish natural runoff patterns on 

those landings used for the project (hydrologic stabilization) to protect water 

quality.

All Alternatives:

All Thinning with 

Removal Units

Watershed24Material will not be sidecast during maintenance, construction or reconstruction 

of landings.

All Alternatives:

All Thinning with 

Removal Units

Watershed25Slash or water bars will be applied to corridors where necessary to minimize the 

concentration of surface runoff and where the ground cover is below 50 percent. 

All Alternatives:

All Thinning with 

Removal Units

Watershed26

Use erosion control methods on access and/or main roads that are treated for 

dust abatement to prevent any water leakage from causing sedimentation of 

streams. 

All Alternatives:

All Applicable 

Roads

Watershed27

Perennial streams, even if dry, will not be crossed by skid trails. Intermittent 

channels may be crossed when dry and at locations designated by the Forest 

Service. 

All Alternatives:

All Thinning with 

Removal Units

Watershed28

Skid trails that cross intermittent streams or dry swales (i.e. depressions in the 

landscape that do not meet the definition for a designation as riparian reserve) 

will be restored before any storm (with reasonable chance of causing offsite 

sediment movement), or after use is complete. This generally consists of 

removing excess soil, reshaping and waterbarring former approaches, and 

spreading slash on the former crossing.

All Alternatives:

All Thinning with 

Removal Units

Watershed29

Limit equipment disturbance within 20 feet on either side of swales by 

minimizing equipment crossings and avoiding running trails up the axis of 

swales. Swales are shallow ephemeral channels that do not meet the definition of 

a riparian reserve because they lack annual channel scour.

All Alternatives:

All Thinning and 

Mastication Units

Watershed30

Masticators will not operate within 150 feet of slope distance on perennial/and 

100 feet slope distance on each side of intermittent streams, or the site potential 

tree height distance on each side of the stream, whichever is greatest (per NWFP 

ACS Strategy 8). A masticator will not operate beyond the break in slope of any 

inner gorge. Consultation with the project fish biologist and/or hydrologist will 

All Alternatives:

All Mastication 

Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 20 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

occur to determine if any additional buffer width for masticator equipment is 

needed for a particular riparian reserve.

Watershed31

Dry intermittent streams may be crossed by a masticator at designated sites only 

after field review and approval by a Forest Service hydrologist. No perennial 

streams, even when dry, will be crossed.

All Alternatives:

All Mastication 

Units

Watershed32

Trees directly rooted into the banks or otherwise and obviously integral to the 

stability of the channel bank will not be removed. Trees in the uplands will be 

directionally felled to protect stream banks. 

All Alternatives:

All Thinning Units

Watershed33

Use temporary roads on existing roadbeds instead of constructing new 

temporary roads except: (1) when temporary roads on existing roadbeds are 

located within stream-course riparian reserves (unless the only way to access the 

unit will be to use a stream crossing on an existing roadbed); or (2) when 

temporary roads on existing roadbeds are located on highly erosive soils, active 

landslides, wetlands or meadows (excluding small springs and seeps).

All Alternatives:

All Temporary 

Roads

Watershed34

Temporary roads on existing road beds and new temporary roads will be blocked 

at the end of the normal or extended operating season when project activities 

cease due to wet weather conditions. All temporary roads will be hydrologically 

restored at project completion, which may include road removal of culverts and 

fills at stream crossings, out-sloping of road surfaces, obliteration of road 

segments, and water barring or covering with slash.

All Alternatives:

All Temporary 

Roads

Watershed35

Improvements to existing roads in the project area will not over-steepen road 

cuts, will minimize sidecasting, and maintain the ditches and cross drains or any 

outslope of the roadway.

All Alternatives:

All Applicable 

Roads

Watershed36

Spot rocking will be used as necessary if small and isolated portions of the road 

system do not adequately dry to allow haul when most of the road is capable of 

haul. Ensure haul over the newly rocked areas will not create adverse impacts, 

such as sediment moving offsite towards channels. 

All Alternatives:

All Applicable 

Roads

Watershed37

Existing low water crossings where forest transportation system roads cross 

perennial or intermittent streams will have temporary stream crossings installed 

for forest product removal, as approved by the project fisheries biologist. 

Installation and use will be seasonally restricted as described in Watershed-4. 

Crossing will be installed in one operating season only and removed prior to end 

of the operating season of use. 

Alternative 2:

Forest Road (FR) 

45N53 and 45N88

Alternative 3: FR 

45N53

Watershed38

Drafting from fish-bearing (anadromous) waters

Use NOAA Fisheries Water Drafting Specifications:

• When in habitat potentially occupied by Chinook and Coho Salmon, intakes will 

be screened with 3/32” mesh for rounded or square openings, or 1/16 inch mesh 

for slotted openings. When in habitat potentially occupied by steelhead trout, 

intakes will be screened with 1/8” mesh size. Wetted surface area of the screen 

or fish-exclusion device shall be proportional to the pump rate to ensure that 

water velocity at the screen surface does not exceed 0.33 feet per second.

Use of a NOAA approved fish screen will ensure the above specifications are met. 

• Fish screen will be placed parallel to flow.

• Pumping rate will not exceed 350 gallons-per-minute (gpm) or 10 percent of 

the flow of the anadromous stream drafted from.

• Pumping will be terminated when tank is full.

Additional applicable specifications:

• Water drafting by more than one truck shall not occur simultaneously.

All Alternatives:

All Water Drafting 

Sites

Watershed39

Drafting from fish-bearing (non-anadromous) waters

Forest Service BMP Handbook direction applies (BMP 2.5)

• Drafting rate should not exceed 350 gpm for streamflow greater than or equal 

to 4.0 cubic-feet-per-second (cfs).

All Alternatives:

All Water Drafting 

Sites
Craggy Vegetation Management Project Scoping Outcome Summary

Page 21 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

• Below 4.0 cfs, drafting rates should not exceed 20 percent of surface flows.

• Drafting should cease when bypass surface flows drop below 1.5 cfs.

• Intakes, for trucks and tanks, shall be placed parallel to the flow of water and 

screened, with opening size consistent with the protection of aquatic species of 

interest.

Screen sizes are not provided by BMPs. It is the best judgment of the fish 

biologist that screen sizes described by NOAA specifications for steelhead (1/8

inch mesh size) are applicable for rainbow trout.

• Water drafting by more than one truck shall not occur simultaneously.

Watershed40

Drafting from non-fish-bearing waters

Forest Service BMP Handbook direction applies (BMP 2.5) 

• Drafting rate should not exceed 350 gallons per minute for stream flow greater 

than or equal to 2.0 cfs.

• Drafting rate should not exceed 50 percent of surface flow.

• Drafting should cease from when bypass surface flow drops below 10 gallons 

per minute.

• Water drafting by more than one truck shall not occur simultaneously.

All Alternatives:

All Water Drafting 

Sites

Watershed41

Water drafting sites located in non-fish-bearing waters only may include minor 

instream modification, such as fine sediment removal and building of 

board/plastic dams, at the discretion of the project fish biologist or hydrologist. 

All boards and plastic will be removed after use. Approaches may be rocked.

Water drafting sites located within fish-bearing stream segments may not be 

modified, except rocking the approach to prevent sedimentation

All Alternatives:

All Water Drafting 

Sites

Watershed42

Fueling and servicing of vehicles used for proposed activities will be done outside 

of hydrologic riparian reserves.

No fueling/refueling of mechanical equipment will occur within 200 feet of any 

flowing watercourse or intermittent drainage. 

Report spills and initiate appropriate clean-up action in accordance with 

applicable state and federal laws, rules and regulations. The forest hazardous 

materials coordinator’s name and phone number shall be available to Forest 

Service personnel who administer or manage activities utilizing petroleumpowered equipment.

In the occurrence of a spill which may affect listed aquatic species, NOAA 

Fisheries will be notified for emergency consultation.

All Alternatives:

All Units

Watershed43 A spill containment kit will be in place where refueling and servicing take place. All Alternatives:

All Units

Watershed44Mastication equipment will be restricted to slopes less than 35 to 45 percent 

depending on the soil type.

All Alternatives:

All Mastication 

Units

Watershed45Maintain existing coarse woody debris by having ground-based equipment avoid 

the larger diameter woody debris as much as practical. 

All Alternatives:

All Thinning with 

Removal and 

Mastication Units

Watershed46Post treatment soil cover will range from 50-80 percent depending on slope 

steepness, soil texture, and fuel reduction treatments.

All Alternatives:

All Thinning and 

Mastication Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 22 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Watershed47 For masticators, soil moistures will be below 18 percent. 

All Alternatives:

All Mastication 

Units

Watershed48 Use of mastication equipment will follow forest wet weather operation standards

All Alternatives:

All Mastication 

Units

Watershed49

Restrictions for hand pile construction

• Place in a checkerboard pattern whenever possible (not one pile directly above 

another).

• Hand piles must be small in size, 6 feet or less in diameter.

• No hand piles within 15 feet of any perennial or intermittent stream channel.

• Between 15 and 30 feet away from perennial or intermittent streams, hand

piles may be constructed if the following conditions exist: (1) not granitic soils, 

(2) slope is less than 35 percent, or (3) ground cover is greater than 50 percent. If 

the condition cannot be met, then slash should be lopped and scattered. 

All Alternatives:

All Fuel Break and 

Thinning Units

Watershed50

Burning hand piles

• See Watershed-49 for hand pile construction description.

If perennial streams are greater than 1 foot in width

• Only hand piles greater than 30 feet from the channel may be burned. 

If intermittent and small (less than 1 foot in width) perennial streams

• Hand piles greater than 15 feet from the channel may be burned.

All Alternatives:

All Fuel Break and 

Thinning Units

Watershed51

Prescribed fire effects in hydrologic riparian reserves will mimic a low intensity 

backing fire, except for hand-piles where higher intensity may occur to consume 

pile material. Ignition of underburns will generally not occur in riparian reserves, 

except to minimize the potential for burning material to roll down into a riparian 

reserve that would increase the potential for moderate or high intensity burns. 

Approval by the district fish biologist is needed for underburn ignitions in

riparian reserve.

All Alternatives:

All Underburn 

Units

Watershed52

For underburning, construction of handlines in riparian reserves closer than 25 

feet to a watercourse shall be avoided where practical. Handline construction in 

riparian vegetation shall be avoided where practical. Handlines will be mitigated 

(waterbarred and covered with organic material) immediately following 

prescribed burning, when safe to do so.

All Alternatives:

All Underburn 

Units

Watershed53When underburning in riparian reserves, at least 90 percent of the large woody 

debris will not be consumed, both standing and on the ground.

All Alternatives:

All Underburn 

Units

Wildlife-1

Retain at a minimum 2-5 snags on an average per acre where available. This is to 

be assessed on a landscape level. Snag retention may not be met equally on every 

acre but will be met at a landscape scale. Retain snags in clump or groups, 

situated around the largest and live trees where possible. Select snags with 

broken tops as first priority.

All Alternatives:

All Units

Wildlife-2

Marking crews will coordinate with a wildlife biologist to ensure suitable 

northern spotted owl (NSO) habitat characteristics are retained as described in 

the unit specific silvicultural prescriptions and marking guidelines.

All Alternatives:

All Thinning with 

Removal Units

Wildlife-3

A seasonal restriction of February 1st to September 15th will apply to all 

activities that modify habitat (including activities that degrade or are beneficial) 

within 0.25 miles of a NSO activity center or unsurveyed nesting/roosting 

habitat. The limiting operating period (LOP) may be lifted if protocol surveys 

determine NSOs are not nesting in the year of action.

All Alternatives:

All Applicable 

Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 23 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Wildlife-4

For areas not in suitable habitat but will potentially be noise-producing activities 

that are above ambient noise levels within 0.25 miles of an occupied NSO activity 

center or unsurveyed suitable nesting/roosting habitat, a seasonal restriction will 

be applied from February 1st through July 9th. The LOP may be lifted if protocol 

surveys determine NSOs are not nesting in the year of action.

All Alternatives:

All Applicable 

Units

Wildlife-5 If surveys are to be implemented, we will follow current NSO protocol guidance.

All Alternatives:

All Applicable 

Units

Wildlife-6

In order to not treat more than 50 percent of an occupied NSO home range within 

any given year: Within occupied or unsurveyed suitable habitat, no more than 50

percent of the nesting, roosting, or foraging habitat will be burned or 

mechanically treated in a single year in any one 7th-field watershed up to 3,500 

acres in size. If the 7th-field watershed is greater than 3,500 acres, apply the 

design criteria at the 8th field watershed scale or in some other manner that 

meets the intent of the design feature.

All Alternatives:

All Applicable 

Units

Wildlife-7 No more than 50 percent of suitable NSO habitat within 0.5 miles of an NSO core 

will be underburned in a given year.

All Alternatives:

All Applicable 

Underburn Units

Wildlife-8

Maintain existing snag and large down log levels across the landscape where fuel 

loading is not excessive but do not go below Klamath Forest Plan standards for 

snags and logs per acre.

All Alternatives:

All Units

Wildlife-9

When burning in spring, smoke is managed so that light to moderate, dispersed 

smoke may be present within a canyon or drainage but dissipates or lifts within 

24 hours. When spring burning is conducted within 0.25 miles and uphill of a 

known NSO activity center or within 0.25 miles of unsurveyed nesting/roosting 

habitat (separated by a topographic feature), smoke is managed as described 

above, and ignition should be discontinued if heavy, concentrated smoke begins 

to inundate suitable habitat late in the afternoon

All Alternatives:

All Applicable 

Units

Wildlife-10

No known bald eagle nest trees, perch trees, or roost trees within winter roost 

areas will be removed or destroyed as a result of prescribed fire or fuels 

reduction activities if discovered.

All Alternatives:

All Applicable 

Units

Wildlife-11

To minimize smoke effects on bald eagles, prescribed burning will not occur in or 

within 0.5 miles of a known or suspected nest territory from January 1st to 

August 31st, or a known or suspected winter roost area from November 1st to 

March 31st if discovered. If surveys demonstrate that nest sites are not active, no 

seasonal restrictions are required.

All Alternatives:

All Applicable 

Units

Wildlife-12

Activities that create noise above ambient levels within 0.25 miles of active or 

suspected bald eagle nests if discovered, or occur within a 0.5 mile line-of-sight of 

such nests, will be seasonally restricted from January 1st to August 31st. If 

surveys demonstrate that bald eagles nest sites are not active, no seasonal 

restrictions are required.

All Alternatives:

All Applicable 

Units

Wildlife-13

Activities that create noise above ambient levels within 0.25 miles of an active or 

suspected bald eagle winter roost, or occur within 0.5 miles line-of-sight of such 

roosts, will be seasonally restricted from November 1st to March 31st if 

discovered. If surveys demonstrate that roosts are not being used, no seasonal 

restrictions are required.

All Alternatives:

All Applicable 

Units

Wildlife-14

In known occupied northern goshawk nest sites and management areas, no 

burning or use of heavy equipment will occur within 0.25 miles of the nest site 

between March 1st and August 31st. If protocol surveys are conducted and the 

site is found to be unoccupied, proposed actions may proceed.

All Alternatives:

All Applicable 

Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 24 of 46

Design 

Feature Description 

Applicable 

Alternatives/

Areas or Units

Wildlife-15

In order to avoid direct harm to individual Siskiyou Mountain and Scott Bar 

salamanders, in occupied sites or areas modeled as having moderate or high 

likelihood of occupancy; implement burning when salamanders have low 

likelihood of being surface active.

All Alternatives:

All Applicable 

Units

Wildlife-16

Avoid use of heavy equipment on known Siskiyou Mountain and Scott Bar 

salamander sites or on suitable talus that has a moderate or high likelihood of 

occupancy.

All Alternatives:

All Applicable 

Units

Wildlife-17

Treatment units containing suitable Siskiyou Mountain and Scott Bar salamander 

habitat will be flagged and avoided; flagged areas will be utilized as "skips" 

considered in variable density thinning prescriptions.

All Alternatives:

All Applicable 

Units

Wildlife-18

Greater than 60 percent of the existing canopy cover of the larger mature trees, 

large down woody debris, and sufficient forest floor litter will be retained within 

and adjacent to known sites of Tehama chaparral and blue gray tail dropper. 

All Alternatives:

All Applicable 

Units

Wildlife-19 Heavy equipment will not be used on talus slopes in order to protect Tehama 

chaparral and blue gray tail dropper.

All Alternatives:

All Applicable 

Units

Wildlife-20

Treatment units containing suitable Tehama chaparral and blue gray tail dropper 

habitat will have these areas flagged and avoided; flagged areas will be utilized as 

"skips" considered in variable density thinning prescriptions.

All Alternatives:

All Applicable 

Units

Wildlife-21 Recommended direction of felling is away from retained hardwoods to minimize 

logging damage.

All Alternatives:

All Thinning and 

Fuel Break Units

Wildlife-22 Recommended direction of felling is away from meadows. Minimize equipment 

use on sensitive meadow habitats.

All Alternatives:

All Thinning and 

Fuel Break Units

Wildlife-23

Retain approximately 25% of area thinned as untreated islands and irregular 

edge to retain diversity for wildlife habitat needs where fuel break effectiveness 

would not be compromised

All Alternatives:

All Fuel Break and 

Mastication Units

Wildlife-24 For hardwoods in tree form, retain except where removal is required for 

operability or fuel break function. Include in leave tree spacing.

All Alternatives:

All Fuel Break, 

Thinning, and 

Mastication Units
Craggy Vegetation Management Project Scoping Outcome Summary

Page 25 of 46

Appendix D

Disposition of Scoping Comments

Introduction

The details of the scoping efforts for the Craggy Vegetation Management Project can be found in 

the Public Involvement and Scoping section of the Scoping Outcome Summary.

The comments received as a result of public scoping are summarized below.

Method of Scoping Comments Analysis

As a result of scoping, the Forest Service received letters, written comments, and verbal 

messages from 11 interested and affected parties and agencies (see Table 1). Comment 

documents were tracked upon receipt to assure all relevant comments were captured. The letters 

and attachments were logged in and scanned into an electronic file. Individual comments from 

within each comment document were identified and highlighted. Issues and concerns were 

categorized based on the topic in order to identify the subject matter in a manner that the 

interdisciplinary team can use to address comments. To assist the analysis, the comments were 

also categorized by type of issue or concern. Both the subject and type categories are displayed 

in Table 2. Comments that were received prior to scoping were reviewed and considered during 

development of the proposal, and are not included in this disposition.

Comments were categorized as either concerns or issues. Concerns are general comments or 

questions that do not meet the definition of an issue. Issues are defined as points of discussion, 

dispute, or debate about the environmental effects that may directly or indirectly be caused by 

implementing the proposed action, and are further categorized as follows:

1. Relevant Issue. This is an issue that led to development of alternatives or project design 

features not previously identified in the project proposal.

2. Other Issue. An issue may not be relevant for alternative or project design feature 

development for any of the following reasons:

a. The issue is outside the scope of the proposed action, and is not related to the 

decision to be made. 

b. The issue is a procedural concern, which is already decided by law, regulation, 

policy, or direction (Forest Plan). 

c. The issue is a procedural concern, which was addressed through project design

features in the project proposal or was (or will be) addressed through analysis.

d. The issue is not supported by scientific (or factual) evidence. 
Craggy Vegetation Management Project Scoping Outcome Summary

Page 26 of 46

Results

Table 1: Respondent correspondence and any attachments received

Letter 

Number Date Received Name of Respondent/Affiliation Attachment Information

1 01/05/2016 Davy, Amy Phone Conversation

2 01/14/2016 Whipple, Todd Phone Conversation

3 01/14/2016 Smith, Richard Phone Message

4 01/14/2016 Stone, Jeffrey Online Comment

5 01/12/2016 Munson, James - EPA Letter

6 01/19/2016 Sexton, George Letter, Literature Cited

7 01/19/2016 Ravenscroft, Jeremy Letter

8 01/19/2016 Davies, Albert Letter

9 01/29/2016 Smith, Richard Phone Conversation (#2)

10 01/31/2016 van Hees, Gerard - AFRC Letter

11 01/12/2016 Siemers, Roger Written Comment

12 01/12/2016 Wilson, Steve Written Comment

The following table displays the specific comments made by subject, showing the respondent(s) 

by letter and comment number, (refer to Table 1 above). In Table 2, all issues and concerns are 

grouped by topic and then are identified as being a (1) relevant issue, (2) other issue, or (3) 

concern as defined above. 

Table 2: Scoping comments and responses

Topic 

# Type

Comment 

#

Comment & Response

Watershed

1 Relevant 

Issue

6-37

We are extremely concerned about the potential for this project to 

increase the risk of sedimentation, peak flows, and soil 

compaction due ground-based disturbance from tractor yarding, 

especially as a large portion of the area has been compacted in the 

past.

6-3

"A high degree of soil compaction prevails in the Humbug Creek 

area and (sic) rutting on slopes." KNF Travel Management DEIS 

page 120. Road construction, timber haul, landing establishment 

and timber sale yarding activities will exacerbate this situation and 

may result in significant impacts to soils and aquatic resources.

6-15 By codifying additional user-created OHV routes, constructing 

temporary logging roads, and utilizing ground-based yarding, the 
Craggy Vegetation Management Project Scoping Outcome Summary

Page 27 of 46

Topic 

# Type

Comment 

#

Comment & Response

KNF is increasing the aquatic and terrestrial impacts of its grounddisturbing activities.

Response: Alternative 3 was developed to address this issue. The 

environmental impact statement, Water Quality, Aquatic 

Resources and Soils resource reports for this project will evaluate 

the environmental effects of the proposed action and Alternative 

3. Project design features and best management practices that 

minimize or eliminate negative effects will be described in these 

documents.

2 Relevant 

Issue

6-21

Hence Craggy project planners should not assume that temporary 

and new roads will have little environmental effect because they 

are "temporary." The Forest Service will find no scientific evidence 

to support this assumption. In fact, scientific research has shown 

exactly the opposite. Effectiveness of Road Ripping in Restoring 

Infiltration Capacity of Forest Roads. Charles H. Luce, USDA Forest 

Service Intermountain Research Station, 1221 S. Main, Moscow, ID 

83843. September 1996. Restoration Ecology, Vol. 5, No. 3, page 

268.

Response: The proposed action includes the use of existing 

roadbeds for temporary roads. These roadbeds were created in 

previous management activities and after use will be 

hydrologically stabilized according to project design features. The 

interdisciplinary team designed the proposed action to minimize 

construction of new temporary roads, instead proposing to re-use

old roadbeds in order to minimize potential environmental effects.

Environmental effects will be disclosed in the Soils and Water 

Quality resource reports, including consideration of the referenced 

paper as appropriate.

3 Other 

Issue (c)

6-17

Please note that page 69 of the Humbug Landscape Analysis 

concludes that "[n]umerous roads and past management activities 

couples with granitic soils have resulted in erosion problems 

throughout portions of the landscape." Given that previous timber 

sales and road construction have "resulted in erosion problems" 

such that streams in the project area are TMDL-listed for 

sediment, it is essential that the Forest Service avoid additional 

road construction and timber sale activities that will exacerbate 

the current conditions.

Response: The environmental effects of the temporary roads will

be disclosed in the environmental impact statement and relevant 

soils, water quality, and geology resource reports.

Fire and Fuels

Relevant 

Issue

3-1, 9-1, 

and 

general 

comments 

[Summary of oral comments] Provide more fuel reduction 

treatments adjacent to private land.

Response: Additional fuel breaks adjacent to private land are 

included in Alternative 3. An alternative was developed that 
Craggy Vegetation Management Project Scoping Outcome Summary

Page 28 of 46

Topic 

# Type

Comment 

#

Comment & Response

4 from the 

open 

house and 

discussions 

with CAL 

FIRE

maximizes treatments adjacent to private land; this alternative 

(Alternative B) was considered but eliminated from detailed study 

for reasons provided in the Scoping Outcome Summary.

5

Concern

3-1 Whether any treatments were planned near his property

9-1 He is concerned with wildfire impacting his property

9-2 Interested in receiving permission to treat the brush on the USFS 

land immediately adjacent to his property

Response: The USDA Forest Service appreciates the expressed 

concerns, but cannot allow private individuals to treat hazardous 

fuels on National Forest System lands. Alternative 3, which 

proposes additional fuel break treatments adjacent to private 

lands in the project area, was developed in order to address this

and similar concerns.

6 Other 

Issue (c)

6-58

Disclose the effect of leaving untreated logging slash in the timber 

sale units even for a short period of time. Be explicit about 

potential wildfire behavior and risk of escape from initial attack 

prior to slash clean-up.

Response: The environmental impact statement and fire and fuels 

resource report will include a disclosure of potential short-term 

wildland fire behavior risk for all alternatives. The environmental 

impact statement and resource report will discuss the impacts of 

risk in regards to untreated logging slash in the short term.

7 Concern

6-59

Please address the conclusions found in the recently published 

peer-reviewed paper: Odion, D.C., E.J. Frost, J.R. Strittholt, H. 

Jiang, D.A. Della Sala and M.A. Moritz. 2004. Patterns of fire 

severity and forest conditions in the western Klamath Mountains, 

California. Conservation Biology 18(4): 927-936.

Response: The fire and fuels resource report will include a 

discussion of the Odion et al. 2004 paper. 

8

Concern

7-8 Is there an emergency fire plan in the event the prescribed burning 

activities threaten residences within the project area?

7-9

What compensation measures are in place if prescribed burning 

activities damage private property whether habitable structures, 

outbuildings, domestic water facilities, or vegetation?

Response: For prescribed fire operations, the USDA Forest Service 

requires an administratively approved burn plan which includes an 

emergency contingency plan and specified level of response to a 

fire escape. Private landowners will be contacted prior to 

prescribed fire ignition as is similarly required. In the event that 

prescribed burning activities damage private property and the 

Forest Service is found to have not followed the approved burn 
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plan, then the agency may be liable for resulting damages to 

private property.

Process

9 Other 

Issue (c)

10-2 The analysis needs to display how long the treatments will be 

effective in meeting the designed purpose and need.

10-3

In order to meet the desired condition for ecological restoration 

and fuels management the treatments will need to be intensive 

enough to be effective for a considerable period of time

Response: The environmental impact statement and resource 

reports will include the spatial and temporal bounds for analysis of 

the potential environmental effects of the project. Length of 

effectiveness will be disclosed for silvicultural and fuels reduction 

treatments.

10 Other 

Issue (c)

6-31

Second, it must consider the interaction of multiple activities and 

cannot focus exclusively on the environmental impacts of an 

individual project.

6-32

Given the repeated acknowledgements in the Landscape Analysis 

and the Travel Management planning process regarding the 

impacts of past logging and road construction activities on the 

hydrological and terrestrial health of the project area, it is vital 

that the Forest Service analyze and disclose the cumulative 

impacts of past activities and its future plans.

6-25

The cumulative impacts of "temporary" road construction, 

significant unregulated ORV use, landing construction and 

widespread tractor yarding on this highly impacted watershed 

must be fully disclosed in an EIS due to the ongoing significant 

impacts to hydrology (and soils) acknowledged in the WQRP and 

the WA.

6-27

Please provide a thorough cumulative impacts analysis of the 

proposed logging in combination with other federal logging and 

private logging activities. The significant cumulative impacts on 

forest ecosystems and hydrological health from past road 

construction and federal logging must be disclosed in the 

forthcoming NEPA document.

6-28

Furthermore, in order to maintain viable populations of 

threatened and sensitive wildlife species, federal land managers 

must recognize the significant role of nonfederal lands in the 

Humbug watershed. Resource extraction and road building 

activities on nonfederal lands create cumulative effects to wildlife 

and fish habitats at the site and watershed scales.

6-29

The many severe cumulative impacts from timber sale activities, 

road construction, fire suppression, and grazing that are identified 

in the Landscape Analysis for this planning area must meet the 

requirements of NEPA such that: A proper consideration of the 

cumulative impacts of a project requires "some quantified or 
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detailed information;...general statements about possible effects 

and some risk do not constitute a hard look absent a justifications 

regarding why more definitive information could not be provided."

6-30

To this end, we have recently noted two critical features of a 

cumulative effects analysis. First, it must not only describe related 

projects but also enumerate the environmental effects of those 

projects

Response: The effects of past actions will be considered as part of 

the affected environment; the effects of adding project 

alternatives to past, current and reasonably foreseeable future 

actions will be included in the cumulative effects analysis for each 

resource in the environmental impact statement. Actions on both 

federal and nonfederal lands in the analysis areas for each 

resource that have effects that overlap in time and space with the 

project will be considered. Resource reports for the project will 

include an analysis of cumulative effects and findings of significant 

effects will be disclosed in the environmental impact statement.

For some resources, the analysis area includes the project area or 

a smaller area, for others the analysis area includes 7th field 

watersheds that encompass the project area or a larger landscape.

11

Concern

8-1

Unfortunately I am unable to attend your meeting scheduled for 

January 13, 2016 due to your short notice (your post mark was 

only 12-30-15).

10-20 We are also interested in any field trips that may be set up for this 

project.

6-64 Please ensure that we are on your mailing list to receive hard 

copies of all forthcoming documents regarding this project.

10-19 Thank you for the opportunity to comment on the proposed 

project and please keep us informed on the progress of NEPA.

Response: Thank you for your interest in the project. So far, we 

have held two public field trips in 2012 and 2013 to tour the 

project area and discuss proposed treatments. Detailed maps of 

the proposed action and project area are available on the project 

website (http://www.fs.usda.gov/project/?project=31770). We

will issue a legal notice in the newspaper of record (Siskiyou Daily 

News) once a draft environmental impact statement is prepared 

and ready for public comment. Notice of availability and project 

updates will also be sent to interested parties including previous 

commenters. We will try to give more advance notice of upcoming 

meetings, as scheduling allows. 

12

Concern 10-21

We would like the Forest Service to shift their methods for 

protecting resources from that of firm prescriptive restrictions to 

one that focuses on descriptive end-results; in other words, 

describe what you would like the end result to be rather than 

prescribing how to get there.
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Response: All projects are based on desired end-results 

enumerated in the Forest Plan as forest-wide goals and objectives. 

This will be further described in the desired conditions section of 

the environmental impact statement. Protective measures are in 

place to ensure that project activities to reach the desired 

conditions do not have unintended negative effects on resources

and ensure the project is consistent law, regulation, policy and 

Forest Plan standards.

Proposed Action

13 Concern

11-3 The area needs to be treated to prevent another high intensity 

fire. Treat almost all acres w/in project boundary.

Response: Thank you for your comment. The proposed action was 

designed to meet the need of improved fire resiliency by reducing 

fuels and stand density in strategic areas of the landscape and 

within the wildland-urban interface (WUI). Alternative 3 has been 

developed to increase treatment acreage adjacent to private 

property. Alternative C was developed to treat additional acreage; 

this alternative was considered but eliminated from detailed study 

for reasons given in the Scoping Outcome Summary. By focusing 

on the most strategic and near-urban areas, Alternatives 2 and 3

are believed to treat the portion of the project area that would 

result in the greatest overall benefit with the least negative 

environmental effect.

14 Concern

7-11

Bald Eagles/Goshawks: If know[n] nests occur within the project 

area, will nest core areas be treated to maintain or develop fire 

resilient characteristics?

Response: The effects of the project on these two species will be 

assessed in the environmental impact statement, wildlife resource 

report and terrestrial wildlife biological evaluation. This analysis 

will include effects and assessment of bald eagle and northern 

goshawk habitat and will identify any needed species-specific 

project design criteria.

15 Other 

Issue (c)

6-26

In addition to disclosing these cumulative impacts, we strongly 

urge the BLM to avoid the negative impacts associated with these 

practices and begin restoring the damage caused by the agency's 

past actions.

Response: The proposed action and Alternative 3 include legacy 

road sediment source treatment, re-use and hydrologic 

stabilization of existing roadbeds, and plantation thinning 

treatments to minimize the negative effects of past actions and 

events. The effects of these treatments, including cumulative 

effects, will be disclosed in the environmental impact statement 

and relevant resource reports.
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16 Other 

Issue (d)

11-5

Include all ponderosa pine plantations for treatment. They are at 

risk to bark beetle caused mortality which will add to fuel loading 

over time. Approve under NEPA all treatments that the land 

needs. That is environmental decision. How to pay for things is an 

administrative decision(s) beyond NEPA. You can’t do the work if it 

is not approved in NEPA.

Response: Thank you for your comment. The interdisciplinary 

team has recognized this need for treatment and has included in 

the proposed action many of the pine plantations within the 

project area. Alternative C, which would treat all plantations in the 

area, was developed in response to this comment; please see the 

discussion within the section on alternatives considered but 

eliminated from detailed study. The environmental impact 

statement and silviculture resource report will address the 

potential environmental effects of the project on health of 

plantations.

17

Concern

10-4

Road construction items include constructing dips at stream 

crossings, out sloping road surfaces, upgrading culverts, and 

applying rock aggregate. There is also approximately 2 miles of 

temporary road planned in the project. All of these items if 

included in the forest product removal portion of the project will 

be very expensive and will probably exceed the value of the forest 

products.

10-5 Constructing forest roads is essential if active management is 

desired

10-6

we hope that the Forest Service is proposing to construct roads 

that are needed to access and treat as much as the project area as 

possible in an economically feasible way

Response: No new system roads are proposed in this project; the 

economic and ecological costs and benefits of temporary roads to 

meet the purpose and need for the project will be disclosed in the 

environmental impact statement and relevant resource reports.

18 Other 

Issue (a)

12-5

Due to the recent fire ignitions that have occurred near Badger 

Mountain, namely the Hawkinsville Fires of 2011 and 2015, it is 

necessary to attempt to reduce further ignitions from occurring in 

the high use area.

12-6 The proposed project should assist in reducing the potential of 

unwanted fire ignitions.

Response: Thank you for your comment. The proposed action and 

Alternative 3 emphasize vegetation and fuels treatments in 

strategic areas important to fire resiliency. This includes areas with 

a record of previous wildfires such as Badger Mountain. Reducing 

fire ignitions is not within the purpose and need for this project; it 

is part of the larger fire prevention mission of the Forest, other 
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fire-prevention agencies, and community groups such as the fire 

safe councils.

19 Concern

6-63

Please consider developing and implementing a project that thins 

small-diameter ground and ladder fuels while reducing road 

density in the planning area.

6-18

Please focus on careful small-diameter thinning activities and road 

density reductions in order to incorporate the findings of the 

Landscape Analysis and bring the project area towards compliance 

with the Aquatic Conservation Strategy and the Clean Water Act.

Response: No change in the number of system roads is included in 

the project so there will be no effect to road density. The 

proposed action and Alternative 3 emphasize use of temporary 

roads on existing roadbeds, creation of few miles of new 

temporary roads, to minimize negative effects. The temporary 

roads will be closed and hydrologically stabilized after use. The 

environmental effects of the temporary roads will be disclosed in 

the environmental impact statement and relevant soils, water 

quality, and geology resource reports. Vegetation treatments will 

reduce ground and ladder fuels to improve forest health. The 

environmental impact statement includes the relevant findings of 

the Humbug Landscape Analysis and will disclose compliance of 

the project with the Aquatic Conservation Strategy and the Clean 

Water Act.

20 Concern

4-1 I appreciate the fact that the Forest Service is proposing to treat 

legacy road sediment sources within the Craggy Project Area

7-2 The need for the project is clear and I am encouraged that a 

project of this scope is planned.

7-5

Projects like this allow your agency to fulfill the "purpose of 

conservation" which is: "The greatest good to the greatest number 

of people for the longest time." Gifford Pinchot

10-18 AFRC wants to go on record in support of the Craggy Project.

12-1 I'm in support of the Craggy Vegetation Management Project, 

Project # 31770.

12-2 It appears the project as proposed will improve fire resiliency on 

federal lands and in the wildland urban interface (WUI).

12-3

In addition, the commercial thinning portion of the project should 

provide much needed relief to over-stocked stands of trees that 

are currently dying from drought related stress.

12-4 I fully support the ridge and roadside fuelbreaks and mastication 

work as proposed in this project.

12-7

The mastication and fuel reduction work near private property 

boundaries and in close proximity to Yreka city is of great 

significance in improving fire resiliency for those areas

12-9 I support this project which proposed to commercially and precommercially thin some of these drought-stricken stands.
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12-10 Thinning these stands will help to promote a healthy forest

Response: Thank you for your support of the project.

21 Other 

Issue (c)

7-13 Mastication: The proposed treatment generally has a very high 

cost per acre. What other alternative treatments were proposed?

Response: The effects of mastication and alternative treatments 

to remove brush, including the economic costs and effects, will be 

discussed in the environmental analysis for the project, including 

the vegetation (silviculture) and fire and fuels resource reports. 

22 Concern

7-18 Are meadows, dry meadows or other natural openings proposed 

for treatment or enhancement?

Response: The project is proposed primarily to improve the fire 

resiliency of Forest lands within the project area. There are no 

known meadows within the project area and meadow restoration 

was not identified as part of the purpose or need of the project. If 

meadows are identified within treatment areas, project design 

features are proposed to protect them (Watershed-12, 

Watershed-33, and Wildlife-22).

23 Concern 5-2 EPA has no formal comments on the Notice of Intent at this time.

Response: Thank you for reviewing the Craggy scoping proposal.

Private Lands

24

Concern

1-1 whether the project would treat any private lands

8-3

I do note your intent to do a survey/study of the forest including 

my property on the Humbug Creek. Please note I do not wish to 

participate in the survey or study and ask that you exclude my 

property.

Response: The project is proposed to improve fire resiliency on 

National Forest System lands only. The environmental analysis 

applies only to actions proposed on public lands administered by 

the USDA Forest Service. There are a multitude of other public and 

private organizations such as the Yreka Area Fire Safe Council, CAL 

FIRE, and the USDA Natural Resources Conservation Service that 

offer assistance to private landowners seeking to treat their 

properties. 

25 Concern

2-2

Stated he was okay with contractors and USFS personnel working 

in the area, especially if he was made aware of the work in 

advance

7-1 As a neighboring landowner adjacent to the project area, I 

appreciate your consideration in notifying interested parties

8-4 I would consider it a trespassing if you or any one was to enter the 

property without my written permission.

8-5 Do not enter my property for this or any other study or survey 

now or in the future

Response: As part of the scoping outreach process, the Forest 

contacted private landowners within the Craggy Vegetation 

Management Project area. This contact list will be used for 
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communicating updates on the project such as availability of a 

draft and final environmental impact statement and record of 

decision. No project activities are proposed on private land, and no 

crossings will occur except on established easements or rights-ofway.

26 Concern

2-1 Concerned with the public trespassing and cutting trees on his 

property

Response: The Forest has an annual program of work to maintain 

property boundary markings. We appreciate your concern that reconstruction of existing forest roads may encourage additional use 

of these roads by the public; please review the included 

alternative treatment maps and alert us of any roads for which you 

have specific concerns. 

Roads

27 Other 

Issue (a)

4-4 At the very least, I hope action will be taken to close and obliterate 

non-MVUM roads within the project area.

6-13

As acknowledged on page 133 of the Travel Management DEIS, 

Upper Humbug Creek "has a high level of disturbance, including 

road densities of 3.17 miles per square mile. Embeddedness is high 

with the average being about 48%. This is above the maximum 

desired level of 20% as defined in the Forest Plan." Please note 

that the KNF LRMP at MA10-22, MA10-45 and MA10-55 creates 

the nondiscretionary duty to restore riparian conditions. Please 

further note that page 130 of the DEIS acknowledges that "the 

reduction or elimination of vehicle traffic on a road near a stream 

will result in less sediment delivered from the road to the stream." 

Additionally, the KNF LRMP at 20-1 clearly directs that "nonsystem roads not needed for future management shall be put to 

bed." Please implement this non-discretionary guidance in the 

Craggy Project.

6-14

We are extremely concerned that it appears that the KNF is 

proposing extensive temporary road construction while refusing to 

consider the aquatic benefits of needed road decommissioning in 

the project area.

6-16 It is reasonable to implement the direction of the LRMP to put unneeded roads to bed in this highly impacted watershed.

Response: The purpose and need of this project does not include 

reclassification of the existing road system or decisions to close 

unauthorized routes. These considerations have been addressed in 

the Forest Motorized Travel Management Plan. Closing and 

hydrologically stabilizing temporary roads used in the project will 

be addressed in the environmental impact statement and relevant 

resource reports.

28 Concern 4-5 There are several county roads within the project area. Some of these roads are poorly maintained and are sediment sources that 
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affect NFS lands, though none of them are proposed for 

treatment.

4-6

I believe a cooperative effort with the county should be 

undertaken to identify and treat specific sediment sources along 

these roads, particularly roads that will be used to access project 

treatment areas

Response: Coordination of road maintenance is not within the 

purpose and need of this project. Coordination with Siskiyou 

County is an ongoing activity of the Forest.

Silviculture

29 Other 

Issue (c)

6-55

Large numbers of mature trees will be removed from proposed 

logging units. All of these trees would have died and created snags 

and down wood for wildlife. What is the reduction in large 

snag/down wood supply over time (beginning with this logging 

project)? Since many of these trees are 100 years old, the reduced 

snag supply may persist for at least several hundred years.

Response: The effects of the project on snags and downed wood 

will be analyzed and disclosed in the environmental impact 

statement and relevant resource reports. The documents will 

include assessment of snag habitat and will identify project design 

criteria for snag retention. 

30 Concern

6-57

It is essential that that public and the Decision Maker know via 

NEPA the number and size of trees to be logged. This is particularly 

relevant for trees >30"dbh. Please estimate the number mature 

trees (20-30" dbh) and the number of "old growth" trees >30" dbh 

that would be logged from each unit. The most informative way of 

disclosing this data would be to report the pre-logging number of 

trees in these size classes and the post- logging number and size of 

trees in these size classes.

Response: Thank you for your comment. The environmental 

impact statement and silviculture resource report will include 

information on species, sizes, and ages of trees and disclose the 

effects of the proposed action and alternatives. It is not feasible at 

the phase of environmental analysis to report exact numbers of 

trees for removal. It is impossible to do a complete survey of trees 

including those to be designated for removal in all potential 

treatment units because of the large commitment of personnel 

time and resources to a project design that may change with the 

final record of decision and selection of alternatives. It is our 

standard practice to conduct environmental analysis based on 

estimates from sample plots, forest growth and silvicultural 

treatment modelling.

Concern 6-19

As acknowledged in the Humbug Landscape Analysis, this planning 

area is in severe deficit for trees in large "decadent" size class. The 

purpose and need for the project is designed to help address 
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31

hazardous fuels, forest health and water quality. There is no other 

single action the agency can take to ensure a successful 

collaborative outcome that achieves the project purpose and need 

than to implement a diameter limit for this project. Please 

consider implementing a meaningful conservation sideboard to 

retain large diameter trees in this project.

6-20

Finally, please note that in the Thom Seider FEIS (page 343) both 

the Klamath National Forest and the Environmental Protection 

Agency acknowledge that the diameter of conifer trees acts as a 

"measure of resistance to fire." Hence the forest resiliency goals of 

the Craggy project may be best met by retaining such trees where 

they still exist in the watershed.

Response: The response to the Environmental Protection Agency’s 

comment on the Thom Seider project states “Larger trees are 

thicker barked and thus are more fire resistant as noted. However, 

there are many other variables that influence fire behavior 

including stand structure, density, composition, aspect, slope, etc.” 

These factors will be analyzed and disclosed in the Craggy 

environmental impact statement and relevant resource reports. 

Information from the Humbug Landscape Analysis, including the 

small number of small disconnected patches of old, decadent 

conifer stands, will be used in the silviculture report that includes

site-specific prescriptions for thinning forest stands to meet the 

project purpose and need. For the most part, these prescriptions 

call for a thinning from below with preference for removal of 

suppressed and intermediate trees and retention of larger trees 

but adherence to a diameter limit does not always meet project 

needs. For example, as in Thom Seider, clearing around large pines 

to reduce competitive stress may require removal of some trees 

over a given diameter size. 

32

Concern

7-20 Considering the localized heavy fuel loading of dead standing trees 

greater than 10" dbh, are these trees proposed for removal?

7-21 If dead trees greater than 10" dbh are removed, will they be 

marketed, burned or otherwise treated?

Response: Standing dead trees are not proposed for treatment in 

this project. The Forest generally makes standing dead trees on 

National Forest System lands available to the public through a 

personal use firewood permit. Other possible treatments will be 

discussed in the environmental impact statement and relevant 

resource reports. 

33

Concern 12-8

The prolonged drought has created stress in our forests as 

evidenced by the many dead trees within the proposed project 

area
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Response: Thank you for your comment. Climate change, including 

the effects of drought, will be considered in the environmental 

analysis.

34 Concern

7-6 Trees less than 10" dbh will be thinned. To what density standard 

or spacing standard will trees be thinned?

7-14 Thinning without Removal: What density standards are to be 

applied?

7-15 What species will be targeted for removal or retention?

7-16 Are knobcone pine (Pinus attenuata) proposed for treatment?

Response: The environmental impact statement will provide sitespecific prescriptions that include recommended tree spacing, 

species selection preferences, and other provisions for effective 

treatment to meet the stated silvicultural objectives for each

stand.

35 Concern

7-17 What measures will be taken to prevent the thinned and bucked 

tree material to become host for insect infestation?

Response: Measures for avoiding or minimizing insect infestation 

will be discussed in the environmental analysis for this project.

Thinned trees may be removed for biomass, lopped and scattered, 

or hand piled for later disposal by pile burning within one to two 

years. Western pine beetle does not commonly infest dead or 

downed trees, instead preferring live, dense stands of trees 

greater than 6" diameter at breast height (4.5' high).

Threatened & Endangered Species

36 Concern

6-49

Threatened and sensitive fish species exist in and downstream of 

the project area. Aquatic conservation is therefore a significant 

issue for this action.

Response: The primary purpose and need for the project is 

improving fire resilience on National Forest System lands. The 

environmental analysis for the project will include an aquatic 

resources report evaluating potential effects of the project on the 

threatened Southern Oregon/Northern California Coast Coho 

Salmon (Oncorhynchus kisutch).

37 Concern

6-60

Passive management will not recover coho salmon. Temporary 

mitigations to reduce sediment from log haul, although necessary, 

are not sufficient to recover coho salmon. Recovery of threatened 

coho salmon by statute is a high priority for Forest Service. The 

proposed action must be informed of possible recovery actions 

through watershed analyses and the coho recovery plan.

Response: Coho salmon recovery is a Forest-wide goal that is not 

the focus of this specific project. However, the project will have 

project design features in place that are designed to protect Coho 

Salmon and their habitat. In addition, the project will use best 

management practices in place to protect stream habitat and 

riparian zones throughout the project area. 
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38 Concern

6-61

We recommend the proposed action consider the following to 

recover coho salmon: 1) Permanently disconnect the most 

egregious sediment producing roads from the stream network 

through hydrologic obliteration, outsloping, or construction of 

drainage features (e.g. rolling dips) or structures (cross drain relief 

culverts) that direct sediment onto vegetated slideslopes and away 

from ditches or culverts connected to stream network. 2) Identify 

fish migration barriers for both juvenile and adult coho salmon. 

Collaborate with ODFW, watershed council, and private landowners to provide passage to historic coho salmon distribution 

within the planning area. 3) Investigate illegal water diversions 

from Forest Service lands and take corrective actions.

Response: The proposed suggestions are outside the purpose and 

need of this project. The Forest continues to coordinate with the 

National Marine Fisheries Service, North Coast Region Water 

Quality Control Board and others to pursue an active Forest 

program to minimize barriers to fish passage and illegal water 

diversions. 

39 Concern

7-7

Some Threatened, Endangered or Sensitive plants respond 

positively to soil disturbances from forest management activities. 

What are the reasons for limiting equipment use to established 

roadbeds?

Response: Thank you for your interest. The environmental impact 

statement and botany resource report will include reasons for 

limiting equipment use to established roadbeds in specific areas to 

protect sensitive plant species in the project area that do not 

respond positively to soil disturbance. 

40 Concern

6-33

It appears that recovery of this listed species is an afterthought in 

project planning. The extent and severity of proposed logging lead 

us to believe that this project is likely to adversely affect the NSO

[Northern spotted owl] and that an EIS must be prepared to 

document the significant impacts to ESA listed species.

Response: The Forest will prepare a biological assessment for the 

northern spotted owl and consult with the U. S. Fish and Wildlife 

Service. The results of this consultation will be documented in the 

environmental impact statement that is being prepared for the 

project; the U. S. Fish and Wildlife Service will determine if the 

project is likely to adversely affect the northern spotted owl and if 

a biological opinion is required.

Timber

Concern 10-1

Rural communities, such as the ones affected by this project, are 

particularly sensitive to the forest product sector in that more than 

50% of all manufacturing jobs are in wood manufacturing.
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41

10-11

Without the raw material sold by the Forest Service these mills 

would be unable to produce the amount of wood products that 

the citizens of this country demand.

10-12

Without this material our members would also be unable to run 

their mills at capacities that keep their employees working, which 

is crucial to the health of the communities that they operate in.

Response: Thank you for your comments. The proposed action as 

detailed in the project proposal for public scoping lists 2,880 acres 

of thinning with removal of forest products. The environmental 

impact statement will include an analysis of the economic impact 

of the project's proposed activities.

42 Concern

10-8

Consistent and steady operation time throughout the year is 

important for our members not only to supply a steady source of 

timber for their mills, but also to keep their employees working

10-9

The ability to yard and haul timber in the winter months will often 

make the difference between a sale selling and not, and we hope 

that the Klamath National Forest is working to accommodate this.

10-10

Design feature Watershed 3 states that the project is to take place 

during the normal operating season of May 1st through October 

31st for all units and Wildlife 3 states that there will be a seasonal 

restriction of February 1st through September 15th. This leaves a 

possible operating window of approximately 45 days. These kind 

of limited operating restrictions decrease the viability of this 

project being successful

10-15 The primary issues affecting the ability of our members to feasibly 

deliver logs to their mills are firm operating restrictions.

Response: Project design feature Wildlife-3 describes limitations 

on operating periods to protect northern spotted owls based on 

survey results. Project design feature Watershed-3 defines a 

normal operating season to minimize or avoid negative effects 

from wet conditions that also can be extended based on weather. 

The effects of both project design features, and the conditions 

under which they will not apply, will be discussed in the 

environmental impact statement and relevant resource reports. 

43 Concern

7-19

Conifers less than 10" dbh may be marketable as chips or to the 

small log mill in Yreka. If this option was considered, what were 

the reasons for not marketing the small material?

10-13

These benefits can only be realized if the Forest Service sells their 

timber products through sales that are economically viable. This 

viability is tied to both the volume and type of timber products 

sold and the manner in which these products are permitted to be 

delivered from the forest to the mills.

10-14

There are many ways to design a timber sale that allows a 

purchaser the ability to deliver logs to their mill in an efficient 

manner while also adhering to the necessary practices that are 
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designed to protect the environmental resources present on 

Forest Service forestland.

Response: Thank you for sharing your concerns. Whether the 

treatments selected in the record of decision will be implemented 

through stewardship, service, or timber sale contracts is decided 

at the programmatic level. Contracts are prepared through an 

administrative process and the decision on types of forest 

products to market and volumes are based on direction of the 

regional forester.

44 Concern

10-17

Developing an EIS and contract that firmly describes how any given 

unit shall be logged may inherently limit the abilities of certain 

operators. For example, restricting certain types of ground-based 

equipment rather than describing what condition the soils should 

be at the end of the contract period unnecessarily limits the ability 

of certain operators to complete a sale in an appropriate manner 

with the proper and cautious use of their equipment. To address 

this issue we would like to see flexibility in the EIS and contract to 

allow a variety of equipment to the sale areas. We feel that there 

are several ways to properly harvest any piece of ground, and 

certain restrictive language can limit some potential operators

Response: The USDA Forest Service Region 5 Regional Forester 

provided direction that interdisciplinary teams should not 

mandate specific types of equipment or contract provisions in 

NEPA decisions (FS 2430 Yoder Yarding). The project will include a 

logging feasibility report prepared by a qualified logging systems 

specialist. This report will be used for basing yarding system 

requirements in contracts that implement project activities 

selected in the NEPA decision.

Travel Management

45 Concern

4-3

It appears that you have chosen not to perform a travel 

management analysis within the project area. I believe that a 

travel management analysis should be done now because this area 

is close to a population center and experiences significant effects 

from uncontrolled vehicle use. If not now, when?

4-7

Road 45N33, an ML 1 road, crosses private land for a short 

distance between Greenhorn Road and NFS lands. The property 

owner has blocked this road at the property boundary by building 

a barbed wire fence across it (with no gate). There is a Forest 

Service gate on this road (in a different location on private land) 

that is now not serving any purpose and should be considered for 

removal. If the Forest Service has no easement through this 

private land, 45N33 is no longer available for use and should be 

considered for removal from the road system and 

decommissioning.
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Response: The final environmental impact statement (FEIS) for 

motorized travel management on the Forest analyzed effects of 

motorized vehicle use. The Record of Decision for the Motorized 

Travel Management FEIS decided which routes would be added as 

Forest roads and trails, and the Motor Vehicle Use Map 

accompanying the decision identified which roads, trails and areas 

would be available for motorized use. Any other areas of the 

Forest are not available for motorized use. Additional travel 

analysis to accompany a project is required only if the project is 

related to the identification of a minimum road system (36 CFR 

212.5(b)(1)); the designation of roads, trails and areas for 

motorized vehicle use (36 CFR 212.51); or regulation of over-snow 

vehicles (36 CFR 212.81)). Since these are not part of the Craggy 

project, no travel analysis will be part of this project. Similarly, the 

consideration of removal of Road 45N33 will not be part of the 

project.

Watershed

46 Concern

1-2

whether the project would do anything to provide a more 

continuous flow of water in the stream rather than the surges of 

water currently experienced when upstream pools are released

Response: The primary purpose and need of this project is to 

improve fire resiliency on Forest lands. Watershed restoration and 

alteration or promotion of stream flow volume or periodicity are 

not within the scope of the project. The project proposes 

treatments to conserve watershed function through minimizing

the impact of legacy road sediment sources.

47 Concern

6-36

Please address soil chemistry, productivity, hydrology, and 

biological integrity on a site- specific (i.e., unit-by-unit) basis. 

Please map soil types and composites using field reconnaissance 

data and include the maps in the NEPA document. Include a 

qualified, journey-level soil scientist on the ID Team. Design 

actions and mitigation after you have collected field 

reconnaissance data on soils at every site proposed for action.

6-38

The forthcoming Craggy EIS must analyze and disclose of the 

impacts of yarding on pore space, water and gas exchange, or the 

efficacy of ameliorative mitigation

Response: Thank you for your comment. The environmental 

impact statement and soils resource report will provide 

information on soils provided by a qualified soil scientist.

48 Concern 6-53

As stated in the Humbug Landscape Analysis, riparian reserves in 

the project area are degraded now. Without site-specific 

information about conditions in riparian reserves, the BLM can't 

rely on them to mitigate sediment delivery.
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6-54

Given the available scientific literature, it's the agency's burden to 

show that the reserves and other project design features would 

prevent added sediment delivery.

6-62

The forthcoming NEPA analysis cannot evade sediment disclosure 

by merely claiming "no change" to existing sediment loads. The EIS 

must disclose the serious nature of sediment loads from logging 

roads and consider appropriate recovery actions.

Response: Information about conditions in riparian reserves and 

sediment sufficient to evaluate environmental effects of the 

project will be provided in the environmental impact statement 

and relevant resource reports.

49 Concern

7-10

Although unlikely, what measures are in place to prevent 

downstream dewatering resulting from drafting activities? What 

standards will the operators follow in order to not adversely affect 

downstream habitats and streamflow?

Response: The proposed action includes project design features 

Watershed-38, Watershed-39, and Watershed-40 which describe 

maximum drafting rates. Maximum rates vary for anadromous, 

non-anadromous fish bearing, and non-fish bearing streams with 

the intent never to exceed 50 percent of surface stream flow.

50 Concern

11-2

Regardless if we do not treat due to "modeling" estimates of 

watershed condition, and it burns hot again, then the modeling is 

a mute point

Response: Thank for your comment. The environmental impact 

statement and relevant resource reports will analyze effects of the 

project on high intensity fire including the modeled cumulative 

watershed effects of a potential high severity wildfire.

51 Other 

Issue 

6-1 Streams and creeks in the project area violate Clean Water Act 

standards for both sediment and temperature.

6-2

The KNF cannot legally conduct activities such as log haul, road 

construction, and yarding that will further contribute to the 

sediment and temperature problems in TMDL-listed waters in the 

Humbug Watershed

Response: Effects of project activities will be minimized by project 

design features so that the project is in compliance with 

requirements of the North Coast Regional Water Quality Control 

Board (Water Board). Once a decision is made, the Forest will seek 

a Waiver of Waste Discharge Requirements for Nonpoint Source 

Discharges Related to Certain Federal Land Management Activities 

on National Forest Lands in the North Coast Region for the 

treatments described in the proposed action.

Concern

11-1 Watershed modeling is just that a model. It is in all reality under 

estimating land recovery. It is built on manmade assumptions

Response: The Forest uses cumulative watershed effects (CWE) 

models based on field-surveyed monitoring data. These models 
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52

are intended to provide a relative basis for comparing the effects 

of proposed management activities and are part of the analysis of 

effects of project alternatives. Additionally, these CWE models do 

not account for improved watershed conditions that are achieved 

through mitigation activities, project design features, and adaptive 

or best management practices. A detailed evaluation of the CWE 

model results will be included in the water quality report for the

project.

53 Concern

6-51

Direct, indirect, and cumulative effects of proposed activities on 

hydrologic function, sediment regimes, stream temperatures, 

nutrient cycling, pH, and habitat connectivity should be evaluated 

in detail. Consider both positive and negative impacts.

Response: The environmental analysis for the project will include 

both water quality and aquatic resource reports. These reports will 

analyze the direct, indirect, and cumulative effects of project 

alternatives on indicators important to the resource and relevant 

to the project.

54 Concern

6-52

Implement the ACS at the site scale and meet its objectives 

immediately after the project's implementation, not in the "longterm" several years out.

Response: Both short-term and long-term consistency of the 

project with the objectives of the Aquatic Conservation Strategy 

(ACS) at appropriate scales will be disclosed in the environmental 

impact statement and relevant resource reports. Project design 

features that support the ACS will be incorporated into contract 

specifications and other administrative instruments that guide 

project implementation.

Wildlife

55 Other 

Issue (c)

6-34

Please respond to the following finding by Zielinski and others 

(2006): Although owl fish habitat are moderately correlated on 

federal lands, we cannot assume that federal lands can play the 

same relative role (ie contribution to overall population viability) 

for the fisher as they have been expected to do for the owl (USDA 

Forest Service and USDI BLM, 1994). Thus, we should not assume 

that fisher viability in northern California is insured by protections 

for the spotted owl included in the Northwest Forest Plan." 

Zielinski, WJ, C Carroll and JR Dunk, Using landscape suitability 

models to reconcile conservation planning for two key forest 

predators. Biological Conservation 133: 409- 430. This study is 

attached to these scoping comments for your convenience.

6-35

Please do not contend that fisher populations are "stable" to 

justify ignoring the need to avoid actions that will contribute to 

the need to list this species. Please see: Matthews, S, JM Higley, JS 

Yeager and TK Fuller. 2011. Density of fishers and the efficacy of 

relative abundance indices and small-scale occupancy estimation 
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to detect a population decline on the Hoopa Valley Indian 

Reservation, California. Wildlife Society Bulletin 35(2): 69-75.

7-12

Pacific Fisher: This species is known to occur within the project 

area. What provisions are in place considering the presence of this 

species?

Response: Effects of the project on Pacific fisher will be assessed 

in the environmental impact statement and Terrestrial Wildlife 

Biological Evaluation. This analysis will include an assessment of 

fisher habitat and will identify any needed species-specific project 

design criteria. We appreciate that the listed references were 

shared during scoping; they will be considered in the analysis. 

56 Other 

Issue (c)

6-39

The regional decline of migratory birds is a significant issue for this 

project. Numerous studies have reported local and regional trends 

in breeding and migratory bird populations throughout North 

America

6-40

The forthcoming NEPA document for this project should analyze 

and disclose the potential impacts of conifer thinning operations 

and brush removal on neotropical bird population trends.

6-41

The cumulative effects analysis on migratory birds should not rely 

exclusively on Wilderness, Riparian Reserves and LSRs to provide 

for species viability into the future, because many Forest Service 

and BLM Districts are actively logging those land use allocations, 

regardless of the effects on migratory birds, despite their reserve 

status. We refer you to the Westside fire salvage project as an 

example.

6-44

Please develop and implement seasonal operational restrictions to 

avoid project impacts while land birds are nesting in the project 

area.

6-45

The NEPA document should have evaluate the effects of the 

Project and alternatives on migratory birds protected under the 

Migratory Bird Treaty Act (MBTA). The MBTA prohibits the 

destruction of nests and eggs of migratory birds.

6-46

The EA should evaluated the impacts of project activities on 

migratory bird nests, should disclose the breeding season for each 

migratory bird species found in the project area, and should 

proposed measures (such as seasonal restrictions) to avoid 

destruction of nests.

6-65

Simply concluding that the scale of the project is small, relative to 

the size of the nation, hence migratory bird populations will not be 

affected, will not suffice.

Response: Effects of the project on migratory birds will be 

assessed in the Migratory Bird Treaty Act Compliance Analysis of 

the environmental impact statement. 
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57 Concern

6-47

Please be explicit in the forthcoming NEPA documentation about 

the management, and population dynamics, of Bureau Sensitive 

Bat species in this project.

Response: Effects from the project to Forest Service sensitive bat 

species will be assessed in the environmental impact statement 

and Terrestrial Wildlife Biological Evaluation. This analysis will 

include an assessment of bat habitat and will identify any speciesspecific project design features necessary to minimize negative 

impacts to bats. 

58 Concern

6-48

Please disclose the Forest Service strategy for identifying Siskiyou 

Mountain and Scott Bar Salamander habitat in the project area. 

Please ensure the habitat for these species is not disturbed by 

timber sale activities.

Response: The effects of the project on these two salamander 

species will be analyzed in the environmental impact statement, 

Terrestrial Wildlife Biological Evaluation and the Survey and

Manage Compliance Report. These analyses will include an 

assessment of talus habitat and will identify species-specific 

project design features to minimize negative impacts to the 

salamanders.